ML20092P280
| ML20092P280 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/15/1984 |
| From: | Martin J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20092P275 | List: |
| References | |
| NUDOCS 8407060132 | |
| Download: ML20092P280 (10) | |
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Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 993p2.1509)372-p r.
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Docket No. 50-397 y; u i.
June 15, 1984 Mr. Ross A. Scarano, Director Division of Radiological Safety and Safeguards Programs U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
Subject:
NUCLEAR PLANT N0. 2 LICENSE NO. NPF-21 NRC INSPECTION 84-07 MARCH 19-23, 1984
Reference:
(1) Letter, J.D. Martin (Supply System) to R.A. Scarano (NRC) dated 5/10/84, same subject (2) Meeting, R. Dodds/A. Toth (NRC) with J. Martin / Staff on 5/24/84, Discussion of LER and Inspection 84-07
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Responses v
(3) Letter G02-03-1080 dated 11/21/83 from G.C. Sorensen (SS) to J.B. Martin (NRC); NRC Inspection Report 83-14, Notice of Violation, Item C Following our initial response to the Notice of Violation resulting from the subject inspection, the Supply System has completed several follow-up actions. This letter provides additional information to that submitted by Reference (1) and summarizes the status of corrective actions taken by the Supply System.
As you know, a number of review' associated with Process Radiation Monitor-ing and Sampling activities have been performed. Last December, Radiolog-ical Programs began an independent review of Systems 36.0 - Process Radi-ation Monitoring, 37.0 - Radiation Monitoring, 97.0 - Meterology, and 106.0 - Process Sampling. The objective of this review was to determine system readiness for entry into the Power Ascension Test Program (PATP) by showing the functional requirements for each system as stated in licensing commitments and regulatory requirements had been met.
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4. V Mr. R.A. Scarano NRC Inspection 84-07 Page 2 June 15, 1984 Early in the review, nineteen action items required to be closed before fuel load were identified (1).
These items were subsequently addressed by the HP/ Chemistry Manager and their impact on safety resolved on 12/24/83 prior to fuel load (2). The review continued through February 1984 when a second report was issued. This report itemized a total of 110 findings
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including the 19 above (3). Subsequently, a review of the Post Accident Sampling System (106.0-E) was made which delineated 23 preliminary action items, later changed to 16.(4).
At no time have we found radiological safety to be jeopardized.
Throughout 1
our review, we have found the systems and equipment to be in good operating condition. Negative findings involved inequities between installed systems 2
and FSAR descriptions or lack of documented proof of capabilities (5).
As of June 14, 1984, 91 of the 126 identified items have been corrected and closed. The status of the 35 outstanding actions is summarized in i.
None of the 35 actions impact our PATP.
1 During the Reference (2) meeting, the differences between the June 3, 1983 violation in downgrading of QC 1 pipe supports (NRC Inspection Item
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83-14-02) and the PED 218-I-8281 quality class misidentification (NRC L
Inspection 83-07-02) were discussed.
It was noted that the procedures l,
for review and issuance of PEDS were the same and the potential for common-ality of cause for the two violations and the effectiveness of our tech-nical reviews needed to be addressed.
1 NRC Inspection Item 83-14-02 identified an instance in which some pipe supports on safety related systems were inadvertently downgraded from QC 1, Seismic I to QC 2, Seismic I.
This happened because stress pipe
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hanger designers were not sufficiently cognizant of plant' system functions.
These quality class misidentifications were corrected by Burns and Roe j
at the time of discovery.
As related in the Reference (3) response to NRC Inspection Item 83-14-02, BRI reviewed over 300-PEDS to evaluate the quality class downgrade problem.
i A sampling plan was devised to provide a 95% confidence level that less than 5% defects exist in the sample lot size (approximately 29000). Twenty i
PEDS were then identified that should have been denoted as QC 1; however, further evaluation concluded that the field contractors were working to the quality class designations required by contract specifications and associated drawings. None of the PEDS had revised these specifications or drawings. Also, eighteen of the twenty PEDS that should have been t
denoted QC 1 actually_ involved work on non-safety related systems in the category that Regulatory Guide 1.29 states are subject to " pertinent por-tions of 10CFR50 Appendix B" because of potential interactions with QC 1 systems.
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Mr. R.A. Scarano NRC Iaspection 84-07 Page 3 June 15, 1984 The effectiveness of technical reviews relative to the quality class de-noted on PEDS during construction was not considered critical because the quality class on specifications and drawings governed per contract.
Our final response stated the following:
"Having identified these twenty (20) Quality Class 2 PEDS that were im-properly classified per the requirements of WNP-2-017, the Supply System cannot rigorously comply with the 95% confidence criteria that less than 5% of the Quality Class 2 PEDS were improperly classified with respect to quality class, as originally intended. However, based upon the results of the PED evaluation program, summarized above, which indicates that i
there was no impact on the specified construction requirements, the Supply i
System:
1 (1) does not believe that a significant problem warranting further in-l vestigation exists; (2) believes that design control has been maintained; and j
(3) believes that the problem identified with regard to the improper V
downgrading of some Quality Class 1 supports was an isolated occur-rence."
PED 218-I-B281 for relocation of radiation monitors was issued in April 3
1983 - this date falling within the time span of the sample lot size noted above. Because further investigation was not deemed necessary as the
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.above investigation concluded in November 1983, identification and correc-tion of all misidentified PEDS was not accomplished.
PED 218-I-B281, therefore, is an additional case in point in the total lot.
BRI PED 218 I-8281 was issued to relocate a safety system radiation de-tector from inside to outside a ventilation duct. The PED was unique in that the radiation detector had a safety related function; however, the ventilation duct on which it was mounted performs no active safety function and is not designated QC 1.
The PED was issued QC 2, but imple-mented by the WNP-2 Startup organization with the same procedures imple-mented on safety related A,rk.
The PED itself did not authorize changes to quality class designations on drawings or Class lE -lists; however, a commercial grade installation would have been acceptable had the install-ation been complete, i.e., had washers / nuts been placed on the mounting bolts.
The work performed was not acceptable regarr ess of quality class and there were no inprocess checks or inspections that identified the deficient mounting. A significant contributing factor was incomplete mounting in-p) structions. An investigation was conducted by Burns and Roe, Inc., to V
alleviate the generic implication with regard to the installation direc-tions-for other safety related radiation detectors.
Three Radiation
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4d Mr. R.A. Scarano NRC Inspection 84-07 Page 4 June 15, 1984 Monitoring (RM) systems are required for plant safety per FSAR Section 11.5.1.1:
- 1) Main Steam Line RM System; 2) Reactor Building Exhaust Plenum RM System, and 3) Control Room Fresh Air Intake RM System. The reactor building system was addressed in our initial response, Reference (1). The review of the other two systems is summarized in Attachment 3.
No additional problems were found.
As part of our response to the Notice of Violation contained in Reference (1), we discussed corrective' steps we have taken to avoid recurrence of misidentified quality class on PEDS. We maintain that the WNP-2 design control process now governed by the Operating Plant Procedures Manual, coupled with the Plant Technical Staff review of PEDS and the Engineering Directive regarding use of the quality class 1 computer listings (MEL, Class lE and SRM lists), will negate future classification problems.
We believe our technical review procedures are superior to industry stand-ards because the quality of these reviews is dependent upon the integrity and expertise of the individual engineers.
The Notice of Violation resulting from NRC Inspection 84-07 included the i
problem of incorrect quality classification of radiation monitors on work-p) ing documents. As discussed in the Reference (1) response, Plant Quality (V
Assurance (QA) conducted an initial review of seven systems for misidenti-fication of Quality Class (QC) cn Test and Startup work documents. We reported that no significant deficiencies or trends were found except in System 36.0, Process Radiation Monitoring, where seventeen Startup l,
documents were found misidentified (8). Concurrent with this review, the NRC Resident Inspector noted that standby gas treatment fire protection deluge valves were classified QC 1.
Fire protection is a QC 2 system and it was found that two Startup documents and one PED concerning these
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valves were misidentified as QC 2.
l Accordingly, Plant QA extended their review to include Startup documenta-i tion for all QC 1 equipment items that are scoped within QC 2 system bound-aries. System Lineup Component Tracking (SLCT) listings for 42 QC 2 sys-tems were cross-checked with the Class lE/SRM QC 1 listing to obtain the QC 1 components in'each system. Twelve of the 42 systems contain QC-1 l
equipment items and each uf the QC 1 component folders-in the Test and Startup files were reviewed. All SDRs, SPRs, SWRs, MWRs, Instrument Test Records and any referenced PEDS were checked to assure they were marked as QC 1.
The results of the document review are presented.in Attachment 2 (9).
It can be seen that System 36.0 has the greatest number of QC 1 components and correspondingly the greatest number of misidentified documents. How-ever, the data show that the misidentification was not predominately con-3
. fined to System 36.0-as originally indicatt d in our early review. All
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but two of the twelve systems had misiden'.ified work-documents.
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Mr. R.A. Scarano NRC Inspection 84-07 Page 5 June 15, 1984 It appears that the roat cause for misidentification of quality class is twofold:
- 1) The lack of clear and emphatic direction to the Test and Startup engin-eers to assure correct classification on working documents. This emphasis was needed predominately for QC 2 systems having QC 1 com-ponents.
- 2) The fact that both QC 1 and QC 2 work was performed according to the same procedures during Test and Startup activities negated the import-ance of proper classification. Standardized forms governing the work contain several identifying " block" entries, including the quality class block. The importance of correct information in these blocks was diluted through continued repetitive usage.
Corrective actions that have been taken to assure that the above type misidentification problems are precluded during WNP-2 plant operational activities are also twofold. First, direction was issued from the Assis-tant Director, Technology - Generation Engineering to all System Engineers g
designating the )RM/IE MEL lists as the governing document for identifica-v tion of quality class for plant components (10). Secondly, similar direc-tion was issued from the Plant Technical Department Manager to all WNP-2 Plant personnel to designate the Master Equipment List (MEL) as the govern-ing document for quality and seismic classification for WNP-2 plant com-ponents (11).
Corrective actions for the specific misidentified documents are currently in progress. These actions, which are being tracked under the Plant QA Surveillance Program and scheduled for completion 6/22/84 (9), are as follows:
- 1) Each component affected by the identified documents will be reviewed to assure it is properly identified as QC 1, 2, or G.
- 2) Each document will be reviewed to determine the correct document qual-ity classification.
- 3) The action described by that document will be reviewed to determine it.s potential affect on a quality component or function, i
- 4) Work will be reinspected or retested as may be required by the review results.
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9 Mr. R.A. Scarano NRC Inspection 84-07 I
Page 6 June 15, 1984 Upon completion of the review, we will advise you of any final actions taken.
Should you have any questions please do not hesitate to contact me.
Vary truly yours,
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J.D. M in (927M)
WNP-2 Plant Manager jdb l
Attachments 9
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Radiological Programs Status of Independent Review Open Items Number Target of Items Item Description and Status Completion 14 These items identify changes needed to August 1984 the FSAR to correct inconsistencies and update system descriptions to reflect current conditions.
Eight SCNs for these items are being incorporated into the FSAR as Amendment No. 35.
13 These items identify the actions July 1, 1984 remaining and procedure changes for the " Enhanced Calibration Program" associated with ANSI 13.10 criteria. (6) (7) l 4
These items identify dosimeters not in August 1, 1984 compliance with ANSI N13.27. They 1
are out of service pending testing, an FSAR change and procedure definition.
3 These items cover reorientation of one July 1, 1984 monitor and addition of booster pumps in sample lines (PMRs 02-84-0386 and
-0541).
1 An academic item to revise plate-out July 1, 1984 calculation methods.
Page 1 of 1 II REVIEW 0F TEST AND STARTUP DOCl#ENTATION Quality Class 1 Components in Predominately quality class Z systems System System No. QC 1 T&SU Documents Documents No.
Title Items Reviewed Marked QC 2 4.0 Reactor Water Cleanup 22 106 12 11.0 Closed Cooling Water 13 52 8
8-31.1 Floor Drain Processing 4
42 3
31.2 Equipment Drain Processing 2
19 2
I4) 35.0 Radioactive Drains 12 66 2
I7) 20(5) 36.0 Process Radiation 116 Monitoring (3) 37.0 Radiation Monitoring 6
12 0
55.0 Tower Makeup 2
2 0
62.0 Fire Protection 28 3
3(6) 72.0 Reactor Feedwater System 2
4 2
80.0 Reactor Bldg. HVAC 24 75 8(6)
-(7) j(2) 106.0 Process Sampling 26 J
Not7s:
(1) SDRs, SPRs, SWRs MWRs, referenced PEDS and Instrument Control Data Sheets contained in equipment system folders in the T&SU files.
(2) One MWR marked N/A for affixing code data plate.
(3) QC 1 system cited in NRC Violation (81-07-02).
(4) Twelve SDRs/SWRs generated at one time from one SPR marked in error counted as one.
(5)
Includes three PEDS.
(6)
Includes one PED.
(7) Reported in Surveillance 2-84-159; total documents reviewed not recorded.
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RADIATION MONITORING SYSTEM REVIEW r
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Main Sten Line Radiation Itnitoring System (FASR 11.5.2.1.1) MS-RE 3A, B, C, D (D17-N003A, B, C, D)
The following design drawings were reviewed at each revision level subsequent to the addition of the detectors. Any change documents were reviewed to verify consistenc Q.C. I classification.
1.
M563, currently Rev.12 General Arrangement, TU Building, 501'-0"
- Detectors added at Rev.6; no subsequent engineering change de=mts applicable to these detectors.
- Detectors added by PCN 4621; design is to be per General Electric Spec. 22A4211, Rev.0 which requires that the installation " satisfy all safeguard requirements" (Paragraph 3.3.1.2).
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- M563 as a General Arrangement drawing carries no Q.C. designa-i tion. M565 (misc. Sections) was also reviewed with the same results.
2.
E607, currently Rev.25 and E608, Detail "Z" (Rev.24) (I&C conduit and tray plans and dernih, operations floor, TG building, El.
501'-0").
- Detectors and at E607, Rev.6; E608, Rev. 7 by PCN 4621. No subsequent change de=mes applicable to the detectors.
- Per note 9 E599; Division 4, 5, 6, 7 conduit are SCI, QCI.
- Installation by Supply System was Q.C. I (SDR-111711; SWR-15269) 3.
S627, Rev. 14; S640 details of pipe sleeves added by PCN 4621 as Q.C. II. Since these are only guard pipes, the Q.C. II designation is ops up late.
I II. Control Rocxn Fresh Air Intake RaA4atim ibnitoring System (FSAR 11.3.2.1.3)
WOA-RE-31A, B, 32A, B.
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- These detectors were supplied under Contract 92B as a part of Sanple Racks WDA-SR-18A, B 19A, B as Q.C. I, S.C. I equipment.
Qualification data exists to support this classification (Burns and Roe F/N 92B 7237) as does Contract 92B design drawings.
Design Drawings:
92B-00-7037 P&ID Q.C. I on Drawing 92B-00-7230 Monitor Wiring Diagram Q.C. I on Drawing l
92B-00-7149 Top Assembly Q.C. I on Drawing l
92B-00-7142 Wiring Diag. - C&I Box Q.C. I on Drawing 92B-00-7088 Field Interconnect Wiring Q.C. I on Drawing
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92B-00-7025 Outline Drawing Q.C. I on Drawing Eame 9acks vare insta'.1W Q.C. I per drawing F755 (PIT 218-C?-A713)
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BIBLIOGRAPHY 1.
IOM dated 12/23/83 from D.E. Larson to J.D. Martin; Systems 36 - Process Radia-tion Monitoring, 37 - Radiation Monitoring; 94 - Meterology, and 106 - Process
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l Sampling 2.
IOM dated 12/24/83 from R.G. Graybeal to J.D. Martin; same subject as above 3.
IOM dated 2/3/84 from D.E. Larson to J.D. Martin; same subject as above 4.
IOM dated 4/13/84 from D.E. Larson to J.D. Martin; Independent Review of System 106D, Preliminary Report 5.
IOM dated 5/3/84 from D.E. larson to J.D. Martin; Status Report on Independent Review of Systems 36, 37, 97 and 106 6.
Letter G02-83-1128 dated 12/8/83 from G.C. Sorensen (SS) to A. Schwencer (NRC);
Definition of Applicable ANSI 13.10 Criteria
)7.
Letter G02-83-1136 dated 12/9/83 from G.C. Sorensen (SS) to A. Schwencer (NRC);
Definition of Applicable ANSI 13.10 Criteria 8.
WNP-2 Plant QA Surveillance Reports 2-84-101 and -159 issued 4/5/84 and 5/2/84, respectively N
9.
WNP-2 Plant QA Surveillance Report 2-84-164 issued 5/18/84
- 10. IOM dated 5/10/84 from L.T. Harrold to C.R. Noyes/N.S. Porter /G.L. Gelhaus; 4
Quality Class Designation of Design Changes for Class 1 Components
- 11. IOM dated 6/7/84 from K.D. Cowan to All Plant Personnel; Identification of Quality Classification and Seismic Classification for WNP-2 Components.
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