ML20147E703
| ML20147E703 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 12/11/1978 |
| From: | Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20147E638 | List: |
| References | |
| NUDOCS 7812210161 | |
| Download: ML20147E703 (7) | |
Text
i:.
Washington Public Powcr Supply Syst:m
'y A XWT OMRAllNG AGENCY s3 -.................._.,_.. _ ... _ .. ..... - . ..... ........
December 11, 1978 l i
G01-78-897 l
tlucinar Regulatory Commission Region V Suite 202, Halnut Creek Plaza l 1990 11. California Boulevard )
Walnut Creek, California 94596 h 3 0000NIENT CONTMM(
- I S. Spencer, Chief POOR QUM !
Attention: Mr. C'. i Reactor Construction and Engineering Support Branch
Dear Mr. Spencer:
l
Subject:
WPPSS Huclear Projects Hos. 1/4 HRC Inspection - October 10-13, 1978 Docket Hos. 50-460 & 50-513 CPPR Nos. 134 and 174
References:
Letter. G. S. Spencer to N. O. Strand, dated November 8,1970 1.etter, D. T. Knuth to All AEC l.icensees, dated December 31, 1974, " Criterion for Determining Enforcement Action and Categories of Honcompliance."
This is in response to your letter of November 8,1978 which discussed the results of the inspection conducted on October 10 - 13, 1978 of activities The letter authorized by HRC Construction Permits Hos. CPPR 134 and 174.
identified thren (3) Items of Honcompliance categorized in accordance with reference 2 and required that the Supply System provide a response to these items.
The specific HRC findings as stated in your letter and the Supply System responses are provided in Attachment 1 to this letter.
Very truly yours, ON D. l.. Renberger Assistant Director - Technology l
' RCH:djs Attachment cc: CR Bryant - BPA SB Barnes - UE&C, Field BD Redd - UET.C. Phil.
EC Haren - UE&C, Field ,
I or 9 781221C;\@
. . r i
. i J
ATTACHMENT 1 , l 'l 9
.y ,
6 l
~
flRC F1tO1ttG >
A. 10CFR50 Appendix B Criterion V and WPPSS PSAR Paragraph 17.1.5
- requires that activities affecting quality be prescribed by in- )
structions and procedures and be accomplished in accordance with ' '
these instructions and procedures. ,
Shurtieff and Andrews Quality Assurance Procedure 2.E, Stud Welding .
and inspection, requires that for stud welding, ,~;
- 1. Studs be free of rust. [
?. The first two studs included on each member be bent to en ! ;'
angle of 30 degrees.
- 3. The first two studs welded on each member be bent to check '
out the welding equipment and procedure. .
'I Contrary to the above, at Units 1 and 4 on October 12, 1978 rusted '
studs were being helded, approximately 40% of the first two studs ' .l; welded on each member were not being bent the required 30 degrees, x, '
'I and vnen two men were welding on the same member using different welding equipment, only one bent the first two studs welded. ;!'
This is an infraction.
_ SUPPLY SYSTEH RESPONSE 4
Actions to Correct _the Identified item -
- 1. Rust on Studs. '-
Rusty studs are cleannd with abrasive grit in a sma'll mixer.
Use of rusty studs occurred when already cicaned studs were not ,.
used for several days and rusted again. Consequently, all rusty studs in this condition were recleaned in the mixer. 9 2/3. Bending of Studs.
Sincethefirgttwgstugsthatrequire30 bending were not hent quite 30 (15 - 25 ) on completed work, the following back-check was initiated. Twenty percent (20%) of all studs which '
g have beenrehall concrete welded be through the bent to 15 metaf.decg)and (40 -2 . Theare studs not to embedded be testedin on each beam shall be selected on a random basis. Replacement of hv9 e
e e e e e o e e e e s e e s ee e e ~se e e e . .. r~ . - e a e . e.
l
^ ~
.~
Attachment 1 1 Page 2 I studs that~ fail plus addition of new studs shall be determined as follows and shall be unifonnfly distributed on the beam:
(Studs Replaced & Added) = (% Failed) X (Total Studs) l The following example illustrates the method:
Studs on Beam 100 20% Tested 20 '
Number failed 5
% Failed (f0 x100) 25%
Studs Replaced & Added (25% x 100) 25 Action _s_ _Taken to Pre _cl__ude Recurrence - Specific
- 1. Rust on Studs, As a result of a Corrective Action Request issued by Contractor 9779-207 (CAR-207-12), Shurtleff & Andrews has issued instructions to cican all studs to be used during each shift on a daily basis.
2/3. Bending of Studs.
The Shurtleff & Andrewr, Project Superintendent ingtructed the general foreman regarding the necessity of the 30 bend test requirements. As an overcheck for the integrity of the stud Walds,alfnewstudg)weldedthroughthedeckwillbebendo tested 15 (40 , -2 replaced and tested, All studs that fail this test will be b,ctions Taken to Preclude Recurrence - General Because of numerous quality problems and deficiencies encountered with
^
Contractor 9779-207 (Allied-Capitol) construction activities since late 1977, the WilP-1 and 4 Project Division Manager has requested corrective action from the Vice President and Chainnan of the Board of Allied Structural Steel Company. Letter UEAL-78-5323 dated December 4,1978 itemizes the quality problems encountered to-date and solicits appropriate management actions to assure effective implementation of the oppmved A/.C-Quality Assurance Program.-
3 or1
,. .~.. .....
! . 1 l
Attachment 1 Page 3 hRC FINDING
=B. 10CFR50 Appendix B Criteria 11 and IX, the WPPSS PSAR Paragraphs 17.1.2 and 17.1.9, and the WPPSS Quality Assurance Manual, Chapter 9, Paragraph 4.1.3 requires that inspection personnel be trained and qualified in accordance with applicable stsndards.
Shurtleff and Andrews Quality Assurance Procedure 13, Qualification of Quality Assurance Personnel, requires thet:
- 1. The level 111 inspector be a graduate of an accredited college or h1 9h school graduate with ten years exoerience.
- 2. A Level 11 inspector be a graduate of high school and have four years experience.
Contr5ry to the above, at Units 1 end 4 on October 12, 1978, the Level III inspector had a Masters Degree in Electrical Engineering from John Quincy Adams College which is not accredited. This degree was the only education listed. The Level 11 inspector was a high school graduate but did not possess four years experience.
This item is an infraction.
The failure of Shurtief f and Andrews quality control inspectors to meet personnel qualification requirements was cited once previously as an item of Noncompliance in IE Inspection Report No. 50-460/77-03.
S_UPPLY SYSTEM RESPONSE Actions to Correct the Identified item
- 1. Level !!! Inspector.
The experience and past education of the Level 111 Inspector in question were identified in more detail and docunentation attesting to these facts was placed in the Inspector's personnel file. A review of the Inspector's records show that he is a high school graduate with ten years experience and does meet the Level 111 requirements. The fact that he has the equivalent of a BSEE and a masters degree from an unaccredited college only adds to his credentials and is over and above the minimum level !!! requirements.
- 2. Level II Inspector.
The Level II Inspector's certification was rescinded after a WPPSS review confirmed the lack of experience. A check was rade for field surveillance and inspections that were performed by'the Level II, but none had been accomplished negating any reinspections hy a properly certified Level 11 inspector.
F1 M or
,, . . . . . .~ .
n Attachment 1 Pa9e 4 Actions Taken to preclude Recurrence A review of the records for all Contract 9779-207 certified inspectors ,
was made. The check revealed one additional Level 1 did not have sufficient experience to meet ANSI N45.2.6 certification requirewents.
The certification for this individual was also rescinded and no inspec- -
tions had been performed by this person.
To preclude recurrence and assure the ANSI N45.2.6 inspector certifica-tion requirements are met, WPPSS/UE&C QA will periodically review the associated documentation of the Contractor 9779-207 certified inspectors.
In addition, WPpS5 WNP-1 and 4 Project Mensgement has issued a request for corrective action to the Vice President and Chairnen of the Board of Allied Structural Steel Company (Reference letter UEAL-78-5323, dated -
12/4/78). The letter sunnerizes numerous QA problems and deficiencies encountered with Contractor 9779-207 to-date and reauests appropriate management actica to assure effective implenentation of the Allied-Capitol Quality Assurance Program.
HRC FINDING C. 10CFR50 Appendix B Criterion XIII states in part, that " Measures-shall be established to control the . . . storage . . . and preser-vation of material and equipment in accordance with work and inspection instructions. . . "
paragraph 17.1.13 of the PSAR states in part, that ". . . documenta-tion pertaining to the . . . preservation . . . storage , . of the items . . . will be filed "
and maintained in a traceable, retrievable
. . . manner . . . ; ". . . items delivered to the site are stored
. . . and preserved in accordance with . . . equippent manufacturer's requirements . . ."; and ". . . these functions (storage, preservation) are perforned in accordance with approved procedures and instructions WPPSS Procedure QAP-16, as approved procedure entitled, " Handling, Storage and Shipping" requires that:
- 1. Documentation 9enerated as a result of procedure implementation shall be filti and reintained. -
- 2. Measures be established to control stora9e, includin9 preser-Vation of equipment.
Contrary to the above, on October 11, 1978 records for the preventive maintenance inspection of valves 1-DH-V7A, 1-DHR-FCV-3 A and B requested during inspection 78-06, were still unavailable at the tine of this inspection. Also records indicated that storage conditions for the reactor vessel had not been inspected for 39 days on October 11, 1978, contrary to the 30-day maximum interval specified in the storage instructions.
, . o . ., ; ,.,-i
. . . . . . . . . . . . . . . . . . . .. o. . 8_, % 7 . . . . . .. . . . . . . ----.
.' Attachment 1 -
Page 5 Further, on October 12, 1978 it was found that definitive storage instructions for the rotor of the diesel driven electric generator were not established which resulted in storage conditions different than those established by the equipment manufacturer.
This item is a deficiency.
SUPPLY SYSTEM RESPONSE Actions to_ Correct the Identi_fied Item
- 1. Valves 1-DH-V7A,1-DHR-FCV-3A, and -3B.
Subsequent to the initjal finding by the NRC during the July-August 1978 inspection (78-06),1-NCR-CM-21 was issued for Preventative haintenance (PM) checks missed during June and July 1978 on valves 3-DHR-FCV-3A and -3B, 1-NCR-CH-22 was issued for the PM check missed during June 1978 on valve 1-DH-V7A. Prevente-tive Maintenance was resumed for valves -3A and -3B on August 1, 1978 and was already done for valve -V7A on July 12, 1978. PM has continued as required for all three valves since these dates.
Engineering disposition of the NCRs was made designating "Use-As-Is" and was based on the satisfactory condition of desiccant indicators ,
and no physical damage to the valves or protective coverings when PM was resumed.
1dontification of missed PM actions for other equipnent received on,-
site has been initiated by the WNP-1/4 QA Material Control section, It is planned to issue one NCR for each affected contract once all equipment deficient in required PM checks has been tabulated.
The preventative maintenance check for the reactor vessel (RV) was performed on October 12, 1978 while the NRC Inspection was still in process (October 10-13,1978). The cause of the missed PN check resulted from a communication misunderstandin9 between the mill-wrights and boilerrukers. The PM of the RV was changed from
, millwright to boilermaker cognizance, but each believed the other craft had the PM assignment for October and neither performed the check at the required interval.
- 3. Diesel Driven Electric Ganerator.
The stator and rotor for the generator were shipped as separate units by the nanufacturer and are, consequently, in storage as separate units as received. The vendor recommended storage for the diesel / generator sets received by transmittal T-095, dated 10/28/77 states in part in Paragraph 4,2.1, ". . . The windings should also 6er b l
l
Attachment 1 Page 6 be protected against sweating and freezing utilizing a safe and reliable heating system which should be adequate for keeping the temperature of the nochine above the dew point of the surrounding area."
The diesel / generator set was stored in a Kelly Building which is heated by thermostatically controlled electric heaters. One of these heaters, when energized by the thermostat control, blows directly on the generator rotor. During the inspection, this heater was "off" because of the relatively warm day (approx. 65'F) and apparently not considered, in light of the above requirement, during the inspection.
The Preventative Maintenance Coordinator contacted the vendor (Portec) and confirmed that the method in use for storage of the rotor was satisfactory. Therefore, no changes have been nede to rotor storage conditions.
Actions to Preclude Recurrence To preclude recurrence, additional WPPSS/UE8C Construction Management personnel have been assigned to assist the Preventative Maintenance Coordinator. The 9779-228 Contractor (Capital Development Company) staff performing PM activities has been increased and authorization was issued to hire a PM Specialist to coordinate and direct the overall effort (Referenco letter UECD-78-5055(228), dated October 6, 1978),
in addition, both the Field General Construction Procedure (FGCP-16) and the field Quality Standard (FQS 13-4) governing conduct and verification of the WNP-1/4 PM program have been revised to clarify and provide a more workable PM program. It is anticipated that all the above actions will be fully impicmented by January 26, 1979.
A rmjor thhnge in the WNP-1/4 PH program has also been approved. The change encompasses conversion of all PM requirements and records to the Supply System standardized PH computer program. This program will provide better control of PM activities for each piece of equipment, en itemized listing of all past PM activity for each item and daily work cards for
, items requiring PM, An itemtred computer listing identifying any overdue items can be obtained at any desired interval (e.g. daily or weekly),
Full implementation of the above program is scheduled for March 31, 1979.
')OF l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - - _ _ - - - - - -