ML20205R506

Responds to NRC Re Violations Noted in Insp Rept 50-508/86-13.Licensee Disagrees W/Violations Re Reinforcing Steel Clearance Acceptance Criteria of ACI-318-71 & Identifying Nonconforming Concrete Grout for Future Rework

ML20205R506
Person / Time
Site:	Satsop
Issue date:	03/31/1987
From:	Olson P WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO3-87-82, NUDOCS 8704060366
Download: ML20205R506 (7)

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Washington Public Power Supply System Box 1223 Elma, Washington 98541 (206)482-4428 March 31, 1987 G03-87-82 Docket No. 50-508 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

NUCLEAR PROJECT 3 NRC INSPECTION AT WNP-3 IE REPORT NO. 50-508/86-13 VIOLATION ITEMS 86-13-18 AND 85-13-19

Reference:

NRC letter, Robert J. Pate to D.W. Mazur, subject, "NRC Inspection - WNP-3", dated February 26, 1987 The referenced letter reported the results of the NRC inspection conducted by Mr. A.D. Toth and C.G. Bruch on December 8-19, 1986. Two violations were identified as follows:

Violation 1 (86-13-18)

The WNP-3 construction specification for concrete installed for the reactor building did not incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71.

Violation 2-(86-13-19)

Nonconforming concrete grout had not been corrected nor otherwise identified for future rework.

8704060366 870331 8 DR ADOCK 0500

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U.S. Nuclear Regulatory Commission G03-87-82 Page Two March 31, 1987 Attached is the Supply System approved repcrt detailing our disagreement with both violations. Should you have any questions or desire further information, ple contact me directly.

aul . son Program Director, WNP-3 DRC/st cc: Mr. J. A. Adams, NESCO Mr. R. M. Boucher, Pacific Power & Light Co.

Mr. W. L. Bryan, Washington Water Power Co.

Mr. R. E. Dyer, Portland General Electric Co.

Mr. W. J. Finnegan, Puget Sound Power & Light Co.

Mr. J. R. Lewis, BPA Mr. J._ B. Martin, U.S. NRC Region V Office, Regional Administrator Mr. R. J. Pate, U.S. NRC Region V Office Mr. N. S. Reynolds, Bishop, Liberman, Cook, Purcell & Reynolds Mr. D. Smithpeter, BPA Ms. R. M. Taylor, Ebasco - Elma Ebasco - New York l

9 VIOLATION 1 (86-13-18) 10CFR50 Appendix B Criterion V requires, in part, that " Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

The WNP-3 Final Safety Analysis Report identifies ACI-318-71 as the applicable industry standard for construction of WNP-3 concrete and reinforcing steel structures.

Contrary to the above, at the time of the inspection the WNP-3 construction specification for concrete installed for the reactor building, WPPSS-3240-412, did not incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71 Part 7.4.1 and 7.4.5, which require a minimum of one nominal bar diameter clear distance between parallel bars (i.e.,1.4 inches for size #11 bar). The WPPSS specifications ' allowed as little as 1.0 inch clearance, based upon 3/4 inch and less aggregate size allowed by the specifications.

RESPONSE

The Supply System does not agree that Violation 1 is an item of noncompliance.

It is the Supply System's position that the WNP-3 construction specification for concrete installed for the reactor building (WPPSS-3240-412) does incorporate the appropriate reinforcing steel clearance acceptance criteria of ACI-318-71.

The Supply System's position is based on the following:

1. The WNP-3 Final Safety Analysis Report (Sections 3.8.3.2 and 3.8.3.6) identifies several codes, standards and Ebasco Specifications for design and construction of the Category I structures.

For design of concrete structures, reference to ACI-318-71 Code is made in Section 3.8.3.2.lb of the FSAR which states, "All concrete internal structures are designed in accordance with applicable portions of ACI-318-71....".

For construction of concrete structures, the detailed requirements for materials, design criteria, fabricatien, erection, inspection and quality compliance are described in Section 3.8.3.6.1 of the FSAR. A listing of-applicable purchase specification topics, which includes Formed Concrete Construction, is provided in Section 3.8.3.2.3d of the FSAR. The WNP-3 construction specification for " Formed Concrete Construction" is WPPSS 3240-412.

FSAR Section 3.8.3.6.1.1 states, "The requirements for concrete construction materials are -established by purchase specification compiled for the project. which clearly enumerate applicable ASTM, ACI and ANSI Standards or portions thereof".

Therefore, it is evident that design and construction of concrete structures was based on ACI-318-71 and other applicable documents.

Construction of concrete structures was governed by the applicable purchase.

specifications, which included references to ACI-318-71 on a selective basis.

VIOLATION 1 (86-13-18) CONTINUED

2. Nuclear plant structures are considered special structures and involve unique considerations in design and construction which are not fully covered by ACI-318-71 Code. Both the ACI building code and its associated commentary recognize this fact. Section 1.1 of the commentary states, in part, "Some special structures involve unique problems which are not covered by the Code...".

3. Ebasco Specification WPPSS-3240-412 covers the requirements of conveying, placing, curing, and finishing of the concrete. It also includes formwork and placing of reinforcing steel requirements. The specification is based on ir.dustry standards including ACI-301, ACI-304, ACI-305, ACI-306, ACI-309 and ACI-318. References to the above standards are made in various paragraphs of the specification relative to which specific provisions of the standards are to be adhered to. In Paragraph 5.0 (Placing Reinforcement) of the subject specification, the Engineer made no reference to ACI-318 in placing of reinforcing steel, including spacing or tolercace requirements.

4. The Commentary to ACI-318-71 Code states, "The minimum limits (spacing requirements) were established to permit concrete to flow readily into spaces between bars and between bars and forms without honeycomb and to ensure against concentration of bars on a line that might result in shear or shrinkage cracking."

5. The ACI Code allows and in special instances requires that the Engineer take exception with the provisions of the code, providing that in all cases a rationale for such exceptions is justified.

6. Considering all the above, the specification requirements for minimum spacing for reinforcing steel, together with maximum aggregate size, must meet the intent of the ACI-318-71 Code, Paragraphs 7.4.1 and 3.3.2.

Accordingly, Paragraph 5.02 of the specification WPPSS-3240-412 states, in part, " Clear distance between bars shall not be less than 1 inch, nor less than 1-1/3 times the maximum size of the coarse aggregate unless otherwise approved by the Engineer." In all instances, the Engineer approved the actual size of coarse aggregate used which in combination with the rebar spacing detailed on the design drawings meet the requirements of the ACI Code.

VIOLATION 2 (86-13-19) 10CFR50 Appendix B Criterion XV requires, in part " Nonconforming items shall be -

reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."

Contrary to the above, in 1983, concrete grout on the pedestal of the "A" Containment Spray Pump base was identified as nonconforming to approved specifications. The responsible organization prepared a Quick Fix Project Change Proposal, which was subsequently marked void after incorporation into approved design drawings. At the time of the inspection, the nonconforming condition had not been corrected nor otherwise identified for future rework.

RESPONSE

The Supply System does not agree that Violation 2 is an item of noncompliance.

It is the Supply SysteW s position that the " nonconforming condition" of the concrete grout was properly identified and tracked for future rework. The following chronological history of Containment Spray Pumps "A" and "B" base grouting is provided for clarification:

o Both Containment Spray Pumps were released for grouting by Peter Kiewit Sons, Inc. (Contract 3240-251), the mechanical contractor responsible for the pump and connecting piping installation, in August of 1982. Morrison-Knudsen (Contract 3240-263), the RAB civil / structural contractor, performed proprietary grouting of Spray Pump "A" on August 25, 1982 and Spray Pump "B" on August 26, 1982. Both grout installations were adequately documented with no resulting discrepancies or nonconformances.

o The grout configuration, as placed, conformed to the requirements of the design drawing in effect at the time of placement.

o In June of 1983, an Ebasco Civil Engineer noted that the grout configuration as placed and shown on the design drawing yielded a condition not recommended by Master Builders, the manufacturer of the non-shrink grout product used for this installation. In accordance with the site design change procedure, the Ebasco Engineer, under the authority of the Resident Engineer-Civil prepared a Project Change Proposal (PCP) which was submitted to the design engineer, requesting a drawing configuration change relative to the Spray Pump grouting details. This change was subsequently approved and posted as an outstanding (unincorporated) modification to the design drawing.

o In early 1983 the project was entering the present construction suspension period and most field construction activities were halted, with the exception of activities required for maintenance and preservation. As a result, the work required by the PCP was not and has not yet been performed. Contract 3240-263 (Morrison-Knudsen) is identified on the PCP as the contractor responsible for performing the required grout work.

Contract 263 is presently in a long-term suspension mode with contractual provisions to complete their original scope of work in accordance with 10CFR50, Appendix B requirements upon notification of construction restart by the Supply System.

kfl0LATION 2 (86-13-19) CONTINUED o Morrison-Knudsen's Document Control System, as described by an approved MK Procedure tracks design changes issued by Ebasco. Through this system, MK's engineering department identifies those items requiring additional work based on the design change. This program is currently in suspension but will be in effect at restart.

During the suspension period, as during construction, Ebasco's Site Document Control System tracks design changes (e.g., PCP's and drawing revisions) and their status of issuance to the contractors in accordance with the Ebasco Site Procedure for Document Control. At the time of the NRC inspection, the Document Control System computer printout indicated that the PCP had been incorporated into the latest revision of the design drawing and the revised drawing had not been issued to the contractor.

Design changes not issued to the contractor due to the delay will be issued to the installation contractor at project restart at which time the contractor document control system, as described above, will initiate the field work necessary to implement the design.

o During the suspension period, Design Engineering has incorporated outstanding modifications to design drawings and specifications to streamline issuance of contract documents upon construction restart. As a result, the requirements of the PCP were incorporated into the drawing and will be issued to the contractor in accordance with the Ebasco Document Control Program.

The referenced PCP copy marked void, was located in the Civil Document Control Station, Copyholder No. R40. The station is maintained in accordance with the Ebasco Site Procedure for Document Control. The PCP was stamped " VOID", indicating its inactive status which is per the requirements of Ebasco's QA ASME Manual (Section I-1, paragraph 4.1.2).

o During a routine inspection in December of 1986, the NRC Region V inspector observed cracks in the exposed non-shrink grout on the Spray Pump pedestals and a 6" x 6" triangular outside corner section on the pump "A" pedestal that had been broken off at an undetermined time.

Based on the above, the Supply System position is as follows:

There is no evidence to indicate that the damage to the grout placement, as noted by the NRC inspector, was present at the time that the PCP was generated. The PCP description of problem indicates that the originator, an experienced Civil / Structural Field Engineer, recogized a potential problem with the as-built and designed configuration of the grout and proposed the change as shown on the PCP. A Quick Fix Project Change Proposal is the proper document for effecting a change and/or correcting an error on a design document. Block 16 on the subject PCP form states that the change was made for " engineering correction, omission or error".

Although the condition of the exposed grout on the Containment Spray Pump pedestals may have appeared to be a nonconforming condition to the NRC inspector, existence of the aforementioned PCP and resulting outstanding work identified against the pump foundation drawing requiring additional work on the pedestal grout (including removal of the damaged areas) simply identifies an incomplete work-to go item. Therefore, a Nonconformance

! Report (NCR) is not warranted in this case.

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. NIOLATION 2 (85-13-19) CONTINUED The incorporation of the PCP into the drawing does not indicate that the required work has been performed or will not be performed in the future.

The responsible contractor is, under the terms of the suspension agreement, required to implement all programs and procedures upon construction restart to assure that their scope of work is complete prior to turnover to the Supply System.

Analogous to this situation would be the incomplete status of a given bay of structural steel as of the date of work suspension. The fact that particular members shown on the design drawing are not yet installed is not a discrepant condition. The contractor is responsible for turnover of a complete system.

Additionally, the project PRIDE Program (Project Review of Installation, Documentation and Engineering) has been established for WNP-3 in part to assure that installation has been accomplished in accordance with the latest design revisions. PRIDE utilizes physical plant walkdowns, documentation review, design installation verification and work package controls to establish an overall program capable of verifying installation to the latest design at the time of installation, completeness of records, and ensuring that design changes are incorporated into final installation.

The design installation verification portion of this program is performed prior to system / area turnover to the Owner in accordance with the Ebasco Site Procedure for System Completion and Provisional Acceptance.

In addition to providing a response to Violation 2, the referenced NRC letter also requested that the Supply System " discuss the method the Readiness Review Program will implement to assure that construction changes have been accomplished in accordance with such design revisions". Accordingly, the following discussion is provided:

The Construction Assurance portion of the Readiness Review Program also samples completed installation work. If an installation, such as the Spray Pump pedestal with an outstanding design modification, surfaced in the CAP sample for field inspections, the Review Team is required to obtain the latest design information (including the drawing) to identify construction and inspection requirements. As the repeat visual inspection of " completed work" is performed, the uncompleted design change would be identified.

Follow-up investigation to determine the cause of difference between the as-built condition and the final design would reveal the item as work to go. Such follow-up work is required by CAP Procedure CAP 6.5, Revision 3, paragraph 3.10. Further, the CAP Office informs the project in writing of work-to-go and construction-related damage items identified in its field inspections.

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