ML20041C883

Responds to NRC 811021 Ltr Re Violation Noted in IE Insp Repts 50-508/81-14 & 50-509/81-14.Corrective Actions:Design Pressure for Guard Pipes in All Three Penetrations Made Uniform (50 Psig) Over Entire Length

ML20041C883
Person / Time
Site:	Satsop
Issue date:	12/23/1981
From:	Leddick R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20041C867	List: ML20041C883
References
GO3-81-2866, NUDOCS 8203020632
Download: ML20041C883 (9)

Text

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Washington Public Power Supply System Box 1223 Elma, Washington 98541 (206)482-4428

.c p LO Docket Numbers 50-508 and 50-509 December 23, 1981 G03-81-2866 U. S. Nuclear Regulatory Commission, Region V Office of Inspection and Enforcement 1450 Maria Lane, Suite 260 Walnut Creek, California 94596-5368 Attention: Mr. B. H. Faulkenberry Chief, Reactor Construction Projects Branch

Subject:

NRC INSPECTION AT WNP-3/5 DOCKET NUMBERS 50-508 AND 50-509 ITEM 0F NONCOMPLIANCE IE REPORT N0. 50-508/509/81-14/01

Reference:

1) NRC Letter, NRC Inspection at Washington Nuclear Project Nos. 3 and 5, Mr. B. H. Faulkenberry to Mr. R. S. Leddick, dated October 21, 1981.

Reference l reported the results of the NRC inspection conducted August 10-16, 1981, of activities authorized by NRC Construction Permit Nos. CPPR-154 and 155. One Item of Noncompliance (81-14/01),

concerning a failure to assure proper testing of penetration welds, was identified. The Supply System was directed to provide a re-sponse to the Notice of Violation and include a discussion of the reasons for failure to adequately investigate and effect corrective actions to preclude the subject Item of Noncompliance.

Attached is a report detailing corrective / preventive actions taken '

for the subject noncompliance. In addition to providing a response to the violation, the report addresses the additional concerns raised by the NRC. The Supply System considers the violation to be satisfactorily resolved.

8203020632 820222 ~

PDR ADOCK 05000508 G PDR @ ~ l c20

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.Mr. B. H. Faulkenberry Page 2 December 23, 1981 G03-81-2866 Should you have any questions or desire further information, please contact me directly.

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. . Leddick/1000 Program Director, WNP-3/5 DRC/tt Attachment cc: J. Adams - NESCO-WO/A D. Smithpeter - BPA-WO/A Ebasco - New York-WO/A WNP-3/5 Files - Richland-WO/A

R. S. LEDDICK, Being first duly sworn, deposes and says: That he is the Program Director, WNP-3/5, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the fore-going on behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge. -

DATED N bCCSf6 , 1981.

R. S. LEDDICK STATE OF WASHINGTON )

) ss COUNTY OF GRAYS HARBOR )

On this day personally appeared before me R. S. LEDDICK to me known to be the individual who executed the foregoing instrument and acknowledged that he signed the t4me as his free act and deed for the uses and pur-poses therein mentioned.

GIVEN under my hand and seal this 03 day ofh e.4 m 6d,1981.

m.ab Notary Public in and for the State of Washington Residing at El. rn cu

ATTACHMENT I Page 1 Nuclear Regulatory Commission - Noncompliance (50-508, 509/81-14/01) 10CFR50, Appendix B, Criterion XI states that "A test program shall be established to assure that all testing required to demonstrate that struc-tures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applica-ble design documents."

Paragraph 17.1.11 of the Quality Assurance Program documented in approved PSAR Deviation No. 26-WP, states that: " Construction testing will be per-formed by the contractors to ensure that installed equipment meets appli-cable codes, standards, and design requirements."

Contract Specification No. 3240-251/226, Page S-8, Revision 5, states, in part, that: " Field welds on pipe sleeves and penetrations shall be tested in accordance with ASME III, Article NC-6000...."

1. The ASME Boiler and Pressure Vessel Code Section III, 1977 Edition including addenda through Summer, 1978, Paragraph NC-6111.1 states, in part, that: "All components and appurtenances constructed or installed under the rules of this subsection shall be hydrostatically tested...." Paragraph NC-6111.2 states: "When a hydrostatic test is not practical (NC-6112), a pneumatic test in accordance with NC-6300 may be substituted." Paragraph NC-6321(a) specifies that: "The pneu-matic test pressure for components or appurtenances except storage tanks shall not be less than 1.25 times the system design pressure..."

Paragraph NC-6315 specifies, in part, that: "Following the applica-tion of pressure... examination for leakage in accordance with NC-6215 shall be made."

Contrary to the above, a 7.5 PSIG pneumatic pressure test was performed by the contractor in accordance with procedure No. PKS-WI-306, Revision 3, as approved by Ebasco, on Unit No. 3 containment penetration No. 24 sleeve welds which resulted in Field Weld No. 4 on penetration No. 24 not being tested at 1.25 times the design pressure of 50 PSIG. Field Weld No. 4 is now embedded in concrete which prevents examination of the surface for leakage.

2. Paragraph NC-6112(a) states, in part, that: " Pneumatic tests may be used in lieu of the hydrostatic test required by NC-6111.1...

only when the following conditions exist: (1) When components...

are so designed or supported that they cannot be safely filled with water. (2) When components...which are not readily dried are to be used in services where traces of the testing medium cannot be tol-erated...." Paragraph NC-6215 states, in part, that: "Following application of the hydrostatic test pressure... examination for leak-age shall be made of all joints...." Paragraph NC-6221(b) states, in part, that: "All pressure retaining components...shall be sub-jected to a system hydrostatic test at a pressure not less than 1.25 times the system design pressure."

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. Attachment to Letter G03-81-2866 Page 2 Dated December 23, 1981 Contrary to the above, Contract 251 Procedure No. PKS-WI-306, Revision 3, specifies a pneumatic test of the process pipe on penetration Nos. 23, 24, and 44. The process piping in these penetrations has been designed to accommodate the testing medium (water). Closure welds have been completed on penetration Nos. 24 and 44 in Unit 3 rendering the joints inaccessible for examination for leakage. The specified test pressure for penetration No. 44 is 188 PSIG whereas the specified design pressure of the process piping is 200 PSIG which would require a test pressure of 250 PSIG.

Items 1 and 2 represent failures to properly incorporate code requirements into applicable test procedures.

This is a severity Level V violation (Supplement II) applicable to Unit 3.

General Information Penetrations 23 and 24 are Type IV penetrations serving the Containment Spray System. The lines are the suction lines from the containment sumps to the Containment Spray pumps. Penetration 44 is a Type IV A penetration.

It is provided to accommondate the passage of the drain line from the Re-actor Drain Tank through the containment to the Gas Stripper.

Corrective Actions Taken A. Background Information For Part 1 Of The Noncompliance Concurrent with installation of Penetrations 23, 24, and 44, Ebasco performed a design review and verification with regard to the design pressures and temperatures of these components. The result of this investigation was documented by the issuance of a DCN on June 15, 1981.

The purpose of the DCN was to clarify that the guard pipes for these penetrations have dual design parameters. The guard pipes inside the containment form part of the containment vessel pressure boundary, thest are line numbers 2CS40-20lSA, 2CS40-203SB and 2CH8-328SA/BR. The de-sign pressure of these lines is 50 PSIG which is in accordance with

, PSAR Paragraph 6.2.4.1.la and is greater than the design pressure of the containment (44 PSIG). The DCN only changed the design pressure for line 2CH8-328SA/BR which was lowered from 150 PSIG. The design pressure of 150 PSIG was incorrectly based on the design pressure of the process line instead of the design pressure of the containment.

The guard pipes outside containment are not part of the containment pressure boundary. They are only exposed to atmospheric pressure.

The design pressure of line numbers 2CS40-200SA, 2CS40-202SB and 2CH8-624SA/BR was thus established at 5 PSIG. This was a decrease in design pressure for all three lines. Additionally, the DCN noted that the inside containment guard pipe welds would be tested during the combir ad ILRT and Overpressure Test of the containment as they are part of the containment vessel pressure boundary.

In accordance with the direction provided by the DCN, the 251 Contrac-tor (Peter Kiewit and Sons) performed the required ASME code pressure

. Attachment to Letter G03-81-2866 Page 3

.

• Dated December 23, 1981 Corrective Actions Taken (Continued)

A. Background Information For Part 1 Of The Noncompliance (Continued) test of the guard pipes based on the design pressure of 5 PSIG for Penetration 24. It was recognized that the inside containment guard pipe would still require pressure testing in accordance with a design pressure of 50 PSIG. The pressure test performed at 7.5 PSIG was not intended to qualify the inside containment guard pipe welds. After the pressure test of 7.5 PSIG, the blockout inside the containment around Penetration 24 was poured, covering fielo weld #4, one of three circumferential guard pipe welds, thus making the weld inaccessible.

On August 20, 1981, an NCR was written by Ebasco Quality Assurance stating that the construction sequence did not provide for visual accessibility of Penetration 24 during the required pressure test in accordance with ASME Section III, NC-6000, 1977 Edition, Summer 1978 Addenda. Ebasco Engineering's disposition on October 7, 1981 was that the required pressure test and examination be performed in accordance with NC-6129, Winter 1978 Addenda. This subparagraph provides a means of examination for pressure testing of inaccessible welded joints in piping. Contractor 251 is not able to perform this test as his ASME Certificate of Authorization extends up to and includes the Summer 1978 Addenda. Therefore, Contractor 224 will be assigned the responsi-bility of performing the required pressure test and preparing the necessary procedures to perform the work. The Supply System will be requested by Ebasco to inform the proper regulatory and State author-ities of Ebasco's use of this later code addenda for this particular case.

The DCN will be superseded with another DCN by December 31, 1981.

This DCN will revise the outside containment guard pipe design pres-sures to 50 PSIG for all three penetrations. While 50 PSIG is a highly conservative design pressure for these guard pipes, the use of a single design pressure for the entire length of the guard pipes is consis-tent with the original design intent. This will also clarify the test requirements for the penetration assemblies.

Contractor 224 shall also perform the pressure tests of the guard pipes of Penetrations 23 and 44, where the circumferential welds are accessible in accordance with NC-6112. It is anticipated that the pressure tests will be completed by June 30, 1982.

B. Background Information For Part 2 Of The Noncompliance Several issues were addressed by this portion of the noncompliance.

They were:

1. The pressure testing of the process pipe welds should have been performed prior to their surfaces becoming inaccessible for exam-ination when the penetrations were completely welded up.

i Attachment to Letter G03-81-2866 Page 4  :

. Dated December 23, 1981 Corrective Actions Taken (Continued)

8. Background Information For Part 2 Of The Noncompliance (Continued)

2. The specified design pressure for process line number 2CH3-514 SA/BR for Penetration 44 is 200 PSIG. Therefore, Procedure PKS-WI-306 should require a test pressure of 250 PSIG, not 188 PSIG as stated.

3. Procedure PKS-WI-306 states that the pressure test of the process pipes shall be pneumatic. This is not in accordance with Paragraph NC-6112 and another PKS procedure.

Ebasco addressed these issues as follows:

1. It was acceptable for Engineering to use inaccessible process pipe welds in the design of these particular penetrations. The ASME BPV Code allows the use of inaccessible welds for piping intended for this service. Specifically, Subparagraph NC-6129, issued in the Winter 1978 Addenda to the ASME Section III Code allows con-struction with inaccessible welds and provides details for per-forming the required pressure tests. This subparagraph was issued in the Winter 1978 Addenda to incorporate ASME Code Case 1541.

The Code Case, entitled Hydrostatic Testing of Embedded Class 2 and Class 3 Piping for Section III, Division I construction, was first issued in 1972. The A5ME's issuance and the NRC's acceptance of this Code Case and its subsequent revisions as stated in Regu-latory Guide 1.84, reflects the industries' position on the use of and testing of embedded and inaccessible welds.

All penetrations have been studied for access requirements (i.e.,

ISI). Penetrations 23, 24, and 44 have no access requirements and therefore, may utilize inaccessible welds in their construction.

It is physically impossible to pressure test the process pipe por-tion of these three penetrations at any time prior to complete installation of the process pipe within the penetration assembly.

The original NCR, mentioned previously, was also written against the pressure testing of these process pipes. Again, Engineering's disposition was to perform the test in accordance with NC-6129.

2. The specified design pressure for line number 2CH3-514 SA/BR is 150 PSIG. It has always appeared as such in the line list and was corrected to 150 PSIG fr a 200 PSIG on the appropriate Drawing by a Field Change Request, dsted December 12, 1980. Therefore, the correct test pressure is shown in Procedure PKS-WI-306 as 150 x 1.25 = 188 PSIG.

3. The use of a pneumatic test for testing the process pipes of Pene-trations 23, 24, and 44 is wrong. The pressure test should, and

, Attachment to Letter G03-81-2866 Page 5

- Dated December 23, 1981 Corrective Actions Taken (Continued)

B. Background Information For Part 2 Of The Noncompliance (Continued)

3. (Continued) will be, a hydrostatic test. Engineering failed to detect this during the procedure review. As the process pipe circumferentias welds are inaccessible, they must be tested in accordance with NC-6129 which was added in the Winter 1978 Addenda. As in the previous case, Contractor 251 cannot perform this work because his ASME Certificate of Authorization extends up to and includes the Summer 1978 Addenda. Again, Contractor 224 will be assigned '

the responsibility and will be required to develop a testing proce-dure and perform the work. It is expected that the prestare tests will be completed by May 31, 1982. Procedure PKS-WI-306 Revision 3 will be revised to delete pressure testing of the process pipes by Januarj 31, 1982.

C. Summary By resolving the pressure testing difficulties associated with these three penetrations in the dispositioning of the original NCR, the ASME Code and regulatory requirements will be satisfied. With the exception of the oversight in the review of Procedure PXS-WI-306 and the lack of clarity of the DCN, the actions taken by Ebasco as described herein provide evidence of adherence to Code requirements.

D. Corrective 5teps Taken The following corrective actions have been taken to assure compliance with the applicable code:

1. The design pressure for the guard pipes in all three penetrations

(#23, 24 and 44) has been made uniform (50 PSIG) over their entire length. This eliminates the original dual pressure requirements for the inboard (containment boundary) and outboard (atmospheric plus 5.0 PSIG) portions of the guard pipes.

2. Blockouts have been provided for Weld No. 4 on Penetrations #23 and #44 to allay any concerns relative to the accessibility of these welds during internal pneumatic pressure testing of their guard pipes at 62.5 PSIG.

! 3. Contractor 224 has been designated responsibility for performing the 62.5 PSIG pneumatic test of the guard pipes and the hydrosta-tic pressure test of the process pipes of these penetrations.

Action Taken to Prevent Recurrence For WNP-3, blockouts have been established for the guard pipe field welds on Penetrations #23 and #44 to eliminate any questions relative to access '

,, Attachment to Letter G03-81-2866 Page 6

- Dated December 23, 1981 l .

l Action Taken to Prevent Recu rence (Continued) during pressure testing of these welds. These blockouts will be maintained until pneumatic testing at 62.5 PSIG has been successfully completed.

For WNP-5, blockouts for these field welds on Penetrations #23, 24 and 44 guard pipes will be maintained until successful completion of the 62.5 PSIG pneumatic tests.

A Discussion of the Reasons for Failure to Adequately Investigate and Effect Corrective Actions to Preclude This Item of Honcompliance The Mechanical Contractor (251) installed the penetration assembly and per-formed all required tests, including a 7.5 PSIG internal pneumatic test which included Weld No. 4. Weld No. 4 falls within the containment boun-dary and as such requires testing as part of the containment. This weld will not be accessible during containment leak rate testino (Over Pressure and Integrated Leak Rate); however, its integrity will be established as part of these tests. Engineering took no corrective action after the NRC expressed its concern in May over the completion of pressure testing of field weld number 4 prior to concrete encasement because no corrective action was required. Procedure PKS-WI-306 does not specify that the pres-sure test be performed prior to the weld surface becoming inaccessible because Contractor 251 does not control concrete placement. However, as part of this procedure, it is required that pressure testing of these penetrations be performed to complete the installation activity. As an area cannot be worked by more than one Contractor at a time, Ebasco was assured that the ASME code internal pressure test could be performed, which it was, prior to concrete placement. In consideration of the above, the Civil Contractor, without concurrence of Mechanical Engineering, was re-leased to place concrete inside the containment including encasing field weld No. 4. It was not realized by Civil Construction that this blockout was intended to remain open.

Date of Full Compliance Access to Weld No. 4 on Penetrations #23 and #44 has been accomplished.

Integrity of these welds on Penetrations #23, 24 and 44, and their confor-mance to Code requirements, will be established by pneumatic pressure testing planned for completion by July 30, 1982.