ML17272A835
| ML17272A835 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/04/1980 |
| From: | Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML17272A834 | List: |
| References | |
| GO2-80-30, NUDOCS 8002280060 | |
| Download: ML17272A835 (9) | |
Text
Washington Public Power Supply System A JOINT OPERATING AGENCY P. O. BOX 955 3000 GSO. WaS~IVOTON WAY R>CRLANO. WiSRIVCrOrr 99352 PHONS (509) 375 5000
Subject:
WPPSS NUCLEAR PROJECT NO.
2 DOCKET NO ~ 50-397, CPPR-93 NRC INSPECTIO 22-25, 1979 REPORT NO.
-397/79-1
Reference:
Letter G.
S.
Spencer to N. 0. Strand, dated December 18, 1979
Dear Nr. Spencer:
G02-80-30 February 4, 1980 G.
S.
- Spencer, Chief Reactor Construction and Engineering Support Branch Nuclear Regulatory Commission Region V
Suite 202, Walnut Creek Plaza 1900 N. California Boulevard Walnut Creek, California 94596 J
IIII::wL'II g-',
FFB 8 1'80 p'\\
"p, This is in response to your letter of December 18, 1979 (referenced above),
which documented the results of the NRC inspection conducted on October 22-25, 1979 of activities authorized by NRC Construction Permit No.
CPPR-93.
This letter identified three items of noncompliance which were categorized as infractions.
The specific NRC findingsas stated in your letter, and the WPPSS responses are provided in Appendix A to this letter.
If you have any questions or desire further information, please advise.
Very truly yours, D. L.
RENBERGER Assistant Director, Generation and Technology DLR/PJM/ln Attachment; As stated cc w/att:
JH Blas -
Stello - Office of Inspection 8 Enforcement, Washington, D.C.
JJ Verderber - BSR, NY
APPENDIX A Washington Public Power Supply System P.O.
Box 968
- Richland, Washington 99352 Docket Number 50-397 Construction Permit Number CPPR-93 NOTICE OF VIOLATION Based on the results of NRC inspections conducted between October 22 and 25, 1979, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC facility license No.
CPPR-93 as indicated below.
A.
10CFR 50, Appendix B, Criterion V, states in part, that "activities affecting quality...shall be accomplished in accordance with...
instructions, procedures, or drawings..."
Paragraph D.2.5 of the WPPSS guality Assurance Program documented in the PSAR states in part, that "...all project contractors for the nuclear related portions of the plant will be required to have a guality Assurance Program...the program shall include the following items as...applicable to the...construction for which the contractor is responsible."
Paragraph D.2.5.5 states in part, that, "activity affecting quality...shall be accomplished in accordance ijith...procedures...".
(1)
Work procedure SP-2005-H2, of the Johnson Controls Inc.,
a site contractor, states"in part, that "all pipe and tube endings will be capped or otherwise closed at the end of each day."
Contrary to the above, on October 24, 1979, at the end of the work
- day, one process instrument line on containment penetration no. 72, two process instrument lines on penetration no.
- 548, and four process instrument lines on penetration no.
29 were found uncapped, exposing the internals of the reactor vessel.
This is a repeat of previous NRC findings on February 27 and March 1, 1979.
This is an infraction.
ACTION TO CORRECT DEFICIENCY Corrective Action Request No.
220-1425 was initiated against the deficient penetration.
All deficient areas were inspected for cleanliness and recapped.
The 220 contractor documented the inspection and rework on Inspection/Surveillance Report Number 477, dated 11/5/79.
J p
~ 4.
Appendix A (continued)
ACTION TO PREVENT RECURRENCE Daily surveillances were doubled by Johnson Controls in all areas in their custody.
This activity began on October 29, 1979.
Johnson Controls Project Manager issued a
memo to all craft supervision regarding the importance of capping or sealing instrument lines and penetrations.
This memo was issued and posted on the craft bulletin board November 15, 1979.
Training sessions for craft and gA personnel were held between October 29 and December 12, 1979.
Eleven classes were held.
DATE OF FULL COMPLIANCE Full compliance was achieved December 15, 1979.
(2)
Fischbach/Lord Electric Company procedure CP208 states under general maintenance requirements:
"covers,
- caps, plugs, and other closures shall be maintained intact."
This procedure goes on to state "dust coverings,
- shrouds, local sealing, heating methods and mechanical cleaning shall be employed to keep the structure as clean and dry as possible."
Contrary to the above, inspection of instrument racks H22 P026, H22 P027, H22 P005, and H22 P004, on October 24, 1979, revealed:
(a)
A heavy accumulation of dust, dirt, and debris on all racks.
(b)
The racks were not. protected from adjacent construction activities and were used to store structural bolts, structural steel
- plates, and a gas pressure bottle cap.
(c)
On rack H22 P026, instruments B22 N038A and B22 N036B had been removed without capping or otherwise protectinq the opened tube ends leading to the instruments.
Likewise, on rack H22 P005, instruments C34 N004C and B22 N026C had been removed without capping or otherwise protecting the opened tube ends leading to the instruments.
(d)
Dirt and debris was evident during a visual inspection of the inside of uncapped instrument sensing lines on the above mentioned racks.
This is an infraction.
ACTION TO CORRECT DEFICIENCY All deficient equipment was cleaned and sealed or capped immediately.
0
Appendix A (continued)
ACTION TO PREVENT RECURRENCE Surveillance activities have been increased to assure implementation of maintenance requirements and protection from construction activities.
Corrective Action Request No. 218-1424, against the deficient maintenance and cleanliness activities, has been issued to the contractor.
A revised maintenance procedure has been issued which clarifies maintenance requirements and establishes specific time intervals for maintenance performance.
Audits/
surveillances are being conducted to verify adequate corrective action.
In addition, for equipment under the cognizance of Test and Startup, the Instrument Test Guide will be revised to require performance of System Lineup Test I-3 when removing or installing any instruments in the plant.
This will assure cleanliness and proper plugging/taping of instrument lines.
DATE'OF FULL COMPLIANCE Full compliance was achieved on January 31, 1980.i.
B.
10CFR 50, Appendix B, Criterion III, requires in part, "measures shall be established to assure that applicable regulatory requirements...are correctly translated into specifications,
- drawings, procedures, and instructions."
FSAR table 3.2-1 lists reactor protective system components as guality Class I ("meets the quality assurance requirements of 10CFR 50, Appendix B") and Seismic Category I.
The PSAR paragraph 7.2.1.1,2 "classification",
further states..."The Reactor protective system is classified as Safety Class 2, Seismic Catego'ry I, and guality Group B (Electrical Safety Class IE)".
Contrary to the above requi rements, on October 23, 1979, inspection of the reactor protection system (RPS) disclosed 4 turbine stop valve position switches (POS N006 A through D), and 8 pressure switches pro-viding RPS indication of turbine governor valve fast closure (PS N005 A through D) were not specified and purchased to Electrical Safety Class IE and Seismic Category I requirements.
This is an infraction.
ACTION TO CORRECT DEFICIENCY An Engineering change is being processed (Project Engineering Directive (PED)
No. 218-E-2340) to replace the existing instrumentation with qualified instruments or type tested existing instruments.
ap 0
Appendix A (continued)
In addition, the HNP-2 FSAR is being reviewed and will be revised to clarify the seismic classification, the quality group, and the quality class, as applicable, of the turbine generator inputs to the Reactor Protective System.
ACTION TO PREVENT RECURRENCE 1)NP-2 has a program in progress to identify all Class IE equipment and verify that adequate documentation exists for each piece.
The type of problem noted above will be identified during this program, Corrective action will be taken as appropriate.
DATE OF FULL COMPLIANCE Full compliance will be achieved by June 27, 1980.
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