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| number = ML17272A835
| number = ML17272A835
| issue date = 02/04/1980
| issue date = 02/04/1980
| title = Responds to NRC 791218 Ltr Re Violations Noted in IE Insp Rept 50-397/79-16.Corrective Actions:All Deficient Areas Were Inspected & Recapped & All Areas Were Cleaned & Capped
| title = Responds to NRC Re Violations Noted in IE Insp Rept 50-397/79-16.Corrective Actions:All Deficient Areas Were Inspected & Recapped & All Areas Were Cleaned & Capped
| author name = Renberger D
| author name = Renberger D
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
| author affiliation = WASHINGTON PUBLIC POWER SUPPLY SYSTEM
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = GO2-80-30, NUDOCS 8002280060
| document report number = GO2-80-30, NUDOCS 8002280060
| title reference date = 12-18-1979
| package number = ML17272A834
| package number = ML17272A834
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
| page count = 9
}}
}}
See also: [[see also::IR 05000397/1979016]]


=Text=
=Text=
{{#Wiki_filter:Washington
{{#Wiki_filter: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
Public Power Supply System A JOINT OPERATING AGENCY P.O.BOX 955 3000 GSO.WaS~IVOTON
 
WAY R>CRLANO.WiSRIVCrOrr
==Subject:==
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:
WPPSS NUCLEAR PROJECT NO.
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
2 DOCKET NO ~ 50-397, CPPR-93 NRC INSPECTIO 22-25, 1979 REPORT NO.
and Engineering
-397/79-1
Support Branch Nuclear Regulatory
 
Commission
==Reference:==
Region V Suite 202, Walnut Creek Plaza 1900 N.California
Letter G.
Boulevard Walnut Creek, California
S.
94596 J IIII::wL'II
Spencer to N. 0. Strand, dated December 18, 1979
g-', FFB 8 1'80 p'\"p, This is in response to your letter of December 18, 1979 (referenced
 
above), which documented
==Dear Nr. Spencer:==
the results of the NRC inspection
G02-80-30 February 4, 1980 G.
conducted on October 22-25, 1979 of activities
S.
authorized
: Spencer, Chief Reactor Construction and Engineering Support Branch Nuclear Regulatory Commission Region V
by NRC Construction
Suite 202, Walnut Creek Plaza 1900 N. California Boulevard Walnut Creek, California 94596 J
Permit No.CPPR-93.This letter identified
IIII::wL'II g-',
three items of noncompliance
FFB 8 1'80 p'\\
which were categorized
"p, This is in response to your letter of December 18, 1979 (referenced above),
as infractions.
which documented the results of the NRC inspection conducted on October 22-25, 1979 of activities authorized by NRC Construction Permit No.
The specific NRC findingsas
CPPR-93.
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
This letter identified three items of noncompliance which were categorized as infractions.
and Technology
The specific NRC findingsas stated in your letter, and the WPPSS responses are provided in Appendix A to this letter.
DLR/PJM/ln
If you have any questions or desire further information, please advise.
Attachment;
Very truly yours, D. L.
As stated cc w/att: JH Blas-BdlR, NY HR Canter-88R, NY JR Lewis-BPA, Richland V Stello-Office of Inspection
RENBERGER Assistant Director, Generation and Technology DLR/PJM/ln Attachment; As stated cc w/att:
8 Enforcement, Washington, D.C.JJ Verderber-BSR, NY  
JH Blas -
APPENDIX A Washington
: BdlR, NY HR Canter - 88R, NY JR Lewis - BPA, Richland V
Public Power Supply System P.O.Box 968 Richland, Washington
Stello - Office of Inspection 8 Enforcement, Washington, D.C.
99352 Docket Number 50-397 Construction
JJ Verderber - BSR, NY
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
APPENDIX A Washington Public Power Supply System P.O.
were not conducted in full compliance
Box 968
with conditions
: 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.
of your NRC facility license No.CPPR-93 as indicated below.A.10CFR 50, Appendix B, Criterion V, states in part, that"activities
CPPR-93 as indicated below.
affecting quality...shall
A.
be accomplished
10CFR 50, Appendix B, Criterion V, states in part, that "activities affecting quality...shall be accomplished in accordance with...
in accordance
instructions, procedures, or drawings..."
with...instructions, procedures, or drawings..." Paragraph D.2.5 of the WPPSS guality Assurance Program documented
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."
in the PSAR states in part, that"...all project contractors
Paragraph D.2.5.5 states in part, that, "activity affecting quality...shall be accomplished in accordance ijith...procedures...".
for the nuclear related portions of the plant will be required to have a guality Assurance Program...the
(1)
program shall include the following items as...applicable
Work procedure SP-2005-H2, of the Johnson Controls Inc.,
to the...construction
a site contractor, states"in part, that "all pipe and tube endings will be capped or otherwise closed at the end of each day."
for which the contractor
Contrary to the above, on October 24, 1979, at the end of the work
is responsible." Paragraph D.2.5.5 states in part, that,"activity affecting quality...shall
: day, one process instrument line on containment penetration no. 72, two process instrument lines on penetration no.
be accomplished
: 548, and four process instrument lines on penetration no.
in accordance
29 were found uncapped, exposing the internals of the reactor vessel.
ijith...procedures...".
This is a repeat of previous NRC findings on February 27 and March 1, 1979.
(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
This is an infraction.
line on containment
ACTION TO CORRECT DEFICIENCY Corrective Action Request No.
penetration
220-1425 was initiated against the deficient penetration.
no.72, two process instrument
All deficient areas were inspected for cleanliness and recapped.
lines on penetration
The 220 contractor documented the inspection and rework on Inspection/Surveillance Report Number 477, dated 11/5/79.
no.548, and four process instrument
 
lines on penetration
J p
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.
~ 4.
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)
Appendix A (continued)
ACTION TO PREVENT RECURRENCE
ACTION TO PREVENT RECURRENCE Daily surveillances were doubled by Johnson Controls in all areas in their custody.
Daily surveillances
This activity began on October 29, 1979.
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
Johnson Controls Project Manager issued a
regarding the importance
memo to all craft supervision regarding the importance of capping or sealing instrument lines and penetrations.
of capping or sealing instrument
This memo was issued and posted on the craft bulletin board November 15, 1979.
lines and penetrations.
Training sessions for craft and gA personnel were held between October 29 and December 12, 1979.
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
Eleven classes were held.
Full compliance
DATE OF FULL COMPLIANCE Full compliance was achieved December 15, 1979.
was achieved December 15, 1979.(2)Fischbach/Lord
(2)
Electric Company procedure CP208 states under general maintenance
Fischbach/Lord Electric Company procedure CP208 states under general maintenance requirements:
requirements: "covers, caps, plugs, and other closures shall be maintained
"covers,
intact." This procedure goes on to state"dust coverings, shrouds, local sealing, heating methods and mechanical
: caps, plugs, and other closures shall be maintained intact."
cleaning shall be employed to keep the structure as clean and dry as possible." Contrary to the above, inspection
This procedure goes on to state "dust coverings,
of instrument
: shrouds, local sealing, heating methods and mechanical cleaning shall be employed to keep the structure as clean and dry as possible."
racks H22 P026, H22 P027, H22 P005, and H22 P004, on October 24, 1979, revealed: (a)A heavy accumulation
Contrary to the above, inspection of instrument racks H22 P026, H22 P027, H22 P005, and H22 P004, on October 24, 1979, revealed:
of dust, dirt, and debris on all racks.(b)The racks were not.protected from adjacent construction
(a)
activities
A heavy accumulation of dust, dirt, and debris on all racks.
and were used to store structural
(b)
bolts, structural
The racks were not. protected from adjacent construction activities and were used to store structural bolts, structural steel
steel plates, and a gas pressure bottle cap.(c)On rack H22 P026, instruments
: plates, and a gas pressure bottle cap.
B22 N038A and B22 N036B had been removed without capping or otherwise protectinq
(c)
the opened tube ends leading to the instruments.
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
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.
C34 N004C and B22 N026C had been removed without capping or otherwise protecting
(d)
the opened tube ends leading to the instruments.(d)Dirt and debris was evident during a visual inspection
Dirt and debris was evident during a visual inspection of the inside of uncapped instrument sensing lines on the above mentioned racks.
of the inside of uncapped instrument
This is an infraction.
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.
ACTION TO CORRECT DEFICIENCY
 
All deficient equipment was cleaned and sealed or capped immediately.  
0
0  
 
Appendix A (continued)
Appendix A (continued)
ACTION TO PREVENT RECURRENCE
ACTION TO PREVENT RECURRENCE Surveillance activities have been increased to assure implementation of maintenance requirements and protection from construction activities.
Surveillance
Corrective Action Request No. 218-1424, against the deficient maintenance and cleanliness activities, has been issued to the contractor.
activities
A revised maintenance procedure has been issued which clarifies maintenance requirements and establishes specific time intervals for maintenance performance.
have been increased to assure implementation
Audits/
of maintenance
surveillances are being conducted to verify adequate corrective action.
requirements
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.
and protection
This will assure cleanliness and proper plugging/taping of instrument lines.
from construction
DATE'OF FULL COMPLIANCE Full compliance was achieved on January 31, 1980.i.
activities.
B.
Corrective
10CFR 50, Appendix B, Criterion III, requires in part, "measures shall be established to assure that applicable regulatory requirements...are correctly translated into specifications,
Action Request No.218-1424, against the deficient maintenance
: drawings, procedures, and instructions."
and cleanliness
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.
activities, has been issued to the contractor.
The PSAR paragraph 7.2.1.1,2 "classification",
A revised maintenance
further states..."The Reactor protective system is classified as Safety Class 2, Seismic Catego'ry I, and guality Group B (Electrical Safety Class IE)".
procedure has been issued which clarifies maintenance
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.
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.
This is an infraction.
ACTION TO CORRECT DEFICIENCY
ACTION TO CORRECT DEFICIENCY An Engineering change is being processed (Project Engineering Directive (PED)
An Engineering
No. 218-E-2340) to replace the existing instrumentation with qualified instruments or type tested existing instruments.
change is being processed (Project Engineering
 
Directive (PED)No.218-E-2340)
ap 0
to replace the existing instrumentation
 
with qualified instruments
or type tested existing instruments.  
ap 0  
Appendix A (continued)
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
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.
System.ACTION TO PREVENT RECURRENCE
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.
1)NP-2 has a program in progress to identify all Class IE equipment and verify that adequate documentation
The type of problem noted above will be identified during this program, Corrective action will be taken as appropriate.
exists for each piece.The type of problem noted above will be identified
DATE OF FULL COMPLIANCE Full compliance will be achieved by June 27, 1980.
during this program, Corrective
 
action will be taken as appropriate.
0 ~
DATE OF FULL COMPLIANCE
1}}
Full compliance
will be achieved by June 27, 1980.  
0~1
}}

Latest revision as of 08:58, 8 January 2025

Responds to NRC Re Violations Noted in IE Insp Rept 50-397/79-16.Corrective Actions:All Deficient Areas Were Inspected & Recapped & All Areas Were Cleaned & Capped
ML17272A835
Person / Time
Site: Columbia Energy Northwest icon.png
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)
v • d • e


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 -

BdlR, NY HR Canter - 88R, NY JR Lewis - BPA, Richland V

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.

0 ~

1

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