ML17272A835

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

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: IR 05000397/1979016 ML17272A833 ML17272A835 ML17272A836 ML17272A837
References
GO2-80-30, NUDOCS 8002280060
Download: ML17272A835 (9)

See also: IR 05000397/1979016

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