IR 05000400/1981018
| ML18017B558 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/26/1981 |
| From: | Conlon T, Harris J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18017B554 | List: |
| References | |
| 50-400-81-18, 50-401-81-18, 50-402-81-18, 50-403-81-18, NUDOCS 8112230227 | |
| Download: ML18017B558 (28) | |
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uNITED STATES NUCLEAR REGULATORYCOMMISSlON
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORG IA30303 OCT 27 ]88 Report Nos. 50-400/81-18, 50-401/81-18, 50-402/81-18, 50-403/81-18 Licensee:
Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:
Shearon Harris Docket Nos. 50-400, 50-401, 50-402, 50-403 License Nos.
CPPR-158, CPPR-159, CPPR-160, CPPR-161 Inspection at Shearon Harris site near Raleigh, NC Inspector:
J
. Harris Approved b T. E. Conlon, Section Chief Engineering Inspection Branch Engineering and Technical Inspection Division Date S gned g~ -~c,- s'l Date Signed SUMMARY Inspection on September 8-11, 1981 Areas Inspected This special unannounced inspection involved
inspector-hours on site to address 12 allegations regarding protective coatings, structural concrete, control of design changes, intake structure gate guides, foundations, and protection of installed electric motors.
Results The inspection of the 12 allegations revealed the following:
1.
Four allegations were correct or partially correct as stated; however, the licensee's gA program had detected the problems described and corrective action was taken or is in progress.
2.
Four allegations were correct or partially correct as stated; however, these did not involve violation of NRC regulations and are of no safety signifi-cance...
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3.
One allegation was partially correct as stated.
Investigation of this allegation resulted in identification of an unresolved item pending further review by NRC.
4..
Investigation of one, allegation is incomplete and wi 11 continue in future NRC investigations.
5.
The remaining two allegations were not substantiated; however, during investigation of one of these allegations, a violation was identified (Control of ESM Gate Guides - paragraph 7.g).
REPORT DETAILS 1.
Persons Contacted Licensee Employees
"R. M. Parsons, Site Manager
~H. R. Banks, Manager Corporate QA
"A. M. Lucas, Senior Resident Engineer
- G. L. Forehand, Director of QA/QC
"B. Seyler, Principal Civil Engineer
"L. R. Garner, Senior Construction Specialist, Civil
- E. L. Kelly, Senior QA Specialist
"J.
F. Nevi 11, Principal Civil Engineer
- L. E. Jones, Principal QA Engineer P. Morris, Engineering Administration Specialist G. Thompson, Civil Construction Inspection Supervisor J. Abernathy, Materials 5 Coatings Engineer Other licensee employees contacted included five construction craftsmen, six technicians, and three office personnel.
Other Organizations
"W. D. Goodman, Project Manager, Daniels NRC Resident Inspector
"G. Maxwell
"Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on September ll, 1981 with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions.
New unresolved items identified during this inspection are discussed in paragraph 7 S
5.
Independent Inspection No independent inspection was conducted.
6.
Scope of Inspection Individuals contacted NRC, Region II representatives and expressed various concerns with construction activities at the Shearon Harris Nuclear Plant.
These individuals, hereinafter referred to as "allegers",
contacted the NRC independent of each other.
Each of the allegers expressed different con-cerns'~
The specific allegations addressed during this inspection are as follows:
a.
A prohibited substance was used to repair cracks and fill construction joints inside the containment building.
b.
A letter was provided to the NRC which erroneously stated that no epoxy was used in the containment building below the 246 elevation.
c.
Protective coatings were improperly applied and may not adhere properly.
d.
Areas in concrete where placement form tie rods had been cut off (bug holes) were not properly repaired.
e.
When problems are found, field change requests ( FCR's)
are issued to avoid the original specifications.
f.
A cold joint exists on the 211-elevation in the "core key" area of the Unit 2 containment building.
g.
Non-seismically-qualified gate guides were used at the intake structure when seismically qualified gate guides were required.
h.
Concrete was poured even though preparation for the pour was known to be inadequate.
i.
Sheet metal welded to seismic plates touching reinforcing bar may lead to damage to the reinforcement due to cathodic action.
j.
Installed motors were improperly protected during sandblasting opera-tions and now have sand inside them.
k.
Waterproofing on the below grade portion of the turbine building wall was damaged and improperly repaired.
l.
Imprope~ rebar cadwelds have been performed by several welders through-out the containment buildin.
Allegations, Discussions and Findings a.
Allegation An alleger expressed the concern that a
substance referred to as
"Concresive" was used to repair cracks and construction joints to stop water in-leakage on the 211-elevation of the
"Core Key" area of the containment building.
The individual indicated that the repair sub-stance contained epoxy which was not supposed to be used below the 246-elevation because of possible radiation affects on the epoxy.
Discussion The inspector examined the 211-elevation in the core key area of the containment building and discussed the use of Concresive 1411 epoxy grout with responsible engineers.
Concresive 1411 epoxy grout is being used and has been approved for use in Service Level 1 areas which includes the 211-elevation of the core key area of the containment building.
Examination of its use and discussions with responsible engineers disclosed that Concresive is being used in accordance with specification CAR-SH-COR-02, "Protective Coating Application".
Exami-nation of technical report 215-78-G,
"Compatability Testing-Concresive 1411 Epoxy Mortar" showed that Desi'gn Base Accident tests with simulated LOCA conditions were performed by Southern Imperial Coatings Corporation on January 25, 1978.
However, the test report was not clear as to whether the testing included radiation tolerance.
Section 1 of the PSAR states that the gA requirements for protective coatings comply with regulatory guide 1.54.
Regulatory Guide 1.54 references American National Standards N101.4, N101.2 and N5.9 which require that coatings used in Service Level 1 areas be tested for radiation tolerance.
Lack of evidence verifying that radiation tolerances have been performed on Concresive 1411 epoxy grout was identified to the licensee as Unresolved Item 50-400,401,402,403/81-01,
"Epoxy Grout Radiation Tolerance",
pending review of the test data by NRC.
Findings The allegation is partially correct as stated in that Concresive was used below the 246 elevation in the containment building.
However, the Concresive grout has been tested for Design Base Accident environmental conditions and approved for use in the containment building.
The test data was not clear as to whether the testing included radiation toler-ance.
Lack of verification of radiation tolerance was identified to the licensee as an unresolved item.
No violations or deviations were identifie b.
Allegation An alleger expressed a concern that a letter was provided to the NRC which erroneously stated that epoxy was not used in the containment building below the 246-elevation.
Discussion The NRC inspector examined the subject letter and discussed the use of epoxy based coatings and grout materials in the containment building with responsible engineers and inspectors.
The subject letter, da'ted May 14, 1981, is an internal memorandum from the Senior Resident Engineer to the Site Director of QA/QC.
A copy of, this memorandum was provided to the NRC resident inspector.
The memorandum does state that epoxy was not used below the 249 elevation in the containment buildings.
However, the memorandum also references FCR-C-2417 for clarification of areas acceptable for use of epoxy material.
FCR-C-2147, and its referenced documents (FCR-C-096, FCR-C-1648, and FCR-C-174)
state that approved epoxy based materials can be used anywhere in the containment building except on the inside face of the primary shield wall between elevation 236 and 249.
As stated in paragraph 7.a, an epoxy grout was used in the core key areas on the elevation 211 level of the containment building.
Exami-nation of the areas in the containment building where coatings have been applied and review of test reports on coating materials disclosed that epoxy coatings have been applied below the elevation 249 level in the containment building.
The inspector discussed with responsible licensee engineers, the internal memorandum which implies that no epoxy was used below elevation 249 in the containment building.
These discussions disclosed that, as a result of a compositional error, the memorandum was not clear and implied that no epoxy was used below elevation 249 in the containment building, when in fact it was.
This memorandum was not an official QA record or document nor was it an official letter to the NRC.
Findings The allegation was correct as stated in that a letter was provided to the NRC which erroneously stated that no epoxy was used in the contain-ment below elevation 246.
However, this letter was a
copy of an internal memorandum from the Resident Engineer to the Site QA/QC Director and not an official letter to the NRC.
The memorandum con-tains a compositional error which implies that epoxy was not used below elevation 249 of the containment bui lidng.
This memo is not a
QA record.
The use of epoxy based materials in areas below elevation 249 in the containment building is clearly documented in site QA records.
No violations or deviations were identifie c.
Al 1 egati on According to an alleger, 11-S coating was applied on top of Concresive grout used to seal cracks on the 211-elevation in the core key area before in-leakage of water was stopped.
The alleger does not believe the coating cured properly because of moisture present.
Discussion Discussions with responsible engineers and examination of the subject area disclosed that deficiency report number DR PC-34 was written because of improperly applied ll-S coating on the 211 elevation of the core key and that the improperly applied 11-S coating was removed.
DR PC-34 was initiated before the allegation was reported to the NRC and is still open pending resolution of the deficiency.
Findings The allegation was correct as stated.
However, the licensee identified the deficiency and initiated a deficiency report in accordance with the site gA/gC program.
No violations or deviat,ions were identified.
d.
Allegation According to an alleger, dry patch, which was used to repair tie rod holes (bug holes) in concrete in zones 3 and 4 of the unit one contain-ment building, began to crumble.
The crumbling dry patch was subse-quently covered with grout and protective coatings.
Discussion The inspector examined the concrete in zones 3 and 4 of the containment building and discussed the use of dry patch in repairing
"bug holes" and problems encountered in the use of coatings on dry patch with responsible engineel s.
Discussions with responsible engineers disclosed that the subject concern had been identified by the licensee as a deficiency in DR PC-09 on March 20, 1981.
Examination of DR PC-09 and the attached investigation report showed that improperly cured dry patches had been covered with Concresive 1411.
The discovery of Concresive being applied over improperly cured dry patches resulted in a comprehensive investigation of all concrete surfaces which received a
Nutec 11S coating in Zones 1,
3 and 4 of the containment building.
In the investigation report, three responsible gC inspectors stated all improperly cured dry patches were removed prior to coating with Nutec-llS.
The cause of the improperly cured dry patches was attributed to not covering the patches with a curing compound.
To
prevent recurrence of the problem, concrete personnel have been instructed to use curing compounds on all cosmetic repairs of bug holes resulting from cut-off of tie rods.
All dry patches improperly covered with Concresive were removed and repaired.
Examination of the subject areas by the NRC inspector showed no improperly cured dry patches or evidence that coatings have been applied to improperly cured dry patches.
Findings The allegation was correct as stated.
Improperly cured dry patches were covered with Concresive grout 1411; however, the licensee's gA program detected the deficiency before the allegation was reported to the NRC and adequate corrective action was taken.
No violations or deviations were identified.
Allegation An alleger stated that some of the design field change requests (FCR's)
are
"taken care of on site" rather than going back to the person or organization which approved the original specification.
Discussion The inspector examined sections 2 and 3 of the revised Corporate gA Program Manual and Section 3 of the Nuclear Power Engineering Design (NPED)
procedure manual.
These manual sections pertain to design changes, FCRs and specification amendments.
Examination of these manuals and discussions with responsible management disclosed that the revised gA Manual and implementing NPED procedures meet the design control requirements specified in Regulatory Guide 1.64, ANSI Standard N45.2. 11, 1974 and Criter'ion III, Design Control, of Appendix B, Title 10 of the Code of Federal Regulations.
These requirements specify that:
"Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization".
The plant owner shall designate the new responsible organization which may be the owners'wn engineering organization."
The CP&L Corporate gA Manual specifies that the Vice President of the Nuclear Power Engineering Department (NPED), is responsible for Nuclear Power Engineering.
It further specifies that he assigns responsibility for engineering of the Shearon Harris plant to the Manager of Engineering.
These responsibilities include direction of the plant design effort and management of the assigned A/E contracts.
Also, in
accordance with delegated responsibility from the Vice President of NPED, Manager of Engineering is responsible for deciding the di sposi tioning of FCR'.
Most of the FCR'
are dispositioned through the original A/E.
However, in accordance with the Corporate QA program, the Manager of Engineering, Harris Plant, has the authority to disposition FCR's onsite if the following criteria are met:
(1)
CP&L has access to pertinent background information; (2)
CP&L has demonstrated design competence; and (3)
CP&L has an understanding of the design intent.
Examination of FCR controls by this NRC inspector and by other NRC inspectors on design control,s (documented in NRC reports 80-12 and 81-09)
showed that FCR's are being controlled in accordance with the Corporate QA Program, and that the licensee appears to have an adequate management control system in the area of engineering and design controls Findings The allegation was correct as stated.
Specification amendments and FCRs are sometimes approved by CP&L without going back to the origi-nator for approval.
However, these changes are permissible under the Corporate QA program manual and NPED procedure manual.
No violations or deviations were identified.
f.
Allegation According to an alleger, about one and one-half years ago, a concrete placement of approximately 3000 yards was being made in the core key area of the Unit 2 containment building when a cold joint developed.
When this cold joint developed, instructions were given by responsible CP&L management to put concrete over the joint and blend it with a
vibrator.
Discussion The inspector examined the records for the concrete pours made to date in the core key area of the Unit 2 containment building.
Only two large pours were made, pour number 2CBSL216001 (3000 cubic yards)
and pour number 2CBSL216002 (4889 cubic yards).
Examination of documenta-tion and discussions with responsible construction craft and engineers disclosed that some problems were encountered in placing pour number 2CBSL216002, but not pour number 2CBSL216001.
Pour number 2CBSL216002 was placed on December 13-14, 1979, in the core key area between eleva-tion 208 and 216.
According to the CP&L Construction Superintendent and the CP&L QC inspector on the placement there was some concern as to
whether or not a cold joint developed.
The Civil gC Inspector documented the concern on the Field Inspection Report.
Discussions with responsible engineers and examination of the Field Inspection Report disclosed the following:
(I)
During the placement on
. December 14, 1979, at approximately 8:30 p.m.,
a questionable area of concrete was observed.
(2)
The Civil gC =Inspector directed that the area be vibrated which resulted in penetration of the concrete.
(3)
The concrete pump malfunctioned and its length of potential downtime was unknown.
(4)
A bucket was ordered to place fresh concrete in the area.
(5)
The Site Manager and the Construction Superintendent were notified that the concrete appeared to have an initial set.
(6)
After twenty minutes, fresh concrete was placed on the question-able concrete.
(7)
The Site Manager, Construction Superintendent and Civil gC Inspector
'observed vibrating operations; the penetration was sufficent to consolidate the two layers.
(8)
The Site Manager, Construction Superintendent, Civil gC Inspector and Daniel Construction Superintendent were in agreement that the area was definitely not a cold joint.
Findings The allegation was not substantiated.
There was some concern during the placement of pour number 2CBSL216002 in the core key area of the Unit 2 containment building that a cold joint might have developed.
Documentation and discussions indicated that fresh concrete was put on the old concrete to keep it alive (a normal construction practice)
and vibrated.
A cold joint did not develop during this placement.
The action of placing fresh concrete on top of old concrete and vibrating it prevented formation of a cold joint.
No violations or deviations were identified.
g.
Allegation Non-seismically-qualified gate guides were used at the intake structure when seismically qualified gate guides were require Discussion Examination of pertinent drawings disclosed that the following type gate guides are to be installed in the Emergency Service Water and Cooling Tower Mater Intake Structure.
GUIDE TYPE CLASS (1)
Traveling screen guides (2)
Coarse screen guides (3)
Fine screen guides (4)
Stop log guides Seismic & Non-Seismic Seismic Seismic Non Seismic The drawings show that the non-seismic traveling screen guides are for the cooling tower (i.e., non-safety related)
bay of the intake struc-ture.
Examination of purchase documents showed the following.
The coarse screen, fine screen and stop log guides were all purchased as seismic class (i.e ~
, safety-related)
components.
The stop log guides were purchased as seismic, even though this classification was not required for these items.
The traveling screen guides were purchased as safety related (seismic)
and non-safety related (non-seismic)
components.
The safety related traveling screen guides were purchased under purchase order number 435-223 and the non-safety related screen guides were purchased under purchase order number 435-222.
On September 10, the inspector examined controls on storage of the traveling screen guides.
The inspector observed that safety-related and non-safety related screen guides were tagged with gA acceptance tags and stored together in the permanent laydown area.
The inspector also observed that the safety related and non-safety related screen guides were stored together in the temporary storage area at the intake structure pending their installation in the structure.
The screen guides in the temporary storage area were not identi,fied as to which ones were safety related and which ones were non-safety related.
The inspector examined the screen guides and could not detect any visible difference between the safety related and non-safety related screen guides.
In accordance with 10 CFR 50, Appendix 8, Criterion VIII, as implemented by CP&L's PSAR Section 1.8.5.8, CP&L's Corporate gA Program, Section 5,
and Shearon Harris Construction Procedures A-Xlll-08and CQC-7, materials, parts and components, are to be identi-fied and controlled to prevent the use of incorrect or deficient materials, parts, and components.
Failure to control safety-related materials in accordance with these requirements was identified to the licensee as Violation Item 50-400, 401, 402, 403/81-18-02,
"Control of ESM Gate Guides"
Findings The allegation was not substantiated.
However, during the investi-gation of the allegation, it was determined that storage of seismically qualified screen guides was not controlled.
Lack of control on storage of the traveling screen guides may have resulted in non-seismically qualified gate guides being installed in the intake structure.
This was identified to the licensee as a violation.
h.
Allegation According to an alleger, an exterior wall in the fuel handling area was poured over a surface that had not been properly cleaned.
Dirt had not been cleaned from an area of approximately 3 to 4 square feet.
Discussion The NRC inspector examined exposed concrete surfaces and construction joints in the fuel handling building and discussed preplacement cleanup inspections with responsible construction inspectors.
Examination of exposed concrete surfaces and construction joints and discussions with responsible engineers disclosed some voids were discovered in a hori-zontal construction joint.due to dirt pockets.
However, these voids were identified by the licensee in deficiency report number DR-C-156 on January 15, 1979, and are being corrected in accordance with the QA program.
The area of concern was in placement number 1FHSL246001 in the South Fuel Pool Slab.
No other areas of voids due to improper cleanup were detected by the inspector.
Findings The allegation was substantiated.
One case o'f voids due to improper prepour cleanup was disclosed; however, the licensee identified the deficiency before the allegation was reported to NRC and initiated a
deficiency report in accordance with the site QA/QC program.
Prepour cleanup will be examined by NRC in future inspections.
No violations or deviations were identified.
Allegation According to an alleger, sheet metal is welded to seismic plates which are in contact with reinforcing steel in the northeast corner of the fuel handling building at the 236 elevation.
This could lead to damage of the reinforcement due to cathodic actio Discussion Seismic plates are imbedded and anchored in the concrete for the purpose of attaching equipment to the concrete walls.
The seismic plates are anchored in the concrete by steel bars welded in a vertical position to the backside of the plate.
These bars are attached to the reinforcing steel to hold the plates in position during the concrete pour.
The steel bars and reinforcing steel are similar metals and thus have limited potential for cathodic reaction.
Also, for a cathodic reaction to take place, moisture must be present.
Even if the materials were dissimilar, there would be little potential for a
cathodic reaction as their imbeddment in concrete would limit the presence of moisture.
The inspector examined the 236-elevation of the fuel handling building.
Observations showed that galvanized unistrut material is welded to seismic plates which in turn are in contact with reinforcing steel.
Electric conduit pull boxes are bolted to the unistrut material.
Observations and discussions revealed that the seismic plates are serving their intended function and that conditions do not exist which would cause a cathodic reaction that would harm the reinforcing steel.
Findings The allegation is partially correct as stated in that sheet metal is welded to seismic plates touching reinforcing bar.
However, the purpose of the seismic plates is to weld sheet metal hanger material to the plates and then attach equipment to the hanger material.
Condi-tions for an adverse cathodic reaction were not identified by the NRC inspector.
No violations or deviations were identified.
Al 1 egati on According to an alleger, installed electric motors in a series of small rooms on the 236-elevation in the reactor auxiliary building were not protected during sandblasting operations.
Discussions The NRC inspector examined the subject electric motors and discussed this concern with responsible engineers.
The licensee is aware of the problem and identified the problem in deficiency report number DDR 552 on April 1, 198 Findings The allegation 'is correct as stated.
Some electric motors were not properly protected during sandblasting operations on the 236-elevation in the reactor auxiliary buildings.
However, the licensee identified the problem in a deficiency repo} t before the allegation was reported to NRC and is taking corrective measures in accordance with the site QA/QC program.
No violations or devia'tions were identified.
k.
Allegation According to an alleger, waterproofing on the below grade portion of the turbine building was damaged and improperly repaired.
Discussion The turbine building foundation is a non-safety related structure and is not subject to the requirements of the site QA/QC program or the requirements of Appendix 8, Title 10 of the Code of Federal Regula-tions.
However, the NRC inspector examined the subject area and discussed the subject. concern with the Site Manager.
The Site Manager indicated he was present during the exc'avation and patching of the waterproof liner.
He stated small blisters of water had formed in the waterproofing membrane as a result of water in-leakage where the top of the membrane was exposed at the surface.
Normally, the membrane is surrounded by impervious backfill.
He stated that workmen were excavating the fill and exposing the blisters, cutting them to drain the water and then patching the cuts.
He stated the excavating and patching had proceeded to a depth such that the foundation of the adjacent transformer structure was indanger of being undermined and collapsing on the workmen.
Because of the unsafe conditions he ordered the workmen to cease the digging, blister draining and patching operation and to backfill the area.
He stated the small blisters contained only small amounts of moisture and were not detrimental to the membrane integrity or-foundation.
He felt that the, water blisters could be accepted rather than to continue with a digging operation that could have resulted in a serious accident.
Findings The allegation was correct as stated.
However, this allegation involved a non-safety related structure and the item of concern was witnessed by the Site Manager and handled in accordance with sound engineering judgement.
No violations or deviations were identifie.
Allegation According to an alleger improper rebar cadwelds have been made by several welders throughout the containment building.
Discussion The NRC inspector interviewed the four cadwelders working the second shift.
Discussions with the cadwelders disclosed that they were knowledgeable in cadwelding operations and requirements'he cad-welders all stated that they did not know of any improper cadwelding and had not heard anyone make comments regarding improper cadwelds.
Findings The NRC inspector was unable to sustantiate that any improper cadwelds have been made.
This allegation will be examined further in future NRC inspections.
No violations or deviations were identifie i O~