IR 05000400/1982009
| ML20052C354 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/14/1982 |
| From: | Burger C, Maxwell G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20052C352 | List: |
| References | |
| 50-400-82-09, 50-400-82-9, 50-401-82-09, 50-401-82-9, NUDOCS 8205040696 | |
| Download: ML20052C354 (9) | |
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'o UNITED STATES
NUCLEAR REGULATOF.Y COMMISSION o
g a
REGION ll
@,8 101 MARlETTA 3T., N.W., SUITE 3100 o,
ATLANTA, GEORGIA 30303
Report flos. 50-400/82-09 and 50-401/82-09 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, t1C 27602 Facility flame: Sheatma Harris
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Docket flos. 50-400 and 50-401 License flos. CPPR-158 and CPPR-159 Inspection at SMar n Harris site 1 Raleigh, fiorth Carolina h#
M Inspector:<.
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G. F. flaxwell /
Date Signed O
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Approved by:
C. Burg'sr, Section ' Chief, Division of Date Signed Project and Resident Programs SUffiARY Inspection on February 20 - tiarch 20, 1982 Areas Inspected
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This routine inspection involved 112 resident inspector-hours on site in the areas of licensee action on previous inspection findings; 10 CFR50.55(e)
construction deficiency reporting; concrete; cadwelding; storage; fire protection; and independent inspection.
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Resul ts Of the seven areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted Licensee Employees
- R. ft. Parsons, Site !!anager
- N. J. Chiangi, fianager Engineering and Construction, QA/QC
- G.- L. Forehand, Director, QA/QC
- H. Lee Williams, Engineer
- J. F. Nevill, Engineer
- F. W. Taylor, QC Supervisor Other licensee employees contacted included 12 construction craftsmen, one security force member, and 28 office personnel.
- Attended exit interview 2.
Exit Interview
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The inspection scope and findings were summarized on flarch 19,1982, with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (400/82-02) " Documentary evidence that material and equipment conform to procurement requirements." Subsequent reviews of the information concerning the support columns for loop "A" reactor coolant pump casing have provided information to show that the columns were manufactured of materials sufficient to meet drawing and specification requirements.
This item is closed.
4.
Unresolved Items
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Unresolved items were not identified during this inspection.
5.
10 CFR 50.55(e), Construction Deficiency Reporting and Requests for Clarification of Information a.
The inspector selected eleven CP&L Deficiency and Disposition Reports (DDRs) and four CP&L Discrepancy Reports (DRs) and reviewed the status of these items. The purpose of the selection and review was to determine if CP&L is notifying the NRC of each deficiency found in design and construction, which, were it to have remained uncorrected, could have adversely affected the safety of operations of the plant at any time throughout the expected lifetime of the plant.
Further, the purpose is to determine if the deficiencies represent a significant breakdown in any portions of the QA program; a significant deficiency in final design; a significant deficiency in construction of, or significant damage to, a structure, system or component which will
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require extensive evaluation, extensive redesign or extensive repair; or deviation from perfonnance specifications which will require extensive evaluation, redesign or extensive repair. The evaluation covered a period of about eight months and included verification of
procedural adequacy and the implementation of the procedures as they related to 10CFR50.55(e).
During the inspection the following were referred to for requirements:
10CFd50.55(e),10CFR21, NRC guidance for 10CFR50.55(e), CP&L construction procedures AP-IX-16, CQC-2 and TP-17, b.
As a result of the review two areas of concern were identified.
This observation was made as the result of reviewing the status of two NRC open items which were identified previously as an unresolved item,
" Incomplete filled weld groove on RHR heat exchanger" (400/81-22-04),
and a violation " Failure to identify and correct nonconforming conditions on electrical cable tray supports" (400/81-25-01).
(1) The above noted unresolvcd item was identified by RII regional personnel on or about November 18, 1981 and was brougnt to the attention of CP&L management personnel during the NRC exit meeting on November 20, 1981. A review of the CP&L inspection records which resulted from the unresolved item revealed the following:
(a) The CP&L inspection reports are dated January 7,1982.
This date indicates that no formal evaluation was started by CP&L for at least forty-eight days after notification that a construction deficiency might exist on the safety-related heat exchangers.
(b) The information which was contained in the inspection reports dated January 7,1982 did not provide sufficient information to perform an adequate engineering evaluation of the welds on the heat exchangers.
For example, the reports only listed
visual welding defects and did not reference such things as weld sizes.
It was later observed by the NRC inspector that
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sufficient drawings or design requirements were not available for the CP&L QA welding inspectors to utilize while re-inspecting the welds on the RHR heat exchangers.
(c) On February 21 and 22,1982 the NRC inspector questioned why I
the RHR heat exchanger welds had not been documented by CP&L l
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QA for tracking potentially reportable construction deficiencies.
Subsequently, on February 26, 1982 CP&L documented some of the visual conditions of the RHR heat exchanger welds on a Deficiency and Disposition Report (DDR).
The DDR, numbered 843 was not written until approximately
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ninety-eight days after the RHR heat exchangers were reported to CP&L management by the NRC as potentially having defective vendor welds.
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(d) The CP&L procedure which is utilized for site processing of items in accordance with 10CFR50.55(e) and 10CFR21 is construction Procedure AP-IX-16.
Section 3.2 of AP-IX-16 requires a DDR to be issued against vendor products that are found to be in nonconformance due to fabrication.
The same
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Section of AP-IX-16 also requires that the resulting DDR be promptly reviewed and evaluated within fourteen days following the discovery of the item.
CP&L's failure to take prompt, thorough action in identifying the defective vendor welds has resulted in a condition not within the intent of 10CFR 50.55(e) as explained in an attachment to a letter sent to CP&L from the NRC, RII dated August 27, 1980. The title of the attachment is:
" Guidance - 10CFR50(e), Construction Deficiency Reporting," dated April 1, 1980.
RII personnel provided CP&L further explanations of the attachment to the above letter in a time-flow chart, dated October 31, 1980, which encourages promptness in identifying and documenting potentially reportable nonconforming conditions. This is an inspector followup item, (400/82-09-01) " Timely completion of DDRs".
(2) The violation (400/81-25-01) involved two instances whereby vendor welds on seismic I electrical cable tray supports were defective.
The NRC inspector identified only two defective vendor welds, which were observed during a routine inspection.
CP&L QA docu-mented the nonconformances on DDR 748, dated December 10, 1981.
The following conditions were observed as the result of the RII
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inspector's evaluation of DDR 748 and its resolution.
(a) DDR 748 identified only deficiencies pointed out by the RII inspector.
Therefore, the engineering evaluation of the
" safety significance" was very limited.
(b) The inspector was shown twenty other DDRs which have been i
written to document weld deficiencies with Seismic I cable tray supports, all supplied by the same vendor (Peden Steel).
The dates of these DDRs were August 4,1981 to date.
(c) Ten of the twenty DDRs including DDR 748 were evaluated as
"not reportable" under 10 CFR 50.55(e). The conditions in each instance were evaluated on an individual basis, not on a " generic" scale.
i (d) The inspector discussed with CP&L management his concern c
about the Peden Steel shop weld defects not receiving
" generic" attention. The inspector was assured that ir every instance where shop welds are undersized or have other visible nonconformances, the issues will be evaluated thoroughly.
The site CP&L QA/QC Director required DDR 858 to be written against Peden Steel, identifying shop weld defects
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on a generic basis. The inspector has no further questions about this matter at this time.
This is an inspector follow-up item, " Evaluation of shop welds supplied by Peden Steel" 400/82-09-02.
c.
The inspector selected and evaluated fifty documents which were utilized by CP&L QA personnel during the last year for getting clarifications on potentially nonconforming conditions. The evaluation was made to detemine if the appliable procedure was being followed (construction procedure AP-IX-04); if the reference documents were sufficient; if the description of the condition was adequate; if the inquiry was sufficient to detennine exactly what information was needed and if the responses to the requests were adequate.
In twenty Request for Clarification of Information (RCIs) documents, the inspector reviewed the documents or work conditions about which the RCIs were written.
In all cases, with one exception, the response was adequate. The noted exception concerns RCI-H-140, which was initially written by CP&L QA welding inspection personnel.
The RCI, dated June 1, 1981, questioned instances where fillet welds attach two separate support members to a common member. The inquiry described conditions of the welds in which the toe of the separate welds make contact or the welds overlap each other, appearing to be almost entirely fused into one weld.
The fused welds caused the weld to lose its identity as two separate fillet welds thereby causing two other concerns of how can the welding inspector inspect the fillet welds for correct size if they are fused together, and what effect will the fused welds have on the strengths which would normally be expected, as they now share weld metal (fastening capabilities) rather tMn represent two separate full-size fillet welds.
The concern where the tce of the separate welds are touching each other is, if the toe of the welds are touching, what happens to the fastening abilities of the welds if force (seismic or otherwise) is simulataneously applied to both of the members that are attached to the common member.
The inspector checked two installed heating, ventilation air conditioning (HVAC) seismic supports which share common vertical supports which are also utilized to support seismic electrical cable tray members. The inspector observed one instance where the vendor-applied fillet welds on the separate members fused together.
The inquiry conditions listed in RCI-140 and the condition found by the inspector were discussed in detail with the CP&L Senior Resident Engineer and the responsible CP&L QA supervisor. As a result of the
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discussions these conditions were found satisfactory and the inspector j
has no further questions about the seismic hanger in question.
However, it was observed that an adjacent hanger which had common members of support did not have its shop welds applied in the locations prescribed on the applicable drawing. The hanger CD2309 frame 9B1, located about elevation 245' Unit 1 reactor auxiliary common building, does not have required shop welds shown in section "AA" of design drawing number 1364-14204 revision 2.
The inspector was informed, by CP&L management, on itarch 18, 1982 that the nonconforming shop weld would be documented on a nonconformance report DDR 859.
This is an inspector follow-up item, " Shop Welds on Common HVAC and Electrical Vertical Supports, "400/82-09-03.
Except as noted, no violations or deviations were identified in the areas inspected.
6.
Concrete and Cadwelding - Unit 1 a.
The inspector observed portions of concrete placements being made in Unit 1 fuel handling building (pours numbered 1FHIW292001 and 1FHXW310017) and pour numbered 1ACIW322003C in the reactor auxiliary comon building. The above observations included:
(1) The condition of the concrete forms was inspected for cleanliness, level and tightness.
(2) Concrete placement activities were inspected as they pertained to delivery time, rate of rise, free fall and testing of the concrete at the point of delivery and consolidation.
(3)
Construction inspection personnel were present to assure compliance with the specification anc' procedural requirements.
(4) Suitable weather protection was provided, as applicable.
b.
While observing concrete pour numbered 1FHXW310017, the inspector observed concrete defects at four locations adjacent to the spent fuel pool embedded angle iron.
The defects are associated with previously placed concrete, pours numbered 1FHIW286004, 1FHIW286005 and 1FHIW286006.. An evaluation was made by site engineering and it was determined that the defects were caused by concrete which had cracked initially due to foaming under the edge of the angle iron during placement. Once the cracks had started, freeze-thaw and inclement weather allowed the cracks to widen to a point where the embeds (Nelson studs which were attached to the angle iron) lost their holding
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abilities in at least two places.
The inspector discussed the above observations with CP&L management.
As a result, the inspector was infomed that construction had been aware of the cracking problems since December 11, 1981 and further, that a nonconformance report (DR) would be written to document the unsatisfactory conditions. Prior to the NRC exit meeting the inspector was given a copy of a DR numbered DR-C-1475 which identifies the
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concern and will assure that it is corrected.
The inspector has no further questions about this matter at this time.
c.
The inspector observed the in-process requalification tests being administered by the responsible CP&L QC personnel to two reinforcing steel cadwelders.
The tests were both in the diagonal positions utilizing number 18 nuclear grade reinforcing steel.
d.
The inspector evaluated the curing logs associated with the last three concrete placements which were made on Unit 1 containment exterior walls (pours numbered 1CBXW37600', 1CBXW376002 and 1CBXW366001).
The inspector observed that pour number 1CBXW376001, while curing, fell below the minimum curing temperature requirements (50 F).
The temperature fell to a low of 43 F and resulted in the required curing time being extended for another full day.
Personnel were questioned and as a result, there were no indications that the concrete reached the freezing point.
The following were referenced during the above observations:
PSAR section 1.4,1.8; design specification CAR-SH-CH-6; construction procedures WP-01, WP-05, WP-15, CQA-6, TP-15 and TP-17.
No violations or deviations were identified in the areas inspected.
Storage - Units 1 and 2 a.
The inspector observed the stored conditions of Units 1 and 2 reactor vessels and Unit 2 steam generators.
The storage conditions were evaluated to determine whether requirements are being met as follows:
(1) The vessels and steam generators were stored in accordance with the procedural requirements.
(2) The protective coatings on the vessels and steam generators were intact.
(3) The supports for the vessels and steam generators were adequate to prevent excessive dirt or water from accumulating in or around them.
(4) The supports for the vessels and steam generators were adequate to prevent shifting or collapse of the support structures.
The inspector, accompanied by(yards numbered 12 and 14).
b.
responsible CP&L QA personnel, toured the outside piping laydown yards During the tours the stored conditions of the piping were evaluated to determine whether requirements are being met as follows:
(1) Piping in general, with five exceptions, were stored off the ground to prevent entry of dirt into them and/or contamination
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from environmental conditions.
CP&L took immediate corrective action to place five spool pieces back on adequate supports.
(2) The piping storage areas were identified sufficiently to provided identity and location as required by those who may be seeking the location of certain spool pieces.
(3) The drainage, in general, was acceptable in areas where the piping spool pieces were stored.
(4) Access was adequate for placement or removal of the spool pieces.
(5) Soma small bore spool pieces (non-nuclear) showed signs of abusive handling 1.e., they were bent.
The inspector saw three instances of this condition. This condition is isolated to yard number 14 and it involves only non-nuclear, non-safety related spool pieces.
The inspector has no further questions about this matter.
Yard 14 is estimated to cover an area of about ten acres where both safety-related and non-safety related pipe spool pieces are stored.
(6) Several spool pieces were capped with wooden caps which are not water tight. They allowed water to collect inside the spool pieces contrary to good storage practices.
CP&L took immediate corrective action to correct these conditions.
During the observations and evaluations the following were referred to:
PSAR section 1.4, construction procedures WP-106, AP-XIII-05, PGD-002 and AP-XIII-07.
No violations or deviations were identified, in the areas inspected.
8.
Fire Protection Units 1 and 2 a.
The inspector evaluated the condition of the site as it relates to practices and implementation of the fire protection and prevention procedures and requirements. The following areas were evaluated:
(1) Burning operations inside Unit 1 containment building were observed.
In each instance the inspector observed that qualified fire watches, with fire extinguishers were posted to. prevent a fire from starting. Also, adequate fire covers were provided below the areas of the burning activity to prevent burning metal
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from damaging adjacent equipment.
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(2) The inspector reviewed the fire protection equipment inspection
records which cover the last four months.
The records indicate
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that the required inspections for fire hose houses, portable fire extinguishers and sprinkler systems have been conducted as
prescribed in construction procedure AP-VII-05.
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(3) At twenty strategic locations portable fire extinguishers were checked and found to be adequately charged and in useable condition.
(4) The inspector did not observed any instances whereby wood scaffolding, form work or other combustible materials were stored such that their locations or conditions constituted a potential fire hazard, b.
- The inspector visited the fire pond and observed that the fire pumps are cycling as needed.
Further, the pond contains at least four million, eight hundred thousand gallons of water which could be utilized to fight a fire at the site location.
The inspector checked the contents of one of the nine fire hose house and found it to contain the equipment listed in construction procedure AP-VII-05.
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The inspector evaluated the content of the site ambulance and found it to contain sufficient major emergency equipment for treating burns which may result from a site fire.
No violations or deviations were identified in the areas inspected.
9.
Other Areas Inspected - Units 1 and 2 The inspector assisted another RII inspector during a site inspection concerning weld inspections by one CP&L QA welding inspector. The results of the inspection are documented in RII report nu'mbered 400,401/82-06.
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