IR 05000400/1982019

IE Insp Repts 50-400/82-19 & 50-401/82-19 on 820614-17.No Noncompliance Noted.Major Areas Inspected:Ie Bulletins,Qa Manual & Implementing Procedures for RCPB & safety-related Piping & Components & Licensee Action on Previous Findings

ML20062J451
Person / Time
Site:	Harris
Issue date:	07/08/1982
From:	Economos N, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20062J437	List: IR 05000400/1982019 ML20062J434
References
50-400-82-19, 50-401-82-19, IEB-80-21, NUDOCS 8208160371
Download: ML20062J451 (10)

Text

1. UNITED STATES 8 4*f, NUCLEAR REGULATORY COMMISSION t a REGION il 101 MARIETT A ST., N.W., SUITE 3100 s ATLANTA, GEORGIA 3o303

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s Report Nos. 50-400/82-19 and 50-401/82-19 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Harri s Docket Nos. 50-400 and 50-401, License Nos. CPPR-158 and CPPR-159 Inspection at Harris site near Raleigh, Inspector: A E. H. Girard 7 -

Date Signed Approved' by: Mhmzw N. Econ'omoh Abting Section Chief

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,0ats Signed Engineering Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on June 14-17, 1982 Areas Inspected This routine, unannounced inspection involved 30 inspector-hours on site in the areas of licensee action on previous inspection findings (Unit 1), status of IE Bulletins (Units 1 and 2), quality assurance manual (Units 1 and 2), quality assurance implementing procedures for reactor coolant pressure boundary and other safety-related piping (Units I and 2), and quality assurance implementing procedures for safety-related components (Units 1 and 2).

Results No violations or deviations were identified.

8208160371 820719 PDR ADOCK 05000400 G PDR

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! REPORT DETAILS j

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j Persons Contacted Licensee Employees

R. M. Parsons , Site Manager

• G. L. Forehand, Director QA/QC l *A. M. Lucas, Senior Resident Engineer

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• D. C. Whitehead, QA Supervisor A. H. Hall, Lead Auditor

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K. Douglas, QA/QA Tech 1 J. Harold, QA Inpsector i E. Betz, Senior QA Specialist, NDE NRC Resident Inspector

• G. F. Maxwell i

* Attended exit interview i

l Exit Interview i

. The inspection scope and findings were summarized on June 18, 1982, with t those persons indicated in paragraph I above. The inspector's findings were presented by the NRC resident inspector. The following item, identified as

) a result of this inspection, was described during the interview:

) (0 pen) Inspector Follow-up Item (400/82-19-01): Qualifications of Auditors,

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paragraph 6.

f Licensee Action on Previous Inspection Findings

{ (Closed) Unresolved Item (400/81-07-01): Audit !

!' This item was previously opened to address the inspector's concern that the licensee's audits appeared to be directed entirely towards records

! rather than work and, therefore, they did not appear to adequately I address the proficiency of personnel in the peformance of special

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processe In the current inspection the inspector reviewed the checklists used by the licensee for performance of audits QAA 81-16 (May 1981). QAA 170-7 (January 1982) and QAA 170-8 (February 1982). In reviewing these audits the inspector found that actual work and work performance had been examined, including that of personnel performing certain special processes. The inspector considers this item close .

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4. Unresolved Items j Unresolved items were not identified during this inspection.

5. Status of IE Bulletins (IEB's).(Units 1 and 2)

(Closed) IEB 400, 401/80-80-21: Valve Yokes Supplied by Malcolm Foundry

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Company, Inc.

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! The licensee submitted the initial response to this bulletin in a letter dated January 5, 1981. The response indicated that they had in storage for-installation in Units 1 and 2, four active safety-related valves containing yokes manufactured by Malcolm Foundry. In addition, the letter stated that

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they had 40 active safety-related valves with hand wheels manufactured by Malcolm Foundr j The inspector discussed this item with the QA Supervisor and reviewed the i licensee's actions relative to the item as documented in their Deficiency (

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and Disposition Report (DDR) 516 and their Corrective Action Report (CAR)

12-1-81. The disposition reported and verified in the documentation was to

replace the yokes manufactured by Malcolm Foundry with acceptable yoke *

The CAR documented verification of yoke replacement on 11/23/81. Replace-j ment of hand wheels manufactured by Malcolm Foundry was deamed unnecessary i

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by the license Based on his review, the inspector considers this item closed.

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6. Review of QA Manual (Units 1 and 2)

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As referred to in the title above, the licensee's "QA Manual" is considered

! to be the aggregate collection of QA and QC related instructions, proce-

dures, plans and schedules which are used to implement the QA program described in the facility SA The inspector reviewed the licensee's "QA

] Manual" to verify that instructions, procedures, plans and schedules, had ,

j been established to control and accomplish selected safety-related activi- ,

ties in accordance with the approved QA program. The inspector's review was .

limited to activities for reactor coolant pressure boundary and other l

! safety-related components and pipina being installed at the Harris facility '

! by contractor Daniel Construction Compan The specific activities addressed by the inspector in his review and the related QA program imple-menting documents established by the licensee to accomplish and control i

, these activities are as follows:  :

I Activities

(1) Organizational structure and QA personnel i (2) Audits

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(3) Quality requirements (specified, reviewed, controlled documented, i records maintained, identification, and control of items included) .

(4) Work and quality inspection procedures '

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(5) Control of material i

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(6) Control of processes (7) Corrective action (8) Document review (9) Test control and control of test equipment (10) Quality records Implementing Documents for Above Activities (1) Corporate Quality Assurance Program, Revision 3 (2) Corporate Quality Assurance Department, Engineering and Con-struction Quality Assurance / Quality Control Section (a) QA Instructions Number Title Revision QAI- QA/QC Personnal Qualification Requirements 8 QAI-12.1 Mechanical Installation Monitoring Guide for Safety-Related Piping, Valves & Components 0 QAI-12.2 Mechanical Installation Monitoring Guide for Safety-Related (Seismic Class I) Pipe Hangers 0 QAI-12.3 Mechanical Installation Monitoring Guide for Installation Mechanical Equipment & Components 1 (b) QA Procedures Number Title Revision COA-1 Personnel Training and Qualification 9 CQA-2 QA Document Control 2 CQA-4 QA Records O CQA-5 Document Reviews 0 CQA-8 Material Issue Surveillance O CQA-12 Mechanical Equipment Installation Monitoring 0 COA-21 Storage Control Surveillance O COA-24 Procurement Control 1

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CQA-26 Hoisting and Lifting Equipment Surveillance 0 (c) QC Procedures Number Title Revision CQC-1 Tool and Measuring Device Control 1 CQC-2 Nonconformance Control 4 CQC-6 Receiving Inspection 0 CQC-7 Marking and Tagging 0 CQC-12 Inspection of Code Valve Installation, Disassembly and Assembly 2 CQC-22 Hydrostatic Test Inspections 2-(3) EBASCO Specification - General Power Piping, CAR-SH-M-30 R14 (4) Site Specification 30 R6, Field Fabrication and Erection of Power Piping (5) Site Specification 34 R8, Nondestructive Examination, Visual Inspection and Testing Requirements for Code Class 1, 2, 3, MC, Seismic and Non Seismic Structure (6) Construction Procedures Manual Administrative Procedures Number Title Revision AP-IV-03 Preparation Approval Control of Procedures 28 AP-IX-02 Document Distribution and Control 15 AP-IX-05 Field Change Request (FCR) 25 AP-IX-06 Handling of Nonconformances 12 AP-IX-10 Specification for Site Procurement Use 17 AP-IX-16 SHNPP Site Processing of Deficiencies in Accordance with 10CFR50.55(e) and 10CFR21 3 AP-XIII-02 Material and Equipment Receiving 3

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-AP-XIII-03 Receiving Identification and Inspection 11 AP-XIII-04 Receiving Discrepancy 4 AP-XIII-05 Material Storage 11 AP-XIII-06 Receiving Reports and Documentation 2 AP-XIII-07 In-Storage Inspections and Maintenance 14 AP-XIII-08 Material Issue 10 (7) Construction Procedures Manual (a) Technical Procedures Number Title Revision TP-04 Calibration of Controlled Tools 18 TP-17 Construction Inspection Non Conformance Control 7 TP-24 Mechanical Pipe Installation Inspection 6 TP-28 Inspection of Equipment Installation 5 TP-45 Inspection of the Installation and Repair of Valves and Speciality Items' 0 TP-53 Inspection of Piping Flanged Connections 0 (b) Work Procedures Number Title Revision WP-102 Installation of Piping 8

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WP-106 Maintenance / Protection of Permanent Plant Equipment 8 i

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WP-115 Hydrostatic Testing of Buried or Embedded Pressure Piping (Nuclear Safety Related) 3

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WP-116 Piping Spool Fabrication and Modification 3

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WP-128 Installation and Repair of Valves and Speciality Items 0

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WP-6 Inspection and Testing of Hoisting Equipment Rigging Used in WP-7 4

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WP-21 Inspection of Equipment and Rigging for General Lifting 4 (8) Corporate QA Department Nondestructive Examination Manual (9) Corporate Quality Assurance Department Quality Assurance Procedure Manual In examining the licensee's qualification requirements for auditors, as described in the Corporate Quality Assurance Department Quality Assurance Procedure Manual (procedure CQAS 80-2 RO), the inspector found that the requirements were general in nature. The inspector was concerned that the lack of detail might lead to the use of auditors without adequate knowledge of areas being audited, particularly in the area of special processes. The inspector informed the licensee that the qualifications of auditors would be examined further in a subsequent inspection. This concern was identified as inspector follow-up item 400/82-19-01, " Qualifications of Auditors".

Within the areas inspected no violations or deviations were identifie . Reactor Coolant Pressure Boundary (RCPB) and Other Safety-Related (SR)

Piping - Review of Quality Assurance Implementing Procedures (Units 1 and 2).

The inspector reviewed the licensee's QA related procedures and instructions applicable to RCPB and other SR piping activities (except welding) to determine whether they adequately established and implemented requirements and controls in comformance with the QA program described in the SAR. The code applicable to on site fabrication of this piping is ASME Section III (74W76). Earlier revisions of ASME Section III apply to procured piping material and fabrication, as stated in the SA The control and requirement areas that were addressed by the NRC inspector,.

and the procedures and instructions identified and reviewed relative to these areas are as follows: Control and Requirement Areas (1) Procurement (2) Receiving inspection (3) Storage and issue (4) Handling - including protection from damage and contamination (5) Inspection and work in installation of piping and appurtenances (6) Cleaning Procedures and Instructions (1) Corporate Quality Assurance Program, Revision 3 (2) Admistrative procedures i

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Number Title Revision

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AP-XII-01 The Requisitioning of Materials I

& Equipment 20

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AP-XII-03 Receiving Identification and j Inspection 11 i

l AP-XII-05 Material Storage 11 l (3) General Power Piping (4) Site Specification 30 R6, Field Fabrication and Erection of Power

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Piping

! (5) Site Specification 34 R8, Nondestructive Requirements for Code Class 1, 2, 3. MC, Seismic and Non Seismic Structures I (6) Work procedures l Number Title Revision WP-102 Installation of Piping 8

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WP-106 Maintenance / Protection of Permanent

! Plant Equipment 8

! WP-112 Control of Materials and Equipment That

{ May Be Harmful to Stainless Steel 2

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j WP-113 Cleaning and Cleanliness Maintenance of

ASME SECTION III and all other Piping I Systems 4

WP-115 Hydrostatic Testing of Buried or Embedded Pressure Piping 3 WP-116 Piping Spool Fabrication and Modification 3 WP-129 Bolt Torquing for In-Line Power Piping Flanged Connections 2 (7) Technical procedure TP-24 R6 Mechanical Pipe Installation In-spection (8) Quality control procedures Number Title Revision CQC-6 Receiving Inspection 0 CQC-10 Cleanliness Control of Fluid Systems and Components 2 CQC-22 Hydrostatic Test Inspections 2

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! (9) Quality assurance procedures  !

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Number Title Revision

CQA-8 Material Issue Surveillance 0 ,

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! CQA-21 Storage Control Surveillance 0

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Within the areas inspected, no violations or deviations were identified.

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! Safety-Related Components-Review of Quality Assurance Implementing Proce-  !

dures (Units 1 and 2)

The inspector reviewed the licensee's QA related procedures and instructions i applicable to on-site activites for safety-related components to determine

whether they adequately established and implemented requirements and con-  ;

trols in conformance with the QA program described in the SAR. The proce-dures and instructions reviewed were limited to those covering work per-formed - by contractor Daniel Construction Compan The code applicable to this work is ASME Section III (74W76). [

The requirement and control areas addressed by the NRC inspector and the  ;

procedures and instructions identified and reviewed relative to these areas-were as follows: ,

! Control and Requirement Areas i

(1) Receipt inspection

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(2) Installation - including inspection and testing I (3) Lifting

(4) Post installation cleaning, preservation and inspection Procedures and Instructions (1) Quality control procedure CQC-6 RO, Receiving Inspection i

(2) Quality Assurance procedure CQA-12 R0, Mechanical Equipment .

Installation Monitoring  !

(3) Technical procedures l Number Title Revision ,

j TP-28 Inspection of Equipment Installation 5 i  ?

TP-45 Inspection of the Installation and Repair  !

of Valves and Specialty Items 0 ( i l (4) Work procedures l

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Number Title Revision WP-6 Inspection and Testing of Hoisting and Rigging Equipment Used in WP-7 4 WP-105 Installation of Equipment 6 WP-113 Cleaning and Cleanliness Maintenance of ASME Section III and all other Piping Systems 4 WP-125 Polar Crane Settings 1 WP-128 Installation and Repair of Valves and

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Specialty Items 0 WP-131 Setting Reactor Coolant Pumps 1 Within the areas inspected, no violations or deviations were identified.