IR 05000400/1982028

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IE Insp Repts 50-400/82-28 & 50-401/82-28 on 820720-0820. Noncompliance Noted:Failure to Identify & Correct Nonconforming Welds on Seismic I Electrical Raceway
ML20027E444
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 09/03/1982
From: Burger C, Maxwell G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20027E438 List:
References
50-400-82-28, 50-401-82-28, NUDOCS 8211150323
Download: ML20027E444 (8)


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UNITED STATES o

NUCLEAR REGULATORY COMMISSION 8"

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REGION 11

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101 MARIETTA ST., N.W SUITE 3100

ATLANTA, GEORGIA 30303

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Report Nos. 50-400/82-28 and 50-401/82-28 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Shearon Harris Docket Nos. 50-400 and 50-401 License Nos. CPPR-158 and CPPR-159 Inspection at the Shearon Harris site near Raleigh, North Carolina Inspector:

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G. F. Max'well

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'Date Signed 9 /_? /M Approved by:

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C. W. Btfrger, Sectip(Chief, Division of Project

')Mte fighed and Resident Progrdms SUMMARY Inspection on July 20 - August 20, 1982 Areas Inspected This routine, announced inspection involved 105 inspector-hours on site in the areas of electrical - structural steel (Unit 1), fire retarding system (Unit 1),

Storage (Unit 1 and 2), welding (Unit 1), containment penetrations (Unit 1),

CP&L activities, and assistance to other RII personnel while inspecting concrete and electrical activities.

Results Of the seven areas inspected, no violations or deviations were identified in six areas; one violation was found in one area (Violation - Failure to identify and correct nonconforming conditions on electrical supports).

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DETAILS 1.

Persons Contacted Licensee Employees

  • R. M. Parsons, Project General Manager
  • G. L. Forehand, Director QA/QC
  • A. M. Lucas, Senior Resident Engineer
  • G. M. Simpson, Principal Construction Specialist
  • E. E. Willett, Resident Engineer Mechanical
  • B. Seyler, Principal Civil Engineer
  • D. C. Whitehead, QA Supervisor
  • R. Hunt, Specialist Material Control
  • H. D. Vernon, Specialist QA/QC Welding Other Organizations
  • W. D. Goodman, Daniel Construction Company, Project Manager
  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on August 20, 1982, 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 deviations. New unresolved item identified during this inspection are discussed in paragraphs 6.b., 8.c., and 9.b.(2).

5.

Electrical - Structural Steel - Unit 1(55053C,55063C,51053C,51063C)

a.

The inspector, while touring warehouse storage yard number 12, observed the as found condition of several stacks of seismic suppor " for I

electrical raceway components. During the evaluation the tollowing v.ere observed:

(1) On or about June 22, 1982, 800 seismic support items were received at the site by CP&L.

(2) The items were ordered by site personnel under Site Specification 025 Revision 6.

The site purchase order number is P.O. H-38378 and was awarded to a vendor identified as NES/SELAM C0.

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(3) The purchase order invoked a drawing identified as MPS-B-866 ' dated March 2, 1982.

(4) The items which were evaluated consisted of items which were identified as items 4, 5 and 6 in the purchase order.

(5) The 800 items were receipt inspected on or about June 28, 1982 by site CP&L QC personnel and were found to be acceptable. The inspector was informed that the receipt inspection required a statistical sampling, i.e.186 of the 800 items were inspected, including inspection of the welds on the items, and all 186 were found to be acceptable. Therefore, the remaining portion of the 800 items were considered acceptable.

(6) On August 18, 1982 the inspector requested that a site QC welding inspector measure the welds on five of the 800 accepted items.

The five which the inspector requested to be measured were

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selected from the top of items identified as item number 6 in the purchase order. As a result, the inspector was informed and observed that one of the two welds on each of the five were undersized and therefore nonconforming with the purcisaw order drawing (MPS-B-866) and AWS D1.1.

The drawing required the welds to be a flare level type with a 1/8" cap. The caps were measured and found to be about one-half the proper size. The improper size welds covered a distance greater than 10% of the 32 inch linear length of the welds.

b.

The inspector asked if the above nonconformances with the purchase order drawing were documented and evaluated prior to the above inspection. The inspector was not provided any information or documentation showing that the noncompliances had been identified and/or evaluated.

The inspector informed CP&L management that failure to identify shop welds which are not in accordance with the purchase order drawing is contrary to 10 CFR 50, Appendix B, Criterion XV as implemented by CP&L PSAR section 1.8.5.15 and CP&L Corporate QA Program section 15.1.3.

This is a violation, " Failure to identify and correct nonconforming conditions on electrical raceway supports," 400/82-28-01. This is a repeat violation, as similar conditions have been identified in Region II reports 400/81-25-01 and 400/82-05-01.

Except as noted, no other violations or deviations were identified in the areas inspected.

6.

Fire Retarding System - Unit 1 (55053C, 51063C)

a.

The inspector observed coatings personnel preparing to apply the Thermo-Lag material in selected areas of the cable spreading room, at i

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elevation 286' in the reactor auxiliary bailding. As a result of the observations and interviews, the inspector noted the following:

(1) Design Change Notice (DCN) numbered DCN 650-697-R5 was being utilized by site welding personnel to install the support system for the Thermo-Lag material.

(2) The installation of the Thermo-Lag was being inspected by CP&L coatings inspection personnel in accordance with construction procedure WP-45 and TP-43.

Procedure WP-45 and TP-43 are the procedures that the site utilizes for ANSI N101.4 service level II coatings.

(3) The inspector observei that the Thermo-Lag has been applied to electrical cable tray Seismic Category I supports which had not been previously inspected by the responsible CP&L electrical inspection personnel. The inspector was informed that special

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provisions would be required so that the thickness of the steel pieces could be verified in those cases where Thermo-Lag has already been applied to the Seismic Category I cable tray supports. The application of Thermo-Lag will be further evaluated during subsequent Region II inspections.

b.

The inspector requested to see the fire test results for the appli-caticn of Thermo-Lag at the Harris site. The inspector was informed by CP&L management that the Architect-Engineer, EBASCO, will provide the required proof tests for Thermo-Lag as it applies to its applications at the Harris site. This is an unresolved item, " ASTM E-119 proof testing of Thermo-Lag," 400/82-28-02.

During the above review, the following were referred to for requirements:

10CFR50, Appendix A; 10CFR50, Appendix R; IEEE-279; IEEE-384; FSAR Section 9.5; Construction Procedure WP-45, TP-43, and Design Change Notices DCN-560-162, DCN-650-742, 734, 724 and 697.

No violations or deviations were identified in the areas inspected.

7.

Storage - Units 1 and 2 (50073C)

a.

The inspector observed the stored condition of the reactor vessels and their internals for Units 1 and 2.

The storage conditions were evaluated to determine whether requirements are being met:

(1) Storage was in accordance with approved procedures.

(2) Seals and devices identify vessel internal atmospheric conditions.

(3) Condition of protective coating and/or covering was satisfactory.

(4) Use of dunnage or support prevent entry of dirt, water or flooding.

b.

The inspector observed the stored conditions of the piping spool pieces, steam generators and accumulators located in warehouse laydown a

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yards numbered 14 and 12. The storage areas were evaluated to determine whether requirements are being met:

(1) Piping, in general, was stored on dunnage. However, some isolated instances were found in yard 12 where about ten spool pieces were missing their end caps, and one instance in which a piece of tubular steel was not on dunnage. Upon notification, the responsible CP&L warehouse personnel required that the pipe caps be placed back on the piping, and returned the tubular steel to storage on dunnage.

(2) The safety injection accumulators and steam generators, for Unit 2 were found to be purged with protective gas to prevent corrosion.

During the above evaluations the following were referred to for require-merts: PSAR section 1.4; construction procedures WP-106, AP-XIII-05, PLD-002 and AP-XIII-07.

No violations or deviations were identified in the areas inspected.

8.

Welding - Unit 1(55083C)

a.

The inspector examined welding and cleaning activities described below relative to safety-related piping to determine whether applicable specifications and procedures were being met:

(1 Pipe spool 1-RH-31-1 observed cleanliness inspection (2 Pipe spool 1-RH-31-2 observed cleanliness inspection (3 Pipe spool 1-RH-31-3 observed cleanliness inspection (4) Pipe spool 1-CH-310-1 (observed cleanliness inspection)

(5) Pipe spool weld joint Cl-286-1-MS-80-FW-290 (observed pre-heat and fitup)

b.

The above observations included examination to determine if:

(1) Weld identification and location were as specified.

(2) Welding procedure specification assignment was in accordance with applicable code requirements.

(3) Welding techniques and sequences were specified and adhered to.

(4) Alignment of parts was as specified.

(5) Welding equipment was in good working order.

(6) Welding personnel were qualified.

(7) Weld history records were available and adequate.

(8) Cleanliness conditions were in accordance with the applicable construction procedure (WP-113).

c.

As a result of the above observations, interviews and procedural reviews, the inspector could not determine whether CP&L is in compliance with cleanliness requirements specified in ANSI N45.2.1.

Specifically, CP&L is classifying levels of cleanliness into two categories, Level I and Level II, instead of four levels that are J

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specified in the ANSI standard. The inspector was informed by CP&L supervision that USNRC's NRR group will be advised, in writing, of the alternate method being utilized by CP&L. Also, CP&L is allowing the final stage of cleanliness to be attained by procedures which the site start-up group has developed. The start-up cleanliness procedures were not made available for the inspector to review. The inspector informed CP&L that this is an unresolved item and will remain open pending:

(1) Review of the procedures which start-up plans to utilize for final system clean-up.

(2) Special cleanliness inspections which CP&L must pt form on systems which were installed and not maintained in a cleanliness level prior to the implementation of the procedure currently being utilized (WP-113).

(3) Confirmation, by Region II welding inspection personnel, that the CP&L alternate approach complies with ANSI N45.2.1.

This is an unresolved item, " Alternate cleanliness control of site piping systems," 400/82-28-03.

During the above observations the following documents were referred to:

ASME Boiler and Pressure Vessel Code section III and Construction Procedure CQC-19, CP-06, MP-08, MP-09, MP-10, and MP-10, and WP-113 and ANSI N45.2.1, and FSAR Section 1.8.

No violations or deviations were identified in the areas inspected.

9.

Containment Penetrations - Unit 1 (53053C)

a.

The inspector selected and evaluated the vendor documentation for the 9 foot personnel hatch penetration for Unit 1.

The penetration (serial number 31100) was purchased by EBASCO (the architect-engineer) under purchase order P. O. 435185-X67 to comply with specification CAR-SH-AS-1 revision 6, and ASME Section III, Subsection NE-4424, 1975 winter addenda. The supplier of the penetration was W. J. Woolley Co.

The documents indicated that the penetration was receipt inspected on or about August 14, 1979, and upon receipt was found to have some shop weld deficiencies. The shop weld deficiencies were documented on nonconformance reports numbered DDR-222, 290 and 299. The corrective action (CQC-2 reports) required that the vendor be more attentive to shop applied welds, in reference to DDR 290 and DDR 299.

b.

As a result of the evaluation, the inspector observed the following:

(1) A sitc CP&L field weld sheet, which was filed with the documenta-tion, erroneously showed that AWS D.1.1 had been utilized by receiving inspection personnel. This minor error was corrected by CP&L and the inspector was informed by those involved in the receipt inspection that ASME criteria had actually been utilized

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during the inspection of the sho welds, not AWS. The inspector has no further questions about is matter.

(2) There were several documents which indicated only the company name that had conducted the coating application, instead of the signature of the applicator who had applied the coatings to the penetration. The inspector could not, therefore, determine whether those who performed coatings applications were qualified.

This is an unresolved item, " Signature of coating applicators for containment penetrations," 400/82-28-04.

During the above observations, the following documents were referred to:

ASME Boiler and Pressure Vessel Code,Section III, and Construction Procedure CQC-19, MP-08, MP-09, MP-10, and WP-113, and ANSI N45.2.1, and FSAR Section 1.8.

No violations or deviations were identified in the areas inspected.

10. CP&L Activities - Units 1 and 2 (92706B)

a.

During this inspection pericd the office of Nuclear Reactor Regulation (NRR) visited the site on two separate occasions. The first visit was conducted on July 28, 1982 for the purpose of discussing with CP&L questions which NRR requested CP&L to respond to in reference to its organization for start-up and testing, and Chapter 14 of the FSAR.

The second meeting was held during the week of August 16, 1982 for the purpose of discussing instrumentation a.i control questions which NRR

.has submitted to CP&L for its response.

In general, these questions involve Chapter 7 of the FSAR.

b.

The inspector was informed on August 20, 1982 by CP&L management that CP&L is currently planning to return the internals which were purchased for Unit I reactor vessel to the warehouse storage area, and use in its place the reactor vessel internals for Unit 3.

The purpose of this exchange is to provide a reactor vessel internals for Unit I which has had certain modifications.

Either the resident inspector or other Region II personnel will evaluate further this exchange of reactor i

internal parts during subsequent inspections.

No violations or deviations were noted in the areas inspected.

11. Other Activities - Units 1 and 2 (51063C, 47053C)

l During This reporting period there were three independent inspections conducted by other personnel from Region II at the Harris site. One inspection was held during the week of July 26, 1982 which covered primarily soils and concrete activities; the other two inspections were conducted during the week of August 2,1982 and covered two basic areas, quality assurance and site electrical activities. The results of these inspections are documented in other Region II report r,

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The inspector participated in portions of those inspections ccnducted during the week of July 26, 1982, and portions of the electrical inspection conducted during the week of August 2,1982.

No violations or deviations were noted in the areas inspected.

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