IR 05000400/1984041
| ML20151K950 | |
| Person / Time | |
|---|---|
| Site: | Harris, 05000000 |
| Issue date: | 06/19/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20151J031 | List: |
| References | |
| FOIA-87-866 NUDOCS 8506260336 | |
| Download: ML20151K950 (11) | |
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. . . O JUN ! 91985 MEMORANDUM FOR: R. D. Walker, Director Division of Reactor Projects, Region 11 FROM: J. G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement SUBJECT: ASSESSMENT OF IMPLEMENTATION OF THE NRC INSPECTION PROGRAM j BY REGION 11 AT SHEARON HARRIS NUCLEAR POWER PLANT , i The Office of Inspection and Enforcement described to the Commission in ' SECY-82-150A the assessment of the implementation of the NRC inspection program in corjunction with Construction Appraisal Team (CAT) inspections.
Accord-ingly, we have examined Region ll's implementation of the construction inspec-tion program based on the October-November 1984 CAT inspection at Shearo'n Harris.
The results of the inspection were documented in Inspection Report 50-400/84-41 dated December 24, 1984.
The enclosure to this memorandum docu-ments the results of our assessment of the construction inspection program implementation.
In our review of the region's followup to previous CAT inspection findings it appears that there has been an unnecessary duplication of efforts.
Such ef forts can be better utilized for direct followup and review of corrective actions.
J. G. Partlow, Director Division of Inspection Programs Of fice of Inspection and Enforcement Enclosure: Assessment cc: J. Taylor, IE Distribution 0C5-016 7 RCBP R/F 01 R/F HWong . H a h D 050 " S A" RHeishman [[ A/6 & ! RCFEI:01: IE RCPB I:IE RCPB: 01: IE RCPB:01:IE
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/ . . ' ' REGIONAL CONSTRUCTION INSPECTION PROGRAM ASSESSMENT ~ ' . SHEARON HARRIS (R II) ' , I.
SCOPE A Construction Appraisal Team (CAT) inspection was conducted at the ! Shearon Harris Nuclear Power Plant of the Carolina Power and Light Company during the period October 112 and October 22 November 2,
1984. While the predominant effort of the inspection team was devoted to the hardware inspection, the team also evaluated the control of design chanaas and corrective actions.
In addition, an examination was made of proje ; construction controls, h The purpose of this assessment is to evaluate the implementation by Region !! of the Construction Inspection Progras.
A further purpose of the assessment is to make recommendations, if necessary, to teprove the inspection program so that a comprehensive review of the licensee's construction activities is covered by the Construction Inspection Program.
!!. ASSESSMENT ACTIVITIES A review was made of Region ll's inspection reports, sal.P reports and - enforcement items of the Shearon Harris facility to identify those deficiencies that were previously identified by Region 11 inspectors.
The inspection reports of 1975-1984,1982 and 1983 SAtP reports, open items and violations were reviewed.
The Executive Summary and Potential Enforcement Actions of the Shenron Harris CAT inspection report (50 400/84 41) are provided as Appendix A and Appendix B.
l l The inspection reports for 1983 and the 766 inspection data were analyzed ' and it was determined that approximately 3280 man hours of direct inspection effort were performed by Region 11 at Shearon Harris in 1983.
The analysis of the reports and computer data indicated that the construction inspection program was approximately 85 percent complete at the start of the CAT inspection.
The total man hours and percent completion is comparable to other construction sites and Regional totals for the construction status of the Shearon Harris construction ef fort.
111. INSPECTION FINDlHGS A.
Electrical and Instrumentation Construction 1.
CAT Findings . It was identified that some documents in the area of electrical l
separation for raceways deviate f rom FSAR commitments.
As a result, installations exist in which the required separation has not been maintained between non Class 1E and Class 1E raceway components.
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Humerous deficiencies were identified in non seismic raceway . supports.
Their possible failure could adversely affeet nearby Class IE electrical components.
. 2.
Assessment i The area of electrical separation has been found by the NRC CAT
inspection program to be a source of problems for most construction sites.
The problems are caused by differing interpretations of codes and standards by the NRC, architect engineers, and utilities.
The Region !! office had previously idt.itified a generic concern for
non sellaic raceway support insta11st'.ons in inspection Report 50 400/82 24 and updated in Report W 400/8417.
The CAT findings provided additional details of hardware deficiencies.
3.
Recommendation The NRC CAT findings at Shearon Harris and other facilities show
that utilities and NRC personnel are having problems properly inter-preting the requirements for electrical separation.
IE has recently issued Information Notice No. 8511 to summarize the problems identi-fled by the NR0 CAT program in this area.
IE will evaluate the need for additional inspection guidance in the
area of non seismic components which may adversely affect nearby equipment components.
, B.
Mechanical Construction > 1.
CAT Findings Deficiencies were identified in the applicant's program to effec-
tively identify and resolve hardware clearance problems in the areas of piping and HVAC.
, A prograeviatic concern was noted in the area of a lack of timely
verification of piping and pipe support location to original require-ments.
, Discrepancies were identified in the area of mechanical equipment
fasteners and connections.
i Deficiencies were identified in the required wall thicknesses for
fleid purchased piping.
. 2.
Assessment The area of hardware clearance problems has been found by the NRC .
' CAT program to be one activity often left to be accomplithed late in the construction phase.
1E inspection procedures do not address this problem.
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IE inspection procedures are considered adequate in the area of the review of procedures to cover pipe and pipe support location verifi-cation.
Several Region II inspections have been performed in the , piping and support area and open items were issued concerning several ' aspects; however, the timing of the location verification was not addressed.
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IE inspection procedures are considered adequate in the area of mechanical equipment mounting connections.
A similar deficiency was identified by Region II inspectors (Inspection Report 8313) concerning thread engagement of an anchor bolt nut for a pump.
However, it appears that additional regional attention is necessary in this area.
N The deficiencies in pipe wall thickness for field purchased piping
was brought to the NRC CAT inspectors attention based on findings developed in the IE Vendor Inspection program.
The findings identi-fled at Shearon Harris were provided to the Vendor Program Branch.
3.
Recommendations Of the four NRC CAT findings in the mechanical area, two areas are adequately covered in the IE Inspection program, if properly . implemented.
In the other two areas, IE will evaluate the inclusion of provisions in the IE inspection program to review the utility's program for control of interferences and clearances and the IE Vendor Program Branch is considering the issuance of an Information Notice regarding the pipe wall thickness problem.
C.
Welding NDE 1.
CM Findings A number of examples were identified in which nozzle to shell welds
did not meet design requirements for vendor supplied tanks.
Several radiographic flim quality def!ciencies were identified.
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Assessment The deficiencies in tank welds and radiographic film quality are mostly associated with vendor (off-site) supplied components.
These vendor problems are recurring ones at nuclear construction sites.
3.
Recommendations The recurring problems in vendor tank welding and vendor film quality
will be brought to the attention of the IE Vendor Program Branch for , their evaluation.
IE has issued an Information Notice regarding nozzle to shell welds in vendor supplied tanks.
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Civil and Structural Construction 1.
CAT Findings Three areas were identified where concrete reinforcing steel had not
been placed in accordance with design drawings.
In two areas there was uncertainty among site personnel as to the actual design requirements.
An area of improperly consolidated concrete was identified in one
beam.
Concrete expansion anchor bolts for non-seismic electrical system components were found not to have the minimum embedment depth assumed in analyses.
2.
Assessment Of the three cases of improperly placed reinforcing steel, one case involved missing reinforcing steel and the other two were cases of mispositioned reinforcing steel.
The missing reinforcing steel incident is similar to occurrences identified by the applicant in 1979 and 1980 and for which a meeting in the Region II office was held.
The applicant's corrective actions, implemented in 1980 to ensure responsible personnel understand the design drawing requirements, do not appear to have been fully effective.
In two of the areas, the concrete had been placed af ter 1980.
The current IE inspection procedures are adequate to cover this area if properly implemented.
The one area of improperly consolidated concrete occurred in a location which is fairly inaccessible.
This finding is considered to be of a relatively limited nature.
The current IE inspection procedures are adequate to cover this area.
The finding concerning the concrete expansion anchor bolts is
related to the finding regarding non-seismic raceway supports discussed in II.A.
3.
Recommendations Although there is little concrete work remaining to be performed, there should be consideration of additional Regional attention in the area of reinforcing steel placement.
Current IE inspections procedures are adequate.
E.
Material Traceability and Controls 1.
CAT Findings Problems were identified regarding the traceability of fastener materials.
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Assessment This finding had been previously identified by both the Region !! office and the applicant.
3.
Recommendations Problems in the traceability of f asteners have been identified by the NRC CAT program at several sites.
At the present time, IE inspection procedures address material traceability only in each , technical discipline.
Current procedures do not exist to cover the ' programmatic control for material traceability.
IE will evaluate the need for additional inspection guidance in this area.
F.
Design Change Control 1.
CAT Findings Some design documents were identified which have a large number of
unincorporated design changes.
For'some field design changes, analyses and other backup documenta- = ' tion were not maintained as QA records, - 2.
Assessment
Although the high number of unincorporated design changes created few hardware deficiencies, there is a significant potential for problems to occur in installation and inspection activities.
There had been previous discussions between the Region !! office and applicant in this area.
Current IE inspection procedures are adequate in this area.
' The case of background documents to field design changes not being - being maintained as QA records is an isolated incident and deals ' with a minor aspect of the overall design change area.
The applicant will review their current procedures and make appropriate . changes.
The IE inspection procedures are adequate in this area.
3.
Recommendations
The Region 11 office should continue to closely monitor work activities involving large numbers of unincorporated changes to i ensure work is being performed to all the latest drawings and revisions.
- The IE inspection procedures are adequate in the design change
control area.
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Corrective Actions Systems 1.
CAT Findings Audits in the welding and nondestructive examination area lacked sufficient scope and quality.
2.
Assestment Current IE inspection proceduras cover the general area of QA audits, but do not specifically require a review of welding or nondestructive examination audits.
In addition, the review in the audit area was directed by HRC CAT efforts in the welding area.
The applicant has stated that improvements are planned in this area.
3.
Recommendation Current IE inspection procedures are adequate.
As few actual hardware deficiencies were identified in the welding area, no extra monitoring of the applicant's activities are recommended llcant.
except as normal followup to corrective actions planned by the app IV. OVERAll ASSESSMENT CONCLU$!0NS The implementation of the Construction Program inspection procedures at the Shearon Harris site was satisfactory.
Of the 14 CAT findings identi-fled previously five were sinitar in substance to items identified previously by Re,gion !! Inspections. Of these 14 CAT findings, eight are adequately covered in the Construction Inspection progran procedures, three are not, and three are considered to be in the area of the Vendor ' Program, it appears that additional regional attention is required in the areas of mechanical equipment foundation connections and concrete rein-forcing steel placement.
Areas have been identified for evaluation by the Reactor Construction Prograss Branch and Vendor Program Branch for pos-sible inclusion in the current inspection procedures, ' i >
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APPENDIX A DECUTIVESU!HARY An announced Construction Appraisal Team (CAT) inspection was conducted at the Shoaron Harris site during the period October 112 and October 72 = Kovtirtber 2, 1984 Overall Conclusions s, Itardware and documentation for piping, pipe supports / restraints, HVAC, structural stool (including wolding and nondestructive excmination in these areas) and dams and dikes were generally found to be in accordance with requiren.ents and cotmitments.
However, the team did identify the following con truction program weaknesses that require management attention: 1.
Contlicts were identified between design inputs and r$AR commitments with regard to electrical cable and racesay separation which resulted
in separation deficiencies.
- 2.
Itardwaro discrepancies were found in non seismic items installed over Seismic Category I items.
Failure of these discrepany, non seismic ttems could adversely af fect Class 1E electrical components.
) 3.
Deficiencies identified in the area of interdisciplinary and pipe to pipo c16arances indicated that the identification and resolution of these interforences were not being effectively addressed.
The NRC CAT team considered the direct involvement and control by CPM. in design engineering and the extensive use of field engineers to identify and resolvo problems to be positive aspects of the $hearon Harris construction program., . g,t2 :a1 and Instrumentation
' iho majority of the electrical and instrumentation samples er.amined met the appropriate design and construction reclutrements.
The appitcant's program for inspection of construction activities end maintenance of Class 1E electrical equipment appears to be ef fective.
Construi: tion and design deficiencies were identified in soveral areas including s6fte items which will require additional ' hkC review.
, sone design doceents, which specify separation criteria for electrical raceway installation, deviate from FSAR commitments.
As a result, numerous installations exist where the required separation between Non Class It and Cla s 1E raceway components have not been maintained.
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Uccause of numerous identified hardware deficiencies in non selsaic raceway . supports, their possible failure may adversely affect the ability of nearby } Class lE olcctrical components to perform intinded safety functions.
The correctivo actions being taken by the applicant concerning problems associ-ated with instrumentation appear to be adquate although final actions and approvals were not completed at the time of the NRC CAT inspection.
. .. Pechanica) Construction Piping, pipo supports / restraints, concrete expansion anchors and HVAC supports / rostraints were generally found to be in accordance with applicable drawings and
requirements.
Discrepancies were identified with mechanical equipment founda- ' tion fasteners and sliding end installations.
Noted deficiencies of undersized wall thickness in field purchased piping indicates that the inspection and survoillanco offort in this area requires increased management attention.
Pregraemtic concerns were noted in two areas: (1) lack of verification of ' piping and pipo support / restraint location to original design requirements and, cicarance pr,oblems carly in the construction process.y and resolve hardware (2) lack of an ongoing program to effectively identif [: Both of these concerns involvo practices that could reluit in extensive inspection, analys,es and rework efforts very late in the construction schedule.
'fo_1 ding and !!ondestructive Examination . Wolding and nondestructive examination activities were generally found to be c.onducted in accordance with the governing codes and specifications.
Few doficiencies were identified by the NRC CAT inspectors in this area.
However, a number of examples were identified where vendor supplied tanks did not meet the design requirements for nottle to shell weld reinforcement, and some of tho tanks support welds were undersized.
In the area of NDE, several irregular-ittes involving film quality were identified.
However, the finished wolds were ! - found to,be accepublo.
, ' Civil and Structural Construction . Construction quality and concrete material cortification were in general found to be acceptable.
However, three areas were identified where the reinforcing steel had not been placed in accordance with, the design drawings.
An area of improper concrete consolidation was identified in one of the beams in the Reactor Auxiitary Building.
After chipping out the concrete in this area, a void was identified above the embedded plate and one layer of the bottom reinforcement lapped at this location was placed to one side of the beam instead of being distributed across the bottom of the beam.
A number of non-seismic electrical system components located over seismically quailf ted systems which are supported by unmarked concrete expansion bolts were
identified.
Subsequent ultrasonic testing indicated that the anchor bolt , embedmont lengths were as low as 115 inches.
Also, tension and shear tests performod by CP&t personnel indicate that the factors of safety are approxi-nately 50% of recomended values.
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. s' / \\ . tytterial, Traceability and Controls In grineral, the project material traceability and control program was found to, be dCCCptJble.
Problems were identified regarding traccability of f astener m.itorials, including large anchor bolts and equipment mounting bolts and nuts.
It was noted that both the applicant and the NRC Region !! had previously identified such deficiencios and correctivo actions were in progress by the applicant.
Ooston Channe Control Ortsign chango control, including control of chasses to design documents, was dotorminod to be generally in conformance with applicable requirements.
A nun.ber of minor, non ganeric discrepanclos were identified, none of which are considered significant.
In the area of document change control, the most signifleant finding was the numerous unincorporated changes af foeting many documents.
The most significant finding in the area of design change control is that semo analysos and other backup documentation for fleid changes have not been designated as quality assuranco records.
' C,orrec,tivo Actlon Systems , , , in conoral the applicant's corrective action progru was found to be accept-able, llowever, it was evident that the scope and quality of audit activities regarding nondostructive examination of welding were deficient and should bo ieprovad.
The applicant stated that improvemonts were planned in this arCa.
, . Projec,t Panagefront Project Hansgemont personnel and organization appear to be adequate to assure that construction and startup activities will meet quality requirements.
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....... -... .................. ... . .. ' . APPEllDIX B POTEllTIAl. ENFORCEMENT ACTIONS As a result of the llRC CAT inspection of October 112 and October 22-Itovember 2, 1984, the following items havo been referred to llRC Region !! as Potential Enforcement Actions (section references are to the detailed portion of the inspection report): 1.
Contrary to 10 CFR 50, Appendix B, Criterion !!! and the CP&l. SHilPP FSAR, Cosl0n Control has not been maintained in that the applicant has failed to requirements for separation of Class 1E assure that applicable regulatory 'y components are correctly translated and lion Class 1E electrical racewa into specifications, drawings, proceduros and instructions (Sections II.B.1 and ll.B.2).
2.
Contrary to 10 CFR 50, Appendix B, Criterion V, the applicant has failed to install reinforcing stcol to the toicrances shown on the design drawing and specifications in that;
a) The top reinforcing steel in beam 55-l.-KZ in the Fuel Handling Building was installed 1h inch lower than shown on the rebar place-mont drawing and was not identified during the inspection of the reinforcing steel placement (Section V.B.1), , b) The bottom steel on beam 38 between column line FZ and the exterior wall in th's Reactor Auxiliary Building was placed on one side of the beam instead of being distributed across the bottom of the beam (Section V.B.1).
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Contrary to 10 CFR 50, Appendix B, Criterion VII and the Shearon Harris Plant FSAR, Chapter 17, the program for the control of purchased - mato, rials af fecting quality was not ef fectively impicmented to assure , that purchased piping was in conformance with specified acceptance , critoria and requirements for pipe wall thickness (Section !!1.B.1).
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Contrary to 10 CFR 50, Appendix B, Criterion X and the Shearon Harris Plant FSAR, Chapter 17, the program for inspection of activities affecting quality was not effectively impicmented in that inspection programs did not assure that equipment' foundation connections were ' installed in accordance with specified acceptance criteria and requirements (Section !!!.B 5).
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