IR 05000400/1984044
| ML18003B065 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/16/1985 |
| From: | Fredrickson P, Maxwell G, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18003B064 | List: |
| References | |
| 50-400-84-44, NUDOCS 8503060829 | |
| Download: ML18003B065 (13) | |
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NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA.GEORGIA 30303 Report No.:
50-400/84-44 Licensee:
Carolina Power and Light Company 411 Fayettevil>e Stree.
Raleigh, NC 27502 Oocket No 50-400 Facility Name:
Shearon Harris Inspection Conducted:
November 20 - Oecember 20,
'984 Inspectors:
~ %.
G.
F.
Maxwel R.
. Pre te iJ License No.:
CPPR-158 ate Signed i/ic/d'z Oate Signed Approved by:
P. Fredrickson, Acting Section Chief Oivision of Reactor Projects ate igned SUMMARY Scope:
This routine, announced inspectior. entailed 182 resident inspector-hours hours on site in the areas of licensee action on previous enforcement matters, inspector followuo items, inaepenaent inspection (operations),
electrical, nonconformance control, stor age, other activities, and CAT inspection.
Results:
Of tne seven areas inspected, no violations or deviations were identi-rie REPORT OETAILS 1.
Licensee Employees Contacted
"R. A. Watson, Vice President, Harris Nuclear Project C.
C. Wagoner, Project General Manager, Construction
- R. M. Parsons, Project General Manager, Construction Confirmation Completion J.
L. Willis, Plant General Manager, Operations E. J.
Wagner, Manager, Engineering L. I. Loflin, Manager, Harris Plant Engineering Support, M. Thompson, Jr.,
Manager, Engineering Management B.
Van Metre, Manager, Harris Plant Maintenance
- N. J. Chiangi, Manager, QA/QC Harris Plant C.
S Hinnant, Manager, Start-up J.
M. Collins, Manager, Operations A. H. Rager, Manager, Construction Inspection
- G. L. Forehand, Oir ector, QA/QC
"C.
S.
Bohanan, Oirector, Regulatory Compliance
"M. 0. Vernon, Superintendent, QC
"0. A. McGraw, Superintendent, QA Other licensee employees contacted included 28 construction craftsmen, Z2 engineers, 17 operators, 1Z mechanics, and 15 office personnel.
Other Organizations G.
F. Cole, Vice President, Oaniel Construction Company J.
P. Kirk, Project Administrator, Oaniel Construction Company
"Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on Oecember 20, 1984, with those persons indicated in paragraph
above.
No written material was provided to the licensee by the resident inspectors during this reporting period.
3.
Licensee Action on Previous Enforcement Matters (92701 and 92702)
a.
{Closed)
Violation 400/83-24-01,
"Failure to Establish Corrective Action Measures".
The inspector evaluated CPKL's response to Region II dated September 29, 1983, for this item.
Implementation of a
new nonconformance procedure with a consolidated NCR form and centralized control in January 1984, should eliminate the root cause of this problem and prevent recurrence.
This item will be routinely evaluated by the NRC resident inspector in subsequent inspections.
This item is close (Closed)
Violation 400/83-24-03,
"Failure to Fol low Records Storage Procedure and Correct Conditions Adverse to Quality".
The inspector evaluated CP5L's response to Region II dated September 29, 1983.
Corrective action taken by the licensee and subsequent followup inspections by the resident inspectors indicates that this problem has been corrected.
This item is closed.
(Closed)
Violation 400/83-24-02,
"Failure to Follow Cable Tray Drawing and Procedure Requirements".
The inspector evaluated CP8L'
letter to Region II dated September 29, 1983, concerning this item.
Construction Inspection (CI)
has had its responsibilities and duties changed to remove cable tray supports from the raceway inspection group and detail it to a separate support inspection group within CIA The applicable construction procedures have been revised to accommodate the shift in responsibilities and have added attributes which should enhance the raceway support inspection program.
The implementation of the new CI inspection program will be evaluated routinely by the NRC resident inspector.
This item is closed.
(Closed)
Unresolved Item 400/83-37-06,
"Seismic Bolting Requirements".
CP&L issued nonconformance report (NCR)84-038 to address this problem.
The concern was associated with the use of commercial unmarked
"B Line" bolts for the control room lighting support members.
A sample of the previously installed bolts was removed and tested at the CPS L Energy and Environmental Center test lab.
These tests show that the bolting material exceeds the seismic design requirements for loading.
All remaining bolts were marked prior to issue to provide 100~ inprocess inspection by construction inspection personnel.
The NCR was closed on January, 1, 1984.
Subsequent inspections on this item by the resident and Region II inspectors indicate that this problem has been adequately resolved.
This item is closed.
(Closed)
Unresolved Item 400/83-24-05,
"Material Identification and Traceabi lity Requirements".
CP8L issued DOR 1674 to document and resolve this item.
This OOR was closed on October 10, 1983.
Two new procedures,
"Seismic Category I
Steel Fabrication (CQC-21, issued August 3, 1983)
and
"Material Status Verification" (QCI-6.4, issued October 13, 1983)
have been implemented by the licensee to correct this concern.
Inspection personnel have been indoctrinated in these procedural requirements.
CP5L QA surveillances and resident inspector observations indicate that this item has been adequately resolved.
This item is closed.
(Closed)
Unresolved Item 400/83-24-04,
"Documentation of Cable Tray Support Inspections".
This item addressed a
concern that TP-42 exhibits used to document cable tray inspections were being used as punch lists to allow the construction crafts to wor k off discrepancies prior to final inspection.
The records were not being placed in the QC vault.
CP5L has revised this procedure and these records are now being maintained as QA records.
This item is closed,
(Closed)
Unresolved Item 400/83-05-02,
"Administration Approval of Orawings Associated with Oesign Changes".
CP&L issued a
Request for Clarification/Information (RCI) M-294 to address this item.
The open revision (Rev.
4)
of Orawing 2165-G-107S01 observed by the NRC inspector was an attachment to OCN-530-769, Rev.
and was an interim change to Drawing 2165-G-107501, Rev. ".
Th'.s revision
,vas issued on April 4, 1983.
The use of preliminary (interim) revisions of drawings for construction had been changed so that drawings will not be used for construction until final approval from the Architect/Engineer is received on site.
This will eliminate thi s inspector concern.
This item is closed.
4.
Inspector Followup Item (92701)
(Closed)
Inspector Followup Item 400/83-25-29,
"Specific Inspection Criteria and Inspection Attributes in Work Procedures".
CP&L has revised the applicable work procedure (WP-105)
to allow certain inspection hold points to be marked as not applicable, where appro-priate.
This item is closed.
(Closed)
Inspector Followup Item 400/83-25-28,
"Improving Oocument Revision Procedures".
The NRC resident inspectors have observed improvement in timeliness concerning the incorporation of changes in site procedures.
Improvem'ents have been made to require change notices to be processed more promptly.
Subsequent NRC inspections have not identified that CP&L employees are not working to current procedural requirements.
This item is closed.
(Closed)
Inspector Followup Item 400/83-24-09,
"Control of QA Records".
This item was identified by CP&L as a system RFT number for electrical cable tray supports having not yet been assigned.
Subsequently, QA and Start-up have assigned the Release for Test (RFT)
system numbers to uniquely identify the electrical raceway systems.
The QA records filing system has been frequently inspected subsequent to report 400/83-24.
This item is closed.
d
~
(Closed)
Inspector Followup Item 400/83-25"30,
"Procedural Improvements for Oisposition of NCRs and OORs"..
CP&L's implementation of tne new nonconformance control procedure CQA-3 in January 1984 addressed this problem.
Subsequent followup inspections by the resident inspectors indicate that this potential problem has been corrected.
This item is closed.
(Closed)
Inspector Fol 1 owup Item 400/83-13-01,
"Concrete Anchors for Containment Spray Pump Supports".
The work on this item was incomplete when this discrepancy was identified.
Work has been completed and the item was inspected and accepted on February 1,
1984.
The ancho~ bolts now have correct thread engagement.
This item is close s.
Nonconformance Control (92706B)
The inspector, as part of the routine review of nonconformance reports (NCRs),
noted that NCR 84-2274 had identified a failure by the licensee to make a 50.55(e)
report to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the deficiency was deemed repor.able.
The reportable deficiency,
"Rejectable Welds in Containment Structural Steel That Had Been Accepted by gC",
had been identified by the licensee and documented in NCR 84-1962 on October 22, 1984.
Engineering evaluation had deemed this item to be reportable on November 2, 1984.
However, this item was not reported to the NRC, Region II until November 9, 1984.
The failure to report a significant construction deficiency to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after it has been deemed reportable is contrary to the requi rements of
CFR 50.55( e).
However, in accordance with
CFR 2, Appendix C( IV)(A), the NRC wants to encourage and support licensee initiatives for self-identification and correction of problems, and for this reason, the NRC will not generally issue a Notice of Violation for a violation that meets specific requirements.
In the areas inspected, no vio 6.
Independent Inspection (71302)
The NCR, 84-2274, that identified this discrepancy, was closed by the licensee on November 20, 1984.
The corrective action and preventive measures to preclude recurrence have been reviewed and found acceptable by the resident inspector.
Since this item meets the requirements of 10 CFR 2, Appendix C( IV)(A), no violation will be issued.
Long term adequacy of the corrective action taken by the licensee will be monitored by the resident inspectors as a part of the routine inspection program.
lations or deviations were observed.
The inspector toured the various plant areas during this period.
Plant activities were observed and evaluated to determine if they were being performed in accordance with applicable requirements.
The activities which were evaluated during the tours included:
hot work (welding, burning, cutting, etc.);
accessible fire protection equipment; house-keeping; equipment preservation (protection from climatic conditions);
review of the control room log; clearance log; interviews with Start-up personnel and security of controlled access areas.
b.
The inspector observed the in-process calibration test on an electrical transducer located inside cubicle number two of the emergency diesel generator switchgear ( 1B-SB).
The test technicians were familiar with the applicable procedural requirements (PIC-E010),
The technicians were using required test equipment and conducted the test in accordance with procedural requirements.
The test was witnessed and evaluated by CP&L QA personnel.
C.
CP8L Start-up personnel scheduled a hydrostatic test of the secondary system, i.e.,
the steam generator shell side to include portions of the main steam and feedwater lines up to the isolation valves.
The initial schedule called for the test to be conducted during the week of
November 26, 1984.
However, problems were observed with two loop "B" feedwater valves (gate valve 2FW-V27-SAB1 and check valve 2FW-V24" SAB1).
Valve 2FW-V24-SAB1 was disassembled and required replacement of its valve seal ring.
A similar repair was required for the gate valve which was to be used as an isolation valve, the body of the valve was accidentally gouged.
The gouged area required repairs by welding and grinding to assure that the new seal would not leak.
Ouring the week of November 26, 1984, the welding and grinding were discontinued and the valve was reassembled; however, it was found to still leak.
The status of the gate valve will be tracked during subsequent inspections.
On Oecember 5,
1984, the valve line up was made to allow the hydro-static tests to be independently performed on Loop "A" and
"C" steam generators.
The tests were discontinued before reaching the hydro-static test pressures, as the low pressure relief valves for both steam generators began to leak at about 1300 pounds pressure'.
Start-up personnel found that the relief valves had been
"gagged" at values below the suggested settings.
On Oecember 6,
1984, after CP&L reset the gag settings on loop "A" relief valves, the Start-up personnel made a second attempt to conduct the hydrostatic test on the steam generator.
When the pressure reached about 1400 pounds, another gagged safety relief valve started leaking.
The test pressure was reduced to about 1200 pounds; the relief valve which had leaked was reinforced to reduce the possibilities of leaking again.
The test'ressure was then increased and no relief valves leaked until the system test pressure reached about 1522 pounds.
At about 1522 pounds pressure, one of the relief valve gag devices allowed a safety relief to lift causing the test to be invalidated.
After numerous attempts and efforts to gag the relief valves failed, CPKL removed the valves and'installed blind flanges to allow completion of the hydrostatic tests.
The inspector observed completion of the hydrostatic tests and weld inspection on the steam generators and piping for "A" and
"C" steam generators on Oecember
and on steam generator
"8" on Oecember 11, 1984.
The activities concerning the hydrostatic testing of the steam generators (secondary side),
were
.found to be controlled in accordance with the applicable requirements of the Start-up Manual and test procedures.
Those test and operations personnel who participated in those activities which were evaluated were familiar with the procedural and Start-up Manual requirements.
No significant problems were encountered.
The final results of the hydrostatic testing of the secondary side of the steam generators will be evaluated during subsequent inspections.
No violations or deviations were identifie I 7.
Electr ical (50153C, 51063C, and 92706B)
a
The inspectors observed the installation activities associated with Cl ass 1E cables with the following number s:
12645H-SB, 10188E-SB, 12258A-SA, 10318G-SB, 13167A-SB, 10319L-SB, 10330B-SB, 13152B-SB, and 131520-SB.
The observations related to cable pulling between s'witch-gear and various cabinets and termination activities.
The following were evaluated during the observations:
(1)
The latest pull cards and procedures were in use; (2)
The size and type cable were correct; (3)
The cable identification (cable number and color code)
was correct;
.Sr r
(4)
The correct pulling tension was applied; (5)
The correct bending radius was applied; (6)
The cable routing was correct; (7)
The cables were protected from damage; (8)
Qualified electrical inspection personnel were monitoring the installation activities; (9)
Calibrated termination kits were used; and ( 10)
Nonconformances were documented.
The inspector observed the installation activities associated wi;h modifications being performed on the reactor trip switchgear.
These modifications will add the automatic shunt trip feature and response test.points to the reactor trip breakers.
The work was being performed under Field Change Requests (FCRs)
I-1144, SE-351, E-1244 and Work Request Authorization (WRA) CK6/01.
The work was being performed by craft personnel under the technical guidance of Westinghouse.
CPS L QA personnel were providing QA surveillance and inspection of the work activities.
The testing of this installation will be accomplished as an integral part of the Start-up test program.
The resident inspectors will monitor these test activities when accomplished.
C.
The inspector selected five record packages used for the installation of electrical conduit supports.
The work associated with these packages had been completed and inspected; the packages had received a
final documentation review and had been placed in the QA records vault.
A reinspection of these supports was conducted by the resident
inspector, accompanied by welding gC and Hanger Construction Inspection (CI) personnel.
The results were that no discrepancies were identified in the CI inspection area.
In the welding area, one of the five supports had one slightly undersized weld and one support was welded on two sides vice the three sides specified by the applicable drawing.
These nonconformances were documented by the licensee on nonconformance report (NCR) 84-2346.
Based upon the results of this inspection and a review of additional nonconformances that had been previously identified by the licensee in this area, the resident inspector decided to increase the sample used for this inspection.
The licensee additiona'lly agreed to. perform a
statistical sampling on previously accepted welding on electrical supports.
The new samples selected were ten additional supports by the resident inspectors and 60 additional supports by the licensee.
The results of the resident inspector's additional samples was that welding on nine of the ten hangers was in accordance with the prescribed drawing.
The remaining hanger had two welds that were undersized by approximately 1/16 inch for approximately 50 percent of the weld length.
This deficiency has been documented by the licensee on NCR 84-2482.
The results of the licensee's additional sample'as that welding on 55 of 60 supports was satisfactory.
The remaining five support deficiencies were two documentation errors; one weld with base metal reduction, and two supports not welded in accordance with drawing specification (incorrect size and span on stitch weld and weld on two sides when drawing specified three sides).
This sample involved inspecting 456 welds, of which three were deemed to be unsatisfactory.
This is less than one percent overall.
Based upon preliminary engineering evaluation, none of the above items meet the requirements for reportability under
CFR 50.55(e).
The above items have been documented by the licensee on NCR 84-2484 and will be corrected.
The results of the above and previous inspection findings by the licensee indicate that improvement is needed in 'the welding, welding inspection, and documentation review areas.
As a result, the licensee is presently implementing the following changes to strengthen these areas:
(I)
Revise (}C welding inspection procedure
"Seismic Structural Steel Inspection and Oocumentation System" (gCI-1,8. 1)
to provide clarification on attributes to be inspected on primary and secondary inspection.
(2)
Revise weld inspection criteria "Clarification of AWS 01. 1" (CAR 2165-A003) to cover undersized welds, insufficient throat, stitch welding, slag and base metal reduction.
(3)
Provide training and indoctrination of inspection personnel for the above procedural change (4)
Establ i sh inspector training cl asses to improve inspector
'
working knowledge of design weld details.
(5)
Establish a retraining program and practical examination on the use of fillet ga'uges
~
(6)
Provide additional training to construction and inspection personnel in the use of vendor and EBASCO drawings used for welding and welding inspection of structural steel.
(7)
Increase gA surveillance in this area to insure successful implementation of the above and to identify any additional action required.
The discrepancies identified by the resident inspector and the licensee in these inspections are contrary to the requirements of
CFR 50, Appendix B, Criterion IX as implemented by CP&L PSAR Section 8.4. 1.d; ASW 01. 1 and site welding and inspection procedures and is a violation.
However, since a portion of these and similar problems in this area were licensee identified, and corrective measures were in the process of being implemented prior to this inspection to prevent recurrence, the inspector determined that the provisions of
CFR 2,
Appendix C(IV)(A) which seeks to encourage and support licensee initiatives for self-identification and correction of problems partially apply in this case.
The NRC will not issue a violation at this time but will moni'tor implementation of the corrective action proposed by the licensee for effectiveness.
This item will be identi-fied as an Unresolved Item, "Structural Steel and Welding Inspection Improvements" 400/84-44-01.
Followup inspections will be conducted in this area as a part of the ongoing resident inspection program.
No violations or deviations were identified in the areas inspected.
Storage (50073C and 92706B)
The inspectors toured warehouses 1, 2, and 3, the laydown yards, and various plant equipment storage areas.
Ouring the tours, the storage conditions of the equipment were evaluated to determine whether requirements are being met as follows:
Piping and equipment, in general, were stored off the ground to prevent entry of dirt into them, or contamination from environmental condi-tions.
b.
The storage areas were identified sufficiently to provide identity and locations as required by those who may be seeking the location of certain pipe spool pieces or equipment.
C.
The drainage, in general, was acceptable in areas where the piping spool pieces and tanks were store.
d.
Access was adequate for placement or removal of pipe spool pieces and equipment.
e.
Warehouse equipment was stored in correct position.
f.
The required temperature and humidity control were being met as required.
g.
Access to plant storage areas was being maintained.
h
~
Equipment installed heaters were energized as required.
i.
Protective covers were in place.
Ouring the observations, the following were referenced for requirements:
PSAR Section 1;8, and construction procedures AP-XIII-5, AP-XIII-07, and PGO-002.
No violations or deviations were noted in the areas inspected:
9.
Other Activities (92706B)
a
~
The Integrated Oesi gn Inspection ( IOI)
by NRC Headquarters 18 E commenced on Oecember 3,
1984, at Harris.
The inspection team consisted of R. Architzel (team leader),
six NRC inspectors and nine consultants.
An entrance meeting was held with CPS L management and CPKL team counterparts at the Energy and Environmental (E&E) Center on Oecember 4,
1984.
Region II attendees were P. Fredrickson, Acting Section Chief, Projects Section 1C; and the Senior Resident Inspector for Construction (SRC).
C.
Ouring this reporting period, seven Region II inspectors conducted insoections at the Harris site.
Their findings are documented in separate Region II inspection reports.
The inspectors observed the ongoing activities associated with disas-sembly and inspection on the Transmerica OeLaval (TOI) diesel engines.
10.
Construction Appraisal Team (CAT) Inspection Appendix B of Construction Appraisal Inspection 50-400/84-41 transmitted in our letter dated Oecember 24, 1984, identified four potential enforcement actions, based on CAT inspector observations.
The items in Appendix B have been referred to Region II for review and necessary action.
Subsequent inspections conducted by Region II will review all items identified in
Appendix B.
For tracking purposes, these four items will be identified as unresolved items, pending their subsequent review and disposition.
The correlation of items is as follows:
A endix B Location Unresolved Item No.
Design control related to separation of Class IE and non-Class IE electrical raceway components Installation of reinforcing steel in accordance with design Program for control of purchased materials Program for inspection of activities affecting quality 400/84-49-02 400/84-44-03 400/84-44"04 400/84-44-05