IR 05000400/1986058
| ML18019B128 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/07/1986 |
| From: | Belisle G, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18019B127 | List: |
| References | |
| 50-400-86-58, NUDOCS 8609040144 | |
| Download: ML18019B128 (10) | |
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50-400/86-58 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
July 14-18, 1986 Inspector:
R.
M.
rig t License No.:
CPPR-158 Dat Signed Approved by:
G. A.
6 is e, cting Section C ief guality Assurance Section Division of Reactor Safety a e Signed
Scope:
in-depth previous SUMMARY This routine, unannounced inspection was 'conducted "in'he areas of quality assurance (gA) inspection of performance, and 'licensee action on enforcement matters.
Results:
No violations or deviations were identified..
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REPORT DETAILS Persons Contacted Licensee Employees
- N. Chiangi, Manager Quality Assurance/Quality Control (QA/QC)
K. Douglas, Quality Assurance Specialist
- G. Forehand, Director QA/QC
- S. Hardy, Fire Protection Specialist-Harris Plant Engineering Section (HPES)
- K. Hate, Principal-QA Engineer
- L. Loflin, Manager HPES J. Pinto, Fire Protection Specialist-Consultant for HPES C. Phillips, Penetration Supervisor, Construction Engineering
- R. Somers, Superintendent, Construction Inspection (CI)
- D. Sugg, Unit Super visor, Civil/Mechanical (CI)
- H. Taylor, Sub Unit Supervisor, Penetration Seals 5 Anchors, (CI)
- M. Wallace, Specialist, Regulatory Compliance
- J. Willis, Plant General Manager Other licensee employees contacted included construction craftsmen, engineers, technicians, QA/CI personnel and office personne Other Organizations M. Walsh, BSB (Promatec)
QA Representative S.
Goss, BEB (Promatec)
Engineer NRC Resident Inspectors
, *G. Maxwell
- Attended exit interview 2.
Exit Interview 3.
The inspection scope and findings were summarized on April 18, 1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
Licensee Action on Previous Enforcement Matters (92702B)
(Deleted)
Severity Level V Violation (400/86-25-01):
Failure To Provide Adequate Acceptance Criteria To Initiate Penetration Sealing Inspections
.
The licensee's response dated June 12, 1986, denied the subject violation based on the position that the penetration seals identified are not subject to the requirements of 10 CFR 50, Appendix B.
Discussions with responsible
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HPSE personnel and examination of pertinent design data for the subject penetration seals identified that the penetration seals in question were installed for radiation (ALARA) shielding purposes.
They are not required for the safe shutdown of the plant and are neither safety-related nor fire protection items.
This violation has been withdrawn and our records have been updated to reflect this position.
4.
In-Depth QA Inspection of Performance (35061)
This inspection was performed to determine whether site work was being accomplished in accordance with Safety Analysis Report (SAR) commitments, that the QA/QC program was functioning in a manner to assure that commit-ments were met, and that prompt and effective action was taken to achieve permanent corrective action on significant discrepancies.
Selected ongoing installation and work activities concerning penetration seals were examined by the inspector in the following areas to verify these inspection objectives.
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Work Procedures The inspector selected and reviewed the following listed specifications and procedures to verify that they contained SAR commitments, proper qualitative or quantitative acceptance criteria, and that necessary changes are incorporated into procedures as required.
CAR-SH-AS-60 TP-69 WP-148 b.
Field Inspection Penetrati on Barrier Fire Stop Assembl ies, Internal Conduit Seals, and Fire Breaks Non-Nuclear Safety Equipment, R2 Inspection of Penetration Seals, R5 Penetration Seals and Installation, R4, R5 The inspector observed ongoing work activities for the following penetration seal installations which were found in various stages of completion:
Penetration Number H621 H681 E4094 E4094A E4198 E3357 E3594 E3611A E464E E394E E449F E394D E468E West E468D East E394C Top E468D West The inspector observed craftsmen at work, conducted discussions with randomly selected craftsmen and foreman, and determined that
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their knowledge of penetration sealing operations was adequate to provide the required quality of workmanship.
Quality Control The inspector reviewed inspection records (Penetration Closure Verification Sheets, Material Density Verifications) associated with several of the previously listed seal installations to determine their adequacy, whether deficiencies submitted by inspection personnel received proper corrective action, where applicable, and if work and work controls were adequate.
The inspector reviewed the applicable QC inspection procedures (paragraph 4.a)
to determine if the frequency, timing, and acceptance criteria for the inspection was adequate.
The number of CI inspectors provided for the coverage of these work activities was considered satisfactory.
The inspector accompanied several randomly selected CI sealant inspectors during their inspections and conducted discussions with them to determine if their knowledge of the activities they were observed inspecting was adequate.
While accompanying one such recently assigned inspector, who was found to be a very thorough inspector and knowledgeable of his acceptance criteria, the RII inspector observed that he properly rejected a Silicone RTV foam seal (Penetration No.
E4198A Top)
on his inspection records for inadequate curing.
Although he did not option to do so, subsequent discussions with this new inspector identified he thought an acceptable alternative would have been to simply not accept the installation (i.e., not document anything) telling the crafts why the seal was rejected so they could rework it as necessary to resolve the discrepancy so it would pass a subsequent CI inspection.
This appeared to be an isolated case in that no other sealant inspector interviewed felt he had this option.
The inspector informed the subject sealant inspector that his alternative concept was wrong in that it did not agree with procedure CQA-3, Nonconformance Control nor the licensee's QA program.
Upon notification of this erroneous concept, the CI Penetration Seals Supervisor reinstructed his inspection personnel on subordinate nonconformance reporting to assure continued uniformity of the inspection process.
Other than this apparent isolated incidence, discussions conducted with randomly selected sealant inspectors determined that they were knowledgeable of their inspection functions and acceptance/rejection criteria and were proficient in the performance of their assigned tasks.
Materials and Equipment The inspector examined the sealant materials being utilized for acceptable shelf life, the sealant dispensing machinery for cleanliness and proper operation and the platform scales (ID No fv h>>
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CPL 5866B and CA 5880 B) used for material density verification for current calibration stickers.
gA Survei llances and Audits The inspector reviewed the following gA site surveillance reports and the results of the supervisory audit conducted on each penetration seal inspector for the month of June 1986:
OASC NOS: 86-0008, 86-0037, 86-0057, 86-0162, 86-0237, 86-0258, 86-0297, 86-0496, 86-0886, 86-0891, 86-0892, 86-0893, 86-0894, and 86-0895 The above surveillances were examined to determine if they were meaningful, effective, reflect quality performance, and whether corrective actions taken as a result of the surveillance findings were proper, timely, and complete.
Within the areas inspected, no violations or deviations were identifie il
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