Text

Inps Rept 50-400/85-38 on 851021-25.Violation Noted:Failure to Establish Adequate Measures to Control Storage of Permanent Plant Equipment
	ML18003B163
Person / Time
Site:	Harris
Issue date:	11/07/1985
From:	Blake J, Kleinsorge W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML18003B161	List: ML18003B160; ML18003B162; ML18003B163;
References
	50-400-85-38, NUDOCS 8511270193
	Download: ML18003B163 (17)
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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MAR I ETTA ST R E ET, N.W.

ATLANTA,GEORGIA 30323

Report

No.:

50-400/85-38

Licensee:

Carolina

Power and Light Company

P.

0.

Box 1551

Raleigh,

NC

27602

II

Docket No.:

50-400

4

Facility Name:

Harris

1

License No.:

CPPR-158

Inspection

C

Inspector.

ed

I

so

ob r 21-25,

1985

P 7>~

Date Signed

Approve

by:

J.

.

1

e, Section Chief

E gi

ering Branch

iv sion of Reactor Safety

D te Signed

SUMMARY

Scope:

'This, routine,

unannounced

inspection involved 38 inspector-hours

on site

in the areas

of licensee

action

on previous

enforcement

matters

(92701B)(92702B),

housekeeping

(54834B), material identification and control

(42902B)

and material

control

(42940B),

safety-related

heating,

ventilating,

and air conditioning

(HVAC) systems

(50100),

preservice

inspection

(73052B)(73053B),

and inspector

fol1owup items (92701B).

Results:

One violation was identified "Failure to Establish

Adequate

Measures

to Control the Storage of Permanent

Plant Equipment",

paragraph

Nos.

3. i and 8. c.

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REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees

R. A. Watson,

Vice President,

Harris Plant

G. L. Forehand,

Director, Quality Assurance/Quality

Control

(QA/QC)

(Construction)

D. A. McGaw, Superintendent,

QA

D. C. Whitehead,

QA Supervisor

C. R.

Osman, Principal

QA/QC Specialist

T. W. Brombach, Project Specialist-Inservice

Inspection (ISI)

S.

M. Pruitt, Sr., Specialist,

ISI

M. G. Wallace, Specialist,

Regulatory

Compliance

Other

licensee

employees

contacted

included

construction

craftsmen,

engineers,

technicians,

and office personnel.

Other Organization

J. P. Kirk, Project Administrator, Daniel Construction

Co.

(DCC)

NRC Resident

Inspectors

R. L.

Pr evatte,

Senior Resident

Inspector - Construction

G. F. Maxwell, Senior Resident

Inspector - Operations

S. P. Burris, Resident

Inspector - Operations

Attended exit interview

2.

Exit Interview (30703B)

The inspection

scope

and findings were

summarized

on October 25, 1985, 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.

(Open) Violation 400/85-38-01:

"Failure to Establish

Adequate

Measures

to

Control the Storage of Permanent

Plant Equipment" - paragraph

Nos. 3.i

and

7 ~ co

The licensee

did not identify as proprietary

any of the materials

provided

to or reviewed

by the inspector during this inspection.

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3.

Licensee Action on Previous

Enforcement Matters

(92701B and 92702B)

a ~

(Closed)

Violation 400/84-06-01:

"Failure to Establish

Adequate

Procurement

Controls"

b.

C ~

d.

Carolina

Power

and Light's

(CPSL's) letter of response

dated

May 23,

1984,

has

been

reviewed

and determined

to be acceptable

by Region II.

The

inspector

held

discussions

with the

responsible

engineers

and

examined

the corrective actions

as stated

in the letter of response.

The inspector

concluded that

CPSL had determined

the full extent of the

subject violation, performed the necessary

survey

and follow-up actions

to correct

the

present

conditions

and

developed

the

necessary

corrective

actions

to preclude

recurrence

of similar circumstances.

The corrective actions identified in the letter of response

have

been

implemented.

(Closed)

Violation 400/85-22-02:

"Inadequate

Procedure

for Welding

Stainless

Steel

Piping"

CP&L's letter of response

dated July 19,

1985,

has

been

reviewed

and

determined

to

be

acceptable

by

Region II.

The

inspector

held

discussions

with the responsible

engineers

and examined the corrective

actions

as stated

in the letter of response.

The inspector

concluded

that

CPSL

had

determined

the full extent of the subject violation,

performed

the

necessary

survey

and follow-up actions

to correct

the

present

conditions

and

developed

the

necessary

corrective actions

to

preclude

recurrence

of similar circumstances.

The corrective actions

identified in the letter of response

have

been

implemented.

(Closed)

Violation 400/85-22-04:

Failure to Follow Procedure

for

Control of Welding Consumables"

CPSL's letter of response

dated July 19,

1985,

has

been

reviewed

and

determined

to

be

acceptable

by

Region II.

The

inspector

held

discussions

with the responsible

engineers

and examined the corrective

actions

as stated

in the letter of response.

The inspector

concluded

that

CPSL

had

determined

the full extent of the subject violation,

performed

the

necessary

survey

and follow-up actions

to correct

the

present

conditions

and developed

the

necessary

corrective actions to

preclude

recurrence

of similar circumstances.

The corrective actions

identified in the letter of response

have

been

implemented.

(Closed)

Violation 400/85-29-01:

"Failure to Follow

WPS Wire

Feed

Speed

Requirement"

CPSL letter of response

dated

September

20,

1985,

has

been

reviewed

and

determined

to

be

acceptable

by

Region II.

The

inspector

held

discussions

with the responsible

engineers

and examined

the corrective

actions

as stated

in the letter of response.

The inspector

concluded

that

CP8L

had

determined

the full extent of the subject violation,

performed

the

necessary

survey

and follow-up actions

to correct

the

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present

conditions

and

developed

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corrective actions to

preclude

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of similar circumstances.

The corrective actions

identified in the letter of response

have

been

implemented.

(Closed)

Unresolved

Item 400/84-05-01:

"HVAC Weld Repairs"

This matter

concerns

unclear

HYAC contractor's

documentation for weld

repairs.

The

licensee

made

investigation

and

determined

that the

documentation

was acceptable.

This inspector

reviewed

the licensee's

investigation

and

concurs

that

the contractor's

documentation

is

adequate.

This inspector

has

no further questions,

this matter is

considered

closed.

(Closed)

Unresolved

Item 400/84-05-02:

"Cracks in R2

HVAC Unit"

This item concerned

the licensee's

acceptance

"as-is" of a

HYAC filter

unit with several

"cracks".

The licensee

investigated

and determined

that the indications

were not cracks

and further that the indications

were cold starts.

The inspector

has

no further questions

in this

matter.

This item is considered

closed.

(Closed)

Unresolved

Item 400/84-05-03:

"Missing

HVAC Welds"

This item concerned

missing

welds

on

Bahnson

fabricated air handling

units.

CPSL

made as-built weld

maps for the air handling units in

question.

Evaluation

of the

weld

maps

is given

in calculation

CCL-CAL-100 (Evaluation

by Corporate

Consulting

and

Development

Co.

Ltd.).

This inspector

has

no further questions,

this matter

is

considered

closed.

(Closed)

Unresolved

Item 400/84-05-04:

"Material Substitutions"

This

item

concerned

apparent

material

substitutions

on

HVAC air

handling units

manufactured

by Bahnson.

The licensee

has

evaluated

each of the apparent

material

substitutions

and determined

that the

units

are

acceptable

as-is.

This inspector

reviewed

the licensee's

evaluation

and

concurs

with the conclusion.

This inspector

has

no

further questions,

this matter is considered

closed.

(Closed)

Unresolved

Item 400/85-12-01:

"Adequacy of Corrective Action

to Protect

Permanent

Plant Equipment"

This item concerned

NRC observations

of damaged

permanent

plant equip-

ment,

apparently

resulting from personnel

climbing on that equipment.

The

NRC inspector

making the observations

indicated that the licensee's

efforts to control

storage

of plant

equipment

to prevent

damage

appeared

to

be

unsuccessful

as of March 22,

1985.

The

licensee

informed the inspector that they

had identified similar circumstances

identified in a previous

nonconformance

report.

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As

a result of this item, the licensee

made

an investigation

and found

numerous additional

examples of temporary construction

loads applied to

permanent

plant equipment

due to rigging or scaffolding and live loads

imposed

by personnel.

In addition, the licensee identified additional

examples of equipment

damage

due to temporary construction

loads.

This

investigation confirmed that the licensee's

measures

to control storage

of equipment to prevent

damage

were inadequate.

Inspector

Followup Item 400/85-22-01,

"Housekeeping

in Cable Trays",

discussed

further

in

paragraph 8.c,

describes

two

examples

of

unauthorized

temporary construction

loads

applied to permanent

plant

equipment.

These

observations

were

made during the period

May 28-31,

1985.

On October

21 1985, this inspector identified three additional

examples

of unauthorized

scaffolding

supported

by

permanent

plant

e'quipment (electrical conduit and small

bore piping).

In view of the

above, it is clear that the licensee's

measures

to

control storage of equipment to prevent

damage

are inadequate.

Failure

to establish

adequate

measures

to control

storage

of equipment

to

prevent

damage

is

a violation of Title Ten,

Code of Federal

Regula-

tions, Part 50, Appendix B, Criterion XIII. This matter will be closed

as

an Unresolved

Item and

opened

as Violation 400/85-38-01:

"F'ailure

to Establish

Adequate

Measures

to Control

the

Storage

of Permanent

Plant Equipment".

Within the

areas

examined,

no violations

or deviations

were identified

except

as noted in paragraph 3.i.

4.

Unresolved

Items

Unresolved

items were not identified during this inspection.

5.

Independent

Inspection Effort

Housekeeping

(54834B),

Material Identification

and

Control

(42902B)

and

Material Control

(42940B)

The inspector

conducted

a general

inspection of the power block construction

area to observe activities such

as housekeeping,

material identification and

control; material control,

and storage.

Within the areas

examined,

no violations or deviations

wer e identified.

6.

Safety-Related

Heating, Ventilating,

and Air Conditioning

(HVAC) Systems

(50100)

The ,inspector

reviewed

samples

of safety-related

HVAC system

records

to

determine

whether

the

licensee

was

adequately

preparing,

reviewing,

and

maintaining

a

system

of quality records;

whether

there

is

reasonable

assurance

that the records reflect work accomplished

consistent

with

NRC

requirements

and

SAR commitments;

and

whether

the

records

indicate

any

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potentially generic

problems,

management

control

inadequacies,

or other

weaknesses

that

could

have

safety

significance.

The following specific

areas

were examined.

a.

The inspector

reviewed

documentation

for tHe

below listed safety-

components

to verify seismic

qualification

per

IEEE-344-1975.

~Ta

No.

AH-85(A1-SA)-07125

AH-85(A1-SA)-07115

AH-85 A1-SA -07116

DG-DISA-1-07678

DG-DISA-1-07680

DG-DISA-1-07679

Descri tion

AHV Fan Motor (Reliance)

AHV Cooling Coils (Aerofin)

AHV Centrifugal

Fan (Barry)

Control

Damper (Ruskin)

Limit Switch for Damper

(NAMCO)

Hydramotor Actuator for Damper (ITT)

b.

The inspector

reviewed receipt

inspection

checklists

for the

below

listed

HVAC equipment

to determine

whether inspections

were completed

within the intent of the inspection

procedures.

Tata

No.

DG-GD55B-1

DG-GD65B-1

DG-D7SAB-1

AH-85(1C-1D)

Descri tion

HVAC Damper

HVAC Air Handling Unit

HVAC Fan for Above Air Handling Unit

Within the areas

examined,

no violations or deviations

were identified.

7.

Preservice

Inspection

(PSI)

The applicable

code for PSI inspection is the

ASME

B and

PV Code,

Section

XI, 1980 Edition through Winter 1981 Addenda.

a.

Review of Procedures

(73052B)

The inspector

reviewed

the

PSI

procedures

indicated in the following

paragraphs

to determine

whether

the

procedures

were consistent

with

regulatory requirements

and licensee

commitments.

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The following procedure

was

reviewed in the

areas

of procedure

approval,

requirements

for qualification of

NDE personnel,

and

procedure

scope:

Procedure

No.

Title

CP8IL- 1 ST-608

Rev.

0

"Eddy Current Examination of

Non-Ferromagnetic

Tubing by Use

of MIZ-18 Tester for Nuclear

Steam

Generator

(NSG)"

(2)

Procedure

IST-608,

Rev.

0 was reviewed for technical

adequacy

and

conformance

with

ASME Section

V and other licensee

commitments/

requirements

in the

below areas:

a

two channel

examination unit

was specified;

two channel

examination

indication equipment

was

specified

such

as indicator, meter,

tube, strip-recorder

or tape;

a criteria

has

been

established

for

maximum sensitivity;

a

criteria

has

been

established

for

determining

material

permeability;

the method of examination

was described;

method of

calibration'nd

calibration

sequence

was described;

calibration

simulator was described;

and acceptance

criteria was specified

and

corresponds

with ASME Code, Section

V.

(3)

The

inspector

reviewed

procedure

IST-608,

Rev.

1 to determine

whether

the procedure specifies

completion of required records.

b.

Observation of Work and Work Activities (73053B)

The inspector

observed

the

PSI activities described

below to determine

whether

these

activities

were

being

performed

in accordance

with

regulatory requirements

and licensee

approved

program

and procedures.

(1)

The inspector

reviewed

the qualification records

for the

below

listed

examiners

to determine

whether their qualifications

were

consistent

with the licensee's

procedures

and regulatory require-

ments.

Examiner

RMB

RDM

TDC

SDG

CMC

Method-Level

ET-III

ET-II

ET-I

Or anization

Daniel

Zetec

Daniel

(2)

System

Pressure

Test

The

inspector

reviewed

CP8L

Procedure

1-2005-C-Ol,

Rev. 2,

"Reactor

Coolant

System

Cold Hydrostatic Test",

and Selected

gA

records

to

determine:

whether

procedures

were

available;

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personnel

were knowledgeable of the examination

method; qualifica-

tions

and certifications

of personnel

and

equipment;

results

evaluation of results

and corrective actions/repairs/replacement

recorded

as specified

in PSI

Program.

Observations

were compared

with the applicable

procedure

requirements

for compliance with

regulatory

and

code

requirements.

The following areas:

test

conditions

of pressure

and temperature;

test

condition holding

time; rate of temperature

and pressure

increase;

pressure

and/or

temperature

measuring

instrumentation;

sources

of detected

leakage

located,

evaluated,

and corrective

measures

taken;

and

gauges

calibrated prior to test.

Review of records

was

chosen

to verify the above

as the window of

opportunity for direct observation

had passed.

(3)

Eddy Current Examination

The inspector

observed calibration,

data collection (inspection),

and

a portion of data evaluation for eddy current examination of

the

A and

B steam

generators.

These

observations

were

compared

with the

applicable

code

and

procedural

requirements

in the

following areas:

two channel

Eddy Current

Examination

equipment

was identified including indicator, meter,

tube, strip recorder,

and

tape

as

applicable;

method

for

maximum sensitivity

was

applied;

method for determining material

permeability of material

to

be examined

had

been

recorded;

material

permeability

had

been

recorded;

method of examination

had

been

recorded;

examination

equipment

had

been calibrated

in accordance

with the applicable

performance

reference;

amplitude

and

phase

had

been calibrated

with

the

proper

applicable

calibration

reference

and

was

recalibrated

at predetermined

frequency;

1005 coverage

of steam

generator

tubes

occurred

during the examination;

and

acceptance

criteria

was specified or referenced

and

was consistent

with the

procedure

or the

ASME Section

V; and results

were consistent

with

acceptance

criteria.

Within the

areas

examined,

no violations

or deviations

were

identified.

8.

Inspector

Followup Items

(92701B)

'a ~

(Open)

Item 400/84-30-01:

"VT-2, 3, and

4 Examiners"

At the time of the inspection discussed

in NRC Report 400/84-30-01,

the

licensee's

program did not address

qualification of visual

examiners

VT-2, 3,

and 4.

The licensee

has

subsequently

issued

CPSL Procedure

IST-108,

Rev. 0, dated

January

21,

1985,

"Nuclear Inservice Inspection

Procedure for the Certification of Visual Examination Personnel

(NES)".

to address

the

above qualification.

This inspector

reviewed

the

procedure

and noted the following:

fh

"IL.,<<(c

>>.g<<K

II I

'

l

I

W

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I fi

~

~ f<<

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<<

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1<< ~f>>

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WK

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r)

I L<<<<'

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<<

'll

>>.).

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<<

v

w'I',

<<f,

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>>>>,

.)

(

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~ "I

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ll

l.

<<v'

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~'

>>

Ii

i

I

f

W

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~ W,I <<'

<<

<<<<

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I'

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<<

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I fl

>>>>

>> ~

>>

<<K

v

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I'

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f)<<

~

II

~

l

l<<l

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K.)>>WE)v )

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I

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h

w

" 'Kf/ l'Kw

l

If,

Af'lf

>>

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lt

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)

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<<,

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The

number of segments

(four-basic,

general

(method), specific,

and practical) listed in paragraph

4.3 for Level III examiners is

not consistent

with paragraph

4.4 which indicates

three

segments

(general, specific

and practical) for Level III examiners.

The identification of the segments

listed in CP&L IST-108,

Rev. 0,

and their relative

weighting factors listed

in paragraph

4.4

(General

0.4;

Specific

0.4

and

Practical

0.2)

for Level III

examiners

appear

not to be consistent with the Level III examiner

weighting

factors

listed

in

the

American

Society

for

Nondestructive

Testing

(ASNT) Standard

SNT-TC-1A-1980,

paragraph

8.4.3(3)

((a) Basic

0.2

to

0.5,

(b) Method

0.3

to

0.6,

(c) Specific 0.2 to 0.4)).

The licensee

indicated that they would look into the matter further and

make the

necessary

corrections

to the procedure.

This item remains

open.

b.

(Closed)

Item 400/85-12-02:

"Arc Strikes

on Refueling Cavity Liner

Plate"

This item concerned

arc strikes

on the refueling cavity liner plate,

and the fact that the licensee's

program did not address

arc strikes

on

liner plates

except for those

associated

with and adjacent

to liner

plate

weld joints.

The licensee

has

issued

Revision

18 to C(C-19,

"Weld Control for Piping

and

Fuel

Pool Liners" dated

May 19,

1985, to

cover inspection of fuel

pool liner base material for arc strikes.

To

verify the

implementation

of the

above,

this

inspector

examined

a

portion of the fuel pool liner plate.

This inspector

has

no further

questions,

this matter is considered

closed.

c.

(Closed)

Item 400/85-22-01:

"Housekeeping

in Cable Trays"

This

item identified

two

examples

of temporary

construction

loads

applied to permanent plant equipment.

The licensee

determined that the

above plant equipment

was non-nuclear safety-related.

The licensee's

program

makes

no distinction

between

safety-related

and non-nuclear

safety-related

in their measures

to control

storage

of equipment

to

prevent

damage.

This matter will be closed

as

an inspector followup

item and

become

an example of violation 400/85-38-01

as discussed

above

in paragraph 3.i.

d.

(Closed)

Item 400/85-22-03:

"Documentation for HVAC Duct Welds"

This, item concerns

weld records

for

HVAC duct welds that

were not

available

during

NRC inspection

50-400/85-22.

The licensee

has

made

these

records available.

This inspector

has

no further questions,

this

matter is considered

closed.

Within the

areas

examined,

no violations

or deviations

were identified

except

as noted in paragraph

8.c.

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