ML18004B872
| ML18004B872 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/01/1987 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-563 NUDOCS 8707090083 | |
| Download: ML18004B872 (6) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
Af:CESSION NBR: 8707090083 DOC. DATE: 87/07/01 NOTARIZED:
NO FACIL: 50-400 Shearon Harris Nuclear Power Plant'nit ii Carolina AUTH. NAME AUTHOR AFFILIATION ATSONi R. A.
Carolina Poeer 8c Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 0 05000400
SUBJECT:
Responds to NRC 870602 ltr re violations noted in Insp Rept 50-400/86-77. Corrective actions: site noncomf ormance repts
issued 0 hardware problems corrected bg rework or "accep ted-as-is" based on eng ineer ing evaluation.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTR
(
ENCL l SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit reneeal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD RES TERNAL:. LPDR NSIC INTERNAL:
ACRS DEDRO NRR ROE T M. L NRR/DREP/EPB NRR/DR IS DIR OGC/HDS1 DEPY GI COPIES LTTR ENCL 1
2 2
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIP IENT ID CODE/NAME BUCKLEY> B AEOD ENF LIEBERMAN NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ ILRB REG FILE RG E
01 NRC PDR COPIES LTTR ENCL 2
2 1
1 1
1 1
1 2
2 1
1 1
1 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0.
Box 165 New Hill, NC 27562 JUL 01 1987 File Number'SHF/10-13510E Letter Number:
HO-870452 (0)
NRC-563 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen'.
In reference to your letter of June 2, 1987, referring to I.E.
Report RII:
50-400/86-77, the attached is Carolina Power
& Light Company's reply to violation "B" identified in Enclosure 1.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very truly yours, ZQM~~
R. A. Watson Vice President Harris Nuclear Project RAW:ddl Attachment cc'Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) t 8707090083 870702 PDR ADQCK 05000400 MEM/HO"8704520/PAGE 1/OS1
Attachment to CP&L Letter of Response to NRC I.E. Report RII:
50-400/86-77 Re orted Violation:
B.
10 CFR 50, Appendix B, Criterion V, as implemented by the CP&L accepted QA program (FSAR Chapter 17.2), requires that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Procedures were not followed for welding and inspection of welds on Detail G cable tray support connections as described below'.
(1)
CP&L Procedure Number MP-08, General Welding Procedure for Structural Steel and Hangers, requires craft to complete fillet welds to the size specified on the drawings.
Contrary to these requirements, 49 of 54 3/8 inch fillet welds required by field modification FM-C-CAR-2168-G-251-S01 (Detail G) R-l, on the Detail G
cable tray support connections were undersized.
(2)
CP&L Procedure QCI-18.1, Seismic Structural Steel Inspection and Documentation
- System, requires the QA/QC inspectors to verify weld size and length is in accordance with drawing requirements.
Contrary to this requirement, licensee welding QA/QC inspectors failed to identify the undersized 3/8 inch fillet welds on the Detail G cable tray support connections.
The undersized welds had been inspected and accepted by the QA/QC inspectors.
This is a Severity Level IV violation (Supplement II)~
Denial or Admission and Reason for The Violation'.
The violations are correct as stated.
(1)
The craftsmen involved failed to provide acceptable weld profile for the identified welds during the period of March thru May, 1986.
It should be noted that the subject connections (Detail G) as designed and installed were inherently difficult to perform rework on as was required by Field Modification FM-C-9108.
(2)
QC Inspectors failed to identify the noted weld deficiencies of undersized welds.
While this should not have happened, two factors led to the QC acceptance of the undersized welds.
The first factor involves the inspection difficulty and interpretation of the specified weld design on the Detail G, Revision l.
MEM/HO-8704520/PAGE 2/Osl
Denial or Admission and Reason for The Violation.'(continued)
The weld design increased the size of the weld to the same thickness of the base material (angle iron) which made the weld inspection to be more of a judgement call than a standard weld design.
Also, the statement on the weld symbol to "build weld out to full throat" may have not been consistently interpreted.
The second factor was the support configurations and clearances on which these welds were made restricted the inspector's visual accessibility to the welds and restricted the use of the standard fillet weld gauges.
The combination of these two factors is believed to have led the inspectors to accept welds that appeared to have been welded up as much as possible and yet were found to be undersized when actually measured.
Nonconformance Report NCR-87-014 was issued to resolve this violation.
Corrective Ste s Taken and Results Achieved:
Site Nonconformance Reports OP-86-0149 and OP-86-0163 were issued as a result of reverification of the FM-C-9108 Detail 'G'onnections.
Hardware problems have been corrected by rework or have been "accepted"as"is" based on engineering evaluation.
(2)
A sample review of involved inspectors'upervisory audits was conducted to determine the need for additional corrective action.
This review indicated that the inspectors were satisfactorily performing weld inspections.
Corrective Ste s Taken to Avoid Further Noncom liance:
Investigation of NCR OP-86-0149 and OP-86-0163 revealed that craft welders responsible for the connections identified, are no longer employed at this project.
To ensure adequate preventive measures a training session has been conducted for all remaining craft welders.
This class emphasized the acceptance criteria. for structural welds in addition to other welding program attributes.
(2)
The involved inspectors are no longer on site.
A training class was conducted on April 29, 1987, which included QC weld inspection personnel to alert them to the problems identified in NCR 87-014.
Date When Full Com liance Was Achieved:
Full compliance was achieved on April 29, 1987.
MEM/HO-8704520/PAGE 3/Osl