ML18017B133

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Responds to NRC Re Violation Noted in IE Insp Repts 50-400/80-11,50-401/80-08,50-402/80-08 & 50-403/80-08. Corrective Actions:Investigation Held of Collected Test Data Re Backfill Matl Affecting Category I Piping
ML18017B133
Person / Time
Site: Harris  
Issue date: 06/05/1980
From: Howe P
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18017B132 List:
References
NUDOCS 8007100418
Download: ML18017B133 (3)


Text

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CHAL Carolina Power & Light Company Jltd I.'

l: SO June 5, 1980 Mr. James P. O'Reilly United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of May 13, 1980, referring to RII:

JJL 50-400/80-11, 50-401/80-08, 50-402/80-08 and 50-403/80-08, the attached is Carolina Power and Light Company's reply to the in-fraction identified in Appendi1t A. It is considered that the corrective and preventive actions taken are satisfactory for resolution of this item.

Thank you for your cooperation in this matter.

Yours very truly, P.

M. Howe Vice President Technical Services NJC/mst cc:

Mr. J. A. Jones eoovxoo'/(tr 411 Fayetteville Street

~ P. O. Box 1551

~ Raleigh, N. C. 27602

~.if::>';It,".TAT.COPY

Condition Reporte As required by Criterion III of Appendix B to 10 CFR 50, implemented by Carolina Power and Light PSAR Section 1.8, "Measures shall be establisped to assure that applicable regulatory requirements and the design basis...

are correctly tr anslated into specifications, drawing, procedures, and instructions.

These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled".

ANSI N45.2.11, implemented by PSAR Section 1.8.1, requires design inputs, which include structural requirements such as foundations and pipe supports, to be specified to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for making design decisions.

Contrary to the above, the measures required by Criterion III failed to assure that the design inputs concerning the effect of settlement of the backfill supporting Category I piping adjacent t'o the powerblock was eval-uated in design analysis of the piping.

Omission of these design inputs could have resulted in overstressing and failure of the piping.

As a

result, the backfill supporting the piping has been or will be excavated and replaced with fillconcrete in order to provide the necessar y foundation support for the piping where it enters the powerblock.

Corrective Steps Taken and Results Achieved:

The infraction resulted since the effect of settlement of backfill which provides support for Seismic Category I piping adjacent to the plant buildings was not considered in the design of the building by the Architect Engineer.

Corrective action completed in relation to backfill material affecting Category I piping includes the following:

l.

An investigation into previously collected test data.

2.

Plan and section details added on design drawing reflecting locations of all relevant filland backfill materials affecting Category I piping and duct banks.

3.

Design data input compiled from previous results of field and laboratory tests.

4.

Theoretical estimates of settlements were researched and compiled.

5.

Assessments of the stability and dynamic behavior of the Category I pipelines and fill.

6.

A revised inspection/testing procedure to assure full compliance with realigned design criteria.

7.

Revised design drawing (Revision 2, CAR-2167-G-0488) identifying and detailing backfill adjacent to Seismic Category I buildings.

Infraction Page Two Prior to placement of any backfill material adjacent to the power block where Category I piping would span, a design drawing change was initiated to require 2,000 p.s.i. concrete fill. The concrete was placed in the ex-cavated void under the area of Category I pipes between the building concrete wall and the excavation soil/rock slope, and from the lower foundation rock to six inches below pipe invert.

Corrective Steps Taken to Avoid Further Noncompliance:

The application of concrete backfill in areas of abrupt changes in backfill depth will result in an insignificant differential of settlement and eliminate the possibility of overstressing piping.

The completed research, issue of detailed design drawing and revision to inspection/testing procedure (T.P.-02, Revision 13 and 14) is considered sufficient to preclude further concern of subject design deficiency.

Date '/hen Full Compliance Mill be Achieved:

Item is considered closed as of May 28, 1980.