ML18017B234
| ML18017B234 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/19/1980 |
| From: | Howe P CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B233 | List: |
| References | |
| NUDOCS 8009250351 | |
| Download: ML18017B234 (4) | |
Text
g)QL Carolina Power & Light Company
- Raleigh, N. C. 27602 August 19, 1980 Mr. James P. O'Reilly United States Regulatory Commission Region II 101 Marietta Str eet, Northwest Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of July 25, 1980, referring to RIIt WPK 50-400/80-15, 50-401/80-13, 50-402/80-13, 50-403/80-13, the attached is Carolina Power 8 Light Company's reply to the deficiencies identified in Appendix A. It is considered that the corrective and preventive actions taken are satisfactory for reso-lution of these items.
O Thank you for your consideration in this matter.
Yours very truly,
~ Q~~
W Howe Vice President Technical Services NJC:lm Attachment cc:
Mr. J.
A. Jones
t' f
1 t
INFRACTION Condition Reported:
A.
As required by Paragraph (a)
(1) of 10 CFR 50.55a, "Structures,...
shall be...constructed,
- tested, and inspected to quality standards commensurate with the importance of the safety function'...."
For containment spray system hangers this requirement is implemented by Ebasco Specification AS-07 Revision 10 "Structural Steel",which requires welding to be accomplished in accordance with AMS D-1.1-77.
AWS D1.1-7'7 requires that undercut be no more than 1/32-inch deep.
For containment spray system attachments this requirement is implemented by Ebasco Specification M-30 Revision 10A, which requires that welding be accomplished in accordance with Article NC-4000 (71S) of Section III of the ASME Code.
Paragraph NB-4424, as referenced by NC-4000, requires that undercut shall not reduce material thickn'ess below the required minimum.
Contrary to the above, on March 24 to 26, 1980 the following examples were noted:
1.
The RH vertical weld of clip to pad joint (hanger 1-CT-H-7 and Pad 65C3 on drawing CBRI-65 Rev. 3) exhibited undercut in excess of 1/32" deep.
2.
The top trunnion attachment
- weld, on Bergen Paterson Drawing 1-CT-11-71 and Southwest Fabrication Drawing 1-CT-5-1, exhibited undercut that reduced the material thickness below the required minimum.
B.
As required by Criterion V of Appendix B to 10 CFR 50, and as implemented by Carolina Power
& Light PSAR Section 1.8.5.5, "Activities affecting quality shall be prescribed by documented instructions, procedures or drawings and shall be accomplished in accordance with these instructions, procedures or drawings."
Shearon Harris Procedure AP-X-01, Revision 0, "Temporary Storage of Reinforcing Steel.and Embeds" requires reinforcing steel to be maintained in Level D storage.
Shearon Harris Procedure AP-XIII-05, Revision 8 "Material Storage" requires Level D stored items to be on dunnage to allow air circulation and to minimize trapped water.
Contrary to the above, on June 24, 1980, in the excavated area north of the power block, there were in excess of seventy-five examples of reinforcing steel in the mud.
Corrective Ste s Taken and Results Achieved:
A. 1.
The nonconforming condition listed in the Notice of Violation was reported in Deficiency and Disposition Report No. 382 for purposes of control and resolution.
The responsible contractor was notified of the discrepancy and promptly corrected it.
The undercut area on hanger 1-CT-H-7 has been rewelded and inspected in accordance with their procedure 2.
The nonconforming condition listed in the Notice of Violation was reported in Deficiency and Disposition Report No. 379 for purposes of control and resolution.
INFRACTION Page 2
The subject item deals with a trunnion attachment weld that is not part of the pressure boundary.
The concern with the trunnion resulted when the piping fabricator attempted to provide additional reinforcement on the inside of the trunnion to pipe weld.
To meet the material specification requirements, repairs were made to the extra weld.
All other similar trunnions were examinea.
No additional repairs were found to be necessary.
B.
The Construction Manager was informed of this infraction and a request was submitted by CP&L site management to immediately correct the problem.
The Contractor subsequently placed all reinforcing steel that was not stored in accordance with Administrative Procedures AP-X-01, Revision 0 and AP-XIII-05, Revision 8 on adequate dunnage such that the noncon-forming reinforcing bars were no longer in contact with mud or water.
The bars are now in conformance with applicable Level D, storage re-quirements.
Corrective Steps Taken to Avoid Fur ther Noncompliance:
A.1.
The contractor completed a thorough re-inspection of similar weld-ments in the dome and found no other such deficiencies.
This item was an isolated incident.
A.2.
This item was an isolated incident.
The concern deals with additional reinforcement on the inside of the trunnion to pipe weld.
Quality Assurance personnel at the fabricator's facility and at the site have been made aware of this concern.
The fabricator has been re-minded of the need to monitor this type of weld to prevent further deficiencies of this nature.
Site QA personnel have also been alerted to check this type of trunnion for internal weld problems.
B.
Administrative Procedure AP-XIII-06, titled "Project Housekeeping",
has been revised such that the responsible Area Superintendent will now be held accountable for all housekeeping zones in his area.
This will insure that reinforcing steel housekeeping will be more closely scrutinized as the total volume of bars will now bethe responsibility of several people initmately associated with his own area ratner tnan tne former system of one responsible craft superintendent for the total volume of housekeeping.
Date When Full Compliance Will be Achieved:
A.1.
Full compliance is considered to have been achieved on May 9, 1980.
A.2.
Full compliance is considered to have been achieved on June 4, 1980.
B.
Full compliance is considered to have been achieved on August 4, 1980.