ML18017B284

Forwards Position Re Variances W/Ansi N45.2.2 Per IE Insp on 800428-0502.Position Meets Overall Intent of Prescribed Qa. Util Will Continue Current Practices Pending Branch Review

ML18017B284
Person / Time
Site:	Harris
Issue date:	11/10/1980
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8011140431
Download: ML18017B284 (14)

Text

REGUL'ATOR~INFORMATION DISTRIBUTION QgTEM (RIDS)

ACCESSION NBR:8011140431 DOC DATE: 80/11/10 NOTARIZED:

NO FACIL:50-400 Shearon Harris Nuclear Power Plantg Unit ir Carol jna 50-401 Sheafon Harris Nuclear Power Planti Unit 2p Caroljna 50-402 Shear on Harris Nuc.lear Power Plant~

Unit 3r Carolina 50-403 Shearon Harris Nuclear Power Planti Unit 4i Carol..ina AUTH ~ NAME AUTHOR AFFILIATION MCDUFFIE<M,A, Carolina Power L Light Co.

RECIP,NAME, RECIPIENT-AFFILIATION DENTONrH.R.

Office of Nuclear Reactor Regulationg Director 0500040 0

01 05000402 05000403

SUBJECT:

Forwards position re variances w/ANSI N45.2 '

per IE insp on, 800428-0502.Position meets overall intent of prescribed QA.

Util will continue current practices pending branch review,,

DISTRIBUTION CODE:

B001S COPIES RECEIVED:LTR ENCL ~

SIZE:

TITLE: PSAR/FSAR AMDTS and Related Correspondence NOTES:

RECIPIENT ID CODE/NAME ACTION!

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INTERNAL: ACCID EVALI BR26 CHEM ENG BR 08 CORE PERF BR 10 EMERG PREP 2?

GEOSCIENCES HYD/GEO BR 15 ILE 06 LIC QUAL BR MECH ENG BR 18 NRC PDR 02 OP LIC BR PROC/TST REV 20 RA SSESS BR22 REG IL 01 S

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RECIPIENT>>

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NILSONpJERRY 04 AUX SYS BR 07 CONT SYS BR 09 EFF TR SYS BR12 EQUIP QUAL: BR13 HUM FACT ENGi BR I8C SYS BR 16 LIC-. GUID BR i>>IATL, ENG BR 17 i4IP A OELD POWER SYS BR 19 QA BR 21 REAC SYS BR 23 SIT ANAL BR 24 SYS INTERAC, BR COPIES LTTR ENCL 1

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EXTERNAL: ACRS NSIC 27 05 ie 1

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1 NOY 1 7 1980 TOTAL NUMBER OF>> COPIES REQUIRED:

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I gK00g Carolina Power & Light Company November 10, 1980

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,cpgymi 8 PH I~ ~tl Mr. Harold R. Denton, Directox Office of Nuclear Reactor Regulation United States Nucleax Regulatory Commission Washington, D. C.

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'3'5"',"03I SEAV3CES

'.:".,',><Cr3 SHEARON HARRIS NUCLEAR POWER PLANT~ UNIT NOS ~

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2 j 3 p AND 4 DOCKET NOS ~

50 400~

50 401 ~

50 402~

AND 50 403

~ VARIANCES WITH ANSL N45 2.2

Dear Mr. Denton:

As a result of an inspection conducted by Mr. V. L. Brownlee of the USNRC Region IX ofHce on April 28 through May 2, 1980, inspector followup Item 400/80-12-10; 400/402/403/80-10-10 was identified.

The inspector followup item set forth that Carolina Power

& Light Company's (CP&L) activit1es at the Shearon Harris Nuclear Power Plant (SHNPP) were not 1n complete agreement with ANSX N45.2.2 as required by Section 1.8 of the SHNPP Preliminary Safety Analysis Report (PSAR) ~

This letter and attachment amplify CP&L's position on ANSX N45.2.2 that was discussed with Mr. Brownlee dur1ng his inspection visit.

Carolina Power

& Light Company believes that the position described in the attachment to this letter meets the overall intent of quality assurance prescribed by ANSI N45.2.2.

CP&L will continue current practices pending NRR Quality Assurance Branch's review.

staff.

If you have any quest1ons on this subject, please contact our Yours very truly, MAM/pfb (N//1)

Attachment cc:

Mr. J.

P. O'Reilly (NRC-IX)

M. A. McDuffie Senior Vice President Engineering

& Construct1on 411 Fayetteville Street o P. 0. Box 1551 o Raleigh, N. C. 27602

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SHEARON HARRIS NUCLEAR POWER PLANT CP&L S POSITION ON ANSI N45o 2e 2 INTRODUCTION No specific requirements are contained in this section and hence no clarifications or exceptions are identified.

21 2.1 GENERAL REQUIREMENTS Planning No clarifications or exceptions identified.

24 2 Procedures and Instructions No clarifications or exceptions identified.

20 3 Results The full requirements of this paragraph shall apply to the inspections and tests (QA/QC) that are performed to determine the acceptabil1ty of product quality; whereas the checking of secondary conditions such as warehouse temperature and humidity, inert gas blankets, rotation, lubrication, etc. are considered maintenance functions and need to be documented only to the extent necessary (checker,

date, and results) that, through QA surveillance and review, will provide assurance that an adequate maintenance system is in effect.

2.4 Personnel Qualificat1ons Those personnel that perform inspection, examination, and testing activities for verification and acceptance/

rejection purposes (QA/QC) for permanent plant items shall be qualified in accordance with N45.2.6 (except as amended by the safety analysis report position).

Those personnel engaged in checking of secondary conditions (discussed in 2.3 above) shall be adequately trained to perform the function, though training records will not be required.

Those personnel engaged in checking of product quality character1stics, such as periodic meggering, and lifting equipment inspection (less NDE), shall be adequately trained for the function and training records shall be maintained.

All these personnel shall be familiar with the tools and equipment to be employed and shall have demonstrated profic1ency in their use.

2 ~ 5 Measur1ng and Test Equipment (2.5.2)

That equipment which measures qual1ty of the permanent plant items shall be under the calibration and control program; whereas the equipment used to measure secondary conditions, such as warehouse temperature, humidity, etc., will be maintained in good working order and checked for proper functioning when accuracy is in doubt, but not maintained under the calibration and control program.

Traceability to calibration records will be provided when it is impractical (because of size, conf1guration or application) to physically mark calibration information on the item.

2. 6 Housekeeping The warehouse storage areas will be declared Zone IV in accordance with ANSI N45.2.3, and eating will be limited to designated areas.

Signs will be posted 1n these areas accordingly.

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2. 7 30 3.1 ClassiQcation of Items No clarifications or exceptions identified.

PACKAGING General No clarifications or exceptions identified.

3 ~ 2 Levels of Packaging Site packaging for shipment off-site will be equal to or exceed the original packaging by the vendor, as required to assure the quality of the item is not degraded as a result of site shipping or handling.

Vendor packaging with regard to barrier, containers, and crates will be maintained by the site provided that such packaging does not interfere with storage maintenance and/or that items are stored in an area where deleterious effects of shock, vibration, physical damage, water vapor, salt-spray, condensation, and weather are avoided.

3.3 3.4 Cleaning No clarifications or exceptions identif.ed.

Methods of Preservation No clarifications or exceptions identified.

3. 5 Caps'lugs, Tapes and Adhesives No clariQcations or exceptions identified.

'f 3.6 Barrier and Wrap Materials and Desiccants - The use of 'clear plastic in warehouses will be minimized.

The guide rule is that the clear plastic shall be used only where periodic visual inspection is necessary.

Plastic wrap on items supplied in accordance with a vendor's approved QA/QC program will be accepted and stored without re wra pping at the site.

On site storage protection will include the use of vinyl wrap materials due to the excellent fire retardant properties and availability.

These materials contain halogenated compounds but leave only trace amounts of residuals under postulated exposures to sun, rain, etc.

Therefore, they will not be prohibited from use on austenetic stainless steel products.

3. 7 Containers, Crating and Skids No clarifications or exceptions identified.

3. 8 Cushioning, Blocking, Bracing and Anchoring No clarifications or exceptions identified.

3. 9 4,

Marking No clarifications or exceptions identified.

SHIPPING Requirements of Section 4, Shipping, primarily applies to the vendor.

Site functions with regard to return shipments will meet or exceed the methods of the vendor for the item.

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5.1 RECEIVING General No clarifications or exceptions identified.

50 2 Receiving Inspection Requirements Preliminary visual inspection will be performed prior to unloading, where practical,

however, the receiving inspection of record will be performed in the 'unloading area.

Item inspection will be performed in an area equivalent to the required storage level; except that temperature, humidity and airborne contamination controls will not be in effect during the inspection of items designated for Level B storage.

5. 2. 2(1) Identification and Marking Item 1nspection will include inspection for identif1cation and marking required by the purchase order documents.

Marking that 1s.not quality related or which provides no traceability vill not be inspected.

5.3.1 Acceptable Item acceptance status will be indicated by application of tags,

stickers, ribbons, or signs.

Storage areas are not designated as accept areas except for bulk 1tems (e.g. rebar, structural steel, aggregate, etc.).

5t 302 Nonconforming Segregation will be accomplished where practical, or where necessary to control the inadvertent use of the item.

Otherwise, the use of tags, stickers, ribbons, or signs vill be so conspicuous as to imply segregation.

5.6 Marking The clarifications and exceptions discussed in 5.2.2(1),

identification and marking, apply to this paragraph.

5e 7 Documentation Receiving 1nspection records will prov1de traceability to the item and its status.

Superfluous 1dentification and tagging will not be recorded except when they are the subject of a nonconformance or specifically required by site inspection procedures.

6.

6.1 S TORA'GE General No clarificat1ons or exceptions identif1ed.

6. lo 1 Scope The levels and methods of storage for items between the time of removal from the prescribed storage until placement in the installed location may be relaxed for short periods of time, according to the sensitivity of the 1tem being handled and the elements of contact anticipated during this interval.

Where relaxation of storage requirements of this standard are deemed a ppropriate, the item, conditions, precautions and follow-up inspection for assurance that quality of the 1tem has been mainta1ned will be prescribed in project procedures.

(Example l.

A motor may be removed from Level B storage and moved via open-bed trailer and lift1ng cranes to the 1nstalled location.

The relocation will not be permitted during inclement weather, with the motor unprotected, and the transfer vill be completed in two days.

Following installat1on the prescribed storage environment will be restored and the motor

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subjected to inspection to verify that there was no degradation of qual1ty during handling.

Example 2.

Reinforcing steel bars, shapes and outdoor equipment may be handled in staging areas without providing the level of protect1on from damage, trapping of water or loss of air circulation normally provided in a Level D

storage area.

The bars, shapes and equipment will not be allowed to rema1n in the staging area more than one week without providing the normal protection of Level D storage.

During or following installat1on, the items will be subjected to inspection to verify that there was no degradation of quality during handling).

Once the item is installed, the prescribed storage environment will be maintained except where prohibited by the type of work in progress (e.g.

end covers and purges removed to accommodate installation activities).

6.2.4 Storage of Food and Associated Items The use of food, drinks, and salt tablets will be permitted in areas adjacent to storage areas (e.g.

the warehouse office area).

Warehouse storage areas will be posted to prohibit eating and drinking except in designated areas.

6.3.5 Coverings The clarif1cations and exceptions discussed in Paragraph 3.6, Barrier and Wrap Materials and Desiccants, apply to this paragraph.

6. 4.1 Inspections and Examinations QA surveillance of storage conditions and stored items 1s performed on a periodic basis to assure that storage ma1ntenance personnel are perform1ng and documenting the checks required by this paragraph.

6. 4.2 Care of Items Energizing space heaters (5) and rotation of shafts (7) will be performed as recommended.

by the manufacturer of the item.

Other maintenance requirements specified by the manufacturer (8) may be relaxed following engineering evaluat1on of the item, the requirements and the anticipated results (e.g.

A heat exchanger may be downgraded to Level D storage 1n 11eu of Level C imposed by the vendor '

in s truction).

6. 5

6. 6 70 7.1 7.2 Removal of Items From Storage The clarifications and exceptions d1scussed in other paragraphs of Section 6, Storage, apply to this paragraph as appropriate.

I Storage Records No clarifications or except1ons identified.

HANDLING General No clarifica tions or exce ptions identified.

Methods and Procedures No clarifications or exceptions identified.

7 ~ 3 Hoisting Equipment - The load chart for each crane includes the model number for that crane.

This load chart is considered to be "Certificat1on" by the manufacturer for that crane as required by paragraph

7. 3. l.

Likewise, forklifts are considered certified

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by the manufacturer's literature giv1ng maximum capacity as required by paragraph

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7.4 Inspection of Equipment and Rigging Nondestructive examinat1ons, witnessing of load tests and surveillance of operator maintenance 1nspections will be performed by QA/gC personnel qualif1ed in accordance with ANSI N45.2. 6 (except as amended by safety analysis report position).

Operators will be trained in the operation and maintenance inspections of their assigned equipment.

7. 5 Personnel The responsible organization includes any contractor under contract to CP6L to perform general or special hoisting and lifting operations.

8.

RECORDS No clarification or exceptions ident1f1ed.

9.

STANDARDS, ETC.

No clarifications or exceptions 1dentified.

APPENDIX A.3 PACKAGING A.3. 5. 1 Caps and Plugs; A. 3. 5. 2, Tapes and Adhesives; and A.3. 6. 3, Desiccants

Plugs, caps,

tapes, adhesives, desiccants, markers and other temporary items will be of premium commercial quality.

Permissible levels for halogens, sulfur, chlorides, low melting point metals, etc. for use on stainless steel and nickel alloy surfaces during the 1nstallation process will be held to minimum values within the limits of commercial availability of the products, and as prov1ded for in the pro)ect procedures.

Post-installation cleaning and inspection procedures will be implemented to ensure harmful levels of contaminants are removed pr1or to system operation.

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