ML18017B636
| ML18017B636 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/12/1982 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B635 | List: |
| References | |
| CQAD-82-442, NUDOCS 8204010126 | |
| Download: ML18017B636 (7) | |
Text
tl Carolina Power & Light ColInpanpi March 12, 1982, gP yI,P,H
<IO: 5II CQAD 82-442 Mr. James P. O'Reilly United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 Dear Mr. O'Reilly'.
This letter is in reference to your letter of January 18, 1982 referring to Inspection Report 50-400/401/402/403/81-25 for the Shearon Harris Nuclear Power Plant.
Attached is Carolina Power 6 Light Company's second response to deficiencies identified in Appendix A of the Inspection Report.
This response supplements and clarifies our response of February 17, 1982.
~gH H. R. Banks Manager Corporate Quality Assurance NJC/mt Attachment cc:
Mr. J. A. Jones Sworn to and subscribed before me this 12th day of March, 1982.
Notary Public My commission expires:
Date 8204010i26 820325 PDR ADOCK.05000400 8
PDR 411 Fayetteville Street o P. O. Box 1551 o Raleigh, N. C. 27602
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(SECOND
RESPONSE
SUPPLEMENTING RESPONSE OF FEBRUARY 17, 1982 r
SEVERITY LEVEL V VIOLATIONS A.
- 10CFR50, Appendix B, Criterion ZV as implemented by CP&L PSAR section 1.8.5.15; CP&L Corporate QA Program section 15 '.3 and construction procedure CQC-2, section 4.2 and 4.3 require that nonconforming conditions be identified and corrected.
Contrary to the above, on December 8,
1981 three nonconforming welded conditions were found that had not been identified previously by CP&L or the material supplier.
One undersized fillet weld was found on cable tray support section A (a supplier weld),
one separation crack was found on a weld on cable tray support CD-2616 (a shop weld) and the field-applied tack welds had not been removed from or authorized to remain on cable tray support CD-2618.
Each of these three nonconforming welded conditions were r'elated to installed and accepted seismic I electrical cable tray supports located in the auxiliary building at about elevation 276'.
B.
10CFR50, Appendix B, Criterion IX as implemented by CP&L PSAR section 1.8.5.9; CP&L Corporate QA program section 8.4.l.d and construction procedure MP-08, section 4.10.2 and AW-1 require that special processes such as welding be accomplished in accordance with applicable codes or standards.
The applicable welding code for seismic I electrical cable tray supports is AWS-D1.1-1975, section 9.
Contrary to the above, on December 8,
- 1981, a field-applied welded "Lap Joint" on electrical cable tray support identified as CD-2618, was found not to have the minimum overlap that AWS-D1.1-1975, section 9.10 requires.
Instead of the required five times the thickness of the base
- metal, the overlap was only four times the thickness of the base metal.
Denial or Admission and Reasons for Violation:
A.
The conditions did exist as identified in the Notice of Violation; The actual cause of the separation crack could not be determined and the undersized fillet weld was due to poor vendor workmanship.
Failure to remove the tack welds was due to weld inspector ovexsight.
B.
The violation is not correct as stated.
- However, subsequent reinspections have identified electrical cable tray supports that have been fabricated and accepted which do not meet the requirements of design and erection drawings.
The reinspection and evaluation of these welded connections are not complete at this time, however, the design conservation of requiring a
minimum 1" overlap on the shortest overlapping side of the angle braces is expected to provide the required'esign margin.
This condition exists for both shop welded connections and field welded connections.
Site Deficiency and Disposition Report No.
746 as well as the NRC violation incorrectly assumed that the welded connections in question were "Lap Joints" and that AWS-D1.1-1975 section 9.10 was the design criteria.
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The applicable project specification is CAR-SH-AS-7 which
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invokes AISC "Specification for the Design, Fabrication and Erection of Structural Steel for Building", (Seventh Edition) ~
AISC paragraph 1.17.7 is the correct design reference for the minimum effective length of a strength fillet weld and requires a minimum effective length of "4 times the nominal size" of the weld.
The intersection of structural shapes such as angles to form welded connections are not "Lap Joints" as defined in AWS-D1.1-1975, section 9.10 or *AISC paragraph 1.17.9.
-.For a definition of "Lap Joints" refer to AWS-D1.1-1981 commentary paragraph 9.10.1 which refers to figure C8.8.3 for examples of "Lap Joints".
This 'clarification was reviewed in detail with the Resident NRC Inspector on March 9, 1982.
The cause, as stated in our initial response, was a combination of detailing methods, pre-cut lengths, as built locations and lack of the required attention to detail by fabrication and inspection personnel.
Corrective Ste s Taken and Results Achieved:
A.
Deficiency and Disposition Report number 748 was issued on December 10, 1981, for control and resolution of the v'endor items with the separation crack and the undersized fillet weld.
Nonconformance Report number W-256 was issued to resolve the tack weld item.
The undersized fillet weld and the separation crack on the cable tray support were repaired.
The deficient welds were ground out and the items were rewelded The tack welds were ground out and removed.
B.
A reinspection of shop and field welded connections on installed cable tray and HVAC supports is in progress to verify that minimum effective lengths of strength fillet welds are in accordance with design drawings or evaluted by the responsible design engineers and verified to have the required design margin for the configuration and design load.
Corrective Ste s Taken to Avoid Further Noncom liance:
A.
A program has been implemented whereby CPSL QC Receiving Inspection will verify that nuclear safety-related items received under an Ebasco or Westinghouse Quality Release meet the requirements of the applicable'rocurement documents.
These inspections will be based on a statistical samplin'g and shall be accomplished in accordance with the QC Procedures.
Characteristics to be verified shall include the following, as appropriate:
physical properties, dimensions, weld preparations, workmanship and welding, lubricants, oils and electrical insulation.
Procedure
'CQC-19 has been revised to insure that inspectors pay special attention to the removal of tack welds on the back side of members welded.
Written instructions were issued on January ll, 1982, by memorandum to the Warehouse Supervisor and the Iron Worker Superintendent to exercise care when handling cable tray support hangers to prevent possible damage.
Instructions were also given to report accidentally dropped or damaged items to a QA inspector or the discipline engineer.
The vendor was contacted on December 16,
- 1981, and agreed to emphasize a
more strenuous inspection in areas of handling, porosity, undersized, undercut and cracked shopwelds.
Reinspections of shopwelds on cable tray steel supports and HVAC steel supports supplied by Peden Steel Company which are installed have been conducted on a sampling basis and the results are under evaluation by CP&L engineering,
- Ebasco, and Peden Steel Company.
There have been a number of various welding deficiencies identified during reinspections, but to date engineering evaluations have shown that the deficiencies are not of the severity required to reduce the design margin below an acceptable level.
Reinspections and engineering evaluations will continue until all installed supports are verified to meet project design requirements.
Management actions are being taken to ensure Peden Steel Company fabrication and inspection practices are promptly upgraded as required to ensure project requirements are met.
B.
The QA inspectors have been instructed to inspect for the required effective length of strength fillet welds for welded connections.
Likewise, the field crafts have been instructed to give more attention to this detail.
Field Change Request AS-1048 requires a minimum effective length for strength fillet welds on these connections to be 1" on the shortest side.
Date When Full Com liance Will Be Achieved:
A.
Full compliance is expected to be achieved be the time required to reinspect previous actions necessary to verify acceptability.
compliance.
by August 15, 1982.
This will work of this type and take New work is preceeding in full B.
Full compliance will be achieved by May 1, 1982.
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