ML18018B841
| ML18018B841 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/24/1984 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML18018B842 | List: |
| References | |
| NUDOCS 8501080559 | |
| Download: ML18018B841 (10) | |
See also: IR 05000400/1984041
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UNITEDSTATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON. O. C 20555
December, 24,
1984
Oocket
No. 50-400
Carolina
Power and Light Company
ATTN:
Mr. E.
E. Utley
Executive Vice President
Power Supply .and Engineering
and Construction
P.O.
Box 1551
Raleigh, North Carolina
27602'entlemen:
SUBJECT:
Construction Appraisal
Team Inspection 50-400/84-41
Enclosed is the report of the Construction Appraisal
Team
(CAT) inspection
conducted
by the Office of Inspection
and Enforcement (IE) on October 1-12
and October
22 - November 2, 1984, at the Shearon Harris Unit 1 site.
The
Construction Appraisal
Team was
composed of members of IE,
NRC Region II,
and
a number of consultants.
The inspection
covered construction activities
authorized
by
NRC Construction Permit CPPR-158..
This inspection is the ninth of a planned series of construction appraisal
inspections
by the Office of Inspection
and Enforcement.
The results of these
inspections
are being used to evaluate
the management
control of construction
activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas
examined during the inspection.
Mithin the areas,
the effort consisted primarily of detailed inspection of
selected
hardware
subsequent
to guality Control inspections,
a review of .
selected
portions of your guality Assurance
Program,
examination of procedures
and records,. observation of work activities,
and
an examination of your project
'management.
Appendix A to this letter is an Executive
Summary of the resu1ts
of this
inspection
and of conclusions
reached
by this'office.
Hardware
and
documentation for the construction
areas
reviewed were generally
found to be
in accordance
with requirements
and commitments.
However,
hardware deficien-
cies were noted by the
NRC CAT in several
areas that will require additional
management
attention.
These
areas
include examples
of lack of required design
input for maintaining electrical separation,
non-seismic installations
in
proximity to seismic Category I hardware,
and incorrect placement of concrete
reinforcing steel.
December
24
1984
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Carolina
Power and Light Company
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Of concern to the
NRC CAT inspectors
were several
areas 'in which CP8L failed to
'address
significant problems in a timely manner.
Examples of areas
where this
'as
evident included the determination of the adequacy of non-seismic instal-
lations ovey..Seismic
Category I items
and pipe-to-pipe clearances.
The
NRC CAT
notes that heavy dependence
on walkdowns or engineering
evaluations
to iden-
tify and resolve problems late in construction
has not been successful
at other
facilities and should not be relied upon at Shearon Harris.
The
NRC team observed that there
was evidence of good project management
and
construction practices at the Shearon
Harris site.
. These
good practices
include
a capable project management
organization
.the fact that site engineer
ing and inspection activities are primarily located
and controlled on-site
and
the extensive
use of field engineers
for problem resolution.
e
Appendix
B to this 'letter contains a'list of potential
enforcement
actions
based
on the 'NRC CAT inspection observations.
These are being reviewed by the
Office of Inspection
and Enforcement
and the
NRC Region II Office for appro-
priate action.
In addition,
Region IE will be following your corrective action
for deficiencies identified during this inspection.
In accordance
with 10 CFR 2.790(a) a copy of this letter and the enclosures
are being placed in the, Public Gocument
Room.
No reply to this letter is
required at this time.
However, you will be required to respond
to these
findings, including your plan and schedule for corrective actions, after a
decision is made regarding appropriate
enforcement action.
. Should you have any questions
concerning this inspection,
please
contact
us or
the Region II Office.
Sincer ely,
Richard C./be oung,
0
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Office of Qn pection and Enforcement
Encl osures:
1.
Appendix
A - Executive
Summary
2.
Appendix
B - Potential
Enforcement Actions
3.
Inspection
Report
cc w/enclosures;
See next page
December
24
1984
Carolina Power and Light Company
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cc w/enclosures:
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R.
A. Watson,
Vice President
Harris Nuclear Project
Carolina Power and Light Company
P.O.
Box 165
New Hill, NC
27562
R.
M. Parsons,
Completion Assurance
Manager
Carolina Power and Light Company
P.O.
Box
1.01
New Hill, NC
27562
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APPENDIX A
EXECUTIVE SUMMARY
An announced
Construction Appraisal
Team
(CAT) inspection
was conducted at the
Shearon Harris site during the period October 1-12 and October
22 - November
2, 1984.
Overall Conclusions
Hardware
and documentation for piping, pipe supports/restraints,
HVAC,
structural
steel
(including welding and nondestructive
examination in these
areas)
and
dams
and dikes were generally found to be in accordance
with
requirements
and commitments.
However, the team did identify the following
construction
program weaknesses
that require management
attention:
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1. 'onflicts were identified between
design inputs
and
FSAR commitments
with regard to electrical cable
and raceway separation
which resulted
in separation
deficiencies.
2.
Hardware discrepancies
were found in non-seismic
items installed over
Seismic Category I items.
Failure of these discrepant
non-seismic
.items could adversely affect Class
1E electrical
components.
3.
Deficiencies identified in the area of interdisciplinary and pipe to
pipe clearances
indicated that the"-identification and resolution of
these
interferences
were not being effectively addressed.
The
NRC CAT team considered
the direct involvement and control
by CP8L in
design engineering
and the extensive
use of field engineers
to identify and
resolve problems to be positive aspects
of the Shearon
Harris const uction
program.
Electrical
and Instrumentation
The majority of the electrical
and instrumentation
samples
examined
met the
appropriate
design
and construction
requirements.
The applicant
s program for
inspection of construction activities and maintenance
of Class
1E electrical
equipment appears
to be effective.
Construction
and design deficiencies
were
identified in several
areas
including some items which will require additional
NRC review..
Some design
documents,
which specify separation
c~-teria for electrical
raceway installation, deviate
from FSAR commitments.
As a result,
numerous
installations'xist
where the required separation
between
Non-Class
1E and
Class
1E raceway
components
have not been maintained.
Because of numerous identified hardware deficiencies
in non-seismic
raceway
supports, their. possible failure.may adversely affect the ability of nearby
Class lE electrical components'o'erform
intended safety functions.
The corrective actions
being taken
by the applicant concerning
problems associ-
ated with instrumentation
appear to be adquate
although final actions
and
approvals
were not completed-at--the--time-of
the
NRC CAT i'nspection.
Mechanical
Construction
Piping, pipe supports/restraints,
concrete
expansion
anchors
and
HYAC supports/
restraints
were generally
found to be in accordance
with applicable
drawings
and
requirements.
Oiscrepancies
were identified with mechanical
equipment founda-
tion fasteners
and sliding end installations.
Noted deficiencies of undersized
wall thickness
in field purchased
piping indicates that the inspection
and
surveillance effort in this area requires
increased
management
attention.
Programmatic
concerns
were noted in two areas:
(1) lack of verification of
piping and pipe support/restraint
location to original design requirements
and,
(2) lack of an ongoing program to effectively identify and resolve
hardware
clearance
problems early in the construction process.
Both of these
concerns
involve practices that could result. in extensive
inspection,
analyses
and
rework efforts very late in the construction
schedule.
Weldin
and Nondestructive
Examination
Melding and nondestructive
examination activities were generally found to be
conducted in accordance
with the .governing codes
and specifications.
Few
deficiencies
were identified by the
NRC CAT inspectors
in this area.
However,
a number- of examples
were identified where vendor supplied tanks did not meet
the design requirements
for nozzle to shell weld reinforcement,
and
some of
the. tanks support welds were undersized.
In the area of NOE, several
irregular-
ities involving film quality were identified
However, the finished welds were
found to be acceptable.
Civil and Structural Construction
Construction quality and concrete material certification were in general
found
'to be acceptable.
However, three areas
were identified where the reinforcing
steel
had not been placed in accordance
with the design drawings.
.An area of improper concrete consolidation
was identified in one of the
beams
in the Reactor Auxiliary Building.
After chipping out the concrete in this
area,
a void was identified above the
embedded plate
and
one layer of the
bottom reinforcement
lapped at this location was placed to one side of the
beam
instead of being distributed across
the bottom of the
beam.
A number of non-seismic electrical
system
components
located 'over seismically
qualified
systems'
-w ich are supported
by unmarked concrete
expansion bolts were
identified.
Subsequent
ultrasonic testing indicated that the anchor bolt
embedment
lengths
were 'as low as
1< inches.
Also, tension
and shear tests
performed by CPEL personnel
indicate that the factors of safety are approxi-
mately 50K of recommended
values.
A-2
Material Traceabil it
and Controls
In general,
the project. material traceability and control program was found to.-
be acceptable.
Problems
were identified regarding traceabil ity of fastener
materials,
including large anchor bolts and equipment mounting bolts
and nuts.
It was noted that both the applicant
and the
NRC Region II had previously
identified such deficiencies
and corrective actions
were in progress
by the
applicant.
Desi
n Chan
e Control
Design change control, including control of changes
to design
documents,
was
determined to be generally in conformance with applicable
requirements.
A
number of minor, non-generic
discrepancies
were identified,
none of which are
considered significant.
In the area of document
change control, the most
significant finding was the numerous
unincorporated
changes
affecting many
documents.
The most significant finding in the area of design
change control
is that
some analyses
and other backup documentation for field changes
.have not
been designated
as quality .assurance
records.
Corrective Action 5 stems
In general
the applicant's
corrective action program
was found to be accept-
able.
However, it was evident that the scope
and quality of audit activities
regarding nondestructive
examination of welding were deficient and should
be improved.
The applicant stated that improvements
were. planned in this .
area.
Pro ect Mana ement
Project Management
personnel
and organization
'appear to be adequate
to assure
that. construction
and startup activities will meet quality requirements.
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APPENDIX B
'OTENTIAL ENFORCEMENT ACTIONS.
As a result of the
NRC CAT inspe0tion of October 1-12 and October 22-November
2, 1984, the following items
have
been referred to
NRC Region II as Potential
Enforcement Actions-(section-references- are-tahe -detailed portion of the
inspection report):
1.
Contrary to 10 CFR 50, Appendix B, Criterion III and the
CP8L
SHNPP
FSAR,
Design Control
has not been maintained in ghat the applicant
has failed to
assure that applicable regulatory requirements
for separation
of Class
1E
and Non-Class
lE electrical
raceway
components
are correctly translated
into specifications,
drawings,
procedures
and instructions
(Sections
II.B.1 and II.B.2).
2.
Contrary to 10. CFR 50, appendix
B, Criterion V, the applicanthas
failed
to install reinforcing steel
to the tolerances
shown on the. design
drawing and specifications
in that:
a)
The top reinforcing steel
in beam 55-L-KZ in the Fuel Handling
Building was installed
1~< inch lower than
shown
on the rebar place-
ment. drawing and was not identified during the inspection of the
reinforcing stee'i
placement
(Section V.B.1).
b)
The bottom stee'i
on beam
38 between
column line FZ and the exterior
wall in the Reactor Auxiliary Building was placed
on one side of the
beam instead of being distributed across
the bottom of the
beam
(Section V.B.1).
3.
Contrary to 10 CFR 50, Appendix B, Criterion VII and the Shearon Harris
Plant
FSAR, Chapter 17, the program. for the control of purchased
materials affecting quality was not effectively implemented to assure
that. purchased
piping was in conformance with specified acceptance
criteria and requirements
for pipe wall thickness
(Section III.B.1).
Contrary to 10 CFR 50, Appendix B, Criterion
X and the Shearon Harris
Plant
FSAR, Chapter 17, the program for inspection of activities
affecting quality was not effectively implemented in that inspection
programs did not assure that equipment foundation connections
were
installed in accordance
with specified acceptance
criteria and
requirements
(Section III.B.5).
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