ML18019A350

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Insp Rept 50-400/85-29 on 850729-0802.Violation Noted: Failure of Welders to Follow Welding Procedure Spec Wire Feed Speed Requirement While Welding on safety-related Seismic Class 1 HVAC Ductwork
ML18019A350
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 08/16/1985
From: Blake J, Kleinsorge W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18019A347 List:
References
50-400-85-29, IEB-83-06, IEB-83-07, IEB-83-6, IEB-83-7, NUDOCS 8509040178
Download: ML18019A350 (20)


See also: IR 05000400/1985029

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UNITEDSTATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.IN.

ATLANTA,GEORGIA 30323

Report No.:

50-400/85-29

Licensee:

Carolina

Power

and Light Company

P. 0.

Box 1551

Raleigh,

NC

27602

Docket No.:

50-400

Facility Name:

Harris

1

Inspection

Conduc

e

July

9 - August 2,

1985

Inspector:

ns

Approved by:

J.

a e,

ection

ie

Eng

ne ring Branch

Di is on of Reactor Safety

License No.:

CPPR-158

/3

a

igne

g

ate

igne

SUMMARY

Scope:

This routine,

unannounced

inspection entailed

42 inspector-hours

on site

in the areas of license actions

on previous enforcement matters

(927018),

house-

keeping

(54834B)

material

.identification

and control

(42902B)

and material

control

(42940B), structural

concrete

work observation

(46053), reactor coolant

pressure

boundary

piping

(49053B)

(49054B)

(49055B)

safety-related

heating,

ventilating and air conditioning

(HVAC) systems

(50100) inspector

followup items

(92701B)

and

IE Bulletin '( IEB) (92703B) .

Results:

One violation was identified - "Failure To Follow WPS Wire Feed

Speed

Requirement",

paragraph - 7b(2)(a).

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REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees

  • N. J. Chiangi, Manager, Quality Assurance/Quality

Control

(QA/QC),

Harris Plant

  • R. Hanford, Welding Manager
  • G. L. Forehand,

Director QA/QC

  • D. McGaw, Superintendent

QA

  • R. A. Somers,

CI-Superintendent

  • K. V. Hate', Principal

QA Engineer

D. T. McEwin, Resident

Engineer Heating Ventilating and Air Conditioning

(HVAC)

  • D. Whitehead,

QA Supervisor

  • J. D. Hooks, Mechanical

Supervisors

Other

licensee

employees

contacted

included

construction

craftsmen,

engineers,

technicians,

and office personnel.

NRC Resident

Inspectors

  • R. L. Prevatte,

Senior Resident - Construction

G. L. Maxwell, Senior

Resident - Operations

S. Burris, Resident Operations

  • Attended exit interview

2.

Exit Interview

The inspection

scope

and findings were suraoarized

on August 2,

1985, with

those

persons

indicated

in paragraph

above.

The inspector

described

the

areas

inspected

and

discussed

in detail

the

inspection

findings.

No

dissenting

comments

were received

from the licensee.

(Open) Violation 50-400/85-29-01,

Failure to Follow

WPS Wire Feed

Speed

Requirement - paragraph

7b(2)(a).

The licensee

did identify as proprietary

some material

provided to

and

reviewed

by the inspector

during this inspection;

however, that material is

not discussed

in this report.

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3.

Licensee Action on Previous

Enforcement Matters

(Closed)

Unresolved

Item 400/81-22-04,

Incomplete Filled Weld Groove

on

RHR Heat Exchanger

This item concerned

code unacceptable

material,

accepted

by quality release

from EBASCO being installed in the plant without the discrepant

conditions

being identified and corrected.

This item is

one of many

examples

that

caused

the licensee

to resort to a

100% receipt inspection with discontinua-

tion of

EBASCO

performing

in vendor plant

inspections

and

generating

questionable

quality releases.

The discrepant

material

discussed

in this

item has

been

corrected

as well as other heat

exchangers

supplied

by the

same manufacturer.

In view of the above, this matter is considered

closed.

4.

Unresolved

Items

e

Unresolved

items were not identified during this inspection.

5.

Independent

Inspection Effort

a.

Housekeeping

(54834B), Material Identification and Control

(42902B)

and

Material Control

(42940B)

The inspector

conducted

a general

inspection of power block construc-

tion site

and the diesel

generator

building to observe activities such

'as housekeeping,

material identification and control; material control,

and storage.

b.

Structural

concrete

Work Observation

(46053)

The

inspector

observed

a

portion of the

placement

and

testing

activities for placement

No.

2RASC261001.

The following areas

were

examined:

equipment

to deliver concrete

to the

actual

placement

location

was suitable

and in an acceptable

condition;

placement

has

been cleaned

and joint preparation

was

as specified in the construction

specification;

placement

drop distances

did not exceed

specification

requirements

and

did

not result

in segregation;

vibrators

were

approved,

tested

for frequency,

and

were

used

properly

by trained

individuals; special

attention

was given to areas

of high reinforcing

or embedment

steel

congestion

to preclude

areas

of voids or honey-

combing; concrete

temperature,

slump, air content,

and unit weight were

being determined

at the proper location

and frequency;

and taking of

the sample

and testing techniques

conformed to the procedures

specified

in the

ASTM standards.

Within the areas

examined,

no violations or deviations

were identified.

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6.

Reactor Coolant Pressure

Boundary Piping

The inspector

reviewed procedures,

observed

work and reviewed

records for

non-welding

work activities

as described

below to determine

whether appli-

cable

code

procedure

and

regulatory

requirements

were

being

met.

The

applicable

code for the installation of reactor coolant pressure

boundary

(RCPB)

piping is

American

Society of Mechanical

Engineers

Boilers

and

Pressure

Vessel

(ASNE B&PV) Code

Section III Subsection

NB,

1974 Edition

with Addenda through Winter 1976.

a.

Observation of Wor k and Work Activities (490538

& 490548)

As the window of opportunity

had passed

for direct observation of work

this inspection

was

performed

by examination

of completed

work and

review of applicable quality records.

(1)

Review of specific

work activities were

conducted

to determine

conformance,

where

applicable,

with the following; inspection

and/or work procedures,

record

keeping requirements,

installation

specification

requirements,

specified materials,

and qualified

inspection personnel.

Reactor Coolant

S stem

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Com onent Identification

Procedure

Flanged Connection

Flanged

Connection

Flanged

Connection

Valve Installation

Valve Installation

Threaded

Connection

Threaded

Connection

1-RC-32-F-01

1-RC-30-F-01

1-RC-32-F-01

1-RC-V540-SN-1

1-RC-V501-SN-1

5-RC-2-T-Ol

5-RC-2-T-02

WP-129,

R7

&

CQC-12$

R12

WP-129,

R7

&

CQC-12,

R12

WP-129,

R7

&

CQC-12,

R12

CQC-12,

R6

CQC-12,

R6

WP-102,

R12

&

CQC-12,

R10

WP-102,

R12

&

CQC-12,

R10

Liquid Penetrant

Exam

TW-01RC-420

Liquid Penetrant

Exam

TW-01RC-423

Cleanliness

Inspection

Boss

CQL-RC

PC BO-03

NDE-201,

R6

NDE-201,

R6

WP-113,

R10

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Cleanliness

Inspection

Boss

CQL-RC Pc BO-04

WP-113,

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Storage

and Protection

Various

Residual

Heat

Removal

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AP-XIII-07 R19

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Flange

Connection

Com onent/Identification

1-RH-50-F-01

Procedure

WP-129,

R7

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Valve Installation

1-RH-V67-SB1

Valve Installation

1-RH-V68-SB1

Liquid Penetrant

Exam

1-RH-50-FW-211

Liquid Penetrant

Exam

1-RH-50-FW-212

Cleanliness

Inspection

1-RH-50-2

Storage

and Protection

Various

Chemical

and

Volume Control

S stem

CQC-12,

R6

CQC-12,

R6

NDE-202,

R2

NDE-202,

R2

WP-113,

R10

AP-XIII-07, R19

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Flanged

Connection

Com onent/Identification

1-CS-545-F-01

Valve Installation

1-CS-V34

SN1

Storage

and Protection

Various

Cleanliness

Inspection

1-CS-545-2

Cleanliness

Inspection

1-CS-545-1

Liquid Penetrant

Exam

1-CS-545-FW-3106

Liquid Penetrant

Exam

1-CS-545-FW-3107

Procedure

WP-129

R7 5

CQC 12,

R12

WP-113,

R10

WP-113,

R10

NDE-201, Rev.

2

NDE-201, Rev.

2

CQC-12,

Rev. 5/6

AP-XIII-07, R19

(2)

The following NDE activities

were observed

and inspected,

where

applicable, for compliance with requirements,

calibration

and use

of proper measuring

and test

equipment

and qualifications of NDE

personnel.

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NDE Performed

Liquid Penetrant

Liquid Penetrant

Liquid Penetrant

Liquid Penetrant

Liquid Penetrant

Liquid Penetrant

Liquid Penetrant

Location/Com onent

End Prep

RC-2-FW-1

End Prep

RC-2-FW-2

End Prep

RC-2-FW-4

End Prep

RC-2-FW-5

End Prep C(L-Loop 2-1

Weld

17

End Prep

CgL-Loop 2-5

Weld 15

End Prep Thermo.

Boss

SER Nos. 3-5-75-1 through

8

Procedure

CPIIIL-NDE-201$

RO

CPIIIL-NDE-201,

RO

CPSL-NDE-201$

RO

CPS(L-NDE-201$

RO

  • SWF-PT1,

R2

  • SWF-PT1,

R2

    • BF-DP-3, R4
  • Southwest Fabricating

and Welding Co, Inc.

    • GW Bonney Forge Division of Gulf and Western

(3)

The inspector

made

a walk down inspection of the piping shown

on

the

below listed

drawings

and

compared

the

actual

completed

piping installation with the as-built drawings.

Drawin

No.

1-SI-188,

R4

1-SI-130$

R6

1-SI-149$

R6

1-SI-153,

R5

1-RH-50,

R4

b.

Review of guality Records

(49055B)

~Sstem

Safety Injection

Safety Injection

Safety Injection

Safety Injection

Residual

Heat

Removal

The inspector

reviewed the records of recent

gA audits associated

with

reactor coolant pressure

boundary piping in order to determine that;

scope

and frequency of audits

are

as specified, identified deficiencies

are corrected in a timely manner

and corrective action is adequate.

Audit Reviewed

ASME Corporate Audit gAA/170-85-01- Jan 7-14,

1985

ASME Audit gAA/X170-85-02- May 13-20,

1985

Within the areas

examined,

no violations or deviations

were identified.

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7.

Safety-Related

Heating, Ventilating,

and Air Conditioning

(HVAC) Systems

(50100)

The inspector

reviewed the licensee's

HVAC program to determine whether the

technical

requirements

detailed or referenced

in the facility Safety Analy-

sis

Report associated

with safety-related

HVAC systems

had

been adequately

addressed

in the construction specifications,

drawings,

and work procedures.

The applicable

codes

for the fabrication

and installation of HVAC systems

are:

HVAC General:

AWS D.l.1-77

AWS D.1.3-78

(MTL 1/8-inch and less)

Dampers:

Air Flow

Measuring

Devices

AWS D.1. 1 (latest at time of purchase)

AWS D.1.1-82

AWS D.l.3-81

(MTL 1/8-inch

and less)

a.

Review of Work Procedures

The inspector

reviewed the below listed documents

to determine whether

procedures

and instructions

pertaining to the installation of

HVAC

ductwork,

seismic

supports,

and other safety-related

aspects

of the

installation were reviewed

and approved

by AE/licence personnel,

and to

verify that the approved

procedures

and instructions

were appropriate

and

adequate

for proper installation

and inspection

of the safety-

related

HVAC system.

Those

procedures

were

reviewed

to determine

whether those controls incorporated

the following:

controls to ensure

that the

type

and classification

of seismic

supports

for the

HVAC

ductwork

comply with approved

drawings

and/or specifications;

provi-

sions for ensuring that required preinstallation

and in-process

inspec-

tions

are

performed at the appropriate

time for HVAC safety-related

equipment;

means

to ensure

that bolts, nuts,

and

washers

(including

lubricant if used) for supports

are of the proper type

and correctly

installed,

and where required, bolt preloading (torquing), minimum bolt

embedment,

and thread

engagement criteria are

imposed;

and provisions

to ensure

the proper location of equipment,

dampers, filters and etc.

Document

No.

CP&L-WP-404

R1

CP&L-WP-400,

R1

CP&L-WP-402,

R7

Title

"HVAC Ductwork Packages

Generation"

"Installation of Seismic

I Ductwork

Supports"

"Installation of Ductwork"

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CP&L-IX-15$ R12

CP&L-TP-56,

R4

CP&L-FCR-517,

R2

CP&L-FCR-518,

R3

CP&L-FCR-585,

R2

"Implementation of DCNs"

"Inspection of the installation of

Nuclear

Safety

Related

and

Non-

Nuclear

Safety-Related

Ductwork

Seismically Supported"

b.

Observation of Work and Work Activities

(1)

Personnel

Interviews

The

inspector

interviewed

selected

personnel

engaged

in the

installation of seismic

supports,

ductwork, isolation

dampers

or

additional safety-related

HVAC equipment to confirm the following:

predefined

and

approved

procedures

are followed when it becomes

necessary

to relocate

any seismic

support or other safety-related

equipment

from its original location specified

on drawings;

any

preinstallation field repairs

or adjustments

to the

HVAC equipment

are

performed in accordance

with the manufacturer's

instructions

and specifications

to ensure

that proper materials,

replacement

parts,

and supplies

are used,

and performance

requirements

are met

and are'reviewed

by engineering for acceptance;

personnel

engaged

in the installation

and

inspection of safety-related

supports,

ductwork,

and other safety-related

HVAC equipment

have received

adequate

training to understand

and

perform work contained

in

relevant work and inspection procedures

and instructions.

(2)

Instal 1 ati on Activities

(a)

The inspector

witnessed

portions of installation activities

indicated

below to verify the following:

the latest

issue

(revision) of applicable

drawings

or procedures

is available

to the installers

and is being

used;

and modifications to

supports

are approved

by appropriate

personnel

before imple-

mentation.

~Activit

Duct Fabrication-

Welding

Bolting

Duct Fabrication

Welding

Identification

PC-25

PC-43,

44

& 45

PC 40A

~owawin

HV/1-G-506-501-005

HV/1-G-506-501-006

HV/1-G-506-501-006

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With regard

to the

above

inspection,

the inspector

noted

welder

SK-67 welding

on PC-25

on drawing HV/1-G-506-501-005

and welder SL-67 welding

PC

40A on drawing HV/1-G-506-501-

006.

Both welders

were required to weld in accordance

with

welding procedure specification

(WPS)

525M1, Revision 3.

The

electrode wire feed

speed for welder SK-67 was 106-inches

per

minute

(IPM)

and

136-IPM for welder SL-67.

The

above is

contrary to WPS-525M Revision 3, which specifies

an electrode

wire feed

speed

range of 170 to

204

IPM.

Clearly both

welders

diverted

from the

WPS requirements

while welding on

safety-related

seismic class

1

HVAC ductwork thereby usurping

the engineering

purview of the welding engineer.

Failure to

follow procedure

for activities affecting quality is in

violation of Title Ten,

Code of Federal

Regulations,

Part 50,

Appendix B, Criteria V.

This violation will be identified as

50-400/85-29-01,

Failure

To

Follow

WPS

Wire

Feed

Speed

Requirement.

(b)

The

inspector

witnessed

portions

of the installation

and

testing of concrete

anchor bolts indicated

below to verify

that anchor bolt type, diameter,

embedment

length, shoulder-

to-cone

measurement

and

torque

requirements

(where applic-

able)

meet installation requirements.

Anchor Bolt Identification

Placement

No.

IWP-291026

on draWing CPSL-1FP-H-1728

(c)

The

inspector

noted

that

inspection

activities

were 'in

progress

and appeared

to be adequate.

c.

As-Installed Equipment

The inspector

conducted

a walkdown inspection of the ventilating system

for Diesel

Generator B-train Electrical

Equipment

Room.

All the duct

sections,

seismic

supports,

dampers,

instruments, flexible connectors

and the air handling unit showen

on the

below listed drawings

were

examined for proper location, configuration identification and damage.

~0i

N

EBASCO-CAK-2166-B-430 Sheet

31.182

Rev.

3

CPSL-FSAR-Figure 7.3.1-19

CPSL-HV/1-G486-001 through -006,

018 and -022- all Rev.

0

CPSL-FS-01-DG-6905-ASA

Within the

areas

examined,

no violations

or deviations

were identified

except

as noted in paragraph

7b(2)(a).

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8.

Inspector

Followup Items

(92701B)

(Closed)

Item 400/85-03-01,

Unavailable

PWHT Records

This matter

concerned

the unavailability of Post

Weld Heat Treat

(PWHT)

records.

The inspector

reviewed the

PWHT records for the welds in question

and determined that there

was adequate

objective quality evidence to support

the

PWHT of those

welds.

The inspector

has

no further questions,

this

matter is considered

closed.

9.

IE Bulletin ( IEB) (92703B)

a.

(Closed)

IEB No. 83-06,

Nonconforming Materials Supplied

by Tube-Line,

Inc., Unit 1

The inspector

has

reviewed

CPSL's letters of October 21,

November 15,

1983,

and

June 1,

1984,

and determined that the requested

actions of

the Bulletin have

been

acceptably

addressed.

The

inspector

held

discussions

with responsible

CPSL representatives,

reviewed

suppor ting

documentation

and

observed

representative

samples

of work to verify

that

the

actions

identified in the letters of response

have

been

completed.

This matter

was left open pending

NRC

s review of objective

quality evidence of the disposition of the

39 fittings identified in

CPSL letter

LAP-83-525 of November

1983.

This review has

been

com-

pleted

and this Bulletin is considered

closed.

b.

(Closed)

IEB

No.

83-07,

Apparently

Fraudulent

Products

Sold

by

Ray Miller, Inc., Unit

1

The inspector

reviewed

CPSL's letters of March 23, June

1, November 9,

1984

and January

31,

1985

and determined that the requested

actions of

the Bulletin have

been

acceptably

addressed.

The

inspector

held

discussions

with responsible

CPSL representatives,

reviewed supporting

documentation

and

observed

representative

samples

of work to verify

that

the

actions

identified in the letters

of response

have

been

completed.

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