ML19257C105
| ML19257C105 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/27/1979 |
| From: | Wofford A LONG ISLAND LIGHTING CO. |
| To: | Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19257C104 | List: |
| References | |
| SNRC-435, NUDOCS 8001240394 | |
| Download: ML19257C105 (3) | |
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O' L.ONG ISLAND LIGHTING COM PANY 9
175 EAST OLD COUNTRY ROAD
- HI C K S VI L L E, N E W YORK 11801 ANDREW w. worroRD va:= -c. ion.r SNRC 435 September 27, 1979 Mr. Robert T.
Carlson, Chief Reactor Construction & Engineering Support Franch U.
S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 NRC Inspection No. 79-07 Shoreham Nuclear Power Station - Unit No. 1 Docket No. 50-322
Dear Mr. Carlson:
This letter responds to your letter of August 21, 1979, which forwarded the report of the inspection of activities autho-rized by NRC License No. CPPR-95, conducted by Mr. Toth of your office on May 22-25, 1979.
The letter stated that it appeared that certain of our activities were not conducted in full com-pliance with NRC requirements.
The apparent noncomp1.iances and our responses fo' low:
I.
Apparent Noncompliance with 10CFR50, Appendix B Criterion V, and FSAR Paragraph 17.1.5A Contrary to the above, beam support welds numbered 17 and 17A were accepted by RCI quality control on November 15, 1978 although fitup gaps of 3/16 inch existed in the completed wolds.
Similar fitup gaps existed in three or more other similar beam supports.
General Comment All prior fabrication welding on the RPV pedestal, the CRD sapport beams and the support beam clips was performed to the requirements of the AWS Code.
Consistent with this the installation contractor employed welders qualified to ASME Section IX and selected welding practices for installation welding which fulfilled 1796 029 8 0 01240 3y i
LONG iBLAND LIGHTING COMPANY Mr. Robert T.
Carlson September 27, 1979
- 0. S. Nuclear Regulatory Commission, Region I Page 2 the requirements of AWS Dl.l.
This AWS Code provides criteria for acceptance which permits gaps between the two members of the base material of up to 3/16 inch.
The Code also requires that, when the gap exceeds 1/16 inch, the size of the weld be increased by the approximate amount of gap at the root of the fillet.
Corrective Action and Results All such beam support welds are being reinspected to assure conformance to AWS Dl.l.
In the event that any ncnconformances are identified by this inspection, corrective action will be accomplished as specified by the Nuclear Steam Supply System supplier.
Steps Taken to Prevent Recurrence No specific preventive action is required at this time as no further welding of this nature is presently contemplated.
Should a requirement develop for such. welding, appropriate acceptance criteria relative to fit-up will be published and applied.
Date Full Compliance Will Be Achieved Full compliance will be achieved by November 1, 1979.
II. Apparent Noncompliance with 10CFR50, Appendix B, Criterion XVI, and FSAR Paragraph 17.1.16B Contrary to the above, as of May 25, 1979 S&W specification SH1-159 and associated change EDCR-F19039 parmit installation of race-way which do not conform to the minimum separation criteria, and permit subsequent installation of cables in the nonconforming raceways.
Documentation of each nonconformance is provided by Specification SH1-159, and future disposition of the condition is controlled by the E&DCR control system.
However, corrective action to prevent repeti-tion has not been taken and additional nonconforming installations are being made.
General Comment We take exception to the inspection finding that the condi-tions identified and reported constitute a nonconformance.
Shoreham Specification SH1-159, with the associated E&DCR F-19039, permit such installation in instances where the specified separation by distance criteria cannot be met.
Further, Regulatory Guide 1.75, Physical Independence of Electric Systems, also' allows for alter-native methods of compliance.
1796 030
BONG ISLAND LIGHTING COMPANY Mr. Robert T. Carlson September 27, 1979 U. S. Nuclear Regulatory Commission, Region I Page 2 The basic separation criteria are not waived or changed, but remain a plant design basis.
Therefore, no change to the FSAR is required.
Corrective Action and Results Each nonconforming condition is described and documented on an E&DCR, and specific analyses are being performed to deter-mine the safety implications in each case.
Where the results of these analyses so indicate, any necessary rework will be performed.
Final acceptance in each instance will be predicated upon proper disposition of the applicable E&DCR in accordance with approved procedures.
Date Full Compliance Will Be Achieved Full compliance, including final disposition of all E&DCR's and completion of any necessary rework is not expected until after completion of cable installation at the site.
III. Apparent Noncompliance With 10CFR50, Appendix B, Criterion V, and FSAR Paragraphs 17.1.5A and 3.12.2.2.3 Contrary to the above, on May 24, 1979, installed and inspected RCIC system instrument tubing was separated by less than one foot and was not provided with physical barriers at the con-nection to pipe spool 1 inch - SLP-9-151-2-1.
Corrective Action and Results The RCIC system instrument tubing lines have been relocated to conform to the redundant lines separation criteria of Shoreham Specification SH1-343.
Steps Taken to Prevent Recurrence Inspection responsibility for separation criteria of SH1-343 has been transferred from the installation contractor to Field Quality Control.
Further, a system for color coding of redundant lines has been instituted to make deviations from the four foot separation requirement more readily apparent to the inspector during line walks.
Date Full Compliance Will Be Achieved Full compliance has been achieved.
Very truly yours,
,796 031 1
- h., w @; & y g
A. W. Wofford Vice President