ML19317G573

Responds to AEC Re Violations Noted in Insp Rept 50-302/71-04.Corrective Actions:Addl Storage & Insp Requirements & Improvements to Control & Documentation of in Storage Insp & Maint Programs

ML19317G573
Person / Time
Site:	Crystal River
Issue date:	12/16/1971
From:	Rodgers J FLORIDA POWER CORP.
To:	Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19317G571	List: IR 05000302/1971004 ML19317G573
References
NUDOCS 8003191149
Download: ML19317G573 (6)

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"W F L 0 ll i.l A P O W E ll

5. 0 0 ll i' O ll A.. U X st nunsnna.*:p } nmmn Ns December 16, 1971 Atomic Energy Commission Division of Compliance 230 Peachtme Stmet N.W.

Atlanta, Georgia Attention: Mr. John G. Davis,

Director, Region II

Subject:

AEC/ DOC Letter November 24, 1971 C0: II: RFW 302/71 FPC File Q - AEC/ DOC Site Visits

Dear Mr. Davis:

In response to the subject. letter, we wish to present the following conments concerning the items in the enclosure. This msponse will include the actions taken both past, present and future which are mlevant to the subject activi-ties.

We also delineate changes in our policies or procedures to pmvent m-occurrence of the activities which pmcipitated your letter.

Our response is pmsented in the same order as your enclosum.

Item 1 As a general cceent to this entire item, we should state that the specific storage and inspection mquirements for each piece of equipment are determined by one of two methods.

For B & W supplied equipment, the 8 & W Quality. Control inspector determines the in-storage inspection and in-storage maintenance mquim-ments from the B,& W field specifications and the manufacturers ' instruction manuals and inspects the equipment accordingly. For equipment not furnished by:

B & W, the equipment lists published by Gilbert Associates designate the items within the Quality Prcgram. For each item in the Quality Program an inspection mport is prepamd, designating the storage and maintenance mquirements as determined from the manufactumrs ' instruction manuals, the Gilbert Associates' specifications, and/or the Gilbert Associates' requirement outlines.

Item la The storage and inspection mquirements for the Nuclear Steam Supply System components am specified in the B & W Field Specification for NSSS components.

Requimments am explicit and detailed for the mqctor and other major conuon-Requimments in Section FS-II-I are more general for items such as heat en ts.

exchanges, but do specify storage conditions mquired, such as:

indoor storage -

i with heat and moistu..y. + control, indoor storage - without heat, outdoor heat -

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Mr. John G. Davis December 16, 1971 with weatherproof cover, outdoor storage - without weatherproof cover.

In addition, the manual does specify whem manufacturers' mconnendations are to be used either in lieu of, or in addition to, B & W requirements. The let-down coolers in question wem stomd indoors without heat, and lacking any special storage requirements specified by the manufacturer, they wem left crated for physical protection. Upon mceipt of your letter, the coolers were uncrated for inspection. Their condition was clean and with all openings sealed. An inspection mport was filed with our site Quality office.

In addition, B & W site personnel contacted the B & W Nuclear Products group and requested an upgrading of the field specifications to include more speci:

fic storage and inspection mquirements where necessary. These additional requirements will be implemented on the job site as soon as they are received.-

This revision of the field specifications is necessary due to the delay in the construction of this unit requiring longer term storage than was originally an-ticipated.

Item lb The apparent delay in correcting the in-storage conditions for the Makeup Pumps mported in B & W Deficiency Report #7 dated 7/15/71, but not reported corrected until 10/27/71, was due to a lack of adequate procedures regarding coordination and reporting during the early stages of our in-storage inspec-tion and in-storage maintenance program. Upon further checking after the site DOC visit that precipitated your document, we were able to collect maintenance mcords for the subject pumps.

In-storage maintenance records prepamd by the Millwrights on 8/19/71 and 9/24/71, stated that the pumps were in good condition, and verified that they wem not being neglected during this time span even though the specific action necessary to close the deficiency mport was not reported corrected. A summary of the inspections am on file at our site Quality office.

To guard against recurrences of this nature, B & W Quality Control has been instructed to contact the specific centractor's Quality Control Coordinator dimetly when workmen are mquired to correct a storage condition, and the spe-cific contractor's Q/C Coordinator has been directed to provide the necessary 1

workmen promptly.

Craft fommen have also been designated for instorage inspection and mainten-ance duties to provide for continuity for this important program. A Quality Control organizational chart is attached to illustrate the lines of comunica-tion provided by our system.

Item 1c A similar condition exists for the records of the Steam Generator inspections as stated previously in Item lb. A review of our in-storage inspection and in-storage maintenance program verified that inspections have been made and

Mr. John G. Davis December 16,1971 in-storage maintenance program verified that inspections have been made and in-storage maintenance is being conducted. Furthemore, our personnel had.

been geared to a monthly cycle instead of the 30 day cycle requirement as stated in our pmsent procedums. The inspection sumary for the Steam Gene-rators is on file at the site office.

In addition to the docunentary inspections, we can verify by vertal evidence that the purge on the steam generators was checked every Monday. A letter confirming that fact and giving the procedures followed is also on file at our site Quality office.

We have now revised our inspection schedules to assure that they will be made within the 30 day period and that inspection mport foms and/or logs will be prepared for documenting all inspections and maintenance. Measures to improve our in-storage inspection and maintenance program were being

~

established prior to the mceipt of your letter. These are summarized as:

1.

A B & W Contract Equipment Inspection Schedule was initiated on May 20, 1971.

2.

Reports for in-storage inspection and maintenance of electrical equipment was initiated on April 14, 1971.

3.

Reports for in-storage inspection and maintenance of mechanical equipment outside the B & W contract was formalized on Novenber 1,1971. Samples of completed mports for the above are also available at the site Quality office.

In addition to the above, the following action has been taken to improve the performance of our Quali'ty Control effort in the area of in-storage inspection and instorage maintenance.

A.

The total in-storage inspection and in-storage maintenance program was myiewed with the newly appointed site Quality Control supervisor Mr. John.

Rashinsky.

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B.

Writ. ten instructions wem issu* d on Decenber 7,1971 e

1)

To B & W Construction and the electrical Q/C coordinator (E. C.

Emst Co.) mgarding the routing of all documentation to the Q/C supervisor for Florida Power Corporation.

2)

To all contractors performing in-storage inspections that these in-spections shall be performed at least once every 30 days instead of each calendar month.

3)

To all contractors performing in-s torage inspection regarding availa-bility of appropriate craft manpower to perfom essential in-storage maintenance and/or inspections.

1

~

4 Mr. John G. Davis

- December 16, 1971 1

1 Item 2 2

The questions raised by the discovery of valves supplied for Crystal River' Unit #3 having wall thicknesses that were less than the minimum specified in the applicable U.S.A.S. Standard as stated in our Purchase Order have now been pursued through what has been at times an extremely tortuous task. We have had innumerable meetings, conferences, and correspondence with both the supplier and our engineer and have now determined what the specific problem was. The j

subject valves were purchased to U.S. A.S.-B.16.5.. The manufacturer had designed these valves, as far as the casting is concerned, to the newer Section III of i

the ASME code. We have taken the position that the valves must be proven accep-table on an undividual case basis to our engineer Gilbert Associates. Therefore,

j we had dimcted 'the engineer to supply the valve manufacturer with the appropri-ate engineering criteria that the valves must fulfill. These included end forces for the determination of the strength requirements for these valves that would be i

in addition to the requirements imposed by the pressure of the fluid. The valve manufacturer submitted a series of calculations to us that we forwarded to the

engineer, i

The present status of these valves is:

A..

They are rejected in their present condition due to the application of a deficiency report prepared at site.

B.

" Preliminary analysis" of the data supplied by the valve manufacturer indicates that in order for these valves to be acceptable, all bases for their acceptance must be under the same code.

For example, one requim-ment may not utilize B16.5 whereas another is satisfied under the require-ments of Section.III. Present indications are that the valves will have to be returned to the vendor for additional non-destructive testings to satisfy the requirements of Section III. Hopefully, this question will have been resolved prior to the next scheduled site visit by your inspec-tors.

i i

During the last site visit, Decenber 7 - 10, 1971, we presented a package con 1

taining the complete documentation file justifying.the acceptance of the steam f

generator anchor bolts to your inspectors.

If there are any questions mgarding the information contained in these documents, please notify me.

1 In suninary, we wish to convey to you that the apparent deficiencies referenced i

in your letterare actually deficiences in the procedures that were being fol-lowed during the period prior to your compliance visit or in effect at that time.

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The mquired inspections were in. fact being performed although we agree our ad-ministrative functions in this regard were deficient.

The steps taken to icprove the control and documentation of our in-storage inspection and maintenance pro-gram both before-and since your compliance visit should provide a more satisfac-tory approach to this problem. We expect that under the new Quality Control o

l organizational chart, elditional procedures and directives will be issued that further improve this important phase of our construction activities.

Mr. John G. Davis

- December 16,'1971 If you require further clarification of this response, please notify us and we will provide you with whatever information you n! quire.

Very truly yours,

a J.

. Rodgers Asst. Vice President &

Nuclear Project Manager JTR/cfb

~~

Enclosures cc:

H. L. Bennett W. A. Szelistowski M. H. Kleinman E. E. Froats e'

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