ML19338C335
| ML19338C335 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/24/1980 |
| From: | Aswell D LOUISIANA POWER & LIGHT CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19338C334 | List: |
| References | |
| LPL-14653, NUDOCS 8008150153 | |
| Download: ML19338C335 (4) | |
Text
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I LOUISIANA P O W E R & L I G H T! P o. sox 6008. NEW CALEANS. LOUISIANA 70174 24a ceancues sraeEr
- (504) 366-2345 uYPu?NbsE a t Asm July 24,1980 Vcs 8%sm Power Stusuction LPL 14653 Q-3-A35.02.01 Mr. K. V. Seyfrit, Director, Region IV U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
SUBJECT:
Waterford SES Unit 3 USNRC Inspection Report 50-382/RPT 80-10
Dear Mr. Seyfrit:
The following information regarding the infractions cited by the USNRC Inspectors in IE Inspection Report No. 50-382/Rpt. 80-10 dated June 20, 1980, is herewith submitted.
l A.
Failure to Follow Procedures for Control of Design Modifications l
l Criterion V of Appendix B to 10 CFR 50 requires that activities affect-(
ing quality be prescribed by documented instructions, procedures, or l
drawings of a type appropriate to the circumstances, and shall be l
accomplished in accordance with these instructions, procedures, or draw-ings.
Criterion III of Appendix 3 to 10 CFR 50 states in part that, " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization."
Ebasco Procedure No. ASP-IV-37, Revision H, " Control of 'As-Built' Information for Piping and Pipe Support Systems," paragraph 1.2 states that this procedure is intended for, "=aking minor modifications in the field which do not affect the intent of the design. Paragraph 4.2 states, " Minor modifications are limited to those specified in para-graph 6.3."
Paragraph 6.3 does not include pipe support and restraint design modifications whitn require a new engineering stress analysis.
Contrary to the above:
Pipe restraintNo. CDRR-322 was modified, through the use of Procedure ASP-IV-37, to replacs two W4x13 beams with a 4 inch square box beam manufactured from 1/2 inch steel plate.
Thrcugh discussions with licen-see representatives, it was determined that the mcdification was a 80080150)
e' Mr. K. V. Sayfrit Director, Region IV -
modification which should have been analyzed for structural adequacy prior to installation. Since this design change was beyond the scope of Procedure ASP-IV-37, the change was not subjected to those design control measures applied to the original design.
This is an infraction.
The following information is submitted:
1.
Corrective Action Taken and the Results Achieved:
a)
The Ebasco design reveiw of the change to support No. CDRR-322 has been completed and the design change determined to be accept-able. Additionally, a confirmatory review by Ebasco's subcontractor, Bergen Paterson, has also been completed with similar acceptable
-results.
b)
A review of Ebasco Procedure No. ASP-IV-37, Revision H, " Control of 'As-Built' Information for Piping and Pipe Support Systems,"
has been completed. This procedure has been determined to be deficient in that it does not restrict the scope of Ebasco's red-l line authority with respect to pipe support and pipe whip restraint modifications..This procedure is being revised to correct this deficiency.
2.
Corrective Action Taken to Preclude Repetition:
Ebasco Procedure ASP-IV-37 is being revised to adequately implement Ebasco's design control program.
Specifically,.the procedure will require Ebasco Design Engineering concurrence prior to implementation of red-line changes to pipe supports and pipe whip restraints. Two alter-native approaches will be allowed:
a)
Ebasco Construction Engineering red-lining the proposed change and obtaining Ebasco Design Engineering review and concurrence prior to implementation, or b)
Ebasco Design Engineering initiating the red-lining change.
Initiating the red-line constitutes approval by the design engineers.
Familiarization and indoctrination sessions will'be held with applicable Construction Engineering and Design Engineering personnel upon revision and issuance of ASP-IV-37.
3.
Date When Full Corrective Action Will Be Achieved:
Procedure revision and familiarization and indoctrination of applicable engineering personnel, as described in Item 2 above, will be accomplished by July 31, 1980.
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Mr. K. V. Seyfrit Director, Region IV B.
Failure to Control Use of a Calibrated Tool Within Necessarv Limits Criterion XII of Appendix B to 10 CFR 50 requires that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality be properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
Tompkins-Beckwith Procedure No. TBP-33, Revision B, " Procedure for Inspecting Drilled-In Expansion Type Anchors in Seismic Class I Con-crete, " Exhibit I, " Expansion Anchor Test and Inspection Data,"
requires that 1/2 inch diameter bolts be torqued to a value between 90 and 100 foot-pounds (ft-lbs).
Contrary to the above:
The 1/2 inch diameter anchor bolts on pipe restraint No. CDRR-322 were torqued using controlled tool No. 256 which was not calibrated for the range of torque values specified in Procedure TBP-33.
This is an infraction.
The following information is submitted:
l.
Corrective Action Taken and the Results Achieved:
Anchor bolts on pipe restraint No. CDRR-322 have been retorqued per the specified tolerances set forth in TBP-33.
Documentation for previously accepted anchor bolts was reviewed by Quality Control and it was found that plates CWRH-68, ACR-770 and EGRR-55 were tested with CT-256 (Torque Urench).
Anchor bolts for the above referenced plates have been retorqued in accordance with the specified torque values defined in TBP-33.
The retorquing of anchor bolts for plates CDRR-322, CWRH-68, ACR-770 and EGRR-55 was verified by Quality Control and found acceptable.
2.
Corrective Action Taken to Preclude Repetition:
l A copy of the calibration results will be issued with the torque wrench.
l These results will be reviewed by the QC Inspector prior to the test being conducted, to ensure that the bolt corquing requirements specified in TBP-33 are complied with.
l The QC Inspector will also verify that the torque wrench issued for the application will be operating in the middle third of the range when measuring the specified torque values.
l 3.
Date When Full Corrective Action Will Be Achieved:
f Anchor bolts retorqued on July 7, 1980 and July 10, 1980 and verified by QC.
l l
Torque wrench calibration results implemented on June 16, 1980.
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Mr. K. V. Seyfrit Director, Region IV If you have any questions concerning this response, please advise.
Yours very truly, D. L. Aswell DLA:LLB:grf