ML19339A820

Responds to NRC 800905 Ltr Re Violations Noted in IE Insp Rept 50-364/80-26.Corrective Actions:Reinspected Support & Hanger & Reviewed Valve Checklist

ML19339A820
Person / Time
Site:	Farley
Issue date:	10/01/1980
From:	Clayton F ALABAMA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19339A818	List: ML19339A820
References
80-969, NUDOCS 8011050371
Download: ML19339A820 (4)

Text

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V.* = . Alabims Power Company 6 I

600 North 18th Street Post Office Box 2641 Birmmgham Alabama 35291

• k Telephone 205 250-1000 '; .

,i F. L. CLAYToN. JR.

Senior Vice President gghggg g,g October 1,1980 rne swem w,x sg:r.

Joseph M. Farley Nuclear Plant NRC Inspection of July 30-August 1, 1980 File: A-35.10.03 Log: 80-969 1

Mr. James P. O'Reilly U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W. - Suite 3100 Atlanta, Georgia 30303 Re: RII:WPA 50-364/80-26

Dear Mr. O'Reilly:

The inspection report transmitted by letter dated September 5, 1980 has been reviewed by all concerned parties, and we do not consider any of the information contained therein to be proprietary.

The noncompliance in the inspection reporc was an infraction, 354/80-26-01, which had three (3) examples.

The following is a list of the examples and actions taken in response to the questions in the inspection report.

EXAMPLE 1 FNP QC Procedure 5.4.2.1A Paragraph 5.3 requires that damage to con-crete be reported as part of the concrete expansion anchor inspection.

Paragraph 6.14.2 requires that bolt spacing less than five times the bolt diameter of the concrete expansion anchors be documented.

Contrary to the above, on July 30, 1980, damaged concrete adjacent to pipe support 2MS-R505 was noted and had not been reported on the completed pipe support inspection package; an unused concrete expan-sion anchor was also noted within 4ka inches of a one inch diameter concrete expansion anchor bolt of pipe support 2MS-R505. This condition had not been documented.

... a .a.a.

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L Mr. ' James P. O'Reilly NRC Inspection of July 30-August 1,1980 Page 2 October 1, 1980 Response - Damaged Concrete

1) Corrective steps that have been taken and results achieved.

Reinspected support 2MS-R505. Damage to the concrete consisted of minor surface spalling around the bolt. Spalling is insignificant with respect to the holding power of the concrete. The QC inspector's handling of this spalling was correct (QC inspector filled out a request for grouting form). Damaged area will be repaired.

2) Corrective steps taken to avoid further noncompliance.

QC inspectors have been reinstructed to report concrete damage.

3) The date full compliance will be achieved.

Compliance will be achieved by 10-8-80.

4 Response - Unused Concrete Expansion Anchor

1) Corrective steps that have been taken and results achieved.

Reinspected base plate bolt spacing on support 2MS-R505 and submitted a Field Change Request (2M-52086-1) which included the bolt noted in NRC report. This is considered to be an isolated case as witnessed by other bolts which encroach on the five (5) diameter distance that had been reported on this hangar. The designers review of this unused bolt problem indicate that the unused bolt does not adversely affect the design requirements of the other bolts in this anchor bolts cluster.

2) Corrective steps taken to avoid further noncompliance.

Reinstructed QC inspectors to check all dimensions as required by QC Procedure 5.4.2.1A.

3) The date full compliance will be achieved.

Compliance achieved 9-30-80.

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Mr. James P. O'Reilly NRC Inspection of July 30-August 1,1980 Page 3 t.-:tober 1,1980 EXAMPLE 2 FNP QC Procedum 5.4.2.1 Addendum 1 Paragraph 5.1.2 requires QC to inspect pipe hangers to assure that all design requirements of the hanger sketch are satisfied.

Contrary to the above, on July 30 and July 31, 1980, dimensional discrepancies were noted between the actual installation and the "As-Built" sketches for QC inspected pipe support 2MS-R814, 2RH-R96, 2RH-R95 and 2RH-R97.

Response

1) Corrective steps that have been taken and results achieved.

As outlined in our meeting of August 7, 1980 with the NRC in Atlanta on I.E.Bulletins 79-02 and 79-14, Alabama Power Company comitted to reinspect and reanalyze 100. randomly selected hangers from those which had already been inspected, analyzed and approved per I.E.Bulletin 79-14 requirements. Alabama Power Company be-lieves the 100 randomly selected hangers is a sufficiently large sample to ensure that even a low percentage failure rate would be detected and to ensure a representative sampling of both piping systems and hanger loading conditions.

. Upon reinspection of the 100 hangers, it was found that approximately two-thirds (2/3) of the hangers had minor dimensional discrepancies between the actual installation and the "As-Built" sketches previous-ly submitted to the designers under the 79-14 program. All 100 hangers, including those with no dimensional discrepancies.were re-submitted to the designers for reanalysis. This reanalysis effort i has recently been completed, and none of the discrepancies were found to affect the design of the hangers. Based on these results, Alabama Power Company has verified that its 79-14 program is adequate to ensure that all design requirements for the hangers are satisifed.

Pipe supports 2MS-R814, 2RH-R96, 2RH-R95 and 2RH-R97 were reinspected, and Field Change Requests (FCR's) 2M-50478-3, 2M-50304-2, 2M-50158-2, and 2M-52035-2 were submitted to the designers. These FCR's contained all discrepancies found.

2) Corrective steps taken to avoid further noncompliance.

Reinstructed QC inspectors to check all dimensions shown on hanger sketches as accurately as possible. In addition to the reinstruction,

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t Mr. James P. O'Reilly NRC Inspection of July 30-August 1,1980 Page 4 October 1, 1980 a complete dimensional check is being performed on all Hanger Modifications sent to the site. This check will be made at the time QC inspects the completed field modification.

3) The date full compliance will be achieved.

Compliance achieved 9-30-80.

EXAMPLE 3 FNP QC Procedure 4.01 Appendix B Paragraph 4 requires that if a valve has an extended operator that the orientation of the operator be verified to be correct.

Contrary to the above, the valve inspection checklist for valves QV-003F and QV-003C were marked "N/A" on the paragraph that required verification of operator orientation, valves QV-003F and QV-003C had extended operators.

Response

1) Corrective steps that have been taken and results achieved.

A review was made of all completed valve checklists. Those that in-dicated that no extended operator existed were compared to the "As-Built" installation to determine whether they were correct or not. Each error that was found was corrected and resubmitted to the designer on a Field Change Request or will be resubmitted prior to October 1,1980.

2) Corrective steps taken to prevent further noncompliance.

Instructions were issued to all inspectors -to reaffirm the importance of the proper use of the term "N/A".

3) The date full compliance will be 2,k.d.

Full compliance will be achieved by October 1,1980.

Very truly yours, F. L. Clayton, .

FLC:WCP:sh 4

cc: Mr. W. H. Bradford Mr. D. Price