ML20009H479

Status Deficiency Rept 3,re Procedural Violation in Cutting Rebar,Initially Reported on 800602.Caused by Failure of Supervisor & Craftsman to Follow Procedures.Procedures to Be Verified.Final Rept to Be Submitted by 811117

ML20009H479
Person / Time
Site:	Grand Gulf
Issue date:	07/31/1981
From:	Mcgaughy J MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
AECM-81-275, NUDOCS 8108100169
Download: ML20009H479 (5)

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MISSISSIPPI POWER & LlGHT COMPANY Helping Build Mississippi P. O. B O X 164 0, J AC K S O N, MIS SIS SIP PI 3 9 20 5 11/ "" 3 Pl2

• l 's 3l N 3 n8: It NUCLEAR PRODUCTION DEPARTMENT July 31, 1981 Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission .pgI 0;/ O Region 11 \ \

101 Marietta Street, N.W.

Suite 3100 6'

C N gg Q 6 Atlanta, Georgia 30303 I g

y l\UGO7199gn 7! 9 Attention: Mr. J. P. O'Reilly, Director 1% >

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Dear Mr. O'Reilly:

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SUBJECT:

Grand Gu. .. ion Units 1 and 2 Docket Nos. 50-416/417 File 0260/15525/15526 PRD-80/30, Status Report #3 Procedural Violation in Cutting Rebar AECM-81/275

References:

(1) AECM-80/146, 7/2/80 (2) AECM-80/286, 11/17/80 On June 2, 1980, Mississippi Power & Light Company notified Mr. M. Hunt, of your office of a Potentially Reportable Deficiency (PRD) at the Grand Gulf Nuclear Station (GGNS) construction site. The deficiency concerns the cutting of rebar in violation of procedures. This deficiency was noted during Mr.

Hunt's site inspection 416-80/12 of May 27-30, 1980.

Our progress in the inveutigation into the extent and scope of the deficiency is provided in the attached status report.

We expect to submit a determination of reportability and final report on this deficiency by November 17, 1981.

Yours truly, e

pr J. P. McGaughy, Jr.

ATTACHMENT cc: See page 2 f

I/

8108100169 810731 PDR ADOCK 05000416 Member Middle South Utilities System S PDR

O Mr. J. P. O'Reilly AECM-81/275 NRC Page 2 cc: Mr. N. L. Stampley

-Mr. R. B. McGehee Mr. T. B. Conner Mr. Victor Stello, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory. Commission Washington, D.C. 20555 Mr. G. B. Taylor South Miss. Electric Power Association P. 0. Box 1589 Hattiesburg, MS 39401

o bec: Mr. J. N. Ward Mr. W. A. Braun Mr. R. S. Trickovie Mr. J. W. Yelverton Mr. L. F. Dale Mr. C. K. McCoy Mr. T. H. Cloninger Mr. R. A. Ambrosino Mr. R. C. Fron Mr. G. B. Rogers Mr. M. R. Williams Mr. L. E. Ruhland Mr. D. L. Hunt Dr. D. C. Gibbs Mr. A. G. Wagner Mr. P. A. Taylor PRD File File. ,

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Attachment A to AECM-81/275 Page 1 of 2 STATUS REPORT #3 FOR PRD-80/30 I. Description of the Deficiency During an NRC inspection visit to the site on May ?.7-30, 1980, it was found that rebar was cut in the Diesel Generator Building without being documented in accordance with work plan /pr cedure WP/P-C-24. The rebar had been cut during the installation of concrete expansion anchors for support of electrical equipment. A Notice of Violation was issued to

, MP&L as a result. Potential Reportable Deficiency (PRD) 80/30 was issued as a tracking mechanism for this nonconformity.

II. Approach to Resolution of the Deficiency A. Actions to Prevent Recurrence As an immediate action in response to the deficiency, our Constructor issued a Stop Work. At that time, the procedures were judged adequate, and it appeared that the retraining of the crafts, supervision, and field engineers along with the establishment of a log in the electrical sector were suf ficient actions to assure program compliance. The training was performed, and the Stop Work was lifted. Later, in addition to the training, the wording of the procedures was clarified to L,re precisely define the approval authorities required for rebar cutting. Sequential numbers on approval forms and a standarized form were other improvements added.

A detailed investigation compiled from the various disciplines (civil, electrical, instrumentation, and subcontractors) provided a record of the cut rebar logs in existence. However, in the case identified in 'le notice of violation, no record w0s being maintained and the cut rebar was logged only af ter the initiation of the investigation. The Constructor's Field Engineering organization has concluded that the electrical, instrumentation, and subcontractor disciplines may not have' reported all cases of cut.

rebar.

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B. Actions to Correct Existing Nonconformances i

The following remedial action has been taken by our Architect / Engineer and is still in progress:

1. Four walls previously evaluated for cut rebar were analyzed to determine whether structural integrity had been maintained; these were found acceptable.

2. A statistical approach is being used to develop standard distribution curves for cut rebar in both the horizontal and vertical directions. The sample size has been increased in order to develop the curves.

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• l Attachment A to AECM-81/275 Page 2 of 2

3. Five walls determined to be highly stressed are being evaluated for cut rebar and structural adequacy. The results of this cut rebar evaluation will be combined with the previous evaluation of four walls in order to increase the sample size and develop the standard distribution curves.

4. The cut rebar evaluation will be considered complete if--

a) All nine walls evaluated prove to be structurally adequate, and -

b) The developed curves establish an acceptable confidence level on the percentage of cut rebar.

If either of the above is unacceptable, then either/both of the following will be pursued.

a) An additic sal f. .e walls will be evaluated to increase the sample size in order to develop standard distribution curves with an acceptable confidence leve.l.

b) Curves will be developed which correlate the number nf expansion bolts to the percentage of cut rebar for Loth dirGetions. These curves will then be used to analytically evaluate other walls.

III.. Statue of Proposed Resolution The cause of the deficiency was the failure of supervision and craf tsmen to follow procedures requiring written pe.rmission from Field Engineering prior to cutting rebar. The ef fects <nt the safety cannot be determined until the safety analyses are completed. Similarly, the extent of the deficiency is not yet known. Corrective actions to prevent recurrence (addressed under II.A.) are complete.

1V. _ Reason Why a Final Report Will Be Delayed The safety implications and extent of the deficiency are still being analyzed.

V. Date When A Final Report Will Be Submitted Although our investigation of the extent of unreported cut rebar is not yet cceplete, full compliance for new work has been achieved. ' We expect l to submit a determination on reportability and a' final report on November 17, 1981.

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