ML20050A603
| ML20050A603 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/09/1982 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20050A594 | List: |
| References | |
| NUDOCS 8204010477 | |
| Download: ML20050A603 (3) | |
Text
7 1
Opal Carolina Power & Light Co,rnppny..
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March 9, 1982
'.20 r2 Mr. James P. O'Reilly 7 p q 15 United States Nuclear Regulatory Commissica Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of February 9,1982, referring to RII:
GFM 50-400/401/82-02, the attached is Carolina Power & Light Company's reply to the deficiencies identified in Appendix A.
It is considered that the corrective and preventive actions taleen will be satisfactory for resolution of these items, once completed.
Thank you for your consideration in this matter.
Yours very truly,
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H. R. Banks Manager Corporate Quality Assurance NJC:jp Attachment cc:
Mr. J. A. Jones Sworn to and subscribed before me this 9th day of March, 1982
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Notary Public My commission expires:
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,.;.s 411 Fayetteville Street e P. O. Box 1551 + Rafeigh, N C. 27602 8204010477 820323 r;==Im;;cgnr;am p~,3 PDR ADOCK 05000400 Q
d Severity Level V Violation A.
10 CFR 50, Appendix B, Criterion XIII as implemented by PSAR section 1.8.5.13; CP&L Corporate QA Program, section 5.4.1.f and constructicn procedures AP-XIII-07 (PGD-002) and WP-106 section 4.8 require that safety-related equipment be protected from the environment and adjacent construction activities.
Contrary to the above, safety-related equipment was not properly protected as shown by the following examples.
(1) On December 15, 1981 loop "A" reactor coolant pump casing was found to have concrete curing water dripping onto and into it.
(2) On December 18, 1981, the emergency diesel generator switchgear lA-SA was found to not be adequately protected from adjacent welding, grinding and structural steel activities.
It was also found to contain flammable material and debris.
(3) On January 11, 1982 a feedwater valve was found not to be adequately stored to prevent water from accumulating inside the valve and freezing into ice.
Denial or Admission and Reasons for Violation:
A.
Each example of deficient conditions referenced did exist as identified in the Notice of Violation.
(1) The reactor coolant pump casing was uncovered to permit access for welding activities at the same time concrete curing activities were in progress above the area. Responsible personnel for the work activities failed to recognize the potential problem that occurred and did not take adequate measures for protection of the exposed pump casing.
(2) The switchgear was covered with polyethylene at the time, thou8h the i
manner of covering proved inadequate for protection against the entrance of sandblasting dust. Personnel responsible for the work activities in progress failed to recognize the need for the use of weld blankets and other physical protective measures. Storage i
maintenance and housekeeping personnel failed to identify and initiate removal of the flammable material and debris left behind when the equipment was set.
(3) The feedwater valve was covered by plastic sheet that was partially l
removed which allowed rain water to enter the valve.
-continued-
' Corrective Steps Taker. and Results Achieved:
1.
The pump protective cover was repositioned to prevent further exposure to the concrete curing water. Several swab samples were taken from the pump casing and analyzed for harmful levels of chlorides and flourides. Each sample was found to contain chloride and flouride levels well below the maximum acceptable limits imposed by site procedure WP-112, Control of Materials and Equipment That May Be Harmful to Stainless Steel.
2.
The switchgear was cleaned to remove the dust as a result of sandblasting activities. The use of welding blankets was initiated and personnel have been instructed to avoid walking on the installed equipment. The flammable material and debris were removed. The polyethylene cover was repositioned and made more secare. A follow-up survey of the equipment and area revealed 4
satisfactory conditions.
3.
The water was removed and the valve storage condition was returned to project requirements. The protective covering was resecured to improve the ability to withstand windy conditions.
In addition to correction of the above cited conditions, a general inspection was conducted in the areas of equipment storage, maintenance and housekeeping.
Several other discrepant conditions were identified and have.been documented in site nonconformance reports.
t Corrective Steps Taken to Avoid Further Noncompliance:
A.-
The corrective steps taken to avoid further violations are for the above cited conditions, as well as for the discrepancies identified during the general inspection effort noted above. Classroom training for crafts and engineers in the storage and maintenance program was completed March 3, 1982.
Other actions that are being taken include:
(1) Reaffirming manahement concerns through emphasis to supervisory levels of job responsibility to comply with project requirements.
(2)
Surveys of equipment with high vulnerability to construction damage and fabrication of special enclosures if required.
(3) Assignment to construction housekeeping inspectors of additional responsibility to monitor storage conditions (e.g. pipe caps and protective covers).
(4) Assignment of safety proctors with additional responsibility of j
monitoring rigging off permanent plant equipment.
(5)
Installation of locks on large equipment items, where practical, to reduce unauthorized access to the interior.
J Date When Full Compliance Will Be Achieved:
A.
Full compliance will be achieved by_ April 2, 1982.
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