ML20054D904
| ML20054D904 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/07/1982 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20054D871 | List: |
| References | |
| NUDOCS 8204230491 | |
| Download: ML20054D904 (6) | |
Text
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'M:lling Addr:ss Alabama Power Company 600 North 18th Street Post Office Dox 2641 Birmingham, Alabama 35291 Telephone 205 783-6081
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F. L. Clayton, Jr.
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Alabama Pbwer
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,J L i April 7, 1982 Mr. James P. O'Reilly U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 3100 Atlanta, Georgia 30303 Joseph M. Farley Nuclear Plant NRC Inspection of December 16, 1981 through January 15, 1982 RE:
Report Number 50-348/82-03 Report Number 50-364/82-02 Dear Mr. O'Reilly This letter is Alabama Power Company's response to the violation in the subject inspection report:
10 CFR 50, Appendix B, Criterion V as implemented by paragraph 17.1.5 of the FSAR requires that activities affecting quality be prescribed by documented instructions, procedures and drawings.
Section 7.2 of Alabama Power Company Field Quality Control (Construction Test) Procedure No. 5.6.1.2 requires that work performed per Construction Work Request be inspected by Quality Control and documented on a QC Inspection Report.
Contrary to the above, on December 15-18, 1981, the licensee discovered that Unit 1 containment spray nozzles were not installed in accordance with design drawings.
This condition was caused when the containment spray nozzles were not installed in accordance with established procedures which require that the work be performed under a construction work request and QC acceptance was made by accepting a memo that the spray nozzle had been installed properly without the required QC inspection and verification.
8 204230 "
Mr. James P. O'Reilly April 7,1982 U. S. Nuclear Regulatory Commission Page 2 Admission or Denial The Violation occurred as described in the subject report.
Reason For Violation I.
During the current refueling outage while conducting the 5 year technical specification surveillance testing (Ref:
Section 4.6.2.1.d) to verify that the containment spray nozzles are unobstructed, discrepancies were discovered between the "as constructed" system and the design drawings:
A.
1/3 of the nozzles on the third ring (1A and
- 18) were found oriented properly but were installed on the side of the pipe facing the containment centerline rather than on the side away from the containment centerline as shown on the design drawings.
B.
The two outer rings (4A & B and 5A & B) had nozzles directed towards the centerline of containment rather than away from the centerline as was shown on the design drawings.
C.
One of 16 nozzles on SA and one of 32 nozzles on 2B were not installed.
II. Based upon an exhaustive review of site records Alabama Power Company is confident that the following sequence of events led to the discrepancies between the as found condition of the containment spray headers and the design drawings:
A.
For the discrepancy described in Section I. A.
above:
1.
Approved design drawings were submitted by Alabama Power Company's A/E (Bechtel) to the piping fabricator (Grinnell).
2.
Grinnell made an error in take-off from the design drawings in developing detailed shop fabrication drawings and isometrics that was not discovered by Grinnell internal Q.A. checks or by Alabama Power Company
- 0. A. audits of the Grinnell program.
3.
The erroneous Grinnell isometrics were transmitted to Bechtel for review and approval.
This in'tial review did not discover the discrepancy.
A
Mr. James P. O'Reilly April 7, 1982 U. S. Nuclear Regulatory Commission Page 3 4.
Manufacturing proceeded based on the erroneous drawings.
5.
Bechtel shop inspection was performed and included verification of pipe attachment-location (threadolets welded into pipe for insertion of pipe nipples and spray nozzles after pipe erection).
This inspection, however, was performed against Grinnell shop fabrication drawings in accordance with approved Bechtel Q.C. procedures.
Therefore, the shop inspection would not have discovered the discrepancy.
6.
The piping was Q.C. inspected upon receipt at Farley Nuclear Plant.
This inspection, as provided for in approved procedures, was only for discovery of shipping damage and verification of proper quality assurance documentation.
7.
The containment spray headers were then installed.
8.
The nozzles were to be installed by construction after hydrostatic testing of the system by the Construction Completion and Testing (CCT) group.
The containment spray system was turned over to the plant start-up group from construction for functional testing.
At this time there was an outstanding Q.C. exception against the containment spray system since the nozzles had not been installed.
9.
During a five day period in November of 1976, prior to start-up pre-operational tests, the nozzles were installed in the threadolets.
Based upon the lack of required documentation (i.e., no Construction Work Request from CCT for nozzle installation was written), such installation was completed outside the formal Q.C. progran under the direction of CCT.
No Q.C. inspection of the nozzle installation was performed.
Existing Q.C.
procedures would have ensured discovery of the discrepancy if the required t
7 Mr. Jamss P. O'Reilly April 7, 1982 U. S. Nuclear Regualtory Commission Page 4 Construction Work Request had been written and implemented.
Such inspection would have been performed against the design drawings which indicated proper nozzle location and orientation.
10.
The start-up pre-operational testing verified that the nozzles were not obstructed.
The verification of nozzle orientation, location, or the number of nozzles was not performed during the start-up testing.
Note:
At this time the Q.C. exception mentioned II.A.8 above was still outstanding.
11.
In March of 1977, approximately 4 months after completion of the start-up testing (and nozzle installation) in an effort to clear up all containment spray system Q.C.
exceptions prior to Unit I criticality, a memo was written to mechanical Q.C. by construction piping.
This memo simply stated that the nozzles were installed.
12.
In violation of the applicable Q.C.
procedures this memo was accepted by Q.C.
in lieu of the required inspections.
Note:
It is believed that this physical inspection was no longer practical since scaf folding had been removed.
B.
For the discrepancies noted in Section I.B. above:
1.
During nozzle installation described in Sections II.A.8 and II.A.9 above, the nozzles were positioned 180 from the design direction.
2.
The cause of this misorientation was misinterpretation of the drawings.
Since all orientation on these two rings were precisely 180' in error, it it obvious that a directional error was made during installation.
L
Mr. James P. O'Railly Page 5 April 7,1982 U.15. Nuclear Regulatory Commission C.
For the discrepancies noted in Section I.C. above:
1.
One nozzle was not installed because during fabrication, a threadolet was omitted due to a take-off error in the development of the detailed shop fabrication drawings.
The subsequent history of this discrepancy is the same as that described in Section II. A. above.
2.
One nozzle was not installed due to inter-ference with structural steel.
Failure to obtain design approval of this deviation is due to the lack of formal Q.C. inspection during nozzle installation as described in Section II.A.9.
Corrective Action
-A.
The as constructed conditions described in sections I. A. and I.C. above have been analyzed and do not adversely affect the ability of the containment spray system to meet its intended design function.
No modifications are required.
B.
The nozzles described in section I.B. have been reoriented to conform to the design drawings.
The as constructed orientation of these nozzles was analyzed and'it was verified that, had an event requiring contair. ment spray occurred prior to reorientation, the system would have met its intended design function.
J Results Achieved The ability of the containment spray system to meet its intended design function has been established and design drawings are being revised to reflect the as constructed configuration.
1 Steps Taken to Avoid Further Violations i
This problem is unique to the containment spray rings and is not indicative of potential problems in other_
systems or portions of the containment spray system for the following reasons:
A.
The Farley Nuclear Plant surveillance program verifies the functional capability of all critical.
safety-related systems.
On Unit I all systems have i
f' l
L
Mr. James P. O'Railly April 7,1982 U. S. Nuclear Regulatory Commission Page 6 now gone through at least one surveillance
. verification.
It was this ef fort which discovered the containment spray problem.
B.
The containment spray rings are a unique system in that they are open and not tied physically to another component.
For the other plant systems, similar problems, if they existed, would have been discovered and corrected during installation as components and systems were tied together.
C.
Upon determination that the required Q.C.
inspection was not performed, the dif ficulty in performing the appropriate inspection (due to the fact the scaffolding was already removed at that time) led to a deviation from approved Q.C.
procedures.
D.
Unit 2 nozzle orientation was inspected and verified during preoperational testing.
Date of Full Complian_c_e, Full compliance will be achieved upon receipt of corrected drawings, approximately June 15, 1982.
Affirmation I af firm that this response is true and correct to the best of my knowledge, information and belief.
i Very truly you rs,
/
. Clayton r.
FLCJ r/RSF :Jc-D8 cc:
Mr. S. A. Varga
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Mr. R. A. Thomas Mr. E. A. Reeves Mr. W. H. Bradford I
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