ML20054K216
| ML20054K216 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/04/1982 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20054K207 | List: |
| References | |
| NUDOCS 8207010302 | |
| Download: ML20054K216 (4) | |
Text
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,f Carolma Power & Light Compah June'4, 1982 Mr. James P. O'Reilly H JUN 8 A3 I'
United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of May 6, 1982, referring to RII: WHM 50-400/401/82-10, 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 taken will be satisfactory for resolution of the item, once completed.
Thank you for your consideration in this matter.
Yours very truly,
/
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H. R. Banks Manager Corporate Quality Assurance e
NJC:jp Attachment cc: Mr. J. A. Jones 8207010302 820615 PDR ADOCK 05000400 G
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Daviation PSAR Section 1.8.6.(2) states that periodic inspect 10n and tests at the site on the fire protection program will be prescribed by docu-mented instructicas, procedures and drawings and will be accomplished in accordance with these documents.
These instructions for the storage and preventative maintenance of the fire protection equipment are included in licensee's procedt'res PGD-001 ( AP-XIII-95), Material and Equipment Storage Requirements and PGD-002 (AP-XIII-07) Materials Maintenance Requirements During Storage.
Contrary to the abnve, on April 16, 1982, portions of the fire pro-tection equipment were not stored and maintained in accordance with procedures PGD-001 and PGD-002. The following are examples of this discrepancy:
1.
Fire pump unit was stored outside and pump internals were not protected against entrance of water and airborne debris as required by PGD-001.
2.
Shaft of fire pump unit was not being rotated periodically as required by PGD-002.
3.
Batteries for diesel engine fire pump driver were stored out-side and not inside a Class B warehouse as required by PGD-001.
4 Fire protection sectional control valves were stored outside with the valve internal not protected from airborne contaminants as required by PGD-001.
5.
Bolts for the fire protection valve assemblies were stored out-side without a rust preventer as required by PGD-001.
Denial or Admission and Reasons for Violation:
There was a failure of responsible personnel to implement procedural requirements because of misinterpretation of procedure applicability.
Detailed maintenance instructions were not available to the crafts; therefore, the =aintenance was not executed.
Corrective Steps Taken an'd Results Achieved:
l 1.
The vendor representative was on site April 21, 1982, to inspect l
the pump and declared it to be in satisfactory condition.
The l
uncovered suction bell, a concern of the NRC Inspector, was specifically identified to the pump representative for inspection.
i The openings of the pump have been sealed to protect the internals.
-continued-l l
l
l. *.
. Deviation Page Two 2.
Procedure AP-XIII-07 (PGD-002) has been revised o state that in such cases where vendor requirements do not specity the need for pump shaft rotation, and pump design or storage conditions make rotation unnecessary, the Discipline Mechanical Engineer shall decide whether pu=p shaft rotation should be imple=ented.
In the case of this pump shaft, rotation is not required because the liquid pumped during operation is the only bearing lubricant.
Also, shaft deflection is not a concern in this case because the shaft is adequately supported.
3.
All four batteries were checked.
Two were satisfactory, one was cracked and one contained water. The two damaged ones were re-placed from stock supplies, and all four batteries are now stored in a heated warehouse (Level B).
4.
All valves in question now have their ends capped to prevent moisture / dirt entrance into their internals.
Before installation, the v41ves will be inspected and cleaned.
5.
The bolts have been covered to protect them against the elements as required by AP-XIII-05 (PGD-001). Level C storage is now provided.
In addition to correcting the above, we are examining items in storage for similar conditions. This examination will be completed by June 14, 1982.
As nonconforming conditions are identified, corrective action will be promptly initiated.
Corrective Steps Taken to Avoid Further Noncompliance:
On March 9, 1982, CP&L responded to the previous violation in this area that was identified in the NRC report C:M 50-400/401/82-02. As stated in that response, classroom training for crafts and engineers in the storage and maintenance program was co=pleted on March 3, 1982. Other actions taken were:
1.
Reaffirming management concerns through emphasis to all supervisory levels of the job to comply with project housekeeping and storage requirements.
2.
Conducting surveys of equipment with high vulnerability to con-struction damage and fabrication of special enclosures if required.
3.
Assignment to construction housekeeping inspectors the additional responsibility of monitoring storage conditions.
4.
Assignment of safety proctors with additional responsibility of monitoring rigging off permanent plant equipment.
-continued-
Deviation Page Threo
- 5.. Installation of locks on large equipment items, where practical, to reduce unauthorized access to the item's interior.
The above actions are in various stages of implementation to correct the previous violation and, therefore, apply to the current vio-lation as well. Significant improvements have been, and are continuing to be made as a result of these actions.
These continuing actions are considered to be adequate for both the earlier and current violations.
The Resident Engineering Unit is performing a complete review of main-tenance requirements. This review requires a comparison of purchase order requirements and FSAR commitments with maintenance procedures and maintenance-logs. Any discrepancies identified are being reviewed and evaluated for corrective action. This review is in two parts.
First, it is documented that all of the requirements were reviewed.
Secondly, all discrepancies and recom= ended actions are submitted to the appropriate engineering supervisor (s) for approval.
Upon completion of the review of storage and maintenance requirements, additional trainin.g classes will be conducted to explain implementation and the importance of adherance to the program.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by June 30, 1982.