ML20078D722
| ML20078D722 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/02/1983 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20078D709 | List: |
| References | |
| CON-NRC-109 NUDOCS 8310040600 | |
| Download: ML20078D722 (3) | |
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[47 P. O. Box 101, New Hill, N. C. 27562 I
September 2, 1983 Mr. James P. O'Reilly NRC-109 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of August 3,1983, referring to RII: GFM/RLP 50-400/83-22-1, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.
It is considered that the corrective action taken is satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, WW R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment ec:
Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC) 0310040600 830913 PleR ADOCK 05000400 o
s-Attachment to CP&L Letter of Response to NRC Report Rll: GFM/RLP 50-400/83-22-01 4
Reported Violation:
10 CFR 50, Appendix B, Criterion VII as implemented by CP&L PSAR Section 1.8.5.7 and CP&L Corporate QA Program Section 4.1, requires that shop welds on spool pieces meet the surface finish conditions required by Procurement Specification CAR-SH-M30, Revision 15, Appendix 1, Paragraphs 1.2.1,1.2.3, and Figure 2.
Contrary to the above, on March 2,1983, an inspection by the NRC resident inspector of the area near the containment building equipment loading hatch revealed five ASME piping spool pieces, stored on pallets, in which the finish condition of the shop welds did not meet the surface finish required by the applicable specification.
This is a Severity Level V Violation (Supplement II.E).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
The piping fabrication vendor, Southwest Fabricating and Welding, misinterpreted the Power Piping Specification CAR-SH-M-30, Appendix 1, Paragraph 1.2.3,1.2.4, and Figure 2 on page I-8.
The weld surfaces are required to be " flat, free from sharp surface irregularities such as deep valleys between stringer beads, and that a 250 microinch finish shall be established in the examination area."
In order to set some type of inspection criteria to examine these welds, Southwest Fabricating and Welding prepared two workmanship samples (1979) which were viewed and accepted by both CP&L and Ebasco. The piping spools in question,1-RC-141-1,1-RC-142-1, 1-SI-165-2,1-SI-171-1,1-SI-280-2, were compared to the samples. The subject spools have shop welds (by Southwest Fabricating and Welding) which contain surface irregularities caused by excessive grinding and which are not suitable for ultrasonic examinations. The workmanship samples show welds which are flat and free of these surface finish deficiencies.
Corrective Steps Taken and Results Achieved:
CP&L inspectors examined the piping spool pieces in question and verified that the shop welds did not meet the surface finish required by the applicable specification. Deficiency and Disposition Report (DDR) - 1365 was issued March 8,1983 for purposes of identifying and controlling the condition.
A Southwest Fabricating and Welding (SFW) QA representative came to the site July 13 and 14,1983 to reinspect the welds in question. This reinspection confirmed that the welds contained areas where the profile and surface finish were not conducive to effective ultrasonic examination.
An inspection of installed piping spools which require in-service inspection (ISI) was implemented on August 8,1983 to determine the extent of the weld surface preparation deficiencies. A total of 191 welded joints were inspected. The number of welds found to f
require some amount of surface re-preparation was sufficiently high that Carolina Power
& Light Company (CP&L) determined that all shop welded joints requiring ISI will be identified, inspected and reworked as necessary to meet the specified surface finish requirements.
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, Corrective Steps Taken and Results Achieved (cont'd.):
The process of identifying all shop welded joints which require ISI is underway. It is estimated that some 3000 joints will be within the scope of the inspection and rework effort. Inspection and rework of uninstalled piping spools will commence as soon as the required special equipment can be procured and the necessary training of personnel can be accomplished. Installed piping spools will be inspected and reworked in a sequence which supports CP&L's system Release-for-Test schedules.
Corrective Steps Taken to Avoid Further Noncompliance:
All Unit 1 piping requiring ISI and contracted with SFW is on site and will be included in the above described inspection and rework program.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved prior to Fuel Loading of Unit 1.