ML20095H365

Responds to NRC Re Violations Noted in Insp Rept 50-400/83-25.Corrective Actions:Evaluation Performed to Identify Fasteners in Motor Control Ctrs Under Scope of Reg Guide 1.29

ML20095H365
Person / Time
Site:	Harris
Issue date:	07/26/1984
From:	Parsons R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20095H354	List: ML20095H365 ML20095H385 ML20095H403
References
CON-NRC-244 NUDOCS 8408280460
Download: ML20095H365 (3)

Text

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CD&L I Carolina Power & Ligpt;Cogapy P. O. Box 101, New Hill, N. C. 27562 July 26,1984 Mr. James P, O'Reilly .

NRC-244 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30323 ,

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Dear Mr. O'Reilly:

In reference to your letter of October 19,1983, referring to RII: PRB 50-400/83-25-01, the attached is an update of Carolina Power and Light Company's position on the violation identified in Appendix A. This letter supersedes our November 18,1983 and November 30, 1983 responses as they pertained to Violation 83-25-01.

It is considered that the corrective actions taken are satisfactory for resolution of the item.

Thank you for your consideration in thi:2 matter.

Yours very truly, g h-ed R. M. Parsons Project General Manager Shearon Harris Nuclear Power Ph nt RMP/sh Attachment ec: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. B. C. Buckley (NRC) 8408280460 840810 gDRADOCM 05000400 PDR

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'l Attachment to CPacL Letter Concerning NRC Report RII: PRB S0-400/83-25-01 Reported Violation: l l

10 CFR 50, Appendix B, Criterion X, as implemented by the Carolina Power and Light PSAR Section 1.8.5.10, requires that inspection of activities affecting quality shall be executed to verify conformance with the documented instructions. Construction l procedures TP-28 and WP-105 are the Harris site instructions that are usr.ti M the i installation inspection of safety-related equipment.

Contrary to the above instructions, the installation inspection, which was performed for Motor Control Centers (MCCs) 1A35-SA and IB35-SB was inadequate in its execution in that inspection failed to identify the following:

1. The MCC hold-down fasteners were not tightened.

2. The MCC elevation checks were not adequately performed.

3. The welding of the MCC mounting sill to embedded plates differed from the requirements on the vendor plan which was referenced on the welding instructions.

This is a Severity LevelIV Violation (Supplement II), and is applicable to Unit 1 only.

Denial or Admission and Reason for the Violation:

The violation is correct as stated.

1. The fasteners were loose because either they were not checked closely enougt or they were loosened by others who may have performed work on the MCCs after the inspection by CI.

2. Elevations were checked indirectly by CIInspector by verifying previous sign off of pad elevation by Civil CI when pad / embeds were installed.

3. The QC Structural Welding Inspector inspected the weldments in question as per the vendor drawing's minimum weld size 1/4" x 1/4" x 3". Using the lA4 welding process i and a 1/8" E-7018 electrode, an acceptable 1/4" fillet weld was not attained.

Therefore, to reach the required weld size, multiple passes were performed. The QC Inspector should have requested clarification before performing the final inspection.

Corrective Steps Taken and Results AcReved:

1. An evaluation was performed to identify fasteners in MCCs under the scope of Regulatory Guide 1.29. They have been reinspected to ensure tightness under construction procedure TP-28. Discrepancies were noted and resolved.

2. Since there is no elevation specified by the vendor or Ebasco drawings for the MCC's, and the equipment pads were previously checked by Civil CI, an elevation check is not considered necessary. WP-105 and TP-28 have been revised to reflect this.

3. Motor Control Center mounting sill weldments werc * /aluated by Harris Plant Engineering Section and were found to be structurally sound. FCR-AS-3914 (approved October 27, 1983) was issued to allow for multiple weld passes to attain

- the required weld size.

',* Corrective Steps Taken to Avoid Further Noncompliance:

1. (a) Additional training of inspection personnel involved in inspection of MCCs was conducted by the lead inspector on October 28, 1983 emphasizing closer inspection of MCC fasteners for correct tightness under TP-28.

(b) Exhibit 12, WP-105, is now being used to have CI check the results of work performed on equipment that has been disassembled. Exhibit 12, WP-105, is used for special assembly of equipment. This exhibit will be required to be initiated if equipment has to be disassembled to facilitate installation and has to be reassembled after installation.

2. Inspection personnel involved with inspection of MCCs received training by the lead inspector on October 28, 1983 on the requirements for elevation checks against vendor, Ebasco, or CP&L approved design documents.

3. QC structural welding inspection personnel have been instructed to follow applicable inspection criteria (i.e., FCR's, DCN's, PW's, Vendor and Engineering related drawings). If conflicts arise, inspectors will request clarification of information prior to performing inspection.

Date When Full Compliance Will Be Achieved:

1. Full compliance was achieved on January 31,1984.

2. Full compliance was achieved on January 1,1984.

3. Full compliance was achieved on October 28,1983.

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