ML20095H403

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Updates 840601 Response to NRC Re Violations Noted in Insp Rept 50-400/83-29.Corrective Actions:Site Administrative Procedure Governing Identification of Bolting Matl Issued
ML20095H403
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 07/25/1984
From: Parsons R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20095H354 List:
References
CON-NRC-242 NUDOCS 8408280469
Download: ML20095H403 (2)


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[' i, Form 244 Carolina Power & Light Company L00 MD:12 company correspondence F. O. Box 101, New Hill, N. C. 27562 July 25,1984 -

Mr. James P. O'Reilly NRC-242 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

The following is an update on our progression concerning the violation identified in RII:

GFM/RLP 50-400/83-29. This letter supercedes our June 1,1984 response.

In our December 9,1983 letter, NRC-152, we informed you of the actions we planned to take to resolve the. referenced violation concerning non "Q" class bolting material being used in a "Q" class application. ASME Code bolting, which has specific traceability requirements was not a concern and is not addressed here.

In our February 1,1984 letter, NRC-177, we stated that our commitment to revise site specifications where necessary, to allow substitution of bolts which are marked as standard practice for those which are not already marked or easily identifiable by shape, manufacturers' mark, etc., had been met. We also stated that we had, subsequent to our initial response, identified instances where quantities of unmarked fasteners were being supplied by some vendors along with unassembled equipment or materials, and that we were devising methods for identifying these fasteners, also. In addition, we stated that investigation for acceptability of previously installed fasteners was in progress.

We have now established and implemented a system whereby these vendor-supplied fasteners are marked similarly to those site purchased directly. Unmarked "Q" bolts will no longer be issued to the field, except replacement bolts for those supplied with equipment, and for which there are no acceptable substitutes. These will be controlled through receipt inspection and issued in marked containers.

We are routing requistions for fasteners through the Civil Resident Engineer to assure they are ordered as "Q" which will require them to go through a receipt inspection. We have issued a site administrative procedure governing identification of bolting material and feel that by controlling "Q" bolts, from purchase through installation and final acceptance, we can eliminate the requirement for ordering non "Q" fasteners as "Q", also.

In addition, we have determined there is no project requirement for a Certificate of Conformance for " commercial grade" Q materials such as bolts, only that they receive QC receipt inspection.

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-Mr. James P. O'Reilly NRC-242 Therefore,' with the issue of our procedure, non-ASME Code bolting materials will be controlled as follows:

Requirements have been established to uniquely identify "Q" bolts as to material type and grade and/or other specified ressements and fur +her, to require QC receipt inspection where identification will be verliied.

"Non-Q" fasteners may be ordered "non-QS, b bt w l'u stiil be received by QC receiving. Upon receipt, non-Q fasteners.will be compared with the approved list of

'Q' fastchers. If they are similarly marked, they will receive the same QC receipt inspection required far 'Q' fasteners, arel will be acceptable as 'Q'. If they are not marked similar to the 'Q' fastenerr, they will be released to the warehouse for issue for non-Q use.

Until such time as we have gained confidence in cur procedure, requistions for fasteners will continue to be routed through the Civil Resident Engineer to ensure they are ordered as "Q" and receive a receipt inspection.

j Investigation for acceptability of previously installed fasteners is continuing. To ensure acceptability of fasteners already installed, they are being inspected or verified prior to final system turnover to plant operations. Therefore, we project completion of the reinspection / verification to be March 31,1985.

Thank you for your consideration in this matter.

Yours very truly, l

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. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant l

j RMP/pg ec: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. B. C. Buckley (NRC) l l

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