ML20095L584

Provides Addl Response to NRC Re Violations Noted in Insp Rept 50-400/83-29.Corrective Actions:Procedure for Control of non-ASME Bolting Matls Will Be Implemented by mid-June

ML20095L584
Person / Time
Site:	Harris
Issue date:	06/01/1984
From:	Parsons R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20095L577	List: ML20095L584
References
CON-NRC-224 NUDOCS 8408300350
Download: ML20095L584 (2)

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u Carolina Power & Light Company a mi 5. Pl2 : 3 'l i P. O. Box 101, New Hill, N. C. 27562 June 1,1984 Mr. James P.' O'Reilly. _

NRC-224 United States Nuclear Regulatory Commission L Region II

' 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear.Mr. O'Reilly:

In our December 9,1983 response to RII: GFM/RLP 50-400/83-29, 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-

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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 ara 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 i . 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 and issued in marked containers.

I As stated in our December 9,1983 response, we have purchased all fasteners "Q", to avoid

. confusion, between "Q" and non "Q" requiring a receipt inspection of all site purchased i

fasteners. We are, however, in the process of issuing a site administrative procedure governing identification of bolting material and feel that by controlling "Q" bolts, from

j. purchase through installation and final acceptance, we can eliminate the req 'rement for

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

Therefore, with the issue of our procedure, non-ASME Code bolting materials will be

- controlled as follows:

.' All "Q" bolts will be uniquely identifiable as to material type and grade, and will require

! = QC receipt irspection, where identification will be verified.

D "Non-Q" fasteners may be ordered "non-Q", but will still be received by QC receiving.

Upon receipt, non-Q fasteners will be compared with the approved list of 'Q' fasteners. 'If they are similarly marked, they will receive the same QC receipt inspection required for B408300350-840608 i PDR ADOCM 05000400 i

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, Mr. 3;mes P. O'Rr. illy NRC-224

'Q' fasteners, and will be acceptable as 'Q'. If they are not marked similar to the 'Q' fasteners, they will be released to the warehouse for issue for non-Q use.

Our Bolting procedure should be issued for use by mid June. Until that time, we will continue to order all bolts as "Q".

Investigation for acceptability of previously installed fasteners is continuing. To ensure acceptability of fasteners already installed, they are being inspected or verified prior to each system being turned over 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, p)f k d:=2^

R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh cc: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. B. C. Buckley (NRC) t

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