ML20112C184

Intervenor Exhibit I-JOINT-9,consisting of RM Parsons 830316 Response to NRC Re Violations Noted in Insp Rept 50-400/84-02.Corrective Actions:Exhibit 12 Prepared for Procedure WP-105, Installation & Insp of Equipment

ML20112C184
Person / Time
Site:	Harris
Issue date:	09/05/1984
From:	Parsons R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
CON-NRC-194 OL-I-JOINT-009, OL-I-JOINT-9, NUDOCS 8501110069
Download: ML20112C184 (2)

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• P. O. Box 101, New Hill, N. C. 27562 Alarch 16,19S4

• a5 JAN -8 P3 :44 Mr. James P. O'Reilly gna m: up United11 Region States Nuclear Regulatory Commission IS^R 'CI l k' [C

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101 Marietta Street, Northwest (Suite 2900) f Atlanta, Georgia 30303 j

Dear Mr. O'Reilly:

In reference to your letter of February attached Appendix A. is Carolina Power and Light 17, 1934, referring to RII: WPA 50-400/S4 02, the Company's reply to the violation identified in It isitem.

the considered that the corrective action taken and planned is satisfact ory for resolution of Thank you for your consideration in this matter.

Yours very truly, fypf mW R. M. Parsons Project General Manager RMP/sh Shearon Harris Nuclear Power Plant Attachment cc:

Messrs.

Mr. G. Maxwell B. C. Buckley (NRC) /R. Prevatte (NRC-SHNPP) huph RLggAfgsf COMMMA 3,3,, n,. G c 'lo n -o ' Otticial Ein. no U C#"M' 9 In the matter et b NM' # -

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g a & f Attachment to CP&L Letter of Response to NRC Report RII: WPA 50 400/34 02 Reported Violation:

10 CFR 50 Appen' dix B, Criterion X, as implemented by CP&L PSAR Section 1.S.5.10 requires that inspection of activities affecting quality shall be executed to verify conformance with documented instructions, procedures or drawings. Westinghouse drawing $33FS29 requires the installatton of anchor bolts and nuts on the reactor vessel nozzle supports. Ccnstruction inspection records dated March 30, 1980, verified satisfactory installation and inspection of the 145!f. azimuth RV support in accordance with Technical Procedure 23, Revision 1.

Contrary to the above, TP-23, Revision I and the inspection performed was inadequate because:

a. TP-23, Revision 1, did not require verification of proper installation and tightening of anchor bolt f asteners.

b. On August 25, 1933, one anchor bolt nut was not installed and one anchor bolt nut could be turned by hand on the 145% azimuth reactor vessel nozzle support.

This is a Severity Level IV (Supplement II).

Denial or Admission and Reason for the Violation:

The violation is correct as stated.

The process control for complete installation and inspection of the Reactor Vessel Supports was incomplete. Procedures WP-119, Reactor Vessel Setting, and TP-23, inspection of Equipment for Setting and Grouting, inadvertently f ailed to address post-grouting activities (e.g., final bolting and bolting inspection).

Corrective Steps Taken and Results Achieved:

Procedure TP-23, Revision 3, which incorporated inspection of tightness of connections and fastenings, was issued September 23, 1980. The procedure title was changed at that-time to " Inspection of Equipment Installation".

As a process control measure, an Exhibit 12 to precedure WP-105, Installation and Inspection of Equipment, has been prepared 'or accomplishment of the necessary work and inspection points for the Reactor Vessel Supports. The process will be completed in accordance with WP-105 and TP-23 by May 1,1934.

Corrective Steps Taken to Avoid Further Noncompliance:

A review of existing special procedures (such as WP-119) for installation of major equipment items is being performed to ensure that they are adequate. The review of these procedures, and the issue of revisions as necessary, will be completed by May 1, 1934. Procedures WP-105 and TP-23, through long usage and seasoning, have stabilized the equipment installation program and will enhance the identification of inadequacies that might occur in special procedure situations in the future.

Date When Full Compliance Will Be Achieved:

Full compliance will be achieved by May 1,1934.

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