ML20212K277
| ML20212K277 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/06/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-468 HO-860325-(O), NUDOCS 8608190332 | |
| Download: ML20212K277 (4) | |
Text
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?q Cp&L Carolina Power & Light Company
[,
ll doe O, C SHEARON HARRIS NUCLEAR PROJECT P. O. Box 101 New Hill, North Carolina 27562 AUG C nas File Number:
SHF/10-13510E Letter Number: HO-860325 (0)
Dr. J. Nelson Crace NRC-468 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323
Dear Dr. Grace:
In reference to your letter of July 10, 1986, referring to RII:
50-400/86-41-02, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, d h Ojfr
[ Vice President R. A. Watson Harris Nuclear Project RAW /sde Attachir.cnt cc: Messrs. C. Maxwell (NRC-SHNPP)
B. C. Buckley (NRC).
B608190332 860006 PDR ADOCK 03000400 l
O PDR 1
1EO N MEM/Ho-8603250/ PACE 1/OS1 U.S, NRC REGION U CFFICIN rnpy
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Attcchment to CP&L Lettsr cf Respons2 to NRC R; port RII:- 50-400/86-41-02 Reported Violation 10 CFR 50, Appendix B, Criterion VII, as implemented by PSAR Section 1.8.5.7, requires measures be established to assure that purchased materials conform to procurement documents.
Contrary to the above, the program for the control of purchased materials affecting quality was not effectively implemented to assure that purchased materials were in conformance with specified requirements, as evidenced by the following examples.
The documentation for the High Efficiency Particulate Air filters for the E6(IB-SB) Safety-related air handling unit did not comply with the purchase specification. The filters were not receipt inspected because they were erroneously identified as non-nuclear safety-related.
- Purchased piping failed to meet minimum wall thickness requirements of the purchase specification. The above condition was noted on 30 percent of the 20 pipe sections inspected by the Construction Appraisal Team.
This is a Level IV violation Supplement II.
Denial or Admission and Reason for the Violation:
CP&L admits the violation and for the purposes of this report will respond in two parts. Part A will address the issue of filters. Part B will address piping.
A.
Filters were processed on site as non-safety related and, hence did not receive a formal QA receipt inspection which includes review of documentation for adequacy. The reason for the filters being processed as non-safety related was attributable to the factors listed below:
1)
The filters were bought under Ebasco purchase order NY-435162. The bulk of the items obtained through this purchase order are non-safety related.
2)
Filters for both safety and non safety applications are identical, interchangeable and are not individually designated for use on a specific piece of equipment.
B.
The technique used at receipt inspection to obtain random measurements of pipe wall thickness (i.e., the use of vernier calipers) was designed to detect wall thickness discrepancies near the ends of pipe spools which had been prepared for welding. This was not adequate to identify minimum wall violations in other portions of the pipe, nor was it adequate to identify the extremely small deviations from minimum wall noted by the Construction Appraisal Team (CAT). Ultrasonic techniques were used by CAT to identify these deviations. CP&L, to a large extent, relied on the manufacturers ASME approved QA Program and the Supplier's certification that the piping met the appropriate Code requirements.
MEM/H0-8603250/ PACE 3/0S1
n Corr ctive Stcp1 T-ke7 cnd R:ruito Achicv d:
A.
The Harris Plant Engineering Section (HPES) performed an investigation to identify the Ebasco specifications and purchase orders that had the likelihood of leading to confusion similar to that experienced with the filters. QA verified receipt inspection had been performed on those identified purchase orders:
NY-435084 - Electrical Cable NY-435113 - Metal Clad Switchgear NY-435147 - Water Chillers NY-435152 - Electric Heating Coils NY-435162 - Air Cleaning Units NY-435288 - Hydrogen Analyzer Results of the reverifications are as follows:
NY-435084 - No problems noted.
NY-435113 - No problems noted.
NY-435147 - Six shipments received of which four were safety-related.
Two of the four had not been receipt inspected; also missing documentation was identified. The required receipt inspection has been performed and the missing documentation has been obtained from the vendor.
NY-435152 - Out of thirty-eight shipments, nine were safety-related, of which one had not been receipt inspected. This shipment has now been receipt inspected.
NY-435162 - This purchase order pertained directly to the violation. As part of the corrective action, six hundred and fifteen HEPA filters were receipt inspected. Sixtce.n filters were found damaged. NCR 86-0367 was initiated for missing or erroneous documentation and for the damaged filters. The damaged filters were scrapped. Missing documentation was obtained and minor documentation problems were resolved by permanent waiver, PW-M-1951 and by revision to specification BE-31.
The NCR was l
closed on July 10, 1986. The HEPA filters transferred to the Operations I
warehouse have been receipt inspected. Operations QC issued NCR 86-0033 on June 2, 1986 addressing documentation deficiencies. Deficiencies l
haya been corrected and the NCR was closed on July 3, 1986.
l l
NY-435288 -No problems noted.
Additionally, QA obtained a 10% sample of the purchase orders associated with Westinghouse shop orders 325 - Field Instrumentation, 386 -
Electrical Equipment, 395 - Main Control Board, and 185 - Fuel Handling l
Equipment, to reverify that receipt inspection had been performed on those l
orders. A total of 332 purchase orders were involved, of which 33 were sampled. No problems were noted on 32 of the 33 purchase orders. One purchase order, pertaining to the Pen Pam Recorder for shop order 395, had the required documentation, but there was no evidence of receipt inspection. This material has since been receipt inspected. No hardware j
or documentation problems were noted through this receipt inspection process.
MEM/HO-8603250/ PACE 4/0S1
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.l B.
As netsd by ths CAT inspection in Octobsr/Nov:mbtr of 1984, piping manufactured by Jones & Laughlin Steel Corporation and Phoenix Steel Corporation did not meet iae ANSI standard minimum wall thickness in some areas. Six spools were noted by CAT as suspect. Three of these six spools were found by CP&L, through analysis, to have met design minimum wall. This is documented on permanent waiver PW-P-3123.
The unacceptable portions of the other three spools were either scrapped, taken out of the safety-related program or returned to the vendor (see NCR 84-2087).
Hovaver, they were not evaluated for compliance with design minimum wall since these pieces had not been designated for specific applications.
CP&L conducted an extensive investigation of the problem. Two hundred forty-three (243) total pieces of pipe were identified as supplied by the manufacturers in question. A statistical sample, exceeding the minimum required per MIL STD 105-D, (sample size - 50 pieces) was chosen to compare actual wall thickness to ANSI minimum. Four pieces of pipe were declared suspect and documented on NCR 85-1023. Three of the four pieces were found through analysis to have met design minimum wall. The fourth spool was not evaluated for compliance with design minimum wall since this piece had not been designated for a specific application. The portions of this spool that did not meet the ANSI minimum wall thickness were scrapped.
In summary, an extensive evaluation of the material received from the vendors in question revealed that in no case was piping overstressed due to inadequate material thickness. Suspect pieces that were not technically evaluated were either scrapped, taken out of the safety-related program, or returned to the vendor. Our conclusion, based on our investigation, is that piping installed at Harris is adequate for its intended use.
Corrective Steps Taken to Avoid Further Noncompliance:
A.
Purchasing of equipment / parts has been transferred from Ebasco to CP&L.
Purchase requisitions are generated at the site in accordance with procedure AP-XII-01. Quality classification (i.e., "Q" vs "non-Q") is provided directly on the purchase requisition to clearly designate the l
safety classification of the equipment / parts. Also, on the remaining active Ebasco/ Westinghouse orders involving both "Q" and "non Q" equipment, receipt inspection personnel have been directed to check with appropriate HPES/ Westinghouse personnel to determine if material received is "Q" or "non-Q" before releasing items to the field.
B.
Receipt inspection practices have been revised to require sample check of j
pipe wall thicknesses by the ultrasonic technique. This method is far i
more accurate than the previous technique of measuring wall thicknesses by the use of vernier calipers and allows measurement at random locations l
d ong the pipe.
l Date When Full Compliance Was Achieved:
A.
July 18, 1986 B.
July 18, 1985 MEM/HO-8603250/PAGE 5/OSI l
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