ML18017B133

Responds to NRC 800513 Ltr Re Violation Noted in IE Insp Repts 50-400/80-11,50-401/80-08,50-402/80-08 & 50-403/80-08. Corrective Actions:Investigation Held of Collected Test Data Re Backfill Matl Affecting Category I Piping

ML18017B133
Person / Time
Site:	Harris
Issue date:	06/05/1980
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18017B132	List: IR 05000400/1980011 ML18017B131 ML18017B133 ML18017B134 ML18017B135 ML18017B136
References
NUDOCS 8007100418
Download: ML18017B133 (3)

See also: IR 05000400/1980011

Text

(~.~CHAL Carolina Power&Light Company Jltd I.'l: SO June 5, 1980 Mr.James P.O'Reilly United States Nuclear Regulatory

Commission

Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 Dear Mr.O'Reilly: In reference to your letter of May 13, 1980, referring to RII: JJL 50-400/80-11, 50-401/80-08, 50-402/80-08

and 50-403/80-08, the attached is Carolina Power and Light Company's reply to the in-fraction identified

in Appendi1t A.It is considered

that the corrective

and preventive

actions taken are satisfactory

for resolution

of this item.Thank you for your cooperation

in this matter.Yours very truly, P.M.Howe Vice President Technical Services NJC/mst cc: Mr.J.A.Jones eoovxoo'/(tr

411 Fayetteville

Street~P.O.Box 1551~Raleigh, N.C.27602~.if::>';It,".TAT.

COPY

Condition Reporte As required by Criterion III of Appendix B to 10 CFR 50, implemented

by Carolina Power and Light PSAR Section 1.8,"Measures shall be establisped

to assure that applicable

regulatory

requirements

and the design basis...are correctly tr anslated into specifications, drawing, procedures, and instructions.

These measures shall include provisions

to assure that appropriate

quality standards are specified and included in design documents and that deviations

from such standards are controlled".

ANSI N45.2.11, implemented

by PSAR Section 1.8.1, requires design inputs, which include structural

requirements

such as foundations

and pipe supports, to be specified to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent

basis for making design decisions.

Contrary to the above, the measures required by Criterion III failed to assure that the design inputs concerning

the effect of settlement

of the backfill supporting

Category I piping adjacent t'o the powerblock

was eval-uated in design analysis of the piping.Omission of these design inputs could have resulted in overstressing

and failure of the piping.As a result, the backfill supporting

the piping has been or will be excavated and replaced with fill concrete in order to provide the necessar y foundation

support for the piping where it enters the powerblock.

Corrective

Steps Taken and Results Achieved: The infraction

resulted since the effect of settlement

of backfill which provides support for Seismic Category I piping adjacent to the plant buildings was not considered

in the design of the building by the Architect Engineer.Corrective

action completed in relation to backfill material affecting Category I piping includes the following:

l.An investigation

into previously

collected test data.2.Plan and section details added on design drawing reflecting

locations of all relevant fill and backfill materials affecting Category I piping and duct banks.3.Design data input compiled from previous results of field and laboratory

tests.4.Theoretical

estimates of settlements

were researched

and compiled.5.Assessments

of the stability and dynamic behavior of the Category I pipelines and fill.6.A revised inspection/testing

procedure to assure full compliance

with realigned design criteria.7.Revised design drawing (Revision 2, CAR-2167-G-0488)

identifying

and detailing backfill adjacent to Seismic Category I buildings.

Infraction

Page Two Prior to placement of any backfill material adjacent to the power block where Category I piping would span, a design drawing change was initiated to require 2,000 p.s.i.concrete fill.The concrete was placed in the ex-cavated void under the area of Category I pipes between the building concrete wall and the excavation

soil/rock slope, and from the lower foundation

rock to six inches below pipe invert.Corrective

Steps Taken to Avoid Further Noncompliance:

The application

of concrete backfill in areas of abrupt changes in backfill depth will result in an insignificant

differential

of settlement

and eliminate the possibility

of overstressing

piping.The completed research, issue of detailed design drawing and revision to inspection/testing

procedure (T.P.-02, Revision 13 and 14)is considered

sufficient

to preclude further concern of subject design deficiency.

Date'/hen Full Compliance

Mill be Achieved: Item is considered

closed as of May 28, 1980.