ML18017B267
| ML18017B267 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/19/1980 |
| From: | Howe P CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B266 | List: |
| References | |
| NUDOCS 8010310341 | |
| Download: ML18017B267 (7) | |
Text
Carolina Power & Light Company a~a'pa@ ~m~m~~,, ~wve~e
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'Raleigh, NC 27602 September 19, 1980 Mr. James P. O'Reilly United States Regulatory Commission Region II 101 Marietta Street, Nor thwest Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of August 26, 1980, referring to RII NE 50-400/80-18, 50-401/80-16, 50-402/80-16, 50-403/80-16, the attached is Carolina Power and Light Company's reply to the deficiencies
,identified i.n Appendix A. It is considered that the corrective and pre-ventive actions taken are satisfactory for resolution of these items.
Thank you for your consideration in this matter.
Yours very truly, C3. u.
P.
W.
Howe Vice President Technical Services NJC:jp Attachment cc:
Mr. J. A. Jones Solos.zoZ/I
~ vr'A Y
INFRACTION Condition Reported:
A.
As required by Criterion V of Appendix B to 10 CFR 50, and implemented ualit shall by Carolina Power and Light PSAR Section 1.8.5.5 "At't' n...,
c ivi ies affecting drawin s q
s a
be prescribed by documented instructions p o d
ns, proce ures or
's,...and shall be accomplished in accordance with these instruc-tions, procedures or drawings."
1.
Paragraph 9.1 of CP&L Procedure CQA-2, Rev.
2 states in part that
....procedures or portions thereof that have been superseded or voided will be recalled or destroyed.
Contrary to the above, on July 9, 1980, Revision 2 of Meld Procedure Specification MPS-8BU7, voided by Revision 3 issued on June 18, 1980 was still being used by cr aft in the field.
2.
Appendix A of CP&L Procedure AP-VII-06, Revision 2 states in part that
"...excess materials (trash) shall not be allowed to accumulate and create condition which may adversely affect quality.
Contrary to the above, on July 7 and 8, 1980 construction debris and buildin co trash in excessive amounts were observed inside the f el h d
g, ntainment and other areas where work was in progress.
3.
Paragraph 3.7 of MP-113 states in part that component ends shall be appr opr iatel lu ed o upon.
y p ugge or sealed....when the ends are not being w
k d u
e o
're Contrary to the above on July 8-9 1980 throughout th t
t' e cons ruc ion
, excep e storage yard, stainless steel fabricated spools and on the ro pipe material were observed without protective c
t ive caps, res xng in water, n
e ground and in one instance par tially covered with cement.
B.
As required by Criterion XVII of Appendix B to 10 CFR 50, and implemented by Carolina Power and Light PSAR Section 1.8.5.17, "Sufficient records shall qualit."
Pa be maintained to furnish documented evidence of tf ac ivi ies a
ecting their thickness for whi Paragraph QM-351 of AS1K Section IX require th t th 1't s
a e
imi s of hich a welder is qualified are dependent upon the thickness of the weld deposited with each welding process.
Contrary to the above on July 10, 1980 welder performance qualification records involving combination processes did not indicate the weld metal thickness deposited with each welding process.
C.
As required by Criterion VIIIof Appendix B to 10 CFR 50, and implemented by Car olina Power and Light PSAR Section 1.8.5.8 "Identification and contr ol measures shall be designated to prevent the use of incorrect....material..."
Contrary to the above on July 9, 1980 low carbon stainless steel 308<<L issued to t e f electrodes produced from heat numbers 602571 and 65325HQBD were being he field as regular analysis 308 stainless steel electrodes.
INFRACTION Page Two
'orrective Steps Taken and Results Achieved:
A.
1.
Meld Procedure Specification MPS-8BU7, revision 3, was issued by Document Control on June 18, 1980, to the Melding Engineering Unit and was subsequently issued to the craft in the field on July 10, 1980.
The superceded revision was destroyed.
However, revision 3 to WPS-8BU7 did not affect quality since the change was to a
'"non-essential variable allowing the use of a larger gas cup size.
2.
Discrepant housekeeping items have been corrected.
3.
The site area has, been inspected for discrepancies as listed and corrections have been made.
B.- l.
A M.P.S.
{Meld Procedure Specification) consisting of two welding processes are controlling thickness by specifying one
{1) to three
{3) passes for the root pass by Gas Tungsten Arc Melding process and the balance to be completed by the Shielded Metal Arc Melding process.
This ensures that the welding procedure and welders were properly qualified and employed in the weld joint.
The actual thickness of the weld deposited by each process, was not shown but was controlled by the number of passes.
Welder performance qualifi-cation records involving combination processes have been revised to show the actual weld metal thickness deposited by each process.
All new welder performance qualifications will show the actual weld metal thickness deposited by each process.
2.
When a combination M.P.S. is specified for welding a joint, both welding processes shall be used and welder will be qualified for both processes within the thickness limitations.
3.
A review of safety related items welded revealed that when a com-bination M.P.S.
was specified, both processes were used and the welders were qualified to both processes within the thickness limitations.
When only one process of a combination weld process was specified, the thickness limitation of that process was ensured by Welding Engineering to meet the thickness of the qualification.
This case was found only on a combination bi-metallic W.P.S.
1-8BA4.
This work was checked and verified by reviewing all of the respective Meld Data Cards and resulted in no violations being found.
C.
All of the weld issue station attendents were provided with additional class room training on all filler metals, especially those with "L" and "ELC" designations.
A review of all records revealed that the 308L material had been used only on applications of welding 304 stainless steel and was acceptable to meet, design requirements.
Based on records of heat Numbers of all records where 308L filler metal had been used, a revision to affected documents was made to show the correct type of filler metal used.
A Field Change Request
{FCROW-035) was written and approved by the Architect Engineer to allow the use of 308L material on liner plates.
INFRACTION Page Three Corrective Steps Taken to Avoid Further Noncompliance:
A.
1.
Responsible personnel in Melding Engineering have been instructed to transmit all M.P,S. revisions to the craft in the field no later than one (1) working day from the time of receipt from Document Control.
2.
Steps taken to avoid further noncompliance are as follows:
l.
Areas of housekeeping responsibility have been assigned to supervision.
2... Designated'eating.areas have been assigned per building for all power block structures.
3.
The monitoring of Zone 5 power block areas by Daniel Technical Services has been intensified.
4.
Re-indoctrination of field supervision to requirements of house-keeping has been accomplished.
5.
The indoctrination of new hire craftsmen will include instruction by the Daniel Training Department as to housekeeping requirements and designated eating'areas.
6.
Craft foremen will receive orientation to housekeeping as provided by their respective cr aft superintendents.
3.
CP4L has instructed the Contractor (Daniel Contrustion Company) to keep all pipe ends capped unless work is in process.
On a continuing basis CPhL is monitoring to ensure pipe ends are capped when work is not in process.
Steps taken to avoid further noncompliance by the contractor are as follows:
l.
A meeting was held by the General Pipe Superintendent and all field Piping Superintendents, General
- Foremen, and Foremen for review of procedure requirements.
2.
A walk-through inspection will be performed by the Pipe Superintendent (or his designee) each week and applicable corrective action will be taken for each tour.
3.
Continued emphasis will be placed on "end cap and/or covering" with Foremen and General Foremen.
B.
Portions of a combination M.P.S. will not be utilized in the welding of a field joint. If a single process is required, a M.P.S. using a single process shall be specified.
When a combination procedure is specified, both processes will be used and the welder will be qualified to both processes within the thickness limitation.
Documents weill also list thickness range requirements.
~ '
Ct
INFRACTION Page Four C.
Additional training was conducted by the Melding Engineering Unit for issue stabion attendents, warehouse personnel.,
QA personnel and craft supervision who write material requisitions for welding.
Date When Full Compliance Mill Be. Achieved:
A.l. Full compliance is considered to have been achieved on July 10, 1980.
A.2.
Full compliance is considered to have been achieved on September 15, 1980.
A.3.
Full compliance is considered B.
Full compliance is considered to have been, achieved on September 15, 1980.
to have been achieved on September 3, 1980, C.
Full compliance is considered to have been achieved on July 30, 1980.