ML18017B391
| ML18017B391 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/28/1981 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B390 | List: |
| References | |
| NUDOCS 8105200021 | |
| Download: ML18017B391 (7) | |
Text
CITAL Carolina Power & Light Company
- Raleigh, N..C. 27602 Ap'ril'28, 1981 RC R VOp)(( -r Usq
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0 t 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 April 3, 1981, referring to RII:
- GFM 50-400/401/402/403/81-06, the attached is Carolina. Power 5:Light Company's reply to. the deficiencies identified in. Appendix. A. It is considered. that the corrective and preventive actions taken will be'atisfactory for resolution of these: items.
ll To the.best:of'y knowledge,. information, and belief, the corrective action in thia report is true and complete.
Thank you for your-'consideration in this matter.
Yours very, truly, H. R.. Banks
- Manager, Corporate Quality Assurance NJC:jp Attachment cc:
Mr J.
A., Jones Sworn: to and Subscribed,beforeme this 28th.day of April, 1981.
Notary ublic My -commission expires June 5, 1984.
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Severity Level V Violations Conditions Reported:
A.
10 CFR 50, Appendix B.. Criterion X as implemented by PSAR section 1.8.5.10; CPKL's Corporate QA Pr ogram Part I, section 8.3.4 and construction procedure QCI-19.2, section 5.1 and 5'.l.l requires site QA.welding inspection personnel to conduct inspections at designated QA. inspection hold points.
Contrary to the above, QA inspection: hold. points. numbered.
one through, five on the weld data report for containment penetration weld C1-265-M-108-AFPP.
were not witnessed: or inspected by. the.site welding QA inspection personnel.
On, February 25,, 1981. steps one through five on; the weld data report for containment penetration weld M-108-AFPP were found to have. been completed without, being inspected. by: the.site, designated welding QA inspection group.
B.
10 CFR 50, Appendix. B, criterion V's implemented by'SAR section 1.8.5.5 and CP&L's Corporate QA Program Part I; section, 6.2.1.f. requires procedures to contain sufficient detail..to assure that activities important to safety have'een satisfactorily accomplished.
Qi Contrary to the above,. construction procedure TP-40 revision. 0 does not contain. sufficient detail to determine the necess'ary education or experience required. for mechanical..or. electrica1.,inspection personnel.
As of February 27; 1981. Construction. Inspectors with very limited previous related.
education. or experience are certified as unlimited mechanical and/or electrica1.
inspectors and the Construction Inspection Supervisor responsible for the training, supervision. and qualification of. mechanical and electrical. in-spectors does not have sufficient education or background experience in either mechanical or. electrical fields.
Denial or Admission. and Reasons, for Violations:
A..
The violation, identified by NRC audit was correct as stated.
The QA; Specialist.
(Welding) inadvertently, returned. the subject Weld, Data Report to the Welding Engineering Group for their inspection of the welding..
B.
The violation. identified by NRC audit was correct as stated..
Prior to the Construction Permit for the Harris Project,, the Company had taken
- a. position on Regulatory Guide 1.58 (and,.ANSI'-45.2.6) in that'nspection personnel would not be certified. to levels. of qualification..
The initial concept was to have: inspection personnel qualified, to subcategories of inspection activities in, lieu of broad categories suggested by ANSI N-45.2.6.
To do this, it was, recognized that project procedures would need to specify the detailed requirements, or be written in more general. terms to pe'rmit the latitude needed to accomodate this approach.
Construction and Quality Assurance Management opted. for. the procedures to be in. general insofar-as education and experience requirements were concerned.
The quality assurance procedures and the construction procedures that followed, continued to embrace the early approach.
TP-40, Revision 0, evolved from this philosophy and as noted by the NRC inspector, was found lacking in detail to determine the necessary education and experience required for inspection personnel.
,-Seve>itv* Level V Violations Page Two Contrary to the management philosophy identified above, several unlimited certifications were issued to personnel not fully qualified, though it was intended that necessary experience and tzaining would be gained prior to-performance of inspection on an unlimited scale.
The procedure inade-.
quacy cited by the NRC inspector is considered to be the primary zeason that led to this action.
Corrective Steps Taken and Results Achieved:
A.
Deficiency and Disposition Report No.. 536. was written for control and-resolution of this item.
In addition to the referenced penetration, welding on two (2) other penetrations(M-109 and. M-110) were also found, to have been. witnessed by. the Melding Engineering Group instead of Welding-QA.. 'Although the welding of the penetz ations was completed. a certified affidavit was signed, by the responsible Welding Engineering inspector.
who witnessed and/or verified the five-mandatory hold points for each. penetration in lieu of a, QA inspector.
Each of the referenced pene'trations'elds were radiographed and found to be acceptable.
Revision 1 to construction. procedure TP.-40',- "Tzaining and Qualification of'onstruction inspection. Personnel",.
was issued March 23, 1981.
The revised procedure sets forth explicit education and, experience requirements.
for Construction Inspection Supervisors and the inspection pez'sonnel.
The revised procedures also sets forth explicit. training and qualification re-quirements for the various sub-categories of inspection activities,
- and, thereby. eliminates the issuance of unlimited cez tifications in a given.
discipline.,
Recognizing that ciz'cumstances beyond control of the Company may result in periods of. nonavailability of. personnel with the desired qualifications, the procedure provides for assistance from engineering disciplines in meeting requirements for the training and. qualification of'nspection'ersonnel..
Site. quality assurance proceduze CQA-1 was also revised; on. Apri3 27, 1981,, to incorporate education, experience and. training requirements in the same style as that now inTP-40..
Graduate electrica1. and mechanical. engineers have been assigned as Construction: Inspection Supervisors for the electrical. and mechanical.
inspectiozr activities., respectively.
The education and. experience of the; electrical and mechanical. inspection personnel. have been reviewed and. the certifications of inspection qualifications have been narrowed in scope to be consistent with the requirements for the sub-categories of inspection. activities identified in the revised procedure, TP-40.
Corrective Steps Taken to Avoid Further Noncompliance:
A.
QA procedure, CQC-19 was revised and procedure MP-18 was developed and issued, to clarify requirements for welding and inspection of Class MC components.
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Severity Level V Violations P'age Three I
B.
As previously stated, revisions to construction procedure TP-40 and quality assurance procedure CQA-l, have been issued to set forth requirements that will ensure that inspection personnel are properly qualified and will be under supervisory control of personnel with adequate technical education and/or related." experience.
Future certification for the, inspection personnel will be issued in compliance with the revised procedures.
Date When Full Compliance Will Be Achieved:
Full compliance is considered. to have been achieved with the issue of Revision 0 to CQC-19 on. March 16, 1981,; and with the issue of Revision 0 to MP-19 on April 23,, 1981.,
B Full compLiance is-considered. to have been achieved with the issue of Revision. 1 to TP-40, on March 23,. 1981, and with the issue of Revision. 1, to CQA-1. on April.28, 1981.
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