ML20010H297

Responds to NRC 810730 Ltr Re Violations Noted in IE Insp Repts 50-413/81-16 & 50-414/81-16.Corrective Actions: Training Conducted & Use of Masking Tape Discontinued

ML20010H297
Person / Time
Site:	Catawba
Issue date:	08/26/1981
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20010H292	List: ML20010H297
References
NUDOCS 8109240313
Download: ML20010H297 (2)

Text

• -~ .

L ' ' : ,a D UK E POWE R COM PANY power Dunwixo 422 SouTri Ciroucii STnEET, CHARWTTE, N. C. asa4a

$ I i'ir,' 3 l P2 3i wl LLIAM O.PARM R , ,J R.

• Vicr Patssor=T Tet t Pwow c:AntA 704 STCAme PnODuCTION 373-4083 August 26, 1981 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission

)h _, on II 101 E rietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:LDZ 50-413/81-16 50-414/81-16

Dear Mr. O'Reilly:

Please find attached a response to Violation No. 413, 414/81-16-01 which was identified in the above referenced Inspection Report. Duke Power Company does not consider any ir. formation contained in this report to be proprietary.

I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge.

Ver 'truly yours,

.l u , . .' . (f, Williar O. Parker, J _-

RWO/php Attachment cc: NRC Resident Inspect -

Catawba Nuclear Stat.on Q

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Response to Violation 413, 414/81-16-01

'Yailure to follow procedures -for the control of surface applied material" Violation - 10 CFR_50,' Appendix B Criterion V, as implemented by Topical Report Duke 1-A,'Section 17, paragraph'17.1.5, requires activities affecting quality shall-be. prescribed by documented instr 7tions, procedures, or drawings of a type appropriate to the circumstat es and shall be accomplished in accordance with these instructions, procedures, or drawings. Licensee's procedure CP-170 prohfbits contact of stainless steel with low melting metals such as lead, and procedure CP-479 permits only approved tape to be in direct contact with austenitic stainless steel.

Contrary to the above, on July 17, 1981, lead numbers in direct contact with stainless steel reactor coolant piping joints 2NC-9-3 and 2NC-9-7 of Unit 2 were sighted. -In addition, the lead numbers on joint 2NC-9-3 were affixed to the pipe surface with an unapproved tape.

Response

1. The lead numbers described by this violation were placed adjacent to welds 2NC-9-3 and 2NC-9-7 by Quality Control Inspectors while performing, radiography of repairs to these welds. Upon completion of radiography the numbers were inadvertently not removed.

2. The use of bare lead letters was not prohibited by CP-170 until revision 10 dated 7-9-81. The date of issue of CP-170 (7-9-81) and the date of this violation (7-17-81) indicate that this error was due to unfamiliarity with new requirements. It should be noted that radiography of original .

welds is performed using a band of marker which does prohibit direct contact.

The use of unapproved masking tape was due to failure to follow established procedures.

3. Immediately after discovery of this violation, nonconformance reports 12206 and 12221 were written to describe the bare lead letters and unap-proved tape problems. Training was immediately conducted and the use of masking tape was inmediately discontinued. Since the initial retraining one recurrence of one bare lead number has been noted. The recurrence is described on nonconformance112412. Additional formal, documented training has now been conducted for all radiography personnel. No additional prob-lems have been observed since the documented training occurred.

4. This item will be monitored to assure continued compliance. ,

, 5. All nonconformances related'to this problem will be cleared by November 1, 1981. Corrective actions to date will prohibit any further recurrence.