ML20081H586
| ML20081H586 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/21/1983 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20081H506 | List: |
| References | |
| CON-NRC-130 NUDOCS 8311070515 | |
| Download: ML20081H586 (3) | |
Text
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-6 Cp&L.
Carolina Power & Light Company Esu:::21mwa#, -
w1*ma P. O. Box 101, New Ilill, N. C. 27562 October 21, 1983 Mr. James P. O'Reilly NRC-130 United States Nuclear Regulatory Commission Region 11 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of September 22, 1983, referring to RII: GFM/RLP 50-400/83-26-01, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.
It is considered that the corrective action taken is satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, ghe
.- ?-^
R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sb Attachment ec:
Messrs. G. Maxwell /R. Prevatte (NRC-SIINPP)
Mr. B. C. Buckley (NRC) j 8311070515 831031 PDR ADOCK 05000400 G
r Attachment to CP&L Letter of Response to NRC Report RII: GFM/RLP 50-400/83-26-01 Reported Violation:
10 CFR 50, Appendix B, Criterion II, as implemented by CP&L PSAR Section 1.8.5.2 and CP&L Corporate QA Program Section 1.3, requires that activities such as piping installation inspections be conducted and controlled in accordance with detailed procedural requirements.
Contrary to the above, on August 18, 1983, instances were found which indicated that piping installations were assigned to be inspected without detailed procedures, appropriately controlled drawings, and indoctrination of inspection personnel as to inspection and documentation requirements.
The inspection was to determine construction completion and acceptance of a section of service water piping system prior to turnover to the Operations Department. The deficient examples included: use of marked-up inspection drawings, unauthorized entries on inspection forms, inadequate procedural requirements, lack of established acceptance criteria, and inspections requested prior to work completion.
This is a Severity LevelIV Violation (Supplement II.D).
Denial or Admission and Reason for the Violation:
The violation is correct as stated. The conditions reported by the Inspector were caused primarily from merging "as-builting" functions into a quality inspection procedure. This resulted in differing interpretations of the required procedure content and manner of implementation.
Corrective Steps Taken and Results Achieved:
Site procedure TP-24, Mechanical Pipe Installation Inspection, has been revised as follows:
1.
As-built drawings are no longer used in the inspection process. Acceptance of piping geometry and configuration is based upon criteria contained in approved design installation drawings.
2.
The exposed piping inspection form, Exhibit 2, no longer requires the use of as-built drawings to be listed as part of the inspection package.
Inspection personnel have been instructed that the exhibit is the responsibility of the mechanical engineer to prepare and revise, if needed.
3.
The reference to " spot" check in the procedure has been deleted.
The dimensional and geometrical checks performed by the inspection personnel are now full inspections.
4.
The procedure clarifies that closure welds (versus all welding) are to be completed prior to inspection for dimensions and geometry.
5.
The procedure no longer addresses the use of punch lists. The previous punch list exhibit to the procedure h<ts been deleted. TP-24 continues to invoke TP-17; Construction Inspection Nonconformance Control, for processing nonconforming conditions.
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Corrective Steps Taken to Avoid Further Noncompliance:
The revision to TP-24 eliminated the as-builting functions, and clarifies the procedure ccatent to enhance proper interpretations and implementing actions.
The mechanical engineering and inspection personnel have been instructed in the revised procedure.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on October 17,1983.
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