ML20093E989

Responds to NRC Re Violations Noted in IE Insp Rept 50-261/84-13.Corrective Actions:Const Welding Technical Procedures,Controlling Steam Generator Replacement Activity, Revised to Specify Which Steps Can Be Bypassed

ML20093E989
Person / Time
Site:	Robinson
Issue date:	06/08/1984
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20093E983	List: ML20093E989
References
RSEP-84-407, NUDOCS 8407180249
Download: ML20093E989 (3)

Text

I s, r l 4

Form 244 -

Carolina Power & Light Company 84 JUN I'2 A 9 : 0 0 Company Correspondence H. B. ROBINSON STFRi ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 An ~ s y Robinson File No: 13510E Serial: RSEP/84-407 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Atlanta, Georgia 30303 H. B. Robinson SEG Plant, Unit 2 Dockit No. 50-261 License No. DPR-23 IE Inspection Report IER-84-13

Dear Mr. O'Reilly:

. Carolina Power and Light Company (CP&L) has receivcd and reviewed the subject repo rt and provides the following response.

Severity Level V Violation (IER-84-13-01-SL5) 10 CFR 50 Appendix B, Criterion X, requires the establishment of an adequate inspection program for ac ivities af fecting quality that prohibits work to proceed beyond hold points without the consent of designated represcntative.

CP&L-TP-SGR-48A, Revision 0, " Edge Preparation Channel Head," was identified as the applicable procedure for machining the weld end preparation on the channel head for steam generator "A".

Contrary to the above, an adequate inspection program for activities af fecting quality that prohibits work to proceed beyond hold points without the consent of designated representative was not established as evidenced by the ! allowing examples:

1. Work had progressed .o step 4.5.5 of Procedure TP-SGR-48A even though hold points in steps 4.3.1, 4.4.1, 4.4.2, and 4.4.5 had not been signed off, i

2. When asked, the licensee personnel gave varied definitions and controls relating to hold points.

3. The licensee stated that they do not have a documented - policy containing clear requirements relating to hold points..

8407180249 840628 PDR ADOCK 05000261 G pop

O Hr. James P. O'Reilly Serial: RSEP/84-407 Page 2 Respo nse

1. Admission or Denial of the Alleged Violation CP&L acknowledges the alleged violation.

2. Reason for the Violation A. A statement in procedure TP-SGR-48A allows the steps to be per-formed out of sequence for more ef ficient use of men and equipment which was shared between the three steam generators being replaced.

However, in this instance the statement did not specify which steps may be performed out of sequence. This lack of specification con-tributed directly to the violation.

The hold points in question were sign of fs for the field engineer, they were not QA inspector hold points. The QA inspector hold points were included in the same procedure and were not bypassed.

If the field engineer sign of fs were called surveillance points rather than hold points or if the statement was specific as to which steps could be performed out of sequence or the responsible engineer acknowledged in writing that the hold was being passed for a partic-ular reason there would not have been a violation.

B. A discussion on hold points is in 10 CFR 50 Appendix B. Criteria 10.

C. CP&L's policy on hold points is as discussed in the above document.

There was a discussion with the inspector on the differences between the field engineers " hold points" and the QA inspectors " hold points".

4 The individuals speaking to the NRC inspector were faced with a poten-tial violation on the definition of these " hold points" and did not quote the definition of a " hold point", when asked, until they could read it to the inspector. This may be why it appeared to the inspector ,

that the license did not have a clear definition or policy on " hold points".

D. Corrective Steps Which Have Been Taken The cons truction welding technical procedures controlling the . steam generator replacement activity were reviewed and, where appropriate for procedures not yet performed, changes have been made to specify which steps can be bypassed. Where appropriate, surveillance points were stituted for field engineer hold points. Signing off hold points as work is completed and in sequential order or as specifically allowed by procedure is periodically emphasized to construction personnel in-volved in the replacement of the steam generators.

E. Date When Full Compliance Will Be Achieved Full compliance has been achieved and corrective steps are continuing with constant reminders to ensure hold points are adhered to throughout

the outage.

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Mr. James P. O'Reilly Serial: RSEP/84-407 Page 3 If you have any questions concerning this response, please contact my staf f o r me .

Very truly yours, R. E. Mo n General Manager H. B. Robinson SEG Plant REM /j s ii L

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