ML20093K910

Responds to NRC Re Violations Noted in Insp Rept 50-261/84-27.Corrective Actions:Qa Hold Tags Placed on Valves Prior to Weld Preparation.Const Warehouse Procedure AP-13 Will Supersede Rev 0 to AP-XII-05

ML20093K910
Person / Time
Site:	Robinson
Issue date:	09/14/1984
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20093K902	List: ML20093K910
References
RSEP-84-564, NUDOCS 8410180223
Download: ML20093K910 (4)

Text

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. Carolina Power & Light Company H. Bh PLANT POST OFFICE BOX 790

HARTSVILLE, SOUTH CAROLINA 29550 SEP 141984

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Rcbinson File No: 13510E Serial: RSEP/84-564 Mr. James' P. O'Reilly.

' Regional Administrator U. S. Nuclear Regulatory Commission

-Region 11 101 Marietta Street, Suite 3100

' Atlanta, Georgia 30323 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT '2 DOCKET NO. 50-261 LICENSE NO. DPR-23 IE INSPECTION REPORT IER-84-27

Dear Mr.10'Re111y:

Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response.

A. ' Severity Level'IV Vioistion (IER-84-27-01-SL4) 10CPR50,; Appendix B,. Criterion V, requires activities affecting quality

-to be ' accomplished in accordance with procedures. CP&L Corporate QA Manual, Section14.3.1.3, requires purchase requisitions for Plant quality related services be reviewed and approved in accordance with subsection 4.3.6 by the Corporate Quality Assurance Department prior to award; Section 5.2.2.1 of .the CP&L Corporate Quality Assurance Manual requires Q-List items not be released' until Receiving Inspection has been completed and items have ,

been appropriately tagged to show status. >

- CP&L Procedure AP-XII-05, Rev. O " Warehousing", paragraph 4.6.3, requires all Q or safety-related material to be worked with an appropriate status 1

tag' (" Accept Tag or Conditional Release Tag") prior to release from the warehouse ~ unit control. AP-XII-05, paragraph 4.4.2C. , and ANSI N45.2.2, Packaging, Shipping, Receiving, Storage, and Handling of Items For Nuclear i

~ Power Plant- (During the Cons truction Phase), paragraphs 2.7.3(2)' and 6.1.2, require safety-related valves to be stored indoors.

, . Contrary to the above, activities af fecting quality c:.re not accomplished ,

in accordance with' procedures in that safety-related valves were removed >

- from technical and QA adequacy prior to receiving inspection without status markings which r tsulted in the valves being stored outdoors.

E 8410180223 841001 PDft ADOCK 05000261

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's e Lett:r t t Mr. J me3 P. O'R illy Scrial: 1 RSEP/84-5f4 Page 2 Respo nse

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

'2. Reason for the Violation These valves did not have appropriate Q-status markings because they were transferred from another CP&L plant without the appro-priate procurement documents. Without procurement documents, Material Receiving Reports were not initiated. Procedures did

- not specify the appropriate actions by warehouse personnel when the .Q-s tatus of materials is indeterminant. The valves were moved without proper documentation from outdoor storage at the Construction Warehouse to the welding preparation area. The NRC inspector noted the valve outside the weld preparation area.

3. Corrective Steps Which Have Been Taken QA hold tags were placed on the valves prior to any weld preparation being performed on the valves. The valve identifications and cover / seals were intact. The valves were returned to the warehouse where a Material Receiving Report was issued, a procurement document was written, and QA/QC perf ormed the receipt inspection. A letter was issued to Construction Warehouse personnel as to the appropriate actions to take when the Q-status of material has not been determined. New employees hired for the Constructica Warehouse will be required to read the letter until this position is reflected in procedure AP-13.

Construction Warehouse personnel also attended a training session in issue of . "Q". material. Appropriate Construction management was reminded dsout procedure requirements for requisitions and the approval for purchase of material.

4. Corrective Steps Which Will be Taken Construction Warehouse Procedure AP-13 will supercede AP-XII-05, Rev.0 and will reflect the appropriate actions to take when the status of materials has not been determined.

5. Date When Full Compliance Will be Achieved Full compliance has been achieved with the above mentioned letter issued to Construction Warehouse personnel and the subsequent training. Construction Warehouse Procedure AP-13 is scheduled to be issued November 1,1984.

B. Severity Level IV Violation (IER-84-27-02-SL4]

10CFR50, Appendix B, Criterion IX, requires reasures be estdilished to assure that special processes including nondestructive testing be accom-p11shed in accordance with applicable codes, ASME B&P Code,Section V (80W80), Article 2, Table T-262.2, requires the use of a No. 40 Image Quality

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• Letter' tit ~ Mr. Janea P. 0'R3111y - )

_-Seriale; RSEP/84-564  ;

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Indicator -(IQI) for weld over 2.50 "through 3" and a No. 45 IQI for welds *

over 3.00 "through 4.00". ASME B&PV Code,Section V, paragraph T-235.2,

- repecifies radiographs shall be considered unacceptable if. the image of a Lead Letter "B" appears in the - radiograph. Contrary to the above, measures were not adequate to assure that non-destructive examination was accomplished

• in accordance with applicable codes in that the following was noted: i l

a. A No. 50 IQI only was used for the accepted radiograph of "B" generator feedwater nozzle to remnant weld reported to be 3 to 5 inches thick.

b. The image of a lead letter "B" appeared on two segments of the final accepted radiograohs for the lower girth weld on "C" steam generator. ,

Response  :

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

2. Reason for the Violation

s. The radiographer incorrectly read across the Image Quality Indicator '

(penetrometer) designation chart to the incorrect penetrometer designation. Using this incorrect ir. formation, the radiographer attached the penetrometer to a numbered belt which was used for the three feedwater nozzle to remnant welds. The CP&L reviewer and authorized inspector did not recognize the use of the incorrect penetrometer.

b. The radiographer overlapped film in order to cover a repaired area.

Developing the film resulted in the backscatter "B" on the under-lying film to register on the top film without actual backscatter.

3. Corrective Steps Which Have Been Taken

1. The radiographs in question have been reviewed and have been accepted "as is" based on the following:

a. The radiographs with the incorrect penetrometer were  !

accepted based on the ASME Code Section V formula which allows the . acceptance of equivalent sensitivity.

b. An evaluation of the backscatter "B" on the top film concluded that the source of the backscatter "B" was from the. underlying film and not actual backscatter.

2. A review of radiographs has assured CP&L that no similar conditions ,

exist in like film packages produced by the same contractor during the Steam Generator outage.

3. Appropriate CP&L NDE personnel were made aware of the reported incidents and were instructed to pay more attention to detail.

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Mr. J:ine3 P. O'RO111y Serials RSEP/84-564 Page 4

-4. Corrective Step Which Will be Taken No further action is planned.

5. Date When Full Compliance Will be Achieved Full compliance has been achieved.

If- you have any questions concerning this response, please contact my staf f o r me.

Very truly yours, yf R. E. M an General Manager H. B. Robinson SEG Plant CLW/tk Lm_