ML20100D315
| ML20100D315 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/31/1984 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20100D305 | List: |
| References | |
| CON-NRC-284 NUDOCS 8412050752 | |
| Download: ML20100D315 (2) | |
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h - k' ylf CD&L ddredWb&erAggptyppany P. O.' Box 101, New Hill, NC 27562 October 31,1984 ~
Mr. James P. O'Reilly NRC-234
' United States Nuclear Regulatory Commission
- Region II
~
'101 Marietta Street, Northwest (Suite 2900)
. Atlanta, GA ~ 30323
Dear Mr. O'Reilly:
In reference to your letter of October 2,1984, referring to RII: GFM/RLP 50-400/84-31-01, 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/ planned is satisfactory _for resolution of the
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Thank you for your consideration in this matter.
Yours very truly, W
M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/rst Attachment cc:
Messrs. G. MaxweF R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC)
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}+ et Attachment to CP&L Letter of Response to NRC Report RII:
GFM/RLP 50-400/84-31-01 Reported Violation:-
10 ~CFR 50.55 (f) (1) requires CP&L to implement the Quality Assurance Program described or referenced in the Preliminary Safety Analysis Report. Section 1.8.5.3 of the CP&L Quality Assurance Program requires that measures be established and implemented to
- assure that design changes are properly evaluated and controlled.
Contrary to the above, on July 13,1984, CP&L issued FCR-E-2712 to approve the use of Scotch 33 Tape in safety-related applications without adequate engineering review for environmental qualification. This FCR was then used to di: position NCR-84-0985 which had identified the unauthorized use of the material.
This is a Severity Level V violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
At the time FCR-E-2712 was issued, the approving personnel failed to consider all areas and environments in which Scotch 33 Tape could potentially be used. The FCR was -
approved without area / environment limitations which approved its use throughout the plant.
Corrective Steps Taken and Results Achieved:
The following corrective actions have been or will be taken pertaining to the use of Scotch 33 Tape:
1.
FCR-E-2712 was revised to delete the use of Scotch 33 Tape and approve the use of
. Scotch 130C Tape which is qualified for use as an electrical insulating tape at elevated temperatures.
2.
Instructions have been issued.to craft supervision requesting that Scotch 33 tape be purged from the field. The construction inspectors will also be on alert for Scotch 33 tape.
3..
- HPES will perform an evaluation to identify areas where the use of Scotch 33 Tape may cause adverse affects. Once identified, these areas will be checked to ensure 4
the tape was not used. 'If the tape is found in these areas, it will be removed and replaced with Scotch 130C Tape, as needed.
4.
NCR 84-2066'has been issued to re-open the nonconformance.
Corrective Steps Taken to Avoid Further Noncompliance:
The approving individual involved has been cautioned to ensure that during the FCR approval process, necessary considerations are to be taken, specifically material qualifications of any new materials being specified.
Date When~ Full Compliance Will Be Achieved:
Full compliance is projected to be achieved by January 15,1985.
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