ML18017B467

Responds to NRC 810813 Ltr Re Violations Noted in IE Insp Repts 50-400/81-13,50-401/81-13,50-402/81-13 & 50-403/81-13. Corrective Actions:Air Handling Units Inspected & No Significant Deterioration Found.Metal Awnings Installed

ML18017B467
Person / Time
Site:	Harris
Issue date:	09/11/1981
From:	Banks H CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18017B466	List: ML18017B467
References
NUDOCS 8110160608
Download: ML18017B467 (9)

See also: IR 05000400/1981013

Text

September ll, 1981 Mr.James P.O'Reilly Unit:ed States Nuclear Regulatory

Commission

Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 Dear Mr.O'Reilly: In reference to your letter of August 13, 1981, referring to RII: WPK 50-400/401/402/403/81-13, the attached is Carolina Power&Light Company's reply to the deficiencies

identified

in Appendix A.Our evaluation

of conditions

relative to Appendix A, Item A.3 fail to indicate that a violation of procedures

or commitments

existed.Please consider the attached response information

for possible reclassification

of the item.It is considered

that the corrective

and preventive

actions taken are satisfactory

for resolution

of items A.2,,A.4-A.7 (inclusive), B.l and B.2.It is considered

that the corrective

and.preventive

actions taken for item A.l will be satisfactory

for resolution

of this item, once completed.

Thank you for your considerationin

this matter.Yours very truly, Manager Corporate Quality Assurance~;, NJC/ps Attachment

cc: Mr.J.A.Jones Sworn to and Subscribed

before me this 11th day of September, 1981.Notary Publ'c My commission

expires June 5, 1984.8110160608

811001!PDR*DOCK 05000400'.6...,, PDR~yetteville

Street o P.O.Box 1551~Raleigh, N.C.27602

udP I'.C.~zc a~+~lQ t~ip l I s r!c.-,'

ERITY LEVEL V 5 VI'VIOLATIONS

Conditions

Reported: A.10 CFR 50, Appendix B, Criterion XIII as implemented

by CPAL PSAR Sechion 1.8.5.13 requires measures be established

to control storage and preserva-tion of materials and equipment to prevent, damage or deterioration.

The storage requirements

f'r air handling and coil units are contained in a Bahnson letter dated April 11, 1979, received onsite April 13, 1979.ANSI'45.2.2"Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (During the Construction

Phase)" has been identified

as the applicable

standard for storage and handling.ANSI N45.2.2 prohibits the use of frayed or otherwise deteriorated

rigging.ANSI N45.2.2 further requires the establishment

of 5 program for the inspection

of rigging including a system that will indicate acceptability.

CPAL procedure MP-21, revision 0,"Inspection

of Equipment and Rigging for General Lifting" is the controlling

site inspection

document for handling equipment and materials.

Material and equipment storage are controlled

by CPAL procedures:

AP-XIII-05, revision 10,"Material Storage", PGD-001, revision 20,"Material and Equipment Storage Requirements", PGD-002, revision 12,"Material Maintenance

Requirements

During Storage for SHNPP", and AP-XIII-07, revision 14,"In-Storage

Inspection

and Maintenance".

MP-21 requires rigging materials to be period color coded.PGD-001 requires fabricated

piping assemblies

to be capped.PGD-002 requires general inspections

for damaged or missing caps.PGD-002 further requires that tape be impervious

to water and not subject to cracking or drying out if exposed to sunlight, heat or cold.AP-XlII-05

requires piping assemblies

to be stored on dunnage.Contrary to the above, on July 7 to 10, 1981, measures were inadequate

to'ontrol material and equipment storage and preservation

in that the following conditions

were noted: 1.A number of safety related air handling and coil units we"e improperly

stored out doors.This condition went unidentified

from Apr il 1979 to March 1981.2.Badly abraded and deteriorated

cloth slings are used to lift, support or handle safety related materials and equipment.

3.On safety related materials and equipment, there is no documented

inspection

program for nonlifting

rigging.4.Cloth slings in the power block construction

area are not period color coded.5.Damaged pipe caps on numerous safety related piping assemblies.

6.Numerous examples of deteriorated

tape used to seal safety related piping assemblies.

7.Numerous examples of safety related and balance of plant stainless steel piping subassemblies

off dunnage in contact with mud.

I

SePerity Level V&VI Vi tions Page Two B.10 CFR 50, Appendix B, Criterion XVII as implemented

by CP&L PSAR Section 1.8.5.17 requires sufficient

records be maintained

to furnish evidence of activities

affecting quality.The records shall include qualifications

of personnel.

Contrary to the above, on July 10, 1981, sufficient

records were not main-tained to furnish evidence of activities

affecting quality in that: the training and qualifications

records for several welding inspectors

did not reflect required class-room

training, and the training and qualification

records for one welding inspector indicated one year of QC/QA related experience

when in fact, the individual

had only 10 months QC/QA related experience.

Denial or Admission and Reasons for Violation:

A.The violation is correct as stated.During March and April of 1979, through exchange of correspondence

with the manufacturer

of.the air handling units, CP&L assumed a posture that a quasi-agreement

was in effect which permitted application

of Level D storage for the units, except the associated

motors would required Level B storage.CP&L proceeded on this basis with confidence

that storage of the units and motors as planned, would provide adequate protection.

Negotiations

with the manufacturer

in finalization

of the storage program for the units, and appropriate

revi-sions to the project procedures, failed to materialize.

2.,&4.~~The violation is correct as stated.Nylon slings were not placed under the inspection

program due to limited use and difficulty

in maintaining

the inspection

color code system.3.The violation is, denied as stated.It is CP&L's interpretation

that the requirement

for a documented

inspection

program is directed at the equip-ment and rigging used in"handling" items as discussed in ANSI N45.2.2, paragraph 7, Handling.The standard defines handling as: "The act of physically

moving items by hand or by mechanical

machinery, not including transport modes." The NRC Inspector reported observing a piping assembly secured to a vehicle for transit with deteriorated

holddown straps, contrary to ANSI N45.2.2 paragraph 7.4.1;and cited the lack of a documented

in-spection program for nonlifting

rigging, contrary to paragraph 7.4 of the standard.CP&L agrees that the observed holddown straps are nonlifting

equipment, but that they were being utilized in a transport mode versus handling (lifting)mode-and as such, fall outside of the paragraphs

cited.Inasmuch as the standard is found to be silent as to a documented

inspection

program for nonlifting

rigging (sic), CP&L requests that this violation be rescinded.

5'6.&7.The violations

are correct as stated.Routine handling operations

result in damage to pipe caps and piping subassemblies

falling off dunnage;and deterioration

of sealing tape are continually

occurring conditions.

Personnel error in failing to observe and correct unsatisfactory

conditions

as they occur result in this type of violation.

~, Severity Level V&VI Violations-

Page Three B.This part of the.violation is correct, but should be clarified as follows: The required classroom training had been accomplished

but docurrentation

was not available for the inspector's

review.The classroom training records in question are for those inspectors

qualified for welding related inspection

activities

under revision number two of procedure CQA-1, Personnel Training and Qualification, dated March 16, 1981.During the period of the NRC inspection

July 7-10, 1981)these records were in the locked file of the Melding QA/QC Specialist (supervisor)

who was on vacation.The supervisor

had started a review of all these training records prior to going on vacation and had elected to keep them in his file until the review was completed..

2.The violation is correct as stated.The QA/QC Inspector Qualification/

Cer tification

form (QA-49, revision.4)in use at the time (May 27, 1980)the inspector in question was qualified as Stud iield Inspector, provided a blank to indicate"years in QA/QC related work".The QA/QC Specialist

determin'ed

that the candidate met the minimum experience

requirement (six months), then rounded off to the nearest year (one)when he filled out the form.Corrective

Steps Taken and Results Achieved: A.1'The air handling units have been inspected, and no significant

deterioration

of quality was found.Additional

protection, in the way of metal awnings, has been installed to minimize internal exposure to rain.The units will be moved to level B storage, or placed in an allowed subordinate

storage level following evaluation

and revision of project procedures.

2.&4.Nylon slings have been inspected and unacceptable

slings rejected.In-spection color coding of the slings is being accomplished

in accordance

with project procedures.

5., 6.&7.A general inspection

and corrective

work effor t resulted in replacing of damaged pipe caps, returning pipe to dunnage and non-contact

with the ground, and replacing deteriorated

sealing tape.Records to document required classroom training are prescribed

by procedure CQA-1 and are normally maintained

in the QA/QC Unit administrative

files.Supervisory

review of the training records in question was completed and the records were placed in the file on July 16, 1981.2.The QA/QC Inspector Qualification/Certification

form for the inspector in question has been corrected to read"10 months" instead of"1 year".

(~'I

(~~~Ser verity Level V&VI 3 ations Page Four A.1.An evaluation

of similar storage aspects is being made.Areas found to be weak or inadequate

will be corrected to ensure compliance

with project commitments.

2.&4.Nylon slings are now being inspected in accordance

with project procedures.

Procedure MP-21,"Inspection

of Equipment and Rigging for General Lifting", is being revised to be more definitive

in the inspection

of nylon slings.A Procedure Deviation Notice was issued on September 4, 1981, to affect the above change until the procedure can be revised.5., 6.&7.Through correspondence

and meetings with construction

personnel, management

has reemphasized

the storage requirements

and the need to be constantly

aware of actions and conditions

that lead to these types of violations;

and the need to take prompt corrective

action to restore compliance

with project requirements.

B.1.Supervisors

have been instructed

not to remove inspectors'raining

records from the file for extended periods.This should ensure that these records are available for review on short notice.2.The QA/QC Inspector Qualification/Certification

form (QA-49)was revised on May 8, 1981, to indicate"total months" experience

instead of years, making it highly unlikely to have future problems of this type.Date Mhen Full Compliance

Mill be Achieved: A 1.Full compliance

will be achieved by December 1, 1981, at which time the evaluation

of similar storage aspects will be complete.2.&4.Full compliance

is considered

to have been achieved on September 4, 1981, with the issuance and implementation

of Deviation 1 to revision 3 of procedure MP-21.5., 6.&7.Full compliance

is considered

to have been achieved on August 31, 1981.-B 1.&2.Full compliance

is considered

to have been achieved on July 16, 1981.

L~