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| number = ML18017B619 | | number = ML18017B619 | ||
| issue date = 02/17/1982 | | issue date = 02/17/1982 | ||
| title = Responds to NRC | | title = Responds to NRC Re Violations Noted in IE Insp Repts 50-400/81-25,50-401/81-25,50-402/81-25 & 50-403/81-25. Corrective Actions:Program Implemented to Verify That safety-related Items Meet Specs | ||
| author name = Banks H | | author name = Banks H | ||
| author affiliation = CAROLINA POWER & LIGHT CO. | | author affiliation = CAROLINA POWER & LIGHT CO. | ||
| Line 11: | Line 11: | ||
| contact person = | | contact person = | ||
| document report number = NUDOCS 8203170446 | | document report number = NUDOCS 8203170446 | ||
| title reference date = 01-18-1982 | |||
| package number = ML18017B618 | | package number = ML18017B618 | ||
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | ||
| page count = 6 | | page count = 6 | ||
}} | }} | ||
=Text= | =Text= | ||
{{#Wiki_filter:February 17, 1982 CSQE | {{#Wiki_filter:February 17, 1982 | ||
Commission | : CSQE, Carolina Power & Light Company i 7< ~ | ||
Region XI 101 Marietta Stveet, Novthwest Atlanta, Georgia 30303 Dear Mv.O'Reilly: Xn reference to youv lettev of January 18, 1982,'eferving | ~EGJ J5/ | ||
to RX1: GFM 50-400/401/402/403/81-25,.the, attached is Carolina Power&Light Company's reply to the deficiencies | ,AMTA r EG~....-, | ||
identified | 82I'EB23 All. 3r Mr. James P. O'Reilly United States Nucleav Regulatovy Commission Region XI 101 Marietta Stveet, Novthwest Atlanta, Georgia 30303 | ||
in Appendix A.Xt is considered | |||
that the corrective | ==Dear Mv. O'Reilly:== | ||
and preventive | Xn reference to youv lettev of January 18, 1982,'eferving to RX1: | ||
actions taken will be satisfactor | GFM 50-400/401/402/403/81-25, | ||
y fov resolution | .the, attached is Carolina Power | ||
of these items, once completed. | & Light Company's reply to the deficiencies identified in Appendix A. | ||
Thank you fov your consideration | Xt is considered that the corrective and preventive actions taken will be satisfactor y fov resolution of these items, once completed. | ||
in this matter.H.R.Banks Manager Corporate Quality Assuvance NJC:jp Attachment | Thank you fov your consideration in this matter. | ||
cc: Mv.J.A.Jones Sworn to and subscribed | H. R. Banks Manager Corporate Quality Assuvance NJC:jp Attachment cc: | ||
before me this 17th day of February, 1982.Notary Public My commission | Mv. J. | ||
expires: ate 411 Fayetteville | A. Jones Sworn to and subscribed before me this 17th day of February, 1982. | ||
Street o P.O.Box 1551 I Raleigh, N.C.27602 8203i70446 | Notary Public My commission expires: | ||
820308 PDR ADOCK 05000400 8,, (,.,.PDR | ate 411 Fayetteville Street o P. O. Box 1551 I Raleigh, N. C. 27602 8203i70446 820308 PDR ADOCK 05000400 8,, | ||
Exhibit 6 Mr.James P.O'Reilly United States Nuclear Regulatory | (,., | ||
Commission | . PDR | ||
Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 Dear Mr O'Reill: In reference to your letter of January 18, 1982, referring to RII: GFM 50-400/401/402/403/81-25, the attached is Carolina Power 4 Light Company's reply to the deficiencies | |||
identified | Exhibit 6 Mr. James P. O'Reilly United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 | ||
in Appendix A.It is considered | |||
that the corrective | ==Dear Mr O'Reill:== | ||
and preventive | In reference to your letter of January 18, 1982, referring to RII: | ||
actions taken will be satisfactory | GFM 50-400/401/402/403/81-25, the attached is Carolina Power 4 Light Company's reply to the deficiencies identified in Appendix A. | ||
for resolution | It is considered that the corrective and preventive actions taken will be satisfactory for resolution of these items, once completed. | ||
of these items, once completed. | Thank you for your consideration in this matter. | ||
Thank you for your consideration | Yours very truly, H. R. Banks Manager Corporate Quality Assurance NJC'jp Attachment cc: | ||
in this matter.Yours very truly, H.R.Banks Manager Corporate Quality Assurance NJC'jp Attachment | Mr. J. A. Jones | ||
cc: Mr.J.A.Jones | |||
Severity Level V Violations | Severity Level V Violations A. | ||
A.10 CFR 50, Appendix B, Criterion XV as implemented | 10 CFR 50, Appendix B, Criterion XV as implemented by CP&L PSAR section 1.8.5.15; CP8L Corporate QA Program section 15.1,3 and construction procedure CQC-2, section 4.2 and 4.3 require that nonconforming conditions be identified and corrected. | ||
by CP&L PSAR section 1.8.5.15;CP8L Corporate QA Program section 15.1,3 and construction | Contrary to the above, on December 8, | ||
procedure CQC-2, section 4.2 and 4.3 require that nonconforming | 1981 three nonconforming welded conditions were found that had not been identified previously by CPKL or the material supplier. | ||
conditions | One undersized fillet weld was found on cable tray suppor t section A (a supplier weld), | ||
be identified | one separation crack was found on a weld on cable tray support CD-2616 (a shop weld) and the field-applied tack welds had not been removed fr om or authorized to remain on cable tray su~crt CD-2618. | ||
and corrected. | Each of th~etlt~r. Dmncon-T electrical cable tray supports located in the auxiliary building at about elevation 276'. | ||
Contrary to the above, on December 8, 1981 three nonconforming | B. | ||
welded conditions | 10 CFR 50, Appendix B, Criterion IX as implemented by CPAL PSAR section 1.8.5.9; CP8L Corporate QA Program section 8.4.1.d and construction procedure MP-08, section 4.10.2 and AW-1 require that special processes such as welding be accom-plished in accordance with applicable codes or standards. | ||
were found that had not been identified | The applicable welding code for seismic I electrical cable tray supports is AWS-D1.1-1975, section 9. | ||
previously | Contrary to the above, on December 8, 1981, a field-applied welded "Lap Joint" on electrical cable tt ay support identified as CD-2618, was found not to have the minimum overlap that AWS-D1.1-1975, section 9.10 requires. | ||
by CPKL or the material supplier.One undersized | Instead of the required five times the thickness of the base metal, the overlap was only four times the thickness of the base metal. | ||
fillet weld was found on cable tray suppor t section A (a supplier weld), one separation | Denial or Admission and Reasons for Violation: | ||
crack was found on a weld on cable tray support CD-2616 (a shop weld)and the field-applied | A. | ||
tack welds had not been removed fr om or authorized | The conditions did exist as identified in the Notice of Violation. | ||
to remain on cable tray su~crt CD-2618.Each of th~etlt~r. | The actual cause of the separation crack could not be determined and the undersized fillet weld was due to poor vendor workmanship. | ||
Dmncon-T electrical | |||
cable tray supports located in the auxiliary building at about elevation 276'.B.10 CFR 50, Appendix B, Criterion IX as implemented | |||
by CPAL PSAR section 1.8.5.9;CP8L Corporate QA Program section 8.4.1.d and construction | |||
procedure MP-08, section 4.10.2 and AW-1 require that special processes such as welding be accom-plished in accordance | |||
with applicable | |||
codes or standards. | |||
The applicable | |||
welding code for seismic I electrical | |||
cable tray supports is AWS-D1.1-1975, section 9.Contrary to the above, on December 8, 1981, a field-applied | |||
welded"Lap Joint" on electrical | |||
cable tt ay support identified | |||
as CD-2618, was found not to have the minimum overlap that AWS-D1.1-1975, section 9.10 requires.Instead of the required five times the thickness of the base metal, the overlap was only four times the thickness of the base metal.Denial or Admission and Reasons for Violation: | |||
A.The conditions | |||
did exist as identified | |||
The actual cause of the separation | |||
crack could not be determined | |||
and the undersized | |||
fillet weld was due to poor vendor workmanship. | |||
Failure to remove the tack welds was due to weld inspector oversight. | Failure to remove the tack welds was due to weld inspector oversight. | ||
B.The violation is correct as stated.Field personnel (cr afts)installing"loose" support members (including | B. | ||
beam angles, longitudinal | The violation is correct as stated. | ||
and diagonal braces)failed to exercise care in locating these members during erection.There were also cases when detailed shop drawings utilizing work points did not allow for the required"lap joint" when utilizing material fabricated | Field personnel (cr afts) installing "loose" support members (including beam angles, longitudinal and diagonal braces) failed to exercise care in locating these members during erection. | ||
in accordance | There were also cases when detailed shop drawings utilizing work points did not allow for the required "lap joint" when utilizing material fabricated in accordance with the bill of material. | ||
with the bill of material.This was a contributing | This was a contributing factor to the lack of attention to this detail. | ||
factor to the lack of attention to this detail.-continued | -continued-Corrective Steps Taken and Results Achieved: | ||
A. | |||
Steps Taken and Results Achieved: A.Deficiency | Deficiency and Disposition Repor t number 748 was issued on December 10, | ||
and Disposition | : 1981, for control and resolution of the vendor items with the separation crack and the undersized fillet weld. | ||
Repor t | Nonconformance Report number W-256 was issued to resolve the tack weld item. | ||
of the vendor items with the separation | The undersized fillet weld and the separation crack on the cable tray support were repaired. | ||
crack and the undersized | The deficient welds were ground out and the items were rewelded. | ||
fillet weld.Nonconformance | The tack welds were ground out and removed. | ||
Report number W-256 was issued to resolve the tack weld item.The undersized | B. | ||
fillet weld and the separation | A complete reinspection of the field applied welded lap joints on electrical cable tray suppor ts installed prior to December 28, 1981, is presently in progress to identify all similar cases. | ||
crack on the cable tray support were repaired.The deficient welds were ground out and the items were rewelded.The tack welds were ground out and removed.B.A complete reinspection | The reinspection is expected to be complete by April 1, 1982. | ||
of the field applied welded lap joints on electrical | Upon completion of the reinspection, each case shall be evaluated by the Architect Engineer for structural integrity. | ||
cable tray suppor ts installed prior to December 28, 1981, is presently in progress to identify all similar cases.The reinspection | |||
is expected to be complete by April 1, 1982.Upon completion | |||
of the reinspection, each case shall be evaluated by the Architect Engineer for structural | |||
integrity. | |||
Any rework warranted will then by performed. | Any rework warranted will then by performed. | ||
Corrective | Corrective Steps Taken to Avoid Further Noncompliance: | ||
Steps Taken to Avoid Further Noncompliance: | A. | ||
A.A program hos been implemented | A program hos been implemented whereby CP&L QC Receiving Inspection will verify that nuclear safety-related items received under an Ebasco or Westinghouse Quality Release meet the requirements of the applicable procurement documents. | ||
whereby CP&L QC Receiving Inspection | These inspections will be based on a statistical sampling and shall be accanplished in accordance with the QC Procedures. | ||
will verify that nuclear safety-related | Characteristics to be verified shall include the following, as appropr iate: | ||
items received under an Ebasco or Westinghouse | physical properties, dimensions, weld preparations, workmanship and welding, lubricants, oils and electrical insulation. | ||
Quality Release meet the requirements | Procedure CQC-19 has been revised to insure that inspectors pay special attention to the removal of tack welds on the back side of members welded. | ||
of the applicable | Written instructions were issued on January 11, | ||
procurement | : 1982, by memorandum to the Ware-house Supervisor and the Iron Worker Superintendent to exercise care when handling cable tray support hangers to prevent possible damage. | ||
documents. | Instructions were also given to repor t accidentally dropped or damaged items to a QA inspector or the discipline engineer. | ||
These inspections | The vendor was contacted on December 16, | ||
will be based on a statistical | : 1981, and agreed to emphasize a more strenuous inspection in areas of handling, porosity, undersized, undercut and cracked shopwelds. | ||
sampling and shall be accanplished | B. | ||
in accordance | The QA Inspectors have been instructed to inspect for proper overlap of field applied lap joints installed on or after December 28, | ||
with the QC Procedures. | : 1981, and likewise the craft has been instructed as to proper and improper overlaps. | ||
Characteristics | Field Change Request AS-1048 reduces the acceptable overlap from "five times the thickness of the thinner part being joined" to one inch. | ||
to be verified shall include the following, as appropr iate: physical properties, dimensions, weld preparations, workmanship | Any joints found to violate the minimum one inch over lap shall be evaluated by the Architect Engineer to determine if any rework is necessary. | ||
and welding, lubricants, oils and electrical | -continued- | ||
insulation. | |||
Procedure CQC-19 has been revised to insure that inspectors | Date When Full Compliance Will Be Achieved: | ||
pay special attention to the removal of tack welds on the back side of members welded.Written instructions | A. | ||
were issued on January 11, 1982, by memorandum | Full compliance is considered to have been achieved on January 25, 1982. | ||
to the Ware-house Supervisor | B. | ||
and the Iron Worker Superintendent | Full compliance vill be achieved by May 1, 1982.}} | ||
to exercise care when handling cable tray support hangers to prevent possible damage.Instructions | |||
were also given to repor t accidentally | |||
dropped or damaged items to a QA inspector or the discipline | |||
engineer.The vendor was contacted on December 16, 1981, and agreed to emphasize a more strenuous inspection | |||
in areas of handling, porosity, undersized, undercut and cracked shopwelds. | |||
B.The QA Inspectors | |||
have been instructed | |||
to inspect for proper overlap of field applied lap joints installed on or after December 28, 1981, and likewise the craft has been instructed | |||
as to proper and improper overlaps.Field Change Request AS-1048 reduces the acceptable | |||
overlap from"five times the thickness of the thinner part being joined" to one inch.Any joints found to violate the minimum one inch over lap shall be evaluated by the Architect Engineer to determine if any rework is necessary.-continued- | |||
Date When Full Compliance | |||
Will Be Achieved: A.Full compliance | |||
is considered | |||
to have been achieved on January 25, 1982.B.Full compliance | |||
vill be achieved by May 1, 1982. | |||
}} | |||
Latest revision as of 05:30, 7 January 2025
| ML18017B619 | |
| Person / Time | |
|---|---|
| Site: | Harris |
| Issue date: | 02/17/1982 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B618 | List: |
| References | |
| NUDOCS 8203170446 | |
| Download: ML18017B619 (6) | |
Text
February 17, 1982
- CSQE, Carolina Power & Light Company i 7< ~
~EGJ J5/
,AMTA r EG~....-,
82I'EB23 All. 3r Mr. James P. O'Reilly United States Nucleav Regulatovy Commission Region XI 101 Marietta Stveet, Novthwest Atlanta, Georgia 30303
Dear Mv. O'Reilly:
Xn reference to youv lettev of January 18, 1982,'eferving to RX1:
GFM 50-400/401/402/403/81-25,
.the, attached is Carolina Power
& Light Company's reply to the deficiencies identified in Appendix A.
Xt is considered that the corrective and preventive actions taken will be satisfactor y fov resolution of these items, once completed.
Thank you fov your consideration in this matter.
H. R. Banks Manager Corporate Quality Assuvance NJC:jp Attachment cc:
Mv. J.
A. Jones Sworn to and subscribed before me this 17th day of February, 1982.
Notary Public My commission expires:
ate 411 Fayetteville Street o P. O. Box 1551 I Raleigh, N. C. 27602 8203i70446 820308 PDR ADOCK 05000400 8,,
(,.,
. PDR
Exhibit 6 Mr. James P. O'Reilly United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303
Dear Mr O'Reill:
In reference to your letter of January 18, 1982, referring to RII:
GFM 50-400/401/402/403/81-25, the attached is Carolina Power 4 Light Company's reply to the deficiencies identified in Appendix A.
It is considered that the corrective and preventive actions taken will be satisfactory for resolution of these items, once completed.
Thank you for your consideration in this matter.
Yours very truly, H. R. Banks Manager Corporate Quality Assurance NJC'jp Attachment cc:
Mr. J. A. Jones
Severity Level V Violations A.
10 CFR 50, Appendix B, Criterion XV as implemented by CP&L PSAR section 1.8.5.15; CP8L Corporate QA Program section 15.1,3 and construction procedure CQC-2, section 4.2 and 4.3 require that nonconforming conditions be identified and corrected.
Contrary to the above, on December 8,
1981 three nonconforming welded conditions were found that had not been identified previously by CPKL or the material supplier.
One undersized fillet weld was found on cable tray suppor t section A (a supplier weld),
one separation crack was found on a weld on cable tray support CD-2616 (a shop weld) and the field-applied tack welds had not been removed fr om or authorized to remain on cable tray su~crt CD-2618.
Each of th~etlt~r. Dmncon-T electrical cable tray supports located in the auxiliary building at about elevation 276'.
B.
10 CFR 50, Appendix B, Criterion IX as implemented by CPAL PSAR section 1.8.5.9; CP8L Corporate QA Program section 8.4.1.d and construction procedure MP-08, section 4.10.2 and AW-1 require that special processes such as welding be accom-plished in accordance with applicable codes or standards.
The applicable welding code for seismic I electrical cable tray supports is AWS-D1.1-1975, section 9.
Contrary to the above, on December 8, 1981, a field-applied welded "Lap Joint" on electrical cable tt ay support identified as CD-2618, was found not to have the minimum overlap that AWS-D1.1-1975, section 9.10 requires.
Instead of the required five times the thickness of the base metal, the overlap was only four times the thickness of the base metal.
Denial or Admission and Reasons for Violation:
A.
The conditions did exist as identified in the Notice of Violation.
The actual cause of the separation crack could not be determined and the undersized fillet weld was due to poor vendor workmanship.
Failure to remove the tack welds was due to weld inspector oversight.
B.
The violation is correct as stated.
Field personnel (cr afts) installing "loose" support members (including beam angles, longitudinal and diagonal braces) failed to exercise care in locating these members during erection.
There were also cases when detailed shop drawings utilizing work points did not allow for the required "lap joint" when utilizing material fabricated in accordance with the bill of material.
This was a contributing factor to the lack of attention to this detail.
-continued-Corrective Steps Taken and Results Achieved:
A.
Deficiency and Disposition Repor t number 748 was issued on December 10,
- 1981, for control and resolution of the vendor items with the separation crack and the undersized fillet weld.
Nonconformance Report number W-256 was issued to resolve the tack weld item.
The undersized fillet weld and the separation crack on the cable tray support were repaired.
The deficient welds were ground out and the items were rewelded.
The tack welds were ground out and removed.
B.
A complete reinspection of the field applied welded lap joints on electrical cable tray suppor ts installed prior to December 28, 1981, is presently in progress to identify all similar cases.
The reinspection is expected to be complete by April 1, 1982.
Upon completion of the reinspection, each case shall be evaluated by the Architect Engineer for structural integrity.
Any rework warranted will then by performed.
Corrective Steps Taken to Avoid Further Noncompliance:
A.
A program hos been implemented whereby CP&L QC Receiving Inspection will verify that nuclear safety-related items received under an Ebasco or Westinghouse Quality Release meet the requirements of the applicable procurement documents.
These inspections will be based on a statistical sampling and shall be accanplished in accordance with the QC Procedures.
Characteristics to be verified shall include the following, as appropr iate:
physical properties, dimensions, weld preparations, workmanship and welding, lubricants, oils and electrical insulation.
Procedure CQC-19 has been revised to insure that inspectors pay special attention to the removal of tack welds on the back side of members welded.
Written instructions were issued on January 11,
- 1982, by memorandum to the Ware-house Supervisor and the Iron Worker Superintendent to exercise care when handling cable tray support hangers to prevent possible damage.
Instructions were also given to repor t accidentally dropped or damaged items to a QA inspector or the discipline engineer.
The vendor was contacted on December 16,
- 1981, and agreed to emphasize a more strenuous inspection in areas of handling, porosity, undersized, undercut and cracked shopwelds.
B.
The QA Inspectors have been instructed to inspect for proper overlap of field applied lap joints installed on or after December 28,
- 1981, and likewise the craft has been instructed as to proper and improper overlaps.
Field Change Request AS-1048 reduces the acceptable overlap from "five times the thickness of the thinner part being joined" to one inch.
Any joints found to violate the minimum one inch over lap shall be evaluated by the Architect Engineer to determine if any rework is necessary.
-continued-
Date When Full Compliance Will Be Achieved:
A.
Full compliance is considered to have been achieved on January 25, 1982.
B.
Full compliance vill be achieved by May 1, 1982.