ML18017B467: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
Line 15: Line 15:
| page count = 9
| page count = 9
}}
}}
See also: [[followed by::IR 05000400/1981013]]


=Text=
=Text=
{{#Wiki_filter:September ll, 1981 Mr.James P.O'Reilly Unit:ed States Nuclear Regulatory
{{#Wiki_filter:September ll, 1981 Mr.James P.O'Reilly Unit:ed States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303  
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
==Dear Mr.O'Reilly:==
identified
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.
in Appendix A.Our evaluation
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.-,'
of conditions
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.
relative to Appendix A, Item A.3 fail to indicate that a violation of procedures
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.
or commitments
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.
existed.Please consider the attached response information
Material and equipment storage are controlled by CPAL procedures:
for possible reclassification
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".
of the item.It is considered
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.
that the corrective
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.
and preventive
6.Numerous examples of deteriorated tape used to seal safety related piping assemblies.
actions taken are satisfactory
7.Numerous examples of safety related and balance of plant stainless steel piping subassemblies off dunnage in contact with mud.
for resolution
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.
of items A.2,,A.4-A.7 (inclusive), B.l and B.2.It is considered
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.
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:
Denial or Admission and Reasons for Violation:
A.The violation is correct as stated.During March and April of 1979, through exchange of correspondence
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.
with the manufacturer
Negotiations with the manufacturer in finalization of the storage program for the units, and appropriate revi-sions to the project procedures, failed to materialize.
of.the air handling units, CP&L assumed a posture that a quasi-agreement
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.
was in effect which permitted application
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.
of Level D storage for the units, except the associated
Personnel error in failing to observe and correct unsatisfactory conditions as they occur result in this type of violation.  
motors would required Level B storage.CP&L proceeded on this basis with confidence
~, 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..
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/
2.The violation is correct as stated.The QA/QC Inspector Qualification/
Cer tification
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.
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
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.
determin'ed
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".
that the candidate met the minimum experience
(~'I
requirement (six months), then rounded off to the nearest year (one)when he filled out the form.Corrective
(~~~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.
Steps Taken and Results Achieved: A.1'The air handling units have been inspected, and no significant
2.&4.Nylon slings are now being inspected in accordance with project procedures.
deterioration
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.
of quality was found.Additional
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.
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
L~}}
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~
}}

Revision as of 05:20, 17 August 2019

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  Duke Energy icon.png
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:
References
NUDOCS 8110160608
Download: ML18017B467 (9)
v • d • e


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~

Retrieved from "https://kanterella.com/w/index.php?title=ML18017B467&oldid=1877252"