ML18017B619
| ML18017B619 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/17/1982 |
| From: | BANKS H R CAROLINA POWER & LIGHT CO. |
| To: | OREILLY J P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B618 | List: |
| References | |
| NUDOCS 8203170446 | |
| Download: ML18017B619 (6) | |
See also: IR 05000400/1981025
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
i n 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-
-2-Corrective
Steps Taken and Results Achieved: A.Deficiency
and Disposition
Repor t num ber 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.