ML18017B499
| ML18017B499 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/27/1981 |
| From: | Banks H CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18017B498 | List: |
| References | |
| NUDOCS 8111130542 | |
| Download: ML18017B499 (4) | |
Text
October 27, 1981 Carolina Power & Li)ISUQQa&jEGlON..
ATLANTA,GFORGlt Mr. James P. O'Reilly Bl NOV R United States Nuclear Regulatory Commission Region II 101 Marietta Street, Nor thwest Atlanta, Georgia 30303 n8 qb'ear Mr. O'Reilly:
In reference to your letter of October 2, 1981, referring to RII:
GFM 50-400/401/402/403/81-19, the attached is Carolina Power 0 Light Company's reply to the deficiency identified in Appendix A. It is considered that'he corrective and preventive actions taken will be satisfactory for re-solution of this item.
To the best of my knowledge, information, and belief, the corrective action in this report is true and complete.
Thank you for your consideration in this matter.
Yours very truly, H. R. Banks Manager Corporate Quality Assurance NJC/Dp Attachment cc:
Mr. J.
A. Jones Sworn to and subscribed before me this 27th day of October, 1981.
N tary Public My commission expires:
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Severity Level VI Violation 10 CFR 50, Appendix B, Criterion V, as implemented by PSAR section 1.8.5.5; CPKL Corporate QA Program section 6.2.5 and construction procedure MP-110, section 3, "Installation of safety-related (seismic class I) pipe hangers" requires that if substitute materials are used for hanger installations, such substitutions shall. be documented by memo, clarification request or surplus requisition form.
Contrary to the above, on August 25, 1981, documentation could not be provided by CPAL to show that materials which had been used as substitutes for spacer plate par ts numbered ll on Bergen-Paterson pipe hanger A-2-236-1-CC-H-1242, revision 3/D had been requisitioned in accordance with construction procedure HP-110.
Denial or Admission and Reasons for Violation:
The violation is correct as stated.
The reason for the violation was personnel inattention to the methods prescribed for obtaining and documenting substitute material.
The spacer plate substitute was obtained from qualified stock material, but the installing personnel failed to document the substitution.
Corrective, Steps Taken and Results Achieved:
The hanger weld was cut to provide access to the spacer plate.
The spacer plate purchase order identification was made and traced to the qualified stock material.
A material substitution form was added to the hanger package to properly document substitution of the spacer plate.
A two-fold sampling approach was taken to determine if the reported violation was an isolated case or a generic condition.
The information file of material substitutions was reviewed and found to identify twenty-two (22) recently installed hangers that contained substitutions.
A field inspection was conducted to identify twelve (12) installed hangers that contained material substitutions.
The hangers in the field were randomly selected and encompass the previous two-year work period.
The work packages for these thirty-four (34) hanger s were then reviewed and in each case the material substitutions were properly documented.
As a
- result, the violation is considered to be an isolated case.
Corrective Steps Taken to Avoid Fur ther Noncompliance:
Procedure MP-110, will be revised to require the use of the Construction tdaterial Requisition Form exclusively for the documentation of material substitutions.
A Procedure Deviation Notice was issued on October 21,
- 1981, to affect the above change pending revision of the procedure.
This change will eliminate the variety of methods previously allowed.
Responsible personnel have been instructed in the importance of material control and in the requirements of the revised procedure.
Date Mhen Full Compliance Mill Be Achieved:
Full compliance is considered to have been achieved on October 21,
- 1981, with the issuance of Deviation 3 to revision 5 of procedure HP-110.
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