BSEP-93-0107, Responds to NRC Re Violation & Deviation Noted in Insp Rept 50-324/93-25 & 50-325/93-25.Corrective Actions: self-assessment Process for Nuclear Engineering Dept Controlled Documents Program Being Evaluated
| ML20046A034 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/19/1993 |
| From: | Hinnant C CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BSEP-93-0107, BSEP-93-107, NUDOCS 9307230366 | |
| Download: ML20046A034 (6) | |
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CD&L Carolina Power & Light Company '
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Brunswick Nuclear Plant P. O. Box 10429 Southport, North Carolina 28461 JUL 191993 t
SERIAL: BSEP-93 0107 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION Gentlemen:
On June 18,1993, the Nuclear Regulatory Commission issued Notices of Violation and Deviation for -
L the Brunswick Steam Electric Plant. Details of the underlying NRC inspections are provided in inspection Report Nos. 50-325/93-25 and 50-324/93-25 dated June 18,1993.. Carolina Power & ~
Light Company hereby responds to the Notices of Violation and Deviation. Enclosure 1 to this letter provides CP&L's reply to the Notice of Violation in accordance with the provisions of 10 CFR 2.201.
' to this letter provides CP&L's reply to the Notice of Deviation.
Please refer any questions regarding this submittal to Mr. R. CJ Godley at (919) 457-2412.
Yours very truly, W
C. S. Hinnant, Director Site Operations Brunswick Nuclear Plant GMT/gmt Enclosures
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Mr. S. D. Ebneter Mr. P. D. Milano Mr, R. L'. Prevatte
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ENCLOSURE 1 l
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 and 2 NRC DOCKET NOS. 50-325 & 50-324 4
OPERATING LICENSE NOS. DPR-71 & DPR 62 REPLY TO NOTICE OF VIOLATION VIOLATION :
During an NRC inspection conducted on May 17-21, 1993, a violation of NRC requirements was identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures, and shall be accomplished in accordance with these instructions of procedures. CP&L Nuclear Engineering Department (NED) Procedure 3.5 specifies the -
requirements for using, handling, and storing controlled documents. The requirements of NED Procedure 3.5 were not followed by NED personnel as evidenced by the following examples.
1.
Paragraph 3.5.3.2 of NED Procedure 3.5 requires that uncontrolled copies of procedures shall not be used when designing changes to systems, structures and components.
Contrary to this requirement, uncontrolled copies of Structural Design Guides were used when evaluating short term structural integrity items in calculation number OSEls - 1005.
2.
Paragraph 3.5.3.2 of NED Procedure 3.5 requires that uncontrolled copies of controlled documents be clearly distinguishable from controlled copies.
1 Contrary to this requirement, on April 20,1993, NRC identified that uncontrolled copies of various NED documents, including procedures, structural design guides, and site procedures retained by NED personnelin their work areas and in the NED library q
were not distinguishable from controlled copies.
3.
Paragraph II.A in Attachment 2 of NED Procedure 3.5 requires that NED controlled documents be serialized and issued to specific individuals.- This paragraph also requires that a receipt system shall be utilized to verify receipt of the controlled document and each revision thereto by the person to where the document or revision was issued.
Contrary to this requirement, on April 19,1993, NRC identified that Revision 3 of Design Guide 111.16 had not been issued to the Brunswick site TAC library (NED Control Copy No. 367). The receipt system was not utilized to verify distribution and.
determine that this document had not been issued to or received by the TAC library...
4.
Paragraph 3.5.3.2 of - NED Procedure 3.5 requires that superseded revisions of
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controlled documents retained by NED personnel for reference must be clearly marked
" superseded".
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- Contrary to this requirement, superseded copies of drawings, procedures ' and specifications retained by NED personnel in their work areas and in the NED library 1 of 3 g
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m were not marked superseded.
This is a Severity Level IV violation (Supplement 1).
RESPONSE TO VIOLATION:
Admission of Violation Carolina Power & Light admits this violation.
Reason for Viotalio.m CP&L believes the events cited as examples to this violation resulted from the failure of management to clearly communicate expectations for compliance to document control procedures as detailed in the following discussions:
Example 1 NED personnel involved with development of NED Calculation OSEIS-1005 failed to perform the required verification of the status of the design guide prior to using it in the calculation, i
This resulted in the use of uncontrolled copies of procedures, whereas, paragraph 3.5.3.2 of NED Procedure 3.5 requires that uncontrolled copies of procedures shall not be used in the
. design process.
Examples 2 and 4 Uncontrolled copies including " superseded" copies of documents which were not clearly distinguishable from conPolled copies were found in work spaces and in the NED library. NED personnel failed to implement -the requirements of NED.3.5,
" Handling of Controlled Documents," because management expectations for procedural compliance were not clearly communicated.
Example 3 j
The Technical and Administrative Center (TAC) library copy of NED Design Guide llL16 was not maintained to the latest revision. A review of the control holders distribution profile was performed and determined that this was an isolated revision control data entry error. Per NED 1
Procedure 3.5 the receipt system was and is being utilized'to verify distribution of NED -
t controlled documents, but the Nuclear Revision Control System (NRCS) had not been properly -
updated to show the TAC library as a controlled copy holder. When the revision to' DG 111.16-was approved for issue, the control holders distribution profile did not show the TAC library as a control copy holder and a revision package was not distributed to that location.
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- Corrective Actions Which Have Been Taken and Results Achieved Examnles 1. 2, & 4 BESU Structural and Mechanical Design Guides have been incorporated.into NED Design Guides. Memorandum NED-G-8388, issued June 1,1993, documents the disposition of BESU Design Guides. A review of calculation OSEIS-1005 was performed to ensure technical adequacy. Additionally, a review is currently being performed to determine the impact of using uncontrolled structural and mechanical design guides in prior design products.
Upon completion of this review CP&L will determine whether further corrective actions are needed.
A memorandum was issued on June 11,1993, to all NED personnel to emphasize the requirements of NED Procedure 3.5.
On May 13,1993, training was conducted for NED Brunswick Engineering Support Section (BESS) employees on NED Procedure 3.5, Handling of Controlled Documents.
Work areas have been inspected to ensure compliance with NED Procedure 3.5.
BESS supervisors conducted follow-up inspections of work areas to emphasize compliance with NED Procedure 3.5, On June 11,1993, the BESS On-Site Manager permanently closed the on-site NED Library.
RMP-003, Reproduction, Distribution, and Accountability of Plant Documents Procedure, was revised, ef fective July 19,1993, to establish positive sitewide document control. The revision requires that all quality related activities be performed using a verified working copy.
Example 3 The control holders distribution profile has been corrected to include the TAC library and a controlled copy of NED Design Guide 111.16, Revision 2, has been distributed to the TAC library.
The communication of management expectations for procedural compliance has been accomplished through the following actions:
f Training was provided for NED personnel (Brunswick, Harris, and Robinson) to emphasize familiarization with procedures and the expectations of a procedural compliance ethic.
The NED Training Program has been revised to include procedure compliance training for new e
NED personnel.
Corrective Steos Which Will Be Taken to Avoid Further Violations The self assessment process for the NED controlled documents program is being evaluated.
' Recommendations for improvement will be factored into the organizational study for NED-document control which is currently underway.
i Date When Full Comoliance Will Be Achieved I
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Carolina Power & Light is now in compliance.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 and 2 r
NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF DEVIATION l
DEVIATION :
During an NRC inspection conducted on May 17-21,1993, a deviation of written commitments was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C the deviation is listed below.
in the enclosure to Carolina Power & Light Co. (CP&L) Letter dated September 21,1992, Serial: BSEP-92-0019,
Subject:
Licensee Event Report 2-92-006, CP&L committed to develop q
procedural control enhancements for implementation of plant modifications which address temporary removal of interference from existing equipment. CP&L committed to have the procedures covering these enhancements approved and in place by March 31,1993.
-l Contrary to this commitment, as of May 21,1993, NRC identified that the new procedure which specifies the procedural control enhancements d;scussed above had not been approved '
or issued.
RESPONSE TO DEVIATION:
Admission of Deviation Carolina Power & Light admits this deviation.
P Rgason for Deviation r
Licensee Event Report 2-92-006 listed as a corrective action,- " procedural - control-enhancements for PM implementation are being developed that will cover the temporary removal of existing equipment interferences (e.g. supports)c This procedure, MAP-004, Modification Work Control Procedure, is to be in place by March 31,'1993."
i The procedural control enhancements for implementing plant modifications which address temporary removal of interference from existing equipment were to be included in MAP-004, Modification Work Control Procedure. MAP-004 was scheduled to be in place by March 31, 1993. On March 25,1993, PLP-24, Work Management Process Procedure, was implemented '
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as a site-wide work control process and overlapped much of the originalinformation that was '
to be released as MAP-004, it was determined that MAP-004 was not required as PLP-24 included the basic work control process for modifications. The enhancements committed to '
for the temporary removal of existing equipment interference were then to be included in MAP-i 005, Application of Nuclear Plant Modification Program. The NED personnel responsible for '
revising MAP-005 realized that the revision could not be accomplished prior to the committed -
due date and communicated such to his management. Although NED management recognized that the revision to MAP-005 would not be accomplished prior to the committed due date, NED management did not take the necessary action to notify the NRC. Management's failure to il 1
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take.the appropriate action is due to inadequate enforcement of expectations regarding the extension of action items and notification of missed commitments.
_ Corrective Actions Which Have Been Taken and Results Achieved MAP-005 was approved on June 21,1993, with an effective date of July 31,1993.
Personnelinvolved with this overdue commitment have been counseled.
Additional emphasis has been provided to management on the need to enforce. the expe" cations for compliance to commitments. Imminent commitments are being identified to management for action to ensure their expectations are met.
Corrective Steos Which Will Be Taken to Avoid Further Deviations No additional actions are required.
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