IR 07100026/2012006

Notice of Violation from Insp on 971026-1206.Violation Noted:Licensee Did Not Adequately Develop,Maintain or Implement Procedures for Controlling Computer Software Development & Plant Configuration During Mod Process

ML18016A283
Person / Time
Site:	07100026, Harris
Issue date:	12/31/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18016A282	List: IR 07100026/2012006
References
50-400-97-12, NUDOCS 9801210175
Download: ML18016A283 (4)

Text

NOTICE OF VIOLATION Carolina Power 8 Light Company Shearon Harris Unit 1 Docket No. 50-400 License No.

NPF-63 During an NRC inspection conducted from October 26 through December 6,

1997, violations of NRC requi rements were identified.

In accordance with the

"General Statement ot Policy and Procedure for NRC Enforcement Actions,"

NUREG-1600 'he violations are listed below:

A.

CFR 50 Appendix 8, Criteria V, Instructions.

Procedures, and Drawings. requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Carolina Power and Light Corporate Quality 'Assurance Plan, Revision 18, Section 6.3, Procedures and Drawings, implements this requi rement.

Nuclear Generation Group Standard Procedure EGR-NGGC-0005, Engineering Service Requests (ESR),

Revision 6. section 9. 11 'tep 9. 11.2 provides instructions for ESR closeout and directs that ESR closeout should occur no later than 30 days after approval for non-modification ESRs and requires that design documents be revised consistent with the frequencies identified in procedure.

Procedure EGR-NGGC-0007

'aintenance of Design Documents.

Revision 2, section 9.6. step 9.6.3 requires that the Equipment Database System (EDBS) be considered as a

Category A design document and therefore be updated prior to turnover or within 10 days of Document Update Notification of non-moditication ESRs.

Procedure EGR-NGGC-0007, Maintenance of Design Documents.

controls the document update process, and Procedure EGR-NGGC-156, Environmental Qualification of Electrical Equipment Important to Safety provides instructions for establishing, maintaining'nd implementing the Environmental Qualification (EQ) Program.

Contrary to the above.

the licensee did not adequately develop.

maintain. or implement procedures for controlling computer software development, plant configuration during the modification process, and for maintaining EQ Qualification Documentation Packages as evidenced by the following:

Prior to November 28, 1997. the licensee failed to have adequate instructions or procedures to ensure that software development activities could not affect quality related software and associated data files installed in the plant.

This failure resulted in incorrect data being installed into the operating directory for the POWERTRAX system on August 15.

1997.

9801210175 971231 PDR ADQCK 05000400

PDR Enclosure

CP&L 2.

The document update process was inadequate during implementation of Engineering Service Request 9400116 when replacement hydrogen analyzer sample pump motor starters (1SP-E134:003 and 1SP-E136:003)

were installed in Hydrogen Analyzer panels in September, 1997, and EDBS was not updated until December 2,

1997.

Prior to December 6,

1997, the licensee's procedures for the implementation oi'0 CFR 50.49 associated with the environmental qualification of electrical equipment were inadequate in that they did not establish a clear time requirement for updating environmental qualification documentation packages to ensure that the packages are maintained curr'ent and auditable for installed plant equipment.

This is a Severity Level IV violation (Supplement I).

B.

Technical Specification 6.5.2, Plant Nuclear Safety Committee (PNSC),

requires that a quorum shall consist of a Chai rman or alternate and four members or alternates as designated in writing.

No more than two alternates shall be counted toward meeting the quorum requirements.

Contrary to the above, a

PNSC meeting was conducted on October 29, 1997, without the required quorum membership.

In attendance were the chairman, a member, and three alternates.

,

This is a Severity Level IV violation (Supplement I).

CFR 50 Appendix B Criterion XVII Quality Assurance Records requires that sufficient records shall be maintained to furnish evidence of activities affecting quality.

Carolina Power and Light Corporate Quality Assurance Plan.

Revision 18.

Section 14.2

~

QA Records states that collection. storage, and maintenance of records shall be in accordance with commitments to Regulatory Guide 1.88 and/or ANSI N45.2.9 and the plant Technical Specifications.

ANSI N45.2.9 - 1974, Requirements for Collection. Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants, requires that the licensee maintain a records index of quality assurance records.

Contrary to the above. prior to November 19, 1997, the licensee failed to properly maintain a complete records index of all quality assurance records in that the records which implement TS 6.5.2 to appoint Plant Nuclear Safety Committee members in writing were not listed as quality assurance records.

This is a Severity Level IV violation (Supplement I).

Enclosure

CP8L Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN:

Document Control Desk.

Washington, D.C.

20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

This reply should be clearly marked

"Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, os if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved.

(3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an Order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration wi 11 be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR). to the extent possible, it should not include any personal privacy, proprietary.

or safeguards information so that it can be placed in the PDR without redaction.

However, if you find it necessary to include such information. you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

The NRC has concluded that information regarding the reason for violations

and C, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report No. 50-400/

97-12 which is Enclosure 2 of this letter.

However. you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.

In that case, or if you choose to respond, please follow the instructions in the paragraphs above.

Dated at Atlanta, Georgia this 31st day of December 1997 Enclosure

U. S.

NUCLEAR REGULATORY COMMISSION

REGION II

Docket No:

License No:

50-400 NPF-63 Report No:

50-400/97-12 Licensee:

Carolina Power 8 Light (CPEL)

Facility:

Shearon Harris Nuclear Power Plant, Unit

Location:

5413 Shearon Harris Road New Hill, NC 27562 Dates:

October

- December 6,

1997 Inspectors:

Approved by:

J.

Brady. Senior Resident Inspector (SRI)

G. MacDonald, Project Engineer (Section 02. 1 and E3. 1)

C. Patterson, SRI, Brunswick (BNP) (Sections 07. 1-07.6)

E.

Brown. Resident Inspector, BNP (Section 08.2. El. 1)

N. Merriweather, Reactor Engineer (Section 07.4, 07.5)

J.

Coley.

Reactor Engineer (Sections Ml.1. Ml.5. M1.6, M2.1)

H. Whitener.

Reactor Engineer (Sections Ml.1, M1.2.

Ml.3. M1.4, M1.6)

W. Rankin, Senior Project Manager (Sections Rl.l, R1.2, R8.1.

R8.2)

N. Stinson, Inspector in Training E. Guthrie, Inspector in Training M. Shymlock, Chief, Projects Branch 4 Division of Reactor Projects Enclosure 2