ML18004B638
| ML18004B638 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/10/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-514 NUDOCS 8612220227 | |
| Download: ML18004B638 (8) | |
Text
Carolina Power 8 Light Co a
Ll5 F3; )g HARRIS NUCLEARPROJECT P. 0. Box 1:65,'ew Hill, N. C.
27562 December '10,'986 File 'Number: SHF/10-1.3510E
'NRC-51'4 Dr. J. Nelson Grace United States'Nuclear Regul'atory Commission Region II
'101; Marietta Street, Northwest (Suite 2900):
Atlanta, Georgia
.30323
Dear Dr. Grace:
'Pur'suant to 'our'. telephone conference;call,.:with your'r. P. Fredricks'on on
, November 24, '1986 regarding 'our.reply to RII::50'-400/86-68-01,:the attached
'.is Carolina Power' Light*Company's.'supplementary response to,parts b'
c.
It is considered.that.the corrective actions.taken are.satisfactory for resolut'ion of,the'. item.
. Thank you 'for y'our. consideration in.this:matter.
Your's very truly, R. A. Watson
.:Vice President Harris Nuclear Project RAW:jp Attachment cc:
Mr. G. F.",Maxwell,(NRC-SHNPP),
.W/A.
Mr'. B. C. "Buckl'ey.(NRC),
W/A.
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t Dr. J. Nelson Grace Page Two NRC-514 Attachment to CP&L Letter of Supplementary
Response
to NRC Report RII:
50-400/86-68-01 (parts b
& c)
Re orted Violation:
10CFR50.,55(f)(l) requires CP&L to implement the Quality Assurance Program described or referenced in the Preliminary Safety Analysis Report.
Section 1.8.5.5 of the CP&L Quality Assurance Program requi're that measures be established to ensur'e that activities are coriducted in accordance with documented instructions and procedur'es.
a ~
Maintenance Management Manual MMM-001, "Sections 4.4,and 5.5.
and MMM-012,, Section 5.4 and Appendix B requi're that maintenance be conducted in accordance with an approved WR&A.
Contrary to.the above,.maintenance personnel performed work on two steam generator power operated relief valves which were not identified on WR&A 86-AUAK1.
b.
'Quality Assurance Procedure QAP-202, Section 7.1 requires, that QA identify necessary QC hold points in WR&A's.
Contrary to,.the above, QA personnel failed to identify,the necessary QC hold points on WR&A 86-AUAK1.
c.
Quality Assurance Procedur'e QAP-202., Sections 7.4 and 7..5 require, that QA personnel review 'WR&A's to erisur'e.that the documents reflected the actual work performed.
Contrary to the above, QA personnel.failed to provide an adequate review of completed WR&A's 86-ABXA1, 86-ABXA2, 86-ABXA3.
d.
'Quality Control Procedure QCP-302, Section 7, and Maintenance Management Manual Procedur'e MMM-001,, Sections 4.4 and 5.5.8, and MMM-012, Section
. 5.4 and Appendix B require that inspections be conducted by QC personnel at established hold points.
Contrary to the above, QA personnel failed to perform the required QC hold point inspections for WR&A's 86-AXTAl, 86-AXTB1, 86-AXTD1, 86-AXTEl, 86-AXTQ1, 86-AXTRl, 86-AXTSI, 86-AXTT1, and 86-AXTU1.
e.
Section 7 requi'res that nonconforming conditions be documented on a Nonconformance Report.
Contrary to,the above, QC'supervision failed to properly document an identified nonconforming condition, an 'improperly controlled WR&A, (86-AUAK1).
This is a Severity Level IV violation (Supplement II).
Dr. J. Nelson Grace t
Page Three Denial or Admission and Reason for the Violation:
NRC-514 The deficiencies related to parts b
& c of the Violation are discussed below:
b.
The following personnel errors and procedure deficiencies related to WR&A 86-AUAK1 were identified.on Nonconformance Reports OP-86-0061' OP-86-'0065:
1)
The engineering authorization to reset the 'guide and nozzle rings was not referenced or made a part of the WR&A.
2)
. The WR&A was not identified as a "MOD".
3)
The WR&A did not indicate that, maintenance was to perform adjus'tments.
4)
Work was performed on valves not specifically identified on the WR&A.. 5)
,The natur'e and scope of the work were not clearly defined on the WR&A.
(This resulted in no QC inspection hold points being applied.)
C ~
While the QA -reviews of the WR&A's in 'question were performed in accordance with,the governing procedure,
.the reviews failed to prevent the WR&A,'s from being processed with incorrect valve
'numbers in the "Natur'e of Tr'ouble" block.
The review procedure "did not address review of.data in this block.
Corrective Ste s Taken and Results Achieved:
b.
Individual WR&A's were issued for each of the 17 valves to be worked.
These"fully described the scope and natur'e of the work to be done and indicated the Vendor representative was to provide technical 'guidance.
Required QC inspection holdpoints were includ'ed.
ce The file copies of the WR&A's in "question were corrected to indicate the proper.valve 'numbers in,the "Nature of Tr'ouble" block.
A.sample of '2'00'R&A's in the QA Records vault was reviewed for erroneous'quipment identification data in the "Nature of Tr'ouble" block.
There were 2 cases where the item
'listed, in the ",Nature of Tiouble" block was not the item ultimately identified for work.
In neither case.was the wrong item worked "due to the wrong identification being listed in the "Nature of Tr'ouble" block.
.Since the proper items were worked in accordance with the. "Repair Instruc'tions" block and.the work fully described in the "Corrective Action" block, no action is planned to correct item identification errors in the "Nature of Trouble" block of WR&A's.which,have been previously processed.
Corrective Ste s Taken to Avoid Further Noncom liance:
b.
An Advance Change to procedure MMM-012 was issued to prevent the issue of a "general assist" type work request when assistance to a vendor representative is to be provided.
"Vendor assist" work -requests are now initiated, planned and processed with the
.same detail used on a maintenance work request.
The Advance Change also requires individual,work reque'sts for each tag 'number or specific item identification.
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Dr. J. Nelson Grace Page Four NRC-514 Maintenance Plannners/Analysts, have been trained in the provisions of the new requirements of MHM-012 and the concerns of this violation.
The Start-Up Engineer who issue'd the WR&A in question has been counselled on properly filling'out the WR&A.
QC personnel have been instructed to ensur'e that specific repair instructions are provided on 'WR&A's prior to approval for 'fur'ther processing.
c ~
QA/QC Section Procedur'e OQA-202,. Docum'ent Review,,which became effective September 1,
1986, requires that.the initial QC review of WR&A's includ'e a "clear and concise description of,the tr'ouble".
QC personnel.have "been instructed in the provisions of this procedure.
Date When Full Com liance Was Achihved:
Full compliance,was achieved on October 3, 1986.
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