ML18010A418

Responds to NRC 911002 Ltr Re Violations Noted in Insp Rept 50-400/91-18.Corrective Actions:Initiated Nuclear Assessment Dept Procedure 100-03, Assessment Process, Rev 2

ML18010A418
Person / Time
Site:	Harris
Issue date:	10/02/1991
From:	Loflin L CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-91-262, NUDOCS 9110090324
Download: ML18010A418 (4)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM, REGULATORY XNFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR: 9110090324 DOC. DATE: 91/10/02

~ NOTARIZED: NO DOCKET ¹ ACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina

~ ~ ~

05000400 AUTH. NAME AUTHOR AFFILIATION LOFLIN,L.I. Carolina Power & Light Co.

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RECIP.NAME RECIPIENT AFFXLXATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 911002 ltr re violations noted in Xnsp Rept 50-400/91-18.Corrective actions:initiated Nuclear Assessment Dept Procedure 100-03, "Assessment Process," Rev 2.

D DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR, l ENCL I SIZE:

TITLE: General (50, Dkt)-Insp Rept/Notice of Vi&o ation R sponse NOTES:Application for permit renewal filed. 05000400 /

A RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD2-1 PD 1 1 MOZAFARI,B. 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 D

AEOD/DEIIB 1. 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR HARBUCK,C. 1 1 NRR MORXSSEAU,D 1 1 NRR SHANKMAN,S. 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 1 1 OGC/HDS1 1 1 REG FIL 02 1" 1 RGN2 FXLE 01 1 1 EXTERNAL: EGGG/BRYCE, J. H. 1 1 NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE i i ASTE. CONTACT THE DOCUMENT CONTROL DESK ROOi~I PI-37 (EXT. 20079) TO ELliXIINATL'OURNAi~IE FROiVI DISTRIBUTION LIS1S I OR DOCUliIENTS YOU DON'T NEED!

AL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

C~L Carolina Power 4 Light Company October 2, 1991 S ERIAL: 'LS - 9 1- 262 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REPLY TO A NOTICE- OF VIOLATION Gentlemen:

Carolina Power & Light Company (CP&L) has reviewed NRC Inspection Report No.

50-400/91-18, dated- September 6, 1991. Enclosed is CP&L's reply to the violations identified in Enclosure 1 to that report. CP&L acknowledges the violations and considers the corrective actions taken to be satisfactory for resolution of these violations.

The inspection report also identified that fragmented documentation made it difficult to determine the effectiveness of'he audit program. In order to correct this weakness, Procedure 100-03, "Assessment Process," Revision 2 was approved on September 24, 1991 and provides that a compliance file should be assembled and filed by the lead assessor, along with the assessment report and the specific assessment agenda/plan. The compliance file, along with the assessment report, should contain sufficient information to clearly demonstrate that a quality assessment was performed and regulatory commitments satisfied.

If you require additional information on this subject, please contact Mr. Lewis Rowell at (919) 546-2770.

Yours very truly, L.. Lof1 n Manager Nuclear Assessment Department LSR/jbw (1325HNP)

Enclosure cc: Mr. S. D. Ebneter Ms. B. L. Mozafari Mr. J. E. Tedrow (NRC-SHNPP)

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Enclosure to NLS-91-262 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/91-18 VIOLATION 400 91-18-02 Re orted Violation:

Technical Specification 6.5.4.4 requires that audit reports shall be prepared, approved by the Manager - Quality Assurance/Nuclear Assessment Department, and forwarded within 30 days after completion of the audit to the Executive Vice President - Power Supply and Senior Vice President - Nuclear Generation.

to the above, the 1991 Fire Protection Audit, Maintenance and E&RC 'ontrary Audit, and the Management/Modification Audit were not approved and forwarded within 30 days after completion of the audit; and the audits were not forwarded to the Executive Vice President - Power Supply and Senior Vice President Nuclear Generation.

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

Denial or Admission and Reason for the Violation:

CP&L admits the violation as stated. The reports were not issued within the required period because of efforts to improve the format and content for assessment reports to be consistent with the newly formed Nuclear Assessment Department mission.

The reports were not forwarded to the Executive Vice President - Power Supply and Senior Vice President - Nuclear Generation because the Manager - Nuclear Assessment Department now presents verbal summaries of assessment reports to these executives.

Corrective Ste s Taken and Results Achieved:

A Nuclear Assessment Department Memorandum 91-195, Revision 1 was issued on July 18, 1991 when Nuclear Assessment management became aware that the 30-day requirement of Technical Specifi.cations had not been met. The memorandum was directed to all persons having responsibility for issuing assessment reports.

It explicitly required that reports were to be issued within 30 days after the assessment exit or debriefing, whichever came later. Debriefings were to be held on the last day of the assessment and exits held later only if new information was developed during the wrap-up period when the report was being prepared.

On September 24, 1991, Nuclear Assessment'epartment Procedure 100-03, "Assessment Process," Revision 2 was approved to incorporate the above requirement. In addition, the procedure specifies assessment report distribution to the Executive Vice President - Power Supply and Senior Vice President-Nuclear Generation. Since July 30, 1991, assessment reports have been issued within the 30-day time limit and have had the required distribution noted above.

Corrective Ste s That Will be Taken to Avoid Further Violations:

The planned corrective steps to avoid further violations have been completed.

(1325HNP)

Enclosure to NLS-91-262 Date When Full Com liance Will be Achieved:

Full compliance has been achieved as of September 24, 1991.

VIOLATION 400 91-18-03 Re orted Violation:

10CFR50, Appendix B, Criterion XVIII and the licensee's accepted Quality Assurance Program, Corporate Quality Assurance Program Manual, Revision 14 collectively require that the corrective action for significant conditions adverse to quality be documented. The Corporate Quality Assurance .Manual, paragraph 12.4.2, further requires that if the condition is not confirmed, the initiating document shall be canceled, the bases for cancellation noted on the document, and the document shall be placed in a permanent file.

Contrary to the above, maintenance and E&RC corrective actions to various adverse conditions noted during Assessment 91-02, were not properly documented.

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

Denial or Admission and Reason for the Violation:

CP&L admits the violation as stated. The corrective actions to various adverse conditions noted during Assessment 91-02 were not properly documented as a result of efforts to improve the content of assessment reports to be consistent with Nuclear Assessment Department strategy. Nuclear Assessment Department strategy centers on identifying trends that may represent bariiers to performance relating to nuclear safety, reliability, and quality. To identify trends, experienced personnel conduct performance-based observations of activities that are critical to barrier identification. Typically, these observations identify performance not meeting expectations. To enhance trend identification, assessor observation field notes are entered into an integrated computer database. Individual data entries are evaluated by Nuclear Assessment Department assessors to the extent necessary to determine if the data constitutes a condition adverse to quality.

Nuclear Assessment Department assessors are sensitive to the need for conditions

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adverse to quality to be properly dispositioned upon discovery. Regardless of this evaluation, the data would still be placed in the database for trend analysis.

Corrective Ste s Taken and Results Achieved:

In order to reinforce this understanding, Guideline 300-01, "Data Management,"

Revision 1 was approved on September 24, 1991 'and requires that the assessor note whether or not the condition represents an adverse condition when documenting field observations on the Observation Input Sheet. If an adverse condition is identified, appropriate documentation is initiated.

Corrective Ste s That Will be Taken to Avoid Further Violations:

The planned corrective steps to avoid further violations have been completed.

Date When Full Com liance Will be Achieved:

Full compliance has been achieved as of September 24, 1991.

(1325HMP)