ML18011A252
| ML18011A252 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/16/1993 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HNP-93-866, NUDOCS 9312220308 | |
| Download: ML18011A252 (6) | |
Text
ACCELERATED DISTRIBUTION DEMONSTPWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SUBJECT:
Responds to violations noted in insp rept 50-400/93-21.
Corrective actions:procedure AP-032 'revised to further clarify that vendor procedures for work on safety-related structures,sys or components formatted per AP-005.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL g SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response NOTES:Application for permit renewal filed.
ACCESSION NBR:9312220308
,DOC.DATE: 93/12/16 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION ROBINSON,W.R.
Carolina Power
& Light Co.
RECIP.NAME,
, RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400 05000400 R
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RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS1 RES/HFB EXTERNAL: EG &G/BRYCE, J. H.
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1 RECIPIENT ID CODE/NAME LE,N AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 OE DIR BF~XK&
02 RGN2
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D NOTE TO ALL"RIDS" RECIPIENTS PLEASE HELP US TO REDUCE iYASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24 D
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Carolina Power & Light Company Harris Nuclear Plant PO Box 165 New Hill NC 27562 File: HO-930209 DEc )
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United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Serial:
HNP-93-866 10CFR2.201 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:
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In reference to your letter of November 18, 1993, referring to NRC Inspection Report 50-400/93-21, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1.
We consider the corrective actions taken/planned to be satisfactory for resolution of the violation.
Questions
'regarding this matter may be referred to Mr. R. W. Prunty at (919).362-2030.
Very truly yours, W. R. Robinson Vice President Harris Nuclear Plant MGW:che Attachment c:
Mr. S. D. Ebneter (NRC-RII)
Mr. N. B. Le (NRR)
Mr. J. E. Tedrow (NRC-SHNPP) 9312220308 931216 PDR ADOCK 05000400 Q
PDR State Road 1134 New Hill NC
Attachment to HNP-93-866 Page 1 of 2 REPLY TO A NOTICE OF VIOLATION
'RC INSPECTION REPORT NO. 50-400/93-21 r
Re orted Violation:
Technical Specification 6.8.1(a) requires that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, requires administrative piocedures governing the review and approval of procedures.
Administrative Procedure AP-006, Procedure Review and Approval, Section 5.2 requires, in part, that procedures generated by an off-site source for use on site shall be reviewed and approved in accordance with Section 5.1. Section 5.1 of AP-006 outlines the steps involved in reviewing and approving procedures and requires a safety and technical review.
Contrary to the above, in October 1993, the inspector discovered that several off-site procedures used by a vendor for leak repairs on safety-related components at Harris did not receive the above required technical or safety review by the licensee.
This is a Severity Level IVviolation (Supplement I).
Denial or Admission:-
The violation is admitted.
Reason for the Violation:
Leak Repair vendor procedures were not included in the Plant Operating Manual when the initial contract was written in 1987. AP-032, Procedure to Obtain Non-Company Labor and Services, did not specify how to deal with vendor procedures until the requirement was added to the Designated Contract Representative responsibilities in Revision 3 dated October 29, 1991. The impact ofrequiring vendor procedures to be processed in accordance with AP-006, Procedure Review and Approval, was not adequately addressed for the existing Leak Repair contract.
MEM/HO930209/OS1
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q Attachment to HNP-93-866 Page 2 of 2 Corrective Ste s Taken and Results Achieved:
Technical and safety reviews of the vendor procedures used in safety-related temporary leak repairs still in place were satisfactorily performed.
This action was completed on December 10, 1993.
Areview ofother vendor procedures revealed no similar occurrences. Incorporation ofLeak Repair vendor procedures into the Plant Operating Manual in accordance with AP-006, Procedure Review and Approval, willbe completed prior to their use for any safety-related applications.
Corrective Ste s Taken to Prevent Further Violations:
AP-032 (Procedure to Obtain Non-Company Labor and Services) willbe revised to f'urther clarify that vendor procedures forwork on safety-related structures, systems, or components will be formatted per AP-005, Procedures Format and Preparation, and,approved in accordance with AP-006 (Procedure Review and Approval) or the procedure will be included in the modification package as a work instruction and will be reviewed, both technical and safety, as a part of the modification package. This action willbe completed by January 21, 1994.
Designated Contract Representatives have been notified ofthe requirements for review and approval of vendor procedures.
Additional instruction on AP-032 requirements willbe provided for Designated Contract Representatives.
This action willbe completed by February 25, 1994.
Date When Full Com liance Was Achieved:
Full compliance was achieved on December 10, 1993, upon completion of the technical and safety reviews of procedures used in safety-related temporary leak repairs still in place.
MEM/H0930209/OS1