ML18018B438
| ML18018B438 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/29/1983 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18018B437 | List: |
| References | |
| CON-NRC-122 NUDOCS 8311070611 | |
| Download: ML18018B438 (5) | |
Text
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Exhibit 8 P. O. Box 101, New Hill, N. C.
27562 September 29, 1983 Mr. James P. O'Reilly United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30303 NRC-122
Dear Mr. O'Reilly:
In reference to your letter of September 1, 1983, referring to RII:
PEF 50-400/83-24-1, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.
It is considered that the corrective action taken is satisfactory for resolution of'the item.
Thank you for your consideration in this matter.
'ours very truly, R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh
'ttachment cc:
Messrs. G. Maxwell/R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC)
~lr, James P. O'Reilly N RC-122 occ:
Mr. H. R. Banks Mr. C. S. Bohanan Mr. J. R. Bohannon Mr. G. S. Cashell Mr. N. J. Chiangi Mr. A. B. Cutter Dr. T. S. Elleman Mr. G. L. Forehand iVlr. B. J. Furr Dr. J. D. E. Jeffries iVlr. I. A. Johnson Mr. L. I. Loflin Mr. R. E. Lumsden Mr. R. L. Mayton, Jr.
Mr. S. McManus Mr. C. H. Moseley, Jr.
Mr. R. M. Parsons Mr. J. J. Sheppard Mr. Sheldon D, Smith-'r.
J. L. Willis File: HX-0544
'0 4 ~ 0
Attachment to CPRL Letter of Response to NRC Report RII: PEF 50'-400/83-24-01 10 CFR 50, Appendix B, Criterion XVI, as implemented by PSAR paragraph 1.8.5.16, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, measures have not been established to assure that conditions adverse to quality are promptly identified and corrected in that the quality assurance program as implemented contains the following deficiencies:
1.
Multiple inadequate control interfaces exist between document systems such as occurs when a condition adverse to quality is upgraded to a higher tiered corrective action system.
2.
Non-quality and non-serialized documents such as punch lists are utilized to accomplish corrective actions.
3.
Voiding and cancellation of quality documents are not adequately controDed within both the Construction Inspection and Quality Control systems.
4.
Inspector's findings, particularly'when non-quality documents such as punch lists were used, are not preserved.
5.
Periodic trending of nonconformances for the purpose of determining adequacy of corrective actions, does not include all types of nonconformances generated at the site.
This is a Severity Level IV Violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
CPM, concurs with the Inspector that the conditions described in the report are individual program weaknesses.
The nonconformance program, during the development and review processes, was considered to be in basic compliance with the applicable
- criteria, as interpreted.
Even though the base requirements have not changed, a need for refinement of the style and content of the program occurred without being fully met.
CPdcL does, however, respectfully request that the NRC consider downgrading the severity level to Level V based on the fact that in all cases actually identified by the Inspector, there was not a direct loss of control.
Corrective Ste Taken and Results Achieved:
Prior to the NRC audit on July 19-22,
- 1983, and the resultant violation, the overall nonconformance and corrective action program was being evaluated for consolidation into a single procedure, and for upgrading several areas considered to be in need of enhancement, some of which are in the same vein as the Inspector's findings.
A composite procedure, now being developed, will address and resolve the individual t
weaknesses that were identified by the Inspector.
Pending issue of the new composite procedure, QA/QC Procedure CQC-2, Nonconformance
- Control, has been revised to delineate the process for voiding and canceDing QA/QC~enerated nonconformance reports.
Also, for nonconformance reports
"2-Corrective Ste s Taken and Results Achieved (cont'd.):
generated by Construction Inspection, memoranda have been issued to clarify the processing in accordance with site procedure TP-17, Construction Inspection Nonconformance Control.
The memoranda pertain to nonconformance resolution and acceptance, and the issue of aQ nonconformance reports for dispositioning, even though the report fails to describe a nonconforming condition.
The electrical "punch lists" observed by the Inspector are being formaQy incorporated into site procedure TP&2.
Installation of Safety Related or Seismically Installed Raceways and Components, which will change the "punch list" to an inspection report and an official QA record.
Corrective Ste Taken to Avoid Further Noncom liance:
The new nonconformance and corrective action procedure, in addition to correcting the weaknesses, will contain guidance in the use and disposition of documents considered to be part of nonconformance
- handling, even though the documents (e.g.,
punch lists, travelers) are part of a work or inspection procedure.
Date When Full Com liance WillBe Achieved:
Issue of the new nonconformance and corrective action procedure is scheduled for December 15, 1983. Full compliance for aQ aspects of the violation will be completed by February 1, 1984.