ML19256E050
| ML19256E050 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/01/1979 |
| From: | Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML19256E046 | List: |
| References | |
| NUDOCS 7910250569 | |
| Download: ML19256E050 (6) | |
See also: IR 05000324/1979027
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETT A ST., N.W., SUITE 3100
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ATLANTA, GEORGIA 30303
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In Reply Refer To:
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50-324/79-27
50-325/79-28
Carolina Power and Light Company
Attn:
J. A. Jones, Senior Executive
Vice President and Chief
Operating Officer
411 Fayetteville Street
Raleigh, North Carolina 27602
Gentlemen:
This refers to our letter dated September 4, 1979 which forwarded
inspection report 50-324/79-27 and 50-325/79-28. Due to an error
on our part, details pages 4 through 9 contain several transformations
of information as well as omissions of other information.
Please
replace pages 4-8 of the referenced report with the enclosed pages
4-8.
We regret any inconvenience this may have caused you.
Should you have any question concerning this letter t.e will be glad
to disctiss them with you.
Sincerely,
& c.
R. C.
ewis, Acting Chief
Reactor Operations and
Nuclear Support Branch
Enclosure:
Replacement pages 4-8 of
Inspection Report 50-324/79-27
and 50-325/79-28
cc:
A. C. To111 son, Jr.
Plant Manager
Box 458
Southport, North Carolina 28461
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by 10 CFR 50.59(b). The inspector verified that the licensee's use of
the word " unresolved" in response to this item was meant tg be "unre-
viewed." With that clarification, the licensee's te ionse was then
inspected.
The licensee stated that " Revisions to this procedure
(ENP-3) approved on February 9, 1979, require writtm. bases on all
modification packages." While the subject procedure has indeed been
revised as of February 9, 1979, the changes required that " Comments"
be included on each madification form, not " written bases" for the
determination that the modification does not involve an unreviewed
safety question. In addition, the inspector reviewed selected safety-
related modifications (#79-165, vessel level transmitter; #79-156, D/G
saddle tank vents and Battery Room fire dampers; #79-090, drywell
penetration seismic support; #79-083, bearing temperature monitor
installation;79-031; reactor recirculation system, setpoint change).
In each of these cases, " comments" had been placed on the form as
required by the procedure.
In 3 (79-165,79-083, 79-031) of the 5
examples reviewed, these " comments" did not contain the bases for the
required determination; in the remaining examples the " comments" did
provide a bases for the required determination. Since the procedure
had not been revised to require a bases for the required determination
as the licensee had stated in his response and since 3 examples were
found where the bases were not included, a deviation from the licer.see's
commitment to the NRC exists and is designated (324/79-27-02,
325/79-28-02). The inspector's sample was a random basis and should
not be used to conclude that three-fifths of the modifications did not
include the records of the bases. As with the original citation, the
deviation deals with records (required by 10 CFR 50.59(b)) not with
inadequate engineering determinations.
(0 pen) Infraction (324-325/79-02-08): Appendix A, item B, failure to
establish housekeeping, recordkeeping and document control programs
which meet the requirements of the accepted QA Program's commiteents
to ANSI N45.2.3, N18.7, and N45.2.9.
The licensee combined record-
keeping and document control issues when making his response, and he
delineated 7 items which would be a,
omplished to effect corrective
actions. The first commitment further stated that changes would be
made as a result of that study; the buuget items have been submitted,
but the required changes have not yet been made.
The remaining 6
items referenced in the response were inspected and found as stated
except the revision to AI-2 (covering items 6 and 7 was accomplished
on July 13, 1979, as opposed to June 30, 1979,a. stated). With respect
to housekeeping, the licensee gave a response indicating that a
program would be implemented by September 1, 1979. Since the due date
had not arrived as of this inspection, this item was not reviewed.
However, as part of a fire prevention prograin inspection (50-324/79-28,
50-325/ 79-29) two areas were found (cable spreading room and battery
room) with unacceptable housekeeping pratices.
These areas were
cleaned up prior to the end of the inspection and the referenced
report should be consulted for additional details.
Until the house-
keeping program is implemented and the changes recommended by the
records review study have been implemented, this item remains open.
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(0 pen) Infraction (324-325/79-02-09): Appendix A, item C, failure to
establish measures to assure the calibration of safety-related instru-
mentation used to verify LCO conditions but not specifically requirea
to be calibrated by the Technical Specification. As indicated in the
licensee's response, the instruments have been identified. The licensee
was in the process of writing calibration procedures, but the stipulated
implementation dires (October 31, 1979, for identifitation of remaining
instruments, and December 31, 1979, for implementation of complete
program) have not been reached. This item remains open.
(0 pen) Infraction (324-325/79-02-10): Appendix A, item E, failure to
have or follow procedures for calibration of safety-related laboratory
instrumentation. The citation addressed several related issues which
were also addressed in the licensee's response.
The licensee had
issued a letter dated March 30, 1979, placing these instruments under
Volume VIII of the POM; this letter was retracted in a letter
(0QA-79-65, file 2510) dated April 23, 1979. The licensee further
stated that these instruments would, in the future, be controlled
under section 6 of the Corporate QA Fanual; these instruments have
been added to that Section. Two procedures were identified as missing *,
one for calibration of a pH meter, the other for calibration of a
conductivity bridge. RC&T Procedure 1300, Revision 0 dated June 29,
1979, covers the standardization of pH meters and Procedu:
'320,
Revision 0 dated June 29, 1979, covers calibration of portable conduc-
tivity bridges.
The complete review of laboratory instrumenn and
implementation of a calibration program for those used in activities
affecting quality was not scheduled for completion until December 31,
1979; progress was being made and the item will be inspected after the
commitment date.
The licensee's recponse letter also included a
statement that Section 13 of the CP&L Radiation Control and Protection
Manual would be deleted; the licensee has decided to retain this
Section for nonsafety-related items.
The licensee will issue a
supplementary response to clarify this commitment. Until the calibra-
tion program has been implemented for all laboratory instruments used
in activities affecting quality, this item remains open.
(0 pen) Deficiency (324-325/79-02-11): Appendix A, item H, failure to
have indication of calibration status on all safety-rciated instru-
ments as required by the accepted QA Program. The licensee submitted
a supplementary response for this item in a letter dated April 20,
1979 (0QA-79-73, file 2630(b)).
T' e licensee wcs reviewed with rerpect
to this supplemental response. The licensee took an additional excep-
tion to ANSI N45.2.8, Draft 3, Revision 3 to allow the use of external
methods (status cards, computer printout) to indicate the status of
calibration instead of calibration stickers on installed instruments.
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The letter stated that this method would be used unless notified as
unaccepta,ble by NRR. The remaining part of the supplemental response
for this item stated that a list of affected instruments would be
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developed by June 30, 1979; with the exception of Environmental Tech-
nical Specification and Fire Protection instruments, that list was
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completed.
The instruments were to be included in a calibration
program by December 31, 197"; this aspect will be reviewed later. The
identified instruments were contained in a memorandum (0QA-79-121,
file 2630 (b)) dated May 29, 1979. This item remains open.
b.
Items (0 pen) Item (324-325/79-02-12):
Inclusion of consumable /
expendable items on the CP&L "Q"
List.
Review was in progress,
original completion date was scheduled for September 1, 1979. This
item remains open.
(Closed) Item (324-325/79-02-13):
Need to docunient current audit
practices, five specific areas. QAAI-1, Revision 6 dated June 1, 1979,
covered 3 of the 5 areas (need for detailed informai. ion, page 4;
handling of field notes, page 7; handling of items previously identi-
fied by the audited organization, page 4). QAAP-1, Revision 7 dated
June 1,1979, covered the remaining 2 areas (handling of items requiring
immediate correction, item 6.3.6.6; handling of overdue responses,
item 6.5.1) . This item is closed.
(Closed) Item (324-325/79-02-14): Need to complete initiated action
to document pre-audit conference attendees. QAAP-1, Revision 6 dated
June 1,
conference (p; age 5, item D.1).19'9 requires the documentation of attendees at
The inspector reviewed two recent audit
reports and found that pre-audit attendees were documented. This item
is closed.
(Closed) Item (324-325/79-02-15): Need to complete annual review of
all plant operating manuals.
This item was not cited since Opera-
tions QA had identified this inadequacy during audit QQAS-78-10 dated
November 1, 1978. The required reviews were completed, OQA closed the
item on January 22, 1979. The inspector also reviewed the POM on a
sampling basis and found that the required reviews had been conducted.
This item is closed.
(Closed) Item (324-325/79-02-16):
Need to establish a method for
transferring plant surveillance identified items to construction from
operations. Procedure Joint QAI-I, " Transmitting of Deficiencies for
Resolution", Revision 0 dated February 28, 1979, provided the needed
methods. This item is closed.
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(Closed) Item (324-325/79-02-17):
Need to establish a method to
control items which need rework or repair to replace the current use
of Surveillance Reports. A procedure, QAP-10, " Method of Documenting
Removal of Equipment for Repairs", Revision 0 dated February 28, 1979,
defines a method. The inspector reviewed the Nonconforming Equipment
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Fonn (NEF) log. This item is closed.
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(0 pen) Item (324-325/79-02-18):
Need for timeliness of corrective
actions and responses. The licensee had written a Procedure QAP-2,
Revision 6, dated June 15, 1979. As a result of this revision, the
inspector found that responses were now being received. However, the
procedure does not require that the response identify a date for
completion of corrective action. This identification was being required
(by the direction of the QA Supervisor, above the written requirements
of the procedure) on recent (since July 1, 1979) surveillance reports.
However; since escalation actions are keyed to overdue commitments,
this lack of commitment dates precludes procedural requirements for
escalation. The licensee stated that the procedure will be revised by
August 31, 1979, to require that the cause of the item found, the
proposed corrective action, and a date for acnieving full compliance
be identified in the response. Until these additional provisions have
been added to the procedure and backfitted to outstanding Surveillance
Reports, this item remains open.
(Closed) Item (324-325/79-02-19): Need for escalation of corrective
action to surveillance reports when auditor and the responsible
organization disagree.
The provisions have been made in QAP-2,
Revision 6, item 5.6; to date, this process has not been used. For
audits performed by DQA, procedure OQA-2, Revision 4 dated March 12,
197S has an escalation process set forth in items 7.3 and 8.0.
This
item is closed.
(0 pen) Item (324-325/79-02-20): Need for a program for evaluation of
repetitive failures. Although the original target date was August 1,
1979,the licensee had determined that the needed program would require
additional time to properly generate. The target completion date was
revised to be December 31, 1979. This item remains open.
(Closed) Item (324-325/79-02-21): Generate a procedure for receipt of
Q material after normal working hours. SK-2, Revision 0 dated July 12,
1979 now provides for such receipt. This item is closed.
(Closed) Item (324-325/79-02-22): Document a requirement to followup
orally or informally transmitted design information with a written
document. Engineering Department procedure 3.1, Revision 15, requires
(item 3.1.3.1) that when it is necessary to transmit design information
informally, such information shall be confirmed in writing. This item
is closed.
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(Closed) Item (324-325/79-02-23): PNSC to review all modifications to
determine if a proposed modification affects nuclear safety. ENP-3,
Revision 6 dated February 9,1979, paragraph 3.2.3 requires a determina-
tion to be made (and block 10 on the traveler appropriately checked)
if a proposed modification could affect nuclear safety even when the
modification itself is nonsafety-related. This item is closed.
(0 pen) Item (324-325/79-02-24): Update of drawings. This item was
originally designated as 79-02-34 in Detail 9.c (page 20) of combined
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reports 50-324/79-02, 50-325/79-02; this item should be designated
79-02-24. The licensee has addressed this item in two le.tters, one
dated March 14,1979,(GD-79-654, file 3513(B)) the other dated August 1,
1979, (GD-79-1967, file 3513 (B)). '. As indicated in these letters the
licensee has identified those prints which will require revision. All
completed plant modifications are to have their associated prints
revised by September 14, 1979. This item remains open. The revision
of System Descriptions is due December 31,1979,as originally scheduled.
(0 pen) Item (324-325/79-02-25): PNSC to review all procedures required
by Regulatory Guide 1.33, Appendix A. These were being reviewed, but
the completion date of January 31, 1980,has not been reached. This
item remains open.
(Closed) Item (324-325/79-02-26):
Review use of revised AQAS-7 to
assure reaudit of inactive vendors prior to being placed back on the
active vendor list.
The inspector discussed this item with the
Principal Vendor Surveillance Specialist and reviewed the file for a
recently revitalized vendor (Yarway).
The system is operating as
described in AQAS-7. This item is closed.
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