ML19262B064

Responds to NRC 791012 Ltr Re Violations Noted in IE Insp Rept 50-261/79-19.Corrective Actions:Procedures Will Be Revised or New Procedures Implemented to Assure Deviations Properly Evaluated

ML19262B064
Person / Time
Site:	Robinson
Issue date:	11/02/1979
From:	Furr B CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML14175B111	List: ML19262B064
References
GD-79-2798, NUDOCS 7912110497
Download: ML19262B064 (5)

Text

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. s 6 Carolina Poiver & Light Company November 2, 1979

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File: NG-3513(R) Serial: CD-79-2798 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO IE INSPECTION REPORT NO. 50-261/79-19

Dear Mr. O'Reilly:

We have received and reviewed the subject report and are hereby responding to the infractions and deficiency as requested.

Enforcement Item Infraction A (79-19-03)

As required by Section 21.21(a) of 10CFR21 each entity subject to these regulations shall adopt appropriate procedures for evaluation of deviations and assure that a director or responsible officer is informed if the construction or operation of a facility, or activity, or a basic component supplied for such a facility or activity fails to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regu-lation, c. der, or license of the Commission relating to a substantial safety hazard or contains a defect. Section 21.21(b)(3) delineates the information to be included in the written report. Section 21.51 delineates the maintenance of records requirements. Carolina Power &

' Light Company (CP&L) Procedure for compliance with Part 21 Title 10 of the Code of Federal Regulations by the Corporate Director of CP&L and Procedure for Evaluating and Reporting of Defects and Noncompliance in accordance with 10CFR21 and other group procedures have been developed to comply with Part 21 reporting requirements and other reportable occurrences. ,

Contrary to the above, CP&L has not developed and implemented appropriate procedures to assure that deviations are evaluated (21.21(a)(1)); the Director or responsible officer is informed (21.21(a)(2));

the written report to the Commission contains information (21.21(b)(3));

' and that the required records are maintained (21.51).

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• Raleigh, N. C. 27602 UkOY7/

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4 Mr. James P. O'Reilly November 2, 1979

Response

The extent to which the Company's procedures fail to satisfy the requirements of 10CFR, Part 21, are not altogether clear from the Notice of Violation as written, especially when read against the background of the discussion in Details, Item 8. Based on statements made by the inspector and on our own reading of the regulctions, there appear to be only two ways in which our existing procedures may not meet the literal requirements of Part 21. These are: (1) Our corporate Part 21 regula-tions do not requ'* e, nor have plant procedures required, review of all procured items an, Jervices for deviations from the technical require-ments of procurement documents as required by 10CFR21.21(a)(1)(i) and 21.3(e) and (i); and (2) formal procedures have not been developed as required by 21.21(a)(2)(i) and (ii) pursuant to which a director or responsible officer is informed of (a) all failures to ccmply relating to a substantial safety hazard or (b) all defects (as defined in 21.3(d)), although virtually all such failures to comply and defects would in fact be reported to a responsible officer.'

In all other respects, we continue to believe that our procedures comply with the intent and spirit of 10CFR, Part 21. In this regard, we note that in Inspection Reports 50-325/78-8 and 50-324/78-8 the inspector examined our Procedure for Compliance with Part 21 by the Corporate Directors and our Procedure for Evaluating and Reporting of Detects and Noncompliances in accordance with Part 21 and stated that he "had no questions concerning the implementation of the program from the corporate office". Moreover, Report No. 50-261/78-07 stated for both the Brunswick facility and H. B. Robinson Unit 2: "It was determined that the requirements of 10 CFR Part 21 has been implemented by CP&L."

Although with the exceptions noted in the first paragraph we believe our procedures technically comply with the requirements of 10CFR, Part 21, we appreciate the concern and additional objectives reflected in the inspector's comments during the exit interview. That concern, as we perceive it, is that although our system of reporting failures to comply and defects may in fact provide NRC actual notice of all events which are or could be reportable under Part 21, it does not

" flag" or otherwise adequately address the significance of the reported defects and failures to comply either for NRC or for the responsible corporate officer.

1Additionally, in regard to paragraph 8.b of the inspection report, CP&L would like to clarify that deviations associated with activities dis-cussed in that section of the report have been and are being evaluated

• to both 10CFR50.55(e) and 10CFR, Part 21, criteria. These reviewc were sad will continue to be performed without specific request from a Company director or officer.

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Mr. James P. O'Reilly November 2, 1979 6

In response to these concerns, which we believe are valid, we are taking the following actions.

Corrective Action

1. Shearon Harris Nuclear Power Plant

a. Procedures (interim / final) will be revised to further clarify that deviations, failures to comply, and defects are to be evaluated to both 10CFR50.55(e) and the 10CFR21 substantial safety hazard criteria, and that a responsible officer is notified of the results of all deviations, failures, and defects related to a substantial safety hazard,

b. All items considered "potentially reportable", to date, which af ter evaluation had been subsequently considered to be non-reportable, will be reevaluated for reportability under 10CFR21 criteria, and a follow-up report filed, if required.

2. H. B. Robinson S. E. Plant

a. Existing plant procedures that provide for the identification of deviations or, if necessary, new procedures will be revised / implemented to assure that deviations are evaluated relative to a substantial safety hazard.

b. Existing plant procedures or, if necessary, new procedures will be revised / implemented to assure that failures to comply which relate to a substantial safety hazard and defects are reported to a responsible officer.

c. Existing plant procedures that provide for reporting of occurrences or, if necessary, new procedures will be revised / implemented to assure those items which also consti-tute a substantial safety hazard as defined in 10CFR21.3(k) are reported with the information required of 10CFR21.21(b)(3).

If a report was issued because of an occurrence reportable

' under Technical Specifications or 10CFR20 aul is later determined to also involve a substantial safety hazard, a supplementary report shall be sent so as to provide the information of 10CFR21.21(b)(3).

d. Existing plant procedures that provide for record retention, or, if necessary, new procedures will be revised / implemented to assure that the records required by 10CFR21.51 are main-tained.

i* e. Corporate 10CFR21 procedures shall be reviewed and revised as necessary.

' f. Failures to comply and defects which may have occurred subse-quent to J.inuary 6,1978, and which have not been evaluated

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Mr. James P. O'Reilly November 2, 197) to deter' ne if they would have been reportable pursuant to the crite in 10CFR, Part 21, will be evaluated and a responsible officer and the NRC notified as to any failures to comply or defects which are found to meet the reportability criteria pursuant to 10CFR, Part 21, whether or not the defect or failure to comply has previously been reported to NRC.

Corrective Action to Prevent Further Noncompliance The methods outlined in Corrective Action paragraphs 1 and 2 will be followed to prevent i_ture noncompliance with 10CFR21, and to meet the further objectives discussed in tFis response.

Date(s) When Full Compliance Will Be Achieved Item 1.a - prior to November 15, 1979.

Item 1.b - prior to December 1, 1979.

Items 2.a thru 2.d - Interim measures by November 15, 1979. Fully approved piagram by January 1, 1980.

Item 2.e - Completion prior to January 1, 1980.

Item 2.f - Completion prior to March 1, 1980.

Enforcement Item Infraction B (79-19-02)

As required by Technical Specifications, Section 6.8.1, " Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972 an! Appendix A of USNRC Regulatory Guide 1.33 dated November 3, 1972." Adminis' .ative Instruction Section 11.11, Jumpering and Wire Removal, requires jumpers to be tagged and logged in the Shift Foreman's Jumper and Wire Removal Log located

. in the Control Room.

Contrary to the above, a jumper had been installed from a spare breaker located on MCC-9 and the Computer Inverter as a temporary power supply without being tagged and logged as described in Section 11 of Volume I Administrative Instructions.

Corrective Action As identified in Detail 7.b of Inspection Report 79-19, corrective action regarding this infraction was satisfactorily completed by CP&L f'

and verified by the inspector. No further immediate corrective action 1s required.

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Mr. James P. O'Reilly November 2, 1979 g Corrective Action to Prevent Further Noncompliance Personnel who are involved in the installation of jumpers and temporary power supplies have been instructed to control temporary power supplies in the same manner that jumpers are controlled.

Date When Full Compliance Will Be Achieved Full compliance with Section 11 of Volume I, Administrative In-structions, was achieved on October 30, 1979.

Enforcement Item Deficiency C (79-19-01)

As required by 10CFR50, Appendix B, Criterion V and CP&L's accepted QA Program ('iSAR Section 10, Ar'icle V) activities affecting quality shall be prescribed by documented procedures...The Corporate QA Program (Section 1.6.1) requires that a written procedure be provided to develop and control the administration of the Q-list.

,i Contrar-j to the above, as of September 14, 1979, there was no

' written procedure for developing and controlling the administration of the Q-list.

Corrective Action Procedures will be generated and/or revised to include developing and controlling the administration of the Plant Q-list.

Corrective Action to Prevent Further Kencompliance Further noncompliance in this area shall be prevented by implemen-tation of the procedures and/or revisions addressed above.

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Date When Full Compliance Will be Achieved Full compliance shall be achieved by January 31, 1980.

If furtter information is required, please notify me.

Yours very truly, N

B . Furr I Vice President DRB:WJD:cp*

i Nuclear Operations e

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