ML19274F029

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Responds to NRC 790221 Ltr Re Violations Noted in IE Insp Repts 50-324/79-02 & 50-325/79-02.Corrective Actions:Review of safety-related Sys Will Be Made & QA Manual Revised
ML19274F029
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 04/20/1979
From: Furr B
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19274F028 List:
References
OQA-79-73, NUDOCS 7906080151
Download: ML19274F029 (3)


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Carchna Power & Light Company 1979 April 20,U41';][* -:-

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Serial: OQA-79-73 File: NG-3513 (B) 2630 (B)

Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 & 2 LICENSE NOS. DPR-62 AND DPR-71 DOCKET NOS. 50-324 AND 50-325 SUPPLEMENTAL RESPONSE TO IE INSPECTION REPORT 79-02

Dear Mr. O'Reilly:

Deficicacy B cf the subject IE Report stated:

B. 10CFR50, Appendix B, Criterion XIV, states in part:

" Measures shall be established to indicate, by the use of markings such as... labels...the status of inspections and tests performed upon individual items of the nuclear power plant..." The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 6.5.2, states in part: "...Where practical, the calibration status shall be indicated on stickers or tags attached to or accompanying the equipment..."

Contrary to the above, as of January 16, 1979, measures had not been established to indicate the status of calibration performed on individual items in that, except for instruments designated "M&TE", there were no stickers on installed plant safety-related instruments.

Carolina Power & Light Company's response to this item stated:

Resolution to this deficiency will be made as follows:

1. A review of safety-related systems shall be made to determine which instruments serve a safety f unction s

' other than solely being pressure retaining. This list

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shall be developed by June 1, 1979.

2. These instruments shall be included in the plan: cali-bration program as required by Section 6 Calibration Control, of the Corporate Quality Assurance Manual.

This action will be implemented by December 31. 1979.

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  1. Mr. James P. O'Reilly April 20, 1979
3. As these inctruments are identified or calibrated, status etickers/ tags shall be attached to or accompany the instrument. This action will be co=pleted by December 31, 1979.

Additional review of the requirements of 10CFR50, Appendix B, Criterion XIV, and those ANSI Standards written to provide acceptable methods to implement this criteria has revealed the following information:

. 1DCFR50, Appendix B, Criterion XIV, allows the use of methods other than stickers or tags to indicate inspection, test, or check status.

ANSI N45.2.4-1972, " Installation, Inspection, and Testing Requirements for Instrumentation and Electrical Equipment During the Construction of Nuclear Power Generating Stations",

requires in paragraphs 2.5.2, " Calibration & Control", and

6. 2.1, " Equipment Test", items / equip =ent to be tagged or labeled.

ANSI N45.2.4-1972 is endorsed by Safety (Regulatory) Guide 30, 8/11/72, for the operational phase of a nucleat power generating station.

ANSI N45.2-1971/1977, "QA Program Requirements for Nuclear Power Plants", paragraph 15, allows the use of statun indicators other than tags or stickers.

ANSI N45.2.8, Draf t 3, Revision 3,* " Supplementary QA Require-ments for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," to which CP&L has committed to for the operations phase, paragraph 2.8.2, " Calibration and Control", requires marking of equipment.

It is evident that inconsistency between the requirements of 10CFR50, Appendix B, and the ANSI Standards exists. Based upon this review, CP&L viskes to change the response to this deficiency, which is restated as follows:

1. A review of safety-related systems shall be made to determine which instruments serve a safety function other than solely being pressure retaining. This list shall be developed by June 17 1979.
2. Theseinstrumentssballbeincludedintheplantcalibratior

' ; j ,i ,' program as required by Section 6. Calibration Control, of the Corporate Quality Assurance Manual. This action vill be implemented by gecember 31, 1979.

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' April 20, 1979 Nk. James P. O'Reilly .

3. An exception will be requested prior to April 30, 1979 relative to the ANSI N45.2.4 and N45.2.8 require =ents of placing status indicators on the equip =ent. CP&L will propose the following alternative:

. Portable items of M&TE shall have status indicators attached to or accompanying the equipment. These indicators shall require the recording of date of calibration, date of recalibration, and person per-forcing calibratio-.

. Permanently installed safety-related instru=entation shall be in a calibration program which requires a method of indicating calibration status, by means of stamps, tags, labels, routing cards, inspection records, or computer programs. This program shall have the capability to indicate the status of calibration and date calibration is due. Identity of individual per-forming calibration shall be made on the calibration data document.

4. Section 6, Calibration Control, of the Corporate QA Manual vill be revised to indicate the alternatives proposed above. This revision shall be made prior to May 15, 1979.
5. In the event that the exception is not granted, CP&L shall place stickers or tags on/ accompanying the instrumentation as required by ANSI N45.2.4 and N4.5.2.8, and Section 6 of the CP&L Corporate QA Manual.

It is believed that this restatement of our response provides a better alternative to the requirements.

Very truly yours, B. J. Furr Manager Generation Department k'JD: cp*

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