ML19345G964
| ML19345G964 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/03/1981 |
| From: | Furr B CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345G954 | List: |
| References | |
| NUDOCS 8104220915 | |
| Download: ML19345G964 (17) | |
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- FILE: NG-3513 (B)
SERIAL: NO-81-192 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 3100 Atlanta, GA 30303 Brunswick Steam Electric Plant, Unit Nos. I and 2 Docket Nos. 50-325 and 50-324 License Nos. DPR-71 and DPR-62 Response to Notice of Violations
Dear Mr. O'Reilly:
Attached you will find Carolina Power & Light Company's response to your letter of January 9, 1981, transmitting IE Inspection Report No. 50-325/80-42 and 50-324/80-39. Should you have any questions regarding this information, please contact my staff.
Yours very truly, f
. Furr Vice President Nuclear Operations Department DCS:p fb*
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VIOLATION A:
Environmental Technical Specification 5.4.1.1.a requires a semiannual report covering the previous six months' operation which includes a summary of the quantities of radioactive effluent released from the plant and potential doses, as outlined in the NRC Regulatory Guide 1.21.
Contrary to the above, the semiannual report covering the period January 1 to June 30, 1980, did not include the quantities or potential doses for radioactive effluent released from the plant on or about January 23, 1980; February 28, 1980; March 2, 1980; March 6, 1980; and March 13, 1980.
Carolina Power & Light Company's Response:
A thorough investigation was carried out regarding the purported auxiliary boiler releases subsequent to February 22, 1980, to determine if additional radiorctive releases to the atmosphere did in fact occur, and if they did what was the magnitude of those releases.
Five additional situations were identified where conditions existed which could have resulted in releases to the auxiliary boiler stack.
It was found, however, that sufficient information does not exist to estab1!.sh that any of these boiler leaks resulted in atmospheric releases of radioactive material to the unrestricted area. The only release for which there is independent radiological evidence confirming that a release of radioactive material to the unrestricted area occurred is for the release of February 22, 1980. Notwithstanding the lack of radiological evidence confirming that radioactive releases to the unrestricted area did occur, calculations have been made to quantify the maximum release that could reasonably be postulated to have occurred for each time period. Dose calculations associated with even these maximum calculated releases are a small fraction of 10CFR50, Appendix I, numerical guides for maintaining effluents as low as reasonably achievable, based on atmospheric conditions which existed at the time. Notwithstanding the improbability that releases of the magnitude which have been conservatively calculated occurred, the six-month effluent report for this period is being amended to describe these maximum theoretical releases.
This amendment will be submitted by March 1, 1981. A complete report of this investigation has been forwarded to NRC Region II in our correspondence to you dated January 22, 1981, Serial No. NO-81-119.
It has been determined upon further evaluation that no potential for release existed during the period of January 23, 1980, as stated in the violation.
Carolina Power & Light Company admits that the purported releases indicated in the statement of the violation were not included in the semiannual environmental. report.
The purported releases were not included because insufficient evidence exists as stated above to confirm that reportable releases in fact occurred.
It has been our practice to include any significant releases of radioactivity in the semiannual report and we will continue tc report any releases in this report as required.
VIOLATION B:
10CFR50, Appendix B, Criterion XVI requires that measures be established to assure that conditions adverse to quality such as failures, deficiencies, deviations, and nonconformancea are promptly identified and corrected. The accepted QA Program, FSAR Section 13.4.3.R.3, states that measures shall be established to follow up ou corrective actions to assure proper implementation and closeout.
Contrary to the above, measures had not been established nor had conditions adverse to uality been promptly corrected as of October 29, 1980, in that:
1.
Thirteen items identified by QA audits had exceeded established dates without completion of defined corrective action; eight items had no established corrective action that was satisfactory to resolve the identified problem; and three items had not received any response by the established due date. The above inadequacies represent 46 percent of the total number (52) of open items still outstanding as of this date.
2.
The controlling QA Procedure, QAP-2, On-site QA Surveillance, Revision 10, dated June 16, 1980, does not establish required measures because it does not specify the action to be taken when a response is not received and the required follow-up memorandum is ignored; nor does it specify the action to be taken when proposed corrective action is inadequate.
Carolina Power & Light Company's Response:
Carolina Power & Light Company admits that this violation occurred.
This event was created by procedural inadequacies and the lack of an adequate tracking program on outstanding items. To correct this problem, a new procedure has been written and is in effect which provides for better control of outstanding QA items.
This new controlling procedure, QAP-2a, provides an established system for handling an inadequate response or no response by notifying the assigned supervisor's manager of the response deficiency.
If an adequate response is still not obtained within the new time limit, the item is again escalated into an enforcement meeting of the assigned supervision with the plant QA supervision for resolution.
The plant General Manager is notified if this meeting does not resolve the deficiency. The Manager of Operations QA is responsible for ultimate resolution of the deficiency if further escalation is necessa ry.
Increased emphasis has been placed on the utilization, by the Plant QA organization, of a computer tracking system which had has been established to provide all Supervisors / Managers with a list of their outstanding items and when they are required to respond. This system will assist the QA subgroup in more easily identifying when a response is past due such that the escalation process can begin.
Full compliance on this item has been met.
VIOLATION C:
10CFR50, Appendix B, Criterion V and the accepted QA Program, FSAR Section 13.4.3.B.1, requires that activities affecting quality shall be prescribed and accomplished in accordance with documented procedures.
Procedure OQA-2, Conduct of Plant Surveillance Program, Revision 4, dated December 6, 1979, paragraph 4.3 requires that items discovered during the surveillance which require corrective action will be identified.
1.
Contrary to the above, Surveillance 0QAS-80-13 (B) was not accomplished in accordance with Procedure OQA-2 in that 27 plant QA items were identified as either lacking corrective action or lacking a known status; an Action Item was not written identifying a need for corrective action.
2.
Contrary to the above, 0QAS-80-14 (B) identified as a comment that several record books in use such as jumper log, administrative operating instructions, and annunciator status logbook contained obsolete portions of the Plant Operating Manual; an Action Item was not written identifying a need for corrective action.
3.
Contrary to the above, 0QAS-80-4 (B) identified as a comment several problems with Periodic Tests (pts) such as changes being made, signoffs being made without meeting acceptance criteria, equipment being used without being recorded, PT forms not being properly filled out, using pts of the wrong revision, and pts not being locatable; an Action Item was not written identifying a need for corrective action.
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Carolina Power & Light Company's Response:
Carolina Power & Light Company admits to the above violation. The Operations QA program and procedures were developed to function as an arm of the Vice President of the Nuclear Operations Department to perform in-depth surveillance at the operating nuclear plants.
The Procedure OQA-2 required that items discovered during the surveillance be identified, and as such OQA had identified the problems cited in the non-compliance.
It is recognized that failure to include comments in the " tracking" system and to control the " timeliness of corrective action" are the underlying reasons for this non-compliance.
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The items were identified as comments rather than " Actions Items" based upon the discussions held with site management; not to lower the significance of the items but to indicate to the responsible personnel that corrective action should be established on their part.
Identifying the items in OQAS-80-13 (B) as a separate item of
" timeliness of corrective action" was deemed unnecessary since the report indicated the status of each of the "open" action items.
In
addition, the report indicated that OQA was concerned relative to timeliness of corrective action.
Carolina Power & Light Company is currently reorganizing its QA organization into a single department and as such the off-site OQA Surveillance Unit will be dissolved and procedures OQA-2, " Conduct of Plant Surveillance Program" will be deleted. Until such time as the reorganization is completed and appropriate procedures developed, surveillance activities will be performed by the on-site QA staff and in accordance with their procedures. Their procedures require that findings be identified on a Surveillance Report Form which falls under a formalized tracking system.
In addition, the "open" action items which were identified and followed by the off-site OQA Surveillance Unit are also identified on the Plant Surveillance Report Forms and as such will be tracked and resolved in accordance with the on-site QA procedure (see response to item B above).
Operations QA Surveillance Procedure OQA-2 will be deleted by Februa ry 15, 1981.
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Violation D:
Technical Specification 6.5.4.1.c requires that results of actions taken to correct deficiencies occurring in methods of operation that affect nuclear safety shall be audited by the Operations and Maintenance Unit of the Corporate Nuclear Safety and Quality Assurance Audit i
Section at least once per six months.
l Contrary to the above, corrective action on plant quality assurance t
items have not been audited at least every six months in that only l
two audits (QA %-31-9 on 12/16/77 and QAA-21-13 on 11/9/79) have been l
conducted during the period from December, 1977, through October, 1980, covering the subject area.
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Carolina Power & Light Company Response:
The statement in the IE Report is incorrect or at best misleading.
The Technical Specification item cited in the report, 6.5.4.lc states:
"These audits shall encompass:... The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety at least once per 6 months."
Included in the broad Technical Specification requirement above are corrective actions iuentified and committed to in Licensee Event Reports, IE Reports, D'aA Surveillance Reports, CQA Audit Reports, CNS Reports of Concerns, and a myriad of other documents. A check of our audit plans and reports verifies that a sampling of these documents has been included in past audit reports sufficient to meet this requirement. The violation specifically states that items identified by Plant QA Surveillance Reports had not been audited every six months.
We believe singling out one nonspecified item of a potentially large list of items covered by the Technical Specification requirement is too prescriptive and, if extrapolated, would preclude audits from being performed on a sampling basis, changing traditional audit methods into constant continual surveillances.
Based on the above, we deny that this is a violation; however, we agree with the principle that plant surveillance items requiring corrective action are important enough to require audit every six months, and accordingly have changed our audit agenda / plan to require audit of plant QA corrective action activities every six months.
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VIOLATION E:
10CFR50, Appendix B, Criterion II requires that the QA Program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. The accepted QA Program, FSAR Section 13.4.3.D.7, states that QA program indoctrination and training of plant personnel will be conducted; and, as appropriate, qualifications will be achieved, maintained, and documented. Paragraph 2 states that personnel training will include personnel instruction in the performance and documentation of material inspections, process and test witnessing.
Such training will be conducted in a formal atmosphere.
Criterion V and Section 13.4.3.G.1 both require that activities be prescribed and accomplished in accordance with documented procedures and instructions.
Contrary to the above, suitable proficiency of persons performing activities affecting quality was not achieved and maintained in that:
1.
Procedure QAI-2, Training Requirements for BSEP QA Surveillance Personnel, had not been revised since September, 1975. As consequence, it referenced procedures for personnel training that no longer exist; and it did not cover over 25 standards and procedures that are part of the current QA controls.
2.
Procedure QAI-2 was not followed with respect to Section 3.c because personnel had not received the required oral checkout by the QA Supervisor following completion of the required training (readings).
3.
Documentation of training was not complete in that additional training that had been conducted according to the QA Supervisor had not been recorded.
4.
Proficiency was not maintained by the program in that over 95 percent of the documented training had been completed with initial employment in the QA/QC area. For the five technicians /
specialists in the QA/QC group, two were initially trained in i
1977 and three in 1978/1979.
5.
Formal training for test witnessing and process witnessing had not been completed in that all persons interviewed indicated that no formal training in assignment of QC hold points had been received.
Carolina Pow-
& Light Compan*'s Response:
Carolina Power & Light Company admits that this item occurred and was a result of administrative oversight. To ensure that the training program for the QA subgroup is satisfactorily maintained, the following actions have been or will be taken:
1.
Appropriate personnel have been counselled on not deviating from specific requirements of a procedure and on the necessity for maintaining procedures current.
2.
QAI-2 will be revised by February 15, 1981, to bring this procedure up to current standards. This revision will include the requirements for the documentation of all training, add current references, and delete obsolete references.
3.
A new procedure is being developed to establish the requirements necessary for maintaining the proficiency of the QA perso'tnel.
This procedure will be in effect by April 1, 1981.
4.
The criteria for establishing hold points will be addressed in a plant procedure by April 1, 1981; and by April 15, 1981, a formal training session on these criteria will be held by the QA subgroup.
5.
The plant QA organization has been strengthened by the addition of one Senior QA Specialist and two QA technician slots.
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I VIOLATION F:
10CFR50, Appendix B, Criterion VI, requires that measures be established to control issuance of documents that prescribe all activities affecting quality. The accepted QA Program FSAR Section 3.4.3.H.1, requires that measures shall be established to review documents prior to release to assure quality requirements are sufficiently, clearly, and accurately stated.
Contrary to the above, 20 documents were issued or revised without QA review.
Carolina Power & Light Company's Response:
Carolina Power & Light Company admits that this violation occurred.
This event occurred as a result of inadequate administrative control of one aspect of plant document revisions. Due to the high number of document revisions, manually maintaining current the master procedure index list, which defines what documents require QA approval, proved difficult. These administrative controls have been upgraded whereby the master list is now maintained on a computer program so that a current list can be immediately obtained to identify those procedures that require QA approval. Also, procedures that have been identified as requiring QA approval have had their cover sheets revised to require a signature showing that this approval has been obtained.
A 100 percent surveillance was performed by the QA Supervisor of past revisions, and those found not to have been reviewed were reviewed and documented. With the computer listing operable and the revised cover sheets in service, full compliance of this item has been met.
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Violation G:
Technical Specification 6.5.4.1.b requires that training and qualifications of the entire facility staff shall be audited by the Operations and Maintenance Unit of the Corporate Nuclear Safety and Quality Assurance Audit Section at least once per twelve months.
In a letter dated Februa ry 14, 1979, the licensee stated that the accepted QA Program would conform to ANSI N45.2.12-1977 (by committing to comply with Reguistory Guide 1.144 dated 1/79). ANSI N45.2.12-1977 states in part (Sections 4.3.2.2 and 3) that objective evidence shall be examined for compliance with quality assurance program requirements and that selected elements shall be audited to the depth necessary to determine whether or not they are being implemented effectively.
Contrary to the above, the qualifications and training of plant QA/QC personnel were not audited at least every twelve months by review of objective evidence to the depth necessay to determine effective implementation. The lack of QA/QC personnel training, as identified in item E of this Appendix, was not detected in either of the audits of this area conducted during the period from April, 1979, through October, 1980.
(QAA-21-9 of April 13, 1979, and QAA-21-14S of March 10-14, 1980).
Carolina Power & Light Company Response:
Carolina Power & Light Company admits that this violation occurred.
In order to audit the training records of over 400 people at BSEP, the annual audit of plant training has consisted of reviewing individual personnel training files.
It has been determined that to audit in the detail necessary to disclose some of the items specified in the IE Report, several hundred additional precedures would ha"e to be reviewed in detail annually at BSEP. This includes procedures that l
address training directly and procedures that require skills which l
must be provided for in the training process.
Audits will be conducted to cover all plant personnel for broad l
requirement and required certifications annually.
In order to audit to a greater depth, the O&M audit plan will be modified to selectively review in detail different areas of training during each audit.
Discrete areas, such as RC&T, QA, maintenance, etc., will be audited on a detailed sampling basis such that all areas are covered every two years.
In addition, proposals from outside consultants are being evaluated for an overall reactor operator training program assessment.
If undertaken, the results of such an assessment can be used to zero in on areas on a need priority basis.
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Violation H:
10CFR50, Appendix B, Criterion V and the accepted QA Program, FSAR Section 13.4.3.B.1, requires that activities affecting quality shall be prescribed and accomplished in accordance with documented procedures.
Corporate Quality Assurance Audits are conducted per QAAP-1, Procedure for Corporate and ASME QA Audits, Revision 10, dated May 14, 1980.
Paragraph 4.0 defines a finding as "A deficiency in characteristic, documentation or procedure which renders the quality of an item unacceptable or indeterminate..." and defines a concern as "...an isolated deviation which does not violate specific quality requirements..."
Contrary to the above, findings (nonconformances) were incorrectly identified as concerns in two audits: QAA/21-13, December 7, 1979, Concern 5 which states in part "...a master surveillance schedule has not been established as described in Section 5.2.8 of ANSI N18.7-1976 and Section A.2 of NRC Regulatory Guide 1.33-1972...;"
and QAA/21-14, April 4, 1980, Concern 3, which stater in part"...a commitment was made for the PNSC to review these QAP changes in the accepted QA Program by March 1, 1980. Contrary to this commitment to NRC, audit of the PNSC Meeting minutes indicate that the required reviews have not been made."
Carolina Power & Light Company Response:
This violation states that findings were incorrectly identified as concerns based on the CP&L definition of a finding in QA Audit procedure QAAP-1. During Audit QAA/21-13, the failure to develop a Master Surveillance Schedule, as defined by Section 5.2.8 of ANSI N18.7-1976 and Section A.2 of Regulatory Guide 1.33-1972, was identified as a concern. At the time of the audit, surveillance schedules of activities defined in the above references were produced by the plant staff, however, they had not been incorporated into a Master Schedule.
The auditors determined that the situation did not fall within the definition of a finding, i.e.,
to not render the quality of the item unacceptable; however. it was listed as a concern in that a Master Schedule was called for by the standard and would probably be easier to implement and maintain instead of several separate schedules.
Because the item was reported as a concern did not mean that it ended with the audit report as pointed out in the IE Report. Follow-up action was taken by the auditors to assure the item was corrected.
During Audit 21-15, it was discovered that a portion of the Master Surveillance required for in-service inspection had not been developed and this was reported as a finding. Based on the above arguments, CP&L denys that QAA/21-13 concern 5 not being designated a finding is a violation.
Carolina Power & Light Company admits that QAA/21-15 concern 3 should have been reported as c finding.
When it was found that the commitment date had been missed, the action commited to had been completed.
It was felt at the time that since the action had been completed that reporting the missed commitment date was punitive in nature and would not assure prompt corrective action in the future.
In the future, we will report all failures to meet NRC commitment dates as findings.
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Violation I:
Technical Specification 6.8.1 requires that procedures be implemented.
1.
Procedure ENP-3 Section 3.20, requires when a modification has been declared operational that responsible personnel revise applicable procedures. Modification 79-272, declared operational November 16, 1979, required four valves to be removed from the reactor recirculation system.
Contrary to the above, OP-2 valve lineup was not updated to reflect removal of these valves from the system.
2.
Procedure ENP-3, Section 3.20, requires when a modificaton has been declared operational all controlled drawings at the plant shall be stamped per the Drawing Notification Sheet.
Contrary to the above Drawings, FP-50554 (M-80-14), FP-9527-5757 (M-79-271), FP-50530 (M-79-164), FP-5992 (M-79-057) and LL 90046 sheets 15 an! 16 (M-80-04) were not stamped as required.
3.
Procedure EN'"3, Section 3.20, requires when a modification has been declarec operational that cognizant personnel (one of which is the Training Coordinator) be notified.
Contrary to the above, the Training Coordinator is not notified when modifications are made operational.
4.
Procedure RMI-3, Section 9.0, requires drawings to be stamped denoting modifications in effect.
Contrary to the above, Drawings LL-9364-88 (M-79-065) and LL-9252-30 (M-79-094) were not stamped to indicate modifications in effect.
5 Operating Manual, Volume 1, Administrative Procedures, Section 5.1 requires a period of time to be specified for usage of special procedures (SP).
Contrary to the above, SP-79-37, SP-33A-D, SP-79-38, SP-80-2 and SP-79-22 did not specify a period of time for usage.
Carolina Power & Light Company Response:
Carolina Power & Light Company admits to this violation.
1.
Previous operation under the plant modification procedure ENP-3 required that each specific subunit was responsible for reviewing 1
i plant modifications, making a determination as to how it affected the procedures they were responsible for, and then revising those procedures as required. Through a personnel oversight,
when OP-2 was revised to reflect the changes of this plant modificaton, four valves were omitted. These valves have been deleted from the procedure.
ENP-3 has been revised to require the engineer to include " proposed" revisions to all documents affected by a modification in the modification package. Each subunit will still have the final responsibility to verify that the engineer has included all required proposed revisions and to incorporate these revisions into the Plant Operating Manual.
This double review of plant modifications for necessary procedure changes should prevent any future events of this nature. Full compliance on this item has been set.
- 2. and 4.
While converting from the SEPIA system to the Aperture Card System for plant document storage, several drawings were not stamped as required.
Besides those drawings noted in the inspection, a thorough review of all other drawings was conducted and several more non-stamped drawings were found. All drawings have been stamped as required. Responsibility for revising and stamping of these drawings has also been reassigned to a higher technical position to help assure that the required review and stamping are performed. The administrative control for this item is considered adequate. Full compliance for this item has been met.
l 3.
Not informing the Training Coordinator that a plant modification has been declared operational is considered to be an administrative i
oversight. The Training Coordinator was being supplied with copies of all approved plant modifications so that they could revise any required training documents; hcwever, the system did not inform him when the modification was declared operational and therefore when to implement his procedure changes. Revisions 11 and 12 to ENP-3 now require that a copy of the operebility statement be routed to the Training Coordinator and also requires that the cognizant engineer follow-up with training to ensure that they have no problem updating their procedures with respect to the modification.
Full compliance to this item has been met.
5.
The required expiration date on the noted Special Procedures was found to be located on the procedure revisioa form in its historical file versus in the procedure itself. These procedures were revised to show the expiration date on the cover sheet for each test. Section 5.1 of the Administrative Procedures has been revised to require that each special procedure have no expiration date included on its cover sheet. Full compliance on this item has been met.
Violation J:
10CFR50, Appendix B, Criterion III requires that measures be established to assure applicable regulatory requirements are translated into specifications, drawings, procedures, and instructions. The accepted QA Program, FSAR Chapter 13.4.3.E.4, states that suitable design analysis, as appropriate, will be performed where applicable.
ANSI N45.2.ll-1974 as endorsed by the accepted QA Program, Section 4.2 requires design analysis to be performed.
Contrary to the above, measures have not been established to assure that design analyses will be provided on modifications performed by the plant staff.
Carolina Power & Light Company Response:
Carolina Power & Light Company admits to this violation.
Plant Engineering had been working under the philosophy that if the plant modification did not alter the original design analysis, then no further design analysis was required; however, this was not specifically spelled out in the plant modification procedure, ENP-3.
This procedure has been revised (Revision 12) to adequately define this philosophy and to provide specific guidance on when a design analysis is required. Full compliance has been achieved on this item.
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I Violation K:
Technical Specification 6.5.3.3.a requires that the Corporate Nuclear Safety Unit (CNSU) review the safety analysis of modifications in the facility as described in the FSAR.
Contrary to the above, the CNSU did not review the safety analysis for plant modification 79-57, which required an FSAR change.
i Carolina Power & Light Company Response:
This item is misleading both as written in the Notice of Violation and in the main body of the report. The facts are as follows: A modification to remove the CRD return line thermal sleeve on Unit 2 at BSEP was reviewed by CNS.
Knowing that a similar modification was planned for Unit 1, CNS personnel discussed it with plant personnel and determined that indeed the modification planned for Unit I was identical in all respects to the one performed on Unit 2.
Nevertheless, a memorandum was written from CNS to the plant requesting a review i
copy of the modification package since all modifications are required to be reviewed by CNS. At the time of the IE inspection, the memorandum request was old and the modification package had not been received.
Plant Engineering Procedure ENP-3 provides instructions on obtaining the required CNS review of plant modifications that revise the FSAR; however, it did not provide an adequate method or instructions to assure that documentation of this review was made a part of the modification package. ENP-3 has been revised (Revision 12) to include a sign-off verifying that a CNS review has been performed where required and that documentation of this review is contained in the modification package. Also, training classes on ENP-3 have recently been conducted with plant engineering personnel with emphasis placed on this required review. Full compliance has been achieved l
cn this item.
Although there is no time limit specified for CNS to review safety analyses of modifications, action on this item cannot be considered timely.
In the future safety analyses identified as requiring l
review but not received by CNS, will be pursued more aggressively until received.
It abould be pointed out however, which the IE Report failed to do, that since an identical safety analysis had been reviewed, no safety problem existed in the interim time period.
In addition, the IE Report failed to recognize that CNS had identified the missing package and had requested it from the plant.
The violation as written in the IE Report gives an impression that a safety issue was unreviewed; however, the circumstances described above, which the inspector was fully aware of, do not support the report inference.
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e Violation L:
i 10CFR50, Appendix B, Criterion XV requires that measures be established to control materials, parts, or components which do not conform to requirements in order to prevent their use. The accepted QA Program, FSAR Chapter 13.4.3.Q.1, requires that measures and procedures be established to control identification, documentation, segregation, review, disposition, and notification of the affected organization of nonconformance of material, parts, components, or services to prevent inadvertent use of operation. ANSI N45.2.2-1972 as committed to by the accepted QA Program, Section 5.3 requires a statement documenting authority and technical justification for conditional release of an item for installation.
Contrary to the above, measures have not been established to provide a statement documenting authority and technical justification for conditional release of an item for installation.
Parolina Power & Light Company Response:
Carolina Power & Light Company admits this violation. Due to an administrative oversight, plant procedures had not been established to provide a statement documenting authority and technical justification for the conditional release of an item for installation.
Conditional releases were being approved on a case by case basis by the QA Supervisor.
To correct this situation, Quality Assurance Procedure, QAP-20, has been revised (Revision 1) to incorporate the required measures for the handling of conditional releases in the plant. Full compliance has been achieved on this item.
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