ML19346A115

Responds to NRC 810320 Ltr Re Violations Noted in IE Insp Repts 50-518/81-04,50-519/81-04,50-520/81-04 & 50-521/81-04. Corrective Actions:Qcirs Will Be Reviewed & Upgraded as Required & Audit Will Be Conducted by QA Unit

ML19346A115
Person / Time
Site:	Hartsville
Issue date:	05/15/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19346A114	List: ML19346A115 ML19346A116
References
NUDOCS 8106050118
Download: ML19346A115 (3)

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400 Chestnut Street Tower II

! I'O.Y 2(l E? . 40 May 15, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

On April 17, 1981, TVA submitted the response to parts A and B of Inspection Report Nos. 50-518/81-04, -519/81-04, -520/81-04, and

-521/81-04 regarding activities at our Hartsville Nuclear Plant which appeared to have been in violation of NRC regulations. Enclosed is our response to part C of the subject report. As discussed with F. S. Cantrell of your staff on May 5,1981, TVA was granted an eight-day extension on the submittal date of this response. An additional three-day extension was granted by P. A. Taylor of your staff en May 13, 1981.

If you have any questions, please call Jim Domer at FTS 857-2014.

To the best of my knowledge, I declare the statements contained -

herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY

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L. M. Mills, Manager Nuclear Regulation and Safety Enclosure 8106050ll$

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. ENCLOSURE HARTSVILLE NUCLEAR PLANT' RESPONSE TO Nh? - OIE LETTER FROM ER. C. LEWIS TO H. C. PAh3IS DATED MARCH 20, 1981 This report responds to part C of the Nodice' of: Violation described _in Appendix A of the-0IE inspection report referenced above. This is our final report on' this item of noncompliance.

Noncompliance Item - Severity Level V Violation 518-521/81-04-02

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10CFR50, Appendix B, Criterien V as implemented by PSAR Section -17.1 A.5 requires that activitiesfaffecting quality shall be-accomplished'in.

accordance with documented procedures. ~TVA Construction Engineering Procedure No.-16.03 defines which conditions adverse.to quality can be

' handled as,a QCIR'and which conditions must be handled as an NCR report with appropriate management-review.

Contrary to the above, requirements for handling of conditions adverse to .

-quality were not being adhered to in that on March 6, 1981, there were a number of' completed-QCIR's in--the records 1 vault ~that described conditions

, which should have been escalated to nonconforming report status to obtaln-

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appropriate management attention.

This is a Severity Level V Violation (Supplement II.E).

Response

1. Admission or Denial of-the Alleged Violation-TVA admits the violation occurred as stated.

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2. The Reasons for the Violation

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The reason for the violation was due to a difference in interpretation of -the procedures for upgrading QCIR's to NCR's between the NRC inspector and site personnel. The review of QCIR's for technical adequacy and upgrading to NCR status was being i

accomplished by an assistant construction engineer based on the CONST Jnterpretation of the procedures in effect at the time of.the NRC inspector's visit.

. 3 Corrective Steps Taken and Results Achieved We will review the QCIR's which were identified in the inspection report and upgrade those that require upgrading in light _of~our_

revised procedures.

In addition, an audit will be conducted by the HTN site QA Unit to i

verify compliance by site personnel with above procedures. It will include a representative sample of previously issued QCIR's.

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4 Correctiva Steps Teksn to Avoid Further 'Noncompli*nca As a result of this violation, audit. findings,-and general confusion on the part of many personnel relative to upgrading.of QCIR's.to NCR's, ._ the following actions have been taken:

The OEDC Program fequ,irements Manual-has been revised and the Division of Construction- QA ' Procedures -hava been revised txi clarify-and state when QCIR's are to be upgraded to an NCR.

Repetitive or generic conditionsLare identified by the' management personnel who review and approve the disposition of QCIR's. When a-candition adverse to quality is determined:to be generic,.an NCR'is.

generated. Repetitive conditions are considered commensurate to their quality implications and,' if deemed -necessary, .an NCR ,is generated.

Relative to the prasence of the designer's (i.e., C. F. Braun's)

' signature on the QCIR's.which were observed by the NRC. inspectors,.

we will discontinue the' practice of: having C. F. Braun's and/or EN-DES personnel's signature on QCIR's where the QCIR is'shown to or discussed-with C. F. Braun or EN DES' personnel for.information or

-informal advice.

5 Date When Full Compliance Will Be Achieved HTN will be in full compliance.on August 1, 1981'.

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