ML19346A115
| 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: |
| References | |
| NUDOCS 8106050118 | |
| Download: ML19346A115 (3) | |
Text
'
- ~ ' ~ ~ ~
~
400 Chestnut Street Tower II E?. 40
! I'O.Y 2(l 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
'l
[
L. M. Mills, Manager Nuclear Regulation and Safety Enclosure 8106050ll$
6
t
~
h
. 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
~
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-
~
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.
2.
The Reasons for the Violation
~
~
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 verify compliance by site personnel with above procedures.
It will i
include a representative sample of previously issued QCIR's.
)
_, 4
~
- y 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'.
I e
1
,w
-