ML20054G938

Reponds to NRC Re Violations Noted in IE Insp Repts 50-400/82-07 & 50-401/82-07.Corrective Actions: Concrete,Protective Coating Reinforcing Steel & Mechanical Equipment Installation Will Be Audited During 820524-28

ML20054G938
Person / Time
Site:	Harris
Issue date:	05/19/1982
From:	Banks H CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054G931	List: IR 05000400/1982007 ML20054G930 ML20054G938 ML20054G941 ML20054G945
References
NUDOCS 8206220426
Download: ML20054G938 (2)

Text

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,?- l CD&L Carolina Power & Light Coto RC REGION .'I o o.,

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May 19, 1982 g g A g. Q3 Mr. James P. O'Reilly United States Nuclear Regulatory Commission "' '

Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 .

Dear Mr. O'Reilly:

In reference to your letter of April 19, 1982, referring to RII:

RW 50-400/401/82-07, the attached is Carolina Power & Light Company's reply to the deficiencies identified in Appendix A.

It is considered that the corrective and preventive actions taken will be satisfactory for resolution of the item, once completed.

Thank you for your consideration in this matter.

Yours very truly,

,;/ /,p/

yL / L H. R. Banks Manager Corporate Quality Assurance NJC:jp Attachment cc: Mr. J.. A. Jones i

8206220426 820608 PDR ADOCK 05000400 0 PDR 411 Fayetteville Street

• P. O. Box 1551

• Raleigh. N C. 27602 ,

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Srvarity Ltval IV Violction 10 CFR 50, Appendix B, Criterion XVIII and the accepted QA program in the PSAR Section 1.8 require a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program. CP&L is committed to Regulatory Guide 1.144. Paragraph 3.a(2) of the subject guide requires the licensee to audit internal design and construction phase activities annually or at least once within the life of the activity, whichever is shorter.

Contrary to the above, examination of audits conducted by the Corporate Performance Evaluation Unit during calendar year 1981 revealed that no audits were performed for' concrete or protective coating activities, reinforcing steel controls, or for mechanical equipment installation activities although such activities were in progress at that time. .

Denial of Admission and Reason for Violation (1) Carolina Power & Light Company admits that the following activities were not audited in 1981: concrete, protective coating, reinforcing steel, and mechanical equipment ins ta lla tion. These activities wer~e in progress during 1981. Although these activities were not audited by the audit group, the activities were covered by surveillance / monitoring by the site QA/QC Unit. These activities were not considered to be out of control at anytime.

(2) In 1980, two Quality Assurance Audit Units were involved in the audit program at SHNPP. One of the units was responsible for ASME audits; the other unit was responsible for the other audits required by the Corporate QA Program. In 1981, the responsibility for planning and scheduling all of the SENPP site audits was delegated to one person. During the transition period when two accountability systems were being consolidated into one system, Performance Evaluation failed to determine that audits of the activities identified above were required in 1981.

Corrective Steps Taken and Results Achieved Audits performed in 1980 & 1981 are being reviewed to determine if other activities were not audited as required. If any others are found they will be included in the future audit schedule. Concrete, protective coating reinf orcing steel, and mechanical equipment installation will be audited during the week of May 24-28, 1982.

Corrective Steps Taken to Avoid Further Noncompliance Planning and scheduling SHNPP site audits has been delegated to the same Senior QA Specialist responsible for all of the audits; engineering, construction, and quality assurance; performed at the site. Failure to audit activities as required has been discussed with the Specialist now responsible for the site audit prograa. The necessity of giving suf ficient attention to planning and scheduling of audits to insure that they are performed as required was emphasized to the Specialist.

Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 30, 1982.

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