ML20081H659
| ML20081H659 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/21/1983 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20081H506 | List: |
| References | |
| CON-NRC-131 NUDOCS 8311070544 | |
| Download: ML20081H659 (2) | |
Text
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Cp&L Carolina Power & Light Company m:www
,==xx*gx::a P. O. Box 101, New Hill, N. C. 27562 October 21, 1983 Mr. James P. O'Reilly NRC-131 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of September 22,1983, referring to RII: GFM/RLP 50-400/83-26-02, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.
It is considered that the corrective action taken is satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly,
- ll>yf
= ' :=M R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachments cc:
Messrs. G. Maxwell /R. Prevatte (NRC-SIINPP)
Mr. B. C. Buckley (NRC) 8311070544 831031 gDRADOCh 05000400 PDR
Attachment to CP&L Letter of Response to NRC Report RII: GFM/RLP 50-400/83-26-02 Reported Violation:
10 CFR 50, Appendix B, Criterion V, as implemented by CP&L PSAR Section 1.8.5.5 and CP&L Corporate QA Program Section 6.2.5, requires that activities affecting quality be accomplished in accordance with procedural requirements.
Contrary to the above, on August 2,1983, three conditions were found in which nonconformance reports had not been written to document instances which had Field Change Requests exceeding 60 days without having received design approval.
Construction Procedure AP-IX-04, Revision 12, Deviation 3, allowed work to be done without design approval for the fabrication and installation of instrumentation tubing supports. However, the procedure required that if approval had not been attained within 60 days, a nonconformance report was to be written.
This is a Severity Level V Violation (Supplement II.E).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
Although requirements existed to issue a nonconformance report within 60 days if approval of the FCR/PW has not been accepted, existing procedures did not provide adequate procedural interfaces to ensure implementation.
Corrective Steps Taken and Results Achieved:
DDR's 1828,1829, and 1830 were issued respectively on subject RCI's -AS-480, -483, and -
484, as required by AP-IX-04.
Corrective Steps Taken to Avoid Further Noncompliance:
Weaknesses in the RCI Program had been identified by CP&L during CP&L's Internal Pre-CAT Assessment, finding Item No. Three (3) and previous site QA/QC DDR No.1348. As a result of the CP&L identified weaknesses, an action plan was developed to:
1.
Terminate issuance of RCI's. (Complete) 2.
Void RCI Procedure AP-IX-04. (Scheduled for November 1,1983, pending completion of No. 5 below.)
3.
Review existing RCI's and provide design information in the appropriate design documents. (Complete) 4.
Expedite completion of outstanding RCI's/PW's. (Complete) 5.
Revise existing procedures which invoke RCI's as source documents for quality affecting activities. (Completion by November 1,1983.)
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved on November 1,1983.
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