ML20112C249

Intervenor Exhibit I-JOINT-4,consisting of 830902 Response to NRC Re Violations Noted in Insp Repts 50-400/83-22 & 50-401/83-22.Corrective Actions:Approx 150 Deficiency & Deposition Repts Reviewed for Closure

ML20112C249
Person / Time
Site:	Harris, 05000001
Issue date:	09/05/1984
From:	Parsons R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
CON-NRC-111 OL-I-JOINT-004, OL-I-JOINT-4, NUDOCS 8501110102
Download: ML20112C249 (5)

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P. O. Box 101, New Hill, N. C. 27562 ~ ~3 @, ~

C September 2, 1983 ,- 3

'85 s' -s P3 :27 Mr. James P. O'Reilly vpn NRC-Ill _.

United States Nuclear Regulatory Commission 00C 6~.7i c, i $g -

Region 11 ' U. C "

101 Marietta Street, Northwest (Suite 2900) f Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of August 3,1983, referring to RII: GFM/RLP 50-400/33-22-02, the attached is Carolina Power und 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,

?;V} W R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attaenment .

cc: Messrs. G. Maxwell /R. Prevatte (N RC-SHNPP) j Mr. B. C. Buckley (NRC)

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-Attachment to CP&L Letter of Response to NRC Report RII: GF5i/RLP 50-4 REPORTED VIOLATION:

Section 6.2.5, requires that Deficiency Reports, am and De Nonconformance Reports be controded in accordance with procedural require .

Contrary to the above, on June 29, 1983, an inspection revealed that nonc nce '

reports are not being documented and processed in accordance with .

applicable NPCD portions. Response to each is providedandunder ea QA/QC Violations (as referenced in reoorth

- 1.

DDR's and NCR's were observed. Multiple instances of unauthorized initiated, reviewed, dispositioned, One instance was noted in which a DDR was inspector. reinspected and accepted by the same QC

-2.-

Site QA failed to review all DR's for acceptance of disposition, and to revi the reportability requirements of Part 21 and 10CFR50.55(e).

3.

which is four days; this is a result of inspection per DDR tracking numbers.

• _ Construction Insoection Violation (as referenced in recorth

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Atultiple were instances observed. of unauthorized personnel signing dispositions acceptance

_ DENIAL OR ADallSSION AND ItEASON FOR T32 VIOLATION:

9A/QC Violations:

1.

The violation is correct as stated. The lead technician referenced was des fulfill the technical duties of the QA/QC Specialist in his absence.

Since the technician --had been designated, he assumed it .was acceptable e' ' to sign fo Specialist to expedite processing of DDR's and NCR's. Review of appro closed DDR's indicate that other lead technicians have made similar assum

. 2.

. The violation is correct as stated. QA personnel had reviewed DR's f and dates) was not shown to indicate a QA Specialist's revie .

3.-

The violation.is correct as stated.

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DDR's and NCR's' were being initially reviewed by Supervisors to determine if a nonconformance actually existed before a was assigned.

scrutinized .DDR's 1684 and 1635 listed in the NRC^ report (as examples) w to verify that ~ nonconformances existed - and to ensure that' the been issued when, in fact, no nonconformance existed stated in the report._ To prevent this, the supervisors were instructed to revie d.,a _ _ _ _mi__

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1' DDR's and NCR's to the extent necessary to minimize the number ot invalid j- nonconformance reports entering the system. In performing these : eviews,

(. supervisors, on a few occasions, failed to comply with the procedure in respect to timely issue of nonconformance reports.

Construction Insoection Violation:

1.

The . violation is correct as stated with clarification. The details of the.NRC Inspector's report cited " unauthorized personnel signing disposition acceptance on

...'.... DR's." -For the DR's in question, the corrective action and resolution details (response) were not signed by the designated authority (Principal Discipline Engineer). The -resolution verification and acceptance (" disposition acceptance")

sign-offs were by authorized Construction Inspection personnel.

The DR responses were developed by the " unauthorized personnel" and submitted t

directly to Construction Inspection. The close-out review failed to detect that the DR response did not include the sign-off of the Principa1' Discipline Engineer.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

.QA/QC Violations:

1.

Approximately 150 closed DDR's have been reviewed by the Superintendent - QC for

_ deficiencies and acceptable issue and closure by the QA/QC Specialist. The review revealed 12 DDR's that had been either issued or closed by someone designated to sign for the QA/QC Specialist. In the 12 cases noted, the DDR had been reviewed by

. the QC Supervisor or the Superintendent - QC for technical adequacy prior to issue.

All closed DDR's and NCR's will be reviewed to determine those closed without the review of corrective action by the proper level of QA/QC supervision. In any e.ise.

where the corrective action is tound not to be acceptacle as determined by QA/QC Supervisors, the item will be. reopened with the issue of a new NCR or JDR. as acorocriate. All open DDR's and NCR's issued without review oy the croper level df QA/QC supervision will be reviewed by the QA!QC Supervisor or the QA.MC Specialist to ensure correctness. Any errors vill be -correcad and tne

. nonconformance reissued. The " blanket" memorandums designating Lead

. Technicians authorized to sign for the QA/QC Specialist have been rescinded. New memorandums designating technicians to perform technical responsibilities assigned to QA/QC Specialists have been issued.

the issuing and closing of none'onformances.These memorandums specifically exclude 2.

All open DR's have been re-reviewed by the appropriate QA Specialists. These

' reviews have been documented on the DR's with their respective initials and dates.

l Additionally, . closed DR's on' file in the QA Records vault received a technical review by QA personnel prior to filing.

During this re-review, no conditions were encountered necessitating upgrading of-t.he DR's to DDR's.

3.

L!mmediate (July 1,1983) training was held by the Director - QA/QC for all Unit

' supervisory personnel on review and issue of ODR's.

A memorandum was !ssued to all Unit Supervisors on July 1,1980 as a follow-up to the training session. Specifics of the training and memo were as follows: -

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. 3 a.

After completing the draft of a nonconformance obtain a DDR number either through his supervision, an inspector is the individual responsible for the DDR Log . or by oirect contact with b.

The inspector supervisor for review,is to sign and date the DDR wh

c. en he turns it over to his The supervisor is responsible for a timely and thor for evaluation. ensure accuracy and completeness prior to issue and warding to engineering -

d.

Paragraph 6.5 in Procedure CQC-2, Nonconforman without exception. Additionally, if during review thece Control, is to changed significantly, the changes are to be reviewednonconform ensure he understands the rationale for the .

withchanges the inspector to C_onstruction Insnection Violation: _

. I.

In the case of the DR's, no reworking of the necessary to approved due to the resolution details being found satisfclosed-out repo specifications. project specifications or to actory to restore the items meet cognizant Principal Discipline Engineers to the and otherIn additio standard distribution. ransmitted to the management personnel through CORRECTIVE STEPS TAKEN COMPLIANCE:

9A/QC Violations:

TO AVOID FURTHER NON.

1.

QA/QC technicians are no longer authorized to sign for issue and NCR's.

In the absence of the QA/QC specialistand closure of DDWs 2.

escalated to the QA/QC supervisor.for issue .

and closc-out

. the nonconformance is individual reviews the DR's. Flow of DR's within QA

3.

maintained on file in the QA Af office.

ter QA review, copies of tne apen DWs 'are Procedure CQC-2 clarify the.respons,ibilities for reviewevised training session' and memorandum by the Di andtoissue further of noncon ormance reports. The

- and the timely issue of DDR's. eliminate any misunderstandings r ors obtaining DDR numbers

- C nstruction insoection Violation: _

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,, The Principal Discipline Engineer in 2

.in the requirements for DR response;uestion sign-off. has instructed the discipline pe Supervisor has issued a memo of instruction existing n to remi dThe Construction In Engineer. procedures invoke ' DR response sign-off by thethe inspection personn Principal Discipline

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DATE WilEN FULL COMPLIANCE WILL.BE ACHIEVED:

'QA/QC Violations:

1. .

Review of DDR's and NCR's processed prior to this report will be completed by September 30,1983.

2. - DR review and/or evaluation is anticipated to be complete by November 4,1983.

3. Full compliance was achieved on July 1,1983.

' Construction Insoection Violation:

1. ' Full compliance was achieved on August 23 1983 D

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