ML20113E525
| ML20113E525 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/07/1985 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20113E476 | List: |
| References | |
| CON-NRC-331 NUDOCS 8504160495 | |
| Download: ML20113E525 (3) | |
Text
c CD&L
?rmewsm P. O. Box 101 New Hill, North Carolina 27562 March 7,1985 Dr.'3. Nelson Grace NRC-331 United States Nuclear Regulatory Commission int)
Region II
((/F 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323
Dear Dr. Grace:
In reference to your letter of February 7,.1985, referring to Ril: GFM/RLP 50-400/34-49-01, the attached is Carolina Power and Light Company's reply to the violation identified in.
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.
W R. M. Parsons Project General Manager Completion Assurance Shearon Harris Nuclear Power Plant RMP/sae Attachment cc:
Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC) 8504160495 850322 PDR ADOCK 05000400 0
PDR se9/1
4 Attachment to CP&L Letter of Response to NRC Report RII: GFM/RLP 50-400/84-49-01 Reported Violation:
10 CFR 50.55(f)(1) requires CP&L to implement the Quality Assurance Program described or referenced in the Preliminary Safety Analysis Report. Section 1.8.5.15 of the PSAR (versus the Quality Assurance Program, as stated in the Notice of Violation) requires that measures be established and implemented to assure that nonconforming conditions are properly identified, documented, and receive the correct evaluation and disposition.
Contrary to the above, on December 26, 1984, the inspector observed craf t personnel performing repairs to soldered connections in the safeguards test cabinets.
An investigation of the work activities revealed that this rework was to correct vendor deficiencies under the direction of site Westinghouse personnel. These deficiencies had not been documented with a nonconformance report. The failure to properly document these deficiencies could have prevented their evaluation for reportability under the requirements of 10 CFR 21, and 10 CFR 50.55(e). Af ter identification of these items to the licensee, NCR 84-2516 was written by the licensee to document this item.
This is a Severity Level V violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
The inspector did not properly interpret Procedure CQA-3, Nonconformance Control. As a result, he felt that the use of a subordinate nonconformance document was acceptable for this situation.
Corrective Steps Taken and Results Achieved:
A)
NCR 84-2516 was initiated on December 27, 1984, to properly document the condition in question that had been previously identified on a subordinate nonconformance document. This NCR was determined to be not reportable per Procedure CQA-3.
B)
A review in the CI cable pull group has shown that for some specific requirements, there have been nonconforming conditions documented on a subordinate nonconformance document, which should have been documented on an NCR. These nonconforming conditions have been resolved in accordance with site work procedures and inspection procedures, therefore, the quality attributes of these items are assured of being acceptable.
An evaluation of these nonconforming conditions has determined that they were not reportable per 10 CFR 50.55(e) and 10 CFR, Part 21,' based on Procedure CQA-3. Therefore, no further action is needed for these items. Review of discussions with inspectors, and lead inspectors from other CI Electrical groups indicated that there are no other known instances of improper use of subordinate nonconformance reports. To support this, a sample size of fif ty items was chosen in each group of the Electrical CI Section. A review se9/3
a w=
1 Corrective Steps Taken and Results Achieved:(cont'd) of these items (a total of 250) produced four items, which should have been documented on an NCR. The four items were determined to be not reportable per Procedure CQA-3. On two of the items, the conditions were resolved through the inspection report, therefore, no further action is needed. The other two items remained as unresolved items identified on open inspection reports, therefore, NCR's 85-0353 and 85-0566 were written to ;roperly document, and track these conditions.
Based upon the sampling results, the dispositions of the items, and the fact that the nonconforming conditions noted were not reportable, no further action is considered necessary.
Corrective Steps Taken to Avoid Further Noncompliance:
Electrical construction inspection personnel have been retrained in the requirements for correct usage of subordinate nonconformance documents, and nonconformance reports in accordance wth CQA-3.
Date When Full Compliance Was Achieved:
Full compliance-was achieved on March 7,1985.
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