ML20113E528
| ML20113E528 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/06/1985 |
| 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-328 NUDOCS 8504160500 | |
| Download: ML20113E528 (2) | |
Text
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. v Cp&L Carolina Power & Light Company 85 MAR 11 P S *oMx 101 New Hill, North Carolina 27562
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March 6,1985 Dr. 3. Nelson Grace h
NRC-328 0
United States Nuclear Regulatory Commission Region II m'$
101 Marietta Street, Northwest (Suite 2900)
U Atlanta, Georgia 30323
Dear Dr. Grace:
In reference to your letter of February 7,1985, referring to RII: GFM/RLP 50-400/84-49-03, 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, y
- ?
- #
R. M. Parsons Project General Manager Completion Assurance Shearon Harris Nuc' ear Power Plant RMP/bs d
A ttachment cc:
Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC) 8504160500 850322
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PDR ADOCK 05000400 G
PDR se7/1
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Attachment to CP&L Letter of Response to NRC Report RII: GFM/RLP 50-400/84-49-03 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 nonconforming conditions be identified and documented in accordance with prescribed procedural requirements.
Contrary to the above, a review of recent operations QA surveillance reports indicate that at least five nonconforming conditions contained in the reports should have been identified and documented as nonconformances (NCRs) in accordance with the applicable site procedure (CQA-3). Af ter notification by the resident inspector, the licensee required a review of all outstanding QA surveillance reports. NCRs have been written to document these nonconforming conditions.
This is a Severity Level V violation (Supplement I).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
Misinterpretation of the interfacing requirements of CQA-23 (QA Surveillance) and CQA-3 (Nonconformance Control), as how to report an insignificant nonconformance (concern) identified during surveillance activities, was the cause of the violation.
Corrective Steps Taken and Results Achieved:
Start-up QA Surveillance Reports with open concerns were reviewed for upgrading to NCRs. As a result, fourteen (14) NCRs were issued.
Corrective Steps Taken to Avoid Further Noncompliance:
CQA-3 has been revised to specifically recognize the " Surveillance Report" as a subordinate nonconformance document for reporting " Concerns", and to state the action to be taken if timely responses are not submitted by the responsible organization.
CQA-23 has been revised to clarify when to write an NCR versus a concern.
A training class was held on February 3,1985, for the Start-up QA Subunit personnel. This class emphasized compliance with CQA-3, when determining if identified conditions should be documented as an NCR or concern.
Date When Full Compliance Was Achieved:
Full compliance was achieved on February 27,1985.
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