ML20214L392

Responds to Violations Noted in Insp Rept 50-261/86-26. Corrective Actions:Changes to 1985 Facility Summary Rept Prepared & Submitted to NRC on 860926 & Personnel Responsible for Submittal of Rept Counseled

ML20214L392
Person / Time
Site:	Robinson
Issue date:	11/18/1986
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
RNPD-86-5323, NUDOCS 8612030055
Download: ML20214L392 (2)

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AB. 08 ROBINSON NUCLEAR PROJECT DEPARTMENT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 NOV181986 Robinson File No:

13510E Serial: RNPD/86-5323 Dr. J. N. Grace Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30323 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 INSPECTION REPORT 86-26

Dear Dr. Grace:

Carolina Power and Light Company (CP&L) provides this response to the alleged violation discussed in the USNRC Inspection Report 86-26.

Alleged Severity Level V Violation (RII-86-26-01-SL5) 10CFR50, Appendix B, Criterion V, as implemented by Section 6 of the CP&L Corporate QA Manual, requires that activities affecting quality be accomplished in accordance with documented instructions, procedures, or drawings.

10CFR50.59(b) requires the licensee to furnish to the NRC a summary of the licensee's safety evaluation of licensee changes accomplished pursuant to 10CFR50.59. Licensee procedure AP-030 requires the submittal of an annual report in July describing changes, tests, and experiments conducted in the previous year without prior NRC approval.

Contrary to the above, activities affecting quality were not accomplished in accordance with AP-030, in that the licensee failed to submit to the Region II office a brief description of the 1985 facility changes, tests and experiments, and a summary of the safety evaluation of each.

RESPONSE

1.

Admission or Denial of the Alleged Violation CP&L acknowledges the violation.

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Ictt:r to J.-N. Cr:c3 S;rict: RNPD/86-5323 Page 2 2.

Reason for the Violation if Admitted AP-030, Revision 3, NRC REPORTING REQUIREMENTS, Paragraph 5.7 requires Regulatory Compliance personnel to prepare an annual summary report for submission to the NRC Region II office in July of each year describing changes, tests, and experiments affecting the facility pursuant to 10CFR50.59. This summary report is prepared in conjunction with the annual FSAR Update Amendment submitted to the NRC by the Corporate Licensing Staff.

In the summer of 1986, Regulatory Compliance staffing changes and a resultant misunderstanding delayed submittal of the 1985 Changes to the-Facility Summary Report. It was believed that the FSAR Update satisfied the requirement.

3.

Corrective Steps Which Have Been Taken and Results Achieved Upon discovery of the oversight, the 1985 Changes to the Facility Summary Report was prepared and submitted to the NRC Region II on September 26, 1986.

Regulatory Compliance personnel have reviewed the event and discussed it with the Corporate Licensing Staff. The responsibility for submittal of the summary report is clearly understood.

4.

Corrective Steps Which Will Be Taken to Prevent Repetition of the Violation Discussed in 3. above.

5.

Date When Full Compliance Will Be Achieved Completed.

If you have any questions concerning this response, please contact Mr. J. M. Curley, telephone (803) 383-4524.

Very truly yours, R. E. Morgan General Manager H. B. Robinson S. E. Plant i

DAS:

cc Document Control Desk H. E. P. Krug R. E. Morgan R. W. Prunty H. J. Young