ML20214L629
| ML20214L629 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/07/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-467 NUDOCS 8609100302 | |
| Download: ML20214L629 (3) | |
Text
Deb q\\
v Cp&L ca' ""* " " ' '.'9"'_c@@ U M. 5 2 HARRIS NUCLEAR PROJECT P.O. Box 101 New Hill, North Carolina 27562 AUG7 h6 A
File Number:
SHF/10-13510E Letter Number: HO-860326 (0)
Dr. J. Nelson Grace NRC-467 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323
Dear Dr. Grace:
In reference to your letter of July 9, 1986, referring to RII:
50-400/86-46, the attached is Carolina Power & Light Company's reply to the deviation identified in Enclosure 1.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, 74Lh W
[ Vice President R. A. Watson Harris Nuclear Project JLW/sae Attachment cc: Messrs. C. Maxwell (NRC-SHNPP)
B. C. Buckley (NRC)
\\\\
8609100302 860807 PDR ADOCK 05000400
,hd G
PDR MEM/HC-8603260/ PACE 1/0S1
a
}
Q V
Attachment to CP&L Letter of Response to NRC Report RII:
50-400/86-46 Reported Deviation:
FSAR Chapter 17.2.2.1, Quality Assurance Program During the Operations Phase, states that the CP&L Corporate Quality Assurance (CQA) Program for Operations will be implemented at least 90 days prior to fuel load. The licensee's fuel load date at the time of the inspection was July 25, 1986, within 90 days.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, as implemented by the CQA Program and FSAR Chapter 17.2.5, require that activities affecting quality shall be prescribed and accomplished in accordance with documented instructions and procedures. FSAR Chapter 1.8 commits CP&L to Regulatory Guide 1.33, Rev. 2, 1978, which endorses ANSI N18.7-1976.
Section 5.2.4, Special Orders, of ANSI N13.7-1976, requires that a mechanism shall be provided for issuing management instructions which have short-term applicability. Shift Notes, OMM-009, Revision 1, implement the ANSI N18.7-1976 requirement.
1.
OMM-009,Section 5.2, requires the Operations Supervisor to initiate reviews of all active Shift Notes once per 30 days and to document the review by initialing and dating the top page of each note.
Contrary to the above, Shift Notes were not reviewed once per 30 days in that, as of May 25, 1986, at 4:00 p.m., no Operations Supervisor review had been documented for Shift Notes since January 25, 1986.
2.
OMM-009, Section 5.3.7, requires that updates of Shift Notes shall require cancellation of previous note and issuing a new updated note.
Contrary to the above, updates of Shift Notes were performed without cancellation of the previous note in that, on May 25, 1986; (a) Shift Note OP-010-86 had been updated by adding caution notes with two yellow stick-on notes, (b) Shift Note OP-006-86, Start-up Instructions for NSW, had Steps 4 and 8 deleted, and Step 13 changed through a pen and ink change.
Corrective Action Taken:
The requirement for reviewing active Shift Notes once per 30 days was overlooked. This occurred because the Operations Supervisor was alternately involved in license training and routine activities. Both he and the individual acting in his place missed this activity in their turnovers to each other. The Shift Notes were reviewed by the alternate to the Operations Supervisor the day the deviation was noted and have been reviewed and initiated / dated as required since that time.
MEM/HO-8603260/ PACE 3/0S1 1
4
=
~
o v
Updates to Shift Notes require cancellation of the previous note and issuance of a new updated note. This requirement was deviated i
from due to a lack of understanding of the procedural requirements by the Operations personnel involved. Yellow stick-on notes were removed and non-applicable Shift Notes were cancelled.
The pen and ink changes noted by the inspector were made prior to approving the subject Shift Note. OMM-009 specifically allows the Supervisor to use handwritten mark ups of an existing procedure if possible and approve it as a Shift Note.
Corrective Action to Prevent Further Deviations:
The Operations Supervisor was counselled by the Manager-Operations on the requirement to review Shif t Notes once per 30 days as required per OMM-009.
Personnel on shift were counselled on the administrative requirements of OMM-009. Changes to Shift Notes and timely review and initiating by shift members was specifically emphasized.
Date When Corrective Actions Were Completed:
The above corrective actions were completed on June 20, 1986.
J 1
l MEM/HO-8603260/PAGE 4/OS1
-