ML20215J650
| ML20215J650 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/17/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-485 NUDOCS 8610270135 | |
| Download: ML20215J650 (3) | |
Text
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CD&L Carolina Power & Light Company 36 0CT20 P S: 10 HARRIS NUCLEAR PROJECT P. O. Box 165 00T 171986 New Hill, North Carolina 27562 File Number:
SHF/10-13510E Letter Number: HO-860355 (0)
Dr. J. Nelson Crace NRC-485 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 September 19, 1986, referring to RII: 50-400/86-65-01, the attached is Carolina Power & Light Company's reply to the violation 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, f
J R. A. Watson Vice President Harris Nuclear Project RAW /lah Attachment cc: Messrs. C. Maxwell (NRC-SHNPP) i B. C. Buckley (NRC) i
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8610270135 861017 PDR ADOCK 05000400 G
FDR MEM/H0-8603550/ PACE 1/OS1 I
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1 ATTACHMENT TO CPSL LETTER OF RESPONSE TO NRC REPORT Ril 50-400/86-65-01 Reported Violation 10 CFR 50, Appendix B, Criterion XVI requires that measures be established to assure that nonconformances are promptly identified and corrected. This criterion also requires, for significant adverse conditions, that the measures assure that the cause of the condition is determined and corrective action is taken to preclude recu rrence.
Contrary to the above, licensee management has failed to take adequate corrective action to preclude recurrence of unauthorized work in that:
NRC inspectors verified that forty-eight ( 48) nonconformance reports (NCRs) recently issued by Quality Assurance / Quality Control / Construction Inspection confirmed the continuing. existence of personnel performing work without appropriate procedures. These NCRs document significant conditions adverse to quality.
Quality Assurance Trend Data reports have consistently reported unauthorized work as 10 percent to 19 percent of the NCRs written since mid-1984.
The corrective action reports issued by craft management (in response to unsatisfactory trends in the unauthorized work area issued by the Quality Assurance Organization ) have not always been sufficient; often failing to include the results of a detailed investigation of each occurrence of unauthorized work and falling to establish adequate corrective action.
This is a Severity Level IV violation (supplement II).
Denial or Admission and Reason for the Violation:
The violation is admitted. There are several contributors which caused unauthorized work as noted by the inspector to occur. One example is craft performing work which required them to disturb a component of another discipline unknowingly invalidating previous QC/Cl inspections and acceptance. Another example would be that craft personnel did not - follow approved procedures which were provided to control rework of previously inspected items. The Quality Assurance trend reports identifying problems in this area were reviewed and acknowledged by craft management and as a result of these trends procedural changes were made. This helped the problem, however, tne problem did continue. The items identified were safety insignificant.
1 Corrective Steps Taken and Results Achieved:
Investigation into the unauthorized work issue revealed that the electrical craft and penetration sealing craft were two areas where most of the problems were occurring.
Procedure changes in both areas were implemented. Since the procedure changes have been implemented, the incidence rate of unauthorized work has decreased.
However, there are still NCRs being written on this subject. As a project, we will continue to push to minimize this problem. Retraining of the craft involved in this area was performed.
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Corrective Steps Taken to Avoid Further Noncompliance:
T raining classes have been conducted on this issue and a letter from the construction manager to craft supervision stressing the importance of following procedures and quality workmanship was issued.
Future NCRs dealing with
" unauthorized work" will be handled on a case-by-case basis. There will be a full investigation into the case to determine personnel involved, corrective action and preventive measures including possible termination of employment.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on September 22, 1986.
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