ML20079G427

Suppl to Answer to First Set of Interrogatories & Request to Produce

ML20079G427
Person / Time
Site:	Robinson
Issue date:	01/17/1984
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	HARTSVILLE GROUP
Shared Package
ML20079G430	List: ML20079G427 ML20079G436 ML20079G440
References
83-484-03LA, 83-484-3LA, ISSUANCES-OLA, NUDOCS 8401200086
Download: ML20079G427 (78)

Text

{ v i UNITED STATES OF AMERICA DOCKETED NUCLEAR RECULATORY COMMISSION M BEFORE THE ATOMIC SAFETY AND LICENSING BOAR

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CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-261-OLA

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(H.B. Robinson Steam Electric Plar.t, ) ASLBP No. 83-484-03LA Unit 2) )

SUPPLEMENT TO APPLICANTS ANSWERS TO THE HARTSVILLE GROUP FIRST SET OF INTERROGATORIES AND REQUESTS TO PRODUCE Since the service of CP&L's Answers to the Ilartsville Group's First Set of Interrogatories on June 30, 1983, there have been additional responses by CP&L to violations assessed by the NRC at Severity LevelIII (Interrogatory No.1-30) and Severity Level IV (Interrogatory No.1-31). CP&L hereinbelow supplements its answer to said Interrogatory No.1-30 and Interrogatory No.1-31 as follows:

INTERROG ATORY NO.1-30. Describe in detail each C P & L violation of NRC operating procedures, rules and regulations categorized at Severity Level III pursuant to NRC Enforcement Policy.

SUPPLEMENT TO ANSWER l-30. For the Brunswick Plant, see BSEP Attachment l

1.b. SUPPLEMENT attached hereto.

INTERROG ATORY NO.1-31. Describe in detail each C P & L violation of NRC operating procedures, rules and regulations categorized at Severity Level IV pursuant to NRC Enforcement Policy.

SUPPLEMENT TO ANSWER 1-31. For the H. B. Robinson Plant, see IIDR Attachment 2.a. SUPPLEMENT attached hereto. For the Brunswick Plant, see BSFP Attachment l

2.b. SUPPLEMENT attached hereto. For the Harris Plant, see SilNPP Attachment I 2.c. SUPPLEMENT attached hereto.

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P. O. 80s 1551 e Releegh, N. C. 27602 SE.D 2 71983 SERIAL: LAP-83-421 L L UTLEY Executeve Vice Preeksent Power Suppey and Engineettag & Constructnen ATTACHMENT CONTAINS INFORMATlDii WHICH IS:

Mr. James P. O'Reilly, Regional Administrator United States Nuclear Regulatory Commission "2"**2203 AFEGUARDS INFORMATI C Atlanta, GA 30301 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 O LICENSE NOS. DPR-71 AND DPR-62 I.E. INSPECTION REPORTS 50-324/83-24 AND 50-325/83-24 RESPONSE TO NOTICE OF VIOLATION

Dear Mr. O'Reilly:

In accordance with the Code of Federal Regulations, Title 10, Section 2.201, Carolina Power & Light Company (CP&L) provides the enclosed t response to the September 1, 1983 transmittal of IE Inspection Reports I

50-324/83-24 and 50-325/83-24 for the Brunswick Steam Electric Plant, Unit Nos. I and 2. The response to the violation identified is enclosed as Y Attachment A.

Since the content of Attachment A deals with matters pertaining to plant security, CP&L reauests that this information be protected as Safeguards Information in accordance with the provisions of 10 CFR 73.21, and if redesignated as not protected, we request that this information be withheld from public disclosure as provided in 10 CFR 2.790(d)(1).

UNAUTHORIZED DISCLOSURE SU3)ECT TO CRIMINAL & CIV L SANCTIONS WHEN SEPARATED FROM ENCLOSURES HANDLE THIS DOCUMENT AS DECON

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SEP 2 71903 James P. O'Reilly If you have any questions concerning this response, please contact our staff.

Yours very truly, M

E. E. Utley D .

WRM/pgp (7874WRM)

Enclosure cc: Mr. D. O. Myers (NRC-BSEP)

Mr. S. D. MacKay (NRC)

E. E. Utley, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are ,

officers, employees, contractors, and agents of Carolina Power & Light Company.

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HARPSVTT.TR, SOUTH CAROLINA 29550 AUG121983 Ibbinson File Ib: 13510E Serial: RSEP/83-1032 Mr. James P. O'Peilly Regional ldministrator U. S. Nuclear Pegulatory Co:nnission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 H. B. ROBINSCN STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO IE INSPECTICN REPORT IER-83-15

Dear Mr. O'Peilly:

Carolina Poder and Light Conpany (CP&L) has received and reviewd the subject report and provides the following response.

A. SEVERITY LEVEL 4 VIOLATION (IER-83-15-01-SL4) 10TR50, JWiendix B, Criterion 16, requires that measures be established to assure that conditions adverse to quality are pronptly identified and corrected. This requirement is inplemented by Corporate Quafity Assurance Program Section 15 and Plant Idninistrative Instruction 12 and 15 concerning nonconformance/ deviation corrective action tracking. CP&L letter RSEP/83-83, dated January 21, 1983, and IE Inspection Report l

261-82-37 document necessary corrective action for the deviation associated with the failure to install a low pressure alarm on the backup nitrogen system for the low temperature overpressure protection system.

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Contrary to the above, as of May 22, 1983, adequate corrective actions w re l not taken in that backup nitrogen pressure for the los temperature overpressure protection system was not being checked at least daily to

! ensure adequate nitrogen supply. This resulted in the nitrogen pressure being beloa the mininum required by Plant Operating Procedure-50 during a l

period when the 10a tenperature overpressure protection system was required l to be operable.

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.- to Mr. James P. O'Peilly

, als RSEP/83-1032 2

Response

1. Admission or Denial of the Allegad Violation .

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Carolina Pwer and Light Company acknowledges the alleged violation.

2. Reason for the A11ec.sd Violation

'Ihe low temperature overpressure protection system (LTVP) operates on

- 85 psig instnment air. Bottled nitrogen is used as a backup pressure supply.

Discussion in NRC Inspection Peport IER-82-37 identified an Inspector Followup Item (IER-82-37-07-IFI) to ensure a low pressure nitrogen alarm is installed during the next refueling outage. Included in this paragraph, the Inspector discussed CP&L's intention to check the bottle nitrogen pressure daily when the LTOP system is required l

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operable. Although both items were identified by the Plant as requiring ccmmitment tracking, only the cc:matment to install the low

. pressure nitrogen alann was tracked under IER-82-37-07-IFI.

If the intention to check the pressure daily had entered the tracking system, then it muld have been proceduralized.

Renerbering the ' earlier discussion with the NRC Inspector, the Operators were directed to check the LTOP bottled nitrogen pressure

. daily during the May Stea.n Generator Outage shutdown. However, the bottled nitrogen pressure was not checked for a day and a half during the subsequent startup. When checked, the bottled nitrogen backup pressure was at 400 psig which is below the required 800 psig. This pressure would have allowed the Power Operated Pelief Valves (PORV) to operate through 73 cycles.

3. Corrective Steps which Have Been Taken and Pasults Achieved ,

Considering the volume of the 400 psig bottled nitrogen baclmp pressure, our Engineering Evaluation determined that the PORVs would cycle 73 times if the nonral supply of instrument air is lost.

Chccking ti'.u LTOP bottle nitrogen pressure at lhast daily, when the i system is required operable, has been proceduralized in the Mini;num Equipmnt List (Standing Order 11) .

! In addition, Operations has inplemented a new book of infonnation and directives which is provided by the Qrrating Supervisor to the Shift Foremen and STAS. Regulatory and other key operational issues are to be documented by the Operating Supervisor and reviewed by the Shift Forenen and STAS. This doctment will provide nore timely and consistent infonration of significant issues to the Shift Fore:mn.

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.. RSEP/83-1032 3

Carmencing in 19S3, the QA personnel review IEC Inspection Reports and responses to ensure that all identified cmnatrents have been included in the ca:mtitment tracking system. ,

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'lhis event has been reviewed by personnel involved in maintaining the Plant cormlitment tracking system.

Corrective Steps hhich Will Be Taken to Prevent Further Violations

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Corrective steps taken should prevent further violation.

5. Date hhen Full Cc::aliance Will Be Achieved Full compliance has been achieved.

B. SLVERITY IEJEL 4 VIGATION (IER-83-15-03-SL4)

'Ibchnical Specification 6.5.1.1.1 requires that written procedures shall be established and implem.ated that meet the require ents of Appendix A of U3IEC Pegulatory Guide 1.33,. FEVision 2, with respect to procedures controlling containnent integrity. ,

contrary to the above, as of June 6, 1983, adeauate procedures had not been established or implemented in that the six capped instnment tubing lines in Sleeve 18 and the' cap inside containment on penetration 67, sleeve 25, were not required to be checked during containment integrity verification.

Response

1. Mmission or Denial of the Alleced Violation Carolina Ptuer and Light Campany acknowledges the alleged violation.

2. Reason for the Alleced Violaticn . ,

Although there is evidence that the caps on the Peactor Vessel IcVel Instnrent System (RVLIS) penetration insida containrent were installed,- there is no evidence how or then they were renoved.

bbdification 526 has evidence that the caps in question were installed per Lbdification 445-0. bbdification 445-0 has a signoff on 3/2/81 that the RVLIS penetration plugs were installed. A review of outage construction and cperation and raintenance activities in the vicinity of these RVLIS plugs did not reveal any evidence of the caps being renoved.

3. Corrective Steps thich Have Been Taken and Results Achieved Caps were installed on the RVLIS panetrations inside contairrent. 'Ihe caps on the INLIS penetration outside contaitrent wre hand checked for tightness to ensure the containment integrity had been raintained while the inner caps were reroved.

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RSEP/83-1032 4

4. Corrective Steps hhich Will Be Taken to Prevent Further Violations

'ihe RVLIS penetration caps will be included on the contairmunt _

integrity check list. 'Ib provida a definite method of checking that the caps have not loosened, it has been preposed (subject to field verification) that shrink tubing be installed over the caps and part of the tubing. The integrity check would be to ensure the shrink tubing has not been tampered with. This method or an equivalent positive mathod will be installed during the next cold shutdown.

5. Date h#nen Full Compliance Will Be Achieved Full compliance will be achieved prior to the startup following the cold shutdown.

C. SEVERITY LEVEL 5 VIOLATION (IER-83-15-03-SL5)

Technical Specification 6.13.1.b requires that each high radiation area has a locked door and that the keys are maintained under administrative control of the Shift Foreman. t Contrary to the above, on June 1, 1983, the access door to the ion er. change /denineralizer room (a high radiation area) was found not to be locked and unaided. Unassisted entry to the room could be made without use of the Shift Foreman's keys. .

Response

1. Admission or Denial of the Alleced Violation Carolina P wer and Light Company ackn w ledges the alleged violation.

2. Reason for the Alleaed Violation I

'Ihe Spent Resin Storage Tank Room had been previcusly locked.

Iheever, this lock did not adequately provida for rapid egress.

During installation of a rapid egress lock, it was determined that the existing door was not cmtible with the preposed lock. It uas also determined that continued work on the lock would not be in accordance with good ALARA practices due to the high radiation levels around the full spent resin tank. Therefore, it was decided to finish vork on the lock after the tank was emptied and as a temporary reasure, a U-bolt lock was installed to acccmmodate egress. It is understood that the violation is based on the U-bolt lock being hand tight and not requiring a tool to loosen the bolts.

3. Carrective Stcos hhich ifave Deen Taken and Idsults Achieved The area is new locked in such a manner co that. a tool would be -

requirrd in order to gain entry into this area.

, to Mr. Janes P. O'Reilly

, ,a RSEP/83-1032

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4. Corrective Steps hhich Will Be Taken to Prevent Further Violations As soon as it became apparent that the H. B. Pobinson staff's interpretation of what is required to secure a Iocked High Radiation Area was not in complete agreement with the NRC's, additional guidance

.was sought from NRC. Based on the guidance received, all the Iceked High Radiation Area doors were checked and after a few minor adjust 2nents wre verified to be secured by a lock or by a device that requires a tool to unsecure the access door.

The Incked High Radiation Area walls were also checked for ladders which could be used to easily go in access over the walls. 'Ihis check did not indicate any problem areas.

A new barrier with a rapid egress door will be installed in the Spent Resin Storage Tank Roam when the tank is e:rptied.

5. Date hhen Full Comoliance Will Be Achieved Full cmpliance will be achieved by October 1,1983.

If you have any questions concerning this response, please contact my staff or me.

Very truly yours,

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,/_ 4 W R. B. Starkey, Jr.

General Manager t H. B. Robinson SEG Plant I 1

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• ., y SEER u U. L<ddu F& inson File No: 13510E Serial: RSEP/83-1237 Mr. James P. O'Reilly Fegional Adr.tinistrator -

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Pesidcnt Insoectcr and the H. B. ?&incen Manager of Technical Strpport, Carolina Pcwer and Light Conrany (CP&L) provides the following infortration as a cuppitrcnt to CP&L's August-12, 1983 response to Violation B of the subject Inspection Report.

E. STERITY LEVEL 4 VIOIATION (IER-83-15-03-SL4)

Ischnical S:ecificaticn 6.5.1.1.1 recuires that icitten nremdures shall be .

cstablishtd and irplerented that neet the require. Tents of Ippendix A of CS'i?C Pegulatory Guife 1.33, Frvicica 2, with respect to procedures-co:. trolling contai nant integrity.

. Contrary to the above, ac cf June 6,1952, adequare procedures had not been estchliched or irplcranted in that the uix capped instnrnent tubing lines in Sleeve 18 r.nd the can inside ecntairmant en Fenetratien 67, Sleeve 25,

• rere nct required t.o be checked during ccntainmant integrity verification,

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~ he six (6) ccpped instn: ent tubes and their respective caps in Sleeve 18

,.are fitted wiS chrid tubing se th2 crerators c uld determine during .

icir centniment ine rrity che &s dat de ccps have not been ta. pared -

i 1:n. P.ile the unit i.m = the line, Chrink tubing was installed in the 4

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' tubing / caps outside contai:rmnt in August,1983, ar.3 ~cr. the tubing / caps inside contaiment during a cold shutdcwm in September,1983.

Tne caps.en both ends of Sleeve'18 and the cap inside contairrent on

' Penetration 67, Sleeve 25, have been added to the contairrent integrity --

checklist, Operating Procedure OP-1954.

A preliminary rew. af mechanical penetrations has not identified any additional penetrations that need to be added to the contairrent integrity checklist.. A complete review of all penetrations will be conducted during the next refueling outage.

Tne modification control procedures were revised in 1983 to address the

_ . , conduct of partial turncvers of in progress modifications prior to heating.

up the Ilant above cold shutdom. Tnis partial turnover process should ensure controls are established on capped lines penetrating contain.ent resulting fram .mdifications.

If you have any cuestions concerning this supplere .tal respense to the subjec :

'Inspecticn Psport, please contact ma or my s:cff.

Very truly yours, hf' q,; s-

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Carolina Power & Ught Company SERIAL: LAP-83-545 P. O. Box 1551. Raleigh, N. C. 27602 DEC 121983 r.r.uTLev Executive Vice President Power suppi, and Engineenne a construerton Mr. Richard C. DeYoung, Director Of fice of Inspection and Enforcement United States Nuclear Regulatory Ommission Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 I. E. INSPECTION REPORT NO 50-261/83-22 RESPONSE TO NOTICE OF VIOLATION

Dear Mr. DeYoung:

In accordance with the Code of Federal Regulations, Title 10, Sect'an 2.201, Carolina Power & Light Company (CP&L) provides the enclosed response to the November 15, 1983 transmittal of IE Inspection Report 50-261/83-22 for the H. B. Robinson Steam Electric Plant, Unit No. 2. 'Ihe

! response to the violation identified is enclosed as Attachment A.

Since the contents of Attachment A deal with matters pertaining to plant security, CP&L regt.ests that this information be protected as Safeguards Information in accordance with the provisions of 10 CFR 73.21, and if redesignated as not protected, we request that this information be withheld from public disclosure as provided in 10 CFR 2.790(d)(1).

In as much as CP&L does not protest the imposition of the civil I

penalty, please find enclosed a check in the amount of Wenty Thousand Dollars (S20,000) in pay.nent of this penalty.

WHEN SEPARATED FROM ENCLOSURES, HANDLE THIS DOCUMENT AS DECONTROLLED.

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DEC 121983 Richard C. DeYoung -.2 -

If you have any questions concerning this response, please contact our staff.

Yours very truly, Original Signed By E. E. UTLEY E. E. Utley JBW/tda (85510NH)

-Attachments

-oc: Mr. J. P. O'Reilly (NRC-RII) W/A' Mr. G. Requa .(NRC)

Mr. Steve Weise (NRC-HBR) f E. E. Utley, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light i r Company. .

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'> Notary (Seal) J My commission expires:

ti d,/ N bec: Mr. G. P. Beatty, Jr. Mr. L. H. Martin Mr. D. L. Bensinger Mr. R. L. Mayton, Jr.

Mr. G. S. Cashell Mr. S. McManus

.Mr. R. M. Coats Mr. R. E. Morgan (HBR) W/A Mr. A. B. Cutter Mr. C. H. Moseley, Jr.

Dr. T. S. Elleman Mr. D. L. Nordstrom (LIS)

Ms. S. F. Flynn Mr. D. C. Stadler Mr. B. J. Fure Mr. J. J. Sheppard Mr. F. M. Gilman (HBR) Mr. A. C. Tollison Mr. J. L. Harness Mr. J. B. Walker, Jr. W/A Mr. P. C. Hopkins Mr. A. R. Wallace l Dr. J.' D. E. Jeffries Mr. J. L. Willis

. Mr. I. A. Johnson Mr. H. J. Young Mr. A. H. McDaniel File: RC/A-2 File: R-2-0700 File: 13510.2 1 'Only those individuals with W/A (with Attachment) following their names are

.to receive copies of the letter and Attachment. All other individuals and files to receive the letter only.

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Robinson File No: 13510E Serial: RSEP/83-1410 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 i

' DOCKET NO. 50-261 LICENSE NO. DPR-23 Response to NRC Inspection Report IE-83-26

Dear Mr. O'Reilly:

Carolina Power and Light Company has received and reviewed the subject report and provides the following response.

A. Severity Level IV Violation (IER-83-26-04-SL4)

Technical Specification 6.5.1.1.1.a requires that written procedures be implemented that meet the requirements of Appendix A of USNRC Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33 requires procedures for access control to radiation areas including a radiation work permit system. Licensee Health Physics Procedure-006, Revision 0 establishes these procedures and radiation work permit (RWP) requirements.

Corarary to the above, as of September 10, 1983, this procedure had not been implemented in that 1) a mechanic performed work on RWP 1470 Revision 1 in a high radiation and high contamination area without required health physics coverage or respiratory protection and 2) a health physics technician responsible for work on RWP 1470 Revision 1 did not provide the required continuous coverage. This resulted in ingestion of radioactive material by the mechanic to levels approaching 16 MTC-hours.

Response

1. Admission or Denial of Alleged '71olation Carolina Power at.d Light acknowledges the alleged violation.

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Lstesr-to Jame2 P. O'Railly Serial: RSEP/83-1410

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'2. Reason for Admission e

The-individual was involved in the removal of the pressurizer spray valve, RC-455B, to the operating deck of containment. During the morning of the incident, health physics (HP) personnel- determined the need for additional dosimetry and respiratory protection. In response the radiation work permit for the work (RWP 1470 Revision 0) was revised -

'(Revision 1) to require additional dosimetry, continuous health physics coverage, and respiratory protection for cleaning of the valve. This RWP was made available prior to the individual re-entering his work area in containment that afternoon. The individual later indicated he had not-read Revision 1 to the RWP before signing the RWP Log and entering containment. The individual mistakenly thought that it was the HP technician's responsibility to inform him of any changes in the RWP.

Additionally; contrary to the RWP, there was no continuous HP coverage during the cleaning and filing operation. The HP technician was not-aware that the opera; ion was in progress until he found the individual cleaning and filing on the valve. Thw HP technician had previously provided coverage while the individual inspected the valve, but later left the area without halting work or emphasizing work must not continue in his absence. Upon discovery of the cleaning operation, the HP

technician immediately halted all work. Upon exiting the containment it was determined that the individual was internally contaminated.

' 3.

Corrective Action Taken ani Results Achieved The. individual was excluded from the Radiation Control Area until resolution of the contamination incident. A bioasesy program wa=

initiated to determine the extent of internal contamination. The bioassay and whole body count program concluded the individuals intake  ;

equaled to approximately 16 MFC hours. j p 4. Corrective Action That Will be Taken to Frevent Further Violation l'

The individual has been formally reprimanded. Additional training of HP ]-

2 L and maintenance personnel on the purpose of RWPs and of compliance to them will be conducted prior to the next refueling outage. Lessons l l learned will be added to the general employee radiation control training.

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.6. Date When Full Compliance Will be Achieved  ;

Corrective actions will be completed by February 29, 1984.

~ B. Severity Level IV Violation (IER-83-26-01-SL4)

Technicial Specification 4.2.5.2 requires that all steam generator tubes that are determined to have degradation exceeding the plugging limit, as defined in Technical Specification 4.2.5.1.5, shall be plugged prior to i return to p'wer.

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r u;te;r to Jam;a P. O'R; illy Serial: RSEP/83-1410 Page 3 of 5 Contrary to the above, as of September 5, 1983, two tubes in 'A' Steam ,

Generator had not been plugged despite May 1983 eddy current data indicating that both tubes exhibited essentially through-wall indications. This resulted in a required plant shutdown due to primary-to-secondary leakage.

Response -

1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.

2. Reason for the Violation On September 5, 1983, with the unit at 79% power, a primary-to-secondary leak, which had been monitored since June, 1983 in "A" Steam Generator ir. creased to approximately .32 GPM. Tha Plant was shutdown for inspection and repair of "A" Steam Generator.

Upon inspection of "A" Steam Generator, two tubes, Row 14, Column 19, t (Hot Leg) and Row 28, Column 57 (Cold Leg) were determined to be leaking.

Eddy Current examination of these tubes revealed approximately 100%

indications at 18 inches and 23 inches abovh the tubesheet respectively.

A review of the Eddy Current Testing (ECT) tapes from the May, 1983 Steam Generstor Inspection determined that both tubes exhibited near through-wall indications and should have been plugged. Based on this information, it was concluded that these two tubes proceeded to through-wall as would be predicted by previous corrosion rate calculations.

3. Corrective Steps Taken and Results Achieved The two leaking tubes were mecnanically plugged and hydrotested satisfactorily on September 11, 1983.

Additionally, on September 11, 1983, a re-examination of 10% of the ECT tapes from the May, 1983 inspection of "A" Steam Generator was completed and no additional missed pluggable indications were discovered.

In October, 1983, a review.of all the ECT tapes from the May, 1983 Outage was begun. On November 2, 1983, during the course of this complete re-review a tube was identified with a poteerial 92% defect. Continued operations based on this indication could not be justified, therefore, a plant shutdown was begun for corrective action. It was decided that a full scope eddy current inspection would be performed to determine the condition of the Steam Cenerators.

The investigation as to the root cause of why the two tubes were missed har not been completed. Some steps were taken during the November Steam Ge terator inspection to reduce the likelihood for missing tubes. The ef?cctiveness of these steps is continuing to be reviewed. Upon corpletion of our investigation a supplemental response to this violation

5

• to Jenos P. O'Railly 1: RSEP/83-1410 e 4 of 5

.will be'provided with the corrective actions to prevent further violations.

5. Date When Full Compliance Will be - Achieved JL supplemental response will be provided by January 31, 1984.

C. Severity Level V Violation (IER-83-26-05-SL5)

Technical Specification 6.5.1.1.1.e requires that written procedures be established that meet the requiremeucs of Appendix A of USNRC Regulatory Guide 1.33, Revision 2.

Regulatory guide 1.33 requires procedures for operation and calibration of nuclear instruments and the reactor protection system.

Contrary to the above, as of September 15, 1983, procedures had not been established to control the data acquisition and evaluation and require the formal review and approval of subsequently developed setpoints for calibration of the intermediate range nuclear instrument reactor trip setpoints and rod stop setpoints.

Response

1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.

2. ' Reason for the Violation During a June 23, 1983 shutdown, an intermediate range high flux trip signal initiated at 16% instead of 25% (Plant did not trip because trip was defeated). On. July 29, 1983, Nuclear. Instrumentation data was taken to reset these intermediate range trip setpoints. The intermediate range trip setpoints were not reset prior to the September 5, 1983 shutdown.

During a plant shutdown on September 5,1983, to inspect steam generator

~

tubes the plant tripped because an intermediate range high flux trip setpoint and reset were too low. The data gathered by the operators and the review of the data by the operations staff were thought appropriate.

Although this process was not formalized into procedures, as steced in the-violation, the information has since been verified to have been ccrrect. It was determined that these intermediate range trip setpoint and reset problems are related to unique flux changes associated with the present core design.

3. Corrective Steps Taken and Results Achieved The present intermediate range trip setpoints have been verified.

4. Corrective Steps Which Will be Taken to Avoid Further Violation Procedure for the evaluation and determination of curre it corresponding to the nuclear instrumentation setpoints will be formalized for the next

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$ of 5 core cycle. In the interim the intermediate range detector responses will be monitored and any changes to setpoints will be proceduralized.

5.. Date When Full Compliance Will Be Achieved Procedures will'be implemented prior to che start up for the next cycle.

If you have any questions concerning this response, please contact my staff or

- me.

Very truly yours,

/ A

/S v R. E. Morgan General Manager H. B. Robinson SEG Plant CLW:FMG:JMC/th ec: R. C.'DeYoung j

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. y o f,CEIBON 11 3 $ 101 MARIETTA STREFT, N.W.

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ATLANTA. GEORGIA 30303

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Decenter 21, 1983 e

Carolina Power and Light Company ATTN: Mr. E. E.-Utley Executive Vice President '

411 Fayetteville Street Raleigh, NC- 27602' Gentlemen:

SUBJECT:

REPORT NO. 50-261/83-27 This refers to the routine, safety inspection conducted by Mr. R. H. Albright of this office on October 3-7, 1983, of activities authorized by NRC Operating License No. DPR-23 for the H. B. Robinson facility. Our preliminary findings were discussed with Mr. R. E. Morgan, Plant General Manager, at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, .the inspection consisted of selective examinations of procedures and r:presentative records, interviews with personnel, and observations by the inspector.

'~

During the inspection, it was 'found that certain activities under your license appear to violate NRC requirements. These items and references to pertinent requirements are listed in the Notice of Violation enlosed herewith as Appendix A. Elements to be included in your response are delineated in Appendix A.

One new unresolved item is identified in the enclosed inspection report. This item will be examined during subsequent inspections.

We have' examined actions you have taken with regard to previously identified l enforcement matters. These are discussed in the enclosed inspection report.

i I

'One new unresolved item is identified in the enclosed inspection report. This item will be examined during subsequent inspections.

In accordance with 10 CFR 2.790(a), a copy of this letter, its enclosures, and your reply will be placed in NRC's Public Document Room upon completion of our

, evaluation of the reply. If you wish to withhold information contained in the i inspection report, please notify this office by telephone and include a written application, to withhold information contained therein, in your response. Such application must be consistent with the requirements of 2.790(b)(1).

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Carolina Power and Light. Company 2 December 21, 1983 The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Sincerely, Kc, Richard . Lewis, Director Division of Project and Resident Programs

Enclosures:

1. Appendix A, Notice of Violation

2. Inspection Report No. 50-261/83-27 cc w/encis:

R. E. Morgan, Plant General Manager G. T. Beatty, Jr. , Manager Robinson Nuclear Project Department I

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a APPENDIX A l

NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-261' H.:B. Robinson, Unit 2- License No. DPR-23 As a result of the inspection conducted on October 3-7, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9387 (March 9. 1982), the following violation was identified.

Technical Specification Table 4.1-3. item no. 14 states that once per operating cycle the charcoal and absolute filters for the Residual Heat Removal Compartments, HVE-5, shall be tested in place to show 299 percent removal of polydispersed DOP particles by the HEPA filters and freon by the charcoal filters.

Technical Specifications 4.12 and 4.15 require the -Control Room and Spent Fuel Building filter systems to be tested in place at the stated frequen-4 cies. The-in place tests shall veri.fy:

,1) That the HEPA filt'ers remove 299 percent-of DOP when tested in place in accordance with ANSI N101.1 (1972)

2)- That the charcoal filters remove 299 percent of a halogenated hydro-carbon when tested in place ANSI N101.1 (1972) Section 3.3 requires that when a single sample point is

' used in determining filter efficiency, the sample point shall be represen-tative of the DOP concentration across the~ sample plane. The single sample point for the unfiltered mixture may be considered representative of the samoling plane if the unfiltered mixture across the sampling plane is sufficiently uniform such that the maximum and minimum DOP concentrations do not differ by more than 10 percent of the maximum DOP concentration. The sampling plane for the filtered mixture shall be considered sufficiently

- uniform if the difference.between the maximum and minimum DOP concentration

( is . not more than 0.01 percent of the DOP concentration in the unfiltered air.

Contrary to the above, the tests demonstrating system operability performed prior to Octooer 8, 1983, of the Spent Fuel Handling Building, Control Room, and Residual Heat Removal Compartment filter systems were inadequate in that:

a. The single sample points used during the period of this inspection to

, cetermine filter efficiencies for the above systems were not represen-tative in that DOP concentrations across the sample planes differed from the maximum DOP concentrations by 25 percent.

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4 Carolina Power and Light Company 2 Docket No. 50-261 H. B. Robinson, Unit 2 License No. DPR-23

b. The requirement that filters in the Residual Heat Removal Compartment and Control Room filter systems be tested in place to verify 299 percent removal of DOP and halogenated hydrocarbon gas was not met in that in place filter tests performed during the period of this inspection failed to include filter bypass in the efficiency test.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged viola-tion; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will _ ,

be taken to avoid. further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

Date: December 21. 1983

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, p REhg UNITED STATES jog NUCLEAR REGULATORY COMMiSS!ON

[. o REHION 11

'!. $ 101 MARlETTA STREET, N.W.

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ATLANTA, GEORGIA 30303

%....../ DEC 291983 Carolina Power and Light Company '

' ~

ATTN: Mr. E. E. Utley Executive Vice President '

7.

411 Fayetteville Street Raleigh, NC 27602 ,

Gentlemen: ~ ~ '

SUBJECT:

REPORT NO. 50-261/83-33 On November 11 - December 10, 1983, NRC inspected activities authorized by NRC Operating License No. OPR-23 for your Robinson facility. At the conclusion of the inspection, the findings were discussed with those memoers of your staff identified in the enclosed inspection report.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.

The inspection findings indicate that certain activities violated NRC require-i ments. The violations, references to pertinent requirements, and elements to be included in your response are presented in the enclosed Notice of Violation.

Your attention is invited to unresolved items identified in the inspection report. These matters will be pursued during future inspections.

In accordance with 10 CFR 2.790(a), a copy of this letter, its enclosures, and your reply will be placed in NRC's Public Document Room upon completion of our evaluation of the reply. If you wish to withhold information contained therein, please notify this office by telephone or include a written application to l withhold information in your response. Such application must be consistent with

( the requirements of 2.790(b)(1).

The responses directed by this letter and the enclosures are not subject to the l clearance procedures of the Office of Management and Budget issued under the

! Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this letter, please contact us.

Si cer ly, l  ! '

ll/ ts_.

. Lewis, Director Div sion of Project and l Resident Programs

Enclosures:

(See Page 2) l

- . - . - - = . - -_ . - . - -. - . - _ - - _ _ .

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- Carolina Power and Light Company 2 0

Enclosures:

1. Notice of Violation

2. Inspection Report No'. 50-261/83-33 i

^

cc w/encls:

1R. E. Morgan, Plant General Manager G. P. Beatty, Jr. , Manager i

Robinson Nuclear Project Department l-l l

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ENCLOSURE I NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-261 H. B. Robinson 2 License No. DPR-23

.The following violations were identified during an inspection ceaducted on November 11 -

Dec. ember 10, 1983. The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

A. 10 CFR 50, Appendix B, Criterion II, as implemented by the licensee's Corporate Quality Assurance Program, requires that activities affecting quality shall be accomplished under suitably controlled conditions.

Contrary to the above, as of November 5, 1983, the licensee failed to

- establish suitable controls on activities affecting safety-related service water. equipment in that, underground power, control, and indicat hn electrical cables for service water pumps and valves were damaged during power excavation activities.

This is a Severity Level IV (Supplement I). .

B. Technical Specification 6.5.1.1.1.a. requires that written procedures be implemented which meet the requirements of Appendix A of USNRC Regulatory Guide 1.33, Revision 2, with respect to procedures for equipment control.

Administrative Procedure-027, Section 11.6, established the management controls for impiementation of these requirements.

Contrary to the above, as of November 21, 1983, these procedures were not adequately implemented with respect to clearance 83-1613 in that fuses removed to disable the three main steam isolation valve control circuits were not identifled by circuit affected and the appropriate clearance tags

.were not placed on those circuit:.

This is a Severity Level V (Supplement I).

C. Technical Specification 6.9.2.b(2) requires that conditions leading to operation in a degraded mode permitted by a limiting condition for operation be reported within thirty days by written report to the Regional Administrator of Region II.

Contrary to the above, as of December 5,1983, the inoperability of one train of the low temperature overpressure protection system on November 4, 1983, had not been reported or identified as a reportable occurrence.

This is a Severity Level V (Supplement I).

s Carolinc Power and Light Company- Docket No. 50-261 H. B. Robinson 2 2 License No. DPR-23

. Pursuant to 10 CFP. 2.201, you are required to submit to this office within thirty days of the' date of. this Notice, a written statement or explanation in- reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective <te;,s which have been taken

-and the' results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

DEC 2 91583 ,

Date:

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ATTACHMENT 2.b.

E SUPPLEMENT 0 '

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O O l CRiik Carolina Power & Light Company l

August 12, 1983 FILE: 13510.1 SERIAL: NO-83-816 Mr. R. C. Lewis, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Ccmmission Region II P. O. Box 2203 Atlanta, Georgia 30301 E E'D-EIRT P J - -

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CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS. 1& 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO NOTICE OF VIOLATION

Dear Mr. Lewis:

In accordance with the Code of Federal Regulations, Title 10, Section 2.201, Carolina Power & Light Company (CP&L) provides the enclosed response to the July 15, 1983, transmittal of IE Inspec-tion Reports 50-324/83-22 and 50-325/83-22. The response to the violation identified is enclosed as Attachment A.

Inasmuch as the content of Attachment A deals with matters pertaining to plant security, it is requested that this informa-tion be protected as Safeguards Information in accordance with the provisions of 10CFR73.21, and if redesignated as not protected, 411 Fayetteville Street

• P. O. Box 1551

• Raleigh, N. C. 27602

, v rm?.e::, _ v 7"T. .cVW.Mr2E; rr-mmu T,q

. Mr. R. C. Lewi ircctor ,

h August 12, 1983 e

I it is requested that this information be withheld from public diaclosure as provided in 10CFR2.790 (d) (1) . ,

Yours very truly, c3 . (,0-P. W. Howe Vice President

. Brunswick Nuclear Project BB:nbs*

MEMO 3 Attachment Mr. P. W.

Howe, having been first duly sworn, did depose and say that the information contained-herein is true and correct to his own personal knowledge or based upon information and belief.

Ww Y.

Y&MW Notary (Seal)

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My commission expires: 85 C**** f8* HH6 ,

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bcci eBC/A-4 (w/o Attachment) ',

/'B-X-0544 (w/o Attachment)

._ Mr. C. R. Dietz i

Mr. K. E. Enzor (w/o Attachment)

Mr. P. W. Howe (w/o Attachment)

Mr. J. J. Sheppard (w/o Attachment)

Mr. J. B. Walker, Jr.

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D'LE t..]G .3 Carolina Power & Light Company Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429 September 23, 1983 FILE: .B09-13510C ~

SERIAL: BSEP/83-3167 Mr. James P. O'Reilly, Administrator U. S. Nuclear Regulatory Commissinn Region II, Suite 3100 101 Marietta Street N.V. .

Atlanta, GA 30303

, BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1&2 i DOCKET NO. 50-325 aNu 50-324 LICENSE NO DPR-71 AND DPR-62 RESPONSE TO IhTRACTIONS OF NRC REQUIREMENTS

Dear Mr. O'Re'111y:

The Brunswick Steam Electric Plant (BSEP) has received IE Inspection Report 324/83-23 and 325/83-23 and finds that it does not contain any information of proprietary nature.

The report identified one item that appears to bo in noncompliance with NRC requirements. This item and Carolina Power & Light Company's (CP&L) responso are provided in the following text:

Violation 10CFR71.12 states conditions under which a gancral license for shipment in DOT specification containers-is issued. One condition requires the person who uses a packago pursuant to c general license to comply uith the terms and

conditions of the NRC Certificate of Compliance as it relates to the shipment j package. The NRC Certificate of Complianco No. 5805, Revision No. 10 for i

CNS-3-55 shipping cask requires that, prior to delivery of the package to a carrier for transport, the package containment cavity shall be leak tested.

Contrary to tho' abovo, on March 31, 1983, the licenrae made a largo quantity shipment (shipment No.83-166) in a CNS-3-55 shipping cask that had not boca leak tested prior.to delivery of the package to a. carrier for transport.

This is a Severity Level IV violation (Supplement V).

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r. J. P. O'Reilly CP&L Response A. Admission _or Ik.nial of the Violation CPLL ack eled;;cs that a violation of SRC requirements did occur. _

B. Rea:.on for the Violation This violation resulted from the failure by CP&L to identify the additional requirement for the Icak test which resulted froc Revision No. 10 to the Certificate of Complicnce No. 5805. Since the revised requirement was not identified, the required revisions to the plant special handling procedure were not impicmented.

C. Corrective Actions That Have Been Taken CP&LSpecialProcedureSP-82-56wastheprocedurc[hichwasusedfor handling, loading, and unloadirg of the CNS-3-55 cask. This procedure was issued as valid for only a temporary period of time since the use of this cask is not routiro. As the authorized tima for use of this procedure expired on June 30, 1983, no action is necessary for correction of this procedure to require the Icak test.

The certificates of compliance (for casks of which Brunswich is a licensed uscr) have been verified to be the latest revision.

Shipping personnel at Brunswick have received training on the requirements to ensure compliance with certificates.of compliance on shipping casks.

The shippers' checklist form has been updated to include a requirement to review the certificate of compliance for the purpose of ensuring all requirements cre met.

D. Corrective Actions to be Tcken A procedure will be impicmented by November 30, 1983, to ensure revisions to certifiertes of compliance will be identified and appropriate procedure changes implemented.

E. Date for Full comoliance l ull compliance relative to this event will be achieved with the implemen-tation of 'the procedure referenced in Section D (November 30, 1983).

Your transmittal letter relative to the subject inspection report requested additional information relative to Brunswick guidelines on LSA shipments (Ttem 8.c, page 4). The following inforretien is provided:

i

-l Mr. J. P. O'Reilly , Brunsuick has taken the following steps to improve packaging and inspections methods prior to shipment of strong, tight containers to improve documented compliance with requirements for LSA shipments.

A. Retraining of ELRC shipping per.sonnel has been performed relative to -

potential problems to avoid in selection of packages for type A quantity LSA shipments.

B. Future shipments of !! EPA filter un;ts will be enclosed in crates or othenviso securely contained.

C. Responsible E&RC supervisory persennel are currently inspecting radioactive shipments prior to release.

D.

Radioactive material shipp'.ng procedure ESRC-0510 was revised July 22, 1983, and is now undergoing another revision to reficct recent DOT and I;RC regulatory changes for shipments. These revisions reflect additional LSA packaging requirements and provide addi.tional guidance for a shipper

, of LSA radioactive material in a strong, tight package to assure

, regulatory compliance.

Vory truly yours, ORIGINAL SIGNED CY.

. E. .W. HOWE P. U. Mcwe, Vicn President Brunswick Nuclear Project TEC/pms/LETPS1 cc: Mr. R. C. DeYoung NRC Document Control Desk bec: Mr. D. L. Densinger Mr. R. E. Ifelme Mr. D. O. !!yers Mr. J. R. Bohannon Mr. L. P. licwlett Mr. B. L. Parks, Jr.

Mr. R. M. Coats Mr. P. C. Hopkins tir. J. J. Sheppard/

Mr. A. B. Cutter Mr. P. W. Howe File: BC/A-4 Mr. J. S. Dietrich/ Dr. J. D. E. Jeffries Mr. R. B. Starkey, Jr.

File: B-X-345 Mr. I. A. Johnson Mr. L. V. Vagoner Dr. T. S. Elleman Mr. L. E. Jones Mr. J. L. Villis Mr. B. J. Furr Mr. L. H. Martin Ms. M. S. Vingo Mr. W. P. Guarino Mr. C. h. Hoac1cy INPO

__ ~

FORM 22 h[~

Carolina Power & Light Company ~

Brunswick Steam Electric Plant P. O. Box 10429 -

Southport, NC 28461-0429 December 7, 1983 FILE: B09-13510C SERIAL: BSEP/83-3782 Mr. James P. O'Reilly, Administrator U. S. Nuc1 car Regulatory Commission Region II, Suite 3100 101 Marietta Street N.W.

Atlanca, GA 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. I and 2 DOCKET NO. 50-325 and 50-324 LICENSE NO. DPR-71 and DPR-62 SUPPLEMENTAT. RESPONSE TO IE REPORT 324/83-23 and 325/83-23

Dear Mr. O'Reilly:

Our letter of September 23, 1983, provided a response to the violation identified in IE Report 324/83-23 and 325/83-23. The response committed CP&L to implement a procedure to ensure revisions to certificates of compliance will be identified and appropriate on-site changes implemented. The procedure was to be implemented by November 30, 1983.

Correctjve action has been implemented as of October 18,'1983, which we feel satisfies the aforementioned committment. Chem-Nuclear Systems, Inc., has established controlled copics of CNSI Cask Books at Brunswick and will issue revisions to certificates of compliance directly to us. This eliminates HE&EC having to forward the certificates of compliance from the Corporate office to Brunswick, thus eliminating the requirement for additional procedural controls.

If you have any questions concerning the above, please contact me or a member of my staff.

l- Very truly yours, ORIGINid. S1320 EW C.

• C = '

C. R. Dietz, General Manager Brunswick Steam Electric Plant i

RMP/kal/ LETCH 1 Enclosure cc: Mr. R. C. DeYoung NRC Document Control Desk L . .-. --

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.Mr.'J. P. O' Reilly 2-bcc: Mr. D. L. Bensinger Mr. R. E. Helme Mr. C. H. Moseley

.Mr. J. R. Bohannon Mr. L. P. Hewlett Mr. D. O. Myers Mr. R. M. Coats Mr. P. C. Hopkins Mr. B. L. Parks, Jr.

Mr. A. B. Cutter Mr. P. W. Howe Mr. J. J. Sheppard/

Mr. J. S. Dietrich/ Dr. J. D. E. Jeffries File: BC/A-4 File: B-X-545 Mr. I. A. Johnson Mr. L. V. Wagoner Dr. T. S. E11eman Mr. L. E. Jones Mr. J. L. Willis Mr. B. J. Furr Mr. L. H. Martin Ms. M. S. Wingo Mr. W. P. Guarino Mr. R. E. Morgan INPO i g ie L

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Carolina Power & Light Company Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429 December 7, 1983 FILE: B09-13510C SERIAL: BSEP/83-3859 Mr. James P. O'Reilly, Administrator U. S. Nuclear Regulatory Commission Region II, Suite.3100 101 Marietta Street N.W.

Atlanta, GA 30303 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 & 2 DOCKET NO. 50-325 AND 50-324 LICENSE NO. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS Deat Mr. O'Reilly:

The Brunswick Steam Electric Plant (BSEP) has received IE Inspection Report 324/83-32 and 325/83-32 and finds that it does not contain any information of a proprietary nature.

The report identified one item that appears to be in nonccmpliance with NRC requirements. This item and Carolina Power & Light Company's response are provided in the following text:

Violation Technical Specification 6.8.1.a requires written procedures be established for recommended activities in Appendix A of Regulatory Guide 1.33, November 1972.

Item A.4 of Regulatory Guide 1.33 recommends that Administrative Procedures for Procedure Adherence be established.

Technical Specification 3.7.7.2 requires the deluge systems associated with the Standby Gas Treatment System to be operable; or, with one or more of the deluge systems inoperable, a fire watch must be established within one hour.

Contrary to the above, on September 1, 1983, an auxiliary operator failed to adhere to the requirements of Operating Instruction 0I-13, Valve and Electrical Line-Up Verification, when he did not ensure that the component he was positioning had an identification tag as specified in Section 3.4 of the procedure. This failure resulted in improper identification of the component, a valve in the fire protection system, and this valve was improperly shut. As a result, the deluge systems of the Standby Gas Treatment System were inoperabic from September 1-6, 1983, and no fire watch was established as required.

This is a Severity Level IV Violation (Supplement I.D.2).

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Mr. J. P. O'Reilly '

1. Admission or Denial of Alleged Violation CP&L concurs that the violation occurred as stated.

2. Recton for the Violation The root cau.o of this event was the failure of an auxiliary operator to comply with the requirements of Operating Instruction.0I-13, Valve and Electrical Line-Up Verification, by not ensuring that the component he was positioning had an identification tag as specified in Section 3.4 of the procedure. Contributory causes involve the lack of c painted color ccde on the subject valve and the misuse of a piping and instrument diagram. Additional det: ils involving this event are provided in LER 2-83-83.

3. Corrective Actions Which Have Been Take;n_

a. The auxiliary operator involved has received appropriate disciplinary action.

b. Real-time training use provided to operating shift personnel r

concerning 0I-13 and its applicability to this event.

c. Additional real-time training was performed for Operations personnel involving methods for valve identification, actions to be taken upon discovery of an " unidentified" valve, administration of clearance procedures, proper use of P& ids, and an integrated review of this event. <

These corrective measures have resulted in a satisfactory awareness of Operations personnel to prevent future occurrences of this nature.

i

4. Corrective Actions to be Taken Underground valves will be appropriately painted and/or labeled by December 31, 1983.

5. Date for Full Compliance l

Full compliance involving this event has been achieved.

[ Very truly yours, I

O . G;. ow_

P. W. Howe, Vice President Brunswick Nuclear Project TEC/pms/LETPS1 cc: Mr. R. C. DeYoung NRC Document Control Desk

. -. . - . . . . . ~ . _ . -- - . - . - . - - _

r. . :- ,- o o bec: Mr. D. L. Bensinger Mr. R. E. Helme Mr. C. H. Moseley Mr. J. R. Bohannon Mr. L. P. Hewlett Mr. D. O. hycrs Mr. R. M. Coats Mr. P. C. Hopkins Mr. B. L. Parks, Jr.

i Mr. A. B. Cutter Mr. F. 1. Howe Mr. J. J. Sheppard/

Mr. J. S. Dietrich/ Dr. J. D. E. Jeffries File: BC/A-4 File: B-X-545 Mr. I. A. Johnson Mr. L. V. Vagoner Dr. T. S. E11eman Mr. L. E. Joner Mr. J. L. Willis Mr. W. P. Guarino Mr. L. H. Martin Ms. M. S. Wingo 1 Mr. J. L. Harness Mr. R. E. Morgan INFO 4

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SHNPP ATTACHMENT 2.c, SUPPLEMENT d

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Carolina Power & Light Company P. O. Box 101, New Hill, N. C. 27562 September 2, 1983 .

Mr. James P. O'Reilly NRC-111 United States Nuclear Regulatory Commission Region II -

• 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of August 3,1983, referring to RII: GFM/RLP 50-400/83-22-02, the attached is Carolina Power end Light Company's reply to the violation identified in Appendix A.

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, g

R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment l cc: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP) l Mr. B. C. Buckley (NRC) l l

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Mr. James P. O'Reilly NRC-111 bec: Mr. H. R. Banks Mr. C. S. Bohanan Mr. J. R. Boh:sanon Mr. G. S. Cashell Mr. N. J. Chiangi Mr. A. B. Cutter Dr. T. S. Elleman Mr. G. L. Forehand Mr. B. J. Furr '

Dr. J. D. E. Jeffries Mr. I. A. Johnson Mr. L.1. Loflin Mr. R. L. Mayton, Jr.

Mr. S. MeManus Mr. C. H. Moseley, Jr.

Mr. R. M. Parsons Mr. J. J. Sheppard Mr. Sheldon D. Smith i Mr. J. L. W111is

' cFilei HX-0544 '"%

• MiiiEgeF,QA Se5 ices (c/o C. L. McNenzie) l l

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e Attichment to CP&L Lstter of Rcsponsa to NRC Report RII: GFM/RLP 50-400/83-22-02 ,

REPORTED VIOLATION: ,

10 CFR 50, Appendix B, Criterion V as implemented by CP&L Corporate QA Program Section 6.2.5, requires that Deficiency Reports, Deficiency and Disposition Reports, and Nonconformance Reports be controlled in accordance with procedural requirements.

Contrary to the above, on June 29, 1983, an inspection revealed that nonconformance reports are not being documented and peccessed in accordance with applicable procedures.

l' Fo. ease of response, the violation has been subdivided as outlined below for QA/QC and NPCD portions. Response to each is provided under each heading.

QA/QC Violations (as referenced in reoort):

1. Multiple instances of unauthorized personnel signing disposition acceptance on DDR's and NCR's were observed. One instance was noted in which a DDR was initiated, reviewed, dispositioned, reinspected and accepted by the same QC inspector.

2. Site QA failed to review all DR's fcr acceptance of disposition, and to review for the reportability requirements of Part 21 and 10CFR50.35(e).

3. DDR's are not being issued in accordance witti the-time requirements of CQC-2, which is four days; this is a result of inspection personnel not being able to obtain DDR tracking numbers.

Construction Inspection Violation (as referenced in reoort):

1. Multiple instances of unauthorized personnel signing disposition acceptance on DR's were observed. ,

DENIAL OR ADMISSION AND REASON FOR THE VIOLATION:

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QA/QC Violations:

l 1. The violation is correct as stated. The lead technician referenced was designated to l fulfill the technical duties of the QA/QC Specialist in his absence. Since the technician had been designated, he assuraed it was acceptable to sign for the Specialist to expedite processing cf DDR's and NCR's. Review of approximately 150 closed DDR's indicate that other lead technicians have made similar assumptions.

2.. The violation is correct as stated. QA personnel had reviewed DR's for reportability and disposition acceptability although in all cases documented evidence (i.e., initials and dates) was not shown to indicate a QA Specialist's review.

3. The violation is correct as stated. DDR's and NCR's were being initially reviewed by Supervisors to determine if a nonconformance actually existed before a number was assigned. DDR's 1684 and 1685 listed in the NRC report (as examples) were scrutinized to verify that nonconformances existed and to ensure that the nonconforming conditions were correctly and accurately stated. Several DDR's have been issued when, in fact, no nonconformance existed or the conditions were not as stated in the report. To prevent this, the supervisors were instructed to review

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DDR's and NCR's to the extent necessary to niinimize the number of invalid nonconformance reports entering the system. In performing these reviews, supervisors, on a few occasions, failed to comply with the procedure in respect to timely issue of nonconformance reports.

( Construction Inspection Violatiom 4

~ 1. The violation is correct as stated with clarification. The details of the NRC Inspector's report cited " unauthorized personnel signing disposition acceptance on

..... D R's." For the DR's in question, the corrective action and resolution details

, (response) were not signed by the designated authority (Principal Discipline Engineer). . The resolution verification and acceptance (" disposition acceptance")

signmffs were by authorized Construction Inspection personnel.

The DR responses were developed by the " unauthorized personnel" and submitted 6

directly to Construction Inspection. The close-out review failed to detect that the

DR response did not include the sign-off of the Principal Discipline Engineer.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED: .

, QA/QC Violations: a

1. Approximately 150 closed DDR's have been reviewed by the Superintendent - QC for deficiencies and acceptable issue and closure by the QA/QC Specialist. The review revealed 12 DDR's that had been either issued or closed by someone designated to sign for the QA/QC Specialist. In the 12 cases noted, the DDR had been reviewed by

'the QC Supervisor or the Superintendent - QC for technical adequacy prior to issue.

All closed DDR's and NCR's will be reviewed to determine those closed without the review of corrective action by the proper level of QA/QC supervision. In any case where the corrective action is found not to be acceptable as determined by QA/QC Supervisors, the item will be reopened with the issue of a new NCR or DDR, as appropriate. All open DDR's and NCR's issued without review by the proper level of QA/QC supervision will be reviewed by the QA/QC Supervisor or the QA/QC Specialist' to ensure correctness. - Any crors will be corrected and the nonconformance reissued. The " blanket" memorandums designating Lead Technicians authorized to sign for the QA/QC Specialist have been rescinded. New memorandums designating technicians to perform technical responsibilities assigned to QA/QC Specialists have been issued. These memorandums specifically exclude the issuing and closing of nonconformances.

2. , All open DR's have been re-rdviewed by the appropriate QA Specialists. These reviews have been documented on the DR's with their respective initials and dates.

Additionally, closed DR's on file in the QA Records vault received a technical review by QA personnel prior to filing.

During this re-review, no conditions were encountered necessitating upgrading of the DR's to DDR's.

3. Immediate (July 1,1983) training was held by the Director - QA/QC for all Unit supervisory personnel on review and issue of DDR's. A memorandum was issued to all Unit Supervisors on July 1,1983 as a follow-up to the training session. Specifics

. of the training and memo were as follows:

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After completing the draft of a nonconformance, an inspector is permitted to obtain a DDR number either through his supervision or by direct contact with the individual responsible for the DDR Log.

b. The inspector is. to sign and date the DDR when he turns it over to his supervisor for review.

c. The supervisor is responsible for a timely and thorough review of the DDR to ensure accuracy and completeness prior to issue and forwarding to en~gineering j for evaluation.

d. Paragraph 6.5 in Procedure CQC-2, Nonconformance Control, is to be followed without exception. Additionally, if during review the nonconformance is to be changed significantly, the changes are to be reviewed with the inspector to ensure he understands the rationale for the changes.

Construction Inspection Violatiom 1.

In the case of the DR's. no reworking of the closed-out reports are considered necessary due to the resolution details being found satisfactory to restore the items

' to approved project specifications or to meet an approved ravision to the specifications. In addition, distribution of closed-cut DR's are transmitted to the cognizant Principal Discipline Engineers and other management personnel through standard distribution.

CORRECTIVE STEPS TAKEN TO AVOID FURTHER NONCOMPLIANCE:

QA/QC Violations: ^

1.

QA/QC technicians are no longer authorized to sign for issue and closure of DDR's and NCR's. In the absence of the QA/QC specialist, the nonecnformance is escalated to the QA/QC supuvisor for issue and close-out.

! 2.

' Flow of DR's within QA has been streamlined to ensure that the appropriate QA individual reviews the DR's .

After QA review, copies of the open DR's are maintained on file in the QA office.

3.

Procedure CQC-2, Nonconformance Control is currently being revised to further i

clarify the responsibilities for review and issue of nonconformance reports. The training session and memorandum by the Director - QA/QC were intended to eliminate any misunderstandings related to the inspectors obtaining DDR numbers and the timely issue of DDR's.

Construction Insoection Violatiom -

- 1.

' The Principal Discipline Encineer in question has instructed the discipline personnel in the requirements for DR response sign-off. The Construction Inspection Unit Supervisor has issued a memo of instruction to remind the inspection personnel that ,

existing procedures invoke DR response sign-off by the Principal Discipline Engineer. -

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

QA/QC Violations:

J. Review of DDR's and NCR's processed prior to this report will be completed by September 30,1983.

2. DR review and/or evaluation is anticipated to be complete by November 4,1983.

3. Full compliance was achieved on July 1,1983.

Construction Inspection Violation:

1. Full compliance was achieved on August 23,1983.

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0:r:d.as h: ar a '_! nt 00tM::ny NN P. O. Box 101,_ New Hill, N. C. 27f,62 August 31,1983 .,

Mr. James P. O'Reilly NRC-107 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of August 3,1983, referring to RII: GFM/RLP 50-400/83-22-3, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.

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 Shearon Harris Nuclear Power Plant RMP/sh Attachm<ent -

cc: Messrs. G. Maxwell /R. Prevatie (NRC-SHNPP)

• Mr. B. C. Buckley (NRC) i

• b Mr. James P. O'Reilly NRC-107 bec: Mr. H. R. Banks Mr. C. S. Bohanan Mr. J. R. Bohannon Mr. G. S. Cashell .

Mr. N. J. Chiangi Mr. A. B. Cutter Dr. T. S. Elleman Mr. G. L. Forehand Mr. B. J. Furr Dr. J. D. E. Jeffries Mr. I. A. Johnson Mr. L. I. Loflin Mr. R. L. Mayton, Jr.

Mr. S. McManus Mr. C. H. Moseley, Jr.

Mr. R. M. Parsons  !

Mr. J. J. Sheppard Mr. Sheldon D. Smith Mr. J. L. Willis .

File?HX-0544 ^ :.

'Tlanager,'QA Services (c/o C. L. McKenzie)

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' Attachment to CP&L Letter of Response to NRC Report RII: GFM/RLP 50-400/83-22-03 Reported Violation:  ;

10 CFR 50, Appendix B, Criterion V as implemented by CP&L PSAR Section 1.8.5.5 and CP&L Corporate QA Program Section 6.2.5 and Construction Procedure WP-110, requires that the material used in Seismic I pipe support hangers be of the size specified on drawings, and that when drawings are not followed, inspection personnel will. detect and require correction of such irregularities.

Contrary to the above, on June 30, 1983, an inspection of hanger number SA-H-123, Item Number 3, revealed that incorrect size material had been used, and that Phase I inspection personnel failed to detect and correct the incorrect hanger material size. .

Denial or Admission and Reason for the Violation:

Violation is correct as stated.

Due to the time lapse between the Phase I inspection (September 24,1982) and the Phase II inspection (June 30, 1983), and no evidence to the contrary, it is assumed that the violation is a result of inspector oversight.

Corrective Steps Taken and Results Achieved: -

The mhterial used has been evaluated and found to be acceptable as-is. Approval for the material is documented on Bergen-Paterson Pipe Support sketch A-5-236-1-SA-H-123, Revision IS3.

I Corrective Steps Taken to Avoid Further Noncompliance:

1. The inspector of record for the Phase I inspection of hanger SA-H-123 participated in the research effort to determine the cause of the violation. The research included review of inspection reports and field books, and examination of the installed material. This effort emphasized to the inspector the need for attention to detail.

2. It should be noted that Phase I inspections have been declared preliminary as discussed in our response to NRC Report RII: JWY 50-400/83-20. Phase II inspections are considered to be the inspection of record except for items which can be easily altered after inspection. Those type items will be rechecked at time of the 79-14 final walkdown. The discrepancy in the tube steel size was discovered at the time of our Phase II inspection and proper controls were exercised.

L Date When Full Comoliance Was Achieved:

Full compliance was achieved on August 15,1983.

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P. O. Box 101, New Hill, N. C. 27562 September 20, 1983 Mr. James P, O'Reilly NRC-122 U 'ted States Nuclear Regulatory Commission R ; ion II lot Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303 -

Dear Mr. O'Reilly:

In reference to your letter of September 1,1983, referring to RII: PEF 50-400/83-24-1, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.

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, f_- ; "

R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RSIP[sh Attachment '

e: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. B. C. Buckley (NRC)

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O Attachment to CP&L Letter of Response to NRC Report RII: PEF 50-400/83-24-01 Reoorted Violation:

10 CFR 50, Appendix B, Criterion XVI, as implemented by PSaR paragraph 1.8.5.16, requires that measures be established to assure that conditions adverse to quality are _

promptly identified and corrected.

Contrary to the above, measures have not been established to assure that conditions adverse to quality are promptly identified and ccrrected in that the quality assurance program as implementea contains the followmg deficiencies:

1. Multiple inadequate control interfaces exist betw.en document systems such as occurs wien l a condition adverse to quality is upgraded to a higher tiered corrective action system.

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2. Non-quality and non-serialized documents such as punch lists are utilized to accomplish corrective actions.

3. Voiding and cancellation of quality documents are not adequately controlled within both the Construction Inspection and Quality Control systems.

4. Inspector's findings, particularly when non-quality documents such as punch lists were used, are not preserved.

5. Periodic trending of nonconformances for the purpose of determining adequacy of corrective actions, does not include all types of nonconformances generated at the site. -

'Thi is s a Severity LevelIV Violation (Supplement II).

Denirl or Admission and Reason for the Violation:

The violation is correct as stated. CP&L concurs with the Inspector that the conditions described in the report are individual program weaknesses. The nonconformance i program, during the development and review processes, was considered to be in basic compliance with the applicable criteria, as interpreted. Even though the base j

requirements have not changed, a need for refinement of the style and content of the program occurred without being fully met. CP&L-does, however, respectfully request that the NRC consider downgrading the severity level to Level V based on the fact that in all cases actually identified by the Inspector, there was not a direct loss of control.

Corrective Steos Taken and Results Achieved:

Prior to the NRC audit on July 19-22, 1983, and the resultant violation, the overall i

nonconformance and corrective action program was being evaluated for consolidation into a single procedure, and for upgrading several areas considered to be in need of enhancement, some of which are in the same vein as the Inspector's findings. A composite procedure, now being developed, will address and resolve the individual weaknesses that were identified by the Inspector.

Pending issue of th'e new composite procedure, QA/QC Procedure CQC-2, Nonconformance Control, has been revised to delineate the process for voiding and cancelling QA/QC-generated nonconformance reports. Also, for nonconformance reports i

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Corrective Steps Taken and Results Achieved (cont'd.):

generated by Construction Inspection, memoranda have bee _n issued to clarify the processing in accordance with site procedure . TP-17, Construction Inspection -

Nonconformance Control. The memoranda pertain to nonconformance resolution and acceptance, and the issue of all nonconformance reports for dispositioning, even though the report fails to describe a nonconforming condition.

2 The electrical " punch lists" observed by the Inspector are being formally incorporated '

into site procedura TP-42, Installation of Safety Related or Seismically Installed Raceways and Components, which will change the " punch list" to an inspection report and an official QA record.

Corrective Steps Taken to Avoid Further Ncncompliance: . -

The new nonconformance and corrective action procedure, in addition to correcting the weaknesses, will contain guidance in the use and disposition of documents considered to be part of nonconformance handling, even though the documents (e.g., punch lists, travelers) arc part of a work or inspection procedure.

Date When Full Compliance Will Be Achieved:

Issue of the new nonconformance and corrective action procedure is scheduled for December 15,1983. Full compliance for all aspects of the violation will be completed by February 1,1984.

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NRC-145 Serial LAP-83-535

• Carolina Power & L12ht , Company

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P. O. Box 101, New Hill, N. C. 27562 November IS,1983 Mr. James P. O'Reilly, P,egional Administrator United States Nuclear Regulatory Commission Region Il 101 Marietta Street, Northwest (Suite 2900)

' Atlan 2, Georgia 30303 SHEARON HARRE NUCLEAR POWER PLANT UNIT NOS.1 AND 2 DOCKET NOS. 50-400 AND 50-401 -

IE INSPECTION REPORT NOS. 50-400/83-25 AND 50-401/33-25

Dear Mr. O'Reilly:

Carolina Power & Light Company (CP&L) has received Mr. R. C. Lewis' letter dated October 19, 1983 which documents' the results of the special Regional Construction Assessment Team inspection conducted by Mr. P. R. Bemis on Augus;15-26,1983.

We consider this inspection to be one of the most, thorough reviews conducted of our -

Harris Project Activities, and appreciated the professionalism and high degree of expertise with which it was conducted. The findings and observations noted in the above rcport, and discussed at the exit critique, are being given management attention as we continue our internal evaluations of program improvements. In addition to the items covered in your letter, we would like to take notice of a number of strengths found by your assessment team and discussed at the critique:

1. Project management meetings, such as the project review meeting, are oriented towards the resolution of problems. The meetings focus on the identification of the problems and the agreement of how to attack and resolve the problems. The responsibility to handle the tasks is clearly defined when problems emerge.

2. The warehouse storage program is well developed, and the use of operations personnel to insure that operations equipment has adequate preventive maintenance' while in storage is a very positive aspect. ,

3. There is an on-site engineering group - Harris Plant Engineering Section - which provides design self-sufficiency.

4. There is a mechanism to incorporate industry experience feedback into the nuclear power plant design.

5. The techn.ical audits conducted by CP&L of the Architect Engineer (Ebasco) are of substance and are over and'above the required programmatic audits.

.' br.*3cmts P. O'Reilly (v]

NRC-145

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6. Tne electrical construction inspectors are considered to be very knowledgeable and cons.:lentious in their work areas.

7. Mai;gement is actively involved in getting problems associated with concrete

, placement addressed and corrccted.

8. 'Engheers are extremely responsive in addressing concerns raised by the NRC.

In addi.io.. to.the strengths noted above, we acknowledge the seven violations that were identified. We herewith submit (Attachment) our responses to violations in accordance with the p.ovisions of 10 CFR 2.201.

We considsr that the corrective actions taken are satisfactory for lhe resolution of the items.

Thank you for the consideration in this matter.

' Yours very truly, 77f W

• R. M. Parsons Project Genera! Manager Shearon Harris Nuclear Power P; ant RMP/sh

.Attachme .t cc: Mess s. G. Ma.twell/R. Prevatte (NRC-SHNPP)

Mr. 5. C. Buckley (NRC) e 4

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Mr. James P. O'Reilly , NRC-145 bec; Mr. H. R. Banks Mr. C. S. Bohanan .

Mr. H. R. Bowles .

Mr. C. Carmichael (2)

Mr. G. S. Cashell Mr. N. J. Chiangi Mr. A. B. Cutter Dr. T. S. Elleman Ms. S. F. Flynn Mr. G. L. Forehand Mr. J. F. Garibaldi (Ebasco) .

1 Mr, J. L. Harness Mr. P. C. Hopkins Dr. J. D. E. Jeffries Mr. I. A. Johnson Mr. S. A. Laur Mr. L. I. Loflin '

Mr. R. E. Lumsden Mr. R. L. Mayton, Jr.

~ ' Mr. S. McManus Mr. C. H. Moseley, Jr.

Mr. D. L. Nordstrom (LIS)

Mr. R. M. Parsons Mr. J. J. Sheppard Mr. Sheldon D. Smith Mr. A. C. Tollison Mr. R. A. Watson Ms. M. A. Weaver (Westinghouse)

Mr. J. L. Willis Mr. T. A. Baxter (Shaw, Pittman, Potts & Trowbridge)

Mr. M. F. Thompson File: HI/A-2D ,

File: H-X-0544 4

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j ATTACHMENT l

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j Responses to Violation Identified During

. ~ che Inspection Conducted on August '15-26,1983 ,

(IE' Inspection Report Nos. 50/400/401/83-25) l 1 -

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o. O Carolina Power & Light Company Shearon Harris Nuclear Power Plant 1E Inspection Rep' ort 50-400/401/83-25 -

Violation A Reported Violation:

10 CFR 50, Appendix B, Criterion X, as icplement'ed by the Carolina Power &

Light PSAR Section 1.8.5.10, requires that inspection of activities affecting quality shall be executed to verify conformance with the documented instructions. Construction procedures TP-28 and WP-105, are the Harris site instructions that are used in the installation inspection of safety-related equipment.

. Contrary to the above instructions, the installation inspection, which was performed' for Motor Control Centers (MCCs) 1 A35-SA and IB35-SB was inadequate in its execution in that inspection f ailed to identify the following:

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1. The MCC hold-down fasteners were not t1ghtened.

2. The MCC' elevation checks were not adequately performed.

3. The welding of the MCC nounting sill to c=be'dded plates differed from the requirements on the vendor plan'which was referenced on the welding

. instruction.

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This is a Severity Level IV Violation (Supplement II), and is applicable to Unit 1 only. ,

Denial or Admission and Reason' for the Violation:

The violatics is correct as stated.

1. The f asteners were loose because either they were not checked closely enough or they were loosened by others who say have perforned work on the MCC's af ter the inspection by CI.

. 2. Elevations were checked indirectly by CI inspector by verif ying previous sign off of pad elevation by Civil Cl when pad /e= beds were installed.

3. The QC Structural Welding inspector inspected the weldments in question as per the . vendor drawings mini =um weld si'ze 1/4" x 1/4" x 3". Using the 1A4 welding' process and a 1/8" E-7018 elec, trode, en acceptable 1/4" fillet veld was not attained. Therefore, ,to reach the required weld size, multiple passes were performed. The QC Inspector should have requested clarification before performing the final inspection.

Corrective Steos Taken and Results Achieved:

^1. All fasteners in MCCs under the scope of Regt;1 story Guide 1.29 have been reinspected under TP-28. Discrepancies were noted ard are being resolved.

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2. Procedural steps under WP-105 and TP-28 have been initiated to recheck the elevation of all.MCCs under the scope of Regulatory Guide 1.29 against vendor, Ebasco, or CP&L approved design docusents. This recheck is expected to be complete by December 1,1983.

3. Motor Control Center mounting sill weldments were evaluated by Harris Plant Engineering Section and were found to be structurally sound.

FCR-AS-3914 (approved October 27, 1983) was' issued to allow 'for multiple weld passes to attain the required weld size. -

Corrective Steps Taken to Avoid Further Nonco=cliance:

. 1. (a) Additional training of inspection personnel involved in inspection of MCCs was conducted by the lead inspector on October 28, 1983 emphasizing closer inspection of MCC fasteners for correct tightness under TP-28.

(b) Exhibit 12, WP-105, is now being used to have CI check the results of wo,rk performed on equipment that has been disassembled. Exhibit 12, WP-105, is used for special assembly of equipment. This exhibit will be required to be initiated if equipment has to be disassembled to f acilitate installation and has to be reasse= bled af ter installation.

'2 . Inspectica personnel involved with inspection of MCCs received training by the lead inspector on October _28,1983 on the requirements for elevation checks against vendor, Ebasco, or.CP&L approved design docu=ents.

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3. QC structural welding inspection personne'l have been instructed to follow applicable inspection criteria (i.e. ,, FCR's, DCN's , FW's, Vendor and Engineering related drawings) . . If conflicts arise, inspectors will

+ request clarification of information prior to perfor=ing inspection.

Date When Full Cocoliance Will Be Achieved:

1. & 2. Full compliance will be, achieved on Dece=ber 1, 1983.

'3. Full compliance was achieved on October 28, 1983.

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, Carolina Power & Light Codpany Shearon Harris Nuclear Power Plant IE Inspection Report 50-400/40'1/83-25 Violation B Reported Violation:

10 CFR S0, Appendix 3, Criterion V, .as implemented by Carolina Power & Light Company PSAR,'Section 1.8.5.5, requires that activities affecting quality shall be prescribed by docusented instructions, procedures, or drawings and -

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_shall be accomplished in accordance with these instructions, procedures, and dratrings.

1. Pipe support drawing SW-E-456, Revision 4/D, required two piece l's, 4 x 4 tubing, to be welded to a steel tube of support SW-E-366 with a 1/4" fillet welded all around both piece l's.

2. Pipe support drawing SW-E-456, Revision 4/D, required a 1/16" clearance between the support and the top and both sides -of.its pipe.

3. WP-110, Revision 8, paragraph 3.4, requires documentation of pipe support stock sub stitutions. The strut for support SW-E-946 was required to be I welded to support SW-H-944.

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4. Procedure MP-d5, Revision 18, paragraph 4.6, required welders to identify their work at the time of fit-ups or before fit-up begins.

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' Contrary to-the above,

1. One of the support SW-H-456, piece l's was not welded on one of its four i sides. .

2. There was less than 1/32" cle,arance between support SW-H-456 and the top

,of the pipe it supported. , .

3.- The' strut f or support 'SW-H-943 was used in support SW-E-946 and welded to support SW-H-944. The strut for support SW-E-942 was used in support SW-H- 943. The strut f or support SW-H-946 was used in support SW-E-942.

- - The licensee was unable to provide documentation authorizing the above noted material substitutions. s

4. .There was no discernible evidence that.the welder (s) had stamped their stencils on field welds C1-255-M-22-FW3, C1-236-1-SI-244-FW-601, and FW-597-598, 599, 60,0 (tack welds on code plate of SI penetration).

This is a Severity Level V Violation (Supplement II), and' is applicable to thit 1 only . ~

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Denial or Admission and Reason for the Violation:

The violation is correct as stated, with the following clarifications

1.- Pipe hanger SW-E-456 is a box frame hanger attached to a large existing Service Water pipe hanger. It was to have all'around 1/4" fillet welds

[ connecting two items #1'(4 x 4 tdoe steel) to an existing 6 x 6 tube steel member of SW-E-366. The welds _were only performed on three sides leaving off, the inside welds.

It appears the inspector accepted the joint knowing the welds were 4 deleted, per FCR-5-564. The FCR allows the deletion.of the inside window welds for box f rame hangers on 12" and smaller pipe when the members require all around fillet welds. Due to the configuration of this hanger, . the inspector thought that the FCR was applicable. In the case of the reported joints, the FCR is not applicable.

2. Banger SW-E-456, Rev. 4/D, was inspected to Phase II by the C.I. Inspector

'(Hanger Q.C.. Inspector). It appears that during this inspector's review, he inadve Lently ~ f ailed to detect the specified design clearance requirement violation. It appears that an error occurred in. reading or recording the dimension. Therefore, the reason f or the violation is considered to be a physical inspection error.

3. For hangers SW-E-942, 943 & 946, although a material substitution

. violation is acknowle'dged, the violation, as stated, is misleading. The violation stated that "the strut" was substituted in each case without the i.__ proper documentation when, in fact, it was not the strut but rather the pipe clamp which was substituted. ,

WP-110, Rev. 8, paragraph 3.4, 'requir,es documentation of pipe support stock substitutions. Apparently, due to the fact that all three (3)

, hangers (SW-E-942, 943, and 946) require the same type and size pipe L clamp, the insp'ector failed to realize a violation of site procedure had been made. The records suggest that the inspector made a document review error :as opposed to a physical inspection error. ,

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4. In. reference to the NRC reported violation that on weld joints C1-255-M-22-FW3; C1-236-1-SI-244 FW 601; and the tack welds on the code plate of containment penetration #M-22 reported as FW597, 598, 599', 600, the welder (s) had not stamped their welds; a further investigation into the details has b etc performed by Welding Engineering.

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1S1-244 FW 597, 598, 599, 600, which are socket velds identified on isometric 1SI244. were not velded at the time' of 'the NRC audit and.were mistakenly. identified by the NRC report as the four (4), tack welds L . attaching a Code. data plate to the cont inment penetration #M-22. This ,

Code data plate was moved to a new location on the penetration in 1981 for which a WDR was generated which is presently in the. Q. A. Records Vault.

p On August 26, 1983, Welding Engineering was notified of the NRC Inspector's reported violations on containment penetration weld joint j #C1-255-M-22-FW3, 3" diameter pipe veld joint #Cl-236-1-SI-244-FW601, and l the.f our (4) tack velds connecting the Code data plate to the containment f

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penetration #M-22'. The Senior Engineer,' Metallurgy / Welding, innediately requested a CPGL.Q. C., Lead Technician and a Welding Engineering

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Supervisor to accompany him and assist in investigating the details. Upon arrival at the weld joints, the Welding Engineering Supervisor and the Q.C. Technician located the stencils which had been sta= ped at the

' penetration weld joint #C1-255-M-22 FW3 (stencils #B-79, #C-79) and the stencil which had been stamped at the penetration code plate tack welds

,,(stencils #F-16). It was, however, verified that welder #C-79 ha4 i f orgotten to stamp pipe weld j oint #C1-236-1-SI-244-FW601; as required by

. site. procedure MP-05. It should be noted, however, that it is not a Code violation.

Corrective St eps Taken and Results Achieved:

, .1. Af ter. the violation was discovered, the hanger was placed on DDR #1919, Deficiency Report. It was then evaluated by Harris Plant Engineering and the j oint was found to be acceptable _ "as is". The hanger design drawing was revised to reflect the as-built condition.

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2. The- condition was identified and reported for hanger SW-H-456, Rev. 4/D, and docunented on DR No. E-273. ,

Banger SW-H-456, Rev. 4/D, will be reworked to correct the improper pipe to support member clearance.

3. Due to the f act that all three (3) ~ hangers involved (SW-H-942, 943, and 946) required by design the identical type and size cla=ps and the clanps are all. standard catalogue parts, the interchange is acceptable "as is". -

4. DDR 1933.was generated on August 26, 1983 to document the failure of C-79 to stencil pipe weld fj oint #1SI244 FW601. ' Working to the Corrective Action Report of the DDR, the pipe weld joint was stanped as required by MP-05.

Corrective Steps Taken te Avoid Further Noncompliance:

1 WP-110 shall be~ revised to discourage the use of generic FCR's (i.e. ,

1. . _ FCR-H-564) by the craf t or the inspector for installation and inspection.

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2. For' hanger SW-H-456, Rev. 4/D, the C.I. Inspector ceased e=ploynent in the Pipe Hanger'C.I. -Unit (unrelated to this incident) and transferred to a different C.I. discipline. Due to the relatively~short ti=e frame from the issua'n ce'of the nonco=pliance' report to the inspector's transfer, only a verbal reemphasis of procedures was performed. If the inspector had

.re=ained in the group, he would have undergone a docusented and formal retraining relative to the nonconpliance. Site policy has been ree=phasized to all Pipe Hanger C I. Inspectors to assure that they understand Phase II Inspection procedures and criteria.

The use of catalog parts shall be in accordance with design. This shall 3.

be verified,at the point of installation. WP-110 and TP-34 shall be r

revised to clearly state these requirements. .

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4. Welder C-79 was issued a written reprimand and reoriented to MP-05 by his supervisor.

Date When Full Cocoliance Will Be Achieved:

~ 1 - 3. Full compliance will be achieved on December 15, 1983.

4. ' Full compliance was achieved on September 2,1983. -

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Shearon Harris Nuclear Power Plant IE Inspection Report 50-430/401/83-25

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Violation C .

Reported Violation 10 CFR 50, Appendix B, Criterion V, requires that procedures written .f or activities af fecting quality be followed, FSAR, Section 1.8, co=:its to Regulatory Guide 1.28 which endorses ANSI Standard N45.2. Secticn VI cf the standard defines the same requirements as Crittrion V. Quality procedures AP-XIII-05, Appendix A, requires that the Senior Lead Engineer will, for each ship =ent, check for storage requirements from the vendor.

Contrary to the above, as of August 24, 1983, quality procedures were not followed in that the Senior Lead Engineer had not checked the vendor storage

. requirements f or HEPA filters designated f or use in safety-related HVAC filtration units. These filters were not sto ed in accordance with vendor instructions.

This is a Severity Level V Violation (Supplement II).

Denial or Admission and Reason for the Violation:

The violation is correct as stated. The vendor storage requirenents were not

-. on site.

Corrective Steps Taken and Results Achieved:

' The HEPA filters have' been inspected to -insure that no damage occurred because of the previous improper storage. None was f ound. The filters were restacked to co= ply with the requirements of ANSI N509-1976. The vender requirements for storage are not on site, but at the time of the discovery of the violation, the NRC Inspector called the vendor. The vendor raid his storage requirements were the same as ANSI N509-1976. .

dorrective Steps'Taken to Avoid Further Noncompliance:

The material storage procedure AP-XII-05 was revised to include the specific storage requirements -f or HEPA filters as described in ANSI N509-1976.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on Nove=her 10, 1983.

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Carolina Power:& Light Company Shearon Harris Nuclear Power' Plant IE Inspection Report 50-400/401/83-25 Violation D Reported Violation:

10 CFR 50, Appendix B, Criterion V, requires activities af fecting quality shall ,be accomplished in ~accordance with procedures, drawings, etc. Carolina Power & Light Company proccdure CQA-4, Revision 5, QA Records, Attachment 1, identifies radiographs as QA records. Paragraph 7.7.2 requires special process records such as radiographs and microfilms to be packaged and stored to prevent damage due to temperature, humidity, light, etc.

Contrary to 'the above, radiographic film had been stored in the Superintendent's QA office, outside the vault, for approximately two weeks.

This is a Severity Level V Violation (Supplement II).

, Denial or Admission and Reason for the' Violation:

The violation is correct as stated. The volume of radiographs received on site in a limited period of time exceeded available storage in the QA Records

. Vault.--Timely rearrangement of vault storage was not taken.

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Corrective Steps Taken and Results Achieved: -

Radiographs were transfer > ed to the vault on October 14, 1983. (The vault rearrangement .was completed the same day.) The radiographs were re=oved from the sealed packing crates and 'placed in the radiograph storage cabinets the next .two days and are now stored according to requirements.

Corrective Steps Taken to Avoid Further Noncompliance:

Any future receipts of radiographs which exceed QA Records' storage capacity will.be ~ stored in the Harris Plant Doccuent Control vault which is the-

. permanent QA Records' storage facility for the plant.

l Date When Full Compliance Will Be Achieved:

Full co=pliance was achieved on- October.14, 1983.

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• Shearon-Harris Nuclear Power Plant IE Inspection Report. 50-400/401/83-25

' Violation E

. Reported Violation:

10 'CFR -50, Appendix B , Criterion XVI, requires 'that measures be established to assure that conditions adverse'to quality, such.as deficiencies, deviations, and nonconformances are pro =ptly identified and corrected.

Contrary to the above, the Shearon Harris Plant Engineering Organization did not have'a procedure f or identifying and correcting ceficiencies, deviatior.s,

,and'nonconformances. In addition, during re-performance of calculations for pipe. support CH-H-1030, the-designer noted a violation'of AISC requirements in the original calculations. _ The support was redesigned but the violation was not. identified to the original designer ( A/E-contractor), nor evaluated for potential generic significance.

This is a Severity I.evel V Violation (Supplement II).

. Denial or. Admission and' Reason for the Violation:

IThe violation is correct as stated. The Harris Plant Engineering Sections

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uses departmental and Corporate procedures for identifying and correcting

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deficiencies, deviations, and nonconformances.- NPED procedures, and the procedures applicable to specific design efforts such as on-site hanger . ,

- design, incorporate the design control requirements of ANSI N45.2-11. NPED procedures f or evaluating nonconformances under 10 CFR 50.55(e) and 10 CFR 21 are part of the mandatory training for all' design personnel.. Criterion XVI,

.10 CFR 50, Appendix B , ' requires that significant conditions' adverse to quality be documented and reported, and the NPED procedures reflect this requirempt. Also, please note that the specific design question concerning a pipe support, which was' identified during this audit, was neither-significant" nor ~* adverse to quality" If the design had not been revised, the support would have performed,the design function.

Corrective Steps Taken and Results Achieved:

Each applicable. HPES employee has been reminded of our procedural co=mitments (NPED 3.9); however, due to the nature of 'the specifically identified concern (e.g., not sij;nificant), no fur.her speci,fic action for the particular' item is d eemed ' a ppropriate. .

Corrective Steps Taken to Avoid Further Nonco::aliance:

' A Section Instruction is scheduled for issuance by November 30, 1983. The

, purpose of this Instruction is to more clearly define specific actions to be taken by-HPES personnel when nonccnformances are identified.

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Date When Full Co=cliance Will Be Achieved:

Full co=pliance will be achieved on Novecher 30, 1983.

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Carolina Power & light Cocpany "Shearon Harris Nuclear Power Plant IE Inspection Report 50-400/401/83-25 '

Violation F Reported Violation:

10 CFR'50, Appendix B , Criterion V, requires that activities af fecting quality be prescribed by and perforced in accordance with instructions, procedures, or drawings.

1. FSAR, Section 1.8, page 50, coc=its to compliance with NRC Regulatory Guide 1.38 and ANSI N45.2.2-1972. AP-XIII-05, Revision 12, requires the reactor internals to be stored in accordance with the manufacturer's instructions. The NSSS Component Receiving and Storage Criteria, dated March 1976, states that storage criteria was in accordance with ANSI N45.2.2-1972. During inspection of the storage condition for the upper reactor internals stored in the reactor vessel and an inspection of storage areas in the auxiliary building, the following itens were noted:

a. ANSI N4 5.2.2-1982', paragraph 6.2.1, require,d access control to storage areas.

b. ANSI N4 5.2.2-1972, paragraph 6.2.2, required storage areas to be cleaned to avoid accumulation of trash, discarded packaging materials, and other detrLnentcl soil.

c. ANSI N45.2.2-1972, paragraph 6.3.3, prohibits the storage of ,

. hazardous che=icals in close proximity to important nuclear items.

Contrary to the above:

a. (1) On July 23, 1983, and twice on July 25, 1983, the caterials storage area in the auxiliary building was found unlocked and ,

without an attendant.

(2) The storage area for the reactor internals'was not posted as a l controlled area.and unrestricted access to the storage area was

. ob s erved.

b. Uhderneath the reactor upper internals cover and on the uppir l

l internals, over six wads of used tape, two rolls of tape, and cleaning cloth were observed. ,In addition; the RV flange was not protseted and nu=erous cigarette butts were observed on the RV flange grooves. ,

I ' c. A can of cutting flujd was observed to be stored on top of the upper reactor internals and underneath its canvas protective cover.

2. On August 25, 1983, a craf ts:an working on the upper internals lif ting rig infor=ed the inspector that he had taped over the spray nozzle holes of the upper internals because he was concerned about dropping something into the holes while working above them. He further stated that he determincd i

how deep the holes were by dropping a nut tied to a string into the holes.

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o Contrary ':.o the above, the craf tsman did not have' a procedure for deter:irdng the depth of the holes and for taping the holes.

This is a Severity Level V Violation (Supplement II), and is applicable to Unit 1 only.

Denial or Admission and Reason for the Violation:

The violation is correct as stated with the following exception: '

The lower internals cannot be interpreted as being in a stored area with respect to access control. . Permanent plant locations are considered storage locations by site policy with the exception of access control. Access control for_ materials and equipment in its permanent plant location is controlled by procedure on a case-by-case basis. The violation occurred because of f ailure to implement the policy and the inflexibility of the procedure.

Corrective Steps Taken ar.d Results Achieved: -

Valve storage areas and the reactor vessel internals storage area are being locked during non-working hours and during times when access to the areas is

-not required.

Valve storage areas have signs posted at the entrance allowing authorized personnel only t; enter the area av well as forbidding the use of tobacco, f ood or beverages.

The reactor vessel internals.have been cleaned of ' subject debris, and stored in - the reactor. vessel which is in a relatively isolated area. Polyethylene

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has been used to seal the internals inside the vessel and a barricade was

. installed with a lockable door to restrict access. A sign was placed at the

. entrance designating the area as Zone 4.

The work being done on the vessel internals by the craf ts=an witho'ut a procedure will b e eliminated by the new access control for the area. Also, management has reemphasized placing covers over accesses to equipment, piping systems , etc. where the entrance of f oreign objects could cause potential

. problems.

Corrective Steps Taken to Avoid Further Nonco::aliance:

Procedure AP-X-02 has been reviewed and found to be co=patible with ANSI standards governing housekeeping requirements. Management h'as e=pha ized the importance of compliance with this procedure to all personnel.

Ihte When Full Compliance Will Be Achieved:

Full co=pliance was achieved on Novecher 10, 1903.

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b Carolina Power & Light Cocpany "Shearon Harris Nuclear Power Plant IE Iaspection Report 3 0-400/401/83-25 Violation G Reported Violation:

10 CFR 50, Appendix B, Criterion V, as i=plemented by Carolina Power & Light Co=pany, PSAR, Section 1.8.5.5, requires in part that activities affecting quality shall be prescribed by docusented instructions.and procedures of a type appropriat'e to the circumstances. Contrary to this ' requirement, the f ollowing civil procedure instructions were not appropriate f or the circu=sta'nces as described below:

1. Procedure TP-32, Structural Steel Inspection, requires that extra flat washe'rs be used on oversize holes, but does not provide for instructions or doce:entation for inspectors to inspect and document oversize holes.

2. Procedure WP-28 does not adequately prescribe instructions for the hand methods being used to nix grout in that it does not stress the i=portance of blending cement and sand before adding water and it prescribes that grout be cixed in a truck or paddle mixer.

.This is a Severity Level V Violation (Supplement II).

Denial or Admission and Reason for the violation:

- The violation is correct as stated..

1. The require =ent to inspect for oversize holes was inadvertently omitted from the procedure (TP-32).

2. The para 6raph of WP-29 which is in question, 3.10.2, concerns dry pack grout, and states grout will be mixed by mixer or by hand. For actuni mixing instructions, it references paragraph 3.12.2 which covers controlled shrinkage grout. ,Paragrapn 3.12.2, however, states mixing shall be by paddle mixer or by truck, which contradicts paragraph 3.10.2.

Detailed instructions for hand mixing were not included in 3.10.2 except to require thorough mixing of the ingredients - cement, sand, and vster.

• Corrective Steps Taken and Results Achieved:

1. ' Deviation Notice No. 2 was written to TP-32, Rev. 5, establishing '

procedural require =ents for inspection and documentation of bolt noles sizes on August 26, 1983 and is now being used by field inspection personnel. DR-AS-300 was written on Septe=ber 1,1983 addressing the possibility that high strength bolts =sy have been installed in oversized holes without the required hardened washers over the . holes. PR-AS-3624 was approved on September 1, 1983 resolving this discrepancy.

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2. Procedure WP-29 was revised by Procedure Deviation Notice No. 6 on August 23, 1983 to delete requirement for rJmxing dry pack grout with a paddle mixer. Deviation Notice No. 7 was approved on August 25, 1983 adding the requirement for thoroughly b1*ending th'e sand and cement before water is added.

Corrective Steps Taken to Avoid Further Noncocoliance: .

1. TP-32, Rev. 6. approved on Nove=ber 4, 1983, 1ncludes inspection for oversized holes in the erection phase and a check during the bolting phase for oversized holes which may result from reaming and drilling.

2. Work Procedure revisions. (See Corrective Steps Taken and Results Achieved.)

Date When ?ull Co=nliance Will Be Achieved _:

Full Cot.pliance was achieved on November 4,1983.

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P. O. Box 101, New Hill, N. C. 21562 November 30,1983 Mr. James P. O'Reilly NRC-147 United States Nuclear Regulatory Commission Region 11 101 Marietta Street, Northwest (Seite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In our November 18, 1983 response to IE Inspection Report 50-400/401/83-25, we committed to having our corrective action for Violation A completed by December 1,1983 and corrective action for Violation E completed by November 30, 1983. This letter is to notify you that we will require additional . time to complete our commitments.

Violathn A (Part 1): All fasteners in MCC's under the scope of Regulatory Guide 1.29 were reinspected to ensure lightness under TP-28. . Discrepancies were noted and resolution was projected to be complete by December 1,1983. The vendor has been requested to evaluate the discrepancies and recommend corrective action. The vendo?'s resolution is expected by January 1,1984. In order to complete any rework which may be necessary, we will require until January 31, 1984 to be in full compliance with our commitment.

Violation A (Part 21: Procedural steps were imtiated to recheck the elevation of all MCC's under the scope of Regulatory Guide 1.29 against vendor, Ebasco, or CP&L approved design documents. This recheck was expected to be complete by December 1, '

1983. It has been determined that since there is no elevation specified by the vendor or Ebasco drawings for the MCC's, and the equipment pads were previously caecked by Civil CI, an elevation check for these MCC's is not considered necessary. WP-105 and TP-28 are being revised to reflect this. The approval of these procedure changes should be complete and full compliance achieved by January 1,1984.

Violation E: A Section Instruction was scheduled for issuance by November 30,1983, but due to review cycle delays and an identified concern to assure that Section Instructions l and Departmental Procedures are compstible, it is necessary to extend the expected completion date of this item from November 30, 1983 to January 31, 1984 to be in full compliance with our commitment.

Thank you for your consideration in this matter.

Yours very truly, fyf W R. M. Parsons Project General Manager RMP/sh Shearon Harris Nuclear Power Plant cc:

Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. B. C. Buckley (NRC)

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, e Mr. James P. O'Reilly NRC-147 bec: Mr. H. R. Banks Mr. C. S. Bohanan Mr. H. R. Bowles Mr. C. Carmichael (2)

Mr. O, S. Cashell Mr. N. J. Chiangi Mr. A. B. Cutter Dr. T. S. Elleman Ms. S. F. Flynn Mr. G. L. Forehand Mr. J. F. Garibaldi (Ebasco) -

Mr. J. L. Harness Mr. P. C. Hopkins Dr. J. D. E. Jeffries Mr. I. A. Johnson Mr. S. A. Laur Mr. L. I. Loflin Mr. R. E. Lumsden .

Mr. R. L. Mayton, Jr.

Mr. S. MeManus Mr. C. H. Moseley, Jr.

Mr. D. L. Nordstrom (LIS)

Mr. R. M. Parsons Mr. J. J. Sheppard Mr. Sheldon D. Smith Mr. A. C. Tollison Mr. R. A. Watson Ms. M. A. Wehver (Westinghouse)

Mr. J. L. Willis Mr. T. A. Baxter (Shaw, Pittman, Potts & Trowbridge)

Mr. M. F. Thompson

, File:. HI/A-2D File: H-X-0544 9

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P. O. Box 101, New Hill, N. C. 27562 October 21, 1983

, Mr. James P. O'Reilly NRC-130 United States Nuclear Regulatory Commission Region II

-101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of September 22, 1983, referring to RII: GFM/RLP 50-400/83-26-01, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.

It is considered that the corrective hetion taken is satisfactory for resolution of the item.

Thank you for your consideration in this matter.

Yours very truly, g[p A -

R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment ,

cc: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. d. C. Buckley (NRC) -

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~ Attachment to CP&L Letter of Response to NRC Report RH: GFM/RLP 50-400/83-26-01 Reported Violation:

10 CFR 50, Appendix B, Criterion II, as implemented by CP&L PSAR Section 1.8.5.2 and-CP&L Corporate QA Progrum Section 1.3, requires that activities such as piping -

installation inspections be conducted and controlled in accordance with detailed procedural requirements. -

Contrary to the above, on August 18, 1983, instances were found which indicated that piping installations were assigned to .be inspected without detailed procedures, appropriately controlled drawings, and indoctrination of inspection personnel as to inspection and documentation requirements. The inspection was to determine construction completion and acceptance of a section of service water piping system prior to turnover to the Operations Department. The deficient examples included: use of marked-up inspection drawings, unauthorized entries on inspection forms, inadequate procedural requirements, lack of established acceptance criteria, and inspections requested prior to work completion.

This is a Severity LevelIV Violation (Supplement II.D).

Denial or Admission and Reason for the Violation:

The violation is correct as stated. The conditions reported by the Inspector were caused primarily from merging "as-builting" functions into a quality inspection procedure. This resulted in differing interpretations of the required procedure content and manner of implementation.

Corrective Steos Taken and Results Achieved:

Site procedure TP-24, Alechanical Pipe Installation Inspection, has been revised as follows:

1. - As-built d?awings are no longer used in the inspection process. Acceptance of piping geometry and configuration is based upon criteria contained in approved design installation drawings.

2. The exposed piping inspection form, Exhibit 2, no longer requires the use of as-built drawings to be listed as part of the inspection package. Inspection personnel have been instructed that the exhibit is the responsibility of the mechanical engineer to prepare arid revise, if needed.

3. The reference to " spot" check in the procedure has been de!eted. The dimensional and geometrical checks performed by the inspection personnel are now full inspections.

4. The procedure clarifies that closure welds (versus all welding) are to be completed prior to inspection for dimensions and geometry.

5. The procedure no longer addresses the use of punch lists. The previous pur.ch list exhibit to the procedure has been deleted. TP-24 continues to invoke TP-17; Construction Inspection Nonconformance Control, for processing nonecnforming conditions.

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~ ~ Corrective Steps Taken to Avoid Further Noncompliance:

The r: vision to TP-24 eliminated the as-builting functions, and clarifies the procedure content to enhance proper interpretations and implementing actions.

Th3 mechanical engineering and inspection personnel have been instructed in the revised proctdure.

Drte When Full Compliance Will Be Achieved:

Full compliance was achieved on October 17,1983.

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f-)h 0.bY P. O. Box 101, New Hill, N. C. 27562 December 9,1983 Mr. James P. O'Reilly NRC-152 United States Nuclear Regulatory Commission Region 11 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of November 10, 1983, referring to RII: GFM/RLP 50-400/83-29, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.

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, g p :'s &

R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment ec: Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)

Mr. B. C. Buckley (NRC)

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Mr. James P. O'Reilly NRC-152 bec: Mr. H. R. Banks Mr. C. S. Bohanan Mr. H. W. Bowles Mr. C. Carmichael (2)

Mr. G. S. Cashell Mr. N. J. Chiangi Mr. A. B. Cutter Dr. T. S. Elleman Ms. S. F. Flynn Mr. G. L. Forehand Mr. J. F. Garibaldi (Ebasco)

Mr. J. L. Harness Mr. P. C. Hopkins Dr. J. D. E. Jeffries Mr. I. A. Johnson Mr. S. A. Laur Mr. L. I. Loflin Mr. R. E. Lumsden Mr. R. L. Mayton, Jr.

Mr. Ss McManus Mr, C. H. Moseley, Jr.

Mr. D. L. Nordstrom (LIS) hir. R. M. Parsons Mr. J. J. Sheppard Mr. Sheldon D. Smith Mr. A. C. Tollison M . R. A. Watson Ms. M. A. Weaver (Westinghouse)

Mr J. L. Willis Mr. T. A. Baxter (Shaw, Pittman, Potts & Trowbridge)

Mr. M. F. Thompson File: HI/A-2D giE.ll5EN~E~0S.$$];';A l

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. Attaenment to CP&L Lett:r cf Response to NRC Report RII: GFM/RLP 50-400/85-29 Reported Violation:

10 CFR 50, Appendix B, Criterion VIII, as implemented by PSAR Section 1.8.5.8 and CP&L Corporate QA Program Section 5.2, requires that materials used on "Q" class components and systems be purchased, issued and controlled in accordance with applicable codes, standards, specifications, criteria and other special requirements.

Contrary to the above, on August 24, 1983, it was found that non "Q" class bolting material was being used during the installation and assembly of a "Q" class system. The known affected systems are fire protection and radiation waste. This practice also involves bolting material used in other safety systems prior to April 1983.

This is a Severity Level IV Violation (Supplement II.D).

Denial or Admission and Reason for the Violation:

The violation is correct as stated.

The problem addressed by this violation consists of two parts:

1. Bolts purchased for "Q" applications are required to have a Certificate of Conformance from the vendor; however, since they are considered " commercial grade" items, source approval is not required. Bolts for non-Q applications require no Certificate of Conformance but in all other respects meet the same stanoards as "Q" bolts. Since Q and non-Q bolts are identical (if of the same type and reade),

they are not distinguishable beyond receipt under the existing program et the iiarris site.

2.

Bolts specified for some "Q" applications are manufactured with no distinruishing marks which would prevent them from being replaced by bolts of a lesser quality or grade which are also unmarked.

Corrective Steps Taken and Results Achieved:

1.

Site purchased bolts are considered acceptable for the specified application. While the specified documentation may be in question for bolts in'some "Q" applications, material quality is not a concern. Therefore, no further corrective action is necessary.

2.

Investigations are underway to determine the acceptability of bolting materials in the various disciplines, i.e., to determine whether bolts of a lower grace tnan required have been installed.

Corrective Steps Taken to Avoid Further Noncompliance:

1.

Only "Q" bolts will be purchased, therefore eliminating the need for distinguisning "Q" bolts from "non-Q" bolts.

2.

Site specifications are being revised where necessary to allow the substitunn of bolts which are marked as standard practice for those which are not already marked or easily identifiable by shape, manufacturer's mark, etc. Where substitutions are not allowed, bolts will be marked upon receipt. The approved marking will be a requirement for acceptance during installation inspection. Unmarked bolts are no longer being ordered.

,o ..

Date When Full Compliance Will Be Achieved:

The required revisions to site specifications are projected to be complete by February 1, 1984. In order to complete our investigation of installed bolts and corrective actions as necessary, it is projected that full compliance of all aspects will be achieved by June 1, 1984.

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(

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER & LIGHT COMPANY ) Dockct No. 50-261-OLA

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(H.B. Robinson Steam Electric Plant, ) ASLBP No. 83-484-03LA Unit 2) )

AFFID AVIT OF S. R. ZIMMERM AN W AKE COUNTY )

NORTH CAROLINA )

S. R. Zimmerman, being duly sworn according to law, deposes and says that he is Manager-Nuclear Licensing Section with Carolina Power & Light Company; that the supplements to Applicant's answers to Interrogatory Nos.1-30 and 1-31 contained in Supplement to Applicant's Answers to the Hartsville Group First Set of Interrogatories to Applicant, are true and correct to the best of his knowledge,information and belief, and that the sources of his information are officers and employees of Carolina Power & Light Company.

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j S. merman Sworn to,and subscribed before me this /7E day of January,1984. p"'"*

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