ML18005A732

Responds to NRC Re Violation B Noted in Insp Rept 50-400/88-34.Corrective Actions:Methods by Which Audits Scheduled & Documented Made & Copies of Completed Audit Forms Retained Until Original Received by Document Svcs

ML18005A732
Person / Time
Site:	Harris
Issue date:	12/19/1988
From:	Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-654 HO-880245-(O), NUDOCS 8812270134
Download: ML18005A732 (6)

Text

ACCELERATED DISTI+UTION DEMONSTRXTN SYSTEM

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR: 8812270134 DOC. DATE: 88/12/19 NOTARIZED:

NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION WATSON,R.A.

Carolina Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 881122 ltr re violations noted in Insp Rept 50-400/88-34.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse NOTES:Application for permit renewal filed.

D 05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB NRR SHANKMAN,S NRR/DLPQ/QAB 1 0 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 COPIES LTTR ENCL 1

1 2

2 1

1 1

1 1

. 1 1

1 1

1 1

1 1

1 1

1 RECIPIENT ID CODE/NAME BUCKLEY,B AEOD DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR ll NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OE~II;EB,J KGMILE 02 COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 2

2 1

1 1

1 1

1 ERNAL: LPDR NSIC 1

1 NRC PDR 1

1 RES L MARTIN 1 D 1

1 1

1 R

I D

h NOI,E 10 ALL "RIDS" RECIPIENTS:

PLEASE HELP US K) REDUCE WASTE!

CXNZACr THE DOCUMENT CONGEAL DESK, ROOM Pl-37 (EXT. 20079)

KO EZJMZNATE YOUR NAME FMH DIPHK8UTIQN LISTS H)R DOCUMENTS YOU DONiT NEED)

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 25 ENCL 25

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I CPKK Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0. Box 165 New Hill, North Carolina 27562

<DFC i9 i988 File Number'SHF/10-13510E Letter Number:

HO-880245 (0)

NRC-654 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO ~ 50-400 LICENSE'O ~ NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In reference to your letter of November 22,

1988, referring to I.E. Report RII:

50-400/88-34, the attached is Carolina Power 6

Light Company's reply to violation "B" identified in Enclosure l.

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

Thank you for you consideration in this matter.

Very truly yours, MGW:acm R. A. Watson Vice President Harris Nuclear Project Attachment cc'Messrs.

W. H. Bradford (NRC-SHNPP)

B. C. Buckley (NRC)

M. L. Ernst (NRC) g812270134 881219 POR ADOCy O ~t tOn4OO I:J F'itC

'MEM/HO-8802450/1/Osl

k 0

Attachment to CPRL Letter of-Res onse to'RC I.E.

Re ort RII:

50-400 88-34 Violation B

Re orted Violation.'0CFR50 Appendix B, Criteria V, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of,a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings'dditionally, the licensee's administrative procedure, AP-021, Caution Tag Procedure, Rev.

1, Section 5.4'1, states:

"Monthly, the Operating/Radwaste Supervisor shall initiate an administrative audit of the caution tag logs."

Contrary to the

above, the licensee failed to produce documentation indicating that caution tag audits had 'een conducted between the dates of May 29,

1988, and August 31, 1988.

This is a Severi,ty Level IV violation (Supplement I).

f Denial or Admission and Reason for the Violation.'he violation is correct as stated.

It was the practice to conduct the audit during the applicable month without regard to the number of days between audits.

It was acceptable to perform an audit early in anticipation of large outage work loads.

Thus, it was expected by CP&L that only one audit was conducted during the noted time frame.

For this audit, a search was conducted to locate the missing audit documentation.

Although Operations personnel remembered seeing the missing

form, no record could be found to satisfy the requirement for July 1988.

Based on discussions with operations personnel, it is believed that the records documenting the audit were misplaced prior to being submitted to the vault for retention.

Corrective Ste s Taken and Results Achieved:

Not applicable; see Corrective Steps Taken to Avoid Further Violations.

Corrective Ste s Taken to Avoid Further Violations:

Changes in the method by which the audits are scheduled and documented have been made.

The audits are now scheduled for. a specific day of the month instead of allowing performance of the audit anytime during the month.

This will increase the awareness of responsible personnel to the requirement for the audits MEM/HO-8802450/2/OS1

Corrective Ste s Taken to Avoid Further Violations:

(continued)

With regard to record retrievability, copies of the completed audit forms are now being retained by the Op'erations Unit until verification is received that the original has been received by Document Services.

Date When Full Com liance was Achieved:

The above actions were implemented as of December 6,

1988.

MEM/HO-8802450/3/OS1