ML20008D966
| ML20008D966 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/23/1980 |
| From: | Miller H GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20008D965 | List: |
| References | |
| NUDOCS 8010240005 | |
| Download: ML20008D966 (9) | |
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September 23, 1980 United States Nuclear Regulatory Commission Office of Inspection and Enforcement
REFERENCE:
Region II - Suite 3100 RII: WAR 101 Marietta Street, NW 50-321/80-28 Atlanta, Georgia 30303 50-366/80-28 ATTENTION:
Mr. James P. O'Reilly Gentlemen:
Georgia Power Company's letter dated September 12, 1980, responded to the findings of an inspection conducted by W. A. Ruhiman on overall management of Plant Hatch programs.
Submitted herein are revisions of clarification and amplification for several of our responses contained in that letter. These revisions are made pursuint to a telephone con-versation between Mr. J. T. Beckham, Jr., Manager of Nuclear Generation and members of your staff on September 18, 1980.
i Should you have any further questions concerning this or p>evious letters, please contact Mr. Beckham at extension 3980.
Sincerely, I
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- o ITEM: B'(Continuid)
CATEGORY: INFRACTION 1
DESCRIPTION:
(Continued) 3.
The accepted QA Program (FSAR) Section 17.2.10 requires that inspectors shall be certified in accordance with applicable standards. Section 17.2 states that applicable standards for the Program are listed in Appendix A of the FSAR. Appendix A of the FSAR states that the Program complies with ANSI N45.2.6-1973. ANSI N45.2.6-1973, Section 2.2, requires that each person who verifies conformance of work activities to quality requirements shall be certified as being qualified to perform his assigned work. An assigned quality requirement, according to the accepted QA Program's commitment to ANSI N45.2.2, Section 5.2.1, is the Shipping Damage Inspection.
Contrary to the above, the licensee has not established an inspection program in accordance with the accepted QA Program in that there are no provisions to certify persons performing Shipping Damage Inspections.
Based on interviews and observations, the inspector did verify that those persons assigned this inspection activity were qualified to perform the function.
CPC RESPONSE:
ITEM:
B.3 Plant Hatch Procedures do not allow any materials or equipment designated for use in a safety-related system to be issued from the warehouse without proper QC inspection as described in Procedure HNP-821, "QC Work Inspection", and Procedure ERP-822, " Material Inspection Request". Because of this restriction, shipping damage inspections are not considered to provide a quality function.
They provide only an economic function.
Current commitments contained in the FSAR require compliance with ANSI N45.2.2 and ANSI N45.2.6 including Shipping Damage Inspections by qualified inspectors. A proposed change to the FSAR will be se' aitted requesting modification to the commitment of Section 5.2.1 of ANSI N45.2.2 in light of the more stringent QC inspections required by plant procedures. This QC inspection provides superior assurance of quality in safety-related equipment, and does not, therefore, reduce the effectiveness of the plan in any manner. Receipt in-spections will' continue to be made for commercial reasons, but will not be subject to the requirements of the ANSI standards subsequent to the approval of the proposed change. The expected date for submittal of the change to the FSAR description of the QA program is October 15, 1980. In the interim prior to approval of the proposed FSAR change, warehouse personnel will receive documented instruction in the proper performance of a receipt inspection per ANSI N45.2.2 Section 5.2.1.
This training is expected to be completed by October 31, 1980.
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ITEM: E CATEGORY: IhTRACTION DESCRIPTION:
As required by 10 CFR 50, Appendix B, Criterion VI, measures shall be established to control tr.e issuance of documents, including changes thereto, which prescribe all activities affecting quality.
T 2 accepted QA Program (FSAR) Section 17.2.6.1 states that an Administrative Assistant shall establish a system ensuring that the responsible supervisors receive current revisions of required documents.
Contrary to the above, as of July 16, 1980, measures had not been established for the control of vendor technical manuals, and changes thereto, referenced in safety-related plant procedures and necessary for carrying out the activities prescribed therein.
Specific examples include, but are not limited to:
(1) current revisions were not entered into the Control Room, Test Shop and Maintenance Shop copies of manual GEK 9690, Volume X, Part 3; (2) current revisions were not entered into the Maintenance Shop copy of the High Pressure Coolant Injection Pump, Instrument and Operations Instructions Manual; and, (3) current revisions were not entered into two of four Master File copies of the Main Steam Relief Valve Technical Manual.
GPC RESPONSE:
ITEM: E Manuals cited will either be revised or removed from plant files by October 1, 1980.
To ensure controlled documents are maintained current with the proper revisions, a document index is being prepared to identify all authorized drawings or manuals other than those which may be designated for information use only.
This index shall include, but shall not be limited to, all controlled documents referenced in safety-related plant procedures necessary for carrying out the actions prescribed therein. When completed, only those drawings and documents on the index will be authorized for use. These control documents will be updated by Records Management.
The expected.
completion date is March 1, 1981.
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o-ITEM: F (Continued)
CATEGORY: INFPACTION CPC RESPONSE:
ITEM: F.2.(Continued)
FDL l-80-3619: The corrective action as listed on the FEt was " installed
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original preamp..."..
The corrective action should have read, "A spare preamp was installeu and did not resolve the problem, therefore, the original preamp was reinstalled...".
No parts were used other than to troubleshoot the problem.
MR 1-80-3414: The work description listed on the }St was "lGM checked good. Found EGR bad. Mechanics changed EGR, see FDL l-80-3411".
The problem was resolved on the referenced MR and all parts used are listed on that MR.
No parts used for MR l-80-3414.
MR l-80-3511: The work description listed on t;. MR used the wording, " replaced door knob".
The word ' replaced' was used to indicate the original door knob, which had fallen from the door, was placed back onto the door.
Of the 25 MR's reviewed by the NRC inspector, only one is indicative of the problem as stated. A sample of approximately 500 MR's was taken by plant personnel subsequent to the inspection. Of these, approximately 200 required parts replacement; of those 200, only 4 d14 not list the parts. On one MR, the parts were traceable to an IMR through warehouse records. Parts for the other three MR's were, a shear key, a light bulb and a wire mesh for use on a door.
As a result of this review, the number of occurrences is considerably e
less than previously indicated, and does not represent generic failure to follow procedure, but rather oversight. To address this oversight problem, emphasis has been, and will continue to be, placed on the completion of all documentary requirements by maintenance personnel and the. review by QC and department supe.rvisors required on all MR's.
A detailed MR training program is being developed to instruct appropriate personnel on the requirements of the maintenance program.
This training is scheduled to be complete by November 1, 1980. Full com-pliance will be in effect subsequent to this date.
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. ITEM: I CATEGORY: DEFICIENCY DESCRIPTION:
As required by Technical Specification 6.8.3, each procedure required by Technical Specification 6.8.1 shall be reviewed periodically as set forth in administrative procedures.
Procedure HNP-814, " Procedure Reviews", Revision 6,~ dated April, 1980, Section B, states that:
" Biennial reviews shall be conducted within the month specified by the Records Department".
Contrary to the above, procedures required by Technical Specification 6.8.1 are not periodically reviewed as set forth in HNP-814 in that of the 700 procedures specified by the Records Department to be reviewed in the months of February, March, April, May and June of 1980, 540 were not reviewed in the month specified and 473 remained unreviewed as of July 10, 1980.
GPC RESPONSE:
ITEM: I Plant management is in the process of researching the status of procedure reviews. To date, no procedures have been discovered which have exceeded the maximua two-year review requirement of the Technical Specification.
In order to prevent this in the future, certain procedural changes are being considered. These changes include.the establishment of a grace period (total time span between reviews including grace period will not exceed two years) and organizational changes to allow a more streamlined review process. Necessary draft procedure changes will be completed by October 1, 1980.
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ITEM: J CATEGORY: DEFICIENCY DESCRIPTION:
As required by 10 CFR 50, Appendix B, Criterion IV, measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents.for pro-curement of mat.erial, equipment, and services. The accepted QA Program (FSAR) Section 27.2, states that Program is established, in part, by compliance with ANSI N45.2.13-1976. This standard defines " procurement document" to include purchase requisitions.
Section 3.1 requires that changes to procurement documents shall be subject to the same degree of control as utilized ~in the preparation of the original document.
Contrary to the above the licensee has not established measures to assure that requirements are included in procurement documents in that there are no provisions for controlling changes made to purchase requisitions.
The inspector determined by interview with responsible managers, that changes to purchase requisitions are made after these documents have been trans-mitted to the Company Offices for the plant site and without the same degree of control utilized in the documents' preparation.
GPC RESPONSE:
ITEM: J Georgia Power and Piant Hatch have been utilizing the definition of procurement document from ANSI N45.2.10, which is a " contractually binding document". Under this definition Georgia Power purchase orders, and not purchase requisitions, are subject to Qualiry Assurance programs.
In the interim, until the FSAR for Plant Hatch can be revised to clarify the apparent conflict between the ANSI N45.2.10 and ANSI N45.2.13 definitions of procurement documents, the Supervisor Nuclear Procurement Standards will assure that significant revisions (more than editorial changes) to requisitions are re-reviewed by appropriate members'of the Plant staff or originating organization as applicable in accordance with ANSI N45.2.13.
The scheduled date for submittal of the FSAR change is October 15, 1980.
The interim measure is in effect currently.
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ITEM: K CATEGORY: DEFICIENCY DESCRIPTION:
As required by 10 CFR 50, Appendix B, Criterion XVII, records shall be maintained to furnish evidence of activities affecting quality and requirements cc7cerning record location. The records shall include the results of inspections. The : ; gicJ QA rrogram (Fdar) sectlen 17.2.17 requires that records be prepared to document activities effecting quality and lists inspection results as a typical record. The Section further requires that written procedures control the storage of recceds.
Contrary to the above, records _of inspections were not maintained and requirements concerning record location were not established in that:
(1) records of shipping damage inspections are not maintained; and, (2) Unit 1 and 2 records are stored in the Georgia Power Company Block House on site and this structure is not described as a record storage location in the licensee's procedure KNP-820, " Plant Records Management", Revision 10, dated 8/79.
GPC RESPONSE:
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ITEM:
K.1 Plant Hatch procedures do not allow any safety-related materials or equipment to be issued from the warehouse without proper QC inrpection as described in Procedure HNP-821, "QC Work Inspection" and Procr. dura HNP-622, " Material Inspection Request". Because of this restriction, documents generated as a result of shipping damage inspections are not considered to provide quality-related data. The data provided by the shipping damage inspections are economic in nature. The quality-related data are i
generated as a result of HNP-821 and HNP-822.
Current commitments contained in the FSAR require compliance with ANSI N45.2.2 and ANSI N45.2.6 including Shipping Damage Inspection reports.
A proposed change to the FSAR will be submitted taking exception to the provisions of Section 5.2.1 of ANSI N45.2.2 in light of the more stringent QC inspections required by plant procedures. The QC in-i spections provide superior assurance of quality in safety-related
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equipment in a documented manner, and do not, therefore, reduce the effectiveness of the plan in any manner.
The expected date for submittal of the change to the FSAR description of-the QA program is October 15, 1980.- In the. interim, prior to the approval of the proposed FSAR change, the receipt inspection results will be documented on the Material Inspection Request. This will be performed on safety-related equipment by warehouse personnel. This interim measure will be implemented by October 31, 1980.
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ITEM: K (Continutd)
CATEGORY: DEFICIENCY.
GPC RESPONSE:
ITEM:. K.2 All records presently stored in the blockhouse will be moved to the plant record storage area. Additional cabinet space will.be provided for these
-documents. This action will be completed by November 1, 1980.
Plant management has instructed Records Management Supervisor not to utilize the blockhouse for records storage. Future plans call for removal of the blockhouse.
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l ITEM: L CATEGORY: DEFICIENCY DESCRIPTION:
As re uired by 10 CFR
, Appendix B, Criterion XIII, measures sFall be established to control he storage of material and equipment to pravent damage. The accepted QA Program (FSAR) Section 17.2 states that the Program will follow Standards listed in Appendix A.
Appendix A states that the licensee's Program will meet the requirements of ANSI N45.2.2-1972.
ANSI N45.2.2-1972, Sections 3.5.1 and 6.4.2 require that threads and weld end preparations shall be protected with caps or plugs.
Contrary to the above, measures were not established to control the storage of materials and equipment to prevent damage to weld end preparations in that:
(1) the licensee had no program to install caps or plugs as required by the Program's commitment to ANSI N45.2.2; and, (2) the inspector found numerous stainless steel elbow, with weld end preparations, purchased under order PEH2-6442 that were stored without the required caps or plugs.
None of the stored elbows had any observable damage to the weld end preparations.
GPC RESPONSE:
ITEM: L A review of the FSAR commitment to ANSI N45.2.2 is being conducted to determine if modifications to previous commitments should be requested.
The modifications requested will be made considering the procedures which now require a QC inspection prior to use in a safety system. After the modificarn approvals are received from the NRC, the necessary changes will oe implemented to provide for control of the storage of materials and equipment consistent with the new commitments.
The review of the commitments will be complete by December 31, 1980.
The changes in the program required based on the modifications to commit-ments will be implemented within three months of receiving the approval for the change in the FSAR commitment.
In the interim period, QC hold-tags or the required protective measures will be installed to ensure that no damaged material is used in a safety-related function. On that material on which protective devices are installed, the material will be inspected prior to installation of the protective device. On that material in which a QC hold-tag is placed, the material will be inspected for damage prior to use in a safety system. This interim measure will be implemented by October 31, 1980.
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