IR 05000321/1979033

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IE Insp Repts 50-321/79-33,50-366/79-37,50-424/79-16 & 50-425/79-16 on 791105-06,08 & 13.Noncompliance Noted: Failure to Adequately Implement Requirements of 10CFR21
ML19308C697
Person / Time
Site: Hatch, Vogtle  
Issue date: 11/26/1979
From: Brownlee V, Hunt M, Murphy C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19308C679 List:
References
50-321-79-33, 50-366-79-37, 50-424-79-16, 50-425-79-16, NUDOCS 8002010146
Download: ML19308C697 (5)


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UNITED STATES E

i NUCLEAR REGULATORY COMMISSION

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101 MARIETT A ST., N.W., SUITE 3100 j'

ATLAN TA, GEORGIA 30303 Report Nos. 50-321/79-33, 50-366/79-37, 50-424/79-16 and 50-425/79-16 Licensee:

Georgia Power Company 270 Peachtree Street Atlanta, Georgia 30303 Facility Name: All Georgia Power Company nuclear facilities in operation and under construction Docket Nos. 50-321, 50-366, 50-424, and 50-425 License Nos. DPR-57, NPF-5, CPPR-108 and CPPR-109 Inspection at Georgia Power Company General Offices, Atlanta, Georgia Southe n ompany Services, Inc., Birmingham, Alabama Inspectors:_ ~

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V. L rown'l ee ate ' Signed

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M. D. flunt Date r,b,

[/IY Approved by:

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C. E. Murphy,' Chitif r RC&ES Branch

/ Dat'e Signed SUMMARY Inspection on November 5, 6, 8, and 13, 1979 Areas Inspected This special, announced inspection involved 28 inspector-hours at the General Offices in review of procedures cad controls adopted by Georgia Power Company to implement the requirements of 10 CFR Part 21.

Results One item of noncompliance involving adequacy and implementation of procedures to implement the requirements of 10 CFR Part 21 was identified [ Infraction - E. I.

llatch Part 21 procedures - Paragraphs 5.c and 5.d. ].

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DETAILS 1.

Persons Contacted Licensee Employees

  • W. A. Widner, General Manager of Nuclear Operations
  • R. W. Staffa, Manager, Quality Assurance
  • C, W. Hayes, Project Quality Assurance Manager (Vogtle)
  • C. B. Boatwright, Senior Quality Assurance Engineer (Hatch)

Other Organizations Southern Company Services, Inc. (SCS)

D. M. Crowe, Manager of Generic Licensing P. Herrmann, Generic Licensing Engineer

  • Attended exit interview 2.

Exit Interview An exit interview was held with Mr. W. A. Widner, General Manager of Nuclear Operations on November 6, 1979, and with R. W. Staf fa, Manager of Quality Assurance on November 13, 1979. The Georgia Power Company (GPC) representa-

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tives were apprised of the scope of inspection and inspection findings as noted in this report.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

Compliance with 10 CFR 21 References:

a)

Georgia Power Company (GPC), Policy Statement and 10 CFR 21 Departmental Procedure Guidance, June 30, 1977 b)

GPC Procedure No. QA-04-02, Significant Deficiency Reporting (10 CFR 50.55(e)), Rev. 4, May 22,1979

c)

GPC Generating Plant Construction Procedure GD-A-06, Reporting of Defects and Noncompliance in Accordance with 10 CFR Part 21, Rev.1, September 24, 1978

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d)

VNP Project Policy Manual, Part C, Quality Assurance Section 2, 2.6 Reporting 10 CFR 50.55(e) and 10 CFR 21 occurrences, Rev. 3, July 20,1978 e)

Southern Company Services (SCS),

Inc., Engineering Policies and Procedures No. 4-21, Identification, Eval-uation, and Reporting of Significant Deficiencies (Nuclear only), Rev. 6, January 31, 1978

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Southern Company Services, Inc., Engineering Policies and Procedures No. 4-22, Identification Evaluation, and reporting of Deviations, Possible Defects, and Possible Failures to Comply (Nuclear only), Rev. 3, September 7, 1979 g)

Bechtel VNP Project Reference Manual, Part D, Procurement, Section 5, Reporting of Defects and Noncompliance - NRC Regulation 10 CFR 21, Rev. 2, August 1,1977 h)

Bechtel VNP Project Reference Manual, Part A, Mar.agement,

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Section 10, Reporting of Substantial Safety Hazard Defects, Noncompliances, and Significant Deficiencies, Rev. O, September 13, 1978 i)

Bechtel VNP Project Reference Manual, Part C, Engineering, Section 28, Reporting of Substantial Safety Hazard Defects, Noncompliances, and Significant Deficiencies, Rev. O, October 13, 1978 JJ E. I. Hatch Nuclear Plant Procedure HNP-425, Deviation Report, Revision 1, June 2,1978 k)

E. I. Hatch, Nuclear Plant Procedure HNP-456, Reporting of Defects and Noncompliance, Rev. 1, October 10, 1978 1)

SCS correspondence dated November 7, 1979, addressing embed plate Part 21 evaluation.

a.

General The purpose of this inspection was to ascertain whether GPC and appro-priate responsible officers had established and implemented procedures and other instructions to ensure compliance with 10 CFR 21 requirements relative to reporting of defects and noncompliances. Part 21 requires that each organization, such as GPC, that constructs, owns or operates facility which involves " basic components" as defined under Part 21 a

is subject to its regulations.

GPC and its responsible officers must therefore ensure compliance with requirements of Part 21 as specified in Section 21.6, for posting; 21.21.(a), for procedures; 21.21.(b), for notification and written

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-3-reports to the Commission; 21.31, for the inclusion of appropriate references in procurement documents; and 21.51, for preparation and maintenance of records.

Inspector determinations are based on the requirements of 10 CFR 21 as clarified by staf f positions in NUREG-0302, Revision 1.

As a result of this inspection, the inspectors identified one (1)

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item of noncompliance discussed in paragraphs 5.c and 5.d below, b.

Construction and Engineering Services (1) Program Review The inspectors reviewed the above noted controlling procedures noted in References:

a), b), c), d), e), f), g), h), i), and 1).

The inspectors concluded that procedures have been established for the control of posting (21.6), evaluating deviations [21.21(a)],

informing the director [21.21(a)], notification and written reports to the Commission [21.21(b)], assure that procurement documents specify that provisions of 10 CFR Part 21 will apply when applicable (21.*1), Maintenance of records [21.51(a)], and disposition of reco:Js [21.51(b)].

GPC performs initial review of deficiencies, defects and noncon-formances to determine need for further evaluation relative to Construction Deficiency Reports (CDR) and Part 21 reporting. SCS performs the detailed evaluations for GPC.

(2)

Implementation The inspectors held discussions with personnel noted in paragraph I above and examined the areas noted in paragraph 5.b.(1) above. The inspectors determined that those personnel interviewed were knowl-edgeable of Part 21 requirements, the controlling procedures, and the implementation of the controlling procedures.

During discussions with responsible personnel and review of the procedures the inspectors identified that SCS procedure 4-21, paragraph 8.a does not clearly delineate the requirement for evaluating deviations [(21.21(a)(1)] as required by 10 CFR 21.

GPC and SCS representative concurred that clarification is needed and agreed to revise and issue the procedure during January 1980.

This matter is identified as inspector followp item No. 424/79-16-01 and 425/79-16-01, SCS Procedure 4-21 Revision.

The inspectors concluded that no safety issues are involved with the identified inspector followup item due to the early stages of construction and GPC presenting the inspectors with objective evidence that Part 21 evaluations are being performed on signficant items identified.

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Operating Department (1) Program Review The inspectors reviewed the above noted controlling procedures in References:

a), j), and k), and verified that procedures have been established and address posting (21.6), evaluating deviations 121.21(a)], informing the director [21.21(a)], assuring that the director will inform the Commission [21.21(b)], assure that pro-curement documents specify that provisions of 10 CFR Part 21 will apply when applicable (21.31), Maintenance of records [21.51(a)]

and disposition of records [21.21(b)].

(2)

Implementation The inspectors held discussions with personnel noted in paragraph 1 above and examined the areas noted in paragraph 5.c.(1) above.

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During the inspection it could not be demonstrated that Part 21 evaluations were being implemented at E. I. Hatch Plant as required by Part 21.21(a)(1). Consequently, the informing of the responsible officer of defects and failure to comply relating to substantial safety hazards [21.21(a)(2)], NRC notification [21.21(b)(3)], and record maintenance (21.51) requirements of Part 21 could not be met.

The inspectors were informed by GPC representatives that the findings were correct. The representatives informed the inspec-tors that a complete procedure review would be accomplished to assure that all the requirements of Part 21 were addressed and that the procedures would be revised as needed and implementation of those procedures would be verified by GPC.

d.

Findings GPC has not fully developed and implemented appropriate procedures at E. 1. Hatch to provide guidance and evaluation criteria to assure that deviations are evaluated (21.21(a)(1)); the director or responsible officer is informed of defects and failures to comply relating to substantial safety hazards (21.21(a)(2)); the written report to the Connission contains the required information [21.21(b)(3)]; and that the required records are maintained (21.51). This matter is identified as an item of noncompliance, infraction level 321/79-33-01 and 366/79-37-01, E.1. Hatch Part 21 Procedures.