IR 05000348/1985021
| ML20133N671 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/23/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R ALABAMA POWER CO. |
| References | |
| NUDOCS 8508130576 | |
| Download: ML20133N671 (4) | |
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July 23,1985 Alabama Power Company ATTN: Mr. R. P. Mcdonald Senior Vice President-Nuclear Generation P. O. Box 2641 Birmingham, AL 35291 Gentlemen:
SUBJECT:
REPORT NOS. 50-348/85-21 AND 50-364/85-21 Thank you for your response of June 19, 1985, to our Notice of Violation issued on May 21, 1985, concerning activities conducted under NRC Operating License Nos. NPF-2 and NPF-8. Additional information was also provided for the violation during telephone conversations conducted between Messrs. A. Belisle, F. Cantrell, and R. Walker of my staff and Mr. J. McGowan of your staff.
These conversa-tions occurred July 2 and July 10, 1985, respectively.
We have reviewed your response to the violation and have concluded, for the reasons presented in the enclosure to this letter, that the violation occurred as stated in the Notice of Violation.
We will examine the implementation of your corrective action during future inspections.
Should you have any questions concerning this letter, we would be happy to meet with you and discuss the matter further.
Sincerely, ORIGINAL SciED BY!
j. NELSON GRACE J. Nelson Grace Regional Administrator Enclosure:
Staff Evaluation of Licensee Response cc w/ encl:
W. O. Whitt, Executive Vice President J. D. Woodard, Plant Manager W. G. Hairston, III, Manager, Nuclear Engineering and Technical Support J. W. McGowan, Manager-Safety Audit and Engineering Review H. O. Thrash, Manager, Nuclear Operations and Administration W. G. Ware, Supervisor-Safety Audit and Engineering Review bec w/ encl:
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Alabama Power Company
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NRC Resident Inspector E. Reeves, Project Manager, NRR Document Control Desk State of Alabama
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ENCLOSURE STAFF EVALUATION OF LICENSEE RESPONSE l
DATED JUNE 19, 1985
Our assessment of your reasons for denial of violation 50-348, 364/85-21-01 is as follows:
a.
You make the following statement in your denial:
"This violation has been classified as a Severity Level V violation.
However, 10 CFR Part 2, Appendix C defines a Severity Level V violation
as having ' minor safety or environmental concerns.'
Alabama Power
Company contends that this violation has no safety or environmental concerns; therefore, it is not in fact a iiolation as defined in
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10 CFR."
10 CFR 50 Part 2, Appendix C states that a Notice of Violation is a written notice setting forth one or more violations of a legally binding require-
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ment.
A legally binding requirement has not been adhered to; consequently,
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a violation is warranted.
This violation does have minor safety signifi-l cance; therefore, a Severity Level V categorization was appropriate.
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b.
You make the following statement in your denial:
"The audit reports are in full compliance with ANSI N45.2.12 since the i
ANSI phrase ' persons contacted during the pre-audit, audit, and post
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audit activities' does not necessarily require that all persons
contacted be listed individually by name.
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"In order to maximize the effective utilization of audit reports while complying with regulatory commitments to the fullest extent, Alabama l
Power Company contends that ' persons contacted' refers to persons who were a source of assistance during the audit or persons with whom meaningful communication occurred concerning potential audit findings.
This is generally supervisory and other such key personnel."
The accepted QA program (FSAR 17.2.18) states that an audit system that complies with the requirements of ANSI N45.2.12-1974 shall be described in approved written plans, policies, and procedures.
Sections 4.4 and 4.4.3 require that an audit report provides persons l'
contacted during audit activities.
SAER-AP-06, Audit Implementation, Revision 9, does not clarify ANSI N45.2.12-1974 Sections 4.4 and 4.4.3.
SAER-AP-06, Appendix A, does, however, contain a column heading, Audited Organization Representatives.
This heading is common for pre-audit conference, conduct of audit, and post-audit conference. The Alabama Power
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i-Company interpretation of ANSI N45.2.12-1974 requirements did not appear to be understood by your auditors when they were que.itioned by our inspector.
Further, these interpretations are not specifically delineated in the accepted QA program or sub-tier implementing procedures.
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Enclosure
c.
You included a listing of the following actual excerpts from Alabama Power Company audit reports cited:
Audit Reports Audit Date 84-10 3/28 - 4/03/84
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84-10 4/04 - 4/11/84 84-09 3/05 - 4/03/84 84-09 3/21 - 3/27/84 84-09 3/26 - 3/30/84 84-08 3/06 - 3/16/84 84-07 2/08 - 3/16/84 84-02 1/23/84 Audit 84-09 dated 3/26 - 3/30/84 and audit 84-02 dated 1/23/84 do not reflect the Alabama Power Company position stated in the June 19, 1984, submittal.
In conclusion, it is our position that the violation occurred and that the appropriate severity level was assigned.
Implementation of the Alabama Power Company policy regarding naming of individuals in audit reports will correct this violation.
Proceduralizing this policy would assure continued compliance.
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