ML19260E044
| ML19260E044 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/02/1979 |
| From: | Eric Turner HOUSTON LIGHTING & POWER CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19260E041 | List: |
| References | |
| ST-HL-AE-388, NUDOCS 8002130182 | |
| Download: ML19260E044 (5) | |
Text
'l Houston h
r I
company Electric Tower f
RO. Box 1700 l)
Houston. Texas 77001 November 2, 1979 ST-HL-AE-388 SFN: C-0S70 Mr. W. C. Seidle Reactor Construction 6 Engineering Support Branch U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Pla::a Drive, Suite 1000 Arlington, TX 76012
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FINDINGS DOCKET NOS. 50-498/79-13 AND S0-499/79-13
Dear Mr. Seidle:
The following are Houston Lighting S Power Company's (HLSP) response to the items of noncompliance identified in IE Inspection Report Numbers S0-498/79-13 nd 50-499/79-13 dated October S 1979.
A.
Failure to Follow Procedures for Maintaining Pittsburgh-Des Moines (PDM) JA Manuals Corrective Action The PDM Corporate Field QA Manual is a generic document and was not written specifically for the South Texas Project. The intent of the requirement in Section 12 for a semiannual or more frequent review is when the Manual is used on a project that does not have a speci-fic code and addenda.
In the case of the South Texas Project, our Code and Addenda as stated u the Final Safety Analysis Report (FSAR) is the 1971 Edition of the Code with the Winter 1973 Addenda. The Manual is currently being revised to make the intent of this re-quirement more precise.
1.
Manual Supplements are issued to delineate additional requirements applicable to a specific site. The 8002130
Houston Lg;hting & IWer Company Mr. Seidle November 2, 1979 Page Two transmittal and acknowledgment letter used to transmit a manual supplement, and the manual supplement, describe to the manual holder how the supplement is to be integrated into the manual after receipt.
2.
Criterion V of 10CFR50, Appendix B, requires that activities affecting quality be accomplished in accordance with written instructions, procedures or drawings.
PDM accomplished this requirement, as applied to auditor qualifications, by compliance to specific procedures written for this purpose.
These procedures are maintained by the PDM Division QA bbnager and are available for information upon request.
It is not a requirement that this informa-tion be stated in the QA bbnual and it is PDM's pre-ference to maintain separate procedures for auditor qualification requirements.
3.
QA Manuals number 67 and 150 have had the additional documents removed. Manuals number 132 and 177, which were deficient, have been reviewed and are up-to-date.
The manual holders for manuals number 132 and 177 had received the transmittals, however, had failed to update their manuals.
Recurrence Control The PDM Corporate QA Manual is currently being revised to clarify the intent of the requirement for a semiannual review. This manual has been submitted to Brown 6 Poot for approval.
B.
Failure to Follow Procedures for Conduct of PDM Site Audits Corrective Action 1.
PDM commenced with operation in August of 1976.
PDM conducted two mini audits over specific sections of the Manual in 1976. They were 76-208 on 9/16/76 and 76-212 on 11/11/76.
In January of 1977, audit 77-201 was conducted. This was a full audit of all sections of the Manual applicable to site operations at the time.
In April of 1977, audit 77-202 was conducted.
Houston Lufting & Pom Company Mr. Seidle November 2, 1979 Page Three This was also a full audit of applicable sections of the Manual.
In May of 1977, audit 77-203 was conducted. Again, a full audit of applicable se -
tions was performed. All of these audits were per-formed within 10 months of commencement of work at the South Texas Project Site by PDM.
Cection 13.0 of the PDM QA Manual requiring annual audits has been fulfilled.
2.
In that the PDM QA Manual is a Corporate Manual, all documentation is not maintained at the South Texas Project Site, however, copies of the men-tioned corrective action statements signed by QA Management have been sent to the South Texas Site and are available for review.
3.
a.
The audit results are maintained at the Corporate headquarters, however, copies of these results showing they have been reviewed by responsible management have been sent to the Site and are available for review.
b.
Per QA hhnual, paragraph 13.5, "The Division QA Manager shall initiate re-audits as required to assure correction of deficiencies". The re-sults shall be reported to the Division Chief Engineer. Audit 77-202 was case of such audit, being deemed as required by the Division QA Manager, and with results reported at the Divi-sion Engineer.
In the cases of other audits, the Division QA Manager has not deemed re-audits as necessary. This is in compliance with Section 13.0 of the QA Manual.
c.
Since 1977, PDM Drawing Control has been a recurring deficiency as noted in several audits.
This problem was caused because of difficulties in coordinating the PDM Drawing Control System with the Brown 6 Root Drawing Control System.
Another deficiency of similar nature identified in 1978 led to both groups using the Brown 6 Root system and classifying the PDM system as "information only".
Another drawing control deficiency as noted in audit 79-203 was in error and is apparent after reading the Audit Deficiency Report.
Houston ugit[ng & Pour Company Mr. Seidle November 2, 1979 Page Four Recurrence Control PDM is following Section 13.0, Audits, of their Manual therefore no recurrence control is required.
C.
Failure to Delineate Organizational Change in PDM QA Manual Corrective Action The new Manual has been submitted to Brown 6 Root for approval on November 1, 1979, which will correct the noted deficiency in the organization chart.
Recurrence Control This organizational change was made approximately two weeks prior to the NRC Audit and their hhnual had not been revised to reflect this change.
A major rewrite of their Manual was to be made in the near future and they had held back waiting for the new revision to make the necessary changes.
PDM has been reminded to be more timely in the future when changes to their Manual are necessary.
D.
Failure to Maintain Completed Audit Checklists in Audit Files Corrective Action As noted in U.S. Nuclear Regulatory Commission Inspection and Enforcement Manual:
A deficiency is an item of noncompliance in which the threat to the health, safety, or interest of the public or the common defense and security is remote; and no undue expendi-ture of time or resources to implement correc-tive action is required; and deficiencies in-clude such items as noncompliance with reccrds, posting, or labeling requirements which are not serious enough to amount to infractions.
Although there was no "X" placed in the satisfactory column of the checklist, the " Comments" column slowed the require-ments on the checklist were audited and the activity was acceptable.
Houston is) ting & liwr Company Mr. Seidle November 2, 1979 Page Five Recurrence Control Personnel have been reminded to incluCe a copy of the completed audit checklists in the specific audit folders.
E.
Failure to Destroy or Stamp a Deleted Procedure Corrective Action The holder of the Brown 6 Root, South Texas Procedures hbnual (ST-QAP) number 29, had chosen to retain a de-leted procedure, number ST-QAP-5.12, as a persona; reference document.
This was permissible by ST-QAP-2.2 providing the holder stamps the procedure as " VOID" or
" SUPERSEDED". The manual holder had inadvertently failed to stamp the procedure as required by ST-QAP-2.2.
Recurrence Control This is considered as an isolated oversight and procedure number ST-QAP-5.12 has been removed from manual number 19 and destroyed.
Very truly yours, o
. aNw E. A. Turner, Vice President Power Plant Construction 6 Technical Services EAT:rka cc: Messrs. G. W. Oprea, Jr.
R. A. Frazar D. G. Barker M. L. Borchelt (CPL)
J. W. Moore (CPL)
J. B. Poston (CPS)
R. C. Mecke (CPS)
R. L. Hancock (COA)
M. C. Nitcholas (COA)
T. D. Stanley G. B. Painter M. D. Schwarz (Baker 6 Botts)
H. S. Phillips (NRC)
J. R. Guerts (B6R)
C. W. Vincent (B6R)
.