ML19274C751

Responds to 780922 NRC Ltr Re Violation Noted in Inspec Rept #50-466/78-02.Corrective Actions:Unapproved Draft Procedures Reviewed & Other Procedures Will Be Revised

ML19274C751
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/23/1978
From:	Eric Turner HOUSTON LIGHTING & POWER CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19274C748	List: ML19274C751
References
AC-HL-AE-264, NUDOCS 7811170090
Download: ML19274C751 (5)

Text

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. Houston r

Company October 23, 1978 Electric Tower AC-IIL-AE-264 PO Box 1700 Houston. Texas 77001 Mr. W. C. Seidle, Chief Reactor Construction and Engineering Support Branch U.c Nuclear Regulatory Commission Ofrice of Inspection and Enforcement, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012

SUBJECT:

RESPONSE TO NRC INSPECTION FINDINGS ALLENS CREEK NGS - UNIT NO. 1 DOCKET NO. 50-466/RPT. 78-02

Dear Mr. Seidle:

The following is our response to the deviations identified in IE Inspection Report No. 50-466/Rpt. 78-02, dated September 22, 1978:

1. Failure to Provide an Approved Procedure for Processing Field Construction Contracts A. Action to Correct Problem The unapproved draft procedule, ASP-4, " Field Construction Contracts", is being reviewed and approved. The activities of the Ebasco con-struction field office have been reviewed and no condition adverse to quality was identified because of the use of draft procedures.

B. A tion to Preclude Recurrence Ebasco Construction has been informed to obtain complete approval of a procedure before perform-ing any activities covered by that procedure.

Ebasco Construction's activities will be monitored to ensure compliance to this requirement.

C. Date Action Will Be Completed and Full Compliance Achieved A

The procedure is scheduled to be approved by November 10, 1978.

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Houston Ligpting & Power Company Mr. Seidle October 23, 1978 Page Two

2. Failure to Prescribe Vendor Surveillance Report Format A. Action to Correct Problem The procedure, QAP-3, " Procedures for Vendor Surveillance", will be revised to include as an attachment, the vendor surveillance report format.

B. Action to Preclude Recurrence Procedures will be reviewed to ensure that referenced forms are attached or included in the procedure or a referenced procedure.

C. Date Action Will Be Completed and Full Compliance Achieved The procedure has been revised and will be issued by November 1, 1978. The review of the other procedures has been completed.

3. Failure to Provide Training Requirements in Departmental Procedures A. Action to Correct Problem The eight departmental procedures referenced in your report will be revised to include the requirement for quality assurance indoctrina-tion training. Implementation will begin im-mediately.

Section 1.5.3 of the QAPM will be revised to reficct the method of technical training to be used within HLSP.

B. Action to Preclude Recurrence Procedures will be reviewed to ensure that QA indoctrination training is adequately included.

The departmental managers or supervisors are required by procedure to not.fy the QA Manager when QA indoctrination training sessions are needed for their personnel.

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liouston tighting & Power Company a

Mr. Seidle October 23, 1978 Page Three C. Date Action Will Be Completed and Full Compliance Achieved The eight departmental procedures referenced in your report and Section 1.5.3 of the QAPM will be revised and approved by November 10, 1978.

A QA indoctrination training session was con-ducted on September 28, 1978, and attended by personnel from the Power Plant Engineering 6 Construction Department, Quality Assurance Department, and the Engineering Department, Civil Division.

4. Failure to Provide Approved Procedures A. Action to Correct Problems The Design Document Control Procedures, Civil Engineering, have been submitted to QA for re-view and approval and are being reviewed by QA.

The procedure, PP-5.0, " Design Review Procedure",

has been revised to include a copy of the Docu-ment Revi,ew Sheet in the procedure and has been renumbered as PP 152. The revised procedure is being reviewed by QA.

B. Action to Preclude Recurrence The Civil Division has been informed, along with the other departments, to obtain com-plete approval of a procedure before perform-ing any activity covered by that procedure.

Procedures will be reviewed to ensure that referenced forms are attached or included in the procedure as a referenced procedure.

The activities of the various llL6P groups will be monitored to ensure compliance with this requirement.

Ifouston' Ughtin & Power Company Mr. Seidle October 23, 1978 Page Four C. Date Action Will Be Completed and Full Compliance Achieved The Design Document Control Procedures, Civil Engineering, will be approved by November 10, 1978. The activities of the Civil Division performed with the unapproved procedures have been reviewed and - condition adverse to quality was identified because of the use of the procedures.

The new procedure, PP-152, " Design Review Procedure", will be reviewed and approved by Notember 10, 1978.

5. Failure to Provide Procedures A. Action to Correct Problem

/ procedure to control the maintenanc3 and use of Design Review Worksheets within t' a Nuclear Division will be developed and submi ted to QA for review and approval.

No corrective action is required by the Systems Engineering Division because the Division is no longer responsible for any DRRL items which re-quired the use of the Design Review Worksheets.

The responsibility for those DDRL items have been assumed by the Electrical Division, Power Plant Engineering.

B. Action to Preclude Recurrence The QA Department will continue to monitor the project activities to ensure that adequate pro-cedural controls are developed.

C. Date Action Will Be Completed and Full Compliance Achieved The new procedure will be developed by the Nuclear Division and reviewed and approved by QA by November 10, 1978. -

Houston Ughting & Power Company Mr. Scidae October 23, 1978 Page Five We trust that you will find this response satisfactory. Should you require any further clerification or information, please advise.

Very truly yours,

. ct . h E. A. Turner, Vice President Power Plant Construction 6 Technical Services FWS:rka cc: Mr. R. A. Frazar Mr. P. A. Horn

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