ML19289D068

Responds to NRC 781201 Ltr Re Violations Noted in IE Insp Rept 50-348/78-27.Corrective Actions:Provision for Tickler Sys to Track Response to Noncompliances,Document Control Audit of Drawing Files & Vendor Manual Files

ML19289D068
Person / Time
Site:	Farley
Issue date:	12/19/1978
From:	Clayton F ALABAMA POWER CO.
To:	Long F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19289D065	List: ML19289D068
References
NUDOCS 7901290192
Download: ML19289D068 (4)

Text

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!!w? CCut?WYl1IMCllC SfSlCm O December 19, 1978 J. M. Farley Nuclear Plant NRC Inspection of September 12-15, 1978 Mr. F. J. Long U. S. Nuclear Regulatory Commission G 101 Marietta Street, N. W.

• Suite 3100 c" -

Atlanta, Georgia 30303 C -

Re: RII: WAR 50-348/78-27

Dear Mr. Long:

This refers to the apparent infractions and deficiencies in the subject inspection report.

A. Infraction Statement:

"10 CFR 50, Appendix B, Criterion XVI states in part: " Meas ures shall be established to assure that conditions adverse to quality, such as. . .nonconformances are promptly identified and corrected. . ." The accepted quality assurance program (FSAR Chapter 17) Section 17.2.16 states in part: "An Adninistrative Procedare will be written to assure that conditions adverse to quality such as deficiencies, deviacions, defective material and equipment and other nonconformances are pronptly identified and corrected". 0QA-AP-09, " Corrective Action", Revision 8 dated April,1978 states in part in paragraph 4: " Appropriate action shall be taken to correct the condition and preclude recurrence. The corrective action is to be conpleted within 30 days of notification of the condition. In the event corrective action cannot be completed with-in that period, an explanation as to why it cannot be completed and a schedule date for its completion are to be inc.1.uded in the }bnthly Report of OQA Corrective Action".

Contrary to the above, three (3) nonconformances involving eleven (11) specific deficiencies were identified in an internal audit report dated 7/25/78, corrective actions were not compJeted and/or reported until 10/02/78 (68 days elapsed); five (5) nonconformances were identified in a vendor audit report dated 5/01/78, corrective actions were not completed and/or reported until 8/29/78 (119 days elapsed); and one (1) nonconform-ance was identified in a vendor audit report dated 2/24/78 and corrective actions were not completed and/or reported until 6/06/78 (89 days elapsed)".

7901290 %

3 Corrective Action:

The audit responses identified above were late but had been re-ceived as indicated in the infraction statement.

Revision 11 dated December 8,1978 to the OQA Administrative Procedures added specific provision for a tickler system to track the response to noncompliances of the type identified in the above infraction description. This provision also includes action to be taken in the event of untimely responses. This tracking system will be used for all noncompliances identified in audits by OQA, except for plant and Production Nuclear Section noncompliances which are provided for in the respective organizations' procedures. This tickler system is in use now and although this system will not assure strict compliance regarding an audit finding response within 30 days, it will provide documentation of efforts made and actions recommended by Operations Quality Assurance. The plant corrective action system is not involved in this infraction. This infraction has been discussed with the appropriate supervisors in the Production Nuclear Section and future compliance will be audited during Schedule OQA audits.

This places Alabama Power Company in full compliance.

B. Deficiency Statement:

" Technical Specification 6.8.1 states in part: " Written procedures shall be established, implemented and maintained. . ." Administrative Procedure 4, Section 8.7.2, states in part: ". . .FCR 's and CN's whir.h are outstanding in the particular revision being issued shall be logged in on the status block of the affected drawings #. . ." Contrary to the above, on October 4,1978, the below listed drawings in the Control koom were af fected by outstanding CN's but were not annotated as required:

D-1750 73 Main Feedwa ter Sys tem Revision 6 D-170806 Air Start System for Diesel Generators 1C/2C Revision 3/2 D-170807 Air Start Sys tem for Diesel Generators 1A/2A Revision 1 "

Corrective Action:

Document control shall conduct an audit of the drawing files and prepare a list of controlled drawings checked out to various groups and individuals. These lists shall be forwarded to each group or individual along with instructions to review the drawing lis t and determine if the drawings are necessary to support routine activities.

Drawings t it being used on a frequent basis shall be returned to document control for updating and refiling. Drawings wl.ich are used to support day to day nctivities shall be brought to document control for updating. At that time, the drawing holder will be trained in procedures for future updating. Full compliance will be achieved by February 1,19 79.

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C. Deficiency Statement:

"10 CFR 50, Appendix B, Criterion III states in part: "... Measures shall be established for the identification and control of design inter-faces and for coordination among participating design organizations.

These measures shall include the establishment of procedures among participatint de si gn rganizations for the review, approval, release, distribution and revision of documents involving design interfaces. . ." The accepted quality assurance program (FSAR Chapter 17) Section 17.2.17 states in part: "... An Administrative Procedure will develop a method for identifying, filing and maintaining records in accordance with the guidance provided in ANSI N45.2.9-1974..." ANSI N45.2.9-1974, Section 4.2 states "To assure their availability, a specific submittal plan shall be established for quality assurance records by agreement between the purchaser and arpplier".

Contrary to the above, as of October 4,1978, the facility had had an operating license for fif teen (15) months; however, design documents from Bechtel Corporation had not been turned over to Alabama Power Company and neither an agreement nor a specific submittal plan were established to affect this transfer".

Corrective Action:

On October 27, 1978 Alabama Power Company transmitted a letter authorizing Bechtel to proceed with microfilming and f urniching of records according to plans negotiated from October, 1977 to October, 1978. The record turnover is presently in progress and is scheduled to be completed in 1979. The agreement finalized on October 27, 1978 completes the action required by this deficiency.

D. Deficiency Statement:

"10 CFR 50, Appendix B, Criterion VI states in part: "lbasures shall be established to control the issuance of documents, such as instructions, procedures , and drawings , including changes thereto, which prescribe all activities affecting quality..." The accepted quality assurance program (FSAR Chapter 17) Section 17.2.6 states in part: ". . . An OQA Adminis trative Procedure will describe the method used by the 0QA Department to control documents. ..." Administrative Procedure FNP-0-AP-04, Revision 2, Section 8.1 states in part: ". . 0fficial copies are issued by the Central File to authorized holders and are maintained current by automatic distribution of new revisions as 'Sey are approved. . . ." Additionally, Sec tion 8.3 s ta tes in part: ".. 8.. 1 Each of ficial copy of a Class A document shall be identified as follows: a. Stamp the outside of each binder or volume with "0FFICIAL COPY; COPY NO. X," where X represents the actual copy number.

. . ."and ". . 8.3.2 Each of ficial copy of a Class B document shall be identified by stamping the outside of each binder or volume with the s tamp used for Class A documents. ..."

Contrary to the above, as of October 3,1978, one copy of Component Cooling Water Pump manual (U168870), a Class B controlled document, was uncontrolled in that it was in the possession of the Mechanical Maintenance

Department without the required check-out from the Central File.

Additionally, one copy of the same manual was not identified and serialized as required".

Corrective Action:

Document control will audit vendor manual files and checkout records to accomplish the following:

1. Assure that all vendor manuals in document control are properly identified in accordance with FNP-0-AP-4,

2. Compile a list of vendor manuals checked out to various groups and individuals.

3. Ver! fy revision level on vendor manuals and post changes in accordance with FNP-0-AP-4 Each group or individual will be transmitted a list of controlled vendor manuals checked out in their name. The list will include the manual number, revision level and controlled copy number. Each holder will review the list and the need to retain the manual (s) in their possession. Manuals which are not needed to support routine work activities shall be returned to document control for filing. Manuals which are determined to be out of date shall be returned to document control for updating.

In addition to the above, the Assistant Plant Manager will generate a memorandum directing all vendor manuals in possession of plant personnel, which are not identified in accordance with FNP-0-AP-4, be submitted to document control for proper identification.

Full compliance will be achieved by February 1,1979.

We do not consider any of the information in the subject inspection report to be proprietary.

Yours very truly, hW F. L. Claytqh, Jr.

FLCJr/mmb cc: Mr. R. A. Thomas Mr. G. F. Trowbridge

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