ML20008D968

Responds to NRC 800822 Ltr Re Violations Noted in IE Insp Repts 50-321/80-28 & 50-366/80-28.Corrective Actions:Manager of QA Will Be Provided Closer Access to Company Executives Concerned W/Activities Re Nuclear Safety

ML20008D968
Person / Time
Site:	Hatch
Issue date:	09/15/1980
From:	John Miller GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20008D965	List: ML20008D966 ML20008D968
References
NUDOCS 8010240007
Download: ML20008D968 (17)

Text

+~ ; - , ' Georgd Pese/ Cecj:any' ~ ~

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• 270 Peachtree Street

'\ ) t Post Oftre Box 4545 8

A;larta Georga 30302

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J. H. Miller, Jr. n -

Executwe wce Presscer,t d 'g Ct l6 A0*}l tre southern ercrc s,s:em September 15, 1980 United States Nuclear Regulatory Commission Office of Inspection and Enforcement

REFERENCE:

Region II - Suite 3100 RII: WAR 101 Marietta Street, NW 50-321/80-28 Atlanta, Georgia 30303 50-366/PJ-28 ATTENTION: Mr. James P. O'Reilly Gentlemen:

In accordance with Section 2.201, Part 2, Title 10, Code of Federal Regulations, Georgia Power Company hereby submits the following information in response to your report of the inspection conducted by W. A. Ruhlman and others on July 7-11, 14-18, and 22-24, 1980. That inspection reviewed overall managehent in selected areas of responsibility at both the site and corporate offices. Certain apparent items of noncompliance were identified during the inspection. The enclosed is our response to each of the identified items of noncompliance, indicating corrective actions and schedules.

The response to Item A, in particular, provides a description of the mechanisms being stressed to assure conformance to quality requirements.

The Manager of Quality Assurance will be afforded closer ac ess on a more frequent basis to Company executives concerned with activities involving nuclear safety.

Should you have any questions concerning this letter, we will be glad to discuss them with you.

Sincerely, f

,', j

. H.1 ller, LTG. b ~

Enclosure xc: M. Manry R. F. Rogers, III '

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-ITEM: !A~

' CATEGORY: INFRACTION DESCRIPTION: ,

As requ red by-10 CFR 50, Appendix'B, Criteria I and XVI, the persons and l organizations performing quality assurance funct Dus shall have sufficient l authority and organizational freedom to identify quality problems and to l verify implementation of solutions. It is further required'that measures I shall be established to assure that conditions adverse to quality are promptly corrected.. The accepted QA Program (FSAR) Section 17.2.1.1.3

-states that the Manager of Quality Assurance, by reporting to the Executive Vice President, has the authority and independence necessary to effectisely assure conformance to quality requirements. .Section 17.2.18 states that the Quality Assurance Department will use, audit finding reports (AFR's) to assure that responsible management has implemented corrective action.

-Contrary to the above, the Quality Assurance Department does not effectively assure conformance to quality standards in that it does not assure prompt

-correction of conditions adverse to quality. Specifically, between

October 27, 1978 and April 11, 1980, the Nuclear Regulatory Commission has issued five citations for failure to take corrective actions by the 1

mechanisms defined for corrective action within the QA Program (Reports i 50-366/78-44; 50-321/79-07, 50-366/79-08; 50-366/79-09; 50-321/79-11; 50-

366/79-15; and 50-321, 50-366/80-17). Further, of 119 QA Program AFR's written in 1978 and 135 written in 1979, 9 items from 1978 and 35 items i from 1979 remain uncorrected as of July 11, 1980. In addition, of 45 i

AFR's written in 1980 which required completion of corrective action on or before March 13, 1980, 12 remain uncorrected as of July 11, 1980 (i.e., overdue by 120 days or more),

t GPC RESPONSE:

ITEM: A '

The Georgia Power Company will take a number of steps to improve the effectiveness of the QA Department in assuring conformance to quality standards. These measures are designed to assure prompt and complete correction of conditions adverse to quality. They will also improve and expand the mechanisms by which the Manager of Quality Assurance executes his responsibility to assure conformance to quality requirements.

Organizationally, the Manager of QA continues to report to the Executive =

Vice President and has the authority and independence necessary to effectively assure conformance to quality requirements. In addition,.the Executive Vice President has appointed the_Vice President-Power Supply Engineering and Services as his Deputy .to assist in discharging responsibilities t6 -

the Plant Hatch QA Program. This shall' encompass the corporate audit functions, NRC inspections, and corrective actions by the Power Generation Department. The Deputy will assist the. Executive Vice President in handling the day-to-day details of QA Program activities'and will keep him fully' informed of his actions. The Deputy will also support the manager

! of QA in the resolution of day-to-day problems in the overall development t

of the.QA Program and particularly in the prompt response to audit findings ,

by the Power Generation Department.

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ITEM: A (Continued)

CATEGORY: INFRACTION GPC RESPONSE: (Continued)

The'following additional measures are either planned or have been implemented:

_ l. The Manager of QA or his designee attends and will continue to attend the monthly management meetings held at Plant Hatch among members of corporate and plan. management. This will serve as a forum for presentation of QA reports on status of corrective action, special QA concerns, and general adequacy of the QA Program.

2. The Manager of QA or his designee attends and will continue to attend the weekly staff meetings of the Vice President and General Manager of Nuclear Generation. At these meetings, the Manager of QA is afforded the opportunity to present any QA matters or concerns.

3. The Manager of QA or his designee will meet periodically with the Manager of Nuclear Generation to discuss special QA concerns such as adverse trends, adequacy of liaison between Power Generation and QA, open items over 30 days, open items escalated to the Manager of QA by the QA Field Supervisor, and general adequacy of the Httch QA Program.

4. Approximately once a month, the Vice President-Power Supply Engineering and Services (Deputy to the Executive VP on QA matters) will call a meeting with the Manager of QA or his designee, the Vice President and General Manager of Nucicar Generation or the Manager of Nuclear Generation, and others as appropriate to discuss the effectiveness of the Plant Hatch QA Prograd. Specific attention will be given to the effectivness, promptness, and completeness of corrective actions against NEC and QA audit findings. The meeting will be chaired by the Vice President-Power Supply Engineering and Services from an agenda prepared by the Manager of QA. A report of the proceedings of this meeting will be prepared and presented by the Vice President-Power Supply Engineering and Services (or the Manager of QA in his absence) at the monthly staff meeting of the Executive Vice President.

5. Specific criteria will be issued to the site QA staff for referring audit findings to the Manager of QA who will evaluate them for QA Program effectiveness. The status or resolution of these findings will be forwarded to the site QA staff by the Manager of QA.

The Georgia Power company believes that when the foregoing actions are -

fully implemented, the effectiveness of the QA Department will be sub-

.stantially improved and that the mechanisms affordad the Manager of QA to execute his responsibilities will be more effective in assuring confor-mance to QA Program requirements. Georgia Power Comeany believes that full compliance in this area will be achieved by 0.cober '1,1980.

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• ITEM: B CATECORY: INTR *.CTION DESCRIPTION:

As requi. red by 10 CFR 50, Appendix B, Criterion X, a program for inspection of activities shall be establishcd and shall be executed by individuals other than those who perform the activity being inspected.

1. The accepted QA Program (FSAR) Section 17.2.10 states that the QA Manual, Section 10, requires inspection by personnel other than those performing the activity. The QAM, Section 10, paragraph 10.2 states that: "To satisfy the general inspection requirements stated above, the following specific requirements shall be Laplemented.

, a. Measures shall be established to 1ssure that inspection personnel are independent from the individual or group performing the activity being inspected".

Contrary to the above, a program for inspection of activities effecting quality was not executed by individuals other than those performing the work activity being inspected as defined in the licensee's accepted QA Program in that.

(1) the inspection of firestops associated with 2 Maintenance Requests (MR's) on Unit 1 (1-79-285, 1-79-741) and with 3 MR's on Unit 2 (2-79-4076, 2-79-4658, 2-78-4714) were conducted by the foreman of the men who performed the activity; (2) the inspection following the repair of Hydraulic Control Unit 18-35 (MR 1-79-25) on Unit 1 on July 2, 1979, sas conducted by the foreman directing the repair activity.

All of the above examples were taken from selected work activities reviewed for the period from January through October 1979.

2. The accepted QA Program (FSAR) Section 17.2.2.2, Item 2, requires implementing procedures to be written, reviewed and approved by each responsible organization. Item 1 of the same section states that the QA Manual contains the requirements that must be met. Section 2.4 of the QA Manual states that detail procedures shall be prepared, approved and controlled by the organization responsible for their implementation. Section 10.3 of the QA Manual states that the GPC Power Generation Department shall be responsible for the surveillance inspection of work performed by plant personnel and contractors at the plant site.

Contrary to the above, the licensee has not established an inspection program in that portions of the QA Program which allow personnel v.ithin a department to perform surveillance inspection of work within that department (the alternate inspection program) have not been documented by written procedures. Specifically:

(1) there was no documented method for designating alternate inspectuis or for specifying when and how alternate inspectors were to be utilized.

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, ITEM: B (Continued)

CATECORY: INFRACTION

- DESCRIPTION (Continued)

(2) there were no criteria for establishing the " independence" of these inspectors as required by Section 10.2 of the Quality Assurance Manual; and, -

(3) based on six Maintenance Requests reviewed (1-79-285, 1-79-741, 2-79-4076, 2-78-4658, 2-78-4714, and 1-79-2529), alternate inspection activities are not carried out in accordance with the accepted QA Program.

• GPC RESPONSE:

ITEMS: B.1 and B.2 Inspections of work in progress on the cited NRS cannot be rerformed after the fact. To ensure full compliance on future work, the follow-ing program has been initiated.

Experienced personnel are working full time on development of a draf t procedure redefining the Quality Control Program and its requirements.

This draft will be completed by October 1, 1980. All NRC and Quality Assurance identified deficiencies will be considered in development of the draf t. Necessary changes to the draft and initial implementation will begin by March 1, 1981.

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ITEM: B (Continurd)

CATEGORY: INFRACTION DESCRITPION: (Continued)

3. The accepted QA Program (FSAR) Section 17.2.10 requires that inspectors shall be certified in accordance with applicable standards. Section 17.2 states that applicable standards for the Program are listed in Appendix A of the FSA 1 Appendix A of the FSAR states that the Progras complies with ANSI N45.2.6-1973. ANSI N45.2.6-1973, Section 2.2, requ"-es that each person who verifies conformance of work activities to quality requirements shall be certified as being qualified to perform his assigned work.- An assigned quality require--

ment, according to the accepted QA Program's co=mitment to ANSI N45.2.2, Section 5.2.1, is the Shipping Damage Inspection.

Contrary to the above, the licensee has not established an inspection program in accordance with the accepted QA Program in that there are no provisions to certify persons performing Shipping Damage Inspections.

Based on interviews and observations, the inspector did verify that those persons assigned this inspection activity were qualified to perform the function.

GPC RESPONSE:

ITEM: B.3 Plant Hatch Procedures do not allow any materials or equipment designated for use in a safety-related system to be issued from the warehouse without proper QC inspection as described in Procedure HNP-821, "QC Work Inspection", and Procedure ENP-822, " Material Inspection Request".

Because of this restriction, shipping damage inspections are not con- ~

sidered to provide a quality function. They provide only an economic function.

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ITEM: C CATEGORY: INFRACTION DESCRIPTION:

As regiired by 10 CFR 50, Appendix B, Criterion XVIII, followup action, including reaudit of deficient areas, shall be taken where indicated.

The accepted QA Program (FSAR) Section 17.2.10, states that the audit program will be regularly reviewed by the Mancher of QA to assure imple-

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mentation of the requirements in the Quality Assurance Manual. Section 17.2.2.2 of the accepted QA Program also states that the QA Manual contains the requirements that must be met. Section 18.2.d of the QA Manual requires that measures shall be established to assure that deficient areas are promptly reaudited until corrections have been accomplished.

Contrary to the above, reaudits of deficient areas were not conducted where indicated in that items identified during three specific audits had not been reaudited nor was the current status of correction known by the auditing organization as of July 24, 1980. Specifically: the audit of Power Supply Engineering and Services conducted on September 5-7, 1978, identified 7 deficient areas which had not been reaudited nor was their status known; the audit of Environmental Programs conducted October 17-18, 1979, identified 2 deficient areas one of which was closed on February 5, 1980, but the other had not been reaudited nor was its status known; and, the audit of "Q" Motor Repair Program conducted January 24, 1980, identified 2 deficient areas which had not been reaudited, which had no specified completion date, and the status of corrections was not known.

GPC RESPONSE:

ITEM: C To assure that deficient areas discovered during QA audits are reaudited, the following procedural changes will be made by October 1, 1980. Procedure  ;

QA-05-06, " Site Preoperational, Startup and Operational Audits", will be revised to define the reaudit program used at Plant Hatch. Procedure QA-05-13, "Open Items Control", will be changed to require that deficient areas discovered during QA corporate audits be included in a Corporate QA Audit Finding Status Report. Additionally, the procedure will require that the report be updated at least each 90 days.through reaudit. In this regard, ~ existing Corporate QA Audit Findings have been reaudite '.

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ITEM:' D CATEGORY: , INFRACTION DESCRIPTION:

As required by 10 CFR 50, Appendix B, criterion V, activities affecting quality shall be accomplished in accordance with documented procedures.

The accepted QA Program (FSAR) Section 17.2.5 also states that activities affecting quality shall be accomplished in accordance with documented procedures.. Procedure QA-05-06, "Preoperational, Startup and Operational Audits", Revision 6, dated February, 1980, requires in paragraph D.3 that

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the audited organization provide a response to an Audit Finding Report (AFR) within 30 days of receipt.

Contrary to the above, activities affecting quality were not accomplished in accordance with procedure QA-05-06 in that:

(1) for 7 AFR's written in the last quarter of 1979 fcc which required responses were-not received within the 30-day period, the average period overdue was 50.28 days; and, (2) for 5 AFR's written in the first half of 1980 for which required responses were not received within the 30-day period, 4 had not been received as of July 11, 1530, and the average period overdue as of that date was 87.5 days.

.GPC RESPONSE:

4 ITEM: D Procedure HNP-835, " Audit Findings - Responses and Notifications", has been revised to require a 30-day acknowledgement of QA audit findings.

The requirements include the establishment of a " tickler file" to prevent the 30-day requirement from being exceeded. In addition, plant management has taken action to stress the importance of a 30-day re-sponse to QA audit findings. All QA items without an initial response have been reviewed and responses provided for those over 30 days old. ,

Full compliance was achieved on August 18, 1980. l i

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ITEM: E CATEGORY: INFRACTION DESCRIPTION: ,

As required by 10 CFR 50, Appendix B, Criterion VI, measures shall be established to control the issuance of documents, including changes thereto, which prescribe all activities affecting quality. The accepted QA Program (FSAR) Section 17.2.6.1 states that an Administrative Assistant

_ ahall establish a system ensuring that the responsible supervisors receive ctrrent revisions of required documents.

Contrary to the above, as of July 16, 1980, measures had not been estab-lished for the control of vendor technical manuals, and changes thereto, referenced in safety-related plant procedures and necessary for carrying out the activities prescribed therein. Specific examples include, but are not limited to:

4 (1) current revi:, ions were not entered into the Control Room, Test Shop and Maintenance Shop copies of manual GEK 9690, Volume X, Part 3; (2) current revisions were not entered into the Maintenance Shop copy of the High Pressure Coolant Injection Pump, Instrument and Operations Instructions Manual; and, (3) current revisions were not entered into two of four Master File copies of the Main Steam Relief Valve Technical Manual.

GPC RESPONSE:

ITEM: E Manuals cited will either be revised or removed from plant files by October 1, 1980. To keep revisions current on controlled documents, a document index is being prepared to identify all authorized drawings or manuals other than those which may be designated for reference use only.

When completed, only those drawings and manuals on the index will be authorized for use and will be updated by Records Management. Plant management may also issue other guidelines prescribing authorized-levels

' of manual use. The expected completion date is targeted for March 1, 1981.

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ITEM: F-CATEGORY: INFRACTION DESCRIPTION; As requi. red by Technical Specification 6.8.1, procedures shall be implemented.

1. HNP-821, " Quality Control Work Inspection", Revision 5 dated 9/78, paragraph B.6 requires alternate inspectors to be designated by the Site Quality Control Supervisor (SQCS) and upon completion of the inspection, that the results be documented on the forms referenced in the procedure.

Contrary to the above, procedure HNP-821 was not implemented in that the alterrate inspectors verifying activities associated with the replaceme at and repair of 270 valves on the Hydraulic Control Units of Unit . .n July of 1979 were not designated by the SQCS nor were the inspection results documented on tha specified forms.

2. HNP-8,'" Maintenance Request (MR)", Revision 13 dated 3/80, paragraph 12.c requires that when consumables or off the shelf items are used and are not obtained with an Inventory Material Request (IMR), the worker shall provide a description of the item (s) used on the back of the MR form.

Contrary to the above, procedure HNP-8 was not implemented in that for 4 of 25 MR's reviewed (1-80-3398, 1-80-3619, 1-80-3414, and 1-80-3511) items were replaced and no IMR was used and the parts were not identified on the FR.

This is an infraction applicable only to Unit 1 based on the specific examples identified.

GPC RESPONSE:

ITEM: F.1 Inspections of work in progress on the cited FGG cannot be performed after the fact. To ensure full compliance on future work, the following program has been initiated.

Experienced personnel are working full time on development of a draft procedure redefining the Quality Control Program and its requirements.

This draft will be completed Ir October 1, 1980. All NRC and Quality Assurance identified deficienc.es will be considered in development of the draft. Necessary changes to the draft and initial implementation will begin by March 1, 1981.

ITEM: F.2 _

The four Maintenance Requests listed in the infraction have been further reviewed by the plant staff. The results are as follows:

FR l-80-3398: Corrective action was to fabricate a coupling from a small piece of plexiglass to repair the mode switch on SRM D (ICSI-K600D). A 3/4 inch square _ piece of plexiglass was used and was not listed on the MR.

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. ITEM: F: (Continued)

- CATECORY: INFRACTION GPC RESPONSE:

lTEM: F.2 (Continued)

MR l-80-3619: The corrective action as listed on the MR was " installed original preamp...". The corrective action should have read, "A spare preamp was installed and did not resolve the problem, therefore, the original preamp was reinstalled. ...

No parts were used other than to troubleshoot the problem.

MR l-80-3414: The work description listed on the MR was " IGM checked good. Found EGR bad. Mechanics changed EGR, see MR l 3411". The problem was rescived on the referenced MR and

.all parts used are listed s that MR. No parts used for 1

MR 1-80-3414.

MR 1-80-3511: The-work description liv.ed on the MR used the wording,

" replaced door knob". 't ne word ' replaced' was used to indicate the original door knob, which had fallen from the doot, was placed back onto the door.

Of the 25 MR's reviewed by the NRC inspector, only one is indicative of the problem as stated. A sample of approximately 500 MR's was taken by plant personnel subsequent to the audit. Of these, approximately 200 required parts replacement; of those 200, only 4 did not list the parts.

Da one MR, the parts were traceable to an IMR through warehouse records.

Parts for the other three MR's were, a shear key, a light bulb and a wire mesh for use on a door.

As a result of this review, the number of occurrences is considerably less than previously indicated, and does not repr; cent generic failure to follow procedure, but rather oversight. To addreca this oversight problem, emphasis has been, and will continue to be', placed an the performance and review required-on all MR's.-

A detailed FR training program is beir.g developed to instruct appropriate personnel on the requirements of the maintenance program, f

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ITEM: G

, CATEGOEY: INFRACTION -

DESCRIPTION:

As required by 10 CFR 50, Appendix B, Criterion V, activities affecting

. quality shall be prescribed by documented procedures which shall contain

appropriate quantitative and qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. The

. accepted QA Program (FSAR) Section 17.2.5 also requires activities

, affecting quality to be prescribed by documented procedures that contain appropriate qualitative or' quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary _to the above, the procedure covering the QC inspection activity (RNP-821, " Quality Control Work Inspection", Revision 5, dated 9/78) does not contain either qualitative or quantitative acceptance criteria for determining when the inspection activity must be accomplished. The procedure states that a Quality Control specialist reviews Maintenance Requests (MR's) and then determines if an inspection is required. The decision is to be made "if the work involved is significant enough to warrant QC inspection". The inspector found no QC inspection performed on any MR's associated with Instrumentation and Control Work (one case of improper alternate inspection was conducted) and no involvement in non-MR areas such as operations and health physics.

GPC RESPONSE:

ITEM: G Inspections of work in progress on MR's associated with Instrument and control work cannot be performed after the fact. To ensure full compliance on future work, the following program has been initiated.

Experienced personnel are working full time on development of a draft procedure redefining the Quality Control Program and its requiremnets.

This draft will be completed by October 1, 1980. All NRC and Quality

-Assurance identified deficiencies will.be considered in development of the draft. Necessary' changes to the draft and initial implementation will begin by March 1, 1981.

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. ITEM: H CATEGORY: DEFICIENCY DESCRIPTION: ,

As required by 10 CFR 50, Appendix B, criterion II, the status and adequacy of the QA Program shall be regularly reviewed. The accepted QA program (FSAR)~Section 17.2 states that the QA Program implements ANSI N18.7-1976. ANSI N18.7-1976, paragraph 5.2.15 requires that procedures shall be reviewed no less frequently than every two years to determine if changes are necessary or desirable.

Contrary to the above, the status and adequacy of the QA Program was not regularly reviewed in that of the 45 procedures in the QA Department Procedure Manual, 23 had not been reviewed for period in excess of two years. Two procedures were last reviewed in 1975; seven procedures were last reviewed in 1976; three procedures were last reviewed in 1977; and eleven procedures were last revicwed in the first half of 1978. Since review of procedures is not documented, the latest revision date was used to determine the date of last review. (A revision is considered a review under paragraph 5.2.15 of ANSI N18.7-1976) .

GPC RESPONSE:

ITEM: H To assure that QA Department Procedures are reviewed biennially, a pro-cedure will be added to the QA Department Procedure Manual. This pro-cedure will state the position responsible for schedule development, will specify the positions reponsible to review specific procedures, and will establish the method of documentation. The procedure will be issued no later than October 30, 1980. Additionally, procedures now exceeding the two-year review requirement will be reviewed no later than January 15, 1981.

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ITEM: I

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. CATECORY: DEFICIENCY DESCRIPTION:

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As required by Technical Specification 6.8.3, each procedure required by Technical Specification 6.8.1 shall be reviewed periodically as set forth

'in administrative procedures. Procedure EITP-814, " Procedure Reviews", .

Revision 6, dated April, 1980, Section B, states that: " Biennial reviews shall be conducted within the month specified by the Records Department".

-Contrary to the above, procedures required by Technical Specification 6.8.1 are not periodically reviewed as set forth in ICIP-814 in that of the 700 procedures specified by the Records Department to be reviewed in the months of February, March, April, May and June of 1980, 540 were not reviewed in the month specified and 473 remained unreviewed as of July 10, 1980.

GPC RESPONSE:

ITEM: I Plant management is in the process of researching the status of procedure reviews. To date, no procedures have been discovered which have exceeded the two-year review requirement of the Technical Specification.

However, realizing the problems experienced with maintaining the procedure review schedule, some procedural changes are being considered. These changes include the exclusion of non-safety-related procedures from the biennial review requirement, the establishment of a grace period, and organizational changes to allow a more streamlined review process.

J Necessary draft procedure changes will be completed by October 1, 1980.

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ITC1: J CATEGORY: DEFICIENCY DESCRIPTION:,

e As required by 10 CFR 50, Appendix B, Criterion IV, measures shall be established to assure that applicable regulatory requirements, design bases, ar.d other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for pro-curement of material, equipment, and services. The accepted QA Program (FSAR) Section 17.2, states that Program is established, in part, by compliance with ANSI N45.2.13-1976. This standard defines " procurement document" to include purchase requisitions. Section 3.1 requires that changes to procurement documents shall be subject to the seme degree of control as utilized in the preparation of the original document.

Contrary to the above the licensee has not established measures to assure that requirements are included in procurement documents in thit there are no provisions for controlling changes made to purchase requisitions. The inspector determined by interview with responsible managers, that changes to purchase requisitions are made after these documents have been trans-mitted to the Company Offices for the plant site and without the same degree of control utilized in the documents' preparation.

GPC RESPONSE:

ITEM: J Purchase requisitions, as defined at Plant Hatch, do not fall within the definition of a procurement document of ANSI 45.2.13. Requisitions are an internal system used by the plant to notify the procurement department of the need for an item or service.

Utilizing the requisition as a work sheet, the procurement department generates a purchase order. This purchase order becomes the " contract-urally binding document" defined in ANSI 45.2.13.

To preclude incorrect information in Plant Hatch procurement documents I related to safety ("Q") equipment or services, all such requisitions l are reviewed by the Supervisor of Nuclear Procurement Standards (SNPS) be- i fore being forwarded to the procurement department. Corrections are made )

as appropriate to assure compliance with both the technical and QA

, program requirements applicable to the items or service requisitioned.

Corrections or changes are reported to site personnel for their infor-mation and use. Subsequent to the SNPS's review, the procurement depart- l ment generates a purchase order which is controlled by a defined quality J

assurance program. Any changes made after the issuance of the purchase I order receive the same degree of control that is applied to the original I purchase order. '

The appropricte procedures and instructions will be reviewed and modified to ensure that the above information is reflected in a clear manner no later than September 30, 1980.

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.' ITEM: K CATECORY: DEFICIENCY DESCRIPTION:

• e As required by 10 CFR.50, Appendix B, Criterion XVII, records shall be maintained to furnish evidence of cetivities affecting quality and requirements concerning record location. The records shall include the results of inspections. The accepted QA Program (FSAR) Section 17.2.17 requires that records be prepared to document activities effecting quality and lists inspection results as a typical record. The Section further requires that written procedures control the storage of records.

Contrary to the above, records of inspections were not maintained and requirements concerning record location were not established in that:

(1) records of shipping damage inspections are not maintained; and, (2) Unit 1 and 2 records are stored in the Georgia Power Company Block House on site and this structure is not described as a record storage location in the licensee's procedure HNP-820, " Plant Records Fbnagement", Revision 10, dated 8/79.

CPC RESPONSE:

ITEM: K.1 Plant Hatch procedures do not allow any safety-related materials or equipment to be issued from the warehouse without proper QC inspection as described in Procedure HNP-821, "QC Work Inspection" and Procedure HNP-822, " Material Inspection Request". Because of this restriction, documents generated as a result of shipping damage inspections are not considered to provide quality-related data. The data provided by the shipping damage inspections are economic in nature. The quality-related data are generated as a result of HNP-821 and HNP-822.

ITEM: K.2 All records presently stored in the blockhouse will be moved to the plant record storage area. Additional cabinet space will be provided for these documents. This action will be completed by November 1, 1980.

Plant management has instructed Records Management Supervisor not to utilize the blockhous; for records storage. Future plans call for removal of the blockhouse. ,

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ITEM: L -

. CATEGORY: DEFICIENCY DESCRIPTION:,

8 As required by 10 CFR 30, Appendix B, Criterion XIII, measures shall be established to control the storage of material and equipment to prevent damage. The accepted QA Program (FSAR) Section 17.2 states that the Program will follow Standards listed in Appendix A. Appendix A states that the licensee's Program will meet the requirements of ANSI N45.2.2-1972.

. ANSI N45.2.2-1972, Sections 3.5.1 and 6.4.2 require that threads and weld end preparations shall be protected with caps or plugs.

Contrary to the above, measures were not established to control the storage of materials and equipment to prevent damage to weld end preparations in that:

(1) the licensee had no program ta install caps or plugs as required by the Program's commitment to ANSI N45.2.2; and, (2) the inspector found numerous stainless steel elbow, with weld end preparations, purchased under order PEH2-6442 that were stored without the required caps or plugs.

None of the stored elbows had any observable damage to the veld end preparations.

GPC RESPONSE:

ITEM: L Plant management is reviewing the FSAR commitment to ANSI N45.2.2-1972,

" Packaging, Shipping, Receivin'g, Storage and Handling of Items for Nuclear Power Plants". A preliminary review has determined that in some cases caps and plugs can be detrimental to equipment in that they can cause moisture to accumulate. After completion of the review, any exceptions to ANSI N45.2.2 will be documented in correspondence to the NRC. This will be done within three months. Additionally, we believe that our present system to prevent damage to weld-end preparation is adequate in that there has been no observable damage to weld-end pre-parations.

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