ML20041D672

Responds to NRC 811203 Ltr Re Violations Noted in IE Insp Repts 50-321/81-27 & 50-366/81-27.Corrective actions:HNP-25, Revision 4,issued on 811105 & Implemented on 811120, Requiring QA Review of safety-related Procedures

ML20041D672
Person / Time
Site:	Hatch
Issue date:	12/30/1981
From:	Widner W GEORGIA POWER CO.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20041D668	List: ML20041D672 ML20041D674
References
RII:RCL, NUDOCS 8203080599
Download: ML20041D672 (3)

Text

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W. A. Widner Vice Pn s 4 t and Genera: f/anager r c ~ au e,,.o cen.a n United States Nuclear Regulatory Commission Office of Inspection and Enforcement REFEREfCE:

Region II - Suite 3100 RII: RCL 101 Marietta Street, N.W. 50-321/50-366 Atlanta, Georgia 30303 Inspection Report 81-27 ATTENTION: MR. R. C. LEWIS Gentlemen:

The referenced inspection report identified two violations of NRC requirements. We have reviewed the violations and offer the following responses:

VIOLATION A 10 CFR 50, Appendix B, Crit.mtion XII requires that measures be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. The approved QA Program (FSAR 17.2.12) endorses ANSI N18.7-1976. Paragraph 5.2.16 of this standard states that when measuring devices are found out of calibration, an evaluation shall be made and documented concerning the validity of previous tests and the acceptability of devices previously tested from the time of the previous calibration.

Contrary to the above, measures have not been established to assure the validity of tests since the previous calibration when measuring the test equipment used on instrumentation and control systems is subsequently found out of calibration.

RESPONSE

1. The violation occurred as stated.

2. It occurred becaur procedure HIP-807, " Control of Test Shop Instrumentation," did not adequately reflect our committment to l ANSI N18.7-1976 and ANSI N45.2.4-1972 (Reference FSAR Section 17.2.12). I I

3. To prevent future violations, procedure HM'-807 is being revised to conform to the ANSI Standards. The procedure revision is in the I review process at the plant.

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GeorgiaPower d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement December 30, 1981 Page Two

4. Full compliance will be achieved after the revision is approved and implemented. We expect to complete this by January 15, 1982.

VIOLATION 8 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality be prescribed by documented instructions, procedures or drawings appropriate to the circumstances. The accepted QA Program (FSAR 17.2.5.1) requires that administrative procedures, inspection plans, tests, calibrations, special processes, maintenance, modifications, repair procedures and changes thereto be reviewed and concurred with by the site QA Department to ensure inclusion of qualtiy requiremer'ts.

HNP-25, Quality Assurance Review of Plant Procedures establishes the method of complying with FSAR Section 17.2.5 Contrary to the above, HNP-25 is inadequate for the following reasons:

1. Table 1 does not include all procedures required to be reviewed by Q.A.

2. Figure 1 is not included in the procedure but referenced in several procedural steps involving mandatory and recommended changes.

3. A method is not provided by which QA concurs that a procedure contains acceptable quality assurance requirements prior to issuance.

4. Mandatory changes must be made to comply with guidelines, but step C.5 states that QA comments will be considered for implementation in a subsequent procedure revision.

5. The procedure does not address the requirement that changes to existing procedures be reviewed for quality requirements by the QA Department.

RESPONSE

1. The violation occurred as stated.

2. It occurred because procedure HtP-25, " Quality Assurance Review of Plant Procedures," did not fully reflect the requirements of FSAR Section 17.2.5.

3. To correct these deficiencies, HtF-25, Revision 4 was issued on November 5, 1981. The procedure now requires that the Quality Assurance Department reviews procedures which are on a safety related procedures list. In addition, a review form was initiated to prioritize deficiencies and establish criteria for corrective action. A procedure review program was implemented on November 20, 1981, to assure compliance with HtP-25.

GeorgiaPower d

. U. S. Nuclear Reguitory Commission Office of Inspection and Enforcement December 30, 1981 Page Three

4. These changes have been implemented and full compliance with FSAR Section 17.2.5 has been achieved.

W. A. Widner states that he is an officer of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.

GEORGIA POWER COWANY By: k (. (4/

W. A. Widner i

Sworn to the subscribed before me t s 30th day of December, 1981 at:) m

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Not Public "oy Pubhc, Georgie. Seate et Lerge PLS/cj My Commiss;on h,mcs Jdy 26. M-e xc: M. Manry R. F. Rogers, III

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