ML20055B131

Forwards Response to NRC Re Violations Noted in IE Insp Rept 50-323/82-09.Corrective Actions:Audit of All Class I Purchase Orders from Jan 1978 to Present Completed

ML20055B131
Person / Time
Site:	Diablo Canyon
Issue date:	07/14/1982
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8207200390
Download: ML20055B131 (4)

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.. 'n? 7.2 00t*ETED PACIFIC GAS AND E LE C T R,I)MC C O M PANY 77 BE ALE STREET, S AN F R AN CISCO, C ALIFO R_NI A 44AD6 TELEP N E (415) 7814211 .

FO*3 i P. O. BOX 7 4 4 7. S A N FR A NCISCO, C ALIFORN 4 . h 'T lE R (415) 543 7813

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July 14, 1982 S

Mr. R. H. Engelken, Regional Administrator i U.S. Nuclear Regulatory Commission h Region V g 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 p Re: Docket No. 50-323 b Diablo Canyon Unit 2 _

Notice of Violation 1 IE Inspection Report 82 Release of Material $

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Dear Mr. Engelken:

i NRC Inspection Report 50-323/82-09, dated June 14, 1982, ii included a Notice of Violation (Severity Level V) . PGandE's response to this Notice is enclosed. {

6 Very truly yours, $

n Philip A. Crane, Jr.

Enclosure cc w/ encl Service List I

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t PGandE's Response to Notice of Violation - -

in NRC Inspection Report 50-323/82-09 On June 14, 1982, NRC Pegion V issued a Severity Level V Notice of '

Violation (" Notice") as part of NRC Inspection Report 50-323/82-09 on Diablo Canyon Unit 2. The Notice cited the failure of a PGandE contractor to confom to their existing approved procedures when receiving, handling and releasing materials .for construction. The violation was described in the Notice as:

10 CFR 50, Appendix B, Criterion VII, as implemented by Section 17.1.7 of the FSAR and the PGandE Quality Assurance

• g Manual Section III states in part that, " Documentary g evidence that material and equipment confom to the g procurement requirements shall be available at the nuclear i power plant...p'rior to installation or use of such material [

and equipment. ,

2 The Howard P. Foley Company Quality Control Procedure QCP-3, ,

" Processing and Control of Deviations and Nonconformances," i and QCP-4, " Receiving, Handling, and Storage" require that  !

documentation be received prior to releasing material to i construction. 2 I

Contrant to the above requirements, materials purchased under eight different purchase orders were received and c released for construction prior tc receipt of material  :

documentation. This finding was a result of an audit ordered by the licensee and initiated by Foley on March 15, l

.g 1982. The audit was prompted due to an allegation received  ;

l by the NRC regarding release of material for construction 4 prior to receipt of proper documentation. g 1

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8 The concern involves releasing of material for installation in a  ;

8 manner not confoming to the written procedures. The Contractor's ptocedures required that material be installed after receipt of documentation. Contrary

. to this procedure, installation prior to receipt of documentation, was initiated on the basis of written Contractor memoranda. g 5

This method of releasing material for construction prior to receipt of l required documentation is in agreement with 10 CFR 50, Appendix B, f Criterion XV, as implemented by Section 17.1.15 of the FSAR, provided that appropriate procedures cover such conditions. Material installed in this  !

manner is considered nonconfoming until appropriate evidence and confomance is provided. j i

The Contractor's memoranda releasing material for installation prior i

. 5 to receipt of required documentation were first used in 1978 Corrective Steps Taken and Results Achieved l The following corrective steps were taken to obtain compliance:  :

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1) The Contractor has completed a 1007, audit of all Class I purchase 9 orders dating from January 1978 to date.

2) It is now detemined for all referenced purchase orders that

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either all documentation has been received, or where appropriate, corrective action has been taken.which has provided back-up i t-documentation or justification for acceptability.

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3) The Contractor's procedures QCP-4 " Receiving, Handling and 3 i

Storage" and QCP-3, " Processing and Control of Deviations and

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Nonconfomances" have been revised to provide for releasing of 4

materials to construction, with appropriate quality control to d

follow the material which is considered nonconfoming until receipt of documentation.

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4) Training sessions for Contractor's Supervisors and Quality -

Control personnel have been completed in regard to these procedure changes.

The above actions assure that appropriate procedures for acceptability and installation of materials are followed, and further assure that appropriate evidence for acceptability of materials is obtained.

Corrective Steps Which Will Be Taken Based on the actions described above, PGandE believes that adequate corrective action has been taken. Therefore, no additional corrective steps are necessary.  ;

Date of Full Compliance j Full compliance was achieved on June 30, 1982. f i

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