ML20064D180

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Responds to Violations Noted in Insp Repts 50-369/78-26 & 50-370/78-12.Corrective Actions:Procedures QA-602 & QA-210 Will Be Revised by 781101 & Personnel Instructed Re Requirements for Verification of Corrective Actions
ML20064D180
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 10/16/1978
From: Parker W
DUKE POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 7810310259
Download: ML20064D180 (3)


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3.. m Mr. J. P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 RE: RII:VL3 50-369/78-26 50-370/78-12

Dear Mr. O'Reilly:

Please find attached our response to Items 369/78-26-01, 02, 03 and 370/78-12-01, 02, 03 which were identified in IE Inspection Report No. 50-369/78-26, 50-370/78-12.

Duke Power Company does not consider any information in the inspection report to be proprietary.

Ve truly yours,

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a' William O. Parker, J.

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IE INSPECTION REPORT:

50-369/78-26 50-370/78-12 APPENDIX A NOTICE OF VIOLATION License No. CPPR-83 Duke Power Company Based on the results of the NRC inspection conducted on August 8-11, 1978, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below. These items have been categorized as described in our correspondence to you dated December 31, 1974 A.

Criterion V of Appendix B to 10 CFR 50, as implemented by commitments set forth in the DPC Topical Report, Section 17, paragraph 17.1.5 specifies, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures,

. and shall be accomplished in accordance with these instructions, procedures,

." Procedure QA 602 of the DPC Quality Assurance Department Quality Assurance Manual requires that any deficiency found as a result of QA surveillances shall be documented utilizing Quality Assurance Form QA-602B (Vendor Surveillance Deficiency Report).

Contrary to the above requirements, the inspectors found that all deficiencies are not being documented on vendor surveillance deficiency reports. This was evidenced by a review of ITT Grinnell and Fisher Controls surveillance reports discussing deficiencies which were not documented by vendor surveillance deficiency reports.

This is a deficiency.

B.

Criterion V of Appendix B to 10 CFR 50, as implemented by commitments set forth in the DPC Topical Report, Section 17, paragraph 17.1.5 specifies, in part, that

" Activities affecting quality shall be prescribed by documented instructions, procedures." Paragraph 17.1.18 of DPC's Topical Report states that audit data are analyzed for quality trends and the results are forwarded to management.

Contrary to the above requirements, the inspector noted that DPC's procedure QA-304, failed to implement analysis of departmental audit data for quality trends. As a result, audit data for departmental audits was not being analyzed for trends and the results were not being forwarded to management.

This is a deficiency.

Criterion V of Appendix B to 10 CFR 50, as implenented by commitments set forth C.

in the DPC Topical Report Section 17, paragraph 17.1.5 specified, in part, that

" Activities affecting quality shall be prescribed by documented instructions, procedures,

. and shall be secomplished in accordance with these instruc-tions, procedures, Procedure QA-210 of the DPC Quality Assurance that the Audit Division Department Quality Assurance Manual requires, in part, and determine that effective corrective action has been taken on each finding if nec-the audit team shall evaluate the action taken and perform a reaudit, essary, to verify implementation of the corrective action.

finding IV-5 Contrary to the above requirements, the inspectors found that of a ctmpleted Civil and Electrical Division Audit E-77-4 had not been corrected in one area of the finding.

This is a deficiency.

RESPONSE

The specific deficiencies addressed in your report have been resolved with Procedure QA-602 will be revised by November 1, 1978, to pro-A.

vide more complete instructions on how to document and resolve deficiencies of the vendors.

different degrees of severity.

intended to address trend analysis of audit findings.

B.

Procedure QA-304 is not Audit Division personnel review previous audits and In performing each audit, Procedure QA-210 will be surveillances for evidence of recurring items.

revised by November 1, 1978, to formalize this practice.

Audit Corrective action for finding IV-5 of audit E-77-4 has been verified.

Division personnel have been reinstructed in the requirements for verification C.

of corrective action prior to closing an audit finding.

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