ML20106B482

Responds to NRC Re Violations Noted in Insp Repts 50-424/84-14 & 50-425/84-14.Corrective Actions:Qa Dept Procedures & Practices Revised

ML20106B482
Person / Time
Site:	Vogtle
Issue date:	08/24/1984
From:	Foster D GEORGIA POWER CO.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20106B478	List: ML20106B482
References
GN-410, NUDOCS 8410230223
Download: ML20106B482 (3)

Text

- _ .

. Aug 34.'so 19 9s 083 V0G7LE P O D.83

Georg a Power cotta'y w.r ee. m f

DEe'IYo4$.43.'se,u'!!i33ec

.- .o. -

.: me t

~

o.o.put. Georgia Power

! $'eYuNg'eP*" August 24, 1984 ' n"N e-l vore

• o.e:: ,

United States Nuclear Regulatory Comission Office of Inspection and Enforcement File: X7BG10 Region II - Suite 3100 Log: GN-410 l

101 Marietta Street Atlanta, Georgia 30303

Reference:

50-424/84-14, 50-425/84 14 Attention: Mr. R. C. Lewis The Georgia Power Company wishes to submit the following information concerning the violations discussed in your inspection report t 50-424/84-14 and 50-425/84-14:

Violation 50-424, 425/84-14-01.. "Thme Audits Not Doceented. Issued or Followed Up in Accordance with ANSI N45.2.12" - Severity Level IV.

(1) Georgia Power Company acknowledges that reports were not issued for three QA audits, which were conducted in 1981 and early 1982, as identified in the Notice of Violation. In addition, the OA 5.y. . A . . , l ui, n i min miwouvn nsa iuenuries one scanlondi

audit. CD04-81/13, which was never reported. This audit was con-ducted in February, 1981, to investigate the applicability of

, infomation gathered in a vendor audit for another plant to the Vogtle Project. The audit detemined that the information was not applicable to Vogtle and was therefore cancelled and no report was issued. A total of 509 audits have been conducted by the Site Quality Assurance organization at the Vogtle Electric Generating Plant from the start of construction in 1977 to the

, present, Only four of these, all of which are identified in the l NRC hetice of violation and this response, were not reported as required by ANSI N45.2.12.

(2) Georgia Power Company Quality Assurance Department Procedure

• o: QA .05-01. Revision 4, required that program elements be reviewed MS. to the depth necessary to determine whether they were being used

$8 wirsuLively. The draflu for the three audits 1oent1rloo in Ine gg violation as presented by the auditors to the QA Site Supervisor o for review were found to be inconclusive, subjective, or in some Ng cases incorrect by the QA $1te ' Supervisor. Issuance of the reports gg as conducted and written would have been contrary to procedure cia QA-05-01. It was tre QA $tte Supervisor's prerogative and decision l 84 not to issue the audit reports. However, the reasons for_ there

$ rierisinns were nnt dnrumented. 'The basic cauto of Lwonknoscon ana.e in the conduct and control of the subfect audits included Tnadequate direction in QA practices and procedures for audit planning, audit conduct and internal QA audit review and follow-up.

' Au& 34 '90 19: 58 943 UOETLE D 6 P.03

-(3) The draft repor.s for audits CC01-81/75 CD06-81/80, and $P01-82/124 have been reviewed for content and each concern raised in the draft reports is being re-evaluated at this time. Results of the reviews and evaluations will be femally documented. Each concern identified in the draft audits will be addressed, resolved

and, if necesssary, documented regardless of the validity of the l original concern or its significance.

(4) In. late 1982, the General Manager of Quality Assurance (GMQA) l conducted an in-depth assessment of Georgia Power Company QA Depart,  !

ment practices and identified the weaknesses that had previously i resulted in the deficiencies identified -by the NRC inspection i report. The conduct, results and actions of the GMQA's evaluation l

. . wore discussed in detail with NRC representatives at the exit l continuation meetings on July 2 and 5, 1984. The key actions '

taken to resolve the weaknesses found by the GMQA involved major changes to the QA Department procedures and practices in February, ,

1983. These changes significantly strengthened the planning,  !

, control and supervisory involvement in the QA audit process. For i

example, the audit process now includes:  !

- a discussion and approval by QA management of the audit objec- l tives prior to beginning the audit; a discussion between the audit team and QA management of the progress and potential findings of the audit about midway through the audit; and a discussion of the entire audit and a review of the init.ial report draft prior to scheduling the exit meeting.

Subsequent to the development and implementation of these upgraded 4

practices in early 1983, problems like those identified in the NRC inspection report have not recorred.

(5) Full compliance to applicable regulatory requirements was and

, has been achieved since actions taken in February, 1983. Corrective actions in paragraph 2 will be completed by September 28, 1984. .

Violation 50-424, 425/84-14-02, " Incomplete Corrective Action for Closure of Audit Findings" - Severity Level IV. 1 (1) Georgia Power Company acknowledges the discrepancies identified in the violation.

(2) Audit Finding Reports CD06-81/51-235 and CD06-81/51-236 were poorly written in that insufficient detail was provided to assure that corrective actions could be effectively accomplished by the audited organization. In fact, remedial actions had been taken by the ndited organization and long tem correctlye actions were in progress for the two audit findings at the time of their closure.

Closure was based on the past effectiveness of the audited organiza-tion in addressing audit findings and on the QA Site Supervisor's

' GU6 34.'84 85:59 093 UDGTLE D 6 P.eo-detemination that full resolution was forthcoming for both items.

There was, however, no objective evidence available to substantiate whether long-tem corrective actions were accomplished as committed.

(3) A review of actions taken relative to the concerns of Audit Finding tem corrective actions Reports 235 and 236 detemined that longished with one exception to resolve the involving the findings design basis have been accident accomp(D8A)testing of coating materials. DBA testing for coating materials used at the Vogtle Electric Generating Plant has been accomplished, but discrepancies exist between the DBA conditions noted in the Vogtle Final- Safety Analysis Report, typical DBA test conditions prescribed in ANSI N101.2-1972, and D8A test data for some of the coating materials.

The General Manager - Project Engineering and Licensing is in the process of resolving these discrepancies.

(4) Major changes to upgrade QA Department audit practices as discussed above were implemented in February,1983. These changes signifi-cantly strengthened the corrective action practices for audit findings and included the requirement that objective evidence of the adequacy and completion of corrective actions be available for review prior to closure of Audit Finding Reports. Compliance with this requirement has prevented further violations such as those identified in the NRC inspection report. ,

(5) The General Manager - Project Engineering and Licensing has infomed QA that discrepancies relative to DBA testing of coating materials are being evaluated and are expected to be resolved by September

28. -1984. All corrective actions will be complete and full compli-ance with applicable regulatory requirements will be achieved at that time.

This response contains no proprietary infomation and may be placed in the NRC Public Document Room. ,

Yours truly.

80 %#*

D. O. Foster REF/D0F/tdm xc: U. S. Nuclear Regulatory Commission .

Attn: Victor J. Stallo, Jr., Director Office of Inspection and Enforcement Washington, D. C. 20555 R. J. Kelly D. E. Dutton J. A. Bailey L. T. Gucwa R. E. Conway W. F. Sanders 0. Batum M. Malcom G. F. Head R. H. Pinson H. H. Gregory G. Bockheid J. T. Beckham B. M. Guthrie W. T. Niccorson P. D. Rice R. A. Thomas E. D. Groover J. L. Vota C. S. McCall G. A. McCarley C. E. Belflower i

- _ _ _ . . . _ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . . _ . . _ _ _ _ _ _ _ _ _ . _ . . _ _ _ . _ . . _