ML20133D487

Responds to Violations Noted in Insp Rept 50-414/85-08. Corrective Actions:Qa Procedure QA 601 Revised to Address Triennial Vendor Audits

ML20133D487
Person / Time
Site:	Catawba
Issue date:	05/25/1985
From:	Tucker H DUKE POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8507220218
Download: ML20133D487 (3)

Text

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DUKE Powen GOMPAhT P.O. HOx 33180 CHAMLOTTE, N.C. 28C42 HAL B. TUCKER ,,oy

,(([,"d*[*" (704) 073-4538 May 25, 1985 g cf C

U Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission -0 Region II N 101 Marietta Street, NW, Suite 2900

• Atlanta, Georgia 30323 5-Re: RII:LIU/RW 50-413/85-08

Dear Dr. Grace:

Please find attached a response to Violation No. 414/85-08-01 as identified in the above referenced inspection report.

Very truly yours, Hal B. Tucker lh!

LTP/mjf Attachment cc: NRC Resident Inspector Catewba Nuclear Station Robert Guild, Esq.

P. O. Box 12097 Charleston, South Carolina 29205 l

Palmetto Alliance 2135 Devine Street Columbia, South Carolina 29205 Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carlina 28207 DR 850529 G h 05000414PDR

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.n DUKE POWER COMPANY CATAWBA NUCLEAR STATION Violation (414/85-08-01): Failure to Audit Vendors Triennially 10 CFR 50 Appendix B Criterion XVIII states that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program. The licensee's accepted Quality Assurance (QA) Program (Duke 1-A,

-Amendment 7) Table 17.0.1 endorses Regulatory Guide 1.144 and ANSI N45.2.12 (1977) with the exception that audits l of suppliers are conducted in accordance with methods l described in ANSI N45.2.13 (1976). Regulatory Guide 1.44, j Regulatory Position C.3.b(2)(b) requires applicable -

elements of a supplier's QA program to be audited by the purchaser on a triennial basis.

Contrary to the above, the licensee's implementing pro-cedures do not require triennial audits of all vendors l by Duke Power Company. Therefore, triennial audits of all vendors are not being implemented by the purchaser.

Response

1. Admission or denial of the alleged violation:

Duke Power admits to the violation in that triennial audits of I certain vendors were not being performed. Duke Power Quality {

Assurance feels that effective vendor control has been maintained j through our annual evaluation of the vendor and our shop sur- j veillance program. t

2. Reasons for this violation if admitted. j t

Duke Power had agreed to comply with aegulatory Guide 1.144 with the following alternatives.

C3b external audits. " Duke Power Company will follow ANSI 45.2.13- l 1976, Paragraph 7.3 and Regulatory Guide 1.123 in complying with I Paragraph 4.3,4.4, and 4.5 of ANSI 45.2.12(1977)." Paragraph 7.3 of ANSI 45.2.13 permits us to perform audits of our suppliers in accordance with established methods. Those established methods did not require triennial audits of certain active suppliers. We feel that our established methods meet or exceed the requirements of Regulatory Guide 1.144 in that all vendors were being audited at the stipulated frequency by ASME and/or CASE members. Further vendor control was assured through our surveillance program of active suppliers.

This violation occurred, in our opinion, because the description of the exception taken to Regulatory Guide 1.144 in our Topical Report did not clearly communicate our intent to take exception to the triennial audits. Our program as implemented has been previously reviewed by NRC as well as the ASME and found to be satisfactorily carrying out our commitments.

Violation -(414/85-08-01): Failure to Audit Vendors Triennially Page -3. Corrective steps which have been taken and the results achieved:

Duke Power has reviewed its purchase orders and Approved Vendors List and determined there are approximately 60 active suppliers who have not been audited by Duke Power Company in the past three

-years. The quality. assurance programs for these suppliers have been monitored in the following ways: 1) Shop and product surveillance, 2) Annual evaluation. No loss of control over these suppliers has occurred. To date we have performed an audit of_eight vendors and seven more are currently scheduled through May 1985. To date we have found no indication of a Quality Assurance Program breakdown in any program audited.

4. ' Corrective steps which will be taken to avoid further violations:

Duke Power Company QA Procedure QA 601 will be revised to address triennial audits by stating that active vendors will be audited /

surveyed on a triennial basis. Duke QA will continue to monitor purchase orders and the Approved Vendors List to ensure that all active suppliers are audited / surveyed within the specified time zone.

5. _ Date when ' full compliance will'be achieved:

Our objective is assuring that all active vendors are under the scope of triennial audits. We will be in compliance by January 1, 1986.

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