ML20197J534
| ML20197J534 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/09/1986 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Brownlee V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-904, NUDOCS 8605200067 | |
| Download: ML20197J534 (3) | |
Text
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- [9ha Pow r pany s-Waynesboro. Georg.a 30830 Telephone 404 554-9961. Ext. 3360 404 724-8114, Ext. 3360
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7 GeorgiaPower
- o. o. roster
'p' the souttwwn vectrc system May 9, 1986 United States Nuclear Regulatory Commission Region II File: X7BG10 Suite 2900-Log:
GN-904 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/86-15 Attention: Mr. Virgil L. Brownlee
~
The Georgia Power Company wishes to submit the following infomation
_concerning the violation identified in your inspection report 50-424/
j.
86-15:
Violation 50-424/86-15-01, " Inadequate Pullman Power Products Drawing Control Corrective Action" - Severity Level V
?
The violation states that Pullman Power Products' (PPP) drawing i
controlt were for the most part unacceptable between March 1983 and August 1985 as evidenced by internal document control audits performed by the Construction Department during the period.
Although appropriate 4
levels of management were informed and corrective actions were implemented throughout the subject interim period, consistent unacceptable error rates continued.
Effective corrective action to bring the PPP drawing control system back to acceptable standards and to prevent recurrence does 'not appear to have been taken until the problem was again identified in Georgia Power Company QA Audit Report GD07-85/22.
Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:
Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.
Both Georgia Power Company * (GPC) and Pullman Power Products (PPP) management were aware of PPP's drawing control problems and had made numerous efforts to resolve them.
As indicated in the USNRC inspection report, drawing control discrepancies were identified and corrected throughout the March 1983 - August 1985 period.
However, long-term actions to prevent recurrence were not effectively implemented.
8605200067 860509 DR g
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i Page Two As presented in the USNRC inspection report, a meeting was held during the inspection at the plant site with the inspectors and knowledgeable, responsible GPC and PPP personnel to discuss this issue.
The USNRC inspectors concluded from discussions, review of applicable procedures, and consideration of various other programmatic checks and balances to catch drawing control errors that the possibility of using outdated drawings for hardware installation was very slight.
Following the issuance of GPC QA Audit Report GD07-85/22 in March 1985, PPP relocated their drawing files from the engineering offices to a limited number of field libraries, where drawing files can be more closely controlled and maintained by PPP document control personnel.
To enable PPP management to evaluate the effectiveness of these actions, an ongoing internal monitoring program was developed and implemented.
This program provides for the tabulation of monitoring results by drawing file location and responsible individual, thus allowing attention to be focused on specific problem areas.
GPC Construction document control audits since September 1985 have shown significant improvement in PPP's ability to maintain an acceptable drawing control program.
Five of the last six audits of PPP drawing control have resulted in acceptable ratings.
An acceptable rating was missed in the remaining audit (conducted in January 1986) by a very small margin.
To prevent drawing control problems similar to those encountered with PPP from recurring, the following steps have been implemented for all contractor organizations and GPC Construction Department sections which maintain drawing files:
1.
Document control audits are conducted by the GPC Construction Depart-ment on each organization quarterly.
If an unacceptable rating
- results, the responsible organization is audited monthly until an acceptable level of control is established.
2.
Each audit report is evaluated by GPC Document Control to identify any areas of weakness within the audited organization's drawing control program.
The responsible organization is then directed to take appropriate corrective actions.
3.
GPC Document Control is maintaining charts to show error rates for each audited organization over an extended period.
This information is provided to the audited organizations and GPC management to be used in the early detection of adverse trends and to evaluate the effectiveness of previous corrective actions.
As indicated in the USNRC inspection report, effective corrective actions relative to PPP's drawing control program have been implemented.
The additional actions described in this response should prevent recurrence.
s Page Three This response contains no proprietary information and may be placed in the USNRC Public Document Room.
Yours truly,
/
1 C
D. O. Foste REF/D0F/tdm xc:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 J. H. Miller, Jr.
P. R. Bemis W. T. Nickerson G. F. Head J. A. Bailey D. S. Read J. T. Beckham
- 0. Batum Sr. Resident (NRC)
R. E. Conway G. Bockhold D. L. Kinnsch (BPC)
J. P. O'Reilly C. E. Belflower F. B. Marsh (BPC)
R. H. Pinson H. H. Gregory C. S. McCall (OPC)
P. D. Rice E. D. Groover D. A. Bartol (W)
B. M. Guthrie L. T. Gucwa J. E. Joiner D. E. Dutton C. W. Hayes (Troutman, et. al.)
R. A. Thomas G. A. McCarley D. C. Teper (GANE)
D. R. Altman R. W. McManus NORMS i_