ML20090D701

Responds to NRC Re Violations Noted in IE Insp Repts 50-424/84-09 & 50-425/84-09.Corrective Actions:Rev 2 to Procedure QC-T-11, Failure to Document Surveillance Insps on Fire Water Protection Sys, Issued on 840118

ML20090D701
Person / Time
Site:	Vogtle, 05000434
Issue date:	06/11/1984
From:	Foster D GEORGIA POWER CO.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20090D693	List: ML20090D701
References
GN-373, NUDOCS 8407190145
Download: ML20090D701 (2)

Text

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• Georgia Power Company Route 2. Box 299A Waynesboro, Georg:a 30830 i

Teiephone 404 554 9C41, Ext. 3360 1

- 404 724-8114 Ext. 3360 l D. O. Foster

.gg Georgia Power Gene t nage N "A*"'I*"*

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Vogtle Project Jgng 11, }gg4 United States Nuclear Regulatory Commission Office of Inspection and Enforcement File: X78G10 Region II - Suite 3100 Log: GN-373 101 Marietta Street Atlanta, Georgia 30303

Reference:

50-424/84-09,50-425/84-09 Attention: Mr. R. C. Lewis Gentlemen:

The Georgia Power Company wishes to submit the following information ,

concerning the violation discussed in your inspection report 50-424/84-09 '

and 50-425/84-09:

Violation 50-424, 425/84-09-01, " Failure to Document Surveillance Inspections on the Fire Water Protection System" - Severity Level V.

(1) Georgia Fower Company acknowledges that mechanical equipment installation surveillances for fire protection systems were not documented in accordance with Procedure QC-T-11, Revision 1, when Unresolved Item 83-20-01 was identified during NRC Inspection 50-424, 425/83-20 (October 25-28,1983). It should be noted, however, that Revisior. 2 of Procedure QC-T-11, which effectively clarified the intended purposes of the mechanical surveillance program and the documentation requirements for these surveillances, was issued on January 18, 1984, to re-solve the concerns of Unresolved Item 83-20-01. Subsequent to these corrective actions, during NRC Inspection 50-424,425/

84-09 (April 17-20,1984), Unresolved Item 83-20-01 was upgraded te a Violation.

(2) Procedure QC-T-11, " Mechanical Surveillance Program", was de-veloped to provide direction and guidance to the Georgia Power Company Surveillance Section in performing routine surveillance of mechanical equipment installation activities performed by site contractor organizations with their own quality assurance /

quality control (QA/QC) programs. The purpose of the mechanical surveillance program is to monitor contractor work activities on an informal basis to ensure that installation and testing of mechanical equipment is conducted in accordance with approved procedures, specifications, drawings, and codes; thereby evaluating the contractors' fulfillment of its contractural 8407190145 840628 PDR ADOCK 05000424 G PDR L'

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Mr. R. C. Lewis

. Page Two 1

obligations to the Georgia Power Company. It was never in-4 tended that the mechanical surveillance program be considered part of the Georgia Power Company Quality Assurance Program or of the Vogtle Project Fire Protection Quality Assurance Program. '

i Under the Georgia Power Company Quality Assurance Program, con-tractor QA/QC programs are reviewed, approved, monitored and

- evaluated through the Quality Assurance Auditing Program.

(3)&(4) Revision 1 of Procedure QC-T-11 was revised and reissued on 1

January 18, 1984. The following clarifications regarding the intended purpose and use of the mechanical surveillance pro-gram were made:

a. The mechanical surveillance program applies to all con- '

tractor QA/QC programs to the extent considered necessary by Georgia Power Company QC management.

b. Results of surveillances may be documented by the inspector

in a personal field book or other appropriate method. Sur-i veillance documentation is retained as considered necessary i by Georgia Power Company QC Management and is not considered j permanent quality assurance records. l

c. Discrepancies or deviations noted during surveillances are documented and dispositioned in accordance with Procedure '

GD-T-01, "Nonconformance Control," which provides for per-

manent quality assurance records for the identification,

[ evaluation, and resolution of' nonconforming items.

(5) Full compliance with applicable requirements was achieved with the

revision and reissuance of Revision 2 of Procedure QC-T-11 on-

} January 18, 1984.

1 i-9 This response contains no proprietary information and may be placed in

, the NRC Public Document Room.

I i Your truly,

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i D.d.Fo'st REF/DOF/tdm c xc: U. S. Nuclear Regulatory Consnission

' Attn: -Victor J. Stello, Jr., Director

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R. E. Conway- W. F. Sanders - 0. Batum - M.-Malcom-

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