ML19207A774
| ML19207A774 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/29/1979 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 7908220281 | |
| Download: ML19207A774 (8) | |
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D UK E POWER COM PA8Y /
- f PowEn Brawawo 422 Sorin CHURCH STREET, CluRWTTE N C 2624 '.
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Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:WDJ 50-269/79-10 50-270/79-10 50-287/79-10
Dear Mr. O'Reilly:
letter of June 7, 1979, which transmitted With regard to Mr. R. C. Lewis'50-269/79-10, 50-270/79-10, 50-287/79-10, Duke Power IE Inspection Report Company does not consider the report to be proprietary.
Please find attached our responses to the cited items of noncompliance.
Very truly yours, M
William O. Parker, Jr.
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DUKE POWER COMPANY OCONEE NUCLEAR STATION Response to IE Inspection Report 50-269/79-10, 50-270/79-10, 50-287/79-10 As required by 10 CFR 50, Appendix B, Criterion V, " Activities af f ecting
.. accomplished in accordance with instructions, pro-A.
quality shall be.The accepted Quality Assurance Program, Paragraph 17.2.5 cedures.
.. it is "With regard to specific operational activities.
required that such activities be accomplished in accordance with procedur requires that, The accepted Quality Assurance Program, Section 17.2.16, requires,
.. taking appropriate corrective action whenever any deficiency 1.
in the implementation of the requirements of the program is determined."
Contrary to the above, as of April 6, 1979, corrective action had not been taken to resolve the lack of measures to satisfy QA program requirements for protection of items in storage such as monitoring of inert gas pressure, monitoring of desiccant and shelf-life control.
10, 1975, This item was originally identified by the licensee on July and subsequently in September 1977, in February 1978, and December 1978.
Response
The items listed above were inventoried and evaluated with regard to shelf Protection requirements were life, preservation and preventative maintenance.
then determined.
Some items have been placed in plastic bags, and others in pl desiccant and indicator.
d tion in those instances where a shelf life could not be determine.
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The accepted Quality Assurance Program, Section 17.2.1.1 states in part "The policies described in the Corporate Quality Assurance Program 2.
Manual are implemented through departmental program manuals and proce-
- that, contained in the Corporate Quality Assurance dures."
The Policy Statement "All matters concerning quality assurance Program Manual stated in part:
h ll which cannot be resolved at the normal inmerfaces among departments s aEn be referred to the Senior Vice President, Additionally, the Accepted Quality Assurance Program, Paragraph 17.2.2
. Procedures and work instructions necessary to imple-states in part, ".
ment the requiremetns of the operational quality assurance program are developed.
Contrary to the above, on April 6, 1979, the requirerent for following inadequate, or improperly implemented up audit responses which are late, was not prescribed by documented instructions or procedures and no be resolved documented method existed for bringing matters which cannot Senior the normal interfaces among departments to the attention of the at Vice President, Engineering and Construction.
Response
Procedure QA-210 is being revised to clarify actions to be taken when audit The revised pro-inadequate, or improperly implemented.
responses are late, cedure will be issued by July 23, 1979.
A corrective action escalation policy has been approved by the Corporate Quality Assurance Manager and has been incorporated into the Co Assurance Manual as Chapter 16A.
bringing quality assurance matters which cannot be resolved at the normal interfaces among departments to the attention of the Senior Vice President, Engineering and Construction.
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QA Procedure No. QA-210, Revision 6, dated October 1978 3.
audit e program paragraph 5.5.1.4 that the effectiveness of that portion of the quality assurancl d days audited and in paragraph 5.5.3 that within thirty (30) ca en arresponsible after receipt of the audit report, Additionally, paragraph shall reply in writing to the audit report.shall be provided by the a follow-up report d the date 5.5.3.2 requires that audited organization stating the corrective action taken an corrective action was completed.
d Contrary to the above, activities were not accomplished with proce ures, h March in that of the audits reviewed for the periods March dd the response by the audited organization excee edays), for fo as required. Also, the thirty (30) calendar days (overdue f rom 4-19five audit il 3, contain the Additionally, one of the six audits reviewed did not 1979.
required evaluation.
Response
19, 1979, by the Corporate Quality A letter has been written, dated June of each interfacing depart-Assurance Manager, to the responsible management in responding to ment addressing their requirements and responsibilities irements.
audit findings and the importance in compliance with these requ 79410f
The accepted Quality Assurance Program Table 17.0-1 commits to ANSI Section 6.1.2 of the Standard requires a level B ware-4.
Additionally, Section 6.2.4 of the Standard N45.2.2-1972.
house to be weathertight.
prohibits the use or storage of food and drinks in the storage area.
Contrary to the above, rainwater leakage into the level B wareho noted in April 1979.
and lunches was observed in a portion of the warehouse which was not segregated from the level B varehouse.
Response
All Necessary work to correct leakage into the warehouse stored or consumed in the warehouse in the future.
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As required by 10 CFR 50, Appendix B, Criterion XVIII, "A comprehensive system of planned and periodic audits shall be carried out to verify com-B.
pliance with all aspects of the quality assurance program and to determ the effectiveness of the program."the program conforms to ANSI N45.2.12, Draft 3, ANSI N45.2.12 Draft 3, Revision 4 dated Table 17.0-1, states that Revision 4, dated February 1974.
" Applicable elements of the February 1974, Paragraph 3.4.2 requires that least annually."
quality assurance program shall be audited at r all aspects of Contrary to the above, a comprehensive system of audits i l Office the QA program was not carried out in that no audit of Generathe Oconee site was activities which affect the QA program at Specifically, during the period from January 1, 1978 through April 5, 1979.
the following activities were not audited:
control and records (Criteria VI and XVII) 1.
Document Administrative procedure and staff review activities thereof (Criteria 2.
11 and V) activities (Criteria IV, II and Staff review and inputs to procurement 3.
VII)
Activities of the calibration lab (Criteria XII, X, XI and SVII) 4.
to plant modifications (Criteria III, II and V) 5.
Staff review and input
Response
l A Departmental Audit, 0-79-6, of the Steam Production Department, Genera with the report being issued June 6, 16, 1979, Office, was completed MayThe audit encompassed the Standards and Testing Facili Saf ety Review Board (NSRB); document control; administrative procedures; 1979.
d procurement of materials, parts, and components; modifications and recor s.
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As required by 10 CFR 50, Apper. dix B, Criterion III, " Design Changes, to design control measures C.
including field changes, shall be subject commensurate with those applied to the original design and be approved by the organization that performed the original design unless the The accepted applicant designates another responsible organization."
"The con-Quality Assurance Program, Paragraph 17.2.3 atates in part, the control measures applied to the modification originally.
Contrary to the above, provisions were not established to require that revisions to saf ety-related Nuclear Station Modifications (NSM) be reviewed by the originating design organization; in that submission of the design the Design Engineering Department without l
package back to the originating design group for review prior to approva and implementation of the revised NSM.
Response
4, Provisions for the processing of station modifications are given in Section 4.
" Administrative Instructions for Station Modifications," of the Duke Power Company Steam Production Department " Administrative Policy Manual for These instructions are consistent with Section 17.2.3, "DesignBoth the APM/NS Stations."
Control," of the Duke Quality Assurance Program Topical Report.
l for the and QAPTR identify the station Manager as the individual responsib e is, pursuant to the provisions final approval of each station modification that
) has of Criterion III of Appendix B to 10CFR 50, the applica for the approval of station modifications and revisions thereto.
Individual modifications and revisions thereto may be designed, evaluated, i d on reviewed, etc. by various qualified individuals / organizations as determ ne The control measures a case by case basis consistent with established policies.
applied to each item are the same however.
Specifically, in the case of NSM-ON-0089, similar design control measures we Both the original applied to the original modification and Revision 6 thereto.
Manager.
It modification and Revision 6 received final approval by the sta is not P
As required by 10 CFR 50, Appendix B, Criterion XIV, which states in part,
" measures shall be established to indicate, by the use of markings such as D.
the status of inspections and tests performed stamps, rags, labels,
. "The licensee's upon individual items of the nuclear power plant 366-1971. ANSI accepted QA progarm imposes ANSI N45.2.4-1972/IEEE Std.
Paragraph 2.5.2, " Calibration and Control" states in part, N45.2.4-1972,
" Measuring and test equipment used to determine compliance with specifi-
. Records of the calibra-cations shall be adjusted and calibrated, tions shall be maintained and equipment suitably marked to indicate date of next required calibration.
Contrary to the above, measures were not established to indicate, by the use of markings, the status of calibrations of installed safety-related None of the identified in the Technical Specifications.
instruments not eleven installed safaty-related instruments reviewed were marked to indicate the status of calibration.
Response
The above item indicates that installed safety-related instruments are considered of Appendix B to 10CFR 50.
to be " test and measuring equipment" in the context with the reviewed and approved Duke Power Company This position is not consistent program for the control of test and measuring equipment as described in the Section 17.2.12 of the QAPTR addresses Quality Assurance Program Topical Report.and it is clearly evident that the con-(offline) test and measuring equipment, trols for test and measuring equipment are not applicable to installed instrumen-(For example, Items (f) and (g) of tation as construed by the inspection report.
Section 17.2.12 address storage and issuance of devices, functions which are only In context, it is also considered that ANSI applicable to offline devices.) differentiates between test and measuring equip-N45.2.4-1972/IEEE Std. 336-1971 and installed instrumentation.
ment Additionally, the distinction between test and measuring equipment and installed instrumentation has been previously addressed and resolved by Duke Power Company (Refer to Item B of Inspection Report and the NRC consistent with the above.and correspondence related thereto dated July 13, Au 50-269, -270, -287/77-9 16, August 29, October 21 and December 6, 1977 and January 3, 1978.)
It is considered therefore that an item of noncompliance as cited did not occur in August this instance.
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