ML19273B163

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Responds to NRC Re Violations Noted in IE Insp Rept 50-369/78-42.Corrective Actions:Future Maint of Level 1 Cleanliness During Reactor Vessel Head Removal,Battery Room Doors Posted as Level 4 Cleanliness Areas
ML19273B163
Person / Time
Site: McGuire Duke Energy icon.png
Issue date: 01/18/1979
From: Parker W
DUKE POWER CO.
To: Oreillly J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19273B150 List:
References
NUDOCS 7902060426
Download: ML19273B163 (3)


Text

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DUKE POWER COM PANY Powra 13citarso 422 SocTn Cucacu STarzT, CHARIDTTE, N. C. 28242 E

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January 18, 1979 Vics PACStOENT Tgg gpuc%g; As ga 704 sv Esos PmODvCtiom j 3 7 3-40 8 3 c

Mr. J. P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 RE:

RII:kiC 50-369/78-42

Dear Mr. O'Reilly:

Please find attached our response to Item 369/78-42-01 which was identified in IE Inspection Report No. 50-369/78-42.

Duke Power Company does not consider any information in the inspec-tion eport tobepqprietary.

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Vgry truly yours

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,U w._ G. asla?

/ William O. Parker, Jr.

GJP:ses Attachment 790206042G 790000l3

L g Attachment J. P. O'Reilly - January 18, 1979 A

IE Inspection Report 50-369/78-42 APPENDIX A NOTICE OF VIOLATION Duke Power Company License CPPR 84 Based on the results of the NRC inspection conducted on December 5-8, 1978, it appears that certain of your activities were not conducted in full compliance with requirements as indicated below. These items have been categorized as described in our correspondence to you dated Decem-ber 31, 1974.

10 CFR 50, Appendix B, Criterion V, says in part " activities affect-ing quality shall be prescribed by documented instructions, procedures,

. and shall be accomplished in accordance with these instructions, procedures.

." In the area of housekeeping and cleanliness activities, these requirements are established by Duke Power Company Quality Assurance Program Topical Report, Section 17.2.5, and the Steam Production Department Administrative Policy Manual, Section 3.11.

These requirements are implemented by Station Directive 3.11.0, Housekeeping and Cleanliness, which states in part:

a.

Level I cleanliness shall be applied to any area containing open portions of the reactor coolant pressure boundary.

b.

Level IV areas shall be marked by prominently displayed signs as per Attachr ant 6 to the directive, Inspection of a Level IV cleanliness area shall be performed c.

on a random basis by a Quality Control Engineer.

Contrary to the above:

a.

The reactor vessel head was removed, stored, and replaced under maintenance work request OPS-12401 issued August 10, 1978, without the application of Level I cleanliness require-ments. The work was accomplished utilizing the less stringent Level III cleanliness requirements.

b.

On a tour of the Auxiliary Building on December 7,1978, the inspector noted that the v.ssential Battery Rooms were not posted as a Level IV cleanliness area.

The Essential Bcttery Rooms have not been inspected as a Level c.

IV cleanliness area since their provisional acceptance by the Steam Production Department in February 1977.

This is an infraction.

b l Attachment

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J. P. O'Reilly January 18, 1979 Page Two

Response

a.

As stated in the inspection report, the reactor vessel head was removed, stored, and replaced following the cold hydro to prepare for hot functional testing. The general area was not maintained as Level I cleanliness as required by the Administrative Policy Manual (APM) and implemented by Station Directive 3.11.0. A complete inspection of the Reactor Vessel and internals was performed prior to replacing the reactor vessel head to insure that cleanliness requirements were met.

In future removal of the reactor vessel head, the general area will be maintained as a Level I cleanliness area as required by the APM and Station Directives.

b.

As a result of the NRC inspection on December 7, 1978, all doors to the essential battery rooms have been posted as Level IV cleanliness areas as required by administrative controls.

Periodic inspections will be conducted of this area to insure proper posting of the essential battery rooms.

The station is in full compliance with the cleanliness requirements at this time.

c.

The Steam Production QC/QA Department periodic inspection program at McGuire presently includes an inspection for cleanliness of the essential battery rooms. These areas will be inspected on a periodic basis similar to other areas in the plant.

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