ML19322A734
| ML19322A734 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/30/1972 |
| From: | Thies A DUKE POWER CO. |
| To: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19322A730 | List: |
| References | |
| NUDOCS 7911210766 | |
| Download: ML19322A734 (5) | |
Text
.
..k ^
U, s, A' g COMPU4 DUKE POWER COMPANY ATVHTA, y,;I m umww.
som cmme smo,commm.s.c....og 3 g 16 AUG A. C. Tarza same wc N.ione hr ~ -
P. o. Box.17e
~.r.....
June 30, 1972 g7 Mr John G Davis U S Atomic Energy Commission Directorate of Regulatory Operations Region 11, Suite 818 230 Peachtree Street, Northwest Atlanta, Georgia 30303 Re: RO:ll:CEM 50-269/72-6 50-270/72-5 50-287/72-3
Dear Mr Davis:
This is in response to your letter of June 2 expressing your general concerns with respect to the effectiveness of our Oconee quality Assurance Program and its implementation. As your letter states, there have been improvements in recent r.ionths in our program, but this letter is to specify what steps we have taken or will take to strengthen the implementation and supervision of our quality Assurance Program.
These steps are as follows:
Construction Deoartment at Oconee 1.
To strengthen competence and supervision in welding quality assurance, all welding engineers, fourteen welding inspectors and eleven engineers of other types have completed an 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> course in welding metallurgy.
(See my letter of June 21.)
2.
To provide additional management strength, the Project Manager and the i
Principal Field Engineer, have participated in technical conferences on quality control.
(See my letter of June 21.)
1 3.
Engineers involved in welding quality assurance have attended AWS courses on welding, testing, and inspection.
(See my letter of June 21.)
4.
Technicians are being given specific as well as broadening training in quality assurance.
5.
Procedures are being developed for certification of our inspection personnel in all areas.
6.
Regularly scheduled and documented weekly management meetings are held among quality assurance supervision on site.
(See my letter of June 21.)
- 79112107 0
Mr John G Davis Page 2 June 30, 1972 m
-: 4;pe _
7 Additional audits by sjte personnel,have been made and are planned.
p,. -
8.
As we have reviewed the deficiencies that you have cited in recent months, we note that their main thrust is with respect to adequacy of decamentation details and not unacceptable quality. We are strengthening the on-site organization to provide additional exclusive attention to the establishnent of complete and pertinent documentation.
9.
With the assistance of an outside consultant and others outside the Oconee organization, a massive integrated re-review of welding records is now at an advanced stage. We are keeping your office posted on the progress of this program and expect to provide you with full written reports in the near future. This applies particularly to the welding items that are out-standing in your letters.
- 10. We have had meetings with first-line quality assurance supervision on the site to emphasize the importance of a thorough Job of implementation and will conduct periodic per.formance reviews of these Individuals as well as of their supervision, with these reviews to be documented.
- 11. On an interim basis to clear up the backlog of necessary documentation, we are supplementing the site organization so that those personnel can emphasize the on going quality assurance program. These Imterim assion-ments include twelve experienced personnel with supervision from our Engineering Department, three experienced engineers on a part-time basis f rom other work in the Construction Department, experienced technicians from other groups within the company, and experienced technicians and supervision from outside consulting firms.
- 12. We have hired additional personnel for quality assurance work on site and are vigorously recruiting to obtain the services of other experienced persons to reinforce the organization with other than interim assignments.
- 13. The strengthening of Oconee's quality assurance implementation is and will continue to receive the daily attention of one or more Company officers, including measurement of results and af firmative action to improve effectiveness where Indicated.
Steam Production Deoartment The following documents the effort being put forth to strengthen the Oconee Nuclear Station Quality Assurance Program.
1.
The Oconee Nuclear Station Quality Assurance Manual is currently under development at the station. Portions of the manual are now in draft form. This manual will be the guiding document for implementation of the Quality Assurance Program and will address al0 applicable areas of Appendix B to 10CFR20.
Mr John G Davis Page3
'm June 30, 1972
.: g,_
2.
A guide for conducting stamiEtpr procedures" af ter the operating licenses are received is also under development at Oconee Nuclear Station and will be a part of the quality Assurance Manual. This guide will be similar to the " Guide for Conducting the Oconee Preoperational Test Program" and will define the requiremes.ts, preparation, revision and review of operating procedures, maintenance procedures, instrument procedures, periodic test procedures, emergency procedures, and alarm procedures.
3.
The General Office Review Committee is reviewing test procedures and results to identify areas that affect the quality of testing and its documentati on.
As defined by the " Guidelines for the General Office Review Committee Review of Nuclear Sataty Related Test Results" attached to the committee's bylaws, "the goal of the GORC is to emphasize the importance of the review process especially for those station personnel designated to review and appi:"e test results."
4.
A training program for new and recently hired engineers at Oconee Nuclear Station has been instituted to provide them with orientation into nuclear power plant work.
Included in this training program is an instructional period devoted to defining the requirements of 10CFR50 Appendix B and "Gulde for Conducting the Oconee Preeperational Test Program" to these new engineers.
5 The Steam Producti on General Office has defined an audit team to work with the General Office Review Committee to perform detailed audits within Oconee Nuclear Station to assure that the requirements of Criterion 18 of 10CFR50 Appendix 8 are properly met.
6.
Oconee Nuclear Station personnel are attending industry quality assurance meetings to obtain experience of other companies and organizations in developing the Oconee quality Assurance Manual and organization.
7.
As identified in my letter of June 21, 1972, (Reference item 7 of June 21 1972 letter, A C Thies to J G Davis) certain tests will be conducted at Oconee Nuclear Station to give further assurance that on tests previously, completed the results had not been compromised by lift,ed leads, wiring jumpers, or bypassed mechanism. These tests will be performed after the identification and control procedures outlined in the June 21 letter have been established.
8.
I met with members of the statien management and members of the Steam Production Department General Office Staff and later with all station supervising personnel on November 10, 1971, to discuss methods and procedures to assure that potential quality assurance problems are recognized and overcome.
. ** v%
s Mr John G Davis Page 4
-:~-d June 30, 1972
.p: : -
9 Meetings have been held with the supervisors and test coordinators of Oconee Nuclear Station that stress the importance of meeting Appendix 8 of 10CFR50. For example, on November 15, 1971, in a meeting with J E Smith, Oconee Nuclear Station Superintendent, each supervisor was given a copy of Appendix 8 of 10CFR50 and the supervisors were advised of the major areas of 10CFR50 Appendix B which applied to Oconee Nuclear Station quality Assurance Program. Emphasis was placed oa the need for cooperation of each supervisor in assuring that these requirements were met.
10.
Instructional memoranda such as the one issued February 29, 1972 by J E Smith to all supervisors and test coordinators further detail and strengthen the quality Assurance Progr am.
The subject matter of this memorandum is documented in the June 21, 1972 letter (Reference item 6,9 of June 21, 1972 letter, A C Thies to J G Davis). Also documented in the June 21, 1972 letter are steps that were taken to assure that FSAR require-ments are being properly identified and incorporated into the testing program,
- 11. At Oconee Nuclear Station a policy has been established that all safety related completed test results are being audited to assure that the test was performed according to the procedure and the acceptance criteria has been met. Where results of documentation is inadequate, retests are performed. As an example, the " Integrated Engineered Safeguards Test" was reperformed because of a conputer failure on documentation of the test results although the test was otherwise satisfactory.
12.
The Station Review Committee has been given instructions by the Oconee Superintendent to check each new procedure to assure that :he Acceptance Criteria is properly and specifically stated and that the FSAR require-ments and references are contained within the test procedure.
Involving several departments, we are reviewing the FSAR in its entirety to resolve any conflicts that may remain between it and as-built conditions, and this process will also become a part of our on going quality Assurance Program. This refers specifically to item 2 of your letter of June 2, 1972.
Mr Lee and I are in constant touch with the strengthening program des _ribed above.
We have periodically reviewed this' program with Duke's President, Mr ' ir n, and Executive Vice President, Mr Parker. The quality of results at Oconee is re-ceiving the highest priority of attention from our Company's top management.
Yours very truly, 4ddC A C Thies ACT/s cc Mr W S Lee Mr R L Dick Mr E D Powell Mr W H Cwen
.-....s n
-5 4g., _
,g --
Ltr to Duke Power Company..
- - ~
dtd 7/11/72 he -- -
DISTRIBITfION:
J. G. Keppler, RO j
J. B. Henderson, 30 RO Office of Operations Evaluation
' Q.__.!
R0 AD for Procedures RO AD for Inspection & Enforcement L, DD for Reactor Projects RO Files DR Central Files PDR Local PDR NSIC ITfIE l
5 h
c f
I i
I 1
i 1
i l
i
.