ML19322A735
| ML19322A735 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/18/1972 |
| From: | Thies A DUKE POWER CO. |
| To: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19322A725 | List: |
| References | |
| NUDOCS 7911210767 | |
| Download: ML19322A735 (3) | |
Text
1 0 DUKE PowEn CoxPm Powra Dun.onto a
4aa SouTu Cascacu STnzzT, CuAnt.oTTz, N. C. asaos A. c THits P. o. Dox 217s sceseon vica Peasect=r Peooucteose asuo Taaresasissions February 18, 1972 Mr. John G. Davis, Director United States Atomic Energy Commission Division of Compliance Region II - Suite 818 230 Peachtree Stree?, Northwest Atlanta, Georgia 30303
Subject:
C0:II:CDi 50-269/71-8
Dear Mr. Davis:
In answer to your letter of January 21, 1972 concerning items of apparent non-compliance with AEC requirements, we offer the following:
1.
In regard to Item 1 of your enclosure, Plan U, " Quality Audits" was
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written and approved by the Vice President, Construction on August 23, 1971.
It was imposed as a requirement of the Quality Assurance Program by him on September 15, 1971. This plan provides a system for determining the effectiveness of the Quality Assurance Program.
In accordance with this plan the Vice President, Construction appointed an audit team which conducted an audit at Oconee on January 4, 5, and 6, 1972. Prior to this date all audits performed at Oconee were on an infor:aal bcsis and did not follow a written procedure.
2.
Regarding Item 2 of the enclosure, the test coordinator made a major change to the procedure not realizing that the deleted portion was a requirement of the Final Safety Analysis Report. We agree that this should not have occurred and was identified in the audit of this procedure. The sentence relating that.the omission of the inspection was not evaluated is' incorrect as this procedure had not received final audit and approval of test results. The requirements of this test will be met after hot functional testin'g and prior to fuel loading.
3.
Our response to the specific concerns for compliance with Criterion V of Appendix B to 10 CFR 50 are as follows:
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a.
A test procedure (TP 1B 150 9) had been written and approved prior
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to the initiation of the test. Daring the conduct of the test it was deter =ined that the procedure as written was not adequate.
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However, before the revisions were at, proved, portions of the test
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Mr. John G. Davis, Director
,,s Page 2 February 18, 1972 not affected by the revisions were completed. We have, however, cautioned the test coordinators to insure that procedures were approved prior to initiation of testing.
b.
The test coordinators have been informed that data called for in a proced,ure must be recorded unless proper approval of a change is obtained.
It was determined that hourly pressure and temperature readings c.
were not required for this test (TP 1B 1509), therefore, the data was not recorded. The test coordinator has been notified that deviation from a procedure must have the proper approval and be properly documented.
d.
The failure to initial a change to the test procedure on the cover sheet was due to the test coordinator writing the change outside of the available space for changes. The test coordinators have been cautioned to use additional change sheets as required rather than writing outside of the space provided. Regarding the changes r.ot being nede in the body of the procedure, we are unable to verify this discrepancy.
In regard to the four changes that were apparently predated, test coordinators have been in-f structed not to predate test procedure changes.
Prerequisites for the Reactor Internal Vent Valve Inspection e.
Test (TP 1A 200 1) were revised during testing because of unavailability of the underwater TV for viewing the vent valve seats. This resulted in an unauthorized major change to the test procedure. Therefore, to correct this problem, the vent valve seat inspection portion of the test is planned after hot functional testing. Other steps of the test procedure which were unaffected by this change have been done.
To strengthen the Oconee test program in general, Mr. J. E. Smith, Oconee Nuclear Station Superintendent, held a meeting on November 15, 1971 with all test coordinators in which comments by AEC Compliance inspectors on our procedures were reviewed in depth. The need for test procedure approval prior to the initiation of the test, proper documentation of changes to procedures, differentiation between major and minor changes,
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and the need for following a procedure as written or properly revised was emphasized. A follow-up meeting was held with these test coordinators on November 22, 1971 te discuss' other aspects of proper conduction of the test program and to answer any of their questions. We believe that these meetings have resulted in a better understanding of how to properly conduct and document our tests, v_
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1 Mr. John G. Davis, Director n
Page 3 Feb ruary 18, 1972 We trust that the above information adequately addresses the concerns of your letter.
Very truly yours, afee'is A. C, Thies ACT:vr cc:
Mr. W. S. Lee Mr. W.11. Owen Mr. E. D. Pcwell Mr. R. L. Dick e
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