ML19322A906
| ML19322A906 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/17/1973 |
| From: | Jennifer Davis US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Horn C DUKE POWER CO. |
| Shared Package | |
| ML19322A903 | List: |
| References | |
| NUDOCS 7911270663 | |
| Download: ML19322A906 (8) | |
Text
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UNITED STATES 3
S ATOMIC ENERGY COMMISSION b
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washington. D.C. 20P45
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aus 2 7 wa Duke Power Company Docket No. 50-269 ATTN: Mr. Carl Horn President Power Building 422 South Church Street Charlotte, North Carolina Gentlemen:
This letter refers to the inspection of your activities authorized under AEC Facility License No. DPR-38 conducted by Messrs. Murphy, Warnick and Jape of our Region II (Atlanta) Regulatory Operations Office on June 20-21, 1973, at the Oconee Nuclear Station. It also refers to the discussions held with you and Messrs. Thies, Parker, Lee and Powell on July 19, 1973, by Mr. Moseley, Director of our Region II (Atlanta) Regulatory Operations Office.
Based on the results of this inspection, it appears that certain of your activities were not conducted in full conpliance with AEC requirements. These matters, which were discussed with Mr. Powell and members of his staff at the conclusion of the inspection and with you and others at the July 19, 1973 meeting, are identified in the enclosure to this letter. These violations have been categorized into severity levels as described in corre-spondence to you dated June 5, 1973.
As you are aware from the " Criteria for Determining F.nforcement Action," which was provided to you with the letter from Mr. Kruesi of November 1, 1972, the enforcement actions available to us in the exercise of our regulatory responsibilities include adminis-I trative actions in the form of written notices of violations, civil monetary penalties, and orders pertaining to the modification, suspension or revocation of an operating license. After careful evaluation of tl. license violations identified in the enclosure to this letter, and with consideration given to the relatively short period of time you have possessed an AEC facility operating license, this Notice of Violation is sent to you pursuant to the provisions of Section 2.201 of the AEC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office within 20 days of your receipt of this notice, a written statement of explanation in reply including:
(1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further violatiens; i
and (3) the date when full compliance will be achieved.
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Mr. Carl Horn,s As discussed during the meeting in your office on July 19, 1973, we believe that,. collectively, the inspection findings are indicative of a failure to adequately implement your operational quality assurance program. Specifically, we believe that these findings indicate that:
- 1) the Station Review Committee has not functioned as required by the Technical Specifications; 2) the Superintendent has not performed reviews of operations and has not developed a system for obtaining information to permit the performance of such reviews: and 3) the administrative procedure system has not prevented improper classi-fication of procedures, thereby allowing safety related procedures i
to be generated without proper review. These conclusions are based on an inspection of a limited sample of your quality assurance program within selected areas.
In addition to your response to the specific violations identified in the enclosure, please provide us with your comments concerning those actions taken or planned to improve the effectiveness of your quality assurance program and management control systems.
Should you have any questions concerning this letter, we would be glad to discuss them with you,
- incerely, J. G. Davis, Deputy Director for Field Operations Directorate of Regulatory Operations
Enclosure:
Description of Deficiencies i
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fus 1 'l E B.er. Carl Born
-b beat J. F. O' Leary, L L L Ragalkan, 20 V
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L Cienbusse. L L F. Fraley, Acts (3)
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J. O Mandria, L L D. Thornberg, 30 J. G. Davis, 30
.J. Galls, 00C s
F. A. Morris, 30 L, Reeder, 30 J. G. Esppler, 30 R Central Files
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L Sehwenoer L DR Reading Files
..T D. J. Skovholt, L 30 Films J. F. O'Reilly, 30:1 FDR
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O C. Moseley, 30 II Imeal FDR
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Form AEC.Sta (Rev.9 53) ABCM 0240
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ENCLOSURE e'3 Duke Power Company Docket No. 50-269 Certain of vour' activities conducted under JZC Operating License No. DPR-38 appear to be in violation with license requirements as indicated below:
1.
Violations considered to be of Category II severity are as follows:
Paragraph 50.54(i) of 10 CFR 50 specifies that manipula-a.
tion of the controls of a facility shall be under control of a licensed operator.
Contrary to the above, an unlicensed maintenance technician manipulated the centrol rods while performing miscellaneous test procedure " Check of Safety and Shim Control Rod Actuators for Frictional Binding."
b.
Paragraph 50.59(b) of 10 CFR 50 requires a documented safety evaluation of the basis for the determination that a change of the facility does not involve an unreviewed safety question.
Contrary to the above, written safety evaluations were not prepared for modification of the following safety related equipment:
(1) RCP Oil Drain System.
(2) Turbine Bypass Control Modification.
(3) Feedwater Flow-Turbine Trip.
(4) Electrical Auxiliary Transfer.
(5) CRD Motor Fault Time Delay, Criterion II of Appendix B to 10 CFR 50 requ' ires management c.
review of the status and adequacy of the quality assurance program.
Contrary to the above, the Nuclear Safety Review Committee (NSRC) failed to act on 18 itens which had been placed before the Committee for resolution during the period November 1971 to January 1973.
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Enclosure ~h d.
Criterion V of Appendix B to 10 CFR 50 states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the requirements of this criterion:
(1) Impicmentation of safety related d'esign changes was not as prescribed by applicable station instructions. The following design changes were completed without prior submission to the Station Review Committee for review, and without review by the station superintendent to determine if the change could proceed with his approval or whether additional review and approval was required:
(a) Control Rod Drive Gas Vent Piping.
(b) RCP Oil Drain System.
(c) Turbine Bypass Control Modification.
(d) Feedwater Flow-Turbine Trip.
(e) Electrical Auxiliary Transfer.
(f) CRD Motor Fault Time Delay.
(2)
Implementation of safety related tests was not as prescribed by applicable station procedures and instructions. The following miscellaneous test procedures had not been properly classified as safety related and assigned an alpha-numeric designation as required by paragraph 4.4.4.2 of the Administrative Policy Manual for Operational Quality Assurance (APM/NS), to assure proper reviews and approvals:
(a) 4160 v Bus Transfer Time Test.
(b) Emergency Feedwater Pump Functional Test.
(c) Check of Safety and Shim Control Rod Actuators for Frictional Binding.
(d) ' Auto Transfer froo IT to CTl Transformer Without Generator Lockout.
(e) Inspection of Retainer Nuts on ES Valves.
(f) Hydro of RC-48 (g) Shuffling Control Components in Spent Fuel Pool.
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Enclosure am (3) The following miscellaneous test procedure was revised and the revisions were not processed as required by paragraph 4.4.6.1 of the APM/NS:
Emergency Feedwater Pump Functional Test.
(4) The following miscellaneous test procedure did not provide adequate instructions and limits for conduct of the test:
Check of Safety and Shim Control Rod Actuators for Frictional Binding.
(5) The following miscellaneous test procedure did not receive the proper approval or review as required by paragraph 4.3.2.2.8 of the APM/NS:
Inspection of Retainer Nuts on ES Valves.
e.
Criterion VI of Appendix B to 10 CFR requires documents and changes thereto that affect quality to be reviewed and approved.
Contrary to the above, revisions to miscellaneous test procedure " Emergency Feedwater Pump Functional Test" were made without approval and review as required by APM/NS, paragraphs 4.4.2.2.3 and 4.4.6.1(c) and (g).
f.
Criterion XI of Appendix B to 10 CFR 50 states, in part, that test procedures incorporate design require-ments and acceptance limits.
Contrary to the above, miscellaneous test procedure "4160 v Bus Transfer Time Test" did not provide acceptance limits or applicable design documents such that the test coordinator could determine whether or not the test had been successful.
1 g.
Criterion XIV of Appendix B to 10 CFR 50 requires that the operating status of safety related components be identified.
Contrary to the above, following performance of miscellaneous test procedure " Auto Transfer from 1T to CT1 Transformer with-out Generator Lockout," the status of the emergency start relays was not verified.
h.
Criterion XVI of Appendix B to 10 CFR 50 requires that conditions adverse to quality be promptly identified and corrected.
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Englosure.
m Contrary to the above, there is apparently no formal method i
for assuring that the superintendent be made aware of unusual events'and abnormal occurrences so that these may be assigned for prompt investigation and correction.
1.
Technical Specification 6.1.2.1, " Station Rcview Committee,"
specifies the functions and responsibilities of the Station Review Committee (SRC).
Contrary to the requirements of this technical specification:
(1) The SRC did not always have a quorum in attendance at its meetings.
(2) The SRC failed to review new procedures, proposed revisions to safety related procedures and test results.
This is recorded in the SRC minutes of March 29, April 5, 10,16,19, 25, 27 and 30, thy 8 and 22, and June 15, 1973.
Miscellaneous test procedures "4160 v Eus Transfer Time Test" and " Shuffling Control Components in Spent Fuel Pool" were not reviewed by the SRC.
(3) The SRC failed to review station operation and safety considerations.
Specifically, the minutes of the SRC did not reflect that the SRC had reviewed the premature lifting of the main steam relief valves.
j.
Technical Specification 6.2.2 specifies that the superintendent shall cause the SRC to perform a review and prepare a written report for any abnormal occurrences and unusual events.
Contrary to the requirements of this technical specification, as determined from discussions with the staff and from available documentation, it was not evident that the' superintendent caused the following incident to be reviewed.
(1) Abnormal Occurrence - Leak in Incore Instrumentation Line.
(2) Unusual Event - Oil Fire at RCP-1A1 (3) Engineered Safeguard Valve CF-1 not fully open.
(4) Engineered Safeguard Valves BS-1 and -2 failed to open.
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Technical Specification 6.5, " Station Operating Records,"
specifies the required records to be retained at the station.
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Enclosure,
O Contrary to the above, the minutes of the NSRC meetings
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held since January 30, 1973, were not available at the station.
2.
Violations considered to be of Category III severity are as follows:
Criterion XVII of Appendix B to 10 CFR 50 requires certain records to be maintained as evidence of activities affecting quality.
Contrary to the above, accurate records were not available regarding the performance of miscellaneous test procedures
" Emergency Feedwater Pump Functional Test" and " Inspection of Retainer Nuts on ES Valves."
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