ML19322B565
| ML19322B565 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/07/1973 |
| From: | Horn C DUKE POWER CO. |
| To: | Jennifer Davis US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 7912040594 | |
| Download: ML19322B565 (25) | |
Text
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DuxE PowEn OoxP m P. O. Box u17a GInmtoTre, N. G. canot CAR L HOR N. J R.
Pas seo s se f September 7, 1973 Mr. John G. Davis Deputy Director for Field Operations Directorate of Regulatory Cperations U. S. Atomic Energy Commission Washington, D. C.
20545 Re: Oconee Nuclear Station Docket No.
Dear Mr. Davis:
We have roccived your letter of August 17, 1973 concerning certain k
activities it Oconce Nuclear Station that apparently were not conducted in full ccmpliance with AEC requirements.
Attached is our reply to the specific concerns identified within your letter.
1.'e have taken several actions to improve the effcetiveness of the quality assurance program and aduinistrative procedures at Oconee Nuclear Station.
Based on infor=ation obtained at the June 21, 1973 exit interview and our appraisal of the operating situation at Oconee Nuclear Station, activities that were strengthened were:
l (1) Station Review Cot:=rittee review of safety-related items (2) Classification of equipment and actions as " safety-relatad" (3) Procedure for statien modifications ne following changes have been made:
i (1) The Station Review Ccemittee membership has been expanded to include additional members.
This will have the effect of providing additional expertisc within the cormittee membership and will provide additicnal members for discharging the cocmittee's duties.
1 (2) A number of the violations cited in the enclosure to your August 17, 1973 letter were the result of improper classification of procedures.
In certain cases a miscellaneous test procedura tras used with regard 1
to testing of a safety-related structure, system, or ccmponent.
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This was caused when judcrent en the part of the individuals in-volved resulted in certain miscellaneous test procedures being utili:cd for safety-related testing.
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Mr. John G. Davis P gn 2 September 7, 1973 the Steam Production Department "Ad=inistrative Policy Ebnual for Operational Quality Assurance of Nuclear Stations." In the future, all procedures which cav involve safety-related ite=s will be classified as safety-related and processed in a manner consistent with the " Administrative Policy Manual for Operational Quality Assurance of Nuclear Stations." In addition, a cooperative effort between the Stea= Production Departcent General Office and the Design Engineering Department is in progress to review identification of the safety-related structures, systems, and components at Oconee Nuclear Station in order that similar errors in judg=ent may be prevented in the future.
This activity is expected to be co=pleted by January 1, 1974.
P (3) At.the time of the June 21, 1973 audit by AEC/DRO personnel, modifi-cations were handled as they had been during the construction phase and an operations phase btation modification procedure was not in effect.
Since that time, a nuclear station todification plan has been developed and has been issued for review and corment by other departments within the co=pany.
In the interic, all station codifications are being reviewed by both the Design Engineering Department and the Steam Production Department General Office.
It is expected that the finaliced, approved plan will be implemented prior to October 15, 1973.
The approved plan will be incorporated into the " Administrative Policy Manual for Operational Quality Assurance of Nuclear Stations."
In order to strengthen the participation of the Steam Production Depart-ment General Office in the activities of the nuclear station, the Steam Production Department quality assurance staff issued on July 18, 1973 an audit plan which identifics station activities which shall be audited.
An objective of these audits is the verification that station safety-related activities are in cocpliance with established requirements.
The audit frequencies are commensurate with the safety significance of the items being audited.
In no case is the audit interval greater than 24 months.
Provisions are also cade for special audits which may be conducted at the request of co pany management.
To improve the quality and timing of station reports of abnormal occurrences, unusual events, and technical specification violations, an addition to the Administrative Policy Manual, to be incorporated by revision of the manual, was proposed on June 13, 1973.
This proposed addition places requirements on the station as to proper timing and distribution of each The revision also provides guidance with regard to appropriate report.
report content.
We are following this procedure at the present time and expect to revise the Administrative Policy Manual in the very near future.
We believe that the additional emphasis placed on quality work at the station, improved administration of station modifications, impicmentation
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Kr. John G. D vis Pags 3 September 7, 1973 of an effective audit plan, expansion of the Station Review Co=mittee membership, and increased management attention to activities within the station vill preclude future violations such as those identified in your letter.
Very truly yours, i);<'l,/f,i-j
- L k,. !, \\ h) j Carl Horn, Jr.
I' President Attachment 4
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t REPLY TO AEC/DRO LETTER OF AUGUST 17, 1973 (Attached to C. Horn's Letter of September 7, 1973)
Item 1.a.
Paragraph 50.54(1) of 10CFR50 specifies that manipulation of the controls of a facility shall be under control of a licensed operator.
Contrary to the above, an unlicensed maintenance technician manipulated the control rocs while performing miscellaneous test procedure, " Check of Safety and Shim Contral Rod Actuators for Frictional Binding."
REPLY The lifting of a control rod assembly using an air hoist on the auxiliary fuel handling bridge to determine frictional binding is not interpreted to be " manipulation of the controls of a facility" by Oconee Nuclear Station personnel.
The work was bei g performed in accordance with a miscellaneous test procedure, " Check of Safety and Shim CRA's for Frictional Einding."
There was no possibility of the reactor going critical during this operation, as the Reactor Coolant System was at refueling boron concentration as required by Section 7.0 of the procedure, " Required Plant Status." In addition, a Limitation and Precaution of the procedure states, "If source count rate increases by a factor of two (2) or more, suspend further motion and evalucte."
Section 8.0, " Prerequisite System Conditions," requires " Establish cccmuni-cation with control room over fuel loading co= mand sound-powered telephone circuit with operator at CRDS in direct com=unication with Reactor Operator in control room."
It is true that a licensed operator'vas not in the Reactor Building directing the movement of the control rod, however, the operation was being controlled by a licensed operator in.the control room monitoring the source count rr..e instrumentation.
Due to this control and monitoring by a licensed operatee, with the requirement to" suspend further motion and evaluate" if the count rate increased by a factor of two or more, and due to the fact that the Reactor Coolant System was at a boron concentration of greater than 1800 ppa boren, we do not feel that the safety of the unit was in any way compromised.
If after further evaluation it is determined that this procedure is not acceptable, we can require that a licensed operator be present in the Reactor Building to observe and direct similar activities in the future.
We would like to have further discussions with the AEC on this item.
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Item 1.b._
l tion of the Paragraph 50.59(b) of 10CTR50 requires a documented safety eva ua l
basis for the determination that a change of the f acility does not invo ve an unreviewed safety question.
d for Contrary to the above, written safety evaluations were not prepare modification of the following safety-related equipment:
(1) RCP Oil Drain System (2) Tu,rbine Bypass Control Modification (3) Feedwater Flow-Turbine Trip (4) Electrical Auxiliary Transf er (5) CRD Motor Fault Time Delay i
4 REPLY l ation.
The modifications listed did not receive a documented station safety eva nd During the interval between issuance of the Facility Operating License a ibility for June 1973, the station was in a transition period in that respcns Engineering station modifications was being transferred from the DesignIt was assumed that Des Department to the Steam Production Department.in accordance with the d modifications i
uality assurance Engineering, program, performed saf ety evaluations for design changes an t to perform.
which they had approved and directed the Construction D by Design Engineering.
h Since transfer of responsibilities to Steam Production is now complete, t e fi ht Oconee Nuclear Station organication has the responsibility for veri y ng t a i te required docunented safety evaluations have been performed by appropr a organications prior to implementation of the modifications.
hin A permanent plan for station modifications is presently under revi the Steam Production Depart =ent.It is expected that the per=anent plan will be im 1973, is in use.
The interim plan requires that all modifications have a safety analysis perforced or that a documented determination b prior to October 15, 1973.
tem or that the modification does not affect a safety-related structure, sys Component.
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N Item 1.c.
Criterion II of Appendix B to 10CFZ50 requires management review of the status and adequacy of the quality assurance program.
Contrary to the above, the Nuclear Safety Review Co==ittee (NSRC) failed to act on 18 ite s which had been placed before the Com=ittee for resolution during the period November 1971 to January 1973.
IIPLY The Nuclear Safety Review Co=mittee is an independent group established to help verify that the operation of Oconce Nuclear Station is performed in a safe manner consistent with approved operating procedures and license pro-visions; to review important proposed station changes, tests, and pre-cedures; to verify that unusual events and abnormal occurrences are properly investigated and corrected in a manner which reduces their probability of recurrence; and to detect trends which may not be apparent to a day-to-day observer.
In performing its duties, the com:ittee reports its findings and rccocmendations to the Exechtive Vice President and General Manager; Senior Vice President, Production and Transmission;~ Senior Vice President, Engineering and Construction; Vice President, Design Engineering; Assistant Vice President, Steam Production; and the Oconee Station Superintendent.
The committee has acted on the items that it deems within its purview, as determined by the Oconee Nuclear Station's Technical Specificatiens and the co=mittee's by-laws.
In the performance of its duties, the cc=mittee main-tains a list of outstanding items which includes reco==endations that the committee has previously made and the status of each.
The 18 ite=s referred to above were reco=mendations, made by the com=ittee in the performance of its duties, to various individuals within the company.
Some of these reco=cendations had not been acted upon at the time of this audit.
In order to assure that all co=mittee reco==endations are acted upon by responsibic company personnel in a timely manner, Mr. E. D. Powell, Assistant Vice President, review the status of the co=mittee's reco=nendations, to exped of the committee's reco=mendations and to report the status of the recom-mendations to him.
be resolved in a more timely manner.In this mannar, the co=mittee's recommendatio l
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Item 1.d.
Criterion V of Appendix B to 10CFR50 states, in part, that activities af-fccting quality shall be prescribed by documenred instructions, procedures, or drawings of a type appropriate to the circu= stances and shall be ac-complished in accordance with these instructions, procedures, or drawings.
Contrary to the require =ents of this criterion:
(1) Implementation of safety-related design changes was not as prescribed by applicable station instructions.
The.iollowing design changes were completed without prior submission to the Station Review Ccemittee 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) C6ntrol 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 REPLY - 1. d (1)
Administrative Procedure No. 10 requires that proposed modifications to station safety-related structures, systems and co=ponents be submitted in the for= of a Station Problem Report to the Chairman of the Station Review Co=mittee.
The procedure requires that the Station Review Cocaittee review the reque'st, and if the request is approved, forward the request to the Station Superin-tendent; and requires that the Station Superintendent determine if the modification adversely affects the proper functioning of safety-related structures, systems, or co=ponents.
Requests for modifications that we're originated within the station itself were being handled in a manner consistent with Administrative Procedure No. 10.
However, modifications that were made by Design Engineering Department were being handled in a manner similar to that used during the construction of the station.
In order to provide a consistent method for administering station modifi-cations, a permanent plan is currently under review within the Steam Pro-duction Deparecent as described in the reply to 1.b. above.
The Station Superintendent and the Station Review Co=mittee must approve all modifications to safety-related structures, systems and components before work is initiated.
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(Continutd)
(2) Implementation of safety-related tests was not as prescribed by applica station procedures and instructions.
e The following miscellaneous test procedures had not been properly classified as safety-related and as-signed an alpha-numeric designction as required by paragraph 4.4.4.2 of the Administrative Policy Manual for Operational Quality Assurance (A to assure proper reviews and approvals:
(a) 4160 V Eus Transfer Tine Test (b) Emergency Feedwater Pump Functional Test (c) Check of Scfety and Shim Control Rod Actuators for Frictional Ein (d) An+
Transfer from 1T to CT1 Transformer Without Generator L (e) Inspection of Retainer Nuts on ES Valves ockout (f) Hydro of RC-48 (g) Shuffling Control Components in Spent Fuel Pool P
REPLY - 1.d(2)
Tects which have a safety relationship should be assigned alpha-numeric designations and receive the proper review and approval before being used as required by APM/NS.
been perfor=ed using miscellaneous test procedures and did proper review and approvcl.
Therefore, on June 22, 1973, the Oconee Station Superintendent issued an Intrastation Letter to all Supervisors and St ti Test Coordinators requiring that safety-related tests must be administer d a on in accordance with the provisions of APM/NS.
e This will prevent recurrence of these violations.
A copy of this letter is enclosed as Attachment 1.
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Item 1.d (Continued)
(3) The following miscellaneoua test procedure was revised and the revisions were not processed as required by Paragraph 4.4.6.1 of the APM/US:
Energency Feedwater Pu=p Functional Test.
REPLY - 1.d(3)
The "Daergency Feedwater Pump Functional Test" was improperly classified as l
a miscellaneous test procedure.
Misec11ancous test procedures are not in-tended to address safety-related testing and, consequently, are not addressed by the " Administrative Policy Manual for Operational Quality Assurance of Nuclear Stations" (APM/NS).
The classification of this test as a formal Preoperational Test Procedure (TP) would have resulted in the procedure being subject to the requirements of the APM/NS.
The proper classification of future tests has bee:: addressed in the reply to ite= 1.d(2) above.
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(4) The following misec11aneous test procedure did not provide adequate instructions and limits for conduct of the test:
Check of Safety and Shim Control Rod Actuators for Frictional Einding.
REPLY - 1.d(4)
As stated in the reply to Item 1.d(2), improper classification as a non-safety-related test procedure led to the deficiencies in this procedure, and corrective measures have been discussed above.
With regard to this specific test, however, in the exit interview on June 21, 1973, a Regulatory Operations inspector listed the following deficiencies in the procedure:
(a) The minimum boron concentration of the reactor coolant was not specified.
(b) The verification of proper operation of the nuclear instrumentation was not specified.
(c) The qualifications of the hoist operator were not specified.
(d) Therc was t.o limitation on the number of control rods that could be in the "out" position at any one time.
(c) There was no requirement that the re-insertion of the control rod be verified.
(f) There was no requirement that the position indication be verified at any time during the operation.
(g) The procedure did not provide any method, such as check sheets, to assure that the procedure steps were followed or to document that the procedure was followed.
(h) The procedure did not specify the steps to be followed in the event of an emergency.
(1) The procedure did not require that a licensed operator manipulate the controls or to be present when the controls were manipulated.
(Controls in this case being the air hoist.)
Item (a) is not considered a deficiency in the procedure, " Check of Safety and Shim Control Rod Actuators for Frictional Einding," in that Section 7.0,
" Required Plant Status," required that the Reactor Coolant System be at re-fueling boron concentration.
This concentration is defined to be greater than 1800 ppm boron, therefere, minimum boron concentration was specified.
We agree with the concern in (b), (c), (d), and (e) and these co=ments will be incorporated into sn: subsequent procedures. With regard to Item (f),
the operation involved was monitored for position indication by a tape measure
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Ccenent (g) indicates that no method was provided such as check u sets to assure that procedure steps were followed. Data sheets were provided and were properly filled in supplying the information required in the procsdure.
For Ites (h), the procedure did not specify an e=crgency action.
It did, however, require ter=ination of the operation if the source count rate increased by two or more.
Item (1) is addressed in the reply to Item 1.a.
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%a Item 1.d -(Continued)
(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:
i Inspection of Retainer Nuts on ES Valves.
REPLY - 1.d(5) i
" Inspection of Retainer Nuts on ES Valves" was improperly classified as a miscellaneous test procedure.
Miscellaneous test procedures are not intended to address safety-related testing end, consequently, are not addressed by the
" Administrative Policy Manual for Operational Quality Assurance of Nuclear Stations" (APM/NS).
The classification of this test as a formal Pre-operational Test Procedure (TP) would have resulted in the procedure being subject to the requirements of the APM/NS.
The proper classification of future tehts has been addressed in the reply to Item 1.d(2) above.
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Item 1.e Criterion VI of Appendix B to 10CFR requires documents and changes thereto that affect quality to be reviewed and approved.
Contrary to the above, revisions to ciscellaneous test procedure, " Emergency Feedwater Pu=p Functional Test," were =ade without approval and review as required by AP11/:is, Paragraphs 4.4.2.2.3 and 4.4.6.l(c) and (g).
REPLY The " Emergency Feedwater Pu=p Functional Test" was improperly classified as a miscellaneous test procedure and, therefore, was not subject to the require-ments of the " Administrative Policy Manual for Operational Quality Assurance of Nuclear Stations." This error, and the subsequent ramifications, such as improper ad=inistration of procedure revisions is being corrected as dis-cussed in the reply to Item 1.d(2) above.
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h Item 1. f Criterion XI of Appendix B to 10CrR50 states, in part, that test procedures incorporate design requirements and acceptance limits.
Contrary to the above, miscellaneous test procedure, "4160 V Eus Transfer TL=c Test," did not provide acceptance licits or applicable design documents such that the test coordinator could deter =ine whether or not the test had been successful.
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REPLY The stated purpose of the procedure was to determine the operating time of breakers ElT1 and 31T3.
The procedure did not state acceptance criteria other than " data gathering for Design Engineering information." The procedure was conducted only to obtain inf ormation f or D.esign Engineering relating to the actual time to transfer and any notation of voltage transients during This test has yet to the rapid transfer from the normal to startup source.
be completed.
It has been assigned an alpha-nu=cric nunber TP/1/B/061C/16 and again has the same acceptance criteria.
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e Item 1.g Criterion XIV of Appendix B to 10CTR50 requires that the operating status of safety-related co=ponents be identified.
Contrary to the above, following perforcance of miscellaneous test procedure,
" Auto Transfer from 1T to CT1 Trcnsformer Without Generator Lockout," the status of the emergency start relays was not verified.
REPLY Citation for violation of Criterien XIV of Appendix B to 10CFR is due to failure to establish the status of the emergency start relays following performance of miscellaneous test procedure " Auto Transfer from 1T to CTl Transformer Without Generator Lockout." The procedure was perfomed with the requirceent that the Keovee Hydro emergency start relays be disabled.
The procedure was deficient in that it did not require documentation that the emergency start relays were returned to nomal conditions following the test.
Subsequent testing of the Keovee Hydro unit have verified that the emergency start relays were operating properly.
Future tests of the auto transfer will require that the proper condition of emergency start relays be verified prior to returning the syctem to operating status.
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Item 1.h Criterion 7XI of Appendix E to 10CTR50 requires that conditions adverse to quality be pronptly identified and corrected.
Contrary to the above, there is apparently no formal method for assuring that the superintendent be made aware of unusual events and abnor=al occurrences so that thcce may be assigned for pro =pt investigation and correction.
REPLY Effective June 28, 1973, an Incident Reporting Form has been provided which not only docu=ents that the Station Superintendent is notified of incidents, including unusual events and abnomal occurrences, but that proper reporting to the Steam Production Depart =ent General Office and to the Atomic Energy Coc=1ssion is perfor=ed.
This form along wit 1} an Intrastation Letter dated June 28, 1973, should correct this deficiency.
Copies of these are attached as Attachment 2 and Attachment 3.
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t' Item 1.1 Technical Specification 6.1.2.1, " Station Review Co==ittee," 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 recordcd in the SRC cinutes of Ibrch 29, April 5,10,16,19, 25, 27, and 30, eby 8 and 22, and June Miscellaneous test procedures, "4160 / Bus Transfer Time 15, 1973.
Test," and " Shuffling Control Components in Spent Fuel Fool," were not reviewed by the SRC.
(3) The SRC f ailed 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.
REPLY
- 1. i(1)
Since January 1, 1973, the Station Eeview Co=nittee has met 96 times.
One of these times a quorum was not in attendance; however, the Station Superintendent was present during this neeting.
At certain times it is difficult to obtain a quorum of SRC members.
To alleviate this, the Superintendent has appointed additional plant personnel to serve on the Station Review Co=mittee.
In the future, Station Review Committee business will not be conducted j
unless a quoru= of appointed Station Review Co=mittee members is i
present.
4 1.i(2) A limited number of procedures were not reviewed by the Station Review Committee because they were classified as miscellaneous procedures.
The "4160 V Bus Iransfer Time Test" and " Shuffling Control Component in the Spent Fuel Pool Test" fall into this Miscellaneous procedures of a safety-related nature have category.
been discontinued at Oconee, therefore, failure of the Station Review Committee to review new procedures will not recur.
In the past, the Station Review Committee did not review all changes to existing pro-cedures, but did review a certain percentage of the changes selected on a random basis.
However, changes to all procedures were reviewed by one of the Oconee Nuclear Station Group Heads each of which is a member of the Station Review Co==ittee.
In the future, all changes to procedures will be reviewed by the Station Review Cocmittee as presented to the Committee by the Group Head responsible for the procedure and change.
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A The Station Review Co=ittee is not required to review all test results.
The comittee does review test results as they pertain to major evolutions of station operations; such as, conpletion of hot functional testing, fuel loading, ::cro power physics testing, and major power plateaus of power escalation testing prior to proceeding with the next step or phase of operations.
1.i(3)
Station Review Co=:aittee minutes numbered 73-52 and dated June 6, 1973 do in f act document review by the Station Review Con:=ittee of premature lif ting of the main steam relief valves on Unit No.1.
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Item 1 1 Technical Specification 6.2.2 specifies that the superintendent shall cause i
the SRC to perform a review and prepare a written report for any abnormal occurrences and unusual events.
9 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 fo11ceing incidents 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 ES-1 and -2 f ailed to open REPLY The report of the valve CF-1 failure was reviewed by the Station Review Com-mittee on May 3,1973.
Failure of Valves ES-1 and -2 to open was reviewed by the Station Review Co==ittee on April 6, 1973.
Minutes of these meetings are identified as SRC Meetings 73-30 and 73-28,respectively.
These were availabic at the station for review at the time of the DRO audit.
The report of the abnormal occurrence, " Leak Through Incore Instrument Line," dated May 24, 1973, was reviewed by the Station Review Co=mittee in their June 25, 1973 meeting (73-63).
The unusual event associated uith the oil fire at i
RCP-1A1 is being reviewed by the Station Review Cc mittee. We believe the new method of documenting and initiating investigations of incidents insti-tuted June 28,1973 (see Attachments 2 and 3) will provide a more timely handling of these incident reports.
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Item 1.k.
'i Technical Specification 6.5, " Station Operating Records," specifies the required records to be retained at the station.
Contrary to the above, the minutes of the NSRC meetings held since January 30, j
1973 were not available at the station.
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During, the exit interview, minutes of the March 9,1973 and !! arch 20, /R0 1973 NSRC meetings had been incorrectly filed but were shown to the AEC inspectors during their inspection.
At the time of the Regulatory Operations audit only the preliminary minutes of the 15 30-31, 1973 NSRC meeting were not availabic.
Since these were not approved, Regulatory Operations Inspectors wer'e not allowed to review these They were informed that the preliminary minutes had been issued minutes.
for com:nent by the NSRC members.
Previously, the NSRC has issued minutes of their meeting in preliminary form, and after cce=ents are received, final minutes are issued. At the August 28, 1973 meeting, the NSRC decided to issue minutes in final fora as soon as possible af ter each meeting; any corrections to previous minutes will be noted in the next meeting minutes.
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Item 2 Violccions considered to be of Category III severity are as follows:
Criterion XVII of Appendix B to 10CFR50 requires certain records to be main-tained as evidence of activities affecting quality.
Contrary to the above, accurate records were not available regarding the performance of tiscellaneous test procedures, "Onergency Feedwater Pump Functional Test," and " Inspection of Retainer Nuts on ES Valves."
d'. PLY It is believed that bringing safety-related tests of this nature under the formal testing progra= f or review, approval and auditing, as required by the
" Administrative Policy Manual for Operational, Quality Assurance of Nuclear Stations" will correct the deficiencies noted in documentation of information in these two procedures.
The procedure regarding inspection of retainer nuts on ES valves had several c'nsures or marking over of signs to indicate "less than" which made it difficult, in some instances, to determine if the acceptance criteria had been Proper auditing of such data will prevent recurrence of this deficiency.
met.
The miscellaneous test procedure, "E=crgency Feedwater Pump Functional Test,"
has been reviewed and deficiencies were noted.
There were a number of blanks on data sheets not completed and several data items in the procedure had not been properly initialed.
Proper auditing of these procedures following their completion will help correct this condition.
In addition to the above, an Intrastation Letter has been issued to all Supervisors and Station Test Coordinators noting the deficiencies as found in these two procedures with a reminder of the necessity of being accurate and complete in the documentation as specified in test procedures.
(See Attach-ment 4) 60 9
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INTRASTATION LETTER OCOSEE UUCLEAR STATION June 22, 1973 TO:
Supervisors and Test Coordinators
SUBJECT:
Miscellaneous Tests In a meeting with ec=bers of the AEC/RO Branch on June 21, 1973,.we were informed that we were in violation of our Quality Assurance Manual by conducting tests on rafety related systc=s without following the
,re for review and approval as specified in the Quality Assurance
, proc 11anue To bring ourselves in co=pliance with our Quality Assurance Manual
- and Appendix B of 10CFR50 on futur,b testing of safety related systems or relating to safety, procedures cust be reviewed and approved according to our Quality Assuran'ce Manual Section 4.3 and 4.4.
Mis-cc11ancous' Tests are to be perforced only when there is no safety related system or saf ety considerations involved.
Group 11 cads are to make this determination.
The AEC audit of this particular area has indicated a number of Misec11a-neous Tests that have been performed without following our Quality Assurance Manual.
It is realized that this will have an effect on expediting Misec11aneous Tests but we have no a'lternative.
This requirement cust be rigidly applied.
Where tests not covered by the Test Index are'provided, a number for the procedure should be secured from cither L. E. Su= merlin or D. J Rains.
We will then correct the Procedure Index to ref1cet the addition of these tests.
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J. Ed Smith Superihtendent JES/vb ces:
Mr. E. D. Powell Ms. D. Brackett Ms. M. Branictt Ms. J. Hollins e
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^.techment 2 IITIRASTATION LETTER OCONEE NUCLEAR STATION June 28, 1973 TO:
Mr. J. W. Ilampton Group Ecads SULJECT:
Reporting of Station Incidents
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When an incident occurs here at the Station which could be interpreted as a violation of Technical Specifications it should be reported immediately.
to myself or, in my absence, to J.
U.' Hampto'n.' This incident will then be discussed with K. S. Canady or S. E. Nabow, by myself or J. F.a=pton, todeterminewhetheritsreportabletoA$C/R0asanAbnormalOccurrence, an Unusual Event, or other Technical Specification violation.
We vill also determine the degrec and type of investigation which is to be initiated.
Upon making this detcrmination with K. S. Canady or S. E.
Nabow, I or J. Ilampton will contact ME. Frank Jape, AEC/RO, to report this Technical Specification violation.
p.: Following 'this reporting to the AEC/RO, the investigation of the incident
.and preparation of a report will be initiated with copics cf this report being sent to J. W.11ampton as Chairman o,f the Station Review Com=ittee and myself.
The Station Review Committee will then r,cview the incident for possible safety implications and act to correct the situation and preclude recurrence.
Copics of the Station Review Co==ittee findings,
,along with a copy of the Incident Report, are to be forwarded to the following individuals:
Mr. Lionel Lewis-Chairman, Nuc1 car Safety Review Committee Mr. K. S. Canady as person responsibic for preparing any '
written report to AEC/RO.
Mr. J. E. Smith - Superintendent's File Mr. J. Cox - QA File h
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,9 Shm.4 gd.E(Smith Superintendent JES/vb
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i Date Unit Incident Investigetion Report No.
TI::r:/Date of Incident Incident
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Tir.c/Date Repor:cd to Sept.
Tinc/Date Reported to Gen. Office Tentative Type of Incident:
- TSV, Other General Office Representative Contacted AEC/RO Regica II Notified:
Yes No.
Tine /Date AEC Inspector Contacted Type of Incident:
A0; Tent ative,
Declared UE; Tentative, Declared TSV:
Tentative, Declared Investigator Assigned j
Routing:
This vorn Report SRC Renort
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Supt.
SRC NSRC Investi gator QA Gen. Office (KSC)
Other (Specify)
REMARKS:
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INTRASTATION LETTER August 29, 1973 OCONEE NUCLEAR STATION All Supervisors and Test Coordinators TO:
Complete and Proper Documentation of Test Procedures
SUBJECT:
audit performed by AEC/R0 personnel, several Test l
In the June 21, 1973 Procedures were reviewed which were in the Miscellaneous Test Procedur l
As noted in my Intrastation Letter of June 22,,1973, the use
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of Micec11aneous Teste are restricted to tests on non-safety related category.
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- However, systems and those uhich do not involve safety conriderations.
i that regardless of the type of test we are conducting it is important complete and accurate records be obtained at,the time the test is per-forced.
Several of the procedures reviewed by Regulatory Operations personnel turned up de sciencies in areas such as:
Where infor=ation is called for on data 1.
Data Sheets not co=plete.
chects, the data has been omitted.
Where data is specified, the should be so noted l
data should be entered or if not applicabic, it and initialed.
Blanks for notation of data taker are not filled in.
It is preferabic 2.
to sign data sheets rather than initial them.
The Proposed procedure revision forms are only partially complete.
3.
approval (Item 13 on the form) are not completed.
Proposed changes as listed in Item 6 on the Proposed Revision Form 4.
are not being properly made in the body of the procedure.
Data is being taken and then marked over making it highly illegibic 5.
Where mistakes such as these are made and casily misunderstood.
proper crasures should be made, or uhen made in ink they should be marked out and rewritten uith proper initials of the individual making In most instances it would be preferable to get a cican the change.
data sheet and start over When a Supervisor or Test Coordinator is using other personnel to obtain data it is important that the Test Coordinator or Supervisor review the data sheets to assure that the above probica areas do not exist.
9 w ' h u.[
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