ML19322B647
| ML19322B647 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/01/1977 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19322B643 | List: |
| References | |
| 721101, NUDOCS 7912040674 | |
| Download: ML19322B647 (3) | |
Text
i L.xe POWER COMPANY Powr3 Btstonwo j
422 Socin Cuacen ST :zzi, Cuantortz. N. C. c:a4a aiwa= o Paa a r a.sa.
November 1, 1977 Vict Pets.ct=?
TELt*=o%t' Asta 704 5'ta= Peoowctio=
373 4 03 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Suite 1217 230 Peachtree Street, Northwest Atlanta, Georgia 30303 RE: RII:CEA 50-269/77-20 50-270/77-20 50-287/77-20
Dear Mr. O'Reilly:
With regard to your letter of October 5,1977 concerning IE Inspection Report 50-269, -270, -287/77-20, please find attached our response to the item of noncompliance described in Appendix A.
Very truly yours, Y
ap k
William O. Parker, Jr.
gg LJB:ge Attachment yets040b7'/
J RESPONSE TO OIE ' 'PECTION REPORT 50-269, -270,
' '/77-20
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~'lTEM Technical Specification 6.4.1 requires that the station shall be operated and maintained in accordance with approved procedures.
Section 4.2.4 of the Administrative Policy Nbnual (APM) establishes the methods by which changes may be made to approved permanent procedures and requires that changes to proceduras for temporary use be reviewed and approved prior to use by two members of the plant staf f at least one of whom shall hold a Senior Reactor Operator license on the affected unit.
Contrary to the above the inspector found several instances where signifi-cant numbers of steps in maintenance procedures had been marked as not applicable by the craftsman doing the work and for which no approval had been documented as specified in Section 4.2.4 of the APM.
Specific examples include:
J 1.
MP/0/A/1200/3 used to repair valve ILP-18 on Unit 1 under Work Request No. 19422 dated January 13, 1977.
2.
MP/0/A/1300/2 used to repair the 3A Low Pressure Injection pump on Unit 3 under Work Request No. 17774A dated November 3, 1976.
RESPONSE
aintenance procedures such as those described in this notice are written to cover all work that could be required to repair a specific piece of equipment. Applicable portions of the procedures are then performed and documented to implement specific repairs.
Steps which are not required to accomplish the specific repair are marked "not applicable", i.e., "N/A".
Marking steps not applicable is not considered a procedure change, there-fore Section 4.2.4 of the Administrative Policy Manual does not address this situation.
In fact, in one of the procedures cited in Appendix A, MP/0/A/1200/3, the procedure instructions include a statement to use only sections appropriate to the work being accomplished.
Procedures written to address general repairs and containing statements such as this will continue to allow "not applicable" entries without approval or documentation as these entries are considered part of the procedure.
To maintain control over the use of the "not applicable" designation in other procedures, Oconee Nuclear Station Directive 4.2.1.3 states, "Proce-dures must be performed in the sequence indicated unless the consequences of performing them in other than the prescribed sequence are evaluated by at least two individuals, one of whom is a supervisor familiar with the procedure and the system and/or component involved.
In the case of an Operating Procedure, this supervisor shall hold an NRC Senior Reactor Operators License". This directive does not require documentation of this evaluation.
To accomplish the intent of Technical Specification 6.4.1 by assuring that ocumentation records are adequate to reconstruct an activity, Station
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,41rective 4.2.1 will be revised by November 15, 1977 to provide for j
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_,ocumentation of this evaluation by requiring the reviewing supervisor
_ to initial the "not applicable" steps or sections reviewed pursuant to this directive. In the interim, all maintenance supervisors have been instructed by letter to perform and document this evaluation.
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