ML19322B744
| ML19322B744 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/27/1976 |
| From: | Parker W DUKE POWER CO. |
| To: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19322B742 | List: |
| References | |
| NUDOCS 7912050743 | |
| Download: ML19322B744 (5) | |
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DUKE POWER COMPMY l'owen I$citoiso 422 SouTu Cnuncu Stater.Cuant.orTE, N. C. :mm 1
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'/*C F Passiocut 3?3-4033 S etaa. Paoovct'on August 27, 1976 Mr. Norman C. Moseley, Director U. S. Nuclear Regulatory Commission Suite 818 230 Peachtree Street, Northwest Atlanta, Georgia 30303 Re:
IE:II:TNE 50-269/76-6 50-270/76-6 50-287/76-6
Dear Mr. Moseley:
Pursvant to my letter of August 18, 1976, please find attached our responses to Items I.A.1 and.I.A.2 of Inspection Report 50-269, -270,
-287/76-6.
Additionally, your letter of July 27, 1976 indicated concern about the implementation of our management control systems and requested a descriptien ef actions planned or taken to improve their effectiveness.
Of particular concern, apparently, is the series of occurrences related to electrical equipment maintenance.
In this regard, as identified in our response to Item I.A.2, it is agreed that while adequate administrative controls existed, their implementation as related to interface control needs improvements.
This development, however, was recognized by the Steam Production Department and discussions initiated as to the cause and necessary corrective action prior to the June 9, 1976 Duke /NRC management meeting.
As actions to evaluate the situation continued, it was determined that improved interdepartmental communication and coordination was necessary.
Accordingly, on July 27, 1976 the Vice Presidents of the concerned organizations formally established the task force mentioned in the response to Item I.A.2.
It is considered that the established management control system served to detect an adverse trend promptly and initiate appropriate action to 7912050[f3
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l i-Mr. Norman C. Moseley i
Page 2' August 27, 1976 f
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evaluate the situation and resolve any problem.
Such management control i
ef forts will continue and should serve to detect and resolve any future j
similar adverse trends that may occur.
The specific corrective measures identified in the attached should serve to correct the specific applicable j
deficiencies.
Ve truly yours, s
t N a n..
&. aH I
William O. Parker, Jr.
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. Response to Item I.A.1 In the instances identified, the work performed was of a routine and/or non-complex nature, and was performed in a safe, competent manner by adequately qualified personnel. The use of the Maintenance Work Request and Out-of-j Normal Checksheet systems provided effective management controls over such t
maintenance and operating activities.
It is recognized, however, that the work was not accomplished in accordance with a procedure which had been reviewed and approved pursuant to the Oconee Technical Specifications.
TI,erefore, in order to prevent a similar recurrence, all future maintenance and operating evolutions affecting safety-related structures, systems and j
components will be performed using properly reviewed and approved procedures.
Specifically, for activities such as those addressed in the Inspection Report, procedures will be written to provide suf ficiently detailed guidance such that These qualified personnel can perform the tasks without direct supervision.
procedures will address such routine and/or non-complex work activities as The Work troubleshooting, minor maintenance, equipment isolation, etc.
Request and Out-of-Normal Checksheet systems will be used in conjunction with these procedures to provide additional control and to document work details. For more complex tasks, procedures containing more detailed guidance will be utilized, as is the current practice, as necessary to perform each task.
It is considered that the use of procedures which contain a degree of guidance appropriate to the tasks to be performed by qualified personnel on safety-related equipment will correct the identified deficiency, fully comply with applicable criteria and assure the quality of the work performed.
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g Response.to Item I.A.2 The Inspection Report states that maintenance activities on safety-related electrical equipment at Oconee, including Keowee, were not properly con-trolled, as evidenced by five reportable occurrences during the period January
-June, 1976.
While it is considered that adequate administrative controls did, and continue to, exist, it is agreed that the occurrences listed indi-cate that improved implementation of the established controls is necessary.
Specifically, improved implementation of interface controls related to electrical equipment maintenance has been determined to be required.
Those Company organizations involved in such activities which must interface with the Steam Production Department Oconee organization include the Operating Department, the Electrical Maintenance and Construction Department (EMSC) and the Relay, Meters and Communications Department (RM&C).
The Operating Department interfaces with Oconee in that it is responsible for the routine operation of Keowee Hydro Station and mechanical / hydraulic maintenance at Keowee.
EM&C is responsible for certain electrical maintenance (e.g.,
breakers) at Oconee and Keowee.
RM&C performs various relay and metering related activities at Oconee and Keowee.
As Keowee serves as the onsite emergency power source for Oconee, it is considered that the interface between personnel at Keovee and the Oconee organization is the most critical.
Therefore, as an immediate corrective
, measure, in addition to normal administrative controls, any maintenance work performed on safety-related electrical equipment at Keowee will receive prior review by a representative from the Design Engineering Department or the Steam Production Department General Office staff who is knowledgeable of the Keowee electrical systems design and designated individuals from the Oconee organization and the Operating Department's Keowee staff.
The purpose of this review will be to determine:
(1) that the work to be done has been clearly identifted, (2) that necessary procedures are available and are adequate to perform the specified task, and (3) that the work will not adversely affect other critical equipment. Any change in the scope of the work as reviewed will also receive prior review by the designated individuals.
Also, as the Oconee/ Operating Department /EM&C interface is of particular concern, a single EMSC work crew is being assigned to perform scheduled maintenance at Keowee.
This crew will receive additional training concerning maintenance administrative controls and the basis for such.
It is considered that these measures will be adequate until different and/or additional long-term corrective measures can be identified and implemented.
In this regard, it is considered that the deficiencies in the implementation of interface controls are primarily due to a lack of sufficient knowledge /
understanding of, and/or experience with, nuclear station administrative controls on the part of various interfacing organizations.
Therefore, an interdepartmental task force has been established to foster communications, identify problem areas and recommend solutions, coordinate joint corrective measures, etc.
This task force is currently reviewing existing administrative controls, work procedures, maintenance schedules and interface policies.
I Although the task force's efforts are, and will be, ongoing, a need for additional training and orientation for interfacing personnel has been
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identified.
Specifically, training in station procedures and work methods, Technical Specification requirements and interface policies - and the bases for these items - has been determined to be necessary.
Training classes l
have been scheduled to begin on August 30, 1975, and further training will be scheduled and conducted as necessary.
It is considered that the above described pcogram of immediate corrective action, in conjunction with a comprehensive effort to determine and correct any basic deficiencies, should serve to improve the implementation of Oconee
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interface control criteria.
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