ML19322E345
| ML19322E345 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/20/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19322E344 | List: |
| References | |
| NUDOCS 8003270233 | |
| Download: ML19322E345 (5) | |
Text
's DUKE Powen COMPm G
PowEn Uuss.oixo 422 Sourn Cucacu STREET, CHAHl.OTTE, N. C. coa 42 wi w w o. m a n n a.
February 20, 1980 Wcr Potsiorwr TELtewowt:Anta 704 Srsau Pacoversow 373-4083 b5 p
Mr. James P. O'Reilly, Director
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U. S. Nuclear Regulatory Commission
~ 2; ne dO Region II 101 Marietta Street, Suite 3100 3
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Atlanta, Georgia 30303 to Re: RII:CMH 50-269/79-35 50-270/79-32 50-287/79-35
Dear Sir:
With regard to Mr. J. P. Stohr's letter of January 28, 1980 which transmits the subject inspection report, Duke Power Company does not consider the infor-mation contained therein to be proprietary.
With regard to the item in the cover letter Duke Power Company is concerned about raising such an issue after it has been addressed on several other occa-sions. Historically, inspections and the associated reports were limited in scope, in that they sought to compare the licensee's actions with the regula-tions, license conditions, commitments, etc.
However, this report and the cover letter discuss the inspectors views on independent verification.
On page 6 the report documents that licensee representatives were appraised of this opinion. Duke Power welcomes such dialogue and will continue to make every effort to explain our practices to the various inspectors and will give appro-priate consideration to differing views.
However, Duke Power is concerned that such views are elevated to a level requiring a 20-day response without any apparent justification. Absent any references to the contrary, it appears that the inspector was in agreement with our administrative controls and concurs that they were in full compliance with the regulations.
It should be noted that the subject of independent verification was covered in depth in response to your request documented in a letter to Mr. A. C. Thies, Senior Vice President, Production and Transmission dated October 25, 1979. As a result of this request a special audit of operating practices specifically associated with such areas as independent verification was carried out.
Several recommendations resulted from tnis audit and are being pursued internally. The results of this audit and related areas was discussed in great detail in our meeting with Region II on November 30, 1979 (documented in Inspection Report l
50-269/79-40, 50-270/79-37, and 50-287/79-39).
It is therefore concluded that Region II management has been quite adequately informed of our positions and has had an opportunity to express their concerns, if any.
8003270253 OFMCIAL COPY
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t Mr. James P. O'Reilly, Director February 20, 1980 Page Two Please find attached our response to the cited iteits of noncompliance. This response is considered to address the aforementioned area of concern.
Ve,#y truly yours l
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William O. Parker, Jr.
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DUKE POWER COMPANY i
OCONEE NUCLEAR STATION Response to IE Inspection Report 50-269/79-35, -270/79-32, -257/79-35 ITEM A As required by Technical Specification 6.4, the station shall be operated and maintained in accordance with approved procedures.
1.
Station Procedure HP/0/B/1000/10, " Working limits for contamination con-trol" states that in areas where contamination exists above the working limits specified, a posted and/or roped-off contamination area will be
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established.
Contrary to the above, procedure HP/0/B/1000/10 was not followed in that a posted and/or roped-off contamination area was not established on November 19, 1979 around four Unit I high pressure turbine holddown bolts contami-nated above the limits specified by procedure.
2.
Station Procedure OP/0/A/1102/06, " Removal and Restoration of Station Equip-ment," Enclosure 7.1, step 7.1.13 specified the proper valve or breaker posi-tion required for restoration of a system to service.
Contrary to the above, on October 16, 1979, while restoring the Unit 3 low pressure injection system "B" train to service, vent valve 3GWD-152 was not closed as called for on the Removal and Restoration of Station Equip-ment Checklist, although the checklist was initia11ed and dated indicating the valve was left in the proper position.
This is an infraction.
RESPONSE
Item A.1 This item resulted from the failure of a vendor Health Physics Technician to follow the station procedure by posting a contaminated area after he tagged the bolts. The bolts were immediately moved to a posted contamination area. The area where the bolts were originally stored was surveyed with no contamination above limits detected. This incident and the importance of following procedures were discussed with all HP supervisors and technicians, and with the vendor site coordinator.
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Item A.2 This item resulted from personnel error in that the Nuclear Equipment Operator l
involved failed to properly close valve 3GWD-152. As noted in the inspection report, the valve was subsequently closed properly and clean-up procedurew were l
initiated. Temporary dams have been installed at the doorways of the Penetra-tion Rooms to restrict water spillage. Additional corrective actions are being considered.
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RESPONSE
Item A.2 Continued The NEO involved was counseled about his deficient performance in this incident.
All Operators will have reviewed this incident by February 22, 1980. The proper sequencing of valves or breakers prior to placing in service has been discussed at Shift Supervisors and crew meetings.
In addition, revisions will be made to OP/0/A/1102/06, Removal and Restoration of Station Equipment, which will include instructions for the Operators to ensure alignment of valves or breakers are sequenced such that the system will not be placed in service prior to completion of the second verification. These revisions will be completed by April 1, 1980.
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ITEM B As required by 10 CFR 20.203(f), each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents and pro-viding sufficient information to permit individuals handling or using the con-tainers, or working in the vicinity thereof to take precautions to avoid or mini-mize exposures.
Contrary to the above, on November 27, 1979, five bags of radioactive material located on the Unit 3 low pressure injection deck, were observed without the proper labels.
4 This is a deficiency.
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RESPONSE
This item resulted from Procedure IIP /0/B/1000/9, Removal of Items from Radia-tion Control Zones or Radiation Control Areas, being unclear in defining tag-j ging requirements for material removed from a RCZ or RCA.
This procedure has been revised to clarify the labeling of radioactive material. The material cited was removed and disposed of as radioactive waste.
The incident was re-viewed by all IIP supervisors and technicians, including vendor personnel.
The clarified requirements were also reviewed by these personnel.
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