ML19341D662
| ML19341D662 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/27/1981 |
| From: | Thies A DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19341D657 | List: |
| References | |
| NUDOCS 8104080359 | |
| Download: ML19341D662 (5) | |
Text
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'.y-s DUKE POWER COMPANY Powrn Butt.orwo 4aa Sourn Cuunca Srazer, CaAntortz, N. C. asaos r.
A C THits P.o. Box aste SEmsom Vict Pa.Sectm,
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February 27, 1981 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re:
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50-269/80-36 50-270/80-32 50-287/80-29
Dear Sir:
With regard to J. Philip Stohr's letter of February 5, 1981, which transmitted the subject inspection report, Duke Power Company does not censider the in-
~ formation contained therein to be proprietary.
Please find attached responses to the cited items of noncompliance.
'Very truly yours,
.A. C. Thies ACT:pw Attachment-80 N 81040
/
Mr. James P. O' Reilly, Director February 27, 1981 Page Two A. C. THIES, being duly sworn, states that he is Sr. Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this response to IE Inspection Report 50-269/80-36, 50-270/80-32, 50-287/80-29 with respect to Oconee Nuclear Station; and that all statements and matters set forth therein are true and correct to the best of his knowledge.
A. C. Thies, Sr. Vice President
. Subscribed and sworn to before me this 27th day of February, 1981.
Gb na (
7hvt Notary Public
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My Commission Expires:
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e W-DUKE POWER COMPANY OCONEE NUCLEAR STATION Response to IE Inspection Report 50-269/80-36, -270/80-32, -287/80-29 Violation-
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Item A: Technical Specification 6.4.1 requires that the station shall be operated and maintained in accordance with approved procedures and that written procedures with appropriate check-off lists and in-structions be provided for radiation control procedures. Technical Specifications 3.9.8 and 3.10.9 requires sampling, and analysis of liquid and gaseous radioactive wastes for radiostrontium.
Contrary to the above, the station was not operated in accordance with written approved procedures in that on December 10, 1980 there was no written approved procedures for radiostrontium analysis of liquid radioactive wastes and gaseous radioactive wastes.
This is a Severity Level V Violation (Supplement I.E.)
' Response Duke Power Company is meeting the requirements of Oconee Nuclear Station Technical Specifications 3.9.8 and.3.10.9 which require the analysis of liquid and gaseous radioactive wastes for radiostrontium and Technical Specification 6.4.1 which requires that these analyses be performed for us by Teledyne Isotopes, Westwood, New Jersey, in accordance with the schedule requiremects.
of Technical Specifications 3.9.8 and 3.10.9.
Teledyne also maintains a set of approved written procedures, including check-off sheets, for these analyses satisfying Technical Specification 6.4.1.
It is appropriate that Duke does not approve in detail Teledyne's procedures but rather examines the accuracy
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of the analyses performed by the vendor through such programs as the NRC split sampling program and the EPA cross-check program. This is done and neither the NRC nor Duke haveLthereby found any reason to doubt the accuracy of the-radiostrontium analyses performed by Teledyne.
In addition, Duke's General Office maintains and reviews an up-to-date copy of Teledyne's Environmental i
l Radiation Monitoring Quality Control Manual.
f Duke Power Quality Assurance Department performed an on-site survey of Teledyne's Westwood, New~ Jersey Quality Program.
The program was considered satisfactory, therefore, the location was placed on Duke's Approved Vendor List. The survey consisted of an evaluation of. their QA/QC Program which_ included a review of appropriate procedures.
I Procedures outlined in the QA Department Quality Assurance Program-have been established which implement-the survey / audit program for_ vendors. Vendor survey / auditing is performed by personnel in the Vendors Division of Quality Assurance.
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Detailed review and approval of Teledyne's analysis procedures would be an inappropriate use of a limited and scarce resource, the time of Duke Health Physics personnel, which can be used much more effectively in other appli-cations.. Duke Pover's examination of results effectively determines the accuracy of Teledyne's radiostrontium analyses.
Duke Power is currently pursuing this matter with Office of Nuclear Reactor Regulation (ONRR).
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, Violation Item B: Tect.nical Specification 6.4.1 requires that the station be operated and maintained in accordance with approved procedures and that written pro-cedures with applicable checkoff lists be maintained for radiation con-trol procedures, operation of radioactive waste management system, and nuclear safety-related periodic test procedures.
Contrary to the above, the station was not operated in accordance with written approved procedures in that (1) during the period of September 10, 1980 to December 10, 1980, the daily performance checks were not performed in the manner specified by Procedure HP/0/B/1000/67; (2) on February 6, 1980 and other occasions, the accuracy performance checks for boron analysis were out of limits and were not repeated as required by Procedure CP/0/B/100/3; and (3) during 1980 some precision control charts for phosphate, boron, and chloride analysis were not dated as required by Procedure CP/0/B/100/3.
This is a Severity Level V Violation (Supplement I.E.).
Response
Item 1:
This item resulted from an administrative / procedural deficiency.
The calibration procedure HP/0/B/1003/08 had previously had its performance criteria revised.
The QA/QC procedure HP/0/B/1000/67, which covers the same operation, had not been similarly reviscd to include the new criteria.
This procedure was-revised on December 24, 1980, to provide performance continuity between the two related procedures.
Items 2 & 3:
The procedure CP/0/B/100/3 was deficient in that it did not specifically address a method for documenting corrective action taken when an analysis exceeded control limits.
While-the documentation of the required rechecks was not performed, we are confident that the rechecks were performed as required.
In addition, personnel involved did not properly date or check charts in the procedure. All personnel involved have been counseled on their deficiencies, and all appropriate parsonnel-have been trained on proper use of the precision and accuracy control charts. Procedure CP/0/B/100/3 is being revised to assure adequate quality control in its use and associated documentation. Training will be given to all appro-priate personnel on the revised procedure.
The procedure revision and training will be completed by May 1, 1981.
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