ML20101T632

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Responds to NRC Re Violations Noted in Insp Repts 50-269/84-26,50-270/84-25 & 50-287/84-28.Corrective Actions: Station Directive Describing Processing of Nonconforming Item Repts Deleted & Replaced by Compliance Manual Section
ML20101T632
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 12/04/1984
From: Tucker H
DUKE POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20101T627 List:
References
NUDOCS 8502060270
Download: ML20101T632 (2)


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Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Subject:

Oconee Nuclear Station IE Inspection Report Nos. 50-269/84-26 50-270/84-25 50-287/84-28

Dear Sir:

In response to your letter dated November 9, 1984 which transmitted the subject Inspection Report, the attached response to the cited item of non-compliance is provided. I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge on December 4, 1984.

Very truly yours, f std.

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Hal B. Tucker SGG:slb Attachment cc:

Mr. J. C. Bryant NRC Resident Inspector Oconee Nuclear Station 8502060270 850110 gDRADOCK 05000269 PDR

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-VIOLATION-

-Technical Specification 6.4.1 states that'the station shall be operated and-maintained in accordance with approved procedures. QA Procedure QCK-1 requires that any personnel discovering a nonconforming item shall promptly initiate a nonconforming item report _(NCIR) and that production personnel shall initiate.NCIR's :Ln accordance with Station Directives.

- Contrary to the above. requirements, although licensee personnel determined Lon or about September 5, 1984,:that a Cuno filter in the low pressure service water supply line to.high. pressure injection pump coolers had been

. installed backwards, an NCIR was not written until September 24, 1984.

Also, neither Station Directives nor the general employee training program address NCIR's.

'This is a Severity Level IV violation (Supplement I).

RESPONSE

1) Admission or denial of the' alleged violation:

This violation is correct as stated.

2)~ Reasons for.the violation:

This violation resulted from an administrative deficiency.; The Station Directive describing the processing of NCIR's-did not include.the prevision that any person could initiate a NCIR. The directive referred-to NCIR's being issued by the QA Group, thereby inferring that only the QA Group was responsible for the initiation of a NCIR. This ambiguity led to the delay in the initiation of:the NCIR.'

3) Corrective actions taken and results:

The Station Directive-describing the processing of NCIR's has been deleted and replaced by. a section in the Compliance Manual.- This section includes the requirement that NCIR's may be. initiated by any station personnel discovering items which do not conform with specifi-cations, codes, design drawings, or other QA requirements.

In addition the Station' Directive concerning Reporting has been revised.

to include the requirements that any personnel' discovering-a' non- -

conforming item, shall promptly initiate a'NCIR.

'4)

Corrective actions.to be taken to avoid further' violations:-

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None 4

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5) Date when full compliance will-be achieved:

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The revisions to Station Directives ~noted'in.the corrective action described above were offective December 1, 1984.

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