ML19316A110

Responds to NRC 741127 Ltr Re Violation Noted in Insp Repts 50-269/74-10,50-270/74-08 & 50-287/74-11.Corrective Actions: Mgt Control Sys Reorganized,Computer Program Schedules, Periodic Tests & Security Training Developed

ML19316A110
Person / Time
Site:	Oconee
Issue date:	12/19/1974
From:	Thies A DUKE POWER CO.
To:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19316A101	List: ML19316A103 ML19316A106 ML19316A110
References
NUDOCS 7911280632
Download: ML19316A110 (11)

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i December 19, 1974 i

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Mr. Norman C. Moseley, Director Directorate of Regulatory Operations

! U. S. Atomic Energy Co= mission Region II - Suite 818 230 Peachtree Street, Northwest I Atlanta, Georgia 30303 Re: R0 Inspection Report 50-269/74-10 50-270/74-8 50-287/74-11

Dear Mr. Moseley:

We have rcviewed R0 Inspection Report Nos. 50-269/74-10, 50-270/74-8 and 50-287/74-11. Duke Power Company does not consider the infor-mation contained in this report to be proprietary.

With regard to the specific concerns identified in your letter, please find attached our responses. In addition to the information provided in the attached, we have taken actions to improve the effectiveness of our management control systems. Most significant of these actions is the recent reorganization within the Steam Production Department. This reorganization has served to clarify areas of j responsibility, and the authority commensurate thereto, both within the Steam Production Department General Office and within the station organization. Also, the position of Manager, Nuclear Production has been established. The nuclear station Managers report to the Manager, Nuclear Production who, in turn, reports to the Vice President, Steam Production. This change has served to strengthen line management i

control and involvement with regard to nuclear station operations.

To assist management in effectively discharging its responsibilities, a program has been developed to maintain and periodically distribute a written compilation of all outstanding cccmitments relating to Oconee Nuclear Station. In this manner, it can be assured that proper and timely actions are taken with regard to items identified.

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Mr. Wor ~an C. Moseley Page 2 December 19, 1974 It is felt that actions taken to date, and which are continuing, have served to significantly improve the effectiveness of the management control system with regard to the operation of Oconee Nuclear Station.

Very truly yours,

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[ '. b $ec x A. C. Thies ACT:vr l

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RESPO:'SES TO R0 INSPECTION REPORT 50-269/74-10, 50-270/74-8, 50-287/74-11 December 19, 1974 i

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ITEM I.A.l.b: .

i Technical Specification 6.4.1 requires that procedures be developed and adhered to for activities affecting quality. Section 3.2.2.5 of the DPC Steam Pro-duction Department (SPD) Administrative Policy Manual (APM) for Nuclear Stations requires each station to establish a periodic testing schedule to assure that all safety-related testing is performed and properly evaluated

in a timely manner.

Contrary to the above, a periodic testing schedule has not been developed and (Details II, implemented as specified by paragraph 3.2.2.5 of the APM.

paragraph 4.a) ,

RESPONSE

A computer program has been pr(pared for the purpose of scheduling periodic tests. This program is presently available for statien use and the information for a number of periodic tests has been input to the program data base. Those tests are currently being scheduled thereby. Information for other periodic tests with a frequency of greater than weekly is currently being input to the program data base. This task should be completed by January 15, 1975, and, subsequent to that date, the program will be used for scheduling such periodic tests.

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ITEM 1.A.l.a: -

Technical Specification 6.1.?.l.d.5 requires the Station Review Committee (SRC) to review proposcd safety-related changes or modifications to the station design.

Contrary to the above, the SRC did not review station modification re, quest 0-300-S, which changed the steam generator water level control from 95%

to 50% for natural circulation cooling. (Details I, paragraph 3.a)

RESPCNSE:

As noted in the inspection report, DetaiIs I, paragraph 3.a. the modification to change the steam generator level control setpoint for natural circulation cooling frca 95% to 50% was recommended by the Babcock and Wilcox Ccapany (B&W) in a letter dated July 24, 1974. The Station Review Committee31, (SRC) 1974.

reviewed the safety implications of the recommended change on July It is considered that this review of the safety i=plications of, and concurrence with, the proposed modification was adequate.

With regard to'SRC review of future station modifications, new policies for the control of modifications are to be incorporated into the Steam Production Department's " Administrative Policy Manual for Nuclear TheseStations" policiesonrequire December 20, 1974, for implementation on January 1, 1975.

that the SRC review each proposed modification to safety-related structures, systems and components subsequent to design of the modification and prior to implementation of the modification. These policies also require that the fact that such a review has been performed be verified prior to implementation of the subject ecdification.

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Technical Specification 6.4.1 requires that the station be operated and main-

! tained in accordance with approved procedures, and Technical Specification 6.1.2.1.d requires the SRC to review safety considerations, unusual events, violations of Technical Specifications and new procedures that affect nuclear safety. .

Contrary to the above:

(1) No documentary evidence could be located to verify that the following

-procedures had been reviewed by the.SRC. .

(a) PT/1/A/201/3, Core Flood System.

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(b) PT/0/A/204/9, Reactor Building Spray System Engineered Safeguards Tests (c) PT/0/A/202/ll, High Pre? ure Injection System Performance Test (Details II, paragraph 2.d(2))

(2) An i= proper valve lineup resulting in an unplanned drop in the level of the Borated Water Storage Tank for Unit 1, on August 26, 1974, was not reviewed for safety considerations by the SRC. (Details III, paragraph 2.e)

RESPONSE

(1) Subsequent to the exit interview of November 13, 1974, a review of those procedures noted as not having been reviewed by the Station Review Co=mittee (SRC) was conducted. This review determined that documentary evidence is available with regard to SRC review of two of the noted procedures. PT/1/A/0201/03, Core Flood System, was reviewed by the SRC on October 17, 1972, as indicated by a copy of the procedure in the I

Master File. PT/0/A/0202/ll, High Pressure Injection System Perfor=ance Test, was reviewed by the SRC on November 18, 1972, as shown by SRC minutes.

No written evidence can be found showing that PT/0/A/0204/09, Reactor Building Spray System Engineered Safeguards Test, was reviewed prior to its approval on March 10, 1973, as required by Technical Specification 6.1.2.1.d. however, a complete revisio, to this procedure was reviewed by the SRC on July 25, 1974, prior to the initial utilization of this procedure. It is felt that since the date of this incident, i.e., March,

1973, that'the control of the preparation, review and approval of pro-1 cedures has continually improved. This is evidenced by the fact that, I although PT/0/A/0204/09 was not originally reviewed by the SRC, the July, l 1974 revision to the procedure did receive SRC review.

(2) The incident cited occurred on August 26,'1974. O'n August 27, 1974,'an investigation was conducted to determine if Technical Specifications had been violated and it was concluded that a Technical Specifications violation had not occurred. Based on this conclusion, this incident was l

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not classified as an Abnormal Occurrence or an Unusual Event and, therefore, was not reviewed by the SRC. Since the date of ehis incident, however, management has placed increased emphasis on the importance of reviewing incidents promptly for their safety significance and reportability to the AEC as an Abnormal Occurrence or Unusual Event - see response to Violation I.A.l.d. Incidents similar to the one noted are currently being re-viewed by the SRC as required. It is believed that, as a result of these corrective actions, present methods are adequate to assure future com-pliance with the Technical Specifications.

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, ' ); ITEM I'.A.1.d:

Technical Specification 6.1.2.1.d.3 requires the SRC to review all unusual events. Technical Specification 6.6.2.1.b requires that unusual events be reported to the Directorate of Regulatory Operations within 30 working days.

Contrary to the above: ,

i (1) The SRC did not review a condition that permitted both doors of the Unit 2 reactor building personnel hatch to be opened at the same time, which (Details III,

! could have resulted in a loss of containment integrity.

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l (?) A report of the unusual event was not submitted to the Directorate of j Regulatory Operations. (Details III, paragraph 1.a) -

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RESPONSE

i The deficiency noted in Details III, paragraph 1, of the inspection report resulted from the failure to note the interlock failure in the shif t j supervisor's log. The incident was noted in the Unit 2 reactor operations f

log, but no entry was made in the shift supervisor's log due to the fact i that (1) existing unit conditions (cold shutdown) did not require containment l integrity, (2) timely maintenance action, and (3) the administrative controls i imposed (a man was stationed inside the hatch to control traffic and prevent i both doors from being opened simultaneously) during the time the interlock was inoperable. If the incident had been noted in the shif t supervisor's log, it would have been brought to the attention of the Technical Servicas l

Engineer, who is more knowledgeable of the Oconee FSAR, and a better determi-i nation of the reportability of the incident would have been made.

As noted in Details III, paragraphs 1 and 2, the Technical Services Engineer reviews the shif t supervisor's log to identify any incidents or conditions

, which warrant further investigation. The results of this investigation, including recommended corrective action, are summarized in an Incident Investi;,ation Report. These reports are reviewed by the Station Review

]) Co=nittee (SRC), station management, and the Licensing Unit in the General 4

Office. If it is determined that the incident is reportable to the AEC i under the definitions of Abnormal Occurrence or Unusual Event centained in L the Technical Specifications, the Incident Investigation Report, with SRC

! and station Manager comments, is forwarded to the Licensing Unit for i preparation of a report'to the AEC.

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. ITEM 1.A.1.c: .

Technical Specification 6.4.l requires that operation of the station be conducted in accordance with procedures appropriate to the circumstances.

Contrary to the above:

of a (1) The emergency procedure stating action to be taken in the event loss of coolant flow was not changed, following a change of the steam generator level setpoints. (Details 1, paragraph 3.a)

(2) The ccatrolling procedure for unit startup, OP/2/A/1102/1, was not revised to reflect Change No. 6 (issued May 29, 1974) to the technical specifications. (Details III, paragraph 2.a)

(3) Procedure PT/0/B/200/5, Running Reactor Coolant Pump Motors, was in-adequate, in that the procedure permitted irstallation of jumpers on safety-related equipment and did not specify removal of the jumpars following completion of testing. (Details III, paragraph 2.c)

RESPONSE

With regard to the three items listed, the following corrective action has been taken:

1974 to change the (1) Change 1 to EP/0/A/1800/06 was made on December 4, OTSG level setpoint from 95% to 50%.

(2) Change No. 20 to OP/2/A/1102/1 revised OP/2/A/1102/01, the controlling procedure for unit startup, to reflect Change No. 6 to the Technical Specifications. Change No. 20 was approved on October 18, 1974.

(3) Change No. 2 to PT/0/B/0200/05, dated October 18, 1974, corrects the deficiency noted in this procedure.

To prevent recurrence of incidents similar to those noted above, a more complete review of station modifications and Technical Specificatica changes will be performed, and procedure changes will be made in a timely manner. Specifically with regard to station modifications, new policies for the control of modifications are to be incorporated into the Steam Pro-duction Department's " Administrative Policy Manual for Nuclear Stations" on These policies December 20, 1974, for implementation on January 1,1975.

will require that verification of the completion of a modification include verification that any required procedure changes have been made.

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y ITEM 1.A.l.f: .

Technical Specification 6.1.1.5 requires that a training program be established the provision of for all personnel, including security procedures, which meet ANSI M18.1.

Contrary to the above, training and retraining of personnel(Details in secur,ity I, pro-cedures has not been effected for all station employees.

paragraph 4.d)

RESPONSE

Employees have previously received train'ing in station In ordersecurity althbugh a to improve formal training program had not been established.

employee training in station security requirements, a formal training program has been developed, and will be presented to all station during January, 1975. of the orientation training in the area of security procedures as partRetraining of all Oconee employee program for new employees.

procedures will be conducted annually.

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ITEM X.A.l.g:

Technical Specification 6.1.2.2.b states that the activities of the Nuclear Safety Review Committee (NSRC) shall be guided by a written charter, and lists the activities that must be contained within the charter.

Contrary to the above, the following activities, required to be contained in the SSRC charter, are not discussed in the by-laws which serve as a charter.

(1) Subjects w.i. thin the purview of the committee.

(2) Identification of managecent position to which the group reports,.

(3) Provisions for assuring that the committee is kept inforced of matters within its purview.

RESPONSE

The By-Laws (Charter) of the Nuclear Safety Review Committee are presently being revised to fully reflect the requirements of the current Technical Specifications'. The By-Laws will be revised within ene month following each future revision of the Technical Specifications af fecting the Nuclear Safety Review Committee. It is expected that the current revision of the By-Laws will be completed by February 1, 1975.

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li ' ITEM I. A.1.h: ,

Technical Specification 6.1.2.2.1 requires the NSRC to review abnormal occurrences and unusual events.

Contrary to the above, the NSRC did not review the abnormal occurrence (incorrectly reported as an unusual event), relating to the failure of,the Unit 2 Low Pressure Injection Valve. (Details II, paragrapn 5.g(1))

RESPONSE

The Nuclear Safety Review Committee (NSRC) reviewed the unusual event relating to the failure of a Unit 2 low pressure injection valve as Oconee In'cident Report B-174 during their review of the July 15, 1974 minutes of the Station Review Committee (SRC). This review is documented as Item 7 of the September 27, 1974 Minutes of the NSRC. Prior to the September 27, 1974 meeting of the SSRC, the Chairman distributed Unusual Event Report No. UE-27 0/74-3, which describes this valve failure to all members for review. Members then had the opportunity to ask questicas or make comments, as appropriate, during the September 27, 1974 meeting.

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ITEM 1.A.l.i: , .

! Criterion XVI of Appendix B to 10 CFR 50 requires that prompt corrective action to preclude recurrence of nonconforming items be taken.

Contrary to the above, prompt corrective action was not taken of deficiencies identified in an internal QA audit performed on June 10, and in a reau,dit of August 16, 1974, concerning document control and tagging of equipment. The QA records do not reflect that corrective action to prevent recurrence had been taken as of October 23, 1974. (Details I, paragraph 6.a)

RESPONSE: ,

Quality Assurance Department personnel conducted Level II audit 0-74-1 during the week of June 10, 1974, and issued a report thereof on June 21, 1974. On July 26, 1974, Mr. J. E. Smith, bbnager, Oconee Nuclear Station, responded to the concerns noted in the audit report. Quality Assurance Department personnel conducted a reaudit on August 16, 1974, the report of which was issued on August 20, 1974. The report of the reaudit did not specifically request a response and, therefote, none was prepared at that time. A response to the reaudit has since been transmitted by Mr. Smith to the Steam Production Depart-ment General Office. This response is currently being processed and will be forwarded to the Quality Assurance Department by January 1, 1975.

On November 5,1974, Mr. William O. Parker, Jr. , Vice President, Steam Production, established a policy for future handling of Level II audit reports. Also, on December 20, 1974, a revision to the Steam Production Departnent's " Administrative Policy Manual for Nuclear Statiens" is to be issued which will include requirements for the proper and timely correction of identified deficiencies. As a result of these actions, incidents of the type noted should not recur.

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1TCt I.A.l.j:

Criterion lG'III of Appendix g to 1C CT: 50 requires that audits be perfor=ed by appropriately trained personnel in the areas being audited.

Contrary to the above, none of the Level I QA auditors performing audits of the operating facilities have received appropriate training or are experienced in reactor opeJations. (Details I, paragraph 6.c) -

RESPO:;SE:

During 1975, selected Quality Assurance Department personnel involved in performing Level I audits will receive formal training in reactor op'brations.

This training will consist of classroom instruction and discussion, supplemented with appropriate video tapes, on nuclear station systems and procedures.

It is anticipated that each participant in the training will receive approxi-mately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of training.

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3 ITEM 1.A.l.k:

l r Technical Specification 6.1.2.1.a requires the superintendent to appoint an on-site review committee (SRC) consisting of at least five members of the station supervisory staf f. Technical Specification 6.1.2.1.c specifies that a quorum shall consist of the chairman plus two = cabers.

Contrary to the above, SRC meetings were conducted without the required quorum of supervisory members present. (Details II, paragraph 2.a)

RESPCNSE:

The Tcchniccl Specifications 6.1.2.la requires that the Manager appo' int a Statior. Review Committee of at least five members of the Station Supervisory Staff, it requires representation from Operations and Technical Services and that personnel with expertise appropriate to items being considered participate on the Committee.

The initial comnittee was made up of the Station Assistant Superintendent as Chairman, the Operating Engineer, the Technical Support Engineer, the Main-tenance Supervisor, and the Health Physics Supervisor. With the initiation of station operation and development of the expertise of other station personnel, the number of individuals in the station supervisory organization qualified to serve on this committee has increased. The Manager has performed a continuing review of personnel in the station supervisory organization as regards their qualifications and listed those who are qualified to serve on a basic five man committee. The Intrastation I<*.ter is a list of supervisory personnel qualified to participate on this cons;; tee and is not intended to infer that this is a thirty-three man committee.

Normally, meetings of this committee are scheduled with five members present with representation from the Operacions and Technical Services Groups participating, Where items of a particular discipline are being considered, a member of the supervisory organization in the area being considered is included in the committee meeting. Special called meetings require at least a quorum present.with participation of a member of the supervisory organi-zation who has expertise in the area being considered.

As regards Section 12A.5 of the FSAR, this is only a partial listir.g of the station supervisory organization, ar.d it is not required or intended that all station supervisory personnel be identified. Sectica 12A.5 is intended to establish that there are in the station org--1:ation adequate supervisory personnel with technical capabilities to s . _ly operate and maintain the station in keeping with the safety review atd in keeping with ANSI 18.1.

The Intrastation Letter is being revised to clarify any misunderstanding that any have resulted.

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/ XTEM I.A.2.a:

• Technical Specifications 6.5.2.d and 6.5.2.h require station maintenance histories for safety related structures, systems and components, including periodic testing records, be prepared and maintained thefor a minimum station of six shall be years. Technical Specification 6.4.1 states that operated in accordance with approved procedures.

Contrary to the above:

(1) No documentation could be provided to show that the replacement of pressurized safety valves was done in accordance with an approved records'of the procedure and the maintenance history and periodic test II, paragraph (Details installed safety valves could not be located.

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be (2) Records of the periodic tests of the Core Flood System could not located. (Details II, paragraph 4.b(2))

RESPONSE

Details II, paragraph 4.b(1),

(1) As indicated in the inspection report, documentation is availabic which verifies that the Oconee 1 pressurizer safety valves were properly adjusted by Dresser Industries, the valve manufacturer. Discussion with the supervisor involved in the replacement of the valves determined that a copy of PT/0/A/0200/29 was used and completed at that time. During the subsequent review and audit process, however, the completed procedure was misplaced. Consequently, the periodic test records and maintenance histories were not updated.

Reorganization of the station Maintenance Group in July of this year introduced a Planning Section, which has the responsibility for maintaining maintenance histories. Document transmittal controls are now in effect which require a document receipt signature when documents are received for permanent storage.

This method of handling should preclude similar occurrences in the future.

(2) OP/ /A/1102/01, Controlling Procodure for Unit Startup, has been revised to require that PT/ /A/0201/03, Core Flood System, be completed during each unit startup. This change will assure that the necessary testing is adequately documented.

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Ltr to Duke Pcwer Ccepany from !i. C. Moseley dated ggy g 7 jg74 RO Inspection Report ::cs. 50-269/74-10, 50-270/74-8 and 50-287/74-11 DISTRIBUTIC3:

H. D. Thornburg, RC RO:HQ (5)

Directorate of Licensing (13)

E C .% DR Central Files Regulatory Standards

• PCR

• Local PCR

• NSIC

• TIC

• State

• To be dispatched at a later date I

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