ML19207A774

Responds to NRC 790607 Ltr Re Violations Noted in IE Insp Repts 50-269/79-10,50-270/79-10 & 50-287/79-10.Corrective Actions:Necessary Work to Correct Leakage Into Warehouse Completed

ML19207A774
Person / Time
Site:	Oconee
Issue date:	06/29/1979
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 7908220281
Download: ML19207A774 (8)

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PowEn Brawawo 422 Sorin CHURCH STREET, CluRWTTE' N C 2624 '.

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Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:WDJ 50-269/79-10 50-270/79-10 50-287/79-10

Dear Mr. O'Reilly:

letter of June 7, 1979, which transmitted Duke Power With regard to Mr. R. C. Lewis'50-269/79-10, 50-270/79-10, 50-287/79-10, IE Inspection Report Company does not consider the report to be proprietary.

Please find attached our responses to the cited items of noncompliance.

Very truly yours, M .

William O. Parker , Jr. /pA f./

RLG:aes Attachment I

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DUKE POWER COMPANY OCONEE NUCLEAR STATION Response to IE Inspection Report ,

50-269/79-10, 50-270/79-10, 50-287/79-10 A. As required by 10 CFR 50, Appendix B, Criterion V, " Activities af f ecting

. . accomplished in accordance with instructions, pro-quality shall. .be.".The accepted Quality Assurance Program, Paragraph 17.2.5 cedures . "With regard to specific operational activities .

. . it is "

requires that, required that such activities be accomplished in accordance with procedur

1. The accepted Quality Assurance Program, Section 17.2.16, requires,

" . . taking appropriate corrective action whenever any deficiency in the implementation of the requirements of the program is determined."

Contrary to the above, as of April 6, 1979, corrective action had not been taken to resolve the lack of measures to satisfy QA program requirements for protection of items in storage such as monitoring of inert gas pressure, monitoring of desiccant and shelf-life control. 10, 1975, This item was originally identified by the licensee on July and subsequently in September 1977, in February 1978, and December 1978.

Response

The items listed above were inventoried and evaluated Protectionwith regard towere requirements shelf life, preservation and preventative maintenance.

then determined.

Some items have been placed in plastic bags, and others in pl desiccant and indicator. d tion in those instances where a shelf life could not be determine .

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2. The accepted Quality Assurance Program, Section 17.2.1.1 states in part that, "The policies described in the Corporate Quality Assurance Program Manual are implemented through departmental program manuals and proce-contained in the Corporate Quality Assurance dures." The Policy Statement "All matters concerning quality assurance Program Manual stated in part: h ll which cannot be resolved at the normal inmerfaces among departments s aEn be referred to the Senior Vice President, Additionally, the Accepted Quality Assurance Program, Paragraph 17.2.2 states in part, ". .

. Procedures and work instructions necessary to imple-ment the requiremetns of the operational quality assurance program are developed . . . ."

Contrary to the above, on April 6, 1979, the requirerent inadequate, forimplemented or improperly following up audit responses which are late, was not prescribed by documented instructions or procedures and no be resolved documented method existed for bringing matters which cannot Senior at the normal interfaces among departments to the attention of the Vice President, Engineering and Construction.

Response

Procedure QA-210 is being revised to clarify actions to be The taken whenpro-revised audit responses are late, inadequate, or improperly implemented.

cedure will be issued by July 23, 1979.

A corrective action escalation policy has been approved by the Corporate Quality Assurance Manager and has been incorporated into the Co Assurance Manual as Chapter 16A.

bringing quality assurance matters which cannot be resolved at the normal interfaces among departments to the attention of the Senior Vice President, Engineering and Construction.

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3. QA Procedure No. audit QA-210, Revision 6, edated program October 1978, paragraph 5.5.1.4 that days the effectiveness of that portion of the quality assuranc l d audited and in paragraph 5.5.3 that within thirty (30) ca en arresponsible after receipt of the audit report, Additionally, paragraph shall reply in writing toa the audit report.shall follow-up report be provided by the 5.5.3.2 requires that d the date audited organization stating the corrective action taken an corrective action was completed.

d Contrary to the above, activities were not accomplished with proce ures, h March in that of the audits reviewed for the periods dd March as required. Also, the response by the audited organization excee il 3, edays), for fou the thirty (30) calendar days (overdue f rom 4-19five contain the audit 1979.

Additionally, one of the six audits reviewed did not required evaluation.

Response

19, 1979, by the Corporate Quality A letter has been written, dated June of each interfacing depart-Assurance Manager, to the responsible management in responding to ment addressing their requirements and responsibilities irements.

audit findings and the importance in compliance with these requ 79410f

4. The accepted Quality Assurance Program Table 17.0-1 commits to ANSI Section 6.1.2 of the Standard requires a level B ware-N45.2.2-1972. Additionally, Section 6.2.4 of the Standard house to be weathertight.

prohibits the use or storage of food and drinks in the storage area.

Contrary to the above, rainwater leakage into the level B wareho noted in April 1979.

and lunches was observed in a portion of the warehouse which was not segregated from the level B varehouse.

Response

All Necessary work to correct leakage into the warehouse stored or consumed in the warehouse in the future.

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As required by 10 CFR 50, Appendix B, Criterion XVIII, "A comprehensive B.

system of planned and periodic audits shall be carried out to verify com-pliance with all aspects of the quality assurance program and to determ the effectiveness of the program."the program conforms to ANSI N45.2.12, Draft 3, Table 17.0-1, states that ANSI N45.2.12 Draft 3, Revision 4 dated Revision 4, dated February 1974. " Applicable elements of the February 1974, Paragraph 3.4.2 requires that least annually."

quality assurance program shall be audited at r all aspects of Contrary to the above, a comprehensive system of audits i l Office the QA program was not carried out in that no audit of Generathe Oconee site was activities which affect the QA program at Specifically, during the period from January 1, 1978 through April 5, 1979.

the following activities were not audited:

1. Document control and records (Criteria VI and XVII) 2.

Administrative procedure and staff review activities thereof (Criteria 11 and V) activities (Criteria IV, II and

3. Staff review and inputs to procurement VII)

4. Activities of the calibration lab (Criteria XII, X, XI and SVII)

5. Staff review and input to plant modifications (Criteria III, II and V)

Response

l A Departmental Audit, 0-79-6, ofwith the the Steam Production report being issuedDepartment, June 6, Genera 16, 1979, Office, 1979.

was completed MayThe audit encompassed the Standards and Testing Facili Saf ety Review Board (NSRB); document control; administrative procedures; d procurement of materials, parts, and components; modifications and recor s.

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C.

As required by 10 CFR 50, Apper. dix B,toCriterion III, " Design design control measures Changes, including field changes, shall be subject commensurate with those applied to the original design and be approved by the organization that performed the original designThe unless acceptedthe applicant designates another responsible organization." "The con-the Quality Assurance Program, Paragraph 17.2.3 . . ." atates in part, control measures applied to the modification originally .

Contrary to the above, provisions were not established to require that revisions to saf ety-related Nuclear Station Modifications (NSM) be reviewed by the originatingsubmission designof organization; the design in that the Design Engineering Department without l package back to the originating design group for review prior to approva and implementation of the revised NSM.

Response

4, Provisions for the processing of station modifications are given in Section 4.

" Administrative Instructions for Station Modifications," of the Duke Power Company Steam Production Department " Administrative Policy Manual for These instructions are consistent with Section 17.2.3, "DesignBoth the APM/NS Stations."

Control," of the Duke Quality Assurance Program Topical Report. l for the and QAPTR identify the station Manager as theis, individual pursuantresponsib e to the provisions final approval of each station modification that ) has of Criterion III of Appendix B to 10CFR 50, the applica for the approval of station modifications and revisions thereto.

Individual modifications and revisions thereto may be designed,i evaluated, d on reviewed, etc. by various qualified individuals / organizations Theas determ control ne measures a case by case basis consistent with established policies.

applied to each item are the same however.

Specifically, in the case of NSM-ON-0089, similar design Both the original control measures we applied to the original modification and Revision 6 thereto. Manager. It modification is not and Revision 6 received final approval by the sta P

D. As required by 10 CFR 50, Appendix B, Criterion XIV, which states in part,

" measures shall be established to indicate, by the use of markings such as the status of inspections and tests performed stamps, rags, labels, . . . . . . "The licensee's upon individual items of the nuclear power plant 366-1971. ANSI accepted QA progarm imposes ANSI N45.2.4-1972/IEEE Std.

N45.2.4-1972, Paragraph 2.5.2, " Calibration and Control" states in part,

" Measuring and test equipment used to determine compliance with specifi-cations shall be adjusted and calibrated, . . . Records of the calibra-tions shall be maintained and equipment suitably marked to indicate date of next required calibration . . . ."

Contrary to the above, measures were not established to indicate, by the use of markings, the status of calibrations of installed safety-related None of the instruments not identified in the Technical Specifications.

eleven installed safaty-related instruments reviewed were marked to indicate the status of calibration.

Response

The above item indicates that installed safety-relatedofinstruments Appendix B to are considered 10CFR 50.

to be " test and measuring equipment" in the context with the reviewed and approved Duke Power Company This position is not consistent program for the control of test and measuring equipment as described in the Section 17.2.12 of the QAPTR addresses Quality Assurance Program Topical Report.and it is clearly evident that the con-(offline) test and measuring equipment, trols for test and measuring equipment are not (For applicable example,to installed Items (f)instrumen-and (g) of tation as construed by the inspection report.

Section 17.2.12 address storage and issuance of devices, functions which are only In context, it is also considered that ANSI applicable to offline devices.) differentiates between test and measuring equip-N45.2.4-1972/IEEE Std. 336-1971 ment and installed instrumentation.

Additionally, the distinction between test and measuring equipment and installed instrumentation has been previously addressed and resolved by Duke Power Company (Refer to Item B of Inspection Report and the NRC consistent with the above.and correspondence related thereto datedItJuly 13, Au 50-269, -270, -287/77-9 August 16, August 29, October 21 and December 6, 1977 and January 3, 1978.)

is considered therefore that an item of noncompliance as cited did not occur in this instance.

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