ML19309F632

Responds to NRC 800206 Ltr Re Violations & Deviations in IE Insp Repts 50-269/79-37,50-270/79-34 & 50-287/79-37. Corrective Actions:Shift Operating Personnel Instructed on Manual Transfer Intercommunication Sys & Alarm Procedures

ML19309F632
Person / Time
Site:	Oconee
Issue date:	03/03/1980
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19309F629	List: ML19309F632
References
NUDOCS 8004300214
Download: ML19309F632 (4)

Text

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DUKE POWER COMPANY 80 04300 2,l 'l  ;

,, Powna Duitnixo 422 Sourn Cnunen STnzzT, CIIARLoTTE, N. C. 2sa42 w n.ua u o. **a n c a. s a. March 3, 1980 WCr Passeormt TELtpaon t:Anta 704 Sycane Paoouction 373-4083 Mr. iames P. O'Reilly, Director y .

U, S. Nuclear Regulatory Commission , 3 C

Region II ,, [j 101 Marietta Street, Suite 3100 "3 . 3i Atlanta, Georgia 30303 m -jO

.d n g ..

Re: RII:DRQ ,

50-269/79-37 2 50-270/79-34 50-287/79-37

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Dear Sir:

With regard to Mr. R. C. Lewis' letter of February 6, 1980 wNich transmitted the subject inspection report, Duke Power Company does not consider the infor-mation contained therein to be proprietary.

Please find attached responses to the cited items of noncompliance.

V ry truly yours,

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William O. Parker, Jr KRW:scs Attachment i

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I Item

.) 1. As required by Technical Specification 6.4.1.c. the station shall be oper-ated and maintained in accordance with approved procedures. Written pro-cedures with appropriate check-off lists and instructions shall be provided for actions taken to correct specific and foreseen potential malfunctions )

of systems or components involving nuclear safety and radiation levels, including responses to alarms, suspected primary system leaks and abnormal reactivity changes.

Contrary to the above, adequate. procedures did not exist to guide the oper-  !

ator properly during the loss of most control board indications, which occurred on November 10, 1979, as a result of loss of the KI inverter power supply for the Integrated Control System and most control board indications.

Procedures were also inadequate to guide the operator during recovery from this event in that maximum allovable Reactor Coolant System cooldown rates l were exceeded. l This is an infraction.

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Response

l Duke Power does not consider thin to be a valid citation. Technical Speci-fication 6.4.1.c states that " written procedures . . . shall be provided for j

. . . actions taken to correct specific and foreseen potential malfunctions  ;

of systems or components involving nuclear safety and radiation levels, inclu-ding responses to alarms, suspected primary system leaks and abnormal react-ivity changes." Within the context of this statement, the " specific and fore-seen potential malfunctions" were analyzed in the FSAR prior to licensing the facility, and procedures were written to cover these particular malfunctions.

It is our interpretation of this specification that procedures are not required, j nor can be written, for unforeseen potential malfunctions such as the event cited. Therefore, we feel that the specification was met.

As a result of the incident, several actions have been or will be taken to l help prevent recurrence of or reduce the effects of a similar incident.

As immediate corrective action, all shift operating personnel were instructed i on manual transfer of ICS power, and they reviewed Alarm Procedures AP/1702/23 (ICS Auto Power Failure) and AP/1702/24 (ICS Manual Power Failure).

Further corrective action included the issuance of a new Emergency Procedure EP/0/A/1800/31 (Loss of KI Bus and Control Room Indication Powered from KI). l This procedure provides guidance for the operators in the event of a loss of  ;

KI bus power, including symptoms of the condition, immediate action to be j taken, and action to be taken when ICS power is restored. The following j Alarm Procedures were revised to reflect the addition of a redundant ICS auto- i matic transfer switch: AP/3/1713/19 (ICS Inverter Output Voltage Low); l AP/3/1702/47 (Emergency Feedwater Power Failure); AP/3/1703/25 (ICS Emergency '

Power Failure); AP/3/1703/23 (ICS Automatic Power Failure); and AP/3/1702/24 (ICS Manual Power Failure). The last two procedures listed were also revised to list equipment failures and failure modes upon loss of ICS power. The same changes will be made to the Unit I and 2 procedures when the redundant ICS automatic transfer switches are installed on these units. Finally, all operators have reviewed the loss of ICS power incident.

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Item

• B. As required by Technical Specification 3.1.2.1, Oconee Unit 3 Reactor Cool-ant System cooldown rates shall be limited in accordance with Figure 3.1.2-2.c. This figure specifies that, the maximum cooldown rate between 5320F l and 432 F will be less than or equal to 100 F per hour. l Contrary to the above, during recovery from the transient event on November 10, 1979, the Unit 3 Reactor Coolant System was cooled down approximately 140 F, within thirty minutes, from an indicated 560 F to an indicated 4200F.

This is an infraction.

Response

Corrective actions taken for this item are the same as for Item A. An over-all evaluation of the excessive cooldown presently indicates that the cool-down was not as severe as the one which occurred at Rancho Seco plant on March 20, 1978. Steam generator tube to shell temperature differences and tube weld stresses during the cooldown are being compared to those that occurred at Rancho Seco. This comparison is expected to show that the structural integrity of the steam generator was not affected.

Deviation Item 6 of IE Bulletin 79-05B, dated April 21, 1979, required that you review your prompt reporting procedures for NRC notification to assure that NRC is notified within one hour of the time the reactor is not in.a controlled or expected condition of operation. Further, at that time an open continuous communication channel shall be established and maintained with NRC.

Your response to IE Bulletin 79-05B indicated that the following actions were taken to assure compliance with the Bulletin requirements:

The Oconee Nuclear Station Emergency Plan (Station Directive 3.8.5) includes prompt reporting procedures for NRC notifica-tion of serious events. The section of the Emergency Plan pertaining to reports and notifications has been revised to include the following statement under those events requiring immediate notification of the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region II:

"Any situation whereby the reactor is not in a con-trolled or expected condition of operation. A situa-tion such as this could be defined as any unscheduled event involving the reactor which cannot be controlled or stabilized by use of normal operating procedures.

NOTE: In a situation whereby the reactor is not in a controlled or expected condition, the NRC shall be notified no later than one (1) hour following de-termination of the uncontrolled or unexpected condi-tion. Upon notification, an open, continuous communica-tions channel shall be established and maintained from the station to the NRC."

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Item B Continuid j

To provide additional assurance that the NRC is promptly noti-fied, Station Directive 3.1.5 (Notification of Station Manage-ment) has been revised to include the following event which will require prompt notification of the Station Manager:

Unscheduled event involving the reactor which cannot be controlled or stabilized by use of normal operating procedures.

Contrary to the above, at 3:15 p.m. on November 10, 1979, Oconee Unit 3 experienced a transient during which the loss of the KI Inverter resulted in the unit being in an unexpectcJ condition of operation, and the NRC was not notified until approxteately 8:30 p.m. on the same date.

This is a Deviation.

Response

The deviation cited is not considered to be valid or justified. The Sta-tion Directives noted in the deviation limit reportability to "any un-scheduled event involving the reactor which cannot be controlled or sta-bilized by use of normal operating procedures." The transient and loss of ICS power were controlled by use of existing operating procedures; therefore, notification of the NRC within one hour was not required.

Several operator actions significantly contributed to the control and safety of the unit. HPI was initiated early, during the ICS power loss, so that reactor coolant system pressure was recovered and maintained. The Power Operated Relief Valve was not opened during the overheating transient.

Although RC system cooldown limits were exceeded, at least 79 F subcooling margin was maintained. No Engineered Safety features actuation setpoints were reached and, except for the ICS inverter failure, there were no component malfunctions. Operator action through existing procedures kept the unit in a controlled condition of operation.

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