ML19318A758
| ML19318A758 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/02/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19318A750 | List: |
| References | |
| NUDOCS 8006240117 | |
| Download: ML19318A758 (2) | |
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t DUKE POWER COMPANY Powra Braunxo 422 SocTa Cnuncu SrazzT, CnARLOTTE, N. C. 28242
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May 2, 1980
%cr Patsroemt Ttttewowc: Anta 704 Strau PnoowcTrom 373-4083 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 10303 Pe: RII:DRQ-50-269/79-37 50-270/79 4 50-287/79-37
Dear Mr. O'Reilly:
B With regard to your letter of April 7, 1980, Duke Power Company has reeval-usted our response in light of your comments. The explanation of Violation A, an infraction, stated that Technical Specification 6.4.1.c required pro-cedures which were in fact not provided. We replied that the specific event sequence was not foreseeable and that adequate procedures for response to the various alarms were properly provided.
Our review of our Technical Specifica-tions, FSAR, ANSI N18.7-1976/ANS 3.2, NUREG-0103 (B&W Standard Technical Speci-fication), Regulatory Guide 1.33, etc. confirms that none could reasonably be interpreted to require the specific Emergency Procedure which we have since provided. We are unable to agree that Duke Power Company was specifically in violation of Technical Specification requirements when neither the industry as a whole (ANSI N18.7-1976/ANS 3.2) nor the NRC Staff (Regulatory Guide 1.33) anticipated this specific event. Fowever, as stated before, EP/0/A/1800/31 (Loss of KI Bus and Control Room Indication powered from KI) has been issued.
The explanation of the Deviation from IEB-79-05C requirements as implemented by Station Directive 3.8.5 indicates that the plant was in an unexpected condition not' controllable by normal operating procedures.
It continues to be Duke's position that this event was controlled by normal procedures augmented by proper operator action which resulted, in part, from his training and plant experience.
i Therefore, since the plant was in a controlled condition (no automatic ESF actua-tion, no PORV opening, etc.) no immediate report was required. With regard to the newly issued 10CFR 50.72 Duke Power has implemented its requirements and appropriate administrative controls will be formalized by June 1, 1980. Separate s00624' N a c1Atcopy
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6 Mr. James P. O'Reilly, Director Nhy-2, 1980 Page Two comments on 10CFR 50.72 have been forwarded to the Commission.
We, in those comments, expressed our strong belief that the requirements are an ill-conceived response to the political hysteria associated with criticism of the Staff's effectiveness. Their result will be, at best, yet another unnecessary adminis-trative burden and, at worse, a diversion of essential manpower from actual transient recovery. The volume of reports which could reasonably be expected to result will not only inundate the Staff involved but will serve to gradually reduce the Staff response to actual problems by obscuring them among hundreds of completely routine events.
Duke Power is not requesting further dialogue on the citations in question but simply wants to make our position clear.
V y trul:' your,
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William O. Parker, Jr.
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