ML19322A930

Responds to NRC 750226 Ltr Re Violation Noted in IE Insp Repts 50-269/75-01,50-270/75-01 & 50-287/75-01.Corrective Actions:Leak Test to Follow Administrative Controls,Maint Activities Defined & Procedure Revised for Trip Setting

ML19322A930
Person / Time
Site:	Oconee
Issue date:	03/26/1975
From:	Thies A DUKE POWER CO.
To:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19322A925	List: ML19322A924 ML19322A926 ML19322A928 ML19322A929 ML19322A930
References
NUDOCS 7911270816
Download: ML19322A930 (7)

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Duxn Powsn COMPANY Powrn Bu Lonco 4aa Sourn Gnunen Stazzr, CHAmmTTE,N.C. azaot

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i March 26, 1975 1

Mr. Norman C. Moseley, Director i U. S. Nuclear Regulatory Commission

, Suite 818 j 230 Peachtree Street, Northwest

! Atlanta, Georgia 30303 y

j Re: IE:II:TNE 50-269/75-1

50-270/75-1

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50-287/75-1 l

Dear Mr. Moseley:

In reference to your letter which transmitted IE Inspection Report I

l l- 50-269, -270 and -287/75-1, Duke Power Company does not consider infor=ation contained in this report to be proprietary.

Please find attached our responses to Items I.A.1, I.A.2, I.A.3, I.B.1,.and I.B.3. ,

j With regard to Section IV, Status of Previously Reported Unresolved

< items, the following is an updated status of selected items:

S Oconee 2 74-7/4, "LPI Valve Failure"

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Details I, paragraph 10 states that an interim ceasure is planned to remove the valve guide pins within one month. Due to extensive man-i power requirements during recent outages, this schedule will not be met. Removal of the guide pins is currently scheduled to be completed by >by 1, 1975.

Oconee 3 74-5/16, " Quality Assurance Records" h Due to delay in material delivery, the estimated cecpletion date of

[i April 1,~1975 should be changed to April 15, 1975.

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1 Mr. Norman C. Moseley fixf }" Page 2

.; March 26, 1975 a

Oconce 1, 2, 3 4 74-10, 08, 11/9, "Unreviewed Safetv Question" With regard to responsibility for determining whether or not an item involves an unreviewed safety question, it is felt that the following 4

is sufficient to resolve this item:

, (1) The Administrative Policy Manual for Nuclear Stations was revised on February 17, 1975 to specify the requirements for determining ,

I whether or not new procedures (which would include tests and experiments) involve an unreviewed safety question - see Sections 4.1.4.4(e), 4.2.4.4(f) and 4. 3.4.4(f) .

(2) Item (8) of Figures 4.1-6, 4.2-13 and 4.3-12 of the APM specifies the requirement for determining whether or not a procedure revision involves an unreviewed safety question.

(3) Sections 4.4.4.4.2 and 4.4.4.4.3, incorporated into the APM on ,

J December 20, 1974, specify the requirements for determining whether or not a modification involves an unreviewed safety question, j Section V of the inspection report states the licensee failed to meet j

written commitment dates for corrective action required to resolve problems with various effluent radiation monitors. The dates referred

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2 i to were target dates provided in my letter dated September 9,1974, 3

for resolution of these problems. Additional information was provided d concerning these monitors in my letter dated February 14, 1975. The current status of actions taken to resolve the problems is detailed below:

(a) Liquid Waste. Process Monitors RIA-33 and -34 The liquid waste process monitors RIA-33 and -34 have been moved to the turbine floor to a high point in the. discharge line. Dual chambers have been installed so that 'one can be decontaminated while the .other is in use. However, problems virh contamination of these monitors persists and additional investigation is required.

(b) Waste Gas process Monitors RIA-37 and -38 My letter of September 9,1974 stated that a collimator would be

installed in the waste gas process monitors RIA-37 and -38 and the I target da~te for completion was._Sovember 15, 1974. It was reported in my letter. dated February 14, 1975 that stainless steel'collimators 4

'had been installed and tested prior to November 15, 1974. However, i .

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A Mr. Norman C. Moseley Page 3 March 26, 1975 testresultsshowedthatth$collinatordidnotsolvetheproblem.

At present, we are investigating the possible effects of using longer holdup times for gaseous wastes.

(c) Iodine Monitors RIA-44 and -48 My 1ctter of September 9, 1974 stated that the prefilters for iodine monitors RIA-44 and -48 would be relocated upstream from the detector to reduce background rad iation. As stated in my letter of February 14, 1975, it is anticipat.... that the prefilters will be relocated prior to April 1, 1975.

(d) Particulate Monitors RIA-43 and ~47 The Unit 1 particulate conitors RIA-43 and -47 have been codified to provide better correlation between the monitors and grab samples.

Data concerning the ef f ectiveness of the modification are presently being collected and evaluated. It is anticipated that data collection will be completed by April 1,1975, and the evaluation of the effectiveness of this modification will be completed by mid-April.

Resolution of the problems associated with these radiation monitors continues to receive high-level canagement attention. We have formed a working group of radiation monitoring and engineering specialists from Oconce, the Steam Production Department and the Design Engineering Department to actively pursue resolution of these problems. Significant progress has been made in identifying the causes, and work will continue to expeditiously resolve the engineering problems associated with the monitors. In the ceanwhile, appropriate monitoring will continue to assure effluent releases are maintained within station limits and guidelines . We will advise you of our progress by providing you another status report by May 1, 1975.

Very truly yours,

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A. C. Thies ACT:vr Attachnent i

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DUKE P O '[ E R C0MP ANY OCONEE NUCLEAR STATION RESPONSES TO ITEMS I.A.1, I.A.2, I.A.3, I.B.1, I.B.3 0F INSPECTION REPORT 50-269/75-1, 50-270/75-1, 50-287/75-1 s

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i March 26, 1975 l

I I.A.1 Contrary to Technical Specification 6.4.1.e, repair and testing was performed on Type A electrical containment penetration in Unit 3 on December 30, 1974, without an approved procedure.

RESPONSE

The concainment penetration was determined to be leaking during performance of a local leak detection test. It was the understanding of the performance engineer that the SF6 gas in the penetration cannister was only for the purpose of acting as a quenching agent for spark suppression. Therefore, no requirecents for periodic surveillance or minimum pressure were specified, other than the manufacturer's reco=nendations. For this reason, the impli-cations of this leak and the scope of maintenance activity required to repair the leak were not realized. It was not considered as an iten which could affect nuclear safety or radiation exposure to personnel; hence, the appropriate administrative controls were not utilized.

In order to prevent recurrence of this type of infraction, all performance group personnel have reviewed ;his incident and are faniliar with the necessity for following appropriate procedures and instructions. In addition, the Administrative Policy }bnual for Nuclear Stations and Station Administrative Procedures have been reviewed to ensure understanding.

A periodic test is being prepared to address survey of the SF6 Pressure in all electrical penetrations. The electrical penetration has been repaired and is currently holding SF6 pressure; thus, containment integrity is being main tain ed. A spare Type A electrical penetration has been repaired and tested and will be installed at the first available outage, which is estimated to be the end of April, 1975.

I.A.2 Contrary to Criterien V of 10 CFR 50 Appendix B, a number of deficiencies were obs arved in i=plementation of the controlling precedures contained in Duke Power Company, Stean Production Department Administrative Policy Manual for Nuclear Plants (APM), Quality Assurance Department, Quality Assurance Manual (QAM), and Oconee Nuclear Station Administrative Procedure No. 9, Equipment Renoval and Restoration.

RESPONSE

The existing controls of maintenance activities have been examined and have been determined to be adequate; however, since they involve interface between the Operations and Maintenance Groups, some degree of coordination was. required to assure proper implementation. In order to provide better i

r t controls over these activities, several definitive steps have been taken to more cicarly specify the group responsibilities associated with the various aspects of a maintenance function. These steps are described below:

(a) Administrative Procedure 9 was revised on February 15, 1975. This clearly specifice that the removal and restoration of equipment is to be an Operations Group resptasibility. This will facilitate the necessary awareness of station conditions by the Operations Group threugh the use of an out-of-normai log.

(b) To assure that Work Requests are properly handled, Maintenance Directive 8 was issued on February 25, 1975. This directive specifies use of a revised work request form which deals only with =aintenance activities. The Planning Engineer has conducted training sessions with all station groups stressing the proper utilization of the form and the new program. The Planning Section is also performing an audit on cocpleted work requests to assure complete sign off before they are filed.

(c) All maintenance and instrument procedures are being reviewed and up-dated to include provisions for documenting that the station unit status is as required to perform the specified maintenance. This will be completed by June 1, 1975.

I.A.3 Contrary to Technical Specification 4.0.2, several Oconee 3 annual sur-veillance items have exceeded the 18 month limit.

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RESPONSE

With regard to the initial performance of surveillance items for which a frequency is given in the Technical Specifications, it was Duke Power Company's previous understanding from the Nuclear Regulatory Co= mission that the beginning date for the interval specified is the date of issuance of the Facility Operating License for a unit. Therefore, a surveillance specified to be parformed annually for a particular unit could be perforced in accordance with the Technical Specifications, up to 18 months following issuance of the Facility Operating License for that unit. In the case of Oconee 2, all required surveillance has been performed within 18 conths of the issuance of the license for the unit.

The above described position has been communicated to the Division of Reactor Licensing of the Nuclear Regulatory Cocmission, and a response requested if this application of the Oconee Technical Specifications is not Correct.

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/T I.B.1 Contrary to Technical Specification 6.5.2.h, records of recalibration of the flux / flow / imbalance trip setpoints could not be produced by the licensee.

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RESPONSE

The instrument procedure for flux / flow / imbalance trip setting had been performed and the data recorded. Subsequently, the data sheet was misplaced and could not be produced for the inspector. To prevent future incidents, the procedure has been revised to include the data sheet as an integral part of the procedure. These data sheets will be retained as required by Technical Specification 6.5.2.h. Also, the flux / flow /

imbalance test has been perfo.aed since the deficiency was identified and the settings were recorded on the data sheet and filed with the procedure.

I.B.3 Contrary to 10 CFR 20.401, the licensce's fourth quarter, 1974, personnel exposure records were not accurate, in that a decernined correction factor was not uniformly applied.

RESP 0"SE:

The doses to the two individunis of concern were reduced after proof of lower exposure was provided by the TLD contractor. These individuals were the only ones that previously had appeared to have exceeded the 10 CFR 20 quarterly limits. The previously recorded exposure data for other personnel was not similarly lowered as thi; was the mos,t accurate, conservative data available. This practice of correcting the exposure records for two out of a large group of records does not appear to be inconsistent with the requirements of 10 CFR 401.

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Duke Power Company Oconee 1 50-269/75-1 f7 ,

Oconee 2 50-270/75-1 Oconee 3 50-287/75-1 Ltr to Duke Power Company fa N. C. Moseley dtd:

IE Inspection Report Nos. 50-269/75-1, 50-270/75-1 and 50-287/75-1 DISTRIBUTION H. D. Thornburg, IE IE:HQ (5)

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