ML19332A127
| ML19332A127 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/23/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19332A126 | List: |
| References | |
| NUDOCS 8009100807 | |
| Download: ML19332A127 (3) | |
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Tett>=ont:Anta704 S tano Paoouction 373 4053 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:FJ 50-269/80-17 50-270/80-12 50-287/80-11
Dear Sir:
With regard to Mr. R. C. Lewis's letter of May 23, 1980 which transmitted the subject inspection report, Duke Power Company does not consider the informa-tion contained therein to be proprietary.
Please find attached responses to the cited items of noncompliance.
Ver truly yours, f
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o illiam O. Parker, Jr.
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DOKE POWER COMPANY OCONEE NUCLEAR STATION Response to Inspection Report 50-269/80-17, -270/80-12, -287/80-11 As required by Technical Specification 6.6.2.l.b(3), a written report is requir-ed to be submitted within 30 days of discovery of an inadequacy in the implemen-tation of procedural controls which are intended to ensure surveillance activi-ties are performed within specified time intervals to meet operability require-ments of Ilmiting conditions for operations.
Contrary to the above, on February 1, 1979 and on February 28, 1979, the IIcen-see discovered that surveillance testing on safety-related batteries and reactor building pressure analog channels had not been performed within the time inter-val specified by Technical Specifications 4.6 and 4.1, respectively.
Both events were investigated by the licensee, but were not reported to the NRC.
This is a deficiency.
RESPONSE
These items, as well as similar items not cited, were investigated by the sta-tion pursuant to Technical Specification 6.1.2.1.f.
As noted, these items were not reported to the NRC pursuant to Technical Specification 6.6.2.1.
This deficiency occurred as the result of the station's interpretation of the reporting requirements.
In the two cases cited, it was discovered that sur-veillance was not performed at a time prior to current tests which had confirm-ed operability. Therefore, at the time of discovery, no reduction of the de-gree of redundancy provided by the Reactor Protective System or Engineered Safety Feature Systems occurred. Also, no degraded modes or violation of limiting conditions for operation occurred.
It was the station's interpreta-tion that failure to perform surveillance was only reportable if it required a component or system to be declared inoperable and that inoperability result-ed in:
1.
Operation in a degraded mode permitted by a limiting condition for operation or shutdown required by a limiting condition for operation.
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2.
Violations of limiting conditions for operation estab-lished in the Technical Specifications.
3 Reductions of the degree of redundancy provided in the Reactor Protective System or Engineered Safety Feature Systems.
In. order to comply with the requirements as interpreted in the Notice of Vio-lation, the following action has been taken.
Incidents involving failure to perform surveillance are being reviewed for reportability pursuant to items I, 2, and 3 During this review, it is being assumed that the component or system is inoperable from the date the Interval expires until the surveillance is performed.
If it is determined that items I, 2, or 3 existed for some period of time, whether or not the inoperability is determined at that time, then the incident will be reported within the specified time from the date of Identification. Also, we will submit reports on the two incidents cited with-in 30. days.
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m, J4 In the past, i t has been the position'of our Resident inspector that failure to perform any type of surveillance requires a thirty-day written report. We
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would like to emphasize that it continues to be ou, position that failure to perform surveillance is not reportable, per se.
Any failure to perform sur-veillance must be investigated pursuant to Technical Specification 6.1.2.1.f.
However, this problem would only be reportable if the inoperability of the component or system in question results or resulted (either now or in'the past) in items reportable pursuant to items I, 2, ar.d 3 as above noted.
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