ML19337A883
| ML19337A883 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/25/1980 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19337A880 | List: |
| References | |
| NUDOCS 8009300626 | |
| Download: ML19337A883 (3) | |
Text
t, DUKE Powgp)q' m n"GohPANY' '
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Powra Du Lomo 422 Socin Cnuncu Srazzr, Cuantorre, N. C. 2s242
August 25, 1980 Vice Passiogn, Tt 6 t e-ow c:Anta704 Sitase Paoovction 373 4383 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, Suite 3100 i
Atlanta, Georgia 30303 Re: RII:FJ 50-269/80-23 50-270/80-20 00-287/80-17
Dear Sir:
With regard to R. C. Lewis' letter of July 30, 1980 which transmitted the subject inspection report, Duke Power Company does not consider the infor-mation contair'2 therein to be proprietary.
Please find attached a response to the cited item of noncompliance.
Ve truly yours,
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1111am O. Parker, Jr.
FTP:scs Attachment
DUKE POWER COMPANY OCONEE NUCLEAR STATION 4
Response to IE Inspection Report 50-269/8-23, -270/80-20, -287/80-17 Item l
Technical Specification 6.4.1.J requires that safety-related periodic tests be performed in accordance with current, written approved procedures.
Contrary to the above, on June 11, 1980, the Oconee Unit 2 Turbine Driven Emergency Feedwater Pump and associated equipment was test operated using an Oconee Unit 1 operating procedure, and, on' June 12, 1980, the same feedvater pump, and associated equipment, was test operated employing a valve line-up configuration which was contrary to the requirements of the appropriate procedure.
Response
The above citation, as stated, is incorrect.
On June 11, 1980, the Oconee Unit 2 Turbine Driven Emergency Feedwater Pump (TDEFWP) and associated equipment was operated in accordance with Unit 2 Operating Procedure OP/2/A/1106/06 (Emergency Feedwater System) in preparat.on to run the Overspeed Trip Test Portion (section 4.0).
The working copy of the procedure was verified against the control copy, signed and dated before any testing was started. This copy Lr the procedure was located in the Unit 1 and 2 control room. Telephone commusications were established between the TDEFWP and the control room. This phono is not located at the pump and requires a short walk fro? the pump to the phone.
An Assistant Engineer, Operations (( EO) was assigned by his supervirar to provide assistance to the Nuclear Equipment Operator (NEO) who was responsible for the actions necessary to be performed locally at the pump.
It should be noted that the NEO was performing his actions under the cognizance and direction of the operator in the control room, who had the " official" Unit 2 procedure.
The AE0 was there primarily for the learning experience and to provide assistance as required. The NEO does not work for or report to the AEO. The AEO, prior to proceeding to the pump location, obtained a procedure for his use in following the test. After arriving at the pump location, the AE0 realized he had a Unit 1 pro-cedure. However, since he was not actually performing the procedure and since he realized that the Unit 1 and Unit 2 procedures were identica7 1.xcept for unit designations, he did not conside* it necessary to obtain the r.orrect procedure.
No equipment manipulations were made using this procedure. Tae use of this pro-cedure was limited to verifying local indications and following the program of the procedure. Steps 4.2.1 thru 4.2.11 were successfully completed on June 11, 1980.
However, due to a problem with a statalarm, the test was halted and scheduled for completion on the following day.
Step 4.2.2 of OP/2/A/1106/06 (Emergency Feedwater System) requires isolating and red-tagging the EFWPT for the actual uncoupling of the turbine from the pump by closing 2AS-38'(EFWPT Auxiliary Steam Supply) and 2MS-90 (MS to EFWPT Auxiliary Supply). However, since the pump had been uncoupled earlier in the outage, this step was determined to be no longer applicable.- Since the unit was at cold shut-down, main steam was not a factor.
i e
Oconee Station Directive 4.2.3 allows for such a deviation from written pro-cedures provided the step is documented on the procedure by the supervisor holding an SRO license. Verbal permission was received from the Shift Super-visor on June 11, 1980 prior to marking Step 4.2.2 not applicable. Documen-tation of the approval was made on June 13, 1980. The OIE Resident Inspector observed the step having been marked "Not Applicable" prior to this documentation being completed.
The actual overspeed test was completed as outlined in the Unit 2 operating procedure OP/2/A/1106/06, on June 12, 1980.
Although the citation,as stated, is incorrect, it is felt that the inspector has identified two (2) areas of concern which the licensee shares. They are:
1.
The AE0 should have had in his possession either a Unit 2 procedure which had been verified against the control copy or an information copy which was plainly marked "For Information Only." This item has been discussed with the AE0 involved as to the poor judgment displayed by his utilization of this procedure.
In addition, this citation and its response will be reviewed by operations personnel to insure that only correct and verified procedures are used. Any procedure use "for information" should be plainly marked for information only.
2.
The documentation of the SRO granting verbal permission to mark step 4.2.2 "not applicable" was inadequate. Administrative procedures will be revised to clarify this requirement.
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