ML19340A254
| ML19340A254 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/11/1974 |
| From: | Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Thornburg H US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML19340A255 | List: |
| References | |
| NUDOCS 8001310573 | |
| Download: ML19340A254 (3) | |
See also: IR 05000269/1974004
Text
{{#Wiki_filter:g -)3 , . C ." . # ',. , ' , ' ) ~ [[,@~.ug u t,r .m n i m a - ' ,g ATGM!r. ENE_RGY COMMIS'M , . . , . . . ,. .. " ,[ ' . . . . , , , .. . . qw ..+ . . July 11, 1974 H. D. Thornburg, Chief, Field Support and Enforcement Branch Directorate of Regulatory Operations, Headquarters DUKE POWER COMPANY (OCONEE - 1), LICENSE NO. DPR-38, DOCKET NO. 50-269 EVALUATION OF LICMSEE'S RESPONSE TO ENFORCEMENT CORRESPOND ECE DATED JUNE 28, 1974 Headquarters evaluation is requested on Duke's response to violation I.A.1.a discussed in RO inspection report 50-269/74-4. The report and their response are enclosed. 10CFR50.59 requires that proposed changes to the facility involving an unreviewed safety question shall not be carried out unless authorized by the Atomic Energy Commission. Contrary to this requirement, during the period fram January 18, 1974, to April 26, 1974, Unit I was operated with as many as six asymmetric rod monitors for individual control rod drives turned off. DPC's response to the above presents an analysis which attempts to show that results are approximately the same with or without control rod action when an asymmetric rod condition exists. Section 14.1.2.7.1 of the Oconee FSAR states that in the presence of a distorted power distribution, the return to full power might lead to localized power densities and heat fluxes in excess of design limitations. Section 14.1.2.7.2 states that protective action taken on one misaligned rod is that all rod-out motion is inhibited and the steam generator load demand is run back to 607. of rated. Technical Specifications 3.4.2.2.e require that reactor power be reduced to less than 607. of rated if an asymmetric rod exists. The asymmetric rod monitoring system also provides a visual and audible alarm in the control room for any asymmetric rod and requires the operator to assure that reactor power is less than 607, as required by the technical specifications. This feature was disabled on those control rods with switches turned off. A relative position system is also available to indicate rod position but only has a small 8001s10 I 7 3 g
- , Duke Power Company -2- yellow light and meter to indicate rod position and does not provide . rod out inhibit or an alarm function. Duke takes the position that the asymmetric rod monitoring system can be disabled without prior Commission approval even though this system is described in the accident analysis (FSAR) as providing the protective functions discussed above. Region II considers a change to involve an unreviewed safety question if it disables one of the systems providing protection as described in the FSAR accident analysis. Region Il recommends that Duke be informed that they fa not have the authority to disable this or any other protective function without prior Commission approval. Region II also recommends that Duke be required to submit the information in their response to Licensing for approval in accordance with 10CFR50.59 , before operating with any asymmetric rod monitoring switch turned off, t DPC also requested that the Category I classification of this violation be changed because they do not concur that the change involved an unreviewed safety question. Please provide us with your evaluation of their response as soon as possible. This office was particularly perturbed by the last paragraph on Page 4 of the licensee's response. We believe that it conveys a distortion of the facts concerning early identification of the matter since our inspector identified this item as being quite significant and stated that in his opinion it was a violation of 10 CFR 50.59 based on the information available during the inspection. This item was brought to the licensee's attention on the day preceeding the exit interview and during the exit interview. Headquarters evaluation is also requested on Duke's response to violation I. A.3.b of the same report. Technical Specification 1.2.B (App. B) requires that all water discharged froa the waste water collection basin shall have a pH between 6.0 and 8.5. Contrary to this requirement, during the period from December 1,1973, to April 12, 1974, there were 44 incidences of pH reading outside the specified range. DPC's response states that a proposed revision to this Technical Specification is under review by Licensing and work is in progress to enlarge the wastewater collection facility. Full compliance would require the completion of both. We do not consider this a satisfactory response. It says nothing to their effort to expedite the action or to their seeking interim relief from the requirement. This would mean that they will continue to be in violation for some unspecified period of time. >- !
. . -3- Duke Power Company We have learned from telephone contact with DPC that their request for revision to the Technical Specification was that they be allowed to sample on site beyond the outf all from the basin to take advantage of additional dilution. In addition, they will improve circulation in the basin by adding another pump and the enlargement of the basin should be completed by September 1,1974. Although not stated in their response letter, they have contacted Licensing previously in an effort to expedite the requested Tech. Spec. revisions. It is clear to us that DPC has erred and is at fault for not meeting the Tech. Spec requirement; but, since this has occurred, our pcsition car.not be one of condoning continued violation until certain actions are completed, one of which is a Licensing action of undeterminable timing. We believe that some remedial course may be achieved by discussion of this with Licensing by RO:Hqs, and we ' recommend this. t . ~s , l l/ f'C.M.Uprigh,AcyngChief . Facilitie perations Branch cc: N. C. Moseley T. N. Epps jy n - e . L- m }}