ML20054K331

Responds to NRC Re Violations Noted in IE Insp Repts 50-269/82-12,50-270/82-11 & 50-287/82-11.Corrective Actions:Procedures Revised to Specify Equipment Not Operated While Ventilation Sys Out of Svc

ML20054K331
Person / Time
Site:	Oconee
Issue date:	06/01/1982
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054K325	List: IR 05000269/1982012 ML20054K324 ML20054K331 ML20054K333 ML20054K337
References
NUDOCS 8207010433
Download: ML20054K331 (4)

Text

T DUKE POWER COS.i,pl3rt. REC;']t; 1 ~n-,

I'OWER DUIDING ~ e' n r"

• U c'VO ' ? N' 422 Sourn Cucacu SraEzr, CHAHWTTE, N. C. 28242 WILLI AM O. PAR M ER, JR.

32 JUN 4 A9:50

%cr PotsiDrest TEL E ***o n t:Anta 704 s,r. P.oover.o June 1, 1982 273-40s3 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: Oconee Nuclear Station IE Inspection Report 50-269/82-12 50-270/82-12 50-287/82-12

Dear Sir:

With regard to Mr. R. C. Lewis's letter of May 3, 1982 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.

I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge, executed on June 1, 1982.

V y truly yours, CQ

~

William O. Parker, Jr JFN/php Attachment 8207010433 820621 PDR ADOCK 05000269 O PDR

O Violation A Technical Specification 3.8.12.b requires two trains of spent fuel pool ventilation to be operable during all operations involving the movement of fuel within the spent fuel pool.

Contrary to the above, both trains of spent fuel pool ventilation were inoperable between March 23, 1982 and March 30, 1982 during the movement of ten fuel assemblies within the Unit 3 spent fuel pool and on April 2, 1982 during the movement of one fuel assembly within the Unit I and 2 spent fuel pool.

This is a Severity Level IV Violation (Supplement I.D.2.).

Response

1) Admission or denial of the alleged violation:

The violation is correct as stated. The Unit 3 incident was reported to the NRC as R0-287/82-05, and the Unit 1 and 2 incident was reported as R0-270/82-06,

2) Reasons for the violation:

Both incidents cited were the result of personnel error. For Unit 3, the White Tags used for removal and restoration of the ventilation fans were not properly placed or removed. For Units 1 and 2, the individual-moving the fuel assembly failed to properly verify the operability of the ventilation system in accordance with the Fuel and Component Handling procedure.

3) Corrective actions taken and results:

For Unit 3, the ventilation system was returned to operability by proper clearing of the White Tags. For Units 1 and 2, fuel handling was suspended until the ventilation system was-returned to service.

The personnel involved in both incidents have been counseled. Operations and Performance personnel have reviewed these incidents.

4) Corrective actions to be taken to avoid further violations:

Appropriate procedures are being evaluated and will be revised to specify equipment not to be operated when the Spent Fuel Pool Ventilation system is out of service. This evaluation will also assure that any procedure involving fuel handling requires verification by Control Room personnel

f e

that the SFP Ventilation system and Area Radiation Monitors are operable prior to fuel handling. The Fuel Bridge Operator qualification program has been modified to include a review of the operability verifications noted above. All currently qualified Fuel Bridge operators will review the SFP Ventilation system operability requirements.

5) Date when full compliance will be achieved:

Corrective actions noted in (4) are expected to be completed by July 1, 1982.

Violation B 10 CFR 50.59(b) requires that a summary of the safety evaluation of each change to the facility made pursuant to this section be submitted to the NRC at 1 cast annually.

Contrary to the above, facility change safety evaluation summaries were not submitted annually to the NRC in that the 1980 report of Oconee facility changes, submitted to the NRC on November 20, 1981, did not contain a summary of the safety evaluations for the listed modifications.

This is a Severity Level V Violation (Supplement I.E.).

Response

1) Admission or denial of the alleged violation:

The violation is correct as stated.

2) Reasons for the violation:

The annual summary report submitted on November 20, 1981, contained a summary safety evaluation statement which was intended to cover the con-clusion of each safety evaluation performed for each facility modification without having to restate that conclusion for each modification. It was considered by Duke that such a submittal adequately met the requirements of 10 CFR 50.59.

3) Corrective actions taken and results:

Based on subsequent discussions with Region Il personnel, it is now understood that our interpretation of the type of safety evaluation summary which is required in the annual facility modification report was not adequate.

i Future such reports will contain individual safety summaries of each facility l

modification.

l l 4) Corrective tetions to be taken to avoid further violations:

i

Duke personnel are now aware of the correct format to be utilized in these l

reports and will ensure that future facility modification lists include the required individual safety evaluation summaries.

5) Date when full compliance will be achieved:

The correct format for safety evaluation summaries will be incorporated in the next facility modification report which is expected to be completed by August 1, 1982.

l