ML20116N747
| ML20116N747 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/18/1992 |
| From: | Hampton J DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9211240115 | |
| Download: ML20116N747 (3) | |
Text
Duke hmvr Compny J W Ihvenn Ocortee Nuclear Generation Department Vee Prendent l'O Bar H39 (M3)MS4499 0%e Seneca, SC 29679 i70t)373422;!,x DUKEPOWER November 18, 1992 U.S. Nuclear Regulatory Commission Attention.
Document Control Desk Washington, DC 20555
Subject:
Oconee Nuclear Site Docket Nos. 50-269, -270, -287 Inspection Report 50-269,'-270, -287/92-23 Reply to Notice of Violation
Dear Sir:
By letter dated October 20, 1992 the NRC issued a Notice of Violation as described in Inspection Report No. 50-269/92-23, 50-270/92-23, and 50-287/92-23.
Pursuant to the provision of 10 CFR 2.201, I am submitting a written _ response - to the violation identi fied in the above Inspection Report.
I would like to note that this violation was not received by the site until ' November -- 2, 1992.
Although the_ notice of 4
violation was dated October 20, 1992, the postmarked date was October 27, 1992 - I appreciate your attention-to this matter-in future reports.
Very truly yours, (0
- ['
J. W. Hampton.
IL cc:
.Mr.
S. D. Ebneter, Regional Administrator U.
S. Nuclear Regulatory Commission,_ Region II Mr.
L.-A. Wiens, Project Manager Office of Nuclear Reactor Regulation Mr. P. E. Harmon-Senior Resident Inspector Oconee Nuclear Site
- f. Q n i's ? ;\\
9211240115 921118 gDR ADOCK 05000269 PDR
-[I (v
____i.____________
TIOLATION 269,270,287/92-23-01, SEVERITY LEVEL IV Oconee Technical Specification 3.6.5 requires that prior to critical!:y following refueling shutdown, a check shall be made to confirm that all manual containment isolation valves which should be closed are closed and tagged.
Oconee Technical Specification 3.6.1 requires that containment integrity be maintained whenever the RCS pressure is 300 psig or greater, and RC temperature is 200*F or greater, and nuclear fuel is in the core.
Containment integrity 10 defined to exist when all non-automatic containment isolation valves and blind flanges are closed as required.
Contrary to the above, the above requirements were not met in that manual containment isolation valve IN-107 remained in the open position from May 30, 1992, till September 8, 1992.
RESPONSE?.
1.
The reason for the violation, or, if contested, the basis for disputing the violation:
00 May 29, 1992, PT/1/A/115/08, Reactor Building Containment Isolation and Verificat'on, was initiated in preparation for startup. 3 4, Outside Reactor Building Manual Isolation Valve Checklist Verification, includes verifying that 1N-107 is closed.
On June 2,1992, the pressurizer was pressurized with nitrogen in accordance with OP/1/A/1103/02, Filling and Venting the Reactor Coolant System.
This task required 1N-107 to be open in order to provide a
flow path for nitrogen-to the pressurizer.
The procedure does not contain a step requiring the closure of 1N-107, and instead relies on PT/1/A/115/08 to close the valve pr.icr to exceeding 200*F and 300 psig in the Reacter Coolant System.
The use of these procedures was directed by OP/1/A/1102/01, Controlling Procedura for Unit Startup, Enclosure 4.1, Unit Startup from Cold Shutdown to Beactor Coolant System Temperature and pressure of 250*F and 350 psig.
This procedure allows parallel performance of PT/1/A/115/08, OP/1/A/1103/02, and the Pre-Heatup Checklist, a part of OP/1/A/110?/01.
The deficiency that existed in OP/1/A/1103/02 allowed 1N-107 to remain open af ter - the heatup and pressurization of the plant made containment integrity necessary.
The procedure should have contained a step to close the valve.
1 e
ilolation Response 92-23-01 Page Two 2.
The corrective aceps that have been taken and tr e results achieved:
The immediate corrective action taken was to close 1N-107 to restore containment integrity.
3.
The corrective steps that will be taken to avoid further violations:
Procedure OP/1,2,3/A/1103/02 will be revised to return 1N-107 to the closed position upon completion of the procedure.
Procedure OP/1,2,3/A/1102/01, Enclosure 4.1, will be revised to perform the Containment Integrity Checklist after the completion of procedures that affect manual Containment Isolation Valves.
4.
The date when full compliance will be achieved:
Full compliance was achieved on September 8, 1992 when valve 1N-107 was closed.
The procedures will be revised prior to the completion of the next refueling outage for each unit:
Unit 1 EOC14 Refueling Outage (scheduled to begin 12/3/92)
Unit 2 EOC13 Refueling Outage (scheduled to begin 4/14/93)
Unit 3 EOC14 Refueling Outage (scheduled to begin 12/12/93)
In addition to the corrective actions listed under Item 3, operating procedures that position valves that are verified in Periodic Test (PT) procedures performed quarterly or prior to startup will be reviewed to ensure that the procedure returns the valves to the correct position as indicated in the verification PT.
Procedure changes wl'1 be
- made, if necessary, based on this review.
While this review cannot guerantee that a similar occurrence w_11 never take place, it will lessen the likelihood of recurrence.
This item will be tracked under LER 269/92-13.
I 1