ML20197J697

Suppls Response to NRC Re Violations Noted in Insp Repts 50-269/85-25,50-270/85-25 & 50-287/85-25. Corrective Actions:Containment Hydrogen Recombiner Sys Governed by Operating Procedure OP/O/A/1102/23

ML20197J697
Person / Time
Site:	Oconee
Issue date:	05/02/1986
From:	Tucker H DUKE POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8605200149
Download: ML20197J697 (3)

Text

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'$ e DUKE POWER GoxPm P.O. 33180 CIIAJtM) N.G.28242 IIAL15 TUCKE14 ,

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nexteam emooncriou May 2, 1986 Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, GA 30323

Subject:

Oconee Nuclear Station Docket No. 50-269/85-25, 50-270/85-25, 50-287/85-25 4

Dear Dr. Grace:

By letter dated April 3, 1986, NRC/ Region II requested a supplemental response relative to the Duke Response of October 14, 1985 to the Notice of Violation identified i the subject inspection report issued by a September 19, 1985 NRC letter. In response, please find attached the requested supplemental response.

Very truly yours, Hal B. Tuck.er PFG/jgm xc: J.C. Bryant NRC Resident Inspector Oconee Nuclear Station

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8605200149 860502 PDR ADOCK 05000269 G PDR l I hh

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Violation 10 CFR 50.44(b) states that each boiling or pressurized light-water nuclear power reactor fueled with oxide pellets within cylindrical zircaloy cladding shall be provided with the capability for measuring the hydrogen concentra-tion in the conta~inment.

An NRC Confirmatory Order in the case of Oconee Nuclear Station dated March 18, 1983, required the implementation of certain post-TMI related items as set forth in NUREG-0737 for which the NRC staff reque.ced completion on or after July 1, 1981. NUREG-0737, Item II.F.1.6, "Provfoes contiw,)us indica-tion of hydrogen concentration in containment," was reported as coc;1eted for all Oconee units by the Order. NUREG-0737, Item II.F.6 states, in pact, that the accuracy and placement of the hydrogen monitors shall be provided and justi-fied to be adequate for their intended function. The accuracy of the licensee's equipment was accepted by the NRC in a July 1984 Safety Evaluation.

Contrary to the above, trains A and B of the license's Unit 1 Reactor Building Hydrogen Monitoring System were inoperable from March 6, 1985, to March 26, 1985.

This is a Severity Level IV violation (Supplement 1).

Response

1) Admission or denial of the alleged violation:

Duke Power Company acknowledges the Commission's position and admits the violation with reservations.

As previously stated, our reservations center on the fact that no explicit, written, operability and surveillance requirements for the

. RB Hydrogen Monitoring System have been identified in either 10 CFR 50.

44(b), or NUREG-0737, Item II.F.1.6, or the associated Confirmatory Order.

Pursuant to Generic Letter 83-37, which recognizes the necessity of opera-bility and surveillance requirements for this system, and recognizes plant Technical Specifications as the appropriate place for these require-ments, proposed Technical Specifications were submitted to the Commission on October 8, 1984. Since the time of initial implementation in September 1982, Duke Power Company feels that all reasonable efforts possible have been expended to maintain the system operable.

2) Reasons for the violation: '

This violation resulted from an administrative failure to adequately interpret 10 CFR 50.44(b) and the Confirmatory Order to NUREG-0737, Item II.F.1.6. The implied operability and surveillance requirements were not properly identified.

3) Corrective steps which have been taken and the results achieved:

A) The proposed Technical Specification operability and surveillance requirements are being administered as binding until approved Techni-cal Specifications are issued by the Commission. Since March 1985, no incidence of both hydrogen monitoring trains being out-of-service for 7 days has occurred on any Oconee unit.

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B) Following a LOCA, the operation of the Containment Hydrogen Recombiner System (CHRS) is governed by Operating Procedure OP/0/A/1102/23. A " Limit and Precaution" has been added to this procedure, stating:

If all hydrogen analyzers are out of service and information is not available to determine hydrogen concentration in the reactor building following a LOCA, place the CHRS in service on the affected unit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of engineered safeguards actuation.

With containment hydrogen not being a real concern until more than a month after the design basis hydrogen generation event, this procedural control should completely address any concerns about adequate compensatory measures in the event of hydrogen monitoring system failures.

4) Corrective steps which will be taken to avoid further violation:

No further corrective actions are required. Of course, once an approved Technical Specification on hydrogen monitoring system operability and surveillance requirements is received, it will be appropriately administered.

5) Date when full implementation will be achieved:

Full implementation of the identified corcective actions was achieved on February 18, 1986.

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