ML20024H764

Responds to NRC 910507 Ltr Re Violations Noted in Insp Repts 50-269/91-09,50-270/91-09 & 50-287/91-09.Corrective Actions: Changes Will Be Incorporated Into Startup Procedures to Keep Fire Station Isolation Valves Apart

ML20024H764
Person / Time
Site:	Oconee
Issue date:	06/04/1991
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9106100434
Download: ML20024H764 (3)

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{ DUKCPOWER June 4,1991 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

Subject:

Oconee Nuclear Station Docket Nos. 50-269, 270,-287 Inspection Report 50 269, -270, -287/91-09 Reply to Notlee of Violation

Dear Sir:

By letter dated hiay 7,1991, the NRC issued Inspection Report Nos. 50 269/91 09, 50-270/9109 and 50-287/9109 with a Notice of Violation. Pursuant to the provisions of 10 CFR 2.201, I am submitting a written response to the violation identified in the above Inspection Report.

Very truly yours,

??'{.l tebta /g bl. S. Tuckman, Vice President Nuclear Operations RRE192/wp ec: hir. S. D. Ebneter Regional Administrator U. S. Nuclear Regulatory Commission Region 11 101 h!arietta St. NW Atlanta, GA 30323 NRC Resident inspector Oconec Nuclear Station hir. L. A. Wiens Office of Nuclear Reactor Regulation

U. S. Nuclear Regulatory Commission l One White Flint North, hiail Stop 9113 j Washington, DC . 20555

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VIOLATION (4t287/91-09-02), SEVERITY LEVEL (IV)

Technien1 Speci fiention 6.4. I requirns that the station be operated and maintained in necordance with approved procedures. Procedure

-OP/3/A/1102/10, fontrol11ng Procedure for Unit Startup, Enclosure 4.5, Prohent Reactor Building Startup Valve Checklist, requires valves 3LPSW-563 and 3LPSW-564 to be shut prior to reaching Renctor Coolant System temperatures and presnuren of 250 degrees fahrenheit and 330 paig respectively.

Contrary to the abovo, Unit 3 wns not operated and maintained in accordance with approved procedures in that, on April 12, 1991, valven 3LPSW-563 and 3LPSW-564 were found open. They had been open since March 24, 1991, to meet exinting plant conditions at that time but were not shut when n new startup procedure was initinton.

RESPONSE

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1. Rennnn fer the violation:  !

The reason this viointion occurred wnn the use of an inadequat e procedure. The misponi tioned valves, 3LPSW-563 and 3LPCW-564, were opened by sign-off ntepa in the nhutdown procedure, but were not set apart an sign-off steps in the startup procedure. They were controlled by a checklist containing Ronctor Coolant Pump cooling water valven in the str.rtup procedure. Since the procedure didn't not the valven apart, the fact that thny needed to be reposi ti oned was overlooked during thn ntnrtup following the cooldown for incore instrument lonk repair.

A contributing factor to this violation van the inndequate review of the complated checklint containing 3LPSW-563 and 3hPSW-564. The checkli nt complet ed during the post-refueling outage hentup.wnn not properly t aviewnd on completed and wan

lef t in the 9tnrt up procedure notebook in ure at the time.

Since this checklint was found in tha nntebook, the SRO signnd off tha stop in the new pre-bentup checklint requi ri ng that thin encionurn of the procedure be run.

-2. Corrective steps that have been taken and the results achieved:

f The immediate corrective action was to place the valven in their requi red poni tion. In addi tion, the SRO that signed of f the pre-hentup chncklint per thn innppropriate valve checklint was counseled in the proper use of completed checklists.

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3. Corrective steps that will be taken to avoid further viointions: ,

Procedure changes will be incorporated in the startup  ;

procedures for all three Oconee unitn. These changes will set the fire station inointion valven apart as a sign-of f stop in the body of the procedure. The nhutdown procedure will also be changed to standardize the point at which the valves are opened and closed.

A review of the startup and shutdown procedures will be performed to identify similar opportunition for improvement.  ;

A training pachnge will be innued ernphanizing the necensity of caution when signing off steps of proceduren based on previously- completed proceduren and the neconnity of processing completed checklinto in a timely manner. This training packnge will be reviewed by all licenned operators.

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4. Date of full compliance:

Procedure changen impncting the fire ntation isointion valven will- be completed prior to the Unit I refueling outage scheduled to begin Augunt 1, 1991.

. Procedure changos resulting f rom the more comprehensive review ,

,- of the startup and shutdown proceduren will be completed l before January 1, 1992. I l

The training pachnne will be innued before Augunt 1, 1991.

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