ML20140B561

Responds to NRC Re Violations Noted in Insp Repts 50-269/85-41,50-270/85-41 & 50-287/85-41.Corrective Actions: Reactor Coolant Leakage Procedure Will Be Revised by 860501 & Personnel Counseled

ML20140B561
Person / Time
Site:	Oconee
Issue date:	03/13/1986
From:	Tucker H DUKE POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8603240235
Download: ML20140B561 (4)

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DUKE Powen GOMPANY-e.o. nox aai8o CHAltLoTTE, N.C. 28242 HALB.Tl!CKER Tztrenown vws es an, r r. (70.s) 07Maat

<.o t#.317 P 2 ; 3 4 March 13, 1986 Dr. J. Nelson Grace, Regional Administrator U.S. ~ Nuclear Regulatory Connaission - Region II 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 4

Subject:

Oconee Nuclear Station IE Inspection Report Nos. 50-269/85-41 50-270/85-41 50-287/85-41

Dear Sir:

In response to your letter dated February 12, 1986 which transmitted the subject Inspection Report, the attached response to the cited items of non-compliance is provided.

Very truly yours,

/

/ VL Hal B. Tucker PJN/jgm Attachment xc: J.C. Bryant

'NRC Resident Inspector Oconee Nuclear Station 8603240235 860313 PDR ADOCK 05000269 G PDR

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_1-Violation 1 Technical Specification (TS) 3.1.6.2 requires the licensee to shut down the reactor within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection of any unidentified reactor coolant leakage which exceeds 1 gallon per minute (gpm), excluding normal evaporative losses.

1 Contrary to these requirements, on Friday, December 13, 1985, upon detection of Unit 2 reactor coolant Jeakage in excess of I gpm, the leakage was not subsequently identified or determined to be less than 1 gpm. Prior to shut-

. down, unidentified leakage rate calculations ranged up. to 1.65 gpa. While the licensee made every attempt to identify the leakage, a period of approx-imately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> elapsed from the time of detection until the reactor was shut down.

This violation applies to Unit 2 only.

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

Response

i j (1) Admission or denial of the alleged violation:

This violation is technically correct as stated. However, the Notice of Violation does not reflect the following information (although the details in Part 8 of the Inspection Report do address some of these~ items):

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(A) During an approximately 58 hour6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> period from 12/12/85 to 12/14/85, 26 leakage monitoring calculations were made to closely monitor the leakage status. Out of these calculations, 7 of 26 were less than or equal to 1.0 gpm.

(B) Extensive leak searches and evaluations were made during this period.

There was considerable management involvement and continuous monitoring of critical leakage indicators.

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4 (2) Reasons for the violation if admitted:

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The Reactor Coolant Leakage Procedure defines the specific point at which the Technical Specification Limiting Condition for Operation (LCO) is entered; however,'it does not explicitly-' define the conditions at which-j the LCO can be exited. In the cited situation, the leakage: calculation l results periodically indicated less than 1.0 gpm leakage. Although leak-searches and evaluations were performed, it was felt that reactor shut-down was not necessary until conclusive and/or consistent leakage results were obtained. The shutdown was initiated at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on 12/14/86 even l though a leakage indication of 0.62 gpm was obtained less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

, earlier.

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The course of action taken by plant management was considered to be appro--

priate and responsible, although it is recognized that NRC could interpret the actions as a violation of Technical Specifications, particularly in the absence of procedural guidance. ,

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

Appropriate personnel have been informed of the citation and the associated interpretation by NRC of compliance with the RCS leakage Technical Specifi-

cations. No similar leakage events have occurred since the cited event on which to review the effectiveness of these communications.

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! (4) Corrective steps which will be taken to avoid further violations:

} The Reactor Coolant Leakage Procedure will be revised to define the points at which the associated LCO's are entered or exited, as follows:

I (A) If a valid leakage calculation results in a leakage rate greater than i 1.0 gpm, obvious leakage indicators (letdown storage tank and reactor i

building sump) will be monitored and a second leakage calculation will be initiated. A. valid leakage calculation is defined within the procedure and relates to system stability.

(B) If 2 consecutive valid calculations result in leakage rates greater than 1.0 gpm, the LCO will be entered (based on the time of the'first  !

j calculation results) and the appropriate actions taken.

1 (C) Once the LCO is entered, it will remain in effect until the time at which the leakage is corrected and/or 2 consecutive valid calculations indicate leakage rates less than or equal to 1.0 gpm. ' If subsequent calculations result in reentering the LCO (as defined in (B) above),

j the time associated with entering the LCO will be reinitialized as if leakage had not previously existed.

t It is felt that this approach fully complies with the requirements of the Technical Specification. Furthermore, incorporation of this approach into the procedure will prevent any future misinterpretation associated with I entering and/or exiting the LCO.

(5) Date when full compliance will be achieved:

The procedure revision noted in-(4) above will be completed by'May 1, 1986.

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3 Violation 2 Technical Specification 6.4.1 states that the station will be operated and maintained according to approved procedures. The Oconee Project Services Manual, Section 4.4, Exempt Changes, paragraph 3.5, requires that although j the work described in an exempt change may proceed following verbal approval by Design Engineering, the system shall not be returned to service until the associated Variation Notice, which provides details of the change, is resolved by Design Engineering.

Contrary to the above requirements, on October 6, 1985, after receipt of verbal approval, an~ exempt change was implemented on a reactor coolant system sample line and the system returned to service prior to approval of the variation notice. Subsequently, the variation notice was rejected by Design Engineering due to use of materials with insufficient wall thickness.

i-j This violation applies to Unit 3 only.

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

Response

(1) Admission or denial of the alleged violation:

This violation is admitted; however, the wording in the second paragraph of the violation is not completely accurate. The opening sentence should read, " Contrary to. . .to service prior to resolution of the variation notice."

(2) Reasons for the violation if admitted:

This violation resulted from personnel error by the Projects engineer who

, implemented the exempt change. He inadvertently failed to follow the 1 established program noted.

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

. The engineer involved has been counseled. In normal practice, exempt l changes on operating units or units in the process of starting up will not be issued for implementation until the resolved copy is received back from Design Engineering. Appropriate Projects personnel have been reminded of the requirements for processing of exempt changes.

(4) Corrective steps which will be taken to avoid further violations

i Established programs are adequate to prevent further violations if followed.

Since this violation resulted from an isolated personnel error, no further-corrective action is necessary.

(5) Date when full compliance will be achieved:

All corrective steps are complete.

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