ML20101Q815

Responds to NRC Re Violations Noted in Insp Repts 50-269/92-11,50-270/92-11 & 50-287/92-11.Corrective Actions: Estimated Critical Position Calculated & Verified Using Unit 1 Reactivity Curves & Curves Placed in unit-specific Book

ML20101Q815
Person / Time
Site:	Oconee
Issue date:	07/08/1992
From:	Hampton J DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9207150112
Download: ML20101Q815 (3)

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July 8, 1992

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U.G. Nuclear Regulatory Commission Attention:, Document Control Desk Washington,.DC 20555 1

Subject:

Oconee Nucls'tr Site L

Docket Nos. 50-269, -270, -287 Inspect!.on Report 50-239, -270, -287/92-11 Reply to Notice of Violation

Dear Sir:

By letter dated Mv/ 20, 1292 the NRC issued InGpe,.: tion Report No.

50-269/92-11, 50-270/92-1.1, and 50-287/92-11 with a Hotico of Violation.

Pursuant. to the provision of 10 CFR 2.201, I am submitting a written response to the violation identified la the above

-Inspection Report.

.Very truly yours,

/bdT, I_

-o<,< <.m

~

J. W. Hampton.

y Mr. S.LD. Ebneter, Regional Administracor cc:

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S.' Nuclear' Regulatory Commission, Region II 101 Marietta Street, NW-Suite 2900 Atlanta, CA 30223-

- Mr. L.-A'.

Wiens,. Project Manager Office of Nuclear-Reactc,r Recy:lation U. S. Nuclear Regulatory Comalsalon

- One White Flint North, Mail Stop.9H3 Washington,.DC: 120555 P. E. Harmon Senior Resident ' inspector l-

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I VIOLATJpy 269/92-11-01. SEVfEITY LEVEL IV LTechnica1' Specification 6.4.1 requires that the station be operated 4

in accordince with approved procedurea.

Operating Procedure ' OP/1/A/1102/01, Unit Startun, requires that

Reactivity Balance Procedure, DT/1/A/1102/15, be used to calculate Estimated Critical Position (ECP) and Estimated Boron Concentration

.(ECB); prior to going critical.

Contrary to the.aoove., the station wac not op3 rated in accordance with OP/1/A/1102/01 in tht the Unit 2

Reactivity Balance Procedure, PT/2/A/1105/15 was used on se veral occasions on May 11 to calculate the Unit 1 ECP and ECB.

BESPONSE_

1.

The reason for the violatton, or, if contested, the basis for disputing the violation:

T'ae reactivity curves for both Unita 1 and 2 were located in similar notebooks in a common bookshell.

Each notebook also contained the Control Copy of the procedure and working copies._. (Generally, the Control Copy of Opera'ing Procedures

. and Perloc.10- Tosts specific to a unit are contained in color coded folderr and filed in separate cabinets.)

The Unit

-Supervisor inadvertently pulled the notebook for Unit 2 instuad := of - thcl' notebook for Unit 1.

He performed the c

Estimated Critical' Baron (ECB) calculet. tor. nsing the curves

=and procedure #for Unit 2.

The calculations were repeated for verification l by the Shif t Manager,J using che same proce.iure and curves..

h.'

.When it vus'determ.!ned that criticality would not be reacted lJ

-during' the calculated time period, the ECB calculation was ropeated by the Unit. Supervisor and verified by the Shift Meager.

-Unit-2 curves and procedure werce used again.

.]

/The Estimated Critical Rod Position 4 (FCP) was calculated by 5

the1 Unit Superviser;and werified by-the Shift' Manager, using

-the; Unit iEcurves and' procedure.

the procedure yas turned over to the ev9ning shift, where y

- power escalation was continued to 62%.

Nearing the end-of the evening shift,-the Unit Supexvisor reviewed the completed procedures-from his ehlft and discovered that Unit 2

t enclosurus' ware used to perfor.n - ECB - and ECP calculations ou p

Unit 1.

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e Violation Response 92-11-01.

Page Two 2.

The corrective steps that have been taken and the resultu achieved:

The ECP was calculated and verified using the Unit I

reactivity curves.

The Shutdown Margin available was calculated and verified to assure. that an adequate shutdown margin existed.

Resul;.

Indicated an adequate shutdown margin was available.

The reactivity curves were placed in unit specific, color coded notebvoks.

The working copies of the Reactivity Balance Procedure were placed into Working Copy file cabinets.

Other procedures and notebcoks in the Units 1 and 2 Control Room were considered for similar possibility of using the wrong unit's procedure.

It was determined that the only procedures for both units located on the same bookshelf were the Emergency and Abnormal Operating Procedures.

The Emergency Operating Procedures are contained in a red birider and the Abnormol Operating Procedures are contained in a blue binder.

These. procedurer are clearly marked with the unit designator.

The personnel involved in this event were counseled concerning their responsibility to use correct procedures and properly perform independent verification.

3.

The corrective steps that will be taken to avoid turther violations:-

This. incident will be discussed in the Shift Supervisor's meeting and with licensed personnel in Operations.

4.

The date when full compliance will be achieved:

Discussions will be completed by September 30, 1992.

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