IR 05000269/1993029

Discusses 931108 Enforcement Conference in Region II Ofc, Re Apparent Violation Noted in Insp Repts 50-269/93-29, 50-270/93-29 & 50-287/93-29 on 931019-27.List of Attendees, Meeting Summary & Licensee Presentation Encl

ML20058J737
Person / Time
Site:	Oconee
Issue date:	11/30/1993
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Hampton J DUKE POWER CO.
References
EA-93-252, NUDOCS 9312140219
Download: ML20058J737 (17)

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NOV 301993 Docket Nos. 50-269, 50-270, 50-287 License Nos. DPR-38, DPR-47, DPR-55 EA 93-252 Duke Power Company ATTN: Mr. J. W. Hampton Vice President Oconee P. O. Box 1439 Seneca, SC 29679 Gentlemen:

SUBJECT: ENFORCEMENT CONFERENCE SUMMARY - OCONEE UNITS 1, 2 AND 3 NRC INSPECTION REPORT NOS. 50-269/93-29, 50-270/93-29 AND 50-287/93-29 This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by Mr. P. E. Harmon on October 19 through 27, 1993, at the Oconee Nuclear Station. The report documenting this inspection was sent to you by letter dated October 29, 1993. As a result of this inspection, an apparent violation of NRC requirements was identified. The apparent violation related to the untimeliness of the corrective action taken once it was determined that testing to demonstrate the Keowee Units would perform satisfactorily in service was incomplete. When a permissive relay was tested on September 29, 1992, some 20 months after your Design Basis Documentation (DBD) program identified that testing of the circuit was required, it was found to be inoperable and would have prevented Keowee Unit 2 from performing its intended safety function when aligned to the overhead emergency pat An Enforcement Conference was held on November 8, 1993, in the NRC Region II Office to discuss this apparent violation, its cause and safety significance, and to provide you the opportunity to point out any errors in the inspection report. A list of attendees, enforcement conference summary, and a copy of your enforcement conference handout are enclose Your presentation provided additional information and clarification of both the issues associated with the apparent violation and the items identified in our inspection report. Our report indicated that breaker ACB-2 did not close as required due to the failure of a MG-6 relay, that the overhead emergency power supply path and this MG-6 relay had never been tested, and that this path could have been inoperable since initial installatio However, during your investigation of this event, you found that the MG-6 relay was tested as part of the plant pre-operational test program in February 1972. You also found the safety significance to be low since the overhead path was affected only from Keowee Unit 2. This MG-6 relay failure had no effect on the redundant overhead path from Keowee Unit 1 or the underground path from either Keowee uni +/ d 9312140219 931130 PDR G

ADOCK 05000269 PDR I d[

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Duke Power Company 2 NOV 3 01993 l

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Following your presentation, the NRC staff met and determined that no -

violation of regulatory requirements occurred because the relay was initially ,

tested and additional testing was not required by the Technical ,

Specifications. However, we view your failure to aggressively pursue the i

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testing of the overhead emergency power supply and the function of circuit breakers ACB-1 and ACB-2 at Keowee, following your staff's identification that these items needed to be tested, as a significant deficiency. We are also i concerned with the prioritization and scheduling of the corrective actions for  ;

this potential deficiency, and the possible generic implications associated  !

with this issu In view of our concerns, we request that you provide a -

written response to the following questions within 30 days of receipt of this j lette !

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Describe the specific prioritization procedures for the correction -

of problems identified during your DoD review evaluatio ;

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Describe the specific procedures used to establish the schedule  :

for correcting discrepancies identified during your DBD "

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evaluatio Describe the process by which extension due dates are approved I including the management level of approval, the requirements for j justification, and the level of oversight, if an l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice", a copy of this letter and its enclosures will be placed in the NRC Public Document Roo i The responses directed by this letter are not subject to the clearance '

procedures of the Office of Management and Budget as required by the Paperwork i Reduction Act of 1980, Pub. L. No. 96-51 ,

Should you have any questions concerning this letter, please contact u ;

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Sincerely,

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j hl * 'OM Mf Ellis W. Merschoff, Director .

Division of Reactor Projects l

Enclosures- l List of Attendees i Meeting Summary Licensee's Presentation r

cc w/encis: l M. E. Patrick  !

Compliance Duke Power Company P. O. Box 1439 '

i Seneca, SC 29679 cc w/encls: Continued see page 3 l

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Duke Power Company 3 NOV 301993 l cc w/encls: . Continued i A. V. Carr, Es ,

Duke Power Company .

422 South Church Street i Charlotte, NC 28242-0001 '

County Supervisor of I Oconee County .

Walhalla, SC 29621

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Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525  !

Rockville, MD 20852 i J. Michael McGarry, III, Es j Winston and Strawn j 1400 L Street, NW t Washington, D. C. 20005

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Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Max Batavia, Chief j '

Bureau of Radiological Health  :

South Carolina Department of Health  !

and Environmental Control 2600 Bull Street Columbia, SC 29201  ;

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Manager, LIS f NUS Corporation l 2650 McCormick Drive -!

Clearwater, FL 34619-1035 l

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G. A. Copp  ;

Licensing - EC050 i Duke Power Company _

P. O. Box 1006 1 Charlotte, NC 28201-1006 o i

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Karen E. Long Assistant Attorney General

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N. C. Department of Justice P. 0. Box 629 Raleigh, NC 27602 '

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Duke Power Company 4 NOV 301993 .

bec w/encls:  ;

L. A. Wiens, NRR W. Miller, RII ,

M. S. Lesser, RII ,

A. R. Herdt, RII Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission t Route 2, Box 610 Seneca, SC 29678 1 fokm , AT I

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I CONCURRENCE SEE ATTACHED

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L. A. Wiens, NRR  ;

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M. S. Lesser, RII ,

A. R. Herdt, RII Document Control Desk NRC Resident Inspector  :

U.S. Nuclear Regulatory Commission '

Route 2, Box 610 Seneca, SC 29678 i

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ENCLOSURE 1  ;

LIST OF ATTENDEES U.S. Nuclear Reaulatory rommission  ;

S. D. Ebneter, Regional Administrator, Region II (RII)

J. R. Johnson, Deputy Director, Division of Reactor Projects (DRP), RII J. P. Jaudon, Deputy Director, Division of Reactor Safety (DRS), RII j

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A. R. Herdt, Chief, Reactor Projects Branch 3, DRP, RII M. S. Lesser, Chief, Reactor Projects Section 3A, DRP, RII G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff, RII C. F. Evans, Regional Counsel, RII B. Uryc, Senior Enforcement Specialist, RII J. G. Luehman, Senior Enforcement Specialist, Office of Enforcement (By Phone)

L. A. Wiens, Project Manager, Project Directorate II-3, Office of Nuclear Reactor Regulation (NRR)

P. E. Harmon, Senior Resident Inspector, Oconee, DRP, RII W. H. Miller, Project Engineer, DRP, RII f

Duke Power Company J. W. Hampton, Vice President, Oconee Nuclear Station (ONS)

H. B. Barron, Station Manager, ONS B. L. Peele, Engineering Manager, ONS J. M. Davis. Safety Assurance Manager, DNS .

R. H. Lynn, Commodities and Facilities Manager, ONS D. V. Deatherage, Unit 1 Operations Manager, ONS D. B. Coyle, Superintendent, System Engineering, ONS M. E. Patrick, Regulatory Compliance, ONS i

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ENCL.0SURE 2  ;

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ENFORCEMENT CONFERENCE SUMMARY On November 8,1993, representatives from Duke Power Company. (DPC) met with the NRC in the Region 11 Office in Atlanta, Georgia to discuss an apparent !

violation related to the untimeliness of corrective action following the .

l-licensee's determination that testing to demonstrate the Keowee Units would perform satisfactorily in service was incomplete. When the permissive relay >

was tested on September 29, 1992, it was found to be inoperable, some 20 months after the Design Basis Documentation program identified that testing of the relay was required to be tested. The relay would have prevented Keowee t

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Unit 2 from performing its intended safety function when aligned to the

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overhead emergency pat :

Following opening remarks by Mr. S. D. Ebneter, Regional Administrator, Region II (RII) and Mr. J. R. Johnson, Deputy Director, Division of Reactor Projects, RII, DPC gave a presentation, Enclosure 3, on the issu !

An introduction to DPC's presentation was given by Mr. J. W. Hanpton, Vice ,

President, Oconee Nuclear Station (ONS), with the formal presentation given by j Mr. B. L. Peele, Oconee Site Engineering Manager, ONS. The presentation s included a description of the Oconee electrical system and emergency power i supply system, the circumstances surrounding the event, integrated test l considerations for the emergency power supply system, the safety significance l

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of the event and the corrective actions implemented to prevent recurrenc The presentation provided additional information and clarification of both the issue associated with the apparent violation and the items in the inspection j report. The inspection report indicated that breaker ACB-2 did not close as

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required due to the failure of a MG-6 relay, that the overhead emergency powe l

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supply path and this MG-6 relay had never been tested, and that this path could have been inoperable since initial installation. However, the licensee's investigation of this event found that the MG-6 relay was tested during the plant pre-operational test program in February 1972. Mr. Hampton provided a summary of the presentatio ,

NRC closed the meeting by thanking DPC for an informative presentation which enhanced the NRC's understanding of the issue associated with this even I

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ENCLOSURE 3

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DUKE POWER COMPANY

OCONEE NUCLEAR SITE  :

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UNTIMELY CORRECTIVE ACTION l

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ENFORCEMENT CONFERENCE NOVEMBER 8,'1993

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AGENDA l

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INTRODUCTION J. W. H AMPTON l

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EVENT DESCRIPTION B.L.PEELE i i

i SAFETY SIGNIFICANCE B.L.PEELE  !

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CORRECTIVE ACTIONS B.L.PEELE  !

SUMMARY J. W. H AMPTON l

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INTRODUCTION  !

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APPARENT VIOLATION: 3

l Lack of Prompt Corrective Action

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Emergency Power System Found Not Adequately l Tested l

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Eventual Test Discovered inoperability

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TEST HISTORY OF THE OVERHEAD PATH l INTEGRATED TEST CONSIDERATIONS  !

SAFETY SIGNIFICANCE  !

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CORRECTIVE ACTIONS  !

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EVENT DESCRIPTION i

TEST HISTORY OF THE OVERHEAD PATH l

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Original Pre-Ops Test - Feb 1972

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Past Testing (Tech Spec) Has lleen Performed In Pieces

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Originally identified Need For Test - Sept 1990 DBD Confirmed Need To Perform Integrated Test -

Jan 1991  !

- Mod Verification Test Identified The Problem With The Auto-Closure Permissive for ACIl-2 - Sept 1992

- Integrated Test Successfully Performed - May 1993

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INTEGRATED TEST CONSIDERATIONS

- Prior to 1987: Integrated Test Could Not Have Been Performed Without Units I&2 Shutdown

- Initial Test Procedure Written - April 1991 i

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Evaluation Of Risks inherent In The Test:

Exposure To Natural Circ In Event Of Unit Trip i Timeframe For Exposure In Initial Test ,

- Current Test Presents Less Exposure - 27 Minutes ]

i Integrated Test Doesn't Take Overhead Path Out Of Service

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- Cales Were Being Performed To Reduce Challenge To Operators (Natural Cire)

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SAFETY SIGNIFICANCE

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- Overhead Path Affected From Keowee Unit 2 Only l

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Path Still Manually Available j i

• Underground Path Was Always Available- l

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LOCA/ LOOP Probability - 9.6 E-09 per year  ;

• LOOP - More Likely Scenario Licensing Basis Takes Credit For Manual Action For LOOP Core Damage Probability For Keowee _ Unit 2 Inoperability - 5.0-08 per Year Assumes No credit For Lee 100KV Line

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- DIID Process Confirms Need for Testing by L Identifying Test Acceptance Criteria (TACs) ,

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- Enhanced System Testing:

Testing Philosophy j

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. SUMMARY Original Pre-Ops Test in 1972 Verified Function f

- Could Have I3een More Aggressive .

- Actively Working On Test Procedure Since Sept 1990

- Current Testing Philosophy

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i KEOWEE EMERGENCY POWER  !>

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OCONEE POWER SYSTEM  !

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230/525KV Keewee Lee !'

Switchyarns Hydroelectric CT Generators Generators :

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