IR 05000269/1997008
| ML15118A225 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/27/1997 |
| From: | Holland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15118A224 | List: |
| References | |
| 50-269-97-08, 50-269-97-8, 50-270-97-08, 50-270-97-8, 50-287-97-08, 50-287-97-8, FACA, NUDOCS 9707220386 | |
| Download: ML15118A225 (15) | |
Text
As REG&q UNITED STATES 0G NUCLEAR REGULATORY COMMISSION o
.REGION
ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303:
Docket'Nos.:
50-269, 50-270, 50-281, 12-04 License Nos.:
DPR-38, DPR-47, DPR-55 and SNM-2503 Report Nos.:
50-269/97-08, 50-270/91-08, 50-281/91-08 Licensee:
Duke Power Company Facility:
Oconee Nuclear Station, Units 1, 2 & 3 Location:
P. 0. Box 1439 Seneca, SC 29679 Dates:
June 3 - 6, 1997 Inspector:
T. Cooper, Resident Inspector Crystal River Approved by:
50-29/9i
50-270/97-08,ie 5028/9-08'olg Maintenance Branch Division of Reactor Safety 9707220386 970627
-.5 PDR AIDOCK 05000269 Q
PDfR
EXECUTIVE SUMMARY Oconee Nuclear Station, Units 1, 2 & 3 NRC Special Inspection Report 50-269/97-08, 50-270/97-08, 50-287/97-08 The purpose of this special inspection was to determine whether ONS complied with NRC rules and regulations for those issues discussed in the Augmented Inspection Team (AIT)
Report Nos. 50-269/97-06, 50-270/97-06, and 50-287/97-06 dated May 30, 1997. The AIT report documented the NRC's special inspection of an event that occurred at ONS, Unit 3, on May 3, 1997, and resulted in degradation of the High Pressure Injection System (HPIS)
during unit cooldown. This report covers a four day period of special inspection using a resident inspector to perform a follow-up inspection of these issue Operations
An apparent violation was identified for failure to adhere to Technical Specification operability requirements for the HPIS on Unit 3, (Section 08.1).
- An apparent violation was identified with three examples of failure to follow operations procedural requirements. Examples included failure to follow administrative procedures during a Unit 3 cooldown and in response to off-normal conditions. The licensee's procedure compliance was inadequate which significantly impacted the safe operation of the unit (Section 08.2).
Maintenance
An apparent violation was identified, with multiple examples, for failure to take adequate corrective actions for conditions adverse to quality associated with compression fitting maintenance and licensee identified design vulnerabilities for the High Pressure Injection System (Section M8.1).
Engineering
An apparent violation was identified for failure to provide adequate design control measures for letdown storage tank level and pressure instrumentation, (Section E8.1).
Plant Support
An apparent violation was identified for failure to make a report within the time required by 10 CFR 50.72 (b), (Section P8.1).
REPORT DETAILS
On May 5, 1997, an AIT was established by the Regional Administrator to inspect and assess the facts surrounding an event that resulted in degradation of the ONS Unit 3 HPIS during a plant cooldown on May 3,1997. The AIT findings were documented in NRC Augmented Team Inspection Report 50-269/97-06, 50-270/97-06, and 50-287/97-06 dated May 30, 199 This special inspection was conducted to follow-up on regulatory issues identified during the performance of the AIT inspectio Summary of Plant Status Prior to the event on May 3, 1997, Unit 1 was operating at full power, Unit 2 was in cold shutdown with reactor vessel water level being maintained at approximately 17 inches, reduced inventory (top of reactor coolant loop piping), and Unit 3 was being cooled down in order to conduct inspections of high pressure injection (HPI) piping at the interface of the reactor nozzl I. Operations
Miscellaneous Operations Issues 0 Unit 3 Operational Status Relating to Technical SDecification Requirements Inspection Scope (92901)
The inspector performed a review of technical specification requirements for the HPI system on Unit 3. In addition, findings identified in NRC Augmented Team Inspection Report 50-269/97-06, 50-270/97-06, and 50-287/97-06 dated May 30, 1997, were reviewe Observations and Findings In the event on May 3, 1997, a loss of reference leg fill resulted in a loss of letdown storage tank (LDST) inventory, while LDST indicated level remained (erroneously)
normal. No LDST level alarms or off scale indications were received. This resulted in operation of two HPI pumps with inadequate net positive suction head during this event. A licensee engineering evaluation of May 5, 1997, determined that the Oconee Unit 3 HPI system would not have been able to perform its intended safety function during power operations from February 22, 1997, until the unit was shutdown on May 3, 199 Unit 3 went critical on March 6, 1997, following a refueling outage and reached 60%
full power on March 17, 1997. On March 20, 1997, during testing, the unit trippe The unit went critical and reached 60% full power on March 21, 1997, and remained above 60% full power until the unit shutdown beginning on May 2, 1997. During operation from March 6, 1997, in the event of a small break loss of coolant accident, the potential existed for hydrogen from the LDST to enter into the common suction of the HPI pumps as the borated water storage tank (BWST) volume was deplete Because the HPI pumps at Oconee had a common suction line, lacked automatic
pump protection trips, and received automatic start signals under certain operational or engineered safeguards conditions, there was a potential for common mode failure of two or more HPI. pumps whenever there was a problem with the HPI pump suction source. Two HPI pumps were needed to meet the success criteria for HPI in the Oconee accident analyses. Technical Specification 3.2.1.a(1), HIGH PRESSURE INJECTION AND CHEMICAL ADDITION SYSTEMS, requires that the reactor shall not be critical unless two high pressure injection pumps per unit are operable except as specified in 3.3. Technical Specification 3.3, EMERGENCY CORE COOLING, REACTOR BUILDING COOLING, REACTOR BUILDING SPRAY, AND LOW PRESSURE SERVICE WATER SYSTEMS, Specification 3.3.1, High Pressure Injection System, requires that when the reactor coolant system (RCS), with fuel in the core, is in a condition with temperature above 350aF and reactor power less than 60%
Full Power, two independent trains, each comprised of an HPI pump and a flow path capable of taking suction from the borated water storage tank and discharging into the reactor coolant system automatically upon Engineered Safeguards Protective System actuation shall be operable. Specification 3.3.1.a(3)(1) requires, when reactor power is greater than 60% full power, that the remaining HPI pump shall be operable. The failure to maintain an operable high pressure injection system, with the reactor above 350aF during the period of March 6 - May 2, 1997, was identified as Apparent Violation 50-287/97-08-01, Failure to Adhere to Technical Specification Operability Requirements for the HPI system on Unit Conclusion An apparent violation was identified for failure to adhere to Technical Specification operability requirements for the HPI system on Unit.2 Operator Performance During Unit 3 High Pressure Iniection System Event Inspection Scope (92901)
The inspector performed a review of operations administrative and technical procedures to assess operator performance during cooldown of Unit 3 on May 3, 1997. In addition, findings identified in NRC Augmented Team Inspection Report No /97-06, 50-270/97-06, and 50-287/97-06 dated May 30, 1997, were reviewe Observations and Findings Licensee Operations Management Procedure (OMP) 2-1, "Duties and Responsibilities of On Shift Operations Personnel," Revision 40, defined the responsibilities of Licensed Reactor Operators (RO) on the control board and the Senior Reactor Operator (SRO) in the Control Room, defined those procedural items which ROs and SROs should have committed to memory, defined a control board walkdown, and defined Operations Management non-technical expectations for shift personne Enclosure 4.4, "Responsibilities of the SRO in the Control Room", Step 4, requires
that the SRO maintain a "BIG PICTURE" overview of the operation of the unit(s) to which he/she is assigned. His/her function is to oversee the operation of the unit from the Control Room and to supervise the Reactor Operators in the performance of their dutie Enclosure 4.5, "Responsibilities of the Reactor Operators", contains a section which describes responsibilities shared by the operator at the controls (OATC) and the balance of plant operator (BPO).
Step 9 of Enclosure 4.5, shared responsibilities, requires that all ROs ensure that his/her normal or selected instruments monitoring their associated parameters are responding as expected for the existing condition. If an instrument is responding contrary to what would be expected, the redundant instrument should be checked to verify the indicatio During the period of time between 7:45 a.m. and 9:12 a.m., on May 3, 1997, none of the ROs on shift noted that the LDST level indication was not responding as expected for the reactor cooldown. During a cooldown, with the pressurizer level being maintained at a constant level, the LDST level was expected to be decreasing constantly, as was demonstrated during the previous shift, when the operations crew needed to repeatedly add water to the LDST for Unit 3 cooldown. This lack of questioning attitude displayed by the operations crew in failing to monitor reactor inventory parameters and assuring that they were responding as expected May 3, 1997, was identified as Apparent Violation 50-287/97-08-02, Failure to Follow Operations Procedures During the Unit 3 Cooldown and/or Event Response on May 3, 199 *
Step 2 of Enclosure 4.5 requires that the ROs assigned to any control room are charged with the responsibility of operating their assigned unit. They are to operate the plant with a questioning attitude, keeping nuclear safety and
"Operations Conservatism" in mind. Step 5 of this section requires that in addition to normal plant monitoring, ROs are responsible for making at least three complete control room rounds per shift, as defined in Enclosure This enclosure requires that each control room operator make a complete, detailed board walkdown soon after relieving to verify turnover items and to ensure their understanding of plant and control room equipmen *
Step 8 of Enclosure 4.5 requires that a RO shall acknowledge all alarm When an alarm is received, he/she shall take appropriate actions in response to the alarm. This action may include a comparison/check of relevant supporting parameters to validate the alarm, taking such actions as designated in the Alarm Response Guide, Emergency or Abnormal Procedures. When an alarm is received that is unexpected for the existing plant conditions or without apparent cause, he/she shall notify the Control Room SRO immediatel Interviews with the ROs and SROs on shift at the time of the May 3, 1997 event, revealed that the crew took actions for greater than 15 minutes before referring to a procedure. The failure to use procedures (i.e., alarm response guides or abnormal
procedures) was identified as an additional example of Apparent Violation 50-287/97 08-02, Failure to Follow Operations Procedures During the Unit 3 Cooldown and/or Event Response on May 3, 199 *
Enclosure 4.5 also includes a section for responsibilities of the OATC. Step 3 of this section states that the OATC shall have the responsibility for the operation of the assigned unit. Step 4 of this section requires that the OATC shall provide surveillance of operations and instrumentation monitored from the control room to ensure the safe operation of the uni Licensee Procedure OP/3/A/1 104/49, "Low Temperature Overpressure Protection (LTOP)", Revision 6, Step 2.8, states that a dedicated LTOP operator is required whenever Reactor Coolant System (RCS) temperature is < 3250F and the RCS is closed (no LTOP vent path is established) and a HPI pump is operating and capable of injecting into the RCS via 3HP-120 (RC Volume Control) and the 3HP-120 travel stop is inoperabl At 11:58 p.m., on May 2, 1997, LTOP was established with a dedicated operator, who was also the OATC. Enclosure 4.3, "Dedicated LTOP Operator Guidelines", of OP/3/A/1 104/49, Step 1.3, states that prevention of low temperature over pressurization is the only responsibility and duty of the LTOP operator. Utilizing the OATC as a dedicated operator for LTOP control was identified as an example of Apparent Violation 50-287197-08-02, Failure to Follow Operations Procedures During the Unit 3 Cooldown and/or Event Response on May 3, 199 The inspector reviewed the operational information and event sequence and noted the most significant concern was the lack of operator awareness and responsiveness to inventory balancing during the unit cooldown between 7:45 a.m., and 9:13 a.m., on May 3, 1997. Operators should have acted on the need for reactor makeup during a cooldown based on both their training and experience. The sequence of events between 4:00 p.m., and 11:00 p.m., on May 2, 1997, clearly showed the relationship between plant cooldown and inventory makeup requirements for the LDS Conclusions An apparent violation, with three examples, was identified for failure to follow procedures during unit cooldown and in response to off-normal conditions. The licensee's procedure compliance was inadequate which impacted significantly the safe operation of the uni II. Maintenance M8 Miscellaneous Maintenance Issues M Maintenance/Modification Activities Based on Past Plant or Industry Information or Events Inspection Scope (92902)
Findings identified in NRC Augmented Team Inspection Report 50-269/97-06, 50 270/97-06, and 50-287/97-06 dated May 30, 1997, were reviewed. The inspector focused on licensee procedures for conducting maintenance on components which involved compression fittings, in relation to problems which had been encountered previously at the site; and the history of design issues identified, by the licensee, as contributing factors to the May 3, 1997, even Observations and Findings COMPRESSION FITTING ISSUE The inspector reviewed LER 50-287/91-008, "Excessive Reactor Coolant Leak, Reactor Trip, and Inadvertent Protective System Actuation Result From Management Deficiencies and Equipment Failure," and NRC Information Notice 92-15, "Failure of Primary System Compression Fitting," which discussed consequences of lack of control of compression fittings in the plant. As part of the corrective actions for the 1991 event, the licensee created Procedure IP/0/A/0075/012, "INSTRUMENT LINE TUBE FITTINGS", Revision 0. Section 7.0, General Description, of IP/0/A/0075/012 stated that the procedure was used to provide guidelines for proper installation of tube fittings of safety-related and non-safety related stainless steel instrument lines ranging from 1/4 to 1 inch. Section 5.0, Step 5.6, Limits and Precautions, states: "DO NOT mix or interchange parts from other manufacturers. IF mixed fittings are identified, contact engineering for appropriate action."
In May 1996, the licensee created an additional, system-wide Procedure, Sl/0/A/5090/001,'TUBE FITTING AND TUBING INSTALLATION", Revision 0. In August 1996, an additional Procedure SI/0/A/5090/002, "Parker CPI, Swagelok, and Hi-Seal Tube Fitting Removal and Reconnection" was issued. Procedure SI/0/A/5090/002 purpose section included the statement, "Guidance for fitting initial installation and other fitting guidance (including information on process and instrument tubing, tubing caps and plugs, etc.) was provided in SI/O/A/5090/001". In October 1996, Procedure IP/0/A/0075/012 was deleted and replaced by the two SI procedure Neither procedure incorporated the prohibition of mixing parts from different manufacturer Following the event on May 3, 1997, the licensee revised SI/0/A/5090/002 to include a prohibition against mixing parts, but only in the section added to provide directions for controlling tubing cap The metallurgical analysis performed by the licensee concluded that the test tee for one of the Unit 3 LDST level instruments showed some deformation, indicative of
excessive over-tightening and the use of mismatched parts. The threads of the test tee showed signs of non-uniform stretching, indicating cross threading and excessive over-tightening. A circumferential groove 3600 around the bottom of the test tee seating surface showed that the plug had been driven into the seating surface. An "L" shaped scratch on the seating surface of the test tee was evidence that foreign material was compressed between the seating surface of the test tee and plug. The plug had several scratches varying in size and direction, also demonstrating that foreign material was compressed between seating surface of test tee and plug. The metallurgical evaluation also revealed that 65% to 75% of the test tee seating surface showed signs of wear or damage. This was attributed to foreign material being present, the cap being over-tightened, and the use of mismatched parts. These observations indicated that proper maintenance practices were not being used during removal and installation of this ca Enclosure 4.12, TUBE CAP INSTALLATION, SI/0/A/5090/001, provided guidance for the proper installation of tube caps but included a note that stated the enclosure was for guidance only and that the procedure did not have to be used as long as the technician was knowledgeable of the practices. The inspector reviewed the last three performances of the instrument calibration; WO 96042013 completed October 21, 1996, WO 96013880 completed February 22, 1997, and WO 97019404, completed on May 3, 1997. Neither SI/0/A/5090/001 nor IP//A/0075/012 were referenced by any of the work packages. Even though SI/0/A/5090/001 was only required to be used if the technician was not knowledgeable of the practices, the licensee's work planning process assumed that all technicians were knowledgeable of the practice. As shown by the metallurgical analysis, the technicians were neither consistent nor efficient in the removal and installation of the test cap and were not knowledgeable of the proper methods for installing compression fittings and should have been using the procedural guidanc Federal Regulations 10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition. The inspector determined that corrective actions for past problems associated with safety related maintenance activities was inadequate based on the above discussion. An apparent violation was identified 50-287/97-08-03, Failure to Take Adequate Corrective Actions for Conditions Adverse to Qualit '
.7 HPI SYSTEM DESIGN ISSUE The inspector reviewed a letter dated on January 31, 1983, from engineering to maintenance, discussing the possibility of a loss of HPI pump suction pressure event in reference to a proposed modification, NSM ON-1515, to add protection to the HPI on low suction events. The letter stated:
'The most likely cause for the loss of HPI suction pressure is the draining of the letdown storage tank. Such an event occurred at Oconee Unit 3 while at cold shutdown on November 14, 1979, and resulted in severe damage to HPI pump 3A... If loss of suction pressure due to low LDST level were to occur at hot system conditions, the consequences would most likely be even more severe. Not only would the operating HPI pump be damaged by the lack of positive suction head, but the standby pump would automatically start because of low reactor coolant pump seal flow or low pressurizer level. This could quickly lead to damage to the second pump."
On July 1, 1986, the proposed modification was canceled, by letter from the station manager to design engineering: That letter stated:
"...During normal operation, the proposed modification would protect a high pressure injection pump if the letdown storage tank level decreased or would provide an alarm prior to starting a high pressure injection pump should a suction flow path not exist. This is considered to be an acceptable economic risk to me at this time due to the extensive backlog and priority of modifications at Oconee..."
The inspector determined the failure to implement corrective actions for an identified design vulnerability was an additional example of Apparent Violation 50-269,270, 287/97-08-03, Failure to Take Adequate Corrective Actions for Conditions Adverse to Qualit In October 1988, the operations department initiated Station Problem Report (SPR)
2538 to provide HPI protection for low LDST level. In May 1991, in response to the SPR, a new modification NSM ON-2885 was initiated and SPR 2538 was close Between May 1991 and May 1997, scoping documents were developed for this modification, but the modification had not been installed and a schedule had not been developed for installation until after the May 3, 1997 event. The inspector again determined the failure to implement corrective actions for an identified design vulnerability was an additional example of Apparent Violation 50-269,270,2871 97-08-03, Failure to Take Adequate Corrective Actions for Conditions Adverse to Qualit Conclusion An apparent violation was identified, with three examples, for failure to take adequate corrective actions for conditions adverse to quality associated with compression fitting
maintenance and licensee identified design vulnerabilities for the high pressure injection syste Ill. Engineering E8 Miscellaneous Engineering Issues E Design Control of LDST Instrumentation Lines and Valves Inspection Scope (92902)
The inspector reviewed the findings identified in NRC Augmented Team Inspection Report 50-269/97-06, 50-270/97-06, and 50-287/97-06 dated May 30, 199 Observations and Findings After the event and plant conditions were stabilized on May 3, the licensee performed a verification check of selected valves for Units 1, 2, and 3 LDST level instrument lines to determine the position of Valve HPIIV-0086. This valve was identified as the root isolation valve for a continuous fill line for LDST level instrument reference leg lines as shown on Unit 3 Drawing No. 0-2422X-1, Revision 7. The licensee determined that the referenced valve was closed for each unit. The licensee also noted that several of the instrument root valves for the letdown storage tank were not properly labelled (tagged) as shown on the respective drawings. A resident inspector accompanied the licensee during the valve verifications on Unit 2 and identified the following matrix of labelling deficiencies:
LABEL AND POSITION DRAWING UNIT 1 UNIT 2 UNIT 3 IDENTIFICATION HPIIV-0086 HPIIV-0085 HPIIV-0085 NOT LABELED CONTINUOUS FILL LINE OPEN "
CLOSED CLOSED HPIIV-0085 HPIIV-0086 HPIIV-0086 HPIIV-0085 UPPER TAP OPEN OPEN OPEN HPIIV-0087 HPIIV-0087 HPIIV-0087 HPIIV-0087 LOWER TAP OPEN OPEN OPEN HPIIV-0095 PRESSURE PRESSURE PRESSURE PRESSURE TRANSMITTER TRANSMITTER TRANSMITTER TRANSMITTER TAP HPIIV-0086 I
OPEN
" Unit 1 had two valves in a series located in the :ontinuous fill-line. One valve was unlabelled and closed, the other valve was labelled as note The AIT discussed the observed labelling discrepancies with the licensee. In addition, the AIT requested the licensee to provide documentation as to when the LDST root valves were last verified to be in the correct position. The AIT was trying to understand how valve position verifications could be properly performed noting the high number of mislabelled valves (6 out of 12) for the level and pressure instrumentation for the three units' respective LDST The licensee had not provided design basis information or information on HPI system design changes for the continuous fill lines when this inspection ended. The inspector reviewed the HPI system design specification, ONS Specification Number OSS 0254.00-00-1001, "HPI & Purification & Deborating Demineralizers Systems,"
Revision 5. Section 33.2.1.7 of the Specification discussed the Unit 3 LDST. The specification stated, in part:
There is one Letdown Storage Tank per unit. During normal operation, the tank receives water from the reactor coolant system flowpath and the reactor coolant pumps seal return flowpath. The contents of the tank are used to supply the high pressure injection pumps with water to makeup to the reactor coolant system and to inject into the reactor coolant pumps seal cavitie Hydrogen overpressure is normally maintained on the letdown storage tank to assist in removing dissolved oxygen from the reactor coolant syste In an emergency situation (Engineered Safeguards Actuation), the suction source for the high pressure injection pumps is automatically diverted from the letdown storage tank to the borated water storage tank when engineered safeguards valves HP-24 and HP-25 (isolation valves between borated water storage tank and high pressure injection pumps suction header) open. Initially the head pressure resulting from the higher borated water storage tank elevation overcomes the combined elevation head and gas pressure of the letdown storage tank, thereby ensuring the borated water storage tank is the suction source for the high pressure injection pumps. As the accident progresses, and the borated water storage tank water inventory is reduced, the elevation head of the borated water storage tank water will decrease such that the letdown storage tank water level will begin to decrease. This occurrence is expected and creates no problem as long as the letdown storage tank water level does not decrease to the extent that the hydrogen gas expands into the high pressure injection pump suction piping. Accordingly, a "Letdown Storage Tank Pressure verses Indicated Level" curve is contained in plant operating procedures to define letdown storage tank inventory operating parameter Adherence to this curve is required to ensure that hydrogen entrainment within the high pressure injection pumps suction piping will not occur prior to entering the low pressure injection/high pressure injection piggyback mode of operation for the accident scenari The design specification indicated that the LDST water inventory must be controlled within specified pressure/level ranges using the pressure and level instrumentation provided for each LDST. Therefore, operational requirements of the LDST pressure/lievel instrumentation affected the safety-related functions of the HPI System
which prevents or mitigates the consequences of postulated accidents. The licensee previously recognized that low LDST level could lead to damage of HPI pumps as discussed in Section M8.1.b of this report. Therefore, the instrumentation should have been designated as safety-relate Federal Regulations, 10 CFR 50, Appendix B, Criterion III requires that measures be established to assure the applicable regulatory requirements and the design basis for systems, structures, and components which affect the safety-related functions of those systems that prevent or mitigate the consequences of postulated accidents are correctly translated into specifications, drawings, procedures, and instructions. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original desig The inspector determined that the lack of design control for the LDST instrumentation and the incorrect identification of valves in the LDST level and pressure instrument lines was an Apparent Violation of 10 CFR 50, Appendix B, Criterion III, 50-269,270, 287/97-08-04, Failure to Provide Adequate Design Control Measures for Letdown Storage Tank Level and Pressure Instrumentatio Conclusion An apparent violation was identified for failure to provide adequate design control measures for letdown storage tank level and pressure instrumentatio IV. Plant Support P8 Miscellaneous Emergency Preparedness Issues P Design Control of LDST Instrumentation Lines and Valves Inspection Scope (92904)
The inspector reviewed the findings identified in NRC Augmented Team Inspection Report 50-269/97-06, 50-270/97-06, and 50-287/97-06 dated May 30, 199 Observations and Findings On May 6, 1997, at 6:56 p.m., the licensee submitted a facsimile reporting that a licensee engineering evaluation of the inaccurate LDST level indication determined at 3:15 p.m., on May 5, 1997, that the ONS Unit 3 HPI system would not have been able to perform its intended safety function (mitigate a small break loss of coolant accident)
during power operating conditions from February 22, 1997, until May 3, 1997. The AIT considered this determination was either immediately reportable under 10 CFR 50.72 (c)(2)(i) or (iii), or four-hour reportable under 10 CFR 50.72 (b)(2)(i) or (iii)(D).
The inspector reviewed the licensee's facsimile report and compared it to the requirements of 10 CFR 50.72. Federal Regulations 10 CFR 50.72 (a) requires, in part each licensee shall notify the NRC Operations Center via the Emergency
Notification Center of the declaration of any of the Emergency Classes specified in the licensee's approved Emergency Plan not later than one hour after the time the licensee declares one of the Emergency Classes. Federal Regulations 10 CFR 50.72 (c)(2) requires, in part, with respect to telephone notifications made under paragraph (a) of this section, each licensee, shall during the course of the event immediately report the results of ensuing evaluations or assessments of plant conditions and information related to plant behavior that is not understood. Federal Regulations 10 CFR 50.72 (b)(2) requires, in part, If not reported under paragraph (a) of this section, the licensee shall notify the NRC as soon as practicable and in all cases, within four hours of the occurrence of any event, found while the reactor is shut down, that, had it been found while the reactor was in operation would have resulted in the nuclear power plant, including its principal safety barriers, being seriously degraded or being in an unanalyzed condition that significantly compromises plant safety; or, any event or condition that alone could have prevented the fulfillment of the safety functions of systems that are needed to mitigate the consequences of an acciden The inspector evaluated the reportability requirements against plant conditions when the licensee engineering evaluation was made. At that time, Unit 3 was cooled down below 2000F. The inspector also noted that the licensee terminated the Unusual Event at 7:46 p.m., on May 5, 1997. The inspector concluded, based on plant conditions, that the licensee did not consider the reportability requirements of the engineering evaluation met the requirements of 10 CFR 50.72 (c)(2)(i) or (iii), or they would have immediately (within one hour) reported the results of the engineering evaluation on May 5. Based on the licensee's wording of the engineering evaluation, that the ONS Unit 3 HPI system would not have been able to perform its intended safety function (mitigate a small break loss of coolant accident) during power operating conditions, the inspector determined that the licensee should have reported this condition within four hours of the engineering evaluation determination (3:15 on May 5, 1997). As stated above, the licensee did not make the report until May 6, 1997, at 6:56 p.m. The inspector identified an Apparent Violation of 10 CFR 50.72 (b), 50-287/97-08-05, Failure to Make a Report Within the Time Required by 10 CFR 50.72 (b). Conclusion An apparent violation was identified for failure to make a report within the time required by 10 CFR 50.72 (b).
V. Manaqement Meetinqs X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 6, 1997. The licensee acknowledged the findings presented with dissenting comments. The licensee took exception to the compression fitting issue apparent violation in Section M8.1 and the apparent violation Section E8.1 of this
.
repor PARTIAL LIST OF PERSONS CONTACTED Licensee
- E. Burchfield, Regulatory Compliance Manager
- T. Curtis, Operations Manager
- J. Davis, Engineering Manager J. Hampton, Vice President, ONS
- D. Hubbard, Maintenance Superintendent B. Peele, Station Manager J. Smith, Regulatory Compliance NRC D. Billings, Resident Inspector
- E. Girard, Reactor Inspector
- W. Holland, Chief, Maintenance Branch
- N. Salgado, Resident Inspector
- M. Scott, Senior Resident Inspector
- Attended exit meeting on June 6, 1997
INSPECTION PROCEDURES USED 92901 Followup - Plant Operations 92902 Followup - Maintenance 92903 Followup - Engineering 92904 Followup - Plant Support ITEMS OPENED 50-287/97-08-01 EEl Failure to Adhere to Technical Specification Operability Requirements for the HPI system on Unit 3 (Section 08.1).
50-287/97-08-02 EEI Failure to Follow Operations Procedures During the Unit 3 Cooldown and/or Event Response on May 3, 1997, (Section 08.2).
50-269,270,287/97-08-03 EEl Failure to Take Adequate Corrective Actions for Conditions Adverse to Quality (Section M8.1).
50-269,270,287/97-08-04 EEl Failure to Provide Adequate Design Control Measures for Letdown Storage Tank Level and Pressure Instrumentation (Section E8.1).
50-287/97-08-05 EEI Failure to Make a Report Within the Time Required by 10 CFR 50.72 (b), (Section P8.1).
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Augmented.Inspection Team BPO
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Balance of Plant Operator BWST
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Borated Water Storage Tank CFR
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Code of Federal Regulations DPC
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Duke Power Company EEI
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Escalated Enforcement Issue HPI
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High Pressure Injection HPIS
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High Pressure Injection System LDST -
Letdown Storage Tank LER
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Licensee Event Report LTOP -
Low Temperature/Over-pressure NRC -
Nuclear Regulatory Commission OATC -
Operator At The Controls OMP -
Operations Management Procedure ONS
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Oconee Nuclear Station RC
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-
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Reactor Operator SPR
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Station Problem Report SRO -
Senior Reactor Operator WO
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Work Order