IR 05000269/1998015
| ML15261A392 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/12/1998 |
| From: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mccollum W DUKE POWER CO. |
| Shared Package | |
| ML15261A393 | List: |
| References | |
| 50-269-98-15, 50-270-98-15, 50-287-98-15, NUDOCS 9902240349 | |
| Download: ML15261A392 (7) | |
Text
February 12, 1998
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-269/98-15, 50-270/98-15, 50-287/98-15)
Dear Mr. McCollum:
This refers to the inspection conducted on November 2-6, November 16-20, and December 11, 1998, at Duke Energy Corporation's (DEC) Oconee facility. The purpose of the inspection was to review design basis issues associated with the emergency feedwater system.
The results of the inspection were discussed with DEC at an exit meeting on December 11, 1998, and formally transmitted to you by letter dated December 23, 1998. An open, predecisional enforcement conference was conducted in the Region II office on January 26, 1999, with you and members of your staff to discuss the apparent violations, the root causes, and corrective actions to preclude recurrence. A list of conference attendees, copies of the Nuclear Regulatory Commission's (NRC) slides, and DEC's presentation materials are enclosed.
Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that two violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding them are described in detail in the subject inspection report.
Violation A involves the adequacy of Procedure IP/O/A/0050/001, "Procedure to Provide Emergency Power to an HPI Pump Motor from the ASW Switchgear," to manually connect temporary cables to supply emergency power to a high pressure injection (HPI) pump from the auxiliary service water (ASW) switchgear. DEC used this procedure to mitigate an auxiliary feedwater or main steam line break. The procedure required first racking out the electrical breaker to the HPI pump at the safety-related 4160-volt switchgear. However, in the event of an auxiliary steam or main feedwater line break, the safety-related 4160-volt switchgear could be inaccessible because it could be in a steam environment. As you stated at the conference, this procedural deficiency would not likely have affected the ability of plant operators to safely shutdown the plant in the event of a high energy line break, because your recent analysis indicated that HPI would not be required for up to eight hours, as long as secondary cooling was available to the steam generators. Plant personnel would have had sufficient time to complete procedural revisions to supply emergency power to an HPI pump in less than eight hours. Your corrective actions for this violation included a procedural revision and walkdowns to validate procedural steps and a high energy line break analysis to verify substantial time existed to establish HPI flow.
9902240349 990212 PDR ADOCK 05000269 Q
Violation B involves the failure to conduct an adequate written safety evaluation in accordance with 10 CFR 50.59 when procedure IP/O/A/0050/001 was revised in November 1998.
Specifically, the procedure was revised to add steps to go to the blockhouse and isolate electrical power to the 4160 volt switchgear, if that switchgear was inaccessible. The added steps included pulling two fuses and racking out six breakers in the blockhouse, which could take plant personnel additional time to accomplish. Your staff failed to properly evaluate the effects of the additional time needed to accomplish this task, which exceeded the 30 minute time described in the UFSAR, and thus, represented a potential adverse effect on the ability to mitigate an auxiliary steam line or main feedwater line break in the turbine building. As you stated at the conference, this violation occurred because your staff conducted a screening evaluation of the procedural change which failed to recognize the UFSAR reference, and therefore, the need to conduct a safety evaluation was not recognized as required by 10 CFR 50.59. By facsimile correspondence of February 3, 1999 (Enclosure 5), DEC provided the NRC the results of your 10 CFR 50.59 evaluation. Your evaluation concluded that this change increased the time to repower an HPI pump from 30 minutes to 38 minutes, but did not involve an unreviewed safety question. Your corrective actions for this violation included field walkdowns to validate the procedural change, and the performance of simulator validations of high energy line break mitigation strategy.
Two additional examples of an apparent violation of 10 CFR 50.59 were discussed at the conference, and are documented in the, inspection report. These apparent violations involved procedural changes in 1981 and 1985 to an emergency operating procedure to supply electrical power to an HPI pump. At the conference, DEC denied the violations. Based on the information DEC provided at the conference, the NRC has determined that, although documentation was lacking regarding the basis for the safety analysis conclusions for the changes, these two issues did not involve unreviewed safety questions, and therefore, the issues were not violations of 10 CFR 50.59. We will adjust our records to reflect this conclusion accordingly.
We agree with DEC's conclusions presented at the conference that the potential safety consequences of Violations A and B were low, for reasons as previously discussed and at the conference. For Violation A, we agree with DEC's position presented at the conference that the Oconee design basis did not require HPI to be repowered within 30 minutes or to be started within 35 minutes for mitigation of a high energy line break. DEC's design basis provided for emergency feedwater to be supplied to the steam generators within 15 minutes for mitigation of this event. DEC's design basis also stated that the operator can then begin plant cooldown after manually repowering an HPI pump, which can be accomplished within 30 minutes. The original design basis analysis did not include the potential for an increase in reactor coolant pump seal leakage during this event, which would result in a need for HPI to mitigate the event.
However, DEC's recent analysis, which included a potential increase in reactor coolant pump seal leakage, indicated that HPI would not be required for up to eight hours. However; prompt repowering of the HPI pump is important because of the vulnerability of the reactor coolant system (RCS) to any loss of inventory with no means of RCS injection. For Violation B, we agree with your recent 10 CFR 50.59 evaluation which concluded that increasing the time to repower the HPI pump from 30 to 38 minutes did not involve an unreviewed safety question.
Therefore, the NRC has concluded that Violations A and B, both of which were NRC identified, should be classified separately as Severity Level IV violations.
The NRC has concluded that information regarding the reasons for Violations A and B, the corrective actions taken and planned to correct the violations and to prevent recurrence and the date when full compliance will be achieved are adequately addressed on the docket as discussed in this letter and in NRC Inspection Report Nos. 50-269/98-15, 50-270/98-15, 50-287/98-15. Therefore, you are not required to submit a response to this letter unless the description therein does not accurately reflect your corrective actions or your position regarding these violations. However, if you choose to provide additional information, you should follow the instructions provided in the enclosed Notice.
In reviewing your facsimile correspondence of February 3, 1999, documenting the results of your 10 CFR 50.59 evaluation for changes to procedure IP/O/A/0050/001, the NRC noted DEC's conclusion that a change to the UFSAR was not required. However, based on a telephone conversation between Mr. Victor McCree, Deputy Director, Division of Reactor Safety, Region II, and Mr. Mano Nazar, Oconee Engineering Manager, on February 11, 1999, and our review of Enclosure 4, it is our understanding that you do plan to change the UFSAR to specify current licensing basis requirements for the time to repower the HPI pumps from the ASW switchgear. This enforcement action does not constitute approval of any change in the licensing basis of the facility. If your understanding of this matter differs, please contact Mr. McCree at 404-562-4600.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if you choose to provide one) will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
Sincerely, Original Signed by Jon R.Johnson Luis A. Reyes Regional Administrator Docket Nos. 50-269, 50-270, 50-287 License Nos. DPR-38, DPR-47, DPR-55 Enclosures:
1. Notice of Violation 2. List of Attendees 3. NRC Slides 4. Licensee Material 5. DEC 50.59 Evaluation
cc w/encls:
Manager, LIS Mr. J. E. Burchfield NUS Corporation Compliance 2650 McCormick Drive Duke Energy Corporation Clearwater, FL 34619-1035 P. O. Box 1439 Seneca, SC 29679 Mr. G. A. Copp Licensing - ECOSO.
Mr. Paul R. Newton Duke Energy Corporation Legal Department (PB05E)
P. 0. Box 1006 Duke Energy Corporation Charlotte, NC 28201-1006 422 South Church Street Charlotte, NC 28242-0001 Assistant Attorney General N. C. Department of Justice Executive Director P. 0. Box 629 Public Staff - NCUC Raleigh, NC 27602 P. 0. Box 29520 Raleigh, NC 27626-0520 Mr. Robert B. Borsum Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Mr. J. Michael McGarry, III, Esq.
Winston and Strawn 1400 L Street, NW Washington, D. C. 20005 Director Division of Radiation Protection N. C. Department of Environmental Health & Natural Resources P. O. Box 27687 Raleigh, NC 27611-7687 Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 County Supervisor of Oconee County.
Walhalla, SC 29621
Distribution w/encls:
WTravers, EDO FMiraglia, DEDO MKnapp, DEDE LChandler, OGC JGoldberg, OGC EJulian, SECY BKeeling, CA Enforcement Coordinators RI, RIll, RIV JLieberman, OE GCaputo, 01 WBeecher, OPA HBeII, OIG CEvans, RII ABoland, Rll MTschiltz, OEDO KCIark, RII MScott, RIl RCarroll, RII COgle, Ril BMallett, Rll
.VMcCree, RiI RSchin, RiI KLandis, RIl DLaBarge, NRR HBerkow, NRR RTrojanowski, Rll OE:EA File (BSummers, OE) (2 letterhead copies)
PUBLIC
- FOR PREVIOUS CONCURRENCE SEE ATTACHED COPY SEND TO PUBLIC DOCUMENT ROOM?
YES OFFICE RIl:DRS RI:EICS RII:DRP ORA Signature II______
NAME BWallett*
ABoland*
LPlisco*
JJohnson'
DATE
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YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:S:\\DRS\\FINALEA.WPD
Distribution w/encls:
WTravers, EDO FMiraglia, DED V
MKnapp, DEDE LChandler, OGC JGoldberg, OGC EJulian, SECY BKeeling, CA Enforcement Coordinators RI, RII, RIV JLieberman, OE GCaputo, 01 WBeecher, OPA HBell, OIG CEvans, RI1 ABoland, RIl MTschiltz, OEDO KCIark, Rll MScott, RII RCarroll, Rll COgle, RII BMallett, Rll VMcCree, RII RSchin, RI!
KLandis, Rll DLaBarge, NRR HBerkow, NRR RTrojanowski, RI!
RII Docket Files, DNMS OE:EA File (BSummers, OE) (2 letterhead copies)
PUBLIC SEND TO PUBLIC DOCUMENT RO
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YES OFFICE RI:DRS RII:DRP ORA_
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Signature i
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JJ son DATE
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YES NO NO jYES NO YES NO YES NO YES NO OFFICIAL RECORD COP DOCUMENT NAME:H:\\1980PEN.ENF\\985520CO.DIR\\FINALEA.WPD