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Category:Inspection Report
MONTHYEARIR 05000269/20243012024-01-11011 January 2024 Notification of Licensed Operator Initial Examination 05000269/2024301, 05000270/2024301, and 05000287/2024301 ML23331A7982023-12-14014 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report (01R32) IR 05000269/20230032023-11-14014 November 2023 Integrated Inspection Report 05000269/2023003, 05000270/2023003, and 05000287/2023003; and IR 07200040/2023001; and Exercise of Enforcement Discretion IR 05000269/20230052023-08-25025 August 2023 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2 and 3 (Report 05000269/2023005, 05000270/2023005, and 05000287/2023005) IR 05000269/20230112023-08-25025 August 2023 Comprehensive Engineering Team Inspection Report 05000269/2023011 and 05000270/2023011 and 05000287/2023011 IR 05000269/20230022023-07-28028 July 2023 Integrated Inspection Report 05000269/2023002, 05000270/2023002 and 05000287/2023002 IR 05000269/20230102023-07-19019 July 2023 Biennial Problem Identification and Resolution Inspection Report 05000269/2023010 and 05000270/2023010 and 05000287/2023010 and Notice of Violation RA-23-0128, Refuel 32 (O1R32) Steam Generator Tube Inspection Report2023-05-18018 May 2023 Refuel 32 (O1R32) Steam Generator Tube Inspection Report IR 05000269/20230012023-05-12012 May 2023 Integrated Inspection Report 05000269/2023001 and 05000270/2023001 and 05000287/2023001 IR 05000269/20234012023-04-14014 April 2023 Security Baseline Inspection Report 05000269 2023401 and 05000270 2023401 and 05000287 2023401 IR 05000269/20220062023-03-0101 March 2023 Annual Assessment Letter for Oconee Nuclear Nuclear Station, Units 1, 2 and 3 (NRC Inspection Report 05000269/2022006, 05000270/2022006, and 05000287/2022006) ML23037A0772023-02-0606 February 2023 402 Cyber Notification and RFI Letter Final IR 05000269/20220042023-02-0202 February 2023 Integrated Inspection Report 05000269 2022004 and 05000270/2022004 and 05000287/2022004 IR 05000269/20220032022-11-0707 November 2022 Integrated Inspection Station 05000269/2022003 and 05000270/2022003 and 05000287/2022003 IR 05000269/20220112022-09-26026 September 2022 NRC Inspection Report 05000269/2022011 and 05000270/2022011 and 05000287/2022011 IR 05000269/20220052022-08-26026 August 2022 Updated Inspection Plan for Oconee Nuclear Station, Units 1, 2 and 3 - NRC Inspection Report 05000269/2022005, 05000270/2022005, and 05000287/2022005 IR 05000269/20224012022-08-26026 August 2022 Material Control and Accounting Program Inspection Report 05000269/2022401 and 05000270/2022401 and 05000287/2022401 (OUO Removed) IR 05000270/20220022022-07-29029 July 2022 Integrated Inspection Report 05000269/ 2022002 and 05000270/2022002 and 05000287/2022002 IR 05000269/20220102022-06-30030 June 2022 Triennial Fire Protection Inspection Report 05000269/2022010 and 05000270/2022010 and 05000287/2022010 IR 05000269/20224032022-05-0404 May 2022 Security Baseline Target Set Inspection Report 05000269/2022403 and 05000270/2022403 and 05000287/2022403 IR 05000269/20220012022-05-0404 May 2022 Integrated Inspection Report 05000269/2022001, 05000270/2022001 and 05000287/2022001 IR 05000269/20224042022-04-27027 April 2022 Security Baseline Inspection Report 05000269/2022404 and 05000270/2022404 and 05000287/2022404 IR 05000269/20223012022-03-0707 March 2022 Notification of Licensed Operator Initial Examination 05000269/2022301, 05000270/2022301 and 05000287/2022301 IR 05000269/20210062022-03-0202 March 2022 Annual Assessment Letter for Oconee Nuclear Station, Units 1, 2, and 3 (Report 05000269/2021006, 05000270/2021006, and 05000287/2021006) IR 05000269/20220122022-02-24024 February 2022 Safety Conscious Work Environment Issue of Concern Followup Report 05000269/2022012 and 05000270/2022012 and 05000287/2022012 IR 05000269/20224022022-02-16016 February 2022 Security Baseline Inspection Report 05000269/2022402 and 05000270/2022402 and 05000287/2022402 IR 05000269/20210042022-02-14014 February 2022 Integrated Inspection Report 05000269/2021004 and 05000270/2021004 and 05000287/2021004 and Apparent Violation IR 05000269/20210032021-10-28028 October 2021 Integrated Inspection Report 05000269/2021003 and 05000270/2021003 and 05000287/2021003 IR 05000269/20210102021-09-17017 September 2021 Design Basis Assurance Inspection (Programs) Inspection Report 05000269/2021010 and 05000270/2021010 and 05000287/2021010 IR 05000269/20210052021-08-26026 August 2021 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2, and 3 (NRC Inspection Report 05000269/2021005, 05000270/2021005, and 05000287/2021005) IR 07200004/20210012021-08-26026 August 2021 Operation of an Independent Spent Fuel Storage Installation Report 07200004/2021001 IR 05000269/20210022021-08-0404 August 2021 Integrated Inspection Report 05000269/2021002 and 05000270/2021002 and 05000287/2021002 IR 05000269/20213012021-07-0606 July 2021 NRC Operator License Examination Report 05000269/2021301, 05000270/2021301, and 05000287/2021301 IR 05000269/20210112021-06-0202 June 2021 Biennial Problem Identification and Resolution Inspection Report 05000269/2021011 and 05000270/2021011 and 05000287/2021011 IR 05000269/20210012021-04-23023 April 2021 Integrated Inspection Report 05000269/2021001 and 05000270/2021001 and 05000287/2021001 IR 05000269/20214012021-04-22022 April 2021 Security Baseline Inspection Report 05000269/2021401, 05000270/2021401 and 05000287/2021401 (U) IR 05000269/20200062021-03-0303 March 2021 Annual Assessment Letter for Oconee Nuclear Station Units 1, 2, & 3 NRC Inspection Report 05000269/2020006, 05000270/2020006, & 05000287/2020006 IR 05000269/20200042021-02-22022 February 2021 Reissue- Oconee Nuclear Station Integrated Inspection Report 05000269/2020004, 05000270/2020004, 05000287/2020004 ML21036A0012021-02-0404 February 2021 Integrated Inspection Report 05000269/2020004 and 05000270/2020004 and 05000287/2020004 IR 05000269/20200102021-01-22022 January 2021 NRC Design Bases Assurance Inspection (Team) Report 05000269/2020010 and 05000270/2020010 and 05000287/2020010 and Notice of Violation IR 05000269/20204012020-11-13013 November 2020 Security Baseline Inspection Report 05000269/2020401 and 05000270/2020401 and 05000287/2020401 IR 05000269/20200032020-11-0404 November 2020 Integrated Inspection Report 05000269/2020003, 05000270/2020003, 05000287/2020003, and 07200004/2020002 IR 05000269/20204202020-10-15015 October 2020 Security Inspection Report 05000269/2020420, 05000270/2020420 and 05000287/2020420 IR 05000269/20200052020-08-17017 August 2020 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2, and 3 (NRC Inspection Report 05000269/2020005, 05000270/2020005, and 05000287/2020005) IR 05000269/20200022020-08-11011 August 2020 Integrated Inspection Report 05000269/2020002 and 05000270/2020002 and 05000287/2020002 ML20192A3212020-07-13013 July 2020 Review of the Fall 2019 Steam Generator Tube Inspection Report IR 05000269/20203012020-06-0909 June 2020 Operator Licensing Operating Test Approval 05000269/2020301, 05000270/2020301 and 05000287/2020301 IR 05000269/20000082020-05-12012 May 2020 Final ASP Analysis - Oconee 1, 2, and 3 (IR 050002692000008) IR 05000287/20020152020-05-12012 May 2020 Final ASP Analysis - Oconee 3 (IR 050002872002015) IR 05000269/20000042020-05-12012 May 2020 Final ASP Analysis - Oconee 1, 2, and 3 (IR 050002692000004) 2024-01-11
[Table view] Category:Letter
MONTHYEARML23304A1422024-02-0101 February 2024 Issuance of Environmental Scoping Summary Report Associated with the U.S. Nuclear Regulatory Commission Staffs Review of the Oconee Nuclear Station, Units 1, 2, & 3, Subsequent License Renewal Application ML24005A2492024-01-24024 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting) IR 05000269/20243012024-01-11011 January 2024 Notification of Licensed Operator Initial Examination 05000269/2024301, 05000270/2024301, and 05000287/2024301 ML23331A7982023-12-14014 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report (01R32) ML23262A9672023-12-13013 December 2023 Alternative to Use RR-22-0174, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section XI, Division 1 ML23317A3462023-11-14014 November 2023 Duke Fleet - Correction Letter to License Amendment Nos. 312 & 340 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230032023-11-14014 November 2023 Integrated Inspection Report 05000269/2023003, 05000270/2023003, and 05000287/2023003; and IR 07200040/2023001; and Exercise of Enforcement Discretion ML23219A1402023-10-10010 October 2023 Audit Report Proposed Alternative to Use ASME Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems XI, Division 1 ML23269A1102023-10-0606 October 2023 Letter to Steven Snider-Revised Schedule for the Environmental Review of the Oconee Nuclear Station, Unit 1, 2, and 3, Subsequent License Renewal Application ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230112023-08-25025 August 2023 Comprehensive Engineering Team Inspection Report 05000269/2023011 and 05000270/2023011 and 05000287/2023011 IR 05000269/20230052023-08-25025 August 2023 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2 and 3 (Report 05000269/2023005, 05000270/2023005, and 05000287/2023005) IR 05000269/20230022023-07-28028 July 2023 Integrated Inspection Report 05000269/2023002, 05000270/2023002 and 05000287/2023002 ML23208A0972023-07-27027 July 2023 Subsequent License Renewal List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected IR 05000269/20230102023-07-19019 July 2023 Biennial Problem Identification and Resolution Inspection Report 05000269/2023010 and 05000270/2023010 and 05000287/2023010 and Notice of Violation ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 ML23132A2392023-06-0101 June 2023 Summary of the April 2023 Remote Environmental Audit Related to the Review of the Subsequent License Renewal Application ML23144A0192023-05-25025 May 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report (O3R31) IR 05000269/20230012023-05-12012 May 2023 Integrated Inspection Report 05000269/2023001 and 05000270/2023001 and 05000287/2023001 ML23121A0552023-05-0303 May 2023 Acknowledgement of Withdrawal Request to Revise TS 5.5.2 Containment Leakage Rate Testing Program ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML23117A0432023-04-20020 April 2023 Framatome, Inc., Part 21 Notification of Existence of a Defect ML23075A0732023-04-0505 April 2023 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application Supplement (EPID Number L-2021-SLE-0002) ML23045A1332023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Achp Letter ML23045A1402023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Shpo Letter ML23045A1432023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - State Tribe Letter ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML23069A1102023-03-10010 March 2023 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML23061A1772023-03-0303 March 2023 Notification of Oconee Nuclear Station Comprehensive Engineering Team Inspection - NRC Inspection Report 05000269/2023011, 05000270/2023011 and 05000287/2023011 IR 05000269/20220062023-03-0101 March 2023 Annual Assessment Letter for Oconee Nuclear Nuclear Station, Units 1, 2 and 3 (NRC Inspection Report 05000269/2022006, 05000270/2022006, and 05000287/2022006) ML23039A1632023-02-0808 February 2023 Requalification Program Inspection ML23037A0772023-02-0606 February 2023 402 Cyber Notification and RFI Letter Final IR 05000269/20220042023-02-0202 February 2023 Integrated Inspection Report 05000269 2022004 and 05000270/2022004 and 05000287/2022004 ML22363A3942023-01-12012 January 2023 Subsequent License Renewal Environmental Report Supplement - Proposed Review Schedule ML22356A0512022-12-14014 December 2022 Curtiss-Wright Nuclear Division, Letter Regarding Potential Efect in a Configuration of the 11/2 Inch Quick Disconnect Connector Cable Assemblies Supplied to Duke Energy (See Attached Spreadsheet) for a Total of 460 of Connectors Only Suppl ML22321A0492022-12-0808 December 2022 Issuance of Amendment Nos. 426, 428 and 427, Additional Mode Change Limitations Applicable to the Adoption of TSTF- 359, Revision 9, Increase Flexibility in Mode Restraints ML22329A1042022-11-29029 November 2022 Review of the Fall 2021 Steam Generator Tube Inspection Report ML22321A1582022-11-22022 November 2022 Summary of Conference Call Regarding the Fall 2022 Steam Generator Tube Inspections ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 IR 05000269/20220032022-11-0707 November 2022 Integrated Inspection Station 05000269/2022003 and 05000270/2022003 and 05000287/2022003 ML22301A0112022-11-0303 November 2022 Request for Withholding Information from Public Disclosure Regarding the SLR Application - September 2, 2022 ML22298A0752022-10-27027 October 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application Duke Energy Letter Dated July 25, 2022 ML22264A0322022-10-20020 October 2022 _Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application - Duke Energy Letter Dated July 8, 2022 IR 05000269/20220112022-09-26026 September 2022 NRC Inspection Report 05000269/2022011 and 05000270/2022011 and 05000287/2022011 ML22258A0302022-09-15015 September 2022 Evacuation Time Estimate Reports ML22222A0072022-09-14014 September 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application ML22231B1362022-09-0101 September 2022 Review of the Draft Environmental Assessment and Findings of No Significant Impact for Catawba Nuclear Station, H.B. Robinson Steam Electric Plant, and Oconee Nuclear Station Independent Spent Fuel Storage Installation Decommissioning Fundi ML22234A0062022-08-30030 August 2022 SLRA - Closed Public Meeting Summary - August 18, 2022 2024-02-01
[Table view] |
Inspection Report - Oconee - 2005012 |
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Text
ber 19, 2005
SUBJECT:
OCONEE NUCLEAR STATION - NRC INSPECTION REPORT NOS.
05000269/2005012, 05000270/2005012, AND 05000287/2005012; PRELIMINARY GREATER THAN GREEN FINDING
Dear Mr. Jones:
This letter and the enclosed supporting documentation discuss a finding that appears to have greater than very low safety significance. As described in Section 02.03B.(9) of NRC Supplemental Inspection Report No. 05000269,270,287/2002007, issued on May 31, 2002, Unresolved Item (URI)05000287/2002007-02 was identified regarding the north wall of the Oconee Unit 3 main control room not being designed and constructed to withstand the tornado effects (wind force, missiles, and differential pressure) described in the Updated Final Safety Analysis Report (UFSAR). At the time, Duke Energy Corporation (DEC) considered the Oconee Unit 3 control room north wall to be operable but non-conforming with the UFSAR.
Specifically, DEC determined that (1) the wall did not have sufficient energy absorption capacity to stop certain missiles at design wind speed and (2) the calculated capacity of the wall, when considering the combined effects of wind speed and differential pressure, would be exceeded.
As the supporting evaluation indicated that missile effects were probabilistically negligible, submittal of a license amendment request (LAR) was planned to change the licensing basis for missiles. Additionally, a design modification was planned to resolve the wind loading issue.
Subsequently, as described in Section 4OA2.2b.(1) of NRC Inspection Report No.
05000269,270, 287/2004003, issued on July 23, 2004, the NRC identified that in lieu of a LAR, the 10 CFR 50.59 process was inappropriately used to change the Unit 3 control room tornado missile licensing basis in the UFSAR. This use of 10 CFR 50.59 was an attempted corrective action. In general, the inappropriate change resulted in more than a minimal increase in occurrence of a malfunction of the Unit 3 control room by (1) reflecting the use of the TORMIS probabilistic risk methodology to determine that additional physical protection from tornado generated missiles was not necessary for the Oconee Unit 3 control room north wall and (2)
indicating that specified missile design requirements were no longer applicable to the Unit 3 control room. Pending risk analysis, this use of the 10 CFR 50.59 process to resolve the Unit 3 control room tornado licensing issue was identified as URI 05000287/2004003-02. The associated UFSAR change was subsequently withdrawn, but as of December 2005, a LAR had
DEC 2 not been submitted. In addition, the planned design modification to resolve the wind loading concern was deferred without a projected completion date. Consequently, it has been concluded that adequate corrective actions have not been taken to promptly resolve the tornado-related concerns with the Unit 3 north control room wall.
Absent the aforementioned design modification, DECs Unit 3 north control room wall operability evaluation credited partial failure of the wall in reducing the peak differential pressure across the wall. Given such a failure, a spectrum of missiles with greater probabilities than the design basis missiles would have the potential to penetrate the degraded wall and damage structures, systems, and components necessary for safe shutdown. Accordingly, there is a lack of reasonable assurance that the Unit 3 control room, and therefore its related safety functions, would be available upon being subjected to design tornado effects.
This finding was assessed based on the best available information, including influential assumptions, using the applicable Significance Determination Process (SDP) and was preliminarily determined to be a Greater Than Green Finding. Enclosed is a summary of the SDP Phase 3 analysis. The finding has a potentially greater than very low safety significance because, during a design basis tornado, the Unit 3 control room may not physically be protected. Loss of the control room boundary during a tornado could lead to missile debris and water intrusion, which in turn could cause a trip as well as adversely affect the control of multiple safety systems/functions. Furthermore, the response of control room operators and the damage control teams stationed in the Unit 3 control room could be adversely affected.
The NRC staff conducted a qualitative evaluation of the risk based on information previously made available from DEC. The staff did not conduct a refined risk analysis. Other related risk factors (e.g., resultant effects on control room functions, safety systems, operator response, etc.) were not considered in addressing the significance of this finding.
The finding is also an apparent violation (AV) of 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Action, for failure to promptly identify and correct this significant condition adverse to quality. Specifically, since being initially identified in 1996, DEC has not performed any plant modifications or taken an appropriate licensing action to resolve the long-standing discrepancy between the Unit 3 control room and its tornado licensing basis specified in UFSAR Section 3.5.1.3 and UFSAR Table 3-23. This includes the related UFSAR change in December 2003, which improperly used the 10 CFR 50.59 process to effectively negate the Unit 3 control room tornado design criteria contained in UFSAR Section 3.5.1.3 and Table 3-23. This apparent violation (identified as AV 05000287/2005012-01: Failure to Promptly Identify and Correct a Long-Standing Discrepancy Between the Unit 3 Control Room and its Tornado Licensing Basis Specified in the UFSAR) is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy). Accordingly, for administrative purposes, URI 05000287/
2002007-02 and 05000287/2004003-02 are considered closed. The current Enforcement Policy is included on the NRCs website at http://www.nrc.gov/reading-rm/adams.html.
In accordance with Inspection Manual Chapter (IMC) 0609, we intend to complete our evaluation using the best available information and issue our final determination of safety significance within 90 days of this letter. The significance determination process encourages an open dialog between the staff and the licensee; however, the dialogue should not impact the timeliness of the staffs final determination. Before we make a final decision on this matter, we are providing you an opportunity to: (1) present to the NRC your perspectives on the facts and
DEC 3 assumptions, used by the NRC to arrive at the finding and its significance, at a Regulatory Conference or (2) submit your position on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held within 30 days of the receipt of this letter and we encourage you to submit supporting documentation at least 1 week prior to the conference in an effort to make the conference more efficient and effective. If a Regulatory Conference is held, it will be open for public observation. The NRC will also issue a press release to announce the conference. If you decide to submit only a written response, such a submittal should be sent to the NRC within 30 days of the receipt of this letter.
Please contact Mr. Michael Ernstes at (404) 562-4540 within 10 business days of the date of your receipt of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decisions and you will be advised by separate correspondence of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, a Notice of Violation is not being issued at this time. In addition, please be advised that the number and characterization of the apparent violation may change as a result of further NRC review.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Charles Casto, Director Division of Reactor Projects Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55 Enclosure: SDP Phase 3 Summary
DEC 4 cc w/encl:
B. G. Davenport Lyle Graber, LIS Compliance Manager (ONS) NUS Corporation Duke Energy Corporation Electronic Mail Distribution Electronic Mail Distribution R. L. Gill, Jr., Manager Lisa Vaughn Nuclear Regulatory Issues Associate General Counsel and Industry Affairs Duke Energy Corporation Duke Energy Corporation 526 South Church Street 526 S. Church Street Mail Code EC 07H Charlotte, NC 28201-0006 Charlotte, NC 28201-1244 Peggy Force David A. Repka Assistant Attorney General Winston & Strawn LLP N. C. Department of Justice Electronic Mail Distribution Electronic Mail Distribution Beverly Hall, Acting Director Division of Radiation Protection N. C. Department of Environmental Health & Natural Resources Electronic Mail Distribution Henry J. Porter, Assistant Director Div. of Radioactive Waste Mgmt.
S. C. Department of Health and Environmental Control Electronic Mail Distribution R. Mike Gandy Division of Radioactive Waste Mgmt.
S. C. Department of Health and Environmental Control Electronic Mail Distribution County Supervisor of Oconee County 415 S. Pine Street Walhalla, SC 29691-2145
_________________________
OFFICE DRP/RII DRP/RII EICS/RII DRS/RII SIGNATURE MEE MXS1 NLO DCP for NAME MErnstes MShannon CEvans RBernhard Rgibbs MJohnson DATE 12/12/2005 12/09/2005 12/12/2005 12/12/2005 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
Significance Determination Process (SDP) Phase 3 Summary Statement of the Performance Deficiency The performance deficiency concerns a failure to take adequate corrective actions to bring the Unit 3 control room (i.e., north control room wall) within its licensing basis to withstand the tornado effects (wind force, missiles, and differential pressure) described in the Updated Final Safety Analysis Report UFSAR. As such, there is a lack of reasonable assurance that the Unit 3 control room, and therefore its related safety functions, would be available upon being subjected to design tornado effects.
Significance Determination Basis Phase 1 Screening Logic, Results, and Assumptions This finding affects the Mitigating Systems Cornerstone, as the control room wall protects the safety-related mitigating functions/systems performed/operated from inside the control room. As the finding is potentially risk significant due to a severe weather initiating event, a Phase 3 analysis is required.
It was assumed that the condition existed since Unit 3 construction.
Phase 3 Analysis The following risk assessment was performed with the intent of covering both inadequate corrective action violation examples. The first concerns a failure to take adequate corrective actions to bring the Unit 3 control room (i.e., north control room wall) within its licensing basis to withstand the effects (wind force, missiles, and differential pressure) of differing tornado intensities. The second concerns the inadequate corrective actions involving the inappropriate use of the 10 CFR 50.59 process to effectively eliminate the Unit 3 control room tornado missile requirements from the UFSAR.
The NRC does not have risk tools that allow quantification of the impact of the finding.
However using information previously available from the licensee, a qualitative evaluation of the risk can be made as follows:
- In Problem Investigation Process Report (PIP) O-04-2365, updated on April 26, 2005, the licensee calculated a mean core damage frequency of 4E-7 and noted that with double the number of potential missiles the mean damage frequency would be 9E-7. In PIP O-01-2827, updated on June 2, 2005, the licensee calculated tornado impact on the Unit 3 control room wall would result in a core damage frequency of 6E-7.
- At the time of the 10 CFR 50.59 change, the resident inspectors noted that the licensee was storing a significant amount of unsecured material in zones that would significantly increase the number of potential missiles over the quantity assumed in the licensee's risk evaluation. The number of added missiles was Enclosure
estimated by the resident inspectors to be an increase of 10 to 20 times greater than assumed in the TORMIS model. This would increase the likelihood of missiles striking the wall.
- The licensee noted, the material properties of the block walls were mis-characterized in an overly optimistic manner with respect to the intended TORMIS code." This was an assumption that the walls were 6-inch reinforced concrete instead of the existing cement block wall construction. This could impact the ability of the walls to stop missiles thrown by the tornado and could impact the ability of the wall to withstand differential pressure associated with the tornado without failure.
- The licensee's risk assessment assumes that the operators are pre-staged at the standby shutdown facility (SSF) prior to the tornado. The licensee's risk evaluation noted: From a human action standpoint, if the SSF is not pre-staged when a tornado warning is given then some adverse impact is possible on operator response time, and We only have a qualitative argument at this point.
High uncertainties are associated with even well defined human actions. Without more data this human reliability analysis term is a source of high uncertainty.
Although the NRC does not currently have risk tools to analyze the significance of the apparent violation(s), there is enough uncertainty, and indications of nonconservatism in the licensee's prior calculations to indicate the risk associated with this item is likely greater than 1E-6.
Enclosure