IR 05000269/2008010

IR 05000269-08-010, IR 05000270-08-010, & IR 05000287-08-010 on 06/30/2008, for Oconee

ML083260398
Person / Time
Site:	Oconee
Issue date:	11/21/2008
From:	Wert L Division Reactor Projects II
To:	Baxter D Duke Energy Carolinas, Duke Power Co
Shared Package
ML083260393	List: IR 05000269/2008010 ML083260404
References
EA-08-324 IR-08-010
Download: ML083260398 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

ber 21, 2008

SUBJECT:

OCONEE NUCLEAR STATION - NRC INSPECTION REPORT 05000269/2008010, 05000270/2008010 AND 05000287/2008010; PRELIMINARY GREATER THAN GREEN FINDING

Dear Mr. Baxter:

On June 30, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a quarterly integrated inspection at your Oconee Nuclear Station. The inspection findings were documented in NRC Inspection Report 05000269/2008003, 05000270/2008003, and 05000287/2008003, which was issued on July 25, 2008.

Section 4OA3.1 of that report identified Unresolved Item (URI)05000269/2008003-02, which concerned a loss of reactor coolant system (RCS) inventory while on decay heat removal.

Subsequent to additional inspection, the performance deficiency was identified as a failure to implement a main generator automatic voltage regulator (AVR) maintenance procedure that met the standards/expectations of Nuclear System Directive (NSD) 703, Administrative Instructions for Technical Procedures, to achieve the intended purpose by being technically accurate, safe, and complete. More specifically, AVR maintenance procedure IP/0/B/2005/001, Main Generator Automatic Voltage Regulator Maintenance and Channel Transfer, failed to identify and electrically isolate all AVR trip outputs to the main generator lockout relays. Consequently, during AVR maintenance in Unit 1 on April 15, 2008, a main generator lockout occurred, resulting in a loss of power event that ultimately led to a loss of RCS inventory (70 inches to 54 inches on LT-5) while in Mode 6 (reactor head closure bolts de-tensioned) on decay heat removal. As such, this event challenged the safety function of inventory control. In addition to the above inadequacy, the AVR procedure was also not coded to prevent it from being performed during even higher risk periods of reduced inventory, as had been the case from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (12.5 inches on LT-5) to six hours (23 inches on LT-5) prior to the actual event.

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 copy of the SDP Phase 3 analysis. It reflects a finding of greater than very low safety significance because of the increased likelihood of core damage. The significance of the finding is heavily influenced by human diagnostic and recovery actions. Because of these human actions and their interdependencies, the result was classified as Greater Than Green. The finding does not

DEC 2 represent a current safety concern because AVR maintenance procedure IP/0/B/2005/001 was put on hold until appropriate procedural changes were made.

For administrative purposes, this finding is identified as FIN 05000269/2008010-01, Failure to Implement an Adequate AVR Maintenance Procedure. Accordingly, URI 05000269/2008003-02 is closed. In addition, this finding is considered to have a cross-cutting aspect of complete, accurate, and up-to-date procedures H.2(c), as described in the resources component of the human performance cross-cutting area.

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 the date of this letter. The significance determination process encourages an open dialogue 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 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. Steven Rose at (404) 562-4647 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 you will be advised by separate correspondence of the results of our deliberations on this matter.

In accordance with 10 CFR 2.390 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/

Leonard D. Wert, Jr., 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 cc w/encl.: (See page 3)

_________________________ G SUNSI REVIEW COMPLETE OFFICE RII:DRP NRR:APOB RII:EICS RII:DRP OE NRR RII:DRP SIGNATURE SDR /RA/ via telecom CFE /RA/ JHM /RA/ via email via email via telecon NAME SRose JMitman CEvans JMoorman GGulla MAshley AHutto DATE 11/14/2008 11/13/2008 11/19/2008 11/24/2008 11/18/2008 11/18/2008 11/13/2008 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

DEC 3 cc w/encl: Beverly O. Hall Berry G. Davenport Chief, Radiation Protection Section Compliance Manager Department of Environmental Health Oconee Nuclear Station N.C. Department of Environmental Duke Power Company, LLC Commerce & Natural Resources d/b/a Duke Energy Carolinas, LLC Electronic Mail Distribution Electronic Mail Distribution Susan E. Jenkins Clark E. Curry Director, Division of Waste Management Engineering Manager Bureau of Land and Waste Management Oconee Nuclear Station S.C. Department of Health and Duke Power Company, LLC Environmental Control d/b/a Duke Energy Carolinas, LLC Electronic Mail Distribution Electronic Mail Distribution R. Mike Gandy Philip J. Culbertson Division of Radioactive Waste Mgmt.

Oconee Nuclear Station S.C. Department of Health and Duke Power Company, LLC Environmental Control d/b/a Duke Energy Carolinas, LLC Electronic Mail Distribution Electronic Mail Distribution County Supervisor of Oconee County Preston Gillespie 415 S. Pine Street Manager Walhalla, SC 29691-2145 Oconee Nuclear Station Duke Power Company, LLC Lyle Graber d/b/a Duke Energy Carolinas, LLC LIS Electronic Mail Distribution NUS Corporation 2650 McCormick Drive Scott L. Batson Clearwater, FL 33759-1035 Engineering Manager Oconee Nuclear Station R. L. Gill, Jr.

Duke Power Company, LLC Manager d/b/a Duke Energy Carolinas, LLC Nuclear Regulatory Issues & Industry Affairs Electronic Mail Distribution Duke Power Company, LLC d/b/a Duke Energy Carolinas, LLC Lisa F. Vaughn Electronic Mail Distribution Associate General Counsel Duke Energy Corporation Charles Brinkman 526 South Church Street-EC07H Director Charlotte, NC 28202 Washington Operations Westinghouse Electric Company Kathryn B. Nolan Electronic Mail Distribution Senior Counsel Duke Energy Corporation Dhiaa M. Jamil 526 South Church Street-EC07H Group Executive and Chief Nuclear Officer Charlotte, NC 28202 Duke Energy Carolinas, LLC Electronic Mail Distribution David A. Repka Winston Strawn LLP Electronic Mail Distribution

DEC 4 Letter to David from Leonard D. Wert, Jr. dated November 21, 2008 SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT 05000269/2008010, 05000270/2008010 AND 05000287/2008010; PRELIMINARY GREATER THAN GREEN FINDING Distribution w/encl:

C. Evans, RII L. Slack, RII OE Mail RIDSNRRDIRS PUBLIC L. Olshan, NRR