ML063240383
| ML063240383 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/20/2006 |
| From: | Casto C Division Reactor Projects II |
| To: | Brandi Hamilton Duke Energy Carolinas, Duke Power Co |
| References | |
| EA-06-294, IR-06-018 | |
| Download: ML063240383 (6) | |
See also: IR 05000269/2006018
Text
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
November 20, 2006
Duke Power Company, LLC d/b/a
Duke Energy Carolinas, LLC (Duke)
ATTN: Mr. Bruce H. Hamilton
Site Vice President
Oconee Nuclear Station
7800 Rochester Highway
Seneca, SC 29672
SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT
05000269/2006018, 05000270/2006018, AND 05000287/2006018;
PRELIMINARY GREATER THAN GREEN FINDING
Dear Mr. Hamilton:
On June 30, 2006, 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 05000269/2006003, 05000270/2006003, and
05000287/2006003, which was issued on July 28, 2006.
Section 1R15 of that report identified Unresolved Item (URI)05000287/2006003-03, which
concerned your identification of foreign material in the Unit 3, A and B train reactor building
emergency sump (RBES) suction lines during the Unit 3 end-of-cycle 22 refueling outage
(RFO). The related performance deficiency was identified as a failure to implement adequate
foreign material exclusion controls for the Unit 3 RBES. Although it is not known when the
apparent foreign material exclusion failure occurred, it is inherently certain that the
aforementioned foreign material/debris was in the Unit 3 RBES for at least the duration of cycle
22 [December 24, 2004 (Mode 4 towards startup) through April 29, 2006 (Mode 5 for the EOC
RFO)].
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. It reflects a finding of potentially greater than very low safety
significance because, in the event of a medium or large break loss of coolant accident (LOCA),
there was a lack of reasonable assurance that the low pressure injection (LPI) pumps would
DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY
INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS
DECONTROLLED.
Duke 2
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
have been available to perform their Emergency Core Cooling System (ECCS) recirculation
function. More specifically, supporting staff analysis indicated that the foreign material/debris
found in both RBES suction trains could move downstream during the sump recirculation mode
of medium break and large break LOCA scenarios; thereby, potentially damaging the 3A and
3B LPI pumps. Consideration of the 3C LPI pump as a backup success path to achieve the
necessary ECCS recirculation function was based upon the uncertainties surrounding its
viability (i.e., deteriorative atmospheric conditions and flooding resulting from a damage-
induced seal failure on the 3B LPI pump, test and maintenance situations, and random
failures). The finding does not represent a current safety concern because the foreign
material/debris was removed upon discovery.
The finding is also an apparent violation (AV) of Technical Specification 5.4.1, Procedures, and
Section 9.e of referenced Regulatory Guide 1.33 for the failure to comply with Nuclear System
Directive (NSD) 104, Material Condition/Housekeeping, Cleanliness/Foreign Material Exclusion
and Seismic Concerns, by not maintaining the Unit 3 RBES free of foreign material. This
apparent violation (identified as AV 05000287/2006018-01: Inadequate Foreign Material
Exclusion Controls for the Unit 3, A and B Train Reactor Building Emergency Sump Suction
Lines) is being considered for escalated enforcement action in accordance with the NRC
Enforcement Policy. Accordingly, for administrative purposes, URI 05000287/2006003-03 is
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 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. Jim Moorman 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 enforcement decisions and
you will be advised by separate correspondence of the results of our deliberations on this
matter.
DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY
INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS
DECONTROLLED.
Duke 3
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
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 violations may change as a result of further NRC review.
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/
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 (OFFICIAL USE ONLY - PROPRIETARY INFORMATION)
cc w/encl: (See page 4)
DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY
INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS
DECONTROLLED.
_ML063240383
OFFICE RII:DRP RII:DRP EICS
SIGNATURE JHM /RA/ WGR /RA/ CFE /RA/
NAME Jmoorman Wrogers CEvans
DATE 11/20/2006 11/15/2006 11/16/2006
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
Duke 4
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
cc w/encl:
B. G. Davenport 415 S. Pine Street
Compliance Manager (ONS) Walhalla, SC 29691-2145
Duke Power Company LLC
d/b/a Duke Energy Carolinas, LLC
Electronic Mail Distribution Lyle Graber, LIS
NUS Corporation
cc w/o encl: Electronic Mail Distribution
Lisa F. Vaughn
Associate General Counsel R. L. Gill, Jr., Manager
and Managing Attorney Nuclear Regulatory Issues
Duke Energy Carolinas, LLC and Industry Affairs
526 South Church Street-EC 07H Duke Power Company LLC.
Charlotte, NC 28202 d/b/a Duke Energy Carolinas, LLC
526 S. Church Street
Kathryn B. Nolan Charlotte, NC 28201-0006
Senior Counsel
Duke Energy Carolinas, LLC Charles Brinkman
526 South Church Street -EC07H Director, Washington Operations
Charlotte, NC 28202 Westinghouse Electric Company
12300 Twinbrook Parkway, Suite 330
David A. Repka Rockville, MD 20852
Winston & Strawn LLP
Electronic Mail Distribution Distribution w/encl: (See page 5)
Beverly Hall, Chief Radiation
Protection Section
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
DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY
INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS
DECONTROLLED.
Duke 5
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
Letter to Bruce H. Hamilton from Charles Casto dated November 20, 2006
SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT
05000269/2006018, 05000270/2006018, AND 05000287/2006018;
PRELIMINARY GREATER THAN GREEN FINDING
Distribution w/o encl:
L. Olshan, NRR
C. Evans
L. Slack, RII EICS
OE Mail
RIDSNRRDIRS
PUBLIC