IR 05000269/2009006

IR 05000269-09-006, 05000270-09-006, and 08000287-09-006, on 09/24/2009, Oconee Nuclear Station - NRC Problem Identification and Resolution Inspection Errata

ML092890273
Person / Time
Site:	Oconee
Issue date:	10/16/2009
From:	Daniel Merzke Reactor Projects Branch 7
To:	Baxter D Duke Energy Carolinas
Shared Package
ML092670558	List: IR 05000269/2009006
References
IR-09-006
Download: ML092890273 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 16, 2009

SUBJECT:

OCONEE NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000269/2009006, 05000270/2009006, AND 05000287/2009006 ERRATA

Dear Mr. Baxter:

On September 24, 2009, the US Nuclear Regulatory Commission (NRC) issued the subject inspection report for the Oconee Nuclear Station, ADAMS accession ML092670558. In reviewing this report, it was noted that we referred to an incorrect Problem Investigation Process (PIP) number that you entered into the corrective action program to address the non-cited violation described in section 4OA2.a(3). Accordingly, we are providing a portion of the revised version of Inspection Report 05000269/2009006, 05000270/2009006, and 05000287/2009006 that documents the above change.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, 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 the 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).

I apologize for any inconvenience this error may have caused. If you have any questions, please contact me at (404) 562-4421

Sincerely,

/RA/

Daniel J. Merzke, Acting Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55 Enclosure: Inspection Report 05000269/2009006, 05000270/2009006, and 05000287/2009006 w/Attachment: Supplemental Information cc w/encl. (See page 2)

_________________________ XG SUNSI REVIEW COMPLETE DXM2 OFFICE RII:DRP RII:DRP SIGNATURE EJS2 DXM2 NAME EStamm DMerzke DATE 10/16/09 10/16/09 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

DEC 2 cc w/encl:

Robert Meixell Kathryn B. Nolan Regulatory Compliance Manager Senior Counsel Oconee Nuclear Station Duke Energy Corporation Duke Energy Carolinas, LLC 526 South Church Street-EC07H Electronic Mail Distribution Charlotte, NC 28202 Scott L. Batson Charles Brinkman Engineering Manager Director Oconee Nuclear Station Washington Operations Duke Energy Carolinas, LLC Westinghouse Electric Company Electronic Mail Distribution Electronic Mail Distribution Clark E. Curry County Supervisor of Oconee County Mechanical and Civil Engineering Manager 415 S. Pine Street Oconee Nuclear Station Walhalla, SC 29691-2145 Duke Energy Carolinas, LLC Electronic Mail Distribution David A. Repka Winston Strawn LLP Philip J. Culbertson Electronic Mail Distribution Oconee Nuclear Station Duke Energy Carolinas, LLC R. Mike Gandy Electronic Mail Distribution Division of Radioactive Waste Mgmt.

S.C. Department of Health and Preston Gillespie Environmental Control Manager Electronic Mail Distribution Oconee Nuclear Station Duke Energy Carolinas, LLC Susan E. Jenkins Electronic Mail Distribution Director, Division of Waste Management Bureau of Land and Waste Management R. L. Gill, Jr. S.C. Department of Health and Manager Environmental Control Nuclear Regulatory Issues & Industry Affairs Electronic Mail Distribution Duke Energy Carolinas, LLC Electronic Mail Distribution Beverly O. Hall Chief, Radiation Protection Section Dhiaa M. Jamil Department of Environmental Health Group Executive and Chief Nuclear Officer N.C. Department of Environmental Duke Energy Carolinas, LLC Commerce & Natural Resources Electronic Mail Distribution Electronic Mail Distribution Lisa F. Vaughn Associate General Counsel Duke Energy Corporation 526 South Church Street-EC07H Charlotte, NC 28202

DEC 3 Letter to David from Daniel J. Merzke dated October 16, 2009 SUBJECT: OCONEE NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000269/2009006, 05000270/2009006, AND 05000287/2009006 ERRATA Distribution w/encl:

C. Evans, RII L. Slack, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMOconee Resource

setpoint for the LPI cooler. The insufficient margin between the LPI relief valve set point and the peak pressure of the LPI system upon startup was not incorporated into plant procedures to prevent inadvertent relief valve lifts.

Analysis: The inspectors determined that the licensees failure to provide sufficient margin between the LPI relief valve set point and the peak discharge pressure of the LPI system upon startup was a performance deficiency. The inspectors reviewed Inspection Manual Chapter (IMC) 0612 and determined that the finding was more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern, specifically for loss of inventory if the relief valve failed to reseat.

Additionally, the finding was associated with the design control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown. The inspectors determined that the finding was of very low safety significance (Green) because it had minimal effect on pressurizer level and met the availability requirements set forth in IMC 0609, Appendix G, Shutdown Operations Significance Determination Process (SDP), which verified that the licensee was maintaining an adequate mitigation capability for shutdown operation.

The cause of the finding had a cross-cutting aspect in the area of human performance.

It was directly related to the licensee not conducting effectiveness reviews of safety-significant decisions to verify the validity of the underlying assumptions, identify possible unintended consequences, and determine how to improve future decisions aspect of the decision-making component. Specifically, licensee calculation OSC-5616, reviewed and revised in 2008, identified a possible unintended consequence that 3LP-37 could lift during LPI pump start. This was not incorporated into plant procedures to prevent future relief valve lifts. Additionally, with the assumption that the relief setpoint for 3LP-37 was low, the licensee started the LPI system during the 3EOC24 outage under the same conditions that 3LP-37 lifted during the 3EOC23 outage (H.1(b)).

Enforcement: 10 CFR 50 Appendix B, Criterion III, Design Control, states, in part, that measures shall be established to assure that the applicable design basis for components are correctly translated into procedures and instructions. Contrary to this requirement, from March 27, 2003 to August 5, 2009, the conclusion from OSC-5616, LPI Overpressure/Overtemperature Prevention Analysis, that 3LP-37 may lift when placing the LPI system in service for decay heat removal was not correctly translated into licensee procedure OP/3/A/1102/010, Controlling Procedure for Unit Shutdown.

Consequently, this resulted in the relief valve 3LP-37 lifting upon LPI startup during the 3EC23 and 3EC24 refueling outages. The licensee entered the issue into the corrective action program as PIP O-09-2529 and revised OP/3/A/1102/010 to provide additional margin during LPI startup for decay heat removal. Because this violation was of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as an NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000287/2009006-01, Failure to Provide Margin Between the LPI Relief Valve Setpoint and the Peak Discharge Pressure of the LPI System.

setpoint for the LPI cooler. The insufficient margin between the LPI relief valve set point and the peak pressure of the LPI system upon startup was not incorporated into plant procedures to prevent inadvertent relief valve lifts.

Analysis: The inspectors determined that the licensees failure to provide sufficient margin between the LPI relief valve set point and the peak discharge pressure of the LPI system upon startup was a performance deficiency. The inspectors reviewed Inspection Manual Chapter (IMC) 0612 and determined that the finding was more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern, specifically for loss of inventory if the relief valve failed to reseat.

Additionally, the finding was associated with the design control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown. The inspectors determined that the finding was of very low safety significance (Green) because it had minimal effect on pressurizer level and met the availability requirements set forth in IMC 0609, Appendix G, Shutdown Operations Significance Determination Process (SDP), which verified that the licensee was maintaining an adequate mitigation capability for shutdown operation.

The cause of the finding had a cross-cutting aspect in the area of human performance.

It was directly related to the licensee not conducting effectiveness reviews of safety-significant decisions to verify the validity of the underlying assumptions, identify possible unintended consequences, and determine how to improve future decisions aspect of the decision-making component. Specifically, licensee calculation OSC-5616, reviewed and revised in 2008, identified a possible unintended consequence that 3LP-37 could lift during LPI pump start. This was not incorporated into plant procedures to prevent future relief valve lifts. Additionally, with the assumption that the relief setpoint for 3LP-37 was low, the licensee started the LPI system during the 3EOC24 outage under the same conditions that 3LP-37 lifted during the 3EOC23 outage (H.1(b)).

Enforcement: 10 CFR 50 Appendix B, Criterion III, Design Control, states, in part, that measures shall be established to assure that the applicable design basis for components are correctly translated into procedures and instructions. Contrary to this requirement, from March 27, 2003 to August 5, 2009, the conclusion from OSC-5616, LPI Overpressure/Overtemperature Prevention Analysis, that 3LP-37 may lift when placing the LPI system in service for decay heat removal was not correctly translated into licensee procedure OP/3/A/1102/010, Controlling Procedure for Unit Shutdown.

Consequently, this resulted in the relief valve 3LP-37 lifting upon LPI startup during the 3EC23 and 3EC24 refueling outages. The licensee entered the issue into the corrective action program as PIP O-09-2945 and revised OP/3/A/1102/010 to provide additional margin during LPI startup for decay heat removal. Because this violation was of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as an NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000287/2009006-01, Failure to Provide Margin Between the LPI Relief Valve Setpoint and the Peak Discharge Pressure of the LPI System.