ML111570484
| ML111570484 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/06/2011 |
| From: | Croteau R Division Reactor Projects II |
| To: | Gillespie T Duke Energy Carolinas |
| References | |
| NOED 11-2-003 | |
| Download: ML111570484 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 6, 2011 Mr. T. Preston Gillespie, Jr.
Site Vice President Duke Energy Carolinas, LLC Oconee Nuclear Station 7800 Rochester Highway Seneca, SC 29672
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR DUKE ENERGY CAROLINAS REGARDING OCONEE NUCLEAR STATION UNITS 2 AND 3
[NOED NO. 11-2-003]
Dear Mr. Gillespie:
By letter dated June 2, 2011, you requested that the NRC exercise discretion to not enforce compliance with the actions required in Oconee Nuclear Station (ONS), Unit 2 and Unit 3, Technical Specification (TS) Limiting Condition for Operation (LCO) 3.6.3, Containment Isolation Valves, Required Action A.1. Your letter documented information previously discussed with the NRC staff in a telephone conference on June 2 at 3:30 p.m. (all times refer to Eastern Time).
The principal NRC staff members who participated in the telephone conference are listed in the Enclosure. The NRC staff determined that the information in your letter requesting the NOED was consistent with your oral request.
You stated that, on June 2, 2011, Unit 2 and Unit 3 entered TS 3.6.3 Required Action A.1 at 12:10 p.m. and at approximately 4:10 p.m., Unit 2 and Unit 3 would not be in compliance with TS LCO 3.6.3, Required Action A.1, which would require that the affected penetration flow paths be isolated within four hours. If the affected penetration flow paths were not isolated, then both Unit 2 and Unit 3 must be placed in MODE 3 by June 3 at 4:10 a.m., and MODE 5 by June 4 at 4:10 a.m. Isolating the affected penetration flow paths would have also isolated letdown resulting in a loss of reactor coolant system inventory and chemistry control. Placing both Unit 2 and Unit 3 in MODE 5 would exacerbate an already fragile electrical grid due to extreme demand from hot weather projected during the period needed for necessary repairs. You requested that an NOED be granted for TS LCO 3.6.3, Required Action A.1, for both Unit 2 and Unit 3 pursuant to the NRCs policy regarding exercise of discretion for an operating facility set out in Section 3.8 of NUREG-1600, General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy), for a period not to exceed 14 days or until electrical grid conditions are predicted to return to normal for a period of at least 10 days. This letter documents our decision conveyed to you during the telephone conversation at approximately 6:30 p.m., when we orally granted this NOED request. We understand that the conditions causing the need for this NOED has not yet been corrected and that you will continue to maximize imported power and internal generating capacity to restore Duke Energys grid to normal conditions.
DEC 2 On January 8, 2011, during Unit 1 required testing, valve 1HP-5 failed to fully close following an inadvertent close signal. A root cause investigation found that improper material selection for the gland ring in a 2003/2004 modification resulted in a loss of margin for the actuator for the valve, as well as similar valves on ONS Unit 2 and Unit 3. On May 31, 2011, discussions with the valve and actuator program vendor identified that the software used in the licensees operability determination for the Unit 2 and Unit 3 valves may calculate non-conservative torque values resulting in a reduction in the valves closing margin. Ongoing evaluations indicated the required spring closing forces were inadequate resulting in a negative closing margin at normal reactor coolant system pressure. On June 2, at approximately 12:10 p.m., containment isolation valves 2HP-5, 2HP-21, 3HP-5, and 3HP-21 were declared inoperable. The NRC staff considered the independent entity (SERC Reliability Corporation) in determining placing ONS Unit 2 or Unit 3 in MODE 5 would result in power delivery challenges during a period of significant grid demand which could result in adverse consequences to the health and safety of the public.
To evaluate this NOED request, NRC staff considered your commitments to (1) defer non-essential surveillances and other maintenance activities in the switchyard to reduce the likelihood of a loss of offsite power, (2) defer non-essential surveillances and other maintenance activities on risk-significant equipment including the Keowee Emergency Power System, the emergency feed water turbine-driven pumps, and the standby shutdown facility (SSF), (3) post a dedicated operator located in the SSF for the NOED duration, (4) implement additional procedural steps that, from the control room, manually isolate letdown and valves downstream of HP-5, and (5) monitor grid conditions and ensure the safe and orderly shutdown of one or both units if grid conditions return to normal for a period of at least 10 days. NRC staff also considered that the calculated Incremental Conditional Large Early Release Probability values for Units 2 and 3 did not exceed the threshold guidance provided in Inspection Manual Part 9900 Technical Guidance and were consistent with values calculated by NRC regional analysts; that the noncompliance would not be of potential detriment to the public health and safety; and independent verification of some of these conditions and actions by our inspection staff.
On the basis of the NRC staffs evaluation of your request, we have concluded that granting this NOED is consistent with the Enforcement Policy and NRC staff guidance and has no adverse impact on public health and safety or the environment. This determination was qualitative and based upon balancing the effect on public health and safety of not operating, against the potential radiological or other hazards associated with continued operation (Part 9900, Section B.2.2, (i.e., severe weather NOED)). Therefore, it is our intention to exercise discretion to not enforce compliance with TS LCO 3.6.3, Required Action A.1 for the period from 12:10 p.m., on June 2, 2011, until 12:10 p.m., on June 16, 2011. As stated during the conference call and in your letter, you are still considering a submittal of a TS change.
DEC 3 As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Sincerely,
/RA/
Richard P. Croteau, Director Division of Reactor Projects Docket Nos.: 50-270, 50-287 License Nos.: DPR-47, DPR-55
Enclosure:
As Stated cc w/encl: (See page 4)
__ ML111570484 __ G SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP NRR:DORL SIGNATURE CWR /RA for/ WBJ /RA for/ Via email NAME JBartley RCroteau JGitter DATE 06/06/2011 06/06/2011 06/03/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO DEC 4 cc w/encl: County Supervisor of Oconee County 415 S. Pine Street Division of Radiological Health Walhalla, SC 29691-2145 TN Dept. of Environment & Conservation 401 Church Street W. Lee Cox, III Nashville, TN 37243-1532 Section Chief Radiation Protection Section David A. Baxter N.C. Department of Environmental Vice President, Nuclear Engineering Commerce & Natural Resources Duke Energy Carolinas, LLC Electronic Mail Distribution Electronic Mail Distribution Kent Alter Regulatory Compliance Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution Scott L. Batson Station Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution Terry L. Patterson Safety Assurance Manager Duke Energy Carolinas, LLC Electronic Mail Distribution Charles Brinkman Director Washington Operations Westinghouse Electric Company, LLC Electronic Mail Distribution Tom D. Ray Engineering Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution
DEC 5 Letter to T. Preston Gillespie, Jr. from Richard P. Croteau dated June 6, 2011
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION (NOED) FOR DUKE ENERGY CAROLINAS REGARDING OCONEE NUCLEAR STATION UNITS 2 AND 3
[NOED NO. 11-2-003]
Distribution w/encl:
C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMOconee Resource
List of Participants NRC REGION II ATTENDEES R. Croteau, Director, Division of Reactor Projects (DRP), Region II (RII)
J. Bartley, Chief, Reactor Projects Branch (RPB) 1, DRP, RII A. Sabisch, Oconee Senior Resident Inspector, RPB 1, DRP, RII R. Bernhard, Senior Risk Analyst, RPB 7, DRP, RII W. Rogers, Senior Risk Analyst, RPB 7, DRP, RII NRC HQ ATTENDEES J. Giitter, Director, Division of Operating Reactor Licensing (DORL), Office of Nuclear Reactor Regulation (NRR)
J. Stang, Senior Project Manager, Plant Licensing Branch II-1, DORL, NRR J. Mitman, Senior Reliability and Risk Analyst, PRA Operational Support Branch, Division of Risk Assessment, NRR S. Stuchell, Senior Project Manager, Licensing Processes Branch, Division of Policy and Rulemaking, NRR A. Howe, Deputy Director, DORL, NRR G. Kulesa, Chief, Plant Licensing Branch II-1, DORL, NRR G. Wilson, Chief, Instrumentation & Controls Branch, Division of Engineering (DE), NRR A. McMurtray, Chief, Component Performance & Testing Branch, Division of Component Integrity, NRR L. Lund, Chief, Electrical Engineering Branch, DE, NRR F. Ferrante, Risk Analyst, PRA Licensing Branch, Division of Risk Assessment, NRR J. Jolicoeur, Chief, Licensing Processes Branch, Division of Policy and Rulemaking, NRR R. Dennig, Chief, Containment And Ventilation Branch, Division of Safety Systems, NRR R. Mathew, Team Leader, Electrical Engineering Branch, DE, NRR J. Thompson, Project Manager, Plant Licensing Branch II-1, DORL, NRR Enclosure