ML13064A102

Slides from Predecisional Enforcement Conference with Duke Energy Carolinas, LLC, Oconee Nuclear Station Units 1, 2, and 3, Apparent Violation of a License Condition on Fire Protection

ML13064A102
Person / Time
Site:	Oconee
Issue date:	03/05/2013
From:	Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Boska J
References
Download: ML13064A102 (41)

Text

Oconee Nuclear Station Pre-Decisional Enforcement Conference NFPA 805: Implementation of Protected Service Water (PSW) System NRC Headquarters Rockville, MD March 5, 2013

Oconee Participants Regis Repko Senior Vice President Nuclear Operations Preston Gillespie Oconee Site Vice President Tom Ray Oconee Plant Manager Ed Burchfield Oconee Engineering Manager Bob Guy Oconee Organizational Effectiveness Manager Chris Nolan Regulatory Affairs Director Jim Fuller General Manager, PSW Project Lara Nichols Deputy General Counsel Terry Patterson Oconee Safety Assurance Manager Bob Rishel Fleet Probabilistic Risk Assessment Manager David Goforth NFPA 805 Transition Senior Project Manager 2

Agenda Opening Remarks Preston Gillespie Compensatory Actions Tom Ray Causes and Corrective Actions Bob Guy Risk Perspective Ed Burchfield Event Significance Chris Nolan Closing Remarks Regis Repko 3

Opening Remarks Preston Gillespie 4

Opening Remarks Oconee agrees with the apparent violation described in the NRCs letter dated January 31, 2013.

As an NFPA 805 pilot plant, Oconee has worked closely with the NRC, the industry, and stakeholders to address the requirements associated with transitioning to NFPA 805.

NFPA 805 transition is complex and resource intensive.

NFPA 805 is the right thing to do. Our perspective on the benefits it provides has not changed.

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Opening Remarks NFPA 805 transition provides risk benefits to the facility. Functions for achieving these risk benefits include:

Providing commercial power from PSW to the Standby Shutdown Facility (SSF)

Providing an additional power source to the SSF from the Keowee facility Completing the balance of work activities to implement NFPA 805 Completion of each function provides incremental risk improvement.

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Opening Remarks Upcoming incremental risk benefits do not excuse the fact that we missed our committed implementation date.

They do serve to highlight that the benefits of our NFPA 805 transition are being introduced into the operating facility.

Duke Energy is committed to completing the work needed to fully realize the safety and risk benefits of the NFPA 805 program.

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Compensatory Actions Tom Ray 8

Compensatory Actions Actions to Enhance Mitigation Thermal hydraulic scoping study used to identify the alternate steam generator feed approach for core cooling 9

Compensatory Actions Actions to Enhance Mitigation Simulator used to validate operator actions for revised Emergency Operating Procedure (EOP) 10

Compensatory Actions Actions to Enhance Mitigation Focused EOP training for operators includes classroom instruction and simulator scenarios.

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Compensatory Actions Actions to Enhance Mitigation Pre-staged diesel driven portable pump for backup feed of steam generators 12

Compensatory Actions Actions to Enhance Mitigation Pre-staged 2nd portable diesel driven pump as backup water source for the stations fire suppression system 13

Compensatory Actions Actions to Enhance Mitigation Robust fire brigade shift staffing supported by local fire fighting assets 14

Compensatory Actions Actions to Reduce Fire Exposure Fire Protection Engineer approval for hot work in high safety significant fire zones 15

Compensatory Actions Actions to Reduce Fire Exposure Rapid response to impaired fire mitigation/detection equipment 16

Compensatory Actions Added Actions when SSF is Out of Service Maximize readiness of the diesel driven portable pump to provide defense in depth capability to feed the steam generators 17

Compensatory Actions Added Actions when SSF is Out of Service Augmented shift staffing for rapid response to EOP driven field actions 18

Compensatory Actions Added Actions when SSF is Out of Service Thermal scans of risk significant sections of 4KV bus ducts 19

Compensatory Actions Added Actions when SSF is Out of Service Protecting additional equipment 20

Causes and Corrective Actions Bob Guy 21

Causes and Corrective Actions Evaluation Team and Scope Scope included fleet and ONS oversight of PSW project implementation schedule adherence and timeliness The Root Cause Team (RCT)

Senior Vice President, Nuclear Operations - sponsor Staffed with experienced personnel Included independent members 22

Causes and Corrective Actions Root Causes A flawed project plan led to risks that were not fully understood or appropriately addressed through proactive compensatory measures.

Unexpected quality challenges with vendors resulted in rework, contributing to overall project completion schedule delays.

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Causes and Corrective Actions Extent of Condition Evaluated major projects fleet-wide that may have similar vulnerabilities, for example:

NFPA 805 implementation Fukushima response activities Evaluation of project plans will be conducted.

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Causes and Corrective Actions Completed Actions Senior VP -

Nuclear Operations General VP Project ONS Site Vice Manager Licensing President PSW Project Plant Engineering Manager Manager Dedicated General Projects Manager reporting to Integration Manager Senior VP for Nuclear Operations 25

Causes and Corrective Actions Completed Actions Established Project Command Center to direct PSW activities 26

Causes and Corrective Actions Completed Actions Increased the oversight of project schedule implementation 27

Causes and Corrective Actions Completed Actions Improved vendor oversight and coordination 28

Causes and Corrective Actions Planned Corrective Actions Finalize and document plant level PSW design basis Finalize schedule for the completion of the design effort Revise PSW Project final implementation schedule following independent 3rd party review Establish detailed Risk Mitigation Plan Identify and evaluate the PSW services providers and contractors for restriction or removal from the approved supplier list 29

Causes and Corrective Actions Planned Corrective Actions Revise policy for NRC commitments for future major projects Strengthen standards for project management Improve standards for vendor oversight Implement industry best practices for procurement specifications Strengthen governance and oversight 30

Risk Perspective Ed Burchfield 31

Risk Perspective The PSW Project has three key functions that provide backup capability for existing systems:

SSF backup power source Backup power to selected HPI components High head steam generator feed pump that replaces the existing low head pump 32

Risk Perspective Estimated risk benefit including credit for reactor coolant pump low leakage seals 33

Risk Perspective Estimated reduction in fire core damage frequency of 0.9E-5 associated with providing commercial power from PSW to the SSF will be realized by October 1, 2013.

Estimated reduction in fire core damage frequency of 1.1E-5 achieved through use of low leakage reactor coolant pump seals.

As of the fall 2012, all three units have low leakage reactor coolant pump seals installed.

Approximately 50% of the fire risk benefit will be realized by October 1, 2013.

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Risk Perspective Schedule for remaining portions of NFPA 805 conversion activities will be available within 90 days of issuance of safety evaluation report.

Date for NFPA 805 implementation is November 15, 2016.

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Risk Perspective Oconee has demonstrated a sustained commitment to improve plant safety:

Reactor vessel head replacements Low Pressure Injection System cross-connect Keowee Digital Governor and Exciter Keowee underground cable replacement Low leakage RCP seals Natural Phenomena Barrier System Upgrade of Lee Combustion Turbines Digital Reactor Protective and Engineered Safeguards System Conversion to Digital Control Systems (Control Rod Drive, Turbine Control, Feedwater Pump Control, Integrated Control System, Automatic Voltage Regulator) 36

Event Significance Chris Nolan 37

Event Significance Oconee agrees with the facts identified in the apparent violation.

PSW provides an important risk enhancement.

The potential consequences of the apparent violation have been mitigated:

Oconee is safe as a result of compensatory measures maintained through the transition to NFPA 805.

Safety is further enhanced through the additional compensatory measures.

Failure to complete PSW modification does not result in an increase in plant risk from the current plant risk profile.

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Event Significance The significance of the apparent violation should be considered at Severity Level III:

NRC decision to approve the transition to NFPA 805 was based on PSW implementation.

Other considerations:

Violation was not repetitive Violation was licensee identified Timely implementation of compensatory measures Comprehensive actions to prevent recurrence Degree to which the violation was preventable 39

Event Significance Civil Penalty Considerations:

There were no actual consequences.

This condition was licensee identified.

Actions were timely and comprehensive.

License amendment request was submitted.

Additional compensatory measures were implemented.

Comprehensive actions were taken or planned.

Extent-of-condition to be evaluated with fleet perspective.

Oconee continues to demonstrate its commitment to improving plant safety through NFPA 805 implementation and other projects.

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Closing Remarks Regis Repko 41