ML15118A340
| ML15118A340 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/20/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15118A339 | List: |
| References | |
| 50-269-98-02, 50-269-98-2, 50-270-98-02, 50-270-98-2, 50-287-98-02, 50-287-98-2, NUDOCS 9804270353 | |
| Download: ML15118A340 (4) | |
Text
NOTICE OF VIOLATION Duke Energy Corporation Docket No. 50-269,270,287 Oconee 1, 2, and 3 License No. DPR-38,47,55 During an NRC inspection conducted from February 8 to March 21. 1998, five violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions,"
NUREG 1600. the violations are listed below:
A.
10 CFR 50 Appendix B, Criterion V. Instructions, Drawings, and Procedures, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.
Nuclear System Directive 301, Nuclear Station Modifications, Revision
- 13. states that temporary changes, to structures, systems, and components within the nuclear facility are considered modifications and are required to be controlled.
Contrary to the above, on February 11, 1998. the licensee made temporary changes to the hotwell suction line for the Unit 2 turbine driven emergency feedwater pump without implementing the temporary modification process specified in Nuclear System Directive 301.
This is a Severity Level IV violation (Supplement I).
B.
10 CFR 50 Appendix B, Criterion V, Instructions, Drawings, and Procedures, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.
Nuclear System Directive 104, Housekeeping. Material Condition, and Foreign Material Exclusion, Revision 13. states in part that when parts, tools, or other items can be dropped into the system, implement documentation of tools and materials that enter or leave the cleanliness zone.
Procedure OP/0/A/1510/016. Miscellaneous Spent Fuel Pool (SFP)/Canal Operations, Revision 03, Enclosure 3.4, Diving Operations in SFP/Canal, states in part that the requirements of Nuclear System Directive 104 SHALL be in effect for all activities performed under this procedure.
Contrary to the above, on February 23, 1998, the inspectors identified multiple undocumented items inside the Unit 1 and 2 SFP foreign material exclusion area.
This is a Severity Level IV violation (Supplement I).
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O NOV 2
C.
10 CFR 50 Appendix B, Criterion V. Instructions, Drawings, and Procedures, states that activities affecting quality shall -be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.
Site Directive 2.2.1, Minor Modification Program, dated August 28, 1997, Section 3.10. Procedures/Engineering Instructions states, in part, that:
"If an existing procedure is used, it shall contain detailed instructions sufficient to perform the Quality Assurance (QA) condition 1 activities needed to perform the modification."
Contrary to the above, on January 20, 1998, a minor modification was performed on the high pressure injection system without detailed instructions sufficient to perform QA-1 activities. Specifically, valve 1HP-286, a reactor coolant pump seal injection block valve, was installed in the system without proper engineering instructions to support packing installation that was a part of the modification work.
This is a Severity Level IV violation (Supplement I).
D.
10 CFR 50, Appendix B. Criterion V. Instructions. Drawings, and Procedures, states that activities affecting quality be prescribed by documented instructions or procedures, and shall be accomplished in accordance with these instructions or procedures.
The Duke Power Chemistry Materials Guide Program SDQA Plan "O",
Revision 25, requires that before materials are designated for use in any plant application involving stainless steel material, they are to be analyzed for impurities and approved for use as specified in the above-mentioned guide.
Nuclear System Directive 104, Housekeeping Material Condition and Foreign Material Exclusion, Revision 13, requires that the use, location and deployment of materials shall be controlled to prevent conditions that will adversely affect quality: that mechanical components shall be properly maintained to reflect no degree of neglect; that area owners are responsible for ensuring that material condition/housekeeping measures are working effectively and that corrective measures are initiated for all related problems.
Contrary to the above, activities affecting quality were not accomplished in accordance with procedures, as evidenced by the following examples:
- 1.
As of March 4, 1998. Duke Power Chemistry Materials Guide Program requirements had not been implemented in that lagging adhesive CP 50 was used on stainless steel piping valves and fasteners located in the Unit 2 west penetration room and high pressure injection room 58 without first being analyzed for impurities and approved
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for use in specified applications by the licensee's chemistry group.
- 2.
On March 4. 1998, material condition and housekeeping practices inside the Unit 2 west penetration room and high pressure injection Room 58, were not in accordance with Nuclear System Directive 104 requirements in that grey duct tape, paint smudges, and paint splatters were observed on stainless steel piping, valve bodies, valve motor operator covers, hand wheels and electrical cables: lagging material deposits were observed on a wall mounted instrument line support: the motor stand of high pressure injection pump 2B exhibited a film of oil on the horizontal surface: and significant amounts of coating had peeled off equipment and floors.
This is a Severity Level IV violation (Supplement I).
E.
10 CFR 50 Appendix B, Criterion III, Design Control, and the Duke Topical Report, state in part that design control measures shall provide for verifying or checking the adequacy of design by the performance of design reviews. Design control measures shall be applied to items such as reactor physics analysis.
Nuclear System Directive 306, Nuclear Fuel Reliability, dated December 30, 1997. which implements the above, assigned ownership for the fuel reliability program to the corporate office. Subsection 306.2.15 indicated that the corporate office was to evaluate fuel design changes and relevant plant modifications for their impact on fuel reliability.
Contrary to the above, on February 4 and 10, 1998. the licensee discovered that design change errors had been introduced into and implemented ih Technical Specification 3.5.2.6 addressed core operating limits report power-imbalance limits and computer alarm set points for all three units.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201. Duke Energy Corporation, is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATT.:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Oconee Nuclear Station, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation; (2) the corrective steps that will be taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations: and (4) the date when full compliance will be achieved.
Your response may reference or.include previous docketed correspondence, if the correspondence adequately addresses the required'response. If an adequate reply is not received within the time specified in this Notice, an Order or a
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Demand for Information may be issued as to why the license should not be modified, suspended, or revoked. or why such other action as may be proper should not be taken. Where good cause is.shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Atlanta, Georgia this 20th day of April 1998