ML15261A295
| ML15261A295 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/29/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15261A294 | List: |
| References | |
| 50-269-89-31-01, 50-269-89-31-1, 50-270-89-31, 50-287-89-31, NUDOCS 9001110100 | |
| Download: ML15261A295 (27) | |
Text
ENCLOSURE 1 NOTICE OF VIOLATION Duke Power Company Docket Nos. 50-269, 50-270, 50-287 Oconee Units 1, 2 and 3 License Nos. DPR-38, DPR-47, DPR-55 During the Nuclear Regulatory Commission (NRC) inspection conducted September 22 -
October 10,
- 1989, a violation of NRC requirements was identified.
The violation involved; inadequate testing of containment penetrations following maintenance or modifications.
In accordance with the "General Statement of Policy and Procedure for NRC.Enforcement Actions,"
10 CFR Part 2, Appendix C (1989), the violation is set forth below:
Oconee Nuclear Station Technical Specifications (TS) 4.4.1 identifies the required testing associated with containment penetration. integrity.
Included in this specification is the specific requirement to perform local leak rate testing or integrated leak rate testing, as applicable, following any major modification or replacement of a component affecting the integrity of containment.
Implicit in this statement is the requirement to perform testing following maintenance to components affecting containment integrity.
Contrary to the above, on September 22, 1989, the licensee identified that subsequent to the most recent Integrated Leak Rate Testing of each unit's containment, maintenance and modifications had been performed on several penetrations without performing the specified testing.
This failure to perform the required testing was associated with four specific penetra tions on all three units.
This is a Severity Level IV Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Duke Power Company is hereby required to submit a written statement of explanation to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector within thirty (30) days of the date of.the letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will
Duke Power Company 2
Docket Nos. 50-269, 50-270. 50-287 Oconee Units 1. 2 and 3 License Nos. DPR-38, DPR-47, DPR-55 be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended. or revoked or why such other action as may be proper should not be taken.
FOR THE NUCLEAR REGULATORY COMMISSION Stewart D. Ebneter Regional Administrator Dated at Atlanta. Georgia this 29 day of Dec.
1989 0
ENCLOSURE 2 LIST OF ATTENDEES November 8, 1989 U.S. Nuclear Regulatory Commission J. Milhoan, Deputy Regional Administrator C. Hehl, Deputy Director. Division of Reactor Projects (DRP)
K. Perkins, Acting Director. Division of Reactor Safety (DRS)
A. Herdt. Branch Chief, DRP M. Shymlock, Section Chief, DRP L. Wiens, Project Manager. Office of Nuclear Reactor Regulation (NPR)
R. Goddard, Regional Counsel P. Skinner, Senior Resident Inspector. Oconee G. Jenkins. Director, Enforcement and Investigation Coordination Staff (EICS)
B. Uryc, Senior Enforcement Coordinator G. Todd. Enforcement Compliance Specialist B. Desai. Reactor Engineer Duke Power Company H. Tucker, Vice President. Nuclear Production Department M. Tuckman. Station Manager. Oconee J. Davis. Superintendent of Technical Services W. Foster, Superintendent of Maintenance P. Weatherford, Mechanical Engineer
ENCLOSURE 3 ENFORCEMENT CONFERENCE
SUMMARY
On November 8, 1989. representatives from Duke Power Company (DPC) met with the NRC in the Region II Office in Atlanta, Georgia to discuss problems associated with Containment Penetration testing following maintenance and/or modification.
This issue was identified by DPC as a result of a review of the active valve list program. This review was beoun in September 1988, in response to a Babcock and Wilcox Owners Group concern.
It included Generic Letters 89-04 and 89-10 efforts and the strenathening of the licensee System Expert Program.
Following opening remarks by James Milhoan.
Region II.
Deputy Regional Administrator. DPC gave a presentation (Enclosure 4) on the issue.
DPC's presentation explained the factors leading to the discovery, the sequence of events, the short-term corrective actions, and an assessment of the specific penetrations affected. There were several root causes identified and discussed in detail.
The long-term corrective actions were then presented and some additional related events discussed.
The NRC closed the meeting by stating that DPC's presentations had served to enhance Region II's understanding of these issues and their corrective actions.
ENCLOSURE 4 OCONEE NUCLEAR STATION CONTAINMENT PENETRATION POST MODIFICATION/
MAINTENANCE TESTING NRC CONFERENCE NOVEMBER 8, 1989
OCONEE NUCLEAR STATION AGENDA BACKGROUND DISCUSSION OF EVENTS ROOT CAUSES OF EVENTS LONG TERM CORRECTIVE ACTIONS RELATED EVENTS
SUMMARY
OCONEE NUCLEAR STATION DUKE ATTENDEES MIKE TUCKMAN STATION MANAGER JOE DAVIS TECHNICAL SERVICES SUPERINTENDENT BILL FOSTER MAINTENANCE SUPERINTENDENT RONNIE WEATHERFORD MECHANICAL MAINTENANCE MANAGER
.OSTEVE BENESOLE PERFORMANCE ENGINEER TOM CURTIS COMPLIANCE MANAGER HAL TUCKER VICE PRESIDENT, NUCLEAR PRODUCTION JACK PEELE DESIGN ENGINEERING PROJECTS MANAGER, OCONEE DIVISION PAUL GUILL COMPLIANCE SUPPORT ENGINEER
OCONEE NUCLEAR STATION FACTORS LEADING TO DISCOVERY REVIEW OF ACTIVE VALVE LIST BEGAN 9/88 B&W OWNERS GROUP SPIP ITEM GENERIC LETTERS 89-04 AND 89-10 TYPE A AND C TESTING PREPARATION FOR UNIT 3 SYSTEM EXPERT PROGRAM STRENGTHENED PROGRAM BEGAN IN 1988 REVIEW OF CONTAINMENT INTEGRITY PROGRAM IMPROVEMENT OF DOCUMENTATION
OCONEE NUCLEAR STATION SEQUENCE OF EVENTS PENETRATIONS #53 AND #39 ARE FOR NITROGEN AND WATER ADDITION TO A AND B CORE FLOOD TANKS ORIGINAL CONFIGURATION UTILIZED CF-8, CF-10 AS INSIDE CONTAINMENT ISOLATION VALVES SYSTEM MET ORIGINAL DESIGN STANDARDS PENETRATION TESTED DURING TYPE A TESTS IE BULLETIN 79-02 REQUIRED DETAILED ANALYSIS OF PIPING BETWEEN RB WALL AND CF-8 AND CF-10 DECISION MADE TO ADD CHECK VALVES CF-42, CF-44 CLOSE TO RB WALL AND TO RECLASSIFY DOWNSTREAM PIPING AS NON-SEISMIC
A*SEQUENCE OF EVENTS (CONTINUED)
UNIT 3 CF-42, CF-44 ADDED 6/79 NO POST MODIFICATION LEAK RATE TEST DONE MODIFICATION PROGRAM DID NOT REQUIRE PRIOR REVIEW OF MODIFICATION FOR TESTING REQUIREMENTS NO TYPE A TEST THIS OUTAGE UNIT 3 ADDED VENT VALVES CF-43 AND CF-45 TO ALLOW CHALLENGING DURING TYPE A TEST IN 2/81 CONSERVATIVE TEST DUE TO VENT VALVE LOCATION MET APPENDIX J REQUIREMENTS TYPE A TEST CORRECTLY PERFORMED 2/81 UNITS 1 AND 2 MODIFIED TO ADD CF-42,43, 44,45 ON 11/81 AND 4/82 RESPECTIVELY NO POST MODIFICATION LEAK RATE TEST DONE NO-TYPE A TEST THIS OUTAGE
SEQUENCE OF EVENTS (CONTINUED)
ALL SUBSEQUENT TYPE A TESTS PERFORMED AS THEY WERE PRIOR TO THE MODIFICATIONS TO PENETRATIONS #53 AND #39 PENETRATION #53 INCORRECTLY CHALLENGED AT CF-8 PENETRATION #39 CHALLENGED PROPERLY TYPE A TESTS CONDUCTED 8/83, 4/86 UNIT 1 10/83, 3/88 UNIT 2 5/84, 2/87 UNIT 3
- 9/21/89 TESTING PROBLEM IDENTIFIED BY SYSTEM EXPERT - PIR INITIATED 9/22/89 TESTING PROBLEM CONFIRMED DISCUSSION WITH NRC SUBSEQUENT INVESTIGATION REVEALED A PROBLEM WITH POST MODIFICATION/POST MAINTENANCE LEAK RATE TESTING TECHNICAL SPECIFICATION (TECH SPEC)
INTERPRETATION PROBLEM FOR CERTAIN PENETRATIONS INDIVIDUAL VALVES AFFECTED ON PENETRATIONS #53, #39, #56 (UNIT 2),
- 59 (UNITS 1 & 3)
OCONEE NUCLEAR STATION SHORT TERM CORRECTIVE ACTIONS PENETRATION #53, AND AFFECTED VALVES ON OTHER PENETRATIONS, DECLARED INOPERABLE OUTSIDE CONTAINMENT BOUNDARIES VERIFIED ISOLATED ADMINISTRATIVE CONTROLS INSTITUTED UNIT 1 PENETRATION #53 MODIFIED TO ALLOW TYPE C TESTING SUCCESSFUL TESTING CONDUCTED UNIT 1 PENETRATION #39 SUCCESSFULLY TYPE C TESTED (WITHOUT MODIFICATION)
QUALITATIVE TESTS CONDUCTED ON UNITS 2 AND 3 PENETRATIONS #53 AND #39 EMERGENCY TECH SPECS CHANGE SUBMITTED COMMITTED TO MODIFY PENETRATIONS #53 AND #39 ON ALL UNITS COMMITTED TO PERFORM TYPE C TESTING IN THE FUTURE TEMPORARY WAIVER FROM COMPLIANCE REQUESTED TO ALLOW USE OF PENETRATIONS #53 AND #39
SHORT TERM CORRECTIVE ACTIONS (CONTINUED)
COMPREHENSIVE REVIEW CONDUCTED FOR CONTAINMENT PENETRATIONS FOR WHICH TECH SPECS REQUIRE TYPE A TESTS, BUT NOT TYPE C TESTS 11 PENETRATIONS PER UNIT REVIEW SHOWED ALL WERE PROPERLY TESTED DURING TYPE A TESTS AFFECTED VALVES IDENTIFIED WHICH HAD NOT YET HAD TYPE A TESTS PERFORMED:
PEN 53 PEN 39 PEN 59 PEN 56 UNIT 1
- 1CA-29 *1CF-3
- 1N-131
- 1CF-4 UNIT 2 2CF-42 2CF-44 2SF-81 UNIT 3 3CF-42 3N-131 3CF-3 3CF-4 TYPE C TESTS SUBSEQUENTLY COMPLETED TO SATISFY REQUIREMENT
OCONEE NUCLEAR STATION PENETRATIONS #53 AND #39 ASSESSMENT OF BARRIERS TYPE A TEST OF PENETRATION #39 WAS CORRECT TYPE A TEST OF PENETRATION #53 CHALLENGED CF-8 PIPING BETWEEN CF-8 AND CF-42 IS CLASS G NON-SEISMIC DESIGN ENGINEERING ASSESSMENT IS THAT PIPING IS AS RELIABLE AS SEISMIC PIPING ROUTINELY IS SUBJECTED TO 600 PSI TYPE C TESTING OF PENETRATION #53 ON UNIT 1 WAS SUCCESSFUL QUALITATIVE TESTING OF PENETRATIONS #53 AND #39 SHOWS LEAKAGE ACCEPTABLE WITH EXCEPTION OF 2N-131 BOTH PENETRATIONS ISOLATED BY MULTIPLE BARRIERS IN NORMAL ALIGNMENT REASONABLE ASSURANCE THAT PENETRATIONS WOULD HAVE FUNCTIONED
OCONEE NUCLEAR STATION ASSESSMENT OF PENETRATION #59 IDENTIFIED IN FOLLOW-UP FROM PENETRATIONS
- 53 AND #39 PENETRATION IS FOR SAMPLING OF CORE FLOOD TANKS AFFECTED VALVES (CF-3&4) ARE MOTOR OPERATED OUTSIDE VALVE IS MANUAL AFFECTED UNITS 1 AND 3 ONLY MOTOR OPERATORS WERE REBUILT THIS COULD CHANGE CLOSING FORCE NORMAL PRACTICE IS TO PERFORM LLRT SPECIAL LLRT CONDUCTED ON UNIT 1 AND LEAKAGE ACCEPTABLE 3CF-3&4 DECLARED INOPERABLE PENETRATION VERIFIED ISOLATED
ASSESSMENT OF PENETRATION #59 (CONTINUED)
PIPING IN THIS PENETRATION IS SEISMIC TO THE CFT THE CFT IS NOT EXPECTED TO BE EXPOSED TO CONTAINMENT ATMOSPHERE THE NORMAL FUNCTION OF CF-3&4 IS TO ISOLATE A 600 PSIG SYSTEM FROM A SAMPLING SYSTEM THIS PENETRATION IS NORMALLY ISOLATED WITH MULTIPLE BARRIERS REASONABLE ASSURANCE THAT CONTAINMENT WOULD HAVE FUNCTIONED
OCONEE NUCLEAR STATION ASSESSMENT OF PENETRATION #56 IDENTIFIED IN FOLLOW-UP OF PENETRATIONS
- 53 AND #39 PENETRATION IS FOR FILLING AND DRAINING THE FUEL TRANSFER CANAL SITUATION EXISTED ON UNIT 2 ONLY 2SF-81 WAS REPAIRED WITHOUT POST MAINTENANCE LEAK RATE TESTING 2SF-81 ISOLATION VALVE DECLARED INOPERABLE VERIFIED THAT REMAINING CONTAINMENT ISOLATION VALVE CLOSED PENETRATION ISOLATED BY MULTIPLE BARRIERS BY NORMAL ALIGNMENT PIPING IS SEISMIC FROM 2SF-60 TO 25F-61 2SF-61 IS CHALLENGED DURING TYPE A TEST REASONABLE ASSURANCE THAT CONTAINMENT WOULD HAVE FUNCTIONED
OCONEE NUCLEAR STATION ROOT CAUSE DETERMINATION MODIFICATION PROGRAM IN LATE 70'S, EARLY 80'S DID NOT REQUIRE PRIOR REVIEW FOR TESTING/PROCEDURE CHANGE REQUIREMENTS CHANGE IN THE TYPE OF TEST PROCEDURE USED FOR ILRT CHANGED TO TT (TEMPORARY TEST) e TT DID NOT CARRY OVER NEW ALIGNMENT CHANGE OF PERSONNEL 3 TIMES IN THIS PERIOD INADEQUATE TURNOVER INAPPROPRIATE INTERPRETATION OF TECH SPECS TECH SPEC FOR APPENDIX J ISSUED IN 1981 INDIVIDUALS INVOLVED MISUNDERSTOOD REQUIREMENT FOR POST MODIFICATION/
POST MAINTENANCE LEAK TESTING OF PENETRATIONS FOR WHICH TECH SPEC TABLE LISTED TYPE A TESTS, BUT STATED TYPE C TESTS "NONE REQUIRED"
ROOT CAUSE DETERMINATION O (CONTINUED)
TESTING DEFERRED TILL NEXT SCHEDULED ILRT PRE-ILRT REVIEWS CONDUCTED BY APPROPRIATE PERSONNEL POST MAINTENANCE TESTING REQUIREMENTS REVIEWED BY APPROPRIATE PERSONNEL INADEQUATE ADMINISTRATIVE AND PROCEDURAL CONTROLS POST MODIFICATION TESTING REQUIREMENTS IN TWO MANUALS IST MANUAL UNDER CONTROL OF PERFORMANCE STATION DIRECTIVE ON WORK REQUESTS LISTS VALVE POST MAINTENANCE TESTING REQUIREMENTS STATION DIRECTIVE DID NOT HAVE VALVES LISTED FOR PENETRATIONS #53 AND #39, IST MANUAL REVISED IN 1988 TO ADD THEM MAINTENANCE REQUESTED EVALUATION PERFORMANCE MADE DETERMINATION TO TEST DURING NEXT ILRT
OROOT CAUSE DETERMINATION (CONTINUED)
STATION DIRECTIVE DID HAVE PENETRATION
- 59 MAINTENANCE REQUESTED EVALUATION PERFORMANCE MADE DETERMINATION TO TEST DURING NEXT ILRT SF-81 OF PENETRATION #56 NOT LISTED IN STATION DIRECTIVE OR IST MANUAL
OCONEE NUCLEAR STATION LONG TERM CORRECTIVE ACTIONS PENETRATIONS #53 AND #39 WILL BE MODIFIED TO PERMIT TYPE C TESTING ILRT'S PLANNED FOR ALL THREE UNITS AT NEXT REFUELING OUTAGE SYSTEM EXPERT PROGRAM COMPREHENSIVE REVIEW OF ALL CONTAINMENT PENETRATIONS REVIEW DESIGN LICENSING BASIS FOR COMPLIANCE WITH APPENDIX J COMPLETION OF DOCUMENTATION PACKAGE FOR EACH PENETRATION REVIEW/UPGRADE METHOD OF CONTROLLING TESTING REQUIREMENTS IST PROGRAM CONTROLS STATION ADMINISTRATIVE PROCEDURES TRAIN PERSONNEL INVOLVED IN LEAK RATE TEST DETERMINATIONS TRAINING FOR PERSONNEL TO BE INVOLVED IN LEAK RATE TEST DETERMINATIONS
OCONEE NUCLEAR STATION RELATED EVENTS MISSED STROKE TEST ON 1RC-7 12/87 LER 269/88-1 FAILURE OF MANAGEMENT TO ENSURE WORK REQUEST PROGRAM PROPERLY IMPLEMENTED COMMUNICATIONS BREAKDOWN PERSONNEL ERROR MISSED LOCAL LEAK RATE TEST ON 3LWD-1 FOLLOWING MAINTENANCE 7/89 LER 287/89-03
-COMMUNICATIONS BREAKDOWN CHANGED WORK SCOPE AFTER WORK REQUEST WRITTEN FAILURE TO FOLLOW POLICY/PROCEDURE FOUND ON REVIEW OF COMPLETED WORK REQUEST
SUMMARY
THESE WERE RELATED TO PERSONNEL ERRORS WITH PROPER PROGRAMS IN PLACE CORRECTIVE MEASURES IMPROVED AND CLARIFIED THE POST MAINTENANCE TESTING PROGRAM PROBLEMS AND CORRECTIVE ACTIONS NOT DIRECTLY RELATED TO CURRENT EVENT
OCONEE NUCLEAR STATION
SUMMARY
PROBLEMS IDENTIFIED BY DUKE THROUGH PROGRAMMED EFFORTS FOR REVIEW/UPGRADE EXTENSIVE ACTIONS TO REVIEW OTHER PENETRATIONS AND MAINTENANCE ACTIVITIES FOR OTHER PROBLEMS REVIEW OF TESTING RESULTS INDICATE THAT CONTAINMENT WOULD FUNCTION PROPERLY TESTING PROBLEMS WERE CONFINED TO PENETRATIONS FOR WHICH TECH SPECS REQUIRED TYPE A TESTS, BUT NOT TYPE C TESTS CORRECTIVE ACTIONS ARE COMPREHENSIVE AND SHOULD PREVENT RECURRENCE POST MAINTENANCE TESTING PROGRAM IS EXTENSIVE; CORRECTION OF DOCUMENT PROBLEM SHOULD PREVENT RECURRENCE
SUMMARY
(CONTINUED)
POST MODIFICATION TESTING PROGRAM IS EXTENSIVE; WE HAVE NOT EXPERIENCED PROBLEMS SINCE PROGRAM HAS CHANGED CURRENT MODIFICATION REVIEW PROGRAM (TOPFORM) ASSISTS IN IDENTIFYING POTENTIAL PROBLEMS
OCONEE NUCLEAR STATION PENETRATION 53 &.39 AB RB AB RB N-299 N-298 N-130 N-128 CF-45 CF-43 N--
N N-131 CF-44 CF-10 CF-8 CF-42 N-12 CFT CFT B
A CA-29 CA-27 HP-156 HP-155
OCONEE NUCLEAR STATION PENETRATION #56 AB RB 2SF-87 2SF-60 2SF-81 2SF-61 2SF-76
OCONEE NUCLEAR STATION PENETRATION #59 AB RB CFT CFT S
B A
YAA CF-19 M
CF-4 CF-3 CF-7