ML15261A308
| ML15261A308 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/11/1994 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hampton J DUKE POWER CO. |
| Shared Package | |
| ML15261A311 | List: |
| References | |
| GL-89-13, NUDOCS 9402230243 | |
| Download: ML15261A308 (6) | |
See also: IR 05000269/1993025
Text
FEB
I 1994
Docket Nos. 50-269, 50-270, 50-287
License Nos. DPR-38, DPR-47, DPR-55
Duke Power Company
ATTN:
Mr. J. W. Hampton
Vice President, Oconee Site
P. 0. Box 1439
Seneca, SC 29679
Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND NOTICE OF DEVIATION
(NRC INSPECTION REPORT NOS. 50-269/93-25, 50-270/93-25, AND
50-287/93-25)
This refers to the Service Water System Operational Performance Inspection
(SWSOPI) conducted by Mr. W. G. Rogers and others of this office on November 1
through December 14, 1993. The inspection included a review of activities
authorized for your Oconee Nuclear Power Station. At the conclusion of the
inspection, the findings were discussed with members of your staff identified
in the enclosed inspection report.
The enclosed inspection report identifies areas examined during the
inspection. The team assessed the operational performance of your service
water system. In particular, the team performed detailed reviews of the
service water system design, maintenance, operation, surveillance, and
testing. The team also assessed the planned or completed actions in response
to Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety
Related Equipment," issued on July 18, 1989.
The implementation of your Generic Letter 89-13 actions did not include
portions of your safety-related service water systems. This was the most
significant factor in concluding that your actions to the Generic Letter were
not adequate. Most importantly, the High Pressure Service Water system was
not included in your response to the Generic Letter or your implementation of
your commitments to the Generic Letter. Therefore, please submit an
additional response that addresses all Generic Letter actions within 30 days
of receipt of this letter as part of your response to the Notice of Deviation
on this matter.
The material condition was good for those service water systems classified as
safety-related. Also, maintenance and normal operation of the service water
systems were generally adequate. However, there were a number of significant
findings in other areas during the inspection. These included:
1.
The assumption that the Low Pressure Service Water (LPSW) pumps will not
incur any significant damage when operating during a postulated design
basis event with inadequate net positive suction head for 30 minutes was
not adequately validated.
9402230243 940211
PDR ADOCK 05000269
.3
G
Duke Power Company
2
F
II
4
2.
The SSF Auxiliary Service Water discharge lines to the steam generators
were not properly flushed following construction. Consequently,
questions remain as to whether the lines can pass the required flow.
3.
Assumed flow distributions to the steam generators and the service water
pumps in Standby Shutdown Facility (SSF) calculations were not
validated.
4.
There was no analysis of the temperature rise of Circulating Cooling
Water or LPSW systems following a postulated failure of the Keowee Dam.
Additionally, there was no analysis of the intake canal's impounded
volume losses through evaporation or seepage following a postulated
failure of the Keowee Dam.
5.
There was only one valve isolating the safety-related portion of the
LPSW system from the nonsafety-related turbine building portion.
6.
The SSF could not withstand a postulated failure of the Jocassee Dam.
This was inconsistent with your Individual Plant Examination submittal.
7.
The High Pressure Service Water system was not designed or maintained
commensurate with its importance to safety.
Findings 1, 2, 3, and 4 were associated with violations discussed below and
will require your written response. Finding 5 has been classified as an
unresolved item pending our further review of your basis for excluding valves
LPSW-45 and LPSW-139 from consideration as single failures in your analyses of
design basis accidents.
Please provide a written response describing your
basis for this exclusion. A written response describing your analysis and
actions planned regarding items 6 and 7 is also requested. Please submit
these responses to items 5, 6, and 7 within 30 days from the date of this
letter.
There were other findings such as the inadequate implementation of your
GL 89-13 actions, an inadequate material suitability review of Belzona for
repairing reactor building cooling coil leaks and omissions of critical
aspects during engineering reviews of conditions adverse to quality. There
were weaknesses in the SSF periodic test program and in the procedural
guidance of select abnormal events. Also, SSF calculations were not promptly
updated following design changes, and the initiation of the Auxiliary Service
Water system within 40 minutes was questionable.
Collectively, all these findings and others discussed in the inspection report
indicate weaknesses in:
pyour
design control measures which allow the use of unvalidated
and nonconservative calculational assumptions and do not assure
proper translation of the design into the abnormal procedures,
Duke Power Company
3
FEB 1
1994
the adequacy of engineering evaluations,
your testing program, and
the scope of your quality assurance program through inaccurate
classification of components which perform safety-related
functions
Please evaluate this report with special emphasis on these areas and provide
in a separate correspondence, within 60 days of receipt of this letter, those
programmatic corrective actions warranted by the inspection report findings.
As indicated earlier, certain of your activities appeared to be in violation
of NRC requirements as specified in the enclosed Notice of Violation (Notice).
One violation reflected multiple design control inadequacies. One violation
concerned inadequate testing of service water system SSF equipment and
Emergency Condenser Cooling Water. Another violation involved numerous
examples of inadequate or inadequately implemented quality related procedures.
The last violation illustrated inadequate corrective actions for a postulated
waterhammer in the Low Pressure Service Water system and the lack of seismic
qualification of the High Pressure Service Water system.
Certain other of your activities appeared to deviate from previous commitments
made by Duke Power Company. One deviation involves the failure to include all
the applicable service water systems in Generic Letter 89-13 corrective
actions. The other deviation involved an inadequate test of the High Pressure
Service Water system's capability during a Station Blackout.
In addition, the enclosed inspection report identified certain activities that
violated NRC requirements that will not be subject to enforcement action
because your efforts in identifying and correcting the violation met the
criteria specified in Section VII.B of the Enforcement Policy. These
activities included omissions of select Low Pressure Service Water system
check valves from the inservice test program and omissions in your safety
classification system for Condenser Circulating Water equipment supporting Low
Pressure Service Water system operation.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. In your
response, you should document the specific actions taken and any additional
actions you plan to take to prevent recurrence. After reviewing your response
to these Notices, including your proposed corrective actions and the results
of future inspections, the NRC will determine whether further NRC enforcement
action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, the enclosures, and your response to this letter will be placed
in the NRC Public Document Room.
Duke Power Company
4
FEB 1 1 1994
The responses directed by this letter and the accompanying Notice are not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please contact us.
Si ncerely,
(Original signed by A. F. Gibson)
Albert F. Gibson, Director
Division of Reactor Safety
Enclosures:
2. Notice of Deviation
3. Inspection Report No. 50-269, 270,
and 287/93-25
cc w/encls:
M. E. Patrick
Compliance
Duke Power Company
P. 0. Box 1439
Seneca, SC
29679
A. V. Carr, Esq.
Duke Power Company
422 South Church Street
Charlotte, NC
28242-0001
County Supervisor of
Oconee County
Walhalla, SC 29621
Robert B. Borsum
Babcock and Wilcox Company
Nuclear Power Generation Division
1700 Rockville Pike, Suite 525
Rockville, MD 20852
J. Michael McGarry, III, Esq.
Winston and Strawn
1400 L Street, NW
Washington, D. C. 20005
cc w/encls cont'd:
(See page 5)
Duke Power Company
5
FEB
1 191
cc w/encls cont'd:
Office of Intergovernmental Relations
116 West Jones Street
Raleigh, NC
27603
Max Batavia, Chief
Bureau of Radiological Health
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, SC 29201
Manager, LIS
NUS Corporation
2650 McCormick Drive
Clearwater, FL
34619-1035
G. A. Copp, Licensing - EC050
Duke Power Company
P. 0. Box 1006
Charlotte, NC 28201-1006
Karen E. Long
Assistant Attorney General
N. C. Department of Justice
P. 0. Box 629
Raleigh, NC
27602
bcc w/encls:
L. A. Wiens, NRR
W. Miller, DRP
J. Jaudon, DRS
G. Hallstrom, DRS
M. S. Lesser, DRP
A. R. Herdt, DRP
J. Lieberman, OE
Document Control Desk
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
Route 2, Box 610
Seneca, SC
29678
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cc w/encls cont'd:
Office of Intergovernmental Relations
116 West Jones Street
Raleigh, NC 27603
Max Batavia, Chief
Bureau of Radiological Health
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, SC 29201
Manager, LIS
NUS Corporation
2650 McCormick Drive
Clearwater, FL 34619-1035
G. A. Copp, Licensing - ECO50
Duke Power Company
P. 0. Box 1006
Charlotte, NC 28201-1006
Karen E. Long
Assistant Attorney General
N. C. Department of Justice
P. 0. Box 629
Raleigh, NC 27602
bcc w/encls:
L. A. Wiens, NRR
W. Miller, DRP
J. Jaudon, DRS
G. Hallstrom, DRS
M. S. Lesser, DRP
A. R. Herdt, DRB(
J. Lieberman, OE
Document Control Desk
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
Route 2, Box 610
Seneca, SC 29678
- FOR PREVIOUS LIST OF CONCURRENCES, SEE ATTACHED PAGE
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