ML15261A313
| ML15261A313 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/11/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15261A311 | List: |
| References | |
| 50-269-93-25, 50-270-93-25, 50-287-93-25, GL-89-13, NUDOCS 9402230257 | |
| Download: ML15261A313 (2) | |
Text
ENCLOSURE 2 NOTICE OF DEVIATION Duke Power Company Docket Nos. 50-269, 50-270 Oconee Nuclear Plant and 50-287 Units 1, 2 and 3 License Nos. DPR-38, DPR-47 and DPR-55 During an NRC inspection conducted on November 1 through December 14, 1993, deviations from written commitments were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action,"
10 CFR Part 2, Appendix C, the deviations are listed below:
A. Duke Power Company letter to the NRC,
Subject:
Generic Letter 89-13, dated January 26, 1990, stated:
On page 4 that, "Oconee has established a heat exchanger test program for testable safety related heat exchangers...."
On page 8 that, "...an initial heat exchanger test program was performed and a periodic test program was established."
On page 12 that, "Design Study ONDS-252 has been initiated to review the entire raw water system of the plant. This study will determine areas where water is stagnant or subject to intermittent flow...."
On page 17 that, "A SITA (Self Initiated Technical Audit) was completed on the service water system at Oconee...."
On page 18 that, "...training and procedure review programs have been established and address all maintenance, operating, and emergency procedures."
Contrary to the above, as of December 14, 1993:
- 1. A periodic testing program had not been established for the testable Keowee service water system heat exchangers or the Standby Shutdown Facility's testable emergency diesel generator heat exchangers.
- 2. All raw water systems were not reviewed for stagnant orintermittent flow under ONDS-252 in that Keowee service water cooled systems were not included.
- 3. The training and procedures review programs established for service water systems were not adequate in that these reviews never identified that there were no flow indicators in the Auxiliary Service Water discharge lines to the steam generators, no emergency procedure addressed inadequate Low Pressure Service Water flow and there were no operating procedures for Keowee service water systems.
9402230257 940211 PDR ADOCK 05000269 a
-PDR
Notice of Deviation 2
- 4. Numerous service water systems were omitted from the Self Initiated Technical Audit including the Auxiliary Service Water system, the Standby Shutdown Facility's service water systems, the Keowee service water systems, the condenser cooling mode of the Circulating Cooling Water system, and the recirculation mode of the Circulating Cooling Water system.
B. Duke Power Company's written commitments associated with Station Blackout, beginning with your letter of April 17, 1989, indicated that Regulatory Guide 1.155, "Station Blackout," Section 3.5, "Quality Assurance and Specification Guidance for Station Blackout Equipment That is Not Safety Related," would be followed. Section 3.5 in part, refers to Appendix A of the Regulatory Guide for providing guidance on quality assurance activities for non-safety-related equipment. Appendix A, Section 5, "Testing and Test Control," states in part, that'a test program be established and implemented to ensure that testing is performed to demonstrate conformance with design and system readiness requirements.
Contrary to the above, as of December 14, 1993, a test procedure for demonstrating that system readiness requirements were met, was inadequate in that the test acceptance criteria did not assure that a 4-hour inventory of High Pressure Service Water cooling water as assumed in the Station Blackout event was available from the minimum allowable Elevated Water Storage Tank level.
Please provide to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region II, and if applicable, a copy to the NRC Resident Inspector at the Oconee Nuclear Plant, in writing within 30 days of the date of this Notice, the reason for the deviations, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further deviations, and the date when your corrective actions will be completed. Where good cause is shown, consideration will be given to extending the response time.
Dated at Atlanta, Georgia this //- day off tui]994