ML16148A520
| ML16148A520 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/13/1991 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tuckman M DUKE POWER CO. |
| Shared Package | |
| ML16148A521 | List: |
| References | |
| EA-91-052, EA-91-52, NUDOCS 9107160161 | |
| Download: ML16148A520 (7) | |
See also: IR 05000269/1991009
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9107160161
DOC.DATE: 91/06/13
NOTARIZED: NO
DOCKET #
CIL:50-269 Oconee Nuclear Station, Unit 1, Duke Power Co.
05000269
50-270 Oconee Nuclear Station, Unit 2, Duke Power Co.
05000270
50-287 Oconee Nuclear Station, Unit 3, Duke Power Co.
05000287
AUTH.NAME
AUTHOR AFFILIATION
EBNETER,S.D.
Region 2 (Post 820201)
RECIP.NAME
RECIPIENT AFFILIATION
TUCKMAN,S.
Duke Power Co.
SUBJECT: Discusses insp repts 50-269/91-09,50-270/91-09 &
50-287/91-09 on 910324-0427 & forwards notice of violation.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL
SIZE:
, +
R
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response
I
NOTES:
D
RECIPIENT
COPIES
RECIPIENT
COPIES
ID CODE/NAME
LTTR ENCL
ID CODE/NAME
LTTR ENCL
S
PD2-3 PD
1
1
.WIENS,L
1
1
INTERNAL: ACRS
2
2
1
1
AEOD/DEIIB
1
1
AEOD/TPAB
1
1
0
DEDRO
1
1
NRR MORISSEAU,D
1
1
NRR SHANKMAN,S
1
1
NRR/DLPQ/LPEB10
1
1
E
NRR/DOEA/OEAB
1
1
NRR/DREP/PEPB9H
1
1
NRR/DST/DIR 8E2
1
1
NRR/PMAS/ILRB12
1
1
D
NUDOCS-ABSTRACT
1
1
OE DIR
1
1
OGC/HDS2
1
1
02
1
1
RGN2
FILE 01
1
1
11
EXTERNAL: EG&G/BRYCE,J.H.
1
1
NRC PDR
1
1
1
1
1D
0
C
UF
(II)C
T
TOTAL NUMBER OF COPIES REQUIRED: LTTR
23
ENCL
23
JUN13i~
Docket Nos.
50-269, 50-270, and 50-287
License Nos.
EA 91-052
Duke Power Company
ATTN: Mr. M. S. Tuckman, Vice President
Nuclear Operations
Post Office Box 1007
Charlotte, NC 28201-1007
Gentlemen:
SUBJECT: NOTICE OF VIOLATION
(INSPECTION REPORT NOS. 50-269/91-09, 50-270/91-09 AND 50-287/91-09)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by
Mr. W. K. Poertner on March 24 - April 27, 1991, at the Oconee Nuclear Station.
The inspection included a review of the facts and circumstances related to the
reversed impulse lines between the high pressure injection (HPI) crossover flow
instrument to the "B"
HPI header which was discovered by the plant staff on
March 19, 1991, following post modification testing conducted during the
Unit 3 refueling outage. This matter was reported in Licensee Event Report
No. 287/91-003. Followup of this problem on Units 1 and 2 resulted in the discovery
that the orifice plate in the Unit 2 crossover flow element associated with "A"
HPI header was installed in the reverse direction. The report documenting this
inspection was sent to you by letter dated May 7, 1991. As a result of this
inspection, a significant failure to comply with NRC regulatory requirements was
identified. An enforcement conference was held on May 22, 1991, in the Region II.
office to discuss the violation, its cause, and your corrective action to
preclude recurrence. The letter summarizing this conference was sent to you by
letter dated June 3, 1991.
The Technical Specification definition of operability requires that all
instrumentation necessary to assure performance of a system's safety function
must also be capable of performing its related support functions. The viola
tion with two examples described in the enclosed Notice of Violation (Notice)
involves high pressure injection crossover valves in both Units 2 and 3 being
incapable of performing their intended safety function for an extended period
of time. The first example involved the Unit 3 HPI crossover flow instrument
to the "B" HPI header which had its impulse lines reversed. In May 1984, the
impulse lines and flow instruments had been replaced, but a flow test was not
specified as part of the post modification testing and the reversed impulse
lines were consequently not detected. As a result of crossover flow instrumen
tation being inoperable because of the reversed impulse lines, valve 3HP-409
was inoperable from May 1984 until March 1991. The second example, discovered
as a result of corrective actions in response to the first, involved the
9107160161 910613
PDR ADOCK 05000269
PDR/
'
Duke Power Company
2
JUN 13 1991
orifice plate in the Unit 2 crossover flow element associated with the "A" HPI
header which was found to have been installed in the reverse direction.
This
reverse installation degraded the flow instrumentation therefore causing valve
2HP-410 to be inoperable. This condition apparently existed since the initial
installation of the orifice.
The significance of this violation centers on the possibility of pump runout
conditions developing in the HPI system during certain accident scenarios.
These conditions existed for significant periods of time and would have been
discovered only with either flow testing of the system or actual use of the
system. Therefore, this violation has been categorized at Severity Level III
because of the function of the components involved and the length of time the
conditions existed.
In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C (1991), a
civil penalty is considered for a Severity Level III violation. However, after
consultation with the Director, Office of Enforcement, and the Deputy Executive
Director for Nuclear Reactor Regulation, Regional Operations and Research, I
have decided that a civil penalty will not be proposed in this case. Mitigation
was warranted for your identification and reporting of the problems as well as
for your immediate corrective action that included checking Units 1 and 2 for
reversed impulse lines and the subsequent discovery of the reversed orifice.
The duration factor was considered in the categorization of the violation at
Severity Level III and therefore escalation of the base civil penalty using
that factor was found to be inappropriate. None of the other factors warranted
further adjustment of the civil penalty.
As a result of the extensive scope of your continuing corrective actions,
additional orifice related problems were found in other plant systems. For
example, on May 6, 1991, the Unit 2 emergency feedwater train "B" flow instru
ment orifice was found to be installed backwards; on May 9, 1991, the Unit 1
Reactor Building Spray train "B" flow instrument orifice was found to be
installed backwards; and, on May 18, 1991, the Unit 2 Reactor Building spray
train "B" orifice was found to be incorrectly oriented by 90 degrees. Because
discovery of these problems resulted directly from the corrective actions taken
in response to the issues cited in the Notice, separate enforcement action will
not be taken for these additional examples.
You are required to respond to this letter and should follow the instructions
specified in the Notice when preparing your response. In your response, you
should document the specific actions taken and any additional actions you plan
to prevent recurrence. After reviewing your response to this Notice, 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 NRC's "Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
Duke Power Company
3 -
3 99
The responses directed by this letter and the enclosed 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.
Sincerely,
JLMi 1
hoan/for
Stewart D. Ebneter
Regional Administrator
Enclosure:
cc w/encl:
H. B. Barron
Station Manager
Oconee Nuclear Station
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
Suite 525, 1700 Rockville Pike
Rockville, MD 20852
J. Michael McGarry, III, Esq.
Winston and Strawn
1400 L Street, NW
Washington, D. C. 20005
Office of Intergovernmental Relations
116 West Jones Street
Raleigh, NC 27603
cc w/encl cont'd:
(see next page)
Duke Power Company
- 4 -JU
13 1991
cc w/encl cont'd:
Heyward G. Shealy, 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
Stephen Benesole
Duke Power Company
P. 0. Box 1007
Charlotte, NC 28201-1007
R. L. Gill
Nuclear Production Department
Duke Power Company
P. 0. Box 1007
.
Charlotte, NC 28201-1007
Karen E. Long
Assistant Attorney General
N. C. Department of Justice
P. 0. Box 629
Raleigh, NC 27602
H. B. Tucker
Senior Vice President-Nuclear
Duke Power Company
P. 0. Box 1007
Charlotte, NC 28201-1007
State of North Carolina
Duke Power Company.
-5-
JUN 13 1991
-DISTRIBUTION:
LPDR
SECY
CA
JSniezek,
DEDR
JLieberman, OE'
SEbneter, RH
JGoldberg, OGC
TMurley, NRR
JPartlow, NRR
Enforcement Coordinators
RI, RII, RIII, RIV, RV
NRC Resident Inspector
FIngram, GPA/PA
BHayes, .I
DWilliams, 0IG
EJordan, AEOD
JLuehman, OE
Day File
EA File
RI
R
eyes
GRJe
ins
JLilhoan
0 6 /1 22/91
6p/91
6/
991
- FOR PREVIOUS CONCURRENCE --
SEE ATTACHED COPY
- OE
- RA:RII
- D:OE
- DEDS
JLuehman
SEbneter
JLieberman
JSniezek
06/
/91
06/
/91
06/
/91
06/
/91
Duke Power Company
- IRBUION:
L
POR
SECY
CA
JSniaeks DEOR
JLieberman OE
SEbneter, Air
JGoldberg, OGC
Tl~urley, NRR
JPart low, NRR
Enforcment Coordinators
RI, RuI RI!, RIVI RV
Resident Inspector
Flngram, SPA/PA
BHayes. 0!
D hl]ams, CIG
EJordan, AEOD
J~Luehman, OE
Day File
EA Pile
D CS
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SEbneter
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0 6/ /91
06/7 /91
06
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