ML16154A777

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Notice of Violation from Insp on 950226-0325.Violation Noted:Khu Aligned to Grid Was Technically Inoperable Due to Potential Overspeed Lockout While Operating in Excess of 72 MW
ML16154A777
Person / Time
Site: Oconee  
Issue date: 04/21/1995
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML16154A778 List:
References
50-269-95-03, 50-269-95-3, 50-270-95-03, 50-270-95-3, 50-287-95-03, 50-287-95-3, NUDOCS 9505030134
Download: ML16154A777 (2)


See also: IR 05000226/2003025

Text

NOTICE OF VIOLATION

Duke Power Company

Docket Nos. 50-269, 270, and 287

Oconee 1, 2, and 3

License Nos. DPR-38, 47 and 55

During an NRC inspection conducted on February 26 - March 25, 1995, a

violation of NRC requirements was identified. In accordance with the "General

Statement of Policy and Procedure for NRC Enforcement Actions, "10 CFR Part 2,

Appendix C, the violation is listed below:

10 CFR 50, Appendix B, Criterion III, states in part that measures shall

be established to assure that applicable regulatory requirements and the

design basis are correctly translated into specifications, drawings,

procedures, and instructions. It further states that design control

measures shall provide for verifying or checking the adequacy of the

design.

10 CFR 50, Appendix B, Criterion V, states in part that activities

affecting quality shall be prescribed by documented procedures of a type

appropriate to the circumstances.

Contrary to the above, from May 20, 1993, until March 20, 1995, the

design control process, independent verification process, and operating

procedure associated with establishing the maximum power limit of a

Keowee Hydro Unit (KHU) while generating to the system grid, were

inadequate. Specifically:

a.

Oconee Site Calculation (OSC)-6003, Revision 0, "Keowee Operating

Limits To Prevent Overspeed Due To Load Rejection," a QA-1

calculation, established 66 MW as the maximum power output for a

KHU generating to the grid. Revision 1 of this calculation, dated

May 20, 1993, increased the limit to 75 MW. This revision was

non-conservative in that it did not accurately account for

instrument uncertainties. Taking appropriate account of these

instrument uncertainties should have resulted in a limit of 68 MW.

This calculation was independently reviewed and approved without

identifying the error. The non-conservative limit of 75 MW was

subsequently incorporated into procedure OP/0/A/2000/041, "Keowee

Modes Of Operation."

As a result, for a cumulative time of

thirty-one hours and three minutes between May 20, 1993, and

January 27, 1995, the KHU aligned to the grid was technically

inoperable due to potential overspeed lockout while operating in

excess of 72 MW.

b.

OSC-6003, was revised (Revision 3) on March 14, 1995, in order to

raise the maximum power output limit for a KHU from 56 MW to 69

MW. The statistical analysis methodology utilized to reduce

instrument uncertainties was incorrect for this revision.

Utilizing the appropriate statistical methodology should have

resulted in a maximum power limit of 68 MW. This calculation was

Enclosure 1

9505030134 950421

PDR ADOCK 05000269

0

PDR

2

independently reviewed and approved without identifying the error.

The non-conservative limit of 69 MW was subsequently incorporated

into OP/O/A/2000/041, "Keowee-Modes Of Operation."

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 or explanation 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 a copy to the NRC

Resident Inspector at the Oconee Nuclear Plant, 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 have been 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.

If an adequate reply is not received within the time specified in this Notice,

an order or 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.

ODated at Atlanta, Georgia

this 21 day of April 1995

Enclosure 1