ML16295A300
| ML16295A300 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/15/1987 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Tucker H DUKE POWER CO. |
| References | |
| EA-87-014, EA-87-14, NUDOCS 8712170002 | |
| Download: ML16295A300 (6) | |
See also: IR 05000269/1986016
Text
PRREG(J4
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, 0. C. 20555
DEC 15 ic.6
7
Docket Nos. 50-269, 50-270, 50-287
License Nos. DPR-38, DPR-47, DPR-55
EA 87-14
Duke Power Company
ATTN: Mr. H. B. Tucker, Vice President
Nuclear Production Department
422 South Church Street
Charlotte, NC 28242
Gentlemen:
SUBJECT:
NRC RESPONSE TO DUKE DENIAL OF VIOLATION
(NRC INSPECTION REPORTS NOS. 50-269/86-16, 50-270/86-16, AND
50-28786-16)
This refers to your April 13, 1987 response to the Notice of Violation and Pro
posed Imposition of Civil Penalty (Notice) transmitted to you by letter dated
March 12, 1987. The Notice described three violations identified during an NRC
inspection at the Oconee Nuclear Station on May 5 - June 11, 1986. A civil
penalty in the amount of Twenty-five Thousand Dollars was proposed for
W
Violation I.
While admitting the occurrence of the other violations, you have denied the
the occurrence of Violation I and have requested mitigation of the proposed civil
penalty. After consideration of your response, we have concluded for the reasons
given in the enclosure to this letter that the violation, as stated, did not
occur. Therefore, this violation has been deleted from our records and the
proposed civil penalty has been withdrawn. However, while withdrawing this
violation, the NRC still remains concerned that your design control process was
weak in this instance. The design process could have been better performed had
there been communications with the pump vendor at the time of the modification to
ensure that the pumps would meet all expected demand situations and to determine
if either short-term or long-term operation at pump runout conditions would be
detrimental to system or component performance. We understand that your planned
hardware modifications will alleviate the potential problems, and we request
that you notify NRC Region II of your plans and schedule for the modifications.
With regard to the violations in Section II of the Notice, we have evaluated
your response and have found that it meets the requirements of 10 CFR 2.201. We
will examine the implementation of your corrective actions during a future
inspection.
87117002 9871215
87127 %c~05000269
pD0V
pDR-
Duke Power Company
- 2
In .accordance with Section 2.790 of the NRC's "Rule of Practice", Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and the enclosure
will be placed in the NRC's Public Document Room.
We regret our delay in this matter.
Sincerely,
J
es M. Tay r, Deputy
xecutive Director for
Operations
Enclosure:
Evaluations and Conclusions
cc (w/encl):
M. S. Tuckman, Station Manager
ENCLOSURE
EVALUATIONS AND CONCLUSIONS
On March 12, 1987, a Notice of Violation and Proposed Imposition of Civil
Penalty (Notice) was issued for violations identified during an NRC Safety
System Functional Inspection (SSFI).
Duke Power Company (DPC or licensee)
responded to the Notice on April 13, 1987. DPC denied Violation I and requested
withdrawl of the proposed civil penalty. The NRC evaluation and conclusion
regarding the licensee's arguments are as follows:
Restatement of Violation I
10 CFR 50, Appendix B, Criterion III, requires that measures be established to
assure that applicable regulatory requirements and the design basis, as defined
in §50.2 and as specified in the licensee application for those structures,
systems, and components to which this appendix applies, are correctly translated
into specifications, drawings, procedures, and instructions.
Contrary to the above, measures had not been established to assure the regula
tory requirements and design basis were correctly translated into specifications,
drawings, procedures, and instructions in that the design changes for the instal
lation of the motor driven emergency feedwater (EFW) pumps in 1979 did not docu
ment and account for pump runout or adequate net positive suction head (NPSH)
which were part of the design basis of the equipment. This lack of pump
runout/NPSH protection in the EFW system design could result in the loss of EFW
function during design basis transients.
This is a Severity Level III violation (Supplement I).
Civil Penalty -
$25,000.
Summary of Licensee's Response
In the licensee's April 13, 1987 response, the licensee denies Violation I and
states that the design control process in place for the modification, which added
motor driven EFW pumps, assured that the new EFW system design and analysis were
commensurate with the original design. The licensee contends that specific
protection for EFW pump runout to guard against postulated short-term bearing
failure was not a criterion of the original nor modified EFW design and that
runout was only determined to be a problem after the pump vendor,at the
licensee's request, reviewed the capability of the pump bearings to withstand
vibration associated with low net positive suction head (NPSH) and high flow.
The motor driven EFW pumps were considered capable of withstanding the wear due
to cavitation throughout any design basis scenario.
The licensee also contends that no credit was given for its identifying the
undesirably high EFW flow rates and the fact that remedial calculations had
already been initiated. In this regard, the licensee asserts that an analysis
was in progress while the NRC SSFI was being performed.
Enclosure
2
The licensee further contends that the NRC has misunderstood the licensee's
written response of July 23, 1982 to IE Bulletin 80-04. The licensee clarifies
this response by explaining that the impact to the containment pressure response
due to EFW runout flow following a steam line break was not explicitly consid
ered. The licensee also explains that the ability of the EFW level control
system to preclude the occurrence of the EFW system operating at runout flow
rates was limited to the main steam line break inside containment transient.
For other transients, the level control system with operator action was
considered adequate in precluding pump damage, predicated on what was known at
the time about the pump behavior at runout conditions. In an October 14, 1982
letter to DPC, the NRC had acknowledged that DPC would rely on operator action
to prevent pump damage for the postulated pump runout conditions. The licensee
contends that it was not known at that time that pump damage could occur in the
short-term due to bearing failure.
In May 1986, DPC determined that the runout flow conditions were more extensive
than had earlier been postulated. DPC advised the pump vendor of this problem,
but the vendor was unable to assure that some damage would not occur during
pump runout.
NRC Evaluation of Licensee's Response
The NRC staff agrees with the licensee's contention that the design change
.
process which added the motor driven EFW pumps were.commensurate with the
original design and that pump runout and net positive suction head analysis
were part of the design basis of the EFW system when the motor driven EFW
pumps were added to the system. While the licensee appears to not have
considered all potential system demand situations in both the original design
and design change, the licensee was not aware of the potential short term
damage to the pump bearings that could be caused by pump runout until later.
Therefore, based on this information the NRC staff agrees that the violation
did not occur as stated and withdraws the violation and proposed civil penalty.
As mitigation of the civil penalty for this violation, the licensee asserts
that it had identified this problem and was addressing the concerns prior to
the NRC inspection. The NRC staff recognizes that Duke personnel had noted
concerns in this area in January 1986, which could be considered for mitigation
of the civil penalty. Because the violation has been withdrawn, consideration
of arguments for mitigation of the civil penalty is not necessary.
While the violation cited the licensee for not assuring the design basis
(which the NRC previously had assumed fully accounted for pump runout) was
correctly translated into specifications, drawings, procedures, and instructions,
it now appears that the licensee applied design control measures which were
commensurate with the original design. Although this original design had some
problems, given that planned hardware modifications will alleviate any further
problems in this area and the time that has passed, further enforcement action
on this matter is not warranted.
Enclosure
3
NRC Conclusion
The NRC concludes that the violation, as stated, did not occur. Therefore, the
violation has been deleted from our records, and the proposed civil penalty has
been withdrawn.
DEC 1 5
Duke Power Company
DISTRIBUTION:
SECY
CA
J. Taylor,DEDO
T. Martin, DEDRO
L. Chandler, OGC
J. Lieberman, OE
P. Milano, OE
J. N. Grace, RH
Enforcement Coordinators
RI, RII, RIII, RIV, RV
T. Murley, NRR
B. Hayes, 01
S. Connelly, OIA
E. Jordan, AEOD
F. Ingram, PA
Package delayed due to additional comnents.
RH
.
PMilano
LChandler
JNGrace
JLie erman
11/4/87
111//87
1l/3 /87
12
/87