ML20207T538

Discusses Functional Insp Repts 50-269/86-16,50-270/86-16 & 50-287/86-16 on 860505-0611 & Proposed Imposition of Civil Penalties in Amount of $25,000

ML20207T538
Person / Time
Site:	Oconee
Issue date:	03/12/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
Shared Package
ML20207T539	List: ML20207T538 ML20207T543
References
EA-87-014, EA-87-14, IEB-80-04, IEB-80-4, NUDOCS 8703240111
Download: ML20207T538 (3)

See also: IR 05000269/1986016

Text

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MAR 121987

Docket Nos. 50-269, 50-270, and 50-287

License Nos. DPR-38, DPR-47, and DPR-55

EA 87-14

Dyke Power Company

DATTN: Mr. H. R. Tucker, Vice President

Nuclear Production Department

422 South Church Street

Charlotte, NC 28242

Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

(INSPECTION REPORT NOS. 50-269/86-16, 50-270/86-16, AND 50-287/86-16)

This refers to the Nuclear Regulatory Commission (NRC) Safety System Functional

Inspection conducted at the Oconee facility on May 5 - June 11, 1986. The report

documenting this inspection was sent to you with a letter dated August 1, 1986.

'As a result.of this inspection, significant failures to comply with NRC regula-

tory requirements were identified, and accordingly, NRC concerns relative to the

inspection findings were discussed by Dr. J. N. Grace, Regional Administrator,

NRC, Region II, with you and members of your staff in an Enforcement Conference

held on December 22, 1986.

Violation I described in the enclosed Notice of Violation and Proposed Imposition

of Civil Penalty involved a failure to provide adequate design control and as a

result, the motor driven emergency feedwater (EFW) pumps were susceptible to

runout and inadequate net positive suction head when the pumps were operated in

anticipated design conditions. The events that resulted in the pump runout ,

problem were initially identified when Duke Power Company advised the NRC in a -

May 7, 1980, response to IE Bulletin 80-04, that emergency feedwater runout was

not explicitly addressed by their analysis and that the level control system

would be used to mitigate the transient. Duke Power Company training personnel

had also noted that the Oconee simulator was modeling undesirably high emergency

feedwater flow rates, and calculations concerning emergency feedwater flow

capacity were initiated in January 1986. The NRC is concerned that an adequate

design analysis for pump runout had not been previously performed and that

emergency feedwater pump runout could occur during normal emergency feedwater

actuation if the flow control valves stayed fully open. Under certain design

basis transients, the runout condition would require immediate operator action

to preclude damage to the pumps and the potential loss of EFW function.

To emphasize the need to assure that equipment is installed to fulfill the

regulatory requirements, I have been authorized, after consultation with the

Director, Office of Inspection and Enforcement, to issue the enclosed Notice

of Violation and Proposed Imposition of Civil Penalty in the amount of

Twenty-Five Thousand Dollars ($25,000) for the violation described in the

enclosed Notice. In accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1986)

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LDuke Power Company- -2- MAR .1 21987 .

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(knforcementPolicy),ViolationIdescribedintheenclosedNoticehas'been

_ categorized as a Severity Level III. violation. The base value of a civil

_ penalty for a Severity Level III violation is $50,000. The NRC Enforcement

x Policy allows for reduction of a civil penalty under'certain circumstances.

In this case, the base civil penalty amount has been reduced by 50 percent

because of your unusually prompt and extensive corrective actions to prevent

recurrence..

Your unusually prompt and extensive corrective actions to preclude recurrence

of'the design control deficiencies is acknowledged. Also, your short term

corrective actions for the specific problem concerning EFW pump runout and

-loss of net positive suction head is considered adequate taking_into account

your other systems which could be utilized and your extensive operator training.

However, we have concerns about the schedule for your long term corrective

actions. Therefore, your response to the violation should include an enhanced

schedule for your long term corrective actions for hardware changes which

would eliminate the need for immediate operator actions to preclude damage to

the EFW pumps during certain design basis transients.

The violations in Section II in the enclosed Notice involved a failure to provide

adequate procedures which resulted in inadequate control of motor-operated valve

torque switch and limit switch settings and a failure to provide control over

implementation of design changes for the Keowee station battery racks. Because

these violations involve issues of lesser safety significance, they have been

categorized as Severity Level IV violations.

In addition to the need for corrective action regarding the specific matters

identified in the enclosed Notice, we are concerned about the implementation of

your management control system that permitted this situation to develop.

Consequently, your response should describe those particular actions taken or

planned to improve the effectiveness of your program. The violation for inade-

quate designs and implementation of design also caused the design bases of the

equipment not to be translated into adequate operational procedures. Therefore,

please address what additional measures your staff has identified to improve your

management system which controls and encourages communications between the site

and design engineering.

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 prevent recurrence. After reviewing your response to this Notice,

including your proposed corrective actions and the results of future inspections,

the NRC will detennine whether further NRC enforcement action is necessary to

ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC Public Document Room.

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Duke' Power Company -3- MAR 121987

The responses directed by this letter and its enclosure are not subject to the

clearance procedures of the Office of Management and Budget as required by the

Paperwork Reduction Act of 1980, PL 96-511.

Sincerely.

Original signed by A. Gibson

J. Nelson Grace

Regional Administrator

Enclosure:

Notice of Violation and Proposed

Imposition of Civil Penalty

cc w/ enc 1:

LM, S. Tuckman, Station Manager

cle

g.-J. 0. Callan,SectionChief,IE

Martin, Reactor Inspector, IE

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