ML20246L086
| ML20246L086 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/08/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905180231 | |
| Download: ML20246L086 (3) | |
Text
-.
11 l
. Duke ibuer Company IIA 1.11 Taer
. PO Box.U198 Vice l'resulent Charlotte, NC 28242 Nuclear hoduction (70I)373 4531 i
' DUKE POWER May 8, 1989 Director, Office of Enforcement' U. S. Nuclear Regulatory Commission '
Washington, DC 20555 Attention:
Document Control Desk
Subject:
Oconee Nuclear Station
' Doc. Nos; 50-269, -270, -287 Inspection Report Nos. 50-269/88-35, 50-270/88-35, 50-287/88-35 Reply to Notice of Violation
.By a letter from S. D. Ebneter dated April 11, 1989, the NRC transmitted to me a notice of violation and proposed imposition of Civil penalty for a violation reported in NRC Inspection Report 50-269/88-35, 50-270/88-35, and 50-287/88-35.
In accordance with the provisions of 10CFR 2.201, I am-submitting e check for the amount of twenty-five thousand dollars
($25,000.00) as payment for the civil penalty proposed.
.. I declare under penalty of perjury that the statements setforth herein are true and correct to.the best of my knowledge.
Very truly yours, sM~
Hal B. Tucker PFG/50/td C
. Attachment cc: Mr. S. D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, GA 30323 Mr. P. H. Skinner NRC Resident Inspector Oconee Nuclear Station Mr. D. B. Matthews 90 Office of Nuclear Regulation
(,0 p)pt/f U. S. Nuclear Regulatory Commission p
l Washington, DC 20555 L
8905180231 890508
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Duke power Company Oconee Nuclear Station Reply to Notice of Violation VIOLATION Technical Specification (TS) 3.3.5b(1) requires when'the Reactor Coolant System (RCS) with fuel in the core is in a condition with pressure equal to or greater than 350 psig or temperature equal to er greater than 250 degrees F and subcritical that two independent reactor building cooling (RBC) trains, each comprised of a RBC fan, cooling unit and associated Engineered Safety Features (ESF) valves shall be operable.
TS 3.3.5c(1) requires that when the reactor is critical, in addition to the above requirements, the remaining RBC fan, associated cooling unit and ESF valves shall be operable.
4 Contrary to the above, it was discovered on January 7,1989, that all of the fusible linked dropout plates on the Reactor Building Cooling Unit (RBCU) ductwork would not perform their intended function if required.
The units had each operated, cince licensing, in all operational conditions with the plates inoperable.
Under certain analyzed accident conditions, the failure of these plates to drop free of the ductwork would render the RBC system inoperable.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $25,000
RESPONSE
(1) Admission or Denial of the Violation:
The violation is admitted and is correct as stated. The violation was previously reported at LER 269/89-03.
(2) The Reasons for the Violation if Admitted:
The reason for this violation was due to a failure to perform a preoperational functional verification test nf the RBCU dropout plates.
If such a test had been performed, the interference caused by the adjacent structural steel would have been discovered prior to I
reactor operation.
In addition a periodic post-operational i
surveillance program for the RBCU dropout plates was not required or performed.
If periodic surveillance of the RBCU dropout plates had been performed, problems associated with plate adherence to the ductwork would have been discovered or prevented.
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..., c (3) The Corrective Steps That Have Been Taken and The Results Achieved:
The immediate corrective action taken was to declare the RBCU coolers for Units 1, 2, and 3 inoperable. This resulted in all three units being under the provisions of technical specification 3.0, which requires the affected unit to be placed in a hot shutdown condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a cold shutdown condition within another 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
A safety evaluation consistent with the requirements of 10 CFR 50.59 was performed by Design Engineering which determined that there were no unreviewed safety questions involved if the fusible dropout plates were removed while the unit was operating. Accordingly, the dropout plates for all three reactors were removed thereby establishing the necessary flow path required during an accident.
All three Unit 1 RBCU fusible dropout plates have been redesigned, re-installed and successfully tested. A similar design to the Unit 1 design has been prepared and issued by Design Engineering to the station for implementation on Units 2 and 3.
This will ensure that the RBCU dropout plates will properly drop away from the ductwork thereby providing an exhaust path, thus fulfilling its safety related function.
(4) The Corrective Steps Which Will be Taken to Avoid Further Violations:
Install and test the redesigned RBCU fusible dropout plates on all three RBCU's for Units 2 and 3.
Upon reinstallation of the plates a periodic functional test on the RBCU dropout plates will be performed at a frequency suitable to ensure plate operability, as we'll as preventive maintenance.
(5) The Date When Full Compliance Will be Achieved:
A redesigned RBCU fusible dropout plate will be installed and tested, for both Units 2 and 3 during their next refueling outages.
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