RA-21-0019, Reply to a Notice of Violation; EA-2021-004

Reply to a Notice of Violation; EA-2021-004

ML21050A439
Person / Time
Site:	Oconee
Issue date:	02/19/2021
From:	Burchfield J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-21-004, RA-21-0019
Download: ML21050A439 (4)

Text

£ ~ DUKE J. Ed Burchfield, Jr.

~ ENERGY Vice President Oconee Nuclear Station Duke Energy ONO/ VP/ 7800 Rochester Hwy Seneca, SC 29672 o: 864.873.3478

t. 864.873.4208 RA-21-0019 10 CFR 2.201 Ed.Burchfield@duke-energy.com February 19th, 2021 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287 Reply to a Notice of Violation; EA-2021-004

References:

1. NRC Letter to Duke Energy Carolinas, LLC, Oconee Nuclear Station - Design Basis Assurance Inspection {Teams) Inspection Report 05000269/202001 O and 05000270/202001 O and 05000287/202001 O and Notice of Violation, dated January 22, 2021 (ADAMS Accession No. ML21022A160)

The enclosure to this letter provides Duke Energy's reply to the Notice of Violation contained in the enclosure to Reference 1 letter (05000270, 05000287,05000269/2020010-02), dated January 22, 2021. The Notice of Violation was associated with the licensee's failure to perform all corrective actions identified to correct voltage calculations for safety-related 4160V circuit breaker 125Vdc control circuits and failure to perform all corrective actions to correct voltage calculations for safety-related 120Vac MCC control circuits.

There are no regulatory commitments contained in this submittal. If there are any questions, contact Sheila Dalton, Manager Nuclear Support Services, at 864-873-3657.

Sincerely, J. Ed Burchfield, Jr.

Vice President Oconee Nuclear Station

Enclosure:

Reply to a Notice of Violation; EA-21-004

RA-21-0019 February 19, 2021 Page 2 cc (with enclosure):

L. Dudes Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303 J. Nadel Senior Resident Inspector U.S. Nuclear Regulatory Commission Oconee Nuclear Station S. Williams NRG Project Manager (ONS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mailstop O-881A Rockville, MD 20852

Oconee Nuclear Station Reply to a Notice of Violation; EA-2021-004 1.0 Restatement of the Violation Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and non-conformances are promptly identified and corrected.

Contrary to the above, since June 27, 2014, the licensee failed to correct conditions adverse to quality. Specifically, the licensee (1) failed to correct voltage calculations for safety-related 4160V circuit breaker 125VDC control circuits and (2) failed to correct voltage calculations for safety-related 120VAC MCC control circuits.

This violation is associated with a Green Significance Determination Process (SOP) finding.

2.0 Reason for the Violation The failure to promptly correct conditions adverse to quality associated with the control voltage for 4160V breaker closing coils and MCC control circuits was documented in Condition Report (CR) 02343959.

The cause was determined to be that Engineering and Regulatory Affairs leadership did not exhibit sufficient intrusiveness to detect gaps in rigor and standard adherence in resolving NRC violations.

3.0 Corrective Steps That Have Been Taken and the Results Achieved The following corrective actions have been taken to ensure adequate control voltage for 4160VAC breaker closure and MCC control circuit during design basis events:

• Engineering Change 418190 was performed to ensure calculations for Safety-Related 4160V circuit breaker 125VDC control circuit support operation of the 4160V breaker close coil. (CR 02343949-01 completed on 10/5/2020)

• An extent of condition was performed to determine the use of test report TR-144 as the basis for allowing lower close coil voltages in other Oconee calculations. All applicable Oconee calculations have been updated to use test acceptance criteria sheets in lieu of TR-144. (CR 02343949-02 completed on 10/22/2020)

• The unit specific MCC contactor voltage adequacy and fuse adequacy verification calculations (5930, 6143, and 6144) have been revised to include the minimum required terminal voltage for the 600VAC RCMU pumps MCC control voltage during a design basis event. (CR 02343569-01 completed on 01/28/2021)

• Maintenance procedure IP/0/A/3011/016, Motor Control Center, Distribution Center, And Power Panelboard Preventative Maintenance, revision 014 was issued to test applicable MCC contactors at the manufacturer minimum voltage levels. (CR 02343569-02 completed on 10/20/2020).

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Oconee Nuclear Station Reply to a Notice of Violation; EA-2021-004 4.0 Corrective Steps That Will Be Taken No additional actions to be taken.

5.0 The Date When Full Compliance Will Be Achieved Full compliance with Appendix B to 10 CFR Part 50, Criterion XVI, Corrective Action, with respect to the examples cited in this violation, has been achieved by ONS on January 28, 2021.

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