ML063240383

NRC Inspection Report 05000269, 270, 287/2006018 Preliminary Greater than Green Finding - Attachments Removed

ML063240383
Person / Time
Site:	Oconee
Issue date:	11/20/2006
From:	Casto C Division Reactor Projects II
To:	Brandi Hamilton Duke Energy Carolinas, Duke Power Co
References
EA-06-294, IR-06-018
Download: ML063240383 (6)

See also: IR 05000269/2006018

Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

November 20, 2006

EA-06-294

Duke Power Company, LLC d/b/a

Duke Energy Carolinas, LLC (Duke)

ATTN: Mr. Bruce H. Hamilton

Site Vice President

Oconee Nuclear Station

7800 Rochester Highway

Seneca, SC 29672

SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT

05000269/2006018, 05000270/2006018, AND 05000287/2006018;

PRELIMINARY GREATER THAN GREEN FINDING

Dear Mr. Hamilton:

On June 30, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a quarterly

integrated inspection at your Oconee Nuclear Station. The inspection findings were

documented in NRC Inspection Report 05000269/2006003, 05000270/2006003, and

05000287/2006003, which was issued on July 28, 2006.

Section 1R15 of that report identified Unresolved Item (URI)05000287/2006003-03, which

concerned your identification of foreign material in the Unit 3, A and B train reactor building

emergency sump (RBES) suction lines during the Unit 3 end-of-cycle 22 refueling outage

(RFO). The related performance deficiency was identified as a failure to implement adequate

foreign material exclusion controls for the Unit 3 RBES. Although it is not known when the

apparent foreign material exclusion failure occurred, it is inherently certain that the

aforementioned foreign material/debris was in the Unit 3 RBES for at least the duration of cycle

22 [December 24, 2004 (Mode 4 towards startup) through April 29, 2006 (Mode 5 for the EOC

RFO)].

This finding was assessed based on the best available information, including influential

assumptions, using the applicable Significance Determination Process (SDP) and was

preliminarily determined to be a Greater Than Green Finding. Enclosed is a summary of the

SDP Phase 3 analysis. It reflects a finding of potentially greater than very low safety

significance because, in the event of a medium or large break loss of coolant accident (LOCA),

there was a lack of reasonable assurance that the low pressure injection (LPI) pumps would

DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY

INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS

DECONTROLLED.

Duke 2

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

have been available to perform their Emergency Core Cooling System (ECCS) recirculation

function. More specifically, supporting staff analysis indicated that the foreign material/debris

found in both RBES suction trains could move downstream during the sump recirculation mode

of medium break and large break LOCA scenarios; thereby, potentially damaging the 3A and

3B LPI pumps. Consideration of the 3C LPI pump as a backup success path to achieve the

necessary ECCS recirculation function was based upon the uncertainties surrounding its

viability (i.e., deteriorative atmospheric conditions and flooding resulting from a damage-

induced seal failure on the 3B LPI pump, test and maintenance situations, and random

failures). The finding does not represent a current safety concern because the foreign

material/debris was removed upon discovery.

The finding is also an apparent violation (AV) of Technical Specification 5.4.1, Procedures, and

Section 9.e of referenced Regulatory Guide 1.33 for the failure to comply with Nuclear System

Directive (NSD) 104, Material Condition/Housekeeping, Cleanliness/Foreign Material Exclusion

and Seismic Concerns, by not maintaining the Unit 3 RBES free of foreign material. This

apparent violation (identified as AV 05000287/2006018-01: Inadequate Foreign Material

Exclusion Controls for the Unit 3, A and B Train Reactor Building Emergency Sump Suction

Lines) is being considered for escalated enforcement action in accordance with the NRC

Enforcement Policy. Accordingly, for administrative purposes, URI 05000287/2006003-03 is

considered closed. The current Enforcement Policy is included on the NRCs website at

http://www.nrc.gov/reading-rm/adams.html.

In accordance with Inspection Manual Chapter (IMC) 0609, we intend to complete our

evaluation using the best available information and issue our final determination of safety

significance within 90 days of this letter. The significance determination process encourages

an open dialogue between the staff and the licensee; however, the dialogue should not impact

the timeliness of the staffs final determination. Before we make a final decision on this matter,

we are providing you an opportunity to: (1) present to the NRC your perspectives on the facts

and assumptions used by the NRC to arrive at the finding and its significance at a Regulatory

Conference or (2) submit your position on the finding to the NRC in writing. If you request a

Regulatory Conference, it should be held within 30 days of the receipt of this letter and we

encourage you to submit supporting documentation at least 1 week prior to the conference in

an effort to make the conference more efficient and effective. If a Regulatory Conference is

held, it will be open for public observation. The NRC will also issue a press release to

announce the conference. If you decide to submit only a written response, such a submittal

should be sent to the NRC within 30 days of the receipt of this letter.

Please contact Mr. Jim Moorman at (404) 562-4647 within 10 business days of the date of your

receipt of this letter to notify the NRC of your intentions. If we have not heard from you within

10 days, we will continue with our significance determination and enforcement decisions and

you will be advised by separate correspondence of the results of our deliberations on this

matter.

DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY

INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS

DECONTROLLED.

Duke 3

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Since the NRC has not made a final determination in this matter, a Notice of Violation is not

being issued at this time. In addition, please be advised that the number and characterization

of the apparent violations may change as a result of further NRC review.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

your response (if any) will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRCs

document system (ADAMS). ADAMS is accessible from the NRC web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Charles Casto, Director

Division of Reactor Projects

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

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

Enclosure:

SDP Phase 3 Summary (OFFICIAL USE ONLY - PROPRIETARY INFORMATION)

cc w/encl: (See page 4)

DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY

INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS

DECONTROLLED.

_ML063240383

OFFICE RII:DRP RII:DRP EICS

SIGNATURE JHM /RA/ WGR /RA/ CFE /RA/

NAME Jmoorman Wrogers CEvans

DATE 11/20/2006 11/15/2006 11/16/2006

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

Duke 4

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cc w/encl:

B. G. Davenport 415 S. Pine Street

Compliance Manager (ONS) Walhalla, SC 29691-2145

Duke Power Company LLC

d/b/a Duke Energy Carolinas, LLC

Electronic Mail Distribution Lyle Graber, LIS

NUS Corporation

cc w/o encl: Electronic Mail Distribution

Lisa F. Vaughn

Associate General Counsel R. L. Gill, Jr., Manager

and Managing Attorney Nuclear Regulatory Issues

Duke Energy Carolinas, LLC and Industry Affairs

526 South Church Street-EC 07H Duke Power Company LLC.

Charlotte, NC 28202 d/b/a Duke Energy Carolinas, LLC

526 S. Church Street

Kathryn B. Nolan Charlotte, NC 28201-0006

Senior Counsel

Duke Energy Carolinas, LLC Charles Brinkman

526 South Church Street -EC07H Director, Washington Operations

Charlotte, NC 28202 Westinghouse Electric Company

12300 Twinbrook Parkway, Suite 330

David A. Repka Rockville, MD 20852

Winston & Strawn LLP

Electronic Mail Distribution Distribution w/encl: (See page 5)

Beverly Hall, Chief Radiation

Protection Section

N. C. Department of Environmental

Health & Natural Resources

Electronic Mail Distribution

Henry J. Porter, Assistant Director

Div. of Radioactive Waste Mgmt.

S. C. Department of Health and

Environmental Control

Electronic Mail Distribution

R. Mike Gandy

Division of Radioactive Waste Mgmt.

S. C. Department of Health and

Environmental Control

Electronic Mail Distribution

County Supervisor of

Oconee County

DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARY

INFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT IS

DECONTROLLED.

Duke 5

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

Letter to Bruce H. Hamilton from Charles Casto dated November 20, 2006

SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT

05000269/2006018, 05000270/2006018, AND 05000287/2006018;

PRELIMINARY GREATER THAN GREEN FINDING

Distribution w/o encl:

L. Olshan, NRR

C. Evans

L. Slack, RII EICS

OE Mail

RIDSNRRDIRS

PUBLIC