IR 05000269/2012010

IR 05000269-12-010; Duke Energy Carolinas, LLC; 11/5-9/2012; Oconee Nuclear Station Unit 1, NRC Post-Approval Site Inspection for License Renewal, Inspection Report

ML12335A243
Person / Time
Site:	Oconee
Issue date:	11/29/2012
From:	Vias S NRC/RGN-II/DRS/EB3
To:	Gillespie T Duke Energy Corp
References
IR-12-010
Download: ML12335A243 (16)

Text

UNITED STATES ber 29, 2012

SUBJECT:

OCONEE NUCLEAR STATION UNIT 1 - NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL, INSPECTION REPORT 05000269/2012010

Dear Mr. Gillespie,

Jr.:

On November 9, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-Approval Site Inspection for License Renewal at your Oconee Nuclear Station, Unit 1. The enclosed report documents the inspection results, which were discussed on November 8, 2012, with members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings were identified.

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

T. Preston Gillespie, Jr. 2 NRC's 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/

Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-269 License Nos. DPR-38

Enclosure:

NRC Post Approval Site Inspection For License Renewal, Inspection Report 05000269/2012010 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-269 License Nos: DPR-38 Report No: 05000269/2012010 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station, Unit 1 Location: Seneca, SC 29672 Dates: November 5 - 9, 2012 Inspectors: Robert Williams Jr., Reactor Inspector Approved by: Steven J. Vias, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000269/2012010; November 5 - 9, 2012; Oconee Nuclear Station Unit 1; Post Approval

Site Inspection for License Renewal The report covers an inspection conducted by regional inspectors in accordance with NRC Manual Chapter 2516 and NRC Inspection Procedure 71003.

Based on the sample selected for review, the inspectors determined that commitments, license conditions, and regulatory requirements associated with the renewed facility operating license were either being met or, where commitment actions had not been completed, the licensee had administrative controls in place to ensure completion before the period of extended operation.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings None

Licensee-Identified Violations

None

REPORT DETAILS

4OA5 Other Activities: Post-Approval Site Inspection for License Renewal (Phase 1)

.1 Implementation of License Conditions and Commitments, including Aging Management

Programs (AMP)

a. Inspection Scope

The inspectors reviewed a sample of license renewal activities scheduled for the Unit 1 Fall 2012 refueling outage, which was the last outage before the beginning of the period of extended operation (PEO). The inspectors selected this refueling outage because it would present the best opportunity to observe the majority of the one-time inspections associated with license renewal commitments. The objective of this inspection was to maximize observations of the actual implementation of license renewal activities before the beginning of the PEO (February 6, 2013), and to verify that the licensee completed the necessary actions to:

(a) comply with the conditions stipulated in the renewed facility operating license,

(b) meet the license renewal commitments described in NRC Memorandum dated March 6, 2007 (ADAMS Accession Number ML070640041), and (c)meet the future inspection activities described in the Updated Final Safety Analysis Report (UFSAR) supplement submitted pursuant to 10 CFR 54.21(d). The previous Phase 2 implementation of inspection procedure 71003 was completed on August 23, 2012 and is publicly available on ADAMS under accession number ML12277A420. The license renewal application (LRA) for Oconee Nuclear Station, Units 1, 2 and 3 and the corresponding NRC Safety Evaluation Report (SER) documented in NUREG-1723 are publicly available on ADAMS under accession numbers ML003692763 and ML003695154, respectively.

The inspectors reviewed supporting documents; conducted interviews with licensee staff; observed in-process outage activities; and performed visual inspection of structures, systems, and components (SSCs) including those not accessible during power operation. The specific inspection activities conducted for each AMP are also described below. Specific documents reviewed are listed in the report attachment.

ONS Calculation 4.5 - Coatings Program: This AMP specified that, continuing through the period of extended operation, the Coatings Program would ensure that the coatings inside the reactor building to protect the containment liner plate, hatches and penetrations would be effectively managed against loss of material due to corrosion.

The Coatings Program provides controls for selection, procurement, surface preparation, application, and testing of Service Level l coatings. The program also requires visual inspection of accessible coatings inside the Reactor Building, every refueling outage to detect coating degradations, including rusting, blistering, crazing, and peeling.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, applicable condition reports, and work orders regarding these documents to verify that the program had been implemented as described in the license renewal application. The inspectors verified that the licensee developed procedures and conducted inspections as described in the Program Basis Document and the UFSAR.

The inspectors also verified that the inspections were appropriately scheduled and tracked to meet the required inspection period. Additionally, the inspectors directly observed the implementation of a coatings repair in the U1 reactor building to verify that essential variables such as surface preparation and coating application were performed in accordance with the license renewal commitment.

Based on the review of licensee actions completed at the time of this inspection, the timeliness of those actions, and the administrative controls in place to track pending tasks, the inspectors determined that there was reasonable assurance that the licensee would manage the aging effects associated with the Coatings Program and continue it during the PEO.

ONS Calculation 4.18.1 & 4.18.2 - Fire Protection Program: This AMP specified that the existing Fire Protection Program would be credited to ensure that the licensing basis would continue to be met for the Fire Water System, Fire Hydrants, Fire Barriers and Fire Detection System. Section 18.3.17.8 of the UFSAR supplement for license renewal stated that the Fire Hydrant Flow Tests would be managed by the Fire Protection Program and the Problem Investigation Process. The other portions of the Fire Protection Program were not explicitly identified in the UFSAR supplement, but were all covered within UFSAR Section 9.5.1 under the Fire Protection Program.

During the Phase 2 implementation of inspection procedure 71003, an observation was made that, the Acceptance Criteria or Standard subsection of Section 4.16.1.1 of the LRA, Program Description, stated For fire barrier penetration seals, no visual indication of cracking, separation from wall, separation of layers of material, holes and ruptures or puncture of seal. The inspectors identified that the implementing procedure for the Fire Barrier inspection utilized a 1/8 crack as an acceptance criterion, contrary to the statement in the Commitment. This issue was entered into the licensees corrective action program as PIP O-12-09426. At the time of this current inspection, the licensee was implementing the corrective actions detailed in PIP O-12-09426 including developing a license renewal commitment change that would align the acceptance criteria listed in the commitment with those currently in use in the implementing procedure. This would have both the implementing procedure as well as the commitment detail an acceptance criterion of a 1/8 crack.

Based on the review of licensee actions completed at the time of this inspection, the timeliness of those actions, and the administrative controls in place to track pending tasks, the inspectors determined that there was reasonable assurance that the licensee would manage the aging effects associated with the Fire Protection Program and continue it during the PEO.

ONS Calculation 4.32.14 - Standby Shutdown Facility Diesel Fuel Oil Tank Inspection:

The Standby Shutdown Facility (SSF) Diesel Fuel Oil Tank Inspection Program is an aging management program that monitors the loss of tank material due to corrosion.

The licensee implemented this program as a preventive maintenance activity that inspects the tank at a frequency of every ten years. An SSF diesel fuel oil tank inspection was performed in August of 2012 to meet a commitment made to the NRC and provide reasonable assurance that the existing inspection program was adequate to manage the aging effects of Microbiologically Induced Corrosion (MIC).

During the Phase 2 implementation of inspection procedure 71003, an observation was made that the SSF diesel fuel oil tank inspection performed in August of 2012 identified 9 locations of through-wall pitting due to MIC at elevations ranging from 790 ft to 786 ft.

The corrosion in these areas was removed and the tank was repaired in accordance with requirements of the licensees repair/replacement program, ASME Section XI, and ASME Section III, which was the construction code of the tank. Due to the close proximity in time of the SSF diesel fuel oil tank inspection and the license renewal Phase 2 inspection, the licensee had not completed the engineering evaluations which were needed for the NRC inspectors to complete their review. This issue was entered into the licensees corrective action program as PIP O-12-9334. At the time of this current inspection, the licensee was implementing the corrective actions detailed in PIP O-12-09334 including successfully performing post maintenance testing on the repairs made and changing the SSF diesel fuel oil tank inspection frequency from once every ten years to, initially, once every 2 years. The results of the future inspections will be evaluated to determine if the increased inspection frequency is still valid.

Based on the review of licensee actions completed at the time of this inspection, the timeliness of those actions, and the administrative controls in place to track pending tasks, the inspectors determined that there was reasonable assurance that the licensee would manage the aging effects associated with the SSF Diesel Oil Fuel Tank and continue it during the PEO.

ONS Calculation 4.41 And 4.42 - Reactor Vessel Internals Program [NRC Memorandum Commitment No. 11]: On June 16, 2010, Duke sent a letter of intent to adopt Material Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, (MRP-227-A). On November 8, 2010, Duke Energy submitted LAR 2010-06. In that submittal, Duke Energy requested that the NRC review and approve a Reactor Vessel (RV) Internals inspection plan based on Materials Reliability Program:

Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-Rev.0). The MRP-227 guidance was a proposed industry approach to manage aging of the reactor vessel internal materials and it had been submitted to the NRC for review and approval through the Nuclear Energy Institute in January 2009. The licensees letter of intent to adopt MRP-227 represented a change to the approach described in the original commitment to manage aging of the reactor vessel internals.

Following the Dukes LAR submittal, the NRC issued NRC Regulatory Issue Summary (RIS) 2011-07 License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management dated July 21, 2011, to provide guidance to the utilities pending the issuance of MRP-227-A. On December 16, 2011, the NRC issued Revision 1 of the Safety Evaluation Report to incorporate technical changes required to ensure the final approved version of MRP-227 (i.e. MRP-227-A) included all NRC required changes. On June 28, 2012, Duke Energy submitted LAR 2010-06 - Supplement 1 which included a revised inspection plan and a commitment change request. The commitment change request was associated with the anticipated delayed completion dates required by Licensee Action Items 2, 4, 6, and 7 from revision 1 of the SER for MRP-227, Revision 0. At the time of this current inspection the licensee had completed the majority of the items required to implement MRP-227-A; however, the outstanding items (licensee action items 6 and 7) will not be completed prior to entering the PEO, but are currently being tracked by the licensees corrective action program.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, applicable condition reports, and work orders regarding these documents to verify that this program was implemented in accordance with the revised commitment as described in the letter submitted to the NRC on June 28, 2012. Additionally, the inspectors observed (either by direct observation or video review) the sample listed below for portions of the visual (VT) and ultrasonic (UT) examinations to verify that essential attributes such as calibration, equipment configuration, and disposition of indications were performed in accordance with the revised license renewal commitment.

• UT examination of the lower core barrel bolting

• UT examination of the flow distributor bolting

• VT examination of the core barrel inside diameter

• VT examination of the SUSI baffle bolting

• VT examination of the lower core barrel bolting

• VT examination of the flow distributor bolting Based on the review of licensee actions completed at the time of this inspection, the timeliness of those actions, and the administrative controls in place to track pending tasks, the inspectors determined that there was reasonable assurance that the licensee would manage the aging effects associated with the Reactor Vessel Internals Program and continue it during the PEO.

b. Findings and Observations

No findings or observations were identified

.2 License Renewal Commitment Changes

The review of license renewal commitment changes pursuant to the guidance in NEI 99-04, Guidelines for Managing NRC Commitment Changes, was completed during the Phase 2 implementation of inspection procedure 71003.

.3 Newly Identified SSCs

The review of newly identified SSCs pursuant 10 CFR 54.37(b) was completed during the Phase 2 implementation of inspection procedure 71003.

.4 Description of AMPs and Time-Limited Aging Analyses (TLAAs) in the UFSAR

Supplement The review of the description of AMPs and TLAAs in the UFSAR supplement submitted pursuant 10 CFR 54.21(d) was completed during the Phase 2 implementation of inspection procedure 71003.

.5 Operating Experience

The review of licensee actions to address recent industry operating experience and its applicability to the existing Aging Management Programs was completed during the Phase 2 implementation of inspection procedure 71003.

4OA6 Management Meetings

.1 Exit Meeting Summary

On November 8, 2012, the inspectors presented the inspection results to members of the licensee management staff. The licensee acknowledged the inspection results. The inspectors confirmed that all proprietary information reviewed during the inspection was returned to the licensee and that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Smith, Licensing Administrator

H. Galloway, License Renewal Program Owner

S. Perry, Regulatory Affairs

E. Swanson, License Renewal Lead

NRC

S. Vias, Chief, Engineering Branch 3

LIST OF REPORT ITEMS

Opened

None

Closed

None

Discussed

None