ML063240383
| 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 INFORMATIONDOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARYINFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT ISDECONTROLLED.November 20, 2006EA-06-294
Duke Power Company, LLC d/b/a Duke Energy Carolinas, LLC (Duke)
ATTN:Mr. Bruce H. Hamilton Site Vice President
Oconee Nuclear Station7800 Rochester Highway
Seneca, SC 29672SUBJECT:OCONEE NUCLEAR STATION - NRC INSPECTION REPORT05000269/2006018, 05000270/2006018, AND 05000287/2006018;
PRELIMINARY GREATER THAN GREEN FINDINGDear Mr. Hamilton:
On June 30, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a quarterlyintegrated inspection at your Oconee Nuclear Station. The inspection findings weredocumented 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, whichconcerned 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 influentialassumptions, 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
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
Duke 2DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARYINFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT ISDECONTROLLED.have been available to perform their Emergency Core Cooling System (ECCS) recirculationfunction. 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 thenecessary 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, andSection 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 Exclusionand 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 NRC's website at
http://www.nrc.gov/reading-rm/adams.html
.In accordance with Inspection Manual Chapter (IMC) 0609, we intend to complete ourevaluation 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 staff's 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 yourreceipt 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.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
Duke 3DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARYINFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT ISDECONTROLLED.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 andyour response (if any) will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of 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/Charles Casto, DirectorDivision of Reactor Projects Docket Nos.: 50-269, 50-270, 50-287License Nos.: DPR-38, DPR-47, DPR-55 Enclosure: SDP Phase 3 Summary (OFFICIAL USE ONLY - PROPRIETARY INFORMATION)
cc w/encl: (See page 4)
_ML063240383 OFFICERII:DRPRII:DRPEICSSIGNATUREJHM /RA/WGR /RA/CFE /RA/NAMEJmoormanWrogersCEvansDATE11/20/200611/15/200611/16/2006
E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
Duke 4DOCUMENT TRANSMITTED HEREWITH CONTAINS OFFICIAL USE ONLY - PROPRIETARYINFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT ISDECONTROLLED.cc w/encl:B. G. Davenport
Compliance Manager (ONS)
Duke Power Company LLC
d/b/a Duke Energy Carolinas, LLC
Electronic Mail Distributioncc w/o encl
- Lisa F. Vaughn
Associate General Counsel
and Managing Attorney
Duke Energy Carolinas, LLC
526 South Church Street-EC 07H
Charlotte, NC 28202Kathryn B. NolanSenior Counsel
Duke Energy Carolinas, LLC
526 South Church Street -EC07H
Charlotte, NC 28202David A. RepkaWinston & Strawn LLP
Electronic Mail DistributionBeverly Hall, Chief RadiationProtection Section
N. C. Department of Environmental
Health & Natural Resources
Electronic Mail DistributionHenry J. Porter, Assistant DirectorDiv. of Radioactive Waste Mgmt.
S. C. Department of Health and
Environmental Control
Electronic Mail DistributionR. Mike GandyDivision of Radioactive Waste Mgmt.
S. C. Department of Health and
Environmental Control
Electronic Mail DistributionCounty Supervisor of Oconee County415 S. Pine StreetWalhalla, SC 29691-2145Lyle Graber, LISNUS Corporation
Electronic Mail DistributionR. L. Gill, Jr., ManagerNuclear Regulatory Issues
and Industry Affairs
Duke Power Company LLC.
d/b/a Duke Energy Carolinas, LLC
526 S. Church Street
Charlotte, NC 28201-0006Charles BrinkmanDirector, Washington Operations
Westinghouse Electric Company
12300 Twinbrook Parkway, Suite 330
Rockville, MD 20852Distribution w/encl: (See page 5)
OFFICIAL USE ONLY - PROPRIETARY INFORMATIONDuke5Letter to Bruce H. Hamilton from Charles Casto dated November 20, 2006SUBJECT:OCONEE NUCLEAR STATION - NRC INSPECTION REPORT05000269/2006018, 05000270/2006018, AND 05000287/2006018;
PRELIMINARY GREATER THAN GREEN FINDINGDistribution w/o encl
- L. Olshan, NRRC. Evans
L. Slack, RII EICS
OE Mail
RIDSNRRDIRS
PUBLIC