IR 05000269/1986016

Discusses Functional Insp Repts 50-269/86-16,50-270/86-16 & 50-287/86-16 on 860505-0611 & Proposed Imposition of Civil Penalties in Amount of $25,000

ML20207T538
Person / Time
Site:	Oconee
Issue date:	03/12/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
Shared Package
ML20207T539	List: ML20207T538 ML20207T543
References
EA-87-014, EA-87-14, IEB-80-04, IEB-80-4, NUDOCS 8703240111
Download: ML20207T538 (3)

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MAR 121987 Docket Nos. 50-269, 50-270, and 50-287 License Nos. DPR-38, DPR-47, and DPR-55 EA 87-14 Dyke Power Company DATTN: Mr. H. R. Tucker, Vice President Nuclear Production Department 422 South Church Street Charlotte, NC 28242 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (INSPECTION REPORT NOS. 50-269/86-16, 50-270/86-16, AND 50-287/86-16)

This refers to the Nuclear Regulatory Commission (NRC) Safety System Functional Inspection conducted at the Oconee facility on May 5 - June 11, 1986. The report documenting this inspection was sent to you with a letter dated August 1, 198 'As a result.of this inspection, significant failures to comply with NRC regula-tory requirements were identified, and accordingly, NRC concerns relative to the inspection findings were discussed by Dr. J. N. Grace, Regional Administrator, NRC, Region II, with you and members of your staff in an Enforcement Conference held on December 22, 198 Violation I described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty involved a failure to provide adequate design control and as a result, the motor driven emergency feedwater (EFW) pumps were susceptible to runout and inadequate net positive suction head when the pumps were operated in anticipated design conditions. The events that resulted in the pump runout ,

problem were initially identified when Duke Power Company advised the NRC in a -

May 7, 1980, response to IE Bulletin 80-04, that emergency feedwater runout was not explicitly addressed by their analysis and that the level control system would be used to mitigate the transient. Duke Power Company training personnel had also noted that the Oconee simulator was modeling undesirably high emergency feedwater flow rates, and calculations concerning emergency feedwater flow capacity were initiated in January 1986. The NRC is concerned that an adequate design analysis for pump runout had not been previously performed and that emergency feedwater pump runout could occur during normal emergency feedwater actuation if the flow control valves stayed fully open. Under certain design basis transients, the runout condition would require immediate operator action to preclude damage to the pumps and the potential loss of EFW functio To emphasize the need to assure that equipment is installed to fulfill the regulatory requirements, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-Five Thousand Dollars ($25,000) for the violation described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1986)

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LDuke Power Company- -2- MAR .1 21987 .

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(knforcementPolicy),ViolationIdescribedintheenclosedNoticehas'been

_ categorized as a Severity Level III. violation. The base value of a civil

_ penalty for a Severity Level III violation is $50,000. The NRC Enforcement x Policy allows for reduction of a civil penalty under'certain circumstance In this case, the base civil penalty amount has been reduced by 50 percent because of your unusually prompt and extensive corrective actions to prevent recurrenc Your unusually prompt and extensive corrective actions to preclude recurrence of'the design control deficiencies is acknowledged. Also, your short term corrective actions for the specific problem concerning EFW pump runout and-loss of net positive suction head is considered adequate taking_into account your other systems which could be utilized and your extensive operator trainin However, we have concerns about the schedule for your long term corrective actions. Therefore, your response to the violation should include an enhanced schedule for your long term corrective actions for hardware changes which would eliminate the need for immediate operator actions to preclude damage to the EFW pumps during certain design basis transient The violations in Section II in the enclosed Notice involved a failure to provide adequate procedures which resulted in inadequate control of motor-operated valve torque switch and limit switch settings and a failure to provide control over implementation of design changes for the Keowee station battery racks. Because these violations involve issues of lesser safety significance, they have been categorized as Severity Level IV violation In addition to the need for corrective action regarding the specific matters identified in the enclosed Notice, we are concerned about the implementation of your management control system that permitted this situation to develo Consequently, your response should describe those particular actions taken or planned to improve the effectiveness of your program. The violation for inade-quate designs and implementation of design also caused the design bases of the equipment not to be translated into adequate operational procedures. Therefore, please address what additional measures your staff has identified to improve your management system which controls and encourages communications between the site and design engineerin You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will detennine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo *

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Duke' Power Company -3- MAR 121987 The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 Sincerel Original signed by A. Gibson J. Nelson Grace Regional Administrator Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enc 1:

LM, S. Tuckman, Station Manager cle g.- . Callan,SectionChief,IE Martin, Reactor Inspector, IE

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