IR 05000269/2011016

IR 05000269-11-016, 05000270-11-016 and 05000287-11-016, on 03/15/2011 - 05/19/2011, Oconee Nuclear Station Units 1, 2, and 3, Radioactive Gaseous and Liquid Effluent Treatment

ML111751823
Person / Time
Site:	Oconee
Issue date:	06/23/2011
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Gillespie T Duke Energy Carolinas
References
Download: ML111751823 (11)

Text

UNITED STATES une 23, 2011

SUBJECT:

OCONEE NUCLEAR STATION - NRC INSPECTION REPORT 05000269/2011016, 05000270/2011016 AND 05000287/2011016

Dear Mr. Gillespie:

On May 19, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of your Oconee Nuclear Station Units 1, 2 and 3. The enclosed inspection report documents the inspection results which were discussed on May 23, 2011, with you and other 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.

The report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating the violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest the NCV, you should provide a response within 30 days of the date of this inspection report with the basis for your denial to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region 2; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 2055-0001; and the NRC Resident Inspector at Oconee Nuclear Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report with the basis for your disagreement, to the Regional Administrator, Region 2, and the NRC Resident Inspector at Oconee Nuclear Station.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the

DPC 2 NRC Public Document Room of from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-269, 50-270, 50-287 License Nos: DPR-38, DPR-47, DPR-55

Enclosure:

Inspection Report 05000269/2011016, 05000270/2011016 and 05000287/2011016

REGION II==

Docket Nos: 05000269, 05000270, and 05000287 License Nos: DPR-38, DPR-47, DPR-55 Report Nos: 05000269/2011016, 05000270/2011016, and 05000287/2011016 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station, Units 1, 2, and 3 Location: Seneca, SC 29672 Dates: March 15, 2011, through May 19, 2011 Inspectors: R. Hamilton, Sr. Health Physicist (Section 2RS6)

Approved by: Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000269/2011016, 05000270/2011016 and 05000287/2011016; 03/15/2011 - 05/19/2011;

Oconee Nuclear Station Units 1, 2, and 3; Radioactive Gaseous and Liquid Effluent Treatment The report covers the inspection and closure of an Unresolved Item. One non-cited violation was identified. The significance of most findings is identified by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP); the cross-cutting aspect was determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. 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.

Cornerstone: Mitigating Systems

• Green: An NRC-identified Non-Cited Violation (NCV) of Technical Specification 5.4.1.d, for failure to follow procedures NSD 513, Primary to Secondary Leak Monitoring Program, and OP/0/A/1106/031, Primary to Secondary Leak Rate Monitoring and Instrumentation, which required compensatory actions and compensatory sampling during certain times when RIA-40 (Condenser Off-Gas Radiation Monitor) was out of service. This violation was entered into the licensees corrective action program under PIP O-10-06151.

The failure to recognize that the condenser off-gas radiation monitors were inoperable was a performance deficiency. This performance deficiency is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective in that the capability to detect, quantify, and respond to primary to secondary leakage was degraded. The inspectors evaluated the significance of this finding using inspection Manual Chapter 0609.04, Phase 1-Initial Screening and Characterization of Findings, and determined this finding was of very low safety significance (Green) because the finding did not result in a loss of safety function.

This finding had a cross-cutting aspect in the area of Problem Identification and Resolution under the Corrective Action Program component because the licensee failed to recognize that 1, 2 RIA-40 were inoperable, and to take appropriate corrective actions to address the issue in a comprehensive manner commensurate with its safety significance and complexity

[P.1 (d)] (Section 2RS6).

REPORT DETAILS

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

(Closed) Unresolved Item (URI) 05000269, 270 and 287/2010004-2 Potential Inoperability of Condenser Off-Gas Radiation Monitors

a. Inspection Scope

As documented in NRC IR 2010004, the inspectors identified a potential inoperability of 1 and 2 RIA-40, Condenser Off-Gas Radiation Monitors, in that the flow indicator sight glass downstream and physically above each of the monitors detector chambers contained water. The inspectors opened an Unresolved Item for this issue pending the licensees evaluation of the basis for operability of these detectors, and the ability of the monitors to adequately respond to a primary to secondary leaks. This inspection was conducted to evaluate the results of the licensees evaluation and other pertinent licensee documentation.

b. Findings

Introduction:

An NRC-identified Green NCV of Technical Specification 5.4.1.d, was identified for the failure to follow procedures NSD 513, Primary to Secondary Leak Monitoring Program, and OP/0/A/1106/031, Primary to Secondary Leak Rate Monitoring and Instrumentation, which required compensatory actions and compensatory sampling during certain times when RIA-40 (Condenser Off-Gas Radiation Monitor) was out of service.

Description:

The licensee performed an operability evaluation of 1, 2 RIA-40, and determined both monitors to be inoperable due to water intrusion into the detector chambers. The licensee previously identified the accumulation of water in the monitors shortly after they were installed in the 1990s. At that time, the licensees corrective actions included the installation of moisture separators in the piping upstream of the radiation monitors and periodic draining of the rotameter sight glasses; however, operability of the radiation monitors was not evaluated. The licensee did not recognize the inoperability of the monitors even though the detectors required replacing at a much higher frequency than expected due to water in the detection chamber damaging the Mylar window. The presence of water in the detection chamber was a clear indication that the monitor was inoperable because it shielded the beta radiation detector, reduced the measuring chamber gas volume, and invalidated quantitative measurements.

The condenser off-gas monitors 1 and 2 RIA-40 perform two major functions:

(1) they are the primary means of detection and quantification of a primary- to- secondary leak; and

(2) they are effluent gas monitors. The plant was allowed to continue operation with RIA-40 inoperable due to other monitors (Nitrogen-16 monitors RIA-59 and RIA-60)being credited as providing redundancy for primary to secondary leakage detection, and the unit vent noble gas monitor (RIA-45) providing the effluent monitoring redundancy.

Licensee procedures provided for compensatory sampling when the redundant monitors were also inoperable. With RIA-40 being in an inoperable condition, the monitors functions were not consistently met because the required compensatory actions were not performed. OP/0/A/1106/031, Primary to Secondary Leak Rate Monitoring and Instrumentation, step 2.1, required the completion of Attachment 4.8, which evaluated compensatory monitoring requirements. This included immediately and then periodically sampling the condenser off-gas and primary coolant due to not having an operable continuous radiation monitor capable of detecting >30 gallons per day, primary to secondary leakage whenever RIA-40, and RIA-59 or RIA-60 were out of service; and increased surveillance and sampling below 40 percent RTP because RIA-59 and 60 were only operable above 40 percent RTP. The compensatory monitoring evaluation also addressed the concurrent operability of RIA-45, RIA-59 or RIA-60.

Analysis:

The failure to recognize that the condenser off-gas radiation monitors were inoperable due to the presence of water in the monitors detection chamber was a performance deficiency. This performance deficiency was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective in that the capability to detect, quantify, and respond to primary to secondary leakage was degraded. The significance of the finding was evaluated using inspection Manual Chapter 0609.04, and determined to be of very low safety significance (Green) because there was not a loss of safety function.

The inspectors determined that this performance deficiency had a cross-cutting aspect in the area of Problem Identification and Resolution under the Corrective Action Program component because the licensee failed to recognize that 1 and 2 RIA-40 were inoperable, and to take appropriate corrective actions to address the issue in a comprehensive manner commensurate with its safety significance and complexity

P.1(d).

Enforcement:

Technical Specification 5.4.1.d required, that written procedures shall be established, implemented, and maintained covering various defined activities to include the programs defined in Technical Specification 5.5. Technical Specification 5.5.10.e, established the requirement that the Steam Generator (SG) Program had provisions for monitoring operational primary to secondary leakage. Procedure NSD-513, Primary to Secondary Leakage Monitoring Program, Section 4.1.1, No Available Continuous Radiation Monitor, required compensatory sampling at all times, when a unit is below 40% power and 1 and 2 RIA-40 are inoperable, and at any time when RIA-40, and either RIA-59 or RIA-60 are inoperable. Procedure OP/0/A/1106/031, Primary to Secondary Leak Rate Monitoring and Instrumentation, step 2.1, directs the performance of attachment 4.8 which evaluates compensatory sampling requirements with RIA-40 inoperable.

Contrary to the above, with 1 and 2 RIA-40 in an inoperable condition following their installation in the 1990s, compensatory sampling requirements were not evaluated, and compensatory sampling to meet primary to secondary leak monitoring requirements was not performed. Because this violation was of very low safety significance and was entered into the licensees corrective action program under PIP O-10-06151, this violation is being treated as a non-cited violation in accordance with the NRCs Enforcement Policy: NCV 0500-0269/270/2011016-1 Failure to take required compensatory actions for 1 and 2 RIA-40 condenser off-gas radiation monitor inoperability.

4OA6 Management Meetings (Including Exit Meeting)

Exit Meeting Summary

The inspector presented the inspection results to Mr. Preston Gillespie, and other members of licensee management on May 23, 2011. The licensee acknowledged the findings presented. The inspector stated that there had been no proprietary documents provided by the licensee. The inspector identified that a proprietary EPRI document was reviewed that was not procured from the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY PERSONNEL

Licensee

P. Gillespie Site VP

T. Ray Engineering Manager

T. Patterson Safety Assurance Manager

D. Robinson RP Manager

K. Alter Regulatory Compliance Manager

E. Lampe RP Supervising Scientist

J. Smith Regulatory Compliance Licensee Admin

NRC

A. Sabisch Sr. Resident Inspector -Oconee Nuclear Station

G. Ottenberg Resident Inspector- Oconee Nuclear Station

LIST OF REPORT ITEMS

Opened and Closed

05000269 and 270/2011016-1 NCV Failure to take required compensatory

actions for 1 and 2 RIA-40 condenser off-

gas radiation monitor inoperability

Closed

05000269, 270, and 287/2010004-2 URI Potential inoperability of condenser off gas

radiation monitors

List of Documents Reviewed

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

(Closed) Unresolved Item (URI) 05000269, 270 and 287/2010004-2 Potential

Inoperability of Condenser Off-Gas Radiation Monitors

Procedures

Nuclear Station Directive 513, Primary-to-Secondary Leak Monitoring Program,

Rev. 5, - Section 513.4.1.1 No Available Continuous Radiation Monitor

OP/0/A/1106/031, Primary to Secondary Leak Rate Monitoring and Instrumentation,

Rev. 105

AP/1/A/1700/031, Primary to Secondary Leakage, Rev. 17

CP/0/B/3002/023, Primary to Secondary Leak Rate Monitoring and Response, Rev. 6

Corrective Action Documents

PIP O-10-06151, The NRC has issued an Unresolved Issue (URI) to ONS due to the

condensation visible in the rotameters for 1RIA-40 and 2RIA40.

Other Documents

Oconee Nuclear Station Consolidated NRC Inspection Report 2010-04, Section 2RS6

Oconee Nuclear Station Selected Licensee Commitments (SLC) 16.11.3, Rev. 12/10/07

NEI 97-06 Steam Generator Program Guidelines, Rev. 2

EPRI PWR Primary-to-Secondary Leak Guidelines, Rev. 3

Oconee Nuclear Station Technical Specification 3.4.13, "RCS Operational Leakage"

Attachment