IR 05000269/2006018

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PROPRIETARY INFORMATIONDOCUMENT TRANSMITTED HEREWITH CONTAINS 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 Site Vice President Oconee Nuclear Station7800 Rochester Highway Seneca, SC 29672

SUBJECT: OCONEE NUCLEAR STATION - NRC INSPECTION REPORT05000269/2006018, 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 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 PROPRIETARY INFORMATIONDuke2DOCUMENT TRANSMITTED HEREWITH CONTAINS 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. PROPRIETARY INFORMATIONDuke3DOCUMENT TRANSMITTED HEREWITH CONTAINS 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 ( PROPRIETARY INFORMATION) cc w/encl: (See page 4) PROPRIETARY INFORMATIONDuke3DOCUMENT TRANSMITTED HEREWITH CONTAINS 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 notbeing 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 ( PROPRIETARY INFORMATION) cc w/encl: (See page 4)G PUBLICLY AVAILABLE X NON-PUBLICLY AVAILABLEX SENSITIVE G NON-SENSITIVEADAMS: G YesACCESSION NUMBER:_ML063240406 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 RECORD COPY DOCUMENT NAME: C:\FileNet\ML063240406.wpd PROPRIETARY INFORMATIONDuke4DOCUMENT TRANSMITTED HEREWITH CONTAINS 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 County 415 S. Pine Street Walhalla, 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) PROPRIETARY INFORMATIONDuke5DOCUMENT TRANSMITTED HEREWITH CONTAINS PROPRIETARYINFORMATION. WHEN SEPARATED FROM THE ENCLOSURE, THIS DOCUMENT ISDECONTROLLED.Letter to Bruce from Charles Casto dated November 20, 2006

SUBJECT: 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