IR 05000269/2011008
| ML12080A148 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/27/2012 |
| From: | Gillespie T P Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IR-11-008 | |
| Download: ML12080A148 (8) | |
Text
Duke T. PRESTON GlLESPiE, JR.Vice Presideniriwfjnergy. Oconee Nuclear StatinDuke EnergyONOI VP / 7800 Rochester Hwy.Seneca. SC 2967210 CFR 2.201 864-873-4478864-873-4208 faxFebruary 27, 2012 1.G0I$sPie@duke-energy.conU.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-001Subject, Duke Energy Carolinas, LLC. (Duke Energy)Oconee Nuclear Station, Units 1, 2, and 3Docket Nos. 50-269, 50-270, 50-287.Reply to a Notice of ViolationReference: Letter from Richard P. Croteau (NRC) to Preston Gillespie (Duke Energy),"Oconee Nuclear Station -NRC Problem Identification and Resolution InspectionReport 05000269/2011008, 05000270/2011008, and 05000287/2011008, AndNotice of Violation," dated January 26, 2012In the referenced letter, the U.S. Nuclear Regulatory Commission (NRC) transmitted ProblemIdentification and Resolution Inspection Report (IR) 0500026912011008, 05000270/2011008,and 05000287/2011008 (ADAMS Accession No. MLI 20260740) to Duke Energy whichpertained to the Oconee Nuclear Station (ONS). The letter also included a Notice of Violation(NOV) identifying a violation of NRC requirements set forth in 10 CFR 50, Part B and 10 CFR50.49(f). The violation, identified by the NRC as "VIO 2011008-001," involves ONS's failure topromptly identify and correct a condition adverse to quality involving the environmentalqualification (EQ) of Limitorque actuators. The violation is associated with a:Green SignificanceDetermination Process finding.Pursuant to the provisions of 10 CFR 2.201, Duke Energy has prepared a written reply to thesubject violation as Attachment 1 to this letter. Duke Energy does not contest the violation. Todate, corrective actions have been taken on a select number of Limitorque actuators whichDuke Energy believes corrected the adverse condition for those actuators. Details related to theremaining corrective actions necessary to resolve the violation are described in Attachment 1.One new regulatory commitment from this letter is identified in Attachment 2.Any questions regarding the content of this report should be directed to Mr. Kent Alter, ONSRegulatory Compliance Manager, at 864-873-3255.
Sincerely,T. Preston Gillespie, Jr... .. ....IWY kX(L-(L78. of U.S. Nuclear Regulatory CommissionFebruary 27, 2012Page 2
Attachments:
1. Reply to a Notice of Violation -NRC Inspection Report No. 05000269/2011008,05000270/2011008, and 05000287/20110082. List of Regulatory Commitmentscc: Mr. Victor McCreeAdministrator, Region IIU.S. Nuclear Regulatory CommissionMarquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257Mr. John StangProject ManagerU.S. Nuclear Regulatory CommissionOffice of Nuclear Reactor RegulationWashington, DC 20555Mr. Andrew SabischNRC Senior Resident InspectorOconee Nuclear Station Attachment IOconee Nuclear Station -Units 1, 2, and 3Reply to a Notice of ViolationNRC Inspection Report No. 0500026912011008, 0500027012011008, and05000287/2011008Attachment Page 1 of 5 U.S. Nuclear Regulatory CommissionFebruary 27, 2012Attachment 1Reply to a Notice of ViolationNRC Inspection Report No. 05000269/2011008, 05000270/2011008, and 0500028712011008Restatement of Violation VIO 2011008-001During an inspection completed on December 16, 2011, a violation of NRC requirements wasidentified. In accordance with the NRC Enforcement Policy, the violation is set forth below:A. 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires in part, thatmeasures shall be established to assure that conditions adverse to quality, such asfailures, malfunctions, and non-conformances are promptly identified and corrected.10 CFR 50.49(f) requires that each item of electric equipment important to safety shallbe qualified by one of the following methods:(1) Testing an identical item of equipment under identical conditions or under similarconditions with a supporting analysis to show that the equipment to be qualifiedis acceptable;(2) Testing a similar item of equipment with a supporting analysis to show that theequipment to be qualified is acceptable;(3) Experience with identical or similar equipment under similar conditions with asupporting analysis to show that the equipment to be qualified is acceptable; or(4) Analysis in combination with partial type test data that supports the analyticalassumptions and conclusions.Contrary to the above, from October to November 2010 (Unit 3 refueling outage), fromApril to June 2011 (Unit 1 refueling outage), and in November 2011 (Unit 2 refuelingoutage), the licensee failed to establish measures to assure that a condition adverse toquality, identified by the NRC in NCV 2010004-03, was promptly identified andcorrected. Specifically, the licensee missed reasonable opportunities during each Unit'srefueling outage to confirm the population of Limitorque actuators that were potentiallyinstalled in an unqualified configuration in order to properly assess the extent of the non-conforming condition discussed in NCV 2010004-03 and take appropriate correctiveactions. Consequently, an unknown population of Limitorque actuators in Units 1, 2, and3 remained in a configuration that was not qualified in accordance with one of themethods described in 10 CFR 50.49(f).This violation is associated with a Green Significance Determination Process finding.Admission or DenialDuke Energy does not contest the violation. The condition adverse to quality identified in aboveVIO 2011008-001 was entered into Duke Energy's Corrective Action Program.Attachment Page 2 of 5 U.S. Nuclear Regulatory CommissionFebruary 27, 2012Attachment 1Reasons for the ViolationThe reason for the Violation is that Duke Energy relied upon a calculation that was lackinganalysis to support which Limitorque actuators at the Oconee Nuclear Station (ONS) required"T-drain" installation on the actuator's limit switch compartment (LSC) housing in order to beconsidered environmentally qualified. A description of the events that lead to Duke Energy'sfailure to promptly resolve an identified condition adverse to quality is as follows:The issue involving environmental qualification (EQ) of select Limitorque actuators was initiallyidentified during an NRC EQ inspection at the ONS in August 2010. Specifically, someLimitorque actuators were installed at ONS with the LSC mounted in a vertically downorientation and without the installation of T-drains on the LSC housing. The applicableLimitorque EQ Test Report (Report B0058) indicated that this type of actuator was tested byLimitorque with the LSC oriented in the vertical up position and with a T-drain installed on theactuator motor to verify the unsealed design and drain any potential condensation resulting froma design basis event.The LSC vertically down orientation could potentially allow for accumulation of condensation inthe LSC and could cause limit switch and torque switch failure, electrical shorts, etc. As a resultof this adverse condition, the NRC cited ONS with non-cited violation (NCV) 2010004-03, "EQComponents Not Installed in the As-Qualified Configuration," in Integrated Inspection Report2010004 (ADAMS Accession No. ML103020265).Duke Energy believed that the proper action to resolve this adverse condition was thedevelopment of a calculation that supported analysis of the Limitorque EQ report that wasutilized to determine LSC orientation requirements. On September 29, 2011, a calculationentitled "Environmental Qualification (EQ) Evaluation of Limitorque MOV Actuator InstalledOrientations" was approved and issued. The calculation reviewed the various valves that wereinstalled with Limitorque actuators and the environments where the valves were installed. Thecalculation determined that drainage was only potentially needed on the valves that were incontainment and had long term actions to respond following a loss of coolant accident (LOCA).This calculation provided what Duke Energy believed was the analysis and results needed inorder to resolve the Limitorque actuator EQ issue. However, as noted in the NRC inspectionreport, the calculation results only served to address the Valves which had an operabilityconcern and did not ensure compliance with EQ requirements for all valves. Based on the NRCinspection report, the analysis performed by the calculation was not considered adequate for fullEQ compliance for Limitorque actuators at ONS that are installed in a configuration differentfrom the orientation originally tested by the Vendor. Duke Energy now believes in order forLimitorque actuators at ONS that are installed in a configuration different from the orientationoriginally tested by the vendor to be considered in full EQ compliance either:(1) have supporting documentation to demonstrate that Limitorque actuators installed in aconfiguration different from the orientation originally tested by the vendor (i.e. LSC in thevertical down position and without drainage) are in compliance with the EQ requirementsin 10 CFR 50.49, or(2) install LSC drainage in the lowest existing LSC housing plug port or drill and tap the LSChousing at its lowest achievable point for all environmentally qualified Limitorqueactuators where the LSC is not oriented in the EQ-tested position (i.e., vertically up).Attachment Page 3 of 5 U.S. Nuclear Regulatory CommissionFebruary 27, 2012Attachment 1As a result of the calculation, only environmentally qualified Limitorque actuators in the ReactorBuilding required walkdowns, as all other environmentally qualified Limitorque actuators hadbeen evaluated as not requiring LSC T-drains. ONS planned on performing Limitorque actuatorwalkdowns and LSC T-drain installations during upcoming refueling outages for each unit. Theanalysis-required LSC T-drain installations for Unit 2 Limitorque actuators were performed in theUnit 2 Fall 2011 refueling outage. Analysis-required Limitorque actuator LSC T-draininstallations were planned for Unit 3 in the Unit 3 Spring 2012 refueling outage and for Unit 1 inthe Unit 1 Fall 2012 refueling outage. Since no actions were taken to ensure compliance untilafter the calculation was approved, Duke Energy did not address the non-compliance with theEQ requirements in a timely manner. Duke Energy failed to take any actions during theprevious Unit 3 outage (Fall 2010) and Unit 1 outage (Spring 2011). The failure to take timelyactions was due to improper prioritization of the drain installations until after the calculation wasperformed. Duke Energy should have installed the drains to ensure compliance while awaitingthe results of the calculation.In December 2011, ONS management directed that the installation of the analysis-required LSCT-drains in Units 1 and 3 Limitorque actuators be performed as soon as reasonably possiblewith the units at power. Thus, on December 15, 2011, LSC T-drains were installed on theremaining Unit 1 and 3 analysis-required Limitorque actuators, with the exception of one valve(3LP-1 04) in Unit 3. This valve is difficult to access due to its location and will require temporaryscaffolding installation. For this reason, and since the function of 3LP104 without the LSC T-drain was not an operability concern, ONS management directed that the LSC T-draininstallation for this valve be performed during the Unit 3 refueling outage in Spring 2012.In conclusion, the above described course of action failed to completely resolve the adversecondition specified in NCV 2010004-03 in that some environmentally qualified Limitorqueactuator LSCs were still installed in an un-tested orientation (i.e., LSC not mounted vertically up)and Duke Energy's supporting calculation failed to provide adequate analysis that this untestedorientation complied with the EQ requirements of 10 CFR 50.49(f). Finally, the duration of timethat elapsed from initial issue identification (August 2010) until the time that Duke Energycommenced walkdowns and LSC T-drain installations of environmentally qualified Limitorqueactuators (October 2011) was excessive. Duke Energy failed to commence walkdowns andLSC T-drain installations of environmentally qualified Limitorque actuators in the Unit 3 Fall2010 refueling outage and the Unit 1 Spring 2011 refueling outage to resolve the Limitorqueactuator EQ issue.Corrective Steps Taken and Results Achieved1. On December 15, 2011, ONS completed installation of LSC T-drains on the analysis-required Limitorque actuators in Units 1 and 3, with the exception of Unit 3 valve 3LP-104.Installation of a LSC T-drain for this valve requires temporary scaffolding installation. Sincethe valve was considered operable, Duke Energy chose not to install a LSC T-drain on thisvalve until the Unit 3 Spring 2012 refueling outage due to the valve's location and elevation.Attachment Page 4 of 5 U.S. Nuclear Regulatory CommissionFebruary 27, 2012Attachment 12. On January 11, 2012, ONS reviewed the adverse condition of Unit 3 operating with apotentially non EQ-qualified Limitorque actuator for impact on Emergency OperatingProcedures (EOPs), and determined that no EOP changes were necessary.Corrective Steps That Will be Taken1. By March 8, 2012, ONS Engineering management will issue a communication toEngineering personnel reminding them of the need to provide timely response to NRCviolations. The communication will indicate that compliance with requirements must berestored in a timely manner at the first available opportunity. In addition, the prioritization ofthe activities will be re-inforced by the communication.2. By the end of the Unit 2 Fall 2013 refueling outage, ONS will either (A) have supportingdocumentation to demonstrate that Limitorque actuators installed in a configuration differentfrom the orientation originally tested by the vendor (i.e. LSC in the vertical down position andwithout drainage) are in compliance with the EQ requirements in 10 CFR 50.49, or (B) installLSC drainage in the lowest existing LSC housing plug port or drill and tap the LSC housingat its lowest achievable point for all environmentally qualified Limitorque actuators where theLSC is not oriented in the EQ-tested position (i.e., vertically up).3. The Engineering Corrective Action Review Board will establish process changes to addressthe analysis quality and timeliness of the original NCV response. This review will becompleted by March 22, 2012.4. Processes that monitor the evaluations and implementation of corrective actions associatedwith violations will be strengthened. These process enhancements will be made byJune 30, 2012.Date When Full Compliance Will Be AchievedDuke Energy commits to be in full compliance with 10 CFR 50.49 on this issue by the end of theUnit 2 Fall 2013 refueling outage, November 30, 2013.Attachment Page 5 of 5 U.S. Nuclear Regulatory CommissionFebruary 27, 2012Attachment 2ATTACHMENT 2List of Regulatory CommitmentsThe following commitment table identifies those actions committed to by Duke EnergyCarolinas, LLC (Duke Energy) in this submittal. Other actions discussed in the submittalrepresent intended or planned actions by Duke Energy. They are described to the U.S. NuclearRegulatory Commission (NRC) for the NRC's information and are not regulatory commitments.No. Commitment Description Due Date1 Duke Energy will restore full compliance with 10 CFR 50.49 on the Limitorque 11/30/13actuator EQ issue.Attachment Page 1 of 1