IR 05000269/1991036
| ML16148A593 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/07/1992 |
| From: | Jape F, Casey Smith, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A594 | List: |
| References | |
| 50-269-91-36, 50-270-91-36, 50-287-91-36, NUDOCS 9201280265 | |
| Download: ML16148A593 (12) | |
Text
UNJTED STATES o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-269/91-36, 50-270/91-36, and 50-287/91-36 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-269, 50-270, License Nos.: DPR-38, DPR-47, and and 50-287 DPR-55 Facility Name:
Oconee 1, 2, and 3 Inspection Conducted: December 9-13, 1991 Inspectors:r-Y, M. Thomas D te Signed C. Smith Dte Si gne Approved by:
7676<.yt 7/
F. Jape, Chief Date Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of Design changes and modifications, and engineering and technical support activitie Results:
In the areas inspected, violations or deviations were not identifie CFR 50.59 safety evaluations reviewed were detailed, thorough, and technically adequate for the NSMs and TSMs reviewed. The 50.59 evaluations for the exempt changes reviewed did not provide adequate detai The licensee underwent a reorganization which became effective November 1, 1991 where design engineering will be relocating from the corporate office to the sit The staffing level and experience of. the Component Engineering Section was considered a strengt Licensees commitment to the Design Basis Document Project is demonstrated by scope and extent of activities related toward completion of this projec PDR ADOCK 05000269 PDR
1. :~~~:~otacedREPORT DETAILS'
1.,
Persons Contacted Licensee Employees H. Barron, Station Manager
- S. Benesole, Supervisor, Safety Review Coyle, Manager, System Engineering
- T. Curtis, Compliance Manager (Acting)
- 8. Dolan, Manager, Mechanical/Nuclear Engineering (Design)
J. Hampton, Oconee Nuclear Site Vice President D. Jamil, Electrical Engineering Supervisor (Design)
0. Kohler, Licensing Coordinator, Regulatory Compliance
- B. Millsaps, Manager, Component Engineering B. Peele, Oconee Engineering Manager
- S. Perry, Assistant Coordinator, Regulatory Compliance
- R. Sweigart,. Operations Superintendent Other licensee employees contacted during this inspection included engineers, operators, and administrative personne NRC Resident Inspectors
- B. Desai, Resident Inspector P. Harmon, Senior Resident Inspector W. Poertner, Resident Inspector
- Attended exit interview 2. Engineering and Technical Support The inspector reviewed the activities of various station groups involved in providing engineering support to plant maintenance and operations. The review focused on the timeliness and thoroughness of engineering involvement in the on-site problem ident.ification and resolution proces a. Engineering Reorganization The licensee recently underwent a reorganization that became effective on November 1, 199 Design activities are being transferred from a central corporate office location to each sit All engineering activities will be under the direction of the site engineering manager who reports to the site vice presiden This includes component engineering (formerly maintenance engineering),
reactor engineering, systems engineering, and design engineerin The inspectors discussed the new organization with licensee personnel who stated that, although the new organization became effective November 1, 1991, engineering activities will continue to be performed under current administrative controls until applicable program documents and controls are revised to reflect the changes in organization and responsibilitie There will be a time period allowed for transition to the new organization. Licensee personnel stated that a task force has been established to develop a transition schedule. The inspectors will review the progress of the transition effort and the effect of the reorganization on engineering support during subsequent inspection Station Problem Reports Licensee engineering personnel identify and resolve technical issues for operations and maintenanc They find and fix problem The primary mechanisms for documenting problems are the maintenance work request and the station problem report (SPR).
Any individual at Oconee.or the General office may initiate a SPR to identify a station problem which may require resolution by means of a nuclear statio modification (NSM), exempt change, design study, or editorial chang A SPR is the mechanism used by the licensee to initiate changes to the plan SPRs are approved and assigned a category by a station superintenden SPRs that must be resolved immediately.are approved by the station manager before being processe Prior to the reorganization SPRs were processed by the Project Services Section where the determination was made how the SPRs would be resolved ( NSM, exempt change, design study, or editorial change).
Although Project Services no longer exists organizationally, the section will continue to exist functionally during the transition period and perform their same duties and responsibilitie Those responsibilities included, but were not limited to the following:
Provide engineering and administrative support for NSMs designed at the plan Provide engineering and administrative support to assure proper implementation of modifications designed by station personnel and/or D *np3 o
Provide engineering and administrative support for TSM o Pro Ivide engineering and administrative support for exempt change The responsibilities of the Project Services Section will gradually be assumed by Component Engineering, DE, and Systems Engineering under the new organizational structur If a SPR required a NSM and it was determined not to be an urgent SPR, the SPR would.be added to the inactive SPR list. Periodically station management meets to identify which SPRs will be elevated from inactive to active statu Each group superintendent evaluates all SPRs from their sections and provide the necessary input for the other superintendents and the station manager to determine which SPRs need to be added to the active list. Once the decision is made to elevate a SPR to active status, Project Services is responsible for writing a NSM request to resolve the SPR. Station management holds a separate meeting for SPRs which require an exempt change in order to determine which of those SPRs will be activate NSM packages are normally prepared by D Exempt changes are prepared on site by Project Services or Component Engineering. A SPR does not need to be initiated for exempt changes prepared by Component Engineerin Normally, Component Engineering prepares an exempt change based on a work reques All exempt changes must be approved by DE prior to implementatio Licensee personnel stated that allowing Component Engineering to prepare exempt changes has aided Project Services in their effort to control the number of outstanding SPR The inspectors reviewed data which showed that as of December 1, 1991, the number of outstanding SPRs has been reduced from 715 to 423. In addition, during the last 12 months 267 SPRs were received and 555 SPRs were resolve The inspectors considered the licensee's efforts to resolve the number of outstanding SPRs to be a positive aspect of engineering suppor c. Problem Identification Reports The problem identification report (PIR) program was reviewed during the previous SALP period (NRC Inspection Report 50-269, 270, 287/90-01) in order to review the effectiveness and responsiveness of
engineering support (DE) due to the frequent utilization of engineering resources for PIR evaluation and resolutio Program effectiveness and engineering response were considered good for those issues. which were readily identified to be operability or safety concerns. However, those issues which were not readily identified as operability or safety concerns were not consistently processed in timely manner by DE. Some of the PIRs had been in DE for over a year without a response being sent to the site. The inspectors discussed this area with licensee personnel and reviewed data showing the number of PIRs sent to DE for operability reviews since NRC inspection 90-0 The inspectors reviewed the data and found that although not all the operability reviews were performed by their due dates, the responsiveness of DE showed a significant improvemen The inspectors consider that this responsiveness should continue to improve once DE is located on sit d. Component Engineering The Component Engineering Section is part of the site engineering organizatio Prior to the reorganization on November 1, 1991, the Component Engineering Section was called Maintenance Engineering and reported to the maintenance superintenden The section',s main function of providing engineering support to the maintenance department did not change with the reorganizatio Component Engineering has the programmatic lead for the Technical Support Progra The Technical Support Program for systems and components was developed by Component Engineering and consists of routine engineering duties and responsibilities as well as a proactive review to ensure that all aspects relative to operability and reliability are properly integrated into the defined, programmed maintenance for that system or componen The component engineers have primary ownership of the equipment and systems assigned to them and have the engineering lead in resolving maintenance problem Prior to the reorganization, Component Engineering.had responsibility for preparing exempt changes resulting from maintenance work request As a result of the reorganization Component Engineering will assume responsibility for all exempt changes as well as TSM The Component Engineering staff will increase due to the increased responsibilitie The inspectors noted that Component Engineering has a staff of 56, including supervisors and clerk The inspectors consider the size and experience level of the Component Engineering section to be a strengt.
Station Modifications The inspectors reviewed the station modification listed below to determine the adequacy of the safety evaluations performed to meet 10 CFR 50.59 requirements; verify that the NSMs were prepared and installed in accord ance with DE program requirements and applicable industry codes and stand ards; verify that the NSMs were reviewed and approved in accordance with TS and administrative controls; ensure the subject modifications were installed (for those physically inspectable) in accordance with the appli cable NSM packages; applicable plant operating documents (drawings,_ plant procedures, FSAR, TS, -etc.) were revised to reflect the subject modifica tions; the modifications were reviewed and incorporated into operations training programs as applicable; and post modification test requirements were specified and adequate testing was performe a. NSM ON-12622, Torque Switch Bypass Modification for Valves in Auxiliary Steam, Condensate and Heater Drain System, Revision 1, Part BL NSM ON-12622 was developed and implemented as.a result of the findings documented in IEB 85-03,
"MOV Common Mode Failure During Plant Transients Due to Improper Switch Settings."
The scope of the hardware changes consisted of (1)
making wiring changes to existing torque bypass switches located on Limitorque or Rotork MOVs or (2) adding limit switch packs on Rotork MOVs. The design input value specified for the limit switch setpoint allowed the MOVs to open 50 percent before the torque switch engages and de-energizes the moto MOVs within the scope of this design change included four valves in the Auxiliary Steam System, eight valves in the Condensate System, and one valve in the Heater Drain Syste The inspectors reviewed the Nuclear Safety Evaluation completed in accordance with the requirements of 10 CFR 50.59 and verified that it bounded the activities required to implement the design change Post-modification test requirements were also verified to have been specifie Additionally, the inspectors reviewed selected work packages, to verify the adequacy of the installation process and completion of post modification tests. The inspectors concluded that the design changes were developed and implemented in-a controlled and technically adequate manne Also, necessary and required post modification tests had been specified and performed to verify achievement of design objective No deficiencies were identified during review of this plant modification packag NSM ON-12665, Auxiliary Electrical, Power System Upgrade for Unit 1, Revision 0 Licensee management's evaluation of the Oconee electrical system showed that the system is at or near the point where it cannot support additional loads and maintain adequate voltage at all load Load studies, documented in ONDS-133/100 dated June 9, 1986, have shown that a degraded grid voltage coincident with a LOCA condition would cause the voltage on the 208V AC system to be at or near the minimum design limi Additionally, voltages on some non-safety 600 VAC busses are at or near their design limi NSM ON-12665 was developed and implemented as part of the resolution to the above problem. The scope of the plant modification included the following:
Addition of non-safety related equipment consisting of seven new MCCs and three Power Panelboards Removal of specified non-safety related electrical loads from their.present power source to new MCCs and Power Panelboard The inspectors performed a limited review of the DCP to assess the technical adequacy of the plant modifications. Although not reviewed by the -inspectors, design calculations required to facilitate preparation of the plant modification was verified to have been completed and:referenced in the DC The Nuclear Safety Evaluation performed in accordance with the requirements of 10 CFR 50.59 was reviewed and verified to bound the field activities required to implement the design changes. Additionally, the inspectors reviewed portions of the installation work package and verified the adequacy of selected portions of the installation. The inspectors concluded that plant modification NSM ON-12665 was developed and implemented in a technically adequate and controlled manner. No deficiencies were identified during this revie c. Temporary Station Modifications Temporary station modifications (TSM)
are prepared on site by qualified designers in the Project Services Section, in accordance with Oconee Nuclear Station Directive 2.3.5, Control of Temporary Modification The inspectors reviewed the status of active TSM As of December 1, 1991, there were 54 active TSMs, 47 of which are currently installe The inspectors noted that approximately one third of the TSMs currently installed have been installed for more than 18 month Some TSMs have been installed for over five year The inspectors discussed the length of time some TSMs have been installed with licensee personnel who stated that there is an ongoing effort to reduce the number of TSM A total of 137 TSMs were received during the last 12 months and 155 were completed. Permanent modifications are being developed to replace some of the older TSM Licensee personnel further stated that the TSMs are reviewed quarterly to verify that there is still a need for the installed TSM and that the TSM is performing its intended function. The inspectors reviewed the following TSMs and applicable 50.59 evaluation TSM Number Description TSM-175 Install 3-way solenoid valve on BAMT level instrument line and connect service air to blow down boron crystals TSM-368 Install travel stops on valves 2HD-92 and 2HD-95 TSM-537 Install temporary instrumentation in the RBCU duct to measure temperature and humidity to determine RBCU efficiency TSM-823 Install backflow seal on relief valves 2MS-135, 136, 137, 57, 66, and 75 TSM-882 Open sliding link to remove channel 3 of vibration sensors from Unit 3 RCP 3B1 TSM-884 Open link on 3B1 RCP vibration monitor for channel 1 to eliminate constant alarm TSM-896 Unit 3 control rod drive group 4, rod 3 API signal is erroneous due to a high resistance fuse in the patch cabine Simulate API signal for group 4, rod 3 TSM-901 Install 0-5000 PSIG pressure transmitter for PT3 in pane Calibrate PG3 to read higher pressures TSM-934 Defeat interlocks associated with 3LS29 (spent fuel pool level)
and SFP cooling pumps 3A, 3B, and 3 TSM-952 Install chart recorder to RPS channel B, NI-6, top and bottom linear amplifier, total flux summing amplifier and PR detector P/ The inspectors noted that the applicable engineering evaluations for the TSMs reviewed were thorough, detailed, and adequately addressed the effect the TSM would have on system operation. The inspectors reviewed the TSM logs maintained in Units 1, 2, and 3 control rooms to verify that the logs were accurate and properly maintained. The inspectors also performed field walkdowns to verify installation of selected TSM During further review of TSM-901 the inspectors noted.that when licensee personnel performed the three month review of the TSM they found that the TSM was not performing its intended function in that PG3 was not indicating any pressure when licensee personnel attempted to.perform a test on the post accident liquid sample (PALS)
syste The pressure transmitter was changed to allow the system to be operated at higher pressures in order to increase the sample flowrate through the PALS pane Increasing the flowrate would decrease the stay time for chemistry.personnel. When the TSM was found not to be working as intended, the inspector noted that it was over a month before the problem was documented by chemistry personnel and the accountable engineer (AE) who prepared the TSM was notified. The AE then initiated a work request to investigate. why the TSM was not workin The inspectors asked the AE whether the PALs system was still operable and why the problem had gone so long without anyone taking actions to determine what the problem was. The AE stated that the system was still operable because chemistry personnel were still able to obtain their sample The TSM was installed for test purposes and did not impact operation of the PALS system. The AE11 further stated that separate work.requests were initiated to install and remove the TS However, maintenance personnel did not have a work request which would have allowed them to investigate the problem with the TS During further review of station directive 2.3.5 the inspectors noted that the procedure did not address what actions should be taken if a TSM did not perform its intended function after being installe This was considered to be a weakness in the TSM station directive. Licensee personnel stated that this item would be reviewed to determine what actions need to be take After reviewing the licensee's implementation of the TSM program, the inspectors considered that, except for the minor procedural weakness, the licensee's overall implementation and control of TSMs was considered goo d. ONOE-1845, Replace Six Inch Flex Hose on Discharge of 1AS-23 With an Expansion Joint This modification was implemented under the.licensee's exempt change progra An exempt change is a physical change to a structure, system, or component that is minor in scope and complexit Exempt changes are prepared by the site but must be approved by Design Engineering (DE) prior to implementation. The metal flex hose on the discharge of 1AS-23 (which is in the auxiliary steam system) had
developed a,leak and a suitable replacement flex hose could not be.
found, so the flex hose.was replaced with an expansion joint. The work was performed under work request 50540H. The auxiliary steam system is not safety related. In reviewing the 10 CFR 50.59 for this exempt change the inspectors noted that not much detail was provided for the 50.5 The licensee acknowledged the inspector's comments and stated that this area would be reviewed and appropriate actions take The inspectors verified that the exempt change had been reviewed and approved by DE prior to implementatio e. ON0E-3323, Replacement of 2HP-150 with Item No. DMV-195 This exempt change involved replacement of a one inch globe valve, which served as a system vent valve, with a one inch gate valve due to poor back flow. The exempt change was implemented under WR 51870J and applicable maintenance procedures. The inspectors reviewed the 10 CFR 50.59 evaluation and the Valve Evaluation Replacement Request which was part of the exempt change packag The inspectors noted that the 50.59 addressed various design inputs such as the differences in flow and operating characteristics, and test requirements. During review of the 50.59 the inspectors noted that the evaluation did not appear to address the weight difference between the two valves and what affect this had on seismic consideration This item was discussed with licensee personnel who stated that although the weight difference was not specifically addressed in the 50.59, which was prepared by the site, the weight was considered by DE as part of their evaluation prior to approval of the exempt chang The inspectors reviewed DE work place instructions 407-04, Design Phase:
Design Activities; 407-10, Design Phase:
Exempt Changes; and. PR-160-10, Exempt Change The inspectors determined from reviewing these procedures that adequate controls existed for ensuring that applicable design inputs are considered. The inspectors had not further questions in this are. Design Basis Documents Activities The inspectors conducted interviews with licensee's engineering personnel and reviewed objective evidence to verify the status of the DBD Projec Based on review of the quarterly Design Basis Documentation Report, dated November 15, 1991, the inspectors determined that a large number of DBD drafts had been issued. Additionally, the report stated that there was a large backlog of drafts that required review and approval at each statio The inspectors were informed that the 1991 management goal for issuing first draft DBDs for Oconee was 1 The actual number issued is ahead of the goal with'a total of 16 issued to dat Licensee management anticipate that by December 31, 1991, a total of 17 will have been issue The 1991 management goal for issuing final approved DBDs was 13. At the time of the inspection the site had not received any approved DBD for 199 Licensee management does not regard this as a -proble The inspectors were told that the site will be provided with 12 final issue DBDs by December 31, 199 The inspectors concluded that licensee management's commitment to completing the DBD Project appears fir Tentative plans for incorporating the DBD Project into each site-engineering organization as part of the overall reorganization was also discusse Within this area no violations or deviations were identifie. Improvement in Interim Drawing Control The inspectors reviewed objective evidence to verify that controls are in place to assure that the as-built plant is consistent with the documented desig Station Directive 2.3.4, Nuclear Station Modification Program, specifies requirements to ensure adequate configuration control of modified plant systems/component Following implementation of NSMs associated Limited Edition Drawings are returned to CMD Document Contro Prior to returning the modified system/component to service, ONS Document Control provide station personnel with Interim As-Built drawings for those drawings that are deemed critical to the support of plant operations, maintenance and testin These drawings show the modified condition of the statio The above process is implemented via completing-Form No. ONS-535, Transfer of Completed or Partially Completed Modification During reviews of plant modifications addressed in paragraph 2.0, the inspectors verified that the drawing control process was being effectively implemented. No deficiencies were identifie. Exit Interview The inspection scope and results were summarized on December 13, 1991, with those persons indicated in paragraph 1. The inspectors described the areas inspected. and discussed in detail the inspection result Proprietary information is not contained in this repor Dissenting comments were not received from the license. Acronyms and Initialisms AC Alternating Current AE Accountable Engineer CMD Construction Maintenance Department DBD Design Basis Document DE Design Engineering LOCA Loss of Coolant Accident
MOV Motor Operated Valve NSM Nuclear Station Modification ONS Oconee Nuclear Station PAL Post Accident Liquid PIR Problem Identification Report SALP Systematic Assessment of Licensee Performance SPR Station Problem Report TSM Temporary Station Modification