IR 05000269/1995026
| ML15118A060 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/10/1996 |
| From: | Casto C, Fillion P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15118A059 | List: |
| References | |
| 50-269-95-26, 50-270-95-26, 50-287-95-26, NUDOCS 9601190061 | |
| Download: ML15118A060 (8) | |
Text
Pa REGo UNITED STATES o
NUCLEAR REGULATORY COMMISSION
REGION II
o 101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 Report Nos.:
50-269/95-26, 50-270/95-26 and 50-287/95-26 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.:
50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and DPR-55 Facility Name:
Oconee Nuclear Station Units 1, 2 and 3 Inspection Conducted: November 27 - December 1 and December 11 -
15, 1995 Inspecto7: Flin 71. -Fillion Date Signed Approved by:_
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C. Casto, Chief Date Signed Engineering Branch Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted in the area of engineerin The inspection was a follow-up on issues identified during the Electrical Distribution System Functional Inspection (NRC Report No. 93-02).
Results:
In the areas inspected, violations or deviations were not identifie Inspector Follow-up Items 93-02-03 and 94-26-02 Follow up on Inspection Findings Listed in Report 93-02, Appendix A, were closed. Two new related Inspector Follow-up Items were established to track planned future inspection effort. These items are:
Inspector Follow-up Item 95-26-01, Region II Review of NRC Headquarters Special Report
Inspector Follow-up Item 95-26-02, Review Test Program for Mechanical Components at Keowee to Resolve EDSFI finding *
(Report Details Section 2)
9601190061 960110 Enclosure PDR ADOCK 05000269 G
- 2 Inspector Follow-up Items 93-02-04 and 95-16-01, Further NRC Review of Issues as Discussed in EDSFI Report, were closed. Six issues were included in these IFIs: Item 1. Capacity of the Standby Shutdown Facility make-up pump is being reviewed by NRC Headquarters staff, and a special report will be issued. Since the Region II staff must review this report, Inspector Follow-up Item 95-26-01, Review of NRC Headquarters' Report with Regard to SSF Make-up Pump Issue, was established (Report Details Section 2). Item 2. That the Main Feeder Bus Monitoring Panel (MFBMP) is designated as non-safety related. This issue was closed (Report Details Section 3). Item 3. The feeder cables for the switchyard battery chargers are non-safety related and the chargers shed during a loss of offsite power. This issue was closed (Report Details Section 3). Items 4, 5 and 6, refer to single failure criteria. This item was closed; however, single failure will be addressed in a special report by NRC Headquarter.
The classification of equipment issue was resolved. However, inspection effort identified a programmatic weakness in that there was confusion among the affected organizational groups concerning use of the Quality Standards Manua Therefore, Inspector Follow up Item, 95-26-03, Purpose and Limitations of the List of Structures, Systems and Components in the Quality Standards Manual, was established (Report Details Section 3).
Enclosure
REPORT DETAILS 1. Persons Contacted Licensee Employees
- E. Burchfield, Regulatory Compliance
- J. Davis, Engineering Manager
- T. Grant, Electrical Engineer
- J. Hampton, Site Vice President
- T. Ledford, Supervisor, Electrical Engineering
- C. Little, Manager, Electrical Systems and Equipment
- D. Nix, Regulatory Compliance
- J. Peele, Station Manager
- J. Smith, Regulatory Compliance
- L. Underwood, Electrical Engineer Other licensee employees contacted during this inspection included engineers and technician NRC Employees
- P. Harmon, Senior Resident Inspector L. Keller, Resident Inspector
- Indicates attended pre-exit meeting on December 14, 1995.
- Indicates attended exit meeting on December 15, 1995. Follow-up on EDSFI Findings (37550 RI)
The safety objective of this inspection was to review and evaluate issues identified during the Electrical Distribution System Functional Inspection (EDSFI), NRC Inspection Report No. 93-02. Three previous inspections have addressed EDSFI issues, and the inspection results are documented in NRC Inspection Report Nos. 94-26, 95-10 and 95-16. The EDSFI report contained two Inspector Follow-up Items (IFI).
IFI 93-02 03 tracked resolution of inspection findings listed in Appendix A. This item was closed in IR 94-26 and the remaining issues were opened as IFI 94-26-02. Each of these findings implied the need for actions by the license IFI 93-02-04 tracked several issues where further NRC review would take place, and no licensee action was expected while the review was ongoing. This item was closed and the remaining issues were opened as IFI 95-16-01. The issues outstanding prior to this inspection are summarized as follow.
Voltage and frequency performance of the Keowee units during expected start-up transients and following postulated component failures in the voltage regulator/governor had not been clearly demonstrated to be acceptable through analytical analysis or tes These issues encompass findings 2.f, 2.h, 4.a, 5.a, 5.c and listed in EDSFI report 93-02. Since the time of the EDSFI, the Enclosure
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licensee has performed extensive analysis and testing to resolve the concerns. These analysis and test results are being reviewed in detail by NRC Headquarters staff. The staff plans to issue a special report by approximately February 1996 documenting their evaluation and conclusions. The EDSFI findings, i.e. 2.f, etc., are subparts of Inspector Follow-up Items 93-02-03 and 94 26-02. All but one of the EDSFI findings included in IFI 93-02-03 have either been closed in previous reports or are being addressed by NRC Headquarters staff. The one remaining EDSFI finding, 6.b, is discussed in Item 2 below. Therefore, IFIs 93-02-03 and 94-26 02, Follow-up on EDSFI Findings Listed in Report 93-02, Appendix A, are closed. NRC Region II staff must review the special report which will be issued by Headquarters to verify that the report addresses all of the original issues and to ascertain whether the report indicates the need for follow-up action by the Regio Therefore, Inspector Follow-up Item 95-26-01, Review of NRC Headquarters' Special Report is establishe.
The EDSFI team Finding 6.b states that testing was not being performed on safety-related mechanical components (i.e. coolers and pumps). As a result of this finding, the licensee has significantly upgraded the test program for mechanical components at Keowee. The NRC intends to review the maintenance/testing program for Keowee equipment during an inspection scheduled for early 1996. This action item will be tracked under Inspector Follow-up Item 95-26-02, Review Test Program for Mechanical Components at Keowee to Resolve EDSFI Finding.
The EDSFI team reviewed the design of the Standby Shutdown Facility (SSF). The team did not reach a definite conclusion about the adequacy of the capacity of the SSF make-up pump, and determined that further review by the NRC was necessary to reach a conclusion. This issue was included in IFIs 93-02-04 and 95-16-01 (Item 1).
The further review is being conducted by NRC Headquarters staff, and conclusions will be included in the special report mentioned in relation to Item 1 above. Item 1 of IFI 95-16-01 is close.
The EDSFI team reviewed the design of the Electrical Distribution System to determine whether it was designed against single failures. During this review, it became apparent to the team that the licensee was applying a slightly different version of the single failure criterion than later vintage plants were applyin The team concluded that this matter warranted further review by the NRC. The issue included in IFIs 93-02-04 and 95-16-01 (Items 4, 5 and 6) was whether Oconee was applying the single failure criterion consistent with the original licensing basis. This issue will be addressed by NRC Headquarters in a special repor Items 4, 5 and 6 of IFI 95-16-01 are close Enclosure
3 The EDSFI team raised the issue of whether the licensee was classifying all the equipment that performs a safety-related function as "safety-related." The EDSFI report specifically questioned the non-safety-related classification of the power supply equipment to the switchyard battery chargers and the main feeder bus monitoring pane To make a review of the licensee's programs with regard to classification of equipment according to safety function was included in IFIs 93-02-04 and 95-16-0 Inspection activity is discussed in Section.
Classification of Equipment Duke Power Company Topical Report Quality Assurance Program states that the quality assurance program conforms to the criteria established in 10 CFR 50, Appendix B, dated June 27, 1970. The Topical Report states that the program applies to those systems and their attendant components, items and services determined to be nuclear safety-related and detailed as such in the FSAR. Nuclear System Directive 307, Quality Standards Manual is important to implementing the program because its purpose (as stated in the manual) is to provide a list of structures, systems and components (SSCs) covered by the progra The EDSFI team identified a concern that several components that perform a safety-related function were not considered by the licensee to be subject to the Quality Assurance Program. For example, a number of circuit breakers at buses TA, TB, TC, TD and TE performed a safety related function, but had not been listed in the Quality Standards Manual. A Notice of Violation was issued for this problem, and the corrective action was to include this equipment in the Quality Assurance Program. The EDSFI team also noted the main feeder bus monitoring panels and the switchyard battery charger power supply equipment were not in the Quality Standards Manual, but performed a function that was at least important to safety if not safety-related. Further review of the function of this equipment was required to determine whether they should be covered by the Quality Assurance Program, and this was part of IFIs 93-02-04 and 95-16-01 (Item 2 and 3).
Since the time of the EDSFI, the licensee has researched and provided clarification on the original licensing criteria for designating SSCs as safety-related. This clarification was presented and discussed at a meeting with the NRC on February 6, 1995. Also, the clarification is explained in a letter from Duke Power Company to the NRC, dated April 12, 1995. Later, the licensee researched all commitments made over the years of operation which added SSCs to the safety-related classification. These commitments are summarized in a letter from Duke Power Company to the NRC, dated July 10, 1995. The NRC staff reviewed these materials and prepared a Safety Evaluation, which was transmitted Enclosure
to the licensee on August 3, 1995. This letter states that the submittals were acceptable and the NRC found no basis to contradict the statement of the original licensing criteria designating SSCs as safety relate The August 1995 Safety Evaluation resolves the EDSFI team's concern about the licensee's overall program for classifying plant equipmen The inspector reviewed the classification of the main feeder bus monitoring panel and the switchyard battery chargers power supply equipment in light of the more detailed criteria provided in the above mentioned letters. He concluded that their non-safety-related classification was consistent with the original licensing basis criteria and no specific commitment was made to revise the classificatio The main feeder bus monitoring panels initiate circuit breaker switching in response to a limited number of loss-of-power scenarios. They play only a backup role in loss-of-power events where either the safety related External Grid Trouble Protection System is activated or a engineered safeguards signal is present. The function of the main feeder bus monitoring panels is to reduce the operator burden for low probability loss-of-power scenarios where there is no external grid problem nor engineered safeguards actuation signa For example, transformer CT1 faults. Although classified as non-safety-related, the main feeder bus monitoring panels consists of two redundant subsystem In the extremely low-probability scenario where transformer CT1 fails and both monitoring panel subsystems fail, planned operator actions can recover within the required time period. Therefore, there is no compelling reason to upgrade the main feeder bus monitoring panels to safety-related classification. Item 2 of IFI 95-16-01 is close Safety-related switchyard battery charger SY-1 is normally fed from safety-related 4.16 kV bus 1TE. Similarly, charger SY-2 is normally fed from bus 2TE. The power supply equipment between the source and the load is classified as non-safety-related. The equipment consists of a medium-voltage cable run primarily in ductbank and sand filled trench, a medium-voltage disconnect switch, oil-filled transformer, molded-case circuit breaker panel and low-voltage cable. The switch, transformer and panel are of outdoor construction, and are located in the switchyard. The units fed from ITE and 2TE are located about 150 feet apart. The inspector performed a walkdown type inspection of this equipment, and found it to be in good condition. The battery chargers and batteries are in the switchyard relay house. A swing battery charger, cross-connecting cables and key interlocks have been provided to allow bus ITE (or 2TE) to supply power to both batteries and their loads. Charger trouble alarms are provided in the main control roo Specification No. OSS-0254.00-00-2009, Design Basis Specification for the 230 kV Switchyard 125 VDC Power System, Rev 2, Section 20.2. states that the battery, by itself, has the capacity to supply all loads during design basis events for a minimum of one hour. Considering the Enclosure
battery capacity, redundancy, ruggedness and simplicity of the power supply equipment and continuous monitoring of charger output, the inspector concluded that there was no safety concern with classifying the power supply equipment to the switchyard battery chargers as non safety-related. Item 3 of IFI 95-16-01 is close The inspector reviewed implementation of the licensee's Quality Assurance Program through a review of Work Requests completed during the recent Unit 1 refuel outage. The inspector compared the quality assurance classification assigned to the individual work activities with the classification indicated in the Quality Standards Manual for the equipment involved. The inspector did not identify any problems with the classification assigned to the work activities. The inspector observed that four safety-related valves were not listed in the Quality Standards Manua These valves were:
PR-1 and PR-6, which are motor operated containment isolation valves in the Reactor Building Purge System
CF-1 and CF-2, which are motor operated valves in the Core Flood Syste The licensee initiated the Problem Investigation Process (PIP No. 0-095 1687) in response to the inspector's observation. The problem description on the Problem.Investigation Form states: "It appears that the problem is adequate expectations may not have been provided to the Quality Standards Manual users and Engineers regarding documentation of Quality Assurance classification decisions made using the [criteria]."
The problem evaluation section of the form states: "The cause for this PIP is a miscommunication of the intent of the Quality Standards Manual list of SSCs for Oconee." The proposed resolution section states:
"Clarify...
that the Quality Standards manual list is not intended to be all-inclusive, but only should list those items for which the
[safety-related] classification is difficult to make."
It appeared to the inspector that he had identified a weakness in the program. That weakness being that there was confusion among the affected organizational groups concerning the purpose and limitations of the list of SSCs provided in Appendix B of the Quality Standards Manua The concern was that the program could not work effectively if all affected groups within the licensee's organization did not understand how the program was intended to function. The NRC intends to perform additional inspection to determine whether the identified programmatic weakness is being internally resolved. Therefore, Inspector Follow-up Item 95-26 03, Purpose and Limitations of the List of SSCs in the Quality Standards Manual, is establishe Enclosure
5. Exit Meeting The inspection scope and results were summarized on December 14 and 15, 1995, with those persons indicated in Section 1. The inspector described the areas inspected and discussed in detail the inspection results including the items listed below. The licensee was advised of Inspector Follow-up Item 95-26-04 in telephone conversations on December 28, 1995. Dissenting comments were not received from the licensee. Proprietary information is not contained in this repor Item Number Status Description and Reference 93-02-03 Closed Inspector Follow-up Item -
Follow up on Inspection Findings Listed in Report 93 02, Appendix A (Section 2)
93-02-04 Closed Inspector Follow-up Item - Further NRC Review of Issues as Discussed in EDSFI Report (Sections 2 and 3)
94-26-02 Closed Inspector Follow-up Item - EDSFI Finding Items not closed during Follow-up Inspection 95-16-01 Closed Inspector Follow-up Item - Follow-up of Open EDSFI Issues (IFI 93-02-04)
95-26-01 Open Inspector Follow-up Item - Review of NRC Headquarters' Special Report (Section 2)
95-26-02 Open Inspector Follow-up Item - Review Test Program for Mechanical Components at Keowee to Resolve EDSFI Finding (Section 2)
95-26-03 Open Inspector Follow-up Item - Purpose and Limitations of the List of SSCs in the Quality Standards Manual (Section 3)
Enclosure