IR 05000269/2005008

IR 05000269-05-008, 05000270-05-008, 05000287-05-008; 06/13/2005 - 07/01/2005; Oconee Nuclear Station, Units 1, 2, and 3; Additional Baseline Inspection of the Problem Identification and Resolution Program

ML052100373
Person / Time
Site:	Oconee
Issue date:	07/28/2005
From:	Ernstes M NRC/RGN-II/DRP/RPB1
To:	Rosalyn Jones Duke Energy Corp
References
IR-05-008
Download: ML052100373 (21)

Text

uly 28, 2005

SUBJECT:

OCONEE NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000269/2005008, 05000270/2005008, AND 05000287/2005008

Dear Mr. Jones:

On July 1, 2005, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oconee Nuclear Station. The enclosed report documents the inspection findings which were discussed on July 1, 2005, with Mr. Ron Jones and other members of your staff.

This inspection was an examination of activities conducted under your licenses as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating licenses. Within these areas, the inspection involved a selected examination of procedures and representative records, observation of activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The inspectors concluded that generally, problems were properly identified, evaluated and resolved within the corrective action programs. However, during the inspection, a few minor problems were noted involving corrective actions that were incomplete, some issue investigations that lacked thoroughness, and some issues that were categorized at a level which may have impacted the thoroughness of the reviews.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system

DEC 2 (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/

Michael E. Ernstes, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 50-269, 50-270, 50-287 License Nos. DPR-38, DPR-47, DPR-55

Enclosure:

NRC Inspection Report 05000269/2005008, 05000270/2005008, and 05000287/2005008 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-269, 50-270, 50-287 License Nos: DPR-38, DPR-47, DPR-55 Report No: 05000269/2005008, 05000270/2005008, 05000287/2005008 Licensee: Duke Energy Corporation Facility: Oconee Nuclear Station, Units 1, 2, and 3 Location: 7800 Rochester Highway Seneca, SC 29672 Dates: June 13 - 17, 2005 and June 27 - July 1, 2005 Inspectors: J. Zeiler, Senior Resident Inspector, Virgil C. Summer G. McCoy, Senior Resident Inspector, Vogtle D. Simpkins, Senior Resident Inspector, Hatch A. Hutto, Resident Inspector Approved by: Michael E. Ernstes, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

OF ISSUES

IR 05000269/2005-008, 05000270/2005-008, 05000287/2005-008; 06/13/2005 - 07/01/2005;

Oconee Nuclear Station, Units 1, 2, and 3; additional baseline inspection of the problem identification and resolution program.

The inspection was conducted by three senior resident inspectors and a resident inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution; however, several minor plant material condition deficiencies were identified during plant system walkdowns that had gone undetected by licensee personnel. The licensee maintained a low threshold for identifying problems as evidenced by the continued large number of Problem Investigation Process reports (PIPs)entered annually into the CAP. Generally, the licensee properly prioritized issues and examined issues; although several minor problems were noted where lower significance issues were mis-categorized or the investigations lacked thoroughness. Formal root cause evaluations for significant problems were thorough and detailed. Corrective actions specified for problems were generally adequate; although, several minor problems were noted where corrective actions were not complete or not comprehensive. Audits and self-assessments were effective in identifying deficiencies in the CAP. Personnel at the site felt free to raise safety concerns to management and to resolve issues via the CAP.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Effectiveness of Problem Identification

(1) Inspection Scope The inspectors reviewed Problem Investigation Process reports (PIPs) for issues across the reactor safety cornerstones to determine if problems were being properly identified and entered into the corrective action program (CAP) for resolution. The reviews were primarily focused on selected issues associated with seven risk significant plant systems, including: high pressure service water system (HPSW), low pressure service water system (LPSW), standby shutdown facility (SSF), emergency feedwater system (EFW), component cooling water system (CC), low pressure injection system (LPI), and Keowee Hydro Units (for emergency AC power). In addition, the inspectors selected a representative number of PIPs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, emergency preparedness, and security, to assess each departments threshold for identifying and documenting plant problems.

The inspectors reviewed open and completed maintenance work orders (WOs), system health reports, trend reports, and the Maintenance Rule (MR) database for the seven selected systems to verify that equipment deficiencies were being appropriately entered into the CAP. The inspectors conducted plant walkdowns of the seven systems with the responsible system engineers and/or operations personnel to identify any deficiencies that had not been entered into the CAP. The inspectors discussed the condition and status of each of the seven systems with system engineers and other plant personnel.

The inspectors reviewed selected industry operating experience items, including NRC generic communications, to verify that they were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP.

The inspectors reviewed control room operator logs for January to February 2005 to verify that equipment deficiencies, especially those involving the selected systems for the focused review, were entered into the CAP.

The inspectors reviewed licensee audits and self-assessments (focusing primarily on problem identification and resolution) to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.

The inspectors attended several plant daily status and PIP team screening meetings to observe management and PIP screening oversight functions in the corrective action process. The inspectors also interviewed personnel from operations, maintenance, engineering, security, health physics, chemistry, and emergency preparedness to evaluate their threshold for identifying issues and entering them into the CAP.

Documents reviewed to support the inspection are listed in the Attachment.

(2) Assessment The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP. PIPs normally provided complete and accurate characterization of the subject issues. In general, the threshold for initiating PIPs was low as evidenced by the continued large number of PIPs entered annually into the CAP.

Employees were encouraged by management to initiate PIPs. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. The inspectors independent review did not identify any significant adverse conditions which were not in the CAP for resolution.

During the system reviews and walkdowns of accessible portions of the HPSW, LPSW, SSF, EFW, CC, LPI, and Keowee Hydro systems, the inspectors determined that system deficiencies were being identified and placed in the CAP and that the system engineers were appropriately tracking and trending these issues. The inspectors did not identify any significant conditions adverse to quality during the system walkdowns; however, several minor deficiencies were identified for which PIPs had not been written as detailed below:

• During walkdown of the EFW system, the inspectors identified that scaffold erected during the previous refueling outage on Unit 1 was still installed next to the motor driven EFW pumps. The removal date on the scaffold tag had expired. The licensee initiated PIP O-05-4272 to address why the scaffold had not been removed and whether it was adequate for online operation. A subsequent licensee evaluation determined that the scaffold had been built to acceptable online standards, but had been intended to be removed at the end of the refueling outage. The licensee removed the scaffold and a subsequent extent of condition determined that this was an isolated case.

• During walkdown of the EFW system, the inspectors identified a small active boron leak from the packing and downstream pipe cap of a Unit 1 high pressure injection system drain valve, 1HP-69. The boron was dripping onto and penetrating the insulation of carbon steel EFW piping located directly below the valve. The licensee initiated WO 98348520 and PIP O-05-4091 to isolate/capture the leakage and to investigate the potential boric acid corrosion of the EFW piping. The inspectors determined that most likely the leakage had been ongoing since restart from the previous refueling outage, but had gone undetected by plant personnel.

• During a walkdown of the SSF, the inspectors noted an oily substance running down cables and on top of a pressurizer heater control cabinet. The licensee initiated WO 98348395 to clean the cabling and cabinet and to inspect inside the cabinet for any potential degradation.

• During a walkdown of the Unit 3 LPSW system, the inspectors noted that the plexiglass covers installed on the 3A LPSW pump motor bearing reservoirs, were cracked and missing sections of the corners. The inspectors noted that this same issue had caused a problem for another LPSW pump when it had gotten wetted down. The licensee initiated WO 98348547 to replace the degraded covers.

The licensee was effective in evaluating internal and external industry operating experience items for applicability and entering issues into the CAP. Operator logs were detailed regarding information associated with equipment deficiencies and almost always provided reference to PIPs that were generated for the problems.

Department self-assessments and audits performed by the Nuclear Performance Assessment Section (NPAS) and the Independent Nuclear Oversight Team were effective in identifying deficiencies and areas for improvement. The inspectors verified that issues raised during the assessments were entered into the CAP for resolution.

b. Prioritization and Evaluation of Issues

(1) Inspection Scope The inspectors reviewed selected PIPs associated with the seven risk significant plant systems and a representative sample of PIPs generated by each of the major plant department to determine if the identified problems were properly prioritized in accordance with licensee procedure NSD-208, Problem Investigation Process, Revision (Rev.) 27. The PIP action categories (Category 1 through 4) were defined in NSD-208 and were numbered based on decreasing significance and level of effort to resolve the problem. Action Category 1 PIPs are significant conditions adverse to quality (CAQs)that require formal root cause evaluations. Action Category 2 PIPs are defined as CAQs for which formal root cause evaluations are normally conducted, although management could use its discretion in deciding not to perform a formal root cause evaluation. Action Category 3 PIPs are problems for which an apparent cause analysis is sufficient to correct the immediate problem. Action Category 4 PIPs are low level CAQs or conditions not adverse to quality, neither of which require any type of causal evaluation. The inspectors attended daily management status meetings, PIP screening meetings, and engineering status meetings to observe licensee problem processing and issue categorization.

Selected licensee audits and self-assessments were reviewed to determine if identified issues were correctly classified for resolution in accordance with procedure NSD-607, Self-Assessments. Action Category 1, 2, and 3 PIPs were reviewed to assess the adequacy of the root/apparent cause evaluation of the selected problems. The inspectors reviewed the root/apparent cause evaluations against the description of the problem in the PIP and the guidance in procedure NSD-212, Cause

Analysis.

Documents reviewed are listed in the Attachment to this report.

(2) Assessment The inspectors determined that PIPs were generally categorized correctly; however, the inspectors identified several PIPs associated with lower significance issues that were incorrectly classified as Category 4 versus Category 3. These PIPs included O-03-5058, O-03-7578, O-04-4108, and O-05-3148.

Generally, the licensee performed adequate evaluations of issues that were technically accurate and of sufficient depth. Formal root cause evaluations for Category 1 and Category 2 PIPs were especially thorough and detailed. The inspectors did not identify any risk significant issues that had not been appropriately prioritized and evaluated.

However, the inspectors identified several minor problems involving PIPs that lacked thorough investigation and documentation. These issues included the following:

• PIP O-03-5531 described the 3A motor driven EFW pump failure to meet its required recirculation flow during testing due to debris plugging the impulse lines to the flow transmitter. The inspectors identified that there was no documented information on the nature of the debris found, nor how it got there. Also, in the problem description of the PIP, a statement was made that the surveillance test procedure would be revised with a caution alerting to the potential for impulse line plugging. However, a formal corrective action to implement this change was not opened in the PIP. Although the procedure change request was initiated, it was later rejected without any subsequent reference to the original PIP. The licensee initiated PIP O-05-4298 to address the inadequacies with handling the original PIP evaluation.

• PIP O-04-4896 described the failure of Keowee circuit breaker ACB-2 to operate due to a broken auxiliary contact connecting rod. The PIP investigation determined that the failed connecting rod had been cannibalized from the old breaker following breaker replacement in 1999. The inspectors identified that the investigation did not address the adequacy/appropriateness of the process that allowed using the old part on the new breaker. The licensee decided to re-open the PIP to add a corrective action item to re-investigate the circumstances and process used to replace the breaker connecting rod.

• PIP O-03-8181, documented an equipment deficiency related to the sump level high level alarm switch, 2LPILSS0091, for the Unit 2 Auxiliary Building Sump system. The inspectors identified that the PIP failed to identify that the switch function was scoped under the MR when the issue was originally screened. As a result, a 10 CFR 50.65(a)(1) review was not performed and there was a subsequent MR functional failure of the level switch in early 2005. The licensee initiated PIP O-05-4318 to address the inadequate MR review. During subsequent discussions with the licensee following the exit meeting, the licensee completed the MR review and determined that the original level switch problem was not a functional failure.

• PIP O-04-7004, described the failure of circuit breaker ACB-8 that supplies auxiliary power to KHU-2, which rendered the Keowee hydro unit inoperable.

One of the corrective actions in the PIP was to determine why there was a 25 minute delay in declaring the Keowee unit inoperable after the circuit breaker failure. The licensee identified that the Keowee unit operators failed to recognize initially that the condition rendered the Keowee unit inoperable; however, the inspectors noted that the investigation did not address the underlying reason for this lack of sensitivity to Technical Specification requirements for Keowee. The licensee indicated that the original PIP would be re-opened to add additional Technical Specification training for Keowee operators.

• PIP O-04-5776 involved a HPSW fitting that failed and partially drained the HPSW system. This fitting, along with several others, were installed as part of a modification of the HPSW system to support security modifications. The inspectors identified that the apparent cause evaluation failed to consider the risk of common cause failures to other, newly installed fittings. Subsequently, one month after the first failure, another fitting failed in a similar manner. The inspectors determined that this second failure may have been averted if adequate common causal consideration had been applied to all the new fittings.

c. Effectiveness of Corrective Actions

(1) Inspection Scope The inspectors reviewed selected PIPs associated with the seven risk significant plant systems and a representative sample of PIPs generated by each of the major plant department to verify that the licensee had identified and implemented timely and appropriate corrective actions to address the associated problems. The inspectors verified that the corrective actions were properly documented, assigned, and tracked to ensure completion. Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also verified that common causes and generic concerns were appropriately addressed. Documents reviewed are listed in the Attachment to this report.

(2) Assessment The inspectors determined that, overall, corrective actions developed and implemented for problems were timely, effective, and commensurate with the safety significance of the problem. However, several minor problems were identified related to the effectiveness of corrective actions for several lower significance issues. These issues included the following:

• PIP O-04-5704 involved problems aligning the EFW from the opposite Unit within the necessary 15 minutes during a High Energy Line Break (HELB) design basis accident. One of the licensees planned corrective actions to address this issue was to uprate the EFW cross-connect valves (i.e., EFW313, 314) to allow them to be capable of opening under the higher turbine driven EFW pump discharge pressures (from 1400 to 1600 psig). The inspectors noted that the licensee had decided not to hydro test the valves at the higher pressure which was contrary to the valve vendor recommendations. The PIP did not include adequate justification for not conducting the hydro test. Following discussions with the licensee concerning this matter, the licensee decided to implement the vendor recommendations.

• PIP O-02-6304 identified a non-conforming condition where a raised portion of the SSF cable trench was not adequately protected from tornado missiles as specified in the Updated Final Safety Analysis Report. The corrective action to provide a natural phenomenon barrier was combined with the licensees overall tornado mitigation project which was much more complex and still in the developmental stage. The inspectors were concerned that the relatively simple correction to the SSF cable trench was being delayed by combining it with the larger project. As a result of this observation, the licensees SSF risk reduction team decided it was prudent to expedite completion of the trench corrective action independent of the more comprehensive tornado mitigation project.

• PIP O-04-8171 involved the system design pressure of the LPSW being exceeded during the system startup following a refueling outage. The inspectors noted that there was no formal evaluation performed nor resulting corrective actions to address the issue. The PIP disposition indicated that no further action was necessary since the design pressure was not exceeded by too much. The inspectors determined that, most likely, weaknesses in the system startup procedure allowed the condition to occur, and it was reasonable that the licensee should have examined the procedure to identify any necessary enhancements to prevent exceeding the system design pressure in the future.

• PIP O-04-5018 identified that the LPSW maintenance rule database was updated with a new system function (i.e., LPS.15 - provide capability to manually sample the system) without developing any surveillance procedures to ensure that the function could be met. While the immediate problem to provide new surveillance procedures was addressed, the inspectors noted that the PIP failed to address why consideration for developing the procedures was not recognized to begin with and what corrective actions were necessary to address the cause of this oversight.

• PIP O-04-5365 identified a low bearing cooling water flow condition to a High Pressure Injection pump. During maintenance activities in the vicinity of the pump, a worker accidently bumped an isolation valve for the LPSW system and caused a low flow alarm. The issue was quickly identified and corrected. As part of the corrective action, WOs were initiated in 2004 to change this and many other similar valve handles in the area to a new handle type in order to minimize the possibility of this situation occurring again. However, the inspectors noted that none of the WOs had been accomplished, and only one had been planned.

d. Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors interviewed selected licensee personnel from each of the major plant departments to develop a general view of the safety-conscious work environment at Oconee Nuclear Station (ONS) and to determine if any conditions exist that would cause personnel to be reluctant to raise safety concerns. The inspectors also reviewed the licensees Employee Concerns Program (ECP), which provides an alternate method to the PIP process for employees to raise safety concerns with the option of remaining anonymous. The inspectors reviewed the program to determine if concerns were being properly reviewed and resolved.

(2) Assessment The inspectors concluded that licensee management fostered a safety-conscious work environment by emphasizing safe operations and encouraging problem reporting. The inspectors did not identify any reluctance on the part of licensee staff to report safety concerns.

4OA6 Meetings, Including Exit

On July 1, 2005, the inspectors presented the inspection results to Mr. Ron Jones, Site Vice President, and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during this inspection.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Batson, Superintendent of Operations

S. Capps, Mechanical/Civil Engineering Manager

T. Carroll, SRG Engineer

N. Clarkson, Regulatory Compliance Senior Engineer

G. Davenport, Compliance Manager

B. Hamilton, Station Manager

R. Jones, Site Vice President

R. Matheson, SRG Engineer

J. Smith, Regulatory Compliance

P. Stovall, SRG Manager

J. Weast, Regulatory Compliance

NRC Personnel

M. Ernstes, Branch Chief, Division of Reactor Projects (DRP) Region II (RII)

E. Riggs, Resident Inspector, RII

M. Shannon, Senior Resident Inspector, RII

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE

Opened and Closed

NONE

Closed

NONE

Discussed

NONE