IR 05000269/2019003
| ML19311C347 | |
| Person / Time | |
|---|---|
| Site: | Oconee, 07000004  (DPR-038, DPR-047, DPR-055, SNM-2503) |
| Issue date: | 11/07/2019 |
| From: | Frank Ehrhardt NRC/RGN-II/DRP/RPB1 |
| To: | Burchfield J Duke Energy Carolinas |
| J. Worosilo, RGN-II/DRP/RPB1 | |
| References | |
| IR 2019003 | |
| Download: ML19311C347 (25) | |
Text
November 7, 2019
SUBJECT:
OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2019003, 05000270/2019003, 05000287/2019003, AND 07200004/2019002
Dear Mr. Burchfield,
Jr.:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On October 21, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Oconee.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Oconee.
J. Burchfield, Jr.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Frank J. Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects
Docket Nos. 50-269, 50-270, 50-287,72-004 License Nos. DPR-38, DPR-47,
Enclosure:
IR 05000269/2019003, 05000270/2019003, 05000287/2019003, and 07200004/2019002
Inspection Report
Docket Numbers:
50-269, 50-270, 50-287,72-004
License Numbers:
DPR-38, DPR-47, DPR-55, SNM-2503
Report Numbers:
05000269/2019003, 05000270/2019003, 05000287/2019003,
07200004/2019002
Enterprise Identifier: I-2019-003-0022, I-2019-002-0084
Licensee:
Duke Energy Carolinas, LLC
Facility:
Oconee Nuclear Station
Location:
Seneca, SC
Inspection Dates:
July 01, 2019 to September 30, 2019
Inspectors:
J. Nadel, Senior Resident Inspector
J. Parent, Resident Inspector
A. Ruh, Resident Inspector
A. Thomas, Acting Resident Inspector
C. Fontana, Emergency Preparedness Inspector
G. Hutto, Senior Resident Inspector (McGuire)
S. Sanchez, Senior Emergency Preparedness Inspector
J. Tornow, Physical Security Inspector
J. Walker, Emergency Preparedness Inspector
Approved By:
Frank J. Ehrhardt, Chief
Reactor Projects Branch 1
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Oconee Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Control of Heavy Load in Spent Fuel Pool Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000287/2019003-01 Open/Closed
[H.4] -
Teamwork 71111.13 Inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1, Procedures, when the licensee failed to properly pre-plan and control a heavy load lift in the Unit 3 spent fuel pool.
Failure to Notify the NRC within Eight Hours following the Discovery of a Condition that could have Prevented the Fulfillment of the Unit 1 Core Flood Systems Safety Function Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000269/2019003-02 Open/Closed Not Applicable 71111.15 The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.72(b)(3)(v) when the licensee failed to notify the NRC within eight hours following the discovery of a condition that could have prevented the fulfillment of a safety function. Specifically, the Unit 1 core flood system, which is a system needed to mitigate the consequences of an accident, was inoperable because the Unit 1A core flood tank vent valve, 1CF-5, failed to close during a normal venting evolution.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000269/2019-001-00 LER 2019-001-00 for Oconee Nuclear Station,
Unit 1, Standby Shutdown Facility Reactor Coolant Makeup Pump Oil Suction Tubing Failure.
71153 Closed
PLANT STATUS
Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.
Unit 2 operated at or near 100 percent RTP for the entire inspection period.
Unit 3 operated at or near 100 percent RTP for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding for the following areas:
- Standby shutdown facility (SSF) and the auxiliary, turbine, and service buildings regarding maintenance of a 6-inch water sill and resolution of nonconforming conditions in Nuclear Condition Report (NCR) 1905081.
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) SSF alignment during dual Keowee Hydro Unit Outage on July 16-17, 2019
- (2) Unit 3 "A" train high pressure injection (HPI) system, on August 6, 2019 (3)230kV Switch Yard Battery #2 alignment following service test & recharge on August 14, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) Inspectors evaluated system configuration during a complete walkdown of the Unit 1 turbine driven emergency feedwater system, with additional in-office review.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 2 auxiliary building Elevation 838', Fire Zone 117 on August 1, 2019
- (2) Unit 3 auxiliary building Elevation 822', Fire Zone 112 on August 1, 2019
- (3) Unit 1 auxiliary building Elevation 822', Fire Zone 110 on August 2, 2019
- (4) Unit 1 and 2 auxiliary building Elevation 838', Fire Zone 119 on August 2, 2019
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during Units 1, 2, and 3 turbine stop valve testing, on August 8, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operators perform a requal simulator exercise which involved a 1A reactor building cooling unit cooler rupture, 1A2 reactor coolant pump high vibration, delta Tc failure,1CC-8 failed closed causing a reactor trip, station blackout, and turbine driven emergency feedwater pump failure to auto start, on August 27, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) NCR 2272633, 230kV Yellow Bus CCVTs failed Doble testing and were taken out of service for repair
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Risk assessment and work controls for July 16-17, 2019, during a dual Keowee Hydro Unit Outage
- (2) Risk assessment and work controls for July 19, 2019, during CT-1 Open Phase Protection Mod tie-in
- (3) Risk assessment and work controls for rigging a heavy load (3SF-2 valve) across the spent fuel pool on August 20, 2019
- (4) Risk assessment and work controls for August 20-21, 2019, during an SSF outage to perform maintenance on CCW-289
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (7 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Immediate determination of operability (IDO) for NCR 2280231, Unit 1 low pressure service water operability with pinhole leak downstream of 1LPSW-356
- (2) IDO of the SSF standby battery system for a seismic event with temporary equipment (battery charger) staged adjacent to battery and its structural supports
- (3) IDO for NCR 2285443, Unit 1 protected service water (PSW) piping following NRC identification of potential seismic interaction concern with unsecured door
- (4) IDO for NCR 2286307, 3B low pressure service water (LPSW) pump min flow line degraded due to partial blockage and use of manual bypass valve
- (6) IDO for NCR 02283825, SSF Diesel Fuel Oil Tank Inspection Issue
- (7) IDO for NCR 2282444, KPF-9 breaker closed unexpectedly when 86E lockout relay was reset
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Changes to bases for TS 3.7.10 allowing an underground Keowee hydro unit to be credited for protected service water operability
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Work Order (WO) 20340144-01, testing of modified switch for 2LWD-1 containment isolation valve on July 11, 2019
- (2) WO 20173119-05, Unit 3 HPI flow transmitter FT0007A replacement post-maintenance test (PMT) on July 29, 2019
- (3) PT/2/A/0600/013, "Motor Driven Emergency Feedwater Pump Test," on August 7, 2019
- (4) PT/0/A/0400/005, "SSF Auxiliary Service Water Pump Test," on August 24, 2019
- (5) PT/1/A/0261/010, "Essential Siphon Vacuum System Test," on August 26, 2019
- (6) WO 20329003, testing of 1PSW-24 valve following replacement of valve positioner board on September 4, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) WO 20249209-01, PT/0/A/0620/016, Keowee Hydro Emergency Start Test on, July 9, 2019
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) PT/3/A/0203/006 A, Low Pressure Injection Pump Test - Recirculation on the 3B Low Pressure Injection Pump on July 3, 2019
- (2) PT/3/A/0251/001, Low Pressure Service Water Pump Test on the 3B LPSW Pump on August 11, 2019
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) WO 20325326, U0 Flex Equipment: Perform Functional Test and Inspection on July 22, 2019
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of September 16, 2019.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of September 16, 2019.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of September 16, 2019. This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of September 16, 2019.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Inspectors observed an emergency preparedness drill on July 17, 2019, that involved a faulted steam generator with a tube leak and damaged fuel. There was also a fuel handling accident in the spent fuel pool and a fire brigade response due to smoke coming from the Keowee hydro main step-up transformer.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
- (1) Drill & Exercise Performance for the period July 1, 2018, through June 30, 2019.
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) Emergency Response Organization Drill Participation for the period July 1, 2018, through June 30, 2019.
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) Alert & Notification System Reliability for the period July 1, 2018, through June 30, 2019.
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (3 Samples)
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
- (2) Unit 2 (July 1, 2018, June 30, 2019)
- (3) Unit 3 (July 1, 2018 - June 30, 2019)
MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
- (2) Unit 2 (July 1, 2018 - June 30, 2019)
- (3) Unit 3 (July 1, 2018 - June30, 2019)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (3 Samples)
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
- (2) Unit 2 (July 1, 2018 - June 30, 2019)
- (3) Unit 3 (July 1, 2018 - June 30, 2019)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) NCR 2270635 - Resolution of NRC identified problem regarding conflicting technical conclusions on failure mode of the SSF diesel fuel oil pump seal (aging vs. foreign material intrusion)
- (2) NRC 2288543 - Engine Systems, Inc. (Part 21) - Oconee review and evaluation of applicability and effect
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000269/2019-001-00, Unit 1 Standby Shutdown Facility Reactor Coolant Makeup Pump Oil Suction Tubing Failure (ML19225C402). The circumstances surrounding this LER are documented in Inspection Report 05000269/2019090 Section 71152B.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants
- (1) The inspectors evaluated the licensees independent spent fuel storage installation cask loading for Dry Storage Cask (DSC) 159 from July 8, 2019 through July 10, 2019. Specifically, the inspectors observed the following activities;
- Fuel selection and fuel loading
- Heavy load movement of empty/loaded DSC
- Transfer and transport evolutions
- Radiological field surveys
INSPECTION RESULTS
Inadequate Control of Heavy Load in Spent Fuel Pool Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green NCV 05000287/2019003-01 Open/Closed
[H.4] -
Teamwork 71111.13 Inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1, Procedures, when the licensee failed to properly pre-plan and control a heavy load lift in the Unit 3 spent fuel pool.
Description:
On August 20, 2019, the licensee transported a heavy load across the Unit 3 spent fuel pool in support of a permanent plant modification to upgrade the fuel pool transfer tube isolation valve. Engineers developed an engineering change (EC) 412504 to provide a technical basis for the maintenance activity, a basis for a future engineered lift plan, and to assess and manage the increase in risk that may result from the maintenance activity. The EC concluded that the developed mitigation and handling measures were within the guidelines of site rigging/lifting procedures and the site licensing basis associated with NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, Phase I commitments.
Since the modification (EC 412504) planned to utilize the spent fuel bridge auxiliary hoist to handle a heavy load near spent fuel, a new safe load path was developed and documented in an engineered lift plan. While traversing over the fuel assemblies, the load was to be secured to the bridge by four wire rope safety slings and engineered temporary saddle beams. Once the load was no longer over fuel, near the far end of the pool, the safety slings could be removed, and the load would be suspended from a combination of the bridge auxiliary hoist and four submersible lift bags. The lift plan included an additional restriction that the load shall never be suspended closer than 15 feet horizontally from spent fuel. To satisfy this restriction, reactor engineering relocated spent fuel to create a 17-foot radius from the end of the pool. During planning reviews, these actions and restrictions were considered adequate. However, factors that would apply at the location where the load would transition to a suspended load (such as limitations on the positioning of the bridge and the location of the engineered saddle beams) had not been considered.
As a result, during execution of the modification while transitioning the load to the suspended configuration, riggers suspended the 7,100 pound and 121/2 foot tall valve within approximately five horizontal feet of spent fuel. This load was suspended by the 4,000-pound bridge hoist and a set of four 2,000-pound lift bags. During the transition to the bridge hoist, an air supply line to one of the four lift bags became detached due to contact with the removed safety slings. The bag maintained its buoyancy and was repaired by a diver. The load was then drifted to the final installation area and securely installed on the fuel transfer tube.
NRC inspectors identified that although the equipment used was adequate to suspend the load, the failure to adequately pre-plan the location and physical transition to a suspended configuration resulted in a failure to satisfy the engineered lift plan safe load path restriction of maintaining a 15-foot clearance from fuel. Workers also failed to identify the inability to meet the restriction during work execution because there was an impression that the amount of fuel removed from the area was adequate and because the knowledgeable lift engineer was present for the work. These failures negatively impacted the defense-in-depth approach taken to minimize the potential for adverse interaction of heavy loads with spent fuel.
Corrective Actions: The licensee initiated evaluations to identify organizational causal factors and issued a crew learning to the team to explain the difference between shall and should as defined in procedure AD-HU-ALL-0004, Procedure and Work instruction Use and Adherence.
Corrective Action References: NCR 2289055
Performance Assessment:
Performance Deficiency: The failure to properly pre-plan and control a heavy load lift near spent fuel was a performance deficiency. Specifically, engineers failed to establish conditions that ensured all lift plan restrictions could be met during the evolution and the installation team executed the lift without recognizing that safe load path restrictions were violated.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, if the heavy load were dropped on the spent fuel racks, damage to fuel assemblies and a release of fission products could have occurred.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, Barrier Integrity Screening Questions associated with the spent fuel pool, the finding was determined to be Green because it did not adversely affect the decay heat removal capabilities or water inventory of the spent fuel pool, was not associated with crane operations that caused mechanical damage to fuel cladding or a fuel bundle misplacement, and did not affect the spent fuel pool neutron absorber, or soluble boron concentration.
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Inspectors concluded that the error occurred because of a lack of coordination and planning among various departments regarding the location of the transition to a suspended configuration and the amount of spent fuel to remove from the vicinity.
Enforcement:
Violation: Oconee Unit 3 Technical Specification 5.4.1, Procedures, states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Paragraph 9.a, Procedures for Performing Maintenance, requires that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, on August 20, 2019, EC 412504 and the subsequent engineered lift plan were not properly pre-planned resulting in WO 20185881 being performed with procedures, instructions, and drawings that were not appropriate to the circumstances. Specifically, the plans failed to appropriately describe and control the location where the load could transition from a secured load to a suspended load while maintaining the desired clearance from spent fuel. This failure resulted in a 7,100 pound and 121/2 foot tall valve being suspended within approximately five horizontal feet of spent fuel.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Notify the NRC within Eight Hours following the Discovery of a Condition that could have Prevented the Fulfillment of the Unit 1 Core Flood Systems Safety Function Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000269/2019003-02 Open/Closed
Not Applicable 71111.15 The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50.72(b)(3)(v) when the licensee failed to notify the NRC within eight hours following the discovery of a condition that could have prevented the fulfillment of a safety function.
Specifically, the Unit 1 core flood system, which is a system needed to mitigate the consequences of an accident, was inoperable because the Unit 1A core flood tank vent valve, 1CF-5, failed to close during a normal venting evolution.
Description:
At approximately 0400 on July 24, 2019, the licensee began to vent the 1A core flood tank (CFT), by opening 1CF-5, due to a rise in pressure resulting from increased seasonal temperatures. The 1A CFT pressure lowered to an acceptable value and the licensee tried to close 1CF-5 to halt the venting. However, 1CF-5 failed to close and the depressurization of the 1A CFT continued until pressure dropped below the TS allowed minimum. The licensee entered TS Limiting Condition for Operation (LCO) 3.5.1, Condition B for one CFT inoperable. The licensee dispatched operators to restore nitrogen overpressure to the tank by aligning the nitrogen feed system. At 0526, the licensee restored the pressure in 1A CFT to above the TS allowed minimum utilizing a continuous nitrogen feed-and-bleed process. At 0744, the licensee closed the manual isolation valve downstream of 1CF-5 and isolated the nitrogen feed, stabilizing 1A CFT pressure at an acceptable level.
Later that day, licensee engineers determined that although the nitrogen feed-and-bleed process was established to raise the CFT pressure back above the TS allowed minimum, the 1A CFT remained inoperable until the closure of the downstream manual isolation valve (approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later). This conclusion was based on: 1) a safety analysis that credited 1A CFT injection later during an accident than what the 1A CFT would have been able to accomplish on the morning of July 24, 2019, and 2) calculated depressurization rate without crediting the continuous feed of nitrogen, since nitrogen would be manually isolated by procedure under accident conditions. The total inoperability time of the 1A CFT remained less than any required action time to shut down the Unit, so operation in a condition prohibited by technical specifications did not occur.
Resident inspectors reviewed licensee corrective action documents and noted that no discussion of a potential 10 CFR 50.72 missed notification was documented. The inspectors questioned the licensee on whether a 10 CFR 50.72 notification should have been made due to the vent valve failure causing the loss of the CFT safety function. The licensee confirmed that they had missed notifying the NRC within eight hours.
Corrective Actions: The licensee took corrective actions that included initiating a Licensee Event Report to be submitted to the NRC within 60 days, incorporating this operating experience into continuing and initial senior reactor operator, shift technical advisor, and shift manager training, initiating a Crew Learning, and developing an Operations Supplemental Information Package.
Corrective Action References: NCR 2288160.
Performance Assessment:
The inspectors determined this violation was associated with a minor ROP performance deficiency.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: Based on the examples provided in Section 6.9 of the Enforcement Policy, dated May 28, 2019 Inaccurate and Incomplete Information of Failure to Make a Required Report, the performance deficiency was determined to be a SL IV violation. Specifically, Example 6.9 states that a SL IV violation involves a failure to make a report to the NRC in accordance with 10 CFR 50.72.
Violation: 10 CFR 50.72, Immediate notification requirements for operating nuclear power reactors, Section (b)(3)(v) requires, in part, the licensee to notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. Contrary to the above, on July 24, 2019, the licensee failed to notify the NRC within eight hours of the Oconee Unit 1A core flood tank vent valve, 1CF-5, failing to close, which rendered the 1A CFT inoperable and resulted in the loss of the core flood systems safety function, which is needed to mitigate the consequences of an accident.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 21, 2019, the inspectors presented the integrated inspection results to J. Ed Burchfield, Jr. and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
60855.1
Miscellaneous
Oconee Nuclear Station
Independent Spent Fuel
Storage Installation 10 CFR
2.212 Evaluation for Phase
VIII
CR 2281189
NUH-003
Updated Final Safety Analysis
Report for the Standardized
NUHOMS Horizontal
Modular Storage System for
Irradiated Nuclear Fuel
Procedures
AD-HU-ALL-
0004
Procedure and Work
Instruction Use and Adherence
AD-HU-ALL-
0005
Human Performance Tools
MP/0/A/1500/024 Independent Spent Fuel
Storage Installation Phase VIII
DSC Loading and Storage
000
Work Orders
Calculations
OSC-10671
PMP Flood Building
Assessment and Leak Rate
Data
OSC-8849
Design Inputs for Aux. Bldg.
Flood Protection due to MFDW
Line Break or Crack in East
Penetration Rooms
OSC-9010
HELB Flood Impoundment
Design, Units 1, 2, and 3 for
East Penetration Room
Corrective
Action
Documents
1905081, 2126024, 2287997
Drawings
O-0320-C
Standby Shutdown Facility
Sections Concrete
O-0950-C
Electrical Equipment Layout
Outdoors Computer Cable
Routing
O-0954-A
Electrical Equipment Layout
Standby Shutdown Facility
O-PDF-0003
Event Flood Barriers
O-PDF-0003
Event Flood Barriers
5A
Engineering
Changes
401069
Resolution of Nonconformance
Related to ONS Site Grade
and Removal of Sandbags
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
NSM ON-2347
Power Supply for SSF Flood
Barrier Sump Pump
Miscellaneous Oconee Nuclear
Station Site
Survey Data
Oconee Nuclear Door Ways
1/9/2016
Site Directive
3.2.16
Control of Passive Design
Features
Procedures
AP/0/A/1700/006
Natural Disaster
MP/0/A/3005/001 Flood Outlet Devices and
Flood Barriers PM
RP/0/A/1000/035
Severe Weather Preparations
71111.04Q Calculations
OSC-10671
Civil Assessment for
Probabilistic Maximum
Precipitation (PMP) Flood
Concerns, Building: 230 kV
Relay House
Corrective
Action
Documents
NCR 2282472, 2282507,
284859
PRR 2282557, TRF 2285442
Drawings
O-0702-B
One Line Diagram 4160 and
600V Essential Load Centers
Auxiliary Power Systems
Standby Shutdown Facility
O-0703-K
One Line Diagram 600V and
208V Essential Motor Control
Centers Auxiliary Power
Systems Standby Shutdown
Facility
O-0703-L
One Line Diagram
208/120VAC & 120VAC Power
Panelboards
O-PDF-0003
ARCH - Event Flood Barriers -
Plan
005
OFD-101A-3.3
Unit 3 High Pressure Injection
System
OFD-121A-1.4
Flow Diagram of Condensate
System (Hotwell Pumps,
Condensate Coolers,
Generator Water Coolers, &
Hydrogen Coolers)
OFD-121A-1.7
Flow Diagram of Condensate
System (Upper Sure Tanks 1A
& 1B, Upper Surge Tank
Dome, & Condensate Storage
Tank)
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
OFD-121A-1.8
Flow Diagram of Condensate
System (Condensate Make-up
& Emergency FDW Pump
Suction)
OFD-121B-1.3
Flow Diagram of Feedwater
System (Final Feedwater)
OFD-121D-1.1
Flow Diagram of Emergency
Feedwater System
OFD-127C-1.2
Flow Diagram of Nitrogen
System (Nitrogen Supply to
1FDW-315/1FDW-316)
OSFD-121D-1
Summary Flow Diagram of
Miscellaneous EC 408447
Resolution of Nonconformance
Related to ONS Site Grade
and Removal of Sandbags
003
OSS-0254.00-
00-1005
(MECH) Design Basis
Specification for the Standby
Shutdown Facility Auxiliary
Service Water System
OSS-0254.00-
00-2014
(ELECT) DBD for the
4160/600/120V SSF Essential
AC Power System
017
Procedures
AD-DC-ALL-
202
Writers Manual for Procedures
and Work Instructions
AD-EG-ALL-
1106
Configuration Management
and Margin Management
AD-HU-ALL-
0004
Procedure and Work
Instruction Use and Adherence
AD-OP-ALL-
204
Plant Status Control
AM/0/A/1300/059 Pump - Submersible -
Emergency SSF Water Supply
- Installation and Removal
2
AP/0/A/1700/025
Standby Shutdown Facility
Emergency Operating
Procedure
063
OP/0/A/1600/005
SSF Normal Power
OP/0/A/1600/007
SSF Diesel Air System
20
OP/0/B/1600/011
SSF Systems Isolation
Procedure
OP/1/A/1106/006
2
Work Orders
WO 20273756-02, 20304779
71111.05Q Fire Plans
CSD-ONS-PFP-
Pre-Fire Plan for U1 Auxiliary
Building Elevation 822
000
CSD-ONS-PFP-
Pre-Fire Plan for U1 Auxiliary
000
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
Building Elevation 838
CSD-ONS-PFP-
Pre-Fire Plan for U2 Auxiliary
Building Elevation 838
000
CSD-ONS-PFP-
Pre-Fire Plan for U3 Auxiliary
Building Elevation 822
000
Miscellaneous O-0310-K-016
Auxiliary & Reactor Building -
Unit 1 Fire Protection Plan &
Fire Barrier, Flood & Pressure
Boundaries Plan at EL 838+0
& 844+6
2
Procedures
AD-EG-ALL-
22
Duties of a Fire Watch
MP/0/A/1705/032
A
Fire Extinguishers - Auxiliary
Building - Monthly Inspection
2
71111.11Q Procedures
AD-EP-ALL-0803 Evaluation and Critique of Drills
and Exercises
AD-LS-ALL-0006
Notification/Reportability
Evaluation
AD-OP-ALL-
1000
Conduct of Operations
AD-OP-ALL-
1001
Conduct of Abnormal
Operations
AD-TQ-ALL-0420 Conduct of Simulator Training
and Evaluation
AP/1/A/1700/011
Recovery from Loss of Power
059
AP/1/A/1700/016
Abnormal Reactor Coolant
Pump Operation
036
AP/1/A/1700/020
Loss of Component Cooling
2
EP/1/A/1800/001
Unit 1 EOP Immediate Manual
Actions and Subsequent
Actions
2
OMP 1-18
Oconee - Specific
Implementation Standard
During Abnormal and
Emergency Events
045
OMP 1-24
Operations Communication
Standard
017
OP-OC-ASE-44
Simulator Exercise Guide
PT/3/A/0290/004
Turbine Stop Valve Testing
014
RP/0/A/1000/001
Emergency Classification
006
RP/0/A/1000/002
Control Room Emergency
Coordinator Procedure
013
Corrective
Action
NCR 2272633
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
Documents
Procedures
AD-EP-ALL-0803 Evaluation and Critique of Drills
and Exercises
AD-LS-ALL-0006
Notification/Reportability
Evaluation
AD-OP-ALL-
1000
Conduct of Operations
AD-OP-ALL-
1001
Conduct of Abnormal
Operations
AD-TQ-ALL-0420 Conduct of Simulator Training
and Evaluation
AP/1/A/1700/011
Recovery from Loss of Power
059
AP/1/A/1700/016
Abnormal Reactor Coolant
Pump Operation
036
AP/1/A/1700/020
Loss of Component Cooling
2
EP/1/A/1700/001
Unit 1 EOP Immediate Manual
Actions and Subsequent
Actions
2
OMP 1-18
Oconee - Specific
Implementation Standard
During Abnormal and
Emergency Events
045
OMP 1-24
Operations Communication
Standard
017
OP-OC-ASE-44
Simulator Exercise Guide
RP/0/A/1000/001
Emergency Classification
006
RP/0/A/1000/002
Control Room Emergency
Coordinator Procedure
013
Calculations
OSC-1160
Postulated Cask Drop
Accident-Poison Racks
Drawings
21777-28
Refueling Machine General
Arrangement
D3
O-308C-SLP
Auxiliary Building Plan at Elev.
838 + 0 & 844 + 0 Safe Load
Paths
Miscellaneous
Projected ERAT Risk Profile
Oconee Nuclear Station Plant
Status Package on July 16 and
17, 2019
Industry Guideline for
Monitoring the Effectiveness of
Maintenance at Nuclear Power
Plants
4a
Monitoring the Effectiveness of
Maintenance at Nuclear Power
Plants
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
Procedures
AD-EG-ALL-
1004
Conduct of Probabilistic Risk
Analysis Engineering
AD-EG-ALL-
1132
Preparation and Control of
Design Change Engineering
Changes
AD-NF-ALL-0501 Electronic Risk Assessment
Tool (ERAT)
AD-NF-NGO-
0502
Probabilistic Assessment
(PRA) Model Technical
Adequacy
AD-WC-ALL-
200
On-Line Work Management
AD-WC-ALL-
240
On-Line Risk Management
Process
OP/0/A/1107/011
F
Sharing Startup Transformers
Between Units
014
PD-MN-ALL-
0009
Nuclear Rigging & Lifting
Program
Work Orders
WO 20173938, 20330072
Calculations
KC-2190
Failure Mode and Effects
Analysis (FMEA) for the
Keowee 13.8kV Switchgear
(KPF) Power Feeds to
Protected Service Water
System (PSW) Switchgear
(B6T/B7T)
OSC-473
LPSW Between Discharge
Nozzles of Decay Heat Cooler
2B, RB Component Coolers
1A, A, 2A, Aux. Bldg. and T.B.
Basement Floor Piping
Analysis Problem No. 2-14-05
OSC-5649
LPSW Test Acceptance
Criteria
OSC-8159
SSF Diesel Fuel Oil Storage
Tank Inspection
Corrective
Action
Documents
NCR 1937031, 2283825,
283504, 2285028, 2288160
PRR 2283847, 2285047,
285048, 2285049
273613, 2285443
Drawings
KEE-0117-01-0A
Elementary Diagram Keowee
Oconee Remote Controls
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
KEE-0119
Elementary Diagram PSW
Emergency Power 13.8kV
Feeder Bkr KPF-9 Control
Circuit
KM 303-
0036.001
Instruction Manual for 15kV
Switchgear
O-0706
One Line Diagram Essential
SSF 125 VDC Auxiliary Power
Systems
OFD-124B-1.1
Flow Diagram of Low Pressure
Service Water System
(Auxiliary Building Services)
Engineering
Changes
115245
Replace Charging Spring
Relays in Bkrs KPF-09 & 10
91875
Keowee AC Power Supply Tie-
ins
Miscellaneous LCOTR Number
O-0-19-00905
SSF Standby Battery Cell #5
does not meet Category A or B
Tracking Only
NSD-104
Material
Condition/Housekeeping, and
Seismic Concerns
OSS-0254.00-
00-2020
(ELECT) SSF 125 VDC
Essential Power System
Procedures
MP/0/A/5050/039 Diesels - SSF - 12 and 16
Cylinder - Preventive
Maintenance and Inservice
Inspection - 10 and 12 Year
013
OP/0/A/1600/006
Operation of SSF KSF1/KSF2
Inverters and SSF CSF/CSFS
Battery Chargers
26
OP/1/A/1104/001
Core Flooding System
PT/3/A/0251/001
Low Pressure Service Water
Pump Test performed on
August, 9, 2019
Work Orders
WO 20328847, 02063567
Calculations
KC-2079
Governor Oil Pressure Tank,
Oil and Air Minimum Design
Pressure
OSC-9314
NFPA 805 Transition Risk-
Informed Performance-Based
Fire Risk Evaluation
Corrective
01905036, 02294192
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
Action
Documents
Miscellaneous
Technical Specification Bases 3.7.10
Duke Letter RA-
19-0116 dated
February 26,
2019
Duke Energy Response to
NRC Request for Additional
Information (RAI) Related to
Oconee License Amendment
Request 2017-05
Procedures
AP/0/A/2000/002
Keowee Hydro Station -
Emergency Start
EP/2/A/1800/001
0Q
Unit 2 EOP Enclosures 5.41 -
5.46
Drawings
OEE-260-15
Elementary Diagram Waste
Disposal System RB Normal
001 2LWDVA0001
OEE-165-04
Elementary Diagram Protected
Service Water Steam
Generator 1B Flow Control
MOV 1 PSW-24
OFD-101A-3.3
Flow Diagram of High Pressure
Injection System (Charging
Section)
OFD-101A-3.4
Flow Diagram of High Pressure
Injection System (Charging
System)
Engineering
Changes
415742
Procedures
IP/0/A/0101/001
Low Risk maintenance
Configuration Control
IP/3/A/0202/001
D
High Pressure Injection System
Emergency HP Injection Flow
Instrument Calibration
006
PT/0/A/0400/005
SSF Auxiliary Service Water
Pump Test
069
PT/1/A/0261/010
Essential Siphon Vacuum
System Test
20
PT/2/A/0152/014
Liquid Waste Disposal System
Valve Stroke Test
Work Orders
WO 20173119-05, 20173938,
240445, 20274863
Calculations
OSC-2280
LPSW NPSHA and Minimum
Required Lake Level
OSC-4489
Predicted Unit 3 LPSW System
Response to a Large-Break
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
LOCA with Single Failure
Using a Benchmarked
Hydraulic Computer Model
OSC-5649
LPSW Test Acceptance
Criteria (TAC)
OSC-6098
LPSW Instrument Uncertainty
Corrective
Action
Documents
NCR 2271297
Drawings
OEE-120
Elementary Diagram Channel
A Keowee Emergency Start
OEE-120-01
Elementary Diagram Channel
B Keowee Emergency Start
OEE-120-1-A
Elementary Diagram Channel
B Keowee Emergency Start
Contact Development
OEE-120-A
Elementary Diagram Channel
A Keowee Emergency Start
Contact Development
OEE-320
Elementary Diagram Channel
A Keowee Emergency Start
(Unit 3)
OEE-320-1
Elementary Diagram Channel
B Keowee Emergency Start
(Unit 3)
Miscellaneous
Recommended Maintenance
Program - Mechanical Nuclear
Standby Emergency Diesel
Generators
ONTC-3-124A-
0001-001
Test Acceptance Criteria
Procedures
PT/0/A/0620/016
Keowee Hydro Emergency
Start Test
PT/3/A/0203/006
A
Low Pressure Injection Pump
Test - Recirculation
094
Work Orders
WO 20249209-01, 20321990,
20325326-01, 20325326-05
Miscellaneous
ONS Drill 19-02 Scenario
Manual
Critique Report for July 17,
2019 Drill
71151
Miscellaneous
Safety System Functional
Report for period ending in
June 2019, Units 1, 2, 3
Inspection
Procedure
Type
Designation
Description or Title
Revision
or Date
Performance Index (MPSI)
Basis Document
MSPI Derivation Report for
period ending June 2019, Units
1, 2, 3 Heat Removal System
MSPI Indicator Margin Report
for period ending June 2019,
Units 1, 2, 3 Heat Removal
System
CP/0/A/2005/022
Determination of Reported
Tech Spec Dose Equivalent
006
Corrective
Action
Documents
2186873, 1824462, 02288543,
289565
Miscellaneous
Preventive Maintenance
Change 02277613