IR 05000269/2020002

Integrated Inspection Report 05000269/2020002 and 05000270/2020002 and 05000287/2020002

ML20224A059
Person / Time
Site:	Oconee
Issue date:	08/11/2020
From:	Frank Ehrhardt NRC/RGN-II/DRP/RPB1
To:	Burchfield J Duke Energy Carolinas
References
IR 2020002
Download: ML20224A059 (27)

Text

August 11, 2020

SUBJECT:

OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2020002 AND 05000270/2020002 AND 05000287/2020002

Dear Mr. Burchfield:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On July 27, 2020, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. 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 the 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 Nuclear Station. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Frank J. Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000269 and 05000270 and 05000287 License Nos. DPR-38 and DPR-47 and DPR-55

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000269, 05000270 and 05000287 License Numbers: DPR-38, DPR-47 and DPR-55 Report Numbers: 05000269/2020002, 05000270/2020002 and 05000287/2020002 Enterprise Identifier: I-2020-002-0060 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station Location: Seneca, South Carolina Inspection Dates: April 01, 2020 to June 30, 2020 Inspectors: J. Nadel, Senior Resident Inspector J. Parent, Resident Inspector A. Ruh, Resident Inspector B. Collins, Senior Reactor Inspector Approved By: Frank J. Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

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 Alarm Response Guide for ES Voter Trouble Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.18 Systems NCV 05000269,05000270,05000287/202000 2-01 Open/Closed A NRC identified Green Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, was identified when the licensee failed to maintain alarm response guides OP/1/A/6101/007, OP/2/A/6102/007, and OP/3/A/6103/007 appropriate to the circumstances.

Failure to Correct Cubicle Door Interference Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000269,05000270,05000287/202000 2-02 Open/Closed A self-revealed Green Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action, was identified when the licensee failed to correct a condition adverse to quality associated with a standby shutdown facility breaker cubicle door interference that impaired accessibility for in-service inspection, maintenance, and repair.

Additional Tracking Items

None.

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 began the inspection period at or near 100 percent RTP. On April 10, 2020 the unit was shutdown for a scheduled refueling outage. The unit was returned to 100 percent RTP on May 11, 2020 and remained at or near 100 percent RTP for the remainder of the 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 3 low pressure injection system (B train) during reactor coolant system draindown to 80 inches on April 14, 2020

(2) Low pressure service water train A during Unit 3 refueling outage on April 21, 2020

(3) Low pressure service water train B during Unit 3 refueling outage on April 21, 2020

(4) Low pressure service water train C during Unit 3 refueling outage on April 21, 2020

(5) CT5 power alignment while CT3 was out of service due to planned maintenance during Unit 3 refueling outage, on April 23, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) Unit 3 recirculated cooling water system while Unit 3 was defueled with all fuel assemblies in the spent fuel pool on April 23, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Protected area - south fire zone ESVB (Building 8084) on April 15,2020

(2) U1 and U2 auxiliary building elevation 758', fire zones 55/55A/56, on May 14, 2020

(3) Unit 1 auxiliary building 2nd floor hallway, fire zone 85, on June 5, 2020

(4) Unit 2 cable room, fire zone 105, on June 5, 2020

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

The inspectors evaluated pressurized water reactor non-destructive testing by reviewing the following examinations from April 13 - 17, 2020:

(1) 03.01.a - Nondestructive Examination and Welding Activities.

1. Ultrasonic Examination (UT)a. 3" high pressure injection system nozzle piping welds (3-RC-211-70,-

73), ASME Class 1 (reviewed)2. Liquid Penetrant Examination (PT)a. 36" main steam system pipe support (3-01A-0-2401B-H18), ASME Class 2 (reviewed)3. Radiographic Testing (RT)a. 3" high pressure injection system pipe-to-pipe weld (3-HP-0351-60),

ASME Class 2 (reviewed, including welding documentation)

The inspectors reviewed the licensee's boric acid corrosion control program performance.

The inspectors reviewed the licensee's justification for skip-cycle approach on steam generator inservice inspection activities.

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 U3 draindown of the reactor coolant system (RCS) to 80 inches on April 14, 2020

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated crew performance evaluation segment 2001, including a simulated steam generator tube rupture, on June 10, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (4 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Nuclear Condition Report (NCR) 2321306, standby shutdown facility (SSF) and failure on March 18, 2020

(2) NCR 2326989, elevated water storage tank level dropped below 70,000 gallons on April 6, 2020

(3) NCR 2204828, Unit 3 recirculating cooling water system and failure on April 21, 2020

(4) NCR 2334425, quality control (QC) identified a crack in dual fuel filter support on SSF

'B' diesel on June 17, 2020

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Keowee hydro Unit 1 generator breaker ACB-1 maintenance per IP/0/A/4980/094C, ABB Type MG-6 Relay Replacement and Testing on June 24, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) Risk assessment for April 14, 2020 during the drain down of Unit 3 RCS to 80 inches which caused the risk to go yellow due to decay heat removal

(2) Risk assessment for April 15, 2020 with Unit 3 in lowered inventory, yellow high risk plant operating state (HRPOS)

(3) Risk assessment for April 27, 2020 during Unit 3 elevated risk due to drain down of Unit 3 RCS to 80 inches

(4) Risk assessment for April 27 and May 1, 2020 during Unit 2 elevated risk due to turbine building heavy lifts over main feeder busses

(5) Risk assessment for June 16, 2020 during Units 1, 2, and 3 elevated risk due to SSF outage

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Immediate determination of operability (IDO) for NCR 2323774, Unit 2 engineered safeguards voter subsystem trouble alarms

(2) IDO for NCR 2323458, 2B high pressure injection pump vibrations above inservice test alert range during surveillance test

(3) Engineering evaluation for NCR 2325512 regarding acceptability of localized wall thinning in 3B condenser cooling water inlet pipe

(4) Engineering evaluation for NCR 2325972 regarding functionality of 3HP-140 with closing torque exceeding maximum allowed

(5) IDO for NCR 02323274, OSC-2042 TACs do not address all high pressure injection (HPI) pump operational requirements

(6) Engineering evaluation for NCR 2329396, 3CCW-PG-0434 reading high

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) Design changes 90423, 77067, 77069 for replacement emergency safety features actuation system and creation of Selected Licensee Commitment 16.7.15

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) IP/0/A/3001/001 L, As-left diagnostic testing after lowering torque switch setting and slight overthrust of 3HP-24, Work Order (WO) 20334466-06

(2) Torque testing of 3CF-5 following change in valve packing design and torque switch setting, WO 20357500-01

(3) PT/1/A/0202/011, High Pressure Injection Pump Test, following routine maintenance on the 1A HPI pump on May 26, 2020

(4) PT/0/A/0400/004, Diesel Service Water Pump Test, following installation of a new flow orifice in accordance with EC 413000 on June 17, 2020

(5) OP/0/A/1600/010, Operation of the SSF Diesel-Generator, testing following replacement of the 'A' and 'B' SSF diesel governors and relays on June 19, 2020

(6) ACB-1 testing per IP/0/A/4980/094C after relay replacements on June 24, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) The inspectors evaluated refueling outage U3R30 activities from April 11, 2020 to May 9, 2020. The inspectors completed inspection procedure Sections 03.01.a through 03.01.d.1 and 03.01.e.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) PT/2/A/0152/009, Feedwater System Valve Stroke Test, on 2FDW-315 via WO

===20375447 on April 6, 2020 / April 23, 2020

(2) PT/3/A/0152/012, 3LP-22 stroke test, via WO 20260620 on April 23, 2020

(3) PT/3/A/0601/0100 J, Emergency Power Switching Logic Functional Test on April 30, 2020

(4) PT/1/A/0230/015, High Pressure Injection Motor Cooler Performance Test, via WO 20388258 on May 26, 2020 Inservice Testing (IP Section 03.01) ===

(1) NCR 2323458 - PT/2/A/0202/011 - 2B HPI Test - Vibrations in ALERT on April 1, 2020

(2) PT/3/A/0261/010, 3C ESV Pump Test (WO# 20383388) on April 6, 2020

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) PT/3/A/0151/019, Penetration 19 Leak Rate Test on May 2, 2020

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the emergency planning drill which included a leak from the gaseous waste decay tanks and dropped rods on May 27, 2020

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) The inspectors evaluated the emergency planning drill which included a 1T transformer lockout causing a reactor trip and a subsequent loss of coolant accident (LOCA) on June 23,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1 (July 1, 2019 - March 31, 2020)

(2) Unit 2 (July 1, 2019 - March 31, 2020)

(3) Unit 3 (July 1, 2019 - March 31, 2020)

MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)

(1) Unit 1 (July 1, 2019 - March 31, 2020)

(2) Unit 2 (July 1, 2019 - March 31, 2020)

(3) Unit 3 (July 1, 2019 - March 31, 2020)

MS10: Cooling Water Support Systems (IP Section 02.09) (3 Samples)

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

(3) Unit 3 (April 1, 2019 - March 31, 2020)

BI02: RCS Leak Rate Sample (IP Section 02.11) (3 Samples)

(1) Unit 1 (April 1, 2019 - March 31, 2020)

(2) Unit 2 (April 1, 2019 - March 31, 2020)

(3) Unit 3 (April 1, 2019 - March 31, 2020)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the area of equipment reliability that might be indicative of a more significant safety issue.

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) NCRs 2323774,1905415, 1816606, 1806678, 1257514 regarding resolution of emergency safeguards protective system voter trouble alarm design issues

(2) NCRs 1849742, 1851133, 1833499, 2321306 regarding resolution of OTS1-0 breaker cubicle door interference and actuation of sensitive tripping relay

71153 - Followup of Events and Notices of Enforcement Discretion Reporting (IP Section 03.05)

(1) The inspectors reviewed the circumstances of NCR 2325879 surrounding a potential report issue involving a lowering Unit 2 borated water storage tank level due to leakage in excess of selected licensee commitment 16.6.4 limits past a low pressure injection cooler vent valve.

INSPECTION RESULTS

Inadequate Alarm Response Guide for ES Voter Trouble Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.18 Systems NCV 05000269,05000270,05000287/20200 02-01 Open/Closed A NRC identified Green Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified when the licensee failed to maintain alarm response guides OP/1/A/6101/007, OP/2/A/6102/007, and OP/3/A/6103/007 appropriate to the circumstances.

Description:

At 2310 hours0.0267 days <br />0.642 hours <br />0.00382 weeks <br />8.78955e-4 months <br /> on April 3, 2020, the Unit 2 control room received a statalarm ES Odd Voter Trouble and two other alarms on the operator aid computer (OAC): ES Odd Voter 1 Hardware Fail and ES Odd Voter 1 Trouble. At 0005 on April 4, based on the instructions in alarm response guide (ARG) OP/2/A/6102/007, Alarm Response Guide 2SA-07, operators bypassed the ES voter 1 subsystem (comprised of the ES odd voter 1 and even voter 1) since all OAC alarms indicated the problem was with the voter 1 subsystem. Later, instrumentation and electrical technicians began troubleshooting odd voter 1 per IP/2/A/0315/005H, TXS Plant Protective System Cabinets ON2PPSCA0012, ON2PPSCA0013, And ON2PPSCA0017 Troubleshooting, Analysis, And Maintenance, and found that odd voter 1 appeared to be operating normally, but status lights on the odd voter 2 subrack were indicating a 15V power supply failure. Since indications existed that odd voter 2 was inoperable, which was contrary to the OAC alarms and would require actions contrary to the ARG, engineering was requested to validate the conditions against design drawings. Once odd voter 2 was confirmed to be failed, technical specification limiting condition for operation (LCO) 3.3.7, condition A was entered for four emergency safeguards protective system (ESPS) automatic actuation output logic channels being inoperable. This LCO, which has a required action completion time of one hour, was required because with odd voter 1 bypassed, and odd voter 2 in a failed state, there were no ES voters capable of automatically actuating ES equipment associated with ES channels 1, 3, 5, or 7. At 0209 hours0.00242 days <br />0.0581 hours <br />3.455688e-4 weeks <br />7.95245e-5 months <br /> operations returned ES voter subsystem 1 to service and bypassed subsystem 2 to permit exiting the LCO and to make repairs. During the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> period of time that no odd voters were operable, even voter 2 was operable and could have actuated the minimum set of ES equipment associated with ES channels 2, 4, 6, and 8 in the event of an accident.

Inspectors reviewed the engineering changes (EC) that replaced the engineered safety features actuation system (ESFAS) to understand why the ARG contained the non-conservative actions that caused the above event. Ultimately, ARG writers failed to consider that certain hardware failures (e.g. a voter power supply failure) would not activate the OAC alarms associated with the failed voter and instead that only the redundant voters OAC alarm would show as activated. This failure mode was reasonably within the licensees ability to foresee and the event should have been prevented based on information in the systems failure modes and effects analysis (FMEA) and corrective action program.

In the FMEA, OM 201.N-0028.004, Oconee Nuclear Station RPS/ESFAS Controls Upgrade Failure Modes and Effects

Analysis.

Attachment 4, Section 1.11.3 described that the voter trouble statalarm would activate in the event of loss of voter subrack power and the OAC alarms were not listed as a method of failure detection. Additionally, section 1.0.17 described that the OAC would fail to alarm as a result of a power supply failure.

Additionally, between January and June of 2011, the licensee discovered and attempted to resolve several different design issues associated with the voter trouble statalarm during EC implementation on Unit 1. NCRs 1816606 and 1806678 identified that there was no easy means to determine which voter subsystem was causing a trouble statalarm because the system was designed such that the redundant voters (e.g. odd 1 and odd 2) shared a single statalarm. In response, the ARG was drafted to monitor OAC alarms to determine which voter subsystem was failed since the OAC alarms were setup to monitor all four voters individually. Engineers documented that this would be inadequate in some circumstances because hardware failure signals originating from one voter would result in activation of a hardware failure signal in the redundant voter and still hamper diagnosis. The NCR concluded regarding the draft ARG: not ALL scenarios are covered by it and that additional evaluation of this problem was necessary. This additional evaluation was closed to a vendor design change that enabled each voters manual bypass switch to disable its input to the statalarm so the alarm could be cleared and remain available to monitor the remaining voter.

This design change did not address the original problem statement of how to diagnose the alarm in the event of a hardware failure signal. Instead, it only provided a means to clear the alarm after a diagnosis and decision of which voter to bypass had been made. A proper diagnosis required examination of the equipment cabinets for indications of failure; however, the ARG was approved and maintained with instructions for operators to take initial action based strictly on OAC alarms. The ARG did include steps for instrumentation and electrical troubleshooting procedures to aid in alarm diagnosis, but these steps would only be performed if the previous steps (such as OAC alarm reviews) yielded inconclusive results. This alarm response methodology was incorrect for hardware failure events such as the April 3, 2020 voter power supply failure since the OAC would yield false conclusive indications. The inspectors added value by discovering the past NCR corrective action gaps discussed above and therefore this violation is characterized as NRC identified.

Corrective Actions: The licensee revised the ARGs to require more intrusive troubleshooting before taking actions to bypass an ES voter.

Corrective Action References: NCR 2323774

Performance Assessment:

Performance Deficiency: The failure to assure the accuracy and correctness of information in ARGs OP/1/A/6101/007, OP/2/A/6102/007, and OP/3/A/6103/007 per NSD 110, Technical Review and Control, Revision 11, was a performance deficiency. Specifically, for certain equipment failures that would activate the ES even or odd voter trouble alarm, the procedures directed operators to take non-conservative actions due to incorrect instructions.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, following the ARG caused the inoperability of both Unit 2 odd ES voters which prevented the capability to automatically actuate odd channel ES components.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. A detailed risk evaluation was required because the degraded condition represented a loss of the PRA function of four of eight channels of ESPS automatic actuation output logic for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, which was greater than the technical specification required action completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. A regional Senior Reactor Analyst (SRA) conducted a detailed risk assessment in accordance with the guidance of NRC Inspection Manual Chapter 0609 Appendix A, The Significance Determination Process for Reactors at Power. The SRA used Oconee Unit 1, 2, and 3 SPAR model version 8.60 date 5/13/19 and SAPHIRE 8 version 8.2.1. The analyst assumed that equipment on channels 1, 3, 5, and 7 of ESFAS would not receive an automatic start signal on a valid request due to the performance deficiency. Affected equipment includes high pressure injection pumps A and B, low pressure injection pumps A and B, low pressure service water pumps A and C, and the Unit 1 Keowee hydro unit. Channels 2, 4, 6, and 8 are unaffected and the performance deficiency does not impact the operators ability to manually start affected equipment as directed by procedure thus credit for recovery is applied. Exposure time was two hours. The dominate accident sequence was a stuck open primary relief valve with failure of decay heat removal and high pressure recirculation functions. Applying credit for recovery, plant risk was less than 1 E-8 which corresponds to a finding of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Additionally, site procedure NSD 110 required personnel to assure the accuracy and correctness of information when preparing or revising procedures. Contrary to above, beginning in 2011, ARGs OP/1/A/6101/007, OP/2/A/6102/007, and OP/3/A/6103/007 were not maintained appropriate to the circumstances because they were prepared and revised with incorrect information. Specifically, for certain equipment failures that would activate the ES even or odd voter trouble alarm, the procedures directed operators to take non-conservative actions due to incorrect instructions.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Correct Cubicle Door Interference Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000269,05000270,05000287/20200 02-02 Open/Closed A self-revealed Green Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to correct a condition adverse to quality associated with a standby shutdown facility breaker cubicle door interference that impaired accessibility for in-service inspection, maintenance, and repair.

Description:

Between December 2012 and May 2013, multiple problems were discovered and addressed during the installation of a new breaker in the standby shutdown facility for the protected service water system modification. Maintenance personnel initially identified interference between the newly installed OTS1-0 breakers cubicle door, the adjacent breakers door hinges and with newly fabricated metal deck flooring. WO 2049924-39 adjusted the door to clear the interference with the adjacent breakers door hinges, but the door still dragged against the decking. Later in December, NCR 1837741 documented that a broken plug weld was found on a vertical angle bar structural support on the inside of the cubicle door. In March 2013, NCR 1849742 identified problems with the metal decking being distorted and creating a trip hazard. WO 2049924-76 executed repairs to broken welds that were found on the upper hinge and vertical angle bar support by installing bolts through the door at both repair locations. Subsequently, NCR 1851133 identified that the door was still being obstructed by the decking and prevented the ability to open the cubicle door far enough to remove the breaker.

In April 2013 maintenance attempted to remove the breaker, but the interference caused an electrical bus lockout when a sensitive door-mounted 94AR tripping relay was actuated due to jarring of the door against the decking. NCR 1833499 described the effort to overcome the interference as requiring two people: one pushing and one pulling in order to get the door to the necessary fully open position. As a corrective action, the metal decking was flattened, leveled, plumbed, and accepted by maintenance and engineering in May 2013. The repair flattened the decking by bolting a large piece of aluminum bar stock under one end of the decking. This repair addressed the trip hazard, but it failed to resolve the other identified problem of not being able to fully open the cubicles door over other portions of the decking.

Since May 2013, all routine maintenance work was able to be completed with the flattened decking because the work did not require opening the door beyond the point of interference (around 90 degrees open). On March 18, 2020, a first-time preventive maintenance task was scheduled that required the breaker to be removed from the cubicle to allow the breaker to be inspected. The work crew anticipated the potential for interference with the decking based on past experience with this door and other similar plant breakers. During the pre-job brief the crew planned to mitigate the risk of actuating the 94AR relay by making use of clearance in the door hinges by carefully lifting the door over the area of interference. When the work was executed, interference with the decking was encountered and the crew applied slight upward pressure on the door. This action caused the door to spring free, the relay to actuate and an electrical lockout of the OTS1 switchgear. The lockout caused the SSF to become inoperable until the lockout was reset later that day. The licensees investigation of the issue concluded that there was no human performance issue by the work crew and that the cause was ineffective corrective action of the original problem from 2013. The corrective action assigned was to modify or replace the decking.

Corrective Actions: The licensee developed plans to eliminate the interference with the metal decking and to update maintenance instructions to require blocking the 94AR relays for OTS1-0 and B7T-01 prior to manipulating the cubicle door.

Corrective Action References: NCR 2321306

Performance Assessment:

Performance Deficiency: The failure to correct a condition adverse to quality associated with a standby shutdown facility breaker cubicle door interference that impaired accessibility for in-service inspection, maintenance, and repair was a performance deficiency. Specifically, past attempts to correct the condition failed to eliminate the interference.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correct the condition adverse to quality resulted in a lockout of the OTS1 switchgear and caused the standby shutdown facility to be inoperable.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using exhibit 2, Mitigating Systems Screening Questions, inspectors determined the finding was of very low safety significance (Green) because the 11.7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> duration that the SSF was inoperable did not represent a loss of a probabilistic risk assessment function a single train system for greater than its technical specification allowed outage time.

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that conditions adverse to quality be promptly identified and corrected. Contrary to the above, since May 2013, an identified deficient condition associated with the OTS1-0 cubicle door interfering with metal decking and impairing accessibility for in-service inspection, maintenance, and repair was not corrected. Specifically, past attempts to correct the condition failed to eliminate the interference until it resulted in an equipment failure.

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 July 27, 2020, the inspectors presented the integrated inspection results to J. Ed Burchfield and other members of the licensee staff.

• On April 16, 2020, the inspectors presented the Oconee U3 ISI Inspection Exit Meeting inspection results to Mr. Ed Burchfield, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Calculations OSC-2240 Verification of SSF Sump System Parameters 5

Corrective Action 1753624, 1747483, 2272266, 2329909

Documents

Drawings O-447A Piping Layout SSF Plans Sections & Details at El. 754-0 23

O-447C Piping Layout SSF Auxiliary Service Water Piping Plan, 11

Sections & Details

OM 111-0220.001 PLFBCGH Hinged Flood Barrier D0D

OM 111-0266.001 CG11HA D0G

Procedures AP/0/A/1700/047 External Flood Mitigation 26

FG/0/A/1900/005 Initial Assessment and FLEX Equipment Staging 5

MP/0/A/1400/033 Flood Door - SSF Building - Presray - Semi-Annual and 5 14

Year - Preventive Maintenance and Repair

PT//0/A/0400/019 SSF Sump Pump Discharge Check Valve Test 6

71111.04 Corrective Action 2169391

Documents

Drawings OFD-100A-3.1 Flow Diagram of Reactor Coolant System 41

OFD-102A-3.1 Flow Diagram of Low Pressure Injection System (Borated 63

Water Supply and LPI Pump Suction)

OFD-102A-3.2 Flow Diagram of Low Pressure Injection System (LPI Pump 47

Discharge)

OFD-102A-3.3 Flow Diagram of Low Pressure Injection System (Core 24

Flood)

OFD-124B-3.1 Flow Diagram of Low Pressure Service Water System 61

(Auxiliary Building Services)

OFD-125A-3.1 Flow Diagram of Recirculated Cooling Water System (Pump 7

and Heat Exchangers)

OFD-125A-3.2 Flow Diagram of Recirculated Cooling Water System 21

(Turbine Building Loads)

OFD-125A-3.3 Flow Diagram of Recirculated Cooling Water System 6

(Turbine Building Loads)

Inspection Type Designation Description or Title Revision or

Procedure Date

OFD-125A-3.4 Flow Diagram of Recirculated Cooling Water System 17

(Auxiliary Building Loads)

OFD-125A-3.5 Flow Diagram of Recirculated Cooling Water System (Misc. 10

Loads)

OFD-125A-3.6 Flow Diagram of Recirculated Cooling Water System 1

(Turbine Building Loads)

Procedures OP/3/A/1103/011 Draining and Nitrogen Purging RCS 097

OP/3/A/1104/006 SF Cooling System 099

OP/3/A/1104/009 RCW System 035

Work Orders 20334172

71111.05 Calculations OSC-9659 Oconee Nuclear Safety Capability Assessment for Units 1, 2 11

and 3

Fire Plans CSD-ONS-PFP- Pre-Fire Plan for U1 Auxiliary Building Elevation 783 0

1AB-0783

CSD-ONS-PFP- Pre-Fire Plan for U2 Auxiliary Building Elevation 809 0

2AB-0809

Procedures AP/0/A/1700/043 Fire Brigade Response Procedure 10

AP/1/A/1700/050 Challenging Plant Fire 5

AP/2/A/1700/050 Challenging Plant Fire 5

71111.08P Calibration 689151 Standards Laboratory Instrument Certification: IR 7/1/19

Records Thermometer (G503097)

Corrective Action CR02280288 Active Boron Leak on 3SF-19 07/03/2019

Documents CR02301162 Boron Leak Identified on 3B LPI Pump Casing and Bolting 11/06/2019

Miscellaneous Duke Energy Certificate of Method Qualification: UT II-N 1/28/20

(May)

Record of Welder Performance Qualification Test (Murison) 09/26/2008

Sonic Systems International, Inc. Certificate of Qualification: 2020.01.14

UT II-PDI (Harmon)

Sonic Systems International, Inc. Vision Acuity Record 09/06/2019

(Harmon)

Duke Energy Certificate of Method Qualification: UT II-N 2/20/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

(Jensen)

Visual Acuity Record (Jensen) 6/12/20

Visual Acuity Record (May) 01/28/2020

Visual Acuity Record (Ransom) 8/29/19

Duke Energy Certificate of Method Qualification: UT II-N 9/12/2017

(May)

Duke Energy Certificate of Method Qualification: PT II-N 9/6/2017

(May)

171796 Duke Energy Corporation Weld Record (3-HP-0351-60) 10/29/19

19D05K Magnaflux Spotcheck Penetrant SKL-SP2 04/12/2019

19K12K Magnaflux Spotcheck Developer SKD-S2 10/18/2019

GT000808-04 Welding Procedure Specification 0

L-110D Procedure Qualification Record January 3,

1991

L-138 Procedure Qualification Record 9/12/74

L-148C Procedure Qualification Record 4/13/88

NDE Reports 6080 Metallurgy File: ONS O3R30 Reactor Vessel Head Deposit April 20,

Samples 2020

PT-20-008 Liquid Penetrant Examination Record (3-01A-0-2401B-H18) 4/16/2020

UT-20-075 UT Calibration/Examination Record (3-PDB2-47) 4/15/2020

UT-20-106 UT Calibration/Examination Record (3RC-211-73) 4/13/2020

VE-20-012 Ultrasonic Examination Record (3RC-211-70) 4/14/20

Procedures AD-EG-PWR- Boric Acid Corrosion Control Program - Implementation 2

1611

MP/0/A/1800/132 Inspection, Assessment, and Cleanup of Boric Acid on Plant 010

Materials

MP/0/A08140/001 QA and Non-QA Welding 010

NDE-NE-ALL- Utilization of EPRI-DMW-PA-1 Procedure for Manual 000

6304 Phased Array Ultrasonic Examination of Dissimilar Metal

Welds

PD-EG-PWR- Boric Acid Corrosion Control Program 1

1611

71111.11Q Procedures OP/0/A/1102/026 Operations IPTE Pre-Job Briefings 031

Inspection Type Designation Description or Title Revision or

Procedure Date

OP/3/A/1102/001 Controlling Procedure for Unit Startup 279

OP/3/A/1103/011 Draining and Nitrogen Purging RCS 097

OP/3/A/1105/019 Control Rod Drive System 032

PT/0/A/0711/001 Zero Power Physics Test 074

PT/0/A/1103/020 Power Maneuvering Predictions 026

PT/3/A/0600/001 Instrument Surveillance Prior to Mode Change 042

B

PT/3/A/0600/030 NI Overlap 001

71111.12 Calculations OSC-5085 Seismic Analysis of New Floor Mounted Enclosures and 21

Modifications to Existing Floor Mounted Enclosures

OSC-5085-ICC- Door hinge modification on OTS1 Switchgear enclosure March 6,

28 2013

Corrective Action 2323330, 2204828, 2326415, 2321306, 2335524

Documents

Drawings OEE-616-02 Elementary Diagram SSF 4160V Switchgear OTS1 Unit 0 0

Feeder Breaker

OFD-133A-2.5 Flow Diagram of Condenser Circulation Water System (SSF 61

Aux. Service)

Engineering 91876 SSF 4.16kV Alternate Power Feed from PSW 39

Changes

Miscellaneous MRule Manager software

SystemIQ software

Material Issue Ticket 41168800

AD-EG-ALL-1210 Maintenance Rule Program 2

OM 302.A- Qualification Report for Duke Oconee Medium Voltage D08

0097.002 Substation

Procedures IP/0/A/4980/094C ABB Type MG-6 Relay Replacement and Testing 2

Work Orders 20389606

71111.13 Calculations OSC-11805 Generic Load Drop Analysis for Turbine Building Operating 1

Floor Lifts

OSC-11847 Oconee Low Pressure Turbine Replacement Heavy Lift Risk 4

Evaluation

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action 2327188

Documents

Miscellaneous Outage Control Center Outage Status nightshift package

dated April 27, 2020

Standing Instruction 20-04, Rev. 3 - Low Pressure Turbine

Replacement Heavy Lift Mitigation Requirements

Elevated Risk Activity Plan for SSF Annual Outage 2020 May 20,

20

Outage Control Center Outage Status dayshift package April 14,

20

Procedures EP/1/A/1800/001 Unit 1 EOP Enclosures 5.41-5.46 6

0Q

OP/3/A/1103/011 Draining and Nitrogen Purging RCS 097

71111.15 Calculations OSC-0632 Reanalysis of the Condenser Cooling Water Pipe for 8

Seismic Conditions

OSC-0681 Condenser Cooling Water Pipe Design 33

OSC-10403 License Renewal Calculation - CCW System Internal 1

Coating Inspections Program

OSC-10411 License Renewal Calculation - Service Water Piping 1

Corrosion Program

OSC-11241 Low Frequency Electromagnetic Technique Inspection 0

Report

OSC-5599 Generic Letter 89-10 Calculation for Unit 3 Gate and Globe 34

Valves

OSC-7184 Generic Letter 89-10 Calculation for Units 1, 2, 3 Gate and 5

Globe Valves at Oconee

OSC-7380 CCW Intake and Discharge Piping Units 1, 2 and 3; 5 Year 16

Civil/Coating Inspection Report

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action 1784715, 2202906, 2323274, 2323642, 2328102, 2328141,

Documents 2329396, 1928935, 2152176

Drawings ONTC-3-HP-140 Generic Letter 89-10 Test Acceptance Criteria 1

OSC-2042 HPI Pump Motor Upper Bearing Cooling Report 010

OSC-4171 SSF ASW Design Inputs Calculation 038

OSC-7561 Differential Pressure Calculations for Valves FDW-0315 and 000

FDW-0316

OSC-8176 GL 89-10 Review for Valves CCW-268 and CCW-287 0

Miscellaneous OM 253. I/B - PSW DMV 1463 - Technical Manual for 6 Inch 000

0117.001 Modulating Bolted Bonnet Solenoid Operated Valve Model

09L-001

OSS-0254.00-00- Engineered Safety Features Actuation Systems Design 20

2003 Basis Specification

Procedures OP/2/A/6102/007 Alarm Response Guide 2SA-07 10

PT/2/A/0230/015 High Pressure Injection Motor Cooler Performance Test 047

Work Orders 20333945, 1876646

71111.18 Calculations OSC-3348 RPS/ES Failure Modes and Effects Analysis Summary 7

Calculation

Corrective Action 1257514

Documents

Engineering AREVA ECP 131-9159730-000 0

Changes

107004 Unit 1 RPS/ES Hardware Enhancement 3

77067 Unit 2 ESFAS Replacement Modification 15

77069 Unit 3 ESFAS Replacement Modification 26

90423 Unit 1 ESFAS Replacement Modification 39

Miscellaneous OM 201.N-0020- ONS Units 1, 2 and 3 RPS/ESFAS Controls Upgrade 12

001 Maintenance and User Manual Volume 1

OM 201.N- ONS Units 1, 2 and 3 RPS/ES Control Upgrade and User D09

20.008 Manual Volume 4, Hardware Book 1 of 3

OM 201.N- Oconee Nuclear Station Unit 1 RPS/ESFAS Controls D17

24.005 Upgrade Software Design Description

OSS-0254.00-00- Engineered Safety Features Actuation Systems Design 20

2003 Basis Specification

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.19 Calculations OSC-5599 Generic Letter 89-10 Calculation for Unit 3 Gate and Globe 34

Valves

Corrective Action 2325810, 2325897

Documents

Drawings Valve Packing Datasheet: 3-CF-0005 1

KEE-114 Elementary Diagram Generator Control ACB-1 Control

Circuit

OM 245-2387.001 Seismic / Weak Link Report for 1,2,3HP-24 & 25, 6 Powell 1

Model 3023 300 Gate Valve with Motor Operator

ONTC-3-HP-024 Generic Letter 89-10 Test Acceptance Criteria 12

Engineering 409984 Replace 3CF-5 and 3CF-6 2

Changes 411450 3GWD-12 EV, 1/3CF-5,6 EV: Spring Pack Change 0

Miscellaneous OSS-0254.00-00- Design Basis Spec for the Low Pressure Injection and Core 59

28 Flood System (LPI)

Procedures OP/0/A/1600/010 Operation of the SSF Diesel-Generator 096

PT/0/A/0400/011 SSF Diesel Generator Test 015

PT/0/A/0600/021 Standby Shutdown Facility Diesel-Generator Operation 016

PT/1/A/0202/011 High Pressure Injection Pump Test 104

Work Orders 20295946, 20295955, 20295956, 20327685, 20299762,

299763, 20386069

71111.20 Corrective Action 2326176, 2326415, 2328602, 2326987, 2329314, 2326415,

Documents 2326655, 2327878, 2327111, 2327349, 2327952

Drawings OFD-100A-3.1 Flow Diagram of Reactor Coolant System 41

OFD-101A-3.1 Flow Diagram of High Pressure Injection System (Letdown 41

Section)

OFD-106A-3.1 Flow Diagram of Coolant Treatment System (RC Bleed 16

Holdup Tanks)

OFD-109A-3.1 Flow Diagram of Purification Demineralizers 15

OFD-109A-3.2 Flow Diagram of Deborating Demineralizers 5

Miscellaneous AD-MN-ALL-0002 Foreign Material Exclusion 10

Inspection Type Designation Description or Title Revision or

Procedure Date

AD-OP-ALL-0106 Conduct of Infrequently Performed Tests or Evolutions 4

AD-OP-ALL-0203 Reactivity Management 11

OPS-3-20-LP- 5/4/20

3LP-8 PAK LK-

1042

Procedures AP/3/A/1700/035 Loss of SFP Cooling and/or Level 23

OP/0/A/1102/026 Operations IPTE Pre-Job Briefings 031

OP/0/A/1108/001 Curves and General Information 115

OP/0/A/1108/001 Reactor Core and SFP Loss of Cooling Heatup Tables 007

A

OP/3/A/1102/001 Controlling Procedure for Unit Startup 279

OP/3/A/1102/010 Controlling Procedure for Unit Shutdown 250

OP/3/A/1103/004 RCS Boration 025

A

OP/3/A/1103/011 Draining and Nitrogen Purging RCS 097

OP/3/A/1104/006 SF Cooling System 099

OP/3/A/1104/009 RCW System 035

OP/3/A/1105/019 Control Rod Drive System 032

OP/3/A/1107/018 Removal and Restoration of Motor Control Centers 23

PT/0/A/0711/001 Zero Power Physics Test 074

PT/0/A/1103/020 Power Maneuvering Predictions 026

PT/3/A/0115/012 Unborated Water Source Isolation Verification 005

PT/3/A/0600/001 Instrument Surveillance Prior to Mode Change 042

B

PT/3/A/0600/030 NI Overlap 001

TE-MN-ALL-0002 Foreign Material Exclusion Level and Controls Screening 2

Work Orders 20171869

71111.22 Corrective Action 2324709

Documents

Drawings OFD-116A-3.1 Flow Diagram of Reactor Building Purge System 13

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous PT/3/A/0150/034 Leak Rate History Record and Reactor Building Leak Rate May 6, 2020

Verification

PT/3/A/0151/019 Penetration 19 Leak Rate Test May 3, 2020

PT/3/A/0151/019 Penetration 19 Leak Rate Test April 10,

20

Procedures PT/1/A/0230/015 High Pressure Injection Motor Cooler Performance Test 051

PT/2/A/0152/009 Feedwater System Valve Stroke Test 019

PT/3/A/0152/012 Low Pressure Injection System Valve Stroke Test 043

Work Orders 20334840, 20260620, 20375447, 20388258

71114.06 Miscellaneous AD-EP-ALL-0106 Activation and Operation of the Operations Support Center 1

AD-EP-ONS-0106 ONS Site Specific OSC Support 000

AD-OP-ALL-1000 Conduct of Operations 17

EP/1/A/1800/001 Immediate Manual Actions and Subsequent Actions 003

FAD-ON-EP-EAL- Oconee Nuclear Station Classification of Emergency 001

EALMATRIX

ONS 20-02 EMPE Oconee Practice Drill June 23,

20

RP/0/A/1000/001 Emergency Classification 006

71151 Miscellaneous Oconee Unit 1, 2, 3, cooling water support systems

Unavailability data from April 1, 2019 to March 31, 2020

Review of cooling water support systems log entries in

eSOMS from April 1, 2019 - March 31, 2020

AD-PI-ALL-0700 Performance Indicators 4

NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

71152 Corrective Action 2321306, 1833299

Documents

Drawings O-0320-Z-007-A SSF Electrical Equipment Seismic Mounting Plans, Section 0

& Details

OM 302.A- SSF 4.16kV Switchgear OTS1 Unit 0 Layout Drawing D6

25.002

Miscellaneous OM 1201.N- Oconee Nuclear Station Unit 2 RPS/ESFAS Controls 5

24.005 Upgrade Software Design Description

Inspection Type Designation Description or Title Revision or

Procedure Date

OM 1201.N- Oconee Nuclear Station Unit 2 RPS/ESFAS Controls 0

25.011 Upgrade Test Phase V&V Activity Summary Report

OM 1201.N- Oconee Nuclear Station Unit 2 RPS/ESFAS Controls 2

28.004 Upgrade Failure Modes and Effects Analysis

OM 201.N- Oconee Nuclear Station, Units 1, 2 and 3 RPS/ESFAS D26

22.002 Controls Upgrade Hardware Design Solutions

OM 201.N- Oconee Nuclear Station RPS/ESFAS Controls Upgrade 13

28.004 Failure Modes and Effects Analysis

Procedures NSD-703 Administrative Instructions for Technical Procedures 30

OP/1/A/6102/007 Alarm Response Guide 1SA-07 9

OP/2/A/1105/014 Control Room Instrumentation Operation and Information 49

OP/2/A/6102/007 Alarm Response Guide 2SA-07 10

PT/1/A/0600/001 Periodic Instrument Surveillance 342

Work Orders 2049924, 20384707

71153 Drawings OFD-102A-2.2 Flow Diagram Low Pressure Injection System 52

Miscellaneous Reportability Evaluation Worksheet for NCR 2325879

PT-2-A-0203-004 Low Pressure Injection System Leakage 32

24