IR 05000269/2020003
| ML20309A672 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/04/2020 |
| From: | Jared Nadel NRC/RGN-II/DRP/RPB1 |
| To: | Burchfield J Duke Energy Carolinas |
| References | |
| IR 2020002, IR 2020003 | |
| Download: ML20309A672 (25) | |
Text
November 4, 2020
SUBJECT:
OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2020003, 05000270/2020003, 05000287/2020003, AND 07200004/2020002
Dear Mr. Burchfield:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On October 20, 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.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation 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/
Jared H. Nadel, (Acting) Chief Reactor Projects Branch #1 Division of Reactor Projects
Docket Nos. 05000269, 05000270, 05000287, and 07200004 License Nos. DPR-38, DPR-47, DPR-55, and SNM-2503
Enclosure:
As stated,
Inspection Report
Docket Numbers:
05000269, 05000270, 05000287, and 07200004
License Numbers:
DPR-38, DPR-47, DPR-55, and SNM-2503
Report Numbers:
05000269/2020003, 05000270/2020003, 05000287/2020003, and
07200004/2020002
Enterprise Identifier: I-2020-003-0056, I-2020-002-0078
Licensee:
Duke Energy Carolinas, LLC
Facility:
Oconee Nuclear Station
Location:
Seneca, South Carolina
Inspection Dates:
July 01, 2020 to September 30, 2020
Inspectors:
J. Nadel, (Acting) Branch Chief
J. Parent, Resident Inspector
A. Ruh, (Acting) Senior Resident Inspector
D. Bacon, Senior Operations Engineer
C. Fontana, Emergency Preparedness Inspector
B. Kellner, Senior Health Physicist
S. Mendez-Gonzalez, Reactor Inspector
W. Pursley, Health Physicist
S. Sanchez, Senior Emergency Preparedness Insp
M. Toth, Project Engineer
J. Vazquez, Reactor Ops Engineer
J. Walker, Emergency Response Inspector
J. Worosilo, Senior Project Engineer
Approved By:
Jared H. Nadel, (Acting) 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 (ROP). 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
Failure to Provide Unfettered Access to an NRC Resident Inspector Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000269,05000270,05000287/202000 3-01 Open/Closed Not Applicable 71111.04 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.70(b)(3), associated with the licensees failure to provide unfettered access to an NRC resident inspector. Specifically, while the NRC resident inspector was attempting to perform deep backshift observations and inspections, the resident inspector was denied access to the radiologically controlled area (RCA), even though the resident inspector complied with applicable access control measures. As a result, the NRCs ability to regulate was adversely impacted.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000269,05000270,05 000287/2020003-02 Operation of Normally Closed Seismic Boundary Valves 71111.18 Open LER 05000287/2020-001-00 LER 2020-001-00 for Oconee Nuclear Station,
Unit 3, Manual Reactor Trip Due to Reaching Feedwater Heater Level Limit in Operating Procedure 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 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 and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Oconee emergency AC power line-up while in yellow grid condition on July 16, 2020 (2)1A LPI train during 1B LPI train maintenance on August 5, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) Fire Zone 15: Unit 2 main feedpump area on July 10, 2020
- (2) Fire Zone 108: Unit 1 east penetration room on August 13, 2020
- (3) Fire Zone 106: Unit 1 cable room on August 25, 2020
- (5) Fire Zone 81: Unit 2 auxiliary building second floor hallway on August 27, 2020
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Reverse osmosis system
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 replacement and calibration of Unit 1 wide range reactor coolant system (RCS) hot leg temperature instrument on July 12, 2020 and during 1A LPI pump testing on July 29, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated Annual Simulator Exam (ASE-16) on September 8, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2 LPI system and out of tolerance condition for system measuring and test equipment on July 30, 2020
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
- (1) Nuclear Condition Report (NCR) 2321780, resolution of apparent discrepancies with standby shutdown facility (SSF) heating ventilation and air conditioning condenser preventive maintenance and testing for aging management
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Green risk during planned plant service water outage with the standby shutdown facility protected on July 7, 2020
- (2) Green risk during planned CT-4 maintenance on August 4, 2020
- (3) Unit 1 elevated risk due to 1C low pressure injection pump maintenance outage on August 13, 2020
- (4) Green risk during a planned safe shutdown facility outage on August 19, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2334464 regarding errors with assumed actuator loading in seismic qualification of Unit 1 and 3 core flood tank vent valves
- (2) NCRs 2335074 and 1848621 regarding ineffective bypass of SSF OTS1-1 breaker protective relaying during emergency starting of the SSF diesel generator
- (3) NCR 2343788 regarding potentially inadequate guidance in Operability Reference Guide Section 16
- (4) NCR 2341037 regarding a pinhole leak on the 'B' low pressure service water pump packing seal water filter housing
- (5) NCR 02347996 regarding missed surveillance on Keowee out of tolerance relay preventive maintenance
- (6) NCR 02338927 regarding operability of U3 containment in respect to U3 personnel hatch doors testing
- (7) NCR 2338818 regarding excessive airflow from 3A control room outside air booster fan
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) Change package 99-219 for UFSAR Section 3.7.3.9, regarding operation of normally closed seismic boundary valves
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) IP/1/A/0315/070/A, A Channel WR Pressure, following replacement of the instrument on July 12, 2020
- (2) Functional test of B6T-06 protected service water (PSW) primary pump breaker following replacement with spare breaker, Work Orders (WOs) 20296162 and
===20296151
- (3) PT/1/A/0152/013, Low Pressure Service Water System Valve Stroke Test, following 1LPSW-251 actuator maintenance on July 29, 2020
- (4) IP/0/A/2005/004, Nuclear Energy Institute (NEI), PP-EP SVS Static Voltage Regulator Exciter System Test, following SSF diesel generator 'VA' relay replacement, WOs 20297948, and 20294527
- (5) PT/1/A/2200/020, KHU-1 ACB IST Surveillance, following replacement of K1AB-37 (ACB-3 reservoir relief valve), on July 22, 2020
- (6) PT/0/A/0620/009, Keowee Hydro Operation Test, following CT-4 maintenance on August 4, 2020
- (7) PT/3/A/0600/012, Turbine Driven Emergency Feedwater Pump Test, following replacement of solenoid 3MS-SV0074 on valve 3MS-93, on August 6, 2020
- (8) PT/3/A/0150/008 A, RB Personnel Hatch Leak Rate Test, following repairs to Unit 3 personnel hatch internal door on August 27, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) PT/0/A/0150/009, RB Personnel Hatch Outer Door O-Ring Leak Rate Test, on July, 17, 2020
Inservice Testing (IP Section 03.01)===
- (1) PT/1/A/0203/006 A, 1A Low Pressure Injection Pump Test - Recirculation, on July 29, 2020
- (3) PT/2/A/0600/012, Turbine Driven Emergency Feedwater Pump Test, on September 17, 2020
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) FLEX equipment testing under WO 20396560, on July 20, 2020
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency preparedness exercise during the week of August 31, 2020. The simulated scenario began with a report from the field that a spent fuel cask swung into the spent fuel pool (SFP) wall and caused damage resulting in loss of SFP inventory, thus meeting the criteria for declaration of an Unusual Event. Subsequently, an earthquake triggered seismic alarms and resulted in multiple reports of tremors being felt in and around the plant. SFP inventory significantly decreased to the point of meeting the conditions for an Alert declaration. An aftershock was simulated causing a feedwater pump to trip and subsequent reactor trip. SFP inventory continued to decrease, eventually meeting the conditions for declaration of a Site Area Emergency. After the 60-minute timeclock expired and SFP inventory could not be restored, conditions for a General Emergency (GE) were met. Following the GE, the Offsite Response Organizations demonstrated their ability to implement emergency actions.
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 August 31, 2020. This evaluation does not constitute NRC approval.
71114.08 - Exercise Evaluation Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (5 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit 1 and 2 spent fuel pool ventilation discharge system to main plant vent stack
- (2) Unit 1, 2, and 3 liquid release point at the chemical treatment pond release point
- (3) Oconee radwaste facility vent
- (4) Oconee plant liquid waste discharge monitor and release point
- (5) Unit 2 reactor building purge release ventilation system to the plant vent
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated effluent samples, sampling processes and compensatory samples, as available.
- (1) Inspectors observed the liquid effluent sampling of the discharge to chemical treatment pond #3
- (2) Inspectors evaluated effluent sampling of the U1 plant vent
- (3) Inspectors evaluated effluent samples, sampling processes, and compensatory samples, as available
- (4) Inspectors observed iodine and particulate sampling at the U2 vent
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) The inspectors evaluated the dose calculation for the weekly tritium samples for the plant vent on Unit 1
- (2) The inspectors reviewed the dose calculations for a Unit 3 purge sample
Abnormal Discharges (IP Section 03.04) (1 Sample)
The inspectors evaluated the following abnormal discharges:
- (1) Oconee Plant did not have any abnormal release occurrences in the inspection period.
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
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) EP01: Drill & Exercise Performance for the period July 1, 2019, through June 30, 2020.
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) EP02: Emergency Response Organization Drill Participation for the period July 1, 2019, through June 30, 2020.
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) EP03: Alert & Notification System Reliability for the period July 1, 2019, through June 30, 2020.
MS06: Emergency AC Power Systems (IP Section 02.05) (3 Samples)
- (1) Unit 1 (October 1, 2019 - June 30, 2020)
- (2) Unit 2 (October 1, 2019 - June 30, 2020)
- (3) Unit 3 (October 1, 2019 - June 30, 2020)
MS09: Residual Heat Removal Systems (IP Section 02.08) (3 Samples)
- (1) Unit 1 (October 1, 2019 - June 30, 2020)
- (2) Unit 2 (October 1, 2019 - June 30, 2020)
- (3) Unit 3 (October 1, 2019 - June 30, 2020)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (3 Samples)
- (1) Unit 1 (July 1, 2019 - June 30, 2020)
- (2) Unit 2 (July 1, 2019 - June 30, 2020)
- (3) Unit 3 (July 1, 2019 - June 30, 2020)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)09/30/2019 - 06/30/2020
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
Safety Conscious Work Environment
- (1) NRC inspectors assessed the Safety Conscious Work Environment (SCWE) within the Operations department at Oconee Nuclear Station. The inspectors conducted interviews with staff, supervisors, and the Assistant Operations Manager. In total, the NRC interviewed 56 percent of on-shift personnel.
During the inspection, inspectors were sensitive to areas and issues that would represent challenges to the free flow of information, such as areas where employees may be reluctant to raise concerns or report issues because of fear of retaliation.
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 05000287/2020-001-00, Unit 3 Manual Reactor Trip Due to Reaching Feedwater Heater Level Limit in Operating Procedure (ADAMS Accession No.
ML20161A404). The inspectors did not identify a violation of NRC requirements.
Reporting (IP Section 03.05) (1 Sample)
- (1) The inspectors reviewed the circumstances surrounding a potential report issue involving temporary maintenance configurations within the seismic boundary of the Unit 1 and 3 core flood tanks.
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 changes to the licensee's independent spent fuel storage installation program since February
INSPECTION RESULTS
Failure to Provide Unfettered Access to an NRC Resident Inspector Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000269,05000270,05000287/2020003-01 Open/Closed
Not Applicable 71111.04 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.70(b)(3),associated with the licensees failure to provide unfettered access to an NRC resident inspector. Specifically, while the NRC resident inspector was attempting to perform deep backshift observations and inspections, the resident inspector was denied access to the radiologically controlled area (RCA), even though the resident inspector complied with applicable access control measures. As a result, the NRCs ability to regulate was adversely impacted.
Description:
At approximately 9:00 p.m. on Tuesday, July 28, 2020, the resident inspector arrived at the Oconee RCA access point to conduct a planned partial system walkdown of the 1B train low pressure injection (LPI) system during a period where the 1A train of LPI was out of service due to planned maintenance. The planned walkdown was part of a baseline inspection sample required by Inspection Procedure 71111.04, Equipment Alignment. Upon attempting to sign into the RCA by logging into an electronic dosimeter (ED), the resident inspector received an error indicating required radworker training was expired and he could not proceed. The inspector questioned a radiation protection (RP) staff member stationed at the access point. The RP staff member checked the status of the resident inspector in his system and confirmed that the inspectors access authorization had been revoked by the Sentinel software and he could not check out an ED and enter the RCA due to required training that had expired. The RP staff member indicated that there was no way to resolve the access issue on nightshift due to the unavailability of administrative personnel and what was believed to be the legitimate need to complete expired training required for access. The inspector went to the main control room and spoke to multiple personnel, including the shift manager, about his inability to enter the RCA and the response was similar in that he must wait for administrative staff to assist in the completion of the required training before access could be granted. As a result, the resident inspector was neither able to observe all desired portions of the planned inspection activity, nor able to observe station conditions in the RCA during deep backshift, as planned. The resident left the site at approximately 12:00 am on July 29, 2020.
The following day, the inspector informed his management chain and additional licensee staff were able to review his status in the Sentinel software. It was confirmed that the software was showing his access was revoked due to expired training, but in fact the inspector was current on his required site access training. The licensee determined that an internal administrative error had resulted in the expiration date of the inspectors training not being manually updated when the inspector had last taken the training. The resident inspectors RCA access was restored on the morning of July 29, 2020.
Corrective Actions: The licensee performed fact-finding and properly restored the NRC inspectors RCA access. Specific vulnerabilities in the process of updating the Sentinel software were identified and corrected. Communications were conducted at the fleet level to ensure other sites were aware of the vulnerabilities.
Corrective Action References: NCR 2341604
Performance Assessment:
The inspectors determined this violation was associated with a minor 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: The finding was evaluated in accordance with the NRCs Enforcement Policy. The finding was reviewed by NRC management and because the denial of access occurred while the inspector was performing deep backshift observations and inspections reliant on confirming the specific plant configuration at that time access was requested, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV violation, consistent with the Enforcement Policy.
Violation: Title 10 CFR 50.70(b)(3), requires, in part, that the licensee shall afford any NRC resident inspector assigned to that site unfettered access, equivalent to access provided regular plant employees, following proper identification and compliance with applicable access control measures for security, radiological protection, and personal safety. Contrary to the above, on July 28-29, 2020, the licensee did not afford an NRC resident inspector assigned to the site unfettered access to the RCA, equivalent to access provided regular plant employees, following proper identification and compliance with applicable access control measures for security, radiological protection, and personal safety. Specifically, while the NRC resident inspector was performing deep backshift observations and inspections, the resident inspector was denied access to the RCA, even though the resident inspector complied with applicable access control measures. As a result, the NRCs ability to regulate was adversely impacted.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Operation of Normally Closed Seismic Boundary Valves URI 05000269,05000270,05000287/2020003-02 71111.18
Description:
An unresolved item was identified associated with the following issue. In 1998, NCR 1880594 described a need to develop a site licensing position for the opening of normally closed, manually operated, seismic boundary valves and whether any specific limitations or compensatory actions were required. In May of 2000, a position was established and added to UFSAR Section 3.7.3.9, Interaction of Other Piping with Piping Designed for Seismic Conditions, through implementation of UFSAR Change Package 99-219. The change concluded that opening any seismic boundary valve was acceptable and would not impact system operability for evolutions with a clearly definable beginning and end time and that the expectation was that the valve would be in the closed position much more than it would be in the open position. Inspectors were concerned that the 50.59 evaluation performed for UFSAR Change Package 99-219 may not have been appropriately supported. The inspectors requested to review the 50.59 evaluation; however, the licensee was not able to locate a complete, signed record of the evaluation supporting the change. Some draft evaluations were eventually located, but they lacked a qualified reviewer signature. In response, the licensee reassessed the change and ultimately decided to remove the statements from the UFSAR because of the vagueness of some of the statements and the potential that they may conflict with other aspects of the licensing basis for the facility. Further review is necessary to determine whether a performance deficiency or violation exists and whether they would be more-than-minor.
Planned Closure Actions: Inspectors need to evaluate whether UFSAR Change Package 99-219 and the limited number of retrievable records supporting the evaluation were/are in violation of 10 CFR 50.59 or other regulations. The licensee is currently conducting a review of each seismic boundary valve and the potential plant impacts of opening them. Inspectors will need to conduct their own sampling review of recent operations that required opening a boundary valve as well as evaluate the licensees review in order to determine if any violations would be more-than-minor.
Licensee Actions: The licensee has processed a UFSAR change to remove the subject paragraph from Section 3.7.3.9 and is conducting a review of seismic boundary valves.
Corrective Action References: NCR 2347573
Assessment 71152 NRC inspectors assessed the Safety Conscious Work Environment (SCWE) within the Operations department at Oconee Nuclear Station. Based on interviews, the inspectors determined that, overall, licensee management emphasized the need for all employees to identify and report concerns using the appropriate methods established within the administrative programs, including the corrective action program, the employee concerns program, and discussion with supervisors and managers. Personnel interviewed knew that these methods were readily accessible to all employees.
The NRC inspectors, however, concluded that warning signs exist within the Operations department that are indicative of a degraded SCWE. If these warning signs go unaddressed, it could lead to the further development of a chilled work environment.
Approximately 15 percent of those interviewed stated that they felt like they may be retaliated against if they raise certain concerns (which may include nuclear or radiological safety concerns). Furthermore, approximately 23 percent of the interviewees perceived that others in the department may be hesitant to raise some nuclear safety concerns for fear of retaliation. Although these percentages do not rise to the thresholds listed in the NRC Allegation Manual, Section 5.2.i, Chilling Effect/Chilled Work Environment Allegations, the safety significance of the work performed by the Operations department and indications that the reporting avenues affected may include reporting via chain-of-command, the NRC inspectors determined that measures should be taken by the licensee in order to prevent conditions from worsening.
The licensee has initiated NCR 02351953 to assess and establish corrective actions to address potential underlying issues. In discussions with NRC senior management, the licensee has committed to address the concerns from the results of this SCWE inspection to improve the safety conscious work environment within Oconee Operations department. The NRC intends to monitor the licensees progress and will conduct a follow-up assessment to determine whether the licensees corrective actions were adequate.
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 RP inspection results to J. Ed Burchfield and other members of the licensee staff.
- On September 3, 2020, the inspectors presented the emergency preparedness exercise inspection results to J. Ed Burchfield and other members of the licensee staff.
- On September 25, 2020, the inspectors presented the problem identification and resolution follow-up sample regarding safety conscious work environment inspection results to J. Ed Burchfield and other members of the licensee staff.
- On October 20, 2020, the inspectors presented the integrated inspection results to J. Ed Burchfield and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60855.1
Corrective Action
Documents
2341341, 2347768, 2341520, 2337799, 2341520
60855.1
Miscellaneous
ORANO Transfer Cask Examination Report
7/27/2020
60855.1
Miscellaneous
Technical Specification for the Standardized NUHOMS(R)
Horizontal Modular Storage System, Amendment 15 to
COC 1004
Drawings
K-0700
One Line Diagram - Relays & Meters - 13.8 - 230KV
Drawings
K-0709
Three Line Diagram Transformers No. 1, 1X, 2X, CX, 1E &
2E
Drawings
OFD-102A-1.1
Flow Diagram of Low Pressure Injection System (Borated
Water Supply & LPI Injection)
Drawings
OFD-102A-1.2
Flow Diagram of Low Pressure Injection System (LPI Pump
Discharge)
Drawings
OFD-102A-1.3
Flow Diagram of Low Pressure Injection System (Core
Flood)
Miscellaneous
Plant Status Protected Equipment Sheet
Work Orders
20360984, 20297880, 20297879, 02204076
Calculations
OSC-9314
NFPA 805 Transition Risk-Informed, Performance-Based
Fire Risk Evaluation
Calculations
OSC-9375
Oconee Fire PRA, Fire Scenario Report
Calculations
OSC-9378
Calculations
OSC-9491
NSCA Fire Area Impact Reports
Calculations
OSC-9659
Oconee Nuclear Safety Capability Assessment for Units 1,
and 3
Drawings
O-0310-L-002
Turbine Building - Unit 2 Fire Protection Plan & Fire
Barriers, Flood, & Pressure Boundaries Plan at EL 775+0
Drawings
O-310-K-10
Fire Protection Plan & Fire Barrier Flood & Pressure
Boundaries Plan At EL 809 + 3
Fire Plans
CSD-ONS-FS-020
Standard Operating Guide Key Equipment List by Fire Zone
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Fire Plans
CSD-ONS-PFP-
Pre-Fire Plan for U1 Auxiliary Building Elevation 809
Fire Plans
CSD-ONS-PFP-
Pre-Fire Plan for U2 Turbine Building Elevation 775
Corrective Action
Documents
01893113
Drawings
O-405G
Piping Layout Service Building Reverse Osmosis Room &
Warehouse Plan & Sections
Drawings
OFD-104A-1.3
Flow Diagram of Spent Fuel Cooling System Reverse
Osmosis Portion
Miscellaneous
OSC-10790
Oconee Nuclear Station Internal Flooding Analysis
003
Miscellaneous
OSC-8671
Auxiliary Building Flood Design Values
Miscellaneous
S.D. 3.2.16
Control of Passive Design Features
Procedures
AP/1-2/A/1700/030
Auxiliary Building Flood
23
71111.11Q Miscellaneous
ASE-16
Simulator Exercise Guide
00a
71111.11Q Procedures
AD-EP-ALL-0803
Evaluation and Critique of Drills and Exercises
71111.11Q Procedures
AD-LS-ALL-0006
Notification/Reportability Evaluation
71111.11Q Procedures
AD-OP-ALL-0101
Event Response and Notifications
71111.11Q Procedures
AD-OP-ALL-1000
Conduct of Operations
71111.11Q Procedures
AD-TQ-ALL-0420
Conduct of Simulator Training and Evaluation
71111.11Q Procedures
EP/1/A/1800/001
Unit 1 EOP Immediate Manual Actions and Subsequent
Actions
Corrective Action
Documents
1767641, 1786915, 1828997, 1838630, 1889410,
1970295, 1970568, 2341739, 2320466
Engineering
Changes
100512
Miscellaneous
License Renewal Aging Management Program Self-
Assessment Report
9/12/2019
Procedures
IP/0/B/0203/001
F1
Low Pressure Injection System Pressure Gauge
Calibration
Procedures
PT/0/A/0400/016
SSF HVAC System Flow Test
Procedures
PT/0/A/0400/023
SSF Air Conditioning Performance Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
20416236, 20062680, 02209381, 02115268, 02014429,
01947271, 01926242, 01888956, 01829627, 01765707,
1707676, 20181153, 20385095, 02208952
Miscellaneous
Projected ERAT Risk Profile
Miscellaneous
PRT-0-20-PSW
Outage-0148
Clearance\\Hanging Tags
Procedures
AD-NF-ALL-0501
Electronic Risk Assessment Tool (ERAT)
Procedures
AD-NF-NGO-0502
Probabilistic Assessment (PRA) Model Technical Adequacy 4
Procedures
AD-OP-ALL-0201
Protected Equipment
Procedures
CSD-WC-ONS-
240-00
Work Orders
296152, 20296211, 20295551, 20312238
Calculations
OSC-11067
Control Room Outside Air Booster Fan System Flow Rate
Test Acceptance Criteria Determination
Calculations
OSC-4051
1" Vent from Core Flood Tank 3A and 3B thru 3CF-5,
3CF-16, 3CF-18 and 3CF-6 Problem No. 3-53-13
Corrective Action
Documents
1906597, 1859321, 1848621, 1758216, 02338927,
2347996, 2338818
Drawings
OEE-117-95-0B
Elementary Diagram SSF 4160V, Switchgear OTS1 Comp.
No. 4 and 5 Diesel Generator
Drawings
OEE-117-95-0D
Elementary Diagram SSF 4160V, Switchgear OTS1 Comp.
No. 4 and 5 Diesel Generator
Drawings
OFD-124A-1.1
Flow Diagram of Low Pressure Service Water System
Turbine Bldg
Drawings
OM 245-2858.001
Edward Forged Steel Univalve Globe Stop Valve Socket
Welding Ends Size 1 FIG. D36124(F316)MLT2
Engineering
Changes
410811, 409984, 114998, 400736
Miscellaneous
ECV-0601.00-00-
0005
Specification for Seismic Qualification of Valves for ASME
Section III and Duke Energy Safety Class D (Oconee Only)
and F Applications
Miscellaneous
ECV-0601.00-00-
0005
Specification for Seismic Qualification of Equipment
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
OM 245-2858.003
DMV-2267 Design and Seismic Analysis
Miscellaneous
RAL-21360
Design and Seismic Analysis
Work Orders
20101850, 20147866, 20334764, 20357500, 20184958,
20412134, 20397564
Corrective Action
Documents
1880594, 1550001, 2347573
Miscellaneous
UFSAR change package 99-219
May 8, 2000
Miscellaneous
Oconee Nuclear Site 10 CFR 50.59 Annual Report
June 29,
2000
Corrective Action
Documents
2338310, 2342225, 2338927
Drawings
IP/0/A/5180/002
Cutler-Hammer Type M Relay Bench Test
Drawings
O-0985-C-006
Connection Diagram SSF (EOC) Sys Right Rear Half
Interconn Cab IC1
Drawings
O-422H-22
Instrument Detail LPSW Flow Control to Decay Heat (LPI)
Coolers
Drawings
OEE-163
Elementary Diagram SSF (EOC SYS) SSF Diesel Control
Drawings
OEE-608-01
Elementary Diagram Protected Service Water 4.16kV
Breaker B6T-6, 2000HP PSW (Primary) Pump
Drawings
OM 351-0015.004
Engine Control Schematic Diagram
Procedures
IP/0/A/2001/015
PSW 13.8kV/4.16kV Square D Type VR Vacuum Circuit
Breaker Inspection and Maintenance
Procedures
MP/0/A/1210/042
Operator - GH Bettis - T Series - Removal, Disassembly,
Repair, Reassembly and Installation
Procedures
OP/0/A/1107/011
C
Removal and Restoration of CT4 Transformer
005
Procedures
OP/0/A/2000/040
KHS Underground Power Path
011
Procedures
PT/0/A/0150/009
RB Personnel Hatch Outer Door O-Ring Leak Rate Test
036
Procedures
PT/0/A/0620/009
Keowee Hydro Operation
054
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
PT/1/A/0251/022
1LPSW-251 and 1 LPSW-252 Travel Stop Verification
Procedures
PT/1/A/2200/020
KHU-1 ACB IST Surveillance
2
Procedures
PT/3/A/0150/008 A
RB Personnel Hatch Leak Rate Test
010
Procedures
PT/3/A/0600/012
Turbine Driven Emergency Feedwater Pump Test
094
Work Orders
20360984, 20296089, 20398981, 20350541, 20346075,
20351882, 20412134, 20303361, 20178395
Calculations
OSC-8268
Unit 1 LPI Hydraulic Calculation for NSM ON-13093
Corrective Action
Documents
2338927
Drawings
OFD-121D-2.1
Flow Diagram of Emergency Feedwater System
Drawings
ONTC-1-102A-
030-01
LPI Pump Performance Test Acceptable and Required
Action Setpoints for Pump Total Developed Head
Miscellaneous
OM 201-1704.001
Ingersoll Rand NSSS Pumps (HPI, BS, SF, CC)
D45
Miscellaneous
PT/0/A/0150/009
RB Personnel Hatch Outer Door O-Ring Leak Rate Test
036
Procedures
PT/2/A/2200/019
KHU-2 Turbine Sump Pump IST Surveillance
Procedures
20396306, 20395491, 20412905
Work Orders
May 2020 Effluent
Summary Report
May 2020 Liquid and Gas Site Summary Report
06/09/2020
Calculations
Work Order
Number 20226223
PT/1/A/0110/005C, Unit One Reactor Building Purge Filter
Test
11/02/2018
Calibration
Records
Work Order
Number 20300710
Unit 3 PT/3/A/0110/005C Reactor Building Purge Filter
05/07/2020
Calibration
Records
Selected Condition
Reports
Condition Report Numbers 02232280, 02311497,
249755, 02232321 and 02222309
Corrective Action
Documents
2018 ARERR
2018 Annual Radiological Effluent Release Report
05/15/2018
Miscellaneous
2019 ARERR
2019 Annual Radiological Effluent Release Report
04/28/2019
Miscellaneous
CSD-RP-ALL-0028
Development of Ingestion and External Dose Conversion
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Factors for Radionuclides not in Regulatory Guide 1.109
Procedures
HP/0/B/1000/060 A Waste Gas Decay Tank Sampling and Release
Requirements
Procedures
SLC 16.11
Selected Licensee Commitments Chapter 16.11, Effluent
Controls
Procedures
GWR 2020400
Gaseous Waste Release Reactor Building Purge
05/07/2020
Radiation
Surveys
GWR 2020407
May 30 Day Effluent Report Summary for Daily Vents
06/01/2020
Radiation
Surveys
LWR L2020292
Decant Monitor Tank Release to Keowee Tailrace
05/13/2020
Radiation
Surveys
LWR L2020293
Decant Monitor Tank Release to Keowee Tailrace
05/25/2020
Radiation
Surveys
2018-ONS-RPCH-
NOS Audit Report - Oconee Radiation Protection and
Chemistry 2018
08/23/2018
Self-Assessments Quick Hitter Self
Assessment
250341-05
Annual 10CFR20 3-year Roll Up of Compliance
Assessments
11/13/2019
Self-Assessments 400719
LV-1D Air Sampler Calibration Certificate
07/11/2018
Calibration
Records
455020
LV-1D Air Sampler Calibration Certificate
01/27/2017
Calibration
Records
487845
ISCO Model 3710 Portable Sampler
10/08/2018
Calibration
Records
504822
ISCO Model 3710 Portable Sampler
07/15/2019
Calibration
Records
511342
LV-1D Air Sampler Calibration Certificate
10/15/2019
Calibration
Records
519787
LV-1D Air Sampler Calibration Certificate
03/10/2020
Calibration
Records
2126
LV-1D Air Sampler Calibration Certificate
04/13/2020
Calibration
Records
2509
ISCO Model 3710 Portable Sampler
04/20/2020
Calibration
Records
25493
ISCO Model 3710 Portable Sampler
06/15/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
214269, 02222309, 02227405, 02249467, 02276299,
2305408, 02320601, 02327998, 02331636, 02333218
Various
Miscellaneous
2018, 2019, and
20
Meteorological
Data Recovery
Reports
Meteorological Data Recovery Report
Various
Miscellaneous
2019 3rd Quarter
Report
Radiochemistry Crosscheck Program
10/24/2019
Miscellaneous
AD-RP-ALL-2003
Decommissioning record pursuant to 10 CFR 50.75(g)
05/07/2020
Miscellaneous
ENVIRONMENTAL
TLD Reports for
3rd Qtr 2019, 4th
Qtr 2019, and 1st
Qtr 2020
ONS ENVIRONMENTAL TLD Reports for 3rd Qtr 2019, 4th
Qtr 2019, and 1st Qtr 2020
Miscellaneous
Matrix Report
Miscellaneous
AD-CP-ALL-0014
LAND USE CENSUS EVALUATION
Procedures
AD-CP-ALL-0015
RADIOLOGICAL ENVIRONMENTAL MONITORING
PROGRAM DATA EVALUATION
Procedures
AD-CP-ALL-0017
RADIOLOGICAL GROUNDWATER PROTECTION
Procedures
EnRad Procedures
207, 700, 701,
2, 703, 704,
705, 707, 709,
715, 716, 850
EnRad Procedures
Procedures
IP/0/B/1601/004,
IP/0/B/1601/015,
IP/0/B/1601/008,
IP/0/B/1601/011,
IP/0/B/1601/012,
IP/0/B/1601/014,
IP/0/B/1601/003
Meteorological Towers Equipment Checking/Calibration
Procedures
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
01996026
NEI 07-07 Industry Groundwater Protection Initiative
Objectives
10/13/2016
Self-Assessments 02131548
2017 Radiological Environmental Monitoring Program
06/19/2017
Self-Assessments 02222820
08/14/2018
Self-Assessments 02334085
06/15/2020
Work Orders
20308326
METEOROLOGICAL EQUIPMENT CALIBRATION (SEMI-
ANNUAL)
09/02/2019
Work Orders
20349031
METEOROLOGICAL EQUIPMENT CALIBRATION (SEMI-
ANNUAL)
03/16/2020
Work Orders
Unit 1, Unit 2, Unit 3: MSPI Derivation Report (Residual
Heat Removal System) - Unreliability Index (URI)
71151
Miscellaneous
Unit 1, Unit 2, Unit 3: MSPI Derivation Report (Residual
Heat Removal System) - Performance Limit Exceeded
(PLE)
71151
Miscellaneous
Unit 1, Unit 2, Unit 3: System ROP-MSPI-RHR MSPI
Residual Heat Removal System
71151
Miscellaneous
CD/0/A/2005/022
Determination of Reported Tech Spec Dose Equivalent
Idodine-131
71151
Procedures
Unit 1, Unit 2, Unit 3: MSPI Derivation Report (Residual
Heat Removal System) - Unavailability Index (UAI)
71151
Work Orders
OSC-4039
Rigorous Analysis for Problem 1-53-13, Core Flood Tank
1A Vent Line Problem No 1-53-13
Calculations
OSC-4051
1" Vent from Core Flood Tank 3A and 3B thru 3CF-5,
3CF-16, 3CF-18 and 3CF-6. Problem No. 3-53-13
Calculations
2348216, 2271174, 2292614, 2283504
Corrective Action
Documents
OM 22200217.001
Nominal Flexible Metal Hose Assembly (3LPIFX0016
and 3LPIFX0017)
Drawings
OM 246-0006.001
Forged Steel Lists 54 70A / 600# Valves
Drawings
OM 246-0006.005
Velan Valve List
Drawings
MP/0/A/1500/024
Independent Spent Fuel Storage Installation Phase IX DSC
Loading and Storage
2