IR 05000269/2020003

Integrated Inspection Report 05000269/2020003, 05000270/2020003, 05000287/2020003, and 07200004/2020002

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 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 (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 Report Aspect Section Not Applicable NCV Not Applicable 71111.04 05000269,05000270,05000287/202000 3-01 Open/Closed 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 Operation of Normally 71111.18 Open 000287/2020003-02 Closed Seismic Boundary Valves LER 05000287/2020-001-00 LER 2020-001-00 for 71153 Closed Oconee Nuclear Station,

Unit 3, Manual Reactor Trip Due to Reaching Feedwater Heater Level Limit in Operating Procedure

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.

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

(4) Fire Zone 33: Unit 2 4160V TC, TD, TE switchgear on August 27, 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

(2) PT/2/A/2200/019, KHU-2 Turbine Sump Pump IST Surveillance, on July 23, 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

(2) PT/1/A/2200/019, KHU-1 Turbine Sump Pump IST Surveillance, on August 25, 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.

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 Report Aspect Section Not Severity Level IV Not 71111.04 Applicable NCV Applicable 05000269,05000270,05000287/2020003-01 Open/Closed 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 Operation of Normally Closed Seismic Boundary Valves 71111.18 (Open) URI 05000269,05000270,05000287/2020003-02

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 Type Designation Description or Title Revision or

Procedure Date

60855.1 Corrective Action 2341341, 2347768, 2341520, 2337799, 2341520

Documents

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

71111.04 Drawings K-0700 One Line Diagram - Relays & Meters - 13.8 - 230KV 46

71111.04 Drawings K-0709 Three Line Diagram Transformers No. 1, 1X, 2X, CX, 1E & 21

2E

71111.04 Drawings OFD-102A-1.1 Flow Diagram of Low Pressure Injection System (Borated 71

Water Supply & LPI Injection)

71111.04 Drawings OFD-102A-1.2 Flow Diagram of Low Pressure Injection System (LPI Pump 61

Discharge)

71111.04 Drawings OFD-102A-1.3 Flow Diagram of Low Pressure Injection System (Core 31

Flood)

71111.04 Miscellaneous Plant Status Protected Equipment Sheet

71111.04 Work Orders 20360984, 20297880, 20297879, 02204076

71111.05 Calculations OSC-9314 NFPA 805 Transition Risk-Informed, Performance-Based 6

Fire Risk Evaluation

71111.05 Calculations OSC-9375 Oconee Fire PRA, Fire Scenario Report 7

71111.05 Calculations OSC-9378 ONS Fire PRA Summary Report 4

71111.05 Calculations OSC-9491 NSCA Fire Area Impact Reports 1

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

and 3

71111.05 Drawings O-0310-L-002 Turbine Building - Unit 2 Fire Protection Plan & Fire 12

Barriers, Flood, & Pressure Boundaries Plan at EL 775+0

71111.05 Drawings O-310-K-10 Fire Protection Plan & Fire Barrier Flood & Pressure 13

Boundaries Plan At EL 809 + 3

71111.05 Fire Plans CSD-ONS-FS-020 Standard Operating Guide Key Equipment List by Fire Zone 0

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05 Fire Plans CSD-ONS-PFP- Pre-Fire Plan for U1 Auxiliary Building Elevation 809 0

1AB-0809

71111.05 Fire Plans CSD-ONS-PFP- Pre-Fire Plan for U2 Turbine Building Elevation 775 0

2TB-0775

71111.06 Corrective Action 01893113

Documents

71111.06 Drawings O-405G Piping Layout Service Building Reverse Osmosis Room & 1

Warehouse Plan & Sections

71111.06 Drawings OFD-104A-1.3 Flow Diagram of Spent Fuel Cooling System Reverse 4

Osmosis Portion

71111.06 Miscellaneous OSC-10790 Oconee Nuclear Station Internal Flooding Analysis 003

71111.06 Miscellaneous OSC-8671 Auxiliary Building Flood Design Values 8

71111.06 Miscellaneous S.D. 3.2.16 Control of Passive Design Features 9

71111.06 Procedures AP/1-2/A/1700/030 Auxiliary Building Flood 023

71111.11Q Miscellaneous ASE-16 Simulator Exercise Guide 00a

71111.11Q Procedures AD-EP-ALL-0803 Evaluation and Critique of Drills and Exercises 6

71111.11Q Procedures AD-LS-ALL-0006 Notification/Reportability Evaluation 3

71111.11Q Procedures AD-OP-ALL-0101 Event Response and Notifications 12

71111.11Q Procedures AD-OP-ALL-1000 Conduct of Operations 17

71111.11Q Procedures AD-TQ-ALL-0420 Conduct of Simulator Training and Evaluation 17

71111.11Q Procedures EP/1/A/1800/001 Unit 1 EOP Immediate Manual Actions and Subsequent 2

Actions

71111.12 Corrective Action 1767641, 1786915, 1828997, 1838630, 1889410,

Documents 1970295, 1970568, 2341739, 2320466

71111.12 Engineering 100512

Changes

71111.12 Miscellaneous License Renewal Aging Management Program Self- 9/12/2019

Assessment Report

71111.12 Procedures IP/0/B/0203/001 Low Pressure Injection System Pressure Gauge 3

F1 Calibration

71111.12 Procedures PT/0/A/0400/016 SSF HVAC System Flow Test 22

71111.12 Procedures PT/0/A/0400/023 SSF Air Conditioning Performance Test 8

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.12 Work Orders 20416236, 20062680, 02209381, 02115268, 02014429,

01947271, 01926242, 01888956, 01829627, 01765707,

1707676, 20181153, 20385095, 02208952

71111.13 Miscellaneous Projected ERAT Risk Profile

71111.13 Miscellaneous PRT-0-20-PSW Clearance\Hanging Tags

Outage-0148

71111.13 Procedures AD-NF-ALL-0501 Electronic Risk Assessment Tool (ERAT) 5

71111.13 Procedures AD-NF-NGO-0502 Probabilistic Assessment (PRA) Model Technical Adequacy 4

71111.13 Procedures AD-OP-ALL-0201 Protected Equipment 7

71111.13 Procedures CSD-WC-ONS- ONS ERAT Guidance 1

240-00

71111.13 Work Orders 20296152, 20296211, 20295551, 20312238

71111.15 Calculations OSC-11067 Control Room Outside Air Booster Fan System Flow Rate 0

Test Acceptance Criteria Determination

71111.15 Calculations OSC-4051 1" Vent from Core Flood Tank 3A and 3B thru 3CF-5, 6

3CF-16, 3CF-18 and 3CF-6 Problem No. 3-53-13

71111.15 Corrective Action 1906597, 1859321, 1848621, 1758216, 02338927,

Documents 2347996, 2338818

71111.15 Drawings OEE-117-95-0B Elementary Diagram SSF 4160V, Switchgear OTS1 Comp. 4

No. 4 and 5 Diesel Generator

71111.15 Drawings OEE-117-95-0D Elementary Diagram SSF 4160V, Switchgear OTS1 Comp. 8

No. 4 and 5 Diesel Generator

71111.15 Drawings OFD-124A-1.1 Flow Diagram of Low Pressure Service Water System 54

Turbine Bldg

71111.15 Drawings OM 245-2858.001 Edward Forged Steel Univalve Globe Stop Valve Socket 0

Welding Ends Size 1 FIG. D36124(F316)MLT2

71111.15 Engineering 410811, 409984, 114998, 400736

Changes

71111.15 Miscellaneous ECV-0601.00-00- Specification for Seismic Qualification of Valves for ASME 2

0005 Section III and Duke Energy Safety Class D (Oconee Only)

and F Applications

71111.15 Miscellaneous ECV-0601.00-00- Specification for Seismic Qualification of Equipment 1

0005

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.15 Miscellaneous OM 245-2858.003 DMV-2267 Design and Seismic Analysis 0

71111.15 Miscellaneous RAL-21360 Design and Seismic Analysis 3

71111.15 Work Orders 20101850, 20147866, 20334764, 20357500, 20184958,

20412134, 20397564

71111.18 Corrective Action 1880594, 1550001, 2347573

Documents

71111.18 Miscellaneous UFSAR change package 99-219 May 8, 2000

71111.18 Miscellaneous Oconee Nuclear Site 10 CFR 50.59 Annual Report June 29,

2000

71111.19 Corrective Action 2338310, 2342225, 2338927

Documents

71111.19 Drawings IP/0/A/5180/002 Cutler-Hammer Type M Relay Bench Test 5

71111.19 Drawings O-0985-C-006 Connection Diagram SSF (EOC) Sys Right Rear Half 22

Interconn Cab IC1

71111.19 Drawings O-422H-22 Instrument Detail LPSW Flow Control to Decay Heat (LPI) 11

Coolers

71111.19 Drawings OEE-163 Elementary Diagram SSF (EOC SYS) SSF Diesel Control 5

71111.19 Drawings OEE-608-01 Elementary Diagram Protected Service Water 4.16kV 2

Breaker B6T-6, 2000HP PSW (Primary) Pump

71111.19 Drawings OM 351-0015.004 Engine Control Schematic Diagram 0

71111.19 Procedures IP/0/A/2001/015 PSW 13.8kV/4.16kV Square D Type VR Vacuum Circuit 5

Breaker Inspection and Maintenance

71111.19 Procedures MP/0/A/1210/042 Operator - GH Bettis - T Series - Removal, Disassembly, 8

Repair, Reassembly and Installation

71111.19 Procedures OP/0/A/1107/011 Removal and Restoration of CT4 Transformer 005

C

71111.19 Procedures OP/0/A/2000/040 KHS Underground Power Path 011

71111.19 Procedures PT/0/A/0150/009 RB Personnel Hatch Outer Door O-Ring Leak Rate Test 036

71111.19 Procedures PT/0/A/0620/009 Keowee Hydro Operation 054

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.19 Procedures PT/1/A/0251/022 1LPSW-251 and 1 LPSW-252 Travel Stop Verification 19

71111.19 Procedures PT/1/A/2200/020 KHU-1 ACB IST Surveillance 012

71111.19 Procedures PT/3/A/0150/008 A RB Personnel Hatch Leak Rate Test 010

71111.19 Procedures PT/3/A/0600/012 Turbine Driven Emergency Feedwater Pump Test 094

71111.19 Work Orders 20360984, 20296089, 20398981, 20350541, 20346075,

20351882, 20412134, 20303361, 20178395

71111.22 Calculations OSC-8268 Unit 1 LPI Hydraulic Calculation for NSM ON-13093 5

71111.22 Corrective Action 2338927

Documents

71111.22 Drawings OFD-121D-2.1 Flow Diagram of Emergency Feedwater System 41

71111.22 Drawings ONTC-1-102A- LPI Pump Performance Test Acceptable and Required 1

030-01 Action Setpoints for Pump Total Developed Head

71111.22 Miscellaneous OM 201-1704.001 Ingersoll Rand NSSS Pumps (HPI, BS, SF, CC) D45

71111.22 Miscellaneous PT/0/A/0150/009 RB Personnel Hatch Outer Door O-Ring Leak Rate Test 036

71111.22 Procedures PT/2/A/2200/019 KHU-2 Turbine Sump Pump IST Surveillance 20

71111.22 Procedures 20396306, 20395491, 20412905

71111.22 Work Orders May 2020 Effluent May 2020 Liquid and Gas Site Summary Report 06/09/2020

Summary Report

71124.06 Calculations Work Order PT/1/A/0110/005C, Unit One Reactor Building Purge Filter 11/02/2018

Number 20226223 Test

71124.06 Calibration Work Order Unit 3 PT/3/A/0110/005C Reactor Building Purge Filter 05/07/2020

Records Number 20300710

71124.06 Calibration Selected Condition Condition Report Numbers 02232280, 02311497,

Records Reports 02249755, 02232321 and 02222309

71124.06 Corrective Action 2018 ARERR 2018 Annual Radiological Effluent Release Report 05/15/2018

Documents

71124.06 Miscellaneous 2019 ARERR 2019 Annual Radiological Effluent Release Report 04/28/2019

71124.06 Miscellaneous CSD-RP-ALL-0028 Development of Ingestion and External Dose Conversion 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Factors for Radionuclides not in Regulatory Guide 1.109

71124.06 Procedures HP/0/B/1000/060 A Waste Gas Decay Tank Sampling and Release 67

Requirements

71124.06 Procedures SLC 16.11 Selected Licensee Commitments Chapter 16.11, Effluent 27

Controls

71124.06 Procedures GWR 2020400 Gaseous Waste Release Reactor Building Purge 05/07/2020

71124.06 Radiation GWR 2020407 May 30 Day Effluent Report Summary for Daily Vents 06/01/2020

Surveys

71124.06 Radiation LWR L2020292 Decant Monitor Tank Release to Keowee Tailrace 05/13/2020

Surveys

71124.06 Radiation LWR L2020293 Decant Monitor Tank Release to Keowee Tailrace 05/25/2020

Surveys

71124.06 Radiation 2018-ONS-RPCH- NOS Audit Report - Oconee Radiation Protection and 08/23/2018

Surveys 01 Chemistry 2018

71124.06 Self-Assessments Quick Hitter Self Annual 10CFR20 3-year Roll Up of Compliance 11/13/2019

Assessment Assessments

250341-05

71124.06 Self-Assessments 400719 LV-1D Air Sampler Calibration Certificate 07/11/2018

71124.07 Calibration 455020 LV-1D Air Sampler Calibration Certificate 01/27/2017

Records

71124.07 Calibration 487845 ISCO Model 3710 Portable Sampler 10/08/2018

Records

71124.07 Calibration 504822 ISCO Model 3710 Portable Sampler 07/15/2019

Records

71124.07 Calibration 511342 LV-1D Air Sampler Calibration Certificate 10/15/2019

Records

71124.07 Calibration 519787 LV-1D Air Sampler Calibration Certificate 03/10/2020

Records

71124.07 Calibration 522126 LV-1D Air Sampler Calibration Certificate 04/13/2020

Records

71124.07 Calibration 522509 ISCO Model 3710 Portable Sampler 04/20/2020

Records

71124.07 Calibration 525493 ISCO Model 3710 Portable Sampler 06/15/2020

Records

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.07 Corrective Action 02214269, 02222309, 02227405, 02249467, 02276299, Various

Documents 02305408, 02320601, 02327998, 02331636, 02333218

71124.07 Miscellaneous 2018, 2019, and Meteorological Data Recovery Report Various

20

Meteorological

Data Recovery

Reports

71124.07 Miscellaneous 2019 3rd Quarter Radiochemistry Crosscheck Program 10/24/2019

Report

71124.07 Miscellaneous AD-RP-ALL-2003 Decommissioning record pursuant to 10 CFR 50.75(g) 05/07/2020

71124.07 Miscellaneous ONS ONS ENVIRONMENTAL TLD Reports for 3rd Qtr 2019, 4th

ENVIRONMENTAL Qtr 2019, and 1st Qtr 2020

TLD Reports for

3rd Qtr 2019, 4th

Qtr 2019, and 1st

Qtr 2020

71124.07 Miscellaneous ONS SSC Risk ONS SSC Risk Matrix Report

Matrix Report

71124.07 Miscellaneous AD-CP-ALL-0014 LAND USE CENSUS EVALUATION 2

71124.07 Procedures AD-CP-ALL-0015 RADIOLOGICAL ENVIRONMENTAL MONITORING 3

PROGRAM DATA EVALUATION

71124.07 Procedures AD-CP-ALL-0017 RADIOLOGICAL GROUNDWATER PROTECTION 3

71124.07 Procedures EnRad Procedures EnRad Procedures

207, 700, 701,

2, 703, 704,

705, 707, 709,

715, 716, 850

71124.07 Procedures IP/0/B/1601/004, Meteorological Towers Equipment Checking/Calibration

IP/0/B/1601/015, Procedures

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

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.07 Procedures 01996026 NEI 07-07 Industry Groundwater Protection Initiative 10/13/2016

Objectives

71124.07 Self-Assessments 02131548 2017 Radiological Environmental Monitoring Program 06/19/2017

71124.07 Self-Assessments 02222820 2018 ONS REMP Self-Assessment 08/14/2018

71124.07 Self-Assessments 02334085 2020 ONS REMP Self-Assessment 06/15/2020

71124.07 Work Orders 20308326 METEOROLOGICAL EQUIPMENT CALIBRATION (SEMI- 09/02/2019

ANNUAL)

71124.07 Work Orders 20349031 METEOROLOGICAL EQUIPMENT CALIBRATION (SEMI- 03/16/2020

ANNUAL)

71124.07 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 6

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 5

1A Vent Line Problem No 1-53-13

71153 Calculations OSC-4051 1" Vent from Core Flood Tank 3A and 3B thru 3CF-5, 6

3CF-16, 3CF-18 and 3CF-6. Problem No. 3-53-13

71153 Calculations 2348216, 2271174, 2292614, 2283504

71153 Corrective Action OM 22200217.001 1 Nominal Flexible Metal Hose Assembly (3LPIFX0016 0

Documents and 3LPIFX0017)

71153 Drawings OM 246-0006.001 Forged Steel Lists 54 70A / 600# Valves 0

71153 Drawings OM 246-0006.005 Velan Valve List 3

71153 Drawings MP/0/A/1500/024 Independent Spent Fuel Storage Installation Phase IX DSC 2

Loading and Storage

2