IR 05000269/2020010
| ML21022A160 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/22/2021 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Burchfield J Duke Energy Carolinas |
| References | |
| IR 2020010 | |
| Download: ML21022A160 (24) | |
Text
January 22, 2021
SUBJECT:
OCONEE NUCLEAR STATION - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000269/2020010 AND 05000270/2020010 AND 05000287/2020010 AND NOTICE OF VIOLATION
Dear Mr. Burchfield,
Jr.:
On September 24, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station and 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.
Based on the results of this inspection, the NRC has identified an issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined a violation is associated with this issue. This violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is cited in the Notice because it did not meet the criteria to be treated as a non-cited violation because the licensee failed to restore compliance with safety-related electrical system voltage calculations associated with two previous NRC Green NCVs from 2011 and 2014 CDBI inspections. The failure to restore compliance follows guidance from NRC Enforcement Manual Chapter 2.2.2.A, Circumstances Resulting in Consideration of an NOV (vs. an NCV) for Licensees and Non-Licensees with an Approved Corrective Action Program.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRCs review of your response to the Notice will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.
Additionally, one finding of very low safety significance (Green) is documented in this report.
This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) 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. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Oconee 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/
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety
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:
Report Numbers:
05000269/2020010, 05000270/2020010 and 05000287/2020010
Enterprise Identifier: I-2020-010-0044
Licensee:
Duke Energy Carolinas, LLC
Facility:
Oconee Nuclear Station
Location:
Seneca, SC
Inspection Dates:
August 03, 2020 to August 21, 2020
Inspectors:
J. Brand, Reactor Inspector
P. Braxton, Reactor Inspector
M. Greenleaf, Reactor Inspector
J. Parent, Resident Inspector
R. Patterson, Senior Reactor Inspector
T. Su, Reactor Inspector
D. Edwards, Reactor Inspector (Trainee)
Approved By:
James B. Baptist, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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
Failure to Evaluate Design Basis Conditions for PPM Applicability for Motor Operated Valve 1LP-2 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000270,05000287,05000269/202001 0-01 Open
[H.7] -
Documentation 71111.21M The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Appendix B, Criterion V of 10 CFR Part 50 when the licensee failed to demonstrate that MOV 1LP-2 is capable of performing its design basis safety function by failing to justify the use of the EPRI PPM in accordance with DPS-1205.19-00-0002.
Inadequate Corrective Action - Control Voltage for 4160 Breakers Closing Coil and 480V MCC control Circuits were not Assured Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000270,05000287,05000269/202001 0-02 Open None 71111.21M The team identified a Green cited violation, with two examples, of 10 CFR 50, Appendix B,
Criterion XVI, for the licensees failure to correct a condition adverse to quality. Specifically, the licensee (1) failed to perform all corrective actions identified to correct voltage calculations for safety-related 4160V circuit breaker 125Vdc control circuits and (2) failed to perform all corrective actions to correct voltage calculations for safety-related 120Vac MCC control circuits. The above issues were previously identified in NCV-05000269,270,287/2011010-04;
NCV 05000269,270,287/2011010-0; and NCV 05000269/2014007-02; 05000270/2014007-02; 05000287/2014007-02, respectively.
Additional Tracking Items
None.
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), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion 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
===71111.21M - Design Bases Assurance Inspection (Teams)
The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (3 Samples)
- (1) Lee Gas Station Transformer (CT-5)
- Compliance with UFSAR, TS, and TS Bases
- Conformance with manufacturer instructions for installation, maintenance, and operation
- Adequacy of corrective action activities
- Material condition and configuration
- Verification that System Health Report accurately reflect current system conditions
- Design requirements (tap settings, degraded grid and loss of voltage relays setting, load flow analysis and short circuit calculation, etc.)
- (2) Instrument Air (IA) Main Compressor
- Conformance with maintenance and operation procedures
- Adequacy of corrective action activities
- Material condition and configuration
- Design requirements
- Maintenance review
- (3) Unit 3 Control Rod Drive
- Conformance with maintenance and operating procedures
- Adequacy of corrective action activities
- Material condition and configuration
- Design requirements
- Verification that System Health Report accurately reflect current system conditions
- Maintenance review
Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)===
- Compliance with UFSAR, TS, and TS Bases
- Conformance with manufacturer instructions for installation, maintenance, and operation
- Adequacy of corrective action activities
- Material condition and configuration
- Verification that System Health Report accurately reflect current system conditions
- Design requirements
Modification Review - Permanent Mods (IP Section 02.03) (5 Samples)
- (1) EC 107578 - Actuator Change for 1LP-2 to Increase Stroke Time
- (2) EC 95361 - Keowee Main Step-up (KMSU) Transformer Replacement
- (3) EC 113581-Replace the SSF RC Make-Up Pump Motor New Motor
- (4) EC 112329-Install New Unit 2 LPSW Supply to the MDEFWP Motor Coolers and Separate It from Unit 1
- (5) EC 405874-Modify Three Pipe Supports on Unit 3 HPI Injection Due to Thermal Stratification; 51A-0-2479A-H2D, 52A-0-2479A-H13A, and 51A-0-2479A-H16A
Review of Operating Experience Issues (IP Section 02.06) (2 Samples)
- (1) IN 2009-10: Transformer Failures - Recent Operating Experience
- (2) IN 2017-005 - Potential Binding of Masterpact and NW 480-VAC Circuit Breaker Anti-Pump Features
INSPECTION RESULTS
Failure to Evaluate Design Basis Conditions for PPM Applicability for Motor Operated Valve 1LP-2 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green
[H.7] -
Documentation 71111.21M NCV 05000270,05000287,05000269/20200 10-01 Open
The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Appendix B, Criterion V of 10 CFR Part 50 when the licensee failed to demonstrate that MOV 1LP-2 is capable of performing its design basis safety function by failing to justify the use of the EPRI PPM in accordance with DPS-1205.19-00-0002.
Description:
In 2014, the Electric Power Research Institute (EPRI) issued an error notice informing the licensee that the Performance Prediction Methodology (PPM) software had an error that allowed 400 series martensitic stainless steel to be treated as 300 series austenitic stainless steel. This error would lead some licensees to believe that valves with 400 series steel internal sliding surfaces would meet the EPRI PPM applicability criteria. EPRI stated that if licensees could adequately justify appropriate guide rail friction coefficients, then the PPM may be considered applicable and the resulting analyses may be classified as Best Available Information.
The licensee entered the issue into its corrective action program and determined that several valves contained 400 series stainless steel in their guide rail design and performed an engineering evaluation to attempt to demonstrate that the PPM results were best available and would provide reasonable assurance, in part, of the motor operated valve's (MOVs)capability to perform their safety function(s) during design basis accidents. Part of this basis relied on the use of Joint Owners Group (JOG) valve data to establish a bounding coefficient of friction for the 400 series steel valve internal sliding surfaces. In performing this evaluation, the licensee determined that 1LP-2 was one MOV that required such justifications as described in the EPRI error notice.
MOV 1LP-2 is required to open during post-loss-of-coolant-accident (post-LOCA) and steam generator tube rupture accidents to provide an alternate boron dilution path and reactor coolant system (RCS) cooling function, respectively. The method by which the licensee attempted to demonstrate the capability of this MOV relies upon, in part, EPRIs PPM software.
The licensees use of JOG data to determine a bounding coefficient of friction without confirming that the JOG data was applicable and of quality dictated by the licensees QA program failed to justify the coefficient of friction chosen by the licensee (0.72) as an input into the PPM software.
Additionally, in April of 2020, Engineering Change EC 107578 completed the modification of Low Pressure Injection (LPI) MOV 1LP-2 via a change to its overall actuator gear ratio such that it would open slower to prevent the rapid collapse of voids in the LPI piping which had led to a previous pressure transient event in the system. The modification also changed the opening order of MOVs 1LP-1 and 1LP-2 (which are in series) such that 1LP-2 would open after 1LP-1. Specifically, OSS-0254.00-00-1028, Rev. 74, states in Section 2.4.2.22:
1/2/3LP-2 should be the last valve opened and the first valve closed when aligning and isolating the LPI DHR mode of operation. In addition, this valve should be the last valve opened when aligning the alternate boron dilution flow path following a LOCA.
This opening order of the valves was also reflected in Emergency Operating Procedure EP-1-A-1800-001-0I, Rev. 0, LOCA Cooldown, where MOV 1LP-2 would be expected to be opened after 1LP-105 and 1LP-1 to establish a safety-related flow-path between the units decay heat drop line and the emergency sump. Based on the design basis information provided in the emergency operating procedure and the system design basis document (OSS-0254.00-00-1028 Rev. 60), the design of the alternate boron dilution flow-path would indicate that the MOV would be required to be designed for flow conditions when it is required to open post-LOCA.
Based upon language also noted by the inspectors in OSS-0254.00-00-1028 Rev. 60, the inspectors questioned if the 250°F maximum fluid temperature was accurate as described in OSC-4281, OSC-5674, and OSC-5879. The licensee reviewed additional documentation and determined that based upon Babcock & Wilcox Owners Group analysis (as described in technical support center (TSC) guidance EM 5.1) that the expected fluid temperature that 1LP-2 would experience during a LOCA alternate boron dilution alignment was approximately 315°F.
Considering a design basis flow condition at a fluid temperature of 315°F, the inspectors noted that galling of the guide rails is expected (EPRI TR-1002847). Based upon this design basis review, the inspectors found that the justification for the coefficient of friction used in the licensees application of the PPM for 1LP-2 was additionally inadequate based on the expectation of galling at this high temperature under potential flow conditions.
The licensee reviewed its design basis documentation and procedures and determined that technical support center (TSC) guidance document EM 5.1 (which is not a safety-related, quality assurance (QA-1) document) contained procedural steps for placing the alternate boron dilution path into service that differed significantly from the QA emergency operating procedures. Based upon its review of those documents, the licensee asserted that the operations staff would defer to the TSC guidance and not align the alternate boron dilution flow path in such a way as to require 1LP-2 to open under a flow condition.
Inspectors additionally questioned whether voiding of piping downstream of 1LP-2 during normal, abnormal, and design basis accident conditions could occur such that the valve could be opened under flow conditions at temperatures in excess of 200°F. As a result of these questions, the licensee reviewed the potential conditions of downstream piping and determined under LOCA conditions the piping could be voided - leading to a flow condition at high temperatures.
As a result of the inadequate justification for the application of the EPRI PPM based upon the use of unverified JOG valve data, and upon several inaccuracies in the incorporation of the licensees design basis into calculations, procedures and specifications, the inspectors determined that the characterization of MOV 1LP-2 as JOG Class B was not appropriate and that the MOV should be considered as Class D. JOG Class D MOVs are subject to periodic verification of their design-basis capability to satisfy 10 CFR 50.55a(b)(3)(ii) and the licensees GL 96-05 program.
Corrective Actions: The licensee entered these issues into the corrective action program as NCR 02344871. The licensee evaluated the valves functionality considering the potential for galling and concluded that the valve could supply the necessary flow if only opened 1/16 of an inch - a stroke that would be highly likely to be successful even with galling likely to occur.
Additionally, the licensee took immediate actions to order the operations staff to defer to EM 5.1 guidance for alternate boron dilution flow-path alignment procedures until new emergency operating procedures could be written. Based on the licensees functionality assessment, its order to the operations staff and the margin available in the MOV actuator capability, the licensee asserted that the MOV can meet its safety function to open when called upon.
Corrective Action References: NCR 02344871
Performance Assessment:
Performance Deficiency: The failure to appropriately justify the use of the EPRI PPM for MOV 1LP-2 is a performance deficiency. Specifically, Attachment 20 DPS-1205.19-00-0002, requires, in part, that the licensee will be responsible for justifying the use of the EPRI model for valve designs not tested as part of the EPRI program.
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 unjustified use of the EPRI PPM misclassified 1LP-2 as a JOG Class B MOV, which is excused from periodic verification testing under dynamic flow conditions with increased diagnostic testing required by 10 CFR 50.55a(b)(3)(ii). This reduced inspection to track and correct the deleterious effects of degradation over time - adversely impacted the reliability and capability of the MOV to perform its safety function when called upon in post-LOCA and steam generator tube rupture accident scenarios.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This finding was screened to Green because the finding was a deficiency affecting the design or qualification of a mitigating structure, system or component (SSC) and the SSC maintained its operability or PRA functionality.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. This aspect was assigned because the performance deficiency's most significant contributor was the change to the opening order of the MOV 1LP-2 - which was not fully evaluated in EC 107578 which was closed in April of 2020.
Enforcement:
Violation: Appendix B, Criterion V, in 10 CFR Part 50 requires 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. Contrary to this, the licensee failed to demonstrate that MOV 1LP-2 was capable of performing its design basis safety function by failing to justify the use of the EPRI PPM in accordance with DPS-1205.19-00-0002.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Corrective Action - Control Voltage for 4160 Breakers Closing Coil and 480V MCC control Circuits were not Assured Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NOV 05000270,05000287,05000269/20200 10-02 Open
None 71111.21M The team identified a Green cited violation, with two examples, of 10 CFR 50, Appendix B, Criterion XVI, for the licensees failure to correct a condition adverse to quality. Specifically, the licensee
- (1) failed to perform all corrective actions identified to correct voltage calculations for safety-related 4160V circuit breaker 125Vdc control circuits and
- (2) failed to perform all corrective actions to correct voltage calculations for safety-related 120Vac MCC control circuits. The above issues were previously identified in NCV-05000269,270,287/2011010-04; NCV 05000269,270,287/2011010-0; and NCV 05000269/2014007-02; 05000270/2014007-02; 05000287/2014007-02, respectively.
Description:
During the 2020 DBAI, the team reviewed previous violations and their associated corrective actions and identified that all concerns, issues, and corrective actions from the original violations in 2011 and 2014 were not addressed.
Example 1 - Failure to Perform Corrective Actions to Correct Voltage Calculations for Safety-Related 4160V Circuit Breaker 125Vdc Control Circuits
The 2011 CDBI team identified a Green violation of Criterion III to perform adequate 125VDdc control circuit calculations, which credited the use Test Report (TR)-144, Oconee Emergency Power 5HK Switchgear Test," a one time test in 1995 at Oconee, to re-qualify the breaker close coil circuits from 100Vdc as qualified by the vendor, to 70Vdc. The testing did not consider seismic, aging or temperature concerns which were the basis of the vendor qualified rating of 100VDC. Additionally, the licensee took credit for the completion of preventative maintenance procedures which periodically tested the breakers at 85VDC. The violation also questioned whether this 70VDC tested values were used in other Oconee calculations. NCR 1904970 was written in 2011 to evaluate the use of TR-144 in only OSC-6195 that was specifically used as the violation example. As an action, EC110252 was performed to address aging and temperature effects for OSC-6195 but, an extent of condition was not performed to identify all calculations that the same condition would apply. The 2014 CDBI team identified a Criterion XVI Green violation for licensee's failure to correct all calculations for safety-related 4160V circuit breaker 125Vdc control circuits where the same issue identified in 2011 was also applicable. NCR 186283 was written to address only one of the new identified calculations, OSC-8113, but was closed stating in part, that, the condition was a legacy human performance deficiency and no additional actions were required.
After the team raised the issues during the 2020 DBAI, the licensee issued AR 02343949 and AR 02343959 to re-visit the corrective actions from the previous inspection violations and re-evaluate their review of similar fleet OE which represented an additional missed opportunity to revisit their previous actions.
Example 2 - Failure to Perform Corrective Actions to Correct Voltage Calculations for Safety-Related 120Vac Motor Control Center Control Circuits
The 2011 CDBI team identified the following five areas of concern in regard to testing, including sample sizes, ambient temperature, and aging:
- For Sylvania TM starters only two specimens each of size 1 and 2 were tested, providing an inadequate basis for the rating.
- For Joslyn Clark and Cutler Hammer contactors the calculation took credit for Control Power Transformer boost (approximately 2-4%) that had already been credited in tests.
- Tests were conducted on contactors at shop ambient temperature (cold coil). Contactors may have been required to operate in service with hot coils. This could have raised the pickup voltage by approximately 4%.
- The acceptance criteria in the calculation did not provide margin over test criteria to account for degradation over the service life of the contactors. Contactors were not periodically tested to confirm low pickup voltage capability.
- The calculation contained incomplete or obsolete information (e.g. contactors that have been replaced and test reports missing).
The site documented these concerns in PIP 0-11-11440 and 0-11-11510. In CDBI 2014-007, the team issued a Green Violation of Criterion XVI for failure to correct the issues and concerns from the 2011 Violation, as PIP 0-11-11440 issued at that time was closed with some of the corrective actions not fully addressed and was documented in AR 01864324. During this inspection in 2020, the team determined that the original corrective actions were not fully implemented to resolve the issues identified in violations in 2011 and 2014. As a result, Oconee issued AR 02343569 to address of the original corrective actions which required the MCC PM procedure IP/0/A/3011/015 be revised to bound all contactor coil minimum design pickup voltages. This AR still did not adequately address all of the following original issues that were identified in the original 2011 and 2014 violations.
Corrective Actions: This is violation has been entered into the licensees corrective action program AR 02343949, AR 02343959 and AR 02343569.
Corrective Action References: AR 02343949, AR 02343959 and AR 02343569
Performance Assessment:
Performance Deficiency: The licensees failure to perform corrective actions to correct voltage calculations for safety-related 4160V circuit breaker 125Vdc control circuits and to correct voltage calculations for safety-related 120Vac MCC control circuits as required by 10 CFR Part 50, Appendix B, Criterion XVI, was a performance deficiency. The team determined that the performance deficiency was more than minor because it affected the Equipment Performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to account for seismic, aging and environmental effects could negatively impact the reliability of the affected safety-related electrical components.
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. The team determined that the performance deficiency was more than minor because it affected the Equipment Performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to account for aging and environmental effects could negatively impact the reliability of the affected safety-related electrical components.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, 0609.04, Initial Characterization of Findings. Because the finding impacted the Mitigating Systems cornerstone, the team screened the finding through IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, using Exhibit 2, Mitigating Systems Screening Questions. The finding screened as of very low safety significance (Green) because the incomplete corrective actions did not result in losses of operability or function for any of the examples.
Cross-Cutting Aspect: None
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and non-conformances are promptly identified and corrected. Contrary to the above, since June 27, 2014, the licensee failed to correct conditions adverse to quality. Specifically, the licensee (1)failed to correct voltage calculations for safety-related 4160V circuit breaker 125Vdc control circuits and
- (2) failed to correct voltage calculations for safety-related 120VAC MCC control circuits.
This violation is of very low safety significance and has been entered into the licensees corrective action program AR 02343949, AR 02343959 and AR 02343569. The failure to restore compliance follows guidance from NRC Enforcement Manual Chapter 2.2.2.A, Circumstances Resulting in Consideration of an NOV (vs. an NCV) for Licensees and Non-Licensees with an Approved Corrective Action Program.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified 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 September 24, 2020, the inspectors presented the design basis assurance inspection (teams) inspection results to J. Ed Burchfield, Jr. and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21M Calculations
OSC 1776
Problem No. 1-14-08; 3 inch Backwash Piping From LPSW
Pump to L.P. Strainers; System 14
Revised per As-Built EC112329 and per As-Designed
EC113381.000
Rev. 23
OSC 1776
Piping Analysis for 3" Strainer Backwash piping from LPSW
Pumps to 2" piping to Units 1 & 2 EFWP Motors: Piping
Analysis Problem No. 1-14-08
Rev. 26
OSC-0559
Piping Analysis from Penetrations #3 and #44 to the
Component Cooling Pumps Analysis Problem No. 3-55-02
Rev. 13
OSC-10667
Qualification of Component Coolers "3A" & "3B" Piping
Analysis Problem No. 3-55-15
Rev. 4
OSC-11071
Uncertainty Calculation for BWST Discharge Pump Header
Digital Differential Pressure Transmitter (Rosemount 3051N)
Rev. 4
OSC-11202
CRD Filter Nozzle Evaluation
Rev. 1
OSC-11210
Anchorage Evaluation for Component Cooling Coolers 3A &
3B
Rev. 002
OSC-11343
Evaluation of MOV Motors and ETAP Inputs
Rev. 3
OSC-11522
Failure Modes and Effect Analysis for EC 96548
Rev. 1
OSC-11562
ONS Unit 2 Main Generator Relay Settings for the SEL-
300G and Beckwith M-3425A Relays
Rev. 0
OSC-11563
ONS Unit 2 Unit and Auxiliary Transformers Protection for
SEL-487E and Beckwith M-3311A Relay
Rev. 3
OSC-11581
U1/2/3, Keowee EPS and 100kV APS Voltage Adequacy
Analyses
Rev. 1
OSC-2408
Determine the design parameters to adequately ventilate the
instrument air compressor in the Turbine Building
Rev. 0
OSC-3189
BWST Level Uncertainty
Rev. 8
OSC-4276
Oconee 125 Vdc Vital Instrumentation and Control Voltage
Adequacy
Rev. 13
OSC-4281
System Condition Review for LPI Valves
Rev. 18
OSC-4300
(ELEX) Protective Relay Settings
Rev. 38
OSC-5674
Generic Letter 89-10 Calculation for Unit 1 Gate and Globe
Rev. 38
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Valves
OSC-5879
Evaluation of EPRI MOV Methodology for 1LP-002
Rev. 4
OSC-5930
600/208 Vac Essential Auxiliary Power System
Rev. 15
OSC-6587
25 VDC Vital Instrumentation and Control Load Profile,
Battery Sizing and Voltage Analysis
Rev. 7
OSC-7167
Qualified Life Analysis for Limitorque Motor Operated Valves Rev. 5
OSC-7371.01
GL 96-06 Water Hammer Operability Evaluation: Operability
Criteria for Evaluation of Piping, Components and Pipe
Supports/Restraints (Type IV)
Rev. D2
OSC-7561
Differential Pressure Calculations for Valves FDW-0315 and
FDW-0316
Rev. 000
OSC-8113
25 VDC Vital Instrumentation and Control Load profile,
Battery Sizing, and Voltage Analysis
Rev. 0
OSC-8941
Power Conversion Systems (CCW, C, FDW, MS)
Rev. 0
OSC-9239
JOG Classification for Oconee's GL 96-05 MOV Population
Rev. 6
OSC-9610
Evaluation of LPI, CF, RBS & HPI Systems for Generic Letter 2008-01
Rev. 2
OSC-9855
LPI Drop Line Pressure Transient Analyses
Rev. 0
OSC-9855
LPI Drop Line Pressure Transient Analyses
Rev. 0
Corrective Action
Documents
01546807
01709578
01794387
01808457
01816298
01822353
01829206
01864306
01864324
01905117
01905946
01905980
2055781
2055781
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2114967
2119055
2142563
2154009
219546
226564
261444
297905
2304474
2306767
2307601
2310958
2337450
2341043
2341080
2342932
Corrective Action
Documents
Resulting from
Inspection
2341473
ISA Document Revision Incorrect in OSC-11071
2342913
NRC DBAI, 1LP-2 Max DP to Open
2342914
NRC DBAI, LP-17/LP-18 Capability to Open Under Max DP
2342932
NRC DBAI LPI Operation During HI DP from Check Valve
Leakage
2342941
Missing Extension Due Date for AR
2343201
Revision Needed to Clarify OSC-4281 LPI System
Conditions
2343368
Thermal Conduction Impact on Actuator Temperature
2343569
SSF RCMUP Contactors and MCC PM Procedure
2343949
Breaker Close Coil DC Voltage Evaluation
2343959
Review of Previous Corrective Actions
2344570
TS 3.4.14 Allowed Leakage Not Evaluated
2344570
NRC DBAI, TS 3.4.14 Allowed Leakage not Evaluated
2344805
20 NRC DBAI: Inadequate Limitorque Documentation
OSC-7161
2344864
Discovered Air Leak Near 2FDW-316
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2344871
OSC-4281 Does Not Provide Bounding Parameters for 1LP-
2344877
Housekeeping Items Identified
2346192
Question on Step Sequence for Alt Boron Dilution.
Drawings
0-0702
One Line Diagram, 6900 & 4160 STA Auxiliary Sys
Rev. 39
O-0703-K
One Line Diagram - 600V & 208V Essential Motor Control
Aux Pwr Sys SSF
Rev. 81
O-1422M-034-01
Instrument Detail Emergency Feedwater Control Valve
Rev. 1
O-702-A
6900 & 4160V Auxiliary System
Rev. 38
O-703-K
One Line Diagram - 600V & 208V Essential Motor Control
Aux Pwr Sys SSF
Rev. 81
OFD-100A-1.5
Flow Diagram of Reactor Coolant System, 1. Control Rod
Drive Venting Sys., 2. Center Control Rod Drive Gas
Sampling
Rev. 4
OFD-100A-3.5
Flow Diagram of Reactor Coolant Sys. 1. Control Rod Drive
Venting Sys.
Rev. 3
OFD-102A-01-02
Flow System Diagram of Low Pressure Injection System
(LPI Pump Discharge)
Rev. 61
OFD-102A-01-03
Flow Diagram of Low Pressure Injection System (Core
Flood)
Rev. 31
OFD-102A-1.1
Flow Diagram of Low Pressure Injection System Borated
Water Supply & LPI Pump Suction
Rev. 71
OFD-137B-1.1
Flow Diagram of Instrument Air System (Air Compressors,
After Coolers, Receivers, Air Dryers)
Rev. 27
OFD-137B-1.2
Flow Diagram of Instrument Air System (Layout of Major
Rev. 29
OFD-137B-1.3
Flow Diagram of Instrument Air System Auxiliary Building
Receiver Tanks and Instrument Air Headers
Rev. 11
OFD-137B-1.4
Flow Diagram of Instrument Air Accumulator Supply to Main
and Start-up Feedwater Control Valves
Rev. 1
OFD-137B-2.4
Flow Diagram of Instrument Air Accumulator Supply to Main
and Start-up Feedwater Control Valves
Rev. 0
OFD-137B-3.4
Flow Diagram of Instrument Air Accumulator Supply to Main
Rev. 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
and Start-up Feedwater Control Valves
OFD-144A-1.3
Flow Diagram of Component Cooling System (Control Rod
Drive Service Structure & Filters)
Rev. 10
OFD-144A-2.3
Flow Diagram of Component Cooling System (Control Rod
Drive Service Structure & Filters)
Rev. 10
OFD-144A-3.3
Flow Diagram of Component Cooling System (Control Rod
Drive Service Structure & Filters)
Rev. 10
OM 245.--
2055.001
DMV-2158 1/53/040 and 2/53/040 O/L Dwg for 12"
Walworth Gate Valve
Rev. 2
ONTC-1-124A-
0005-001
Oconee Nuclear Station Unit 1 LPSW Pump Minimum Flow
Line Test Acceptance Criteria
Rev. 0
Engineering
Changes
0000112329
Install New Unit 2 LPSW Supply to the MDEFWP Motor
Coolers and Separate It
007
96548
U2 Main Power System Protective Relay Upgrade
Rev. 000
Actuator Change for 1LP-2 to Increase Stroke Time
Rev. 1
Unit 3 CC Pipe Support Modification Per O-12-6670 and O-
2-6673 (OBDN)
Rev. 002
Reduce Design Temp for CC on Units 1, 2, and 3
Rev. 0
Re-Route Unit 1 LPSW Supply to the MDEFWPS
Rev. 005
Provide Cooling to the PIAC Control Cabinet IACCP1
Rev. 000
Keowee Main Step-up (KMSU) Transformer Replacement
Rev. 24
Replace the SSF RC Make-up Pump Motor With a New
Motor
Rev. 5
Miscellaneous
B01019
Qualification Type Test Report of Multi-Point Terminal Strips
for Use in Limitorque Valve Actuators for PWR Service
07/01/1982
B0212
Nuclear Power Station Qualification Type Test Report
Limitorque Valve Actuators with Type LR Motor for
04/10/1985
DBD-OSS-
254.00-00-1028
Design Requirement for Inter-system Leakage
Rev. 60
DCP-
1381.05000049,
Environmental Qualification (EQ) Evaluation of Limitorque
MOV Actuator SB Inside and Outside Containment
Rev. 1
Modify Three Pipe Supports on Unit 3 HPI Injection Due to
Thermal Stratification; 51A-0-2479A-H2D, 51A-0-2479A-
Rev. 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
H13A, and 51A-0-2479A-H16A
EQMM-1393.01-
A02-00
Environmental Qualification Maintenance Manual Equipment
Type: Actuator - Manufacturer Limitorque - Model/Series
SMB/SBD/SB Inside & Outside Containment
Rev. 18
KM 301.--
0010.001
I/B - (Viewable) G.E. Power Transformer
Rev. 15
KM 301.--
0059.001
Single Failure Analysis FMEA for Keowee Transformer
(RAI311531)
Rev. 0
KM 301.--
0060.001
Keowee Main Step-Up Transformer ABB Factory
Acceptance Test Report
Rev. 1
KM 401.--
0058.001
FMEA for Keowee Transformer (RAI311531)
Rev. 0
Metallurgic
Services File #
6033
ONS-2LP-196 Bellows
2/11/2020
NSM ON-33093
U-3, LPI Positive Cross Connect Modification
07/22/2003
OM 302.-
0105.001
ABB HK Switchgear Instruction Manual
Rev. D10
OM 322.-
21.001
SEL-487-E-3, E-4 Relay Current Differential and Voltage
Protection
09/15/2015
OM-245-0979.001 Limitorque Valve Actuator Qualification for Nuclear Power
Station Service Report B0058
09/25/2012
On-19-0032
Replace GR-15 Relays
09/11/2019
ONS-2015-058
TIA 2014-05, Potential Un-analyzed Condition Associated
with Emergency power System
05/11/2015
OS.813.20
Memorandum-Order for Modification of Licenses Concerning
Primary Coolant System Pressure Isolation Valves
04/20/1981
OSS-0243.00-00-
0001
(MECH) Piping Installation Specification
Rev. 033
OSS-0254.00-00-
28
(Mech) Design Basis Spec for the Low-Pressure Injection
and Core Flood System (LPI)
Rev. 60
OSS-0254.00-00-
2000
Design Basis Specification doe the 4 KV Essential Auxiliary
Power System
Rev. 24
OSS-0254.00-00-
Design Basis Spec for the Oconee Definition of QA
Rev. 11
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21
Condition 1
PT-1, 2, 3-A-
0150-015D
Design Bases Objectives RCS to LPI PIVs
2/11/2008
PT-2A-0152-013
Low Pressure SW System Valve Stroke Test
2/06/2020
PT-2A-0251-077
LPSW Water Hammer Protection System Valve and Air
Accumulator Test
2/01/2019
PT-2A-0251-078
LPSW Water Hammer Protection System and Valve and Air
Accumulator Test
Completed
11/30/2019
to 12/1/2019
ST3250
Transformer Station Health Report
08/05/2020
TR-1002847
EPRI Report: Updated Guidance for Evaluating Thrust
Requirements for Gate Valves with Stainless Steel Guides
06/01/2001
TR-144
Oconee Emergency Power 5HK Switchgear Test
08/10/95
Procedures
AD-EG-ALL-1107
Quality Classifications
Rev. 5
AD-EG-ALL-1117
Design Analyses and Calculations
Rev. 1
AD-EG-ALL-1612
Environmental Qualification (EQ) Program
Rev. 6
AD-EG-ALL-1903
Cyber Security Critical Systems and Critical Digital Assets
Identification and Assessment
Rev. 5
AD-OP-ALL-1000
Conduct of Operations
Rev. 17
AD-OP-ALL-1001
Conduct of Abnormal Operations
Rev. 3
AD-OP-ONS-
0001
ONS Operations Administrative Commitments
Rev. 001
AD-PI-ALL-0100
Corrective Action Program
Rev. 23
AP/1/A/1700/022
Loss of Instrument Air
Rev. 30
AP/3/A/1700/003
Boron Dilution
Rev. 15
AP/3/A/1700/011
Recovery from Loss of Power
Rev. 52
AP/3/A/1700/020
Loss of Component Cooling
Rev. 13
AP/3/A/1700/039
Unintentional Boration
Rev. 2
DPS-1205.19-00-
0002
Guideline for Performing Motor Operated Valve Reviews
and Calculations
Rev. 4
EDM 101
Engineering Calculations/Analyses
Rev. 16
EM 5.1
Engineering Emergency Response Plan
Rev. 37
EP/1/A/1800/001
Rev. 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0I
IP/0/A/3001/001
Limitorque Preventative Maintenance
Rev. 96
IP/0/A/3001/011 L
Diagnostic Testing Motor Operated Valves Using
Teledyne/Quiklook System
Rev. 7
MP/0/A/1200/146
B
Valve - Ball - Three Piece - Air Operated - Disassembly,
Repair, and Reassembly
Rev. 13
MP/0/A/1210/010
A
Valve Stem Lubrication for Motor Operated Valves
Rev. 8
NSD-121
Electromagnetic Interference On Plant Equipment
Rev. 2
NSD-806
Digital System Quality Program
Rev. 5
OP/0/A/1106/019
Keowee Hydro At Oconee
Rev. 108
OP/0/A/1106/027
Instrument Air System
Rev. 124
OP/1/A/1104/004
Low Pressure Injection System
Rev. 156
OP/1/A/1104/010
Low Pressure Service Water
Rev. 151
OP/3/A/1107/002
Duke Energy Oconee Nuclear Station Normal Power
Rev. 071
PT-1A-0150-015D Inter-system LOCA Leak Test
Rev. 47
PT/3/A/0610/28 A
Main Feeder Bus 2 Lockout Relay Test
Rev. 3
Work Orders
2139658,
2161814,
2161815,
20043385-01,
20052397-01,
20171404-14,
20185846-01,
20198416-01,
287412-01,
293942-14,
20304469-01,
20304469-01,
20328085-14,
20330007-01,
20355231-14,
20371279-14,
20390877-14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2160810
2160810
TB Basement near valves LPSW-27 and LPSW-30 (TB, N of
Col. H-25, Elev. 775+15), also on the 3" piping
downstream of LPSW-27 and -30 (TB, N of Col. H-28, Elev.
775+15)
08/24/2015
20050014
20050015
20050015
20174777
20181184
20303828
20303829
20387447
20401703