IR 05000269/2021004

Integrated Inspection Report 05000269/2021004 and 05000270/2021004 and 05000287/2021004 and Apparent Violation

ML22040A188
Person / Time
Site:	Oconee
Issue date:	02/14/2022
From:	Eric Stamm Division Reactor Projects II
To:	Snider S Duke Energy Carolinas
References
IR 2021004
Download: ML22040A188 (30)

Text

February 14, 2022

SUBJECT:

OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2021004 AND 05000270/2021004 AND 05000287/2021004 AND APPARENT VIOLATION

Dear Mr. Snider:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On February 9, 2022, the NRC inspectors discussed th e results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclos ed report.

Section 71111.20 o f the enclosed report discusses a finding with an associated apparent violation for which the NRC has no t ye t reached a preliminary significance determination. Th is finding involved an apparent failure to perform an adequate technical review of the procedure revision request for licensee procedure OP/0/A /1107/011 F, Revision 19, Sharing Startup Transformers Between Units, which led to simultaneous lockouts on startup transformers, CT -1 and CT-2.

We intend to issue our final safety significance determination and enforcement decision, in writing, within 90 days from the date of this letter. The NRCs significance determination process (SDP) is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. We ask that you promptly provide any relevant information that you would like us to consider in making our determination. We are currently evaluating the significance of this finding and will notify you in a separate correspondence once we have completed our preliminary significance review. You will be given an addition al opportunity to provide additional information prior to our final significance determination unless our review concludes that the finding has very low safety significance (i.e., Green).

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. If you contest the violations or th e 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 R esident 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 th e Regional Administrator, Region II; and the NRC Resident I nspector at Oconee Nuclear Station.

This letter, its enclosure, and your response (if any) will be m ade available for public inspection and copying at http://www.nrc.gov/reading-rm /a dam s.h tm l 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/

Eric J. Stamm, Chief Reactor Projects Br anch 1 Division of Reactor Projects

Docket Nos. 05000269 and 05000270 and 05000287 License Nos. DPR-38 and DPR-47 and DPR-55

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000269, 05000270 and 05000287

License Numbers: DPR-38, DPR-47 and DPR-55

Report Numbers: 05000269/2021004, 05000270/2021004 and 05000287/2021004

Enterprise Identifier: I-2021- 004-0012

Licensee: Duke Energy Carolinas, LLC

Facility: Oconee Nuclear Station

Location: Seneca, South Carolina

Inspection Dates: October 1, 2021 to December 31, 2021

Inspectors: J. Nadel, Senior Resident Inspector A. Ruh, Resident Inspector N. Smalley, Resident Inspector N. Peterka, Fuel Facility Inspector M. Meeks, Senior Operations Engineer P. Cooper, Senior Reactor Inspector R. Patterson, Senior Reactor Inspector T. Su, Reactor Inspector J. Diaz-Velez, Senior Health Physicist J. Rivera, Health Physicist A. Rosebrook, Senior Reactor Analyst

Approved By: Eric J. Stamm, Chief Reactor Projects Br anch 1 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees performance by conducting an integrated inspection at Oconee Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Assess the Risk Increase from Operations in Cold Mid -loop Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.13 Systems NCV 05000270/2021004-01 Management Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(4) when the licensee failed to adequately assess th e risk associated with lowering the reactor coolant system (RCS) level to reduced inventory, also known as mid-loop, during a Unit 2 refueling outage on November 25, 2021.

Failure to Use a Procedure Appropriate to the Circumstances While Changing Electrical Lineup of Startup Transformer CT-2 Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Pending [H.12] - Avoid 71111.20 AV 05000269,05000270/2021004-02 Complacency Open A finding with its safety significance as yet to be determined (pending) and an associated apparent violation (AV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified when the licensee failed to use a procedure appropriate to the circumstances for an activity affecting quality. Specifically, the procedure for sharing startup transformers between units was inadequate, which led to simultaneous lockouts on CT -1 and CT-2 startup transformers while starting the 2B2 reactor coolant pump (RCP) motor for an uncoupled run.

Prompt Corrective Actions Not Taken for Out-of-tolerance As-Found Data Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71152 Systems NCV 05000269,05000270,05000287/ Procedure 2021004-03 Adherence Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Corrective Action, for the licensees failure to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Specifically, the licensee failed to promptly identify and correct the out of allowable range values documented in work orders 20376561 and 20376768. The licensee performed th e work orders to implement requirements as stated in licensee preventive maintenance procedure IP/0/A/3011/016, Motor Control Center, Distribution Center, revision 14.

Additional Tracking Items

Type Issue Num ber Title Report Section Status NOV 05000270,05000287, Inadequate Corrective 71152 Closed 05000269/2020010- 02 Action - Control Voltage for 4160 Breakers Closing Coil and 480V MCC control Circuits were not Assured LER 05000270/2021001 -00 2B Motor Driven Emergency 71153 Closed Feedwater Pump Past Inoperability Resulted In Condition Prohibited by Technical Specifications

PLANT STATUS

Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.

Unit 2 began the inspection period at or near 100 percent RTP.

On October 21, 2021, the unit began lowering power for coast down to the refueling outage.

On November 12, 2021, the power coast down had reached 88 percent RTP and the unit was shut down for the scheduled refueling outage.

The unit was taken critical on December 6, 2021, and proceeded to shut down to M ode 3 on December 7, 2021, after completing zero power physics testing in order to address issues with control rods.

The unit was taken critical again later on December 7, 2021, and began raising power, reaching 73 percent on December 8, 2021.

On Decem be r 10, 2021, the unit tripped automatically from 73 percent power due to an invalid actuation of the reactor protection system due to a signal spike on a power range nuclear instrument. The unit was taken critical again on December 12, 2021, and began rais ing power, reaching 100 percent RTP on December 13, 2021.

The unit remained at or near 100 percent RTP for the remainder of the 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 websi te a t http://www.nrc.gov/reading -

rm /doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requireme nts most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light -Water Reactor Inspection Program - Operations Phase.

The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs.

The inspectors reviewed selected procedures and records, observed activities, and interview ed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards

71111.04 - Equipm ent Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Emergency power systems while both Keowee hydro units were out of service for repair on October 20, 2021

(2) Reactor coolant system (RCS) level instrumentation during lowered inventory operations, including 2LT-5A/B, permanently installed hot leg level instrumentation, hot leg and cold leg temporary ultrasonic level instruments, and backup steam generator tygon tubing manometers on November 15, 2021

(3) Unit 1 and 2 low pressure service water system while protected during th e Unit 2 outage on November 16, 2021

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

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 low pressure injection ( LPI) sy st em in decay heat removal mode during reduced inventory operations and fuel movement on November 14, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Sam ples)

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

(1) Fire zone 77: Unit 3 auxiliary building 200 level hallway on October 6, 2021

(2) Fire zone 103: Unit 2 east penetration room on November 4, 2021

(3) Fire zone 95: Unit 1 equipment room on November 15, 2021

(4) Fire zone 33: Unit 2 4160V switchgear on November 15, 2021

(5) Fire zone 123: Unit 2 containment on November 29, 2021

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) Unit 2 auxiliary building east penetration room

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protecti on in:

(1) Protected service water ductbank inspection, work order (WO) 20437679

===71111.08P - Inservice Inspection Activities (PWR)

PWR Inservice Inspection Activities Sample (IP Section 03.01)===

(1) The inspectors evaluated pressurized water reactor non -destructive testing by reviewing the following examinations from October 11, to October 28, 2021:

Ultrasonic Examination a.

Core Barrel Bolts, UCB-001 - UCB-120 (reviewed)

Phased Array Ultrasonic Exam ination a.

42.75" RCS Hot Leg, R TE Pad No. A01, ASME Class 1 (reviewed)

Visual Examination a.

Bottom Mounted Instrument Nozzle Penetrations, 2-RPV-BMI-NOZZLES (All), ASME Class 1 (reviewed)

4. Eddy Current Testing (ECT)

a.

Steam Generator (SG) 2A, Tube R138C58, ASME Class 1 (observed)b.

SG 2B, Tube R138C33 and R127C2, ASME Class 1 (observed)

The inspectors also evaluated the licensees boric acid control program performance.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) Annual Review of Licensee Requalification Examination Results: On April 02, 2021, the facility licensee completed the comprehensive biennial requalification written examinations and the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), Requalification Requirements, of the NRCs Operators Licenses." During the week of December 13, 2021, the inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licens ed Operator Requalification Program. These results were compared to the thresholds established in Section 03.03, Requalification Examination Results, of IP 71111.11.

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 Unit 2 shutdown for refueling outage on November 12 and 13, 2021.

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

(1) The inspectors observed and evaluated simulator just -in-time training for unit shutdown casualties on November 10, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) Unit 1 turbine bypass valve 1MS -19 came open at 100% power, causing 3MWe transient on September 10, 2021 (nuclear condition reports ( NCRs) 2397266,

===2397267, 2401887, 2404422, 2404752)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Sam ples)

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) Units 1, 2, and 3 elevated green risk on October 20 to 21, 2021, due to both Keowee hydrostation units out of service for emergent repair work on Keowee Unit 1

(2) Unit 2 protected equipment walkdown during yellow risk on November 14, 2021, due to reduced inventory operations

(3) Unit 2 yellow risk on November 15 and 16, 2021, during the high risk plant operating state due to lowered RCS inventory and high decay heat

(4) Unit 2 yellow risk on November 25, 2021, during operation at reduced inventory (cold mid-loop) in Mode 5

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01)===

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

(1) NCR 02403963, steam leak from Unit 1 main steam #2 safety relief valve

(2) NCR 02405392, 2A steam generator pedestal studs covered in boric acid

(3) NCRs 2405474, 2405634, 2405679, 2405898, 2406086, Alloy 600 weld remediation identified unacceptable flaws in the RCS base metal prior to installation of the weld pad

(4) NCRs 2405875 and 2407202, 3B low pressure service water pump acceptance criteria being outside a nominal 2 percent flow band and consideration of electrical frequency effects

(5) NCR 2405877, internal pits in Unit 2 safety related condenser circulating water intake piping near manway 2B1

(6) NCR 2406476, 2RC -219 did not meet 0.15 coefficient of friction acceptance criterion during diagnostic testing

(7) NCR 2406500, boric acid corrosion found on the 2B1 and 2A2 reactor coolant pump main flange studs

(8) NCR 2408618, operation in Mode 1 with two axial power shaping rods uncoupled from control rod drive mechanisms

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) Nuclear station modification ON-53015, Lee undervoltage and underfrequency permissive modification

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Sam ples)

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

(1) PT/0/A/0620/009, Keowee Hydro Operation and OP/0/A/2000/041, KHS -Modes of Operation following relay replacements and preventive maintenance on Keowee Hydro Unit 1 on October 20 and 21, 2021

(2) PT/2/A/0201/005, High Point Vent Flow Test, following internal repairs to 2RC-155/156, steam generator vent valves, on December 6, 2021

(3) PT/2/A/0160/002, Reactor Building Cooling Unit Air Flow Test after fan replaceme nt, WO 20450716

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated refueling outage U2R30 activities from November 12, 2021, to Decem ber 7, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) PT/3/A/0251/001, Low Pressure Service Water Pump Test, on November 5, 2021

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

(1) PT/2/A/0151/019, Penetration 19 Leak Rate Test, on November 26, 2021

71114.06 - Drill Evaluation

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

(1) Emergency preparedness training tabletop drill 21TT-4 on October 18,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant -related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Sam p les)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA)

(2) Workers exiting the RCA during Unit 2 refueling outage

(3) Workers exiting Unit 2 containment during Unit 2 refueling outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluat ed the licensee's control of radiological hazards for the following radiological work:

(1) Radiation Work Permit (RWP) no. 2158, Unit 2 Reactor Building Remove and Replace Reactor Vessel Head, Rev. 18

(2) RWP no. 2216, Unit 2 Reactor Building "A" and "B" Steam Generators Setup, Remove, and Replace Primary Manway and Handhole Covers, Rev. 30

(3) RWP no. 2121, Unit 2 Reactor Building Replace Valves 2HP3 and 2HP4 and Associated Activities, Rev. 1

High Radiation Area and Very High Radiation Area Control s (IP Section 03.05) (4 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Unit 2 turbine building radioactive material area on the 5th floor, 822 foot elevation

(2) Radwaste Room 111, Liquid Waste Feed Pump "A"

(3) Radwaste Room 112, Liquid Waste Feed Pump "B"

(4) Units 1, 2, and 3 auxiliary building 200 foot elevation corridor

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Sectio n 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (5 S am p les)

The inspectors evaluated the licensees radiological work planning by reviewing the following:

(1) Oconee Nuclear Station O1R31 RP Outage Report - Duration 10/17/2020-11/18/2020

(2) Oconee Nuclear Station O3R30 RP Outage Report - Duration 04/10/2020 - 05/9/2020

(3) Oconee Nuclear Station Long Range As Low as Reasonably Achievable (ALARA)

Plan - 2021

(4) ALARA Plan Num ber 2020-ONS-1-O-001, Alloy 600 Repairs (completed package including in progress and post job reviews)

(5) ALARA Plan Num ber 2020-ONS-1-O-003, SSF-Letdown Line Replacement (completed package including in progress and post job reviews)

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (4 Sam ples)

The inspectors evaluated dose estimates and exposure tracking for the following activities:

(1) Daily Dose Reports from 11/15 to 11/19/2021 (outage daily dose accrual report, individual ALARA Plan dose accrual, significant radiological work complete/upcoming,

etc.)

(2) ALARA Plan Num ber 2021-ONS-2-O-002, Alloy 600 Small Nozzle Repair, Revision 0

(3) ALARA Plan Num ber 2021-ONS-2-O-003, 2HP - 3&4 Replacement, Revision 0 (Letdown cooler outlet isolation valve and motor operator replacement)

(4) ALARA Plan Number 2021-ONS-2-O-006, lncore Instrumentation {High Radiological Risk, IER L2-11-41 (Highly Radioactive In-Core Components), Risk Code (HO)}

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls.

(1) The inspectors reviewed ALARA and radiological work control requirements contained in the following RWPs:

RWP # 2022 Rev: 08, U2 RX BLDG - Alloy 600 - Replacement / Repairs and Associated Activities

RWP # 2026 Rev: 07, U2 RX BLDG - Annulus Inspections and Associated Work

RWP # 2121 Rev: 01, U2 RX BLDG - Replace Valves 2HP3 / 2HP4 and Associated Activities

(2) The inspectors reviewed the following ALARA Plans:

b.

ALARA Plan Num ber 2021-ONS-2-O-002, Alloy 600 Small Nozzle Repair c.

ALARA Plan Num ber 2021-ONS-2-O-003, 2HP - 3&4 Replacement d. ALARA Plan Num ber 2021-ONS-2-O-001, Annulus Inspections

(3) The inspectors reviewed Total Effective Dose Equivalent (TEDE)-AL A RA evaluations for the following work activities:

b.

TEDE-ALARA Screening for PAPRs issued for Alloy 600 work, RWP 2022 Task 2, on 11/16/2021.

c.

TEDE-ALARA Screening for PAPRs issued for 2HP -3 & 4 welding activities, RWP 2121 Task 3, on 11/18/2021.

(4) The inspectors reviewed the following temporary shielding installation packages:

b.

Serial Number: U2RB -12, RO Incore Trench, 10/4/2021 c. Serial Number: U2RB-04, RO Nozzles, 10/4/2021

Radiation Worker Performance (IP Section 03.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance during:

(1) The inspectors evaluated radiation worker and radiation protection technician performance during work activities.

a.

Reactor head lift b. 2HP-3 & 4 valve work

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Sam ples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Units 1 and 2 control room ventilation system

(2) Unit 3 control room ventilation system

Temporary Ventilation Systems (IP Section 03.02) (2 Sam ples)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Portable HEPA SG2010

(2) Portable HEPA SG2012

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self -contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (3 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Internal dose assessment #20-003 was reviewed

(2) Internal dose assessment #20-015 was reviewed

(3) Internal dose assessment #20-021 was reviewed

Special Dosimetric Situations (IP Section 03.04) (3 Sam ples)

The inspectors evaluated the following special dosimetric situations:

(1) One declared pregnant worker record was reviewed

(2) One EDEX dose assessment for #V6077699 was reviewed

(3) One EDEX dose assessment for #V6077856 was reviewed

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (6 Sam ples)

The inspectors evaluated the following radiation detection instrum entation during plant walkdowns:

(1) Installed plant radiation monitors (material condition and configuration):

a.

1RIA-1 - Units 1 and 2 Control Room ARM b.

2RIA-43 through 46 - Unit 2 Vent Monitor, incl. High Range c.

1RIA-11 - Unit 1 and 2 Auxiliary Building Corridor ARM d.

RIA-33 - Liquid Waste Disposal Monitor (Radwaste Building)e.

RIA-45 - Radwaste Facility Vent Monitor f.

Units 1 and 2 RIA-50 - Component Cooling Water Liquid Monitor

(2) Observed routine source response checks of the following portable radiation dose rate survey Instruments:

a.

EnRad # 07228 (Ludlum 19)b.

EnRad # 02526 (Ludlum 3 - m R/h r)c.

EnRad # 13377 (Ludlum 9-3)d.

EnRad # 03847 (AMP -100)e.

EnRad # 07509 (Telepole)

(3) Observed routine source response checks of the following sem i-fixed personnel contamination monitors:

a.

EnRad # 03864 (Argos)b.

EnRad # 13549 (GEM-5)

(4) Observed routine source response checks of the following semi -fixed tool/equipment contamination monitor:

a.

EnRad # 03868 (Cronos)

(5) Observed routine source response checks of the following portable neutron radiation dose rate survey Instruments:

a.

EnRad # 07511 (Ludlum 12-4 Remball)

(6) Observed routine source response checks of the following portable contamination survey instruments:

a.

EnRad # 07982 (Ludlum 177)b.

EnRad # 12966 (Ludlum 3 - cpm )

Calibration and Testing Program (IP Section 03.02) (15 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instrum ents:

(1) 2021 Whole Body Counter Calibration (per AD-RP-ALL-7007), WBC ID #: ONFSF1, 06/23/2021

(2) Tri-Carb Liquid Scintillation System Calibration Verification, Detector Serial #:

SGTC27140350, November 2021

(3) Gamma Spectroscopy system calibration package, Detector Serial #: 9661, Detector Shield #: 3, 09/16/2021

(4) Ludlum Model 9-3 Ion Chamber Survey Meter, Serial Number (S/N) 308363, EnRad ID # 07661 - Calibrated 08/26/2020 & 07/08/2021

(5) Ludlum Model 9-3 Ion Chamber Survey Meter, S/N 288795, EnRad ID # 11899 -

Calibrated 03/27/2020 & 04/01/2021

(6) ROTEM Ind. Model AMP-100, S/N 5008-132, EnRad ID # 03847, Calibrated 02/12/2020 & 07/21/2021

(7) ROTEM Ind. Model AMP-100, S/N 5005-161, EnRad ID # 11217, Calibrated 02/12/2020 & 07/28/2021

(8) Ludlum Model 9-3 Ion Chamber Survey Meter, S/N 288562, EnRad ID # 12089 -

Calibrated 03/06/2020 & 07/19/2021

(9) ROTEM Ind. Model Telepole, S/N 6604-132, EnRad ID # 02093, Calibrated 06/01/2020 & 08/24/2021

(10) ROTEM Ind. Model Telepole, S/N 0914-123, EnRad ID # 07596, Calibrated 08/22/2019 & 03/31/2021

(11) Canberra Model GEM5 Gamma Portal Monitor, S/N 2007 -174-GE0500G, EnRad ID # 13550 - Calibrated 12/07/2020 & 10/31/2021

(12) Canberra Model Argos-5ABZ Contam ination Monitor, S/N 1510-166-AR050AB, EnRad ID # 07806 - Calibrated 08/10/2020 & 08/03/2021

(13) RADOS Model Fibre XL Hand & Foot Contamination Monitor, S/N 373, EnRad ID # 12387 - Calibrated 03/03/2020 & 02/03/2021

(14) Canberra Model Cronos-1 Tool & Equipment Monitor, S/N 1312 -360, EnRad ID # 03869 - Calibrated 05/20/2020

(15) Canberra Model Cronos-4 Tool & Equipment Monitor, S/N 1412 -325-cr0400g, EnRad ID # 03867 - Calibrated 08/10/2020 & 08/03/2021

Effluent Monitori ng Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Unit 2 RIA-57 and 58, Containment High Range (Post-Accident) Radiation Calibration Package, WO 20388011, 10/14/2021

(2) Unit 3 RIA-46, Main Stack Vent High Range Gaseous Radiation Monitor Calibration Package, WO 20146730, 08/15/2017 and WO 20275115, 2/18/2019

(3) RIA-0033, Liquid Effluent Release Radiation Monitor, WO 20301321, 12/17/2019 and WO 20372764, 03/11/2021

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) (3 S am p les)

(1) Unit 1 (July 1, 2020 - September 30, 2021)

(2) Unit 2 (July 1, 2020 - September 30, 2021)

(3) Unit 3 (July 1, 2020 - September 30, 2021)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===

(1) October 1, 2020 through November 29, 2021

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) July 1, 2020 through November 29, 2021

71152 - Problem Identification and Resolution (PI&R)

Annual Follow -up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) CT-1 and CT-2 lockout event on November 27, 2021

(2) The team reviewed Oconees response to Notice of Violation (NOV), EA -2021-004, and various documents associated with the actions taken by the licensee including calculations, breaker qualification, preventive action procedures, design changes and corrective action documents. With the exception of an NCV associated with the lack of promptness in addressing the out -of-tolerance as -found data as documented in Action Request (AR) 02411953, the team did not identify any additional more-th an-minor deficiencies associated with the licensees corrective action taken. The NCV was not directly related to the issues addressed in the NOV and may be addressed through the licensees CAP independent of the NOV closure. The NOV is closed.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated a Unit 2 reactor trip at 0049 and the licensees response on Decem ber 10, 2021.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000270/2021-001-00, 2B Motor Driven Emergency Feedwater Pump Past Inoperability Resulted in Condition Prohibited by Technical Specifications (ADAMS Accession No. ML21277A218). The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2021003 (ADAMS Accession No. ML21301A125) under Inspection Results Section

INSPECTION RESULTS

Failure to Adequately Assess the Risk Increase from Operations in Cold Mid -lo op Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.3] - Change 71111.13 Systems NCV 05000270/2021004 - 01 Management Open/Closed The inspectors identified a Green finding and associated non-cited v iolation (NCV) of 10 CFR 50.65(a)(4) when the licensee failed to adequately assess th e risk associated with lowering the reactor coolant system (RCS) level to reduced inventory, also known a s m id-loop, during a Unit 2 refueling outage on November 25, 2021.

Description:

On November 25, 2021, Oconee Unit 2 was in Mode 6 of a refueling outage and the core had been reloaded the previous day.

The licensee planned to drain the RCS to below 50 inches, an operational state defined as reduced inventory, to remove steam generator nozzle dams.

The planned evolution would ultimately drain the RCS with fuel present in the reactor to a level below the top of the hot leg piping, i.e., less than 18 inches, which is defined as cold mid-loop in the case where the draining occurs after core reload. This evolution had been pre-planned and identified as an infrequently performed test or evolution (IPTE), which required an associated elevated risk acti vity plan (ERAP) and associated risk mitigating actions.

On the morning of November 25, 2021, the residents identified that the licensee had not performed, approved, issued, or communicated a defense-in-depth (DID) status sheet for the change in r isk color from Green to Yellow that occurred when the draining activity to reduced inventory had begun at 0651.

Narrative log entries identifying the color change, which are required by AD - OP-ALL- 0112, Operations Log Keeping and Chart Recorders, Revision 1,

were also not made.

No other significant operational issues were identified associated with the draining activity.

The residents did not identify issues with the implementation of the ERAP for the drain to cold mid-loop. However, it was clear that the or ganization, in general, was unaware of the risk change at the time it occurred.

The residents recognized that inadequate and untimely prior assessments of an increase in risk due to maintenance increases the likelihood of an error or risk management failure.

During periods of shutdown, the licensee manages and assesses risk through the requirements of AD - WC-ALL- 0420, Shutdown Risk Management, which partially implements the requirements of 10 CFR 50.65, Requirements for monitoring the effectiv eness of maintenance at nuclear power plants.

The most current DID status sheet on the morning of November 25, 2021, had been completed at 0400 and showed risk was Green because the RCS had not yet begun the draining activity to reduced inventory.

The res idents noted that AD-WC-ALL- 0420, Revision 7, step 5.2.2.e requires the licensee to document DID status at least once per shift and whenever overall risk color changes.

Upon being questioned by the inspectors, the licensee prepared and issued an updated DI D status sheet, backdated a log entry for the transition to y ellow risk and wrote an NCR.

The residents reviewed the outage DID status sheets from earlier in the outage and identified that the first yellow risk condition of the outage, which occurred duri ng the initial RCS drain to lowered inventory (reactor head flange level) on November 14, 2021, when the unit was in Mode 5, also was not adequately assessed for the increase in risk through the review, approval, issuance, and communication of an accurate DID status sheet prior to the planned activity.

It was noted that site specific procedure AD -WC-ONS-0420, ONS Shutdown Risk Management, Revision 1, has guidance that conflicts with step 5.2.2.e of the fleet procedure, AD-WC-ALL-0420. Specifically, AD-WC-ONS-0420, step 5.3.3.a, has an allowance where a new DID sheet is not required to be issued at the time the risk changes if the planned risk color change was previously included on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> look ahead column from an earlier DID sheet. The 12-hour look ahead is a projection of the risk condition over the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> based on the outage schedule at the time the DID status sheet is issued.

The inspectors concluded, for the above examples, that the 12-hour look ahead, combined with the lack of awareness and communication, did not constitute an adequate assessment of the risk increase. The licensee documented the conflicting procedural guidance in an NCR to determine appropriate corrective actions.

Corrective Actions: The licensee documented, reviewed, and issued an updated DID status sheet on November 25, 2021, and made a back -dated narrative log entry for the change in risk after being questioned by inspectors.

Corrective Action References: 2408452, 2411210

Performance Assessment:

Performance Deficiency: The licensees failure to perform a risk assessment when required by licensee procedure AD -WC-ALL-0420 was a performance deficiency.

Specifically, the licensee failed to adequately assess the risk associated with RCS draining activ ities on November 14, 2021, and November 25, 2021.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely aff ected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to perform an adequate risk assessment for a risk color change from green to yellow on two occasions on November 14, 2021, and Novem ber 25, 2021.

Significance: The inspectors assessed the significance of the finding using Appendix K, Maintenance Risk Assessment and Risk Management SDP.

Us in g flowchart 1, Assessment of Risk Deficit, inspectors are directed to determine the incremental core damage probability deficit (ICDPD). The senior risk analyst (SRA) conservatively used IMC 0609 Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, to determine the actual core damage frequency.

The SRA assumed the plant was shut down for eight days (first occurrence of the performance deficiency) and in POS - 2E, thus, time to boil for mid-loop was 20 minutes and time to core damage was 297 minutes from IMC 609, Appendix G, Attachment 2, table 8. Definitions and Characterizations of Time Windows from NUREG/CR -6144, Table 5.4-20, assumed a vented RCS (RCS temperature initially 140F).

The performance deficiency could contribute to the likelihood of a loss of level control (LOLC) while in mid -loop; therefore, Worksheet 2 SDP for a PWR Plant - Loss Level Control in POS 2 (RCS Vented) was used to determine the risk for this plant condition. Nominal operator and equipment credits were used for baseline and operator credit was adjusted down by one for feed because 20 minutes was available for diagnosis. The performance deficiency affected initiating event likelihood (IEL ) so the IEL for a LOLC event was changed from a nominal o f 2 (table 5) to 0 (table 1 most conservative assumption.). Event duration for a drain down is assumed to be 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Greater than three risk management actions (RMAs) were in place despite an adequate risk assessment not being performed. This CDF baselin e was 1.1E-6 events/yr and CDF actual was 1.1E -3 events/year (yr).

Thus ICDFD= 48 hour/8760 hour/yr x (1.1E -3 - 1.1E-6) = 5.97e-6. Using this value in flowchart 1 of Appendix K, the finding is characterized as Green since ICDPD was between 1E -5 and 1E -6 and three or more RMAs were in place.

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

Specifically, deficiencies in site specific procedure AD -WC-ONS-0420 were not recognized when conflicting procedural guidance in fleet procedure AD -WC-ALL-0420 was issued.

Enforcement:

Violation: 10 CFR 50.65(a)(4) requires, in part, that before performing maintenance activities (including but not limited to surveillance, post -maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

Contrary to the above, on Novem ber 14, 2021, and November 25, 2021, the licensee failed to adequately assess an increase in risk from green to yellow that resulted from maintenance associated with RCS draining activities.

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

Failure to Use a Procedure Appropriate to the Circumstances While Changing Electrical Lineup of Startup Transformer CT-2 Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Pending [H.12] - Avoid 71111.20 AV 05000269,05000270/2021004 - 02 Complacency Open A finding with its safety significance as yet to be determined (pending) and an associated apparent violation (AV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified when the licensee failed to use a procedure appropriate to the circumstances for an activity affecting quality. Specifically, the procedure for sharing startup transformers between units was inadequate, which led to simultaneous lockouts on CT - 1 and CT-2 startup transformers while starting the 2B2 reactor coolant pump (RCP) motor for an uncoupled run.

Description:

On November 27, 2021, the licensee was performing outage main tenance activities in preparation for Unit 2 startup following a refueling outage. At the time, Unit 1 was in Mode 1 at 100 percent power with electrical loads being powered from its own main transformer, 1T.

Unit 2 was in Mode 5 with loads being powered f rom its normal offsite power source, startup transformer CT-2. Unit 3 was in Mode 1 at 100 percent power and was unaffected by this event. While starting the 2B2 RCP for an uncoupled motor run, both Unit 1 and Unit 2 offsite power sources, CT -1 and CT-2, lost power. Unit 1 did not lose power since its electrical loads were being powered from its own main turbine transformer, 1T. Unit 2 lost power for approximately 31 seconds before regaining power from a different offsite power source, transformer CT-5. For Unit 2, this loss of offsite power (LOOP) caused a loss of decay heat removal (DHR) capability as well as a partial loss of spent fuel pool (SFP)cooling. Upon investigation, the cause of the loss of both offsite power sources was the activation of the lockout relays on each transformer. The licensee found that two switches in the startup transformer crossover scheme, switches B and F, were not in their expected positions. The licensee investigated the lockout relay activations and determined that the B transfer switch being in the incorrect position was the cause of the LOOP.

No reactor coolant system tem perature changes were noted during the short period of time where DHR wa s lost. Units 1 and 2 shared SFP temperature increased 9.4 degrees over 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> and 53 minutes before full SFP cooling could be procedurally restored.

In planning for future electrical lineup changes during the Unit 2 refueling outage, the licensee approved a procedure revision request (PRR) for the procedure to share startup transformers between units, OP/0/A/1107/011 F, Revision 19, in October 2021. This revision was specifically requested to incorporate steps to allow the operators to completely isolate CT -2 while either Unit 1 or Unit 3 supplied Unit 2 electrical loads fro m their own startup transformer, CT-1 or CT-3, respectively. The goal of this revision was to eliminate confusion associated with how to get from a state of Unit 2 startup transformer being cross -tied with either Unit 1 or Unit 3 to isolating CT-2 completely after swapping the Unit 2 main feeder bus power supplies to CT-5, an alternate offsite power source. The PRR was processed in accordance with Duke Energy fleet -wide procedure AD-DC-ALL-0201, Development and Maintenance of Controlled Procedure M anual Procedures, Revision 27. Part of this process includes requirements for technical reviews to be done to ensure that the procedure, with any changes or additions to it, is safe, technically accurate, achieves the intended purpose, and meets all stand ards and requirements for performance, as described in procedure section 5.9.2. However, this revision was improperly prepared and included an error which repositioned incorrect switches while restoring from Unit 2 sharing startup transformers with Unit 1. Specifically, in 4.2 (Unit 2 Sharing CT -1 Removal and Restoration of CT -2), step 2.2.1.G has the operator position the switches for sharing Unit 3 to normal, instead of Unit 1. This allowed transfer relay switches B and F to be left in the i ncorrect position, thus causing the subsequent transformer lockout and LOOP event.

There were at least th ree required review points in the PRR review process per AD -DC-ALL-0201 that could have caught this error, specifically the technical review in step 2, the cross -discipline review in step 3, and the validation review in step 11.

Additionally, it was pointed out by several personnel involved that the A, B, C component identification scheme of the transfer relay switches contributed to the error because the function of each switch and which units are affected is less obvious.

Corrective Actions: Operations staff identified the mispositioned switches and returned them to the required positions. The licensee executed another PRR to fix the error in procedure OP/0/A/1107/011 F, Revision 19. The licensee also initiated a Corporate Functional Area Manager Escalation concerning procedure review quality due to several recent additional occurrences of procedural technical errors not being detected during the procedure technical or validation reviews.

Corrective Action References: NCR 2406969, PRR 2406977, NCR 2408602

Performance Assessment:

Performance Deficiency: The licensees failure to perform an adequate technical review of the PRR fo r th e procedure, Sharing Startup Transformers Between Units, OP/0/A/1107/011 F, Revision 19, in accordance with procedure AD-DC-ALL-0201, Development and Maintenance of Controlled Procedure Manual Procedures, Revision 27, was a perform ance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihoo d of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Specifically, the failure to perform an adequate technical review caused a LOOP and subsequent loss of DHR and partial loss of SFP cooling while performing maintenance on 2B2 RCP on November 27, 2021.

Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP.

The finding could not be screened to Green and is pending an initial significance characterization.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools.

In this case, complacency through multiple levels of technical procedure review, a lack of recognition of the inherent risk associated with the transfer relay switches, and the failure to use adequate descriptive component identifications for the transfer switches all contributed to the event.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on November 27, 2021, the licensee failed to use a procedure appropriate to the circumstances for an activity affecting quality. Specifically, the procedure for sharing startup transformers between units, OP/0/A/1107/011 F, Revision 19, contained an error that specified the incorrect position for two transfer relay switches.

Enforcement Action: This violation is being treated as an apparent violation pending a final significance (enforcement) determination.

Prompt Corrective Actions Not Taken for Out-of-tolerance As-Found Data Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71152 Systems NCV Procedure 05000269,05000270,05000287/20210 Adherence 04- 03 Open/Closed The inspectors identified a Green finding and associated non-cited (NCV) of 10 CFR Part 50 Appendix B, Corrective Action, for the licensees failure to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, d efective material and equipment, and non-conformances are promptly identified and corrected. Specifically, the licensee failed to promptly identify and correct the out of allowable range values documented in work orders 20376561 and 20376768. The licensee performed the work orders to implement requirements as stated in licensee preventive maintenance procedure IP/0/A/3011/016, Motor Control Center, Distribution Center, revision 14.

Description:

The licensee performed work orders 20376561 and 20376768 to implem ent requirements as stated in licensee p reventive maintenance (PM) procedure IP/0/A/3011/016, Motor Control Center, Distribution Center, revision 14.

The as-found values for 1XSFA -F1 C (1HP-3 SSF power supply) and 1XS1-R3C (spare) cubicles were found to be out -of-tolerance and an engineering evaluation was not performed as required per section 1.3 of 9.14 of procedure IP/0/A/3011/016.

The work orders were performed in October 2020 and the deficiencies were not identified until November 4, 2021, when AR 02404429 was initiated after the inspector requested to review the performed PM work orders to verify the PM frequency.

Specifically, licensee preventive maintenance procedure, IP/0/A/3011/016, step 1.3 of 9.14 states that if any contactor failed to pick -up or dropout at required voltage listed below, notify Engineering for evaluation.

Work orders 20376561 and 20376768, documented that the as -found pick -up voltages for 1XSFA -F1C (1HP -3 SSF power supply)and 1XS1-R3C (spare cubicle) to be 93.2 VAC and 82.6 VAC respectively and exceeded their allowable pick -up voltages of 88.6 VAC and 76.6 VAC respectively.

Corrective Action Program procedure, AD -PI-ALL-0100, section 5.5.5 states, in part, that this ensures that equipment and quality concerns are promptly addressed.

Contrary to the procedural requirement, the issue was not identified until a year later.

AR 2404429 was initiated to document only the fact that the out -of-tolerance value issues were not forwarded to Engineering f or evaluation and addressing the correction action but, the lack of promptness was not addressed.

AR 02411953 was initiated to address the lack of promptness.

Corrective Actions: The licensee initiated ARs to have engineering evaluate the out -of-tolerance as-found data and take action.

Corrective Action References: AR 02404429, AR 02411953

Performance Assessment:

Performance Deficiency: The licensees failure to promptly evaluate and correct the out -of-tolerance as -found pick -up voltages was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC 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.

Significance: The inspectors used inspection manual chapter (IMC) 0609, Att achm ent 4, Initial Characterization of Findings, issued December 13, 2019, for mitigating systems, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -

Power, issued November 30, 2020, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design and qualification of a mitigating SSC, and the SSC maintained its operability.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Procedure Adherence in the area of human performance because the licensee personnel did not follow the procedure instruction. (H.8)

Enforcement:

Violation: 10 CFR Part 50, Appendix B, criterion XVI, Corrective Action, states, in part, 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 October 23, 2020, the licensee failed to promptly identify and correct the out -of-tolerance as -found values as documented in the referenced work orders.

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

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On February 9, 2022, the inspector s presented the integrated inspection results to Steve Snider, Site Vice President, and other members of the licensee staff.

• On January 19, 2022, the inspectors presented the RP inspection results to Ste ve Snider, Site Vice President, and other members of the licensee staff.

• On January 13, 2022, the inspectors presented the NOV closure inspection results to Laura Boyce, Regulatory Affairs.

THIRD PARTY REVIEWS

Inspectors reviewed the World Association of Nuclear Operators report that was issued during 2021.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action 02406833

Docum ents

Drawings O FD-102A-02-01 Flow Diagram of Low Pressure Injection System Borated 62

Water Supply and LPI Pump Suction

O FD-102A-02-02 Flow Diagram of Low Pressure Injection System (LPI Pump 53

Discharge)

O FD-124A-01-01 Flow Diagram of Low Pressure Service Water System 055

O-702-A Oneline Diagram 6900V & 4160V Auxiliary Sys. 38

Procedures OP/0/A/1107/003 100kV Power Supply 98

OP/0/A/1107/003 Procedure for Furnishing Power to Oconee 16

B

OP/2/A/1104/004 Low Pressure Injection System 174

OP/2/A/1104/010 Low Pressure Service Water 071

71111.05 Fire Plans CSD-ONS-PFP-Pre-Fire Plan for U1 Auxiliary Building Elevation 796 0

1AB-0796

CSD-ONS-PFP-Pre-Fire Plan for U2 Auxiliary Building Elevation 783 001

2AB-0783

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

2AB-0809

CSD-ONS-PFP-Unit 2 - Auxiliary Building & Reactor Building Elevation 777-0

2RB 861

CSD-ONS-PFP-Pre-Fire Plan for U1 Turbine Building Elevation 796 0

2TB-0796

CSD-ONS-PFP-Pre-Fire Plan Auxiliary Building Unit 3 EL 783, 796 001

3AB-0783

O-0310-FZ-008 Fire Zones Auxiliary Building Unit 3 EL 783 003

O-0310-FZ-013 Auxiliary Building - Units 2 Fire Protection Plan Fire Area and 003

Fire Zone Boundaries Plan at EL 809+3

O-0310-K-006 Fire Prot Aux Bldg Unit 3 EL 783+9 012

O-0310-K-007 Auxiliary & Reactor Building - Unit 1 Fire Protection Plan & 16

Fire Barrier Flood & Pressure Boundaries Plan at EL. 796+6 &

EL. 797+6

Inspection Type Designation Description or Title Revision or

Procedure Date

O-0310-L-005 Turbine Building - Unit 2 Fire Protection Plan & Fire Barrier, 13

Flood, & Pressure Boundaries Plan at Mezzanine El. 796+6

Miscellaneous OSS-0254.00-00- (Mech) Design Basis Specification for Fire Protection 047

4008

71111.06 Corrective Action 2406810

Docum ents

Resulting from

Inspection

Miscellaneous Clearance OPS-2 - 21-HP - RCS INJ HDRS-1270

Procedures AP/1-Auxiliary Building Flood 24

2/A/1700/030

AP/2/A/1700/002 Excessive RCS Leakage 17

71111.11Q Procedures OP-OC-15JT-05 Night Shift Shutdown JITT 10

OP/0/A/1108/001 Curves and General Information 117

OP/2/A/1102/010 Controlling Procedure for Unit Shutdown 227

OP/2/A/114/049 Low Temperature Overpressure Protection (LTOP) 53

71111.12 Corrective Action 2397266, 2397267, 2401887, 2404422, 2404752

Docum ents

Procedures AD-EG-ALL-1311 Failure Investigation Process (FIP) 2

71111.13 Miscellaneous 02R30 Drain to Mid Loop Infrequently Performed Tests or 10/29/2021

Evolutions Evaluation

Procedures AD-OP-ALL-0201 Protected Equipm ent 09

71111.15 Calculations OSC-11448 Oconee Generic Maneuvering Analysis Base Calculation 1

Corrective Action 02403963, 02405392, 02405877, 02408618, 0240861,

Docum ents 02405634

Drawings O-1781 Nuclear Instrumentation and Reactor Protective System 16

OFD-133A-02-01 Flow Diagram of Component Cooling Water System (CCW 037

Intake Pumps Discharge)

Miscellaneous 2A Steam Generator Pedestal Stud Evaluation

Boric Acid Evaluation #2406294

OSS-0254.00-00- Design Basis Document CCW Structures System 9

3002

Procedures AD-EG-PWR-Boric Acid Corrosion Control Program - Im plementation 04

1611

Inspection Type Designation Description or Title Revision or

Procedure Date

AD-OP-ALL-0111 Operations Communications 4

MP/0/A/1200/089 Valve - Main Steam Safety - Setpoint Test 054

Work Orders 20375976, 20501802

71111.18 Calculations OSC-11581 U1/2/3, Keowee EPS and 100kV APS Voltage Adequacy 1

Analyses

OSC-4300 Protective Relay Settings 39

OSC-7028 CYME Modeling of the January 1997 ESF Tests 2, 5, 6 and 3 1

Miscellaneous OSS-0254.00-00- 100kV Alternate Power System Design Basis Document 17

2011

Procedures IP/1/A/4980/027 A CV-2/CV-7 And CV-2 / CV-7 Class 1E Relay Test 32

71111.19 Engineering 414725

Changes

Procedures IP/0/A/4980/040 A KLF-1 Relay Test 15

IP/0/A/4980/060 A General Electric CFVB11A Relay Test 10

IP/0/A/4980/087 A General Electric PVD21 Differential Voltage Relay Test 25

IP/0/A/4980/087 J SSC-T Differential Relay Test 4

PT/2/A/0201/005 High Point Vent Flow Test 14

Work Orders 2119696, 20397282, 20397283

71111.20 Calculations OSC-1594 NUREG-0612 Control of Heavy Loads - Load Drop Analysis 2

Corrective Action 2405634, 2405326, 2405392

Docum ents

Drawings O-1464C-SLP Reactor Building - Unit 2 Floor Plan Elev. 861+6 Safe Load 1

Paths

ONEI-0400-564 O2C31 Final Core Load Map 0

Miscellaneous Elevated Risk Activity Plan, dated November 2, 2021 -

Removal of Unit 2 Main Feeder Bus 1

Clearance PRT-2-21-U-2 MFB1 OOS-0041

Clearance PRT-2-21-EL CLD MLOOP-0273

Procedures AD-OP-ALL-0210 Operational Risk Management 2

AD-WC-ALL-0420 Shutdown Risk Assessment 7

MP/0/A/1150/002 Reactor Vessel - Closure Head - Removal 66

MP/0/A/3005/012 Containment Inspection/Close Out Procedure 18

OP/0/A/1102/026 Operations IPTE Pre-Job Briefings 32

Inspection Type Designation Description or Title Revision or

Procedure Date

OP/2/A/1103/011 Draining and Nitrogen Purging RCS 102

PT/2/A/0115/012 Unborated Water Source Isolation Verification 005

71111.22 Drawings OFD-116A-2.1 Flow Diagram of Reactor Building Purge System 13

Procedures AD-EG-ALL-1705 Containment Leak Test (Appendix J) Program Implementation 2

MP/0/A/1200/088 Valves - Henry Pratt - Reactor Building Purge Isolation - 28

Preventive Maintenance

Work Orders 20450799

71114.06 Miscellaneous TSC Tabletop drill (DEP), 21TT-4 10/12/2021

71124.01 Corrective Action AR 02353210 Received unanticipated SRD dose rate alarm 10/14/2020

Docum ents AR 02406378 Unanticipated Dose Rate Alarm 11/19/2021

Miscellaneous OP/2/A/1102/010 Signed procedure, "Controlling Procedure for Unit Shutdown", 11/13/2021

4.13, step 3, "Pressurizer Cooldown Prep And

2HP-42 Flush".

Procedures AD-RP-ALL-0002 Radiation and Contamination Surveys 2

Radiation Surveys Survey ONS-M-Room 63 LPI & RB Spray Pumps 11/14/2021

211115-18

Survey ONS-M-Room 63 LPI & RB Spray Pumps (follow -up) 11/19/2021

211119-18

Radiation Work RWP 2999 U2 Aux Bldg Outage Related RCA Entry Using Self-Brief 2

Permits (RWPs) Process Per AD -RP-ALL-2011

71124.02 Corrective Action AR's: 02305678, 02326570, 02347744, 02352559, 02355847, Various

Docum ents 02368843, 02369730, 02378889, and 02387852

Miscellaneous Oconee Site ALARA Committee (SAC) Meeting Minutes - 10/6/2021

10/6/2021 (discussion and approval of the O2R30 outage

exposure estimate and major ALARA plans)

71124.03 Corrective Action ARs 02312446, ARs 02312446, 02357582 Various

Docum ents 02357582

Corrective Action AR 02408897 12/11/2021

Docum ents

Resulting from

Inspection

71124.04 Corrective Action AR 02351307 AR 02351307 09/30/2020

Docum ents

71124.05 Calibration S/N 8207 Shepherd Irradiator Model 89 Calibrator Calibration 05/12/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Records Verification Documentation, Source ID: ONS# 732 & ONS#

733

Corrective Action AR's 02306211, 02323708, 02355869, 02368224, 02368688, Various

Docum ents 02382130, 02382974, and 02382994

AR 02234896 2018 ONS PM Reduction Project 10/03/2018

Corrective Action AR 02408890 NRC Obs: Review of IP/0/B/0398/019 12/11/2021

Docum ents AR 02410842 2021 RP NRC Inspection - Traceability of source ONSI 238 01/05/2022

Resulting from

Inspection

Miscellaneous AD-RP-ALL-7009 Interlaboratory Cross Check Program Results - 2019 (counting 02/10/2020

- Attachm ent 01 room systems and whole body counters)

AD-RP-ALL-7009 Interlaboratory Cross Check Program Results - 2020 (counting 02/10/2021

- Attachm ent 01 room systems and whole body counters)

Procedures AD-EP-ONS-0401 ONS - Equipment Important to Emergency Response 001

IP/0/B/0398/019 Radwaste Facility Liquid Radiation Monitor - (RIA-33) 24

IP/0/B/0398/019 Radwaste Facility Liquid Radiation Monitor - (RIA-33) 4, 7/19/1988

Procedure Change Request

Work Orders WO 2037276401 Radwaste Facility Liquid Radiation Monitor (RIA-0033) Annual 03/11/2021

PM [electronic and source calibration]

Work Order (WO) Radwaste Facility Liquid Radiation Monitor (RIA-0033) Annual 12/17/5019

2030132101 PM [electronic and source calibration]

71152 Calculations OSC-5830 Unit 1 Motor Starter Circuit Voltage and Fuse Adequacy 15

Calculation, Attachment 1

OSC-5930 UNIT 1 MOTOR STARTER CIRCUIT VOLTAGE AND FUSE 17

ADEQUACY CALCULATION

OSC-6143 MCC CONTACTOR VOLTAGE ADEQUACY AND FUSE 14

ADEQUACY VERIFICATION - TYPE III

OSC-6144 MCC CONTACTOR VOLTAGE ADEQUACY AND FUSE 18

ADEQUACY VERIFICATION - TYPE III

OSC-6195 U1/2/3, SSF 125VDC Power System Battery and Charge 10

Sizing, Voltage Drop and Short Circuit Analysis

OSC-6195-ICC-EC110252 - OSC-6195, App. E, Case DCLF2 Adjusted Load 0

0014 Profile for Close-In of D.G. Breaker.

OSC-8113 125VDC Vital Instrumentation and Control Load Profile, 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Battery Sizing, and Voltage Analysis

OSC-4300 Protective Relay Settings 39

Corrective Action AR 1808457 CDBI 2011 Item 307 09/27/2011

Docum ents AR 2343569 2020 NRC DBAI - SSF RCMUP Contactors and MCC PM 08/12/2020

Procedure

AR 2343949 DBAI 2020 Breaker Close Coil DC Voltage 08/14/2020

AR 2343959 2020 NRC DBAI-Review of Previous Corrective Actions 08/14/2020

Corrective Action AR 2403150 Editorial Drawing Error on OEE-151-39 10/26/2021

Docum ents AR 2403456 2020 DBAI NOV Closure - Inadequate Extent of Condition 10/28/2021

Resulting from AR 2403594 Error in OSC-5930 for MCC motor starter voltage adequacy 10/29/2021

Inspection AR 2404141 Margin gain opportunity in ETAP models for 600/208V MCCs 11/03/2021

AR 2404429 2020 NOV closeout inspection finding 11/04/2021

Drawings O-702-A1 One Line Diagram 6900V & 4160V Sta Auxiliary System 24

O-702-A One Line Diagram 6900V & 4160V Sta Auxiliary System 38

O-1702-A One Line Diagram 6900V & 4160V Sta Auxiliary System 11

Engineering EC 110252 DOCUMENT OTS1 BREAKERS MINIMUM REQUIRED 0

Changes VOLTAGE AT THE CLOSE AND TRIP

EC 418190 DOCUMENT ABB 5HK BREAKERS MINIMUM REQUIRED 0

TESTING VOLTAGE FOR CLOSING

Miscellaneous OM 302.0105.001 ABB HK SWITCHGEAR INSTRUCTION MANUAL D10

Procedures AD-PI-ALL-0100 CORRECTIVE ACTION PROGRAM 25

IP/0/A/2001/003 A INSPECTION AND MAINTENANCE OF 4.16 KV AND 6.9 KV 59

ACB

IP/0/A/2001/003 H Refurbishing 5HK, 7.5HK, And 15HK (6.6 - 8.25 kV) Air Circuit 51

Breakers

IP/0/A/3011/016 Motor Control Center, Distribution Center, And Power 15

Panelboard Preventive Maintenance

27