IR 05000269/2023003
| ML23310A171 | |
| Person / Time | |
|---|---|
| Site: | Oconee, 07200040  |
| Issue date: | 11/14/2023 |
| From: | Eric Stamm NRC/RGN-II/DRP/RPB1 |
| To: | Snider S Duke Energy Carolinas |
| References | |
| EA-23-127 IR 2023003, IR 2023001 | |
| Download: ML23310A171 (27) | |
Text
SUBJECT:
OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2023003, 05000270/2023003, AND 05000287/2023003; AND INSPECTION REPORT 07200040/2023001; AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Steven Snider:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On October 23, and November 1, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
The NRC identified a violation of Title 10 of the Code of Federal Regulations (10 CFR)
72.212(b)(6) associated with tornado hazard protection. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 22-001, Enforcement Discretion for Noncompliance of Tornado Hazard Protection requirements at Independent Spent Fuel Storage Installations (ISFSI), and because the licensee was implementing compensatory measures and has taken or plans to take the necessary actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and is allowing continued ISFSI handling operations.
November 13, 2023 If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Oconee Nuclear Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000269, 05000270, 05000287; 07200040 License Nos. DPR-38, DPR-47, DPR-55
Enclosure:
As stated
Inspection Report
Docket Nos.
05000269, 05000270, 05000287;
07200040
License Nos.
Report Nos.
05000269/2023003, 05000270/2023003, 05000287/2023003;
07200040/2023001
Enterprise Identifier:
I-2023-003-0021;
I-2023-001-0114
Licensee:
Duke Energy Carolinas, LLC
Facility:
Oconee Nuclear Station
Location:
Seneca, South Carolina
Inspection Dates:
July 1, 2023, to September 30, 2023
Inspectors:
J. Nadel, Senior Resident Inspector
E. Robinson, Resident Inspector
N. Smalley, Resident Inspector
P. Cooper, Senior Reactor Inspector
D. Jackson, Senior Project Engineer
D. Neal, Health Physicist
A. Ruh, Reactor Inspector
Approved By:
Eric J. Stamm, Chief
Reactor Projects Branch 1
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Oconee Nuclear Station, in accordance with the Reactor Oversight Process. 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 Control the Design of the Unit 3 Low Pressure Service Water System in Containment Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000287/2023003-01 Open/Closed None (NPP)71153 A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion III, Design Control, was identified when the licensee failed to assure that appropriate quality standards were specified and that deviations from such standards were controlled for the Unit 3 low pressure service water (LPSW) system engineering change to modify sections of piping inside containment.
Condition Prohibited by Technical Specifications due to Isolation Valve Exceeding Inservice Testing Leakage Requirements Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000287/2023003-02 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of technical specification (TS) 3.7.19 was identified when a manual isolation valve in the Unit 3 spent fuel pool (SFP) cooling purification system failed in-service testing program (IST) leakage requirements. Specifically, on January 8, 2023, during a routine surveillance test of SFP valve 3SF-53, the valve did not meet the leakage requirements of TS surveillance requirement (SR) 3.7.19.2. The valve was declared inoperable and isolated per TS 3.7.19.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EA-23-127 Enforcement Action 23-127:
Tornado Hazards Protection Requirements at Independent Spent Fuel Storage Installations (Enforcement Guidance Memorandum (EGM) 22-001)60855 Closed
Type Issue Number Title Report Section Status NOV 05000270/2023010-02 Failure to Correct a Condition Adverse to Quality Associated with the Low Pressure Injection System Gas Accumulation 71152A Closed LER 05000287/2023-001-00 LER 2023-001-00 for Oconee Nuclear Station, Unit 3, Condition Prohibited by Technical Specifications due to Isolation Valve Exceeding Inservice Testing Leakage Requirements 71153 Closed
PLANT STATUS
Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.
Unit 2 operated at or near 100 percent RTP for the entire inspection period.
Unit 3 operated at or near 100 percent RTP for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe weather associated with Tropical Storm Idalia on August 30, 2023.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)3B motor driven emergency feedwater (MDEFW) and turbine driven emergency feedwater pumps while the 3A MDEFW pump was out of service (OOS) for preventive maintenance on August 23, 2023
- (2) Keowee Hydro Unit (KHU)-2 while KHU-1 was OOS for a planned battery replacement on August 29, 2023
- (3) Unit 1 high pressure injection (HPI) pump motor cooler service water system on August 30, 2023
- (4) Unit 3 emergency feedwater system on September 14, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire zone 15: Unit 2 main feed pump area on July 11, 2023
- (2) Fire zone 81: Unit 2 auxiliary building 200 level hallway on July 13, 2023
- (3) Fire zone 110: Unit 1/2 control room on July 20, 2023
- (4) Fire zone 29: Unit 3 4160V switchgear on July 26, 2023
- (5) Fire zone 106: Unit 1 cable room on August 30, 2023
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 1 HPI pump motor coolers
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 restoration from Unit 1/2 A spent fuel pool cooling pump testing where the A pump failed to start on July 21, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated SEG 2309 (PSE1) on July 18, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Keowee Unit 1 125V battery replacement, work order (WO) 20522957
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Units 1, 2, and 3 green risk during standby shutdown facility planned outage, on July 18, 2023
- (2) Unit 1 elevated green risk due to 1C low pressure injection pump maintenance, on August 9, 2023
- (3) Units 1, 2, and 3 green risk and an elevated risk plan for KHU-1 battery replacement during the week of August 28, 2023
- (4) Units 1, 2, and 3 green risk during yellow grid risk during the week of September 4, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2462431, engineering evaluation of Unit 1 HPI pump motor cooler testing per PT/1/A/0230/015 considering upper motor bearing thrust analysis deficiencies in NCR 2424508
- (2) NCR 2483549, discrepancies between as-built configuration and stress analysis of LPSW system piping
- (4) NCR 2484044, 2C reactor building cooling unit failed to go back to high speed during testing
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) Engineering change (EC) 422457, Unit 1 HPI pump upper motor bearing heat removal test results evaluation
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
(1)1B reactor building spray pump suction valve breaker functional test following breaker replacement, on July 19, 2023, WO 20502908
- (2) PT/1/A/0204/007, 1B Reactor Building Spray Pump Test, following maintenance on 1BS-2, on July 20, 2023, WO 20598149
- (3) PT/2/A/0600/014, U2 B Motor Driven Emergency Feedwater Pump Test, following minimum flow valve work, on August 2, 2023
- (4) IP/0/A/3001/001, Limitorque Preventive Maintenance, on Unit 1 LPSW valve 5, on August 7, 2023
- (5) PT/1/A/0203/006 A, Low Pressure Injection Pump Test - Recirculation, following oil change and lubrication of 1C pump, on August 9, 2023
- (6) PT/2/A/0203/006 A, Low Pressure Injection Pump Test - Recirculation, following motor electrical testing of the 2B low pressure injection pump, on August 31, 2023
Surveillance Testing (IP Section 03.01) (4 Samples)
- (1) PT/0/A/0620/009, "Monthly Keowee Hydro Operability Testing," on July 12, 2023
- (2) PT/3/A/0600/012, "Unit 3 Turbine Driven Emergency Feedwater Pump Test," on August 3, 2023
- (3) PT/0/A/0600/021, "Standby Shutdown Facility Diesel-Generator Operation," on August 15, 2023
- (4) PT/1/A/0230/015, "High Pressure Injection Motor Cooler Performance Test," on August 22, 2023
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
- (1) Training drill 23-03.2, which included emergency response organization (ERO)
Team 4 and participation from the corporate emergency offsite facility, joint information center, and offsite agencies, on August 8, 2023
- (2) Training drill 23-04, which included ERO Team 5, on September 26,
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)===
- (1) Unit 1 (July 1, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
- (3) Unit 3 (July 1, 2022, through June 30, 2023)
MS09: Residual Heat Removal Systems (IP Section 02.08) (3 Samples)
- (1) Unit 1 (July 1, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
- (3) Unit 3 (July 1, 2022, through June 30, 2023)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (3 Samples)
- (1) Unit 1 (July 1, 2022, through June 30, 2023)
- (2) Unit 2 (July 1, 2022, through June 30, 2023)
- (3) Unit 3 (July 1, 2022, through June 30, 2023)
===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (2 Samples, 2 Partials)
The inspectors reviewed the licensees implementation of its corrective action program (CAP) related to the following issues:
- (1) NCRs 2466315, 2442946, and 2434502, recurring protected service water breaker operation failures
- (2) NCRs 2473782 and 2482361, notice of 10 CFR Part 21 potential defect on Oconee control rod drive breakers (3)
(Partial)
The inspectors reviewed the licensees response to notice of violation (NOV)05000270/2023010-02 and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket.
Specifically, the inspectors reviewed procedure revision request 2403854, and confirmed that licensee operations procedure OP/2/A/1104/004 B, LPI System Fill and Startup, Revision 37, had been updated accordingly, and restored compliance.
This NOV is closed.
(4)
(Partial)
NRC inspectors assessed the Safety Conscious Work Environment (SCWE) within the Nuclear Supply Chain (NSC) department at Oconee Nuclear Station. The inspectors conducted interviews with all available staff in the department to assess the licensees environment for raising concerns, and to determine whether challenges existed to maintaining a SCWE.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)===
The inspectors evaluated the following licensee event reports (LER):
- (1) LER 05000287/2023-001-00, Condition Prohibited by Technical Specifications due to Isolation Valve Exceeding Inservice Testing Leakage Requirements (ADAMS Accession No. ML23068A470). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is closed.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60855 - Operation of an ISFSI Inspections were conducted using the appropriate portions of the 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 IMC 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-than-Class C Waste at Independent Spent Fuel Storage Installations (ISFSI) and for 10 CFR Part 71 Transportation Packaging.
Operation of an ISFSI===
- (1) From July 31 to August 3, 2023, the inspectors performed a review of the licensees ISFSI activities to verify compliance with regulatory requirements. During the on-site inspection, the inspectors observed and reviewed licensee activities in each of the five safety focus areas including occupational exposure, public exposure, fuel damage, confinement, and impact to plant operations.
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. Additionally, the inspectors performed independent walkdowns of the heavy load lifting equipment and the ISFSI haul path. The inspector also performed an independent radiation survey of the ISFSI pad.
INSPECTION RESULTS
Enforcement Discretion Enforcement Action EA-23-127: Tornado Hazards Protection Requirements at Independent Spent Fuel Storage Installations (EGM 22-001)60855
Description:
Upon issuance of U.S. NRC Enforcement Guidance Memorandum (EGM) 22-001 (ML22087A496), dated April 15, 2022, the licensee performed an assessment of all outdoor dry cask storage activities that are not explicitly analyzed for tornado hazards in the cask licensing basis. Several configurations were identified including when the transfer cask lid is removed to insert the dry shielded canister (DSC) into the horizontal storage module (HSM). These configurations are not explicitly analyzed in the Standardized NUHOMS 72-1004 final safety analysis report (FSAR). Section 72.212 (b)(6) of 10 CFR, states, in part, that the general licensee must: review the Safety Analysis Report referenced in the certificate of compliance (CoC) or amended CoC and the related NRC Safety Evaluation Report, prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of earthquake intensity and tornado missiles, are enveloped by the cask design bases considered in these reports. The results of this review must be documented in the evaluation made in paragraph (b)(5) of this section. Tornado hazards are evaluated in the Standardized NUHOMS 72-1004 FSAR section 3.2.1, Tornado and Wind Loadings, and section 8.2.2, Tornado Winds/Tornado Missile. These sections of the FSAR do not include an analysis for tornado hazards for these configurations.
Additionally, the licensee did not have an evaluation demonstrating the reactor site parameters enveloped the cask design basis for tornado missiles.
Corrective Actions: The licensee entered the issue into its CAP to address the actions specified in EGM 22-001. Specifically, the licensee established additional measures that:
1. Mitigate tornado hazards, through procedures, during periods of ISFSI handling
operations which include:
a.
Precluding outdoor dry cask storage activities during periods of adverse weather; b.
Establishing meteorological criteria and designating staff to monitor weather during ISFSI handling operations; c.
Describing actions to take in the event of severe weather necessary to place the cask in an analyzed condition; and d.
Minimizing the duration of ISFSI handling operations during which ISFSI important to safety structures, systems, and components are in an unanalyzed condition.
2. Document that required weather checks are complete prior to the start of ISFSI
handling operations.
3. Document in the CAP a request for the CoC holder to request an amendment within
six months of the date of the EGM.
Because the licensee implemented compensatory measures and plans to take necessary actions to restore compliance in accordance with the EGM, the NRC is allowing continued ISFSI handling operations.
Corrective Action References: Action request 02425098
Enforcement:
Significance/Severity: The inspectors assessed the issue as being more than minor significance but not more than Severity Level IV. Consistent with the guidance in EGM 22-001 discussed below, the NRC is exercising enforcement discretion.
Violation: Section 72.212 (b)(6) of 10 CFR, states, in part, that the general licensee must:
review the Safety Analysis Report referenced in the CoC or amended CoC and the related NRC Safety Evaluation Report, prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of earthquake intensity and tornado missiles, are enveloped by the cask design bases considered in these reports. The results of this review must be documented in the evaluation made in paragraph (b)(5) of this section.
Contrary to the above, on May 19, 2022, the licensee did not have a documented evaluation determining whether the reactor site parameters, including analyses of tornado missiles, were enveloped by the cask design bases considered in the Safety Analysis Report. Specifically, the licensee failed to have an analysis for tornado hazards when the transfer cask lid is removed to insert the DSC into the HSM.
Basis for Discretion: Because this violation was identified during the discretion period covered by EGM 22-001, Enforcement Discretion for Noncompliance of Tornado Hazard Protection requirements at Independent Spent Fuel Storage Installations, and because the licensee was implementing compensatory measures and has taken or plans to take the necessary actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and is allowing continued ISFSI handling operations.
Assessment 71152A NRC inspectors assessed the Safety Conscious Work Environment (SCWE) within the Nuclear Supply Chain (NSC) department at Oconee Nuclear Station. Based on interviews with all available NSC personnel, the inspectors assessment did not identify a situation that rose to the level of a chilled work environment. However, the inspectors did identify a challenge to the environment for raising concerns, as some personnel expressed a hesitancy to raise nuclear safety concerns and/or feared retaliation for doing so, which was caused by a loss of trust in multiple reporting avenues. Additionally, some personnel indicated a hesitancy to report non-nuclear safety concerns, such as personnel safety incidents.
The licensee initiated corrective actions to address the underlying issues to improve the SCWE within the NSC department. The NRC intends to conduct a follow-up assessment to determine whether the licensees corrective actions were effective.
Observation: Notice of Violation 05000270/2023010-02 Closure 71152A The NRC issued NOV 05000270/2023010-02 in NRC inspection report 05000269, 270, 287/2023010, dated July 19, 2023. In response, Duke wrote NCR 2472973. Assignment one of the NCR was to conduct an organizational programmatic checklist in accordance with licensee procedure AD-PI-ALL-0106, Cause Investigation Checklists. This checklist reviewed the organizational causes leading to the NOV and recommended corrective actions and enhancements to resolve issues. The checklist included a section which reviewed the detailed history of events that resulted in the 2023 failure of a train of the low pressure injection system (LPI) due to failure of a LPI cross-train relief valve. A past similar failure in 2019 was the subject of NRC violation NCV 05000269, 270/2021001-01, which identified, in part, that a corrective action was needed to change the procedure for filling and venting of the LPI system to prevent the accumulation of gas which was challenging the relief valves. When this corrective action had not been accomplished by the time of the 2023 failure, the NOV was issued. Inspectors noted that four ranked causes were identified by the licensee in the organizational programmatic checklist. These consisted of specific personnel accountability placed on; 1) Engineering staff for extending the procedure change action multiple times, 2) Outage Management staff for failure to implement administrative requirements associated with implementing the procedure change corrective action during a 2021 outage, 3) Regulatory Affairs staff for failing to implement administrative requirements related to the tracking of NRC violations, and 4) Nuclear Support Services management for inadequate oversight of corrective actions associated with NRC violations.
Corrective actions mainly consisted of reviewing the requirements of applicable administrative procedures with personnel, sharing lessons learned, and evaluating if further training is needed. Some enhancement actions were also performed, including creating and sharing a case study of the events and directly coaching staff.
Inspectors noted that while it may be accurate to conclude that the damage to the LPI system, and thus the issuance of the NOV, could have been prevented if the self-imposed administrative procedural requirements had been followed in this case, the checklist did not address the organizational environment within which those procedures were not followed. For example, the failure of Outage Management staff to either approve or deny an outage scope change to add the new fill/vent process for the LPI system occurred 11 days before the start of the Unit 2 outage that was planned for 19 days, shorter than any previous refueling outage at Oconee. Additionally, the organizational programmatic checklist described interviews with Regulatory Affairs personnel which revealed that the administrative requirements in question were previously accomplished by dedicated personnel within Regulatory Affairs prior to a 2019 reorganization that reduced the staff down to two. However, the resource change and any impact it potentially had on the failure of personnel to complete the administrative requirements was not addressed in the checklist. Inspectors recognized that the level of causal detail is less in an organizational checklist than an apparent or root cause, but nonetheless noted the importance of the organizational environment as a potential contributor to or cause of the personnel failures. Additionally, inspectors noted marked differences in staffing, responsibilities, organization, and resources in both the Engineering and Regulatory Affairs departments since 2018, but little change to the self-imposed administrative procedural requirements for this issue over the same period. The checklist did not address the organizational differences present in the decision-making environment, some of which were pointed out by the personnel involved, but instead focused on causes related to personnel accountability with the administrative processes.
The inspection closure activity reviewed the licensees written response to the NOV and confirmed the licensee had restored compliance. However, the corrective actions associated with the organizational checklist and other assignments within NCR 2472973 are subject to additional review under IP 71152, Problem Identification and Resolution. This NOV is closed.
Observation: 10 CFR Part 21 Process and Follow-up Weaknesses 71152A A 10 CFR Part 21, Reporting of Defects and Noncompliance, Notification of Defect, that identified a potential defect in certain power circuit breakers at Oconee Nuclear Station was received by the NRC on April 7, 2023. In May 2023, resident inspectors selected the Part 21 notification as an inspection sample, but no licensee response or evaluation was found after a search of CAP documents. The inspectors raised this concern to the licensee. The licensee initiated NCR 2473782 and took actions to screen and evaluate the Part 21 notification per licensee procedure AD-LS-ALL-0018, Revision 2, Evaluating and Reporting of Defects and Noncompliance in Accordance with 10 CFR 21. However, the licensees initial response did not address the missed 10 CFR Part 21 report which caused the delay in screening and evaluating the defect. The resident inspectors reviewed licensee procedure AD-LS-ALL-0018 and noted that it did not contain clear requirements regarding ownership of 10 CFR Part 21 notification responsibilities, specifically who should initiate an NCR upon receipt. After further resident inspector office engagement, the licensee initiated NCR 2482361 to capture the missed 10 CFR Part 21 notification aspect.
Failure to Control the Design of the Unit 3 Low Pressure Service Water System in Containment Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000287/2023003-01 Open/Closed None (NPP)71153 A self-revealed Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified when the licensee failed to assure that appropriate quality standards were specified and that deviations from such standards were controlled for the Unit 3 LPSW engineering change to modify sections of piping inside containment.
Description:
The LPSW system provides cooling water to various emergency and normal systems throughout the plant. One of the normal systems served by LPSW is the reactor coolant pump (RCP) upper motor bearing oil coolers. On June 22, 2023, after completing a routine makeup to the reactor coolant system (RCS), operators in the Unit 3 control room identified that the reactor building normal sump showed an increased inleakage rate. The licensee analyzed all system inputs into the sump and performed an RCS leak rate calculation. RCS leakage was ruled out based on the results of the calculation and past trends. Unit 3 was reduced to approximately 20 percent power to allow for leak inspections in the steam generator cavities. On June 24, 2023, the leak was identified as coming from 0.25-inch diameter LPSW system piping associated with the 3A1 RCP upper motor bearing oil cooler, upstream of instrument valve 3LPS-IV-0081, which had completely sheared off. Subsequent extent of condition walkdowns identified an additional active leak near instrument valve 3LPS-IV-0082.
The damaged sections of piping were removed and sent for metallurgical analysis. The licensee discovered that the carbon steel piping had failed at a point where it was welded to a stainless steel fitting via stainless steel filler material. A previous LPSW EC 81636, implemented in 1998, had intended to replace all small bore carbon steel LPSW piping in containment, including the sections that failed in this instance. In all, eight locations were identified in Unit 3 containment where carbon steel to stainless steel dissimilar metal welds were still present.
The residents reviewed the event and determined that the amount of LPSW leakage present due to the failed pipe constituted a large enough breach to exceed the 10 CFR Part 50 Appendix J containment leak rate criteria of La. La is defined as the maximum allowable leakage rate at the calculated maximum peak containment pressure resulting from the limiting design bases loss of coolant accident. Duke calculation OSC-7005, Allowable LPSW leakage for Containment Integrity, Revision 0, established a limit of approximately 0.5 gpm leakage through LPSW piping at this elevation inside containment to maintain the La criteria.
This leak was measured at approximately 6 gpm. The residents also noted that the failed section of piping was credited within the design bases as a closed loop inside containment and, along with two single active containment isolation valves, provided the redundant isolation for two containment penetrations that support the containment safety function of limiting leakage of fission product radioactivity during an accident.
Corrective Actions: The licensee repaired the piping at the two locations mentioned above by replacing it with stainless steel material and fittings. The other locations with dissimilar metal welds were inspected and scheduled for replacement at the next planned outage on Unit 3.
Initial extent of condition reviews determined that Units 1 and 2 were not subject to the same missed design scope for their LPSW piping, but actions were created to walkdown applicable piping at the next available opportunity for confirmation.
Corrective Action References: NCRs 2477210, 2477145
Performance Assessment:
Performance Deficiency: The failure to assure that appropriate quality standards were specified and that deviations from such standards were controlled for the LPSW system in accordance with 10 CFR Part 50, Appendix B, Criterion III, was a performance deficiency.
Specifically, EC 81636, to replace small bore carbon steel LPSW piping with stainless steel, was not implemented as intended which resulted in carbon steel piping remaining in Unit 3 containment, and failure of the carbon steel LPSW piping at points where it was welded to a stainless steel fitting.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failed section of piping was credited within the design bases as a closed loop inside containment and, along with a single active containment isolation valve, provided the redundant isolation that supports the containment safety function of limiting leakage of fission product radioactivity during an accident.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, inspectors used Exhibit 3, Barrier Integrity Screening Questions, Subsection C, Reactor Containment, and because the finding represented an actual open pathway in the physical integrity of reactor containment through a valve, the guidance directed inspectors to IMC 0609, Appendix H, "Containment Integrity Significance Determination Process." The finding was considered to be a Type B finding because it was not expected to have any impact on the core damage frequency of the facility. Based on IMC 0609, Appendix H, Table 4.1, small lines (less than 1-2 inches in diameter) would not generally contribute to large early release frequency (LERF). Since the open pathway created by the leak was limited to the 0.25-inch diameter pipe and no other SSCs important to LERF were affected, the finding screened to Green.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components. Contrary to the above, from 1998, until June 26, 2023, the licensee failed to assure that appropriate quality standards were specified and included in design documents, that deviations from such standards were controlled, and that measures were established for the selection and review for suitability of application of materials during the implementation of EC 81636 to the LPSW system. Specifically, carbon steel piping and dissimilar metal welds were unintentionally excluded from the scope of work. As a result, the carbon steel LPSW piping failed at points where it was welded to a stainless steel fitting.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Condition Prohibited by Technical Specifications due to Isolation Valve Exceeding Inservice Testing Leakage Requirements Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000287/2023003-02 Open/Closed Not Applicable 71153 A self-revealed Severity Level IV NCV of TS 3.7.19 was identified when a manual isolation valve in the Unit 3 SFPC purification system failed IST leakage requirements. Specifically, on January 8, 2023, during a routine surveillance test of SFP valve 3SF-53, the valve did not meet the leakage requirements of TS SR 3.7.19.2. The valve was declared inoperable and isolated per TS 3.7.19.
Description:
Oconee Nuclear Station has two SFPs, one pool for Units 1 and 2 and a second pool for Unit 3, and three borated water storage tanks (BWSTs), one BWST for each unit.
Each SFP has its own spent fuel cooling (SFC) system. The primary function of the SFC system is to provide decay heat removal for the spent fuel stored in the associated spent fuel pool. Additionally, the SFPC purification system, a subsystem of the SFC system, provides for purification of the associated SFP and the BWST(s) for the associated units. Following a loss of coolant accident (LOCA), the emergency core cooling system (ECCS) initially injects borated water from the BWST into the RCS to reflood the reactor core and provide for core cooling. Once the BWST inventory is depleted, ECCS pumps are realigned to take suction from the reactor building emergency sump (RBES) to provide long-term core cooling. During this mode of operation, ECCS recirculates potentially contaminated fluid from the RBES. The large break LOCA assumes back leakage from the RBES to the BWST. Valve 3SF-53 serves as a boundary valve between the BWST and the SFPC purification system. It is designed to mitigate back leakage from the BWST to maintain control room and offsite dose within regulatory limits. Leakage of this potentially contaminated fluid from the RBES to the environment must be maintained within analyzed limits.
On January 8, 2023, with Unit 3 in Mode 1 operating at approximately 100 percent full power, TS SR 3.7.19.2 was performed on SFPC purification system manual isolation valve 3SF-53.
The surveillance, conducted in accordance with the IST program, tests the valve for leakage.
Test results showed that the leakage through valve 3SF-53 did not meet the leakage requirements of TS SR 3.7.19.2 and the valve was declared inoperable per TS 3.7.19, Spent Fuel Pool Cooling (SFPC) Purification System Isolation from Borated Water Storage Tank (BWST). At the time of identification, the SFPC was already isolated from the SFC system.
Subsequent investigation revealed the presence of foreign material was impeding the valve disc from fully closing. The foreign material was removed, and valve 3SF-53 successfully passed TS SR 3.7.19.2 testing, thereby restoring operability of the valve. Further review of operation of the valve showed the valve had not been repositioned since it was closed during the last refueling outage on May 17, 2022. Based on the presence of the foreign material and the length of time since the valve had been operated, the licensee determined that there was firm evidence that unacceptable leakage existed for longer than the allowed outage time permitted by TS 3.7.19. A source or specific maintenance activity that could have introduced the foreign material was not identified.
Oconee Unit 3 TS limiting condition of operation (LCO) 3.7.19.b requires, SFPC Purification System branch line manual valves shall be closed and meet Inservice Testing Program leakage requirements in Modes 1, 2, 3, and 4 when the SFPC purification system is not isolated from the BWST. Condition C requires that with a required SFPC purification system branch line manual valve not closed or not meeting leakage requirements, required actions C.1 and C.2 apply with respective 1-hour and once per 31 days completion times to isolate the flow path of at least one closed and de-activated automatic valve, one closed and de-activated non-automatic power operated valve, closed manual valve, or blind flange, and verify the flow path is isolated, respectively. Condition D, in the case that the above required actions and associated completion times are not met, requires the unit to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Corrective Actions: The licensee completed the following corrective actions: Valve 3SF-53 was disassembled, inspected, cleaned, and blue-checked satisfactorily prior to restoration and the surveillance was re-performed. Additionally, the foreign material was removed, and the piping was inspected upstream and downstream with no further foreign material identified.
Corrective Action References: NCRs 2455196, 2459548
Performance Assessment:
The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.
Specifically, a source or maintenance activity that introduced the foreign material into the system was not identified.
Enforcement:
Enforcement Policy, Section 2.2.4, states that violations with no associated performance deficiency will be dispositioned using traditional enforcement. Therefore, operating reactor violations with no associated performance deficiencies should be assigned a severity level and are, thus, not described as findings or assigned a color (e.g., Green).
Severity: This violation is characterized as Severity Level IV based on its similarity to Enforcement Policy, Section 6.0, Violation Examples, Section 6.1.d examples. The inspectors also reviewed NRC Enforcement Policy, Section 2.2.1, "Factors Affecting Assessment of Violations," which states, in part, that "whenever possible, the NRC uses risk information in assessing the safety significance of violations." Accordingly, after considering that the condition represented very low safety significance, the inspectors concluded that the violation is best characterized as Severity Level IV.
Violation: Oconee Unit 3 TS LCO 3.7.19.b requires, SFPC Purification System branch line manual valves shall be closed and meet Inservice Testing Program leakage requirements, in Modes 1, 2, 3, and 4 when the SFPC purification system is not isolated from the BWST.
Condition C requires that with a required SFPC purification system branch line manual valve not closed or not meeting leakage requirements, required actions C.1 and C.2 apply with respective 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 31 days completion times to isolate the flow path of at least one closed and de-activated automatic valve, one closed and de-activated non-automatic power operated valve, closed manual valve, or blind flange, and verify the flow path is isolated, respectively. Condition D, in the case that the above required actions and associated completion times are not met, requires the unit to be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above, from May 17, 2022, to January 8, 2023, required SFPC purification system branch line manual valve 3SF-53 did not meet in-service testing program leakage requirements and the unit did not enter Mode 3 and Mode 5 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively.
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 August 3, 2023, the inspectors presented the operation of an ISFSI inspection results to Steven Snider and other members of the licensee staff.
- On October 23, 2023, the inspectors presented the integrated inspection results to Steven Snider and other members of the licensee staff.
- On November 1, 2023, the inspectors presented the final integrated inspection results to Steven Snider.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
RP/0/A/1000/035
Severe Weather Preparations
009
Corrective Action
Documents
23274, 2424508
O-0444
Piping Layout Pipe Chase Auxiliary Building
O-435K
Piping Layout Enlarged Plan Misc. Piping EL 758-0
Auxiliary Building
O-435N
Sections and Details Miscellaneous Piping EL 758-0
Auxiliary Building
O-510D
Miscellaneous Piping EL 758-0 Auxiliary Building
Drawings
OFD-121D-3.1
Flow Diagram of Emergency Feedwater System
Miscellaneous
OSS-0254.00-00-
1000
(Mech) Design Basis Specification for the Emergency
Feedwater System
059
AD-OP-ALL-0210
Operational Risk Management
AP/0/A/2000/002
Keowee Hydro Station - Emergency Start
25
OP/0/A/1106/019
Keowee Hydro at Oconee
114
Procedures
OP/3/A/1106/006
Emergency FDW System
115
OSC-10816
ONS TCCA A and B Area Basis for AD-EG-ALL-1520
005
Calculations
OSC-9293
NFPA 805 Transition Radioactive Release G-1 Table
004
Corrective Action
Documents
2454161, 2467247, PIP O-15-2007
CSD-ONS-PFP-
Pre-Fire Plan for Unit 2 Auxiliary Building Elevation 783
001
CSD-ONS-PFP-
Pre-Fire Plan for U2 Turbine Building Elevation 775
CSD-ONS-PFP-
Pre-Fire Plan for U3 Turbine Building Elevation 796
O -0310-FZ-026
Turbine Building - Units 2 Fire Protection Plan Fire Area &
Fire Zone Boundaries Plan at El 775+0
O -0310-L-002
Fire Protection Turbine Building Unit 2 El 775+0
O-0310-FZ-007
Auxiliary & Reactor Building - Unit 2 Fire Protection Plan
Fire Area & Fire Zone Boundaries Plan at EL 783+9
Fire Plans
O-0310-K-005
Fire Protect Aux Building Unit 2 EL 783+9
013
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
O-0310-KR-001
Auxiliary Building & Ancillary Structures - Fire, Flood,
Pressure, & Radiation - Table of Penetrations - General
Notes & References
O-0310-KR-100
Auxiliary Building - Unit 1, Fire, Flood, Pressure, & Radiation
Table of Penetrations
004
O-0310-KR-101
Auxiliary Building - Unit 1, Fire, Flood, Pressure, & Radiation
Table of Penetrations
004
O-0310-KR-102
Auxiliary Building - Unit 1, Fire, Flood, Pressure, & Radiation
Table of Penetrations
004
O-0310-L-006
Turbine Building - Unit 3 Fire Protection Plan & Fire Barrier,
Flood, & Pressure Boundaries Plan at Mezzanine EL 796+6
Miscellaneous
OSS-0254.00-00-
4008
(Mech) Design Basis Specification for Fire Protection
047
CSD-ONS-FS-
016
Standard Operating Guide Fires Located Within a
Contaminated RCA/RCZ
001
HP/0/B/1000/054
Radiation Protection Routines
053
Procedures
MP/3/A/1705/018
Fire Protection - Penetration - Fire and Flood Barrier -
Inspection and Minor Repair
048
Calculations
OSC-2042
HPI Pump Motor Upper Bearing Cooling Report
Drawings
OFD-124B-1.1
Flow Diagram of Low Pressure Service Water System
(Auxiliary Building Services)
Pioneer Motor Bearing Engineering Report W1737-
ACPTMOD-R9, Oconee Nuclear Station HPI Pump Oil Tub
Heat Flow Project - Acceptance Model for Operation of the
Upper Oil Pot, dated June 2021
OM 314-0120.003
HPI Pump Motor Cooling Coil Performance Test
Miscellaneous
OM 314-0586.001
Review of Pioneer HPI Pump Upper Motor Bearing Analysis
and Certificate of Conformance
AD-TQ-ALL-0230
Licensed Operator Requalification Annual and Biennial
Exam Development
AD-TQ-ALL-0470
Non-Regulated Exam Security
Procedures
EP/1/A/1800/001
Unit 1 EOP Immediate Manual Actions and Subsequent
Actions
Corrective Action
NCR 2461286, 2370807, 2449194, 2457701, 2470238
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
PRR 2478976
KM 320.--
0009.001
Connections for 59 Cell NCN-27 Battery for Four Row
Installation
KM 320.--
27.001
Two-Tier Battery RAC for NCN-27
KM 320.--
28.001
Installation and Operating Instructions for Keowee Batteries
KM 320.--
29.001
Environmental and Seismic Qualification: 125VCD Class 1E
Power Batteries Vol. 1
Drawings
OFD-110A-1.4
Flow Diagram of Chemical Addition System Post Accident
Liquid Sampling
LCO Tracking Number O-1-21-00275
Miscellaneous
LCO Tracking Number O-1-20-00956
AD-EG-ALL-1210
AD-PI-ALL-0100
Corrective Action Program
PT/1/A/0152/017
Reactor Coolant System Valve Stroke Test
Procedures
PT/1/A/0152/017
Reactor Coolant System Valve Stroke Test
Work Orders
20435053, 20454071, 20586650
Clearance PRT-0-23-SSF OOS-0147
Clearance PRT-0-23-0148
Miscellaneous
Phoenix risk profile report for Unit 1, 23W32
AD-OP-ALL-0201
Protected Equipment
AD-WC-ALL-0200
Online Work Management
AD-WC-ALL-0240
Online Risk Management Process
AD-WC-ALL-0410
Work Activity Integrated Risk Management
AP-OP-ALL-0210
Operational Risk Management
Procedures
OP/0/A/1600/010
Operation of the SSF Diesel Generator
Work Orders
20521411
OSC-0966-09-00-
0001
S/R 1-13-0-400B-JEJ-1901
OSC-0966-09-
0001
S/R 1-13-0-400B-JEJ-1901
Calculations
OSC-1636
Condenser Circulating Water (CCW) for Suction to Service
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Water Pump Problem No. 1-13-09
Corrective Action
Documents
2487656, 1805474, PIP O-11-9953, 1763327, PIP O-05-
20, 2484190
1-13-0-400B-JEJ-
1901
Support/Restraint Number: 1-13-0-400B-JEJ-1901
1-13-0-400B-JEJ-
1901
Hanger Sketch
3A
Drawings
OEE 238-20
Elementary Diagram L.P. Service Water System R.B.
Cooling Unit Fan 2C
Engineering
Changes
104970
Replace CCW Crossover Valve 2CCW-41
Structural Integrity Associates Report 2301156.401
Calculation Impact Review OSC-1636 AR02483549,
Condenser Circulating Water (CCW) for Suction to Service
Water Pump
08/20/2023
Miscellaneous
OSS-0254.00-00-
26
Reactor Building Cooling System Design Basis Document
AP/1/A/1700/011
Recovery from Loss of Power
EP/1/A/1800/001
0L
Unit 1 EOP Rules and Appendix
IP/0/A/3001/013 A
RBCU Fan Motor Starter and Timer PM
OP/0/A/1106/019
Keowee Hydro at Oconee
114
Procedures
PT/0/A/0620/009
Keowee Hydro Operation
OFD-101A-1.3
Flow Diagram of High Pressure Injection System (Charging
Section)
Drawings
OFD-101A-1.4
Flow Diagram of High Pressure Injection System (Charging
Section)
Procedures
PT/1/A/0230/015
High Pressure Injection Motor Cooler Performance Test
OSC-5649
LPSW Test Acceptance Criteria
OSC-5674
Generic Letter 89-10 MOV Calculation for Unit 1 Gate and
Globe Valves at Oconee
043
OSC-7070
Oconee Event Mitigation Database
Calculations
OSC-7993
RBS System Hydraulic Evaluation for Proposed Modification
ON-X3105
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
PIP O-08-00407, 01858769, 01909556
O-0703-G
One Line Diagram Station Auxiliary Circuits 600/208V L/C
1X8, 1X9, 1X10 & MCC 1XS1, 1XS2, 1XS3
OFD-102A-1.1
Flow Diagram of Low Pressure Injection System Borated
Water Supply & LPI Pump Suction
OFD-102A-1.2
Flow Diagram of Low Pressure Injection System Pump
Discharge
OFD-103A-1.1
Flow Diagram of Reactor Building Spray System
OM-251-
0662.002
General Arrangement, Cross Section & Parts for DMV-1000
(2FDW-380)
001
ONTC-0-103A-
0005-001
BS Pump Performance Test Acceptance for Pump Total
Developed Head
ONTC-1-124B-
20-001
LPSW Flow to U1 HPI Pump Motor Coolers Test
Acceptance Criteria
Drawings
ONTC-1-BS-002
Generic Letter 89-10 Test Acceptance Criteria for 1BS-002
OSC-2515
Verification of Emergency Feedwater System Flow Utilizing
MFW System Bypass (Supersedes OSC-2210)
25
OSS-0254.00-00-
1048
(Mech) Design Basis Spec for Keowee Air Circuit (AB) Air
System
OSS-0254.00-00-
2005
(Elect) Keowee Emergency Power Design Basis Document
Miscellaneous
OSS-0254.00-00-
1034
(Mech) Design Basis Specification for the Reactor Building
Spray System
29
IP/0/A/3001/001
Limitorque Preventative Maintenance
098
IP/0/A/3011/013 A
Molded Case Breaker Test and Inspection
2
IP/0/A/3011/015
Removal and Replacement of Motor Control Center,
Panelboards, and Remote Starter Components
040
OP/0/A/2000/041
KHS-Modes of Operation
OP/1/A/1104/005
Reactor Building Spray System
037
PT/0/A/0600/021
Standby Shutdown Facility Diesel - Generator Operation
017
PT/0/A/0620/009
Keowee Hydro Operation
PT/1/A/0152/002
Building Spray System Valve Stroke Test
036
Procedures
PT/1/A/0204/007
Reactor Building Spray Pump Test
106
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PT/1/A/0600/012
Turbine Driven Emergency Feedwater Pump Test
108
PT/2/A/0203/006
A
Low Pressure Injection Pump Test - Recirculation
089
PT/2/A/0600/013
Motor Driven Emergency Feedwater Pump Test
077
PT/3/A/0600/012
Turbine Driven Emergency Feedwater Pump Test
096
Work Orders
20502908, 20516625, 20598149, 20599648, 20518493,
20519847
ONS DRILL 23-04
AP/1/A/1700/002
Excessive RCS Leakage
017
CSD-EP-ONS-
0101-01
EAL Technical Basis Document
004
CSD-EP-ONS-
0101-02
Oconee Nuclear Station Classification of Emergency
003
MSEL 23-03.2
EP Drill
Miscellaneous
Development of Emergency Action Levels for Non-Passive
Reactors
Corrective Action
Documents
2453446
MSPI Margin Report Oconee Units 1, 2 and 3 Emergency
AC Power and Residual Heat Removal Systems, June 2023
71151
Miscellaneous
MSPI Derivation Report Oconee Unit 1 Emergency AC
Power Unreliability Index, June 2023
2409580, 2421448, 2434502, 2442946, 2466315, 2424456,
2453398, 2455803, 2473782, 2482361
2472973
2491256
Corrective Action
Documents
Actions Addressing 2LP-196 Bellows Leakage (2023 PI&R
Inspection)
Drawings
O-6700
One-Line Diagram Main PSW Switchgear 13.8/4.16 kV
System
Miscellaneous
Duke Energy Carolinas, LLC, Oconee Nuclear Station,
Unit 2, Docket No. 50-270, Reply to a Notice of Violation
(NOV) - NOV 05000270/2023010-02
8/17/2023
Procedures
AD-LS-ALL-0018
Evaluating and Reporting of Defects and Noncompliance in
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Accordance with 10 CFR 21
AD-PI-ALL-0100
Corrective Action Program
AD-PI-ALL-0106
Cause Investigation Checklist
AD-PI-ALL-0400
Operating Experience Program
IP/0/A/2001/015
PSW 13.8 kV/4.16 kV Square D Type VR Vacuum Circuit
Breaker Inspection and Maintenance
006
IP/0/A/2001/016
PSW 13.8/4.16 kV Vacuum Circuit Breaker System Removal
and Installation
OP/0/A/1107/011
Removal and Restoration of Auxiliary Electrical Equipment
069
OP/0/A/1650/005
PSW AC Power
20
OP/0/A/2000/075
Keowee Hydro Station - PSW System
008
PT/0/A/0500/020
PSW Power Path Test
017
Work Orders
20595783, 20527995, 20561254, 20595783, 20229853,
222817, 20216582, 20233677, 20246164, 20239456
2477210
Corrective Action
Documents
2455196, 2459548
OFD-124B-03-04
Flow Diagram of Low Pressure Service Water System (RC
Pump Motor Cooling & RB Fire Protection)
036
Drawings
OFD-124B-03-04
Flow Diagram of Low Pressure Service Water System (RC
Pump Motor Cooling & RB Fire Protection)
037
Miscellaneous
OSC-7005
LPSW Allowable Leakage For Containment Integrity