IR 05000269/2023010

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Biennial Problem Identification and Resolution Inspection Report 05000269/2023010 and 05000270/2023010 and 05000287/2023010 and Notice of Violation
ML23193B048
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/19/2023
From: Eric Stamm
NRC/RGN-II/DRP/RPB1
To: Snider S
Duke Energy Carolinas
References
IR 2023010
Download: ML23193B048 (18)


Text

SUBJECT:

OCONEE NUCLEAR STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000269/2023010 AND 05000270/2023010 AND 05000287/2023010 AND NOTICE OF VIOLATION

Dear Steven Snider:

On May 19, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Oconee Nuclear Station. On May 23, 2023, and June 26, 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.

The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

Based on the results of this inspection, the enclosed report discusses a violation associated with a finding of very low safety significance (Green). The NRC evaluated this violation in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that this violation did not meet the criteria to be treated as a non-cited violation because the station failed July 19, 2023 to restore compliance within a reasonable period of time with previously NRC-identified Green non-cited violation 05000269,05000270/2021001-01, Inadequate Design Control of Low Pressure Injection System Modification. Specifically, the station failed to correct a deficiency where a station modification added relief valves at local high points, without providing a means to maintain the piping adequately filled with water, following refueling outage maintenance, to avoid water hammer during system operation. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information you believe the NRC should consider, you may provide it in your response to the Notice. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.

Additionally, one finding of very low safety significance (Green) is documented in this report.

This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the NCV documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Oconee Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Oconee Nuclear Station.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000269 and 05000270 and 05000287 License Nos. DPR-38 and DPR-47 and DPR-55

Enclosures:

1. Notice of Violation 2. Inspection Report 05000269 and 05000270 and 05000287/2023010

Inspection Report

Docket Numbers:

05000269, 05000270 and 05000287

License Numbers:

DPR-38, DPR-47 and DPR-55

Report Numbers:

05000269/2023010, 05000270/2023010 and 05000287/2023010

Enterprise Identifier:

I-2023-010-0033

Licensee:

Duke Energy Carolinas, LLC

Facility:

Oconee Nuclear Station

Location:

Seneca, South Carolina

Inspection Dates:

May 1, 2023, to May 19, 2023

Inspectors:

D. Jackson, Senior Project Engineer

E. Robinson, Project Engineer

A. Ruh, Resident Inspector

W. Tejada, Physical Security 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 a biennial problem identification and resolution 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 Promptly Identify a Condition Adverse to Quality Associated with Low Pressure Service Water System Flow Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000269,05000270,05000287/

2023010-01 Open/Closed

[P.1] -

Identification 71152B The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify conditions adverse to quality. Specifically, the licensee failed to identify that deviations between system flow instruments could adversely affect the ability to determine whether the Units 1, 2 and 3 low pressure service water system (LPSW) pumps were capable of delivering adequate flow at a sufficient pressure to meet accident load demands.

Failure to Correct a Condition Adverse to Quality Associated with the Low Pressure Injection System Gas Accumulation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NOV 05000270/2023010-02 Open

[H.5] - Work Management 71152B The inspectors identified a Green cited violation of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, for the licensee's failure to correct a condition adverse to quality.

Specifically, the licensee failed to correct a deficiency where a station modification added relief valves at local high points, without providing a means to maintain the piping adequately filled with water, following refueling outage maintenance, to avoid water hammer during system operation. The above issue was previously identified in NCV 05000269,05000270/

2021001-01.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors conducted a review of the following systems or portions thereof:

low pressure service water; standby shutdown facility; and instrument air. The inspectors also conducted a five-year review of equipment aging issues. A sample of corrective actions for non-cited violations, minor violations, and findings issued since March 2021 were evaluated as part of the assessment.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B 1) Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was generally effective in identifying problems and entering them into the corrective action program (which includes the work management system), and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports and/or work orders/work requests, as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.

Problem Prioritization and Evaluation: Based on the review of condition reports, work orders, and work requests, the inspectors concluded that problems were prioritized and evaluated in accordance with licensee guidance. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that, in general, plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that, generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused.

However, the team identified one example in which a corrective action to address a condition adverse to quality (CORR) was closed without implementation associated with NRC-identified NCV 05000287/2022003-01, Failure to Use a Procedure Appropriate to the Circumstances While Changing a Unit 3 Spent Fuel Cooling Filter. Specifically, NCR 02429972, assignment 21 (CORR) was closed to a procedure revision request (PRR) which had not been completed. In accordance with the licensee's corrective action program procedure, PRRs are not an approved process for CORR closure.

Additionally, the team identified two violations associated with corrective action program effectiveness as documented in this report.

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.

2) Operating Experience The team determined that the stations processes for the use of industry and NRC operating experience information were effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures.

3) Self-Assessments and Audits The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified. The inspectors verified that action requests were created to document areas for improvement and findings, and verified that, generally, actions had been completed consistent with those recommendations.

4) Safety-Conscious Work Environment Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available. Based on interviews with plant staff and reviews of the latest safety culture survey results, the team found no evidence of challenges to a safety-conscious work environment.

Failure to Promptly Identify a Condition Adverse to Quality Associated with Low Pressure Service Water System Flow Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000269,05000270,05000287/

2023010-01 Open/Closed

[P.1] -

Identification 71152B The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify conditions adverse to quality. Specifically, the licensee failed to identify that deviations between system flow instruments could adversely affect the ability to determine whether the Units 1, 2 and 3 LPSW pumps were capable of delivering adequate flow at a sufficient pressure to meet accident load demands.

Description:

Updated Final Safety Analysis Report section 18.3.22, Performance Testing Activities, described that performance testing of the LPSW system is an aging management activity that will provide assurance that the components are capable of delivering adequate flow at a sufficient pressure as required to meet system and accident load demands. This activity is performed because it is a raw water system that could be affected by fouling. These activities are performed on an intermittent basis by collecting system data during performance of test procedure PT/*/A/0251/023, LPSW System Flow Test. With this plant data, system hydraulic models in calculations OSC-4671, Units 1 and 2 LPSW System Benchmark, and OSC-4488, Unit 3 LPSW System Benchmark, are adjusted until they acceptably match the performance test data. This modified model is then used in calculations OSC-4672 and OSC-4489 to predict LPSW system performance during accident conditions to demonstrate it can perform its safety function.

During review of these calculations and test data, inspectors identified that there was a sizeable deviation between the total indicated flow from system annubars located near the pumps versus the total of the flows measured at each of the major system loads (reactor building cooling units, low pressure injection coolers, component cooling coolers and non-essential header). Based on Unit 3 data collected in 2009, 2014, and 2018, the deviation implied the total annubar reading was between 13 and 19 percent higher than the total of the individual component loads. The licensee suspected that the elevated flowrates were due to fouling in the piping causing an effective reduction in pipe diameter or from their non-preferred physical location relative to nearby flow disturbances in the system.

Assessment of the same type of deviation for the Units 1 and 2 LPSW instruments was not precisely determinable because various flow paths existed that can bypass the installed annubars during system flow tests. Although the licensee used component flows rather than annubar flows for system benchmarking of the hydraulic models, inspectors identified that the accuracy of the indicated flow at the annubar was important because they were being used during periodic surveillance testing to verify the LPSW pumps were performing no more than 2 percent below the nominal pump curve. Verifying this minimum level of pump performance ensured that the results of OSC-4672 and OSC-4489 remained valid for predicting performance under accident conditions.

Inspectors were specifically concerned that the indicated flow during periodic surveillance testing could be inaccurately high to such a degree that the existing test acceptance criteria for developed differential pressure, at the indicated flowrate, would be substantially non-conservative for the actual flowrate being produced. In effect, if the pump was producing 20 percent less than the indicated flow, the pumps developed differential pressure would need to be approximately 14 percent higher than the minimum allowed by the quarterly test procedure. The most recent test data for the five station LPSW pumps showed the pumps were only producing differential pressure between 9 to 11 percent above the minimum allowed. As a result, the licensee evaluated operability of the LPSW system with the LPSW pumps operating at reduced capacities. The licensee determined that LPSW system operability was maintained, but this determination required that certain heat exchangers be evaluated for reduced flowrates by making use of operating margin available from recent heat transfer test results.

Corrective Actions: The licensee initiated actions to revise various system analyses to determine annubar accuracy and/or determine whether changes were necessary for quarterly pump testing.

Corrective Action References: 2473099

Performance Assessment:

Performance Deficiency: The licensees failure to promptly identify a condition adverse to quality during the performance of aging management activities was a performance deficiency.

Specifically, the licensee failed to recognize that an observed significant deviation between system flow instruments could adversely affect the ability to determine whether the Units 1, 2 and 3 LPSW pumps were capable of delivering adequate flow at a sufficient pressure to meet accident load demands.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the deviation in flow instruments implied the LPSW pumps were performing below the minimum acceptable value assumed in system design analyses, which created a reasonable doubt on the capability of the pumps to perform their safety function.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding to be of very low safety significance (Green) because it was a deficiency affecting the design of the Unit 1, 2 and 3 LPSW systems, but once the licensee revised related system analyses, the licensee concluded the systems maintained their operability.

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. In this case, during recent system performance tests, the licensee failed to recognize the flow deviations impact on assessing the functional capability of the LPSW systems.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states in part that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and non-conformances are promptly identified and corrected. Contrary to the above, since 2014, the station failed to promptly identify a condition adverse to quality during the performance of aging management activities. Specifically, the licensee failed to identify that deviations between system flow instruments could adversely affect the ability to determine whether the Units 1, 2 and 3 LPSW pumps were capable of delivering adequate flow at a sufficient pressure to meet accident load demands.

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

Failure to Correct a Condition Adverse to Quality Associated with the Low Pressure Injection System Gas Accumulation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NOV 05000270/2023010-02 Open

[H.5] - Work Management 71152B The inspectors identified a Green cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensee's failure to correct a condition adverse to quality. Specifically, the licensee failed to correct a deficiency where a station modification added relief valves at local high points, without providing a means to maintain the piping adequately filled with water, following refueling outage maintenance, to avoid water hammer during system operation. The above issue was previously identified in NCV 05000269,05000270/2021001-01.

Description:

In 2005, station modification ON-23106, ECCS - EOPI Reroute Lines in RB Emergency Sump, added new piping and relief valves to the suction side of the low pressure injection (LPI) system on Unit 2. The design basis purpose of these suction header relief valves included limiting the pressurization of an idle trains suction header to approximately 150 psi from cross-train leakage past valves on the discharge of the opposite, operating train.

These pressure-reducing relief valves (LP-195 and LP-196) were designed to preserve emergency core cooling system inventory by relieving pressure back to the suction of the operating train. This design was implemented so that the pressure from an operating pump (up to 230 psi) would not lift other system safety relief valves (LP-26 and LP-27) that could discharge highly contaminated reactor building emergency sump water into vented tanks in the auxiliary building during an accident.

Since LP-195 and LP-196 were designed to discharge into the pressurized LPI system, the licensee selected a balanced bellows design to prevent potentially variable system backpressure from affecting the valves set point. Integrity of this bellows was important because its failure during an accident could result in uncontrolled leakage of reactor building emergency sump water into the auxiliary building through an intentionally open vent port in the bonnet of the valve. According to the valve vendor, the bellows had a design pressure rating for 230 psi. The modification installed the valves with new piping in the Unit 2 A train LPI pump rooms that contained the A and C LPI pumps and A reactor building spray pump. The piping was routed in such a manner that it created new high points that could trap air and other gasses, but no vents were included in the design. Additionally, system fill and vent procedure OP/2/A/1104/004 B, LPI System Fill and Startup, was not updated in a manner that would prevent gas from accumulating in these pipes following refueling outage maintenance that drained and refilled the piping. As a result of not managing gas accumulation in these areas, the valves bellows were vulnerable to being exposed to dynamic pressures that could exceed their design pressure.

On February 28, 2023, LPI system suction relief valve 2LP-196 experienced an internal bellows failure during a quarterly test of the 2B LPI pump. This particular valve location experienced the same type of failure in October 2019. A causal factor for the first failure was the subject of a previous NRC-identified NCV 05000269,05000270/2021001-01, Inadequate Design Control of Low Pressure Injection System Modification, where station procedures were identified as not being adequate to ensure the system piping was adequately filled with water following refueling outage maintenance to avoid water hammer during system operation. NCR 2297905 assignment 9 was originated on March 25, 2021, to track revision of OP/2/A/1104/004 B to include instructions for vacuum filling the piping containing the suction relief valves when the system was being refilled after maintenance. Many extensions were granted for this corrective action assignment because work order 20499761 was initiated as an interim measure to vacuum fill this piping during the Unit 2 fall 2021 refueling outage. The inspectors noted that this work order was improperly characterized as not being associated with a condition adverse to quality and was cancelled during the outage, which meant the interim measure was not accomplished prior to startup of the LPI system. Similar to the October 2019 failure, subsequent cross-train leakage during routine surveillance testing of the system caused repetitive high backpressure events to eventually compromise the integrity of the bellows on February 28, 2023. Inspectors reviewed a completed equipment checklist for the February failure and noted that the lack of corrective action associated with the system filling procedure was not identified as a causal factor. The licensee subsequently documented these NRC-identified issues in the corrective action program.

Corrective Actions: The licensee revised OP/2/A/1104/004 B to include instructions to vacuum fill the LPI suction relief valve lines when maintenance activities drained those areas.

Additionally, the licensee promptly executed these revised instructions on the piping associated with relief valve 2LP-195 since only the piping associated with relief valve 2LP-196 had been vacuum filled after repairing the February 28, 2023, failure.

Corrective Action References: 2297905, 2366042, 2463200, 2472973

Performance Assessment:

Performance Deficiency: The licensee's failure to correct a condition adverse to quality with operations procedure OP/2/A/1104/004 B, LPI System Fill and Startup, was a performance deficiency. Specifically, NCR 2297905 identified that the procedure needed to be revised to prevent air voids from accumulating in the LPI suction relief valve piping following maintenance activities that drained this area; however, the station failed to implement these corrective actions before the Unit 2 LPI system was drained and refilled during the fall 2021 refueling outage.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the procedure deficiency led to an equipment performance issue that increased the likelihood of an interfacing system loss of coolant accident. In this case, a relief valve bellows failed, resulting in external leakage on February 28, 2023.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 1, Initiating Events Screening Questions, a detailed risk evaluation was required because, after a reasonable assessment of the degradation, the finding could have likely affected other systems used to mitigate a loss of coolant accident (LOCA) (e.g., Interfacing System LOCA). Specifically, leakage of post-LOCA emergency sump fluid into the LPI pump room as a result of a relief valve bellows failure could cause multiple adverse effects to mitigating equipment. Internal flooding of the room would affect the long-term availability of the 2A and 2C LPI pumps and the 2A reactor building spray pump. Isolation of the leak during an accident could also render the A LPI suction header unavailable. A regional senior risk analyst previously performed a detailed risk assessment for the same degraded condition as documented in NCV 05000269,05000270/2021001-01, which concluded the finding was of very low safety significance (Green). This same conclusion was appropriate because the leakage rate was less than the rate that could inundate the rooms pump motors within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the radiological impacts to control room habitability also screened to Green.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. In this case, the licensee inappropriately characterized and cancelled a planned work order during a refueling outage which prevented resolving a nuclear safety issue.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and non-conformances are promptly identified and corrected. Contrary to the above, from March 25, 2021, to May 22, 2023, the station failed to correct a condition adverse to quality.

Specifically, the licensee failed to correct the deficiency identified in NCV 05000269,05000270/2021001-01, that station modification ON-23106 added relief valves at local high points, without providing a means to maintain the piping adequately filled with water, following refueling outage maintenance, to avoid water hammer during system operation.

Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

On May 23, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Steven Snider and other members of the licensee staff.

On June 26, 2023, the inspectors presented the biennial problem identification and resolution final inspection results to Steven Snider and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OSC-11699

Units 1 & 2 LPSW Hydraulic Model

OSC-3922

Units 1 & 2 LPSW System Flow Model

OSC-4488

Unit 3 LPSW System Benchmark

OSC-4489

Predicted Unit 3 LPSW System Response to a Large-Break

LOCA with Single Failure Using a Benchmarked Hydraulic

Computer Model

OSC-4671

Units 1 & 2 LPSW System Benchmark

OSC-4672

Units 1 & 2 LPSW System LOCA / LOOP Response (TYPE

1)

OSC-5675

Generic Letter 89-10 Calculation for Unit 2 Gate and Globe

Valves at Oconee

OSC-5771

PRA Risk Significant SSCs for Maintenance Rule

Calculations

OSC-7734

Maximum Hypothetical Accident (MHA) Dose Analysis

(Design Basis Radiological Accident Dose Analysis)

71152B

Corrective Action

Documents

22296, 1860209, 1904849, 1904926, 1905579, 1910280,

2114982, 2119055, 2132842, 2146280, 2230445, 2244461,

247523, 2259714, 2261347, 2266374, 2276572, 2276864,

2305752, 2324012, 2336294, 2357711, 2362920, 2362921,

2363046, 2364796, 2367963, 2372374, 2373308, 2373514,

2373708, 2373733, 2376401, 2376426, 2376507, 2376721,

2376822, 2376823, 2377500, 2377819, 2377849, 2378003,

2378756, 2379874, 2379921, 2379936, 2380161, 2380714,

2380736, 2380939, 2381631, 2383182, 2383450, 2383477,

2384248, 2385844, 2386050, 2386259, 2386438, 2386725,

2387761, 2388614, 2391010, 2391095, 2391434, 2392172,

2392364, 2393303, 2393844, 2394153, 2394155, 2394428,

2394429, 2394462, 2398855, 2399045, 2400130, 2401139,

2401395, 2403757, 2403854, 2404429, 2405875, 2405947,

2406969, 2406977, 2407202, 2408602, 2408835, 2409104,

2411493, 2411953, 2413538, 2414859, 2414891, 2414906,

2415999, 2421758, 2422326, 2426486, 2426544, 2427523,

29972, 2433048, 2434074, 2434994, 2435461, 2436640,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2443366, 2446661, 2446669, 2453284, 2457193, 2461935,

2462864, 2463200, 2464333, 2466317, 2469304

2471608

23 ONS PI&R AD-SY-ALL-0150 QA Records

2472973

Actions Addressing 2LP-196 Bellows Leakage (2023 PI&R

Inspection)

2473099

23 ONS PI&R - LPSW Pump Testing Concerns due to

Flow Instrument Inaccuracy

2473152

CORR assignment closed out to unapproved process (ONS

PI&R)

2473261

Control Room Envelope Boundary Leak on AHU 3-14

Corrective Action

Documents

Resulting from

Inspection

2473594

AD-WC-ALL-0210 Prioritization Guidance Ambiguity for

Security Items (ONS PI&R)

O-0400-B

Piping Layout Basement Floor Plan Turbine Building

167

O-0500-A

Heating - Ventilation - Air Conditioning, Auxiliary Building,

General Notes

O-422H-46

Instrument Details Low Pressure Service Water Pump Flow

for Pump C

OM 267.899.001

Industrial Annubar Flow Calculation

OM 267.A-

0049.001

ANF 76 Annubar C07, M07, F07CS SH 1 Of 2

ONTC-1-124A-

0001-001

Unit 1&2 LPSW Pump Test Acceptance Criteria

Drawings

ONTC-3-124A-

0001-001

Unit 3 LPSW Pump Test Acceptance Criteria

Standard Audit Plan - Physical Security Rev 0

Miscellaneous

OSS-0254.00-00-

21

Design Basis Specification for the Control Room Ventilation

System

AD-DC-ALL-0002

Records Procedure

AD-DC-ALL-0003

Management of Nuclear Records

AD-EG-ALL-1210

Maintenance Rule Program

AD-PI-ALL-0100

Corrective Action Program

AD-PI-ALL-0105

Effectiveness Reviews

1, 2, 3

AD-PI-ALL-0400

Operating Experience Program

Procedures

AD-SY-ALL-0110

Protection of Information Related to Nuclear Security

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AD-TQ-ALL-0100

Analysis

4, 5

AD-TQ-ALL-0101

Conduct of the Systematic Approach to Training

AD-WC-ALL-0210

Work Request Initiation

AD-WC-ALL-0250

Work Implementation and Completion

CO-FLT-EP-ERO-

OSC-320

PSG On-Site and Off-Site Field Monitoring Team

CSD-AD-ALL-

0004-01

Corrective Action Program Review Meeting

CSD-AD-NGO-

0004-19

Corporate Oversight Alignment Meeting

IP/1-2/A/0250/001

B

Low Pressure Service Water Pump Discharge Pressure and

Motor Temperature Instrument Calibration

OP/2/A/1104/004

B

LPI System Fill and Startup

OP/3/A/1107/014

Removal and Restoration of 4160V Switchgear and 600V

Load Centers

37, 38

PT/0/A/0110/024

Control Room Pressurization System Configuration for

Tracer Gas Inleakage Test

PT/0/A/0110/025

Control Room Envelope Habitability Program

PT/1/A/0251/023

LPSW System Flow Test

PT/2/A/0251/023

LPSW System Flow Test

PT/3/A/0251/023

LPSW System Flow Test

2457569, 2409616, 2362930, 2372137, 2302471, 2452015,

23-ONS-SEC-01

23-ONS-EMP-PR-01

22-ONS-SEC-PR-01

Self-Assessments

Control Room Habitability Assessment

2/23/20

Work Orders

20499761, 20572218, 20573550, 20571251, 20519329,

20460323, 20448766, 20372761, 20312076, 20306957,

248553, 20172819, 20500888, 20582077, 20561193,

207207, 20485639, 20197422, 20198177, 20198208,

20198298, 20198927, 20220458, 20200460, 20200462,

200491, 20202472, 20203126