IR 05000269/2024002
| ML24201A090 | |
| Person / Time | |
|---|---|
| Site: | Oconee  (DPR-038, DPR-047, DPR-055) |
| Issue date: | 07/25/2024 |
| From: | Eric Stamm NRC/RGN-II/DRP/RPB1 |
| To: | Snider S Duke Energy Carolinas |
| References | |
| IR 2024002 | |
| Download: ML24201A090 (27) | |
Text
SUBJECT:
OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2024002 AND 05000270/2024002 AND 05000287/2024002
Dear Steven Snider:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On July 24, 2024, 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. 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 violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Oconee Nuclear Station.
July 25, 2024 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
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000269, 05000270 and 05000287
License Numbers:
Report Numbers:
05000269/2024002, 05000270/2024002 and 05000287/2024002
Enterprise Identifier:
I-2024-002-0022
Licensee:
Duke Energy Carolinas, LLC
Facility:
Oconee Nuclear Station
Location:
Seneca, South Carolina
Inspection Dates:
April 1, 2024, to June 30, 2024
Inspectors:
N. Smalley, Senior Resident Inspector
E. Robinson, Resident Inspector
D. Dang, Resident Inspector, Acting
B. Bowker, Reactor Inspector
A. Hutto, Senior Project Engineer
J. Nadel, Reactor Inspector
E. Riggs, Senior Technical Training Program Specialist
A. Ruh, Senior Reactor Inspector
J. Vasquez, 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 Maintain Fire Penetration in Accordance with Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000269/2024002-01 Open/Closed None (NPP)71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Oconee Nuclear Station Units 1, 2, and 3, Renewed Facility Operating License Condition 3.D for the licensees failure to maintain in effect all provisions of the approved fire protection program.
Specifically, the licensee failed to ensure that the fire resistive penetration seal assembly in fire penetration 1-M-N-5 was installed to the correct seal thickness per plant design drawings.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000270/2023-001-00 Oconee Nuclear Station Unit 2,
Inappropriate Procedural Guidance for Planned Online Maintenance Results in Event or Condition that Could Have Prevented Fulfillment of a Safety Function 71153 Closed LER 05000287/2023-002-00 Oconee Nuclear Station, Unit 3,
Passive Containment Isolation Device Inoperability Results in Operation or Condition Prohibited by Technical Specifications 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, with the exception of a temporary power reduction to 96 percent RTP on May 1, 2024, as required to implement a measurement uncertainty recapture power uprate from 2568 megawatts to 2608 megawatts core thermal power.
Unit 3 began the inspection period at or near 100 percent RTP. On May 4, 2024, Unit 3 was shut down for a scheduled refueling outage (O3R32). During startup, on May 29, 2024, Unit 3 was limited to 74 percent RTP following unexpected measured high assembly power for assembly location H-05. On June 2, 2024, Unit 3 was shut down for a maintenance outage (O3F32A) to replace two burnable poison rod assemblies (BPRAs) that had incorrect boron concentrations. During O3F32A, indications of a leaking fuel assembly were discovered, independent of the faulty BPRAs. The leaking assembly was isolated and replaced, with no indications of significant fuel damage. The unit was returned to 100 percent RTP on June 20, 2024, and operated at or near 100 percent RTP for the remainder of the 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Standby shutdown facility, protected service water and alternate reactor building cooling portable submersible pump equipment on April 15, 19, and 25, 2024
- (3) Unit 3 low pressure injection system during O3R32 refueling outage on May 21, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 105: Unit 2 cable room on April 16, 2024
- (2) Fire zone 108: Unit 1 east penetration room on April 30, 2024
- (3) Fire zone 89: Unit 3 equipment room on May 22, 2024
- (4) Fire zone 124: Unit 3 containment on May 24, 2024
- (5) Fire zone 112: Unit 3 control room on May 28, 2024
- (6) Fire zone 85: Unit 1 auxiliary building 200 level hallway on June 10, 2024
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 1 reactor building cooling units following performance testing per PT/0/A/0160/006, Reactor Building Cooling Units Performance Test, on April 23 and April 24, 2024
===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 3 during refueling outage O3R32 from May 6 to May 17, 2024.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic Examination (UT)
- 3-RC-212-53V, high pressure injection (HPI) nozzle to safe end, ASME Class 1
- 3-PDB1-46, HPI nozzle inner radius, ASME Class 1
- 3-PDB2-11, HPI nozzle to safe end, ASME Class 1
- 3-PDB2-46, HPI nozzle inner radius, ASME Class 1
Radiographic Examination
- 3-LP-0182-10, low pressure injection (LPI) pipe to valve, ASME Class 2 (associated with work order (WO) 20397347)
- 3-LP-0182-11, LPI valve to pipe, ASME Class 2 (associated with WO 20397347)
Dye Penetrant Examination
- 3-03-0-2401A-SR3, feedwater (FDW) pipe support, ASME Class 3
- 3-LP-0 182-11, 3A LPI header test line, ASME Class 2 (associated with WO 20397347)
Magnetic Particle Examination
- 3-LPS-0769-68, ASME Class 3 (associated with WO 20547399)
- 3-LPS-0769-69, ASME Class 3 (associated with WO 20547399)
Visual Examination
- 3-RPV-BMI nozzles, bare metal VT-2 exam, ASME Class 1
- B4.30 VT-2 on the reactor pressure vessel head, bare metal visual, ASME Class 1 Welding Activities
- Gas tungsten arc welding o
WO 20397347-13, 3A LPI HDR test line, 3" gate valve, ASME Class 2 o
WO 20547399, new 18" valve 3LPSW-1236 and piping, ASME Class 3 PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection
Activities (IP Section 03.02) (1 Sample)
The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:
- (1) Bare metal visual examination of the reactor pressure vessel upper head, ASME Class 1 PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
- Boric acid walkdown - May 7, 2024
- Review of boric acid evaluations o
Action request (AR) 02477429 o
- Review of corrective actions performed for evidence of boric acid leaks that were identified o
Work request (WR) 20268607 o
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 power ascension for Unit 2 due to the power uprate from the main control room on May 1, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated simulator just in time training for power escalation using lesson plan OP-OC-20JT-06 on June 12, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
- (1) C low pressure service water pump (LPSW) pump lubricating oil sampling and addition using commercial grade dedicated oil, WO 20645573
- (2) Nuclear condition report (NCR) 2473173, Unit 1/2 C LPSW pump tripped after maintenance on May 17, 2023
- (3) NCR 2501851, Keowee hydro unit air circuit breaker, ACB-1, failed to open on shutdown on January 22, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 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 due to planned maintenance on the primary instrument air compressor, on April 9, 2024
- (2) Units 1 and 2 green risk due to maintenance for the C train of LPSW, on April 18, 2024
- (3) Units 1, 2, and 3 green risk due to maintenance for protected service water primary and booster pump, on April 26, 2024
- (4) Unit 3 yellow risk due to reactor coolant system draining and lowered inventory operations, on May 5 and May 6, 2024
- (5) Units 1, 2, and 3 green risk following issuance of a tornado watch, on May 8, 2024
- (6) Unit 3 yellow risk due to reactor coolant system draining and lowered inventory operations, on June 4 and June 5, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (3) NCR 2512430, unexpected bearing cooling water alarms during KHU-2 starts
- (4) NCR 2517136, debris discovered in Unit 3 borated water storage tank
- (5) NCR 2517412, Unit 3 core high assembly power at H-05 on power escalation following O3R32 refueling outage
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 modification:
- (1) AR 2403542, replacement of axial power shaping rod assemblies for all 3 units
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated refueling outage O3R32 activities from May 4 to May 29, 2024
- (2) The inspectors evaluated forced outage O3F32A activities from June 2 to June 20, 2024
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) (8 Samples)
- (1) PT/1/A/0251/001, "C Low Pressure Service Water Pump Test," following oil sampling and seal regulator maintenance, on April 19, 2024
- (2) TT/2/A/0261/021, "CCW Pump Flange Seal Data Collection Test," of 2D condenser circulating water pump, on May 1, 2024, following installation of engineering change
===422106
- (3) PT/3/A/0600/012, "Turbine Driven Emergency Feedwater Pump Test," following outage maintenance, on May 22, 2024
- (4) PT/3/A/0151/019, "Penetration 19 Leak Rate Test," following preventive maintenance on reactor building purge valves, on May 22, 2024
- (5) PT/0/A/0711/001, "Zero Power Physics Test," on May 25, 2024
- (6) PT/3/A/0811/001, "Power Imbalance Correlation Test," on Unit 3 following refueling outage, on May 28, 2024
- (7) PT/2/A/2200/011, "KHU-2 Turbine Guide Bearing Oil System Retest," following motor contact inspection, on June 8, 2024
- (8) PT/1/A/0600/13, "1A MDEFW Pump Test," following maintenance, on June 11, 2024 Surveillance Testing (IP Section 03.01)===
- (1) PT/3/A/0261/010, "Essential Siphon Vacuum System Pump Tests," on Unit 3, on April 11 and April 15, 2024
- (2) PT/3/A/0610/001, "J Emergency Power Switching Logic (EPSL) Loadshed Test," on May 17, 2024
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (2 Samples)
- (1) PT/3/A/0151/029, "Penetration 29 Leak Rate Test," on Unit 3, on May 15, 2024
- (2) PT/3/A/0151/019, "Penetration 19 Leak Rate Test," on Unit 3, on June 12, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) The inspectors observed and evaluated a simulator drill and exercise performance examination using lesson plan ASE-13 on June 25,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2023, through March 31, 2024)
- (2) Unit 2 (April 1, 2023, through March 31, 2024)
- (3) Unit 3 (April 1, 2023, through March 31, 2024)
MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)
- (1) Unit 1 (April 1, 2023, through March 31, 2024)
- (2) Unit 2 (April 1, 2023, through March 31, 2024)
- (3) Unit 3 (April 1, 2023, through March 31, 2024)
MS10: Cooling Water Support Systems (IP Section 02.09) (3 Samples)
- (1) Unit 1 (April 1, 2023, through March 31, 2024)
- (2) Unit 2 (April 1, 2023, through March 31, 2024)
- (3) Unit 3 (April 1, 2023, through March 31, 2024)
BI02: RCS Leak Rate Sample (IP Section 02.11) (3 Samples)
- (1) Unit 1 (April 1, 2023, through March 31, 2024)
- (2) Unit 2 (April 1, 2023, through March 31, 2024)
- (3) Unit 3 (April 1, 2023, through March 31, 2024)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) NCR 2516804, Part 21 notification for potential defect of AMETEK oil filled aluminum case capacitors - 07-020139-10
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material issues and foreign material exclusion controls during refueling outages that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
- (1) LER 05000270/2023-001-00, Inappropriate Procedural Guidance for Planned Online Maintenance Results in Event or Condition that Could Have Prevented Fulfillment of a Safety Function (ADAMS Accession No. ML24060A312). The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2023011 (ADAMS Accession No. ML23236A615)under Inspection Results Section 71111.21M. This LER is Closed.
- (2) LER 05000287/2023-002-00, Passive Containment Isolation Device Inoperability Results in Operation or Condition Prohibited by Technical Specifications (ADAMS Accession No. ML24060A311). The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2023004 (ADAMS Accession No. ML24038A367) under Inspection Results Section 71152A.
This LER is Closed.
INSPECTION RESULTS
Failure to Maintain Fire Penetration in Accordance with Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000269/2024002-01 Open/Closed None (NPP)71111.05 The inspectors identified a Green finding and associated NCV of Oconee Nuclear Station Units 1, 2, and 3, Renewed Facility Operating License Condition 3.D for the licensees failure to maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to ensure that the fire resistive penetration seal assembly in fire penetration 1-M-N-5 was installed to the correct seal thickness per plant design drawings.
Description:
On March 14, 2024, during a fire protection walkdown of the Unit 1 east penetration room, the inspectors identified a potentially degraded fire barrier penetration, 1-M-N-5, a 5-inch pipe passing through the wall above door 401B between the Unit 1 cable room and the Unit 1 east penetration room. Although the penetration seal was flush with the wall, inspectors noted possible degradation with signs of potential loss of foam insulation in the seal assembly. The inspectors informed the licensee operations staff and the fire protection engineer, who determined that the penetration seal was non-functional. The licensee established an hourly fire watch and documented the condition in the corrective action program as NCR 2508926.
The licensee determined through a destructive examination that the wall containing penetration 1-M-N-5 had a thickness of only eight inches. This was contrary to the dimensional data listed in the equipment database (EDB), the established method of design control for plant equipment. The EDB had listed 1-M-N-5 as a penetration of 12 inches thick.
Additionally, the penetration was installed with foam insulation seal, but the EDB incorrectly listed a grout seal design. Procedure MP/1/A/1705/018, Fire Protection - Penetration - Fire and Flood Barrier - Inspection and Minor Repair, is used for periodic external visual inspection and repair of fire penetrations such as 1-M-N-5. The licensee identified that this procedure had listed the wall containing this penetration as being 12 inches thick as far back as 1998. Around this time, an effort was undertaken by the licensee to re-inspect and repair many fire penetrations as well as implement the EDB as the method of design control. The engineering change (EC) implemented in 1999, established EDB entries and issued drawings for maintenance and inspection of penetration seals. This information was then used to update inspection procedure MP/1/A/1705/018.
The licensee concluded that the most likely cause of the dimensional design discrepancies was an improper interpretation of plant drawings during the establishment of the EDB and implementation of the EC in 1999. The licensee completed inspections of penetration 1-M-N-5 several times since 1999 per MP/1/A/1705/018. The licensee used drawing O-0310-KM-001 to verify correct penetration seal design. Based on the wall thickness of the penetration in question, the licensee would refer to either Detail M-1 or M-2 for a barrier thickness of less than 12 inches or equal to or greater than 12 inches, respectively. Based on the flawed penetration thickness listed as 12 inches in MP/1/A/1705/018, the visual condition of the penetration would have been acceptable per Detail M-2 as 12 inches of seal material would have been present. However, with the current plant configuration of the penetration being only 8 inches in thickness and the penetration seal being flush with the wall surface, the penetration would not have been acceptable in accordance with Detail M-1 of O-0310-KM-001. Specifically, penetration 1-M-N-5 would be required to have a minimum of 12 inches of foam insulation, extending beyond the barrier plane to achieve the required seal depth. The maintenance procedures consist of external visual inspections, which allowed the as-built configuration being different from the procedure stated wall thickness to go unrecognized since 1999.
Corrective Actions: The licensee declared the penetration non-functional and set an hourly fire watch. Additionally, the correct penetration depth and seal design was determined, and the fire penetration seal was repaired and restored to a functional condition (12-inch foam insulation thickness). The equipment database and associated maintenance procedures for inspection and repair were corrected to reflect actual plant conditions.
Corrective Action References: NCRs 2508926, 2509983
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to maintain fire penetration 1-M-N-5 in accordance with drawing O-0310-KM-001, Penetration Seal Configuration Mechanical Fire Penetration Seal Designs Details M-1 & M-2, was a performance deficiency. Specifically, the licensee failed to ensure that penetration 1-M-N-5 was maintained with a minimum of 12 inches of foam insulation per Detail M-1 to ensure that the 3-hour rated fire boundary was functional as required by the fire protection program.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, fire penetration 1-M-N-5 separates two high risk fire zones in the auxiliary building and was declared non-functional, adversely impacting the 3-hour fire boundary. Additionally, this performance deficiency is similar to the more than minor Example 2.d in Inspection Manual Chapter (IMC) 0612 Appendix E, Examples of Minor Issues.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding was assigned to category 1.4.4 Fire Confinement with a High Degradation rating because greater than 10 percent of the required foam seal depth was missing. Using IMC 0609, Appendix F, 1, Step 1.4.4-E, the inspectors determined that if a fire were to spread from one fire area to another due to the degraded fire barrier, no additional targets would be damaged in the exposed fire area that could impact the credited safe shutdown strategy for the exposing fire area. Therefore, the inspectors determined that the finding was of very low safety significance (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: Oconee Nuclear Station Units 1, 2, and 3, Renewed Facility Operating License Condition 3.D required, in part, Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a)and 10 CFR 50.48(c) and NFPA 805. NFPA 805, Section 3.11.4, requires, in part, that through penetration fire stops shall be protected such that the annular space between the penetrating item and the through opening in the fire barrier shall be filled with a qualified fire resistive penetration seal assembly capable of maintaining the fire resistance of the fire barrier. Oconee implemented this requirement through drawing O-0310-KM-001, Penetration Seal Configuration Mechanical Fire Penetration Seal Designs Details M-1 & M-2, via the licensee's design control equipment database. Fire Penetration 1-M-N-5 is a pipe penetration with a foam seal assembly through an 8-inch fire barrier and is required to be maintained in accordance with Detail M-1 (12-inch foam insulation thickness) of drawing O-0310-KM-001.
Contrary to the above, from at least 1999 until March 15, 2024, the licensee failed to implement and maintain in effect, all provisions of the approved fire protection program as required by drawing O-0310-KM-001. Specifically, the licensee failed to maintain fire penetration 1-M-N-5 in accordance with Detail M-1 of drawing O-0310-KM-001.
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 May 9, 2024, the inspectors presented the inservice inspection results to Steven Snider and other members of the licensee staff.
- On July 24, 2024, the inspectors presented the integrated inspection results to Steven Snider and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2512968
OFD-102A-3.1
Flow Diagram of Low Pressure Injection System (Borated
Water Supply and LPI Pump Suction)
065
OFD-102A-3.2
Flow Diagram of Low Pressure Injection System (LPI Pump
Discharge)
049
OFD-102A-3.3
Flow Diagram of Low Pressure Injection System (Core
Flood)
25
Drawings
OFD-121D-1.1
Flow Diagram of Emergency Feedwater System
038
Miscellaneous
Clearance PRT-3 -24-3A LPI TRAIN-0109
OSC-9293
NFPA 805 Transition Radioactive Release G-1 Table
004
OSC-9314
NFPA 805 Transition Risk-Informed Performance-Based
Fire Risk Evaluation
006
Calculations
OSC-9659
Oconee Nuclear Safety Capability Assessment for Units 1,
2, and 3
011
Corrective Action
Documents
2508926
CSD-ONS-PFP-
Pre-Fire Plan for U1 Auxiliary Building Elevation 783
000
CSD-ONS-PFP-
Pre-Fire Plan for U1 Auxiliary Building Elevation 809
000
CSD-ONS-PFP-
Pre-Fire Plan for U2 Auxiliary Building Elevation 809
000
CSD-ONS-PFP-
Pre-Fire Plan for Unit 3 Auxiliary Building Elevation 796
001
CSD-ONS-PFP-
Pre-Fire Plan for Unit 3 Auxiliary Building Elevation 822
000
Fire Plans
CSD-ONS-PFP-
3RB
Pre-Fire Plan for U3 Reactor Building All Elevations
000
O-0310-FZ-006
Auxiliary Building - Units 1 Fire Protection Plan Fire Area &
Fire Zone Boundaries Plan at EL 783 + 9
003
Miscellaneous
O-0310-FZ-011
Auxiliary Building - Unit 3 Fire Protection Plan Fire Area &
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Fire Zone Boundaries Plan at EL 796+6 & 797+6
O-0310-FZ-017
Auxiliary & Reactor Building - Unit 3 Fire Protection Plan
Fire Area & Fire Zone Boundaries Plan at EL 822+0 & EL
25+0
003
O-0310-FZ-023
Reactor Building - Units 3 Fire Protection Plan Fire Area &
Fire Zone Boundaries Plan at EL 861 + 6
001
O-0310-K-004
Fire Protection Auxiliary Building Unit 1 EL 783 + 9
009
O-0310-K-009
Fire Protection Auxiliary Building Unit 3 EL 796+6
015
O-0310-K-010
Auxiliary Building Unit 1 Fire Protection Plan & Fire Barrier,
Flood & Pressure Boundaries Plan at EL 809+3
O-0310-K-015
Fire Protect Auxiliary Building Unit 3 EL 822+0
017
O-0310-K-018
Auxiliary & Reactor Building Unit 3 Fire Protection Plant &
Fire Barrier, Flood, & Pressure Boundaries Plant at EL 838 +
0, EL 844 + 6, Below EL 876 + 0 and Below EL 886 +5
O-0310-K-021
Reactor Building - Unit 3 Fire Protection Plan & Fire Barrier,
Flood & Pressure Boundaries Plan at EL 861 + 6
O-0310-KM-001
Penetration Seal Configuration Mechanical Fire Penetration
Seal Designs Details M-1 & M-2
AD-FP-ALL-1520
Transient Combustible Control
001
MP/0/A/1705/027
Fire Protection - Fire Barrier Penetrations - Installation and
Repair Using Silicone Foam and Damming Material
047
Procedures
MP/1/A/1705/018
Fire Protection - Penetration - Fire and Flood Barrier -
Inspection and Minor Repair
2
Work Orders
265272
Calculations
OSC-11956
Reactor Building Cooling Units Performance Test
Corrective Action
Documents
2510287, 2438405, 2479288, 2507201, 2515539
Miscellaneous
ONEI-0400-400
Revised Reactor Building Cooling Unit (RBCU)
Requirements in Support of 1-Year Mission Times
Work Orders
20653985
Miscellaneous
Power Escalation JITT, OP-OC-20JT-06
AD-OP-All-0106
Conduct Of Infrequently Performed Tests Or Evolutions
Procedures
AD-OP-ALL-1000
Conduct of Operations
23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-OP-ALL-1001
Abnormal Conduct of Operations
006
AD-OP-ONS-
0002
Oconee Specific Abnormal Operations Guidance
007
AP/0/A/1700/047
External Flood Mitigation
29
OP/2/A/1102/004
Operation at Power
134
Corrective Action
Documents
2473173, 2466960, 2501851, 2355727, 2357958, 2365144,
2446131, 2356835, 2356873, 2503151, 2453446
Drawings
KEE-114
Elementary Diagram Generator Control ACB-1 Control
Circuit
Engineering
Changes
403225
Lubrication Datasheet for ON0LPSPU000C
04/18/2024
Miscellaneous
OSS-0254.00-
2005
(ELECT) Keowee Emergency Power Design Basis
Document
035
AD-EG-ALL-1103
Procurement Engineering Products
Procedures
PT/0/A/0251/029
Siphon Seal Water System Test
Work Orders
262241, 20433314, 20643793, 20447425, 20654745
Corrective Action
Documents
2490772, 2490763
Drawings
OFD-137B-1.1
Flow Diagram of Instrument Air System (Air Compressors,
After Coolers, Receivers, Air Dryers)
Phoenix ONS Risk Profile for all Units on the week of April
2, 2024
Phoenix ONS Risk Profile for Unit 3 on the week of June 3,
24
Miscellaneous
OSS-0254.00-00-
25
Design Basis Specification for the Instrument Air System
018
AD-OP-ALL-0106
Conduct of Infrequently Performed Tests or Evolutions
AD-WC-ALL-0240
On-line Risk Management Process
AD-WC-ALL-0410
Work Activity Integrated Risk Management
AD-WC-ALL-0420
Shutdown Risk Management
Rev 8
AD-WC-ALL-0420
Shutdown Risk Management
Procedures
AD-WC-ALL-0430
Outage Risk Review
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-WC-ONS-
20
ONS Shutdown Risk Management
AD-WC-ONS-
20
ONS Shutdown Risk Management
Rev 5
AP/0/A/1700/006
Natural Disaster
Rev 35
AP/3/A/1700/022
Loss of Instrument Air
29
MP/0/B/3007/049
Compressors - Primary Instrument Air - Sullair - Model 32-
25-400 - Preventive Maintenance
29
OP/0/A/1102/026
Operations IPTE Pre-Job Briefings
033
OP/0/A/1106/027
Instrument Air System
28
PT/0/A/0500/001
Protected Service Water Primary and Booster Pump Test
007
Work Orders
20599978, 20647911
OSC-7220.81
Supporting Design Analyses for ONS 3 EC 424255
Evaluation for Acceptability of Existing Indications on the
000
Calculations
OSC-9033
Risk Significance Evaluation of Sump Outlet Pipe Foreign
Material
Corrective Action
Documents
2511743, 2503915, PIP-O-05-05720, PIP-O-11-09953,
2511097, 2487656, 2512045, 2441303, 2483549, 2511097,
2517412, 2517443, 2517450, 2517461, 2517929, 2515886,
2354522, 2517136, 1761227, 2317886, 2517379, 2515786
KEE-213-2
Elementary Diagram Master Control System Gen.
Miscellaneous Relaying
KFD-100A-2.1
Flow Diagram of Turbine Generator Cooling Water System
Drawings
OFD-124A-3.1
Flow Diagram of Low Pressure Service Water System
Turbine BLDG. (Low Pressure Service Water Pumps)
000
ONEI-0400-592
Oconee 3 Cycle 33 Final Core Load Map
000
ONEI-0400-598
Oconee 3 Cycle 33 Core Operating Limits Report
000
OSS-0254.00-00-
2005
(Elect) Keowee Emergency Power Design Basis Document
034
Miscellaneous
PT/0/A/0811/001
Power Escalation Test
059
AD-EG-ALL-1110
Design Review Requirements
Procedures
AD-EG-ALL-1708
Development of Relief Requests and Alternatives Pursuant
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
to 10 CFR 50.55A
AD-MN-ALL-0002
AD-NE-ALL-1107
Evaluation of Indications and Relevant Conditions
AD-PI-ALL-0100
Corrective Action Program
IP/0/A/2005/006
Maintenance Of Keowee Hydro Station General Electric
EX2100 Digital Exciter
21
OP/0/A/1106/019
Keowee Hydro At Oconee
114
OP/2/A/2000/102
KHU-2 Alarm Response Guide 2SA-2
2
TE-MN-ALL-0002
Foreign Material Exclusion Level and Controls Screening
Work Orders
266554, 20651767, 20255683, 20651767, 20658316,
266313, 20266013, 20661235, 20537999
Corrective Action
Documents
2403506, 2403542, 2423658
Miscellaneous
OSC -11971
Oconee Replacement Axial Power Shaping Rod Assembly
(APSRA) Mechanical Design Evaluation
Corrective Action
Documents
2515019, 2515022, 2515090, 2515091, 2517306, 2518069,
2518189, 2518172, 2518685, 2517443, 2517450
OFD-101A-3.1
Flow Diagram of High Pressure Injection System (Letdown
Section)
044
OFD-101A-3.2
Flow Diagram of High Pressure Injection System (Storage
Section)
044
OFD-102A-3.1
Flow Diagram of Low Pressure Injection System (Borated
Water Supply and LPI Pump Suction)
065
OFD-102A-3.2
Flow Diagram of Low Pressure Injection System (LPI Pump
Discharge)
049
OFD-102A-3.3
Flow Diagram of Low Pressure Injection System (Core
Flood)
25
OFD-104A-3.1
Flow Diagram of Spent Fuel Cooling System
061
OFD-109A-3.1
Flow Diagram of Purification Demineralizers
016
OFD-116-3.1
Flow Diagram of Reactor Building Purge System
Drawings
OFD-121D-1.1
Flow Diagram of Emergency Feedwater System
Engineering
Changes
24347
Disposition for Re-use of Fuel Assembly UDPK01 and
UDPK03
Miscellaneous
Clearance OPS-3-24-HP-LTOP S/U-0667
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Clearance OPS-3-24-LPI-LPI Sys Fill-0680
Pheonix Online Risk profile for Unit 3 for the week of April
28, 2024
O3R32 - Outage Schedule by Early Start, Current
Active/Working Version
Clearance OPS-3-24-RC-PZR Cooldown-0409
Clearance OPS-3-24-HPI-HPI Fill-0678
ONEI-0400-267
Oconee 3 Cycle 32 Spent Fuel Pool Decay Heat
Engineering Instruction
013
ONEI-0400-301
Communication of Requirements for Oconee Technical Specification 3.7.13: Definitions, Boundary Conditions, and
Spent Fuel Pool Storage Qualifications
001
ONEI-0400-349
Core Alignment Verification
001
ONEI-0400-371
Oconee Nuclear Station Unit 3 Loss of Spent Fuel Cooling
Heat Up Times Due to Decay Heat
003
ONEI-0400-592
Oconee 3 Cycle 33 Final Core Load Map
2
OSC-11714
Oconee Nuclear Station Cycle Specific Decay Heat
Calculations
019
OSC-1594
NUREG-0612 - Control of Heavy Loads - Load Drop
Analysis
2
OSC-6051
Verification of Alternate Method Used to Fill Spent Fuel
Pools Following Operation of SSF RC Makeup System
011
OSS-0254.00-00-
1004
(Mech) Design Basis Specification for Standby Shutdown
Facility Reactor Coolant Makeup System
064
OSS-0254.00-00-
1006
(Mech) Design Basis Specification for the Spent Fuel
Cooling System
034
OSS-0254.00-00-
4001
(Mech) Design Basis Specification for Reactor Building
Containment Isolation
046
AD-MN-ALL-0002
AD-MN-ALL-0009
Nuclear Rigging and Lifting
AD-OP-ALL-0201
Protected Equipment
AD-OP-ALL-0203
Reactivity Management
AD-SY-ALL-0460
Managing Fatigue and Work Hour Limits
Procedures
AM/0/A/3009/012
Emergency Plan for Refilling Spent Fuel Pools
013
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
A
AP/3/A/1700/002
Excessive RCS Leakage
016
AP/3/A/1700/026
Loss of Decay Heat Removal
29
AP/3/A/1700/035
Loss of SFP Cooling and/or Level
25
FG/0/A/1900/011
Alternative Spent Fuel Pool Cooling
2
IP/0/B/0200/027 A
Reactor Level Instrumentation and Calibration
033
IP/0/B/0200/027 B
Ultrasonic Level Instrument Installation and Calibration
25
IP/0/B/0200/027
C
Reactor Vessel Level Transmitters Return to Service and
Removal from Service
013
IP/0/B/3002/002 A
Polar Crane Inspection and Preventive Maintenance
015
MP/0/A/1150/002
A
Reactor Vessel - Closure Head - Installation
059
MP/0/A/1400/002
A
Equipment Hatch - Reactor Building - Temporary Opening
and
Closing
2
MP/0/A/1500/009
Defueling/Refueling Procedure
078
MP/0/A/1710/017
B
Crane - Whiting - Polar - Inspection
018
MP/0/A/1800/105
A
RBES - LPI Suction Line Flange Installation and Removal,
Drain Line and Sump Inspections
23
MP/0/A/3005/012
Containment Inspection/Close Out Procedure
2
MP/0/B/1710/022
Operation of Reactor Building Polar Crane and Auxiliary
Hoist (CRD Crane)
039
OP/0/A/1108/001
Curves and General Information
119
OP/0/A/1108/001
A
Reactor Core and SFP Loss of Cooling Heatup Tables
008
OP/0/A/1108/001
B
Spent Fuel Pool Level vs. Temperature Curves
018
OP/3/A/1102/001
Controlling Procedure for Unit Startup
285
OP/3/A/1102/001
Controlling Procedure for Unit Startup
285
OP/3/A/1102/004
Operation at Power
143
OP/3/A/1102/004
Operation at Power
2
OP/3/A/1102/010
Controlling Procedure for Unit Shutdown
256
OP/3/A/1102/015
Filling and Draining FTC
088
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP/3/A/1102/028
Reactor Building Tour and Containment Material Controls
2
OP/3/A/1103/011
Draining and Nitrogen Purging RCS
100
OP/3/A/1104/004
Low Pressure Injection System
171
OP/3/A/1104/006
SF Cooling System
2
OP/3/A/1104/010
Low Pressure Service Water
2
OP/3/A/1104/049
Low Temperature Overpressure Protection (LTOP)
061
OP/3/A/1105/019
Control Rod Drive System
035
OP/3/A/1106/001
Turbine Generator
29
OP/3/A/1106/006
Emergency FDW System
116
OP/3/A/1502/001
Operations Defueling/Refueling Responsibilities
093
OP/3/A/1502/007
Operations Defueling/Refueling Responsibilities
093
OP/3/A/1502/009
Containment Closure Control
050
PT/0/A/0711/001
Zero Power Physics Testing
081
PT/0/A/0750/002
Core Inspections Procedure
031
PT/0/A/0750/012
Development of Fuel Movement Instructions Procedure
054
PT/0/A/0750/012
Development of Fuel Movement Instructions Procedure
054
PT/0/A/0750/018
Refueling Activities
26
PT/0/A/0775/015
Core Alignment Verification
015
PT/3/A/0115/008
Reactor Building Containment Isolation and Verification
043
PT/3/A/0115/012
Unborated Water Source Isolation Verification
005
PT/3/A/0150/029
Performance Containment Verification
015
PT/3/A/0150/030
Containment Verification
004
PT/3/A/0150/034
Leak Rate History Record and Reactor Building Leak Rate
Verification
2
PT/3/A/0200/046
Reactor Coolant System Leak Test
011
PT/3/A/0600/001
B
Instrument Surveillance Prior to Mode Change
PT/3/A/0600/015
Control Rod Movement
030
PT/3/A/0630/001
Mode Change Verification
037
Work Orders
20541411, 20541412, 20268299, 20612211, 20612035,
20612355, 20612627, 20612628
Corrective Action
Documents
2476102, 2473099, 2471437, 2426308, 2426301, 2516589,
2518189, 2515022, 2517412, 2517443, 2505843, 2469093,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2401644, 2327394, 2401085, 2327585, 2401253, 2518116
OFD-102A-3.1
Flow Diagram of Low Pressure Injection System (Borated
Water Supply and LPI Pump Suction)
065
OFD-102A-3.2
Flow Diagram of Low Pressure Injection System (LPI Pump
Discharge)
049
OFD-116A-3.1
Flow Diagram of Reactor Building Purge System
014
Drawings
OFD-121D-1.1
Flow Diagram of Emergency Feedwater System
039
Engineering
Changes
2106, 424347
ONEI-0400-352
Oconee Mast Sipping Limits and Precautions
001
ONEI-0400-477
Oconee Core Power Distribution Comparison Criteria
000
Miscellaneous
OSS-0254.00-00-
1049
(MECH) Design Basis Spec for the Essential Siphon
Vacuum System
015
AD-NF-ALL-0806
Nuclear Fuel Integrity
AD-OP-ALL-0106
Conduct of Infrequently Performed Tests or Evolutions
AP/3/A/1700/026
Loss of Decay Heat Removal
29
AP/3/A/1700/035
Loss of SFP Cooling and/or Level
25
EP/3/A/1800/001
0P
Unit 3 EOP Enclosures 5.31-5.40
MP/0/A/1200/045
Valve - Henry Pratt Type RIA11 - Reactor Building Purge -
Seat to Disc Adjustment
25
MP/0/A/1200/088
Valves - Henry Pratt - Reactor Building Purge Isolation -
Preventive Maintenance
28
MP/0/A/1840/040
A
Pumps - Motors - Miscellaneous Components - Lubrication
Post Maintenance Testing
004
MP/0/A/3009/020
A
DC Motor - Up to 50 HP - Visual Inspection and Preventive
Maintenance
010
PT/0/A/0711/001
Zero Power Physics Test
081
PT/0/A/0750/023
Fuel Assembly Inspection by In-Mast Sipping
009
PT/0/A/0750/025
Fuel Assembly Inspection by Canned Sipping
001
PT/0/A/0800/030
Core Power Distribution Comparison
063
PT/0/A/0811/011
Power Escalation Test
058
Procedures
PT/1/A/0600/013
Motor Driven Emergency Feedwater Pump Test
078
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PT/2/A/2200/011
KHU-2 Turbine Guide Bearing Oil System Surveillance
014
PT/3/A/0150/006
Mechanical Penetration Leak Rate Data
076
PT/3/A/0151/019
Penetration 19 Leak Rate Test
019
PT/3/A/0151/029
Penetration 29 Leak Rate Test
013
PT/3/A/0152/016
Purge System Valve Stroke Test
20
PT/3/A/0261/010
Essential Siphon Vacuum System Test
PT/3/A/0600/012
Turbine Driven Emergency Feedwater Pump Test
096
PT/3/A/0610/001
A
EPSL Normal Source Voltage Sensing Circuit
036
PT/3/A/0610/001
B
EPSL Startup Source Voltage Sensing Circuit
036
PT/3/A/0610/001
C
EPSL Standby Bus 1 And 2 Voltage Sensing Circuits
21
PT/3/A/0610/001
J
Emergency Power Switching Logic Test
056
Work Orders
20647905, 20523776, 20563143, 20645573, 20561397,
20666997, 20611772, 20612606, 20612630, 20612607,
20476249, 20648458, 20469789, 20669079, 20609616,
20655172
Miscellaneous
ASE-13
Corrective Action
Documents
2506370
MSPI Derivation and Margin Reports for Heat Removal for
Oconee Nuclear Station
Mitigating Systems Performance Index (MSPI) Basis
Document
LER 270-2023-001
LER 287-2023-001
LER 287-2023-002
RCS Leak rate data for Oconee Nuclear Station
MSPI Derivation and Margin Reports for Cooling Water
System for Units 1, 2, and 3 from June 2023 to March 2024
AD-PI-ALL-0700
Performance Indicators
71151
Miscellaneous
OSS-0254.00-00-
(Mech) Design Basis Spec for Keowee Turbine Generator
018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1046
Cooling Water (WL) System
PT/X/A/0201/007
RCS Leakage Calculation Test
Corrective Action
Documents
2516908, 2516782
Miscellaneous
Interim Report of a Deviation Associated with an Oil Filled
Capacitors in Aluminum Case Part Number 07-020139-10,
Final Report of a Deviation Associated with an Oil Filled
Capacitors in Aluminum Case Part Number 07-020139-10
Corrective Action
Documents
2504661, 2508057, 2517041, 2517136, 2515865, 2518663,
2494275
Work Orders
263850, 20263851, 20263865, 20263849, 20537999,
20670317
Corrective Action
Documents
2477145, 2477208, 2477210, 2477611, 2489821, 2477886,
2477925, 2480047, 2480068, 2503208