IR 05000270/2022002
| ML22209A250 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/29/2022 |
| From: | Eric Stamm Division Reactor Projects II |
| To: | Snider S Duke Energy Carolinas |
| References | |
| IR 2022002 | |
| Download: ML22209A250 (26) | |
Text
SUBJECT:
OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2022002 AND 05000270/2022002 AND 05000287/2022002
Dear Mr. Snider:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On July 20, 2022, 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.
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.
July 29, 2022 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:
05000269/2022002, 05000270/2022002 and 05000287/2022002
Enterprise Identifier:
I-2022-002-0026
Licensee:
Duke Energy Carolinas, LLC
Facility:
Oconee Nuclear Station
Location:
Seneca, South Carolina
Inspection Dates:
April 1, 2022, to June 30, 2022
Inspectors:
J. Nadel, Senior Resident Inspector
A. Ruh, Resident Inspector
N. Smalley, Resident Inspector
P. Cooper, Senior Reactor Inspector
J. Diaz-Velez, Senior Health Physicist
S. Downey, Senior Reactor Inspector
A. Goldau, Operations Engineer
M. Magyar, Reactor Inspector
A. Nielsen, Senior Health Physicist
N. Peterka, Senior Project Engineer
L. Pressley, Reliability and Risk Analyst
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 prepare and deliver a radioactive material shipment for transportation by a carrier in accordance with 10 CFR 71.5 and 49 CFR 173.421 Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000269,05000270,05000287/
2022002-01 Open/Closed
[H.12] - Avoid Complacency 71124.08 A Green self-revealing, non-cited violation (NCV) of 10 CFR 71.5 was identified for the failure to comply with Department of Transportation (DOT) external surface dose rate limits for a limited quantity package as specified in 49 CFR 173.421.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000269,05000270, 05000287/2022001-
Essential Siphon Vacuum Testing 71111.22 Discussed LER 05000270/2021-005-
Unit 2, Automatic Reactor Trip Due to Spurious Trip Signal Concurrent with System Testing 71153 Closed LER 05000270/2022-001-
Unit 2, Regarding Automatic Reactor Trip Due to Loss of Power to Reactor Coolant Pumps 71153 Closed LER 05000270/2022-002-
Unit 2, Regarding Automatic Actuation of Emergency Feedwater System due to Main Feedwater Pump Malfunction 71153 Closed LER 05000270/2022-003-
Unit 2, Manual Reactor Trip due to Main Feedwater Control Valve Positioner Malfunction 71153 Closed LER 05000287/2022-001-
Unit 3, Response Actions Resulted in Brief Inoperability of Both Onsite and Offsite Emergency AC Power Paths 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 began the inspection period operating near 100 percent RTP. On May 6, 2022, the unit was shut down for a scheduled refueling outage. The unit was returned to 100 percent RTP on June 2, 2022, and remained 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the following system:
230kV switchyard on June 16, 2022
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 due to a tornado warning issued for the local area on May 23, 2022.
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) Unit 3 low pressure injection system during lowered inventory configuration on May 10, 2022
- (2) Instrument air system during planned maintenance of primary instrument air compressor on April 18 and 19, 2022
- (3) Unit 3 protected service water system following restoration from refueling outage on June 17, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) Standby shutdown facility following restoration from Unit 3 refueling outage on June 30, 2022
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 89: Unit 3 equipment room on April 6, 2022
- (2) Fire zone 105: Unit 2 cable room on April 7, 2022
- (3) Fire zone 85: Unit 1 second floor hallway on April 27, 2022
- (4) Fire zone 112: Unit 3 control room on April 27, 2022
- (5) Fire zone 124: Unit 3 containment on May 10, 2022
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 3 east penetration room and risk mitigation actions during breach of low pressure service water system
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors evaluated pressurized-water reactor non-destructive testing by reviewing the following examinations from May 9 to May 19, 2022:
1. Ultrasonic Testing (UT)
a.
3PSL-133, B Elbow Base Metal, Augmented (reviewed)b.
3FDW-267-12, Reducer to Pipe, Class 1 (reviewed)c.
3-PZR-WP26-3, Nozzle to Shell, Class 1 (reviewed)
2. Penetrant Testing (PT)
a.
3-54A-3-0-2439A-H25, Lug to Pipe Weld, Class 2 (reviewed)
3. Eddy Current Examination (ECT)
a.
Steam Generator 3A - ECT for tubes R136C14, R22C77, R77C119, R87C123 b.
Steam Generator 3B - ECT for tubes R149C7, R143C21, R137C67 The inspectors evaluated the licensees boric acid corrosion control program performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 3 reactor shutdown on May 6, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated simulator training for an operating crew using simulator exercise guide SEG 2201 PSE-1(1) on June 21, 2022.
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 (SSCs) remain capable of performing their intended function:
- (1) Primary instrument air compressor with 10 CFR 50.65(a)(1) evaluation from nuclear condition report (NCR) 2386883
- (2) Unit 2 main feedwater system with 10 CFR 50.65(a)(1) evaluation from NCR 2417011
- (3) Unit 3 4kV electrical system with 10 CFR 50.65(a)(1) evaluation from NCR 2413538
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 elevated green risk due to planned maintenance on primary instrument air compressor and turbine building heavy lifts, on April 11, 2022
- (2) Units 1, 2, and 3 elevated green risk due to planned maintenance on primary instrument air compressor, on April 18 and 19, 2022
- (3) Units 1, 2, and 3 yellow risk due to a tornado watch, on May 6, 2022
- (4) Unit 3 yellow shutdown risk due to reactor coolant system draining, on May 8, 2022
- (5) Unit 3 yellow shutdown risk due to cold mid-loop operations, on May 22, 2022
- (6) Units 1 and 2 elevated green risk due to heavy lift of feedwater heaters over Units 1 and 2 main feeder buses, on May 13, May 18, and June 20, 2022
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:
- (2) NCR 2429587, Unit 3 wide range reactor coolant system 'A' hot leg temperature indication failure for the standby shutdown facility and use of spare element on alternate resistance temperature detector
- (3) NCR 2428753, failure of PT/3/A/0610/029, 4160V bus transfer testing
- (4) NCR 2432531, 3A low pressure service water pump approached high motor stator temperature alarm
- (5) NCR 2426380, correction factor for essential siphon vacuum (ESV) pump seal water temperature variation may not be valid
- (6) NCR 2432379, preliminary evaluation of multi-point data collection for 2A essential siphon vacuum pump
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) PT/0/A/0600/021, Standby Shutdown Facility (SSF) Diesel - Generator Operation Test, following preventive maintenance on the SSF diesel engine service water pump, work order (WO) 20453345
- (2) Pressure testing of condenser circulating water pipe patch plate repair of through-wall defect, WO 20395451 (3)3CC-8 diagnostic testing following air operated valve actuator rebuild and adjustments, WO 20486686
- (4) PT/3/A/0202/012, Component Test of ES Channels 1 & 2, following Unit 3 refueling outage system maintenance, WO 20476205
- (5) PT/3/A/0400/007, SSF RC Makeup Pump Test, following Unit 3 refueling outage preventive maintenance, WO 20476110
- (6) PT/3/A/0251/024, High Pressure Injection Full Flow Test, following Unit 3 refueling outage system maintenance, WO 20476144
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage U3R31 activities from May 6, 2022, to May 30, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) CP/2/A/2002/001, U2 RCS Sample on April 11, 2022
- (2) PT/3/A/0261/020, ECCW System Test, on May 8, 2022
- (3) PT/0/A/0711/001, Zero Power Physics Testing, on May 29, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) PT/3/A/0151/019, Penetration 19 Leak Rate Test, on May 24, 2022
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The inspectors observed and evaluated simulator training for an operating crew using simulator exercise guide SEG 2201 PSE-1(1) on June 21,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Non-fuel items in the Unit 1, Unit 2, and Unit 3 spent fuel pools
- (2) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA)
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Radiation work permit 5061 - Filter liner handling activities - lift and load into shipping cask
- (2) ALARA [as low as reasonably achievable] Plan 2022-ONS-3-O-001, Alloy 600, revision 0
- (3) ALARA Plan 2022-ONS-3-O-002, 3B1 Reactor Coolant Pump Motor Remove/Repair/Replace, revision 0 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 3 reactor coolant bleed holdup tank room
- (2) Seal supply filter cleaning and storage room
- (3) Incore probes in warehouse 10 Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials the following areas:
- (1) Unit 3 auxiliary building
- (2) Steam generator mausoleum building
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Unit 3 liquid waste monitoring tanks
- (2) Unit 3 liquid waste demineralizers skid
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
(1)10 CFR 61 Dry Active Waste radwaste stream sample #ON21032900028, dated 03/29/2021 (2)10 CFR 61 Powdex Resin 19-21 sample #ON21041900006, dated 02/18/2021
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the preparation of radioactive shipment RSR# 22-2005
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Radioactive Waste Shipment 20-2027, Low Specific Activity (LSA) II
- (2) Radioactive Waste Shipment 21-2005, LSA II
- (3) Radioactive Waste Shipment 21-2014, LSA II
- (4) Radioactive Waste Shipment 21-2017, LSA II
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, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
- (3) Unit 3 (April 1, 2021, through March 31, 2022)
MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
- (3) Unit 3 (April 1, 2021, through March 31, 2022)
MS10: Cooling Water Support Systems (IP Section 02.09) (3 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
- (3) Unit 3 (April 1, 2021, through March 31, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (3 Samples)
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
- (3) Unit 3 (April 1, 2021, through March 31, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) December 4, 2021, through May 5, 2022 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) December 4, 2021, through March 30, 2022
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:
- (2) Recurring essential siphon vacuum system float valve test failures and cause evaluations (NCRs 1765682, 1774724, 1816518, 1808705, 2238168, 2247826,
2352558, 2375175, 2386700) 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 operations department performance 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 licensee event reports (LERs):
- (1) LER 05000270/2021-005-00, Unit 2 Automatic Reactor Trip Due to Spurious Trip Signal Concurrent with Systems Testing (ADAMS Accession No. ML22039A333). 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 inspectors did not identify a violation of NRC requirements.
- (2) LER 05000270/2022-001-00, Unit 2 Automatic Reactor Trip Due to Loss of Power to Reactor Coolant Pumps (ADAMS Accession No. ML22096A333). The inspection conclusions associated with this LER are documented in Inspection Report
===05000269, 05000270, 05000287/2022001 (ADAMS Accession No. ML22123A236) under Inspection Results Section 71153.
- (3) LER 05000270/2022-002-00, Automatic Actuation of Emergency Feedwater System due to Main Feedwater Pump Malfunction (ADAMS Accession No. ML22104A257).
The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2022001 (ADAMS Accession No.
ML22123A236) under Inspection Results Section 71153.
- (4) LER 05000270/2022-003-00, Manual Reactor Trip Due to Main Feedwater Control Valve Positioner Malfunction (ADAMS Accession No. ML22111A361). The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2022001 (ADAMS Accession No. ML22123A236)under Inspection Results Section 71153.
- (5) LER 05000287/2022-001-00, Response Actions Resulted in Brief Inoperability of Both Onsite and Offsite Emergency AC Power Paths (ADAMS Accession No.
ML22087A512). 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 inspectors did not identify a violation of NRC requirements.
Personnel Performance (IP Section 03.03)===
- (1) The inspectors evaluated operator response to a 3A spent fuel pool cooler filter gasket failure and leakage of 6400 gallons of Unit 3 spent fuel pool water into the auxiliary building and licensees performance on June 3,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===71003 - Post-Approval Site Inspection for License Renewal The NRC continued monitoring Dukes performance at Oconee by conducting a Post-Approval Site Inspection for License Renewal - Phase 4 in accordance with the license renewal inspection program (LRIP). Per IMC 2516, the LRIP is the process used by NRC staff to verify the adequacy of aging management programs (AMPs) and other activities associated with an applicants request to renew an operating license of a commercial nuclear power plant beyond the initial licensing period under 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants.
The inspectors reviewed the licensees implementation of the AMPs shown below by selecting a sample of SSCs within the scope of the respective AMPs. The inspectors performed the following activities, as applicable to each SSC, to determine that there is a reasonable assurance that the effects of aging are being adequately managed: walked down all accessible SSCs to observe their general condition and identify any signs of aging-related degradation; interviewed plant personnel; reviewed completed work orders; reviewed applicable monitoring and trending data; and reviewed the acceptability of inspection and test results. For each AMP shown below, the inspectors also reviewed a sample of aging-related issues entered into the licensees corrective action program to verify that age-related degradation is being identified at an appropriate threshold and corrected.
Post-Approval Site Inspection for License Renewal===
- (1) Crane Inspection Program (UFSAR Section 18.3.5)
Unit 1 Polar Crane
Turbine Aisle Crane (160 T)
Unit 3 Equipment Hatch Hoist
Keowee Hydro Unit (KHU) Overhead Crane KLD-1
SSF Diesel Generator Room Manual Chain Hoist
- (2) Duke Power Five-Year Underwater Inspection of Hydroelectric Dams and Appurtenances (UFSAR Section 18.3.6)
Keowee Intake
Spillway
Powerhouse
- (3) Elevated Water Storage Tank Civil Inspection (UFSAR Section 18.3.7)
Elevated Water Storage Tank (interior)
- (4) Flow Accelerated Corrosion (FAC) Program (UFSAR Section 18.3.9)
Oconee Nuclear Station (ONS) FAC Program O1R31 Post Outage Report
ONS FAC Program O2R30 Post Outage Report
ONS FAC Program O3R30 Post Outage Report
- (5) Boric Acid Corrosion Control Program (UFSAR Section 18.3.10)
3HP-500 (Action Request (AR) 02426830)
- (6) Inspection Program for Civil Engineering Structures and Components (UFSAR Section 18.3.13)
Underwater weir
Elevated water storage tank (exterior)
Tendon galleries
Discharge diversion wall (AR 02233964)
Standby shutdown facility
Trench from ESV building to radioactive waste facility trench
- (7) Insulated Cables and Connections Aging Management Program (UFSAR Section 18.3.14)
Accessible cables and connections in the auxiliary building, turbine building, and elevated water storage tank area
The following inaccessible or direct buried medium voltage cables: CT5c, CT5f, IPBT0010, IPBT0013, protected service water cables, 2TE11
- (8) Keowee Oil Sampling Program (UFSAR Section 18.3.15)
Governor oil system
Turbine building bearing oil system
Unit 1 borated water storage tank (WO 1467528)
Unit 2 borated water storage tank (WO 1466034)
Unit 3 borated water storage tank (WO 1462557)
- (10) Keowee Turbine Generator Cooling Water System Strainer Inspection (UFSAR Section 18.3.17.10)
Train 1 Keowee turbine generator cooling water system strainer o
PT/1/A/2200/002, "KHU-1 - Bi-Monthly Surveillance" o
PT/1/A/2200/002, "KHU-1 - Semiannual Surveillance"
Train 2 Keowee turbine generator cooling water system strainer o
PT/2/A/2200/002, "KHU-2 - Bi-Monthly Surveillance" o
PT/2/A/2200/002, "KHU-2 - Semiannual Surveillance"
- (11) Reactor Vessel Internals Inspection Program (UFSAR Section 18.3.20)
Baffle former bolts (AR 2355692)
Lower core barrel bolt (AR 1846141)
Upper core barrel bolt
- (12) Service Water Piping Corrosion Program (UFSAR Section 18.3.21)
Pipe adjacent to 42 valve 2CCW-041 (AR 2371309)
Pipe downstream 2 valve HPSW-114 (AR 02371553)
Pipe at C1LPS024 (AR 02078087)
Pipe at UT location CK1WL004 and CK2WL004 (AR 02080095)
Service Water Health Report (AR 01858183)
Service Water Trend (AR 01910482)
- (13) Battery Rack Inspections (UFSAR Section 18.3.26)
SSF battery DCSF
SSF battery DCSFS
Battery 1CA
Battery 3CB
Keowee battery 1
230 kV switchyard battery SY-1
INSPECTION RESULTS
URI (Discussed)
Essential Siphon Vacuum Testing URI 05000269,05000270,05000287/2022001-03 71111.22
Description:
This unresolved item was opened in Inspection Report 05000269, 05000270, 05000287/2022001. On June 8, 2022, the licensee collected pump performance test data over a larger range of suction pressures on the 2A essential siphon vacuum (ESV)pump. The results indicated that the pump's volumetric capacity declined as vacuum at the pump suction rose above 15 inches of mercury (inHg). Depending on the assumed lake level, calculation OSC-6961 expected the pump to operate at conditions between 21 and 18 inHg, which could amount to an 11 percent to 7 percent capacity reduction as compared to the performance being demonstrated during routine surveillance testing. However, since the pumps take suction from a sub-atmospheric source during a design event (caused by a water siphon in the condenser circulating water (CCW) piping), rather than the atmosphere (as during surveillance testing), choked flow present during testing would not be expected during a design event. The licensee is evaluating the test data for impacts from instrument uncertainties, temperature effects, and the differences between testing and design conditions. In the interim, test acceptance criteria are being adjusted to accommodate the observed capacity reductions until evaluations are complete.
After this unresolved item was originally opened, inspectors had related questions regarding the formulas in OSC-6961 used to evaluate degassing of air from the lake water flowing into the high point of the CCW siphon. The combined rate of air ingress into the CCW piping through water degassing and general in-leakage through unsealed mechanical clearances is what the required ESV pump capacity is ultimately based on. At reduced lake levels, it appeared that the rate of degassing could be underestimated by up to 56 percent because the methodology reduced the total theoretical air release by a ratio of air densities for vacuum conditions in the CCW pipe to standard atmospheric conditions. It was not immediately clear that use of this ratio was consistent with the conditions being analyzed since the licensee did not have the original reference documents used to derive their methodology. Engineers are validating the formulation but performed a preliminary analysis which concluded that system performance would still remain adequate at the higher degassing rates based on current lake levels, CCW system tightness, and other design margins.
In order to determine whether a performance deficiency exists, the inspectors need additional information concerning whether the pump capacity is expected to be reduced for suction conditions of a design event and whether the current degassing methodology is appropriate.
Failure to prepare and deliver a radioactive material shipment for transportation by a carrier in accordance with 10 CFR 71.5 and 49 CFR 173.421 Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000269,05000270,05000287/
2022002-01 Open/Closed
[H.12] - Avoid Complacency 71124.08 A Green self-revealing, non-cited violation (NCV) of 10 CFR 71.5 was identified for the failure to comply with Department of Transportation (DOT) external surface dose rate limits for a limited quantity package as specified in 49 CFR 173.421.
Description:
On November 11, 2020, the licensee was notified about a discrepancy with a radiation survey measurement on shipment number LQ20-1177. The radioactive shipment had been transported as an excepted package for limited quantities pursuant to the DOT requirements of 49 CFR 173.421(a)(2) and did not include emergency response information.
Upon receipt by the package recipient the contact dose rates on the external surface of the package were found to be greater than the 0.5 millirem per hour (mrem/h) limit allowed by the regulation. The recipient measured a contact radiation level of 0.8 mrem/h. The licensees survey conducted before shipment indicated a maximum dose rate on the package of 0.01 mrem/h. The package contained equipment belonging to a contractor and was being shipped to another utility. The licensees causal investigation concluded that an inadequate radiation survey was performed prior to the package leaving the site and that the shipment should not have been characterized as limited quantity.
Corrective Actions: Immediate corrective actions included a stand-down with all qualified licensee shippers, temporary inactivation of shipper qualifications, and implementation of a dose rate verification requirement for all shipments involving limited quantities of radioactive materials.
Corrective Action References: Condition report 02357711
Performance Assessment:
Performance Deficiency: The failure to prepare and deliver a radioactive material shipment for transportation in accordance with 10 CFR 71.5 and 49 CFR 173.421 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the improper package preparation could have led to members of the public being exposed to higher radiation doses than anticipated for a limited quantity package. In addition, the shipment did not include the hazard communications for carriers and emergency responders that would normally be expected for a package exceeding 0.5 mrem/h on the external surface.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. Although the shipment lacked emergency response information, response efforts would not have been significantly hampered due to the extremely low radiological hazard. Therefore, the inspectors determined that the finding was of Green significance.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools.
Enforcement:
Violation: 10 CFR 71.5(a) requires that a licensee who offers licensed radioactive material for transport comply with the DOT regulations in 49 CFR Parts 107, 171-180, and 390-397.
49 CFR 173.421 excepts limited quantity shipments of radioactive material from certain marking, labeling, and shipping paper requirements, including emergency response information, provided that the radiation level at any point on any external surface of the package does not exceed 0.5 millirem per hour. Contrary to this, on November 9, 2020, the licensee offered a package for transport as an excepted package-limited quantity of material, but the dose rate on the external surface exceeded 0.5 mrem per hour.
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 10, 2022, the inspectors presented the Radiation Protection inspection results to Paul Fisk, Plant Manager, and other members of the licensee staff.
On May 19, 2022, the inspectors presented the Inservice inspection results to Steven Snider and other members of the licensee staff.
On July 20, 2022, 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
NCRs (by number)
242434, 2305360, 2341326, 2375598, 2384556, 2407211
71003
Work Orders
Work Orders (by
number)
20183682, 20296196, 20296203, 20322254, 20351458
Corrective Action
Documents
2396552, 2396652
AP/0/A/1700/006
Natural Disaster
OP/0/B/1104/050
Weather Related Activities
006
Procedures
PT/0/A/0110/018
Hot Weather Protection
009
OEE-149-01
Pressurizer Heaters Arrangement and Legend
OFD-101A-3.5
Flow Diagram of High Pressure Injection System (SSF
Portion)
28
OFD-102A-3.1
Flow Diagram of Low Pressure Injection System (Borated
Water Supply and LPI Pump Suction)
OFD-102A-3.2
Flow Diagram of Low Pressure Injection System (LPI Pump
Discharge)
OFD-102A-3.3
Flow Diagram of Low Pressure Injection System (Core
Flood)
OFD-104A-3.1
Flow Diagram of Spent Fuel Cooling System
060
OFD-121D-3.1
Flow Diagram of Emergency Feedwater System
047
OFD-131A-1.1
Flow Diagram of Protected Service Water System
OFD-131A-3.2
Flow Diagram of Protected Service Water System (Steam
Generator & HPI Pump Motor Cooling Service)
OFD-133A-2.5
Flow Diagram of Condenser Circulating Water System
(SSF Auxiliary Service)
2
Drawings
OFD-137B-1.1
Flow Diagram of Instrument Air System (Air Compressors,
After Coolers, Receivers, Air Dryers)
Miscellaneous
PT/3/A/1600/008
SSF Instrument Surveillance
030
AP/0/A/1700/025
Standby Shutdown Facility Emergency Operating
Procedure
067
OP/0/A/1600/002
Standby Shutdown Facility HVAC System Operation
039
Procedures
OP/0/A/1600/009
SSF Auxiliary Service Water System
039
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OP/0/A/1600/010
Operation of the SSD Diesel Generator
098
OP/0/A/1650/001
PSW System
OP/0/A/1650/005
PSW AC Power
OP/0/A/1650/006
PSW DC Power
OP/2/A/1102/020 D
SSF and Outside Rounds
103
OP/3/A/1102/027
Administrative Controls of Piping Subject to Possible
Overpressurization
008
OP/3/A/1104/004
Low Pressure Injection System
170
OP/3/A/1600/008
SSF RC Makeup and Letdown Systems
030
CSD-ONS-PFP-
Pre-Fire Plan for U1 Auxiliary Building Elevation 783
000
CSD-ONS-PFP-
Pre-Fire Plan for U2 Auxiliary Building Elevation 809
000
CSD-ONS-PFP-
Pre-Fire Plan for U3 Auxiliary Building Elevation 796
000
CSD-ONS-PFP-
Pre-Fire Plan for U3 Auxiliary Building Elevation 822
000
CSD-ONS-PFP-
3RB
Pre-Fire Plan for U3 Reactor Building for All Elevations
000
O-0310-FZ-011
Auxiliary Building - Unit 3 Fire Protection Plan Fire Area
and Fire Zone Boundaries Plan at EL 796+6 & EL 797+6
2
Fire Plans
O-310-K-09
Auxiliary and Reactor Building - Unit 3 Fire Protection Plan
& Fire Barrier, Flood, & Pressure Boundaries Plan at EL
796+6 & EL 797+6
Corrective Action
Documents
27343
Elevated Risk Activity Plan for 3LPS-VA-1116, PM Check
Valve During O3R31
03/30/2022
Miscellaneous
SD 3.2.16
Control of Passive Design Features
MP/0/A/1200/064A
Valve-Crane-Tilting Disc Check-Disassembly, Repair, and
Reassembly
Procedures
MP/3/A/1705/018
Fire Protection-Penetration-Fire and Flood Barrier-
Inspection and Minor Repair
Work Orders
20172203-06
3-LPS-VA-1116 Remove Check Valve
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Oconee Unit 3 O3R31 Outage Steam Generator
Degradation Assessment
ROTSG Site Technique Validation for Oconee Nuclear
Station
3012-AST-102181
Steam Generator Monitoring and Final Operational
Assessment for Oconee-3 O3R29 Outage
000
3012-AST-102562
Two-Cycle Steam Generator Operational Assessment for
Oconee Unit 3 Cycles 30 and 31
000
Miscellaneous
51-9316606-001
Oconee Mathematically Calculated Calibration Curve
2/27/2018
AP/1/A/1700/002
Excessive RCS Leakage
017
AP/1/A/1700/014
Loss of Normal HPI Makeup and/or RCP Seal Injection
2
EP/1/A/1800/001
0L
Unit 1 EOP Rules and Appendix
005
EP/1/A/1800/001
0M
Unit 1 EOP Enclosures 5.1-5.10
001
EP/1/A/1800/00100
Unit 1 EOP Immediate Manual Actions and Subsequent
Actions
003
Procedures
P/1/A/1800/001 0I
Corrective Action
Documents
2370522, 2412228, 2412234, 2370522, 2426459, 2390606,
2391905, 2394232, 2351882, 2343892, 2344593
Procedures
AD-EG-ALL-1210
3, 4
Feedwater Heater Drop Evaluation
04/20/2022
AP-OP-ALL-0111
13
External Department Guidance: Feedwater Heater
Replacement Heavy lifts on Turbine Deck - Elev. 822+0
Miscellaneous
Standing
Instruction 22-05
Feedwater Heater Replacement Heavy Lifts on Turbine
Deck - Elev. 822+0
AD-WC-ALL-0420
Shutdown Risk Management
AD-WC-ONS-0420
ONS Shutdown Risk Management
Procedures
OP/3/A/1103/011
Draining and Nitrogen Purging RCS
O-2785-F
Connection Diagram Integrated Control System Misc.
Remote Mtd. Equip.
OFD-104A-03-01
Flow Diagram of Spent Fuel Cooling System
OM 245-2241.001
8" (DN200) Bolted Bonnet Gate Valve (Cast)
E
Drawings
OM 267-1336.001
Installation/Instruction/Operation Manual for N9031-1A RTD 3
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
and Associated Equipment (For WEED Triple Element
RTD)
Engineering
Changes
21144, 421168
Miscellaneous
OSS-0254.00-00-
1006
Design Basis Specification for the Spent Fuel Cooling
System
AP/0/A/1700/025
Standby Shutdown Facility Emergency Operating
Procedure
IP/0/A/0200/032
RTD Replacement
IP/0/B/0200/049
Auxiliary Control System Reactor Coolant System
Instrument Calibration
IP/3/A/0370/002 B
Unit 3 SSF RC System Temperature
Procedures
OP/3/A/1104/010
Low Pressure Service Water
118
Work Orders
20539195, 20538991
Miscellaneous
Emergency Response Procedures and Guidelines for
Beyond Design Basis Events and Severe Accidents
Calculations
OSC-10330
AOV Design Basis Capability Value CC-8
Corrective Action
Documents
NCR 02428250, 02428547
OFD-101A-3.1
Flow Diagram of High Pressure Injection System (Letdown
Section)
OFD-101A-3.2
Flow Diagram of High Pressure Injection System (Storage
Section)
OFD-101A-3.3
Flow Diagram of High Pressure Injection System Charging
Section
OFD-101A-3.4
Flow Diagram of High Pressure Injection System Charging
Section
OFD-101A-3.5
Flow Diagram of High Pressure Injection System (SSF
Portion)
OFD-102A-3.1
Flow Diagram of Low Pressure Injection System (Borated
Water Supply and LPI Suction)
OFD-102A-3.2
Flow Diagram of Low Pressure Injection System (LPI Pump
Discharge)
Drawings
OFD-104A-3.1
Flow Diagram of Spent Fuel Cooling System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Changes
20718
AOV Post-Test Evaluation for 3CC-8
05/24/2022
Miscellaneous
Quiklook Dynamic Scan Report 3CC0008 As-Left
05/24/2022
MP/0/A/1800/097
Accumulator - Suction Stabilizer - Greer Hydraulics - 10
Gallon - Checking, Precharging, Disassembly, and
Reassembly
OP/0/A/1600/010
Operation of the SSF Diesel Generator
098
PT/0/A/0600/020
Standby Shutdown Facility Instrument Surveillance
25
PT/0/A/0600/021
Standby Shutdown Facility Diesel - Generator Operation
017
PT/0/A/0600/023
Standby Shutdown Facility Fuel Oil Inventory
007
PT/3/A/0202/012
Component Test of ES Channels 1 & 2
PT/3/A/0251/024
HPI Full Flow Test
Procedures
PT/3/A/0400/007
SSF RC Makeup Pump Test
20476261, 20475755
Work Orders
20453345 01
Perform Annual Lube (PM) SSF Diesel Service Water
Pump
04/27/2022
Corrective Action
Documents
25517
Clearance PRT-3-22-REDUCED INV-0190
Clearance OPS-3-22-LPI-2NDDROPLOOPS-0963
Miscellaneous
Elevated Risk Activity Plan for Removal of Unit 3 Main
Feeder Bus 2
03/30/2022
AD-OP-ALL-0106
Conduct of Infrequently Performed Tests or Evolutions
AD-WC-ALL-0410
Work Activity Integrated Risk Management
EP/1/A/1800/001
0Q
Unit 1 EOP Enclosures 5.41-5.47
OP/0/A/1107/011 F
Sharing Startup Transformers Between Units
OP/3/A/1102/001
Controlling Procedure For Unit Startup
281
OP/3/A/1102/004
Operation At Power
140
OP/3/A/1103/011
Draining and Nitrogen Purging RCS
PT /0/ A/0711/001
Zero Power Physics Test
Procedures
PT/0/A/0711/002
Zero Power Physics Test Equipment Checkout
014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PT/3/A/0610/025
Electrical System Weekly Surveillance (Unit 3)
OSC-2280
LPSW NPSHA and Minimum Required Lake Level
OSC-5349
Minimum Lake Level Required to Maintain Sufficient NPSH
to the LPSW Pumps via Gravity Flow
OSC-5670
Emergency CCW System First Siphon
Calculations
OSC-6961
ECCW Siphon Air Inleakage Model ESV System
Performance Model and Test Acceptance Criteria
Corrective Action
Documents
27606, 02428753
OFD-110A-2.1
Flow Diagram of Chemical Addition System (Primary
Sample Hood)
040
Drawings
ONTC-0-133A-
0001-003
ECCW Test Acceptance Criteria
AD-EG-ALL-1450
Preconditioning of Structures, Systems and Components
AD-WC-ALL-0260
Nuclear Generation Response to High or Low Grid System
Load
CP/0/A/2005/022
Determination of Reported Tech Spec Dose Equivalent
007
CP/2/A/2002/001
Unit 2 Primary Sampling System
2
PT/0/A/0261/008
Condenser Circulating Water Valve Leak Test
Procedures
PT/3/A/0610/029
4160V AC Bus Transfer Test
008
Work Orders
224034
Corrective Action
Documents
Resulting from
Inspection
CR 02426218
Miscellaneous
ONS Alpha Program Information
03/02/2022
AD-RP-ALL-0007
Control of Radioactive Material
Procedures
AD-RP-ALL-2014
Work in Alpha Environments
Corrective Action
Documents
CR 02357623,
2357711,
2364735,
2373733,
2375797,
Corrective Action Documents
Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2394135,
2402955, and
2412872
Shipping Records LQ #20-1177 and
LQ #21-1050
Shipping Documents
Corrective Action
Documents
2432820, 239172, 2367963, 2391434
MSPI Cooling Water System URI Derivation and Margin
Reports, Oconee Units 1, 2, 3 for period March 2022
MSPI Heat Removal System URI Derivation and Margin
Reports, Oconee Units 1, 2, 3 for period March 2022
AD-PI-ALL-0700
Performance Indicators
Regulatory Assessment Performance Indicator Guideline
PT/1/A/0600/010
Reactor Coolant Leakage
100
PT/2/A/0600/010
Reactor Coolant Leakage
71151
Miscellaneous
PT/3/A/0600/010
Reactor Coolant Leakage
Corrective Action
Documents
23805, 2352685, 2417396, 2207328, 2393005, 2341117,
2352787, 2408955, 2408602, 2424351, 2430822, 2401963,
2410028, 2415853
O FD-101A-02-02
Flow Diagram of High Pressure Injection System (Storage
Section)
046
O FD-101A-02-03
Flow Diagram of High Pressure Injection System (Charging
Section)
034
O FD-101A-03-02
Flow Diagram of High Pressure Injection System (Storage
Section)
044
O FD-101A-03-03
Flow Diagram of High Pressure Injection System (Charging
Section)
2
O FD-106A-02-01
Flow Diagram of Coolant Treatment System (RC Bleed
Holdup Tanks)
017
O FD-106A-02-02
Flow Diagram of Coolant Treatment System (Concentrated
Boric Acid Storage Tank)
013
O FD-106A-03-01
Flow Diagram of Coolant Treatment System (RC Bleed
Holdup Tanks)
016
Drawings
O FD-106A-03-02
Flow Diagram of Coolant Treatment System (Concentrated
016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Boric Acid Storage Tank)
ASME Inservice Testing Program
Miscellaneous
SLC 16.5.13
HPI and the Chemical Addition Systems
AP/2/A/1700/003,
Boron Dilution
017
PT/2/A/0251/008
2CS-73 Functional Test
24
Procedures
PT/3/A/0251/008
3CS-73 Functional Test
20
Work Orders
200673, 02132473, 20392734, 20429060, 20429061
AP/3/A/1700/030
Auxiliary Building Flood
AP/3/A/1700/035
Loss of SFP Cooling and/or Level
Procedures
OP/0/A/1108/001
Curves and General Information
118