IR 05000269/2013002
| ML13115A063 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/24/2013 |
| From: | Bartley J NRC/RGN-II/DRP/RPB1 |
| To: | Batson S Duke Energy Carolinas |
| References | |
| Download: ML13115A063 (24) | |
Text
UNITED STATES pril 24, 2013
SUBJECT:
OCONEE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000269/2013002, 05000270/2013002, 05000287/2013002
Dear Mr. Batson:
On March 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oconee Nuclear Station Units 1, 2, and 3. The enclosed inspection report documents the inspection results, which were discussed on April 15, 2013, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding of very low safety significance (Green) which was identified during this inspection. This finding was determined to involve a violation of NRC requirements. Further, a licensee-identified violation is listed in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Oconee. 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 Regional Administrator, Region II; and the NRC Resident Inspector at the McGuire Nuclear Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55
Enclosure:
NRC Integrated Inspection Report 05000269/2013002, 05000270/2013002, 05000287/2013002 w/Attachment: Supplementary Information
REGION II==
Docket Nos: 50-269, 50-270, 50-287 License Nos: DPR-38, DPR-47, DPR-55 Report Nos: 05000269/2013002, 05000270/2013002, 05000287/2013002 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station, Units 1, 2 and 3 Location: Seneca, SC 29672 Dates: January 1, 2013, through March 31, 2013 Inspectors: E. Crowe, Senior Resident Inspector K. Ellis, Resident Inspector G. Croon, Resident Inspector G. Ottenberg, Resident Inspector C. Jones, Senior Construction Inspector (Section 1R17)
G. Crespo, Senior Construction Inspector (Section 1R17)
B. Caballero, Senior Operations Engineer (Section 1R11)
M. Meeks, Senior Operations Engineer (Section 1R11)
Approved by: Jonathan H. Bartley, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000269/2013-002, 05000270/2013-002, 05000287/2013-002; 01/01/2013 - 03/31/2013;
Oconee Nuclear Station Units 1, 2 and 3; Operability Evaluations and Functionality Assessments The report covered a three-month period of inspection by the resident inspectors and four Region-based reactor inspectors. One Green non-cited violation (NCV) was identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 12, 2012. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process revision 4.
Cornerstone: Mitigating Systems
- Green: An NRC-identified non-cited violation of 10 CFR 50, Appendix B, Criterion XVI,
Corrective Action, was identified for the licensees failure to take timely corrective actions for a condition adverse to quality. The licensee failed to take timely actions to correct the degraded, nonconforming condition resulting from a sheet metal plate over a penetration in the Unit 3 control battery room pressure boundary wall. The licensee entered this issue into their corrective action program (CAP), performed an operability evaluation, and declared the wall operable but degraded/non-conforming (OBDN).
The performance deficiency (PD) was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Design Control and adversely impacted the cornerstone objective in that functionality of the pressure boundary was not maintained.
The finding was of very low safety significance (Green) because it did not actually result in a safety related system being inoperable. The cause of the finding was directly related to thoroughly evaluates problems in the Corrective Action Program component of the Problem Identification and Resolution area because the licensee failed to evaluate the sheet metal plate to maintain the safety-related pressure boundary function of the battery room wall.
P.1(c) (Section 1R15)
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at approximately 100 percent rated thermal power (RTP) and remained there until the end of the inspection period.
Unit 2 began the inspection period at approximately 100 percent RTP and remained there until the end of the inspection period.
Unit 3 began the inspection period at approximately 100 percent RTP and remained there until the end of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
a. Inspection Scope
Actual Adverse Weather: The inspectors assessed the licensees response to a tornado watch on January 30, 2013. The inspectors reviewed the licensees entry into procedure AP-6, Natural Disaster, and the licensees response to the severe weather condition.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R04 Equipment Alignment
a. Inspection Scope
Partial Walkdown The inspectors performed the four partial walkdowns listed below to assess the operability of redundant or diverse trains and components when safety-related equipment was inoperable or out-of-service and to identify any discrepancies that could impact the function of the system potentially increasing overall risk. The inspectors reviewed applicable operating procedures and walked down system components, selected breakers, valves, and support equipment to determine if they were correctly aligned to support system operation. The inspectors reviewed protected equipment sheets, maintenance plans, and system drawings to determine if the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP. Documents reviewed are listed in the Attachment.
- Review of designated equipment during the Keowee Hydro Unit dual unit outage for planned maintenance
- Review of designated equipment protected during the period the standby shutdown facility (SSF) was out of service for troubleshooting and repair after a failed surveillance test
- Unit 1 high pressure service water train B during routine maintenance on train A high pressure injection (HPI) pump
- Unit 3 A train emergency feedwater and turbine driven pump during B train maintenance
b. Findings
No findings were identified.
1R05 Fire Protection
a. Inspection Scope
Fire Area Tours: The inspectors walked down accessible portions of the four plant areas listed below to assess the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures. The inspectors observed the fire protection suppression and detection equipment to determine if any conditions or deficiencies existed which could impair the operability of that equipment. The inspectors selected the areas based on a review of the licensees safe shutdown analysis probabilistic risk assessment and sensitivity studies for fire-related core damage accident sequences. Documents reviewed are listed in the Attachment.
- Unit 1 Cable Room
- Unit 1 Control Battery Room
- Unit 2 Control Battery Room
- Unit 3 Control Battery Room
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
Routine Operator Requalification Review: On March 12, 2013, the inspectors observed operators in the plants simulator during licensed operator requalification training to verify that the operator performance was adequate, evaluators were identifying and documenting crew performance issues, and training was being conducted in accordance with station procedures. The inspectors observed a shift crews response to the scenario listed below. Documents reviewed are listed in the Attachment.
- Scenario ASE-24 which included a dropped rod, asymmetric rod runback, high vibrations of a main feedwater pump, loss the second main feedwater pump with emergency feedwater unavailable.
Observation of Operator Performance: The inspectors observed licensed operator performance in the main control room during two periods of site orange risk involving maintenance activities of the standby shutdown facility. Inspectors observed licensed operator performance to assess the following:
- Use of plant procedures
- Control board manipulations
- Communications between crew members
- Use and interpretation of instruments, indications, and alarms
- Use of human error prevention techniques
- Documentation of activities
- Management and supervision Biennial Licensed Operator Requalification Inspection: The inspectors reviewed the facility operating history and associated documents in preparation for this inspection.
The inspectors reviewed documentation, interviewed licensee personnel and observed the administration of operating tests associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, Operators Licenses. The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure 71111.11, Licensed Operator Requalification Program. The inspectors also evaluated the licensees simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5-2009, American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination. The inspectors observed five crews during the performance of the operating tests. Documentation reviewed included written examinations, Job Performance Measures, simulator scenarios, licensee procedures, on-shift records, simulator modification request records, simulator performance test records, operator feedback records, licensed operator qualification records, remediation plans, watchstanding records, and medical records. The records were inspected using the criteria listed in Inspection Procedure 71111.11. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the licensees effectiveness in performing the following two corrective maintenance activities. These reviews included an assessment of the licensees practices pertaining to the identification, scoping, and handling of degraded equipment conditions, as well as common cause failure evaluations. For each activity selected, the inspectors performed a detailed review of the problem history and surrounding circumstances, evaluated the extent of condition reviews as required, and reviewed the generic implications of the equipment and/or work practice problem. For those structures, systems and components (SSCs) scoped in the Maintenance Rule per 10 CFR 50.65, the inspectors verified that reliability and unavailability were properly monitored and that 10 CFR 50.65 (a)(1) and (a)(2) classifications were justified in light of the reviewed degraded equipment condition. Documents reviewed are listed in the
.
- PIP O-13-00970, loss of Unit 1-2 spent fuel pool cooling
- PIP-O-13-01923, SSF diesel generator trip while attempting to start for monthly planned maintenance
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors evaluated the following attributes for the six activities listed below: (1)the effectiveness of the risk assessments performed before maintenance activities were conducted;
- (2) the management of risk;
- (3) that, upon identification of an unforeseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and
- (4) that maintenance risk assessments and emergent work problems were adequately identified and resolved. Documents reviewed are listed in the Attachment.
- Emergent risk assessment and management in response to repair activities for train A high pressure injection borated water storage tank suction valve (1HP-24)
- Emergent risk assessment and management in response to the repair activities for the SSF
- Review of Complex Activity Plan associated with Vital I&C Cable Re-Route
- Review of Complex Activity Plan associated with Unit 1 Keowee Outage for replacement of four battery cells as well as electrical generator/stator end winding maintenance and testing
- Review of Complex Activity Plan associated with the Service Air Header Outage which included shutdown of the two service air compressors, isolation of the service air header from the plant instrument air header and isolation of the diesel service air compressors from the service air header
- Review of fire protection compensatory measures due to the failure to fully implement NFPA 805 as scheduled
b. Findings
No findings were identified.
1R15 Operability Evaluations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed the following six operability evaluations or functionality assessments affecting risk significant systems to assess:
- (1) the technical adequacy of the evaluations;
- (2) whether continued system operability was warranted;
- (3) whether other existing degraded conditions were considered;
- (4) if compensatory measures were involved, whether the compensatory measures were in place, would work as intended, and were appropriately controlled; and
- (5) where continued operability was considered unjustified, the impact on Technical Specifications (TS) limiting condition for operations.
Operating Experience Smart Sample (OpESS ) 2012/02, Technical Specification Interpretation and Operability Determination was used by the inspectors during the review. Documents reviewed are listed in the Attachment
- PIP O-12-13496, Assessment of the U3 blockhouse heat loads
- PIP O-12-13497, Assessment of the 230 kV relay house heat loads
- PIP O-13-0055, Unit 1/2 A control room ventilation system carbon filter did not meet acceptance when tested per PT/1-2/0110/005A (Control Room Filter System Test)
- PIP O-13-01944, Battery 2CB performance test issues
- PIP O-13-01546, Unit 3 control battery room
- PIP O-13-01951, Operability performed in PIP O-11-14092 resulted in a declaration of OBDN and implemented a compensatory measure but a required 50.59 was not performed and a plant operations review committee review was not obtained
b. Findings
Introduction:
An NRC-identified Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to take timely corrective actions for a condition adverse to quality. The licensee failed to timely correct the degraded, nonconforming condition resulting from a sheet metal plate over a penetration in the Unit 3 control battery room pressure boundary wall.
Description:
The licensee initiated PIP-07-4812 on August 30, 2007, to review penetrations in high energy line break (HELB) barriers and develop corrective actions.
The review identified that a sheet metal plate covering a penetration in the Unit 3 control battery room wall could fail during a HELB event allowing elevated temperature, pressure and humidity to adversely affect the Unit 3 control batteries. The licensee assumed the sheet metal failed and evaluated the effects of elevated temperature, pressure, and humidity on the battery. However, the battery room wall was also a safety related pressure boundary as specified in MDS Report No. OS-73.2, dated April 25, 1973. As such, the licensee failed to identify corrective actions necessary to return the wall to a condition that met the safety related pressure boundary requirements.
Analysis:
The licensees failure to take timely corrective actions as required by 10 CFR 50, Appendix B, Criterion XVI was a PD. The PD was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Design Control and adversely impacted the cornerstone objective in that functionality of the pressure boundary was not maintained. The inspectors evaluated the safety significance of the finding using IMC 0609 Attachment 4, Determining the Significance of Reactor Inspection Findings At-Power Situations, dated June 19, 2012, and determined the finding was of very low safety significance (Green) because it did not actually result in a safety related system being inoperable. The PD has a cross cutting aspect of thoroughly evaluates problems in the CAP component of the Problem Identification and Resolution area because the licensee failed to evaluate the sheet metal plate to maintain the safety-related pressure boundary function of the battery room wall. P.1(c)
Enforcement:
10 CFR 50 Appendix B, Criterion XVI, Corrective Actions, required, in part, that measures shall be established to assure conditions adverse to quality, such as deficiencies and non-conformances are promptly identified and corrected. Contrary to the above, from August 30, 2007, until present, the licensee failed to correct the degraded Unit 3 control battery room pressure boundary wall, a condition adverse to quality, in a timely manner. Because the finding is of very low safety significance and has been entered into the licensees CAP as PIP-O-13-2311, this violation is being treated as a NCV consistent with section 2.3.2 of the NRC Enforcement Policy: NCV 05000287/2013002-01, Failure to Maintain Pressure Boundary in Unit 3 Control Battery Room.
1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
a. Inspection Scope
Tornado and High Energy Line Break (HELB) Project Modification - Normal Power Supply Feeders for the New Protected Service Water (PSW) System - The inspectors reviewed the Tan-Delta test results for long underground cable runs from the alternate power system (100 kV Fant line) to determine if the analyses of cable performance were based upon specified criteria that were consistent with performance standards published by cable manufacturers.
Tornado and HELB Project Modification - Electrical Equipment for the New PSW System - The inspectors reviewed EC 91833, OD500921 - (OMP) PSW Electrical Equipment Termination (Part B), and associated 10 CFR 50.59 screening to verify the adequacy of the modification package and evaluate the modification for adverse effects on the system.
The inspectors conducted a walkdown to assess the material condition of Class 1E electrical equipment installed in the PSW building. Equipment inspected included 13.8/4 KV switchgear BT6 and BT7, 10 MVA transformers CT6 and CT7, 600V load center LX PX13 (including transformer TF PX13), 600V motor control center XPSW, 125 VDC batteries BA 0001 and 0002, 125 VDC battery chargers BC 0001 and 0002, and the 125 VDC load center PSWDC001. The location, installation, and interconnections were checked to verify equipment items were completely assembled, protected against unauthorized access and use, and protected against intrusions of foreign material. The inspectors determined whether operating equipment exhibited anomalous indications or alarms and assessed the adequacy of temporary support measures such as fire monitoring and control of area environments.
The inspectors reviewed activities related to acceptance testing of electrical equipment installed in the PSW to assess adequacy of test procedures for verifying functionality of installed equipment. The inspectors conducted direct observations of testing of control logic circuitry for medium voltage circuit breakers installed in 13.8/4.16 kV switchgear B6T and B7T. The inspectors interviewed supervisors and test personnel to verify the test sequences and the expected responses to test inputs were understood. The inspectors evaluated the content and use of test procedures to verify activities followed planned and approved sequences and that testing scopes were sufficient to check all of the logic permissives and logic prohibits. Completed test records were reviewed to verify the documentation provided complete and legible records of the quality related activities.
The inspectors conducted direct observation of the replacement of medium voltage cable terminations on one of two parallel conductors of feeder OD500921. The replacement termination was provided on the cable identified as ECT 11E feeding from B6T-02 MV circuit breaker to PX13 transformer feeder bus connection. The inspectors observed Very Low Frequency (VLF) /Tan-Delta testing of the cable. Inspectors evaluated equipment used for control of testing to determine if the system was sufficiently controlled and reviewed completed test records to assess if documentation provided complete and legible records that assured the quality and integrity of information reported for the cable. Also, the inspectors inspected the actual settings of the switchgear relays to verify the settings were in accordance with the PSW switchgear loading and breaker coordination study. Documents reviewed by the inspectors are listed in the Attachment.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following six post-maintenance test procedures and/or test activities to assess if:
- (1) the effect of testing on the plant had been adequately addressed by control room and/or engineering personnel;
- (2) testing was adequate for the maintenance performed;
- (3) acceptance criteria were clear and demonstrated operational readiness consistent with design and licensing basis documents;
- (4) test instrumentation had current calibrations, range, and accuracy consistent with the application;
- (5) tests were performed as written with applicable prerequisites satisfied;
- (6) jumpers installed or leads lifted were properly controlled;
- (7) test equipment was removed following testing; and
- (8) equipment was returned to the status required to perform its safety function. Documents reviewed are listed in the Attachment.
- Alert and Notification System Sirens testing following reprogramming of computer servers
- Unit 0 SSF Diesel (A/B) Monthly Preventative Maintenance and Inservice Test
- Unit 1 B Reactor Building Spray Pump Test following motor replacement
- Unit 1 1HP-24 Testing after replacement of transfer switch
- Units 1 and 2 control room ventilation system A booster fan train carbon filter leakage test following carbon filter replacement
- Unit 3 A high pressure injection pump test following pump motor lubrication and ammeter calibration and pump mechanical seal cleaning and inspection
b. Findings
One licensee-identified violation was identified and documented in section 4OA7 of this report.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors either witnessed and/or reviewed test data for the four surveillance tests listed below to assess if the SSCs met TS, Updated Final Safety Analysis Report (UFSAR), and licensee procedure requirements. In addition, the inspectors determined if the testing effectively demonstrated that the SSCs were ready and capable of performing their intended safety functions. Documents reviewed are listed in the
.
Routine Surveillances
- IP/0/A/0380/006, Standby Shutdown Facility (SSF) Diesel Load and Speed Control
- PT/0/A/0400/004, SSF Diesel Engine Service Water Pump Test
- IP/0/A/3000/023 D, Performance Test of Keowee Battery Bank 1 In-Service Tests
- PT/1/A/0600/013, Motor Driven Emergency Feedwater Pump Test
b. Findings
No findings were identified.
OTHER ACTIVITIES
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed and evaluated the licensees performance in the Unit 1 Simulator, Technical Support Center, and field, during an emergency drill. The assessment focused on the timeliness and location of classification, offsite agency notification, and the licensees expectations of response. The inspectors also evaluated licensees staging of flood mitigation equipment onsite. The performance of emergency response organization was evaluated against applicable licensee procedures and regulatory requirements. The drill involved an initial report by Keowee Hydro personnel of a Condition B (Bravo) for Jocassee Hydro Dam resulting in an Unusual Event Declaration. This was followed by a subsequent report by Keowee Hydro personnel of a Condition A (Alpha) for the Jocassee Hydro Dam resulting in a Site Area Emergency declaration, Keowee Hydro Dam failure. Loss of all onsite and offsite power and flooding of the SSF resulted in a General Emergency declaration. The inspectors attended the post-exercise critique for the drill to evaluate the licensees self-assessment process for identifying potential deficiencies relating to failures in classification and notification. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee data to confirm the accuracy of reported PI data for the following PIs. To determine the accuracy of the report PI elements, the reviewed data was assessed against PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, Revision 6. Documents reviewed are listed in the Attachment.
Cornerstone: Initiating Events
- Unplanned Scrams (3 units)
- Unplanned Power Changes (3 units)
- Unplanned Scrams with Complications (3 units)
The inspectors sampled licensee submittals relative to the PIs listed above for the period January 1, 2012, through December 31, 2012. The inspectors verified that the licensee had adequately identified the number of scrams and unplanned power changes greater than 20 percent that occurred during the previous four quarters. The inspectors compared this number to the number reported for the PI during the current quarter. The inspectors also reviewed the accuracy of the number of critical hours reported and the licensees basis for determining that there were not complications for each of the reported reactor scrams. In addition, the inspectors interviewed licensee personnel associated with the PI data collection, evaluation, and distribution.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Daily Screening of Corrective Action Reports
In accordance with Inspection Procedure (IP) 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed daily screening of items entered into the licensees CAP. This review was accomplished by reviewing copies of PIPs, attending daily screening meetings, and accessing the licensees computerized database.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.
b. Findings
No findings were identified.
.2 (Closed) Temporary Instruction 2515/187 - Inspection of Near-Term Task Force
Recommendation 2.3 Flooding Walkdowns
a. Inspection Scope
The inspectors verified the licensees walkdown packages contained the elements as specified in NEI 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features, Rev. 0-A:
- Yard drain system
- Site elevation and topography including the 6 sill on the Auxiliary, Turbine, and Service Buildings
- SSF external wall penetrations The inspectors accompanied the licensee on their walkdown of the Keowee Spillway and SSF external wall penetrations and verified that the licensee confirmed acceptability of the following attributes for the flood protection features:
- Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed
- Critical SSC dimensions were measured
- Available physical margin, where applicable, was determined
- Flood protection feature functionality was determined using either visual observation or by review of other documents The inspectors accompanied the licensee on their simulation of AP/0/A/1700/047 and verified that the licensee confirmed acceptability of the following attributes for the flood protection feature:
- Verified that the procedure or activity can be executed as written
- Verified that the credited time dependant activities can be completed in the time required.
- Verified that the specified equipment and tools were staged and in good working condition.
The inspectors independently performed their walkdown of the probable maximum precipitation (PMP) rainfall event flood barriers (sandbags and griffolyn, tape, etc).
These are compensatory measures due to the 6 sill no longer remaining in all locations around certain buildings on site. In addition to using the above attributes, the inspectors verified acceptability of the flood protection features using the following attributes:
- Verified that sandbags were staged and in a condition to be used.
- Verified that the manual actions required to place the temporary portion of the flood protection feature could be performed within the required time considering the conditions that could be expected.
The inspectors verified that non-compliances with current licensing requirements, and issues identified in accordance with the 10 CFR 50.54(f) letter, Item 2.g of Enclosure 4, were entered into the licensee's CAP. In addition, issues identified in response to Item 2.g that could challenge risk significant equipment and the licensees ability to mitigate the consequences will be subject to additional NRC evaluation. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA6 Management Meetings (Including Exit Meeting)
Exit Meeting Summary
On April 15, 2013, the resident inspectors presented the inspection results to Mr. Batson and other members of licensee management. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation.
- 10 CFR 50.65 (a)(4) stated in part that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, on February 17, 2013, the licensee failed to assess and manage the risk when placing the 1A reactor building spray train in service for borated water storage tank recirculation for sampling. This condition made train A reactor building spray inoperable. This combined with train A high pressure injection being inoperable due to 1HP-24 (high pressure injection borated water storage tank suction isolation valve)the plant was in an orange risk condition. The licensee previously evaluated risk for an emergent condition associated with 1HP-24 and determined 1HP-24 was available and that the unit was in a yellow risk condition. The licensee recognized this omission later that day and entered the condition into their corrective action program as PIP-O-13-01822. The licensee also restored the reactor building spray train to its normal standby lineup. This finding was assessed using IMC 0609, Phase 1 screening worksheet of Attachment 4 and Appendix K was determined to be of very low safety significance (Green), because the incremental core damage probability is less than 1E-6.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee
- K. Alter, Regulatory Compliance Manager
- S. Boggs, Emergency Services Coordinator
- E. Burchfield, Engineering Manager
T. Cheslak; Oconee Fire Protection Engineer
P. Fisk; Superintendent of Operations
- P. Gillespie, Site Vice President
- R. Guy, Organization Effectiveness Manager
- T. King, Security Manager
- A. Lotfi, Duke - Construction
- T. Patterson, Safety Assurance Manager
- T. Ray, Station Manager
- F. Rickenbaker, OMP Manager
- D. Robinson, Radiation Protection Manager
- J. Smith, Regulatory Compliance
- P. Street, Emergency Planning Manager
NRC
LIST OF REPORT ITEMS
Opened and Closed
- 05000269/2013002-01 NCV Failure to Maintain Pressure Boundary in Unit 3 Control Battery Room (Section 1R15)
Closed
2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns (Section 4OA5.2)