IR 05000269/2014004
| ML14295A581 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/22/2014 |
| From: | Frank Ehrhardt NRC/RGN-II/DRP/RPB1 |
| To: | Batson S Duke Energy Corp |
| References | |
| IR 2014004 | |
| Download: ML14295A581 (24) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 22, 2014
SUBJECT:
OCONEE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000269/2014004, 05000270/2014004, 05000287/2014004
Dear Mr. Batson:
On September 30, 2014, 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 October 16, 2014 with you and other members of your staff. No findings of greater than minor significance were identified.
In accordance with 10 Code of Federal Regulations 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/
Frank Ehrhardt, 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 05000269/2014004, 05000270/2014004, 05000287/2014004 w/Attachment: Supplementary Information
REGION II==
Docket Nos: 50-269, 50-270, 50-287 License Nos: DPR-38, DPR-47, DPR-55 Report Nos: 05000269/2014004, 05000270/2014004, 05000287/2014004 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station, Units 1, 2 and 3 Location: Seneca, SC 29672 Dates: July 1, 2014, through September 30, 2014 Inspectors: E. Crowe, Senior Resident Inspector G. Croon, Resident Inspector N. Childs, Resident Inspector J. Austin, Senior Resident Inspector - Shearon Harris Nuclear Power Plant M. Riley, Reactor Inspector (Section 1R17 and 4OA5)
G. Crespo, Senior Construction Inspector (Section 1R17 and 4OA5)
A. Vargas, Reactor Inspector (Section 1R17)
Approved by: Frank Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000269/2014-004, 05000270/2014-004, 05000287/2014-004; 07/01/2014 - 09/30/2014;
Oconee Nuclear Station Units 1, 2 and 3; Integrated Inspection Report The report covered a three-month period of inspection by the resident inspectors, visiting resident inspector, and visiting Region-II inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process revision 5.
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near 100 percent rated thermal power (RTP) for the inspection period.
Unit 2 operated at or near 100 percent RTP for the inspection period.
Unit 3 operated at or near 100 percent RTP for the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R04 Equipment Alignment
a. Inspection Scope
Partial Walkdowns: The inspectors performed the five 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 corrective action program (CAP). Documents reviewed are listed in the
.
- Unit 1, 2, and 3 electrical distribution systems, CT-4 and CT-5 during dual unit outage at Keowee Hydro
- Unit 1,2, and 3 electrical distribution systems, CT-4 and CT-5 during 0HPSW-25, elevated water storage isolation valve outage
- Unit 1,2, and 3 electrical distribution systems, CT-4 and CT-5 during KHU-1 Pole Replacement
- Unit 3 electrical distribution systems, during 3KI Inverter OOS for planned maintenance
- PSW electrical distribution systems, during PSW pump installation
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.
- U1/2, Blockhouse - fire zone 45
- Unit 0, CT-4 - fire zone 46
- Unit 0, Keowee Hydro - fire zone KHS-001
- Unit 1/2, Control Room - fire zone 110 Fire Drill Observation: Inspectors observed the performance of a shift fire drill on July 11, 2014. The licensee conducted a drill simulating a fire at the hydrogen bulk storage cage located in the plants protected area. The inspectors observed this drill to verify the fire brigades use of protective gear and fire-fighting equipment; that fire-fighting pre-plan procedures and appropriate fire-fighting techniques were used; and that the directions of the fire brigade leader were thorough, clear and effective. The inspectors also observed the post-drill critique to assess if it was appropriately critical, included discussions of drill observations, and identified any areas requiring corrective action. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
Submerged or Buried Cable Inspections: The inspectors inspected the condition of the following cable trench through direct observation. The inspectors inspected the trench to ensure there was no standing water and that the cables within the trench were intact and in good condition.
- CT-5 switchyard trench
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
Routine Operator Requalification Review: On August 26, 2014, the inspectors observed one active simulator training session to assess the performance of licensed operators during the session. The scenario involved dropped rods, steam generator tube rupture, and loss of main feed water. Events progressed to a point where the crew declared a site area emergency declaration. The post-scenario critique conducted by the training instructor and the crew was also observed. Documents reviewed are listed in the
.
Observation of Operator Performance: The inspectors observed operator performance in the main control room on August 23, 2014, during Unit-2 down power and turbine valve movement. 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
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the licensees effectiveness in performing the two activities listed below. 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 Attachment.
- PIP-O-14-08363, 0HPSW-25, elevated water storage tank level control valve has significant leakage following maintenance
- Review of 10 CFR 50.65(a)(3) periodic evaluation
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 three activities listed below:
1) the completeness 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.
- Orange risk assessment and management in response to dual unit outage at Keowee Hydro to set Unit 1 rotor and dewater tailrace
- Orange risk assessment and management in response to HPSW-25 periodic maintenance
- Yellow risk assessment and management response for SSF monthly outage
b. Findings
No findings were identified.
1R15 Operability Evaluations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed the following eight 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.
- PIP-O-02-00634, SSF cable trench is not designed for tornado/missile loads
- PIP-O-14-07438, Unit 1 and 2 block house enclosure fan 1A not running
- PIP-O-14-07504, switchyard battery 2 cell 51 Specific gravity low
- PIP-O-14-07777, 2B low pressure injection (LPI) pump venting following draining of train B LPI for maintenance to 2LP-35 (2C LPI pump discharge check valve)
- PIP-O-14-08609, paint chips discovered inside A and B SSF diesel engine top deck covers
- PIP-O-14-09597, through wall leak discovered of the Unit 3 turbine driven emergency feedwater pump recirculation line down stream of 3FDW-89
- Work platform attached to Unit-3 instrument air receiver without seismic evaluation
b. Findings
No findings were identified.
1R17 Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications
a. Inspection Scope
Evaluations of Changes, Tests, and Experiments: The team reviewed two safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59, to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The team also reviewed eight screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The team reviewed these documents to determine if:
- the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required
- the safety issues requiring the changes, tests, or experiments were resolved
- the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59
- the design and licensing basis documentation used to support the change was updated to reflect the change The team used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. Documents reviewed are listed in the
.
Permanent Plant Modifications: The team reviewed the following four permanent plant modifications that had been installed in the plant during the last three years to determine if 1) the supporting design and licensing basis documentation was updated; 2) the changes were in accordance with the specified design requirements; 3) the test documentation as required by the applicable test programs had been updated; and 4)post-modification testing adequately verified system operability and/or functionality. The team also used applicable industry standards to evaluate acceptability of the modifications and performed walk-downs of accessible portions of the modifications.
Documents reviewed are listed in the Attachment.
- EC 91834, Unit 1 High Pressure Injection Alternate Power Feed from PSW
- EC 91857, Unit 2 High Pressure Injection Alternate Power
- EC 91868, Unit 3 High Pressure Injection Alternate Power from PSW
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following three modifications to verify the adequacy of the modification package and the 10 CFR 50.59 screenings and to evaluate the modification for adverse effects on system availability, reliability, and functional capability.
Documents reviewed are listed in the Attachment.
- OD200503, EPR Water Extraction Door Installation (Flood Outlet Device)
b. Findings
Introduction An Unresolved Item (URI) was identified to review the licensees re-evaluation of the initial 50.59 evaluation for the Flood Outlet Device to determine if the performance deficiency is more than minor.
Description In November 1998, the licensee identified that a HELB induced flood in the EPR could spread to other components in the Auxiliary Building (AB) and affect the ability of various safe shut down (S/D) equipment to perform its safety-related function as described in the Final Safety Analysis Report (FSAR). The licensee developed a modification package in April 2006, to install a Flood Outlet Device (FOD) which required a 50.59 evaluation. An initial 50.59 screening determined that the FOD modification did not require a detailed 50.59 evaluation. On August 21, 2006, the licensee conducted a review of the 50.59 screening and, as documented in PIP O-06-05726, were not able to conclusively determine if the correct conclusion had been made. A corrective action was identified in the corrective action document to perform an in-depth 50.59 screening and evaluation.
The inspectors determined, through personnel interviews and review of documentation, that the licensee failed to perform this corrective action for a condition adverse to quality.
The licensee is performing a revised 50.59 screening. The inspectors will evaluate the results of the screening to determine if a performance deficiency exists. This is identified as URI 05000270/2014004-01, Review of FOD 50.59 Evaluation.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following five 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.
- PT/2/A/0203/006, Low Pressure Pump Test - recirculation following replacement of the 2C low pressure injection (LPI) pump discharge check valve
- PT/1/A/0251/001, Low Pressure Service Water Pump Test (C LPSW pump), after motor replacement per WO 02031035
- IP/0/B/0202/001 L, 2HP-15 Functional test after controller replacement per WO 02169910
- PT/1/A/0600/012, Unit 1 TDFDWP retest, after routine maintenance, per WO 02148560
- PT/3/A/0204/007, Unit 3B Reactor Building Spray test after mechanical and electrical PM per WO 02161975
b. Findings
No findings were identified.
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
- PT/2/A/0600/010, Reactor Coolant Leakage (U2 experienced elevated RCS leakage)
- PT/2/A/0203/006A, Low Pressure Injection Pump Test - Recirculation (2A LPI Pump)
- PT/2/A/2200/018, Keowee Hydro Unit 2, B Governor Oil Pump Test In-Service Tests
- PT/1/A/0202/011, High Pressure Injection Pump Test (1A HPI pump)
b. Findings
No findings were identified.
OTHER ACTIVITIES
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors evaluated the licensees performance in the simulator on July 15, 2014, during quarterly emergency response organization (ERO) drill 14-04 and again on August 19, 2014 during graded emergency response organization (ERO) drill 14-05.
The NRC assessment focused on the timeliness and location of classification, offsite agency notification, and the licensees expectations of response. The performance of emergency response organization was evaluated against applicable licensee procedures and regulatory requirements. The inspectors attended the post-exercise critique for the drills 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 nine 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.
Cornerstone: Mitigating Systems
- MSPI Heat Removal (3 units)
- Safety System Functional Failures (3 units)
Cornerstone: Barrier Integrity
- RCS Leakage (3 units)
For the period of September 20, 2013, through September 30, 2014, the inspectors reviewed Chemistry database data, Operating Logs, Train Unavailability Data, Maintenance Records, Maintenance Rule Data, PIPs, Consolidated Derivation Entry Reports, and System Health Reports to verify the accuracy of the PI data reported for each PI.
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.
.2 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected the issue listed below for a more in-depth review. The inspectors considered the following during the review of the licensees actions:
1) complete and accurate identification of the problem in a timely manner; 2) evaluation and disposition of operability/reportability issues; 3) consideration of extent of condition, generic implications, common cause, and previous occurrences; 4) classification and prioritization of the resolution of the problem; 5) identification of root and contributing causes of the problem; 6) identification of CRs; and 7) completion of corrective actions in a timely manner.
- Keowee governor air and oil pressure/level requirements
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Verification of Completion of Milestone 3 of Protected Service Water Major Plant
Modification
a. Inspection Scope
Milestone 3 of Confirmatory Order EA-13-010 of July 1, 2013, (ML13114A928) states:
The licensee shall provide the capability to supply electrical power from the PSW building switchgear to simultaneously operate at least one high-pressure injection pump per unit, and to operate the associated valves needed to align water flow to the reactor coolant pump seals and to inject water into the reactor coolant system, as an alternate path within the emergency operating procedures.
This modification along with approved plant procedures and the completion of operator training necessary to accomplish this lineup, and a combination of testing and engineering evaluation in accordance with station procedures which verifies this capability, will be completed and operational no later than October 1, 2014.
The inspectors reviewed design change modifications and associated post-modification testing and found that the licensees modification met the intent of Milestone 3. The inspectors reviewed the installation and design of the power feeds from the protected service water (PSW) switchgear to the high pressure injection (HPI) manual alignment switches and transfer switches to verify that the licensee had the capability to supply electrical power from the PSW switchgear to simultaneously operate at least one HPI pump per unit. The inspectors reviewed the installation and design of the power feeds from the 600V PSWLXPX13 load center to verify that the licensee had the capability to supply electrical power from the PSW switchgear to operate the associated valves needed to align water flow to the reactor coolant pump seals and to inject water into the reactor coolant system. The inspectors also reviewed the 125 VDC feeds to panels 1PSW2DC, 2PSW2DC, and 3PSW2DC and the associated distribution to each of the three nuclear plant units. The inspectors reviewed drawings, calculations, product data sheets and cable separation criteria to verify that applicable requirements were met.
The inspectors also conducted a walk down to assess the material condition of the electrical equipment installed in the PSW building, the HPI manual alignment and transfer switches, and newly added valves associated with the milestone.
The inspectors reviewed licensee procedures and training activities related to installation and testing of permanent equipment necessary to power the high pressure injection (HPI) pumps of all three units from the protected service water (PSW) electrical bus.
The inspectors verified that station procedures were adequate for station operators to accomplish the energization of the PSW electrical bus. The inspectors also verified that adequate training was provided to personnel to accomplish the above task. The inspectors observed the start of Unit 2 and Unit 3 HPI pumps from PSW electrical power during the fall outages of 2013.
4OA6 Management Meetings (Including Exit Meeting)
Exit Meeting Summary
On October 16, 2014, the resident inspectors presented the inspection results to Mr.
Scott Batson and other members of licensee management. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee
- S. Batson, Site Vice President
- S. Boggs, Emergency Services Coordinator
- E. Burchfield, Engineering Manager
T. Cheslak; Oconee Fire Protection Engineer
P. Fisk; Superintendent of Operations
- R. Guy, Organization Effectiveness Manager
- A. Lotfi, Duke - Construction
- M. McNeely, Security Manager
- 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
- C. Wasik, Regulatory Compliance Manager
NRC
LIST OF REPORT ITEMS
Opened
- 05000270/2014004-01 URI Review of FOD 50.59 Evaluation (Section 1R18)