ML15224A570

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Insp Repts 50-269/89-17,50-270/89-17 & 50-287/89-17 on 890520-0618.Violations Noted.Major Areas Inspected: Operations,Surveillance Testing,Maint Activities,Safeguards & Radiation Protection & Outage Activities
ML15224A570
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/17/1989
From: Shymlock M, Skinner P, Wert L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML15224A568 List:
References
50-269-89-17, 50-270-89-17, 50-287-89-17, GL-88-17, NUDOCS 8908010144
Download: ML15224A570 (32)


See also: IR 05000269/1989017

Text

o

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION 11

101 MARIETTA ST.. N.W.

ATLANTA, GEORGIA 30323

Report Nos.:

50-269/89-17, 50-270/89-17, 50-287/89-17

Licensee:

Duke Power Company

422 South Church Street

Charlotte, NC

28242

Docket Nos.:

50-269, 50-270, 50-287

License Nos.

DPR-38,

DPR-47, DPR-55

Facility Name:

Oconee Nuclear Station

Inspection Conducted: May 20 - June 18, 1989

Inspectors:,

(',

1W

P. H. Skinner, Seniop/Resident Inspector

DatVSigned

L.

r,

esi oAt Inspector

e Signed

Approved

'y:

I

7

  • '

M. B. Shymlock, Section Chief

ate Signed

Division of Reactor Projects

SUMMARY

Scope:

This routine, announced inspection involved resident inspection on-site in the

areas of operations, surveillance testing, maintenance activities, safeguards

and radiation protection, outage activities, reduced inventory operations and

inspection of open items.

Results:

Two examples of a TS violation concerning procedure inadequacies associated

with the AC power distribution systems were discovered during this period.

Both situations apparently resulted from operating in accordance with

procedures which failed to adequately consider TS operability requirements.

A continuing weakness exists in the operations area due to the complexity of

the TS associated with the EPSL system and the lack of understanding of its

operation.

908 10144 -90717

PDR

ADOCK 05000269

CPDC

REPORT DETAILS

1. Persons Contacted

Licensee Employees

  • M. Tuckman, Station Manager
  • S. Baldwin, Nuclear Production Engineer
  • C. Boyd, Site Design Engineer Representative
  • T. Curtis, Compliance Manager

J. Davis, Technical Services Superintendent

D. Deatherage, Operations Support Manager

W. Foster, Maintenance Superintendent

T. Glenn, Instrument and Electrical Support Engineer

D. Havice, Instrument & Electrical Engineer

D. Hubbard, Performance Engineer

  • E. Legette, Assistant Engineer Compliance

H. Lowery, Chairman, Oconee Safety Review Group

J. McIntosh, Administrative Services Superintendent

G. Rothenberger, Integrated Scheduling Superintendent

  • R. Sweigart, Operations Superintendent

Other licensee employees contacted included technicians, operators,

mechanics, security force members, and staff engineers.

NRC Resident Inspectors:

  • P.H. Skinner

L.D. Wert

  • Attended exit interview.

2. Plant Operations (71707)

a. The inspectors reviewed plant operations throughout the reporting

period to verify conformance with regulatory requirements, technical

specifications (TS), and administrative controls. Control room logs,

shift turnover records, and equipment removal and restoration records

were reviewed routinely.

Discussions were conducted with plant

operations, maintenance, chemistry, health physics, instrument and

electrical (I&E), and performance personnel.

Activities within the control rooms were monitored on an almost daily

basis.

Inspections were conducted on day and on night shifts, during

week days and on weekends.

Some inspections were made during shift

change in order to evaluate shift turnover performance.

2

Actions observed were conducted as required by the Licensee's

Administrative Procedures.

The complement of licensed personnel on

each shift inspected met or exceeded the requirements of TS.

Operators were responsive to plant annunciator alarms and were

cognizant of plant conditions.

Plant tours were taken throughout the reporting period on a routine

basis. The areas toured included the following:

Turbine Building

Auxiliary Building

Units 1, 2 and 3 Electrical Equipment Rooms

Units 1, 2 and 3 Cable Spreading Rooms

Keowee Hydro Station

Station Yard Zone within the Protected Area

Standby Shutdown Facility

Units 1/2 Spent Fuel Pool Room

Intake Structure

ISFSI Construction Site

Unit 1 Reactor Building Containment

During the plant tours, ongoing activities, housekeeping, security,

equipment status, and radiation control practices were observed.

Units 1 and 3 operated at 100% power for this reporting period. The

only exception was a reduction to 93 percent power on Unit 3 at the

request of the dispatcher (load following) for about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on June

18.

Unit 2 entered End of Cycle 10 refueling outage May 20,

1989.

Presently the outage is scheduled to complete on July 2.

Commissioner Curtiss visited the facility on June 5, 1989.

The

Commissioner toured various areas,

including the Keowee Hydro

Station, and sat in on an outage meeting for Unit 2. The Plant

Manager provided a short briefing which discussed plant design

features,

some Oconee statistics and areas in which the plant

management is concentrating to improve maintenance.

Enclosure 3

contains a copy of the slides used by the licensee for this

presentation.

b. Fire Protection Sprinkler System

On May 22, 1989, the licensee notified the inspectors that the fire

protection sprinkler system for the cable and equipment rooms of each

unit were not properly designed such that their supply pressure

requirements would meet the current guidance for operation.

The

sprinkler system is a portion of the High Pressure Water System

3

(HPSW)

which is used for fire suppression for all units.

The system

is supplied by an elevated storage tank and two pumps. A third pump,

a much smaller jockey pump, is used to maintain level in the tank and

system pressure.

Under normal conditions the sprinkler systems in

the cable and equipment rooms are isolated.

One of the design

requirements for the sprinkler system is to provide 0.1 gpm per

square foot of space in each room.

The original calculations

performed prior to 1980, to assure that the design of the sprinkler

system met this value, used a pressure equivalent to system operation

with a running pump.

Under normal operation, the pumps are run in a

standby configuration and do not start automatically until a set

pressure drop or elevated tank low level setpoint is reached. Upon

identification of this problem, the licensee entered the Limiting

Conditions for Operations

(LCO)

associated with TS 3.17.3 and

immediately notified verbally and by memo the operations personnel

(fire brigade leaders) to start a fire pump upon any fire in the

cable and equipment room that requires the use of the sprinkler

system. This was followed by changes to the applicable fire fighting

procedures on May 23,

1989.

The inadequacy of the design of the

cable room sprinklers was identified by Licensee Event Report (LER) 269/87-11 dated January 4, 1988. At that time, piping modifications

were performed and several valves were identified that were labeled

and more closely controlled to correct this problem. Although this

LER stated that the ability to supply a flow of 0.10 gpm per

square foot of floor area was contingent upon the HPSW system

supplying 1238 gpm at a pressure of 92.21 psig to the inlet of the

sprinkler system, this information did not apparently get an adequate

review to assure the pressure at the sprinkler inlet met the design

conditions with the HPSW pumps not operating. This information was

discussed with the Region II fire protection group. This group will

review this area during their next inspection at this plant.

This

is identified as Inspector Followup Item (IFI) 269,270,287/89-17-03:

Adequacy of Fire Protection Sprinkler System Pressure.

c. Emergency Power Switching Logic (EPSL) Issues (71707)

During the report period the licensees Design Engineering (DE) group

discovered, as a result of a Design Basis Document analysis program,

several problems with the Emergency Power Switching Logic (EPSL)

system.

The EPSL system is provided to ensure that a continuous

source of power is supplied to the Oconee units under various

operating conditions. The EPSL system is a complex logic network

which is intended to ensure that the appropriate available power

source is automatically aligned to the essential loads as required

under various conditions/casualties.

The AC power system is an

interconnected set of several subsystems including the following:

-

the auxiliary power systems of each of the units (startup

transformer, main transformer and auxiliary transformer)

-

the Keowee Hydro Station and associated paths

-

the 100 KV Line from Lee Steam Station and Central Switchyard

4

The two unit Keowee Hydrostation provides emergency power when normal

and startup sources are not available. One unit provides a dedicated

underground power path (via transformer CT-4 and the Standby buses)

and the second unit a separate overhead power path (via a safety

related switchyard bus and each units associated startup transformer)

to supply power to the Main Feeder Buses (MFB)

of the

units (2 MFB

per unit which supply essential loads) when required.

The startup

transformers

(CT1,

CT2 and CT3),

which provide power in normal

shutdown conditions, are also available to supply power to the MFB in

certain casualties. The 100 KV system consisting of a 100 KV power

supply line (via CT5 and the standby buses) also provides emergency

power during certain conditions (see Enclosure 4, Oconee Emergency

Power Distribution).

At about 2 p.m. on June 7, 1989, DE identified that the TS governing

operation of the Oconee Electrical Distribution System (including

EPSL) permits an alignment which could cause the plant to be operated

in an unanalyzed condition.

TS 3.7.1(b)1.,

which requires the

underground power path from the Keowee Hydrostation to be operable,

specifically states that only one of the two standby buses is

required to be operable.

DE determined that this permits a

configuration which makes the units susceptible to a single failure

in certain conditions.

If one standby bus is out of service for

maintenance, i.e. its associated feeder breaker from Keowee, (SK1 or

SK2) and each units standby bus breaker (S1 or S2) are open, and a

Loss Of Coolant Accident(LOCA) with a concurrent Loss of Offsite

Power (LOOP) occurs, and a single failure (failure of the standby

breaker to close) from the energized standby bus, the result would be

a loss of automatic power restoration to the MFB.

-

On the LOCA unit after a 12 second delay the EPSL would sense

the voltage on the standby bus energized by a Keowee unit and

supplied via CT4.

The EPSL would not shift to the other

emergency power path (the startup source - which would be

energized from the other Keowee unit via the startup trans

former and a dedicated-switchyard bus) even though the failure

of the S1 or S2 breaker to shut would cause the MFB to remain

deenergized. This is due to a portion of the EPSL which is

called "Retransfer to Startup" which would not be actuated.

This "Retransfer to Startup" logic senses that the EPSL has, or

has tried, to transfer power for the essential loads to the

standby bus during this casualty situation. The "Retransfer to

Startup" enables a retransfer of the MFB's back to the startup

source if the standby bus loses power or if the startup bus

becomes available before power reaches the standby bus. Once the

retransfer logic is satisfied and after a 10 second time delay,

5

the Si and S2 breakers will get a trip signal and the closure of

the El and E2 (startup transformer power path) breakers can

occur. However, if the only operable S breaker does not trip,

this logic will not be satisfied.

The EPSL,

as long as it

senses voltage present on the standby bus, would not shift to

the other available source automatically. The stations Abnormal

Procedure (AP) 1700/11 "Loss of Power" section 502 provides some

guidance to the operators concerning manually energizing MFBs.

In this particular scenario that guidance alone would not have

enabled the operator to restore power to the MFB in a prompt

manner.

-

The non-LOCA units would be supplied power automatically from

their respective El and

E2

breakers via their startup

transformers and the Keowee unit through the switchyard.

(A

system called the Main Feeder Bus Monitor Panel (MFBMP)

logic

would automatically cause this to occur.)

At about 3 p.m. on June 8, 1989, a second issue closely related to

this first situation was identified.

As a part of the compensatory

action to prevent more than one unit loading simultaneously onto the

100KV (SL1 and SL2) line when being supplied by the Lee Steam Station

during a LOCA/LOOP situation, since the 100KV source had been

determined unable to support such loading (see LER 269/88-13),

a

change was made to Operating Procedure (OP) O/A/1107/03, 100 KV Power

Supply.

This change placed the S1 and S2 breaker switches in

"manual" (this action removes automatic closure ability) whenever

the 100 KV line was being utilized to energize the standby buses.

This change, unknowingly, also removed a functional unit required to

be operational for the EPSL system. Under these conditions, if a

LOCA/LOOP occurred, the following would happen:

-

On the LOCA unit, the S1 and S2 breakers would not shut

automatically as required. The EPSL circuitry would sense a

voltage on the standby buses (from Keowee via CT4)

and not

permit actuation completion of the "Retransfer to Startup"

circuitry. The MFB on the LOCA unit would remain de-energized

until the control room operators took action. In this situation

existing procedural guidance would enable the operator to

restore power quickly and easily.

-

On the non LOCA unit, the MFBMP logic would cause power to be

supplied through the overhead path and the associated El and E2

breakers.

A third issue was also identified at about 3:00 p.m. on June 8. If

one unit's MFBs are powered from the Central Switchyard and the 100

KV line via CT5and the SL1, SL2 breakers through the standby buses,

(such as during maintenance on the startup transformer) under certain

degraded voltage conditions, the EPSL would not'be able to provide a

6

power path automatically.

The low voltage signal to EPSL of the

standby bus source will be actuated only if the voltage degrades to

about 50%.

If voltage only degrades to about 60%, many of the ES

required pumps will trip or stall.

Under a LOCA/LOOP scenario, (LOCA

on a unit not supplied by the 100 KV line), since the SL1 and SL2

breakers remain shut, the SK1 and SK2 breakers cannot shut to provide

power to the MFB from the Keowee unit (the SL1,

SL2 and SK1,

SK2

breakers are interlocked).

The EPSL circuitry would continue to

sense that the standby buses are energized and a retransfer to the

startup source would not automatically occur. Operator action would

be required to restore power to the essential loads.

The licensee promptly reported these discoveries to the NRC as

required and initiated corrective actions.

Procedural changes were

made to prevent placing both S breaker switches in manual and

inadvertently effecting EPSL operability.

The CT5 (100 KV) power

path will not be utilized via Central Switchyard unless required by

the applicable Abnormal Procedure. Operators were directed not to

place standby buses out of service for maintenance or testing. A

training package discussing this action has been promulgated.

The first and third issues are relatively complex and only a detailed

examination of all possible EPSL configurations and single failures

would be expected to lead to their discovery. The second situation

(the S1 and S2 breakers being placed in manual) is a more easily

recognized scenario. This action was performed with the concurrence

of the DE group and indicates a significant lack of knowledge

throughout the licensee's work groups concerning EPSL. This lack of

knowledge has been previously addressed by various documentation

including the following:

-

LER 269/87-09 identified a condition where two functional units

of the EPSL system were taken out of service due to apparent

conflicts in TS 3.7. This LER recognized the complexity of this

system and the TS and committed to correcting this problem with

a TS amendment by July 15,1988.

This date was subsequently

changed to March 15,1989.

-

LER 269/88-04 reported that the retransfer to startup logic had

been inhibited on 'several occasions by removing the control

power fuses for the SK1 and SK2 breakers thus placing the plant

in an unanalyzed condition.

An information meeting held with

Region II on April 12, 1988 addressed that incident and included

a discussion of a scheduled Self Initiated Technical Audit among

the corrective actions.

-

In October 1988,

DE had determined several scenarios in which

standby bus voltage may have been inadequate during casualties.

It was calculated that the voltage would have been adequate for

7

2 units at power and the other in cold shutdown as long as the

standby breaker switches remained in "manual"

(LER 269/88-13).

LER 270/89-01 reported that the station had been operated in an

unanalyzed electrical power configuration because these switches

had been left in "automatic" with the standby bus for one unit

energized

from

CT5 via the Lee station.

(Violation

50-269/89-08-02 was written to address other concerns involved

with that situation.)

-

IFI 269,270,287/88-15-01; In July 1988 the inspectors discussed

their concern about the problems associated with EPSL. At that

time they issued this followup item to assure that the licensee

would conduct additional training to operators in this area.

Although this problem was discovered as a result of a DE study of the

EPSL system, with the attention and significance being given to the

"retransfer of startup" portion of the EPSL, the licensee should have

been aware of the functions of the switch positions within the EPSL

system prior to this time.

Operation with the S1 and S2 control

switches in manual is an apparent violation of TS 3.7.1(c) which

specifies the EPSL circuits must be operable. A functional unit of

Table 3.7-1 requires operability of the S1 and S2 control circuitry

including retransfer to startup circuits. This is identified as one

example of Violation 269,270,287/89-17-01: Electrical Distribution

System TS Violations Due To Inadequate Procedures.

The safety significance of this violation is minor due to the very

low probability of the scenarios required to result in these

accidents. In addition, over the many years of operation the Oconee

electrical distribution system has been very reliable. Also in one of

the projected scenarios, procedures existed to aid the control room

operators to restore power quickly.

The inspectors continue to be concerned that the knowledge of this

complex system appears to be limited at the site. In addition, more

guidance and training should be given to operators in order to assure

their understanding of the complex and sometimes conflicting

requirements of TS 3.7, particularly in the area of EPSL functional

units. The licensee should expedite the changes needed to clarify TS 3.7, develop onsite knowledgeable personnel and train appropriate

operations

personnel

on

this

system and the TS. IFI

269,270,287/88-15-01:

Retraining of Personnel on EPSL Operation

remains open.

d. Inadequate Procedure for Testing Emergency System Actuation

On June 18, 1989 during conduct of PT/2/A/0610/01J, EPSL ES Actuation

Keowee Emergency Start Test, the operators noted that both standby

bus supply breakers from Keowee (SK1

and SK2) were open and their

breaker control selector switches were in manual. Keowee Unit Two was

aligned to the underground path and on an ES signal would not be

8

available to supply power via the overhead path.

Since Unit One of

Keowee had been placed in a locked out condition (inability to

startup on any signal) as part of the test, the positioning of these

selector switches in manual removed the circuitry that would allow

the main feeder buses to be automatically energized on an emergency

signal if a LOOP occurred.

Although this was identified by the

operators and only existed for 20 minutes, this placed the units in

an unanalyzed condition. This condition removed all automatic

emergency power restoration capabilities to the essential loads of

the two operating units. Both units one and three were aware of the

test and the actions involved by the test. Control room operators

could have rapidly restored power by operating the appropriate

breaker switches.

This condition has existed during previous

refueling outages since similar procedures are used on units one and

three. This is another example of a lack of understanding of all

aspects of the facilities complex electrical distribution system.

TS 3.7.6 requires that if all the conditions of TS 3.7.1 are not met

and planned tests or maintenance are required which will make both

Keowee units unavailable, the Standby buses shall first be energized

by a Lee gas turbine via the dedicated 100KV line.

In this case a

planned test resulted in both Keowee units being unavailable and the

conditions of TS 3.7.6 were not met. This condition could not have

been met during this test since portions of the test require the

standby buses being deenergized. However, the procedural requirement

to have the remaining Keowee unit in a locked out condition during

this part of the test was inappropriate. Keowee Unit One could have

been available to preclude this condition. This is another example of

violation 269,270,287/89-17-01: Electrical Distribution System TS

Violations Due To Inadequate Procedures,

and will be combined with

the example discussed in 2.c discussed above.

Procedures exist to

aid the operator in restoration of power had this condition occurred.

e. Discretionary Enforcement

On June 16,

1989, the licensee requested discretionary enforcement

associated with TS 4.8.2.

This TS requires that during each

refueling outage the Main Steam Stop Valves (MSSV's) be leak tested

at 59 psig. The specified allowable leakage rate is limited to less

th'an 0.25 cubic feet per hour.

In the past the licensee had

collected this leakage as a liquid and had not converted the obtained

leakage into a vapor. In converting the results of previous tests to

a vapor, the licensee determined that this TS has not been met. An

analysis conducted by the licensee had determined that there is no

design basis for this requirement and that the leakage criteria is

not required to mitigate the consequences of any accident.

The

safety function of the valves is tested by the inservice test program

(stroke time testing).

A conference call between members of the

licensee, NRC Region II management, NRC Headquarters management, and

9

the Resident Inspector was conducted on June 16,

in which the

licensee provided information concerning this subject.

Following

this discussion, the NRC granted the enforcement discretion for this

outage on Unit 2, based on the information provided and confirmation

that the licensee would generate a proposed change to the TS to

remove this requirement by July 14,

1989.

Based on the licensee's

report that a violation of TS 4.8.2 has occurred on past unit

outages, a violation will be identified associated with this problem.

This violation is not being cited because the criteria specified in

Section V.G of the Enforcement Policy were satified. This item is

being identified as a non-cited violation (NCV)

50-269,270,287/

89-17-02, Failure to Perform Appropriate Testing As Required By TS 4.8.2. and based on the actions taken by the licensee and review by

the inspectors, this item is closed.

No additional violations or deviations were identified.

3. Surveillance Testing (61726)

a. Surveillance tests were reviewed by the inspectors to verify

procedural and performance adequacy.

The completed tests reviewed

were

examined for necessary test prerequisites,

instructions,

acceptance criteria, technical content, authorization to begin work,

data collection, independent verification where required, handling of

deficiencies noted,

and review of completed work.

The tests

witnessed, in whole or in part, were inspected to determine that

approved procedures were available, test equipment was calibrated,

prerequisites were met, tests were conducted according to procedure,

test results were acceptable and systems restoration was completed.

Surveillances reviewed and witnessed in whole or in part:

IP/2/A/305/1K

RPS Ch. 'C' RC Flow Inst. Calibration

IP/0/A/375/01B ASW System Steam Generator Level

Indication (SSF)

TT/2/A/375/01B Motor Driven Emergency Feedwater Pump Head

Curve Verification Test

PT/2/A/0610/01J EPSL Emergency Switchgear Actuation Keowee

Emergency Start Test

PT/2/A/0610/01H EPSL Standby Breaker Closure Channel A,B

b. Motor Driven Emergency Feedwater Pump Testing

On May 22,

1989 a performance test was conducted on the 2A and 2B

Motor Driven Emergency Feedwater Pumps

(MDEFWP)

in accordance with

Performance Test (PT)

2/A/0600/22,

Motor Driven Feedwater

Pump

Suction Check Valve Test, dated January 26,

1988.

The purpose of

this test was to demonstrate the ability of the MDEFWP to take a

suction from the hotwell,

to check several valves to verify full

10

cycling capability and collect head curve data for Design Engineering

(DE)

under full flow conditions. The data obtained by this test

indicated the 2A pump was marginally acceptable and that the 2B pump

was unacceptable. Further testing was performed following calibra

tion checks and installing test instrumentation. The results again

indicated that the 2B pump was unsatisfactory and the pump had

degraded even further than the earlier test. Calibration checks of

all instrumentation, disassembly and inspection of the pump, removal

and inspection of various in line valves, and boroscope inspection of

the suction and discharge piping to the pump was performed and no

deficiencies were identified. Since the outage had progressed to the

point of removing portions of the original flowpath, the licensee

developed an alternate flowpath by removal of the internals of two

check valves. A special test procedure was developed to rerun the

test using high accuracy test equipment in parallel with the

installed instruments. This test was performed on both MDEFWP's. The

data indicated that although some deterioration was identified as

expected, the pumps met all requirements necessary to perform their

safety related function. As a result, DE will provide new acceptance

criteria for testing by the performance personnel.

The DE and

performance personnel met with the inspectors to discuss in detail

the problems encountered and the resolutions of these issues.

Although the investigation of this occurrence is still in progress,

the preliminary analysis indicates that the original data taken was

obtained with a faulty instrumentation block valve associated with

the flow instrument.

The inspectors will continue to follow the

licensee's efforts associated with this problem.

No violations or deviations were identified.

4. Maintenance Activities (62703)

Maintenance activities were observed and/or reviewed during the reporting

period to verify that work was performed by qualified personnel and that

approved procedures in use adequately described work that was not within

the skill of the trade.

Activities, procedures and work requests were

examined to verify proper authorization to begin work, provisions for

fire, cleanliness, and exposure control, proper return of equipment to

service, and that limiting conditions for operation were met.

Maintenance reviewed and witnessed in whole or in part:

WR 524381 Repair Leaking Inboard Seal on 2B MDEFWP

WR 54139G Replace Disc in 2MS161

WR 92926C 2B MDEFWP Investigate Low Discharge Header

WR 57270C Breaker Testing Per PT/0/A/4980/52A

WR 57271C Breaker Testing Per PT/0/A/4980/52A

WR 57273C Breaker Testing Per PT/0/A/4980/52A

WR 577858 Perform Test on CT2 Relays

WR 50297F Stem Replacement on Valve 2C-158

S

11

Various other outage related work.

No violations or deviations were identified

5. Safeguards and Radiological Controls Activities (71707)

In the course of the monthly activities, the inspectors included review of

portions of the licensee's physical security activities. The performance

of various shifts of the security force was observed in the conduct of

daily activities which included; protected and vital areas access

controls, searching of personnel,

packages and vehicles, badge issuance

and retrieval, escorting of visitors, patrols and compensatory posts. The

inspectors observed protected area lighting, protected and vital areas

barrier integrity,

and verified interfaces between

the security

organization and other organizations.

No violations or deviations were identified.

6. Unit 2 End of Cycle 10 Refueling Outage

Unit 2 performed a normal reduction in power and took the generator off

line at about 2:00 a.m. on May 20.

Cooldown was continued to establish

plant conditions for the beginning of the overhaul.

Higher than expected

contamination levels were encountered in the reactor building due

primarily to several minor leaks on instrument lines and control rod drive

mechanism flanges.

Major work items to be performed during this outage

are overhaul of two low pressure turbines,

eddy current testing of

approximately 50% of the tubes in each steam generator, rebuild two

reactor coolant pump seals, and refurbish the condenser cooling water

inlet piping.

At this time there has been no significant problems

identified and the outage is proceeding as scheduled.

The outage is

scheduled to complete and the unit returned to service on July 2. At

present the person-rem expended has been less the projected.

7. TI 2515/101 Loss of Decay Heat Removal (GL88-17) (71707)

The inspectors reviewed the licensee's implementation of Generic Letter

(GL) 88-17 expeditious actions in accordance with the submitted response.

The inspectors focused on verification that the licensee is complying with

its submitted response and did not evaluate whether or not the response

meets all the requirements of the GL since a NRC audit will do this in the

future.

The first item committed to in the response concerned training.

The

response states that a training package will be developed on the Diablo

Canyon event. All appropriate personnel,

including shift operators and

supervisors, licensed staff and Operations Section Heads will be trained

on the event. The training will include the Diablo Canyon event, related

events and lessons learned.

Operations Training Package 89-01 was a

12

one-time administered discussion of Oconee's response to GL 88-17.

It

included a detailed review of each of the six expeditious actions

applicable to Oconee.

Additionally it

reviewed all procedural

and

administrative changes implemented as response to GL 88-17.

The package

also contained graphs depicting loss of decay heat removal consequences

specific to Oconee. Graphs of time to boiling, time to core uncovering,

and time to core damage for various RCS inventories and different elapsed

times after shutdown were included. The inspectors had observed some of

this training being administered to on-shift personnel prior to draindown

of Unit 1 during its last outage in early 1989. The training package has

been reviewed by all on shift licensed operators and supervisors, licensed

operations staff personnel and many individuals training to be licensed.

Although these personnel do comprise the final level of control over plant

evolutions and maintenance that could affect decay heat removal operation,

there are other appropriate personnel which should be trained on this

issue.

For instance, section heads and supervising engineers in the

fields of performance testing and NSM implementation should be aware of

their possible impact on decay heat removal system operation.

While

operations personnel have the overall responsibility of coordination and

implementation of work in regards to decay heat removal capability, it

seems that knowledge of the potential problems and consequences within

other work groups could also be valuable. The inspectors also noted that

while the commitment stated that the training will include the Diablo

Canyon event (the requirement specifically stated this also), that event

in itself was not discussed in the training package. The inspectors also

reviewed the requalification program training lesson plans on the Low

Pressure Injection System and Draining and Filling of the RCS.

These

lesson plans, while thorough and detailed concerning loss of decay heat

removal and drained down issues, did not specifically address the Diablo

Canyon event (several other events including problems at ANO2,

Trojan,

Zion and McGuire were briefly discussed along with INPO SOER 85-04

conclusions).

The second of the six applicable expeditious action items addressed

implementation of procedures and controls to ensure containment closure

will be achieved prior to the time at which a core uncovering could result

from an extended loss of DHR. These actions are required (for B&W units)

just prior to draining RCS to a level lower than four inches below the top

of the hot leg flow area (or else do not drain to this level or keep the

containment closed).

This corresponds to about 14 inches on LT-5

(Oconee's Reactor Vessel (RV) level instrument). The licensee has revised

OP/1,2,3/A/1103/11; Draining and Nitrogen Purging of Reactor Coolant

System to provide the administrative controls and guidance committed to in

the response.

Enclosure 4.7 of this procedure is entitled:

Requirements

for Reducing Reactor Vessel Level Less Than 50 Inches on LT-5

(50 inches

on LT-5 corresponds to about 34 inches below the RV lip, 32 inches above

the top of the hot leg flow area.)

This enclosure requires that

containment closure ability be established prior to draining to less than

50 inches on LT-5. This is accomplished by ensuring that the necessary

containment isolation valves outside the Reactor Building (RB) are intact

13

(Enclosures of AP/1,2,3/A/1700/07 "Loss of LPI"

System lists these

components) or equivalently isolated in accordance with a Removal and

Restoration (R&R) procedure. This is called a Containment Closure Survey.

Another enclosure of OP/1,2,3/A/1103/11 requires that the OTSG secondary

side is isolated or controlled by R&R. The Shift Engineer is responsible

for ensuring that the major work groups are aware of their roles if DHR is

lost. Mechanical Maintenance must be ready to secure all secondary side

OTSG openings inside the RB,

shut the hatches and secure any temporary

openings into the RB within the 2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> period.

Instrument and

Electrical are responsible for all instrument penetrations and Performance

controls electrical and Leak Rate Testing penetrations. If a loss of DHR

were to occur with the RCS open and containment integrity not existing,

containment closure would be established.

Operators would complete

enclosures of AP/1,2,3/A/1700/07, (shutting outside RB isolation Valves,

primarily in the penetration rooms) while the above groups would complete

their assigned tasks,

other actions of AP/1,2,3/A/1700/07 would be

completed. Based on observation of most of these tasks, it appears that

containment isolation could be achieved within the 2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> limit. During

the current Unit 2 outage the inspectors observed closely the implementa

tion of these requirements.

No significant deficiencies were noted.

Successful completion of these procedures does require close and extremely

detailed coordination, particularly on the part of Operations Staff

personnel.

At daily outage meetings, draindown to less than 50 inches and

the required precautions were discussed between the work groups.

The

outage coordinators made all reasonable efforts to ensure that draindown

conditions (LT-5 less than 50 inches) were limited as much as possible.

Due to a problem with the OTSG nozzle drains (cold legs) the RCS had to be

drained down less than 50 inches an additional time.

Since it had been

only about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> since the last drained down period, the OTSG secondary

side checklist was not completed again.

Two valves (feedwater drain

valves) had been manipulated in the interim and were not properly

positioned but OTSG secondary side level was sufficiently high enough such

that a flow path from the-RB out to the steam line did not exist.

The review of the remaining four applicable expeditious actions

temperature indications, level indications, limiting operations during

draindown,

and two other means of adding inventory will be completed

during the next inspection period.

8. Inspection of Open Items (92702)

The following open item is being closed based on review of licensee

reports,

inspection,

record review,

and discussions with licensee

personnel, as appropriate:

(Closed) Violation 269/89-08-02:

Performance of Testing Without The

Use of An Approved Test Procedure.

The licensee responded to this

violation in correspondence dated May 4, 1989. The corrective action

has been completed and reviewed by the inspector.

Based on this

review, this item is closed.

14

9. Exit Interview (30703)

The inspection scope and findings were summarized on June 19, 1989,

with those persons indicated in paragraph 1 above.

The inspectors

described the areas inspected and discussed in detail the inspection

findings listed below. The licensee did not identify as proprietary any

of the material provided to or reviewed by the inspectors during this

inspection. Dissenting comments were not received from the licensee.

Item Number

Description/Reference Paragraph

a. VIO 269,270,287/89-17-01

Electrical

Distribution System TS

Violations

Due

To

Inadequate

Procedures, paragraph 2

b. NCV 269,270,287/89-17-02

Failure to perform appropriate testing

as required by TS 4.8.2, paragraph 2.e

c. IFI 269,270,287/89-17-03

Adequacy of Fire Protection Sprinkler

System Pressure, paragraph 2.b.

Licensee management was informed that one previous violation discussed in

paragraph 8 was closed during this inspection.

ENCLOSURE 3

OCONEE NUCLEAR STATION

COMMISSIONER CURTISS VISIT

JUNE 5, 1989

PLANT BRIEFING

-

ORGANIZATION

-

MAJOR PLANT DESIGN FEATURES

-

SELECTED PLANT STATISTICS

-

AREAS OF INCREASED EMPHASIS

-

SELF EVALUATION EFFORTS

-

MAINTENANCE

OCONEE NUCLEAR STATION

ORGANIZATION

ORGANIZATIONAL CHART

DO IT OURSELVES

- MINIMAL VENDORS

ADEQUATE RESOURCES -

ONSITE AND OFFSITE

LOW TURNOVER -

HIGH EXPERIENCE

NON UNION STATUS

SHIFT RESOURCES - 12 HOUR SCHEDULE

TRAINING COMMITMENT

USE OF ENGINEERS/TECHNICAL STAFF

DUKE POWER COMPANY

CHAIRMAN OF Tas BOARD

D. W. BOOTH

PRESIDENT

W. H. RL.D

T'rECUTIVE VICE PRESIDENT

POWER GROUP

R. L. DICK

G. W. (MIER

E. S.

TUCKER.

R. B. PR- ORY

Vice President

Manager

Vice President

Sr. Vice President

Const. & Maint.

Corporate Q.A.

Nuclear Production

J. B. GROGAN

T. MOUKEKIN

J. C. L5A

S

General Manager

Vice President

Vice President

Const. & Maint.

Design

Prod. Support

SITE

DP.

R. M.FKOERB

an Dsign

Gen. Manager

SSIE

(309)

Training

D. L. FREZE

R. J. BRAKETT

N. S. TUCKNAN

C. V. BD

T. S' BARR

Superintendent

ue.ItnetSprnednSueitnetSeiteet

MaintenanceSer

Tatio Merager

Sta

tion

vcs.

(59)

(170)

(235Stff

(79)

(50)

+

(2000

CoContrcctors

I

I

I

V. V FOkX.

L. SGR

JM.

VI

0 TUCKER

R B. PR

ORT

Supritenen

ueMnanagenVicerneident

Sr.ernt e Prsdentean

Maintenanceoperation Q.A

N ch.a SrducestiontdSclg

Sain

y

VicePresdent

2ic Conractoent

OCONEE NUCLEAR STATION

MAJOR PLANT DESIGN FEATURES

3 VIRTUALLY IDENTICAL UNITS

EMERGENCY POWER SOURCE

-

KEOWEE HYDRO STATION

EMERGENCY FEEDWATER SYSTEM

-

FLEXIBILITY/RELIABILITY

SAFE SHUTDOWN FACILITY

EMERGENCY CONDENSER CIRCULATION WATER SYSTEM

OCONEE NUCLEAR STATION

PLANT STATISTICS

HISTORICAL CAPACITY FACTORS

UNIT 1

66.5%

UNIT 2

66.6%

UNIT 3

67.6%

RECENT CAPACITY FACTORS

1983


79.0%

1984


83.0%

1985


75.0%

1986


73.6%

1987


72.3%

1988


83.8%

SIX YEAR AVERAGE

78.3%

SIGNIFICANT RECORDS

OCONEE HAS PRODUCED MORE ELECTRICITY THAN ANY OTHER NUCLEAR PLANT IN U.S.

.

983

UNIT 3 HIGHEST U.S. CAPACITY FACTOR -----

94.7%

1984

UNIT 2 HIGHEST U.S. CAPACITY FACTOR -----

96.6%

1985

UNIT 2 SETS WORLD RECORD

-

439 CONTINUOUS DAYS

1988

BEST EVER UNIT 3 RUN

- 351 DAYS

BEST EVER UNIT 1 RUN

- 235 DAYS

UNIT 1 1988 CAPACITY FACTOR 96.78%

STATION WILL BE AMONG HIGHEST U.S. CAPACITY FACTOR FOR MULTI-UNIT

STATIONS IN 1988

HEAT RATE HISTORICALLY AMONG LOWEST IN U.S.

REACTOR TRIPS

1983

12

1984

7

1985

10

1986

8

1987

3

1988

4

INPO EVALUATIONS -- CATEGORY 1 -- EXCELLENT PLANT LAST FOUR YEARS

NRC VIOLATIONS -- 5 PER YEAR PER UNIT ---------------

LAST 6 YEARS

  • ER'S

-- 8.8 PER YEAR PER UNIT

--

LAST 6 YEARS

NDUSTRIAL SAFETY

-

3 MILLION

3 MILLION

6 MILLION

1 MILLION

OCONEE NUCLEAR STATION

RECENT EMPHASIS

STEAM GENERATORS

- CHEMICALLY CLEANED SECONDARY-- UNITS 1 AND 2

- TUBE SLEEVING TO REDUCE PROBABILITY OF LEAKS

--

UNITS 1 AND 3

- INSTALLED COLD LEG DAMS (MINIMIZE TIME IN DRAINED CONDITION)

- DECON OF CHANNEL HEADS TO REDUCE DOSE

MOTOR OPERATED VALVES

- OVERHAUL APPROXIMATELY 100 LIMITORQUES PER REFUELING

- EXTENSIVE USE OF MOTOR OPERATED VALVE ANALYSIS TEST SYSTEM (MOVATS)

VALVE OUALITY

- EXTENSIVE PROGRAM FOR IMPROVEMENT OF' VALVE PERFORMANCE

BINGHAM REACTOR COOLANT PUMP UPGRADE

- REBUILT 8 BINGHAM REACTOR COOLANT PUMPS DUE TO FAILURE OF 1

AREA- DECONTAMINATION

- RECOVERED MANY SQ. FT. OF CONTAMINATED AREA IN AUXILIARY BUILDING

HOUSEKEEPING/MATERIAL CONDITION

-

UPGRADING PAINTING, INSULATION, HOUSEKEEPING STANDARDS

A LONG WAY TO GO

OCONEE NUCLEAR STATION

RECENT EMPHASIS

(CONTINUED)

SIMULAT.OR-TRAINING

- SIGNIFICANTLY INCREASED THE TIME FOR SIMULATOR TRAINING

SYSTEM/COMPONENT OWNERSHIP

- ENHANCING THE OWNERSHIP OF COMPONENTS/SYSTEMS BY ENGINEERS/STAFF

EXPOSURE CONTROL

- SIGNIFICANT REDUCTIONS IN TOTAL EXPOSURE --1988 LOWEST YEAR IN 14 YEARS

OUTAGE MANAGEMENT

- UNIT 2 REFUELING IN 66 DAYS INCLUDED REBUILDING 4 REACTOR COOLANT PUMPS

- OUTAGE MANAGEMENT HAS IMPROVED-LAST 2 OUTAGES 43 DAYS AND 42 DAYS

- PRESENT OUTAGE SCHEDULED FOR 42 DAYS

EMERGENCY PREPAREDNESS

-

STRONG EMPHASIS WITH 5 FULL SCALE DRILLS PER YEAR--MANY USING SIMULATOR

SELF EVALUATION EFFORTS

-

SITA AUDITS

-

PIR

-

DESIGN BASIS DOCUMENTATION

-

B&W OWNERS GROUP SPIP

BWOG RECOMMENDATIONS

Oconee Status as of 4-6-89

Evaluating

Evaluating

for

for

Closed

Closed Not

Closed

Applicability

Implementation

Implementing

Operable

Applicable

Rejected

TRfTRIP*

0

18

34

93

54

26

AVAILABILITY

0

3

4

24

0

0

ECONOMIC

0

0

0

1

0

0

REGULATORY

0

0

0

4

0

0

ALL PROGRAMS

0

21

38

122

54

26

Reference: BWOG Recommendation Tracking System

  • Trip Reduction/Transient Response Improvement Program (includes safety and performance improvement program)

BWOG GOALS

GOAL - 1990

OCONEE NUCLEAR STATION

AVAILABILITY - 78%

78.16%

(1985-1987)

85.39%

(1988)

REACTOR TRIPS - 1.5/UNIT/YEAR

2.3/UNIT (1985-1987)

1.3/UNIT (1988)

CATEGORY C EVENTS - <.1/YEAR

ONE IN HISTORY (ITA FIRE EVENT)

FORCED OUTAGE RATE 4%

4.6%

(1985-1987)

(3 YEAR AVERAGE)

2.9%

(1988)

SUPERI TENDENT OF

MAINTENANCE

W. W. Foster

PHONE: 3163

-518

Clay A. Little

GROUP CLERK

Phone: 3416

T. Darlene Chapman (A)

In Training

PHONE: 3164

MECHANICAL MAINTENANCE

INSTRUMENT & ELECTRICAL

MAINTENANCE ENGINEERING

PLANNING & MATERIALS

MANAGER

MANAGER

MANAGER

MANAGER

Ronnie M. Weatherford

Don E. Havice

Barry K. Millsaps

M. Dendy Clardy

Phone: 3146

Phone: 3115

Phone: 3133

Phone: 3160

Beeper: 450

Beeper: 350

Beeper: 469

-Craft Organization

-Craft Organization

-Engineering & Technical Support

-Planning/Scheduling

-220

-130

-45

-Materials

-110

05/31/89

FUNCTIONAL ARRANGEMENT

ENGINEERIN!G

-

ONE ENGINEERING MANAGER IN MAINTENANCE

-

MECHANICAL - BY COMPONENTS

-

ELECTRICAL/I&C - BY SYSTEM

-

CLOSE TIE BETWEEN TECH SUPPORT/CRAFT/PLANNERS

PLANNING

-

ORGANIZED BY COMPONENT OR SYSTEM

-

PLANS AND SCHEDULES ALL MAINTENANCE WORK

-

INCLUDES MATERIALS AND DATABASES

EXECUTION

-

STAFFED TO SUPPORT ALL NON-OUTAGE WORK

REFUELING OUTAGES

-

MOST WORKFORCE FROM DUKE RESOURCES

- NPD

- CMD (350)

- TRANSMISSION (30)

- QA/QC

-

LIMITED VENDORS

- I&E (25)

-MACHINISTS (10)

-INSULATORS

(15)

-VALVE (10-30)

- B&W (25-50)

-

ALL WORK PLANNED, SCHEDULED AND MANAGED BY

ONS ORGANIZATION

TRAINING AND QUALIFICATION

-

NPD INPO ACCREDITED MAINTENANCE PROGRAM

-

PSD ORGANIZATION ONSITE FOR TRAINING

-

CORPORATE TRAINING PROGRAMS

- BASIC

- SPECIALIZED

- LIMITORQUE

- ALIGNMENT AND COUPLING

- RIGGING

-

CMD / TRANSMISSION

-

SPECIALIZED TRAINING PROGRAMS

-

ALL TRAINING CONSISTENT ACROSS COMPANY

MAINTENANCE RESULTS

-

HIGH CAPACITY FACTORS

-

SHORT OUTAGE LENGTHS

-

SHORT AND FEW FORCED OUTAGES

-

RADIATION EXPOSURE DECREASING

-

CONTAINMENT PERFORMANCE IMPROVING

-

IMPROVED PLANT MATERIAL CONDITION

-

RECLAMATION OF CONTAMINATED AREAS

-

SMALL BACKLOG <250 >90 DAYS OLD

-

PM/CM APPROXIMATELY 70%

-

FEW PM DEFERRALS

-

FEW PRIORITY 1 WORK REQUESTS <10/MONTH

RECENT ISSUES

-

MAINTENANCE TEAM INSPECTION

-

QUALITY VERIFICATION TEAM

ENVIRONMENTAL QUALIFICATION TEAM

-

SALP

-

INPO EVALUATION

PICLOSUJPE 4

INorth

Greenvills, )- (Control)

(Contral)

South

Asbury

Trp

Docus

Oconee

Calhoun

Mountain Newport Wotrcross

Tr.a2

Trams

to

/.*

-23'*V 525OKu

No.2

No. IR

d

u

'vvy~

0

1

16

19

281It

Hyra14T.n

10TA

1T

-4

S.r

Tram

D

UATEr

2T

3T

CT

T

ST

T