ML16127A253

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Insp Repts 50-269/88-32,50-270/88-32 & 50-287/88-32 on 880917-1014.Violations Noted.Major Areas Inspected:Maint Activities,Operations,Safeguards & Radiation Protection, Surveillance Testing & Insp of Open Items
ML16127A253
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 11/02/1988
From: Peebles T, Skinner P, Wert L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML16127A252 List:
References
50-269-88-32, 50-270-88-32, 50-287-88-32, IEB-88-003, IEB-88-3, NUDOCS 8811090250
Download: ML16127A253 (11)


See also: IR 05000269/1988032

Text

EgkREG&j

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323

Report Nos:

50-269/88-32, 50-270/88-32 and 50-287/88-32

Licensee:

Duke Power Company

422 South.Church Street

Charlotte, N.C. 28242

Docket Nos.:

50-269, 50-270, 50-287

License Nos.

DPR-38, DPR-47, DPR-55

Facility Name:

Oconee Nuclear Station

Inspection Conducted:

Se tember 17 -

October 14, 1988

Inspectors:

.H. Sk 'inner, Senior esident Inspector

a

gned

L.D

I

i

nspecor

bat

Signed

Approved by:

1

7he&

//o

/- /

T.A. P bles, Section Chief

DAte 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 protectionand inspection of

open items.

Results: Within the areas inspected, the following violation was identified:

-

Failure to follow procedures, paragraph 3.b.

8811090250 88S,110C)2

FPDR

ADO:'C K 050 :0269

a

PDC:

REPORT DETAILS

1. Persons Contacted

Licensee Employees

  • M. Tuckman, Station Manager

C. Boyd, Site Design Engineer Representative

  • J. Brackett, Senior QA Manager
  • M. Carter, Site Design Engineer Representative

J. Davis, Technical Services Superintendent

  • W. Foster, Maintenance Superintendent

T. Glenn, Instrument and Electrical Support Engineer

  • P. Guill, Nuclear Licensing Engineer
  • C. Harlin, Compliance Engineer

D. Hubbard, Performance Engineer

H. Lowery, Chairman, Oconee Safety Review Group

  • T. Matthews, Production Specialist

J. McIntosh, Administrative Services Superintendent.

F. Owens, Assistant Engineer, Compliance

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

NRC Representatives:

  • T.A.Peebles, Section Chief, Reactor Projects Section 3A
  • Attended exit interview.

2. Licensee Action on Previous Enforcement Matters (92702)

a.

(Closed) LIV 287/87-48-03:

Failure to Maintain the Required Number

of ESF Digital Channels in Service. Based on review of LER 287/87-09

(see paragraph 7.f.) this item is closed.

b. (Closed) LIV 269/88-01-01:

Containment Isolation Valve 1N-106 Found

Open.

Based on review of LER 269/87-13 (see paragraph 7.d.) this

item is closed.

c. (Closed)

LIV 269/88-32-01:

Violation of T.S. 3.10.5 When Burning

Contaminated Oil.

Based on review of LER 269/88-03 (see paragraph

7.b.), this item is closed.

2.

3. 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 &

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.

Actions

observed were conducted as required by the Licensees 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

Station Yard Zone within the Protected Area

Standby Shutdown Facility

Units 1,3 Penetration Rooms

Keowee Hydroelectric Station

Units 1/2 Spent Fuel Pool Room

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

equipment status, and radiation control practices were observed.

Unit 1 -

Unit 1 operated at 100 percent power for the entire report

period.

Unit 2 -

Unit 2 operated at 100% power for the entire report

period with exception of a few hours at 96% on September 24

following a runback due to the low pressure and high

pressure stop valves on the 'A' feedwater pump turbine went

shut due to low hydraulic oil pressure.

Unit 3 -

Unit 3 returned to 100 percent power on September 26

following a 44 day refueling outage. During the startup a

turbine trip occurred due to an improperly calibrated

thrust wear detector but no reactor trip was initiated

since the reactor power

level

was well

below the

anticipatory reactor trip on turbine trip setpoint.

Unit

Three continued operation at 100 percent for the remainder

3

of the reporting period with the exception of a reduction

to about 85 percent for load following requirements during

the period October 8-10.

b. Overpressurization of Steam Generator Sample Piping (Unit 3)

On September 22,

1988, during the return to operation of Unit 3,

chemistry department personnel reported that they 6ould not obtain a

required sample from the 'B' steam generator. This was attributed to

a clogged sample line.

The chemistry personnel generated a work

request (WR 87340B) to obtain assistance in unclogging-the line. The

WR was assigned to a maintenance planner that normally performed

planning on instrumentation and electrical (I&E) equipment instead of

a mechanical planner.

The planner identified the work as non

safety-related and as a result no procedure was generated to perform

the work.

Maintenance personnel then attached a hydrostatic test

pump to the sample. line in the chemistry lab and attempted to unclog

the line by pressurizing the line and creating a backflow condition

into the steam generator. Pressure was increased to 2500 psig (which

was the capacity of the pump) without obtaining flow in the line. At

this time an operations shift change took place and the oncoming

shift recalled a similar problem that had occurred on Unit 2.

The

problem at that time was thought to have been a valve identification

problem. The operators rechecked the valve line-up and found valve

labelling discrepancies.

After these problems were identified and

the valve line-up was subsequently corrected, the chemistry group

could take the required sample.

Upon investigation into this

problem, the licensee identified that while the sample line was rated

for a design pressure of 1050 psi,

it

had been pressurized to 2500

psi during the attempts to unclog the line. In addition, this line

included containment penetration number 58 which includes containment

isolation valves FDW 107 and FDW 108.

An operability evaluation was

performed which determined that the overpressurization did not effect

the piping integrity and the valves were cycled to check operability.

Station Directive (SD)

3.2.1 Work Request, section 6.1 and Mainte

nance Directive (MD)

7.5.2, Work Request Planning, section 4.1.1

require that the planner identify QA condition work using the "Safety

Related Structures, Systems and Components Manual", the Oconee Flow

Diagrams

(OFD)

and other sources as necessary.

Section 6.10 ,of SD

3.2.1 states all QA condition work will be performed by approved

procedures.

It appears that if the WR had originally been processed

as safety related work this activity would have been performed using

an approved procedure and this overpressurization would not have

occurred.

This is being identified as violation 287/88-32-01;

Failure to Follow Procedure SD 3.2.1 Resulting in an Overpressu

rization of a Feedwater Sampling Line and a Containment Penetration.

4

c. Safe Shutdown Facility (SSF) Pressurizer Heater Capacity Requirements

During the NRC Maintenance Team Inspection conducted in July of 1988,

a question arose concerning the required minimum operable number of

pressurizer heaters powered.from the SSF (SSF diesel generator). As

a result of a request to provide the calculated basis for the 70

kilowatt (kw) value that has been utilized as the minimum SSF heater

capacity, a new safety-related calculation was performed (OSC-3144:

Pressurizer Heat Rejection). The inspector reviewed this calculation

and noted that while the purpose of the heaters (as stated) is to

maintain adequate temperature and pressure in the pressurizer to

assure natural circulation in the reactor coolant system at hot

standby, only heat rejection from the pressurizer was considered.

The inspector felt that a more conservative approach should to

include the heater capacity required to heat up (to saturated

conditions) a volume of water insurged into the pressurizer.

It is

realistic to assume the SSF scenario would involve an outsurge from

the pressurizer before makeup is initiated and the subsequent insurge

water would have to be heated up to saturated conditions by the SSF

pressurizer heaters.

In response to these concerns the licensee's

nuclear safety analysis group analyzed the time required to heat the

insurge as a function of available heater power.

The analysis had

several very conservative conditions and concluded that with the

expected capacity (126kw) available, the pressurizer water would be

heated to saturation at 1850 psig in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

With only the minimum

capacity (70kw)

available it would take about 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> to reach

saturation.

The licensee concluded that given the conservatisms

employed in the calculation (specifically that it

assumed a full

insurge to a level of 220 inches when operators do have an option to

maintain a much lower level), the 70kw of SSF powered heater capacity

is sufficient to overcome ambient heat losses and assure that

saturated conditions can be maintained in the SSF event.

d. Reactor Building (RB) Temperature

(TI 2515/98)

The inspectors completed the evaluation and obtained the data

required by TI 2515/98.

Graphs of Unit 1 RB temperature for the

periods of July - September 1987 and July 1988 were provided, (Units

2 and 3 experience similar temperature distributions) along with

drawings of the RB cooling and RB Auxiliary Cooling Systems.

All

information required by the TI was obtained and forwarded as

requested.

Emphasis was placed on comparing the physical location of the RB

thermocouples and the general layout of the Reactor Building Cooling

system and RB Auxiliary Cooling System.

The inspectors toured the Unit 3 Reactor Building (RB)

as~that unit

was in a refueling outage.

While not all of the thermocouples were

actually sighted (due

primarily to ALARA considerations),

the

thermocouples observed appeared to be located to accurately sense the

5

air temperatures desired.

No thermocouples were observed to be

located directly in the flowpath of a cooling air fan (except those

in the

RBCU

ductwork).

The locations were considered to

conservatively reflect RB temperatures.

For example, the thermo

couple in the 'A' SG cavity was located near the top of the cavity

and fairly close to the pressurizer.

Both of these factors would

contribute to a conservative indication of cavity temperature. The

RB dome temperature thermocouple is located below the actual top of

the dome but appears to indicate an accurate value of dome area

temperature since some ductwork from the RB Auxiliary Cooling System

discharges cooler air at the top of the dome. The Auxiliary Cooling

System, has reduced RB temperatures since it was installed in about

1981.

Overall,

it

appears that the temperatures are accurate

indications and are within the required environmental qualification

limits.

No violations or deviations were identified.

e. Keowee Hydro Station Tour

The inspectors conducted a detailed tour of the Keowee Hydro Station

during this report period.

The two onsite Keowee Hydroelectric

generators provide emergency

power to Oconee Nuclear Station.

Emphasis was placed on the associated electrical distribution systems

(both

AC and DC) and ensuring available operating and maintenance

procedures were properly approved and maintained. Discussions were

held with both the operating staff and supervisory personnel.

The

inspectors also toured the hydrostation intake structure and

floodgate structures.

No violations or deviations were identified.

4. Surveillance Testing (61726)

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/or witnessed in whole or in part:

PT/O/A/200/46

RCS Leak Test

PT/3/A/251/19 MS Atmosphere Dump Valve Functional Test

TT/3/A/711/010 Zero Power Physics Testing

6

PT/O/A/0400/12 SSF Diesel Generator Air Check Valves

Operational Test

PT/O/A/0600/15 Control Rod Movement Test

PT/2/A/0251/10 Auxiliary Service Water Pump (Auxiliary

Building) Performance Test

No violations or deviations were identified.

5. 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.

No violations or deviations were identified

6. Safeguards and Radiological Controls Activities (71707)

In the course of the monthly activities, the Resident 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 operations or maintenance.

No violations or deviations were identified.

7.

Inspection of Open Items (92700)

The following open items are being closed based on review of licensee

reports, inspection,

record review,

and discussions with licensee

personnel, as appropriate:

a.

(Closed) LER 269/88-02:

Violation of Technical Specifications

Due to Missed Inservice Testing of Valves Resulting From

Personnel Error. The corrective action discussed by the LER was

an evaluation of safety related check valves to ensure they meet

the standards of Section XI of the ASME code for Inservice Valve

Testing (IST).

This review has been completed and the valves

identified have been incorporated into the most recent revision

(Revision 15,

dated June 14,

1988) to the IST Program Manual.

Based on this review this item i.s closed.

b.

(Closed) LER 269/88-03:

Violation of Technical Specifications

Due to Management Deficiency in the Control of Offsite Dose

7

Calculation When Burning Contaminated Oil.

This item occurred

as a result of a communications breakdown between corporate

office Radwaste Chemistry and onsite chemistry personnel.

This

communication

problem was associated with a change to a

procedure described in the Offsite Dose Calculation Manual

(00CM) which was not implemented by the onsite personnel since a

copy of the ODCM was not maintained by this section.

The

corrective action described in the LER has been completed and

the action appears to be acceptable.

Since this resulted in a

violation of TS 3.10.5, this is classified as a Licensee

Identified Violation (LIV)

50-269/88-32-01:

Violation of TS 3.10.5 when burning contaminated oil.

This is identified as a

LIV since it meets the requirements specified in 10 CFR 2,

Appendix C, Section G, Exercise of. Discretion.

Since all

corrective actions have been completed and reviewed by the

inspectors, this item is closed.

c.

(Closed)

LER 269/88-11:

Failure to Vent a High Pressure

Injection (HPI)

Pump Results in a Condition Prohibited by

Technical Specifications (TS) Due to Personnel Error. This LER

addressed a case in which the 'lB'

HPI

pump was tested

(Performance Test Procedure PT/1/A/0202/11 was completed after

lubrication of the pump motor to minimize pump runs) without

venting the pump prior to the testing. TS Table 4.1-2 requires

that prior to testing a non-operating HPI pump, the pump casing

must be vented.

While procedures and TS do not require pump

venting (after motor lubrication) prior to operation of an HPI

pump,

it

is specifically required prior to testing a non

operating pump.

The inspector reviewed the corrective actions

(both planned and completed) to ensure venting of any non

operating pump prior to performance testing in the future.

Based on this review, this item is closed.

d.

(Closed) LER 269/87-13:

Technical Specification (TS) Violation

Due to Lack of Containment Integrity Resulting From a Personnel

Error.

This LER addressed an incident where containment

isolation valve 1N-106 was found open when containment integrity

was required.

Inspection Reports 269,270,287/87-48 and 88-01

contain details of the incident.

The inspectors reviewed and

verified as complete all corrective actions set forth in the

LER.

Additionally, the inspectors have noted a significant

increase in the attention to detail regarding the Removal and

Restoration Logbook on the part of all control room operators.

Special emphasis in the potential effects of existing Removal

and Restoration procedures has been observed during changes in

plant status.

Based on this review, this item is closed.

e.

(Closed) LER 270/88-01, Revision 1:

Seismic Inoperability of a

Vital

Power Inverter due to a Defective Procedure.

The

corrective actions described in this LER have been completed and

8

reviewed by the inspectors.

Based on this review, this item is

closed.

f.

(Closed) LER 287/87-09:

Technical Specification (TS) Violation

Due to Inadequate Procedure for Functional Test of Engineered

Safequards (ES) System. This LER addressed the failure of the

ES System Calibration procedures to ensure proper operation of a

rotary test switch in the circuitry.

A fault occurred within

this test switch and rendered a portion of ES System Digital

channel 2 inoperable. The switch is composed of four wafers of

ten contacts each and is located on the Digital Channel Trip

Modules (Bailey Trip Logic Module).

As stated in the LER, the

root cause of this incident was the failure of the ES Analog

channel on line calibration procedure to adequately verify the

correct ES System

Digital Channel response to an analog trip

signal.

The inspector reviewed the changes to the ES System

Analog Channels On Line Calibration procedures which ensure that

the expected Digital Channel response is indicated whenever an

Analog Channel is tripped.

The inspector witnessed several

tests utilizing the revised procedure. On September 6, 1988, a

fault was discovered in the Unit 1 Channel 7 Trip Logic Module

rotary test switch by the use of this. procedure. The Trip Logic

Module was replaced within the time permitted by TS.

All

corrective actions for the LER have been completed with the

exception of an audit of the ES System Maintenance procedures to

ensure an adequate test is performed to verify proper operation

of each component in the ES System.

The inspector discussed

this audit with one of the responsible engineers.

It primarily

consists of field verification of procedures and drawing

verifications (walk throughs) which will result in some

procedural upgrades.

This audit is expected to be completed by

January 1989.

Based on this review, this item is closed.

g. (Closed) NRC Bulletin No. 88-03:

Inadequate Latch Engagement In

HFA Type Latching Relays Manufactured by General Electric (GE)

Company.

Duke Power Company responded to this Bulletin in

correspondence dated July 13, 1988.

In this correspondence they

stated that GE HFA relays with latching mechanisms were not used

in any safety related applications at Oconee Nuclear Station.

Based on this correspondence this item is closed.

h. (Open) LER 287/88-03: Potential Degraded Performance of Reactor

Building Cooling Units Due to Service Induced Fouling. Based on

information

provided

by the licensee at an

Enforcement

Conference held on October 6,1988 concerning this issue

sufficient data has not yet been obtained to firmly establish

that Unit Three was operating with inadequate RBCU capacity to

fully support 100 percent operation. The licensee has continued

to collect additional data and perform more analyses in order to

resolve the issue.

Current status is as follows:

9

Unit One was tested on September 27, 1988.

The operability

determination concluded that the RBCUs would support 100 percent

full power operation *for at least the next 140 calendar days.

(Through to planned EOC shutdown)

Unit Two was tested on October 4, 1988. It was determined that

the RBCUs would support 100 percent full power operation for at

least the next 180 calendar days from that tim6.

Unit Three was tested on October 6, 1988.

The operability

determination concluded that the RBCUs would support 100 percent

operation for at least the next 28 calendar days from that time.

The above operability evaluations utilized several conservative

factors including a lakewater temperature of 80 degrees F and a

fouling rate of .25 percent per day.

As expected (see outline

attached to Meeting Summary Report 50-269,270,287/88-28), this

additional data along with the seasonal decrease in lakewater

temperature is increasing the degree of confidence in the

analysis process and its conclusions.

Lakewater temperature on

October 14 was 73 degrees F. and decreasing.

The licensee

intends to perform additional testing on Units 1 and 2 prior to

the end of November in their continuing effort to resolve this

issue.

8. Exit Interview (30703)

The inspection scope and findings were summarized on October 14, 1988,

with those persons indicated in paragraph 1 above.

The following items

were discussed in detail:

Item Number

Status

Description/Reference Paragraph

LER 269/88-02

Closed

Violation of Technical

Specification

Due

to Missed

Inservice

Testing

of

Valves

Resulting From Personnel Error

LER 269/88-03

Closed

Violation of Technical

Specifications Due to Management

Deficiency in the Control

of

Offsite Dose Calculation When

Burning Contaminated Oil

LER 269/88-11

Closed

Failure to Vent a High Pressure

Injection Pump Results in a

Condition Prohibited by Technical

Specifications Due to Personnel

Error

10

Item Number

Status

Description/Reference Paragraph

(cont'd)

LER 269/87-13

Closed

Technical Specification Violation

Due to

Lack of Containment

Integrity

Resulting

From.

a

Personnel Error

LER 270/88-01

Closed

Seismic Inoperability of a Vital

Power Inverter Due to a Defective

Procedure

LER 287/87-09

Closed

Technical Specification Violation

Due to Inadequate Procedure for

Functional Test of Engineered

Safeguards System

LIV 269/88-01-01

Closed

Containment Isolation Valve

1N-106 Found Open

LIV 287/87-48-03

Closed

Failure to Maintain the Required

Number of ESF Digital Channels in

Service

LIV 269/88-32-01

Closed

Violation of T.S. 3.10.5 When

Burning Contaminated Oil

LER 287/88-03

Open

Potential Degraded Performance of

Reactor Building Cooling Units

Due to Service Induced Fouling

IEB 88-03

Closed

Inadequate Latch Engagement in

HFA

Type

Latching

Relays

Manufactured by General Electric

(GE) Company

VIO 287/88-32-01

Open

Failure to Follow Procedure SD

3.2.1 Resulting in Overpressuriza

tion of a Feedwater Sampling Line

and Containment Penetration

The licensee representatives present offered no dissenting comments, nor

did they identify as proprietary any of the information reviewed by the

inspectors during the course of their inspection.