ML16127A253
| ML16127A253 | |
| Person / Time | |
|---|---|
| Site: | Oconee |
| 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.
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
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'
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
Closed
Violation of Technical
Specification
Due
to Missed
Inservice
Testing
of
Valves
Resulting From Personnel Error
Closed
Violation of Technical
Specifications Due to Management
Deficiency in the Control
of
Offsite Dose Calculation When
Burning Contaminated Oil
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)
Closed
Technical Specification Violation
Due to
Lack of Containment
Integrity
Resulting
From.
a
Personnel Error
Closed
Seismic Inoperability of a Vital
Power Inverter Due to a Defective
Procedure
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
Open
Potential Degraded Performance of
Reactor Building Cooling Units
Due to Service Induced Fouling
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.