ML16154A596

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Insp Repts 50-269/94-08,50-270/94-08 & 50-287/94-08 on 940227-0326.Violations Noted.Major Areas Inspected:Plant Operations,Surveillance Testing,Maintenance Activities, Engineering & Technical Assistance
ML16154A596
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 04/15/1994
From: Harmon P, Sinkule M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML16154A595 List:
References
50-269-94-08, 50-269-94-8, 50-270-94-08, 50-270-94-8, 50-287-94-08, 50-287-94-8, NUDOCS 9405230165
Download: ML16154A596 (16)


See also: IR 05000269/1994008

Text

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REGI

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W., SUITE 2900

ATLANTA, GEORGIA 30323-0199

Report Nos.:

50-269/94-08 50-270/94-08 and 50-287/94-08

Licensee:

Duke Power Company

422 South Church Street

Charlotte, NC 28242-0001

Docket Nos.:

50-269, 50-270 and 50-287

License Nos.: DPR-38, DPR-47

and DPR-55

Facility Name: Oconee Units 1, 2 and 3

Inspection Conducted:

bruar 27 - March 26, 1994

Inspectors:

P. E. Harmon, Senior Resid

In ector

D/te Signdd

W. K. Poertner, Resident Inspector

L. A. Keller, Resident Inspector

P. G. Humphrey, Resident Inspector

Approved by:

7 §

~

'4i

M. V. Sinkule, Chief,

Ddte 3igned

Reactor Projects Branch 3

SUMMARY

Scope:

This routine, resident inspection was conducted in the areas of

plant operations, surveillance testing, maintenance activities,

engineering and technical assistance.

Results:

One violation was identified that involved an inoperable emergency

feedwater pump for a period of time greater than that allowed by

Technical Specifications (paragraph 4.a). A non-cited violation

was documented that resulted from the licensee's reporting of a

potential piping interaction in which the Condenser Circulating

Water discharge vents could be damaged in a seismic event by

buoyancy restraints; thereby, rendering the system inoperable

(paragraph 4.b). A third issue, identified as an Unresolved Item,

related to a lack of documentation for fatigue analysis for the

auxiliary piping connections to the reactor coolant system

(paragraph 4.c).

During this .inspection period, equipment failures resulted in: a

Unit 1 runback to 65 percent power, a Unit 3 plant trip due to a

failed moisture separator reheater level control switch, and a

Unit 3 shutdown because of a steam generator tube leak.

9405230165 940415

PDR ADOCK 05000269

G

PDR

REPORT DETAILS

1.

Persons Contacted

Licensee Employees

  • B. Peele, Station Manager
  • M. Bailey, Regulatory Compliance

S. Benesole, Regulatory Compliance Manager

  • D. Coyle, Systems Engineering Manager

J. Davis, Engineering Manager

  • B. Dolan, Safety Assurance Manager

W. Foster, Superintendent, Mechanical Maintenance

  • J. Hampton, Vice President, Oconee Site
  • D. Hubbard, Component Engineering Manager

C. Little, Superintendent, Instrument and Electrical (I&E)

  • S. Perry, Regulatory Compliance
  • G. Rothenberger, Operations Superintendent

R. Sweigart, Work Control Superintendent

Other licensee employees contacted included technicians, operators,

mechanics, security force members, and staff engineers.

  • Attended exit interview.

2. Plant Operations (71707)

a.

General

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, the temporary

modification log, and equipment removal and restoration records

were reviewed routinely. Discussions were conducted with plant

operations, maintenance, chemistry, health physics, instrument &

electrical (I&E), and engineering personnel.

Activities within the control rooms were monitored on an almost

daily basis. Inspections were conducted on day and night shifts,

during weekdays and on weekends.

Inspectors attended some shift

changes to evaluate shift turnover performance. 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. During the plant tours, ongoing activities,

housekeeping, security, equipment status, and radiation control

practices were observed.

2

b.

Plant Status

At the beginning of the reporting period, Unit 1 was being

restarted following a unit trip that had occurred on February 26,

1994. The generator was placed on-line at 1:37 a.m., on

February 27, 1994. On March 26, 1994, the unit experienced a

runback to 65 percent power due to a loss of the 1A main feedwater

pump (paragraph 2.f).

The unit was returned to full power at

4:10 a.m., on March 27, 1994.

Unit 2 operated at 100 percent power during the reporting period

with no significant problems.

Unit 3 operated at 100 percent power until March 1, 1994, when the

unit tripped on an anticipatory turbine trip/reactor trip

(paragraph 2.c).

The unit returned to power on March 2 and

remained at 100 percent until March 19 when the unit was shutdown

due to a steam generator tube leak (paragraph 2.d).

It was still

shut down at the end of the reporting period.

c.

Unit 3 Trip

At approximately 10:14 a.m. on March 1, 1994, Unit 3 experienced a

reactor trip due to a turbine trip. The turbine trip resulted

from a high moisture separator reheater (MSRH) level signal.

The

invalid high MSRH level signal was the result of shorted contacts

in a corroded mercury switch. The inspectors reviewed the post

trip report and transient monitor traces, and concluded that the

unit's response was normal.

While at hot shutdown the licensee

corrected a problem with a faulty hot leg level transmitter for

train "B" of the Inadequate Core Cooling Monitor (ICCM) which

allowed the unit to exit a 7-day Limiting Condition for Operation

(LCO) associated with TS 3.5.6. The unit returned to power on

March 2, 1994.

d.

Unit 3 Forced Shutdown Due To A Steam Generator Tube Leak

On March 18, 1994, at approximately 11:17 p.m., a high activity

alarm was received on the Unit 3 steam jet air ejector radiation

monitor (RIA-40). Subsequent steam line radiation measurements

and chemistry samples indicated a steam generator tube leak from

the "A" once through steam generator (OTSG).

The count rate on

RIA-40 increased from 1000 cpm to 130,000 cpm (equivalent to a

0.11 gpm tube leak) over a 9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> period. T.S. 3.1.6.4 states

that when the leakage through any one steam generator equals or

exceeds 0.35 gpm, a reactor shutdown shall be initiated within 4

hours and the reactor shall be in cold shutdown within the next 36

hours. Even though the leakage was below the TS limit, the

licensee began a controlled shutdown on March 19 at approximately

9:30 a.m. The resident inspectors observed portions of the

shutdown. The inspectors noted that the leak rate stabilized and

  • 0*

3

began to decrease as the licensee reduced power. All activities

observed during the shutdown were satisfactory.

After shutting down the reactor, the licensee discovered that

there was one leaking tube. This was determined by pressurizing

the secondary side of the "A" OTSG with nitrogen and observing,

via a remotely controlled camera through the upper primary manway,

the location of bubbles exiting the tube(s). The inspectors

observed this test and noted that one tube was leaking. The

leaking tube was at location 92-01 which is on the outer periphery

of the steam generator, just outside the "wedge" area.

Eddy

current testing using Motorized Rotating Pancake Coil (MRPC)

revealed that the leak consisted of a 160 degree circumferential

crack at the upper edge of the fifteenth tube support plate. The

nature and location of the flaw indicated that the failure was due

to flow induced vibration. This tube had been eddy current tested

during the previous outage using a bobbin coil.

That test did not

reveal any flaw indications.

The licensee subsequently conducted extensive eddy current testing

of over 400 tubes in the "A" OTSG. Included were tubes

surrounding the failed tube and tubes around either side of the

wedge and lane area. In addition to the one tube that was

leaking, two tubes (72-15 and 72-17) were found with volumetric

indications and were plugged. Steam generator activities were

completed at the end of the inspection period.

e.

Unit 3 Midloop Operations

Due to the steam generator tube leak discussed above, the licensee

drained down to mid-loop in order to perform MRPC inspections and

to plug tubes as necessary. It was not necessary to install

nozzle dams for this work. A readiness for reduced inventory

inspection was conducted prior to the drain down per NRC policy.

Additionally, the inspectors observed activities in the control

room during portions of the drain down and while at reduced

inventory. The inspection revealed that the licensee met the NRC

expectations for reduced inventory. Specifically:

-

The inspector reviewed the licensee's procedure for reduced

inventory operations. Operations Procedure, OP/3/A/1103/11,

Draining And Nitrogen Purging Of RC System, Enclosure 3.6,

Requirements For Reducing RXV Level To < 50" on LT-5,

stipulated the sequence and steps required for reduction of

RCS inventory and mid-loop operation. It further specified

the precautions and limitations to be adhered to while in

mid-loop. The inspector concluded that the procedure was

adequate.

S-

The inspector noted that containment closure was maintained

while at reduced inventory.

The inspector verified that at least two independent,

continuous temperature indications that were representative

of core exit conditions were available (i.e., both trains of

core exit thermocouples, hot leg temperature, and low

pressure injection (LPI) pump suction temperature were

available).

There were at least two independent, continuous water level

indications available (i.e., both channels of LT-5, and the

hot and cold leg ultrasonic level detectors were available).

Reactor coolant system (RCS) perturbations were avoided.

At least two makeup flow paths were available to maintain.

RCS inventory without assistance from the LPI pumps.

Licensee had contingency plans to repower vital busses from

an alternate source if primary source was lost. All sources

of offsite power, as well as both Keowee units, were

available.

The licensee made a substantial effort to ensure time spent

at reduced inventory was minimized. The time spent at

reduced inventory for this evolution (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />) was

substantially less than that for past evolutions.

f.

Unit 1 Runback

On March 26, 1994, Unit 1 experienced a runback to 65 percent

power following the loss of the 1A main feedwater (MFW) pump. The

1A MFW pump tripped during the performance of procedure

PT/1/A/290/05, Secondary Systems Performance Test. Plant response

was normal during the runback. The licensee was unable to

determine the exact cause of the MFW pump trip and was unable to

duplicate the event during subsequent testing. The MFW pump was

returned to service and the unit returned to 100 percent power at

4:10 a.m., on March 27, 1994.

Within the areas reviewed, no violations or deviations were identified

and licensee activities were satisfactory.

3.

Maintenance and Surveillance Testing (62703) (61726)

a.

Maintenance Activities

Maintenance activities were observed and/or reviewed during the

reporting period to verify that work was performed by qualified

personnel and that approved procedures adequately described work

that was not within the skill of the craft. Activities,

procedures, and work orders were examined to verify that proper

authorization to begin work was given, provision for fire were

made, cleanliness was maintained, exposure was controlled,

5

equipment was properly returned to service, and limiting

conditions for operation were met.

Maintenance activities reviewed/witnessed in whole or in part:

-

Work Order 94023085, Task 01, Replace Insulators on U3

Busline.

The inspectors observed portions of the work activities

associated with this work order. The effort involved

replacement of the insulators on the Unit 3 main transformer

bus line to the 525 KV switchyard. The activities observed

were accomplished satisfactorily and in accordance with

engineering instructions contained in the work order.

-

Work Order 94023113, Task 01, Replace the Orifice Plates in

the TDEFW Pump Minimum Flow Recirculation Line.

There were two 3/4-inch orifice plates in series downstream

of 3FDW-89 in the minimum flow recirculation line. These

were replaced with 5/8-inch orifice plates of the same

design. This work order was written to implement a Minor

Modification (OE-6464) which was necessary because the

licensee determined that the existing orifice plates allowed

too much flow. The inspectors observed portions of the

orifice replacements and identified no operability issues.

All activities observed were satisfactory.

b.

Surveillance Testing

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

inspectors witnessed the tests in whole or in part, to verify that

approved procedures were available, test equipment was calibrated,

prerequisites were met, tests were conducted according to

procedure, tests results were acceptable and system restoration

was completed.

Surveillances reviewed/witnessed in whole or in part:

-

Performance Test, PT/2/A/0203/06A, Low Pressure Injection

Pump Test-Recirculation.

The inspector reviewed testing of the Unit 2 low pressure

injection (LPI) pumps required by TS. The test, performed

on a quarterly basis, was to demonstrate operability of the

pumps and to identify any problem areas that may exist as

early as possible. It included vibration measurements,

6

monitoring of bearing temperatures, closure of discharge

check valves on the non-running pumps, and pressure/flow

evaluations.

The test was performed with reference to TS, Sections 3.3.2,

3.8.3, 4.0.4, 4.5.1.2.1. and Table 4.1-2. In addition, the

performance standards were to be in accordance with.the

American Society of Mechanical Engineers (ASME),Section XI,

Subsections IWP & IWV, 1980 Edition, Winter 1980 addenda.

The licensee performed a pre-job briefing, entered the

appropriate LCO, and performed the test as described in the

procedure.

Performance Test PT/2/A/0202/11, High Pressure Injection

Pump Test.

The inspectors witnessed the performance of this test

procedure conducted on the 2A High Pressure Injection (HPI)

Pump. The procedure implements the requirements of TS 4.0.4, Inservice Testing (IST).

The procedure verifies that

the pump meets the requirements of ASME Section XI. The

inspectors verified that the procedural acceptance criteria

was met and that the acceptance criteria met the

requirements of ASME Section XI.

No deficiencies were

noted.

Performance Test PT/1/A/0150/22A, Operational Valve Stroke

Test.

The inspectors witnessed the performance of this test

procedure conducted on valves 1HP-27 and 1LP-6. The

procedure implements the requirements of TS 4.0.4. The

inspectors verified that the procedural acceptance criteria

was met. No deficiencies were noted.

Performance Test PT/2/A/0230/15, High Pressure Injection

Motor Cooler Flow Test.

The inspector observed performance of the test which was to

evaluate the cooling water flow rate of the low pressure

service water (LPSW) to the HPI pump motors. The quarterly

performance test demonstrates operability of the pumps as

required by TS 3.3 and 4.5.

Within the areas reviewed, violations or deviations were not identified

and licensee activities were satisfactory.

4.

Engineering (71707)

a.

2A Motor Driven Emergency Feedwater Pump Inoperable Due to DC

Ground

7

During routine rounds on December 29, 1993, a non-licensed

operator discovered water leaking from pressure switch 2PS0386.

The switch, which monitors the discharge pressure of the 2A main

feedwater pump and sends a signal to start the 2A motor driven

emergency feedwater pump on a low discharge pressure of the main

pump, was replaced on December 30, 1993.

Lifting the electrical leads during the switch replacement

resulted in the elimination of a Unit 2 direct current (DC)

electrical ground problem that had been in alarm since

December 14, 1993. The licensee's failure to take aggressive

action to locate and correct the ground on the DC electrical

system resulted in the prolonged condition. Although the licensee

had generated Work Order 93090047, Task 01, the effort expended

was limited to monitoring the voltage on the system as opposed to

locating and correcting the ground. The issue of allowing DC

grounds to exist without performing an extensive effort to find

and eliminate the problem had been identified earlier by the NRC

as a weakness in Inspection Report 50-269,270,287/93-26.

An operability assessment completed on February 8, 1994,

determined that the grounded pressure switch, 2PS-0386, had caused

the 2A motor driven emergency feedwater pump to be inoperable from

December 14 through December 30, 1993. The length of time that

the emergency feedwater pump was considered inoperable exceeded

the seven days allowed by TS 3.4.2.a. Failure to meet the

requirement specified by the TS is identified as Violation

50-270/94-08-02, Inoperability of the 2A Emergency Feedwater Pump.

Since the switch was replaced on December 30, 1993, two additional

failures have occurred which were caused by water intrusion in the

switch. The first occurrence was on January 23, 1994, and the

second was on March 4, 1994. The failures were reviewed by the

inspectors to determine if the corrective actions for the

December 14, 1993, event were appropriate. Because of the,

differences in the two subsequent failures, the inspectors

concluded that the corrective actions for the December 14, 1994,

event were appropriate.

The licensee's report, LER 270/94-01, was submitted to the NRC on

March 10, 1994.

b.

Condenser Circulating Water (CCW) Piping Seismic Interactions

On January 18, 1994, the licensee identified a potential piping

interaction in which the CCW discharge vents could be damaged in a

seismic event by the metal buoyancy restraints placed around the

CCW intake piping to stabilize the lines while the piping is

dewatered. The licensee modified the restraints to prevent the

seismic interaction from occurring. This issue was discussed in

NRC Inspection Report 269,270,287/94-01 and identified as an item

8

to review following completion of the licensee's past operability

evaluation.

The licensee completed the past operability evaluation on

February 17, 1994, and determined that air inleakage due to the

potential seismic interaction would be sufficient to cause a loss

of siphon flow under worst case design bases events (i.e., seismic

event/loss of offsite power).

The actual effect on the systems

would depend on which CCW pumps were operating prior to the event.

The CCW buoyancy restraints were installed in July 1991, October

1992, and June 1992 for Units 1, 2, and 3, respectively.

The failure of the modification package to address the

potential seismic interaction between the restraints and the

CCW vent valves is identified as a violation of TS 6.4.1

(50-269,270,287/94-08-01).

The licensee identified this issue as a result of the problem

identification process that initially identified that four CCW

vent valves per unit were not shown on the CCW flow diagrams. The

licensee reported the potential interaction via LER 269/94-01,

dated March 23, 1994, identifying corrective actions implemented

to correct the potential seismic interaction, as well as

corrective actions planned to prevent recurrence. Accordingly,

this violaiton will not be subject to enforcement action because

the licensee's efforts in identifying and correcting the violation

meet the criteria specified in Section VII.B. of the Enforcement

Policy.

c.

Fatigue Analysis for RCS Auxiliary Piping

During a plant tour to gather information concerning fatigue

analysis documentation at various licensed facilities, members of

the NRC Fatigue Analysis Group discovered an apparent discrepancy

in Oconee's documentation. The Oconee RCS was designed to ASME

B31.7 Class I. In part, this code requires all RCS piping,

including the auxiliary connections, to have supporting analysis

and documentation for formal fatigue analysis. The NRC team

determined that the residual heat removal (RHR) piping connected

to the RCS does not have the required analysis.

The licensee initiated a Problem Investigation Process, PIP 0-94

0347, to address the issue. The licensee does not agree that the

piping in question is required to have fatigue analysis as

required by ASME B31.7. This item is identified as an Unresolved

Item, 50-269,270,287/94-08-03: Fatigue Analysis for RHR, pending

further NRC review to determine if the subject piping requires

fatigue analysis.

In this section, two Violations (one of which is Non-Cited) and one

Unresolved Item was identified.

9

5.

Inspection of Open Items (92701) (92702)

The following open items were reviewed using licensee reports,

inspection record review, and discussions with licensee personnel, as

appropriate:

a.

(Closed) VIO 269,270,287/93-05-01, Inadequate Procedure Governing

Testing of the 100 KV Power Supply From Lee Steam Station.

During the performance of PT/1/A/610/06, 100 KV Power Supply from

Lee Steam Station, both battery chargers SY-1 and SY-S, serving

the 230 KV switchyard 125 VDC system were deenergized for

approximately forty minutes. This resulted in the 230 KV

switchyard battery voltage dropping to 121 VDC as opposed to the

TS limit of 125 VDC. The performance of PT/1/A/610/06 involved a

dead bus transfer which deenergized main feeder bus 1TE. This in

turn resulted in the feeder breaker for the switchyard battery

chargers SY-1 and SY-S being loadshed (battery charger SY-2 is fed

from 2TE but was out of service for this test). The personnel

performing the test failed to recognize that all the battery

chargers would be deenergized. The test procedure was inadequate

in that it did not address the alignment of the switchyard battery

chargers. The inspector verified that the procedure was rewritten

to ensure both in-service battery chargers are powered from a unit

not being tested.

b.

(Closed) VIO 269/93-17-01, LDST Operation Outside of Procedural

Limits.

During performance of OP/1/A/1106/17, Hydrogen System, to add

hydrogen to the Unit 1 letdown storage tank (LDST), the pressure

in the LDST exceeded the requirements contained in procedure

OP/1/A/1104/02, High Pressure Injection System. Exceeding the

requirements of OP/1/A/1104/02 placed the Unit 1 HPI system in a

condition outside of its design basis.

Procedure OP/1,2,3/A/1106/17 was revised to add independent

verification on LDST level prior to hydrogen addition. The

inspectors verified that the procedure had been revised to include

independent verification.

c.

(Closed) VIO 269/93-17-02, Failure to Report High Pressure

Injection Outside its Design Basis.

During performance of OP/1/A/1106/17, Hydrogen System, to add

hydrogen to the Unit 1 letdown storage tank (LDST), the pressure

in the LDST exceeded the requirements contained in procedure

OP/1/A/1104/02, High Pressure Injection System. Exceeding the

requirements of OP/1/A/1104/02 placed the Unit 1 HPI system in a

condition outside of its design basis. The licensee failed to

report this condition as required by 10 CFR 50.72.B.1.ii.b.

10

The licensee deleted a TS interpretation that identified this

condition as not being outside the design basis of the HPI system

and revised procedure OP/1,2,3/A/1104/02 to reflect that operation

outside the LDST pressure/level requirements makes both trains of

the HPI system inoperable. The inspectors verified that above

corrective actions had been accomplished.

6.

Review of Licensee Event Reports (92700)

The below listed Licensee Event Reports (LER) were reviewed to determine

if the information provided met NRC requirements. The determination

included: adequacy of description, compliance with Technical

Specification and regulatory requirements, corrective actions taken,

existence of potential generic problems, reporting requirements

satisfied, and the relative safety significance of each event. The

following LERs are closed:

a.

(Closed) LER 269/92-17, Inadequate Seismic Support of Vital

Instrumentation and Control Batteries Due to Unknown Cause,

Possible Installation Deficiency.

The report identified three areas associated with the 125v battery

banks where the installation of the equipment did not agree with

the applicable vendor drawings. The deficiencies involved were:

(1) a vertical support was missing on the 2CB battery rail, (2)

missing splice plates on Units 2 and 3 battery racks, and (3)

battery cells were located above the butt joints on the mounting

racks.

The first two deficiencies were reviewed by the inspectors and

found to be acceptable. The results of that evaluation were

documented in NRC Inspection Report 50-269,270,287/94-01.

The third issue involved battery cells located above the butt

joints of the mounting rails. The vendor manual was revised by the

licensee to allow batteries to be placed above the butt joints on

racks with installed seismic protection. The inspector could not

find the basis for the licensee's revision to the vendor manual

even when considering the addition of the seismic structure.

Accordingly, the inspectors questioned the licensee regarding the

adequacy of their documentation. The licensee subsequently

performed an engineering evaluation and documented the results in

a letter dated March 3, 1994, Subject: Oconee Nuclear Station,

Seismic Behavior of Butt Joint Connection for Exide Battery Racks,

File No. NSD-0183. The evaluation concluded that the placement of

battery cells above the battery rack butt joints was acceptable.

b.

(Closed) LER 269/92-02, Equipment Failure In Emergency Power

System and Inappropriate Action Result In Technical Specification

Violation.

At 9:04 p.m., on January 29, 1992, Unit 1 of the Keowee Hydro

Power System failed when the hydro operator attempted to start the

unit and supply power to the grid. This unit was one of two

generators that can supply electrical power to the grid and serve

as back-up emergency power to the Oconee Nuclear Station. As a

result, the remaining unit (Keowee Unit 2) was started and

operated to supply the needed power to the grid.

The hydro operator inspected the Unit 1 "x" relays because of past

problems associated with them and found none to be out of the

expected position. However, the Unit 1 generator was declared

inoperable from the time that it was last shut down until it was

subsequently restarted at 9:16 p.m., on January 29, 1992.

The licensee investigated the event and determined that the root

causes of the event were: (1) an equipment failure where the

x-relays failed to reset which prevented the generator field

breaker from automatically closing and (2) inappropriate operator

action in that the hydro Unit 2 was not tested by energizing the

standby power bus within one hour as required by TS.

The licensee took corrective actions to counsel both the reactor

operators and the hydro operators on the .importance of

communication between the plants and the need to take immediate

corrective actions at any time when one of the Keowee Hydro units

fails to start. In addition, the mechanical "x" relays were

replaced with an electrical x/y scheme for all Keowee DB breakers

that require automatic closing capability.

The inspector reviewed the documented corrective actions and

determined them acceptable.

c.

(Closed) LER 287/91-07, Equipment Failure Closes Pneumatic Valve

in Condensate Demineralizer System Causing Loss of Feedwater and

Reactor Trip.

Oconee Unit 3 tripped on July 3, 1991, on a loss of feedwater.

The unit was operating at 100 percent power level when a clogged

instrument air line associated with a master valve controller

caused five parallel condensate valves to fail closed. This

resulted in blocking the condensate flow and consequently a main

feedwater pump trip, followed by a reactor trip.

Various other equipment items failed to operate as required during

the trip. As each deficient area was identified, the licensee

took corrective actions to eliminate the condition and to prevent

recurrence. However, a problem was discovered with the system

function and setpoints for actuation of emergency feedwater pumps

in response to loss of low feedwater pressure.- This resulted in

the issuance of LER 269/91-09.

The inspectors reviewed the licensee's resolution for each of the

deficiencies and determined them to be acceptable.

12

d.

(Closed) LER 287/92-01, Inappropriate Action Results in High Steam

Generator Level Causing Loss of Main Feedwater and Reactor Trip.

On January 14, 1992, while operating at 94 percent power, Unit 3

tripped on loss of both main feedwater pumps.

Instrument and

Electrical (I&E) technicians were performing trouble checks on a

suspected faulty controller in the Integrated Control System

feedwater control circuits. The I&E technicians used an

instrument with the test leads configured for current measurement

rather than voltage, causing a false signal to be introduced into

the controller. This increased feedwater flow, resulting in a

high water level in the 3B steam generator which automatically

tripped both main feedwater pumps. The trip of both main

feedwater pumps resulted in an anticipatory reactor trip. The

Licensee determined that the root cause was lack of attention to

detail by the I&E technicians. The I&E technicians were

counselled concerning their inappropriate action in this event.

Additionally, the licensee established a policy to have blank

plugs installed in the current measuring jacks of Fluke 8600

multimeters when issued. The above corrective actions (including

the licensee's root cause evaluation) were reviewed/verified by

the inspector and determined to be adequate.

e.

(Closed) LER 269/92-15, Reactor Trip Results From a Low Main

Feedwater Pump Discharge Pressure Reactor Protective System

Anticipatory Trip Signal Due to a Defective Procedure.

On October 3, 1992, Unit 1 tripped from 7.5 percent power due to a

main feedwater pump (MFDWP) low discharge pressure anticipatory

trip signal.

The trip occurred during an attempt to restore the

1B MFDWP to service following maintenance activities. When the

1B pump suction valve was opened, a momentary discharge pressure

drop occurred on the operating lA main feedwater pump resulting in

the reactor trip signal.

The licensee determined that the

pressure fluctuation was the result of the 1B MFDWP casing not

being pressurized prior to opening the pump suction valve.

This event was discussed in NRC Inspection Report

50-269,270,287/92-24. The inspector verified that the licensee

revised procedure OP/1/A/1106/02, Condensate and Feedwater, to

pressurize the isolated feedwater pump train prior to opening the

suction valve.

f.

(Closed) LER 287/91-08, Excessive Reactor Coolant Leak, Reactor

Trip and Inadvertent Protection System Actuation Result From

Management Deficiency and Equipment Failure

On November 11, 1991, Oconee Unit 3 experienced a RCS leak rate of

approximately 130 gpm through a failed 3/4-inch instrument line on

the RCS hot leg level sensing line. During the unit.shutdown, a

reactor trip occurred at approximately 33 percent power. The trip

was caused by a control loop oscillation which started when

13

operators stopped one of the two feed pumps by procedure. After

responding to the trip, operators continued the cooldown and

depressurization of the RCS. An inadvertent reactor protection

system actuation subsequently occurred when operators deviated

from procedure. Specifically, the shift crew decided to leave the

turbine bypass control station in automatic instead of placing it

in manual per procedure. The crew felt that automatic mode of

control was easier to control than manual for the

cooldown/depressurization in progress. When the Rod Control

System was reset in preparation for withdrawing Shutdown Banks, a

125 psig bias on the steam header pressure was removed

automatically. If the controller had been in Manual, as required

by the procedure, the removal of the bias would not have resulted

in a change in the output of the controller. Since the controller

was in Automatic, the removal of the bias caused the turbine

bypass control to sense that steam header pressure had instantly

increased 125 psig, creating a large pressure error. This caused

the bypass valves to open fully, creating a rapid temperature and

pressure drop. Operators responded by shutting the bypass valves

manually. After the bypass valves shut, temperature and pressure

began increasing, eventually reaching 1710 psig, the shutdown

overpressure trip setpoint. This actuated the RPS, and initiated

a reactor trip.

The cause of the leak was determined to be failure of an

improperly swaged compression fitting. All compression fittings

on the RCS were inspected for similar inadequate compression.

Several additional fittings were found that had not had complete

swaging or compression of the inner ferrule.

NRC Inspection Report 50-269/270/287-91-34 cited a violation for

failure to follow procedures during the cooldown, and a violation

for inadequate procedures used to field fabricate the compression

fittings.

Procedures and training were revised and deficient

fittings were replaced. Operators were counselled regarding their

lack of adherence to procedures during the cooldown. The licensee

determined that a contributing cause of the failure to follow

procedures was a poorly written procedure governing the cooldown.

This procedure was revised. Corrective actions for the violations

and LER were reviewed/verified by the inspector, and determined to

be adequate.

g.

(Closed) LER 269/90-04, Unanticipated System Interaction During

Undervoltage Condition in the 230 KV Switchyard Results in Failure

to Comply With Technical Specifications.

During development of a design basis study of the 230 Kv

switchyard, Design Engineering determined that during certain

degraded voltage conditions in the 230 Kv switchyard, both the 230

S0K

switchyard and the Keowee overhead path could be unavailable to

the Oconee station. Minimum voltage to adequately supply

emergency safeguards loads is 219 Kv, but the protective relaying

14

used to clear and realign the switchyard is 160 Kv. In order for

the overhead path from Keowee to supply the station, the 230 Kv

switchyard must be isolated from the bus section used by the

overhead path. The detection and clearing of the undervoltage

condition (or fault) is accomplished by the External Grid

Protection System. Confirmation that the fault or undervoltage

condition has been cleared and the bus realigned is provided by

the Switchyard Isolate Complete logic circuit. The Switchyard

Isolate Complete circuit then provides the permissive signal to

allow the Keowee overhead path to close in and supply the Startup

Transformers for all three Oconee units. A postulated degraded

voltage below 219 Kv, but above the actuation setpoint of 160 Kv,

would provide inadequate voltage for the safeguards loads and

prevent the Keowee unit from supplying power. If a single failure

of the other Keowee unit or its underground path is assumed, an

Oconee unit undergoing a LOCA would be without emergency power.

Operator action to isolate the switchyard would have to be

performed to restore power.

Immediate corrective actions included development of a procedure

to have operators monitor bus voltages frequently, attempt to

restore voltage if it drops below 225.2 KV, and enter the Action

Statements of TS 3.0 (i.e., correct the condition, or place the

units in hot shutdown conditions within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).

Subsequent corrective actions included:

(1) A station modification was implemented to automatically

isolate the switchyard when a coincident low bus voltage and

engineered safeguards signal is present.

(2) A TS change was submitted clarifying the requirements and

action for degraded grid conditions.

(3) Operator training was developed which included actions to be

taken during conditions described above.

(4) Revisions to previous plant responses to the NRC Generic

Letter (GL) dated August 8, 1979, titled, Adequacy Of

Distribution System Voltages, would be submitted, as

appropriate. This was necessary since the original response

was not accurate because it had not considered the degraded

voltages described in this LER.

This LER commitment was

later deemed unnecessary by the station staff. Therefore,

an amended response to the GL was not submitted. The

licensee concluded that submission of the TS changes, review

of the proposed switchyard modification by NRC, and

extensive review of the entire area of degraded grid

situations by the NRC Electrical Distribution Safety

15

Functional Inspection (EDSFI) team conducted in 1993, made a

revised response not appropriate.

No violations or deviations were identified.

7.

Exit Interview

The inspection scope and findings were summarized on March 30, 1994,

with those persons indicated .in

paragraph 1 above. The inspectors

described the areas inspected and discussed in detail the inspection

findings addressed in the Summary and listed below. The licensee did

not identify as proprietary any of the material provided to or reviewed

by the inspectors during this inspection.

Item Number

Description/Reference Paragraph

50-269,270,287/94-08-01

Non-Cited Violation:

Inadequate

Modification Package Results in Potential

Seismic Interaction (paragraph 4.b).

50-270/98-08-02

Violation:

Inoperability of 2A Emergency

Feedwater Pump (paragraph 4.a).

50-260,270,287/94-08-03

Unresolved Item:

Fatigue Analysis for RHR

(paragraph 4.c).