ML16154A699
| ML16154A699 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/02/1994 |
| From: | Casto C, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16154A696 | List: |
| References | |
| 50-269-94-33, 50-270-94-33, 50-287-94-33, NUDOCS 9411090095 | |
| Download: ML16154A699 (11) | |
See also: IR 05000269/1994033
Text
Ega REGU
UNITED STATES
05
NUCLEAR REGULATORY COMMISSION
2
a
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report Nos.:
50-269/94-33, 50-270/94-33 and 50-287/94-33
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.:
50-269, 50-270, and 50-287
License Nos.:
and DPR-55
Facility Name: Oconee Nuclear Station Units 1, 2 and 3
Inspection Conducted: October 3-7, 1994
Inspector:
7oY
-
Pl, < <L
__
/ Dat.
M. Thomas
Date Signed
Accompanying Personnel: M. Miller, Reactor Inspector
Approved by:
Test Programs Section
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of engineering
and technical support activities, design changes and plant modifications, and
followup on previous inspection findings.
Results:
In the areas inspected, there were no violations identified. One deviation
was identified associated with a Unit 3 temporary modification (TM) installed
in the reactor protective system that did not meet Final Safety Analysis
Report commitments for electrical isolation. (paragraph 3)
The inspection resulted in the following assessments:
-
Current staffing levels were adequate to perform the assigned duties and
responsibilities in the engineering organization. (paragraph 2.a.)
Enclosure
9411090095 941102
PDR ADOCK 05000269
0
2
-
Additional training was being developed to address training needs in
engineering which resulted from the engineering reorganization.
(paragraph 2.a.)
-
Engineering was addressing the Problem Investigation Process backlogs
for those assigned to engineering. (paragraph 2.b.)
-
Backlogged work orders assigned to engineering were not being addressed
in a timely manner. (paragraph 2.b.)
-
Except for the deviation identified with one TM, all other TMs reviewed
were satisfactorily implemented. (paragraph 3)
-
Engineering self assessment activities were effective in identifying
areas for improvement. (paragraph 4)
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- E. Burchfield, Manager, Regulatory Compliance
- T. Campbell, Manager, Unit 2 Work Control
- D. Coyle, Manager, Mechanical Systems Engineering
- J. Davis, Manager, Engineering
- V. Dixon, Engineer, Mechanical/Civil Equipment Engineering
- B. Dolan, Manager, Safety Assurance
- W. Foster, Supervisor, Mechanical Maintenance
- J. Hampton, Oconee Site Vice President
- T. Ledford, Supervisor, Electrical Systems/Equipment Engineering
C. Little, Manager, Electrical Systems/Equipment Engineering
T. Matthews, Valve Engineer, Mechanical/Civil Equipment Engineering
- W. McAlister, Supervisor, Electrical Systems/Equipment Engineering
- M. Miller, Engineer, Electrical Systems/Equipment Engineering
- T. Mills, Supervisor, Mechanical/Civil Equipment Engineering
B. Millsaps, Manager, Mechanical/Civil Equipment Engineering
- D. Nix, Engineer, Regulatory Compliance
- B. Peele, Station Manager
- T. Royal, Supervisor, Mechanical/Civil Equipment Engineering
- R. Sweigart, Superintendent, Work Control
- D. Taylor, Manager, Modifications Engineering
- C. Tompkins, Supervisor, Mechanical/Civil Equipment Engineering
- L. Wilkie, Manager, Safety Review Group
Other licensee employees contacted during this inspection included
engineers, operators, technicians, and administrative personnel.
NRC Personnel
- C. Casto, Section Chief, Division of Reactor Safety, Region II
- P. Harmon, Senior Resident Inspector
G. Humphrey, Resident Inspector
L. Keller, Resident Inspector
- W. Poertner, Resident Inspector
- Attended exit meeting
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2.
Engineering and Technical Support Activities (37550)
a.
Organization, Staffing, and Training
The inspectors reviewed the licensee's organization and staffing
to determine whether the engineering organization was adequately
staffed to provide effective engineering support to the plant.
Oconee Nuclear Station (ONS) implemented a reorganization of its
2
engineering department in March 1994. The engineering
organization structure was defined by roles with other plant
groups and staffed according to functional needs. The new Site
Engineering organization was aligned to accomplish two primary
functions: modification engineering and plant engineering.
Modification engineering consisted of the Modifications Section.
The role of modification engineering was focused on long term
modifications and design functions. The long term modification
function encompassed all plant modification work except for
maintenance minor modifications which were being handled by plant
engineering as short term plant support work.
Plant engineering consisted of the Mechanical Systems Section, the
Mechanical/Civil Equipment (MCE) Engineering Section, and the
Electrical Systems/Equipment (ESE) Engineering Section. The role
of plant engineering was focused on short term engineering support
of the plant while interfacing with modifications engineering
regarding long term support. Plant engineering responded directly
to maintenance and operations personnel for engineering
troubleshooting and day-to-day support.
Engineering and technical support were provided by both onsite and
corporate (General Office) organizations. The inspectors reviewed
selected activities of the various Site Engineering groups.
Discussions were held with licensee personnel and documentation of
selected plant activities was reviewed to evaluate the engineering
involvement and support of day-to-day plant operations. This
support included: trending equipment performance; preparing
nuclear station modifications (NSM), minor modifications (MM), and
temporary modifications (TM); responding to Problem Investigation
Process (PIP) items and work orders; and performing safety
evaluations, failure analyses, etc.
(1) Modification Engineering
The Modifications Section in Site Engineering was primarily
responsible for the design of long term NSMs; configuration
control (which includes drawing control); and other design
functions such as maintaining the plant design criteria,
human factors reviews, design input calculations, Appendix R
evaluations, seismic reviews, etc.
(2) Mechanical Systems Engineering
The Mechanical Systems Section was primarily responsible for
providing day-to-day support to operations. The section was
divided into the following "teams:" (1) primary systems; (2)
secondary systems; (3) balance of plant; and (4) nuclear,
which included reactor engineering. Responsibilities
included system monitoring, trending thermal performance,
system reliability/availability, Technical Specifications
3
knowledge, owners of the design basis documentation (DBD)
for mechanical systems, system walkdowns, system team
reports, PIP operability evaluations and proposed
resolutions, MM development, periodic test results analysis,
50.59 evaluations, reactivity management, fuel reliability
and testing, etc.
The inspectors reviewed the consolidated systems report for
various mechanical systems. The report covered the period
from January 1994-June 1994. The inspectors noted that the
report was thorough and provided detailed information on the
status of the systems.
(3) Mechanical/Civil Equipment Engineering
The principle responsibility of the MCE Engineering Section
was to provide engineering and technical support to the
station mechanical maintenance craft groups. The section
was divided into the following teams: (1) non-rotating
mechanical equipment (piping, heat exchangers, etc.); (2)
rotating equipment (pumps, motors, diesel engines, etc.);
(3) valves; and (4) civil issues. Other responsibilities
included the preventive/predictive maintenance program,
component monitoring and trending, component failure
analysis and trending, MM development, operability
evaluations, post maintenance testing activities, etc.
(4) Electrical Systems/Equipment Engineering
The principle responsibility of the ESE Engineering Section
was to provide engineering and technical support to
operations and to the station electrical maintenance craft
groups. The section was divided into the following teams:
(1) electronics equipment (reactor protection system, rod
control, digital rod position indication, solid state
protection system, etc.); (2) instrumentation and control
equipment (transmitters, controllers and positioners, crane
controls, switches, etc.); and (3) power systems equipment
(switchyard, protective relays, chargers and inverters,
vital AC, DC systems, etc.). Other responsibilities
included the environmental qualification program, DBD owners
for electrical power systems and electronic systems, FSAR
updates, component failure analysis and trending, MM
development, etc.
(5) Training
In addition to reviewing the licensee's organization and
staffing, the inspectors also reviewed documentation and
held discussions with licensee personnel regarding the
training and qualification of the engineering staff. As a
result of the engineering reorganization, licensee personnel
4
performed an evaluation to identify the immediate training
needs of Site Engineering. The training consisted of
initial training, position specific training, and continuing
training. The various engineering sections were developing
schedules to ensure that their personnel would complete the
appropriate training. The inspectors reviewed the training
programs for the various engineering sections and training
records for selected individuals. Appropriate training was
being provided to the engineering personnel.
The inspectors concluded that the current staffing levels for the
Site Engineering organization were adequate to perform their
assigned responsibilities. Site Engineering personnel had
recognized the need for and was developing additional training
based on the engineering reorganization.
b.
Engineering Backlogs
The inspectors reviewed the status of selected engineering
backlogs to determine if sufficient engineering resources and
management attention were being focused to prevent the buildup of
a large engineering work backlog. Items reviewed in this area
included PIPs and open work orders.
(1) Problem Identification and Resolution
The inspectors reviewed the PIP items assigned to Site
Engineering in order to assess whether Site Engineering was
providing timely support in the resolution of plant problems
assigned to them in the form of PIPs. The inspectors
reviewed the September 1994 report issued by the Corrective
Action Continuous Improvement Team. This report tracked and
trended PIP data for various plant departments. This
included the sections in Site Engineering. The inspectors
also reviewed selected PIPs to verify that adequate
evaluations were performed and appropriate corrective
actions were specified. The inspectors concluded that most
of the PIPs were generally being resolved in accordance with
the times specified in Nuclear System Directive NSD 208,
Problem Investigation Process. Most of the engineering
groups had a relatively small backlog of PIP items.
(2) Open Work Orders
The licensee provided the inspectors with a list dated
September 9, 1994, which contained 84 open work orders (WO)
assigned to the various groups in Site Engineering. The
inspectors noted that 47 of the 84 WOs on the list were
initiated prior to 1993. Upon further review and discussion
licensee personnel indicated that the WOs were in the
process of being reviewed by the engineering groups in order
5
to prioritize and develop a schedule for resolution. The
inspectors reviewed the open WOs and determined that none of
the WOs represented operability concerns.
The inspectors concluded that WOs assigned to engineering
were not being addressed in a timely manner. Additional
management attention was needed in this area to ensure that
timely actions are taken to address WOs assigned to Site
Engineering.
Violations or deviations were not identified in the areas inspected.
3.
Temporary Modifications (37550)
The inspectors reviewed and assessed the licensee's temporary
modification (TM) process to determine its adequacy for controlling and
tracking temporary changes to the plant's configuration. Nuclear System
Directive NSD 301.7, Administration of Temporary Modifications; and
Oconee Nuclear Site Directive 2.1.4, Control of Temporary Modifications,
provided controls for the preparation, review, installation, and removal
of TMs. TMs were prepared by the systems or equipment engineers. The
inspectors reviewed several active TMs to determine if the requirements
of the above procedures were being met. The TMs were also reviewed to
verify and ensure that: (1) applicable TS requirements and FSAR
commitments were met; (2) adequate 50.59 safety evaluations and
technical reviews were performed; and (3) testing was specified and
performed where applicable. In addition, the inspectors conducted
walkdowns to verify that the TMs were installed as specified. The
following TMs were examined:
TM 1091, Unit 1 Cross connected (positive to negative and vice-versa)
the input conductors supplying DC power to input
breaker CB1 in transfer diode 1ADA cabinet 2. This TM
was required because the line side of the conductors
to the backup breaker 3A in cabinet 2DCA was
previously reversed and could not be isolated until
the next outage.
TM 1123, Unit 1 Installed a reactor protective system (RPS)
demonstrator unit in RPS Channel E to monitor the RPS.
Channel E was selected because no reactor trip
functions were associated with it. All connections
were made through isolated RPS outputs.
(NOTE: The
demonstrator was a solid state computer module
designed to perform RPS functions. It was connected
to Channel E only to monitor the RPS input signals, no
output signals from the demonstrator were connected).
TM 1133, Unit 3 Connected multi channel chart recorder to RPS Channel
"C" Flow and NI-7 Power signals.
6
TM 1151, Unit KO Opened sliding link in Keowee board EB5 to defeat
relays 94GB in Unit 1 and Unit 2 from picking up relay
86T and locking out the overhead emergency power path.
This temporary modification defeated the overhead path
lockout due to low ACB (air circuit breaker) control
air pressure and loss of ACB control power.
TMs 1091, 1123, and 1151 were found to be satisfactorily implemented.
During the review of TM 1133, the inspectors identified a concern with
the implementation of the TM. During the walkdown of TM 1133 on
October 6, 1994, the inspectors identified that the recorder power cord
was plugged into a local 120 VAC non Class 1E outlet. In the associated
10 CFR 50.59 evaluation, the RPS was described as being nuclear safety
related. FSAR Section 7.2.3.3, Electrical Isolation, stated, in part,
that "All signals leaving the Reactor Protective System are isolated
from the system ....
The effect of this isolation is to prevent faults
occurring to signal lines outside of the Reactor Protective System
cabinets from being reflected into more than one Protective channel."
RPS Channel C is a protective channel.
The inspectors noted that the
10 CFR 50.59 safety evaluation was not adequate in that it did not
address whether there was adequate electrical isolation between the
chart recorder and the RPS channel.
Connection of the temporary
recorder to RPS Channel C and providing 120 VAC power to the recorder
from a non-isolated power source was considered a deviation from
commitments in Section 7.2.3.3 of the FSAR. This item will be
identified and tracked as Deviation 50-287/94-33-01, Non Isolation of a
Temporary Recorder Connected to the Reactor Protective System. After
discussion of this issue during the exit meeting, licensee personnel
unplugged the chart recorder until the TM could be further evaluated.
Violations were not identified in the areas inspected.
4.
Engineering Self Assessment Activities
The inspectors reviewed assessment reports of Site Engineering
activities. Reports reviewed included the Engineering Self Assessment
(which covered the period from May 1, 1993, through June 30, 1994); the
Safety Review Group Evaluation Report IP94-08, 10CFR 50.59
Implementation Review; and the Corrective Action Continuous Improvement
Team report for September 1994. The assessments were thorough and
indepth. Report IP94-08 assessed the effectiveness of the ONS 10 CFR
50.59 evaluation process. This report identified several weaknesses
which included implementation errors in the 50.59 process, the lack of
adequate 50.59 training, etc. The licensee was taking actions to
address the findings in report IP94-08.
The inspectors concluded that the assessments of Site Engineering
performance were effective in identifying areas where additional
management attention was needed for improvement.
Violations or deviations were not identified in the areas inspected.
7
5.
Followup on Previous Inspection Findings (92701)
a.
(Closed) URI 269,270,287/91-13-01, Concern Regarding Design and
Maintenance Actions Stemming From Failure of Valve 2LPSW-4.
During an Engineered Safeguards (ES) test on October 23, 1990, MOV
2LPSW-4 failed to open on the ES signal and the breaker for 2LPSW
4 tripped. A second attempt to open the MOV resulted in a second
breaker trip. On the third attempt, the licensee had bypassed the
torque switch and the motor overload devices and the MOV opened.
It was not clear that those actions had any effect on the MOV
opening since the torque switch was normally bypassed for the
first 50% of the opening stroke and the overload devices had not
de-energized the motor during the previous attempts. The MOV was
cycled several times and a diagnostic test was run to verify
correct operation. This diagnostic test showed that the MOV
thrust exceeded the specified thrust range. The licensee found
the spring pack had an extra Belleville washer installed. The
spring pack was repaired, a new torque switch was installed, and a
diagnostic test (VOTES) performed to set the torque switch for the
specified thrust. The MOV was cycled once a day for the next five
days to verify operability of the MOV.
The concerns listed in NRC Report 50-269,270,287/91-13 for the
GL 89-10 Part 1 inspection performed June 24-28, 1991, were:
-
The investigation and repair of the failure of MOV 2LPSW-4
in October 1990 appeared inadequate.
-
The breaker trip appeared inadequately addressed.
-
The implication of possible inadequate design was not
recognized concerning breaker tripping of the motor instead
of allowing the motor to burn out attempting to perform its
safety function.
-
The possibility of motor insulation damage due to high
current... was not checked.
-
The torque switch was replaced without a documented reason.
The inspectors determined that the licensee's initial response and
corrective actions for the failure of MOV 2LPSW-4 were considered
weak, although acceptable. As a good practice, the motor should
have been meggered for potential insulation damage. However,
there were no requirements, design or otherwise, specifying that
the breakers and overloads should be sized to allow the motor to
burn out. In addition, there was no requirement to document the
reason" for replacing the torque switch, although it is a good
practice. As a result of the GL 89-10 Part 1 inspection, the
- II8
licensee initiated Problem Investigation Report (PIR) 2-091-0071
to address the problem. In addition, the following WOs were
implemented:
WO 52269K
Motor was meggered
WO 52339L
Breaker was upgraded
Valve seats and disc were inspected and machined
Valve operator was inspected, refurbished, and
VOTES tested
The inspectors concluded that the licensee's subsequent actions
have addressed the failure. This item will be closed.
b.
Closed VIO 50-269,270,287/93-12-01, Failure To Properly Maintain
Drawing Changes In The Control Room.
The licensee responded to this violation in a letter dated June 7,
1993. The inspectors verified that the licensee had implemented
the corrective actions specified in their response. Personnel
involved in the upkeep of drawings in operations were retrained on
the proper updating and maintenance of drawings. The training was
completed June 17, 1993. In addition, the Document Management
Section performed a complete audit of all the operations drawing
files. This audit identified additional deficiencies with the
aperture cards and hard copy drawings. As a result of the audit,
Document Management has taken over the responsibilities of
maintaining the drawings for operations. The inspectors concluded
Document Management has done a very thorough job of implementing
appropriate corrective action. This violation will be closed.
Violations or deviations were not identified in the areas inspected.
6.
Exit Interview
The inspection scope and results were summarized on October 6, 1994,
with those persons indicated in paragraph 1. The inspectors described
the areas inspected and discussed in detail the inspection findings
listed below. Proprietary information is not contained in this report.
No dissenting comments were received from the licensee. The following
item was identified:
Deviation 50-287/94-33-01, Non Isolation of a Temporary Recorder
Connected to the Reactor Protective System (paragraph 3).
Unresolved Item 50-269, 270, 287/91-13-01; and Violation 50-269, 270,
287/93-12-01 were reviewed by the inspectors and will be closed.
(paragraph 5)
7.
Acronyms and Initialisms
Alternating Current
ACB
Air Circuit Breaker
CFR
Code of Federal Regulations
Design Basis Documentation
Direct Current
Engineered Safeguards
ESE
Electrical Systems/Equipment
Final Safety Analysis Report
GL
Generic Letter
MCE
Mechanical/Civil Equipment
MM
Minor Modification
Motor Operated Valve
NSD
Nuclear System Directive
NSM
Nuclear Station Modification
Oconee Nuclear Station
Problem Investigation Process
Problem Investigation Report
Reactor Protective System
TM
TS
Technical Specifications
Unresolved Item
VAC
Volts Alternating Current
Vi
Violation
VOTES
Valve Operation Test and Evaluation System
Work Order
Moo0prae av