ML16154A779

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Insp Repts 50-269/95-03,50-270/95-03 & 50-287/95-03 on 950226-0325.Violation Noted.Major Areas Inspected:Plant Operations,Surveillance Testing,Maint Activities,Onsite Engineering & Technical Assistance
ML16154A779
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 04/21/1995
From: Crlenjak R, Harmon P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML16154A778 List:
References
50-269-95-03, 50-269-95-3, 50-270-95-03, 50-270-95-3, 50-287-95-03, 50-287-95-3, NUDOCS 9505030140
Download: ML16154A779 (17)


See also: IR 05000226/2003025

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W., SUITE 2900

ATLANTA, GEORGIA 30323-0199

Report Nos.:

50-269/95-03, 50-270/95-03 and 50-287/95-03

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:

February 26 - March 25, 1995

Inspector:

/

. E. Hafmon, Senior R dent/nspector

Date Signed

W. K. Poertner, Resident Inspector

L. A. Ke 1ler, Resident Inspector

P. G.,

phrey, Re ident Inspector

Approved by:

  • k

/V.rlenA

Chief

Dte Signed

Reactor Projects Branch 3

SUMMARY

Scope:

This routine, resident inspection was conducted in the areas of

plant operations, surveillance testing, maintenance activities,

onsite engineering and technical assistance, plant support,

inspection of open items, and review of licensee event reports.

Inspections were performed during normal and backshift hours and

on weekends.

Results:

An Unresolved Item was identified in Plant Operations regarding

the misalignment of a valve in the Auxiliary Service Water System,

paragraph 2.d.

Within the area of Engineering, one Violation with 2 examples was

identified that involved calculation errors associated with the

maximum power output limits of the Keowee Hydro Units, paragraph

4.b. Additionally, the need for a Technical Specification change

to clarify the number of High Pressure Injection Pumps required

for reactor modes of operation was identified as an Inspector

Followup Item, paragraph 6.a.

Enclosure 2

9505030140 9504216

QPDR

ADOCK 05 0002 9

2

Plant Support activities of the Nuclear Safety Review Board were

well organized and aggressively pursued resolution of plant

problems, paragraph 5.b. In addition, the transportation and

storage of a spent fuel assemblies canister was well planned and

coordinated, paragraph 5.a.

Enclosure 2

REPORT DETAILS

1.

Persons Contacted

Licensee Employees

  • B. Peele, Station Manager
  • L. Azzarello, Mechanical Systems Engineer
  • E. Burchfield, Regulatory Compliance Manager
  • D. Coyle, Systems Engineering Manager

J. Davis, Engineering Manager

T. Coutu, Operations Support Manager

  • W. Foster, Safety Assurance Manager
  • J. Hampton, Vice President, Oconee Site

D. Hubbard, Superintendent, Instrument and Electrical (I&E)

C. Little, Electrical Systems/Equipment Manager

  • J. Smith, Regulatory Compliance
  • G. Rothenberger, Operations Superintendent

R. Sweigart, Work Control Superintendent

  • L. Wilkie, Safety Review Manager

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, 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.

Enclosure 2

2

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.

b.

Plant Status

All three units operated at or near full power throughout the

inspection period.

c.

Reactor Building Tour While At Power

On February 28, 1995, the inspector accompanied licensee personnel

on a tour of accessible areas in the Unit 3 Reactor Building (RB)

while at 100 percent power. The licensee's purpose for the RB

entry was to identify boron leaks in order to plan the necessary

repair activities for the June 1995 refueling outage. The

inspector noted that ALARA (As Low As Reasonable Achievable)

principles were followed and that the radiation protection

requirements were adequate. The inspector did not identify

unsecured equipment or debris, and concluded that the general

cleanliness of the RB was adequate.

d.

Configuration Control Of Plant Equipment

A non-licensed operator found Unit 2 Condenser Circulating Water

valve 2CCW-110 in the closed position on March 23, 1995. The valve

was in the supply line of the Auxiliary Service Water System. It

is required to be in the open position to provide emergency

feedwater to the 2A Once Through Steam Generator per calculation

OSC-2262 (Tornado Protection Analysis) in the event of the

designated emergency. It had been opened and verified open on

October 29, 1994, per operations checklist OP/2/A/1104/12,

Condenser Circulating Water System, Enclosure 4.19, Valve

Checklist, and 4.20, Valve Checklist Verification.

The operator noted the closed valve during a Job Performance

Measures exercise and generated a Problem Identification Process

Report (PIP 2-095-0350). However, the event was similar to that

found by the licensee on August 15, 1994, when the comparable

valves in Units 1 and 3 were found in the closed position. At

that time, the licensee determined that those valves were not

realigned after completion of hydrostatic tests performed on June

2 and 3, 1995. The licensee stated that realignment was thought

to be accomplished under the feedwater system alignment since most

of the valves involved in the hydrostatic test were in the

feedwater system. As a result, the auxiliary service water valves

were missed in the realignment. The reason for the misalignment

of Unit 2 valve 2CCW-110 has not been determined. As a result, an

Enclosure 2

3

Unresolved Item will be opened, URI 50-270/95-03-03, Valve

Configuration.

Within the areas reviewed, the licensee's actions were determined to be

appropriate with the exception of a misaligned valve.

3.

Maintenance and Surveillance Testing (62703 and 61726)

a.

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 (WO) were examined to verify that

proper authorization and clearance to begin work was given,

cleanliness was maintained, contamination exposure was controlled,

equipment was properly returned to service, and limiting

conditions for operation were met.

Maintenance activities observed or reviewed in whole or in part

are as follows:

(1) Investigate And Repair "B" Sullair Compressor,

WO 95020040 Task 01

The inspector observed troubleshooting and repair in

progress associated with the "B" Sullair Compressor which

had dumped oil on the floor. The equipment, which serves as

a backup air supply for the three units at Oconee, was

classified as non-safety and the work effort was performed

in accordance with Duke Class G criteria. The discharge

check valve was suspected of failing in the shut position,

causing the rotor to rotate in the reverse direction and the

subsequent oil dump.

The work order included the performance of maintenance

procedure MP/O/B/3007/009, Compressors - Sullair Frequent

and Periodic Inspections and Preventative Maintenance. This

procedure presented guidelines for monthly, semi-annual and

annual preventive maintenance that included air filter

inspection, cleaning or replacement, oil addition, oil and

oil filter changeouts, and oil separator element

replacement. The maintenance activity was accomplished in

accordance with the controlling procedure and the inspector

did not identify any deficiencies.

(2) Investigate and Repair Delta Pressure On Unit 2 Feedwater

Valves, WO 95020475

Maintenance activities were reviewed by the inspector to

investigate and evaluate an increased pressure differential

Enclosure 2

4

(72 psid vs 35 psid normal) across the 2B steam generator

feedwater control valve (2FDW-41). The activity was

performed on March 13, 1995, and consisted of an evaluation

of pressure transmitter 2FDW PT0032, which measures

differential pressure across the 2A steam generator

feedwater control valve (2FDW-32). The feedwater control

circuitry utilizes input from the differential pressure

transmitters in both feedwater lines to control the

feedwater to the steam generators.

Operation of the feedwater system was placed in manual

control to allow manipulation of the instrument root valves

at pressure transmitter 2FDW PT0032. The purpose was to

check for leakage at the transmitter equalization valve.

Although no leakage was identified, the effort was

successful in the elimination of suspect equipment that

could be causing the unexplained high pressure drop across

control valve 2FDW-41.

The work effort was performed satisfactorily; however, the

condition causing the high pressure differential across the

valve was not determined. The licensee continues to monitor

and investigate this condition.

(3) Replace/Calibrate Reactor Protection System Feedwater Pump

Discharge'Pressure Switches, WO 95005574

Replacement of the Unit 3 Feedwater Pump Discharge Pressure

and Feedwater Pump Control Oil Pressure Switches was

observed in progress by the inspector. The activity was

necessary because the existing pressure switches were

exhibiting excessive drift and had been placed on an

increased calibration frequency. The cause of the

calibration drift was attributed to problems associated with

the switch diaphragm. The switches being replaced were

Static-O-Ring Models 11013805N and 1101380106N, which had a

316 stainless steel welded wetted diaphragm with a 2 layer

polyamide tertiary diaphragm. The replacement switches were

Static-O-Ring Models 1101401231N and 110140123N, which have

316 stainless steel welded wetted diaphragm and 1 layer of

Teflon coated polyamide tertiary diaphragm. (Note:

The

licensee also plans to change out these switches on Units 1

and 2.)

The inspector questioned use of a work order as opposed to a

design change. The concern was that the replacement switch

models may not be documented and later purchases would not

be for the correct equipment. However, engineering had

documented the change and submitted an Acceptable Substitute

Request (Form NPP-212D) to ensure documentation update.

Enclosure 2

5

The inspector determined the activity to be acceptable and

accomplished in accordance with the requirements specified

in the procedure.

(4) Replace Powdex Conductivity Probes, WO 95006002

Task 01

The inspectors reviewed work activities associated with this

corrective maintenance activity. The conductivity probes

were replaced due to frayed electrical connections. Work

activities reviewed were performed satisfactorily. No

deficiencies were noted.

(5) Infrared Thermography Survey of Condensate Booster Pump C,

WO 94073066 Task 01

The inspectors reviewed work activities associated with this

preventive maintenance (PM) activity. This PM is performed

semi-annually and consists of checking the breaker cubicle

for electrical hot spots. The work activity was

accomplished per procedure MP/0/B/3016/012, Using

Inframetric Model 600 Scanner. The maintenance activity was

accomplished in accordance with the controlling procedure

and the inspectors did not identify any deficiencies.

(6) Calibrate Unit 1 Auxiliary Instrument Air (AIA)

Instrumentation, WO 94083457 Task 01

On March 16, 1995, the inspector observed calibration of

various instruments associated with the 1 AIA air

compressor. All activities observed were satisfactory.

(7) Lubrication PM on 3C Spent Fuel Cooling Pump, WO 95017147

Task 01

The inspector verified that the correct lubricant was used

and that the work was accomplished in accordance with the

licensee's generic pump lubrication procedure

(MP/0/A/1840/040). All activities observed were

satisfactory.

b.

The inspectors observed surveillance activities to ensure they

were conducted with approved procedures and in accordance with

site directives. The inspectors reviewed surveillance

performance, as well as system alignments and restorations. The

inspectors assessed the licensee's disposition of any

discrepancies which were identified during the surveillance.

Enclosure 2

6

Surveillance activities observed or reviewed in whole or in part

are as follows:

(1) Turbine Driven Emergency Feedwater Test, PT/2/A/0600/12

The inspector reviewed testing of the Unit 2 turbine driven

emergency feedwater pump on February 27, 1995. The

equipment alignment for the test was in accordance with the

procedure and test instruments were within their calibration

date allowances. The purpose of the test was to demonstrate

operability of the pump as required per TS Sections 3.4,

4.0.4 and 4.9.

The activity was performed to acceptable standards.

(2) Engineered Safeguards System Logic Subsystem 2 High Pressure

Injection and Reactor Building Isolation Channel 2 On-Line

Test, IP/O/A/0310/13A

The inspectors reviewed testing of the Unit 1 Engineered

Safeguards System conducted on March 24, 1995. The

procedure implements the requirements of TS 4.1.1, Table

4.1-1, Item 14. The TS requires that a logic test be

performed monthly. The inspectors verified that the testing

was accomplished in accordance with the procedure and that

the acceptance criteria was met. No deficiencies were

noted.

(3) Unit 1 Motor Driven Emergency Feedwater (MDEFW) Pump Test,

PT/1/A/0600/13

On March 15, 1995, the inspector observed the operability

test of the 1A MDEFW pump. The inspector verified that the

test was performed in accordance with procedure and that all

parameters met the acceptance criteria.

Within the areas reviewed, licensee activities were satisfactory. No

violations or deviations were identified.

4.

Onsite Engineering (37551)

During the inspection period, the inspectors assessed the effectiveness

of the onsite design and engineering processes by reviewing engineering

evaluations, operability determinations, modification packages and other

areas involving the Engineering Department.

a.

Measured Capacities of the 125vdc Control Batteries

Unit 3 control battery 3CA was tested on March 1, 1995. Its

measured capacity was 77.97 percent. Capacity should be at 80

Enclosure 2

7

percent or greater to comply with design calculations and the

Design Basis Documents. As addressed in Inspection Report 50

269,270,287/95-01, the licensee performed calculation OSC-5938 on

January 5, 1995, to determine acceptable operability of the 2CB

battery when it was tested and found to be at 77 percent capacity.

This calculation utilized the maximum design basis load for all

batteries and was applied to the 3CA battery as well.

In addition

to control batteries 3CA and 2CB, a third battery (2CA) was

measured at 80.2 percent.capacity.

All six control batteries (Exide FTC-23) are utilized as a backup

for various safety-related equipment during an accident involving

a loss of electrical power. Representatives from Exide have been

involved and the licensee reported that Exide will provide

replacements for those battery cells which tested low. However, a

delivery schedule was not available at the end of the inspection

period. Inspection of this issue will continue under Inspector

Followup Item 50-270/95-01-01, Control Battery Capacities.

b.

Inadequate QA-1 Calculations Involving Keowee Hydro Unit (KHU)

Power Limits

On October 12, 1992, the licensee discovered a single failure

vulnerability due to the "zone overlap" of certain differential

current protective relays (LER 269/92-16). As discussed in LER 269/92-16, and paragraph 7.a of this report, the corrective action

to eliminate this vulnerability (opening the breaker disconnects

on the overhead path of the KHU aligned to the underground path)

resulted in the inability to simultaneously generate both KHUs to

the grid. The licensee, for financial reasons, determined that

the inability to simultaneously generate both KHUs to the grid was

unacceptable. Therefore, the development of a modification to

preclude this single failure and allow simultaneous generation to

the grid was initiated. This modification was eventually

designated NSM-52966.

On January 11, 1993, the on-going "Keowee Single Failure Analysis"

identified the technical inoperability of the KHUs while

generating to the grid during certain power/lake level

combinations, due to turbine overspeed (LER 269/93-01). A KHU

generating to the system grid at a high load when an emergency

start initiated, would separate from the grid and overspeed.

Under certain power/lake level combinations the speed would reach

the overspeed trip setpoint, which trips the unit and opens the

field breakers and prevents their reclosure. As a result,

operation of a KHU to the system grid was limited to 66 MW. This

limit was documented in calculation OSC-6003, Revision 0, "Keowee

Operating Limits to Prevent Overspeed Due to Load Rejection."

The

basis for the 66 MW limit was load rejection test data from

initial startup. These initial startup load rejection tests were

Enclosure 2

8

conducted at 22, 44, 66, 88 and 100 MW. Since the test at 88 MW

resulted in an overspeed trip and the test at 66 MW did not, 66 MW

was chosen as the load limit.

On May 20, 1993, OSC-6003 was revised (Revision 1) to change the

66 MW operating limit to 75 MW. This was based on load rejection

tests conducted during April 1993 and calculation KC-UNIT-1-2

0097.

On May 16, 1994, another scenario was found that could render the

emergency power system inoperable due to overspeeding following

separation from the grid (LER 269/93-01, Revision 1).

The

scenario involves both KHUs generating to the grid when a

LOCA/LOOP occurs. Both units receive an emergency start signal,

separate from the grid, and then overspeed due to load rejection.

This results in above normal frequency output such that the

electrical supply to certain safety-related motors yields a lower

starting torque, requiring longer time to accelerate which could

result in a motor trip on overcurrent. The licensee expanded the

scope of NSM-52966 to eliminate the possibility of

overspeed/overfrequency while allowing simultaneous generation of

both KHUs to the grid.

On January 19, 1995, the licensee made a presentation to NRC

regarding their proposed modification (NSM-52966) that, if

implemented, would enable them to generate both KHUs

simultaneously to the grid. At this meeting, members of NRC's

Electrical Engineering Licensing Branch (EELB) expressed concern

over the licensee's 75 MW operating limit in that it appeared to

be non-conservative when compared to the 1971 startup test data.

At the meeting, EELB representatives requested additional

information on benchmarking of the computer model and instrument

uncertainties used in the calculations that established the 75 MW

limit. The EELB representatives agreed to visit Oconee to review

the requested information.

On January 26, 1995, EELB representatives visited the Oconee site

to review the relevant calculations associated with NSM-52966.

The EELB representatives noted that calculation KC-UNIT-1-2-0106,

"Keowee Power Operating Restrictions for NSM-52966" was non

conservative in that it did not properly account for potential

instrument inaccuracies associated with previous test data used in

this calculation. The EELB representatives requested that the

licensee review the other QA-1 calculation associated with

overspeed (OSC-6003) to see if it was also non-conservative. The

licensee subsequently determined that OSC-6003, Revision 1, was

non-conservative in that it did not take into account instrument

accuracy uncertainties for those instruments used to collect test

data, and a non-conservative instrument accuracy was used for the

KHU watt meter. On January 27, 1995, the licensee suspended KHU

Enclosure 2

III9

generation to the grid until the load limit calculation could be

revised. On January 27, 1995, OSC-6003 was revised (Revision 2)

to establish a new load limit of 56 MW. On March 12, 1995, the

licensee determined that the KHUs had been past inoperable for 31

hours and 3 minutes since the 75 MW load limits were imposed in

May 1993. The inspectors were concerned that there were errors in

QA-1 calculations and that these calculations were independently

reviewed and approved without identifying these errors. The use

of non-conservative instrument accuracies in OSC-6003, Revision 1,

is identified as Example 1 of Violation 50-269,270,287/95-03-02:

Calculation Errors Associated with Keowee Output Limit.

OSC-6003, was revised (Revision 3) on March 14, 1995, in order to

raise the maximum power output limit for a KHU from 56 MW to 69

MW. The statistical analysis methodology utilized to reduce

instrument accuracy uncertainties was incorrect for this revision.

Utilizing the appropriate statistical methodology should have

resulted in a maximum power limit of 68 MW. This calculation was

independently reviewed and approved without identifying the error.

The non-conservative limit of 69 MW was subsequently incorporated

into OP/0/A/2000/041, "Keowee-Modes Of Operation" on March 14,

1995. The use of an incorrect statistical method is identified as

Example 2 of Violation 50-269,270,287/95-03-02: Calculation

Errors Associated with Keowee Outp-ut Limit.

Within the areas reviewed, one violation was identified.

5.

Plant Support (71750 and 40500)

a.

Provide Support For Spent Fuel Shipment 3/6 ISFSI, WO 95018043

Task 01

The inspector reviewed the licensee's efforts during the

transportation and storage of a canister containing 24 spent fuel

assemblies on March 17, 1995. The canister had been installed in

a cask for transporting from the Unit 1-2 spent fuel pool to the

onsite Independent Spent Fuel Storage Installation (ISFSI).

Maintenance Procedure MP/0/A/1500/007, Independent Spent Fuel

Storage Installation, was utilized and complied with during the

shipping and storage activity.

Thirty-two canisters have been stored in the dry storage facility

which has capacity to store a total of 40 canisters. However, the

licensee informed the inspector of their plans to construct 20

additional ISFSI modules during 1995.

The activity was conducted in accordance with the procedure and

was well planned and coordinated.

Enclosure 2

b.

Self-Assessment

During the inspection period, the inspectors attended several of

the Nuclear Safety Review Board (NSRB) meetings conducted on-site

March 22 and 23, 1995. The NSRB reviewed a wide range of issues

and questioned the station staff closely regarding each.

The

meeting was well organized and placed appropriate emphasis on

issues and programs important to safety. Board members

aggressively pursued answers to their questions and resolution of

their concerns.

6.

Inspection of Open Items (92901, 92902 and 92904)

The following open items were reviewed using licensee reports,

inspection records, and discussions with licensee personnel, as

appropriate:

a.

(Closed) Unresolved Item (URI) 50-269,270,287/90-30-01:

Clarification of Technical Specification 3.3.1

This item addressed high pressure injection (HPI) operability

requirements below 60 percent full power operation. TS 3.3.1

requires only two HPI pumps be operable below 60 percent power and

that three HPI pumps be operable above 60 percent power. In

November 1990, the licensee identified that below 60 percent power

an injection line nozzle break could result in insufficient flow

to the reactor core assuming a single failure if only two HPI

pumps were operable. The licensee reported this condition per LER 269/90-15 and established administrative controls to require that

three HPI pumps be operable prior to exceeding 350 degrees F to

ensure adequate core cooling flow could be obtained assuming a

single failure. This item was reviewed for enforcement action in

Inspection Report 50-269,270,287/90-34 and a non-cited violation

was issued. This URI remained open pending completion of a TS

change to clarify the high pressure injection system operability

requirements. The licensee had not completed the TS change

submittal to revise TS 3.3.1 as of the end of this inspection

period. Since the enforcement aspects of this URI have been

reviewed previously and a Non-cited Violation was issued, this URI

is closed. The review/submittal of the revision to TS 3.3.1 is

identified as Inspector Followup Item 50-269,270,287/95-03-01:

Clarification of TS 3.3.1.

b.

(Closed) Violation 50-269/93-03-01, Failure to Follow Refueling

Procedure

This violation involved two separate instances of mispositioned

fuel assemblies during the December 1992 refueling outage core

off-load and reload. The licensee determined that both instances

were caused by human error on the part of the refueling bridge

Enclosure 2

11

trolley operators. The operators failed to perform an adequate

self check when positioning the bridge trolley.

The immediate corrective action was to properly place the

mispositioned fuel assemblies. In addition, refueling procedures

(OP/1,2,3,/A 1502/07) were revised to require independent

verification of bridge trolley position by an individual other

than the operator.

After completing the procedure change, the refueling outages for

Units 2 and 3 were completed with no mispositioning events.

However, In May of 1994, during the Unit 1 refueling outage, two

more instances of mispositioning fuel assemblies occurred. This

latest event resulted in Violation 50-269,270,287/94-16-01 and the

imposition of a civil penalty due to the ineffectiveness of

previous corrective actions. As followup on this matter will be

pursued under this latest violation, Violation 50-269/93-03-01 is

considered closed.

c.

(Closed) Violation 50-269,287/93-03-02, Failure to Follow

Procedures, Two Examples

The two examples of this Violation, associated corrective actions,

and inspector reviews are described in the closure statements of

the applicable Licensee Event Reports (LER) in Paragraph 7 below.

Example 1 involved the operators mistakenly leaving the Emergency

Feedwater (EFW) control valves in the manual position (LER 287/93

01).

Example 2 involved the inadvertent actuation of an

Engineered Safety Feature (ESF) actuation signal during a cooldown

and depressurization of the Unit 1 reactor coolant system (LER 269/93-02). Accordingly, Violation 50-269,287/93-03-02 is closed.

7.

Review of Licensee Event Reports (92700)

The below listed LERs were reviewed to determine if the information

provided met NRC requirements. The determination included: adequacy of

description, compliance with TS 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 were closed:

a.

(Closed) LER 269/92-16:

Postulated Single Failure That Would

Result in the Loss Of Emergency Power System as Result of a Design

Deficiency

On October 12, 1992, during the performance of a single failure

analysis for the Keowee Emergency Power System, the licensee

determined that the potential existed for a single fault to cause

a loss of both Oconee emergency power paths (overhead and

Enclosure 2

12

underground). This vulnerability existed since plant construction

and was the result of a design oversight.

A network of current transformers, differential relays and lockout

relays are employed to monitor and isolate faults on the Keowee

electrical distribution busses.

Faults are detected by comparing

the electrical current balance for various zones within the

electrical distribution system. The licensee's design employs

overlapping of various protective zones to ensure protection of

the entire power system. There are protective zone overlaps

located at the Keowee overhead air circuit breakers (ACBs). The

licensee determined that a fault occurring within the overlap

region of the overhead path breaker (ACB-1 or 2) associated with

the Keowee unit aligned to the underground path, could disable

both the overhead and underground paths. Due to this particular

zone protection overlap, both the generator (87G) and the

transformer (87T) zone protection relays would detect the

postulated fault. The 87T relay would lock out the overhead power

path by opening both KHUs' overhead breakers. The 87G relay would

open (and lock out) both the underground path breaker and the

overhead breaker (also opened by the 87T) for the KHU aligned to

the underground path. This would leave only the underground path

for the Keowee unit originally aligned to the overhead path, which

would require manually closing in the underground path breaker

associated with that unit. No credit is given in the

design/licensing basis for manual manipulations in the LOCA/LOOP

accident.

To preclude this single failure vulnerability, the licensee

established administrative requirements to open the disconnects

for the overhead breaker associated with the unit aligned to the

underground path. The inspectors verified that this configuration

removes the single failure vulnerability in question by removing

the zone overlap region for the unit aligned to the underground

path. Additionally, the inspectors verified that removing this

particular overlap region does not impact the ability of the

protective relaying to protect the remaining zone areas. This

configuration is acceptable for nuclear safety, but prevents the

licensee from generating both KHUs to the commercial grid at the

same time. Since Keowee is routinely used during peak demand

periods, the licensee has proposed a modification to the Keowee

breaker protective relaying circuitry that would eliminate the

single failure vulnerability and allow simultaneous generation of

both KHUs to the grid. This proposed modification (NSM-52966) is

currently being reviewed by NRR.

Another corrective action discussed in this LER was the completion

of the single failure analysis for the Keowee electrical

distribution system. The inspectors verified that the single

failure analysis was completed. The inspectors did not evaluate

Enclosure 2

II

13

the adequacy of this analysis other than the specific concerns

addressed by this LER.

b.

(Closed) LER 269/93-02, Operator Inattention to Detail Results in

an Unplanned Protective System Actuation During Unit Shutdown

On January 29, 1993, Unit 1 operators were performing procedure

OP/1/A/1102/10, Controlling Procedure for Unit Shutdown, to cool

down and depressurize Unit 1's Reactor Coolant System (RCS) to

repair a leaking core flood tank isolation valve. The reactor was

shut down with Group 1 rods at 50 percent withdrawn in accordance

with the procedure. Shortly after he began RCS depressurization

via manual operation of pressurizer spray, the operator's

attention was diverted by a control rod drive (CRD) position

indication problem. RCS pressure decreased below the 1810 psig

Low RCS Pressure Trip setpoint, and a trip signal was generated.

After responding to the unexpected trip, operators continued the

cooldown and depressurization in accordance with the procedure.

As part of the corrective actions, the operator and the Control

Room Supervisor prepared and presented a "Lessons Learned"

briefing to all 5 operating crews. Additionally, the operating

procedure was revised to require inserting the Group 1 control

rods at 1900 psig in the shutdown sequence. The previous revision

had required the operator to stop the depressurization prior to

reaching the trip setpoint, and insert the rods prior to

proceeding. This incident was cited as Example 2 of Violation

50-269,287/93-03-02, Failure to Follow Procedures. The inspector

reviewed the revised procedure and verified that training records

reflected that the shift briefings had been conducted.

c.

(Closed) LER 269/93-03, Design Deficiency Results in the Technical

Inoperability of the Alternate Reactor Coolant Makeup System

On February 18, 1993, the licensee determined that the Secondary

Shutdown Facility (SSF) Reactor Coolant Makeup Pump (RCMU) for

Unit 1 was inoperable due to excessive nitrogen preload pressure

in the suction stabilizer accumulator's bladder. This condition

could have prevented the bladder and the pump from operating

correctly during a postulated Engineered Safety Feature (ESF)

actuation.

The root cause of this event was determined to be an oversight in

the bladder design calculation. The design calculation had

neglected to include the temperature effect on the bladder

pressure when the RCMU pump is aligned to take suction on the

Spent Fuel Pool during certain accident scenarios.

Corrective actions included venting the excess pressure from the

bladder and completing the scheduled Design Basis Documentation

Enclosure 2

II

14

(DBD) study for the SSF and the RCMU system. The inspector

verified that the bladder had been vented to the new setpoint on

February 21, 1993, and that the DBD was completed and issued in

November 1994. This item is closed.

d.

(Closed) LER 287/93-01, Reactor Trip on Lost Signal Due to

Technician Inattention to Detail, Followed by Operator

Misalignment of Automatic Emergency Feedwater Paths

On January 26, 1993, Unit 3 tripped from 100 percent power when a

technician's error during troubleshooting created a false low

turbine generator output (Megawatt) signal.

The false signal

caused the Integrated Control System (ICS) to open the turbine

control valves wide open, increase reactor power, and increase

feedwater demand in an attempt to recover the "lost" generator

megawatts. The ensuing transient resulted in reducing main steam

pressure and a resultant decrease in the steam driven main

feedwater pumps' output pressure. The Accident Mitigation System

Actuation Circuitry (AMSAC) started the Emergency Feedwater (EFW)

pumps and tripped the main turbine generator, which tripped the

reactor. The unit trip response was normal.

Following the trip, control room operators took manual control of

the EFW control valves to prevent overcooling the RCS, but

neglected to replace the control valve selector switch back in

auto as required by procedure. Leaving the selector switch in

manual would have prevented automatic response of the EFW system

if called upon. This failure of the operators to follow

procedures was identified as Example 1 of NRC Violation

50-269,287/93-03-02, Failure to Follow Procedures.

The technicians had been using a multimeter on a power factor

meter transformer in Unit 3. During this troubleshooting effort

the technicians had inadvertently selected the multimeter's

function to read current instead of voltage. This caused the

Transformer's "X" and "Y" phase fuses to blow and indicate a loss

of Generator Megawatt output to the ICS.

Corrective actions included inserting blank plugs in the current

measuring jacks of all controlled multimeters. The inspector

verified that the tool issue room had installed the blank plugs.

This issue is closed.

8.

Exit Interview

The inspection scope and findings were summarized on March 29, 1995,

with those persons indicated in paragraph 1 above. The inspectors

described the areas inspected and discussed in detail the inspection

findings in the Summary and listed below. The licensee did not identify

Enclosure 2

15

as proprietary any of the material provided to or reviewed by the

inspectors during this inspection.

Item Number

Status

Description/Reference Paragraph

Inspector Followup

Open

Clarification of Technical

Item 269,270,287/

Specification 3.3.1. (paragraph

95-03-01

6.a.)

Violation 269,270,287/

Open

Calculation Errors Associated

95-03-02

With Keowee Output Limit, Two

Examples (paragraph 4.b.)

Unresolved Item 270/

Open

Valve Configuration (paragraph 2.d.)

95-03-03

Unresolved Item 269,

Closed

Clarification Of Technical

270,287/90-30-01

Specification 3.3.1. (paragraph

6.a.)

Violation 269/93-03-01

Closed

Failure to Follow Refueling

Procedure (paragraph 6.b.)

Violation, 269,287/

Closed

FaiTure to Follow Procedures, Two

93-03-02

Examples (paragraph 6.c.)

LER 269/92-16

Closed

Postulated Single Failure That Would

Result in the Loss Of Emergency

Power System as Result of a Design

Deficiency (paragraph 7.a.)

LER 269/93-02

Closed

Operator Inattention to Detail

Results in an Unplanned Protective

System Actuation During Unit

Shutdown (paragraph 7.b.)

LER 269/93-03

Closed

Design Deficiency Results in the

Technical Inoperability of the

Alternate Reactor Coolant Makeup

System (paragraph 7.c.)

LER 287/93-01

Closed

Reactor Trip on Lost Signal Due to

Technician Inattention to Detail,

Followed by Operator Misalignment of

Automatic Emergency Feedwater Paths

(paragraph 7.d.)

Inspector Followup

Open

Control Battery Capacities

Item 270/95-01-01

(paragraph 4.a)

Enclosure 2