IR 05000269/2019002

NRC Inspection Report 05000269/2019002, 05000270/2019002, and 05000287/2019002

ML19226A082
Person / Time
Site:	Oconee
Issue date:	08/14/2019
From:	Frank Ehrhardt Division Reactor Projects II
To:	Burchfield J Duke Energy Carolinas
Reeder D
References
IR 2019002
Download: ML19226A082 (27)

Text

August 14, 2019

SUBJECT:

OCONEE NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000269/2019002, 05000270/2019002, AND 05000287/2019002

Dear Mr. Burchfield:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On July 25, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. These findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Oconee.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Oconee. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Frank J. Ehrhardt, Chief Reactor Projects Branch 1 Division of Reactor Projects

Docket Nos. 05000269, 05000270, and 05000287 License Nos. DPR-38, DPR-47, and DPR-55

Enclosure:

Inspection Report 05000269/2019002, 05000270/2019002, and 05000287/2019002

cc w/ encl: Distribution via LISTSERV

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Oconee Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Failure to Verify Adequacy of Design of LPSW System for Auxiliary Building Flooding Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000269,05000270,05000287/2019002-01 Open/Closed Not Present Performance (NPP)71111.06 Inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to verify the adequacy of design of the low pressure service water (LPSW) system. Specifically, design review calculation OSC-8671, Auxiliary Building Flood Design Values, failed to ensure safety-related equipment would not be adversely impacted by failure of non-seismic LPSW piping in the auxiliary building.

Failure to Monitor or Demonstrate Control of Performance Under the Maintenance Rule Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000269,05000270,05000287/2019002-02 Open/Closed

[H.1] -

Resources 71111.12 The inspectors identified a Green NCV of 10 CFR 50.65(a)(2) when the licensee failed to monitor the performance or demonstrate effective control of performance of the standby shutdown facility (SSF).

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000287/2018-002-00 Actuation of the Keowee Hydroelectric Station Due to Loss of AC Power to the Unit 3 Main Feeder Buses.

71153 Closed LER 05000287/2018-002-01 Actuation of the Keowee Hydroelectric Station Due to Loss of AC Power to the Unit 3 Main Feeder Buses.

71153 Closed

PLANT STATUS

Unit 1 operated at or near 100 percent rated thermal power (RTP) for the entire inspection period.

Unit 2 operated at or near 100 percent RTP for the entire inspection period.

Unit 3 operated at or near 100 percent RTP for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Summer Readiness (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems.

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Protected service water (PSW) system on May 7, 2019, during annual SSF system outage

(2) Keowee Hydro Station alignment on May 7, 2019, during annual SSF system outage

(3) 230kV switchyard yellow bus and degraded voltage protection circuitry restoration on May 16, 2019, following extended system outage, maintenance and modification

(4) Emergency AC power sources (Keowee Hydro Unit 1, SSF, CT-5, and PSW) on June 12, 2019, while Keowee Hydro Unit 2 was out of service

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 Auxiliary Building Elevation 809', Fire Zone 109 on May 11, 2019

(2) Unit 2 Auxiliary Building Elevation 809', Fire Zone 104 on May 11, 2019

(3) Unit 2 Auxiliary Building Elevation 822', Fire Zone 111 on May 24, 2019

(4) Unit 3 Auxiliary Building Elevation 796', Fire Zone 89, 86, and 87 on May 24, 2019

(5) Unit 3 Auxiliary Building Elevation 809', Fire Zone 100, 98, and 99 on May 24, 2019

71111.06 - Flood Protection Measures

Internal Flooding (IP Section 02.02a) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1, 2, and 3 auxiliary building basement high pressure injection (HPI) and low pressure injection (LPI) hatch areas

71111.07A - Heat Sink Performance

Annual Review (IP Section 02.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 3A recirculated cooling water heat exchanger

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) Main control room observation during a downpower to 98 percent reactor power to conduct PT/3/A/0290/003, Turbine Valve Movement, on May 31, 2019

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training on May 22, 2019.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Nuclear Condition Report (NCR) 2241697, Failure of 1HP-4 to operate from SSF control room

(2) NCR 2253656, Cartridge missing from auxiliary building flood flow limiting valve 3LPSW-845

Quality Control (IP Section 02.02) (2 Samples)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) SSF Outage Work Orders (WOs) including: WO 20142395 - 0CCW-277 Manual Override Screw Needs Replacement; WO 20326318 - Replace AHU 0-42 Compressor #1 Timer; WO 20260071 - PM Rebuild SSF Diesel Engine Service Water Pump; WO 20230354 - PM Switchgear OTS1

(2) WO 20225494-02, Unit 1A HPI Flow Transmitter 7A replacement on May 28, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) 1CCW-13 mechanical/electrical preventative maintenance resulting in station yellow risk condition on April 9, 2019

(2) Oconee Nuclear Site elevated yellow risk during planned maintenance outage on the SSF on May 7, 2019

(3) Emergent work on the yellow bus due to degraded CCVTs on May 17, 2019

(4) Risk assessment and work controls for transport of 2SF-2 across Unit 1/2 spent fuel pool on May 30, 2019

(5) Unit 2 low pressure turbine rotor lifts resulting in Yellow Station Risk on June 28, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) NCR 2271172, Both SSF HVAC compressors out of service

(2) NCR 2266198, AP/1-2/A/1700/036 entry due to temporary chiller degradation

(3) NCR 2271174, 3A Core Flood Tank vent valve will not fully close

(4) NCR 2272266, SSF sump pump 1 discharge check valve CCW-312 found stuck open during operator rounds

(5) Operability of KHU 1 & 2 during NERC MVAR testing

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Evaluation Engineering Change (EC) 412504 supporting replacement and rigging of 2SF-2 for transport across spent fuel pool

71111.19 - Post-Maintenance Testing

Post Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) WO 20260071-05, SSF Diesel Engine Service Water Pump test following replacement on May 7, 2019

(2) WO 20324170, Standby Shutdown Facility Diesel-Generator operational test after SSF outage on May 9, 2019

(3) WO 20225494-03, Testing of replacement Unit 1A HPI Flow Transmitter 7A on May 28, 2019

(4) WO 20309525-01, 3A Essential Siphon Vacuum (ESV) train test following adjustments of pump starter relay

(5) WO 20295098, testing of 1RC-165 following repairs

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Inservice Testing (IP Section 03.01)

(1) PT/1/A/0600/013, Motor Driven Emergency Feedwater Pump Test on the 1B MDEFW pump on April 3, 2019

(2) PT/1/A/0251/001, Low Pressure Service Water Pump Test on the B LPSW pump on April 4, 2019

(3) WO 20319437-03, PT/2/A/0261/10, Essential Siphon Vacuum System Test, on June 13, 2019

Routine (IP Section 03.01) (2 Samples)

(1) OP/0/A/1600/010, Operation of the SSF diesel-generator, on April 23, 2019

(2) IP/2/A/0315/014 A, TXS RPS Interposing Relay Test and Control Rod Drive Breaker Trip Timing Test on Unit 2, on May 8, 2019

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Inspectors observed an emergency preparedness drill on May 15, 2019, that involved a loss of core monitoring instrumentation, a feedwater pump trip transient, elevated reactor coolant pump vibrations and fuel damage, a secondary-side steam leak, loss of all offsite and emergency AC power capability, and failure to power SSF equipment and PSW unavailable.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI02: RCS Leak Rate Sample (IP Section 02.11)===

(1) Unit 1 (April 1, 2018 - March 31, 2019)

(2) Unit 2 (April 1, 2018 - March 31, 2019)

(3) Unit 3 (April 1, 2018 - March 31, 2019)

MS07: High Pressure Injection Systems (IP Section 02.06) (3 Samples)

(1) Unit 1 (April 1, 2018 - March 31, 2019)

(2) Unit 2 (April 1, 2018 - March 31, 2019)

(3) Unit 3 (April 1, 2018 - March 31, 2019)

MS10: Cooling Water Support Systems (IP Section 02.09) (3 Samples)

(1) Unit 1 (April 1, 2018 - March 31, 2019)

(2) Unit 2 (April 1, 2018 - March 31, 2019)

(3) Unit 3 (April 1, 2018 - March 31, 2019)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in human and equipment performance that might be indicative of a more significant safety issue.

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) LER 05000287/2018-002-00, Actuation of the Keowee Hydroelectric Station Due to Loss of AC Power to the Unit 3 Main Feeder Buses

(2) LER 05000287/2018-002-01, Actuation of the Keowee Hydroelectric Station Due to Loss of AC Power to the Unit 3 Main Feeder Buses

INSPECTION RESULTS

Observation: Semi-Annual Trend Review 71152 Inspectors identified a negative trend in human and equipment performance associated with inspection and maintaining readiness of emergency response equipment such as fire extinguishers, fire hose reels, fire brigade turnout gear, and emergency lighting stored in emergency equipment lockers. Nuclear Condition Reports 2273853, 2273814, 2271810, 2267309, 2260693, 2255541, 2253667, 2252769, and 2193141 were referenced. Because these various issues were identified by personnel from outside organizations and departments or were discovered by the fire brigade once the equipment was attempted to be used during a drill, the issues indicated there was a weakness in the routine inspection and maintenance of the equipment. One other notable trend was identified by the licensee in NCR 2276467 regarding subtle indicators that operator procedure use and adherence may be declining from station goals and standards. The licensee is developing an action plan to improve performance in this area.

Failure to Verify Adequacy of Design of LPSW System for Auxiliary Building Flooding Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000269,05000270,05000287/2019002-01 Open/Closed

NPP 71111.06 Inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to verify the adequacy of design of the LPSW system. Specifically, design review calculation OSC-8671, Auxiliary Building Flood Design Values, failed to ensure safety-related equipment would not be adversely impacted by failure of non-seismic LPSW piping in the auxiliary building.

Description:

Updated Final Safety Analysis Report Chapter 3.4.1.1.1, Current Flood Protection Measures for Turbine and Auxiliary Buildings stated that the auxiliary building could be subject to flooding from a single break in the non-seismic portions of the LPSW system and that these portions are isolated, or flow limited to allow operators sufficient time to identify and isolate the source. The section also stated that operator response times were tested to ensure flood mitigation can occur before safety related equipment is adversely affected. Design review calculation OSC-8671, Revision 7, established acceptance criteria related to auxiliary building flooding by verifying that safety-related equipment was adequately protected from internal flooding based on the ability of the operators to identify and isolate a postulated break in 45 minutes.

On March 7, 2019, inspectors identified several non-conservative evaluations within OSC-8671 for the LPSW system. These evaluations determined flooding rates for certain break locations but did not consistently consider flow from both ends of a failed pipe and the multiple sources that could supply the failure location. When considered, safety-related equipment could be adversely affected before the design basis operator response time of 45 minutes expired. Specifically: 1) The Unit 3 high pressure injection (HPI) pumps were estimated to be affected by flooding after 19 minutes, 2) The Unit 1/2 HPI pumps were estimated to be affected by flooding after 36 minutes, and 3) The Unit 3 A reactor building spray (RBS) pump (in the Unit 3 A low pressure injection (LPI) pump room) was estimated to be affected by flooding after 35 minutes.

Although the design basis was not met for these areas, time-critical operator action validations per periodic test PT/0/A/0120/033, Time Critical Action Verification, showed that operators have executed the LPSW isolation mitigating actions of abnormal procedure AP/1-2/A/1700/030, Auxiliary Building Flood, and AP/3/A/1700/030 in time frames of approximately 33 minutes and 22 minutes, respectively. For the Unit 1/2 HPI pump room and Unit 3 A LPI pump room, the time validations demonstrated that additional margin would likely be available and would allow operators time to identify and isolate additional components that were not specifically identified in the abnormal procedure. However, for the Unit 3 HPI pump room, there was a reasonable doubt on the capability of operators to isolate certain LPSW breaks before equipment would be adversely affected because the time validation results were 3 minutes longer than the time to impact the pumps. The Unit 3 HPI pump room vulnerability was determined to exist only during summer weather conditions that required the plant to operate all four condenser circulating water (CCW) pumps with the second condensate cooler in service.

Corrective Actions: The licensee took compensatory measures to isolate certain lines to improve operator response time margins. Procedure changes were made to identify additional isolation valves and ladders were installed where necessary to access the new components. On Unit 3, administrative controls were implemented to restrict alignment of the second condensate cooler until alternative measures could be developed.

Corrective Action References: NCRs 02261347 and 02266374

Performance Assessment:

Performance Deficiency: The failure to verify the adequacy of design of the LPSW system per 10 CFR Part 50, Appendix B, Criterion III, was a performance deficiency. Specifically, design review calculation OSC-8671 failed to ensure safety-related equipment would not be adversely impacted by failure of non-seismic LPSW piping in the auxiliary building.

Screening: The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, inspectors identified different postulated failure locations that could result in flooding rates that would individually impact either the three Unit 3 HPI pumps, the six Unit 1 & 2 HPI pumps, or the 3A RBS pump under design basis conditions.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. A regional SRA conducted a quantitative risk evaluation using SAPHIRE Version 8.1.8 and Oconee SPAR model Version 8.60. In completing the evaluation, the SRA assumed that operators would not be able to isolate auxiliary building flooding from breaks of non-seismic LPSW piping in Unit 3 before affecting safety-related equipment, were it to occur under certain seasonal conditions, and would have barely adequate time to do so for Units 1 and 2. The SRA also assumed that FLEX equipment was available. The result was a change in core damage frequency of less than 1E-6/year, which was of very low safety significance (Green). The dominant sequence was an auxiliary building flood with operator failure to isolate, various failures of the SSF, and failure to implement FLEX. Remaining mitigation capability would include operator capability to trip the RCPs, isolate the seal bleed off line, and maintain the RCS subcooled.

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, required, in part, that design control measures shall provide for checking the adequacy of design, such as by the performance of design reviews. Contrary to the above, since October 29, 2014, the design review performed for auxiliary building flooding did not verify adequacy of the design because calculation OSC-8671 failed to ensure safety-related equipment would not be adversely impacted by failure of non-seismic LPSW piping in the auxiliary building.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Monitor or Demonstrate Control of Performance Under the Maintenance Rule Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000269,05000270,05000287/2019002-02 Open/Closed

[H.1] -

Resources 71111.12 The inspectors identified a Green NCV of 10 CFR 50.65(a)(2) when the licensee failed to monitor the performance or demonstrate effective control of performance of the standby shutdown facility.

Description:

On November 7, 2018, testing during a refueling outage revealed that the 1B RCS letdown cooler outlet isolation valve, 1HP-4, operated satisfactorily from the main control room, but it could not be operated from the SSF control room because of a relay failure. Engineers performed a maintenance rule evaluation in NCR 2241697 and determined that the inability to close the isolation valve from the SSF was a functional failure. On March 1, 2019, inspectors identified that the functional failure was incorrectly applied to the high pressure injection system rather than the SSF. One of the SSF functions monitored by the maintenance rule program was the ability of RCS boundary valves to isolate and prevent RCS inventory loss. Because of other existing SSF failures within the monitoring period, the additional functional failure caused the performance criteria for the SSF to be exceeded and required an a(1) evaluation to be performed. Subsequently, because four out of five events were maintenance preventable, the Unit 1 SSF function was changed to maintenance rule a(1) status on April 17, 2019. If the failure of 1HP-4 had been correctly classified originally, the SSF would have more promptly entered a(1) status after the fifth failure in December 2018.

Corrective Actions: The licensee entered the error with the failure classification into their correction action program and performed the required evaluations.

Corrective Action References: NCR 2260902

Performance Assessment:

Performance Deficiency: The failure to monitor the performance or demonstrate effective control of performance of the SSF was a violation of 10 CFR 50.65(a)(2) and a performance deficiency.

Screening: The performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency was associated with multiple functional failures that adversely affected the reliability of the safe shutdown facility.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, the finding screened as very low safety significance (Green) because it was a process error and did not represent a degraded condition that involved an actual loss of function of a single train for greater than its TS allowed outage time.

Cross-Cutting Aspect: H.1 - The inspectors determined that the performance deficiency had a cross cutting aspect of resources in the human performance area because the apparent cause of the performance deficiency was that leaders did not ensure that resources, such as the maintenance rule manager database and design basis documents, contained accurate information for determining which maintenance rule functions were attributable to components that affected multiple systems. This led to a failure being applied to an incorrect function. This vulnerability was originally identified during a May 25, 2016, Maintenance Rule Expert Panel meeting. However, the associated assignment in NCR 2022432 was closed without action based on an assumption that system engineers would be able to determine the correct function. In this case, the presence of inaccurate information created doubt amongst the involved engineers and manager and led to an incorrect determination.

Enforcement:

Violation: 10 CFR Part 50.65(a)(1), requires, in part, that holders of an operating license shall monitor the performance or condition of structures, systems, or components (SSCs) within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.

10 CFR 50.65(a)(2) states, in part, that monitoring specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.

Contrary to the above, from December 2018 through March 2019, the licensee failed to demonstrate that the performance of the SSF had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor against licensee-established goals. Specifically, the license did not identify and account for a maintenance preventable functional failure of the SSF system. This resulted in the licensee failing to account for four total maintenance preventable functional failures of the SSF occurring from January 2018 to December 2018. The failures demonstrated that the performance of the SSF was not being effectively controlled through the performance of appropriate preventive maintenance and, as a result, that goal setting and monitoring was required.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 25, 2019, the inspectors presented the integrated inspection results to J. Ed Burchfield, Jr. and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

NCR 2215114,

216927,

26849,

230316,

230662,

231905,

257173, 2272078

Miscellaneous

Nuclear Switchyard Reliability Working Group Action

Register, Open Items for Oconee Nuclear Station, as of

June 2019

Procedures

System Health Report for Switchyard Power Systems

Q1-2019

AP/1/A/1700/034

Degraded Grid

CSD-EG-ALL-

2000.0

Nuclear Switchyard Operating Guidelines

CSD-EG-ALL-

2000.1

Nuclear Switchyard Interface Agreement

OP/0/A/1106/040

Generator Voltage Schedule

71111.04

Drawings

K-0700

One Line Diagram - Relays & Meters - 13.8 - 230KV

O-6700

One-Line Diagram - Main PSW Switchgear - 13.8/4.16KV

System

O-702-A

One Line Diagram - 6900V & 4160V Auxiliary Sys.

O-702-A-002

One Line Diagram 6900V & 4160V Station Auxiliary System 21

O-702-B

One Line Diagram - 4160 and 600V Essential Load

Centers - Auxiliary Power Systems - Standby Shutdown

Facility

Engineering

Changes

405339

Miscellaneous

Unit 1 and 2

operator narrative

logs, nightshift

dated May 16,

2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

AD-OP-ALL-0201

Protected Equipment

AD-WC-ALL-0410

Work Activity Integrated Risk Management (Critical Activity

Plan)

OMP 5-05

100 KV Backup / Emergency Power System

OP/0/A/1106/019

Keowee Hydro at Oconee

106

OP/0/A/1107/016

E

Removal and Restoration of 230kV Switchyard Buses

OP/0/A/1650/001

PSW System

OP/0/A/1650/002

PSW Ventilation

OP/0/A/1650/005

PSW AC Power

OP/0/A/1650/006

PSW DC Power

PT/0/A/0620/009

Keowee Hydro Operation

Work Orders

239003,

239004

71111.05Q

Calculations

OSC-9588

Oconee Fire Hazard Ignition Source Tabulation

Miscellaneous

AD-EG-ALL-1520

Transient Combustible Control

AD-EG-ALL-1523

Duties of a Fire Watch

AD-EG-ALL-1523

Temporary Ignition Source Control

CSD-ONS-PFP-

1AB-0809

Unit 1 Auxiliary Building Elevation 809'

CSD-ONS-PFP-

2AB-0809

Unit 2 Auxiliary Building Elevation 809'

CSD-ONS-PFP-

2AB-0822

Unit 2 Auxiliary Building Elevation 822'

CSD-ONS-PFP-

3AB-0796

Unit 3 Auxiliary Building & Reactor Building Elevation 796'

CSD-ONS-PFP-

3AB-0809

Unit 3 Auxiliary Building Elevation 809'

O-0-SOG-9000-

010

(Standard Operating Guideline) Equipment Locations

O-0-SOG-9000-

016

(Standard Operating Guideline) Fires Located Within a

Contaminated RCA/RCZ

OSS-0254.00-00-

4008

Design Specification for Fire Protection

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Procedures

MP/0/A/1705/019

Fire Protection-SLC - Related Fire Doors-HELB Doors -

Annual and Bi-Monthly Inspections

MP/0/A/1705/032

Fire Hose Stations - Common Areas - SLC Related -

Inspections

MP/0/A/1705/032

A

Fire Extinguishers - Auxiliary Building - Monthly Inspection

71111.06

Calculations

OSC-10790

Oconee Nuclear Station Internal Flooding Analysis

OSC-7719

Study of Consequences of Pipe Break Scenarios of HPSW

& LPSW Piping located inside the ONS Aux Building

OSC-8671

Auxiliary Building Flood Design Values

Corrective Action

Documents

NCR 02266374, 02261347, 2264236

Drawings

O-2510B

Piping Layout Miscellaneous Piping Turbine Room

Mezzanine Plan

O-2510J

Piping Layout Miscellaneous Piping EL. 796'-6" Auxiliary

Building Plan & Sections

O-2510L

Piping Layout Miscellaneous Piping EL. 809'+3" Auxiliary

Building Plan

O-2510N

Piping Layout Miscellaneous Piping EL. 822'-0" Auxiliary

Building Plan & Sections

OFD-107C-3.1

Flow Diagram of Liquid Waste Disposal System (Low

Activity Waste Tank Portion)

OFD-124A-1.2

Flow Diagram of Low Pressure Service Water System

Turbine Building

OFD-124B-3.6

Flow Diagram of Low Pressure Service Water System

(LPSW) Auxiliary Building Air Handling Units

OFD-125B-1.6

Flow Diagram of Low Pressure Service Water System

Turbine Building

Miscellaneous

Completed PT/0/A/0120/033 dated 22 March 2017

Procedures

AP/1-2/A/1700/030

Auxiliary Building Flood

AP/3/A/1700/030

Auxiliary Building Flood

PT/0/A/0120/033

Time Critical Action Verification

71111.07A

Procedures

MP/0/A/1100/006

Heat Exchanger-Flat Plate-Disassembly, Cleaning, Repair

and Reassembly

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

TE-MN-ALL-0002

Foreign Material Exclusion Level and Controls Screening

Work Orders

20187590

71111.11Q

Miscellaneous

OFD-122A-3.1

Flow Diagram of Main Steam System (Main Steam

Headers 3A and 3B)

OFD-122B-3.1

Flow Diagram of HP and LP Turbine Exhaust & Steam Seal

System (HP Turbine Inlet, Steam Seal Header & Feedwater

Pump Turbine Steam Seals)

OFD-122B-3.2

Flow Diagram of HP & LP Turbine Exhaust & Steam Seal

System (HP Turbine Extraction & Moisture Separator

Reheaters)

OP-OC-SAE-R274

Simulator Exercise Guide (SAE-R274)

00a

Procedures

AD-TQ-ALL-0420

Conduct of Simulator Training and Evaluation

OP/3/A/1102/004

Operation at Power

133

PT/3/A/0290/003

Turbine Valve Movement

71111.12

Corrective Action

Documents

22432, 260902,

241697, 174814,

2192815, 245792,

249515, 198027,

253656, 893113,

2093988,

2172442,

237927,

274665

Drawings

0-422X-3

Instrument Details Emergency HP Injection Flow

Transmitter

OFD-101A-1.3

Flow Diagram of High Pressure Injection System (Charging

Section)

OFD-101A-1.4

Flow Diagram of High Pressure Injection System (Charging

Section)

OM 251. - 0635 -

001

O/L Valcor 2 3-Way Flow Regulator, Duke Item DMV-769,

Version D

Miscellaneous

MRule Manager

Maintenance Rule Program Notebook

Day and Zimmerman Certification of Qualification

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Day and Zimmerman Vision Acuity Record

Day and Zimmerman Continued Satisfactory Performance

Document

Maintenance Rule Expert Panel Meeting Minutes

May 2016

EVAL-2019-ON-

SSF+-00002114

Maintenance Rule a(1) Evaluation

Issue Ticket

2736800

Issue Ticket

49636800

Issue Ticket

61736800

Issue Ticket

75736800

Issue Ticket

81736800

OM-0245-

2415.001

IB/Griswold, Automatic Flow Control Valves

OSS-0254.00-00-

1001

(MECH) High Pressure Injection and Purification &

Deborating Demineralizer Systems

OSS-0254.00-00-

1004

(MECH) Design Basis Specification for Standby Shutdown

Facility Reactor Coolant Makeup System

OSS-0254.00-00-

1009

(Mech) Design Basis Specification for the Standby

Shutdown Facility HVAC System

Procedures

AD-EG-ALL-1210

Maintenance Rule Program

AD-QC-ALL-0108

Nuclear Oversight Vendor QC Acceptance

IP/0/A/0075/008

Rosemount Pressure Transmitter Assembly, Initial

Calibration, and Mounting Instructions

IP/0/A/0101/001

Low Risk Maintenance Configuration Control

IP/0/A/0200/029A

Sealing Cable Entrance Fittings on Class 1E Devices

IP/0/A/2001/003 C

Inspection and Maintenance of Type HK Metal-Clad

Switchgear, Associated Bus, and Disconnects

IP/0/A/2001/003 K

Inspection and Maintenance of 600 Volt K-Line Breakers

IP/0/A/3011/016

Motor Control Center, Distribution Center, and Power

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Panelboard Preventive Maintenance

IP/0/A/5090/001

Tube Fitting and Tubing Installation

IP/1/A/0202/001D

High Pressure Injection System Emergency HP Injection

Flow Instrument Calibration

MP/0/A/1200/108

Valve-Removal and Installation of Flanged Valves or Wafer

Valves to Piping

MP/0/A/1200/168

Valve - Valcor - 3 Way - Disassembly, Repair,

Reassembly, and Adjustment

MP/0/A/1300/035

Pump - Ingersoll-Rand - 4X11 AN Type - SSF - Diesel

Engine Service Water Pump - Removal, Disassembly,

Repair, and Assembly

MP/0/A/3007/019

A

SSF - Air Conditioning Unit - Maintenance

Work Orders

WO 20225494,

2143025,

20123122,

20123261,

20142395,

260071,

20326318,

230354,

273757,

223158,

2018032,

212073

71111.13

Corrective Action

Documents

NCR 02272633

230KV Yellow Bus CCVTs Doble Results

Miscellaneous

Engineered Lift Plan, Install new SF-2 Valve in Unit 1/2

and 3 Spent Fuel Pools

April 4, 2019

Critical Activity

Plan

Unit 2 and Unit 3 SF-2 Replacement

April 16,

2019

Oconee Nuclear

Station UFSAR,

2/31/2016 -

230 kV Switching Station Degraded Grid Protection

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Chapter 8.2.1.3.1

OSS-0254.00-00-

1003

Design Basis Specification (MECH) Condenser Circulating

Water (CCW) System

OSS-0254.00-00-

2004

(Elect) 230kV Switchyard System

SLC 16.8.8

External Grid Trouble Protection System

Technical Specification Bases 3.3.19

Emergency Power Switching Logic (EPSL) 230 kV

Switchyard Degraded Grid Voltage Protection (DGVP)

Procedures

AD-MN-ALL-0009

Nuclear Rigging, Lifting, and Material Handling

AD-MN-ALL-0010

Nuclear Rigging & Lifting Forms

AD-OP-ALL-0201

Protected Equipment

AD-WC-ALL-0240

On-line Risk Management Process

PD-MN-ALL-0009

Nuclear Rigging & Lifting Program

71111.15

Calculations

OSC-11233

Standby Shutdown Facility (SSF) Thermal Environment

Evaluation Using GOTHIC (SSF, HVAC)

Corrective Action

Documents

266198,

271172,

272266,

271172,

271174

Drawings

OFD-102A

3.3, Flow Diagram of Low Pressure Injection System (Core

Flood)

OFD-133A-2.5

Flow Diagram of Condenser Circulating Water System

(SSF Aux. Service)

OM 245.-0675.001

150 LB, C.S. Swing Check Valve

Miscellaneous

Oconee Nuclear Station - Technical Specifications

11/28/2018

Oconee Nuclear Station - Updated Final Safety Analysis

Report, Effective Date of Contents: December 31, 2017

Operator Narrative Logs

May 3 and 4,

2019

Oconee Nuclear Station - Selected Licensee Commitments

11/28/2018

OSS-0254.00-00-

28

(MECH) Design Basis Document for the Low Pressure

Injection and Core Flood System (LPI)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OSS-0254.00-00-

1045

(MECH) Design Basis Spec for Keowee Governor Oil

(OG)System

OSS-0254.00-00-

2005

(ELECT) Keowee Emergency Power Design Basis

Document

Procedures

AD-OP-ALL-0105

Operability Determinations and Functionality Assessments

AD-OP-ALL-1000

Conduct of Operations

AP/1-2/A/1700/036

Degraded Control Room Area Cooling

AP/3/A/1700/036

Degraded Control Room Area Cooling

MP/0/A/1200/078

Valve - Pacific - Swing Check - Disassembly, Repair, and

Reassembly

OP/3/A/1104/001

Core Flooding System

TT/0/A/2200/026

KHS MVAR Capability Verification

Work Orders

20138638,

20141674,

20327748

71111.18

Calculations

OSC-1160

Postulated Cask Drop Accident-Poison Racks

Engineering

Changes

EC 412504

Evaluation of SF-2 Valve Installation Sequence Over Unit 1/2

and 3 Spent Fuel

Miscellaneous

AR 2212375

Evaluation of SF-2 Installation

Procedures

AD-EG-ALL-1132

Preparation and Control of Design Change Engineering

Changes

AD-EG-ALL-1134

Preparation and Control of Evaluation Engineering

Changes

AD-EG-ALL-1137

Engineering Change Product Selection

71111.19

Corrective Action

Documents

269120,

272448,

276624,

277750

Drawings

OFD-101A-1.3

Flow Diagram of High Pressure Injection System (Charging

Section)

OFD-101A-1.4

Flow Diagram of High Pressure Injection System (Charging

Section)

OFD-133A-2.5

Condenser Circulating Water System (SSF Aux. Service)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Miscellaneous

Duke Energy ASME IST Program

27, July

2012

ASME OM Code -

2004

OSS-0254.00-00-

1008

(Mech) Design Basis Specification for the Standby

Shutdown Facility Diesel Support System

Procedures

AD-EG-ALL-1155

Post Modification Testing

AD-EG-ALL-1720

Inservice Testing (IST) Program Implementation

AD-PI-ALL-0100

Corrective Action Program

IP/0/A/0380/006

Standby Shutdown Facility (SSF) Diesel Load and Speed

Control

IP/1/A/0202/001D

High Pressure Injection System Emergency HP Injection

Flow Instrument Calibration

OP/0/A/1104/052

SSW System

OP/3/A/1104/012

CCW System

108

PT/0/A/0400/004

SSF Diesel Engine Service Water Pump Test

PT/0/A/0600/021

Standby Shutdown Facility Diesel-Generator Operation

PT/1/A/0152/017

Reactor Coolant System Valve Stroke Test

PT/3/A/0261/010

Essential Siphon Vacuum System Test

Work Orders

WO 20270234-02,

20324170,

225494,

20309525,

260071,

20301777,

295098

71111.22

Corrective Action

Documents

207594

Drawings

O-800-E

One Line Diagram - AC Elementary Diagram - 3 Line

Connection Diagram - Transformer NO.CT5 & OCB NO.

101

OFD-121A-1.7

Flow Diagram of Condensate System (Upper Surge Tanks

1A & 1B, Upper Surge Tank Dome, & Condensate Storage

Tank)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OFD-121D-1.1

Flow Diagram of Emergency Feedwater System

OFD-124A-1.1

Flow Diagram of Low Pressure Service Water System

Turbine BLDG. (Low Pressure Service Water Pumps)

OFD-124A-1.3

Flow Diagram of Low Pressure Service Water System

(Turbine Bldg. Services)

OFD-129A-1.1

Flow Diagram of Siphon Seal Water System

OFD-129A-2.2

Flow Diagram of Siphon Seal Water System (CCW Pump

Cooling)

OFD-130A-2.1

Flow Diagram of Essential Siphon Vacuum (ESV) System

OFD-133A-1.1

Flow Diagram of Condenser Circulating Water System

(CCW Intake Pumps Discharge)

OFD-121A-1.8

Flow Diagram of Condensate System (Condensate Make-

up & Emergency FDW Pump Suction)

OSFD-133A-1.2

Summary Flow Diagram of Condenser Circulating Water

System

Procedures

IP/0/B/0275/005 H

Emergency Feedwater System Motor Driven Emergency

Feedwater Pump - Non-Safety Related Instrument

Calibration

IP/2/A/0315/014 A

TXS RPS Interposing Relay Test and Control Rod Drive

Breaker Trip Timing Test

OP/0/A/1600/010

Operation of the SSF Diesel-Generator

PT/0/A/0600/021

Standby Shutdown Facility Diesel-Generator Operation

PT/1/A/0251/001

Low Pressure Service Water Pump Test

107

PT/1/A/0600/013

Motor Driven Emergency Feedwater Pump Test

PT/2/A/0261/010

Essential Siphon Vacuum System Test

Work Orders

WO 20319437-03,

20109052,

257191

71114.06

Corrective Action

Documents

273912,

276286, 2185296

Miscellaneous

EPDR-ONS-19-01

Drill Critique Report

OMP 4-02

Verification of Written Correctness for EP/1/A/1800/001 0B

Procedures

EP/1/A/1800/001

0B

EOP Unit 1 Blackout

and 5

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71151

Drawings

0-2702-A

Unit 3 Elementary Diagram AC Circuits Transformer No.

CT3 & 3T

Rev. 22

Miscellaneous

Mitigating Systems Performance Index (MPSI) Basis

Document

MSPI Derivation Report for period ending March 2019,

Units 1, 2, 3 Cooling Water System

MSPI Indicator Margin Report for period ending March

2019, Units 1, 2, 3 High Pressure Injection System &

Cooling Water System

MSPI Derivation Report for period ending March 2019,

Units 1, 2, 3 High Pressure Injection System

MSPI Margin Report for period ending March 2019, Units 1,

2, 3 High Pressure Injection System

Nuclear Energy Institute 99-02, Regulatory Assessment

Performance Indicator Guideline

Unit 1, 2, and 3 PI Summary Document for RCS Leakage

Calculation

Equipment Reliability Suite (ERS)

OSFD-107A-1

Summary Flow Diagram of Coolant Storage System

Quench Tank Portion

6A

WCAP-16423-NP

Pressurized Water Reactor Owners Group Standard

Process and Methods for Calculating RCS Leak Rate for

Pressurized Water Reactors

Procedures

PT/1 2

3/A/0600/010

Reactor Coolant Leakage

71152

Procedures

MP/0/A/1705/032

Fire Hose Stations - Common Areas - SLC Related -

Inspections

MP/0/A/1705/032

A

Fire Extinguishers - Auxiliary Building - Monthly Inspection

MP/0/A/1705/032

F

Fire Extinguisher Carts - Inspection

PT/0/B/0120/032

Field Equipment and Procedures Surveillance

PT/0/B/0250/030

Quarterly Fire Brigade Equipment Inspection

71153

Corrective Action

Documents

NCR 02203967

CT-3 Lockout

05/17/2018

NCR 02205188

Monitoring of the Vital DC ground bus voltages

05/09/2018

NCR 02205189

I/R Positive DC Ground on Vital DC System

05/09/2018

NCR 02205589

Summary of Loss of Power Events for U3

05/11/2018

Drawings

0-0702-A-002

Units 1-3 One Line Diagram 6900V & 4160V Station

Auxiliary System

Rev. 21

0-2700

Unit 3 One Line Diagram Relays & Meters 19KV

Rev. 29

0-2702-A

Unit 3 One Line Diagram 6900V & 4160V Station Auxiliary

System

Rev. 16

0-2705

Unit 3 One Line Diagram 120 VAC & 125 VDC Station

Auxiliary Circuits Instrumentation Vital Buses

Rev. 87

Miscellaneous

Oconee Unit 3 Operator Log

05/10/2018

Work Orders

WO 20252409

CT3, Support Lockout Trip Investigation

05/10/2018

WO 20252422

3B FWPT Terminal Cabinet, Grounded Cable 3TP404

05/10/2018