IR 05000269/2024002

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Integrated Inspection Report 05000269/2024002 and 05000270/2024002 and 05000287/2024002
ML24201A090
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/25/2024
From: Eric Stamm
NRC/RGN-II/DRP/RPB1
To: Snider S
Duke Energy Carolinas
References
IR 2024002
Download: ML24201A090 (27)
v • d • e


Text

SUBJECT:

OCONEE NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000269/2024002 AND 05000270/2024002 AND 05000287/2024002

Dear Steven Snider:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Oconee Nuclear Station. On July 24, 2024, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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 Nuclear Station.July 25, 2024 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000269 and 05000270 and 05000287 License Nos. DPR-38 and DPR-47 and DPR-55

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000269, 05000270 and 05000287

License Numbers: DPR-38, DPR-47 and DPR-55

Report Numbers: 05000269/2024002, 05000270/2024002 and 05000287/2024002

Enterprise Identifier: I-2024-002-0022

Licensee: Duke Energy Carolinas, LLC

Facility: Oconee Nuclear Station

Location: Seneca, South Carolina

Inspection Dates: April 1, 2024, to June 30, 2024

Inspectors: N. Smalley, Senior Resident Inspector E. Robinson, Resident Inspector D. Dang, Resident Inspector, Acting B. Bowker, Reactor Inspector A. Hutto, Senior Project Engineer J. Nadel, Reactor Inspector E. Riggs, Senior Technical Training Program Specialist A. Ruh, Senior Reactor Inspector J. Vasquez, Reactor Inspector

Approved By: Eric J. Stamm, Chief Reactor Projects Branch 1 Division of Reactor Projects

Enclosure

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.

List of Findings and Violations

Failure to Maintain Fire Penetration in Accordance with Fire Protection Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.05 Systems NCV 05000269/2024002-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Oconee Nuclear Station Units 1, 2, and 3, Renewed Facility Operating License Condition 3.D for the licensees failure to maintain in effect all provisions of the approved fire protection program.

Specifically, the licensee failed to ensure that the fire resistive penetration seal assembly in fire penetration 1-M-N-5 was installed to the correct seal thickness per plant design drawings.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000270/2023-001-00 Oconee Nuclear Station Unit 2, 71153 Closed Inappropriate Procedural Guidance for Planned Online Maintenance Results in Event or Condition that Could Have Prevented Fulfillment of a Safety Function

LER 05000287/2023-002-00 Oconee Nuclear Station, Unit 3, 71153 Closed Passive Containment Isolation Device Inoperability Results in Operation or Condition Prohibited by Technical Specifications

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, with the exception of a temporary power reduction to 96 percent RTP on May 1, 2024, as required to implement a measurement uncertainty recapture power uprate from 2568 megawatts to 2608 megawatts core thermal power.

Unit 3 began the inspection period at or near 100 percent RTP. On May 4, 2024, Unit 3 was shut down for a scheduled refueling outage (O3R32). During startup, on May 29, 2024, Unit 3 was limited to 74 percent RTP following unexpected measured high assembly power for assembly location H-05. On June 2, 2024, Unit 3 was shut down for a maintenance outage (O3F32A) to replace two burnable poison rod assemblies (BPRAs) that had incorrect boron concentrations. During O3F32A, indications of a leaking fuel assembly were discovered, independent of the faulty BPRAs. The leaking assembly was isolated and replaced, with no indications of significant fuel damage. The unit was returned to 100 percent RTP on June 20, 2024, and operated at or near 100 percent RTP for the remainder of the 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. 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.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Standby shutdown facility, protected service water and alternate reactor building cooling portable submersible pump equipment on April 15, 19, and 25, 2024
(2) Unit 1 motor driven emergency feedwater (MDEFW) pumps and valves on April 17, 2024
(3) Unit 3 low pressure injection system during O3R32 refueling outage on May 21, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire zone 105: Unit 2 cable room on April 16, 2024
(2) Fire zone 108: Unit 1 east penetration room on April 30, 2024
(3) Fire zone 89: Unit 3 equipment room on May 22, 2024
(4) Fire zone 124: Unit 3 containment on May 24, 2024
(5) Fire zone 112: Unit 3 control room on May 28, 2024
(6) Fire zone 85: Unit 1 auxiliary building 200 level hallway on June 10, 2024

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 1 reactor building cooling units following performance testing per PT/0/A/0160/006, Reactor Building Cooling Units Performance Test, on April 23 and April 24, 2024

===71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 3 during refueling outage O3R32 from May 6 to May 17, 2024.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

Main article: IP 71111.08

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic Examination (UT)
  • 3-GRID-001, UT thickness on containment liner, ASME Class CC

Radiographic Examination

  • 3-LP-0182-10, low pressure injection (LPI) pipe to valve, ASME Class 2 (associated with work order (WO) 20397347)

Dye Penetrant Examination

Magnetic Particle Examination

Visual Examination

Welding Activities

PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) Bare metal visual examination of the reactor pressure vessel upper head, ASME Class 1

PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1)

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) The inspectors observed power ascension for Unit 2 due to the power uprate from the main control room on May 1, 2024.

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

(1) The inspectors observed and evaluated simulator just in time training for power escalation using lesson plan OP-OC-20JT-06 on June 12, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) C low pressure service water pump (LPSW) pump lubricating oil sampling and addition using commercial grade dedicated oil, WO 20645573
(2) Nuclear condition report (NCR) 2473173, Unit 1/2 C LPSW pump tripped after maintenance on May 17, 2023
(3) NCR 2501851, Keowee hydro unit air circuit breaker, ACB-1, failed to open on shutdown on January 22, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Units 1, 2, and 3 green risk due to planned maintenance on the primary instrument air compressor, on April 9, 2024
(2) Units 1 and 2 green risk due to maintenance for the C train of LPSW, on April 18, 2024
(3) Units 1, 2, and 3 green risk due to maintenance for protected service water primary and booster pump, on April 26, 2024
(4) Unit 3 yellow risk due to reactor coolant system draining and lowered inventory operations, on May 5 and May 6, 2024
(5) Units 1, 2, and 3 green risk following issuance of a tornado watch, on May 8, 2024
(6) Unit 3 yellow risk due to reactor coolant system draining and lowered inventory operations, on June 4 and June 5, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) NCR 2511097, 3LPSW-125 and 3LPSW-132 not through bolted
(2) NCR 2511743, KHU-2 exciter warning alarm locked in
(3) NCR 2512430, unexpected bearing cooling water alarms during KHU-2 starts
(4) NCR 2517136, debris discovered in Unit 3 borated water storage tank
(5) NCR 2517412, Unit 3 core high assembly power at H-05 on power escalation following O3R32 refueling outage
(6) NCR 2515786, 3A2 HPI makeup nozzle indications observed during UT examinations

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 modification:

(1) AR 2403542, replacement of axial power shaping rod assemblies for all 3 units

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated refueling outage O3R32 activities from May 4 to May 29, 2024
(2) The inspectors evaluated forced outage O3F32A activities from June 2 to June 20, 2024

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (8 Samples)

(1) PT/1/A/0251/001, "C Low Pressure Service Water Pump Test," following oil sampling and seal regulator maintenance, on April 19, 2024
(2) TT/2/A/0261/021, "CCW Pump Flange Seal Data Collection Test," of 2D condenser circulating water pump, on May 1, 2024, following installation of engineering change

===422106

(3) PT/3/A/0600/012, "Turbine Driven Emergency Feedwater Pump Test," following outage maintenance, on May 22, 2024
(4) PT/3/A/0151/019, "Penetration 19 Leak Rate Test," following preventive maintenance on reactor building purge valves, on May 22, 2024
(5) PT/0/A/0711/001, "Zero Power Physics Test," on May 25, 2024
(6) PT/3/A/0811/001, "Power Imbalance Correlation Test," on Unit 3 following refueling outage, on May 28, 2024
(7) PT/2/A/2200/011, "KHU-2 Turbine Guide Bearing Oil System Retest," following motor contact inspection, on June 8, 2024
(8) PT/1/A/0600/13, "1A MDEFW Pump Test," following maintenance, on June 11, 2024

Surveillance Testing (IP Section 03.01)===

Main article: IP 42210
(1) PT/3/A/0261/010, "Essential Siphon Vacuum System Pump Tests," on Unit 3, on April 11 and April 15, 2024
(2) PT/3/A/0610/001, "J Emergency Power Switching Logic (EPSL) Loadshed Test," on May 17, 2024

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (2 Samples)

(1) PT/3/A/0151/029, "Penetration 29 Leak Rate Test," on Unit 3, on May 15, 2024
(2) PT/3/A/0151/019, "Penetration 19 Leak Rate Test," on Unit 3, on June 12, 2024

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) The inspectors observed and evaluated a simulator drill and exercise performance examination using lesson plan ASE-13 on June 25,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

Main article: IP 71151
(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)
(3) Unit 3 (April 1, 2023, through March 31, 2024)

MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)
(3) Unit 3 (April 1, 2023, through March 31, 2024)

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

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)
(3) Unit 3 (April 1, 2023, through March 31, 2024)

BI02: RCS Leak Rate Sample (IP Section 02.11) (3 Samples)

(1) Unit 1 (April 1, 2023, through March 31, 2024)
(2) Unit 2 (April 1, 2023, through March 31, 2024)
(3) Unit 3 (April 1, 2023, through March 31, 2024)

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) NCR 2516804, Part 21 notification for potential defect of AMETEK oil filled aluminum case capacitors - 07-020139-10

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

Main article: IP 71152
(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material issues and foreign material exclusion controls during refueling outages that might be indicative of a more significant safety issue.

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

Main article: IP 71153

The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.

(1) LER 05000270/2023-001-00, Inappropriate Procedural Guidance for Planned Online Maintenance Results in Event or Condition that Could Have Prevented Fulfillment of a Safety Function (ADAMS Accession No. ML24060A312). The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2023011 (ADAMS Accession No. ML23236A615)under Inspection Results Section 71111.21M. This LER is Closed.
(2) LER 05000287/2023-002-00, Passive Containment Isolation Device Inoperability Results in Operation or Condition Prohibited by Technical Specifications (ADAMS Accession No. ML24060A311). The inspection conclusions associated with this LER are documented in Inspection Report 05000269, 05000270, 05000287/2023004 (ADAMS Accession No. ML24038A367) under Inspection Results Section 71152A.

This LER is Closed.

INSPECTION RESULTS

Failure to Maintain Fire Penetration in Accordance with Fire Protection Program Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.05 Systems NCV 05000269/2024002-01 Open/Closed The inspectors identified a Green finding and associated NCV of Oconee Nuclear Station Units 1, 2, and 3, Renewed Facility Operating License Condition 3.D for the licensees failure to maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to ensure that the fire resistive penetration seal assembly in fire penetration 1-M-N-5 was installed to the correct seal thickness per plant design drawings.

Description:

On March 14, 2024, during a fire protection walkdown of the Unit 1 east penetration room, the inspectors identified a potentially degraded fire barrier penetration, 1-M-N-5, a 5-inch pipe passing through the wall above door 401B between the Unit 1 cable room and the Unit 1 east penetration room. Although the penetration seal was flush with the wall, inspectors noted possible degradation with signs of potential loss of foam insulation in the seal assembly. The inspectors informed the licensee operations staff and the fire protection engineer, who determined that the penetration seal was non-functional. The licensee established an hourly fire watch and documented the condition in the corrective action program as NCR 2508926.

The licensee determined through a destructive examination that the wall containing penetration 1-M-N-5 had a thickness of only eight inches. This was contrary to the dimensional data listed in the equipment database (EDB), the established method of design control for plant equipment. The EDB had listed 1-M-N-5 as a penetration of 12 inches thick.

Additionally, the penetration was installed with foam insulation seal, but the EDB incorrectly listed a grout seal design. Procedure MP/1/A/1705/018, Fire Protection - Penetration - Fire and Flood Barrier - Inspection and Minor Repair, is used for periodic external visual inspection and repair of fire penetrations such as 1-M-N-5. The licensee identified that this procedure had listed the wall containing this penetration as being 12 inches thick as far back as 1998. Around this time, an effort was undertaken by the licensee to re-inspect and repair many fire penetrations as well as implement the EDB as the method of design control. The engineering change (EC) implemented in 1999, established EDB entries and issued drawings for maintenance and inspection of penetration seals. This information was then used to update inspection procedure MP/1/A/1705/018.

The licensee concluded that the most likely cause of the dimensional design discrepancies was an improper interpretation of plant drawings during the establishment of the EDB and implementation of the EC in 1999. The licensee completed inspections of penetration 1-M-N-5 several times since 1999 per MP/1/A/1705/018. The licensee used drawing O-0310-KM-001 to verify correct penetration seal design. Based on the wall thickness of the penetration in question, the licensee would refer to either Detail M-1 or M-2 for a barrier thickness of less than 12 inches or equal to or greater than 12 inches, respectively. Based on the flawed penetration thickness listed as 12 inches in MP/1/A/1705/018, the visual condition of the penetration would have been acceptable per Detail M-2 as 12 inches of seal material would have been present. However, with the current plant configuration of the penetration being only 8 inches in thickness and the penetration seal being flush with the wall surface, the penetration would not have been acceptable in accordance with Detail M-1 of O-0310-KM-001. Specifically, penetration 1-M-N-5 would be required to have a minimum of 12 inches of foam insulation, extending beyond the barrier plane to achieve the required seal depth. The maintenance procedures consist of external visual inspections, which allowed the as-built configuration being different from the procedure stated wall thickness to go unrecognized since 1999.

Corrective Actions: The licensee declared the penetration non-functional and set an hourly fire watch. Additionally, the correct penetration depth and seal design was determined, and the fire penetration seal was repaired and restored to a functional condition (12-inch foam insulation thickness). The equipment database and associated maintenance procedures for inspection and repair were corrected to reflect actual plant conditions.

Corrective Action References: NCRs 2508926, 2509983

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to maintain fire penetration 1-M-N-5 in accordance with drawing O-0310-KM-001, Penetration Seal Configuration Mechanical Fire Penetration Seal Designs Details M-1 & M-2, was a performance deficiency. Specifically, the licensee failed to ensure that penetration 1-M-N-5 was maintained with a minimum of 12 inches of foam insulation per Detail M-1 to ensure that the 3-hour rated fire boundary was functional as required by the fire protection program.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, fire penetration 1-M-N-5 separates two high risk fire zones in the auxiliary building and was declared non-functional, adversely impacting the 3-hour fire boundary. Additionally, this performance deficiency is similar to the more than minor Example 2.d in Inspection Manual Chapter (IMC) 0612 Appendix E, Examples of Minor Issues.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding was assigned to category 1.4.4 Fire Confinement with a High Degradation rating because greater than 10 percent of the required foam seal depth was missing. Using IMC 0609, Appendix F, 1, Step 1.4.4-E, the inspectors determined that if a fire were to spread from one fire area to another due to the degraded fire barrier, no additional targets would be damaged in the exposed fire area that could impact the credited safe shutdown strategy for the exposing fire area. Therefore, the inspectors determined that the finding was of very low safety significance (Green).

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: Oconee Nuclear Station Units 1, 2, and 3, Renewed Facility Operating License Condition 3.D required, in part, Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a)and 10 CFR 50.48(c) and NFPA 805. NFPA 805, Section 3.11.4, requires, in part, that through penetration fire stops shall be protected such that the annular space between the penetrating item and the through opening in the fire barrier shall be filled with a qualified fire resistive penetration seal assembly capable of maintaining the fire resistance of the fire barrier. Oconee implemented this requirement through drawing O-0310-KM-001, Penetration Seal Configuration Mechanical Fire Penetration Seal Designs Details M-1 & M-2, via the licensee's design control equipment database. Fire Penetration 1-M-N-5 is a pipe penetration with a foam seal assembly through an 8-inch fire barrier and is required to be maintained in accordance with Detail M-1 (12-inch foam insulation thickness) of drawing O-0310-KM-001.

Contrary to the above, from at least 1999 until March 15, 2024, the licensee failed to implement and maintain in effect, all provisions of the approved fire protection program as required by drawing O-0310-KM-001. Specifically, the licensee failed to maintain fire penetration 1-M-N-5 in accordance with Detail M-1 of drawing O-0310-KM-001.

Enforcement Action: This violation is being treated as a non-cited violation, 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 May 9, 2024, the inspectors presented the inservice inspection results to Steven Snider and other members of the licensee staff.
  • On July 24, 2024, the inspectors presented the integrated inspection results to Steven Snider and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action 2512968

Documents

Drawings OFD-102A-3.1 Flow Diagram of Low Pressure Injection System (Borated 065

Water Supply and LPI Pump Suction)

OFD-102A-3.2 Flow Diagram of Low Pressure Injection System (LPI Pump 049

Discharge)

OFD-102A-3.3 Flow Diagram of Low Pressure Injection System (Core 025

Flood)

OFD-121D-1.1 Flow Diagram of Emergency Feedwater System 038

Miscellaneous Clearance PRT-3 -24-3A LPI TRAIN-0109

71111.05 Calculations OSC-9293 NFPA 805 Transition Radioactive Release G-1 Table 004

OSC-9314 NFPA 805 Transition Risk-Informed Performance-Based 006

Fire Risk Evaluation

OSC-9659 Oconee Nuclear Safety Capability Assessment for Units 1, 011

2, and 3

Corrective Action 2508926

Documents

Fire Plans CSD-ONS-PFP-Pre-Fire Plan for U1 Auxiliary Building Elevation 783 000

1AB-0783

CSD-ONS-PFP-Pre-Fire Plan for U1 Auxiliary Building Elevation 809 000

1AB-0809

CSD-ONS-PFP-Pre-Fire Plan for U2 Auxiliary Building Elevation 809 000

2AB-0809

CSD-ONS-PFP-Pre-Fire Plan for Unit 3 Auxiliary Building Elevation 796 001

3AB-0796

CSD-ONS-PFP-Pre-Fire Plan for Unit 3 Auxiliary Building Elevation 822 000

3AB-0822

CSD-ONS-PFP-Pre-Fire Plan for U3 Reactor Building All Elevations 000

3RB

Miscellaneous O-0310-FZ-006 Auxiliary Building - Units 1 Fire Protection Plan Fire Area & 003

Fire Zone Boundaries Plan at EL 783 + 9

O-0310-FZ-011 Auxiliary Building - Unit 3 Fire Protection Plan Fire Area & 000

Inspection Type Designation Description or Title Revision or

Procedure Date

Fire Zone Boundaries Plan at EL 796+6 & 797+6

O-0310-FZ-017 Auxiliary & Reactor Building - Unit 3 Fire Protection Plan 003

Fire Area & Fire Zone Boundaries Plan at EL 822+0 & EL

25+0

O-0310-FZ-023 Reactor Building - Units 3 Fire Protection Plan Fire Area & 001

Fire Zone Boundaries Plan at EL 861 + 6

O-0310-K-004 Fire Protection Auxiliary Building Unit 1 EL 783 + 9 009

O-0310-K-009 Fire Protection Auxiliary Building Unit 3 EL 796+6 015

O-0310-K-010 Auxiliary Building Unit 1 Fire Protection Plan & Fire Barrier, 14

Flood & Pressure Boundaries Plan at EL 809+3

O-0310-K-015 Fire Protect Auxiliary Building Unit 3 EL 822+0 017

O-0310-K-018 Auxiliary & Reactor Building Unit 3 Fire Protection Plant & 11

Fire Barrier, Flood, & Pressure Boundaries Plant at EL 838 +

0, EL 844 + 6, Below EL 876 + 0 and Below EL 886 +5

O-0310-K-021 Reactor Building - Unit 3 Fire Protection Plan & Fire Barrier, 3

Flood & Pressure Boundaries Plan at EL 861 + 6

O-0310-KM-001 Penetration Seal Configuration Mechanical Fire Penetration 6

Seal Designs Details M-1 & M-2

Procedures AD-FP-ALL-1520 Transient Combustible Control 001

MP/0/A/1705/027 Fire Protection - Fire Barrier Penetrations - Installation and 047

Repair Using Silicone Foam and Damming Material

MP/1/A/1705/018 Fire Protection - Penetration - Fire and Flood Barrier - 062

Inspection and Minor Repair

Work Orders 20265272

71111.07A Calculations OSC-11956 Reactor Building Cooling Units Performance Test 12

Corrective Action 2510287, 2438405, 2479288, 2507201, 2515539

Documents

Miscellaneous ONEI-0400-400 Revised Reactor Building Cooling Unit (RBCU) 3

Requirements in Support of 1-Year Mission Times

Work Orders 20653985

71111.11Q Miscellaneous EC 105524

Power Escalation JITT, OP-OC-20JT-06

Procedures AD-OP-All-0106 Conduct Of Infrequently Performed Tests Or Evolutions 4

AD-OP-ALL-1000 Conduct of Operations 023

Inspection Type Designation Description or Title Revision or

Procedure Date

AD-OP-ALL-1001 Abnormal Conduct of Operations 006

AD-OP-ONS-Oconee Specific Abnormal Operations Guidance 007

0002

AP/0/A/1700/047 External Flood Mitigation 029

OP/2/A/1102/004 Operation at Power 134

71111.12 Corrective Action 2473173, 2466960, 2501851, 2355727, 2357958, 2365144,

Documents 2446131, 2356835, 2356873, 2503151, 2453446

Drawings KEE-114 Elementary Diagram Generator Control ACB-1 Control 34

Circuit

Engineering 403225

Changes

Miscellaneous Lubrication Datasheet for ON0LPSPU000C 04/18/2024

OSS-0254.00- (ELECT) Keowee Emergency Power Design Basis 035

2005 Document

Procedures AD-EG-ALL-1103 Procurement Engineering Products 7

PT/0/A/0251/029 Siphon Seal Water System Test 30

Work Orders 20262241, 20433314, 20643793, 20447425, 20654745

71111.13 Corrective Action 2490772, 2490763

Documents

Drawings OFD-137B-1.1 Flow Diagram of Instrument Air System (Air Compressors, 28

After Coolers, Receivers, Air Dryers)

Miscellaneous Phoenix ONS Risk Profile for all Units on the week of April

2, 2024

Phoenix ONS Risk Profile for Unit 3 on the week of June 3,

24

OSS-0254.00-00- Design Basis Specification for the Instrument Air System 018

25

Procedures AD-OP-ALL-0106 Conduct of Infrequently Performed Tests or Evolutions 4

AD-WC-ALL-0240 On-line Risk Management Process 4

AD-WC-ALL-0410 Work Activity Integrated Risk Management 14

AD-WC-ALL-0420 Shutdown Risk Management Rev 8

AD-WC-ALL-0420 Shutdown Risk Management 8

AD-WC-ALL-0430 Outage Risk Review 7

Inspection Type Designation Description or Title Revision or

Procedure Date

AD-WC-ONS-ONS Shutdown Risk Management 5

20

AD-WC-ONS-ONS Shutdown Risk Management Rev 5

20

AP/0/A/1700/006 Natural Disaster Rev 35

AP/3/A/1700/022 Loss of Instrument Air 029

MP/0/B/3007/049 Compressors - Primary Instrument Air - Sullair - Model 32-029

25-400 - Preventive Maintenance

OP/0/A/1102/026 Operations IPTE Pre-Job Briefings 033

OP/0/A/1106/027 Instrument Air System 128

PT/0/A/0500/001 Protected Service Water Primary and Booster Pump Test 007

Work Orders 20599978, 20647911

71111.15 Calculations OSC-7220.81 Supporting Design Analyses for ONS 3 EC 424255 000

Evaluation for Acceptability of Existing Indications on the

3A2 HPI Safe End and DMBW

OSC-9033 Risk Significance Evaluation of Sump Outlet Pipe Foreign 0

Material

Corrective Action 2511743, 2503915, PIP-O-05-05720, PIP-O-11-09953,

Documents 2511097, 2487656, 2512045, 2441303, 2483549, 2511097,

2517412, 2517443, 2517450, 2517461, 2517929, 2515886,

2354522, 2517136, 1761227, 2317886, 2517379, 2515786

Drawings KEE-213-2 Elementary Diagram Master Control System Gen. 22

Miscellaneous Relaying

KFD-100A-2.1 Flow Diagram of Turbine Generator Cooling Water System 22

OFD-124A-3.1 Flow Diagram of Low Pressure Service Water System 40

Turbine BLDG. (Low Pressure Service Water Pumps)

Miscellaneous Engineering Change 424255 000

ONEI-0400-592 Oconee 3 Cycle 33 Final Core Load Map 000

ONEI-0400-598 Oconee 3 Cycle 33 Core Operating Limits Report 000

OSS-0254.00-00- (Elect) Keowee Emergency Power Design Basis Document 034

2005

PT/0/A/0811/001 Power Escalation Test 059

Procedures AD-EG-ALL-1110 Design Review Requirements 11

AD-EG-ALL-1708 Development of Relief Requests and Alternatives Pursuant 0

Inspection Type Designation Description or Title Revision or

Procedure Date

to 10 CFR 50.55A

AD-MN-ALL-0002 Foreign Material Exclusion 16

AD-NE-ALL-1107 Evaluation of Indications and Relevant Conditions 4

AD-PI-ALL-0100 Corrective Action Program 30

IP/0/A/2005/006 Maintenance Of Keowee Hydro Station General Electric 021

EX2100 Digital Exciter

OP/0/A/1106/019 Keowee Hydro At Oconee 114

OP/2/A/2000/102 KHU-2 Alarm Response Guide 2SA-2 012

TE-MN-ALL-0002 Foreign Material Exclusion Level and Controls Screening 3

Work Orders 20266554, 20651767, 20255683, 20651767, 20658316,

266313, 20266013, 20661235, 20537999

71111.18 Corrective Action 2403506, 2403542, 2423658

Documents

Miscellaneous OSC -11971 Oconee Replacement Axial Power Shaping Rod Assembly 1

(APSRA) Mechanical Design Evaluation

71111.20 Corrective Action 2515019, 2515022, 2515090, 2515091, 2517306, 2518069,

Documents 2518189, 2518172, 2518685, 2517443, 2517450

Drawings OFD-101A-3.1 Flow Diagram of High Pressure Injection System (Letdown 044

Section)

OFD-101A-3.2 Flow Diagram of High Pressure Injection System (Storage 044

Section)

OFD-102A-3.1 Flow Diagram of Low Pressure Injection System (Borated 065

Water Supply and LPI Pump Suction)

OFD-102A-3.2 Flow Diagram of Low Pressure Injection System (LPI Pump 049

Discharge)

OFD-102A-3.3 Flow Diagram of Low Pressure Injection System (Core 025

Flood)

OFD-104A-3.1 Flow Diagram of Spent Fuel Cooling System 061

OFD-109A-3.1 Flow Diagram of Purification Demineralizers 016

OFD-116-3.1 Flow Diagram of Reactor Building Purge System 14

OFD-121D-1.1 Flow Diagram of Emergency Feedwater System 39

Engineering 424347 Disposition for Re-use of Fuel Assembly UDPK01 and 0

Changes UDPK03

Miscellaneous Clearance OPS-3-24-HP-LTOP S/U-0667

Inspection Type Designation Description or Title Revision or

Procedure Date

Clearance OPS-3-24-LPI-LPI Sys Fill-0680

Pheonix Online Risk profile for Unit 3 for the week of April

28, 2024

O3R32 - Outage Schedule by Early Start, Current

Active/Working Version

Clearance OPS-3-24-RC-PZR Cooldown-0409

Clearance OPS-3-24-HPI-HPI Fill-0678

ONEI-0400-267 Oconee 3 Cycle 32 Spent Fuel Pool Decay Heat 013

Engineering Instruction

ONEI-0400-301 Communication of Requirements for Oconee Technical 001

Specification 3.7.13: Definitions, Boundary Conditions, and

Spent Fuel Pool Storage Qualifications

ONEI-0400-349 Core Alignment Verification 001

ONEI-0400-371 Oconee Nuclear Station Unit 3 Loss of Spent Fuel Cooling 003

Heat Up Times Due to Decay Heat

ONEI-0400-592 Oconee 3 Cycle 33 Final Core Load Map 002

OSC-11714 Oconee Nuclear Station Cycle Specific Decay Heat 019

Calculations

OSC-1594 NUREG-0612 - Control of Heavy Loads - Load Drop 002

Analysis

OSC-6051 Verification of Alternate Method Used to Fill Spent Fuel 011

Pools Following Operation of SSF RC Makeup System

OSS-0254.00-00- (Mech) Design Basis Specification for Standby Shutdown 064

1004 Facility Reactor Coolant Makeup System

OSS-0254.00-00- (Mech) Design Basis Specification for the Spent Fuel 034

1006 Cooling System

OSS-0254.00-00- (Mech) Design Basis Specification for Reactor Building 046

4001 Containment Isolation

Procedures AD-MN-ALL-0002 Foreign Material Exclusion 16

AD-MN-ALL-0009 Nuclear Rigging and Lifting 9

AD-OP-ALL-0201 Protected Equipment 10

AD-OP-ALL-0203 Reactivity Management 16

AD-SY-ALL-0460 Managing Fatigue and Work Hour Limits 8

AM/0/A/3009/012 Emergency Plan for Refilling Spent Fuel Pools 013

Inspection Type Designation Description or Title Revision or

Procedure Date

A

AP/3/A/1700/002 Excessive RCS Leakage 016

AP/3/A/1700/026 Loss of Decay Heat Removal 029

AP/3/A/1700/035 Loss of SFP Cooling and/or Level 025

FG/0/A/1900/011 Alternative Spent Fuel Pool Cooling 002

IP/0/B/0200/027 A Reactor Level Instrumentation and Calibration 033

IP/0/B/0200/027 B Ultrasonic Level Instrument Installation and Calibration 025

IP/0/B/0200/027 Reactor Vessel Level Transmitters Return to Service and 013

C Removal from Service

IP/0/B/3002/002 A Polar Crane Inspection and Preventive Maintenance 015

MP/0/A/1150/002 Reactor Vessel - Closure Head - Installation 059

A

MP/0/A/1400/002 Equipment Hatch - Reactor Building - Temporary Opening 042

A and Closing

MP/0/A/1500/009 Defueling/Refueling Procedure 078

MP/0/A/1710/017 Crane - Whiting - Polar - Inspection 018

B

MP/0/A/1800/105 RBES - LPI Suction Line Flange Installation and Removal, 023

A Drain Line and Sump Inspections

MP/0/A/3005/012 Containment Inspection/Close Out Procedure 022

MP/0/B/1710/022 Operation of Reactor Building Polar Crane and Auxiliary 039

Hoist (CRD Crane)

OP/0/A/1108/001 Curves and General Information 119

OP/0/A/1108/001 Reactor Core and SFP Loss of Cooling Heatup Tables 008

A

OP/0/A/1108/001 Spent Fuel Pool Level vs. Temperature Curves 018

B

OP/3/A/1102/001 Controlling Procedure for Unit Startup 285

OP/3/A/1102/001 Controlling Procedure for Unit Startup 285

OP/3/A/1102/004 Operation at Power 143

OP/3/A/1102/004 Operation at Power 142

OP/3/A/1102/010 Controlling Procedure for Unit Shutdown 256

OP/3/A/1102/015 Filling and Draining FTC 088

Inspection Type Designation Description or Title Revision or

Procedure Date

OP/3/A/1102/028 Reactor Building Tour and Containment Material Controls 022

OP/3/A/1103/011 Draining and Nitrogen Purging RCS 100

OP/3/A/1104/004 Low Pressure Injection System 171

OP/3/A/1104/006 SF Cooling System 102

OP/3/A/1104/010 Low Pressure Service Water 122

OP/3/A/1104/049 Low Temperature Overpressure Protection (LTOP) 061

OP/3/A/1105/019 Control Rod Drive System 035

OP/3/A/1106/001 Turbine Generator 129

OP/3/A/1106/006 Emergency FDW System 116

OP/3/A/1502/001 Operations Defueling/Refueling Responsibilities 093

OP/3/A/1502/007 Operations Defueling/Refueling Responsibilities 093

OP/3/A/1502/009 Containment Closure Control 050

PT/0/A/0711/001 Zero Power Physics Testing 081

PT/0/A/0750/002 Core Inspections Procedure 031

PT/0/A/0750/012 Development of Fuel Movement Instructions Procedure 054

PT/0/A/0750/012 Development of Fuel Movement Instructions Procedure 054

PT/0/A/0750/018 Refueling Activities 026

PT/0/A/0775/015 Core Alignment Verification 015

PT/3/A/0115/008 Reactor Building Containment Isolation and Verification 043

PT/3/A/0115/012 Unborated Water Source Isolation Verification 005

PT/3/A/0150/029 Performance Containment Verification 015

PT/3/A/0150/030 Containment Verification 004

PT/3/A/0150/034 Leak Rate History Record and Reactor Building Leak Rate 012

Verification

PT/3/A/0200/046 Reactor Coolant System Leak Test 011

PT/3/A/0600/001 Instrument Surveillance Prior to Mode Change 44

B

PT/3/A/0600/015 Control Rod Movement 030

PT/3/A/0630/001 Mode Change Verification 037

Work Orders 20541411, 20541412, 20268299, 20612211, 20612035,

20612355, 20612627, 20612628

71111.24 Corrective Action 2476102, 2473099, 2471437, 2426308, 2426301, 2516589,

Documents 2518189, 2515022, 2517412, 2517443, 2505843, 2469093,

Inspection Type Designation Description or Title Revision or

Procedure Date

2401644, 2327394, 2401085, 2327585, 2401253, 2518116

Drawings OFD-102A-3.1 Flow Diagram of Low Pressure Injection System (Borated 065

Water Supply and LPI Pump Suction)

OFD-102A-3.2 Flow Diagram of Low Pressure Injection System (LPI Pump 049

Discharge)

OFD-116A-3.1 Flow Diagram of Reactor Building Purge System 014

OFD-121D-1.1 Flow Diagram of Emergency Feedwater System 039

Engineering 422106, 424347

Changes

Miscellaneous ONEI-0400-352 Oconee Mast Sipping Limits and Precautions 001

ONEI-0400-477 Oconee Core Power Distribution Comparison Criteria 000

OSS-0254.00-00- (MECH) Design Basis Spec for the Essential Siphon 015

1049 Vacuum System

Procedures AD-NF-ALL-0806 Nuclear Fuel Integrity 6

AD-OP-ALL-0106 Conduct of Infrequently Performed Tests or Evolutions 4

AP/3/A/1700/026 Loss of Decay Heat Removal 029

AP/3/A/1700/035 Loss of SFP Cooling and/or Level 025

EP/3/A/1800/001 Unit 3 EOP Enclosures 5.31-5.40 0

0P

MP/0/A/1200/045 Valve - Henry Pratt Type RIA11 - Reactor Building Purge - 025

Seat to Disc Adjustment

MP/0/A/1200/088 Valves - Henry Pratt - Reactor Building Purge Isolation - 028

Preventive Maintenance

MP/0/A/1840/040 Pumps - Motors - Miscellaneous Components - Lubrication 004

A Post Maintenance Testing

MP/0/A/3009/020 DC Motor - Up to 50 HP - Visual Inspection and Preventive 010

A Maintenance

PT/0/A/0711/001 Zero Power Physics Test 081

PT/0/A/0750/023 Fuel Assembly Inspection by In-Mast Sipping 009

PT/0/A/0750/025 Fuel Assembly Inspection by Canned Sipping 001

PT/0/A/0800/030 Core Power Distribution Comparison 063

PT/0/A/0811/011 Power Escalation Test 058

PT/1/A/0600/013 Motor Driven Emergency Feedwater Pump Test 078

Inspection Type Designation Description or Title Revision or

Procedure Date

PT/2/A/2200/011 KHU-2 Turbine Guide Bearing Oil System Surveillance 014

PT/3/A/0150/006 Mechanical Penetration Leak Rate Data 076

PT/3/A/0151/019 Penetration 19 Leak Rate Test 019

PT/3/A/0151/029 Penetration 29 Leak Rate Test 013

PT/3/A/0152/016 Purge System Valve Stroke Test 020

PT/3/A/0261/010 Essential Siphon Vacuum System Test 37

PT/3/A/0600/012 Turbine Driven Emergency Feedwater Pump Test 096

PT/3/A/0610/001 EPSL Normal Source Voltage Sensing Circuit 036

A

PT/3/A/0610/001 EPSL Startup Source Voltage Sensing Circuit 036

B

PT/3/A/0610/001 EPSL Standby Bus 1 And 2 Voltage Sensing Circuits 021

C

PT/3/A/0610/001 Emergency Power Switching Logic Test 056

J

Work Orders 20647905, 20523776, 20563143, 20645573, 20561397,

20666997, 20611772, 20612606, 20612630, 20612607,

20476249, 20648458, 20469789, 20669079, 20609616,

20655172

71114.06 Miscellaneous ASE-13

71151 Corrective Action 2506370

Documents

Miscellaneous MSPI Derivation and Margin Reports for Heat Removal for

Oconee Nuclear Station

Mitigating Systems Performance Index (MSPI) Basis 27

Document

LER 270-2023-001

LER 287-2023-001

LER 287-2023-002

RCS Leak rate data for Oconee Nuclear Station

MSPI Derivation and Margin Reports for Cooling Water

System for Units 1, 2, and 3 from June 2023 to March 2024

AD-PI-ALL-0700 Performance Indicators 6

OSS-0254.00-00- (Mech) Design Basis Spec for Keowee Turbine Generator 018

Inspection Type Designation Description or Title Revision or

Procedure Date

1046 Cooling Water (WL) System

PT/X/A/0201/007 RCS Leakage Calculation Test 1

71152A Corrective Action 2516908, 2516782

Documents

Miscellaneous Interim Report of a Deviation Associated with an Oil Filled

Capacitors in Aluminum Case Part Number 07-020139-10,

Final Report of a Deviation Associated with an Oil Filled

Capacitors in Aluminum Case Part Number 07-020139-10

71152S Corrective Action 2504661, 2508057, 2517041, 2517136, 2515865, 2518663,

Documents 2494275

Work Orders 20263850, 20263851, 20263865, 20263849, 20537999,

20670317

71153 Corrective Action 2477145, 2477208, 2477210, 2477611, 2489821, 2477886,

Documents 2477925, 2480047, 2480068, 2503208

23

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