IR 05000269/2019002
| 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.
REACTOR SAFETY
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:
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:
- (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
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
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
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
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-
Unit 1 Auxiliary Building Elevation 809'
CSD-ONS-PFP-
Unit 2 Auxiliary Building Elevation 809'
CSD-ONS-PFP-
Unit 2 Auxiliary Building Elevation 822'
CSD-ONS-PFP-
Unit 3 Auxiliary Building & Reactor Building Elevation 796'
CSD-ONS-PFP-
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
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
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
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
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
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
2143025,
20123122,
20123261,
20142395,
260071,
20326318,
230354,
273757,
223158,
2018032,
212073
Corrective Action
Documents
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
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
Calculations
OSC-1160
Postulated Cask Drop Accident-Poison Racks
Engineering
Changes
Evaluation of SF-2 Valve Installation Sequence Over Unit 1/2
and 3 Spent Fuel
Miscellaneous
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
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
27, July
2012
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
20324170,
225494,
20309525,
260071,
20301777,
295098
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
20109052,
257191
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
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
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
Corrective Action
Documents
CT-3 Lockout
05/17/2018
Monitoring of the Vital DC ground bus voltages
05/09/2018
I/R Positive DC Ground on Vital DC System
05/09/2018
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
CT3, Support Lockout Trip Investigation
05/10/2018
3B FWPT Terminal Cabinet, Grounded Cable 3TP404
05/10/2018