OCONEE NUCLEAR STATION – NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT

by Bob Meyer

In a letter dated January 26, 2012, the NRC issued the completed report on a Problem Identification and Resolution biennial inspection at Oconee Nuclear Station (ONS) Units 1, 2, and 3.

The inspectors identified one Green finding, and some weaknesses, including minor performance deficiencies, associated with the performance of the corrective action program (CAP) in the areas of problem identification, problem evaluation, adequacy and timeliness of corrective actions, and use of operating experience.

The violation is being cited in the enclosed Notice of Violation (NOV) in accordance with the NRC Enforcement Policy because the NRC determined that ONS personnel failed to restore full compliance for a non-cited violation (NCV) issued in a previous NRC inspection report. Specifically, ONS personnel failed to promptly identify and correct the condition adverse to quality discussed in the NCV for Units 1, 2, and 3 in order to fully address the condition and restore compliance with NRC regulations.

During an inspection completed on December 16, 2011, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is set forth below:

A. 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, and non-conformances are promptly identified and corrected.

10 CFR 50.49(f) requires that each item of electric equipment important to safety shall be qualified by one of the following methods: (1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable, (2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable, (3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable, or (4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

Contrary to the above, from October to November 2010 (Unit 3 refueling outage), from April to June 2011 (Unit 1 refueling outage), and in November 2011 (Unit 2 refueling outage), the licensee failed to establish measures to assure that a condition adverse to quality, identified by the NRC in NCV 2010004-03, was promptly identified and corrected. Specifically, the licensee missed reasonable opportunities during each Unit’s refueling outage to confirm the population of Limitorque actuators that were potentially installed in an unqualified configuration in order to properly assess the extent of the nonconforming condition discussed in NCV 2010004-03 and take appropriate corrective actions. Consequently, an unknown population of Limitorque actuators in Units 1, 2, and 3 remained in a configuration that was not qualified in accordance with one of the methods described in 10 CFR 50.49(f).

This violation is associated with a Green Significance Determination Process finding.

The performance deficiency was directly related to the crosscutting area of Problem Identification of Resolution under the Problem Evaluation aspect of the Corrective Action Program component because the licensee did not thoroughly evaluate the problem which resulted in the failure to promptly identify and correct a condition adverse to quality.

The NRC identified a non-escalated cited violation of 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action” for the licensee’s failure to promptly identify and correct a condition adverse to quality in Units 1, 2, and 3, which resulted in failure to restore compliance with 10 CFR 50.49(f). The condition adverse to quality involved the installation of Limitorque valve actuators in a configuration that was not supported by the vendor’s environmental qualification (EQ) testing or engineering analysis. The licensee implemented immediate actions to address the functionality concern on the affected valves by installing drains to prevent excessive accumulation of condensate that could impact the valves’ safety function.

the NRC is currently monitoring the effectiveness of licensee’s corrective actions to address an open trend discussed in NRC Inspection Report 2011003 associated with inconsistent initiation of PIPs and describing plant issues in sufficient detail and clarity to allow an adequate problem evaluation and appropriate corrective actions to be developed.

The inspectors identified that no formal guidance or mechanism existed in the CAP to ensure that PIPs were generated for plant issues that were initially identified in work requests. The inspectors also noted that there was no specific group with the responsibility to screen WRs/WOs to ensure plant issues have been entered into the CAP as a PIP in order to have potential impact on operability or functionality identified in a timely manner. Based on discussions with licensee management, the inspectors identified that there is a management expectation that a PIP shall be initiated for any equipment related WR. However, this expectation was not formally described in the CAP procedures. Even though a high rate of PIP initiation was observed at the ONS for equipment-related issues, the CAP process was still vulnerable to miss the entry of a condition adverse to quality into the problem investigation program.

The inspectors identified during a walk-down of the Protected Service Water (PSW) building that a portable heating system had been out of service for an extended period the night before the walk-down. The inspectors identified that this condition was not captured in the PIP process as required by NSD-208. The inspectors also noted that no records were available to confirm that compensatory measures were in place to ensure the building temperature did not exceed the minimum limit for the building. The PSW building was a new safety-related building under construction considered, at the time, to be a Class B storage facility with specific temperature limits to meet quality assurance requirements.

The inspectors identified during the review of Autologs for the Keowee Hydro Units that two issues, one associated with the Unit 2 shear pin failure actuation alarm and the other associated with a Godiva gasoline powered backup fire pump battery, were not captured in the PIP process as required by NSD-208.

The inspectors performed a timeliness review of Licensee Event Reports (LERs) required pursuant 10 CFR 50.73 and identified that the licensee experienced challenges to submit LERs containing the full description of the event, its root cause(s) and proposed corrective actions within the required 60 days. In most cases, the licensee submitted an abstract prior to the 60 day clock expiring, and then supplemented the original abstract with a full LER at a later date. The licensee initiated various PIPs to address this issue; however, the inspectors identified that the corrective actions did not seem to effectively drive changes to improve the timeliness of root cause evaluations and completeness of LERs.