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Oconee 3
2Q/2008 Plant Inspection Findings


Initiating Events

Significance:a graphic of the significance Mar 31, 2008
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Implement the Procedure to Stroke RBS Valves (Section 1R22)
A self-revealing non-cited violation (NCV) of Technical Specification (TS) 5.4.1 was identified for failure to adequately implement the procedure to stroke reactor building spray (RBS) valves, which resulted in a loss of Reactor Coolant System (RCS) inventory while in Mode 5.

The inspectors determined that the loss of RCS inventory while in Mode 5 was a performance deficiency. The finding was considered to be more than minor because it affected the Configuration Control attribute of the Reactor Safety/Initiating Events Cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown, as well as power operations. The finding was determined to be of very low safety significance. This was based initially on a determination that the event did not meet the loss of control criteria in MC 0609, Appendix G, and also on the Phase 1 screening criteria found in Manual Chapter (MC) 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 2. This finding has a cross-cutting aspect of appropriate coordination of work activities [H.3.b], including incorporating actions to address interdepartmental coordination, the need to keep personnel apprised of work status, the operations impact of work activities, and plant conditions that may affect work activities, as described in the work control component of the human performance cross-cutting area. (Section 1R22)

Inspection Report# : 2008002 (pdf)

Significance:a graphic of the significance Mar 31, 2008
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Dilution of the RCS While Lining Up for SFP Makeup (Section 4OA3)
A self-revealing NCV of TS 5.4.1 was identified for the failure to properly implement the procedural requirements of OP/3/A/1104/006C, Spent Fuel Pool (SFP) Makeup, which led to an over dilution of the Unit 3 RCS.

The failure to properly implement the procedural requirements of OP/3/A/1104/006C was considered to be a performance deficiency. The finding was determined to be more than minor because it was associated with the Initiating Event Cornerstone attribute of configuration control; thereby, impacting the associated cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors reviewed this finding in accordance with MC 0609, Significance Determination Process. Although the unintentional dilution was a transient initiator, it did not increase the likelihood of a reactor trip, nor did it increase the likelihood that mitigation equipment or functions will not be available. Consequently, the finding was determined to be of very low safety significance. This finding has a cross-cutting aspect of procedural compliance for a failure to follow procedures [H.4.b] as described in the work practices component of the human performance cross-cutting area. (Section 4OA3)

Inspection Report# : 2008002 (pdf)

Significance:a graphic of the significance Dec 31, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Inadequate Loss of Unit 3 SFP Cooling Procedure
A self-revealing non-cited violation (NCV) of Technical Specification (TS) 5.4.1 was identified for failure to establish and implement an adequate procedure for loss of the Unit 3 spent fuel pool (SFP) cooling and/or level. More specifically, Abnormal Procedure AP/3/A/1700/035, Loss of SFP Cooling and/or Level, did not reflect the dependency that Unit 3 SFP cooling has on condenser circulating water (CCW) booster pump flow. If it had, the unexpected Unit 3 SFP temperature increase on December 1, 2007, could have been mitigated in a more timely manner and the SFP temperature increase limited to a lower value.

The licensee’s failure to adequately establish and implement the procedure for loss of spent fuel pool cooling was a performance deficiency. The finding was considered to be more than minor because it affected the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. The finding was not suitable for SDP evaluation, but was reviewed by NRC management and was determined to be of very low safety significance, because the rate of SFP heatup was low (10 degrees F in four hours), the operators demonstrated the ability to restore CCW booster pump flow within a relatively short time period with respect to the heatup rate, and the Unit 1 and 2 recirculating cooling water (RCW) system was available to be lined up to supply cooling to the Unit 3 SFP cooling heat exchangers per existing plant procedures if needed.

This finding was entered into the licensee’s corrective action program. It has a cross-cutting aspect of complete, accurate, and up-to-date procedures (H.2.c), as described in the resources component of the human performance cross-cutting area. (Section 1R20b.(1))

Inspection Report# : 2007005 (pdf)


Mitigating Systems

Significance:a graphic of the significance Mar 31, 2008
Identified By: Self-Revealing
Item Type: FIN Finding
Inadequate Installation of SSF DG Field Flash Relay Cover (Section 1R19)
A self-revealing finding (FIN) was identified for failure to implement self-checking during Standby Shutdown Facility (SSF) diesel generator (DG) field flash relay cover reinstallation, resulting in a failure of the relay during post maintenance testing and subsequent loss of the electronic governor.

The inspectors determined that the licensee’s failure to correctly install the SSF DG field flash relay cover was a performance deficiency. The finding was considered to be more than minor because it affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. The finding was determined to be of very low safety significance (Green), based on the Phase 1 screening criteria found in MC 0609, Appendix A, Attachment 1, in that the additional 15.6 hours of SSF unavailability resulting from the deficiency was less than the TS allowed outage time. Additionally, the Oconee Phase 2 pre-solved table for exposure times of less than three days yields a Green result for the SSF DG. This finding has a cross-cutting aspect of human error prevention techniques [H.4.a], as described in the work practices component of the human performance cross-cutting area. (Section1R19)

Inspection Report# : 2008002 (pdf)

Significance:a graphic of the significance Mar 14, 2008
Identified By: NRC
Item Type: NCV NonCited Violation
Inadequate Design Control in the Translation of Design Basis Information into Procedure for Draining and Nitrogen Purging the RCS (Section 1R21.2.2)
The inspectors identified a finding of very low safety significance involving a
non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control.
Specifically, the licensee failed to verify the applicability of design basis information,
related to critical vortex height to assure adequate low pressure injection (LPI) pump
suction conditions, before translating that information into the shutdown operations
procedure for draining the reactor coolant system.

This finding is greater than minor because if left uncorrected, the finding would
become a more significant safety concern. In particular, the station routinely uses
older calculations, test information, and analyses to establish operator action or
alarm set points, support operability determinations, or change the design of the
plant. If the applicability of that information is not verified for the system
configuration and conditions under review, the quality of that engineering product
could be compromised, resulting in a significant safety concern. The finding was
determined to be of very low significance, via Manual Chapter (MC) 0609, Appendix
G, Attachment 1, Shutdown Operations Significance Determination Process (SDP),
Phase 1 because it did not significantly degrade the station capability to recover
decay heat removal. The cause of the finding is related to the cross-cutting area of
problem identification and resolution, specifically with respect to corrective action,
because the licensee did not thoroughly evaluate the previous similar finding in the
2006 Oconee Component Design Bases Inspection (CDBI) such that the resolution
adequately addressed causes and extent of condition (MC 0305, aspect P.1.c).
[Section 1R21.2.2]
Inspection Report# : 2008006 (pdf)

Significance:a graphic of the significance Mar 14, 2008
Identified By: NRC
Item Type: NCV NonCited Violation
Inadequate Verification of Local Manual Operating Capability for EFW Flow Control Valves (Section 1R21.2.6)
The inspectors identified a finding of very low safety significance involving a
NCV of 10 CFR 50, Appendix B, Criterion III, Design Control. Specifically, the
licensee failed to establish measures to verify the design capability for local manual
handwheel operation of the emergency feedwater (EFW) flow control air operated valves (AOVs). Local manual operation was an alternate method of controlling EFW
flow specified in station emergency procedures.

The finding is more than minor because it is associated with the design control
attribute of the Mitigating System Cornerstone and affected the cornerstone objective
to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The finding was of very low
safety significance since it did not result in a loss of system safety function.
Specifically, the licensee performed a technical evaluation during the inspection
which demonstrated that a plant operator would be able to successfully cycle the
valves using the manual handwheel. [Section 1R21.2.6]
Inspection Report# : 2008006 (pdf)

Significance:a graphic of the significance Sep 30, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure To Promptly Identify A Condition Adverse To Quality
A self-revealing non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for failure to take timely corrective action to repair the Standby Shutdown Facility (SSF) air conditioning compressor #2. As a result, the SSF was unnecessarily inoperable for over one week. The inspectors determined that the licensee’s failure to promptly repair the SSF air conditioning compressor #2 was a performance deficiency. This finding was more than minor because it affected the availability and reliability attribute of the Mitigating Systems Cornerstone, in that it reduced the reliability of the SSF air conditioning system, which was required to maintain building temperatures for both habitability and electrical equipment operability. The licensee determined that the SSF remained available as long as one of the two compressors was functional. However, in the event of the SSF being required, reduced capacity and reliability of the air conditioning system would have reduced the likelihood of successful operation of the SSF. The SSF was inoperable from September 4 - 7, 2007, while inadequate repairs were conducted, and again from September 7 - 13, 2007, while no action was taken. The SSF was available for most of this period because compressor #1 was functional. This finding was evaluated using the SDP and was determined to be of very low safety significance because there was no loss of safety function. The inspectors determined this finding was related to the cross cutting aspect of appropriate corrective action being taken in a timely manner [P.1.d], as described in the corrective action component of the problem identification and resolution cross cutting area (Section 1R19).
Inspection Report# : 2007004 (pdf)


Barrier Integrity

Significance:a graphic of the significance Dec 31, 2007
Identified By: NRC
Item Type: NCV NonCited Violation
Failure to Establish Adequate Procedures for Containment Closure Following a Loss of Decay Heat Removal Event
The inspectors identified an NCV of TS 5.4.1 for the failure to establish and implement adequate procedures for containment closure following a potential loss of decay heat removal (LDHR) event. More specifically, existing procedures did not adequately address control of vehicles blocking the equipment hatch opening, as was the case on October 27, 2007.

The licensee’s failure to implement adequate procedures to close the equipment hatch in the event of a LDHR was considered to be a performance deficiency. The finding was determined to be more than minor as it was associated with the barrier integrity cornerstone attribute of procedure quality, thereby impacting the associated cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The inspectors reviewed this finding in accordance with IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 3. This finding did not meet the criteria in the checklist for requiring a Phase 2 or 3 analysis, and was therefore determined to be of very low safety significance.

This finding was entered into the licensee’s corrective action program. It has a cross-cutting aspect of complete, accurate, and up-to-date procedures (H.2.c), as described in the resources component of the human performance cross-cutting area. (Section 1R20b.(2))
Inspection Report# : 2007005 (pdf)


Emergency Preparedness


Occupational Radiation Safety


Public Radiation Safety


Physical Protection

Although the NRC is actively overseeing the Security cornerstone, the Commission has decided that certain findings pertaining to security cornerstone will not be publicly available to ensure that potentially useful information is not provided to a possible adversary. Therefore, the cover letters to security inspection reports may be viewed.


Miscellaneous

Significance: N/A Jul 27, 2007
Identified By: NRC
Item Type: FIN Finding
PI&R Summary
The inspectors concluded that, in general, problems were properly identified, evaluated, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution; however, several minor plant material condition deficiencies were identified during plant system walkdowns that had gone undetected by licensee personnel. The licensee maintained a low threshold for identifying problems as evidenced by the continued large number of Problem Investigation Process reports (PIP) entered annually into the CAP. Generally, the licensee properly prioritized issues and examined issues; although several minor problems were noted where lower significance issues were mis-categorized or the investigations lacked thoroughness. Formal root cause evaluations for significant problems were generally thorough and detailed. Corrective actions specified for problems were generally adequate; although, several minor problems were noted where corrective actions were not complete or not comprehensive. Audits and self-assessments were effective in identifying deficiencies in the CAP. Personnel at the site felt free to raise safety concerns to management and to resolve issues through the CAP.

Inspection Report# : 2007008 (pdf)

Last modified : August 29, 2008