IR 05000400/2002009

Final Significance Determination for White Finding & Notice of Violation (NRC Inspection Report 05000400/2002-009)

ML021690242
Person / Time
Site:	Harris
Issue date:	06/13/2002
From:	Reyes L NRC/RGN-II
To:	Scarola J Carolina Power & Light Co
References
EA-02-067, IR-02-009
Download: ML021690242 (39)

Text

SNUCLEA UNITED STATES NUCLEAR REGULATORY COMMISSION o REGION II SAM NUNN ATLANTA FEDERAL CENTER 9, *61 FORSYTH STREET SW SUITE 23T85 ATLANTA, GEORGIA 30303-8931 June 13, 2002 EA-02-067 Carolina Power & Light Company ATTN: Mr. James Scarola Vice President - Harris Plant Shearon Harris Nuclear Power Plant P. 0. Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165 SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-400/02-09, SHEARON HARRIS NUCLEAR POWER PLANT)

Dear Mr. Scarola:

The purpose of this letter is to provide you with the final results of our significance determination for the preliminary White finding identified in NRC Inspection Report 50-400/02-07, and discussed in NRC Inspection Report 50-400/01-05. The inspection finding was assessed under the significance determination process and was preliminarily characterized as White, i.e., an issue of low to moderate safety significance, which may require additional NRC inspection. The finding involved a failure of foreign material exclusion controls, identified by your staff, when several pieces of foreign material were discovered in the containment sump suction piping to the A Residual Heat Removal (RHR) pump.

At Carolina Power & Light Company's (CP&L) request, an open regulatory conference was conducted with members of your staff on June 4, 2002, to discuss CP&L's position on this issue. The enclosures to this letter include the list of attendees at the regulatory conference, and copies of the material presented by CP&L and the NRC at the regulatory conference.

During the conference, you agreed with the NRC's estimate that the finding resulted in an incremental increase in core damage frequency of approximately 6xl 0 6/year, and with the NRC's characterization of the finding as a violation of regulatory requirements. In addition, you provided information regarding the discovery of the rubber material in the RHR pump suction piping, CP&L's investigation into the cause of the problem, corrective actions, and the current Foreign Material Exclusion Program at the Harris Nuclear Plant.

At the conference, you requested the NRC to consider the finding as an old design issue in accordance with Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program. Consideration of the finding as an old design issue could cause the NRC to refrain from including this finding in the assessment program. The basis for your request stemmed from your belief that the finding satisfied the IMC's definition of an old design issue, and that your actions and other circumstances satisfied the four criteria listed in IMC 0305.

CP&L 2 After considering the information developed during the inspection and the information CP&L provided at the conference, the NRC has concluded that the final inspection finding is appropriately characterized as White. This determination was based on our review of the relevant risk information during and after our inspection. In addition, the NRC concluded that the finding could not be appropriately considered an old design issue in accordance with IMC 0305. Specifically, the NRC concluded that this finding did not satisfy the definition of an old design issue, in that it did not constitute an engineering calculation or analysis, an associated operating procedure, or installation of plant equipment. This definition is intended to capture those types of issues associated with past deficiencies or inconsistencies in the integrated engineering and design process, which includes design analysis, operating procedures associated with the design, and installation of the plant equipment. In this case, the NRC concluded that the finding was associated with the failure to properly implement the requirements of a maintenance related procedure involving cleanliness and housekeeping. The NRC also determined that the criteria for identification was not satisfied in that the discovery of the foreign material was not a result of a voluntary initiative on the part of CP&L, but in fact was a result of a maintenance activity on an RHR system isolation valve and resulting corrective action and extent of condition reviews by the CP&L staff. The NRC, however, recognizes your staff's efforts to identify and promptly correct this matter. Based on your comments at the conference, however, the NRC may consider clarifying the information contained in IMC 0305 regarding old design issues to preclude future misinterpretations.

You have ten business days from the date of this letter to appeal the staff's determination of significance for the identified White finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter 0609, Supplement 3.

The NRC also determined that a violation occurred involving Technical Specification (TS) 6.8, Procedures and Programs. Specifically, CP&L failed to properly implement the requirements of Maintenance Management Manual Procedure MMM-01 1, Cleanliness and Housekeeping, which contains requirements to prevent the entry of foreign objects into plant systems and components. Adequate foreign material exclusion controls were not implemented for the RHR system when on October 8, 2001, foreign material of a size to affect pump performance (greater than the containment sump screen openings) was identified in the containment sump suction piping to the A RHR pump. As a result, during the operating cycle from April 15, 2000, to September 22, 2001, Unit 1 was operating in Modes 1, 2 and 3 on numerous occasions with the A RHR pump inoperable for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without satisfying the action requirements of TS 3/4.5.2, Emergency Core Cooling Subsystems. The NRC concluded that the TS 3/4.5.2 violation is a result of CP&L's failure to promptly implement foreign material exclusion control procedural requirements, and as such the failure to meet these requirements has been cited as one violation in the enclosed Notice of Violation (Notice). The circumstances surrounding the violation is described in detail in the subject inspection report. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG-1600, the Notice is considered escalated enforcement action because it is associated with a White finding.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is adequately addressed on the docket in NRC Inspection Report 50-400/02-07 and in the information presented by Carolina Power and Light Company at the

CP&L 3 regulatory conference (Enclosure 4). Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

Because plant performance for this issue has been determined to result in increased regulatory response, we will use the NRC Action Matrix to determine the most appropriate NRC response for this finding. We will notify you, by separate correspondence, of that determination.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures, and your response, will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR and PARS without redaction.

For administrative tracking purposes, this letter is issued as a separate NRC Inspection Report, No. 50-400/02-09.

Should you have any questions regarding this letter, please contact Loren Plisco, Director, Division of Reactor Projects, at 404-562-4501.

Sincerely, 4w4 Luis A. Reyes Regional Administrator Docket No.: 50-400 License No.: NPF-63

Enclosures:

1. Notice of Violation 2. List of Attendees 3. Material presented by NRC 4. Material presented by CP&L

REGION II OFFICE, ATLANTA, GA.

I. OPENING REMARKS, INTRODUCTIONS AND MEETING INTENT L. Reyes, Regional Administrator Ii. NRC REGULATORY CONFERENCE POLICY L. Plisco, Director, Division of Reactor Projects III. STATEMENT OF THE ISSUE WITH RISK PERSPECTIVES L. Plisco, Director, Division of Reactor Projects IV. SUMMARY OF APPARENT VIOLATION L. Plisco, Director, Division of Reactor Projects V. LICENSEE RISK PERSPECTIVE PRESENTATION VI. LICENSEE RESPONSE TO APPARENT VIOLATION VII. BREAK / NRC CAUCUS L. Reyes, Regional Administrator VIII. CLOSING REMARKS L. Reyes, Regional Administrator Enclosure 3

Draft ADoarent Violation Note: The apparent violation discussed at this Regulatory Conference is subject to further review and subject to change prior to any resulting enforcement action.

Technical Specification (TS) 6.8, Procedures and Programs, section 6.8.1 requires that written procedures be established implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978 which includes section 9.0, Procedures for Performing Maintenance. Licensee Maintenance Management Manual (MMM) Procedure MMM-01 1, "Cleanliness and Housekeeping," Revision 4, section 5.3," Preventing Contamination During Maintenance," contains the requirements to prevent foreign object entry into plant systems and components.

TS 3/4.5.2 requires 2 operable RHR pumps when in Modes 1-3 with operation with one pump allowed for a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Adequate foreign material exclusion controls were not implemented for the RHR System when on October 8, 2001, foreign material of a size to affect pump performance (greater than the containment sump screen openings) was identified in the containment sump suction piping to the A RHR pump. As a result, during the operating cycle prior to refueling outage 10 (from April 15, 2000, to September 22, 2001), Unit 1 was operating in Modes 1-3 on numerous occasions and the A RHR Pump was inoperable for a time greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the licensee did not satisfy the requirements of TS 3/4.5.2.

Hari NulerPln Regulatory Conference Preliminary White Finding Foreign Material in RHR System

o CP&L A Progress Energy Company

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HNP Attendees e Jim Scarola - Site Vice President

"* Ben Waldrep - Plant General Manager

"*Abdy Khanpour - Engineering Manager

• Jason Laque - Maintenance Manager

• Andy Barbee - Operations Training Superintendent, Root Cause Team Lead

. Steve Laur - PSA Supervisor

• John Caves - Licensing Supervisor CP&L

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Agenda

"*Background

"*Discovery/Investigation

"*Corrective Actions

"*HNP Foreign Material Exclusion Program

"*Conclusions SCP&L

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Background-lr

• HNP admits violation

• HNP accepts NRC conclusion of significance: White finding - Low to mod e rate importance to safety

• Request NRC to con s ider the issue be treated as Old Design Issue in Assessment Program

&'SCP&L

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Discovery of Foreign Materia I

"A CP&L

1'

Foreign Material 6CP&L

/ / K Initial Discovery

• Found during maintenance on Cont. Sump to "A" RHR Pump Isolation Valve

• Discovered by mechanics when valve was disassembled

• Minor debris discovered in valve body

"* Unexpected debris prompted aggressive investigation using inspection mirrors and flashlight

"* Debris was removed

"* Debris discovery immediately reported to management SCP&L

!

Root Cause Investigation

. Multidiscipline team

. Concluded additional invasive inspections needed

"*Expanded to 9 additional internal locations in SI and Cont. Spray (CT)

• Utilized high-resolution inspection camera

"*Root Cause: Substandard work practices

. Corrective Action to Prevent Recurrence

• Validated CURRENT FME Program effectiveness CP&L

( (  !

Additional Inspections

. "A" RHR-found additional rubber-type debris and sediment

"*"B" RHR-no material found

"*"A"CT-found two small metal objects

"*"B" CT-no material found

"*RWST-no material found CP&L

Consequences

- CT determined to be operable

"A"

• "A" RHR determined to be inoperable when on recirc. to the sump o Material unlikely to migrate into pump suction during low flow conditions such as SBLOCA o Large rubber pieces potentially "clog" the impeller eye reducing pump performance in high flow conditions SCP&L

f Results of Investigation

. Validated "as left" cleanliness of safety systems

. Restored confidence in system performance

• Validated strength of FME culture at HNP CP&L

/

FME Program Evolution

"* Prior to 1995 the industry maintained cleanliness in fluid systems in accordance with ANSI N45.2.1

"*SOER 95-01 defined FME as an industry concern.

"*Harris developed the site FME program as a response to SOER 95-01

& CP&L

t SOER 95-01 Reducing Events Resulting From Foreign Material Intrusion

"*Uncontrolled material entering systems and components during maintenance activities

"* Foreign Material Events Had Increased Between 1993 and 1995 o Fuel Cladding Damage o Major Equipment Damage o Heat Transfer Capability Degradation

• System Flow Characteristics Degradation V CP&L

( t P iIgrim

. Main gen erato r fault causes a load rejection results in reactor scram

. Cause - Overheating of stato r bar cooling wate r blocked by gasket material Ieft from work performed four years earlier Q CP&L

Biblis A

. Fire in a reactor coolant pump motor as a result of a Short circuit

. Cause - Chisel found in motor CP&L

!

FME Program Evolution

• Improvements utilized benchmarking and operating experience

• Flange and pipe covers identify FME barriers P NGG-wide procedure P Integration of FME principles into broad scope of training P FME training required prior to entry into FME area

• Recent discovery and prompt resolution of FME in RHR system indicative of strong culture

& CP&L

/

"No Fault" and Reward Environme

. "No-Fault" policy is established to encourage the employee to self-identify any FME issues without adverse consequences.

• Employees are rewarded for identifying and correcting FME concerns.

• An example of this is where a contract employee accidentally removed an FME Barrier, corrected the condition and identified the condition with an Condition Report.

CP&L

Levels of FME Control

• FME Levels prioritized based on nuclear safety and commercial risk factors.

"*Factors include:

• Potential for foreign material intrusion

• Ease of identification and removal

• The potential consequences from foreign material left in the system.

"*Plant Observation Program specifically calls out for a review of FME practices.

SCP&L

FME Cover Examples Bag Style Covers Small Diameter Pipe Covers FME Sticker Flange Cover - Comes in Fabricated Coiwm varying sizes CP&L

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What is next?

. Continuous Improvement Culture

• Corrective Action Program

• Self Assessments P Benchmarking

. Current Business Plan includes an initiative for in-process quality enhancement CP&L

Old Design Issues

• Inspection Manual:

p Definition: A finding involving a past problem in the engineering calculations or analysis, associated operating procedure, or installation ot plant equipment that does not reflect a performance deficiency associated with existing licensee programs, policy, or procedure. As discussed in section 06.06.a, some old design issues may not be considered in the assessment program.

Inspection Manual 0305, Sect. 04.07 CP&L

Criteria for Exclusion

. Licensee identified

• Voluntary initiative after minor debris discovered by mechanics

• After minor debris removed, used mirrors to find piece of rubber outside line of sight

• Mechanics immediately informed management of problem CP&L

Criteria for Exclusion

• Corrected in a timely fashion

• Problem discovered during outage o Extent of condition investigation completed before startup o Root cause corrected several years prior to discovery

• Discovery and subsequent actions demonstrate current program is effective

& cP&L

Criteria for Exclusion

. Not Likely to be identified by routine Iicensee efforts P Water never flows through stagnant pipe

• No surveillance requirements

• Rubber was outside of line-of-sight

• No opportunity for recent QC activities to identify risk-significant condition Q CP&L

Criteria for Exclusion

• Does not reflect a current performance deficiency

• Current FME Program would have prevented occurrence Q CP&L

!

Conclusions

• Large rubber piece most probably introduced in 1991

• Debris found by aggressive investigation -

we have a strong find and fix culture

• Continuous improvements in FME program since debris introduced in RHR system

• High confidence that there are no other foreign material problems in stagnant piping systems CP&L

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HNP Request

• HNP believes criteria satisfied to exclude this finding from action matrix impact

• Respectfully request that NRC consider discretion allowed by MC 0305 CP&L 29