IR 05000400/2003005
| ML032380022 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/22/2003 |
| From: | Fredrickson P NRC/RGN-II/DRP/RPB4 |
| To: | Scarola J Carolina Power & Light Co |
| References | |
| IR-03-005 | |
| Download: ML032380022 (18) | |
Text
August 22, 2003
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000400/2003005
Dear Mr. Scarola:
On July 25, 2003, the Nuclear Regulatory Commission (NRC) completed an inspection at the Shearon Harris Nuclear Power Plant. The enclosed report documents the inspection results, which were discussed on July 25, 2003, with Mr. R. Duncan and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.
On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The inspectors concluded that problems were properly identified, evaluated and resolved within the problem identification and resolution programs. However, during the inspection, several minor problems were identified related to thoroughness and effectiveness of corrective action.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web-site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Paul E. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.:
50-400 License No.:
Enclosure:
NRC Inspection Report No. 05000400/2003005 w/Attachment: Supplemental Information
REGION II==
Docket No:
50-400 License No:
NPF-63 Report No:
05000400/2003005 Licensee:
Carolina Power & Light Company (CP&L)
Facility:
Shearon Harris Nuclear Power Plant, Unit 1 Location:
5413 Shearon Harris Road New Hill, NC 27562 Dates:
July 7 - 11 and 20 - 25, 2003 Inspectors:
J. Zeiler, Senior Resident Inspector, Vogtle Electric Generating Plant (Lead Inspector)
R. Cortes, Reactor Inspector, Division of Reactor Safety R. Hagar, Resident Inspector, Harris Approved by:
P. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects
SUMMARY
OF ISSUES
IR 05000400/2003-005; 07/07-25/2003; Shearon Harris Nuclear Power Plant, Unit 1; Biennial baseline inspection of the identification and resolution of problems.
The inspection was conducted by a senior resident inspector, a resident inspector, and a Region II reactor inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems The licensee was effective at identifying problems at a low threshold and entering them into the corrective action program. The licensee properly prioritized issues and routinely performed adequate evaluations that were technically accurate and of sufficient depth. Formal root cause evaluations for significant conditions adverse to quality were especially thorough and detailed.
Corrective actions developed and implemented for problems were timely and effective, commensurate with the safety-significance of the issue. The licensees self-assessments and audits were effective in identifying deficiencies in the corrective action program. Based on discussions conducted with plant employees from various departments the inspectors did not identify any reluctance to report safety concerns. However, several minor problems were identified related to thoroughness and effectiveness of corrective action, and equipment deficiencies not properly entered into the corrective action program.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a.
Effectiveness of Problem Identification
- (1) Inspection Scope The inspectors reviewed Procedure CAP-NGGC-0200, Corrective Action Program, Revision (Rev.) 7, which describes the administrative process for initiating and resolving problems. A nuclear condition report (NCR) is initiated to document problems that are significant conditions adverse to quality (Priority 1), conditions adverse to quality (Priority 2), or improvement items (Priority 5).
The inspectors reviewed 153 NCRs from approximately 6300 that had been initiated by the licensee since July 2001 (coinciding with the last NRC baseline problem identification and resolution inspection) to verify that problems were being properly identified, appropriately characterized, and entered into the corrective action program (CAP). The reviews primarily focused on issues associated with five risk significant plant safety systems: emergency diesel generator (EDG), emergency service water (ESW), high head safety injection (HHSI), 125 volt DC, and 6.9 Kilovolt AC Distribution.
In addition to the system reviews, the inspectors selected a representative number of NCRs that were identified and assigned to the major plant departments which included operations, maintenance, engineering, security, chemistry, health physics, and emergency preparedness.
The inspectors reviewed completed maintenance work orders (WOs), system health reports, and the Maintenance Rule database for the five risk significant systems to verify that equipment deficiencies were being appropriately entered into the corrective action and Maintenance Rule programs. The inspectors conducted plant walkdowns of equipment associated with the EDG and ESW systems to assess the material condition and to look for any deficiencies that had not been entered into the CAP. The inspectors reviewed control room operator logs for January to February 2003 to verify that equipment deficiencies, especially those involving the five safety systems selected for the focused review, were entered in the CAP.
The inspectors reviewed selected industry operating experience items, including NRC generic communications, to verify that they were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP.
The inspectors reviewed licensee audits and self-assessments (focusing primarily on problem identification and resolution) to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.
The inspectors attended several plant daily status and unit evaluator meetings to observe management and unit evaluator oversight functions in the corrective action process. The inspectors also interviewed personnel from operations, maintenance, engineering, security, health physics, chemistry, and emergency preparedness to evaluate their threshold for identifying issues and entering them into the CAP.
Documents reviewed to support the inspection are listed in the Attachment.
- (2) Assessment The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP. NCRs normally provided complete and accurate characterization of the subject issues. In general, the threshold for initiating NCRs was low and employees were encouraged by management to initiate NCRs. Equipment performance issues involving maintenance effectiveness such as maintenance errors, poor maintenance work practices, and inadequate risk assessments were being identified at an appropriate level and entered into the CAP. However, the inspectors noted instances where NCRs were not always being initiated for Maintenance Rule equipment deficiencies when a maintenance work request was also opened. This could result in loss of equipment performance trending information and not provide a complete and timely recognition of equipment reliability problems.
The licensee was effective in evaluating internal and external industry operating experience items for applicability and entering issues into the CAP.
Department self-assessments and audits performed by the Nuclear Assessment Section (NAS) and the Performance Evaluation Support Section were effective in identifying issues and these deficiencies were entered into the CAP. NAS audits were particularly self-critical and identified substantive issues or directed attention to areas that needed improvement. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
b.
Prioritization and Evaluation of Issues
- (1) Inspection Scope The inspectors evaluated the same 153 NCRs and operating experience items discussed in Section 4OA2.a to verify that the licensee appropriately prioritized and evaluated problems in accordance with Procedure CAP-NGGC-0200. While the majority of NCRs reviewed were classified as Priority 2, the sample also included a representative number of Priority 1 and Priority 5 NCRs. The inspectors review was also intended to verify that the licensee adequately determined the cause of the problems and adequately addressed operability, reportability, common cause, generic concerns, and extent of condition. For significant conditions adverse to quality, the review was also to verify that the licensee adequately addressed the root and contributing causes and appropriately identified corrective actions to prevent recurrence.
The inspectors also reviewed a sample of voided NCRs to verify they were voided for the appropriate reasons.
- (2) Assessment The inspectors determined that the licensee properly prioritized issues entered into the CAP in accordance with Procedure CAP-NGGC-0200. Generally, the licensee performed adequate evaluations that were technically accurate and of sufficient depth.
Formal root cause evaluations for Priority 1 NCRs were especially thorough and detailed. The inspectors did not identify any risk significant issues that had not been appropriately prioritized and evaluated. However, the inspectors identified several minor problems involving NCRs that lacked thorough investigations and minor documentation discrepancies. These issues included the following:
- NCR 60174, A EDG circuit breaker tripped during light bulb replacement: This NCR addressed the tripping of DC control power to the EDG while an operator was attempting to replace a light bulb for the operational light indication on the diesel panel. The NCR stated that the cause of the condition was known to be a result of inadvertent operator action. However, the NCR was closed as No Further Investigation Required, without providing any details regarding what the inadvertent action was or how this implied human performance error was addressed. Upon discussing the NCR with the EDG system engineer, the inspectors learned that a similar problem occurred five months after the first incident involving the same light indication socket. The licensees investigation into the second incident identified a generic problem with the light socket design.
The inspectors determined that the licensee missed an opportunity to identify the real problem earlier due to lack of a thorough investigation. The licensee considered this another example of similar problems that had previously been identified and were addressing as part of NCR 47417.
- NCR 63108, EDG self-assessment weakness, and NCR 71959, Maintenance Rule functional failure on EDG starting air compressor: These NCRs described instances where the licensee failed to classify several spurious EDG starting air compressor circuit breaker trips as Maintenance Rule functional failures. While the cause was identified as incorrect Maintenance Rule database entries by the system engineer, corrective actions were limited to replacing the circuit breaker and updating the Maintenance Rule database to reflect the proper classifications.
The inspectors noted that there was no other discussions regarding why the system engineer failed to properly classify the failures or address corrective actions for this causal factor. This issue was entered into the CAP as NCR 99414.
c.
Effectiveness of Corrective Actions
- (1) Inspection Scope The inspectors evaluated the same 153 NCRs and operating experience items discussed in Section 4OA2.a to verify that the licensee had identified and implemented timely and appropriate corrective actions to address problems. The inspectors verified that the corrective actions were properly documented, assigned, and tracked to ensure completion. Where possible, the inspectors independently verified that corrective actions were implemented as intended. For significant conditions adverse to quality, the review was to verify that effectiveness reviews were adequately performed as required by Procedure CAP-NGGC-0200. The review was also to verify the adequacy of corrective actions to address equipment deficiencies and Maintenance Rule functional failures of the five risk significant plant safety systems that were selected for the focused review as discussed in Section 4OA2.a.
- (2) Assessment Overall, corrective actions developed and implemented for problems were timely and effective, commensurate with the safety significance of the issues. However, several minor problems were identified related to corrective action effectiveness. These issues included the following:
- NCR 91818, Entry into AOP-14: This Priority 1 NCR documented a component cooling water (CCW) system surge tank pressure transient. One of numerous corrective actions identified was to revise the CCW system operation lineup procedure to change the sequence of valve manipulations during normal operations in order to minimize the potential for pressure transients in the CCW surge tank. The inspectors identified that the licensee failed to enter a tracking assignment (CORR) for this item. As a result, the procedure change had not been initiated. The inspectors considered this a minor issue since the procedure change was determined to be an enhancement item. The primary corrective actions, which included system design changes, were implemented to address the initial problem. Also, the inspectors noted that the licensees effectiveness review had not been completed yet for this NCR and one of the expected review items was to verify that assignment tracking items were initiated for corrective actions. The licensee initiated NCR 99784 to address the assignment tracking error.
- NCR 51865, High air particulate release from equipment hatch: This NCR described a release of radioactive particulate material which caused the annual goal for such releases to be exceeded. The investigation identified three apparent causes, and the corresponding report listed three corrective actions.
The report indicated that all three corrective actions were complete, but did not identify the assignment type or responsible group for any action. The inspectors learned that the listed actions were in fact not completed; instead, the licensee completed an alternative to one of the listed actions, and did not complete either of the other actions because they had determined that one was inappropriate and the other was unnecessary. The inspectors considered that the alternative corrective action was adequate to address the adverse condition, without the uncompleted actions. The licensee addressed this issue in NCR 99608 as one example of inadequate documentation of completed corrective actions.
- NCR 88091, Equipment deficiency leads to dilution event: This NCR described a reactor coolant system dilution event that resulted from inadequate maintenance performed on a reach rod for a chemical and volume control system diaphragm valve. The primary corrective action developed was to include a preventive maintenance checklist activity in the planning of any work orders involving corrective maintenance on reach rod operated diaphragm valves. The inspectors noted that the manner in which the new checklist was added to the work planning database would not ensure that the person planning the valve work would know to include the checklist. The licensee addressed this issue by reopening NCR 88091 and providing more specific work planner instructions for ensuring the checklist would be included in future corrective WOs. The inspectors considered this an example where corrective actions were not completely effective.
d.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope During technical discussions with members of the plant staff, to include operations, maintenance, engineering, chemistry, health physics, emergency preparedness, and security personnel, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors also reviewed the licensees employee concerns program (ECP) which provides an alternate method to the C for employees to raise concerns and remain anonymous. The inspectors interviewed the ECP Coordinator and reviewed a select number of ECP reports completed since July 2001 to verify that concerns were being properly reviewed and identified deficiencies were being resolved in accordance with Procedure REG-NGGC-0001, Employee Concerns Program.
- (2) Assessment The inspectors concluded that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs. All of the predominant methods established by the licensee, including the CAP, the WO system, and the ECP, were readily accessible to all employees. Licensee management encouraged all employees to promptly identify nonconforming conditions. Based on discussions conducted with plant employees from various departments, the inspectors did not identify any reluctance to report safety concerns.
4OA6 Management Meetings
The inspectors presented the inspection results to Mr. R. Duncan, and other members of licensee management at the conclusion of the inspection on July 25, 2003. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- J. Caves, Supervisor - Licensing/Regulatory Programs
- F. Diya, Superintendent - Systems Engineering
- R. Duncan, Director - Site Operations
- W. Gurganious, Manager - Nuclear Assessment
- A. Khanpour, Manager - Harris Engineering
- S. Larson, Quality Control
- E. McCartney, Training Manager
- G. Miller, Maintenance Manager
- T. Morton, Manager - Support Services
- T. Natale, Manager - Outage and Scheduling
- T. Pilo, Supervisor - Emergency Preparedness
- J. Scarola, Vice President Harris Plant
- G. Simmons, Superintendent - Radiation Control
- B. Waldrep, General Manager Harris Plant
- E. Wills, Operations Manager
- M. Wallace, Licensing Specialist
NRC personnel
- R. Musser, Senior Resident Inspector, Harris
- L. Plisco, Director, Division of Reactor Projects, RII
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None.