IR 05000400/2020001

Integrated Inspection Report 05000400/2020001

ML20128J492
Person / Time
Site:	Harris
Issue date:	05/07/2020
From:	Stewart Bailey NRC/RGN-II/DRP/RPB4
To:	Maza K Duke Energy Progress
References
IR 2020001
Download: ML20128J492 (18)

Text

May 7, 2020

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000400/2020001

Dear Ms. Maza:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Power Plant. On April 22, 2020, 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.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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 Shearon Harris Nuclear Power Plant.

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 Shearon Harris Nuclear Power Plant. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No. 05000400 License No. NPF-63

Enclosure:

As stated

Inspection Report

Docket Number: 05000400 License Number: NPF-63 Report Number: 05000400/2020001 Enterprise Identifier: I-2020-001-0036 Licensee: Duke Energy Progress, LLC Facility: Shearon Harris Nuclear Power Plant Location: New Hill, NC 27562 Inspection Dates: January 01, 2020 to March 31, 2020 Inspectors: A. Patz, Resident Inspector J. Zeiler, Senior Resident Inspector Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Shearon Harris Nuclear Power Plant, 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.

List of Findings and Violations

Failure to Identify and Correct Condition Adverse to Quality on Safety-Related 125 VDC Emergency Battery Terminals Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.04 Systems NCV 05000400/2020001-01 Resolution Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct conditions adverse to quality involving corrosion mitigation measures to address a known long-standing battery manufacturing deficiency associated with both trains of safety-related 125 Volt direct current (VDC) emergency batteries. As a result, battery terminal connections experienced accelerated corrosion related degradation over time.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power until March 23, 2020, when maintenance on the turbine trip system inadvertently caused a trip of the reactor. After troubleshooting, Unit 1 was restarted on March 24, 2020, and returned to near rated thermal power on March 26, 2020. Unit 1 remained at rated thermal power for the remainder of the 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week during which they conducted plant status activities as described in IMC 2515, Appendix D, and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to reschedule the inspection to a later date.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 'A' essential services chilled water (ESCW) system while 'B' ESCW was out of service for emergent compressor oil leak repair on January 19, 2020

(2) 'B' residual heat removal (RHR) system while 'A' RHR system was out-of-service for planned maintenance on January 21, 2020

(3) 1A-SA and 1B-SB safety-related 125 VDC emergency batteries on February 10, 2020

(4) 'A' and 'B' motor driven auxiliary feedwater systems while the turbine driven auxiliary feedwater system was out of service for testing on March 9, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Reactor Auxiliary Building (RAB) 261' elevation 'A' and 'B' train ESCW system areas (fire zone 1-A-4-CHLR) on January 20, 2020

(2) 'A' emergency diesel generator (EDG) room and support equipment areas (fire zones 1-D-1-DGA-RM, 1-D-3-DGA-ES, 1-D-DTA, 1-D-1-DGA-ASU, and 1-D-1-DGA-ER) on January 22, 2020

(3) RAB 286' elevation 'A' train essential switchgear room, ventilation room, and vital and non-vital battery rooms (fire zones 1-A-SWGRA, 1-A-BAL-J, 1-A-BATA, and 1-A-5-BATN) on February 12, 2020

(4) Emergency Service Water (ESW) pump intake and pump intake screening structures (fire zones 12-I-ESWPA, 12-I-ESWPA-BAL, 12-I-ESWPB, 12-I-ESWPB-BAL, and 5-S-BAL) on March 4, 2020

(5) RAB 305' elevation heating, ventilating, and air conditioning equipment room (fire zone 12-A-6-HV7) on March 5, 2020

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) The inspectors observed and evaluated licensed operator performance in the Control Room during control rod testing and exercising on February 27, 2020

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a simulator scenario for operator training involving a steam generator tube leak followed by a small break loss of coolant accident on February 5, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) 'A' and 'B' containment recirculation sump level transmitters found out of tolerance on October 16-17, 2019

(2) 'B' ESCW chiller experienced excessive chill water outlet temperature oscillations due to faulty hot gas bypass valve actuator control on December 26, 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 accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Elevated (Green) risk during unplanned unavailability of the 'B' ESCW system due to compressor oil filter piping repairs on January 18-20, 2020

(2) Elevated (Green) risk during planned unavailability of the 'B' EDG for corrective maintenance on February 4, 2020

(3) Elevated (Green) risk during unplanned unavailability of the 'B' EDG due to emergent failure of the jacket water heater on February 5, 2020

(4) Elevated (Green) risk during unplanned unavailability of normal control room ventilation equipment and reactor auxiliary building air conditioning equipment on March 2, 2020

(5) Elevated (Green) risk during planned unavailability of the steam generator power-operated relief valves (PORVs) during surveillance testing on March 13, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Gas void area was identified using ultrasonic instrumentation on November 8, 2019 and December 3, 2019 during testing of emergency core cooling system piping (Nuclear Condition Reports (NCRs) 02301464 and 02305497)

(2) Containment isolation valve 1RC-161, Reactor Makeup Water to Containment, had dual indication while attempting to stroke time test on January 10, 2020 (NCR

===02310202)

(3) 'B' EDG jacket water heater breaker experienced hard electrical ground causing heater failure and decreasing jacket water temperature on February 5, 2020 (NCR 02314385)

(4) Corrosion and electrolyte residue identified on safety related battery terminals on February 10, 2020 (NCR 02316234)

(5) Reactor Auxiliary Building Emergency Exhaust System (RABEES) boundary testing failure on March 6, 2020 (NCR 02319578)

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) Permanent Modification EC 0000415683, Auto-Stop Turbine Quadvoter Solenoid Operated Valve Pilot Valve Modification, on March 31, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) ===

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Operations Periodic Test (OPT)-1512, Essential Chilled Water Turbopack Units Quarterly Inspection/Checks Modes 1-6, following repair of 'B' ESCW compressor oil filter housing pipe leak on January 20, 2020

(2) Work Order (WO) 20382354 instructions and Operating Procedure (OP)-155, Diesel Generator Emergency Power System, following emergent replacement of failed 'B' EDG jacket water heater on February 5, 2020

(3) OP-169, Containment Cooling and Ventilation, following breaker contactor replacement for containment cooling fan AH-4 B-SB on February 25, 2020

(4) WO 20365941, perform quarterly functional test of 1FLX-042 FLEX mitigating strategies diesel following replacement of engine control module on March 5, 2020

(5) Operation Surveillance Test (OST)-1052, Reactor Auxiliary Building Emergency Exhaust System Operability, 18 Month Interval, following RABEES boundary testing failure on March 6, 2020

(6) OPT-1509, Turbine Trip Tests Modes 1 and 2, following partial implementation of modification EC 415683 replacing turbine trip solenoid valve 1EH-159A on March 10, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) OST-1861, Remote Shutdown: Individual Component Tests, 36 Month Interval, on January 7, 2020

(2) OST-1823, 1A-SA Emergency Diesel Generator Operability Test 18 Month Interval Modes 1 Through 6 and Defueled, on January 22, 2020

(3) OST-1005, Control Rod and Rod Position Indicator Exercise Quarterly Interval Modes 1-3, on February 23, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) OST-1411, Auxiliary Feedwater Pump 1X-SAB Operability Test Quarterly Interval Modes 1, 2, 3, on March 11, 2020

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) OST-1076, Reactor Coolant System Leakage Evaluation, Computer Calculation, Daily Interval, Modes 1-4, on January 28,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

(1) Unit 1 (January 1, 2019 - December 31, 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) Unit 1 (January 1, 2019 - December 31, 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) Unit 1 (January 1, 2019 - December 31, 2019)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Review of control rod test results from Fall 2019 refueling outage indicated control bank D rod F-10 dropped from step 16 while being manually inserted into the reactor core (NCR 02310117)

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated the unexpected automatic reactor trip due to a loss of turbine electrohydraulic fluid pressure and licensees response on March 23,

INSPECTION RESULTS

Failure to Identify and Correct Condition Adverse to Quality on Safety-Related 125 VDC Emergency Battery Terminals Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.04 Systems NCV 05000400/2020001-01 Resolution Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct conditions adverse to quality involving corrosion mitigation measures to address a known long-standing battery manufacturing deficiency associated with both trains of safety-related 125 VDC emergency batteries. As a result, battery terminal connections experienced accelerated corrosion related degradation over time.

Description:

On February 10, 2020, the inspectors identified visual corrosion and electrolyte residue on the positive terminal connections of 40-50 battery cells associated with the 1A-SA safety-related 125 VDC emergency battery. All 60 of the 1A-SA battery cells contained one or more through wall cracks in the battery cell cover lids, normally emanating from the positive post terminals to the battery cell containers closest corner from the post. In addition, the battery terminal connections were noticeably lacking in the amount of anti-corrosion material applied and the anti-corrosion that was present appeared discolored and aged. There was much less corrosion, if any, on the battery terminal connections associated with the 1B-SB battery cells and noticeably more anti-corrosion material present on the terminals. Similar cover lid cracks were present on approximately 42 cells of the 1B-SB battery. The inspectors reviewed the recently completed (on January 23, 2020) quarterly preventive maintenance and surveillance conducted on the 1A-SA battery and noted that corrosion had to be removed from virtually every positive terminal of the cells. However, the as-found battery terminal resistance testing results that were conducted at the time indicated acceptable resistance. The inspectors were concerned that visual corrosion and electrolyte residue had unexpectedly reappeared on the battery terminals of a significant number of battery cells in only eighteen days. Based on the degraded material condition of the 1A-SA battery cells, the inspectors conducted a more detailed review of the licensees previous actions to address battery cover lid cracks and battery terminal corrosion mitigation measures. As a result of this review, the inspectors identified the following discrepancies related to why accelerated battery terminal corrosion was occurring:

• The licensee failed to implement manufacturer recommended actions designed to mitigate the formation of corrosion due to a known deficiency in the battery manufacturing process. On January 20, 2016, the licensee initiated NCR 01993202 to evaluate unexpected battery cell cover lid through wall cracking in the recently replaced C&D Technologies (manufacturer) Model LCR-19 batteries. The 1A-SA battery was replaced in February 2009 and 1B-SB battery was replaced in October 2010. At the time of the evaluation, 8 of the 60 battery cells on the 1A-SA battery had cover lid cracks and 9 of the 60 battery cells showed signs of positive post seal deformity/expansion. The 1B-SB battery had no indications of cover lid cracks or post seal deformities at that time. The manufacturer acknowledged that model LCR batteries, that were manufactured prior to 2011, were prone to premature cover lid cracking due a battery manufacturing problem. This problem allowed nodular corrosion formation at the lead to rubber bushing interface and wicking of electrolyte up through this interface onto the top of the battery cell cover lids. The nodular corrosion caused deformation of the battery post seals and cover lid cracks due to corrosion induced stress forces at the battery post-to-cover interface. While the manufacturer believed the cracks would not affect the immediate reliability or performance of the batteries, three actions were recommended to minimize further corrosion growth on the batteries. These three action items included: 1) more frequent neutralization of all areas exterior to the battery cell exposed to electrolyte wicking up through the battery posts, 2) keeping the electrolyte level in all battery cells midway between the lower and upper fill marks to mitigate gassing (burping) of electrolyte wicking through the posts, 3) repairing all cracks with manufacturer provided adhesive to limit electrolyte and corrosion from forming on the terminals. During review of NCR 01993202, the inspectors identified that only action item #1 was implemented, although, the licensee had intended to implement all three items. The inspectors concluded that due the licensees failure to implement the remaining actions designed to mitigate the adverse impact from battery corrosion, the batteries had experienced accelerated corrosion related degradation over time.

• The licensee failed to implement adequate procedures for applying anti-corrosion material on the battery terminals and conducting resistance measurements as prescribed by Technical Specifications (TS), committed battery industry standards, and manufacturer vendor manuals. TS Surveillance Requirement (SR) 4.8.2.1.c.2 requires: verifying that(battery) cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material, and TS SR 4.8.2.1.c.3 requires: the resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 10-6 ohm. The LCR-19 batteries contained two positive and two negative terminal posts per cell, therefore, resistance measurements were required for each of the four posts. Maintenance Surveillance Test (MST)-E0027, 1E Battery Cell Connection Resistance and Service Test, was used to implement TS SR 4.8.2.1.c.2 and 4.8.2.1.c.3. The inspectors determined that the procedure was inadequate since it only directed anti-corrosion material to be applied if resistance measurements were outside the allowable range or the battery connections had to be disassembled. In addition, resistance measurements were only required to be performed on one of the positive and negative terminal posts (in the outer-most post locations). The inspectors learned from interviews with battery maintenance technicians that the battery connections on the 1A-SA and 1B-SB battery had not been re-coated with anti-corrosion material since the original installation of the batteries in 2009 and 2010, respectively. In addition, resistance measurements had never been performed on the inside positive and negative battery terminals. The inspectors noted that when terminal and connection cleaning was performed periodically to remove observed corrosion, anti-corrosion material was also being removed, and over time this practice had left many terminal surfaces with less than adequate film of anti-corrosion protection. Since anti-corrosion material was not being re-applied periodically, the battery terminals were more vulnerable to corrosion formation. The inspectors concluded that the failure to maintain adequate anti-corrosion material on the 1A-SA battery contributed to the accelerated corrosion that was being experienced on the battery cells; however, the underlying cause was the result of not implementing the 2016 intended manufacturer actions to address the accelerated corrosion impact from the manufacturing deficiency.

Corrective Actions: Beginning March 11, 2020, the licensee conducted as-found battery cell-to-cell and terminal connection resistance measurements on the 1A-SA battery terminal connections to verify that as-found corrosion conditions had not resulted in resistance in excess of acceptable values. Battery connections with visual signs of corrosion were cleaned, neutralized, and anti-corrosion material was re-applied. The licensee revised battery preventive maintenance and surveillance procedures to include actions to assess the condition of anti-corrosion material on battery terminals and connections in order to decide if anti-corrosion material needed to be re-applied even if resistance measurements were not outside the acceptable range or if the connections were disassembled. Subsequent actions were implemented to revise MST-E0027 to include resistance measurements for all four of the battery terminal posts. Works orders were initiated to implement the missed manufacturer recommended corrosion mitigation actions. In addition, actions were initiated to evaluate upgrading the batteries with models that were not susceptible to nodular corrosion and electrolyte leakage at the battery terminal post seal interface.

When subsequent resistance measurements were conducted on the two inside battery positive and negative terminal posts that had not been previously tested on both the 1A-SA and 1B-SB batteries, the results indicated that the terminal resistances were not in excess of acceptable values. Based on this, the inspectors concluded that the NRC-identified procedural inadequacies in MST-E0027 was a minor violation of TS 6.8.1.a, for the failure to implement adequate procedures required by TS SRs.

Corrective Action References: NCRs 02316234 and 02320227

Performance Assessment:

Performance Deficiency: The licensees failure to implement manufacturer recommended actions designed to mitigate the formation of corrosion due to a known battery manufacturing deficiency was a performance deficiency. This resulted in accelerated corrosion buildup on cell-to-cell and terminal connections associated with the safety-related 125 VDC batteries.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to adequately implement corrective actions designed to mitigate the impact from battery corrosion caused by a battery manufacturing deficiency, if left uncorrected, excessive corrosion buildup had the potential to degrade the battery cell-to-cell and terminal connections that could have led to inability of the battery to perform its safety-related function following a design basis event.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened by Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined this finding was of very low safety significance (Green) because: it was not a design deficiency; did not represent a loss of the probabilistic risk assessments (PRA) function of a single, multi-train, or two separate TS systems for longer than its TS allowed outage time or for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and, did not represent a loss of the PRA function of one or more non-TS trains of risk significant equipment as defined under the maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensee previously identified battery corrosion mitigation corrective actions to address a manufacturing deficiency; however, the licensee failed to implement the intended corrective actions resulting in accelerated corrosion degradation of the safety-related battery terminals. While the failure to implement battery corrosion mitigation measures occurred greater than three years ago, the inspectors determined this cross-cutting aspect was reflective of current licensee performance since several chronic equipment reliability issues have occurred recently, most notably, associated with turbine auto-stop-trip system and ESCW. The underlying cause of these issues were attributed to inadequacies in licensee corrective actions.

Enforcement:

Violation: Title 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, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, between January 2016, to March 11, 2020, the licensee failed to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Specifically, the licensee failed to adequately implement manufacturer recommended corrective actions designed to mitigate corrosion caused by a battery manufacturing deficiency. As a result of not implementing the corrosion mitigation measures, the condition of the safety-related 125 VDC emergency battery terminals and connections continued to degrade due to accelerated corrosion conditions.

Enforcement Action: This violation is being treated as an non-cited violation, 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 April 22, 2020, the inspectors presented the integrated inspection results to Kim Maza and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action NCR 02316234 Residue on safety battery positive terminals 02/14/2020

Documents NCR 02320227 Gaps between TS SR 4.8.2.1 and maintenance procedures 03/10/2020

Resulting from

Inspection

Miscellaneous ANSI/IEEE IEEE Recommended Practice for Maintenance, Testing, and October 24,

Standard 450- Replacement of Large Lead Storage Batteries for 1980

1980 Generating Stations and Substations

IEEE Standard IEEE Recommended Practice for Maintenance, Testing, and February 25,

450-2010 Replacement of Vented Lead-Acid Batteries for Stationary 2011

Applications

Regulatory Guide Maintenance and Testing and Replacement of Large Lead February

1.129 Storage Batteries for Nuclear Power Plants 1978

Vendor Manual Battteries and Chargers Rev. 28

VM-PAA

Procedures MST-E0010 1E Battery Pilot Cell Test Rev. 18

MST-E0011 1E Battery Quarterly Test Rev. 18

MST-E0013 1E Battery Performance Test Rev. 20

MST-E0027 1E Battery Cell Connection Resistance and Service Test Rev. 20

OP-111 Residual Heat Removal System Rev. 63

OP-137 Auxiliary Feedwater System Rev. 46

OP-148 Essential Services Chilled Water System Rev. 80

OP-156.01 DC Electrical Distribution Rev. 39

71111.05 Fire Plans CSD-HNP-PFP- Diesel Generator Building Pre-Fire Plan Rev. 1

DGB

CSD-HNP-PFP- Reactor Auxiliary Building Elevation 261 Pre-Fire Plan Rev. 1

RAB-261

CSD-HNP-PFP- Reactor Auxiliary Building Elevation 286 Pre-Fire Plan Rev. 1

RAB-286

CSD-HNP-PFP- Reactor Auxiliary Building Elevations 305 and 324 Pre-Fire Rev. 4

RAB-305-324 Plan

CSD-HNP-PFP- Out Building Pre-Fire Plan Rev. 5

SEC

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous Fire Protection Permit and Impairment Log Entries

Procedures AD-EG-ALL-1520 Transient Combustible Control Rev. 12

FPP-001 Fire Protection Program Manual Rev. 44

FPP-013 Fire Protection - Minimum Requirements, Mitigating Actions Rev. 102

and Surveillance Requirements

71111.11Q Corrective Action NCR 02310117 Rod F-10 likely dropped from step 16 during last refueling 01/09/2020

Documents outage testing

Procedures Malfunction of Rod Control and Indication System Rev. 53

AOP-001

AD-OP-ALL-1000 Conduct of Operations Rev. 17

AOP-010 Feedwater Malfunctions Rev. 40

AOP-015 Secondary Load Rejection Rev. 29

AOP-016 Excessive Primary Plant Leakage Rev. 58

EOP-E-0 Reactor Trip or Safety Injection Rev. 15

EOP-E-1 Loss of Reactor or Secondary Coolant Rev. 5

EOP-ECA-1.1 Loss of Emergency Coolant Recirculation Rev. 4

OMM-001 Operations Administrative Requirements Rev. 117

OST-1005 Control Rod and Rod Position Indicator Exercise Quarterly Rev. 25

Interval Modes 1-3

71111.12 Corrective Action NCR 02198476 As found data for LIT-7160A containment level transmitter 04/13/2018

Documents deviated more than 0.040 vdc

NCR 02297310 'A' Containment recirculation sump level transmitter out of 10/16/2019

tolerance

NCR 02297562 'B' Containment recirculation sump level transmitter out of 10/17/2019

tolerance

NCR 02308559 WC-2B Excessive Temperature Cycling 12/26/2019

Procedures AD-EG-ALL-1210 Maintenance Rule Program Rev. 2

Design Basis Containment Spray System Rev. 18

Document (DBD)-

106

Work Orders WO 20373568 Troubleshooting to repair oscillations in B-SB ESCW chiller 12/28/2019

chill water outlet temperature

71111.13 Calculations HNP-F/PSA-0119 Online Phoenix PRA Model Rev. 1

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action NCR 02318609 Control room exhaust isolation valve, 1CZ-3, failed to open 03/02/2020

Documents NCR 02318611 1CH-703 failed to move for OST-1411 03/02/2020

NCR 02318759 Loss of indication when AH-7B secured 03/02/2020

Procedures AD-NF-ALL-0501 Electronic Risk Assessment Tool (ERAT) Rev. 4

AD-WC-ALL- On-Line Work Management Rev. 15

200

AD-WC-ALL- On-Line Risk Management Process Rev. 1

240

AD-WC-ALL- Work Activity Integrated Risk Management Rev. 9

0410

OST-1141 B Train HVAC Safety-Related ESCW TCVS ISI Operability Rev. 27

Test, Quarterly Interval, Modes 1-6

OST-1191 Steam Generator PORV and Block Valve Operability Test Rev. 32

Work Orders WO 20378550 Replace oil filter assembly including failed piping on 'B' 1/20/2020

ESCW chiller

71111.15 Procedures AD-OP-ALL-0105 Operability Determinations and Functionality Assessments Rev. 5

OST-1052 Reactor Auxiliary Building Emergency Exhaust System Revs. 28 and

Operability Test, 18 Month Interval, All Modes 29

OST-1104 Containment Isolation Inservice Inspection Valve Test Rev. 55

Quarterly Interval Modes 1-6

OST-1107 ECCS/Containment Spray Flow Path and Piping Filled Rev. 38

Verification Monthly Interval Modes 1-6

Work Orders WO 20382354 Troubleshooting 'B' EDG jacket water heater breaker 2/5/2020

electrical ground

71111.18 Miscellaneous Action Request Perform 50.59 Screen for AST Quadvoter SOV Pilot Valve 02/13/2020

297535 Modification

Work Orders WO 20339948 EC 415683, AST Quadvoter Mod 03/10/2020

71111.19 Procedures PLP-400 Post Maintenance Testing Rev. 64

Work Orders WO 20339948 Replacement of turbine trip solenoid valve 1EH-159A under 3/10/2020

modification EC 415683

WO 20378550 Repair 'B' ESCW chiller compressor oil filter piping leakage 1/20/2020

WO 20384627 Investigate buzzing sound from electrical breaker for 2/25/2020

containment cooling fan AH-4 B-SB

71111.22 Procedures AD-HU-ALL-0105 Human Performance Tools Rev. 4

Inspection Type Designation Description or Title Revision or

Procedure Date

71151 Procedures NEI 99-02 Regulatory Assessment Performance Indicator Guideline Rev. 7

71152 Procedures AD-PI-ALL-0100 Corrective Action Program Rev. 22

AD-PI-ALL-0102 Apparent Cause Evaluation Rev. 4

AD-PI-ALL-0106 Cause Investigation Checklists Rev. 4

71153 Corrective Action NCR 02321895 Unexpected reactor trip 03/23/2020

Documents

Miscellaneous VM-TCS-V08 Turbine Control System Triconex Operation Manuals Rev. 2

Procedures E-0 Reactor Trip or Safety Injection Rev. 15

EOP-ES-0.1 Reactor Trip Response Rev. 4

OMM-001 Operations Administrative Requirements Rev. 117

OMM-004 Post Trip/Safeguards Actuation Review Rev. 42

15