IR 05000400/2021010
| ML21364A165 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/28/2021 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Maza K Duke Energy Progress |
| References | |
| IR 2021010 | |
| Download: ML21364A165 (10) | |
Text
December 28, 2021
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - TRIENNIAL INSPECTION OF EVALUATION OF CHANGES, TESTS AND EXPERIMENTS BASELINE INSPECTION REPORT 05000400/2021010
Dear Ms. Maza:
On November 19, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Power Plant and 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.
No findings or violations of more than minor significance were identified during this inspection.
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/
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety
Docket No. 05000400 License No. NPF-63
Enclosure:
As stated
Inspection Report
Docket Number:
05000400
License Number:
Report Number:
Enterprise Identifier: I-2021-010-0044
Licensee:
Duke Energy Progress, LLC
Facility:
SHEARON HARRIS NUCLEAR POWER PLANT
Location:
New Hill, NC.
Inspection Dates:
November 15, 2021 to November 19, 2021
Inspectors:
P. Braxton, Reactor Inspector
T. Fanelli, Senior Reactor Inspector
T. Su, Reactor Inspector
Approved By:
James B. Baptist, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial inspection of evaluation of changes, tests and experiments baseline 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000400/2021010-01 Treatment of Class 1E interfaces and interlocks with the Turbine Trip System Design 71111.17T Open
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 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.
REACTOR SAFETY
71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)
The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from [enter dates].
(1)50.59 Evaluation: EC 284334-HNP Turbine Control System Upgrade - Cable &
Raceway, 5/11/2018 (2)50.59 Evaluation: EC 284333-HNP Turbine Control System Upgrade - Main Control Board Changes, 5/12/2018 (3)50.59 Evaluation: EC 414172-Turbine Valve FSAR Update, 1/20/2021 (4)50.59 Evaluation: EC 418016 Core/Reactor DESG Revise PLP-114 Subcritical Minimum Duration for Fuel Offload (EAR 2312872), 3/29/2021 (5)50.59 Evaluation: EC 403209 Non-Conservative T/S for EDG Voltage, 1/03/2019 (6)50.59 Evaluation: EC 284339 Turbine Control System Upgrade - Front Standard Modifications, 5/12/2018 (7)50.59 Evaluation: EC 296136 Incorporate NSAL 14-2 Into Plant Documents, 6/11/2020 (8)50.59 Screening: EC 284170- 480V Motor Control Center Bucket Replacement, 11/21/2019 (9)50.59 Screening: EC 413640- Safe Shutdown MCCB Testing Programmatic Change,
11/13/2018 (10)50.59 Screening: EC 417418-Evaluate Replacement of Cable 10943A-SA,
5/12/2020 (11)50.59 Screening: EC 419323-Permanent Change to TCS Time Constraints to Allow Testing Per OPT-1509, 6/10/2021 (12)50.59 Screening: EC 293260 RMS Migration to The Distributed I&C System Platform (DICSP) / Abandonment of Non-Critical Plant Radiation Monitors (Rm-80s),7/10/2019 (13)50.59 Screening: EC 410354 HNP Cycle 23 Tech Spec Changes - Site Impacts, 1/13/2020 (14)50.59 Applicability Determination: EC 292421 6.9 KV Breaker Replacement RFO 19, 20 and 21, 11/14/2019 (15)50.59 Applicability Determination: EC 295762 EDG Full Load Rejection Voltage Low Margin, 10/15/2018 (16)50.59 Applicability Determination: EC 401808 MSSV Tolerance and Pressurizer Level Setpoint Tech Spec Changes, 3/20/2018 (17)50.59 Applicability Determination: EC 414770 Migration to The Distributed I&C System Platform (DICSP) / Abandonment of Non-Critical Plant Radiation Monitors (Rm-80s), 12/19/2019 (18)50.59 Applicability Determination: EC 417073 Power Supply To Remote Monitoring Equipment IMAC (Intelligent Monitoring & Analytics Center), 07/14/2021
INSPECTION RESULTS
Unresolved Item (Open)
Treatment of Class 1E interfaces and interlocks with the Turbine Trip System Design URI 05000400/2021010-01 71111.17T
Description:
The NRC identified an Unresolved Item (URI) while examining modifications to the main turbine trip system. The Harris Turbine Trip System (TTS) was updated and modified to digital controls using non-Class 1E Engineering Change (EC) packages. The inspectors noted that the turbine trips were generated from the Reactor Protection System (RPS) apparently to prevent and mitigate accidents, and thus appear to be safety related functions (Class-1E).
The inspectors noted the following design requirements and specifications. The Updated Final Safety Analysis Report (UFSAR) in Section 7.1, Introduction, specified that the Reactor Protection System (RPS) circuits identified in Sections 7.2, Reactor Trip System, and 7.3, Engineered Safety Features System, met the requirements in IEEE Std. 279-1971 and IEEE Standard 384-1974 and conform to Regulatory Guide 1.75, Physical Independence of Electrical Systems. Additionally, UFSAR Sections 7.2.1.1.1 Functional Performance Requirements, 7.2.1.1.2, Reactor Trips, and 7.3.1.1.3 Digital Circuitry, discusses the TTS to mitigate plant events when initiated by the RPS.
The Class 1E power system design requirements and specifications discussed in the UFSAR subsection 8.3.1.2.30, IEEE Standard 384-1974, specifies, in part, 8) Cables and conduits routed in non-Category 1 structures associated with safety related functions or anticipatory trips (i.e., turbine trip on reactor trip, reactor trip on turbine trip, loss of feedwater) are designed to meet IEEE-Standard 279-1971 including redundancy, separation, and single failure criteria (see detailed description in Section 7.2.1.1.2). These circuits are designated as safety related and identified similar to the reactor protection system channels as described in Section 8.3.1.3. Separation of these circuits is maintained from other reactor trip circuits by routing each of these circuits independently in a separate conduit from the actuating device to the Reactor Protection System cabinet.
In addition, Westinghouse Electric Company (WEC) letter CQL-8627, Subject: Carolina Power & Light Company Shearon Harris Nuclear Power Plant Turbine Trip on Reactor Trip Criteria, dated 2/21/1985, prior to licensing, specified that WEC consistently maintained that these circuits are part of the Reactor Protection System and are thus Class 1E even though they terminate at unqualified equipment. The inspectors noted that the discussions in the UFSAR Sections 7 and 8 appear to agree with this WEC letter in that the turbine trip when initiated from the RPS appear to describe Class 1E functions that use Class 1E power criteria.
URI Item 1. The inspectors reviewed Engineering Change (EC) packages to determine the quality of interfaces between the TTS and the RPS and where this interface occurs. EC-284243, [Turbine Control System] TCS Base/System Integration tested and qualified the TTS functions and actuation devices (hydraulic trip solenoid valves) as non-Class 1E. The inspectors noted that this could have adverse implications on the qualification, functional performance, and installation of the turbine trips as described in the UFSAR Section 7 and 8.
The TTS functions generated by the RPS now resides in non-Class 1E programmable logic controllers (PLCs). The functional performance of these components did not appear to be verified in accordance with Appendix B, Criterion 7. As an example, the inspectors identified that the licensee performance specifications indicated a required a normally energized solenoid valve in an ambient environment of 149 °F. The energized state would increase the solenoid valve temperature significantly; however, the test documents provided back to the licensee specified that the testing was at 75 °F not 149 °F. As a result, heat induced breakdown of the hydraulic fluid in the valve capillaries was not identified as a potential risk. After installation, failures to trip the turbine occurred when at operational temperatures above 75 °F.
URI Item 2. The inspectors noted that the ECs identified the RPS turbine trip wiring as Class 1E to a terminal box "B" but then identified the wiring in terminal box B as non-Class 1E inside the terminal box and beyond to the hydraulic trip valves. The inspectors need to understand how the required independence requirements are meet from the RPS cabinets to the hydraulic trip valves in this design. The inspectors contend that the licensee needed to maintain independence requirements from the RPS to the input terminals of the trip actuation device. This includes independence between trains as well as between Class 1E and non-Class 1E circuits. Not maintaining independence could affect the single failure analysis (IEEE 279-1971/379-1972) for the RPS circuits.
Planned Closure Actions: To close this URI the NRC needs to receive and review information to answer URI Items 1 and 2 above.
Licensee Actions: The licensee entered this issue into the corrective action program.
Corrective Action References: CR02406337, CR02406338
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 19, 2021, the inspectors presented the triennial inspection of evaluation of changes, tests and experiments baseline inspection results to Kim Maza and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.17T Corrective Action
Documents
NCR 600326,
NCR 651057,
NCR 2131373,
NCR 2142338,
NCR 2143543,
NCR 2170819,
NCR 2198430,
NCR 2198718,
NCR 2199907,
NCR 2201225,
NCR 2201225,
NCR 2203928,
NCR 2204275
Engineering
Changes
Turbine Valve FSAR Update
Rev. 0
NON-CONSERVATIVE T/S FOR EDG VOLTAGE AND
FREQUENCY
Rev. 3
480V Motor Control Center Bucket Replacement
Rev 39
HNP Turbine Control System Upgrade - Main Control Board
Changes
Rev 54
Front Standard Modification
Rev 19
Permanent Closure of 1SW-179, 1SW-180, 1SW-204, AND
1SW-206 (Isolate ESW to/from BTRS Chillers)
Rev 5
Radiation Monitoring System (RMS) Migration to the
Distributed I&C System Platform (DICSP) / Abandonment of
Non-Critical Plant Radiation Monitors (RM-80s)
Rev 17
Replace 45 KVA ERFIS Inverter
Rev 11
MSSV Tolerance and Pressurizer Level Setpoint Tech Spec
Changes
Rev 2
HNP Cycle 23 Tech Spec Changes - Site Impacts
Rev 5
Engineering
Evaluations
EC 284102 REV 000 NON-CONSERVATIVE T/S FOR EDG
VOLTAGE AND
Dated
10/08/2015
Dated
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
9/20/2016
EC 284102 Revision 003 MASTER - NON-CONSERVATIVE
T/S FOR
Dated
01/05/2017
2 EDG FULL LOAD REJECTION VOLTAGE LOW MARGIN
Dated
08/08/2018
I&C SYSTEM PLATFORM (DICSP) / ABANDONMENT OF
NON-CRITICAL PLANT
RADIATION MONITORS
Dated
04/08/2019
AD for Modification Providing Power to Remote Monitoring
Dated
03/11/2020
AR 266216266216Radiation Monitoring System (RMS) Migration to the
Distributed I&C System Platform
Rev. 17
NCR 460601
SAFETY BUS UV AND DGV RELAY COORDINATION - CDBI
- 115 & 121
Dated
04/19/2011
Miscellaneous
Application
Bulletin
Operating Fluid Maintenance Guidelines Fyrquel EH Product
Series
Z24
Vendor Quality Management Plan
Criteria for Protection Systems for Nuclear Power Generating
Stations
1971
IEEE Trial Use Guide for the Application of the Single-Failure
Criterion to Nuclear Power Generating Station Safety Systems
1972
IEEE Standard Criteria for Independence of Class 1E
Equipment and Circuits
1974
Procedures
AD-EG-ALL-1132
Preparation and Control of Design Change Engineering
Changes
Rev. 18
AD-EG-ALL-1133
Preparation and Control of Design Equivalent Change
Engineering Changes
Rev. 14
AD-LS-ALL-0008
CFR 50.59 Review Process
Rev. 3
AD-LS-ALL-005
UFSAR Updates
Rev. 9
CM-I0123
Emergency Diesel Generator 1A-SA Automatic Voltage
Regulator Replacement and Adjustment
Rev. 11
CM-I0124
Emergency Diesel Generator 1B-SB Automatic Voltage
Regulator Replacement and Adjustment
Rev. 11
HNP-D-0044
System Requirements Specification - Main Turbine Control
Rev 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
System
PLP-114
Relocated Technical Specifications and Design Basis
Requirements
Rev. 30
Self-Assessments AR 02305786-05
Applicability Determination Process and 50.59 / 72.48
Rev 5
AR 02354187-05
CFR 50.59 Program Inspection Readiness Assessment
Rev 5
EC 418016 R0, 50.59 Screening
Dated
10/20/2020
Work Orders
20153387-15,
20153387-05,
20153387-23,
20153387-46,
20153387-24,
20153387-35,
20153387-38