IR 05000400/2022004

Integrated Inspection Report 05000400/2022004

ML23032A301
Person / Time
Site:	Harris
Issue date:	02/07/2023
From:	Matthew Fannon NRC/RGN-II/DRP/RPB4
To:	Haaf T Duke Energy Progress
References
IR 2022004
Download: ML23032A301 (22)

Text

February 6, 2023

SUBJECT:

SHEARON HARRIS NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000400/2022004

Dear Thomas Haaf:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Plant. On January 18, 2023, 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 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 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, Matthew S. Fannon, 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: 05000400/2022004

Licensee: Duke Energy Progress, LLC

Facility: Shearon Harris Nuclear Plant

Location: New Hill, NC 27562

Inspection Dates: October 01, 2022 to December 31, 2022

Inspectors: M. Bates, Senior Operations Engineer P. Boguszewski, Senior Resident Inspector C. Curran, Resident Inspector J. Diaz-Velez, Senior Health Physicist S. Downey, Senior Reactor Inspector B. Kellner, Senior Health Physicist A. Nielsen, Senior Health Physicist M. Read, Senior Resident Inspector M. Schwieg, Senior Reactor Inspector C. Smith, Senior Resident Inspector

Approved By: Matthew S. Fannon, 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 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 Implement Operating Procedure Results in Lifting Safety Relief Valve and Loss of Reactor Coolant System Inventory While Shutdown Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.4] - 71152A NCV 05000400/2022004-01 Teamwork Open/Closed A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a was identified when the licensee failed to implement written procedures covering activities recommended in Regulatory Guide 1.33, Revision, 2, Appendix A. Specifically, the licensee failed to implement a procedure for placing the B residual heat removal (RHR) loop in shutdown cooling mode which resulted in lifting the suction relief valve for the B RHR pump and discharging reactor coolant system (RCS) water to the pressurizer relief tank (PRT).

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period near rated thermal power. On October 7, 2022, the unit was shutdown for a planned refueling outage. On October 29, 2022, operators commenced a normal plant startup following completion of the refueling outage. On October 30, 2022, while at 16% power, during startup, Unit 1 experienced an automatic trip due to a loss of two out of three reactor coolant pumps caused by a trip of the 'A' auxiliary power bus. After repairs were completed, the unit was returned to rated thermal power on November 5, 2022, and remained at or near 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of forecasted seasonal freezing temperatures on November 17, 2022.

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding for the diesel generator building and switchgear rooms on December 16, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) B emergency service water while 'A emergency service water was unavailable on October 4, 2022

(2) Reactor head vent system on October 13, 2022, and October 14, 2022

(3) 'B' essential service chill water during 'A' essential service chill water maintenance on November 15, 2022

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the residual heat removal (RHR) system between October 15, 2022, and November 10, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Containment 221', 236', and 261' elevations (fire zones 1-C-1-BAL, 1-C-1-CHFA, 1-C-CHFB, 1-C-3-EPA, and 1-C-3-EPB) on October 11, 2022

(2) Reactor auxiliary building 236' elevation A, 'B', 'C' charging pump rooms (fire zones 1C-CSIP-SAB, 1-A-BAL-G, 1-A-BAL-H, and 1-A-3-PB) on December 14, 2022

(3) Emergency diesel generator building (fire zones 1-D-1-DGB-RM, 1-D-1-DGA-RM, 1-D-1-DGA-ASU, 1-D-1-DGB-ASU, 1-D-1-DGB-ER, 1-D-1-DGA-ASU) on December 16, 2022

(4) Reactor auxiliary building 286' elevation A and 'B' switchgear rooms (fire zones 1-A-SWGA, 1-A-SWGRB) on December 16, 2022

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1 reactor auxiliary building RHR systems 190' elevation

===71111.08P - Inservice Inspection Activities (PWR)

PWR Inservice Inspection Activities Sample (IP Section 03.01)===

(1) The inspectors reviewed the following In-service activities from October 17, 2022, to October 24, 2022:

03.01.a - Nondestructive Examination and Welding Activities Ultrasonic testing examinations on the feedwater piping welds 1-FW-503 and 1-FW-504 Visual testing examinations on the steam generator 'B' supports Penetrate testing examination on the reactor head vent line Welding activities on 1-SW-1206 vent line upstream of the essential services chilled water chiller condenser 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities Boric acid program corrective action reports

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The licensee completed the annual requalification operating and biennial requalification written examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2),

"Requalification Requirements," of the NRC's "Operator's Licenses." During the week of December 12, 2022, the inspector performed an in-office review of the overall pass/fail results of the individual operating examinations, the crew simulator operating examinations, and the biennial written examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.

The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating examinations completed on February 18, 2022, and the biennial written examinations completed on June 2, 2022.

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 main control room during the inoperability of all auxiliary feedwater pumps on October 27, 2022, and during reactor startup on November 2, 2022.

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

(1) The inspectors observed and evaluated a simulator scenario for operator training involving small break loss of coolant accident and loss of the 'B' safety bus on November 30, 2022.

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' emergency service water screen wash pump failed to start (Nuclear Condition Report (NCR) 02443861) on October 3, 2022

(2) 'B' steam generator auxiliary feedwater flow control valve slow to close (NCR

===2444635) on November 1, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01)===

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 risk due to emergent 'A' emergency service water unavailability on October 3, 2022

(2) Elevated risk due to lowered inventory for reactor head removal on October 10, 2022

(3) Elevated risk due to 'B' emergency bus outage on October 13, 2022, and October 14, 2022

(4) Elevated risk due to lowered inventory for reactor assembly on October 22, 2022

(5) Elevated risk due to 'B' emergency service water maintenance on December 1, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

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

(1) 'B' RHR system following the suction pressure relief valve lifting on October 28, 2022

(2) Auxiliary feedwater flow control valve, AF-51, slow to close on October 30, 2022

(3) 'A' emergency service water with a thru wall leak on November 19, 2022

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) 'A' safety bus after relay replacements on October 12, 2022

(2) 'B' emergency diesel generator after governor replacement on October 25, 2022

(3) 'B' steam generator auxiliary feedwater flow control valve after maintenance to address an emergent equipment issue on November 1, 2022

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Unit 1 refueling outage activities from October 8, 2022, to October 29, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) OST-1805, Pressurizer PORV Operability Test, on December 19, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) OST-1076, Auxiliary Feedwater Pump 1B-SB Operability Test, on October 7, 2022

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) EST-212, Type C Local Leak Rate Tests, Attachment 28, Penetration M-77A (Nitrogen to SIS Accumulators and Pressurizer PORV LLRT for ISI-290 and 287), on October 23,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) The inspectors observed workers exiting the radiologically controlled area (RCA)during a refueling outage.

(2) The inspectors observed licensee surveys of potentially contaminated material leaving the RCA.

(3) The inspectors observed workers exiting the reactor containment building and doffing protective clothing at the contaminated area step off pad.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Incore seal table work, as low as reasonably achievable (ALARA) Plan 2022HNPH124Rl-003, Revision 0 [Radiation Work Permit (RWP) Numbers 1013 and 1040]

(2) Refueling activities, ALARA Plan 2022HNPH124-002, Revision 0 [RWPs 1010 and 1024]

(3) Diving Activities Associated With the 1-4 Transfer Canal, ALARA Plan 2022HNP1OL-001, Revision 0 [RWP 56]

(4) Reactor Cavity Decon Activities, ALARA Plan 2022HNPH124R1-001, Revision 0

[RWP 1036]

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Fuel transfer tube Locked High Radiation Area (LHRA) boundaries and barriers in the containment and auxiliary buildings

(2) Incore sump access door Very High Radiation Area (VHRA) in the containment

(3) Regenerative heat exchanger cubicle door and barriers in containment (LHRA)

(4) Waste holdup tank room in waste processing building (LHRA)

(5) Fuel transfer tub hatch (VHRA) in the waste processing building

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Main control room emergency filtration system, high efficiency particulate air (HEPA)and charcoal banks, trains A & B

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Portable HEPA filtration unit used to mitigate airborne radioactivity for seal table work

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Reviewed ten

(10) 'for cause' whole body counts completed by the licensee in response to exit portal monitor (GEM-5) alarms.

(2) Reviewed results of tritium bioassay monitoring by the licensee of three

(3) divers who completed work in the spent fuel transfer canal.

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Reviewed monitoring results of one declared pregnant worker performed by the licensee.

(2) Reviewed monitoring results by the licensee of three

(3) divers issued multi-badge packs for work in the spent fuel transfer canal.

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (10 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Gem 5 Portal Monitor, 261' RCA/Men's Exit, EnRad: 10800

(2) Gem 5 Portal Monitor, 261' RCA/Men's Exit, EnRad: 10796

(3) Argos-5AB, Personal Contamination Monitor, 261' RCA/Men's Exit, EnRad:12266

(4) Argos-5AB, Personal Contamination Monitor, 261' RCA/Men's Exit, EnRad:12268

(5) Argos-5ABZ, Portal and Personal Contamination Monitor, Calibration Laboratory, EnRad:13480

(6) Ludlum 9-3, Portable Ion Chamber, EnRad: 12099

(7) Mirion Telepole II, GM detector, Enrad: 16067

(8) Cronos-4, Small Article Monitor, 261' RCA/Men's Exit, EnRad: 12554

(9) Cronos-4, Small Article Monitor, 261' RCA/Men's Exit, EnRad: 12555

(10) Cronos-4, Small Article Monitor, 261' RCA/Men's Exit, EnRad: 12556

Calibration and Testing Program (IP Section 03.02) (10 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) Canberra, Cronos-4, Sn: 2006-144-CR400G, EnRad:13456 (calibration dates:08/16/2022, and 10/04/2021)

(2) Canberra, Cronos-4, Sn: 1312-312, EnRad:10797 (calibration dates:12/07/2020, and 12/06/2021)

(3) Fastscan Whole Body Counter - HNPFS1 calibrated 12/1/2021 and HNPFS2 calibrated 12/2/2021

(4) Canberra, GEM-5, Sn: 1409-175, EnRad:10796 (calibration dates:06/07/2022, and 06/14/2021)

(5) Canberra, GEM-5, Sn: 1409-171, EnRad: 12564 (calibration dates:12/07/2020, and 12/06/2021)

(6) Ludlum, Model 9-3, Sn: 308274, EnRad:07657 (calibration dates: 08/25/2022, and 02/17/2021)

(7) Ludlum, Model 9-3, Sn: 288619, EnRad: 12062 (calibration dates: 08/29/2022, and 02/17/2021)

(8) Ludlum, Model 9-3, Sn: 288272, EnRad: 11396 (calibration dates: 11/17/2021, and 09/29/2020)

(9) Sorrento Electronics (formerly General Atomics), Radiation Monitor RM-01CR-3589SA (Containment High Range Accident Monitor), calibration dates: 10/20/2019, and 06/06/2021

(10) Sorrento Electronics (formerly General Atomics), Radiation Monitor RM-01CR-3590SB (Containment High Range Accident Monitor), calibration dates: 08/14/2021, and 10/29/2019

Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) REM-1WL-3540, Treated Laundry & Hot Shower Tank Pumps Discharge Monitor calibration date: 05/14/2019, and 11/19/2020

(2) RM-21AV-3509-1SA, Plant Vent Stack, High Range Accident Monitor channel calibration date: 01/17/2019, 11/30/2020, and 09/26/2022

(3) REM-01LT-3502A-SA, Containment Leak Detection System Radiation Monitor calibration date: 11/06/19, and 05/08/2021

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS08: Heat Removal Systems (IP Section 02.07)===

(1) Unit 1 (October 2021 - September 2022)

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) Unit 1 (October 2021 - September 2022)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) Unit 1 (March 1, 2021, through September 16, 2022)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) Unit 1 (March 1, 2021, through September 30, 2022)

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) Loss of RCS inventory due to 'B' RHR pressure relief valve lifting on October 26, 2022

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment and human performance that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated an automatic reactor trip on October 30,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

71003 - Post-Approval Site Inspection for License Renewal Post-Approval Site Inspection for License Renewal

(1) For the Phase I License Renewal Inspection, the inspector observed the implementation of the following license renewal activities (listed by aging management program) from October 10, 2022, to October 14, 2022:

1. Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program a. Visual inspection of cables inside containment 2. Flow Accelerated Corrosion Program o Ultrasonic examination of ES065-010 o Ultrasonic examination of HD178-010 o Ultrasonic examination of HD178-024 3. One-Time Inspection program a. Ultrasonic examination of piping upstream and downstream of valve 1FW-276 b. Ultrasonic examination of 1 Boric Acid Addition Line to B Feedwater c.

Visual inspection of A reactor coolant pump Motor Oil Collection Line d. Ultrasonic examination of 3" pipe from 12" RHR line to flange mating with valve 1RH-45 4. Selective Leaching of Materials Program a. Inspection of 1A Condenser Waterbox Outlet Valve (1CW-28)b. Inspection of 1B Condenser Waterbox Outlet Valve (1CW-29)

The inspector also conducted a general containment walkdown with focus on aging management SSCs within the scope of license renewal.

INSPECTION RESULTS

Failure to Implement Operating Procedure Results in Lifting Safety Relief Valve and Loss of Reactor Coolant System Inventory While Shutdown Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.4] - 71152A NCV 05000400/2022004-01 Teamwork Open/Closed A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a was identified when the licensee failed to implement written procedures covering activities recommended in Regulatory Guide 1.33, Revision, 2, Appendix A. Specifically, the licensee failed to implement a procedure for placing the B residual heat removal (RHR) loop in shutdown cooling mode which resulted in lifting the suction relief valve for the B RHR pump and discharging reactor coolant system (RCS) water to the pressurizer relief tank (PRT).

Description:

On October 26, 2022, while preparing to restart the reactor following a refueling outage, the licensee was providing shutdown cooling through the A RHR loop and was in the process of restoring the B RHR loop after it was drained for maintenance. The B RHR loop had been filled but was not pressurized. The RCS was at approximately 330 psig when the licensee opened the RCS letdown isolation valve to the B RHR loop to increase pressure using procedure OP-111, Residual Heat Removal System, step 8.2.2.9. Prior to the procedure step, the procedure provided a Caution to operators to ensure that the operating RHR pump discharge pressure should be less than 425 psig to prevent lifting the RHR suction on the other loop. The control room operator misread the pressure indication and concluded that the discharge pressure was less than 425 psig. The actual 'A' RHR discharge pressure was around 455 psig at that time. By opening the letdown isolation valve to the idle B RHR loop, the suction and discharge piping were pressurized to approximately the pressure of the operating A' RHR pump, which exceeded the B RHR suction safety relief valve setpoint of 450 psig. The safety relief valve opened and began draining the RCS to the PRT. The draining continued for approximately 10 minutes until operators received a PRT high level alarm, identified the leak path, and closed the letdown isolation valve. The safety relief valve closed after pressure lowered in the B RHR loop. The licensee calculated the loss of reactor coolant to be approximately 1,000 gallons.

Corrective Actions: The licensee isolated the letdown isolation valve, which stopped the draining of the RCS. The licensee provided training to operators for reading gauges and training to supervisors on expectations for oversight of critical activities. The licensee also enhanced procedure OP-111, Residual Heat Removal System.

Corrective Action References: NCR 2447152

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to implement an operating procedure for restoring a loop of the RHR system was reasonably within Duke Energy's ability to foresee and correct and should have been prevented. Specifically, the licensee did not implement a procedure for placing the B RHR loop in shutdown cooling mode which resulted in lifting the suction relief valve for the B RHR pump and discharging RCS water to the PRT.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the operator erroneously assessed pressure indications and proceeded to direct the opening of the letdown isolation valve. This resulted in exceeding the lift setpoint of the B loop RHR suction relief valve and began draining the RCS to the PRT.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix G, Shutdown Safety SDP. Specifically, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings. Using the Loss of Inventory Phase 1 Screening questions this issue screens to a Phase 2 evaluation because it was a Loss of Inventory event with leakage rates such that if the leakage were undetected and/or unmitigated it would cause the currently operating decay heat removal method to fail in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less. A regional Senior Reactor Analyst performed an IMC 0609 Appendix G Phase 2 risk screening using Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, Worksheet 5, SDP for a PWR Plant - Loss of Inventory in POS I (RCS Closed). The RCS was closed with level in the pressurizer. RHR Cooling was in service, Steam Generators were intact, filled, and available for decay heat removal if needed. The plant was late in the outage (TW-Late), so decay heat levels were reduced. Evaluating the sequences in worksheet 5. Using IMC 0609 Appendix G 2 Table 3 - Initiating Event Likelihood (IELs) for Loss of Inventory (LOI)

Precursors Note: a shutdown Loss of Inventory event is considered and event where the loss of inventory results in the loss of the in-service method of decay heat removal. IEL is set to 4 because operators would have approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to isolate the leak path, leak isolation can be performed in less than half the time available, RHR pump indication and reactor water level instruments were functional and available, and RHR could be restored. Using IMC 0609 Appendix G, Attachment 2, Table 9 - Counting Rule Worksheet, the issue screens to very low safety significance (Green).

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the control room operator proceeded in the procedure without adequate oversight from the control room supervisor, evaluating critical plant conditions and directing field operator actions.

Enforcement:

Violation: Licensee Technical Specification 6.8.1, Procedures and Programs, requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A to Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 3, lists instructions for energizing, filling, venting, and startup of safety related systems including the emergency core cooling system. The licensee established procedure OP-111, Residual Heat Removal System, for operations involving the RHR system including restoration instructions following maintenance.

Procedure OP-111 Section 8.2 states in part, when placing the second RHR Loop in service, RHR Pump discharge pressure on PI-600A (B) should be less than 425 psig. This will prevent lifting the RHR Suction Relief on the train that has its RCS loop suctions shut.

Contrary to the above, on October 26, 2022, the licensee failed to implement OP-111 Section 8.2 when the operator failed to ensure that A RHR Pump discharge pressure was less than 425 psig before pressurizing the B RHR loop. This action directly resulted in the opening of the RHR suction relief valve and draining approximately 1,000 gallons of RCS water to the PRT.

Enforcement Action: This violation is being treated as a 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 January 18, 2023, the inspectors presented the integrated inspection results to Thomas Haaf, Site Vice President, and other members of the licensee staff.

On October 24, 2022, the inspectors presented the inservice inspection results to Thomas Haaf, and other members of the licensee staff.

On November 7, 2022, the inspectors presented the radiation protection inspection results to Thomas Haaf, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71003 Work Orders Work Orders (by 20498431-05, 20499769, 20499771, 20518700-01

number)

71111.01 Corrective Action NCR 02450043

Documents

Miscellaneous DG-L-1A Diesel Building External Flooding Walkdown Record 08/14/2012

Procedures AP-301 Seasonal Weather Preparations and Monitoring 88

71111.06 Drawings CAR-2165 General Arrangement Reactor Auxiliary Building Plan EL. 20

G-015 190.00' and 216.00'

Engineering PRA-F-E-0004 Reactor Auxiliary Building Unit 1 EL. 190' and 216' Internal 009

Evaluations Flooding Analysis

71111.08P Corrective Action 2444651 1RH-6 Pipe Cap Leak 10/08/2022

Documents

Corrective Action 2446572 NRC review of ISI examination documentation 10/21/2022

Documents

Resulting from

Inspection

Drawings 1-ISI-SG-2A Steam Generator 'B' 1

Engineering EC420252 ESW Vent/Drain Replacements and Upgrades for RFO-24 1

Changes

Miscellaneous 220250 Weld Record 1-SW-560-FW-2054 0

NDE Reports PT-22-01 Liquid Penetrant Examination RPV vent line pipe to pipe 10/14/2022

PT-22-02 Liquid Penetrant Examination RPV vent line pipe to pipe 10/14/2022

UT-22-015 UT Examination pipe to valve 1-FW-504 10/18/2022

VT-22-034 Visual Examination of Steam Generator 'B' support 1 10/13/2022

VT-22-035 Visual Examination of Steam Generator 'B' support 2 10/13/2022

VT-22-036 Visual Examination of Steam Generator 'B' support 3 10/13/2022

VT-22-037 Visual Examination of Steam Generator 'B' support 4 10/13/2022

VT-22-052 Visual Examination of Steam Generator 'B' support 7 10/18/2022

Procedures GTSM0108-01 ASME Section IX Welding Procedure Specification 8

NDE-NE-ALL-Liquid Penetrant Examination 4

4101

NDE-NE-ALL-Utilization of PDI-UT-1, Generic Procedure for the Ultrasonic 1

Inspection Type Designation Description or Title Revision or

Procedure Date

6111 Examination of Ferritic Pipe Welds

NDE-NE-ALL-VT-3 Visual Examination of Component Supports 2

7302

Work Orders 20235441 Minor boron accumulation on 1SI-101 10/19/2022

235442 Evidence of leakage on FE-648A vent 10/19/2022

235443 Evidence of leakage on FE-654 vent 10/19/2022

235444 Minor boron accumulation on valve stem 10/19/2022

71111.13 Procedures AD-OP-ALL-0212 Risk Informed Completion Time Program Calculations 1

71111.15 Drawings CPL-2165-1310 Simplified Flow Diagram Safety Injection System 12

71111.20 Procedures AD-EG-PWR-Boric Acid Corrosion Control Program - Implementation 5

1611

AD-WC-HNP-HNP Shutdown Risk Management 6

20

71124.01 ALARA Plans 2022HNPH124-Refueling Activities - 50% Work In-Progress review 10/13/2022

2

22HNPH124R1-Cavity Decon - ALARA Post Job Critique 10/25/2022

001

22HNPH124Rl-Cavity Decon (Medium & High Risk) 09/08/2022

001

22HNPH124Rl-Seal Table Activities Revision 0

003

Calculations Alpha Radiation Characterization for Harris Nuclear Plant 08/16/2021

Operating Cycle 24

Alpha Radiation Characterization for Harris Nuclear Plant 02/20/2020

Operating Cycle 23

CFR 61 Radioactive Waste Characterization-Dry Active 3/7/2022

Waste (DAW)

Corrective Action NCRs 02381331, 02387102, 02403501, 02405275, Various

Documents 02414992, 02431406, 02434040, 02445874, and 02446866

Miscellaneous Site ALARA Committee Meeting Minutes [2022 Dose Goals] 01/10/2022

Site ALARA Committee Meeting Minutes [Outage Dose 09/06/2022

Goal Approval]

High Radiation Area Key Control Log Various

TSR 22-002 Temporary Shielding Request (TSR) for incore sump cover 12/16/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

when thimbles are retracted.

TSR 22-006 TSR for fuel transfer tube gap shielding. 12/16/2021

Procedures AD-RP-ALL-1000 Conduct of Radiation Protection Revision 5

HPP-625 Performance of Radiological Surveys Revision 049

HPP-625 Performance of Radiological Surveys Revision 49

HPP-625 Performance of Radiological Surveys Revision 50

Radiation AD-RP-ALL-0007, Unconditional Release Log, 10/21/2022 through 11/2/2022 Various

Surveys Attachment 1

HNP-M-Under water survey of upper cavity floor post vacuum 10/19/2022

221020-5

HNP-M-Post Cavity Decon Survey & post head set 10/22/2022

221022-27

HNP-M-Clean seat of 1SF-186 [cavity drain valve] 10/24/2022

221024-6

Radiation Work Radiation Work Seal Table Activities Revision 27

Permits (RWPs) Permit (RWP) #

1013

RWP # 1010 Refuel Activities Revision 35

RWP # 1024 Rx Head Lift/Set Revision 10

71124.03 Corrective Action AR 02335060

Documents

Corrective Action AR 02446482

Documents

Resulting from

Inspection

Procedures AD-RP-ALL-2019 TEDE ALARA Evaluations and DAC-Hour Tracking revision 3

EPM-420 Emergency Equipment Inventory revision 22

71124.05 Corrective Action AR 02448140 Work Orders missing supervisory signature and incorrect 11/2/2022

Documents dates

Resulting from

Inspection

71152A Drawings 5-S-1304 Simplified Flow Diagram Chemical and Volume Control 1

System

S-1324 Simplified Flow Diagram Residual Heat Removal System 12/05/1983

Inspection Type Designation Description or Title Revision or

Procedure Date

Unit 1

Procedures OP-111 Residual Heat Removal System 64

71152S Corrective Action NCR 2447152

Documents

71153 Drawings PD-5165-BC-0001 AC Power Distribution System 05/26/1982

18