IR 05000400/2022011
| ML22201A091 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/20/2022 |
| From: | Matthew Fannon NRC/RGN-II/DRP/RPB4 |
| To: | Haaf T Duke Energy Progress |
| References | |
| IR 2022011 | |
| Download: ML22201A091 (18) | |
Text
July 20, 2022
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000400/2022011
Dear Mr. Haaf:
On June 10, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Shearon Harris Nuclear Power Plant.
On June 9, 2022, the NRC inspectors discussed the results of this inspection with Ms. Kim Maza and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the sites problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
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, Signed by Fannon, Matthew on 07/20/22 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: 05000400/2022011 Enterprise Identifier: I-2022-011-0024 Licensee: Duke Energy Progress, LLC Facility: Shearon Harris Nuclear Power Plant Location: New Hill, NC 27562 Inspection Dates: May 23, 2022 to June 10, 2022 Inspectors: S. Ninh, Senior Project Engineer W. Pursley, Health Physicist C. Smith, Resident Inspector R. Taylor, Senior Project Engineer A. Wilson, Senior Project Engineer (Team Lead)
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 a biennial problem identification and resolution 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
None.
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of equipment aging issues.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B 1. Corrective Action Program Effectiveness Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure AD-PI-ALL-0100, "Corrective Action Program," and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.
Problem Prioritization and Evaluation: Based on the review of condition reports, the inspectors concluded that problems were prioritized and evaluated in accordance with the condition report significance determination guidance in procedure AD-PI-ALL-0100. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.
Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed effectiveness reviews to ensure corrective actions were properly implemented and were effective.
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.
2. Operating Experience
The inspectors determined that the station's processes for the use of industry and NRC operating experience information were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.
3. Self-Assessments and Audits
The inspectors determined that the licensee effectively performed self-assessments and audits to identify issues at a low level, properly evaluate those issues, and resolve them commensurate with their safety significance. Self-assessments were generally detailed and critical. The inspectors verified that corrective action documents were initiated to document areas for improvement and findings resulting from self-assessments and verified that actions had been completed consistent with those recommendations. Quality assurance program audits appropriately assessed performance and identified areas for improvement.
4. Safety Conscious Work Environment
Based on safety culture interviews with plant personnel, reviews of the latest safety culture survey results, and interviews with employee concerns program personnel, the inspectors found no evidence of challenges to the safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Minor Violation 71152B Minor Violation: During the inspectors' review of the maintenance rule program implementation, specifically the documentation of local leak rate test (LLRT) 1SP-40 Pressurizer Liquid Space Sample Valve (IRC), 1SP-41 Pressurizer Liquid Space Sample Valve (ORC), 1SP-84 Safety Injection System Accumulator C Sample Valve (IRC), and 1SP-85 Safety Injection System Accumulator "C" Sample Valve (ORC), the maintenance rule evaluations concluded that a functional failure had occurred for each penetration. The licensees evaluation concluded that the failures were representative of a Repetitive Maintenance Rule Functional Failure (MRFF). In accordance with procedure AD-EG-ALL-1210, Maintenance Rule Program, Rev. 2, step 5.6.2.4.b, a Maintenance Rule (a)(1)evaluation was required for a Repetitive MRFF. Contrary to this procedure requirement, the inspectors found that no Maintenance Rule (a)(1) evaluation was completed. AD-EG-ALL-1210 is used to establish a program for implementing and maintaining the NRC Maintenance Rule as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants. The inspectors determined the failure to accomplish step 5.6.2.4.b of AD-EG-ALL-1210 represents a violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.
Screening: The inspectors determined the performance deficiency was minor. This performance deficiency was screened in accordance with Inspection Manual Chapter (IMC)0612 Appendix B, Issue Screening Directions, dated October 1, 2021, and was determined to be of minor significance because when the Maintenance Rule (a)(1) evaluation was completed for the repetitive MRFF, it was concluded that the initial maintenance rule evaluations failed to take into account the LLRT leakage test failures of each penetration were not in excess of the administrative limits as defined in EST-212, Type C Local Leak Rate Test, and were evaluated as acceptable in Engineering Change 419545. Therefore, the licensee ultimately concluded that the LLRT failures should not be considered functional failures, and thus no unacceptable performance occurred, and the barrier integrity cornerstone objectives were not adversely affected.
Enforcement:
This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Residual Heat Removal (RHR) Breaker Failure Observation 71152B The inspectors reviewed Nuclear Condition Report (NCR) 02376252, originated on March 29, 2021, which documented a failure of the B RHR pump breaker during testing due to a termination that became loose over time and disconnected due to vibrations experienced during breaker cycling. The licensee had experienced a similar breaker failure in 2001, documented in NCR 29022, and recognized that the spade type connections had the potential of coming loose. Actions were initiated in 2001 due to the loose connection and a corrective action was implemented in PM-E0044, "480 VAC Siemens Type RLN(F) Load Center Breaker and Cubicle PM," that required the installation of Ty-Wraps near the connection point to reduce the probability of the connection from coming loose. The inspectors observed that the corrective actions implemented in 2001 did not prevent the failure of the RHR breaker in 2021. NCR 02376252 determined that PM-E0044 could be enhanced by directing the staff to ensure that spade type connections are confirmed to be tight to prevent slip on the connector. Additionally, a revision to PM-E0044 clarified that where the breaker frame is inaccessible Ty-Wraps are to be installed to fasten to adjacent wiring. The inspectors observed that NCR 02376252 did not clarify the as-found configuration of the Ty-Wraps installed on the RHR breaker connection that came loose. The inspectors observed that no similar failures have occurred since PM-E0044 has been revised with the updated guidance, however, the vendor design using slip on spade type connections is not optimum and that a design weakness still remains.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 9, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Ms. Kim Maza and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 2212531
Documents 2222505
23719
24273
232409
235891
258970
259418
263709
276765
288171
297861
297958
2300449
2311457
20227
21895
26566
2330396
2335154
2337926
2339383
2339968
2339978
2340658
2342424
2342816
2344303
2347273
2347492
2348031
2349762
Inspection Type Designation Description or Title Revision or
Procedure Date
2350357
2351619
2353159
2353624
2354050
2354786
2355203
2355227
2356217
2356329
2359102
2359190
2359398
2359532
2360087
2360325
2360875
2361456
2361630
2362309
2363024
2363089
2364175
2366039
2366635
2369515
2369538
2372140
2372270
2374367
2374915
2376252
2379092
2379651
Inspection Type Designation Description or Title Revision or
Procedure Date
2379780
2380375
2380478
2380481
2380777
2380884
2381326
2381331
2381665
2381927
2385454
2387102
2387573
2389593
2390237
2390439
2390732
2392028
2392806
2393021
2395124
2395876
2397219
2398689
2400230
2403501
2403733
2405601
2405765
2406828
2408631
2408989
2409078
2409079
Inspection Type Designation Description or Title Revision or
Procedure Date
2409314
2410990
2411360
2411682
2411730
2412354
2413545
2413628
2413948
2417230
2417987
2418968
2419412
20239
20406
21858
22025
22807
22808
23085
23332
24516
26647
26973
Corrective Action 2428530 Missed Maintenance Rule (a)(1) Evaluation
Documents 2430708 NRC PI&R Inspection Observation
Resulting from
Inspection
Engineering EC 419545 Acceptability of Valves Exceeding LLRT Admin Limits Exiting REVISION 0
Changes RFO-23
Engineering ESR 9800571 Calculation HNP-C/STRS-1050, Evaluation of Permanent 12/23/1998
Evaluations Lead Shielding Installed on RHR Pump 1A
ESR-9900169 Evaluation of Permanent Lead Shielding Installed on RHR 01/28/2000
Pump
Inspection Type Designation Description or Title Revision or
Procedure Date
EVAL-2020-HNP-
1065-00002161
EVAL-2020-HNP-
4085-00002154
EVAL-2020-HNP-
5015-00002157
EVAL-2021-HNP-
2085-00002177
EVAL-2021-HNP-
5145-00002175
EVAL-2021-HNP-
5175-00002173
Miscellaneous Station Health Report - Emergency Diesel Generator and 12/31/2021
Auxiliaries
AD-EG-ALL-1207 Plant Health Process for Bridging Strategy for Refurbishment
of the Siemens, Model RLN, 480V Circuit Breakers
CSD-AD-ALL- CORRECTIVE ACTION PROGRAM REVIEW MEETING REVISION 7
0004-01
EVT-2085-2021- Maintenance Rule Manager Event
00075447
EVT-5145-2021- Maintenance Rule Manager Event
00075253
EVT-5175-2021- Maintenance Rule Manager Event
00075457
MTG- 2021- Maintenance Rule Meeting Minutes
00000291
MTG-2022- Maintenance Rule Meeting Minutes
00000323
MTG-2022- Maintenance Rule Meeting Minutes
00000328
MTG-2022- Maintenance Rule Meeting Minutes
00000336
MTG-2022- Maintenance Rule Meeting Minutes
00000345
Inspection Type Designation Description or Title Revision or
Procedure Date
TTC1018-N CAP
Overview for New
Employees
Procedures AD-LS-ALL--0003 NRC AUDIT AND INSPECTION ACTIVITIES REVISION
AD-MN-ALL-0017 HOUSEKEEPING, MATERIAL CONDITION, AND SEISMIC REVISION 1
REQUIREMENTS FOR EQUIPMENT STORAGE
AD-PI-ALL-0400 OPERATING EXPERIENCE PROGRAM REVISION
ADMINISTRATIVE CONDITION MONITORING OF STRUCTURES REVISION 1
PROCEDURE,
AD-EG-ALL-1214
ADMINISTRATIVE WORK REQUEST INITIATION, SCREENING, REVISION
PROCEDURE, PRIORITIZATION AND CLASSIFICATION. 15
AD-WC-ALL-0210
ADMINISTRATIVE OBSOLESCENCE PROGRAM REVISION 5
PROCEDURE,
AD-EG-ALL-1104
ADMINISTRATIVE PREVENTIVE MAINTENANCE AND SURVEILLANCE REVISION
PROCEDURE, TESTING ADMINISTRATION 11
AD-EG-ALL-1202,
ADMINISTRATIVE EQUIPMENT RELIABILITY CLASSIFICATION REVISION 6
PROCEDURE,
AD-EG-ALL-1206
ADMINISTRATIVE MAINTENANCE RULE PROGRAM REVISION 2
PROCEDURE,
AD-EG-ALL-1210
ADMINISTRATIVE MAINTENANCE RULE PROGRAM REVISION 3
PROCEDURE,
AD-EG-ALL-1210
ADMINISTRATIVE LICENSE RENEWAL AGING MANAGEMENT REVISION 4
PROCEDURE,
AD-EG-ALL-1650
ADMINISTRATIVE BORIC ACID CORROSION CONTROL PROGRAM - REVISION 4.
Inspection Type Designation Description or Title Revision or
Procedure Date
PROCEDURE, IMPLEMENTATION
AD-EG-PWR-1611
ADMINISTRATIVE OPERABILITY DETERMINATIONS REVISION 6
PROCEDURE,
AD-OP-ALL-0105
ADMINISTRATIVE CORRECTIVE ACTION PROGRAM REVISION
PROCEDURE, 27
AD-PI-ALL-0100
ADMINISTRATIVE ROOT CAUSE EVALUATION REVISION 8
PROCEDURE,
AD-PI-ALL-0101
ADMINISTRATIVE CAUSE INVESTIGATION CHECKLISTS REVISION 7
PROCEDURE,
AD-PI-ALL-0106
ADMINISTRATIVE PREPARATION AND SHIPMENT OF RADIOACTIVE REVISION 5
PROCEDURE, MATERIAL AND RADIOACTIVE WASTE
AD-RP-ALL-5000
ADMINISTRATIVE WORK IMPLEMENTATION AND COMPLETION REVISION
PROCEDURE, 14
AD-WC-ALL-0250
AP-038 DEFICIENCY TAG PROCEDURE REVISION
ENGINEERING TYPE C LOCAL LEAK RATE TESTS REVISION
SURVEILLANCE 63
TEST, NUMBER:
EST-212
PM-E0044 480 VAC SIEMENS TYPE RLN(F) LOAD CENTER BREAKER REVISION
AND CUBICLE
- P.M. 24, 25
Radiation Surveys HNP-M- Follow-up Survey in Chemistry Lab Following Dose Rate 05/05/2021
210505-8 Alarm
Self-Assessments 2020-FLEET- NUCLEAR OVERSIGHT - AUDIT FLEET PERFORMANCE
CAP-01 IMPROVEMENT AND CORRECTIVE ACTION PROGRAM
20-HNP-SEC- NUCLEAR OVERSIGHT - AUDIT HARRIS PHYSICAL
SECURITY
Inspection Type Designation Description or Title Revision or
Procedure Date
21-HNP-ENG- NUCLEAR OVERSIGHT - AUDIT HARRIS ENGINEERING
21-HNP-MNT- NUCLEAR OVERSIGHT - AUDIT HARRIS MAINTENANCE
AND SPECIAL PROCESSES
22-HNP-FIRE- NUCLEAR OVERSIGHT - AUDIT
HARRIS FIRE PROTECTION
22-HNP-OPT- NUCLEAR OVERSIGHT - AUDIT HARRIS OPERATIONS
TRAINING
2340613-05 2020 CR Initiation Rate Analysis 07/22/2020
2363582-05 Operator Knowledge of Important Parameters and Control 08/17/2021
2370171-05 Operational Risk 03/04/2021
2406757-05 HNP 2022 NRC PI&R Readiness Assessment 02/17/2022
RP Bench Harris Radiation Protection Technician Qualification Tracker 05/22/2022
Strength 5-2-22
(1).xlxs (Excel
Spreadsheet)
Work Orders 02339383
2340658
2359190
2361630
2372270
2380375
2380478
2380884
2389593
2390237
2392028
2392806
2395124
2398689
2409078
2409079
2410990
2412354
Inspection Type Designation Description or Title Revision or
Procedure Date
2413948
20459046
20445753
20460102
203719
W/O 98704-1 Perform PM E0044, Perform 480VAC Cubicle and Breaker 06/06/2014
Inspection and Cleaning for RHR Pump 1B-SB
15