IR 05000400/2024011
| ML24249A117 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/10/2024 |
| From: | Daniel Bacon NRC/RGN-II/DRS/EB2 |
| To: | Haaf T Duke Energy Progress |
| References | |
| IR 2024011 | |
| Download: ML24249A117 (1) | |
Text
SUBJECT:
SHEARON HARRIS NUCLEAR PLANT NRC FIRE PROTECTION TEAM INSPECTION (FPTI) INSPECTION REPORT 05000400/2024011
Dear Thomas Haaf:
On August 14, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Plant and discussed the results of this inspection with David Hoffman, Plant Manager 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.
September 10, 2024 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, Daniel M. Bacon, Chief Engineering Branch 2 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-2024-011-0019
Licensee:
Duke Energy Progress, LLC
Facility:
Shearon Harris Nuclear Plant
Location:
New Hill, North Carolina
Inspection Dates:
July 22, 2024 to August 14, 2024
Inspectors:
J. Alamudun, Reactor Inspector
E. Coffman, Reactor Inspector
L. Jones, Senior Reactor Inspector (Team Lead)
W. Monk, Senior Reactor Inspector
Approved By:
Daniel M. Bacon, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC 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
Fire Confinement 18-Month Surveillance Requirements Not Performed Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000400/2024011-01 Open/Closed
[H.12] - Avoid Complacency 71111.21N.
The NRC identified a Green Non-Cited Violation (NCV) of Shearon Harris Nuclear Power Plant Unit 1 RFOL, 2.F, Fire Protection Program, for the licensees failure to complete required surveillance requirements (SRs) associated with required barriers. Specifically, the licensee failed to inspect 189 fire wraps and four thermal shields across 5 fire areas (FA) in the Reactor Auxiliary Building (RAB).
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 industry standards.
REACTOR SAFETY
71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA) analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walkdown inspection to identify equipment alignment discrepancies. Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR) pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with FP equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
(1)
(Detection/Suppression) U1 EDG A & B Fire Water Suppression System (2)
(SSD) U1 125V DC Electrical Distribution System & Aux Shutdown Panel (3)
(SSD) U1 Emergency Service Water and Normal Service Water Systems
Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (2) FP Admin Program #2 Fire Brigade Drills and Training Program
Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors verified the following:
a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
b. The adequacy of the design modification, if applicable.
c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.
INSPECTION RESULTS
Fire Confinement 18-Month Surveillance Requirements Not Performed Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000400/2024011-01 Open/Closed
[H.12] - Avoid Complacency 71111.21N.0 The NRC identified a Green Non-Cited Violation (NCV) of Shearon Harris Nuclear Power Plant Unit 1 RFOL, 2.F, Fire Protection Program, for the licensees failure to complete required surveillance requirements (SRs) associated with required barriers. Specifically, the licensee failed to inspect 189 fire wraps and four thermal shields across 5 fire areas (FA) in the Reactor Auxiliary Building (RAB).
Description:
When the inspection team was reviewing the licensees NFPA 805 Monitoring Program and spot checking the completion of required fire protection surveillance requirements (SRs), it was discovered that the licensee had not completed the required 18-month SRs for 189 fire wrap inspections and four thermal shield inspections in the Reactor Auxiliary Building since 08/29/2019.
In 2020, a revision to this Fire Protection Test (FPT-3560 Surveillance) was issued which divided its Attachments 1 - 3 into five separate Attachments. The associated Preventive Maintenance Identification (PMID) was not updated to perform Attachments 4 and 5 as reflected with the change to the FPT. This led to the license not scheduling and completing the required fire wrap and thermal shield SRs. In review of the licensees NFPA 805 Monitoring Program, the inspectors requested the completed work-order packages for fire protection surveillance requirements associated with fire barrier inspections. In response, the licensee discovered that the required 18-month SRs in the Reactor Auxiliary Building had not been completed since 08/29/2019. The inspectors verified the SRs grace period was expired given the observed period was greater than 3 cycles.
The inspectors questioned the population of fire areas and barriers represented by missing the surveillance. In review of the attachments associated with the surveillance it was determined the licensee failed to inspect 189 fire wraps and four thermal shields in the Reactor Auxiliary Building (RAB) populated across 5 Fire Areas (FA).
Corrective Actions:
1) Schedule and perform FPT-3560 Attachments 4 and 5 as soon as possible in order to complete the missed fire wrap and thermal shield SRs.
2) Perform extent of condition review to identify other editorial preventative maintenance (PM)revisions which may have resulted in a need to revise the PM to ensure SR completions.
Corrective Action References: This issue is being tracked in the licensees CAP under NCR 2523456, HNP NRC 2024 Fire Protection Inspection: FPT-3560 Inspections Not Performed, 07/24/2024.
Performance Assessment:
Performance Deficiency: The licensees failure to complete the surveillance requirements in FPP-013, Fire Protection - Minimum Requirements, Mitigating Actions and Surveillance Requirements was a performance deficiency (PD). Specifically, for greater than 3 cycles the licensee failed to inspect 189 fire wraps and four thermal shields in the Reactor Auxiliary Building (RAB) populated across 5 Fire Areas (FA).
Screening: The inspectors determined the performance deficiency (PD) was more-than-minor because if left uncorrected it would have the potential to lead to a more significant safety concern. Specifically, the surveillance requirements were not completed for greater than 3 cycles and the large volume of fire wraps unchecked increased the risk of a fire protection feature not meeting its SR acceptance criteria in turn validating its functionality. Additionally, IMC 0612, APP E, Examples of Minor Significance, Example 11.b supports dispositioning this PD as More-than-Minor.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using IMC 0609, Appendix F, Attachment 1, and after the licensee completed the missed fire wrap and thermal shield SRs, the inspectors determined the issue was of very low safety significance (GREEN). This was because the fire confinement finding continued to provide adequate fire endurance to prevent fire propagation through the fire confinement element, given the combustible loading and location of equipment important to safe shutdown in the fire area of concern (Question 1.4.4-A).
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the license didnt recognize and plan for possible mistakes when the Preventive Maintenance Identification (PMID) was not updated to reflect the changes made in the FPT surveillance requirement revision.
Enforcement:
Violation: HNP license condition 2.F requires in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), NFPA Standard 805, 2001 Edition. NFPA 805, Section 3.2.3, Procedures, states Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.
FPP-013, Fire Protection - Minimum Requirements, Mitigating Actions and Surveillance Requirements, Sections 6.6.3 and 6.7.3 state in part 18-month visual surveillance requirements were required for the 189 fire wraps and four thermal shields in the licensees RAB.
Contrary to the above, from 08/29/2019 until July 2024 (59 months) the license failed to perform the required FPT 18-month surveillance requirements for 189 fire wraps and four thermal shields in the Reactor Auxiliary Building (RAB).
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 August 14, 2024, the inspectors presented the NRC inspection results to David Hoffman, Plant Manager and other members of the licensee staff.
THIRD PARTY REVIEWS No third-party reviews were conducted during the inspection period.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
HNP-E/ELEC-
0003
Safe Shutdown Analysis Manual Action Feasibility
Rev. 10
Calculations
HNP-M/MECH-
27
NFPA 805 Transition - Fire Area 12-A-CR Fire Safety
Analysis
Rev. 4
Corrective Action
Documents
PRR 734935
FPT-3560 Rev. 015
2/26/2015
HNP NRC 2024 Fire Protection Inspection: Non-CPE
Cables Routing Questions
08/05/2024
NCR 2523456
HNP NRC 2024 Fire Protection Inspection: FPT-3560
Inspections Not Performed
07/24/2024
NCR 2523606
HNP NRC 2024 Fire Protection Inspection: Trash
Observation
07/25/2024
NCR 2524890
Attach Fire Wrap Over B5245 SR4
08/07/2024
PRR 2523212
FPP-013 Correct Editorial/Typographical Error
07/23/2024
PRR 2523305
FPP-013 Definition of Safe Shutdown (SSD) to Reflect
NFPA 805 Licensee Condition
07/23/2024
PRR 2524907
AP-301 Procedure Clarification on Temporary Heaters
08/07/2024
ESW Pipe Tunnel Temporary Power Cables Clean-up
08/06/2024
Corrective Action
Documents
Resulting from
Inspection
Attach Fire Wrap Over B5245 SR4
08/07/2024
1364-95310
Fire Wrap Schematic 310
Rev. 1
5-S-0547
Flow Diagram Circulating & Service Water Systems
Rev. 67
5-S-0548
Flow Diagram Circulating & Service Water Systems
Rev. 74
5-S-1324
Simplified Flow Diagram Residual Heat Removal System
Rev. 12
Drawings
6-SK-E-542 S17
Reactor Auxiliary Building Safe Shutdown Analysis in
Case of Fire EL 286
05/10/1983
Fire Plans
A22-5-261-0606
Pre-Fire Plan RAB EL 261 FA 1-A-BAL
Rev. 4
Remote Shutdown - Basis Document
Rev. 34
Safe Shutdown Following a Fire - Basis Document
Rev. 20
Residual Heat Removal System
Rev. 14
71111.21N.05
Miscellaneous
Service Water System Traveling Screes and Screen
Wash System Waste Processing Building Cooling Water
System
6/14/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Emergency Diesel Generator System
2/13/2021
Plant Electrical Distribution System
5/9/2024
Main and Auxiliary Control Boards and Panels
6/21/2018
FIRE BARRIER SYSTEM
Rev. 10
DPS-1552.10-00-
0006
Non-Controlled Plant Equipment (CPE) Cable
Rev. 5
ECA-0.0
Background
Loss of All AC Power
Rev. 3
Annual Live Fire Training
Rev. 0
Self-Assessment
2499654
HNP NRC Fire Protection Team Inspection Readiness
Assessment
04/02/2024
TTC1679-N
(Initial) TTC1680-
N
(Requalification)
Duke Energy-Nuclear Training Scott SCBA
Rev. 0a
TTC1772-N
Emergency Action Levels
Rev. 1
TTC1982-N
SCOTT NIOSH AIR PAK SCBA Initial TTC1982-N,
SCOTT NIOSH AIR PAK SCBA Requalification TTC1983-
N
Rev. 0a
AD-DC-ALL-0201
DEVELOPMENT AND MAINTENANCE OF
CONTROLLED PROCEDURE MANUAL PROCEDURES
Rev. 25
AD-EG-ALL-1503
FIRE PROTECTION PERFORMANCE MONITORING
AND OTHER PROGRAM ELEMENTS
Rev. 5
AD-HS-ALL-0101
INDUSTRIAL SAFETY
Rev. 16
AD-OP-HNP-
205
HNP Time Critical Actions/Time Sensitive Actions
Rev. 3
AD-TQ-ALL-0083
Self Contained Breathing Apparatus (SCBA) Training
Program
Rev. 5
AD-TQ-ALL-0086
Fire Brigade and Hazmat Training
Rev. 6
Rev. 71
Safe Shutdown Following a Fire
Rev. 55
Fire Area: 1-A-ACP
Rev. 17
Fire Areas: 1-A-SWGRA and 1-A-SWGRB
Rev. 23
Procedures
Reactor Trip or Safety Injection
Rev. 15
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Loss of All AC Power
Rev. 11
FIRE PROTECTION - MINIMUM REQUIREMENTS,
MITIGATING ACTIONS AND SURVEILLANCE
REQUIREMENTS
Rev. 116
FPT-3001
MOTOR DRIVEN MAIN FIRE PUMPFUNCTIONALITY
TEST MONTHLY INTERVAL
Rev. 15
FPT-3006
FIRE MAIN FLOW TEST THREE YEAR INTERVAL
MODES: ALL
Rev. 10
FPT-3560
FIRE WRAP INSPECTION 18-MONTH INTERVAL
Rev. 14
MPT-E0019
Diesel Fire Pump Battery Test
Rev. 9
OPT-3303
MAIN DRAIN TEST TURBINE BUILDING 18 MONTH
INTERVAL
Rev. 11
OPT-3308
MAIN DRAIN TEST OUT LYING BUILDING 18 MONTH
INTERVAL
Rev. 14
PD-FP-ALL-1500
FLEET FIRE PROTECTION PROGRAM MANUAL
Rev. 3
FIRE WRAP INSPECTION 18-MONTH INTERVAL
08/29/2019
FIRE WRAP FOR 4-INCH CONDUIT 16267Z-SB HAS A
SMALL TEAR
07/30/2024
U2 EDG BLDG, INSTALLED EUH NOT OPERATING
11/28/2022
Work Orders
FPP-013 INSPECTION OF FIRE WRAP AND THERMAL
SHIELDS
07/30/2024