IR 05000400/2019003
| ML19301A516 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/24/2019 |
| From: | Bradley Davis Division Reactor Projects II |
| To: | Hamilton T Duke Energy Progress |
| Kroeger A | |
| References | |
| IR 2019003 | |
| Download: ML19301A516 (23) | |
Text
October 24, 2019
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000400/2019003
Dear Ms. Hamilton:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Power Plant. On October 14, 2019, 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 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 Harris.
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 Harris. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Bradley J. Davis, 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:
Report Number:
Enterprise Identifier: I-2019-003-0074
Licensee:
Duke Energy Progress, LLC
Facility:
Shearon Harris Nuclear Power Plant
Location:
New Hill, NC 27562
Inspection Dates:
July 01, 2019 to September 30, 2019
Inspectors:
S. Downey, Senior Reactor Inspector
C. Dykes, Health Physicist
D. Jackson, Allegations/Enforcement Specialist
R. Patterson, Senior Reactor Inspector
A. Patz, Resident Inspector
J. Rivera, Health Physicist
J. Zeiler, Senior Resident Inspector
Approved By:
Bradley J. Davis, Chief
Reactor Projects Branch 4
Division of Reactor Projects
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 Implement Effective Corrective Actions to Preclude Repetition of a Significant Condition Adverse to Quality Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000400/2019003-01 Open/Closed
[P.2] -
Evaluation 71153 A self-revealing Green non-cited violation (NCV) of 10CFR50, Appendix B, Criterion XVI,
Corrective Actions, was identified for the licensees failure to implement effective corrective actions to preclude repetition of a significant condition adverse to quality. Specifically, the licensee failed to adequately address turbine trip system failures involving mechanical binding (sticking) of turbine auto-stop trip (AST) solenoid operated valves (SOVs), resulting in repetitive instances where turbine trip engineered safety features actuation system (ESFAS)response times could not be met as required by Technical Specifications (TS).
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000400/2019-001-00 LER 2019-001-00 for Shearon Harris Nuclear Power Plant, Unit 1, Turbine Control System Auto-Stop Trip Solenoid Operated Valves Response Times Impacted 71153 Closed LER 05000400/2019-001-01 LER 2019-001-01 for Shearon Harris Nuclear Power Plant, Unit 1, Turbine Control System Auto-Stop Trip Solenoid Operated Valves Response Times Impacted 71153 Closed
PLANT STATUS
Unit 1 operated at or near rated thermal power until September 20, 2019, when a power coastdown was initiated in preparation for an upcoming refueling outage. The unit was operating at 93 percent rated thermal power at the end of the report 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Dorian on September 4-6, 2019.
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding for the following areas on September 3-6, 2019:
- Emergency diesel generator (EDG) building
- Rooftops and ground elevation flood doors of reactor auxiliary building (RAB),fuel handling building (FHB), turbine building (TB), and waste processing building (WPB)
71111.04Q - 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)
'A' essential services chilled water (ESCW) system while 'B' ESCW chiller was out-of-service due to high oil temperature trip and mechanical cleaning between July 15-17, 2019
- (2) B residual heat removal (RHR) pump while A RHR pump was out-of-service for planned maintenance on July 25, 2019 (3)
'B' EDG while 'A' EDG was out-of-service due to emergent failure of room exhaust fan E-86A between August 22-24, 2019
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated fire brigade performance during a announced fire drill conducted on September 20, 2019. The fire drill scenario involved a hydrogen seal oil fire on TB elevation 261.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) RAB elevation 286 'A' train essential switchgear room, ventilation room, and battery room (fire zones 1-A-SWGRA, 1-A-BAL-J, and 1-A-BATA) on July 29, 2019
- (2) RAB elevation 261 'A' and 'B' electrical penetration rooms, 'A' and 'B' ESCW chiller areas, and alternate seal injection and filter area (fire zones 1-A-EPA, 1-A-EPB, 1-A-4-CHLR, and 1-A-4-COMC) on August 20, 2019
- (3) FHB elevation 261 electrical and ventilation equipment areas (fire zones 5-F-3-CHF-BAL, 5-F-3-CHFA, 5-F-3-CHFB, 5-F-3-DMNZ1, and 5-F-3-DMNZ2) on August 22, 2019
- (4) RAB elevation 261 charcoal filter areas (1-A-4-CHFA and 1-A-4-CHFB) on August 30, 2019
- (5) RAB elevation 261 steam tunnel area (fire zone 1-A-46-ST) on September 9, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) RAB elevation 261 on August 19, 2019
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a simulator scenario for training involving a large-break loss-of-coolant accident on July 9, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Alternate seal injection non-functional due to cooling issues on July 9, 2019 (2)
'B' ESCW chiller tripped on compressor high oil temperature on July 14, 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 risk assessments for the following planned and emergent work activities:
- (1) Elevated (Green) risk during unplanned outage of 'B' ESCW system following trip of
'B' ESCW chiller on July 14, 2019
- (2) Elevated (Green) risk due to planned unavailability of the A RHR pump for preventive maintenance on July 25, 2019
- (3) Elevated (Green) risk due to unplanned unavailability of the 'B' essential safeguards sequencer due to failure of relay 94LO/1169 on August 6, 2019
- (4) Elevated (Green) risk due to planned unavailability of the 'B' and 'C' charging and safety injection pumps while swapping from 'B' to 'C' pump on August 13, 2019
- (5) Elevated (Green) risk due to unplanned unavailability of the 'A' EDG due to failure of room exhaust fan E-86A on August 22, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Turbine control system (TCS) AST QuadVoter solenoid valve 1EH-159A failure on July 1, 2019 (Nuclear Condition Report (NCR) 02279964)
- (2) Elevated amperage conditions on 'A' train ESCW chiller compressor motor due to suspected leakage past hot gas bypass valve on July 9, 2019 (NCR 02281075)
- (3) Unexpected 'B' ESCW chiller trip on compressor high oil temperature on July 14, 2019 (NCR 02281819)
- (4) Low emergency service water (ESW) flow from main reservoir to containment fan cooler air handling unit AH-2 during testing on July 19, 2019 (NCRs 02282820 and
===02283578)
- (5) Failure of 'B' train essential safeguards sequencer thermal overload and torque switch bypass relay 94LO/1169 during testing on August 6, 2019 (NCR 02285575)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors evaluated the following temporary or permanent modifications:
- (1) EC 0000403358, Replace obsolete Technical Specification recorders
- (2) EC 0000410353, Install Phase I Racks in 'D' spent fuel pool (SFP)
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Work Order 20338057 instructions for pressure testing fire suppression piping in TB following temporary repair of broken piping on July 2, 2019
- (2) Technical Procedure Testing (OPT)-1512, Train B Essential Chilled Water Turbopak Units Quarterly Inspection and Checks, following corrective maintenance on the 'B' ESCW chiller on July 18, 2019
- (3) OPT-1538, Emergency Safeguards Sequencer System Test - Train B Quarterly Interval Modes 1-6, following replacement of failed 'B' train sequencer relay 94LO/1169 on August 8, 2019
- (4) Operations Surveillance Test (OST)-1093, Chemical and Volume Control System/Safety Injection System Operability, Train B, Quarterly Interval, following planned maintenance on the 'B' charging and safety injection pump on August 14, 2019
- (5) Operating Procedure (OP)-177, Diesel Generator Building HVAC System, Section 5.3, Diesel Generator Room Ventilation Start-Up, following replacement of failed 'A' EDG room exhaust fan E-86A on August 24, 2019
- (6) OPT-1083, B-SB Train ESW Flow Verification/Balance, following chemical cleaning of service water side of 'B' component cooling water (CCW) heat exchanger on September 13, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) OPT-1082, A-SA Train ESW Flow Verification/Balance, on July 25, 2019
- (2) OST-1086, 1B-SB Diesel Generator Operability Test, Semiannual Interval, Modes 1-6, on August 1, 2019
- (3) OPT-1512, Essential Chilled Water Turbopak Units Quarterly Inspection/Checks Modes 1-6, on August 23, 2019
- (4) OST-1191, Steam Generator PORV and Block Valve Operability Test, on September 9, 2019
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) EST-223, Insitu Main Steam Safety Valve Test Using Assist Device, on September 26, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (2 Samples)
The inspectors evaluated:
- (1) A tabletop drill involving an earthquake during reactor refueling on September 16, 2019.
- (2) An after-hours augmentation drill involving an anticipated transient without scram (ATWS) with loss of heat sink accident on September 18, 2019.
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) A simulator-based licensed operator training evolution involving a large-break loss-of-coolant accident on July 9,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Inspectors evaluated licensee performance in ensuring gaseous and liquid effluent processing systems are maintained to properly mitigate, monitor and evaluate radiological discharges to the public. Inspectors reviewed compensatory measures for out-of-service effluent monitors.
Walk Downs and Observations (IP Section 02.01) (1 Sample)
The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:
- (1) Inspectors reviewed the following:
Systems Liquid waste system Gaseous waste system
Observed routine processing No routine processing available during the inspection period
Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)
The inspectors reviewed gaseous and liquid effluent monitor instrument calibrations by reviewing information not limited to but including alarm set points, periodicity, and National Institute of Standards Traceability for sources used. Information reviewed included but was not limited to the following:
- (1) Effluent monitor calibrations I, MST-I0327, WASTE MONITOR TANKS DISCHARGE REM-3541 CAL, 05/16/16, 05/01/19 I, MST-I0407, Main Steam Line Monitor RM-3592 Calibration, 04/20/2018, 11/2/2016
Sampling and Analysis (IP Section 02.03) (1 Sample)
The inspectors reviewed radioactive effluent sampling and analysis activities.
- (1) Radioactive Effluent Sampling and Analysis Activities Turbine Building Vent Stack sampling
Effluent Discharges None were available for review during this inspection
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed flow rates for effluent stack and related vent flow and surveillances.
Inspectors also reviewed maintenance and methodologies for one or two high-range effluent monitors (or other effluent/process monitor) relied on in emergency operating procedures for decision making.
- (1) The inspectors reviewed the following:
Air Cleaning Systems E-13-1X-SB FHB Emergency Exhaust Surveillance, 02/16/2017; 09/12/2018 EPT - 400: Attachment 6,S-1-1B Containment Airborne Radioactivity Removal periodic test, 04/22/2018
High-Range Effluent Monitor I,MST-I0401/CM-10085, Containment High Range Accident Monitor Calibrations, 12/12/2018; 12/12/2016
Dose Calculations (IP Section 02.05) (1 Sample)
The inspectors reviewed required annual reports for changes, release permits and the offsite dose calculation manual for changes and results. The inspectors reviewed the following to assess public dose:
- (1) The inspectors reviewed the following to assess public dose:
Liquid and Gaseous Discharge Permits
- G-2019-0090, 05/29/2019
- G-2019-0091, 05/29/2019
- G-2019-0092, 05/29/2019
- L-2019-0016, 05/30/2019
Annual Radiological Effluent Release Reports
- 2018 Shearon Harris Nuclear Power Plant Unit 1 Annual Radioactive Release Report
- 2017 Shearon Harris Nuclear Power Plant Unit 1 Annual Radioactive Release Report
Abnormal Gaseous or Liquid Tank Discharges
- G-2017-0214
71124.07 - Radiological Environmental Monitoring Program
Inspectors evaluated licensee performance in ensuring the Radiological Environmental Monitoring Program (REMP) is implemented in accordance with licensing documentation and the REMP is validating that if there is any dose to the public it is within the legal limits. Inspectors also reviewed the licensee's effort to continue to implement the Nuclear Energy Institute (NEI) Ground Water Protection Initiative (GPI).
Site Inspection (IP Section 02.01) (1 Sample)
The inspectors performed walkdowns of sampling stations, thermoluminescent locations and meteorological instrumentation. Inspectors also performed observations of preparation and collections of different environmental sample types. Inspectors reviewed sampling results and maintenance, calibration, quality control and groundwater records.
- (1) Records reviewed, and samples observed included but were not limited to the following:
Walkdowns and calibration and maintenance record review:
- ENRAD Laboratories LV-1D Air Sampler Certificate of Calibration 09072, 4/2/18 and 4/10/19
- ENRAD Laboratories LV-1D Air Sampler Certificate of Calibration
===09083, 3/9/18 and 3/19/19
- ENRAD Laboratories LV-1D Air Sampler Certificate of Calibration 09089, 9/13/17 and 11/5/18
- TLD site no. 1 at 2.6 miles N
- TLD site no. 4 at 3.1 miles NNE
- TLD site no. 26 at 4.7 miles S
- ENRAD Laboratories Certificate of Calibration 09262, ISCO Model 3710 Portable Water Sampler, 9/17/18
Observed environmental sample collections and preparation:
- None were available for observation during this inspection
Missed sample, inoperable sampler, lost TLD or anomalous measurement:
- Composite water sampler location 26 inoperable for approximately 12 days in June 2018
- Air sampler location 47 inoperable for approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> in October 2017
- TLD location 33 was found missing from its designated location in the 4th quarter of 2017
Sampling program for the potential of licensed material entering ground water:
- Old Steam Generator Storage Building Sump
- Old Reactor Head Storage Building Sump
- Component Cooling Water System
Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)===
- (1) The inspectors reviewed the licensee's continuing implementation of the voluntary NEI Ground Water Protection Initiative.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) Unit 1 (July 1, 2018 - June 30, 2019)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Turbine-driven auxiliary feedwater pump tripped on starting after routine surveillance due to a failure of the turbine governor valve positioner (NCR 02253215)
- (2) Multiple TCS AST QuadVoter solenoid valves failed to cycle during testing on April 16-17, 2019 (NCR 02269085)
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000400/2019-001-00 and 05000400/2019-001-01, Turbine Control System Auto-Stop Trip Solenoid Operated Valves Response Times Impacted, on June 17, 2019 and September 16, 2019 (ADAMS Accession Nos. ML19168A008 and ML19259A071). The circumstances surrounding the LER and updated LER submittal is documented in report section Inspection Results.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
71007 - Reactor Vessel Head Replacement Inspection
Reactor Vessel Head Replacement Inspection (1 Sample 1 Partial)
- (1) The inspectors evaluated the following engineering change packages to verify that design changes and modifications associated with the reactor vessel head replacement were properly screened and evaluated, if required, in accordance with Title 10, Code of Federal Regulations (CFR) 50.59:
1. EC 0000294345, Replacement Reactor Vessel Head (RRVH) and Insulation
Design and Installation, Revision 0
2. EC 0000294355, RRVH Project - Equipment Hatch and Interference Removal,
Revision 0
3. EC 0000294346, Control Rod Drive Mechanism (CRDM) and Digital Rod
Position Indicator (DRPI) Cable Design and Installation, Revision NEW A
4. EC 0000294347, RRVH Transport and Haul Path - Transport of Original
Reactor Vessel Head (ORVH) and RRVH to/from Reactor Containment Building to Storage, Revision 0
This sample was reviewed using IP 71111.17T, Evaluations of Changes, Tests, and Experiments, as guidance. The inspectors also reviewed key design aspects of the replacement reactor vessel head (RRVH) as well as provisions for a temporary containment opening using IP 71111.18 as guidance. In addition, the inspectors reviewed site documents and records to verify that the ASME Code requirements used to construct the RRVH were reconciled with those used to construct the original reactor vessel head; that the original ASME Code N-stamp documentation for the reactor vessel remains valid; and that the RRVH complies with the appropriate NRC rules and ASME requirements. Finally, the inspectors reviewed the procurement specification for the RRVH to verify that there is a contract requirement to maintain part identification and traceability during processing of the replacement head.
The review of these inspection items constitutes a completion of the inspection requirements of IP 71007, Steps 02.02.a.1 and 02.02.a.2.
(2)
(Partial)
The inspectors reviewed and observed aspects of the following RRVH activities on September 18-20, 2019:
- Preparations for RRVH haul route testing inside the protected area
- Initial lift of RRVH to upright position from hydraulic transporter using two crane lift system
- Preparations for removing RRVH from shipping container
INSPECTION RESULTS
Failure to Implement Effective Corrective Actions to Preclude Repetition of a Significant Condition Adverse to Quality Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000400/2019003-01 Open/Closed
[P.2] -
Evaluation 71153 A self-revealing Green non-cited violation (NCV) of 10CFR50, Appendix B, Criterion XVI, Corrective Actions, was identified for the licensees failure to implement effective corrective actions to preclude repetition of a significant condition adverse to quality. Specifically, the licensee failed to adequately address turbine trip system failures involving mechanical binding (sticking) of turbine auto-stop trip (AST) solenoid operated valves (SOVs), resulting in repetitive instances where turbine trip engineered safety features actuation system (ESFAS)response times could not be met as required by Technical Specifications (TS).
Description:
On April 16-17, 2019, the licensee performed testing of the four SOVs associated with the AST emergency turbine trip system and four SOVs associated with the Overspeed Protection Control (OPC) turbine trip system. During this testing, two of four AST SOVs (one in each of the two channels) failed to change position when their electrical trip solenoids were de-energized. With a failed SOV in both AST channels, the AST system was incapable of depressurizing the AST hydraulic header which would have prevented a turbine trip had an actual trip actuation demand signal been generated. As a result, this rendered inoperable, the turbine trip instrumentation channels on steam generator water level hi-hi, per TS 3.3.2, ESFAS Instrumentation, Function 5, since the required 2.5 second turbine trip ESFAS response time in accordance with TS surveillance requirement 4.3.2.2 would not have been satisfied. The significance of this event was mitigated by the successful testing and continued functionality of the OPC turbine trip system during the period that the AST system was non-functional. Specifically, had an actual turbine trip signal occurred, the turbine control system would have generated an additional, although delayed by 6-7 seconds, demand signal that would have energized the OPC turbine trip system and effectively tripped the main turbine.
The inspectors reviewed the licensees root cause evaluation for the AST SOV failures.
These failures were attributed to the same phenomenon that occurred June 29, 2018, involving the failure of SOVs in both AST channels due to sticking of the SOV pilot valves.
Forensic analysis and evaluation of the current failures identified several common mode failure issues that most likely contributed to sticking of the spool-type pilot valves in the SOVs. These issues included the following:
- There was buildup of small particles of oil contamination in the clearances of the SOV pilot valve sliding spool internals, a known industry phenomenon referred to as silting.
- The incorrect internal SOV pilot valve trip springs were installed. The need for the higher force spring was to provide greater trip margin and offset the vulnerability of sticking SOV pilot valves due to silting.
- Debris/contamination, including aluminum shavings, from either original valve manufacturing or modification installation was found within all the SOV assemblies.
- High SOV pilot valve electrical coil armature temperatures exceeding the Fyrquel recommended temperature limitation known to cause varnish film buildup leading to spool-type pilot valve sticking.
As part of the licensee's root cause evaluation, a review was conducted of the previous AST SOV failure on June 29, 2018, documented in NCR 02216793. The licensee concluded from this review that the previous root cause evaluation was ineffective at preventing the most recent failures. The previous root cause evaluation was determined to be too narrowly focused and did not validate assumptions through direct observations via forensics of the failed SOV slave and pilot valve internals nor adequately pursue causes other than the initial missed AST SOV testing frequency. The inspectors agreed with the licensees assessment of the previous evaluation since the evaluation missed the above-mentioned issues needed to properly address the common mode vulnerabilities with using the spool-type pilot valve SOVs in a Fyrquel hydraulic fluid application. Since the previous failure investigation was designated in the licensees corrective action program as a significant condition adverse to quality, the inspectors determined that the licensee had failed to implement adequate corrective actions to preclude repetition of a significant condition adverse to quality.
Corrective Actions: The licensees immediate corrective actions included manual cycling of the SOVs and repeated exercising to remove silting and varnish film buildup from the SOV pilot valve internals. In addition, the frequency for testing the AST SOVs was immediately increased from weekly to bi-weekly with each SOV being cycled five times during each test.
Subsequently, the SOV pilot valve trip actuation lower force springs were replaced with the originally intended higher force springs to increase trip margin, and the doors to the turbine enclosure housing where the AST SOVs were located were directed to be left open whenever possible to provide increased cooling. Planned corrective actions included more SOV pilot valve and assembly oil fluid flushing, as well as initiation of a design change to replace the spool-type pilot SOVs with poppet style SOVs that are known to be less susceptible to sticking from silting and the oil varnish phenomenon.
Corrective Action References: NCR 02269085
Performance Assessment:
Performance Deficiency: The licensees failure to implement corrective actions to preclude repetition of a significant condition adverse to quality involving degraded TS ESFAS response times for the turbine AST actuation function was a performance deficiency (PD).
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to preclude repetition of sticking AST SOVs rendered the turbine AST ESFAS function inoperable.
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, under Section C, Reactivity Control Systems. The inspectors determined that a detailed risk evaluation was required since both channels of the turbine AST function were impacted rendering the system incapable of depressurizing the AST hydraulic header needed to generate an automatic turbine trip within the allowable TS response time (i.e., 2.5 seconds) for a steam generator hi-hi level turbine trip ESFAS actuation. A detailed risk evaluation of the PD was previously performed by a Region II Senior Reactor Analyst in accordance with NRC IMC 0609, Appendix A, during NRC review of the AST SOV failures that occurred previously on June 29, 2018. (See NCV 05000400/2018003-001 documented in NRC Integrated Inspection Report 05000400/2018003, dated October 26, 2018). The results of the NRCs previous risk evaluation determined the issue to be a Green finding of very low safety significance. The inspectors determined that this previous risk evaluation remained bounding for the current issue.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the root cause evaluation for the June 29, 2018 sticking turbine AST SOV failure was narrowly focused and failed to address outstanding system common mode vulnerabilities that existed with the AST SOVs that could impact their reliable operation.
Enforcement:
Violation: 10CFR50, Appendix B, Criterion XVI, Corrective Actions, requires in part, that, for significant conditions adverse to quality, measures shall assure that the cause of the condition is determined, and corrective action taken to preclude repetition.
Contrary to the above, from June 29, 2018 to April 16, 2019, the licensee failed to establish measures to assure that corrective action was taken to preclude repetition of a significant condition adverse to quality. Specifically, the licensee failed to adequately address sticking in turbine trip system AST SOVs, resulting in repetitive instances where turbine trip ESFAS response times could not be met as required by TS.
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 October 14, 2019, the inspectors presented the integrated inspection results to Tanya Hamilton and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71007
Calculations
C-3597-110
RRVH Transport & Storage Beams
Revision 0
HNP-C/RVHR-
0003
Shearon Harris RVH Haul Route Evaluation
Revision 0
HNP-C/STRU-
1144
HNP Equipment Hatch Temporary Plates and Weld Analysis
Revision 0
HNP-C/STRU-
1148
Shearon Harris Waste Processing Building RVH Loading
Evaluation
Revision 0
Corrective Action
Documents
RRVH and ORVH Rigging, Lifting and Transportation Into
and Out of Reactor Containment Building
Revision 0
Corrective Action
Documents
Resulting from
Inspection
CRDM and DRPI Cable Bend Radius Installation Instruction
Revision 0
Drawings
1364-097748
Shearon Harris Unit 1 Equipment Hatch Modification
Revision 3
1447E94
Loop Integrated Head Package Cable Arrangement
Revision 0
4R6563
Cable Assembly DRPI - Shutdown
Revision C
Cable Assembly CRDM
Revision D
6R6562
Cable Assembly DRPI Control
Revision C
P-3597-190
RRVH Upending Drawing
Rev. D
SK-EC294347-
(001-004)
Framatome General Arrangement Upending RRVH
Revision 3
SK-EC294347-
017
Framatome Haul Route Offload Location to Hydraulic Gantry
Revision 6
Engineering
Changes
RRVH Transport and Haul Path
Rev. 0
Miscellaneous
CAR-SH-AS-001
Specification EBASCO Containment Liner, Air Locks, and
Hatch
Revision 12
HNP-E-0015
Integrated Head Package Prefabricated Cable Assemblies
Specification
Revision
NEW A
HNP-G-0009
Procurement Specification for the Replacement Reactor
Vessel Head
Revision 7
HNP-M-RVHR-
Control Rod Drive Mechanism Pressure Housing Assembly
Revision 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0017
ASME III Class I Design Report
HNP-M/RVHR-
0013
ASME Section XI Code Reconciliation of the Replacement
Reactor Vessel Head Modified L106-A1 CRDM
Revision 0
HNP-M/RVHR-
0016
ASME Certified Design Report for Shearon Harris Unit 1
Replacement Reactor Vessel Closure Head
Revision 0
HNP-M/RVHR-
0018
Shearon Harris Unit 1 Reactor Vessel Closure Head &
RVLIS Piping Subassembly ASME Code Reconciliation
Revision 0
HNP-RVHR-0001
Certified Design Specification for Replacement Reactor
Vessel Closure Head for Duke Energy Shearon Harris Unit 1
Revision
NEW B
HNP-RVHR-0005
RVLIS and RVHVS Installation Piping Assemblies
Manufacturing Specification for Shearon Harris Unit 1 RRVH
Revision
NEW B
HNP-RVHR-002
Shearon Harris RRVCH CRDM Equipment Specification
Revision
NEW A
Procedures
50-9253449-000
Shearon Harris Unit 1 Outage Master Traveler
06/01/2019
Teledyne Acceptance Test Procedure for Commercial
Nuclear Cable Assemblies
Revision 0
TLR-19-025
Temporary Load Release (for upending RRVH)
9/9/2019
Drawings
8-G-0033, sheet
Door Schedule Special Doors, Watertight, Wire Mesh &
Metal Partition
Rev. 11
Miscellaneous
Licensee
Response Letter
to NRC Near
Term Task Force
Review of
Fukushima Da-
Ichi Accident
Flood Hazard Reevaluation Report, Revision 1
4/1/2015
Licensee
Response Letter
to NRC Near
Term Task Force
Review of
Fukushima Dai-
Ichi Accident
Flood Hazard Reevaluation Report
3/12/2013
Procedures
AP-046
Control of Environmental Protective Features
Rev. 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AP-300
Severe Weather Response
Rev. 34
EPT-040
Flood Barrier Penetration Seal Visual Inspection
Rev. 1
71111.04Q Drawings
CPL-2165S-1308
Simplified Flow Diagram Safety Injection System
CPL-2165S-1310
Simplified Flow Diagram Safety Injection System Sheet 3
Unit 1
CPL-2165S-1324
Simplified Flow Diagram Residual Heat Removal System
Procedures
AD-OP-ALL-0201
Protected Equipment
Rev. 5
Residual Heat Removal System
Rev. 63
Essential Services Chilled Water System
Rev. 80
Diesel Generator Emergency Power System
Rev. 89
Fire Plans
CSD-HNP-PFP-
Turbine Building Pre-Fire Plan
Rev. 3
Procedures
AD-OP-ALL-0207
Fire Brigade Administrative Controls
Rev. 2
Fire Protection Program Manual
Rev. 44
Fire Emergency
Rev. 45
71111.05Q Corrective Action
Documents
Resulting from
Inspection
Revision to Pre-Fire Plan CSD-HNP-PFP-FHB
08/22/2019
Transient combustible material found in the RCA by EAL
09/11/2019
Fire Plans
CSD-HNP-PFP-
FHB
Fuel Handling Building Pre-Fire Plan
Rev. 1
CSD-HNP-PFP-
RAB-261
Reactor Auxiliary Building Elevation 261 Pre-Fire Plan
Rev. 1
CSD-HNP-PFP-
RAV-286
Reactor Auxiliary Building Elevation 286 Pre-Fire Plan
Rev. 1
Miscellaneous
Fire Protection Permit and Impairment Log Entries
Procedures
AD-EG-ALL-1520
Transient Combustible Control
Rev. 12
Fire Protection Program Manual
Rev. 44
Fire Protection - Minimum Requirements, Mitigating Actions
and Surveillance Requirements
Rev. 100
Calculations
PRA-F-E-0006
Reactor Auxiliary Building Unit 1 El. 261' Internal Flooding
Analysis
Rev. 4
71111.11Q Procedures
AD-OP-ALL-1000
Conduct of Operations
Rev. 15
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-TQ-ALL-0420
Conduct of Simulator Training and Evaluation
Rev. 15
Reactor Trip or Safety Injection
Rev. 12
Loss of Reactor or Secondary Coolant
Rev. 5
Transfer to Cold Leg Recirculation
Rev. 4
OMM-001
Operations Administrative Requirements
Rev. 115
Corrective Action
Documents
Alternate seal injection nonfunctional due to 1&2B recycle
monitor tank
2/25/2019
'B' ESCW chiller tripped on compressor high oil temperature
7/14/2019
Miscellaneous
Alternate Seal Injection System
Rev. 4
Procedures
AD-EG-ALL-1210
Rev. 1
Calculations
HNP-F/PSA-0119
Online Phoenix Model
Rev. 1
Procedures
AD-NF-ALL-0501
Electronic Risk Assessment Tool (ERAT)
Rev. 2
AD-WC-ALL-0200 On-Line Work Management
Rev. 14
AD-WC-ALL-0240 On-Line Risk Management Process
Rev. 1
AD-WC-ALL-0410 Work Activity Integrated Risk Management
Rev. 8
Chemical and Volume Control System
Rev. 117
Work Orders
20147570
B-SB Chiller Tripped
7/14/2019
20317600
MPT-M0084, A RHR Motor Oil Change, Mechanical EQ
7/25/2019
20346400
Replace 'B' sequencer thermal overload and torque switch
bypass relay 94LO/1169
8/6/2019
20349380
Replace 'A' EDG room exhaust fan E-86A
8/22/2019
Procedures
AD-OP-ALL-0105
Operability Determinations and Functionality Assessments
Rev. 4
Corrective Action
Documents
Resulting from
Inspection
Calculation 9-SAC-002A Not Issued
7/24/2019
Engineering
Evaluations
50.59 Screening for EC 403358
4/25/2019
Miscellaneous
DBD-1000-V02
Environmental Qualification Design Basis Document
Rev. 11
Guidelines for 10 CFR 50.59 Evaluations Endorsed by
Rev. 1
Procedures
AD-EG-ALL-1132
Preparation and Control of Design Change Engineering
Changes
Rev. 14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-LS-ALL-0008
CFR 50.59 Review Process
Rev. 1
Corrective Action
Documents
B-SB Chiller Tripped
7/14/2019
Procedures
PLP-400
Post Maintenance Testing
Rev. 64
Work Orders
20321229
OST-1093 - Operability of train "B" charging and safety
injection pump
8/14/2019
20322495
Essential Services Chilled Water Systems Operability
7/14/2019
20346400
Replace 'B' Sequencer Thermal Overload and Bypass Relay
94LO/1169
8/7-8/2019
20349380
'A' EDG exhaust room fan E-86A-SA motor replacement
8/24/2019
20351716
Chemical cleaning of 'B' CCW heat exchanger
9/13/2019
Work Orders
20185982
OST-1086, Staggered Test, K610 SI Start Signal
8/01/2019
Miscellaneous
Emergency
Preparedness
Drill Package
2019 ERO Augmentation Drill
FAD-HNP-EP-
EPEAL Matrix
Emergency Preparedness - Emergency Action Level Matrix
Rev. 2
Regulatory Assessment Performance Indicator Guideline
Rev. 7
Procedures
AD-EP-ALL-0105
Activation and Operation of the Technical Support Center
Rev. 3
AD-EP-ALL-0304
State and County Notifications
Rev. 1
AD-EP-ALL-0802
Conducting Drills and Exercises
Rev. 4
AD-EP-ALL-0803
Evaluation and Critique of Drills and Exercises
Rev. 4
AD-EP-HNP-0105 HNP Site Specific Technical Support Center Support
Rev. 0
Emergency Action Levels
Rev. 18
PD-EP-ALL-0800
Drills and Exercises Program
Rev. 6
PEP-110
Emergency Classification and Protective Action
Recommendations
Rev. 28
PEP-230
Control Room Operations
Rev. 30
PEP-310
Notifications and Communications
Rev. 40
PLP-201
Rev. 70
Corrective Action
Documents
2170854,
2169244,
2134678,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
200795,
Miscellaneous
ERC-009
2: Inoperable Monitor Tracking Sheet
Revision 1,
1/2018-
2/2018
Work Orders
13337885 01
I, MST-I0376/CM-I0085, Plant Vent Stack Accident Monitor
Channel Calibration
08/31/2015
20131381 01
I, MST-I0401/CM-I0085, Cont High Rang Accident Monitor
Calibration
2/12/16
Corrective Action
Documents
Cs-137 detected in REMP samples
11/14/2018
Miscellaneous
Annual MET Data Recovery for 2017 & 2018
Procedures
AD-CP-ALL-0017
Radiological Groundwater Protection
Rev. 2
Work Orders
211627 01
Met Tower Equipment Calibration
06/26/2018
288663 01
Met Tower Equipment Calibration
2/11/2019
71151
Miscellaneous
Regulatory Assessment Performance Indicator Guideline
Rev. 7
Procedures
AD-EG-ALL-1217
Mitigating System Performance Index (MSPI)
Rev. 0
AD-PI-ALL-0700
Performance Indicators
Rev. 2
Engineering
Changes
Turbine-Driven AFW Control System Digital Upgrade
Rev. 21
Procedures
AD-LS-ALL-0006
Notification/Reportability Evaluation
Rev. 2
AD-PI-ALL-0100
Corrective Action Program
Rev. 21
AD-PI-ALL-0101
Root Cause Evaluation
Rev. 6
PIC-I825
Terry Turbine Governor Control System Calibration
(Auxiliary Feedwater Pump)
Rev. 20
Work Orders
20307647
TDAFW pump tripped while starting during OST-1044
01/19/2019