IR 05000400/2011005

IR 05000400-11-005 & 05000400-11-502, October 1, 2011, - December 31, 2011, Shearon Harris Nuclear Power Plant, Unit 1, Routine Integrated Report

ML120260672
Person / Time
Site:	Harris
Issue date:	01/26/2012
From:	Randy Musser NRC/RGN-II/DRP/RPB4
To:	Burton C Carolina Power & Light Co
References
IR-11-502, IR-11-005
Download: ML120260672 (44)

Text

UNITED STATES ary 26, 2012

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000400/2011005 AND 05000400/2011502

Dear Mr. Burton:

On December 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Shearon Harris reactor facility Unit 1. The enclosed inspection report documents the inspection results which were discussed on January 25, 2012, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

No findings were identified during this inspection.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is

CP&L 2 accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-400 License No.: NPF-63

Enclosure:

NRC Inspection Report 05000400/2011005, 05000400/2011502 w/Attachment: Supplemental Information

REGION II==

Docket No.: 50-400 License No.: NPF-63 Report No.: 05000400/2011005, 05000400/2011502 Licensee: Carolina Power and Light Company Facility: Shearon Harris Nuclear Power Plant, Unit 1 Location: 5413 Shearon Harris Road New Hill, NC 27562 Dates: October 1, 2011 through December 31, 2011 Inspectors: J. Austin, Senior Resident Inspector P. Lessard, Resident Inspector R. Patterson, Acting Resident Inspector M. Schwieg, Resident Inspector, Brunswick R. Kellner, Health Physicist (Section 2RS1)

W. Loo, Senior Health Physicist (Section 2RS3)

W. Pursley, Health Physicist (Section 2RS4)

J. Eargle, Reactor Inspector (Section 4OA5)

A. Alen, Reactor Inspector (Section 4OA5)

Approved by: Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000400/2011005, 05000400/2011502; October 1, 2011, - December 31, 2011; Shearon

Harris Nuclear Power Plant, Unit 1; Routine Integrated Report.

The report covered a three month period of inspection by resident inspectors and announced baseline inspection by regional inspectors. No findings were identified during this inspection period.

NRC-Identified and Self-Revealing Findings

None

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near Rated Thermal Power (RTP) for the entire inspection period, except on October 22, 2011, the unit was reduced to 90 percent power for Main Turbine Valve Testing and was returned to RTP later that day.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Winter Seasonal Readiness Preparations

a. Inspection Scope

On December 29, 2011, the inspectors conducted a review of the licensees preparations for winter conditions to verify that the plants design features and implementation of procedures were sufficient to protect mitigating systems from the effects of adverse weather. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Cold weather protection, such as heat tracing and area heaters, was verified to be in operation where applicable. The inspectors also reviewed CAP items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the

. The inspectors reviews focused specifically on the following plant systems due to their risk significance or susceptibility to cold weather issues:

• Refueling Water Storage Tank (RWST)

• Emergency Service Water (ESW)

• Emergency Diesel Generators (EDG)

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR# 505043, Exhaust Fan E-88 Did Not Secure When Required Due to Low Temperature

• AR# 429246, Cabinet Temperature too Cold Creating Spurious Fire Trouble Alarms

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed three partial system walkdowns of the following risk-significant systems:

• The A Emergency Service Water (ESW) system during planned maintenance on the B ESW Booster Pump on October 13, 2011;

• The A Diesel Fuel Oil Storage and Transfer system during the B Essential Services Chilled Water system outage on October 19, 2011; and

• The Motor Driven Fire Pump while the Diesel Driven Fire Pump was out of service for a planned maintenance outage on November 1, 2011.

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, applicable portions of the UFSAR, Technical Specification (TS)requirements, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

On October 11, 2011, the inspectors performed a complete system alignment inspection of the Alternate Seal Injection (ASI) system after a planned maintenance outage to verify the functional capability of the system. This system was selected because it was considered risk significant in the licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that auxiliary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders (WOs) was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the CAP database to ensure that system equipment alignment problems were being identified and appropriately resolved. The documents used for the walkdown and issue review are listed in the Attachment.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Resident Inspector Tours

a. Inspection Scope

The inspectors conducted six fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• Reactor Auxiliary Building (RAB), 236 Elevation, Chemical Volume Control System (CVCS) and Boron Thermal Regeneration System (BTRS) Chillers, Boric Acid Batching and Boron Recycle System Areas

• RAB, 236 Elevation, Component Cooling Water (CCW) and Auxiliary Feedwater (AFW) Area

• RAB, Elevation 236, 1C Charging/Safety Injection pump (CSIP) Transfer and Charging Pump Rooms and Residual Heat Removal (RHR) Heat Exchanger Rooms

• Alternate Seal Injection and Filter Area

• ESW Intake Screening Structure

• Termination Cabinet Room The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the Attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Review of Areas Susceptible to Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures (AOPs), for licensee commitments. The specific documents reviewed are listed in the

. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensees corrective action documents with respect to past flood-related items identified in the CAP program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant area(s) to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• Reactor Auxiliary Building 216 Flooding Area

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the licensees testing of the A CSIP Gear Oil Coolers, Air Handler Four (AH-4) and the B EDG Jacket Water Cooler to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing criteria. Specific documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review

a. Inspection Scope

On November 7, 2011, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crews clarity and formality of communications

• Ability to take timely actions in the conservative direction

• Prioritization, interpretation, and verification of annunciator alarms

• Control board manipulations

• Oversight and direction from supervisors

• Ability to identify and implement appropriate TS actions The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements.

The inspectors reviewed the following AR associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #479905, Operator Communications are not Consistently Meeting Established Standards

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment. The inspectors evaluated degraded performance issues involving the following risk significant components:

• AR #496528, Failure of Nuclear Instrument High Voltage Cable during testing;

• AR #495968, The C Plant Air Compressor Breaker, 1E3-4C will not close in the connect position;

• AR #498794, Chemical Addition Valve 1CT-11 while testing, shut unexpectedly The inspectors focused on the following attributes:

• Implementing appropriate work practices;

• Identifying and addressing common cause failures;

• Scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• Characterizing system reliability issues for performance;

• Charging unavailability for performance;

• Trending key parameters for condition monitoring;

• Ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification;

• Verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #500115, Rework 1EA-E012 EDG 1B Starting Air Dryer Sequencing Timer

• AR #500457, S-3 Fans (Reactor Auxiliary Building) Access Door Left Open (prevents heater operation)

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting the five risk-significant equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Reactor makeup control placed in manual to support maintenance on October 3, 2011 risk elevated to yellow;

• Elevated green risk condition that resulted from deenergizing the B Startup Transformer for planned maintenance on October 18, 2011;

• Unexpected unavailability due to corrective maintenance on the C Air Compressor on October 26, 2011, risk remained green;

• Yellow risk condition while the B Feed Regulating Valve was in manual for narrow range level loop operational testing on October 31, 2011; and

• Unexpected unavailability due to the A Heater Drain Pump being secured on December 7, 2011, risk remained green.

These activities were selected based on their potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors selected the following five potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and UFSAR to the licensees evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the Attachment.

• AR #475602, 1A-SA Chiller Tripping due to Low Lube Oil Pressure;

• AR #498794, 1ET-11, Containment Spray Chemical Addition Valve B Train remained closed when cycled manually;

• AR #499754, 1SC-E012 Emergency Service Water Traveling Screen Chain Thickness;

• AR #501445, Operability Evaluation Needed for a Void Found on A Train Low Head Safety Injection(LHSI) Discharge Line; and

• AR #505470, Operability Evaluation Needed for B EDG Governor Speed Setting Drifting.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The following engineering design packages were reviewed and selected aspects were discussed with engineering personnel:

• Engineering Change (EC) #74822 is a permanent modification, New Security Central Alarm System This permanent modification was performed to comply on the Part 73 upgrades. The residents reviewed the modification from both a security and plant impact aspect.

• EC #83956 is a temporary modification that removed the internals from Valve 1SW-35 (Screen Wash Pump 1A SW Supply). The temporary modification removed the internals of the valve to avoid any further impact of system performance because of erosion and corrosion in the valve guides (the valve is normally locked opened).

These documents and related documentation were reviewed for adequacy of the associated 10 CFR 50.59 safety evaluation screening, consideration of design parameters, implementation of the modification, post-modification testing, and relevant procedures, design, and licensing documents were properly updated. The inspectors observed ongoing and completed work activities to verify that installation was consistent with the design control documents.

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

The inspectors reviewed the following six post-maintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

Test Title Related Date Procedure Maintenance Activity Inspected OST-1214 Emergency Service Water System WO #1899144, 1SW-124 October 3, Operability Quarterly Test Breaker Maintenance 2011 EPT-033 Emergency Sequencer Safeguards WO #1958410, Replacement October 12, Test of B Sequencer Relay 2- 2011 55/1163 OP-149 Fire Protection Work Order (WO) #1702639, October 31, Diesel Driven Fire Pump 2011 Starting Battery Replacement OP-145 Component Cooling Water (CCW) WO #1933867, Replace A November CCW Pump Control Switch 2, 2011 on the Main Control Board OST-1122 Train A 6.9 kV Emergency Bus WO #1979143, A Train UV November Undervoltage (UV) Trip Actuating Relay Setpoint Changes 3, 2011 Device Operational Test and Contact Check OP-139 Service Water System Operating Maintenance on Main December Procedure Reservoir Traveling Screen 16, 2011 These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following: the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing, and test documentation was properly evaluated. The inspectors evaluated the activities against TS and the UFSAR to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment.

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #496988, Battery Heating Pad Found Degraded

• AR #497436, Faulty A CCW Pump Control Switch Caused Ground

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Routine Surveillance Testing

a. Inspection Scope

For the two surveillance tests below, the inspectors observed the surveillance tests and reviewed the test results for the following activities to verify the tests met TS surveillance requirements, UFSAR commitments, inservice testing requirements, and licensee procedural requirements. The inspectors assessed the effectiveness of the tests in demonstrating that the SSCs were operationally capable of performing their intended safety functions.

• OST-1023, Offsite Power Availability Verification Weekly Interval Modes 1-6

• OST-1073, B Emergency Diesel Generator Operability Test on December 15, 2011

b. Findings

No findings were identified.

.2 Reactor Coolant System Leak Detection Inspection Surveillance

a. Inspection Scope

The inspectors observed and reviewed the test results for reactor coolant system leak detection surveillance, OST-1026, Reactor Coolant System Leakage Evaluation, Computer Calculation, Daily Interval, Modes 1-4 on December 5, 2011. The inspectors observed in plant activities and reviewed procedures and associated records to determine whether: effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; and the calibration frequency were in accordance with TSs, the UFSAR, procedures, and applicable commitments; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; test data and results were accurate, complete, within limits, and valid; equipment was returned to a position or status required to support the performance of its safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the CAP. Documents reviewed are listed in the Attachment.

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #497776, Evaluate and Trend Potential Service Water Leakage in Containment

• AR #497457, Increased Volume Control Tank Loss Rate During Pressurizer Steam Space Vent

b. Findings

No findings were identified.

1EP6 Emergency Planning Drill Evaluation

a. Inspection Scope

The inspectors observed an emergency preparedness drill conducted on October 24, 2011, to verify licensee self-assessment of classification, notification, and protective action recommendation development in accordance with 10 CFR 50, Appendix E.

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #495777, Missed Drill and Exercise Performance Opportunity

• AR #496739, Accountability Weakness During Drill

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

Hazard Assessment and Instructions to workers: During facility tours, the inspectors directly observed labeling of radioactive material and postings for radiation areas, high radiation areas (HRAs), and airborne radioactivity areas established within the radiologically controlled area (RCA) of the Unit 1 (U1) and auxiliary building, and radioactive waste (radwaste) processing and storage locations. The inspectors independently measured radiation dose rates or directly observed conduct of licensee radiation surveys for selected RCA areas. The inspectors reviewed survey records for several plant areas including surveys for alpha emitters, hot particles, airborne radioactivity, gamma surveys with a range of dose rate gradients, and pre-job and post surveys for recently completed tasks. The inspectors also discussed changes to plant operations that could contribute to changing radiological conditions since the last inspection. For selected jobs, the inspectors attended pre-job briefings and reviewed radiation work permit (RWP) details to assess communication of radiological control requirements and current radiological conditions to workers.

Hazard Control and Work Practices: The inspectors evaluated access barrier effectiveness for selected U1 Locked High Radiation Area (LHRA) and Very High Radiation Area (VHRA) locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with health physics (HP) supervisors. Controls and their implementation for storage of irradiated material within the spent fuel pool (SFP) were reviewed and discussed in detail. Established radiological controls (including airborne controls) were evaluated for selected work tasks in auxiliary building, and radwaste processing and storage. In addition, licensee controls for areas where dose rates could change significantly as a result of plant shutdown and refueling operations were reviewed and discussed.

Occupational workers adherence to selected RWPs and HP technician (HPT)proficiency in providing job coverage were evaluated through direct observations and interviews with licensee staff. Electronic dosimeter (ED) alarm set points and worker stay times were evaluated against area radiation survey results. ED alarm logs were reviewed and worker response to dose and dose rate alarms during selected work activities was evaluated. For HRA tasks involving significant dose rate gradients, the inspectors reviewed and discussed the licensees procedural requirements for the use and placement of whole body and extremity dosimetry to monitor worker exposure.

Control of Radioactive Material: The inspectors observed surveys of material and personnel being released from the RCA using small article monitor, personnel contamination monitor, and portal monitor instruments. The inspectors reviewed source check records and observed current calibration information labels for selected release point survey instruments and discussed equipment sensitivity, alarm setpoints, and release program guidance with licensee staff. The inspectors compared recent 10 Code of Federal Regulations (CFR) Part 61 results for the Dry Active Waste radwaste stream with radionuclides used in calibration sources to evaluate the appropriateness and accuracy of release survey instrumentation. The inspectors also reviewed records of leak tests on selected sealed sources and discussed nationally tracked source transactions with licensee staff.

Problem Identification and Resolution: Condition Reports (CRs or NCRs) associated with radiological hazard assessment and control were reviewed and assessed. The inspectors evaluated the licensees ability to identify and resolve the issues in accordance with procedures CAP-NGGC-200, Condition Identification and Screening Process, Rev. 34 and CAP-NGGC-205, Condition Evaluation and Corrective Action Process, Rev. 14. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent corporate and self-assessment results.

Radiation protection (RP) activities were evaluated against the requirements of UFSAR Section 12; TS Sections 6.8 and 6.9; 10 CFR Parts 19 and 20; and approved licensee procedures. Licensee programs for monitoring materials and personnel released from the RCA were evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively Contaminated Material. Documents reviewed are listed in Section 2RS1 of the Attachment.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

Plant Airborne Radioactivity Controls and Mitigation: The inspectors reviewed the plants UFSAR to identify areas and/or tasks with the potential for elevated airborne radionuclide concentrations. Selected engineering controls that included temporary HEPA filtration units for minimizing personnel exposure, and airborne radiation monitoring instrumentation located within various areas of the plant were discussed with RP and operations staff. In addition, selected licensee documents including TS, UFSAR, design basis documents, Emergency Response Organization rosters, and procedures associated with plant airborne radioactivity controls and monitoring, and with respiratory protection program and emergency planning implementation were reviewed and discussed with cognizant licensee representatives.

Engineering Controls: Licensee engineering controls to control and mitigate airborne radioactivity were reviewed and discussed. The inspectors evaluated the use of temporary and permanent engineering controls to mitigate airborne radioactivity for selected tasks and operations with the potential for generating airborne activity conditions. The inspectors observed the use of high efficiency particulate air ventilation to control contamination during surface disturbing work for the deconning of lead shielding blankets in the Waste Processing Building. The inspectors evaluated the effectiveness of continuous air monitors and air samplers placed in selected work areas to provide indication of increasing airborne levels. The evaluation included procedural guidance, operability testing, and established configurations during specific tasks. In addition, plant guidance and its implementation for the monitoring of potential airborne beta-gamma and alpha-emitting radionuclides were reviewed and discussed with licensee representatives.

Use of Respiratory Protection Equipment: The inspectors reviewed the use of respiratory protection devices to limit the intake of radioactive material. This included the review of devices used for routine tasks and devices stored for use in emergency situations. Selected Self-Contained Breathing Apparatus (SCBA) units and negative pressure respirators (NPR) staged for routine and emergency use in the U1 Control Room, Operations Support Center and Technical Support Center were inspected for material condition, SCBA bottle air pressure, number of units, and number of spare masks and air bottles available. The inspectors reviewed maintenance records for selected SCBA units and evaluated SCBA and NPR compliance with National Institute for Occupational Safety and Health certification requirements. The inspectors also reviewed records of air quality testing for supplied-air devices and SCBA bottles. The inspectors observed the onsite compressor available for supplying breathing air and verified Grade D or greater air certification for the on-site compressors to include the SCBA bottle filling unit located in the Turbine Building. The ability to fill and transport bottles to the various facilities during an emergency was assessed by the inspectors.

Program guidance for issuance and use of respiratory protection devices were reviewed and discussed with responsible licensee representatives. The inspectors verified the licensee had procedures in place to ensure that the use of respiratory protection devices was ALARA when engineering controls were not practicable. Selected whole-body count routine and investigative analysis results for occupational workers were reviewed and discussed. Respirator and medical qualifications were reviewed for selected emergency responder personnel in the Maintenance, Operations, Chemistry and RP departments. In addition, qualifications for individuals responsible for testing and repairing SCBA vital components were evaluated through review of selected training records.

The inspectors verified that the licensee has procedural requirements in place for evaluating air samples for the presence of alpha emitters and reviewed airborne radioactivity and contamination survey records for several plant areas to ensure air samples are screened and evaluated per the procedure requirements.

Self-Contained Breathing Apparatus for Emergency Use: The inspectors reviewed the status and surveillance records of SCBAs staged for in-plant use during emergencies through review of records and walk-down of SCBAs staged in the U1 Control Room, Operation Support Center and Technical Support Center. The walk-down verified the appropriate number of SCBA kits were staged as specified by the emergency plan, appropriate mask sizes and types available for use, and, through interviews, that users were knowledgeable of storage locations of SCBA, spare masks, and vision correction, as well as how to don and use the equipment to include bottle change out. Selected maintenance records for SCBA units and air cylinder hydrostatic testing documentation were reviewed. Maintenance activities for selected respiratory protective equipment, e.g., compressed gas cylinders, regulators, valves, and hose couplings, by certified vendor technicians was verified for selected SCBA units. During the onsite inspection observed the contract vendor test and repair SCBA vital components for selected units.

Problem Identification and Resolution: Licensee CAP documents associated with the control and mitigation of in-plant radioactivity were reviewed and assessed. This included review of selected CRs related to use of respiratory protection devices including SCBAs. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues in accordance with CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Rev. 14. The inspectors also evaluated the scope of the licensees internal audit program and reviewed recent assessment results. Licensee CAP documents reviewed are listed in Section 2RS3 of the Attachment.

RP activities were evaluated against the requirements UFSAR Section 12; 10 CFR Parts 19 and 20; Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection; and approved licensee procedures. Documents reviewed during the inspection are listed in Section 2RS3 of the Attachment.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

External Dosimetry: The inspectors reviewed National Voluntary Laboratory Accreditation Program (NVLAP) certification data (including TLD testing for neutron, gamma, and beta exposures) and discussed program guidance for storage, processing, and results for active and passive personnel dosimeters currently in use. Licensee evaluations for shallow and deep dose assessments for workers with identified skin contaminations were reviewed and discussed. Comparisons between ED and personnel dosimeter data were discussed in detail. In addition, the inspectors reviewed station guidance for the use of extremity dosimetry, multi-badging, and re-positioning of whole body dosimetry.

Internal Dosimetry: Program guidance (including DAC-hr tracking), instrument detection capabilities, and assessment results for internally deposited radionuclides were reviewed in detail. The inspectors reviewed selected routine and investigative in vivo (Whole Body Count) analyses from January 2010 to October 2011. In addition, capabilities for collection and analysis of special bioassay samples were evaluated and discussed with licensee staff.

Special Dosimetric Situations: The inspectors evaluated the licensees use of multi-badging, extremity dosimetry, and dosimeter relocation within non-uniform dose rate fields and discussed worker monitoring in neutron areas with licensee staff. The inspectors also reviewed records of monitoring for declared pregnant workers since January 2010 and discussed monitoring guidance with licensee staff. In addition, the adequacy of shallow dose assessments for selected Personnel Contamination Events occurring between January 2010 and October 2011 were reviewed and discussed.

Problem Identification and Resolution: The inspectors reviewed and discussed selected CAP documents associated with occupational dose assessment. The inspectors evaluated the licensees ability to identify and resolve the identified issues in accordance with procedure CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Rev. 14. The inspectors also discussed the scope of the licensees internal audit program and reviewed recent assessment results.

HP program occupational dose assessment activities were evaluated against the requirements of UFSAR Section 12; TS Sections 6.8 and 6.9; 10 CFR Parts 19 and 20; and approved licensee procedures. Records reviewed are listed in Section 2RS4 of the report Attachment.

b. Findings

No findings were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

To verify the accuracy of the PI data reported to the NRC, the inspectors compared the licensees basis in reporting each data element to the PI definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline.

Mitigating Systems Cornerstone

• Mitigating Systems Performance Index, Residual Heat Removal

• Mitigating Systems Performance Index, Cooling Water Systems The inspectors sampled licensee submittals for the Mitigating Systems Performance Index performance indicators (MSPI) listed above for the period from the third quarter 2010 through the third quarter 2011. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports and NRC Integrated Inspection reports for the period to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified.

Specific documents reviewed are described in the Attachment.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of items Entered Into the Corrective Action Program

a. Inspection Scope

To aid in the identification of repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed frequent screenings of items entered into the licensees CAP. The review was accomplished by reviewing daily action request (AR) reports.

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #505043, E-88 (B ESW Pump Room Fan) Did not secure when required due to low temperature;

• AR #497430, 1A-SA-8 (A Component Cooling Water Pump Breaker) causes A 125VAC System Trouble Alarm when Tested; and

• AR #497535, Multiple New Control Switches was Found Defective.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.1 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the six month period of July 1, 2011, through December 31, 2011, although some examples expanded beyond those dates where the scope of the trend warranted. The review also included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or reworks maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self assessment reports, and Maintenance Rule assessments.

The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

The inspectors reviewed the following AR associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• AR #497356, Three NRC Findings Linked to Cross Cutting Aspect H.4(A) Human Error Prevention

b. Findings

No findings were identified. The inspectors observed that the licensee performed adequate trending reviews. The licensee routinely reviewed cause codes, involved organizations, key words, and system links to identify potential trends in the CAP data.

.3 Selected Issue Follow-up Inspection: Dedicated Shutdown Diesel Generator Failed to

Start During Testing

a. Inspection Scope

The inspectors selected AR #487331, DSDG Failed to Start During Testing, for detailed review. This AR explored the causes of the DSDG failing to start on two separate occasions. The inspectors reviewed this report to verify that the licensee identified the full extent of the issue, performed an appropriate evaluation, and specified and prioritized appropriate corrective actions. The inspectors evaluated the report against the requirements of the licensees CAP as delineated in corporate procedures CAP-NGGC-0200, Condition Identification and Screening Process and CAP-NGGC-0205, Condition Evaluation and Corrective Action Process.

b. Observations and Findings

No findings were identified.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Findings

No findings were identified.

.2 (Closed) NRC Temporary Instruction (TI) 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter (GL) 2008-01)

a. Inspection Scope

The inspectors reviewed the implementation of the licensees actions in response to GL 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. The systems reviewed included the emergency core cooling system (ECCS), residual heat removal system (RHR), and the containment spray system (CSS).

The inspectors reviewed the licensing basis of the facility to verify that actions to address gas accumulation were consistent with the operability requirements of the subject systems.

The inspectors reviewed the design of the subject systems to verify that the licensees actions taken to address gas accumulation were appropriate given the specifics of the functions, configurations, and capabilities. The inspectors reviewed the design and operation of the RHR system to determine if flashing in RHR suction lines would challenge system operability. The inspectors reviewed selected analyses performed by the licensee to verify that methodologies for predicting gas void accumulation, movement, and impact were appropriate. The inspectors verified that the licensees void acceptance criterion was consistent with NRRs void acceptance criteria. The inspectors performed walkdowns of selected subject systems to verify that the reviews and design verifications conducted by the licensee had drawn appropriate conclusions with respect to piping configurations and pipe slope which could result in gas accumulation.

The inspectors reviewed the licensees re-analysis of the CSS water hammer calculation to verify that the reduced containment isolation valves opening stroke times did not have an adverse effect on the peak forces and resulting structural stresses exerted on the systems piping and supports.

The inspectors also reviewed testing implemented by the licensee to address gas accumulation. Selected test procedures and completed test results were reviewed to verify that they were appropriate to detect gas accumulations that could challenge subject systems. The inspectors reviewed the specified testing frequencies to verify that the testing intervals had appropriately taken historical gas accumulation events as well as susceptibility to gas accumulation into account. The inspectors reviewed selected procedures used for filling and venting following conditions which may have introduced voids into the subject systems to verify that the procedures addressed testing for such voids and provided processes for their reduction or elimination.

The inspectors reviewed selected licensees assessment reports, corrective action program (CAP) documents, and trending data to assess the effectiveness of the licensees CAP when addressing the issues associated with GL 2008-01. In addition, the inspectors verified that selected corrective actions identified in the licensees 9-month and supplemental reports were documented. The inspectors also verified that commitments were included in the CAP.

b. Findings

No findings were identified

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 25, 2012 the inspector presented the inspection results to Mr. Chris Burton, and other members of the licensee staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection period.

A final exit with Dave Corlett and John Doorhy was conducted on October 18, 2011, via phone conference regarding TI-177.

On December 8, 2011, the inspectors discussed preliminary results of the onsite radiation protection inspection with Mr. E. Kapopoulos, Plant Manager, and other responsible staff. The inspectors noted that proprietary information was reviewed during the course of the inspection but would not be included in the documented report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

C. Burton, Vice President Harris Plant

D. Corlett, Supervisor, Licensing/Regulatory Programs

J. Doorhy, Licensing Specialist

J. Dufner, Director, Engineering

D. Griffith, Training Manager

K. Holbrook, Manager, Support Services

E. Kapopoulos, Plant General Manager

B. McCabe, Manager, Nuclear Oversight

M. Parker, Superintendent, Radiation Control

M. Robinson, Superintendent, Environmental and Chemistry

T. Slake, Manager, Security

G. Simmons, Emergency Preparedness Superintendent

M. Wallace, Licensing Engineer

J. Warner, Manager, Outage and Scheduling

F. Womack, Manager, Operations

NRC personnel

R. Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects, Region II

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

05000400/2515/177 TI Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter (GL) 2008-01)

(Section 4OA5.2)