IR 05000400/2007004

Download: ML073030052

Text

October 29, 2007

Carolina Power and Light CompanyATTN:Mr. Robert J. Duncan, IIVice President - Harris PlantShearon Harris Nuclear Power Plant P. O. Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT: SHEARON HARRIS NUCLEAR POWER PLANT - NRC INTEGRATEDINSPECTION REPORT 05000400/2007004

Dear Mr. Duncan:

On September 30, 2007, the US Nuclear Regulatory Commission (NRC) completed aninspection at your Shearon Harris reactor facility. The enclosed integrated inspection reportdocuments the inspection findings, which were discussed on October 4, 2007, with Mr. C.

Burton and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, one inspector identified issue and one self-revealingissue of very low safety significance (Green) were identified. The inspector identified issue andthe self-revealing issue were determined to involve violations of NRC requirements.Additionally, one licensee identified violation is also listed in section 4OA7 of this report.

However, because of their very low safety significance and because they have been entered into your corrective action program, the NRC is treating these issues as non-cited violations, in accordance with Section VI.A.1 of the NRC's Enforcement Policy. If you deny these non-cited violations, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Shearon Harris facility.In accordance with 10 CFR 2.390 of the "NRC's Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) components of NRC's document system CP&L2(ADAMS). ADAMS is 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, ChiefReactor Projects Branch 4 Division of Reactor ProjectsDocket No.:50-400License No.:NPF-63

Enclosure:

NRC Inspection Report 05000400/2007004

w/Attachment:

Supplemental Information cc w/encl:See page 3 CP&L2(ADAMS). ADAMS is 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, ChiefReactor Projects Branch 4 Division of Reactor ProjectsDocket No.:50-400License No.:NPF-63

Enclosure:

NRC Inspection Report 05000400/2007004

w/Attachment:

Supplemental Information cc w/encl:See page 3G PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLEG SENSITIVE G NON-SENSITIVEADAMS: G YesACCESSION NUMBER:_________________________OFFICERII:DRPRII:DRPRII:DRPRII:DRSRII:DRSRII:DRSRII:DRSSIGNATURERAM forMFK1 by emailGRWGBK1HJG1ANDJXD2NAMEPO'BryanMKingGWilsonGKuzoHGepfordANielsenJDiazDATE10/29/200710/26/200710/25/200710/27/200710/15/200710/15/200710/29/2007 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO OFFICERII:DRPSIGNATURERAMNAMERMusserDATE10/29/200710/ /200710/ /200710/ /200710/ /200710/ /200710/ /2007E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNOOFFICIAL RECORD COPY DOCUMENT NAME: C:\FileNet\ML073030052.wpd CP&L3cc w/encl:Paul Fulford, Manager Performance Evaluation and Regulatory Affairs PEB 5 Carolina Power & Light Company Electronic Mail DistributionChris L. BurtonDirector of Site Operations Carolina Power & Light Company Shearon Harris Nuclear Power Plant Electronic Mail DistributionJ. Wayne GurganiousTraining Manager-Harris Plant Progress Energy Carolinas, Inc.

Harris Energy & Environmental Center Electronic Mail DistributionThomas J. Natale, ManagerSupport Services Carolina Power & Light Company Shearon Harris Nuclear Power Plant Electronic Mail DistributionDavid H. Corlett, SupervisorLicensing/Regulatory Programs Carolina Power & Light Company Shearon Harris Nuclear Power Plant Electronic Mail DistributionDavid T. ConleyAssociate General Counsel - Legal Department Progress Energy Service Company, LLC Electronic Mail DistributionJohn H. O'Neill, Jr.Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128Beverly Hall, Chief, Radiation Protection Section N. C. Department of Environmental Commerce & Natural Resources Electronic Mail DistributionPublic Service CommissionState of South CarolinaP. O. Box 11649 Columbia, SC 29211Chairman of the North Carolina Utilities Commission c/o Sam Watson, Staff Attorney Electronic Mail DistributionRobert P. GruberExecutive Director Public Staff NCUC 4326 Mail Service Center Raleigh, NC 27699-4326Herb Council, ChairBoard of County Commissioners of Wake County P. O. Box 550 Raleigh, NC 27602Tommy Emerson, ChairBoard of County Commissioners of Chatham County Electronic Mail Distribution CP&L4Letter to Robert J. Duncan, II from Randall A. Musser dated October 29, 2007

SUBJECT: SHEARON HARRIS NUCLEAR POWER PLANT - NRC INTEGRATEDINSPECTION REPORT 05000400/2007004Distribution w/encl:M. Vaaler, NRR C. Evans (Part 72 Only)

L. Slack, RII EICS RIDSNRRDIRS OE Mail (email address if applicable)

PUBLIC EnclosureU. S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket No:50-400License No:NPF-63 Report No:05000400/2007004 Licensee:Carolina Power and Light Company Facility:Shearon Harris Nuclear Power Plant, Unit 1 Location:5413 Shearon Harris RoadNew Hill, NC 27562Dates:July 1 through September 30, 2007Inspectors:P. O'Bryan, Senior Resident InspectorM. King, Resident Inspector G. Wilson, Project Engineer G. Kuzo, Senior Health Physicist (Sections 2OS3, 2PS3, 4OA1)

H. Gepford, Senior Health Physicist (Section 2OS3)

A. Nielsen, Health Physicist (Sections 2OS1, 4OA1, 4OA7)

J. Diaz, Health Physicist (Sections 2PS1, 4OA1)Approved by:R. Musser, ChiefReactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000400/2007-004; July 1, 2007 - September 30, 2007; Shearon Harris Nuclear PowerPlant, Unit 1; Radiation Monitoring Instrumentation and Protective Equipment, Event Follow-up.

The report covered a three-month period of inspection by resident inspectors and an announced inspection by regional health physics inspectors. Two Green non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

A self-revealing non-cited violation (NCV) was identified for the failure to properly implement operating procedures in accordance with Technical Specifications (TS) 6.8.1. Operator error in procedure implementation led to the A-SA emergency service water (ESW) pump becoming inoperable while swapping the A-SA ESW pump suction from the auxiliary reservoir to the main reservoir. The finding is greater than minor because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). The finding was evaluated using MC 0609, Appendix A, significance determination for at-power situations. The finding is considered to have very low safety significance (Green) because loss of the safety function of the A ESW train was not greater than the allowed technical specification outage time. The finding was related to the oversight aspect of the cross-cutting area of human performance because the licensee did not adequately supervise the swapping of the ESW pumps suction source (H.4.c). (Section 4OA3)

Cornerstone: Occupational Radiation Safety

Green.

An NRC-identified non-cited violation (NCV) of 10 CFR 20.1101 was identifiedfor failure to maintain an acceptable program for process radiation monitor calibrations in accordance with 10 CFR 20.1501(b). Specifically, the licensee failed to maintain a program for periodic calibrations required to assure acceptable operability for process radiation monitoring equipment REM-01CC-3501ASA and REM-01CC-3501BSB used to monitor the component cooling water (CCW) system for potential contamination.The issue is greater than minor because the failure to periodically calibrate the CCWprocess radiation monitors could impair the licensee's ability to accurately identify, trend and take appropriate action regarding any potential inadvertent contamination of a non-radioactive system. This finding is associated with the Occupational Radiation Safety 3EnclosureCornerstone and adversely affects the cornerstone objective attribute to properlymaintain and calibrate radiation monitoring instrumentation to support radioactive material control monitoring activities for the potential release of contaminated materials into non-contaminated areas or equipment. This finding was evaluated using the Occupational Radiation Safety Significance Determination Process (SDP) and wasdetermined to be of very low safety significance based on operation of the CCW as a closed system and lack of identified radioactive contamination associated with systemoperation. The cause of this finding is related to the cross-cutting element of Problem Identification and Resolution (P.1.c). (Section 2OS3).

B. Licensee-Identified Violations

A violation of very low safety significance, which was identified by the licensee, has beenreviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

Enclosure

REPORT DETAILS

Summary of Plant Status The unit began the inspection period at full rated thermal power, and operated at full power untilSeptember 28, 2007. On September 28, during plant shutdown for refueling outage number 14, the reactor tripped from approximately 30% power. The unit remained shutdown for the rest of the inspection period.1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R04Equipment Alignment

a. Inspection Scope

Partial System Walkdowns:The inspectors performed the following three partial system walkdowns, while theindicated structures, systems and components (SSCs) were out-of-service (OOS) for maintenance and testing:* B essential services chilled water train with A essential services chilled watertrain out-of-service on August 22, 2007*A emergency diesel generator with B emergency diesel generator out-of-serviceon August 27, 2007*A emergency service water train with B emergency service water train out-of-service on September 11, 2007To evaluate the operability of the selected trains or systems under these conditions, theinspectors reviewed valve and power alignments by comparing observed positions of valves, switches, and electrical power breakers to the procedures and drawings listed in the Attachment.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

For the thirteen areas identified below, the inspectors reviewed the licensee's control oftransient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures, to verify that those items were consistent with final safety analysis report (FSAR) Section 9.5.1, FireProtection System, and FSAR Appendix 9.5.A, Fire Hazards

Analysis.

The inspectors 5Enclosurewalked down accessible portions of each area and reviewed results from relatedsurveillance tests, to verify that conditions in these areas were consistent withdescriptions of the applicable FSAR sections. Documents reviewed are listed in theAttachment. *Switchgear and switchgear ventilation room A including areas 1-A SWBRA and1-A-5-HVA (2 areas)*Switchgear and switchgear ventilation room B including 1-A SWBRB and 1-A-5-HVB (2 areas)*Main control room and termination cabinet room including 12-A-CR and 12-A-6-CR1 (2 areas)*236' level of the reactor auxiliary building including 1-A-3-COMC, 1-A-3-COMB,and 1-A-3-COMI (3 areas)*261' level of the reactor auxiliary building including 1-A-4-CHFA, 1-A-4-CHFB, 1-A-EPA, and 1-A-EPB (4 areas)

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

On August 7, 2007, the inspectors observed licensed-operator performance duringsimulator training for crew C, to verify that operator performance was consistent with expected operator performance, as described in Exercise Guide SD-SIM-17.09. This training tested the operators' ability to safely shutdown the reactor plant. The inspectors focused on clarity and formality of communication, the use of procedures, alarm response, control board manipulations, group dynamics and supervisory oversight. The inspectors observed the post-exercise critique to verify that the licensee hadidentified deficiencies and discrepancies that occurred during the simulator training.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed two degraded SSC/function performance problems orconditions listed below to verify the licensee's handling of these performance problems or conditions in accordance with 10CFR50, Appendix B, Criterion XVI, Corrective Action, and 10CFR50.65, Maintenance Rule. Documents reviewed are listed in the Attachment.

6Enclosure*C Steam Generator PORV Nitrogen Leak on July 1, 2007*B air dryer failure on September 3, 2007The inspectors focused on the following attributes:

• Appropriate work practices*Identifying and addressing common cause failures

• Scoping in accordance with 10 CFR 50.65(b)

• Characterizing reliability issues (performance)

• Charging unavailability (performance)

• Trending key parameters (condition monitoring)

• 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification

• Appropriateness of performance criteria for SSCs/functions classified (a)(2)and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified (a)(1)The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:*AR #231141, 1MS-62 C S/G PORV Low Nitrogen Pressure*AR #237530, 1MS-62 C SG PORV) Declared Inoperable due to Low NitrogenPressure*AR #240044, B Air Dryer Failure to Operate, Venting Both Towers

• AR #241923, Failure of B Plant Air Dryer

• AR #245178, B Instrument Air Dryer Unavailable

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's risk assessments and the risk managementactions for the plant configurations associated with the six activities listed below. The inspectors verified that the licensee performed adequate risk assessments, and implemented appropriate risk management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk was promptly assessed, and that the appropriate risk management actions were promptly implemented.*Corrective maintenance on the C steam generator power-operated relief valveon July 3, 2007*Corrective maintenance on the A emergency diesel generator load sequencer onJuly 16, 2007*Corrective maintenance on the A emergency diesel generator on July 20, 2007.

7Enclosure*Plant level two grid reliability alert on August 8, 2007*Corrective maintenance on the nuclear instrumentation system with A essentialservices chiller out of service on August 22, 2007*Voiding in the emergency service water back-up supply to the auxiliary feedwatersystem on August 28, 2007.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed six operability determinations addressed in the ARs listed below. The inspectors assessed the accuracy of the evaluations, the use and control ofany necessary compensatory measures, and compliance with the TS. The inspectorsverified that the operability determinations were made as specified by Procedure OPS-NGGC-1305, Operability Determinations. The inspectors compared the justifications made in the determination to the requirements from the TS, the FSAR, and associated design-basis documents, to verify that operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred:*AR #240017, A Emergency Diesel Generator Transfer Relay Failure *AR #239651, A Sequencer Relay Failure

• AR #240968, B Containment Spray Overpressurization

• AR #242498, Pinhole Leak in B ESW System

• AR #242919, B Essential Services Chiller Temperature Drift

• AR #243966, B ESW Pipe Voiding to AFW

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

The inspectors reviewed the modification described in Engineering Change 65825, for achange to allow accepting, storing and using Ultra-Low Sulfur Diesel (ULSD) at Progress Energy Nuclear Generating Sites, to verify that:*this modification did not degrade the design bases, licensing bases, andperformance capabilities of risk significant SSCs 8Enclosure*implementing this modification did not place the plant in an unsafe condition*the design, implementation, and testing of this modification satisfied therequirements of 10CFR50, Appendix BThe inspectors reviewed AR, associated with this area, to verify that the licenseeidentified and implemented appropriate corrective actions:*AR #159226, Diesel Fuel Testing Non-Compliance*AR #209755, Ultra Low Sulfur Fuel Oil Received on 8/06 for EDG B

• AR #226902, Diesel Fuel Oil Testing not per 3/4.8.1.1

• AR #228887, Incorrect Record Identified in Investigation

• AR #238294, ULSD Fuel Oil NCON (GL 91-18)

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the five post-maintenance tests listed below, the inspectors witnessed the testand/or reviewed the test data, to verify that test results adequately demonstratedrestoration of the affected safety function(s) described in the FSAR and TS. The tests included the following:*OP-155, Diesel Generator Emergency Power System after replacement oftransfer relay 43T-DG5SA on July 20, 2007*OST-1839 Component Cooling Water Valve Remote Position Indication TestTwo Year Interval and OST-1216 Component Cooling Water System Operability (A-SA and B-SB Pumps in Service) Quarterly Interval following replacement of 1CC-147 limit switch on August 13, 2007*OST-1080, Auxiliary Feedwater Pump 1X-SAB Full Flow Test Quarterly Intervalafter replacement of flow instrument FT-2050B on September 5, 2007*OP-139, Service Water System after corrective maintenance on the Aemergency service water pump breaker on September 11, 2007*OP-155, Diesel Generator Emergency Power System after scheduledpreventative maintenance on the A emergency diesel generator on September 12, 2007

b. Findings

No findings of significance were identified.

9Enclosure1R20Refueling and Outage ActivitiesThe inspectors evaluated licensee activities as described below, to verify that licenseesconsidered risk in developing outage schedules, adhered to administrative risk reduction methodologies developed to control plant configuration, developed mitigation strategies for losses of the key safety functions identified below, and adhered to operating license and technical specification requirements that maintained defense-in-depth. Documents reviewed are listed in the Attachment.*decay heat removal*inventory control

• power availability

• reactivity control

• containment

.1 Review of Outage Plan

a. Inspection Scope

Prior to the outage, the inspectors reviewed the licensee's outage risk control plan toverify that the licensee had performed adequate risk assessments, and had implemented appropriate risk management strategies when required by 10CFR50.65(a)(4).

b. Findings

No findings of significance were identified.

.2 Monitoring of Shutdown Activities

a. Inspection Scope

The inspectors observed portions of the cooldown process to verify that TS cooldownrestrictions were followed.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

For the five surveillance tests identified below, the inspectors witnessed testing and/orreviewed test data, to verify that the systems, structures, and components involved in these tests satisfied the requirements described in the TS and the FSAR, and that the tests demonstrated that the SSCs were capable of performing their intended safety 10Enclosurefunctions.** OST-1215, Emergency Service Water System Operability Train B QuarterlyInterval Modes 1-6 and Defueled on July 6, 2007*OST-1011, Auxiliary Feedwater System Operability Test Monthly Interval Modes1-4 on July 12, 2007*MST-E0010, 1E Battery Weekly Test on July 24, 2007

• • OST-1076, Auxiliary Feedwater Pump 1B-SB Operability Test Quarterly IntervalModes 1-4 on August 8, 2007** OST-1087, Motor Driven Auxiliary Feedwater Pumps Full Flow Test QuarterlyInterval Mode 1 on September 5, 2007*This procedure included inservice testing requirements.

b. Findings

No findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Controls To Radiologically Significant Areas

a. Inspection Scope

Access Controls The inspectors evaluated licensee performance in controlling workeraccess to radiologically significant areas and monitoring jobs in-progress. The inspectors directly observed implementation of administrative and physical radiological controls; evaluated radiation worker (radworker) and health physics technician (HPT)knowledge of, and proficiency in implementing, radiation protection requirements; and assessed worker exposures to radiation and radioactive material.During facility tours, the inspectors directly observed postings and physical controls forradiation areas, high radiation areas (HRAs), and potential airborne radioactivity areas established within radiologically controlled area (RCA) locations of the Reactor Auxiliary Building (RAB), Waste Processing Building (WPB), and Fuel Handling Building (FHB).

The inspectors independently measured radiation dose rates and noted the location of air monitoring equipment for selected RCA locations. Results were compared to current licensee surveys and assessed against established postings and Radiation Work Permit (RWP) controls. Licensee key control and access barrier effectiveness were evaluated for Locked High Radiation Area (LHRA) and potential Very High Radiation Area (VHRA)locations. Changes to procedural guidance for LHRA and VHRA controls were discussed with health physics 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 were evaluated for selected job 11Enclosuretasks including transfer canal maintenance work and contaminated filter change-out. Inaddition, licensee controls for areas where dose rates could change significantly as a result of plant shutdown and refueling operations were reviewed and discussed.For selected tasks, the inspectors attended pre-job briefings and reviewed RWP detailsto assess communication of radiological control requirements to workers. Occupational workers' adherence to selected RWPs and HPT proficiency in providing job coverage were evaluated through direct observations and interviews with licensee staff.

Electronic dosimeter (ED) alarm set points were evaluated against area radiation surveyresults for transfer canal maintenance and filter change-out activities. For work in the transfer canal, the inspectors observed the use of engineering controls to limit airborne radionuclide intake.The inspectors evaluated the effectiveness of radiation exposure controls, including airsampling, barrier integrity, engineering controls, and postings through a review of both internal and external exposure results. Worker exposure as measured by ED and by licensee evaluations of skin doses resulting from discrete radioactive particle or dispersed skin contamination events during the period April 2006 - May 2007 were reviewed and assessed. The inspectors also reviewed selected Whole Body Count records from the same time period to evaluate licensee assessment of internal dose.

Guidance for the use and placement of whole body and extremity dosimetry to monitor worker exposure in areas with significant dose rate gradients was reviewed and discussed. Radiation protection activities were evaluated against the requirements of Final SafetyAnalysis Report (FSAR) Section 12; Technical Specifications (TS) Sections 6.11 and 6.12; 10 Code of Federal Regulations (CFR) Parts 19 and 20; and approved licensee procedures. Access controls for HRAs, LHRAs, and VHRAs were also evaluated against guidance contained in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants, Revision (Rev.) 1. Records reviewed are listed in Section 2OS1 of the report Attachment.Problem Identification and Resolution Licensee Corrective Action Program (CAP)documents associated with access control to radiologically significant areas were reviewed and assessed. This included review of selected Nuclear Condition Reports (NCRs) related to radworker and HPT performance. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with CAP-NGGC-0200, Corrective Action Program, Rev. 19. The inspectors also evaluated the scope of the licensee's internal audit program and reviewed recent audit results. Licensee CAP documents reviewed are listed in Section 2OS1 of the report Attachment. The inspectors completed 21 of the required line-item samples described in InspectionProcedure (IP) 71121.01.

b. Findings

No findings of significance were identified.2OS3Radiation Monitoring Instrumentation and Protective Equipment

a. Inspection Scope

Radiation Monitoring Instrumentation During tours of the RAB, WPB, FHB, and turbinebuilding, the inspectors observed and evaluated material condition and operational status of installed radiation detection equipment including the following: area radiation monitoring systems, continuous air monitoring instrumentation, and process monitoring equipment; portal monitoring equipment (SPM-904C) and personnel contamination monitoring equipment (ARGOS, IPM-8/9); and post-accident sampling system components. Area and process radiation monitoring equipment observed included monitors for component cooling water (CCW) trains A and B, normal and emergency control room outside air intake, charging pump rooms, residual heat removal heat exchanger and pump rooms, and the spent fuel pool. Sensitivity ranges of selected instruments were compared to FSAR details and other applicable requirements. In addition to equipment walk-downs, the inspectors observed functional checks andalarm set-point testing of various fixed and portable detection instruments. These observations included: calibration of Ludlum 12/133-4 portable instrument, weekly response checks of portal monitors and personnel contamination monitoring equipment, and daily source check results for the whole body counter (WBC). The most recent 10 CFR Part 61 analysis for dry active waste was reviewed to determine if calibration and check sources were representative of the plant source term. The inspectors reviewed the most recent calibration records for the Containment HighRange Accident Monitor (RM-01CR-3589-SA), Containment Leak Detection System Radiation Monitor (REM-01LT-3502A-SA), Containment Vent Isolation Monitor (RM-01CR-3561C-SA), and Spent Fuel Pool Radiation Monitor South (RM-1FR-3564B-SB).

The records were evaluated to determine frequency and adequacy of the calibrations.

In addition, calibration stickers on portable survey instruments identified as "ready-to-use" and friskers staged throughout the radiologically controlled area were noted.

Calibration records for instruments used for transfer canal work observed during the inspection were reviewed. In addition, the most recent calibration of the WBC, its analysis libraries, and the last two cross-check analysis results were reviewed.The inspectors evaluated completion and adequacy of radiation survey instrumentcalibrations performed by Progress Energy's central calibration facility located at the Shearon Harris Nuclear Plant. Availability of portable instruments for licensee use was evaluated through discussion with licensee personnel regarding inventory, logistics, and transfer/receipt of instruments. Records associated with the annual certifications of the gamma irradiator and neutron source used for performing calibrations and routine response checks were reviewed in detail. In addition, the inspectors observed the relocated calibration facility for gamma and neutron instrument calibrations and 13Enclosurediscussed its adequacy for performing instrument calibrations with cognizant licenseepersonnel. Operability and reliability of selected radiation detection instruments were reviewedagainst details documented in the following: 10 CFR Part 20; NUREG-0737, Clarification of TMI Action Plan Requirements; TS Sections 3 and 6.8; FSAR Chapter 12; and applicable licensee procedures. Documents reviewed during the inspection are listed in Section 2OS3 of the report Attachment.

Self-Contained Breathing Apparatus (SCBA) and Protective Equipment Select SCBAunits staged for emergency use in the main control room, operations support center, and technical support center were evaluated for material condition, air pressure, and number of units available. Extra air bottles staged for emergency use were inspected for acceptable air pressure and hydrostatic testing markings. The inspectors walked-down the SCBA bottle-filling station/compressor and reviewed Grade D breathing air certification records for the air compressor and service air. Maintenance records for select SCBA were reviewed. The inspectors noted that vital component maintenance for SCBA units was performed by a vendor. Control room operators were interviewed to evaluate their knowledge of available SCBAequipment locations, including corrective lens inserts if needed, and their training on bottle change-out for extended periods of SCBA use. Respirator qualification records were reviewed for select operations, health physics, chemistry, and maintenance department personnel assigned emergency response duties.Licensee activities associated with maintenance and use of respiratory protectionequipment were reviewed against 10 CFR Part 20; RG 8.15, Acceptable Programs for Respiratory Protection; and applicable licensee procedures. Documents reviewed during the inspection are listed in Section 2OS3 of the report Attachment. Problem Identification and Resolution Selected licensee condition reports, self-assessments, and audits associated with instrumentation and protective equipment were reviewed and assessed. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with procedure CAP-NGGC-0200, Corrective Action Program, Rev. 19. Documents reviewed are listed in Section 2OS3 of the report Attachment.The inspectors completed nine of the specified line-item samples detailed inIP 71121.03.

b. Findings

Introduction:

A Green NRC-identified non-cited violation (NCV) of 10 CFR 20.1101 wasidentified for failure to maintain an acceptable program for periodic calibrations of process radiation monitoring equipment in accordance with 10 CFR 20.1501(b).

Specifically, for CCW process monitors REM-01CC-3501ASA and REM-01CC-3501BSB used to monitor for contamination within the CCW system, the licensee had eliminated 14Enclosureperiodic calibrations and did not have quantitative response check requirements toassure acceptable monitor operability and reliability.

Description:

From review and discussion of current preventative maintenancecalibration activities for process monitoring equipment, the inspectors identified that the CCW Train A and Train B process monitors, REM-01CC-3501ASA and REM-01CC-3501BSB, had the frequency of their calibrations changed from 18 - 24 month frequencies to a 'run to failure' classification. As such, calibrations for the subject process monitoring equipment would be scheduled only following equipment failure or other significant maintenance activities. The last calibrations for the subject monitors were conducted in September 2003. In addition, the inspectors were informed by licensee representatives that source checks for the subject monitors were discontinued in January of 2005. The CCW process monitors are part of the radiation monitoring system (RMS) andprovide an indication to operations personnel whenever the activity in the closed CCW system reaches or exceeds a pre-established level. FSAR Table 11.5.2-1 specifies a range of 1 E+1 to 1 E+7 counts per minute (cpm), typical sensitivity of 1.28 E+8 cpm/microcurie per cubic centimeter, and no automatic isolation function for the monitors.

From review of Abnormal Operating Procedure (AOP)-0005, Radiation Monitoring System, Rev. 24, and discussions with licensee personnel, the inspectors determined that the monitors have high alarm set-points established in accordance with HPP-500, Radiation Monitoring System Data Base Manual, but are used primarily for trending purposes. However, upon a high alarm signal, operations is required to enter and take actions in accordance with AOP-014, Loss of Component Cooling Water, and AOP-015, Excessive Primary Leakage for further evaluation of the source of the contamination. In addition, the inspectors noted that although not a licensee commitment, the subject monitors met the intent of IE Bulletin No. 80-10, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to the Environment.

Further, the inspectors noted that FSAR Section 11.5.2.1.1 specifies that the process and effluent monitoring system will conform with RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations - Effluent Streams and the Environment). RG 4.15 specifies the calibration of monitoring equipment at least once per 18 months; and, whenever practicable, the installation of remotely actuated check sources installed for integrity checks of the detector and the associated electrical system.

Analysis:

For the identified CCW process monitors, the inspectors determined that theelimination of a periodic calibration surveillance program and subsequent classification of the equipment as 'run to failure,' in the absence of quantitative response check acceptance criteria, was a performance deficiency. Although several significant operational occurrences such as loss of/low sample line flow, high temperature alarm, detector high voltage or a shorted system signal, or loss of communication alarm RM-80 to RM-11 would lead to identification of significant monitor problems, the failure to assure accurate radiation measurements either through periodic calibrations or quantitative response checks could impair licensee actions to maintain acceptableradioactive material control activities by monitoring for the potential release of 15Enclosurecontamination materials into uncontaminated equipment or areas. This finding isassociated with the Occupational Radiation Safety Cornerstone and adversely affects the cornerstone objective's attributes to properly calibrate and evaluate process radiation monitoring equipment and instrumentation to support occupational health andsafety activities as a result of routine operations and is, therefore, more than minor.

This finding was evaluated using the Occupational Radiation Safety Significance Determination Process (SDP) and was determined to be of very low safety significance based on routine operation of CCW components as a closed system, conduct of quarterly sampling and radionuclide analyses of the CCW system by chemistry, and the lack of any identified contamination outside of restricted areas. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution because the licensee evaluation and resolution of previous emergency preparedness area monitor calibration issues entered into their corrective action program were not thorough enough to address the causes and extent of conditions, as necessary. The finding was related to the cross-cutting area of problem identification and resolution (P.1.c).Enforcement: 10 CFR 20.1101 requires licensees to establish and maintain acceptableprograms commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part. 10 CFR 20.1501(b) requires, in part, instruments and equipment used for quantitative radiation measurements to be calibrated periodically for the radiation measured. Contrary to 10 CFR 20.1101, as of July 13, 2007, for the CCW Train A and Train Bprocess radiation monitors, the licensee failed to maintain an acceptable periodic PM calibration program or quantitative response check and acceptance criteria guidance to ensure compliance with 10 CFR 20.1501(b). Based on the information that the CCW system routinely is operated as a closed system, and a lack of identified contamination within the system based on quarterly grab samples radioanalyses, the identified issue was determined to be of very low safety significance and has been entered into the licensee's corrective action program (NCR No. 241895). This violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000400/2005004-01, Failure to maintain an acceptable program for periodic CCW process radiation monitor calibrations in accordance with 10 CFR 20.1101.Cornerstone: Public Radiation Safety2PS1Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

a. Inspection Scope

Effluent Monitoring and Radwaste Equipment During inspector walk-downs, accessiblesections of the liquid radioactive waste (radwaste) system including liquid waste processing tanks and associated system piping and valves, and selected gaseous and effluent monitors were assessed for material condition and conformance with current system design diagrams. Inspected components of the gaseous effluent process and release system included sample line configurations for the plant vent air particulate/

noble gas/iodine monitor skid, waste processing building including components 16Enclosureassociated with RM1WV-3547-1 (Stack 5a), RM1WV-3547-2 Skid 5a [Note: PIG isabandoned in place], RM1MWV-3546-1, RM1V-3546-2, RE-21AV-35092SA (Plant Vent Stack), REM-01WL-3540 [LRM Skid - treated LHSTK]. The inspectors also performed walk-down of components associated with liquid isolation valves 3LHS-292 [L&HSTK Discharge] and 3FD-421 [Floor Drain Discharge]. The inspectors interviewed chemistry staff regarding radwaste equipment configuration, effluent monitor operation, and system modifications.The operability, availability, and reliability of selected effluent process sampling anddetection equipment used for routine and accident monitoring activities were reviewed and evaluated. The inspectors reviewed results of calibrations and/or performance surveillances for selected effluent monitors including the FHB Exhaust South Radiation Monitor (REM *1FL 3506), Liquid Radiation Monitor (REM-01BD-3527), Waste Monitor Tanks Discharge Monitor (REM 21WL 3541), Main Stack Flow Rate Monitor and Isokinetic Sampling System Calibration (REM 01AV 3509SA), Containment Leak Detection System Radiation Monitor Calibration (RM-01LT-3502-SA), and Plant Vent Stack Accident Monitor Calibration (RM 21AV 3509 1SA).The two most recent surveillances on the RAB normal exhaust ventilation HighEfficiency Particulate Air (HEPA)/charcoal air treatment systems were also reviewed.

The inspectors evaluated selected out-of-service (OOS) effluent monitors for the period January 2006 through March 2007. The inspectors reviewed selected compensatory actions taken by the licensee when monitors were OOS for the dates referenced above.

Technical bases for effluent monitoring Offsite Dose Calculation Manual (ODCM) and/or system design related changes were reviewed and discussed.Installed configuration, material condition, operability, and reliability of selected effluentsampling and monitoring equipment were reviewed against details documented in the following: 10 CFR Part 20; TS 6.8; RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants, June 1974; ANSI-N13.1-1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities; RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations - Effluent Streams and the Environment, Rev. 1; the ODCM, Rev. 19; and FSAR, Chapters 11 and 12. Procedures and records reviewed during the inspection are listed in Section 2PS1 of the report Attachment.Effluent Release Processing and Quality Control (QC) Activities The inspectors directlyobserved the weekly change-out and processing of the main plant vent, waste processing building 5 and 5A vents, and the turbine building continuous airborne effluent monitoring samples. Chemistry technician proficiency in collecting, processing, and analyzing the samples, as well as preparing applicable release permits was evaluated.QC activities regarding gamma spectroscopy and beta-emitter detection were discussedwith count room technicians. The inspectors reviewed selected May through June 2007 daily QC check data for Liquid Scintillation Counters. The inspectors reviewed selected January 2006 through June 2007 QC data for alpha/beta proportional counters. For 17Enclosuregamma spectroscopy system No. 1 through No. 4, the inspectors reviewed CalendarYear (CY) 2006 through June 2007 daily QC quarterly cross-check summaries and the most recent calibration records. The inspectors reviewed inter-laboratory comparison tests (cross-check) for the 3rd Quarter 2005 through 1st Quarter 2007 to assess the quality of radioactive effluent sample analyses performed.Selected procedures for effluent sampling, processing, and release were evaluated forconsistency with licensee actions. Liquid and gaseous release permits were reviewed against ODCM specifications for pre-release sampling and establishment of effluent monitor set-points. The ODCM was reviewed and discussed with responsible licensee representatives to identify and evaluate any changes made since August 5, 2005. The inspectors also reviewed CY 2005 and CY 2006 annual effluent reports for effluent release data trends and anomalous releases.Changes to licensee programs for monitoring, tracking, documenting, and reporting theresults of both routine and abnormal liquid releases to onsite and offsite surface and ground water environs were reviewed and discussed in detail. The data reviewed and discussed included bases for changes to ODCM groundwater monitoring wells, groundwater flow patterns, and initial results of surface and groundwater samples both on and offsite. Tritium analysis results for groundwater monitoring wells and surface waters were compared to ODCM voluntary reporting requirements. Observed task evolutions (sample collection and release permit generation), count roomactivities, and offsite dose results were evaluated against details and guidance documented in the following: 10 CFR Part 20 and Appendix I to 10 CFR Part 50; ODCM; RGs 1.21 and 4.15; RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I, October 1977; and TS 6.8. Procedures and records reviewed during the inspection are listed in Section 2PS1 of the report Attachment.Problem Identification and Resolution. Selected licensee CAP issues and auditsassociated with effluent release activities were reviewed and assessed. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve selected issues in accordance with CAP-0200, Corrective Action Program, Rev. 19. Reviewed documents are listed in Sections 2PS1 of the report Attachment.

b. Findings

No findings of significance were identified. 2PS3Radiological Environmental Monitoring Program and Radioactive Material ControlProgram

a. Inspection Scope

Radiological Environmental Monitoring Program (REMP) Implementation. During theweek of July 9, 2007, REMP program activities conducted by Harris Energy and 18EnclosureEnvironmental Center (HEEC) laboratory staff were reviewed and evaluated. Thelicensee's 2005 and 2006 Annual Radiological Environmental Operating Reports werereviewed and discussed with licensee representatives. The inspectors evaluated data analyses, surveillance results, and land-use census assessments. Report details were assessed for required monitoring frequencies, sample types and locations, and resultant data trends.The inspectors reviewed and evaluated procedural guidance and its implementation, and assessed knowledge and proficiency of responsible staff. In addition, laboratory analysis QC activities were reviewed and evaluated including inter-laboratory sample comparison results; Lower Limit of Detection (LLD) capabilities for tritium and iodine radionuclides; and flow calibrations for pumps used in REMP airborne sampling systemsOn July 10, 2007, the inspectors toured and evaluated selected sampling stations forlocation and material condition of REMP equipment. Collection of air particulate filters and charcoal cartridges, and flow rate determinations were observed at air sampling stations 1, 2, 4, 5, 26, and 47. The collection and initial preparation of surface water and/or drinking water samples were observed at sampling stations 26, 38, 40 and 51.

Licensee programs regarding composite surface water sampling equipment was reviewed and discussed in detail. The placement and condition of TLDs were evaluated at selected monitoring locations. The inspectors toured recently installed groundwater monitoring well locations and discussed their placement relative to site groundwater flow. Proficiency and knowledge of technicians collecting environmental samples and the adequacy of collection techniques were assessed during field observations an discussions. Program guidance, procedural implementation, and environmental monitoring resultswere reviewed against TS; 10 CFR Parts 20 and Appendix I to 10 CFR Part 50 design criteria requirements; FSAR details; ODCM guidance; and applicable procedures listed in Section 2PS3 of the report Attachment. Specific laboratory QC activities were evaluated against RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plant, June 1974; and RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the Environment, December 1977. Meteorological Monitoring Program Implementation. Licensee program activities toassure accuracy and availability of meteorological data were evaluated. The inspectors interviewed licensee individuals responsible for monitoring the meteorological data reliability and the licensee's meteorology contracting consultants. The inspectors reviewed the licensee's meteorological data for January through December for CY 2005 and CY 2006, for proper validation, correction of errors, and data recovery rates. On July 11, 2007, the inspectors toured meteorological facilities and assessed equipment material condition, and reviewed instrument operability and current meteorological data accuracy.

19EnclosureMeteorological instrument operation, calibration, and maintenance were reviewedagainst details listed in the UFSAR, Chapter 2; RG 1.23, (NRC Safety Guide 23), Onsite Meteorological Programs-1972; ANSI -3.11-2000, Determining Meteorological Information; Regulatory Guide (RG) 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plant, June 1974; and RG 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operation) -

Effluent Streams and the Environment, December 1977; and applicable licensee procedures. Reviewed documents and data are listed in section 2PS3 of the report

.Unrestricted Release of Materials from the Radiologically Controlled Area (RCA).Radiation protection program activities associated with the unconditional release ofmaterials from the RCA were reviewed and evaluated. During the week of July 9, 2007, the inspectors directly observed surveys of potentially contaminated materials released from the RCA using the Small Article Monitor (SAM)-9 equipment. In addition, SAM-9 equipment sensitivity was assessed using a low level radioactive source, i.e. activity approximately 5000 disintegrations per minute. To evaluate the appropriateness and accuracy of release survey instrumentation, radionuclides identified within recent waste stream analyses were compared against current calibration and performance check source radionuclide types. Current calibration and performance check data were reviewed and discussed. In addition, licensee guidance to evaluate survey requirements for hard-to-detect radionuclides were reviewed and discussed.The licensee practices and implementation of monitoring for unconditional release ofmaterials from the RCA were evaluated against 10 CFR Part 20, TS, FSAR Section 12, and applicable procedures. The applicable licensee guidance, calibration records, and performance data are documented in the section 2OS3 of the report attachment.Problem Identification and Resolution. Licensee CAP documents associated with REMPactivities, meteorological monitoring, and the unrestricted release of materials from the RCA were reviewed and evaluated. The inspectors evaluated the licensee's ability to identify, characterize, prioritize, and resolve the identified issues in accordance with CAP-NGGC-0200, Corrective Action Program, Rev. 19. Licensee CAP documents reviewed are listed in Section 2PS3 of the report Attachment.

b. Findings

No findings of significance were identified.4.OTHER ACTIVITIES 40A1Performance Indicator Verification

a. Inspection Scope

The inspectors sampled licensee records to verify the accuracy of reported Performance 20EnclosureIndicator (PI) data for the periods listed below. To verify the accuracy of the reported PIelements, the reviewed data were assessed against guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 5 and the NEI Frequently Asked Questions (FAQ) list.Occupational Radiation Safety Cornerstone. The inspectors reviewed the OccupationalExposure Control Effectiveness PI results for the Occupational Radiation Safety Cornerstone from April 2006 through March 2007. For the assessment period, the inspectors reviewed monthly PI reports and selected NCRs related to controls for exposure significant areas. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Report section 2OS1 contains additional details regarding the inspection of controls for exposure significant areas. Documents reviewed are listed in sections 2OS1 and

4OA1 of the report Attachment.Public Radiation Safety Cornerstone The inspectors reviewed the Radiological ControlEffluent Release Occurrences PI results for the Public Radiation Safety Cornerstone

from April 2006 through March 2007. For the review period, the inspectors assessed cumulative and projected doses to the public, and out-of-service (OOS) effluent radiation monitors and implementation of compensatory sampling and subsequent results. The inspectors also reviewed licensee procedural guidance for collecting and documenting PI data. Documents reviewed are listed in sections 4PS1 and

4OA1 of the

report Attachment.

b. Findings

No findings of significance were identified. 4OA2Identification and Resolution of Problems.1Routine Review of ARsTo aid in the identification of repetitive equipment failures or specific humanperformance issues for followup, the inspectors performed frequent screening of items entered into the CAP. The review was accomplished by reviewing daily AR reports..2Annual Sample Review

a. Inspection Scope

The inspectors selected AR #224951 for detailed review. This AR was associated withrelay failures in the emergency power sequencer circuitry. 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 licensee's corrective action program as delineated in corporate procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B.

b. Findings

No findings of significance were identified. 4OA3Event Follow-up.1Operator Error During Swapping of Emergency Service Water (ESW) Suctions

a. Inspection Scope

The inspectors reviewed an event associated with the emergency service water (ESW)system that occurred on September 19, 2007. The inspectors reviewed plant logs anddata, evaluated performance of systems and operators, and confirmed properclassification and reporting of the event. Documents reviewed are listed in theAttachment.

b. Findings

Introduction:

A self-revealing Green NCV was identified for the failure to properlyimplement operating procedures in accordance with TS 6.8.1. Operator error inprocedure implementation led to the A-SA ESW pump becoming inoperable.

Description:

On September 19, 2007 the licensee was performing a scheduled task toalign A-SA ESW pump suction to the main reservoir from the auxiliary reservoir in orderto prepare for refueling outage 14 per Operating Procedure OP-139, Section 8.1. Thisrealignment is performed by manually opening an 8' by 10' butterfly valve (1SW-3) andthen manually shutting a 30" butterfly valve (1SW-1). The licensee started the A-SAESW pump according to OP-139, Step 8.1.2.1. Soon after continuing with theprocedure, the reactor operator in the main control room noticed that valve 1SW-1, A-SA ESW pump suction from the auxiliary reservoir, was being shut before valve 1SW-3,A-SA ESW pump suction from the main reservoir was opened. The procedure statedthat 1SW-3 was to be locked open before 1SW-1 was to be locked closed. The valvesare operated in this sequence in order to maintain the A ESW train functional. Thereactor operator attempted to contact the operator realigning the valves, but could notestablish communications with him. Before 1SW-1 was shut completely, the reactoroperator aligned the A-SA ESW header from normal service water (NSW) and securedthe A-SA ESW pump to prevent damage due to a loss of suction. Once 1SW-1 wasshut completely, the A-SA ESW pump was declared inoperable and unavailable. Afterreestablishing communications, the reactor operator directed the A ESW suction to berealigned to the auxiliary reservoir by reopening 1SW-1. After this was accomplishedand because the A-SA ESW pump never showed signs of losing suction while it wasrunning, the A-SA ESW pump was declared operable and available. The total time thatthe A-SA ESW pump was inoperable and unavailable was approximately six minutes.

Analysis:

The finding is greater than minor because it is associated with theconfiguration control attribute of the Mitigating Systems Cornerstone and affects thecornerstone objective of ensuring availability, reliability, and capability of systems that 22Enclosurerespond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was evaluated using MC-0609, appendix A, significance determination forat-power situations. The finding is considered to have very low safety significance(Green) because loss of the safety function of the A ESW train was not greater than theallowed technical specification outage time. The finding was related to the oversightaspect of the cross-cutting area of human performance because the licensee failed toproperly supervise the swapping of the ESW pumps suction source (H.4.c).Enforcement: Technical specification 6.8.1 requires that procedures be implemented forthe activities listed in Appendix A of Regulatory Guide 1.33. Contrary to thisrequirement, licensee personnel did not properly implement procedural requirements foroperating the ESW system. Specifically, on September 19, 2007, an operator skippedStep 2 within Section 8.1.2 of OP-139 and inadvertently caused the A-SA ESW pump tobe declared inoperable. Because the finding is of very low safety significance and hasbeen entered into the licensee's corrective action program (AR 247193), this violation isbeing treated as a NCV, consistent with section VI.A.1 of the NRC Enforcement Policy:NCV 05000400/2007004-02, Operator Error During Swapping of Emergency ServiceWater (ESW) Suctions..2(Closed) Licensee Event Report (LER) 05000400/ 2007-02-00, Control Rod ShutdownBank Anomaly Causes Entry into Technical Specification 3.0.3. On June 12, 2007, the licensee was performing a surveillance test which requiredcontrol rods to be inserted into the core ten steps and then withdrawn back to their normal operating positions. During the test, while inserting shutdown bank A, a rod control urgent failure alarm occurred and the rods became inoperable. Since more than one shutdown bank rod were not fully withdrawn and were inoperable, the licensee was in a condition prohibited by Technical Specifications. Trouble-shooting revealed that a master cycler counter card failed and repairs were completed three hours and thirty-one minutes after the failure occurred. All control rods were always capable of being manually or automatically inserted into the core, via a reactor trip. The LER was reviewed by inspectors and no findings of significance were identified and no violation of NRC requirements occurred. The licensee documented the failed equipment in AR

1. 236248. This LER is closed..3Reactor Trip

a. Inspection Scope

The inspectors responded to a reactor trip which occurred on September 28, 2007during a plant shutdown for refueling outage number 14. The reactor tripped from approximately 30% power. The inspectors monitored the operator response from the control room and verified the performance of mitigating systems. Additional event response inspection will be documented in Inspection Report 05000400/2007005.

b. Findings

No findings of significance were identified.4OA6Meetings, including Exit On July 13, 2007, inspectors discussed results of the onsite radiation protectioninspection with Mr. R. Duncan, Site Vice President, and other responsible staff. The inspectors noted that any proprietary information reviewed during the course of the inspection would not be included in the documented report. A subsequent telephone exit was conducted on August 28, 2007, to discuss NRC reviewof licensee data provided to address a potential finding associated with calibration of the CCW process radiation monitors. The inspectors noted that from review of additional licensee data provided, a green NCV was identified for failure to maintain a program for periodic calibrations of the CCW process radiation monitors in accordance with 10 CFR 20.1101.On October 4, 2007, the resident inspectors presented the inspection results for theremainder of the inspection activities to Mr. C. Burton and other members of your staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.4OA7Licensee Identified ViolationsThe following finding of very low significance was identified by the licensee and is aviolation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600 for being dispositioned as a non-cited violation (NCV).10 CFR Part 20.1902(b) requires each high radiation area (HRA) to be conspicuouslyposted. Contrary to this, on July 28, 2006, the HRA posting at the entrance to WPB 211' elevation Floor Drain Tank Room "D" was found on the floor, thereby making the subject posting inconspicuous. On April 17, 2007, the HRA posting to the 190' elevation North Equipment Drain Transfer Tank Room was also found on the floor. Both examples were identified and immediately corrected by health physics techniciansperforming routine locked high radiation areas barrier checks. These events were documented in the licensee's CAP as AR 00201481 and AR 00229805. Although this event involved failure to maintain proper controls to actual HRAs, this finding is of very low safety significance because there was no evidence of unauthorized worker entry into the areas nor unexpected/unintended radiation exposures to licensee personnel. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

D. Alexander, Superintendent, Environmental and Chemistry

C. Burton, Director, Site Operations and Plant General Manager

D. Corlett, Supervisor - Licensing/Regulatory Programs

R. Duncan, Vice President Harris Plant

M. Findlay, Superintendent, Security

W. Gurganious, Training Manager

K. Henderson, Maintenance Manager

C. Kamiliaris, Manager - Nuclear Assessment Manager

T. Natale, Manager - Site Support Services

S. O'Connor, Manager - Engineering

J. Pierce, Supervisor - Nuclear Assessment

M. Burton, Acting Supervisor - Emergency Preparedness

G. Simmons, Superintendent - Radiation Control

J. Warner, Manager - Operations

E. Wills, Manager - Outage and Scheduling

NRC personnel

R. Musser, Chief, Reactor Projects Branch 4

A-2Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and

Closed

05000400/FIN-2007004-01NCVFailure to maintain an acceptable program forperiodic CCW Process Radiation Monitor

calibrations in accordance with 10 CFR 20.1101

(Section 2OS3).

05000400/FIN-2007004-02NCVOperator Error During Swapping of EmergencyService Water (ESW) Suctions (Section 4OA3).Closed

05000400/2007-02-00LERControl Rod Shutdown Bank Anomaly CausesEntry into Technical Specification 3.0.3.

(Section 4OA3).

A-3Attachment

Section 1R04: Equipment AlignmentPartial System WalkdownEssential services chilled water system: *Procedure

OP-148, Essential Services Chilled Water System,

• Drawing 2165-S-0999, Simplified Flow Diagram Essential Services Chilled WaterSystemsEmergency diesel generator system:*Procedure

OP-155, Diesel Generator Emergency Power System,

• Drawing 2165-S-0633, Simplified Flow Diagram Emergency Diesel GeneratorSystemsEmergency service water system:*Procedure

OP-139, Service Water System,

• Drawing 2165-S-0547 and 2165-S-0548 , Simplified Flow Diagrams Circulatingand Service Water Systems

Section 1R05:

Fire Protection*FPP-001, Fire Protection Program Manual*FPP-012-02-RAB261,Reactor Auxiliary Building Elevation 261 Fire Pre-Plan

• FPP-012-02-RAB 236, Reactor Auxiliary Building Elevation 236 Fire Pre-Plan

• FPP-012-02-RAB286, Reactor Auxiliary Building Elevation 286 Fire Pre-Plan

• FPP-012-02-RAB305-324, Reactor Auxiliary Building Elevations 305 and 324Fire Pre-Plan

Section 1R11: Licensed Operator Requalification*SD-SIM-17.09, Simulator Training Guide*GP-006, Normal Plant Shutdown From Power Operation to Hot StandbySection 1R12:

Maintenance Effectiveness*NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness ofMaintenance at Nuclear Power Plants*ADM-NGGC-0101, Maintenance Rule Program

• WO

1072424, M, 1MS-62:005, Has Small Nitrogen Leak on Top of Gas Bottle

• WO

1082862, M,

CM-M0186, 1MS-62:005, Repair N2 Leak, Fill & Bleed

• WO

1085675, 1MS-62 Has Low N2 Pressure Causing a MCB Alarm

• WO

731586, Repair 1CO-150 Valve is Leaking By

• WO

1091254, 1CO-189 is Leaking by due to Defective Solenoid 1CO-191

• WO

1120438, Replace 1CO-193, Check Valve Leaks by the Seat

A-4Attachment*WO

1120439, Replace 1CO-194, Check Valve Leaks by the Seat*WO

1116357, 1CO-E045, Dryer is blowing down With Dryer Pressurized andDeenergized

Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation*OMP-003, Outage Shutdown Risk Management.*WCM-001, On-line Maintenance.Section 1R15:

Operability Evaluations*OPS-NGGC-1305, Operability Determinations

Section 1R17: Permanent Plant Modifications*System Description

SD-155.01, Emergency Diesel Generator*Final Safety Analysis Report Section 8.3.1, On-Site Power Systems, AC Power

• Final Safety Analysis Report Section 9.5.4, Diesel Generator Fuel Oil Storageand Transfer SystemSection 1R19: Post Maintenance Testing*WR

295620, 43T-DG5/SA Transfer Relay Will Not Rotate to Transfer Position*AR #240017, Transfer Relay 43T-DG5-SA Failed to Transfer to Local

• WO

1059103, I, 1CC-147 Has Loose Limit Switch Shaft

Section 1R20: Refueling and Outage Activities*FHP-020, Refueling Operations*FHP-014, Fuel and Insert Shuffle SequenceSection 2OS1: Access Controls To Radiologically Significant Areas Procedures, Guidance Documents, and Manuals

• NGGM-PM-0002, Radiation Control and Protection Manual, Rev. 36 *HPS-NGGC-0003, Radiological Posting, Labeling, and Surveys, Rev. 10 *AP-504, Administrative Controls for Locked and Very High Radiation Areas, Rev.23 *HPP-600, Radiation Work Permits, Rev. 21

• CAP-NGGC-0200, Corrective Action Program, Rev. 19Records and Data Reviewed *ALARA Work Plan - Fuel Transfer Canal, Transfer Cart and Gate Valve

A-5AttachmentMaintenance, Rev. 7 *RWP No.

00001771, Routine Operations Activities *RWP No.

00001769, Health Physics Activities

• RWP No.

00001780, Filter Changes on Contaminated Systems

• RWP No.

00004154, Transfer Canal Work

• Air Sample No.

AS-20070710-003,

FHB 286' - 1-4 Transfer Canal, 7/10/07

• Air Sample No.

AS-20070710-004,

FHB 286' - 1-4 Transfer Canal, 7/10/07

• Radiological Survey No. 0307-004,

RAB 190N - Eqmt. Drain TransferTank/Pumps, 3/7/07 *Radiological Survey No. 0211-012,

WPB 211 - Waste Holdup Tank, 2/11/06

• Radiological Survey No. 0710-004,

FHB 286' - South End Gates 1 Thru 4,7/10/07 *Alpha Smear No. 200707101023, 1-4 Transfer Canal, 7/10/07

• Contamination Event Logs, April 2006 - May 2007

• Selected Whole Body Count Records, April 2006 - May 2007

• Selected Access Control Records, April 2006 - May 2007CAP Documents *H-RP-06-01, Harris Radiation Protection Assessment, 10/25/07 *AR

00201481, LHRA posting found on floor, 7/28/06

• AR

00229805, LHRA posting found on floor, 4/17/07 *AR

00193852, Worker logged onto wrong RWP and received dose rate alarmupon entering pressurizer cubicle, 5/8/06 *AR

00222148, Short length of HRA boundary rope found down, 2/11/07

• AR

00213804, Trend noted in radioactive material labeling deficiencies, 11/17/06

• AR

00213034, Alpha surveys missed, 11/15/06

• AR

00223246, Alpha monitoring program needs to be re-evaluated, 2/21/07

• AR

00216291, LHRA door was found with exit latch missing, 12/12/06

Section 2OS3: Personnel Radiation Monitoring Instrumentation and ProtectiveEquipment

Procedures

• Abnormal Operating Procedure (AOP)-005, Radiation Monitoring System,Rev. 24 *AOP-014, Loss of Component Cooling Water, Rev. 29

• AOP-016, Excessive Primary Leakage, Rev. 37

• AOP-018, Reactor Coolant Pump Abnormal Conditions, Rev. 33

• Auxiliary Operator Rounds Guidance, Rev. 39

• AP-512, Use of Respiratory Protection Equipment, Rev. 30

• ADM-NGGC-0107, Equipment Reliability Process Guideline, Rev. 7

• CRC-821, Post-Accident Sampling, Rev. 27

• DOS-NGGC-0019, Whole Body Counter (WBC) Intercomparison Testing, Rev. 6

• DOS-NGGC-0020, WBC System Calibration, Rev. 7

A-6Attachment *EPM-420, Emergency Equipment Inventory, Rev. 7 *HPS-NGGC-0013, Personnel Contamination Monitoring, Decontamination, andReporting, Rev. 6 *HPP-630, Respiratory Protection, Rev. 20

• HPP-631, Certification and Operation of Breathing Air Supplies, Rev. 18

• HPP-725, Operation of Whole Body Contamination and Portal Monitors, Rev. 17

• HPP-780, Radiation Monitoring System Operator's Manual, Rev. 35

• HPS-0005, Calibration of Portable Radiation and Contamination, Rev. 7

• HPS-0009, Operation of Radiation & Contamination Survey Instruments, Rev. 3

• HPS-0011, Cs-137 Calibration Source Standardization, Rev. 4

• SIC-700, Operation and Certification of Calibration Standards, Rev. 10

• SIC-710, Calibration of Semi-Portable Radiation Detection Equipment, Rev. 9

• SIC-720, Calibration of Semi-Portable Air Sampling Equipment, Rev. 9

• SIC-725, Calibration of Whole Body Friskers or Portal Monitors, Rev. 13

Records and Data *WBC Calibration Record, 9/12/06

• MST-I0401/CM-I0085, Containment High Range Accident Monitor Calibration,4/26/06 *MST-I0355/CM-I0085, Containment Leak Detection System Rad MonitorCalibration, 5/7/06 *MST-I0351/CM-I0085, Containment Vent Isolation Monitor Calibration, 4/23/06

• MST-I0387/CM-I0085, SFP Radiation Monitor South Channel Calibration,12/28/05 *EST-212 Attachment 41, Penetration M-88 Liquid Sample Return from Post-Accident Skid LLRT for 1SP-201 and 200, 4/18/06 *EST-212 Attachment 9, Penetration M-33 Gas Sample Return from Post-Accident Skid LLRT for 1SP-208 and 209, 5/11/06 *WBC Calibration Record, Standup #1, 9/8/06

• Results for WBC Confirmatory Measurement Program, 3rd Quarters 2005 and2006 *Calibration Records:

Tennelec s/n 2 (11/14/06); Tennelec s/n 3 (11/15/06);

AMS-3 s/n 1407 (8/22/06);

LMC-12/42-30 s/n 35965 (9/13/06);

LMC 177 s/n34541 (2/19/07);

LMC 177 s/n 45559 (2/19/07);

DCA 3090 s/n

473291 (2/2/07);

RO-2 s/n 2557 (4/11/07);

RO-2 s/n 1706 (4/11/07); SAM s/n 141 (1/26/07); SAM

s/n 142 (6/7/06, 3/1/07); SAM s/n 143 (7/31/06); SAM s/n 154 (8/19/06); SAM s/n

196 (8/18/06); SAM s/n 23 (8/22/06); ARGOS s/n

510014 (1/11/06); ARGOS s/n

510016 (1/12/06); ARGOS s/n

510013 (1/5/06); ARGOS s/n 510-016 (1/5/06);

ARGOS s/n

510014 (1/5/06); ARGOS s/n

510015 (3/29/06);

SPM-904C s/n

90436 (7/15/06);

SPM-904C s/n 90437 (7/17/06);

SPM-906 s/n 906093

(3/28/06);

SPM-906 s/n

906095 (6/8/05);

SPM-906 s/n

906084 (4/18/06); SPM-

906 s/n

906084 (4/20/06);

IPM-8 s/n 368 ( 8/18/06);

IPM-8 s/n 374 (3/28/06,

2/20/07);

IPM-8 s/n 152 (4/1/06);

IPM-9 s/n 317 (3/2/07);

IPM-9 s/n 318

(10/16/06) *Hydrostatic Test Data: bottles 2193 (1/04), 2482 (12/03), and 2959 (1/04)

• Scott PosiCheck3 Data for select SCBA:

12/21/06

A-7Attachment *Respirator Equipment History Record for select SCBA: 2005-2006 *

Grade D Air:

Blast yard compressor (7/26/05, 1/26/06, 2/6/06, 8/2/06, 2/13/07),

Eagle air compressor (7/26/05, 2/8/06, 8/4/06, 2/13/07), Service air compressor(7/26/05, 2/7/06, 8/2/06, 2/13/07) *Battelle Calibration Report, model 530 electrometer, s/n 219, and two probes,9/19/06 *NIST Report of Test, Ludlum model 12 with 10" rem ball, s/n 66625, 2/16/07

• Neutron Certification Data Sheet, 6/13/07

• Radiation Field Measurement Data, Shepherd model 28, 3/29/07

• Radiation Field Measurement Data, Shepherd model 89, 3/27/07

• WO

00192908, Perform

PIC-I907, Inspect & Calibrate Liquid Radiation Monitor,REM-01CC-3501B, 09/17/03 *WO

00224205 01, Perform

PIC-I907, Inspect and Calibrate Liquid RadiationMonitor,

RC-01CC-3501ASA, 10/01/03. *Drawing

CPL-2165 S-1319, Simplified Flow Diagram, Component Cool Water,Sheet 1,Rev. 17 *Drawing

CPL-2165 S-1320, Simplified Flow Diagram, Component Cool Water,Sheet 2, Rev. 0317Corrective Action Program Documents *H-RP-05-01, Harris Radiation Protection Assessment, 11/2/05 *H-RP-06-01, Harris Radiation Protection Assessment, 10/25/06

• Self-Assessment

147223, Radiation Protection Emergency Preparedness,8/29/05-9/2/05 *Self-Assessment

160150, Radiation Protection Central Calibration Facility,7/18/05-7/22/05 *Self-Assessment

178837, Respiratory Protection Program, 7/3/06-12/1/06

• PMR

138482, Delete the RTF PM tasks for system 7005, 9/28/04

• NCR

165629, EP Rad monitors classified as RTF need to be reevaluated, 8/4/05

• NCR

172139, Issue 1 central cal lab output and performance, 10/10/05

• NCR

191133,

RO-2 instrument failure, 4/14/06

• NCR

198890, Instrument used without current source check, 6/29/06

• NCR

200053, HP cal lab environment out of tolerance 7/13/06

• NCR

215383, Material condition of the AV2000 and MSA respirators are in poorcondition,12/5/06 *NCR

220499,

RM-35RM-3505A2, CR ventilation outside air intake failed, 1/27/07

• NCR

222313, Radiation monitor

RM-1CZ-3505A2 in communication failure,2/13/07 *NCR

222655, Instrument used after calibration due date, 2/15/07

• NCR

227536, Evaluate portal monitor alarm check source activity, 3/28/07

• NCR

227595, Radiation monitors in communication failure, 3/29/07

• NCR

228318, RMS Re-occurring problems, 4/4/07

• NCR

232619, RCA exit practice review, 5/10/07

• NCR

232992, Personnel not following RCA exit monitor posting instructions,5/14/07

A-8Attachment

Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and MonitoringSystems

Procedures, Guidance Documents, and Manuals *SHNPP Updated Final Safety Analysis Report, (Chapter 11) *AOP-009,

Accidental Release of Waste Gas, Rev. 17

• AP-523, Preparation of the Annual Effluent Release Report, Rev. 10

• AP 556, Effluent Management Program, Rev 2

• CRC-240, Plant Vent Stack 1 Effluent Sampling, Rev. 10

• CRC-241, Turbine Building Vent Stack 3A Effluent Sampling, Rev. 13

• CRC-242, Waste Processing Building Vent Stack 5 Effluent Sampling, Rev. 14

• CRC-243, Waste Processing Building Vent Stack 5a Effluent Sampling, Rev. 11

• CRC-245, Particulate and Iodine Grab Sampling on Wide Range Gas Monitors,Rev. 6 *CRC-851, ODCM Software Instructions And Documentation

• REG-NGGC-0009, NRC Performance Indicators and Monthly Operating ReportData, Rev. 6 *MST-I0378, Plant Vent Stack Accident Monitor

RM-21AV-3509-1SA OperationalTest *MST-I0302, Waste Monitor Tanks Discharge Flow Loop (F-6119) Calibration

• MST-I0327, Waste Monitor Tanks and Waste Evaporator Condensate TanksDischarge Radiation Monitor

REM-21WL-3541 Calibration *MST I0411, Main Plant Vent Stack Flow Rate Monitor and Isokinetic SamplingSystem Calibration, Rev. 10 *MST I0376, Plant Vent Stack Accident Monitor

RM 21AV 3509 1SA Calibration,Rev 15 *PLP-500, Fish Kill Reporting, Hazardous Substances Release Notification, NonRoutine Radioactive Release Notification, and Oil Spill Notification, Rev. 19 *RST-210, Liquid Effluent Radiochemistry Surveillance, Rev. 19

• RST-211, Gaseous Effluent Radiochemistry Surveillance, Rev. 18

• Plant Operating Manual Volume 1, Part 2, plant Program Procedure,

PLP-500,Fish Kill Reporting, Hazardous Substances Release Notification, Non-routine Radioactive Release Notification, and Oil Spill Notification, Rev. 19

Records and Data *HNP-06-046, 2005 Annual Radioactive Effluent Report, dated 04/17/06 *HNP-07-046, 2006 Annual Radioactive Effluent Report, dated 04/13/07

60009.036.001.G, Gaseous Radioactive Waste Release Permit (Pre-Release

Supplementary Data and Post-Release Permit Update) *70092.031.022.G, Continuous Gaseous Effluent Permit (Pre-Release

Supplementary Data and Post-Release Permit Update) *70112.034.001.G, Gaseous Effluent Permit (Pre-Release Supplementary Data and Post-Release Permit Update) *70116.011.028.G, Gaseous Effluent Permit (Only Post-Release Permit Update) *70021.001.010.L, Liquid Effluent Release Permit

A-9Attachment *70022.002.009.L, Liquid Effluent Release Permit *WO

00149656-02, Perform

PIC-I904 FHB Exhaust Radiation Monitor Calibration(REM *1FL 3506) *WO

00440547-01, Perform

PIC-I906 Calibration of General Atomic LiquidRadiation Monitor (REM-01BD-3527) *WO

00525250-01, Perform MST I0327 Waste Monitor Tanks Discharge Monitor(REM 21WL3541) Calibration *WO

00584736-01, Perform

MST-I0411 Main Stack Flow Rate Monitor andIsokinetic Sampling System Calibration (REM 01AV 3509SA) *WO

00626340-01, Perform

MST-I0355 Cont Leak Detection System RadiationMonitor Calibration (note: monitor

RM-01LT-3502-SA) *WO

00628714-01, Perform

MST-I0351/CM-I0085, Cont Vent ISO MonitorCalibration (note: monitor

RM-01CR-3561CSA) *WO

00654952-01, Perform

MST-I0376 Radiation Monitoring System (RMS) RM21AV 35091SA Plant Vent Stack Accident Monitor Channel Calibration *WO

00709037-01, PVS Flow Rate Monitor Reading High Value

• WO

00733508-01, Perform MST I0302 Waste Monitor Effluent Line FlowCalibration (REM21WL 3541) *WO

00775545-04, Remove Floor Plug for Waste Gas Leak (note: first leak in2005) *WO

00703170-02, Airflow Capacity/E-46/WPB Filtered (note: performance ofEPT-400) *WO

00803679-01, Remove Clamp per

EC 63124 and Replace Piping (note: QClass C Portion/Pipe Replacement) *WO

00803679-02, Leak Repair Pipe per EC 63124

• WO

00803679-04, Remove Floor Plugs for Waste Gas Leakage TroubleShooting *WO

00803679-05, Removing/Reinstalling Floor Plugs in WPB and RAB asDirected by Engineering *WO

00803679-06, Replace Elbow Up-Stream of Valve 3WG-20 and PipeBetween Elbow and Tee Down Stream of 3WG-217 (note: Q Class A

Portion/Pipe replacement) *WO

00883914-01, Perform

MST-I0378 Plant Vent Stack Accident Monitor RM21AV 35091SA Calibration *WO

00890667-01,

EPT-400 E-19 Failed to Achieve Minimum Req. Airflow Rate

• EST-400, E-13-1X-SB FHB Emergency Exhaust Tests (Rev. 16, Attachments 2,3, 4, 5, 6, 7, 8, and 15), multiple dates (June 06) *EPT-400, E-17 RAB Normal Exhaust Tests (Rev. 13, Attachments 2, 3, 4, 6, 7,and 12), multiple dates (July and August 06; Failed Test) *EPT-400, E-17 RAB Normal Exhaust Tests (Rev. 13, Attachments 2, 3, 4, 5, 6,7, 12 and 25), multiple dates (October 06) *EPT-400, E-19 RAB Normal Exhaust Tests (Rev. 13, Attachments 2, 3, 4, 6, 7,and 13), multiple dates (August 06) *EPT-400, E-19 RAB Normal Exhaust Tests (Rev. 13, Attachments 2, 3, 4, 5, 6,7, 13 and 25), multiple dates (October 06) *EPT-400, E-45 WPB Normal Exhaust Tests (Rev. 13, Attachments 2, 3, 4, 5, 6,7,13, 14 and 25), multiple dates (January and February 07)

A-10Attachment *EPT-400, E-46 WPB Normal Exhaust Tests (Rev. 13, Attachments 2, 3, 4, 5, 7,14 and 25), multiple dates (January and February 07) *EST-400, E-6-1A-SA RAB Emergency Exhaust Tests (Rev. 16, Attachments 2,3, 4, 5, 6, 7, 8, 10, and 17), multiple dates (November 06) *EPT-400, S-1-1A&B Exhaust Tests (Rev. 13, Attachments 2, 5, 6, 7, 21, 22 and25), multiple dates (May and June 06) *OP-119, Rev. 16, Attachment 7 - WPB Stack 5A Estimated Flow Rates (usedwhen flow rate monitors are out of service), dated 11/20/06 *ERC 01 009, Evaluation of Lower Limit of Detection of Radioactivity in SewageSludge, Rev. 0, dated 11/15/01 *Chemistry LSC QC (H-3 Bkg., H-3 Eff., C-14 Bkg., C-14 Eff.) Charts (05/07) todated 06/29/07 *Chemistry A/B Counters (units Tennelec 1, 2, and 3) Alpha Bkg., Alpha SourceCheck, Beta Bkg., and Beta Source Check QA Histograms (dates 01/06 to

06/07) *Chemistry HPGE Canberra Counters (units 1, 2, 3, and 4) Total Counts, 122 KeV/779KeV/1408 KeV peak energy, 122 KeV/779KeV/1408 KeV FWHM QA

Histograms (dates 12/05 to 06/07)

CAP Documents *00147195, Environmental Risk Assessment Report (Self-Assessment) *00180278, Triennial Laboratory QA/QC Review

• 00216351, HNP REMP Activities and HNP Groundwater Protection InitiativeImplementation *HNAS-06-024, Harris Environmental and Chemistry Assessment, dated 04/25/06

• NCR

00180434,

AOP-009 Entry Due to Leak in Waste Gas System, dated01/09/06 *NCR

00202867,

SA 180278, W 2, LLD Documentation, 08/10/06

• NCR

00191137, KPI for Particulate Effluent Release Turned Red, 04/14/06

• NCR

00230420, STP Effluent Flow Meter Failure, dated 04/20/07

• NCR

00224995, EMS Software Error Processing High Tritium Permit, dated03/07/07 *NCR

00222165, Gaseous Effluents-Noble Gas KPI, dated 02/12/07

• NCR

00216371, Crystal River Potential Violation Impact on HNP, dated 12/13/06

• NCR

00213702, Review of Revised NRC Inspection Module, dated 11/17/06

• NCR

00203466, Count Room Unavailable due to VAX/CAS Problems, dated08/16/06 *NCR

00202866,

SA 180278 W 1 Cross Check Programs, dated 08/10/06

• NCR

00196007, Entry Error Code Misleading in Gas Effluent Software, dated05/30/06 *NCR

00169769, Radioactive Gas Leakage from RWST Vent via 1CS 752, dated09/19/05 *NCR

00153212, RWST Level Trend Changes, dated 03/10/05

• NCR

00162736, Waste Gas System Leakage, 07/02/05 (includes several InterimMonitoring of Potential Release Point Data Sheet Report) *NCR

00173330,

AOP 009 Entry - Depressurization of Waste Gas Decay Tank J

A-11Attachment *NCR

00198385, HNP Groundwater Initiative (NEI Action Plan), 06/25/06 *NCR

00223840, Potential Underground Leak from Fire Protection or PotableWater, 02/27/07 *NCR

00224994, Underground Leak Evaluation, 03/07/07

Section 2PS3: Radiological Environmental Monitoring Program (REMP) and RadioactiveMaterial Control Program

Procedures, Guidance Documents, and Manuals *Shearon Harris Nuclear Power Plant (SHNPP) Off-Site Dose Calculation Manual,Rev. 17 *EVC-NGGC-0001, Operation and Calibration of HNP Environmental AirSamples, Rev. 6 *EVC-NGGC-0002, Operation of the HNP Portable Water Samplers, Rev. 4

• EVC-NGGC-0003, Radiological Environmental Monitoring Program for HNP,Rev. 5 *EVC-NGGC-0007, The Reporting of Anomalous Results, LLD Requirements, APriori Calculations, and Interlaboratory Comparison Program Acceptance Criteria Evaluation for Radiological Environmental Samples, Rev. 4Data and Records Reviewed *Environmental and Chemistry Technical Note/Report (ERC)-06-002, Evaluationof

GW-58, Rev. 0

Review of Current Radiological Monitoring Program, 08/17/06 *Harris Energy & Environmental Center (HEEC) Environmental Cross CheckProgram Results for: 3rd Quarter 2005, 4th Quarter 2005, 1st Quarter 2006, 2ndQuarter 2006, 4th Quarter 2006 *Dry Gas Meter Calibration Data for: Air Sampler No. 2225, Rockwell Meter6957699; Air Sampler No. 2226, Rockwell Meter

6957698;

Air Sampler No. 2229, Rockwell Meter

7322223; Air Sampler No.2230, Rockwell Meter

22225; and Air Sampler No. 2231, Rockwell Meter

7322226; Air Sampler No. 2232, Rockwell Meter

6957700 and Air Sampler No. 2233, Rockwell Meter

22231; conducted using Venturi Digital Calibrator Serial Number/ID Number

(S/N) 2668/ACL-051, dated 01/29/07 *Dry Gas Meter Calibration Data for: Air Sampler No. 2234, Rockwell Meter7322232; Air Sampler No. 2758, Rockwell Meter

9320375;

Air Sampler No. 2758, Rockwell Meter

9320375; Air Sampler No.2759, Rockwell Meter

20376; and Air Sampler No. 2760, Rockwell Meter

9751890; Air Sampler No. 2761, Rockwell Meter

9571891; Air Sampler No. 2762, Rockwell Meter

9571889; and Air Sampler No. 2763, Rockwell Meter

9571894; conducted using Venturi Digital Calibrator

SN 2668/ACL-051, dated 10/27/06 *Dry Gas Meter Calibration Data for: Air Sampler No. 2225, Rockwell Meter6957699; Air Sampler No. 2226, Rockwell Meter

6957698;

Air Sampler No. 2229, Rockwell Meter

7322223; Air Sampler No.2230, Rockwell Meter

22225; and Air Sampler No. 2231, Rockwell Meter

7322226; Air Sampler No. 2232, Rockwell Meter

6957700; Air Sampler No. 2233, Rockwell Meter

2Attachment7322231 and Air Sampler No. 2234, Rockwell Meter

7322232; conducted usingVenturi Digital Calibrator S/N 2668/ACL-051, dated 04/28/06 *Dry Gas Meter Calibration Data for: Air Sampler No. 2231, Rockwell Meter7322226; Air Sampler No. 2232, Rockwell Meter

6957700;

Air Sampler No. 2758, Rockwell Meter

9320375; Air Sampler No.2759, Rockwell Meter

20376; and Air Sampler No. 2760, Rockwell Meter

9571890; Air Sampler No. 2761, Rockwell Meter

9571891; Air Sampler No. 2762, Rockwell Meter

9571889; and Air Sampler No. 2763, Rockwell Meter

9571894; conducted using Venturi Digital Calibrator S/N 2668/ACL-051, dated 10/11/05 *Calibration Data Sheet, Pressure Calibrator D-812,

SN 2668, Flow Standard

CY 2005, Radiological Environmental Monitoring TLD Report, and RadiologicalMonitoring Analysis Report

CY 2006, Radiological Environmental Monitoring TLDReport, and Radiological Monitoring Analysis Report *Work Order (WO) Package

00964161 01, Perform Maintenance Periodic Test(MPT) - I0129, Meteorological Tower Equipment Calibration, 03/16/07 *WO Package

00835712 01, Perform MPT - I0129, Meteorological TowerEquipment Calibration, 09/15/06 *WO Package

00761767 01, Perform MPT - I0129, Meteorological TowerEquipment Calibration, 03/27/06 *WO Package

00759611 01, Perform MPT - I0129, Meteorological TowerEquipment Calibration, 10/05/05 *WO Package

00994251 01, General Inspection of Met Tower Equipment,06/05/07 *WO Package

01005479 01, General Inspection of Met Tower Equipment,07/03/07 CAP Documents *NCR

00192324, Air Sampler (AC/AP)-1 Power Outage on April 24, 2006,04/26/06. *NCR

00193379, Environmental water compositor found unplugged, 05/03/06

• NCR

00194215, Interlaboratory comparison program evaluation method,05/11/06 *NCR

00196152, Missing broadleaf samples, 05/31/06

• NCR

00196460, Revise Environmental Program Procedures for consistency withODCM, 06/05/06 *NCR

00197343, Power outage at air samplers 26 and 47, 06/13/06 *NCR

00200988, Power outage of HNP air sampler No. 4, 07/24/06

• NCR

00204354, Missing July food crop samples, 08/25/06

• NCR

00204370, Revision to

EVC-NGGC-0012 for longer count times to meetapriori LLDs, 08/25/06 *NCR

00204593, Missing June food crop samples, 06/08/06

• NCR

00208126, Missing HNP food crop samples for August and September,10/03/06 *NCR

00214643, I-131 detected in Cape Fear River, 11/28/06

• NCR

00224688, HNP air sampling stations 26 and 47 power outage, 03/06/07

• NCR

00225713, Malfunctioning Water Samplers,

03/13/07

A-13Attachment *NCR

00225724, Failure to adequately revise procedure, 03/13/07 *NCR

00226140, Individual measurements outside acceptable range for cross-checks, 03/16/07 *NCR

00227414, Missing broadleaf samples, 03/27/07

• NCR

00227423, Missing food crop samples, 03/27/07

• NCR

00229890, HNP air samplers/water sampler power outage, 04/17/07

• NCR

00230012, Telemetry malfunction during power outage, 04/18/07

• NCR

00230699, Missing Broadleaf Samples, 04/24/07

• NCR

00230759, HNP REMP water sample composite incomplete, 04/24/07

• NCR

00233020, I-131 detected in Cape Fear River samples, 05/14/07

• NCR

00233375, Missing HNP food crop samples May 2007, 05/17/07

• NCR

00233912, HNP broadleaf sample unavailability, 05/22/07

• NCR

00235214, Power interruption at HNP air sampler location No. 47, 06/04/07

• NCR

0026140, Third and fourth quarter 2006 Environmental Cross CheckResults Outside of acceptable Criteria Range. *NCR

00235520, REMP Air Sampler Design Improvement, 06/06/07

• NCR

00239267, Evaluate Options for Operation of the HNP REMP WaterComposite Sampling Equipment to Provide for Improved Consistency in Volume of Water Sampled, 07/12/07

Section 4OA1: Performance Indicator Verification

• NEI 99-02, Regulatory Assessment Performance Indicator Guideline *Calculation

HNP-F/PSA-0068, NRC Mitigating System Performance Index BasisDocument for Harris Nuclear PlantProcedures, Guidance Documents *REG-NGGC-0009, NRC Performance Indicators and Monthly Operating ReportData, Rev. 6

Records and Data *Monthly PI Reports, April 2006 - May 2007

• OWP-RM LCO Action Log (Plant Vent Stack Monitor) Sheet 61 of 91, Rev. 27,dated 07/17/06 *OWP-RM LCO Action Log (Stack Flow Rate Monitor) Sheet 56 of 91, Rev. 27,dated 11/19/06 *OWP-RM LCO Action Log (Waste Process Bldg Stack Monitor) Sheet 72 of 91,Rev. 27, dated 03/18/07 *RETS/ODCM Radiological Effluent Occurrence Data Sheets and SupportingInformation for

April 2006, May 2006, June 2006, July 2006, August 2006, September 2006, October 2006, November 2006, December 2006, February

2007, March 2007, April 2007,

A-14Attachment

CAP Documents *AR

00193301, A tri-nuclear filter was improperly tied off along the reactor cavityedge, 5/3/06 *AR

00206438, Appropriate HP coverage was not provided for workers enteringcontainment, 9/15/06 *AR

00220433, Trend noted for security officers failing to respond to electronicdosimeter alarms, 1/26/07

Section 4OA2: Identification and Resolution of Problems

• CAP-NGGC-0200, Corrective Action Program.

Section 4OA3: Event Follow-up

• OP-139, Service Water System *EOP-EPP-004, Reactor Trip Response

• AOP-006, Turbine Generator Trouble

• EOP-EPP-005, Natural Circulation Cooldown

• AOP-025, Loss of One Emergency AC Bus (6.9 KV), or One Emergency DC Bus(125)