IR 05000400/2020003

Integrated Inspection Report 05000400/2020003

ML20310A250
Person / Time
Site:	Harris
Issue date:	11/06/2020
From:	Stewart Bailey NRC/RGN-II/DRP/RPB4
To:	Maza K Duke Energy Progress
References
IR 2020003
Download: ML20310A250 (20)

Text

{{#Wiki_filter:ber 6, 2020

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000400/2020003

Dear Ms. Maza:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Power Plant. On October 21, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Shearon Harris Nuclear Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, /RA/ Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No. 05000400 License No. NPF-63

Enclosure:

As stated

Inspection Report

Docket Number: 05000400 License Number: NPF-63 Report Number: 05000400/2020003 Enterprise Identifier: I-2020-003-0061 Licensee: Duke Energy Progress, LLC Facility: Shearon Harris Nuclear Power Plant Location: New Hill, NC 27562 Inspection Dates: July 01, 2020 to September 30, 2020 Inspectors: S. Freeman, Senior Reactor Analyst A. Patz, Resident Inspector S. Sanchez, Senior Emergency Preparedness Insp G. Smith, Senior Resident Inspector J. Zeiler, Senior Resident Inspector Approved By: Stewart N. Bailey, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Shearon Harris Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to Implement Adequate Maintenance Procedure for Replacing a Turbine Electro-Hydraulic Auto-Stop Trip Pilot-Operated Solenoid Valve Results in Automatic Reactor Trip Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71153 FIN 05000400/2020003-01 Complacency Open/Closed A self-revealed Green Finding (FIN) was identified for the licensees failure to implement an adequate maintenance procedure for replacing turbine digital electro-hydraulic (DEH) auto-stop trip (AST) pilot-operated solenoid valve 1EH-159A. Specifically, during restoration following maintenance, a momentary low pressure condition occurred in the AST hydraulic header monitored by the reactor protection system (RPS) pressure transmitters which resulted in an automatic reactor trip on March 23, 2020.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000400/2020-001-00 LER 2020-001-00 for 71153 Closed Shearon Harris, Unit 1, Automatic Reactor Trip During Turbine Control System Digital Electro-Hydraulic System Maintenance LER 05000400/2020-001-01 LER 2020-001-01 for 71153 Closed Shearon Harris Nuclear Power Plant, Unit 1, Automatic Reactor Trip During Turbine Control System Digital Electro-Hydraulic System Maintenance

PLANT STATUS

Unit 1 operated at or near rated thermal power until August 13, 2020, when a manual reactor trip was initiated following indication that a single control rod dropped to the bottom of the reactor core during quarterly control rod exercise testing. After troubleshooting and evaluation of the incident, Unit 1 was restarted on August 15, 2020, and returned to near rated thermal power on August 16, 2020. Unit 1 remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.02)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather for Hurricane Isaias on August 1-4, 2020

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding for the following areas on September 21-25, 2020:

• Waste Processing Building
• Emergency Service Water (ESW) Intake Screening Structure

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) 'A' train charging and safety injection pump (CSIP) while 'B' train CSIP was out of service for train swap following corrective maintenance on July 8, 2020

(2) 'B' emergency diesel generator (EDG) while 'A' EDG was out of service for preventive maintenance on July 14-16, 2020

(3) 'B' component cooling water (CCW) pump while 'C' CCW pump was out of service for testing on July 22, 2020

71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Diesel fuel oil storage building including 'A' and 'B' fuel transfer pump rooms and outside yard area (fire zones 1-O-PA, 1-O-PB, 5-O-BAL, and 5-O-YARD) on July 15, 2020

(2) Reactor Auxiliary Building (RAB) 236' elevation 'A,' 'B,' and 'C' CSIP pump rooms and CCW pump/heat exchanger area (fire zones 1-A-3-PB, 1-A-BAL-H, and 1-A-3-TA) on July 22, 2020

(3) RAB 261' elevation 'A' and 'B' train essential services chilled water (ESCW) system areas (fire zone 1-A-4-CHLR) on July 28, 2020

(4) RAB 286' elevation 'B' train essential switchgear room, ventilation room, and battery room (fire zones 1-A-SWGRB, 1-A-5-HVB, and 1-A-BATB) on August 5, 2020

(5) ESW intake screening structure (fire zone 5-S-BAL) on September 21, 2020

==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the main control room during reactor startup on August 15, 2020, following a manual reactor trip on August 13, 2020 Licensed Operator Requalification Training/Examinations (IP Section 03.02)==

(1) The inspectors observed and evaluated a simulator scenario for operator training involving a reactor coolant pump seal failure followed by a small break loss of coolant accident on August 26, 2020

71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Dedicated shutdown diesel generator failed to start during testing due to degraded battery on February 8, 2020

(2) 'C' CCW pump outboard bearing seal leakage increased significantly when the pump was secured on June 15, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) Elevated (Green) risk during planned unavailability of the 'B' train CSIP system to swap pumps following seal rebuild for 'C' CSIP on July 8, 2020

(2) Elevated (Green) risk during planned unavailability of the 'A' EDG to conduct 3-year and 6-year frequency preventive maintenance outage on July 14-16, 2020

(3) Elevated (Green) risk during planned unavailability of the 'A' train CCW pump during swap over to the swing 'C' CCW pump following seal rebuild on July 22, 2020

(4) Elevated (Green) risk during startup from reactor trip on August 15, 2020

(5) Elevated (Green) risk during emergent repair of 'B' normal service water (NSW) pump following motor lower bearing failure on September 22, 2020

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) 'B' reactor auxiliary building emergency exhaust system (RABEES) fan air flow transmitter discovered beyond its environmental qualification life (NCRs 02306040 and 02335154) on June 16, 2020

(2) Increasing containment sump inleakage trend (NCR 02342010) on August 4, 2020

(3) 'B' main steam isolation bypass valve, 1MS-83, opened unexpectedly during packing leak sealant repairs (NCR 02343600) on August 8, 2020

(4) Increasing reactor coolant system (RCS) unidentified leakage trend (NCR 02345241)on August 24, 2020

(5) ESW pinhole leak due to pitting corrosion in 3/4-inch welded instrumentation piping connection on discharge piping of 1B CCW heat exchanger (NCR 02349411) on September 20, 2020

==71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample) The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary modification engineering change (EC) 417843, rod position indication non-urgent alarm bypass, implemented on July 14, 2020, due to control room nuisance alarm with control rod L5 position indication display problem

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

[[IP sample::=

=IP 71111.18|count=5}}

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Operations Surveillance Test (OST)-1093, Chemical and Volume Control/Safety Injection Operability, Train B, Quarterly Interval, Modes 1-4, following scheduled maintenance on the 'C' CSIP on July 8, 2020

(2) OST-1013, 1A-SA Emergency Diesel Generator Operability Test Monthly Interval Modes 1-2-3-4-5-6, following scheduled preventive maintenance outage on the 'A' EDG on July 16, 2020

(3) OST-1316, Component Cooling Water System Operability (Pump 1C-SAB in Service)

Quarterly Interval Modes 1-4, and EST-201, ASME System Pressure Tests, following scheduled refurbishment of 'C' CCW pump mechanical seals on July 22, 2020

(4) OPT-1512, Essential Chilled Water Turbopak Units Quarterly Inspection/Checks Modes 1-6, following scheduled preventive maintenance on 'B' ESCW chiller on July 29, 2020

(5) OPT-1531, Dedicated Shutdown Diesel Operability Run Annual Interval Modes: All, following semi-annual and annual preventive maintenance on July 30, 2020

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) ORT-1500, Shutdown/Control Rod Exercise Test, on August 24, 2020

(2) OPT-1530, Dedicated Shutdown Diesel Generator Operability Test Monthly Interval, on September 1, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) OST-1411, Auxiliary Feedwater Pump 1X-SAB Operability Test Quarterly Interval Mode 1, 2, 3, on September 9, 2020

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) OST-1026, Reactor Coolant System Leakage Evaluation, Computer Calculation, Daily Interval, Modes 1-4, on August 26, 2020

71114.03 - Emergency Response Organization Staffing and Augmentation System Inspection Review (IP Section 02.01-02.02)

(1) The inspector completed the evaluation of the readiness of the Emergency Response Organization (ERO) on July 28, 2020. This was a continuation of an inspection that was performed remotely during the week of April 20, 2020, but was unable to be completed due to aspects that did not lend themselves to being performed remotely. Inspection Report 2020-002 documented the initial inspection activities.

71114.05 - Maintenance of Emergency Preparedness Inspection Review (IP Section 02.01 - 02.11)

(1) The inspector completed the evaluation of the maintenance of the emergency preparedness program on July 28, 2020. This was a continuation of an inspection that was performed remotely during the week of April 20, 2020, but was unable to be completed due to aspects that did not lend themselves to being performed remotely. Inspection Report 2020-002 documented the initial inspection activities.

==71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample) The inspectors evaluated:

(1) A tabletop emergency preparedness drill involving an offsite plant radiological release above the criteria for declaring a General Emergency on August 18, 2020 Drill/Training Evolution Observation (IP Section 03.02)==

The inspectors evaluated:

(1) A simulator-based licensed operator training evolution involving a reactor coolant pump seal failure followed by a small break loss of coolant accident on August 26,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Unit 1 (July 1, 2019 - June 30, 2020)

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) Unit 1 (July 1, 2019 - June 30, 2020)

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) Unit 1 (July 1, 2019 - June 30, 2020)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Automatic reactor trip on March 23, 2020, during restoration from planned maintenance activity to replace turbine control system auto-stop turbine trip Quadvoter valve 1EH-159A (NCR 02321895)

(2) 'B' ESCW chiller experienced high motor winding temperatures and the inability to maintain chill water outlet temperature within acceptance criterion during testing on May 26, 2020 (NCR 02331982)

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) The inspectors evaluated the manual reactor trip due to an unexpected dropped control rod during surveillance testing and licensees response on August 13, 2020.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000400/2020-001-00 and 05000400/2020-001-01, Automatic Reactor Trip During Turbine Control System Digital Electro-Hydraulic System Maintenance (ADAMS Accession Nos. ML20142A454 and ML20181A414). The circumstances surrounding the LER and updated LER submittal is documented in this report under Inspection Results Section

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/194 - Inspection of the Licensees Implementation of Industry Initiative Associated With the Open Phase Condition Design Vulnerabilities In Electric Power Systems (NRC Bulletin 2012-01) Revision 0 of this TI was previously inspected, and closed, in Inspection Report 05000400/2019012. However, a subsequent revision to the Nuclear Energy Institute (NEI) Voluntary Initiative (Revision 3) provided plants the option to leave the open phase protection (OPP) system in monitoring mode only in lieu of activating the automatic trip circuitry, provided it was supported by a risk evaluation. Revision 1 (and later Revision 2) of this TI was issued to provide inspection guidance for the new option.

The inspectors reviewed licensee analyses and procedures that demonstrated operator manual actions would successfully mitigate the impact of an open phase condition (OPC). The analyses were reviewed remotely, and the procedures were reviewed and walked down on site. The inspectors completed Section 03.01c of TI 2515/194, Revision 2.

The inspectors verified that modeling used for the OPC reflected the as-designed and as-built plant, assumptions made by the licensee were reasonable, and licensee procedures were adequate to successfully respond to an OPC. The inspectors also verified that human reliability analysis and recovery evaluations were done in accordance with NEI and voluntary initiative guidance.

INSPECTION RESULTS

Observation: Automatic Reactor Trip During Turbine Control System Restoration 71152 Following Quadvoter Replacement (NCR 02321895) This issue was chosen as it dealt with an automatic reactor trip and involved a formal root cause report. The event was reported to the NRC as event notification (EN) 54599 on March 23, 2020 at 1336 as an automatic RPS actuation pursuant to 10CFR50.72(b)(2)(iv)(B). More details on this issue are discussed in Section 71153 of this report. The issue was a result of a flawed maintenance procedure utilized during replacement of a turbine trip solenoid valve. The inspectors determined that the causal analysis was thorough and that immediate and long term corrective actions appeared to be adequate. The inspectors reviewed these actions and verified that they addressed the cause and were actually being implemented. The inspectors evaluated the following attributes of the licensees actions:

• complete and accurate identification of the problem in a timely manner
• evaluation and disposition of operability and reportability issues
• consideration of extent of condition, generic implications, common cause, and previous occurrences
• classification and prioritization of the problem
• identification of root and contributing causes of the problem
• identification of any additional condition reports
• completion of corrective actions in a timely manner During a review of this issue, the inspectors noted an overreliance on the accuracy of the vendor technical manual. The vendor technical manual was ultimately deemed to be flawed and directly resulted in a reactor trip. The licensee did observe the initial validation of maintenance activities described in the technical manual at the vendor site. However, the maintenance activity of concern was performed differently than described in the technical manual. This deviation was not initially noted by the licensee. Specifically, the sequence of two manipulated manual valves was reversed and was subsequently deemed to be the "correct" sequence and not the version that was depicted in the technical manual that ultimately ended up in the plant maintenance procedure, CM-I0165, "Quadvoter Corrective Maintenance." The licensee did not display a questioning attitude when they failed to fully validate the vendor technical manual and this ultimately resulted in a flawed plant procedure. Additionally, the preexisting hydraulic header pressure was deemed to be lower than normal during the maintenance activity. The licensee failed to recognize that this parameter could impact the maintenance restoration process and increase the risk of a reactor trip. The inspectors noted that there were opportunities to question the risk of the maintenance activity as well as the method of performance prior to the resulting reactor trip.

Failure to Implement Adequate Maintenance Procedure for Replacing a Turbine Electro-Hydraulic Auto-Stop Trip Pilot-Operated Solenoid Valve Results in Automatic Reactor Trip Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71153 FIN 05000400/2020003-01 Complacency Open/Closed A self-revealed Green Finding (FIN) was identified for the licensees failure to implement an adequate maintenance procedure for replacing turbine digital electro-hydraulic (DEH) auto-stop trip (AST) pilot-operated solenoid valve 1EH-159A. Specifically, during restoration following maintenance, a momentary low pressure condition occurred in the AST hydraulic header monitored by the reactor protection system (RPS) pressure transmitters which resulted in an automatic reactor trip on March 23, 2020.

Description:

On March 23, 2020, at 1012, the unit experienced an automatic reactor trip due to low pressure in the main turbine AST header. The operators responded to the reactor trip and stabilized the plant in Mode 3. At the time of the trip, maintenance technicians were restoring the AST header following replacement of the AST Quadvoter trip solenoid, 1EH-159A. The Quadvoter subsystem was part of a larger Turbine Control System (TCS)modification installed in 2018 in order to improve the reliability of the TCS. The maintenance technicians noted that just prior to the reactor trip, they were opening a manual hydraulic valve (1EH-174) in order to un-isolate the clearance boundary in accordance with CM-I0165, "Quadvoter Corrective Maintenance," Rev. 5. Immediately after opening this manual valve, the technicians noted the main turbine governor and throttle valves immediately close.

Maintenance activities were ceased at this point.

Following the reactor trip, the licensee began a detailed root cause evaluation in order to fully understand the cause of the event. Subsequent investigation revealed that the restoration of 1EH-159A involved a re-pressurization of a volume of 17 cubic inches from the AST header rather than the electrohydraulic (EH) header. The AST header is the hydraulic header that senses low hydraulic pressure in order to cause an automatic reactor trip. This trip is designed to trip the reactor in response to a sensed turbine trip. Investigators deemed that the re-pressurization should have been from the EH header which has a formal source of hydraulic pressure via the EH pumps. The root cause team concluded that maintenance procedure CM-I0165 incorrectly sequenced the opening of two manual valves during the restoration process that allowed the AST header to experience a momentary reduced pressure that ultimately caused the RPS to trip the reactor.

The licensee noted that plant procedure CM-I0165, was developed directly from the vendor technical manual which utilized the incorrect valve opening sequence during maintenance. Additionally, during preoperational testing at the vendor facility which was observed by the licensee, replacement of the AST trip solenoid was demonstrated without affecting pressure in the AST header. However, the investigators noted the restoration valve sequence used at that time was performed properly. Additionally, the licensee had previously performed a similar maintenance activity in 2019 utilizing the same incorrect restoration sequence, yet no reactor trip signal was received at that time. This was due to a slightly higher pressure that existed in the header during the maintenance activity.

The root cause team concluded that the maintenance procedure, CM-I0165, was flawed. Specifically refilling and re-pressurizing a voided section of hydraulic piping from the AST header due to an incorrect restoration sequence in conjunction with a slightly lower initial header pressure caused enough of a pressure perturbation in the AST hydraulic header monitored by the RPS pressure transmitters that resulted in the RPS trip signal.

Corrective Actions: Numerous corrective actions were implemented as a result of the root cause team's efforts. The most notable corrective action was the revision of CM-I0165 which properly sequenced the opening of two manual valves. This procedure change allowed the voided section of piping to be refilled using the EH header as the source of the hydraulic fluid rather than the AST header, which is expected to prevent the pressure perturbation in the AST hydraulic header.

Corrective Action References: NCR 02321895

Performance Assessment:

Performance Deficiency: The licensee failed to implement an adequate online turbine AST pilot-operated solenoid valve replacement procedure that properly accounted for the pressure transient on the pressure transmitters for initiating an RPS trip when restoring the system to service.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to implement adequate guidance for restoring the system to service following replacement of the AST pilot-operated solenoid valve resulted in a pressure transient in the AST hydraulic header causing an automatic reactor trip.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because when screened as a transient initiator, it did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g., loss of condenser or feedwater).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The inspectors determined the licensee became too complacent with the risks of performing this maintenance activity online since it had been conducted successfully in the past, and was not sensitive to the inherent risks involved, nor have an adequate understanding of the magnitude of the pressure transient created when restoring the system to service.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 21, 2020, the inspectors presented the integrated inspection results to Kim Maza and other members of the licensee staff.
• On August 5, 2020, the inspectors presented the Emergency Preparedness Program Inspection results to Kim Maza and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 2515/194 Calculations HNP-F/PSA- Harris PRA Analysis of Implementation Options for Open Rev. 0 28, Phase Condition Protection Corrective Action NCR 02351526 Inadequate Communication of SUT Open Phase Protection 10/01/2020 Documents Changes to Operations Resulting from Inspection Engineering EC 402237 Startup Transformer Open Phase Fault Detection and Revs. 1-6 Changes Protection EC 412796 Open Phase Fault Detection and Protection (Child Rev. 0 Modification) Miscellaneous CutSets Top 50 Core Damage CutSets for: Base Case, Startup 09/30/2020 Transformers 1A and 1B Open Phase Protection in Manual, and Open Phase Protection in Auto. email Letter from Edward

A. Lipetzky to Robert P. Boyer, Plant 09/12/2019;

Impacts Associated with OPC on SUT-1A or SUT-1B 3:07:42 PM Training Review TRF for EC 402237, Rev. 5, Change in open phase Rev. 2 Form (TRF) automatic trip to alarm only 2303555 Procedures AOP-039 Startup and Unit Auxiliary Transformer Trouble Rev. 16 and APP-ALB-022 Main Control Board (Annunciator Alarm Panel Procedure) Rev. 96 and 71111.01 Calculations Engineering Beyond Design Basis Impact Evaluation Rev. 0 Change (EC) 409305 PMS-0001 Probable Maximum Storm Ponding on All Building Rev. 5 Miscellaneous Shearon Harris Flood Hazard Reevaluation Report 03/12/2013 Nuclear Plant Letter HNP-13- 031 Shearon Harris Flood Hazard Reevaluation Report, Revision 1 04/01/2015 Nuclear Plant Inspection Type Designation Description or Title Revision or Procedure Date Letter HNP-15- 27 Shearon Harris Response to March 12, 2012, Request for Information 09/13/2017 Nuclear Plant Enclosure 2, Recommendation 2.1, Flooding, Required Letter HNP-17- Response 3, Flooding Focused Evaluation Summary 2 Submittal Procedures AP-300 Severe Weather Response Rev. 35 71111.04 Procedures OP-107 Chemical and Volume Control System Rev. 117 OP-145 Component Cooling Water Rev. 80 OP-155 Diesel Generator Emergency Power System Rev. 91 71111.05 Fire Plans CSD-HNP-PFP- Diesel Fuel Oil Storage Building Pre-Fire Plan Rev. 1 DFOSB CSD-HNP-PFP- Reactor Auxiliary Building Elevation 236 Pre-Fire Plan Rev. 2 RAB-236 CSD-HNP-PFP- Reactor Auxiliary Building Elevation 261 Pre-Fire Plan Rev. 1 RAB-261 CSD-HNP-PFP- Reactor Auxiliary Building Elevation 286 Pre-Fire Plan Rev. 1 RAB-286 CSD-HNP-PFP- Out Building Pre-Fire Plan Rev. 5 SEC Procedures AD-EG-ALL-1520 Transient Combustible Control Rev. 13 AD-EG-ALL-1522 Duties of a Compensatory Fire Watch Rev. 11 FPP-001 Fire Protection Program Manual Rev. 44 FPP-013 Fire Protection - Minimum Requirements, Mitigating Actions Rev. 104 and Surveillance Requirements 71111.11Q Miscellaneous DSS-028 Licensed Operator Training Simulator Evaluation Guide Rev. 8 Procedures AOP-018 Reactor Coolant Pump Abnormal Conditions Rev. 49 EOP-E-0 Reactor Trip or Safety Injection Rev. 15 EOP-E-1 Loss of Reactor or Secondary Coolant Rev. 5 EOP-ES-0.1 Reactor Trip Response Rev. 4 GP-004 Reactor Startup (Mode 3 To Mode 2) Rev. 66 GP-005 Power Operation (Mode 2 To Mode 1) Rev. 109 71111.12 Corrective Action NCR 02315026 DSDG failed to start during testing 02/08/2020 Inspection Type Designation Description or Title Revision or Procedure Date Documents NCR 02334865 'C' CCW pump seal leakage degraded 06/15/2020 Procedures AD-EG-ALL-1210 Maintenance Rule Program Rev. 2 71111.13 Procedures AD-NF-ALL-0501 Electronic Risk Assessment Tool (ERAT) Rev. 5 AD-WC-ALL- On-Line Work Management Rev. 17 200 AD-WC-ALL- On-Line Risk Management Process Rev. 2 240 AD-WC-ALL- Work Activity Integrated Risk Management Rev. 10 0410 Work Orders WO 20425040 Troubleshoot 'B' NSW elevated lower motor bearing 09/22/2020 temperatures WOs 20051171, Work orders supporting 'C' charging and safety injection 07/08/2020 20068954, pump seal rebuild and testing 20354093, 20354094, 20359210, 20376203, 20378426, 20389981, and 20393436 WOs 20253030, 'A' EDG 3-year and 6-year preventive maintenance activities 07/14- 261549, 16/2020 271085, 293095, 20312565, 20322394, 20322509, 20328716, and 20373617 71111.15 Engineering EC 418338 Generic Letter 90-05 Flaw Evaluation of Weld to ESW Line Rev. 0 Evaluations 3SW1-141B Miscellaneous NRC Inspection Operability Determinations 10/01/2019 Manual Chapter 26 Inspection Type Designation Description or Title Revision or Procedure Date Nuclear Energy Operability Determination Rev. 0 Institute (NEI) 18- Procedures AD-OP-ALL-0105 Operability Determinations Rev. 6 71111.18 Corrective Action NCR 02334330 RPI non-urgent alarm on B shutdown bank control rod L5 06/10/2020 Documents general warning Engineering Action Request EC 417843 10CFR50.59 screening evaluation 06/23/2020 Evaluations (AR) 02336381 Procedures AD-EG-ALL-1132 Preparation and Control of Design Change Engineering Rev. 16 Changes AD-EG-ALL-1133 Preparation and Control of Design Equivalent Change Rev. 12 Engineering Changes Work Orders WO 20406569 Implementation of EC 417843 to bypass erroneous control 07/14/2020 rod indication display alarm with control rod L5 71111.19 Procedures AD-EG-ALL-1155 Post Modification Testing Rev. 4 PLP-400 Post Maintenance Testing Rev. 64 Work Orders WO 20405307 1C CCW pump mechanical seal rebuilds 07/21/2020 WOs 20051171, 'C' CSIP preventive maintenance activities 07/08/2020 20068954, and 20359210 WOs 20322509, 'A' EDG preventive maintenance activities 07/16/2020 20328713, 20328716, 20328717, and 20373617 WOs 20379692 Semi-annual and annual preventive maintenance on DSDG 07/30/2020 and 20381901 WOs 20410615, 'B' ESCW chiller preventive maintenance activities 07/28- 279408, and 29/2020 20390798 71114.06 Procedures AD-EP-ALL-0101 Emergency Classification Rev. 1 AD-EP-ALL-0105 Activation and Operation of the Technical Support Center Rev. 5 AD-EP-ALL-0106 Activation and Operation of the Operations Support Center Rev. 4 AD-EP-ALL-0109 Offsite Protective Action Recommendations Rev. 5 Inspection Type Designation Description or Title Revision or Procedure Date AD-EP-ALL-0111 Control Room Activation of the ERO Rev. 1 AD-EP-ALL-0802 Conducting Drills and Exercises Rev. 6 AD-EP-HNP- HNP Site Specific TSC Support Rev. 0 0105 CSD-EP-HNP- EAL Wallchart Rev. 0 0101-02 PEP-350 Protective Actions Rev. 12 71152 Procedures AD-PI-ALL-0100 Corrective Action Program Rev. 23 AD-PI-ALL-0101 Root Cause Evaluation Rev. 7 AD-PI-ALL-0102 Apparent Cause Evaluation Rev. 4 AD-PI-ALL-0106 Cause Investigation Checklists Rev. 4 71153 Engineering EC 418115 Engineering Evaluation to Support Removal of Requirement 08/17/2020 Evaluations to Trip Reactor with a Dropped Rod during Performance of OST-1005 Procedures AOP-001 Malfunction of Rod Control and Indication System Rev. 54 EOP-E-0 Reactor Trip or Safety Injection Rev. 15 EOP-ES-0.1 Reactor Trip Response Rev. 4 GP-006 Normal Plant Shutdown from Power Operation to Hot Rev. 92 Standby (Mode 1 to Mode 3) OMM-004 Post Trip/Safeguards Actuation Review Rev. 43 OST-1005 Control Rod and Rod Position Indicator Exercise Quarterly Rev. 26 Interval Modes 1-3 17| ]]