IR 05000400/2015007

IR 05000400/2015007, November 16, 2015, Through December 10, 2015, Shearon Harris Nuclear Power Plant - NRC Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications

ML15356A801
Person / Time
Site:	Harris
Issue date:	12/22/2015
From:	Bartley J NRC/RGN-II/DRS/EB1
To:	Waldrep B Duke Energy Progress
References
IR 2015007
Download: ML15356A801 (15)

Text

UNITED STATES cember 22, 2015

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - NRC EVALUATION OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS INSPECTION REPORT 05000400/2015007

Dear Mr. Waldrep:

On December 10, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Shearon Harris Nuclear Power Plant Unit 1, and discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Shearon Harris plant.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs " Rules of Practice, a copy of this letter, its Enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management System (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/

Jonathan H. Bartley, Chief Engineering Branch 1 Division of Reactor Safety Docket No.: 50-400 License No.: NPF-63

Enclosure:

Inspection Report 05000400/2015007 w/Attachment: Supplementary Information

REGION II==

Docket No.: 50-400 License No.: NPF-63 Report No.: 05000400/2015007 Licensee: Duke Energy Progress, Inc.

Facility: Shearon Harris Nuclear Power Plant, Unit 1 Location: 5413 Shearon Harris Road New Hill, NC 27562 Dates: November 16, 2015, through December 10, 2015 Inspectors: Eric Stamm, Senior Reactor Inspector (Team Leader)

Sandra Herrick, Reactor Inspector Marcus Riley, Reactor Inspector Michael Greenleaf, Trainee Approved by: Jonathan H. Bartley, Chief Engineering Branch 1 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report (IR) 05000400/2015007; 11/16/2015 - 12/10/2015; Shearon Harris Nuclear

Power Plant, Unit 1; Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.

This report covers a two week onsite inspection by one senior reactor inspector, two reactor inspectors, and one trainee. One NRC-identified violation is documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process, (SDP) dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision

Cornerstone: Mitigating Systems

• Green: The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to establish a periodic as-found testing program of safety-related 6.9kV vacuum breakers in accordance with applicable design document IEEE 308-1971. The licensee entered this issue into their corrective action program as action request 01983086 and initiated a procedure change request to have the procedure changed to verify the as-found capability of the breakers before performing the first scheduled preventative maintenance on the breakers in April 2016.

The performance deficiency was determined to be more than minor because, if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to establish as-found testing could mask degradation of the circuit breakers and decrease the reliability of the breakers to perform their safety-related function when called upon. The finding was determined to be of very low safety significance (Green), because it was a deficiency affecting the design or qualification of a structure, system, or component, which maintained its operability. The team determined that no finding cross-cutting aspect was applicable because the finding did not reflect current licensee performance. (Section 1R17)

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, Experiments and Permanent Plant Modifications

a. Inspection Scope

Evaluations of Changes, Tests, and Experiments: The team reviewed seven safety evaluations performed pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests, and experiments, to determine if the evaluations were adequate, and that prior NRC approval was obtained as appropriate. The team also reviewed 16 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The team reviewed these documents to determine if:

• the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59, and that sufficient documentation existed to confirm that a license amendment was not required

• the safety issues requiring the changes, tests, or experiments were resolved

• the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59

• the design and licensing basis documentation used to support the change was updated to reflect the change The team used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Rev. 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000.

Permanent Plant Modifications: The team reviewed eight permanent plant modifications that had been installed in the plant during the last three years. The modifications reviewed are listed below:

• EC 0000260437 - ESW Pump Wear Ring and packing Material Change

• EC 0000269609 - Replace 1A-SA EDG Governor with Upgraded Version

• EC 0000275885 - Upgrade NCD3 and NTD1 Cards for the Westinghouse 7300 System

• EC 0000279461 - Overload Relay, Ambient Compensated, Hand-Auto Reset

• EC 0000281469 - Replacement for PT-01CT-7160BSB Wide Range Containment Pressure

• EC 0000286799 - Changes Resulting from Repair at OEM

• EC 0000290607 - CM-E0010 Breaker Testing Criteria

• EC 0000291213 - CVCS Over-pressurization The modifications were selected based upon risk significance, safety significance, and complexity. The team reviewed the modifications selected to determine if:

• the supporting design and licensing basis documentation was updated

• the changes were in accordance with the specified design requirements

• the procedures and training plans affected by the modification had been adequately updated

• the test documentation, as required by the applicable test programs, had been updated, and

• post-modification testing adequately verified system operability and/or functionality The team also used applicable industry standards to evaluate acceptability of the modifications and performed walkdowns of accessible portions of the modifications.

Documents reviewed are listed in the Attachment.

b. Findings

Introduction:

The team identified a Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to establish a periodic as-found testing program of safety-related 6.9kV vacuum breakers in accordance with applicable design document IEEE 308-1971.

Description:

Harris was committed to Institute of Electrical and Electronics Engineers (IEEE) 308-1971, IEEE Standard Criteria for Class 1E Power Systems for Nuclear Power Generating Stations, per the UFSAR Section 8.3.1.2.23. IEEE 308-1971, Section 6.3, titled Periodic Equipment Tests, specified in part, that tests shall be performed at scheduled intervals to:

(1) Detect the deterioration of the system toward an unacceptable condition.

During review of EC 266427, Replace existing Siemens FB type 6.9KV Air Circuit Breakers with new Siemens 3AH type 6.9KV Vacuum Circuit Breakers, Revision (Rev.)

12, the team noted that maintenance procedure PM E0048, 6.9kV Vacuum Breaker Inspection, Rev 9, was due to be performed for the first time on eight safety-related breakers as early as April 2016. The team found that the procedure did not require performance of electromechanical as-found testing at the reduced voltages specified by the plant design basis prior to inspecting, cleaning, and lubrication of the breakers.

Inspecting, cleaning, and lubricating the breakers before performing as-found testing at reduced voltages could mask the deterioration and degradation of the circuit breakers that could be revealed at reduced voltages. As-found electromechanical functional testing under design basis conditions of circuit breakers is necessary to determine if the circuit breakers could have performed their specified safety functions, as credited in electrical design basis calculations and the safety analysis. The team was not provided any other procedures that were established which verified this capability.

The licensee initiated a procedure change request to have the procedure changed to verify the as-found capability of the breakers before performing the first scheduled preventative maintenance on the breakers in April 2016 and entered this issue into their corrective action program as action request (AR) 01983086.

Analysis:

The failure to establish periodic as-found electromechanical testing of safety-related 6.9kV vacuum breakers in accordance with IEEE 308-1971 was a performance deficiency (PD). The PD was determined to be more than minor because, if left uncorrected, it had the potential to lead to a more significant safety concern.

Specifically, the failure to establish as-found testing could mask degradation of the circuit breakers and decrease the reliability of the breakers to perform their safety-related function when called upon. The finding was assessed using IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012, for Mitigating Systems, and IMC 0612, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, and determined to be of very low safety significance (Green),because it was a deficiency affecting the design or qualification of a structure, system, or component, which maintained its operability. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires, in part, A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components (SSCs) will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. UFSAR Section 8.3.1.2.23, stated the Class 1E power system conforms to IEEE 308-1971. Section 6.3 of IEEE 308-1971, titled Periodic Equipment Tests, specified, in part, tests shall be performed at scheduled intervals to:

(1) Detect the deterioration of the system toward an unacceptable condition. Contrary to the above, since 2006, the licensee failed to establish a testing program which identified all testing required to demonstrate that SSCs would perform satisfactorily in service in accordance with written test procedures which incorporated the requirements and acceptance limits contained in IEEE 308-1971, the applicable design document. The failure to establish as-found testing could mask degradation of the circuit breakers and decrease the reliability of the breakers to perform their safety-related function when called upon. The licensee initiated a procedure change request to have the procedure changed before performing the first scheduled preventative maintenance on the breakers in April 2016.

This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as AR 01983086. (NCV 05000400/2015007-01, Failure to Establish As-found Testing on 6.9kV Vacuum Breakers)

4OA6 Meetings, Including Exit

On December 10, 2015, the team presented inspection results to Mr. Benjamin Waldrep and other members of the licensees staff. The team verified that no proprietary information was retained by the inspectors, or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Cahill, Manager, Maintenance

J. Caves, (Acting) Manager, Nuclear Regulatory Affairs

A. Goodman, Engineer, Regulatory Affairs

M. Grantham, Director, Design Engineering

T. Hamilton, Plant General Manager

C. Holden, Consultant

I. Nordby, Senior Engineer, Regulatory Affairs

S. OConnor, General Manager, Nuclear Engineering

B. Waldrep, Site Vice President

NRC personnel

J. Dodson, Senior Project Engineer, Division of Reactor Projects, Projects Branch 4

J. Austin, Senior Resident Inspector, Division of Reactor Projects, Harris

M. Riches, Resident Inspector, Division of Reactor Projects, Harris

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000400/2015007-01 NCV Failure to Establish As-found Testing on 6.9kV Vacuum Breakers [Section 1R17]