ML113000409
ML113000409 | |
Person / Time | |
---|---|
Site: | Harris |
Issue date: | 10/27/2011 |
From: | Randy Musser NRC/RGN-II/DRP/RPB4 |
To: | Jefferson W Carolina Power & Light Co |
References | |
IR-11-502, IR-11-004 | |
Download: ML113000409 (42) | |
See also: IR 05000400/2011502
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
October 27, 2011
Mr. William Jefferson, Jr.
Vice President
Carolina Power and Light Company
Shearon 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 INTEGRATED
INSPECTION REPORT 05000400/2011004 AND 05000400/2011502
Dear Mr. Jefferson:
On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Shearon Harris reactor facility. The enclosed integrated inspection report
documents the inspection results, which were discussed on October 19, 2011, with you and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one NRC-identified finding and one self-revealing finding of very low
safety significance (Green). These findings were determined to involve violations of NRC
requirements. However, because of the very low safety significance and because they are
entered into your corrective action program, the NRC is treating these findings as non-cited
violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest
any NCV, you should provide a response within 30 days of the date of this inspection report,
with the basis for your denial, 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
addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region II, and the NRC Senior Resident
Inspector at the Shearon Harris facility.
CP&L 2
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRCs document 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/
Randall A. Musser, Chief
Reactor Projects Branch 4
Division of Reactor Projects
Docket Nos.: 50-400
License No.: NPF-63
Enclosure: NRC Inspection Report 05000400/2011004, 05000400/2011502
w/Attachment: Supplemental Information
cc w/encl: (See page 3)
_ML113000409_____________ X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED
OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRS RII:DRS
SIGNATURE JSD JGW1 JDA by e mail PBL1 by email PBO by email BLC2 for by email ADN by email
NAME JDodson JWorosilo JAustin PLessard POBryan MBates ANielson
DATE 10/24/2011 10/25/2011 10/25/2011 10/25/2011 10/24/2011 10/27/2011 10/24/2011
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
OFFICE RII:DRS RII:DRS RII:DRP
SIGNATURE RKH1 by email WTL RAM
NAME RHamilton WLoo RMusser
DATE 10/25/2011 10/25/2011 10/27/2011
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
CP&L 3
cc w/encl: Kelvin Henderson, General Manager
Brian C. McCabe Nuclear Fleet Operations
Manager, Nuclear Oversight Progress Energy
Shearon Harris Nuclear Power Plant Electronic Mail Distribution
Progress Energy
Electronic Mail Distribution Public Service Commission
State of South Carolina
Donald L. Griffith, Training Manager P.O. Box 11649
Shearon Harris Nuclear Power Plant Columbia, SC 29211
Progress Energy
Electronic Mail Distribution Chairman
North Carolina Utilities Commission
R. Keith Holbrook Electronic Mail Distribution
Manager, Support Services
Shearon Harris Nuclear Power Plant Robert P. Gruber, Executive Director
Electronic Mail Distribution Public Staff - NCUC
4326 Mail Service Center
David H. Corlett, Supervisor Raleigh, NC 27699-4326
Licensing/Regulatory Programs
Progress Energy Chair
Electronic Mail Distribution Board of County Commissioners of Wake
County
David T. Conley, Senior Counsel P.O. Box 550
Legal Department Raleigh, NC 27602
Progress Energy
Electronic Mail Distribution Ernest J. Kapopoulos Jr.
Plant General Manager
Donna B. Alexander Carolina Power and Light Company
Manager, Nuclear Regulatory Affairs Shearon Harris Nuclear Power Plant
(interim) Electronic Mail Distribution
Progress Energy
Electronic Mail Distribution Chair
Board of County Commissioners of
John H. O'Neill, Jr. Chatham County
Shaw, Pittman, Potts & Trowbridge P.O. Box 1809
2300 N. Street, NW Pittsboro, NC 27312
Washington, DC 20037-1128
Senior Resident Inspector
Joseph W. Donahue, Vice President U.S. Nuclear Regulatory Commission
Nuclear Oversight Shearon Harris Nuclear Power Plant
Progress Energy 5421 Shearon Harris Rd
Electronic Mail Distribution New Hill, NC 27562-9998
W. Lee Cox, III, Section Chief
Radiation Protection Section
N.C. Department of Environmental
Commerce & Natural Resources
Electronic Mail Distribution
CP&L 4
Letter to William Jefferson, Jr. from Randall A. Musser dated October 27, 2011
SUBJECT: SHEARON HARRIS NUCLEAR POWER PLANT - NRC INTEGRATED
INSPECTION REPORT 05000400/2011004 AND 05000400/2011502
Distribution w/encl:
C. Evans, RII EICS
L. Douglas, RII EICS
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMShearonHarris Resource
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50-400
License No.: NPF-63
Report No.: 05000400/20110004, 05000400/2011502
Licensee: Carolina Power and Light Company
Facility: Shearon Harris Nuclear Power Plant, Unit 1
Location: 5413 Shearon Harris Road
New Hill, NC 27562
Dates: July 1, 2011 through September 30, 2011
Inspectors: J. Austin, Senior Resident Inspector
P. Lessard, Resident Inspector
P. OBryan, Senior Resident Inspector, Brunswick
M. Bates, Senior Operations Engineer (Section 1R11)
A. Nielson, Senior Health Physicist (Section 2RS5)
R. Hamilton, Senior Health Physicist (Sections 2RS7, 4OA1)
W. Loo, Senior Health Physicist (Sections 2RS6, 4OA1)
Approved by: Randall A. Musser, Chief
Reactor Projects Branch 4
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000400/2011004, 05000400/2011502, Carolina Power and Light Company; on 07/01/2011
- 09/30/2011; Shearon Harris Nuclear Power Plant, Unit 1; Post Maintenance Testing, and
Radiation Monitoring Instrumentation.
The report covers a three month period of inspection by resident inspectors, a senior operations
engineer and senior health physicists. One NRC-identified finding and one self-revealing finding
of very low safety significance (Green) were identified. The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects are determined using
IMC 0310, Components within the Cross Cutting Areas. Findings for which the SDP does not
apply may be Green or be assigned a severity level after NRC management review.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. A self-revealing Green NCV of Technical Specifications (TS) 6.8.1, Procedures, was
identified for the licensees failure to develop an adequate post maintenance test (PMT)
procedure for the replacement of a defective 6.9kV undervoltage relay (UVTXSB/1732).
Specifically, the licensee failed to ensure that the PMT procedure CM-E0032 (UVTXSB/1732
relay replacement) established adequate steam isolation to the turbine driven auxiliary
feedwater (TDAFW) pump to prevent an inadvertent actuation. This resulted in the TDAFW
pump inadvertently starting and injecting water into the steam generators which caused an
increase in reactor power to 100.2 percent for approximately one minute. As corrective actions,
the licensee secured the TDAFW pump, restored reactor power to 100 percent, and replaced
the failed relay. In order to return the TDAFW pump to operable, the licensee performed a
surveillance test to meet the requirements of the PMT. The applicable procedures were placed
on administrative hold for evaluation and revision. Additionally, an investigation was performed
to determine further corrective actions. The issue was placed into the CAP as AR #472616.
The licensees failure to develop an adequate PMT procedure CM-E0032 (UVTXSB/1732 relay
replacement) to ensure adequate steam isolation to the TDAFW pump and prevent an
inadvertent actuation was a performance deficiency. The performance deficiency was more
than minor because it is associated with the human performance attribute of the Mitigating
System cornerstone, and it affected the cornerstone objective of ensuring the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage). Specifically, it resulted in the automatic start of the TDAFW
pump, water flowing to the steam generators, and a resultant increase in reactor power to 100.2
percent. Using IMC 0609, Significance Determination Process, Phase 1 screening worksheet,
this finding was determined to be very low safety significance because it was not a design or
qualification deficiency confirmed to result in a loss of operability or functionality, did not
Enclosure
3
represent a loss of system safety function, did not result in a loss of safety system function for a
single train for greater than TS allowed outage time, did not result in a loss of safety function of
one or more non-TS trains of equipment designated as risk significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,
and did not screen as potentially risk significant due to seismic, flooding, or severe weather
initiating event. The finding has a cross-cutting aspect of Human Error Prevention, as described
in the Work Practices component of the Human Performance cross-cutting area, because the
licensee did not apply sufficient human error prevention measures during the development and
implementation of the PMT procedure (CM-E0032), to establish adequate steam isolation and
prevent an inadvertent TDAFW pump actuation (H.4(a)). (Section 1R19)
Cornerstone: Occupational Radiation Safety
Green. The inspectors identified a Green Non-cited Violation (NCV) of 10 CFR 20.1501 for the
failure to periodically calibrate radiation monitoring equipment. Specifically, in 2004 the licensee
eliminated periodic calibrations for 64 radiation monitors used to evaluate the magnitude of
radiation levels and quantities of radioactive material. The licensee entered the issue into their
corrective action program as Action Request (AR) #477569. Planned corrective actions include
re-assignment of all radiation monitors to a periodic calibration frequency and a design change
to eliminate radiation monitors that are redundant or infrequently used.
The inspectors determined that classifying radiation monitors as run-to-failure and thereby
eliminating periodic calibrations was a performance deficiency. This finding was greater than
minor because it adversely impacted the cornerstone objective to ensure the adequate
protection of worker health and safety from exposure to radiation from radioactive material
during routine civilian nuclear reactor operation. Although operational occurrences such as low
sample line flow, loss of counts, detector high voltage, or loss of communication alarms could
lead to identification of significant monitor problems, the failure to perform periodic calibrations
and response checks could impair the licensees ability to reliably quantify radiation levels in the
plant environs and in radioactivity released to the environment during normal and accident
situations. The finding was evaluated using IMC 0609, Appendix C, Occupational Radiation
Safety Significance Determination Process (SDP), and was determined to be of very low safety
significance (Green) because the finding is not related to ALARA dose planning, did not result in
an overexposure, and the ability to assess dose was not compromised due to the use of
appropriate personnel dosimetry and frequent radiological surveys of RCA areas. This finding is
not indicative of current licensee performance and therefore has no cross-cutting aspect.
(Section 2RS5)
B. Licensee-Identified Violations
None.
Enclosure
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near Rated Thermal Power (RTP) for the entire inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness For Impending Adverse Weather Condition
a. Inspection Scope
On August 26, 2011, Hurricane Irene was approaching the North Carolina coast. The
inspectors reviewed the licensees overall preparations/protection for impending adverse
weather conditions. The inspectors walked down areas of the plant susceptible to high
winds, including the licensees emergency alternating current (AC) power systems. The
inspectors evaluated the licensee staffs preparations against the sites procedures to
determine if the staffs actions were adequate. During the inspection, the inspectors
focused on plant specific design features and the licensees procedures used to respond
to specified adverse weather conditions. The inspectors also toured the plant grounds to
look for any loose debris that could become missiles during a tornado. The inspectors
evaluated operator staffing and accessibility of controls and indications for those
systems required to control the plant. Additionally, the inspectors reviewed the Updated
Final Safety Analysis Report (UFSAR) and performance requirements for systems
selected for inspection, and verified that operator actions were appropriate as specified
by plant specific procedures. The inspectors also reviewed a sample of corrective action
program items to verify that the licensee identified adverse weather issues at an
appropriate threshold and dispositioned them through the corrective action program in
accordance with station corrective action procedures. Specific documents reviewed
during this inspection are listed in the Attachment.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #484735, Fallen Tree on Plant Access Road due to Hurricane Irene
b. Findings
No findings were identified.
Enclosure
5
1R04 Equipment Alignment
.1 Quarterly Partial System Walkdowns
a. Inspection Scope
The inspectors performed three partial system walkdowns of the following risk-significant
systems:
- The exhaust portion of the Containment Ventilation System after it was restored
following emergent repairs to Containment Purge Radiation Monitor-3502A on
August 4, 2011;
- The A and B Emergency Diesel Generators (EDG) during normal plant operations
on August 10, 2011; and
- The A Containment Spray (CT) system while the B CT system was inoperable for
planned maintenance on August 10, 2011.
The inspectors selected these systems based on their risk-significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors attempted
to identify any discrepancies that could impact the function of the system and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, applicable portions of the UFSAR, TS requirements, outstanding work
orders, condition reports, and the impact of ongoing work activities on redundant trains
of equipment in order to identify conditions that could have rendered the systems
incapable of performing their intended functions. The inspectors also walked down
accessible portions of the systems to verify system components and support equipment
were aligned correctly and operable. The inspectors examined the material condition of
the components and observed operating parameters of equipment to verify that there
were no obvious deficiencies. The inspectors also verified that the licensee had properly
identified and resolved equipment alignment problems that could cause initiating events
or impact the capability of mitigating systems or barriers and entered them into the
corrective action program with the appropriate significance characterization. Documents
reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Quarterly Resident Inspector Tours
a. Inspection Scope
The inspectors conducted six fire protection walkdowns which were focused on
Enclosure
6
availability, accessibility, and the condition of firefighting equipment in the following risk-
significant plant areas:
- Reactor Auxiliary Building (RAB), 261 Elevation, Boric Acid Batching and Boron
Recycle System Area
- RAB, 261 Elevation, Water Chiller Area A and B
- RAB, 216 Elevation, Mechanical Penetration Area
- RAB, 190 Elevation, A Residual Heat Removal (RHR) and CT Pump Room and
Floor Drain Pump Room
Room
- RAB, 236 Elevation, Mechanical Penetration Area
The inspectors reviewed areas to assess if the licensee had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant, effectively maintained fire detection and suppression capability, maintained
passive fire protection features in good material condition, and had implemented
adequate compensatory measures for out of service, degraded or inoperable fire
protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to fire risk as
documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to impact equipment which could initiate or mitigate a
plant transient, or their impact on the plants ability to respond to a security event. Using
the documents listed in the Attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
fire detectors and sprinklers were unobstructed, that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition. The inspectors also verified that minor issues identified
during the inspection were entered into the licensees corrective action program.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #475487, June 2011 Key Performance Indicator (KPI) - Unplanned Fire
Protection Action Statement Entries is Red
- AR #480615, Rag Left in Non Intervening Combustible Zone
- AR #486849, Fire Wrap Worn Down Around B Chiller
- AR #490585, Unsatisfactory Response to Site Fire Alarm by Site Personnel
- AR #491139, Fire Brigade Dispatch did not Meet Management Expectations
b. Findings
No findings were identified.
Enclosure
7
.2 Annual Fire Protection Drill Observation
a. Inspection Scope
On August 23, 2011, the inspectors observed fire brigade performance during an
announced drill. This drill exercised the fire brigades response to a beyond design
basis event in the Fuel Handling Building requiring use of the emergency diesel makeup
pump and other infrequently used equipment, as well as coordinating with an offsite fire
department which sent a ladder truck and personnel to assist. The observation was
used to determine the readiness of the plant fire brigade to fight fires. The inspectors
verified that the licensee staff identified deficiencies; openly discussed them in a self-
critical manner at the drill debrief, and took appropriate corrective actions. Specific
attributes evaluated were:
- Proper wearing of turnout gear and self-contained breathing apparatus
- Proper use and layout of fire hoses
- Sufficient firefighting equipment brought to the scene
- Effectiveness of fire brigade leader communications, command, and control
- Utilization of pre planned strategies
- Adherence to the pre planned drill scenario
- Fulfillment of drill objectives
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review
a. Inspection Scope
On September 7, 2011, the inspectors observed a crew of licensed operators in the
plants simulator during licensed operator requalification training to verify that operator
performance was adequate and training was being conducted in accordance with
licensee procedures. The inspectors evaluated the following areas:
- Licensed operator performance
- Crews clarity and formality of communications
- Ability to take timely actions in the conservative direction
- Prioritization, interpretation, and verification of annunciator alarms
- Correct use and implementation of abnormal and emergency procedures
- Control board manipulations
- Oversight and direction from supervisors
Enclosure
8
- Ability to identify and implement appropriate TS actions and Emergency Plan actions
and notifications
The crews performance in these areas was compared to pre-established operator action
expectations and successful critical task completion requirements.
b. Findings
No findings were identified.
.2 Annual Review of Licensee Requalification Examination Results
a. Inspection Scope
On April 13, 2011, the licensee completed the annual requalification operating tests
required to be administered to all licensed operators in accordance with 10 CFR
55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results
of the individual operating tests and the crew simulator operating tests. These results
were compared to the thresholds established in Manual Chapter 609 Appendix I,
Operator Requalification Human Performance Significance Determination Process.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were entered into the corrective action program with the appropriate
significance characterization. Documents reviewed are listed in the Attachment.
The inspectors evaluated degraded performance issues involving the following risk
significant components:
- AR #481394, Demineralized Water Transfer Pump Tripped on Low Discharge
Pressure; and
- AR #480812, E-5A Breaker (Containment PRE-Entry Exhaust Fan) did not trip as
required during testing.
The inspectors focused on the following attributes:
- Implementing appropriate work practices;
Enclosure
9
- Identifying and addressing common cause failures;
- Scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;
- Characterizing system reliability issues for performance;
- Charging unavailability for performance;
- Trending key parameters for condition monitoring;
- Ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification;
- Verifying appropriate performance criteria for structures, systems, and components
(SSCs)/functions classified as (a)(2) or appropriate and adequate goals and
corrective actions for systems classified as (a)(1).
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the
five maintenance and emergent work activities affecting risk-significant equipment listed
below to verify that the appropriate risk assessments were performed prior to removing
equipment for work:
- Expected Yellow Risk Configuration during Demineralized Water Resin Regeneration
on July 8, 2011;
- Expected Yellow Risk Condition while B Main Feed Regulation Valve is in manual
for testing on August 1, 2011;
- Unexpected Yellow Risk Condition resulting from the Demineralized Water Transfer
Pump (DWTP) tripping on August 7, 2011;
- Unexpected Risk Assessment following Seismic Event on August 23, 2011, yielded
Green Risk based on present plant data; and
- Unexpected Yellow Risk Condition for a Tornado Warning on September 6, 2011.
These activities were selected based on their potential risk significance relative to the
reactor safety cornerstones. As applicable for each activity, the inspectors verified that
risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
and complete. When emergent work was performed, the inspectors verified that the
plant risk was promptly reassessed and managed. The inspectors reviewed the scope
of maintenance work, discussed the results of the assessment with the licensee's
probabilistic risk analyst or shift technical advisor, and verified plant conditions were
consistent with the risk assessment. The inspectors also reviewed TS requirements and
walked down portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met.
The inspectors reviewed the following ARs associated with this area to verify that the
Enclosure
10
licensee identified and implemented appropriate corrective actions:
- AR #480828, Unexpected Trip of DWTP
- AR #486403, AP-300, Severe Weather Response Procedure Response to the
Tornado Warning
- AR #486613, Public Address System Announcements Cannot be Heard in the Mail
Room
b. Findings
No findings were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors selected the following four potential operability issues to evaluate based
on the risk significance of the associated components and systems. The inspectors
evaluated the technical adequacy of the evaluations to ensure that TS operability was
properly justified and the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors compared the operability and
design criteria in the appropriate sections of the TS and UFSAR to the licensees
evaluations, to determine whether the components or systems were operable. Where
compensatory measures were required to maintain operability, the inspectors
determined whether the measures in place would function as intended and were
properly controlled. The inspectors determined, where appropriate, compliance with
bounding limitations associated with the evaluations. Additionally, the inspectors also
reviewed a sampling of corrective action documents to verify that the licensee was
identifying and correcting any deficiencies associated with operability evaluations.
Documents reviewed are listed in the Attachment.
- AR #475602, A Essential Services Chilled Water (ESCW) Chiller Tripped on Low
Lube Oil Pressure;
- AR #477108, Reactor Coolant System (RCS) Flow Loop A Channel is Drifting High;
- AR #475166, A Containment Spray Pump Lower Motor Oil Leakage; and
Inlet Relief Valve is Leaking by Seat.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #480803, Unexplained Increase in ESCW Expansion Tank
- AR #480812, Containment Pre-Entry Purge Exhaust Fan did not Trip as Required
- AR #480983, Sample Line for Tank Area Radiation Monitor Clogged
- AR #481128, Valve Hand Wheel Turns when it is Stroked Remotely
Enclosure
11
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following seven post-maintenance (PM) activities to verify
that procedures and test activities were adequate to ensure system operability and
functional capability:
Test Title Related Date
Procedure Maintenance Activity Inspected
Engineering Change (EC)
OPT-1530 Dedicated Shutdown Diesel July 7, 2011
- 81662, Installation of Check
Generator (DSDG) Operability
Valve in Fuel Supply Line
Test Monthly Interval All Modes
DSDG
EPT-033/ Emergency Safeguards Work Orders (WO) #1893252, July 18,
EPT-443 Sequencer System Test/ 1921061, 1921062 and 2011
Emergency Safeguards 1921064, Replace Selected
Sequencer Relay Trend and Relays and Indicating Light
Analysis Resistors
MPT- Molded Case Circuit Breaker WO #1899046, E-29-1B August 9,
E0024 (Safe Shutdown) Test Switchgear Room B Exhaust 2011
Fan Scheduled Maintenance
OPT-1529 Alternate Seal Injection Pump WO #1930249, Alternate Seal August 12,
Operability Test Quarterly Injection (ASI) Pump has Oil 2011
Intervals All Modes Leak Coming From the Gear
Drive
CM-E0032 Undervoltage Relay WO #1930574, Time Delay August 19,
(UVTXSB/1732) Replacement Pick Up Relay Replacement 2011
OST-1013 Emergency Diesel Generator WO #1517714, Replace The September
Operability Test Monthly Interval Listed "A" EDG Pressure 1, 2011
Modes 1-6 Switches
Enclosure
12
OST-1215 Emergency Service Water WO #1899448, Stroke Test September
System Operability Train B ISW-124 following Scheduled 19, 2011
Quarterly Interval Maintenance (Breaker Testing)
These activities were selected based upon the structure, system, or component's ability
to impact risk. The inspectors evaluated these activities for the following: the effect of
testing on the plant had been adequately addressed; testing was adequate for the
maintenance performed; acceptance criteria were clear and demonstrated operational
readiness; test instrumentation was appropriate; tests were performed as written in
accordance with properly reviewed and approved procedures; equipment was returned
to its operational status following testing, and test documentation was properly
evaluated. The inspectors evaluated the activities against TS and the UFSAR to ensure
that the test results adequately ensured that the equipment met the licensing basis and
design requirements. In addition, the inspectors reviewed corrective action documents
associated with post-maintenance tests to determine whether the licensee was
identifying problems and entering them in the corrective action program and that the
problems were being corrected commensurate with their importance to safety.
Documents reviewed are listed in the Attachment.
b. Findings
Introduction: A self-revealing Green NCV of TS 6.8.1, Procedures, was identified for the
licensees failure to develop an adequate post maintenance test (PMT) procedure for the
replacement of a defective 6.9kV undervoltage relay (UVTXSB/1732). Specifically, the
licensee failed to ensure that the PMT procedure CM-E0032, UVTXSB/1732 relay
replacement, established adequate steam isolation to the TDAFW pump to prevent an
inadvertent actuation. This resulted in the TDAFW pump inadvertently starting and
injecting water into the steam generators which caused an increase in reactor power to
100.2 percent for approximately one minute.
Description: During the performance of a new procedure, on June 21, 2011, the
licensee replaced the UVTXSB/1732 relay. The replacement of the relay was performed
by procedure CM-E0032.
During the actual relay replacement efforts, no problems were encountered. During the
restoration section of the procedure, DC power fuses were replaced and the Key Test
Switch for KTS-SB-1732A was placed to test. This energized a relay that opened 1MS-
72 (main steam line C to TDAFW control isolation valve) which opened and emitted
steam to start the TDAFW pump. This resulted in water flowing to the steam generators,
and a resultant increase in reactor power to 100.2 percent.
As corrective actions, the licensee secured the TDAFW pump, restored reactor power to
100 percent, and replaced the failed relay. In order to return the TDAFW pump to
Enclosure
13
operable, the licensee performed a surveillance test to meet the requirements of the
PMT. The applicable procedures were placed on administrative hold for evaluation and
revision. Additionally, an investigation was performed to determine further corrective
actions. The issue was placed into the CAP as AR #472616.
Analysis: The licensees failure to develop an adequate PMT procedure CM-E0032
(UVTXSB/1732 relay replacement) to ensure adequate steam isolation to the TDAFW
pump and prevent an inadvertent actuation was a performance deficiency. The
performance deficiency was more than minor because it was associated with the human
performance attribute of the Mitigating System cornerstone, and it affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core
damage). Specifically, it resulted in the automatic start of the TDAFW pump, water
flowing to the steam generators, and a resultant increase in reactor power to 100.2
percent. Using IMC 0609, Significance Determination Process, Phase 1 screening
worksheet, this finding was determined to be very low safety significance because it was
not a design or qualification deficiency confirmed to result in a loss of operability or
functionality, did not represent a loss of system safety function, did not result in a loss of
safety system function for a single train for greater than TS allowed outage time, did not
result in a loss of safety function of one or more non-TS trains of equipment designated
as risk significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not screen as potentially risk
significant due to seismic, flooding, or severe weather initiating event. The finding had a
cross-cutting aspect of Human Error Prevention, as described in the Work Practices
component of the Human Performance cross-cutting area, because the licensee did not
apply sufficient human error prevention measures during the development and
implementation of the PMT procedure (CM-E0032), to establish adequate steam
isolation and prevent an inadvertent TDAFW pump actuation (H.4(a)).
Enforcement: TS 6.8.1, Procedures, requires that written procedures shall be
established, implemented, and maintained, covering applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Section 9 of Appendix A of Regulatory Guide 1.33 requires procedures for maintenance
that can affect the performance of safety related systems. Procedure CM-E0032,
UVTXSB/1732 relay replacement, contained the steps for the 6.9kV undervoltage relay
replacement, including PMT. Contrary to this requirement, the licensee failed to
establish an adequate procedure for the replacement of the 6.9kV undervoltage relay, in
that the performance of procedure CM-E0032 resulted in an inadvertent start of the
TDAFW pump. This caused water to be injected to the steam generators and increased
power of 100.2 percent. As corrective actions, the licensee secured the TDAFW pump,
restored reactor power to 100 percent, and replaced the failed relay. In order to return
the TDAFW pump to operable, the licensee performed a surveillance test to meet the
requirements of the PMT. The applicable procedures were placed on administrative
hold for evaluation and revision. Additionally, an investigation was performed to
determine further corrective actions. Because the finding is of very low safety
significance and has been entered into the CAP as AR #472616, this violation is being
Enclosure
14
treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy:
NCV 05000400/2011005-01, Inadvertent Actuation of Turbine Driven Auxiliary
Feedwater Pump Caused by Inadequate Procedure.
1R22 Surveillance Testing
.1 Routine Surveillance Testing
a. Inspection Scope
For the three surveillance tests below, the inspectors observed the surveillance tests
and/or reviewed the test results for the following activities to verify the tests met TS
surveillance requirements, UFSAR commitments, inservice testing requirements, and
licensee procedural requirements. The inspectors assessed the effectiveness of the
tests in demonstrating that the SSCs were operationally capable of performing their
intended safety functions.
- OPT-1512, Essential Chilled Water Turbopak Units Quarterly Inspection/Checks
Modes 1-6 on July 12, 2011;
- OST-1119, CT Operability Train B Quarterly Interval Modes 1-4 on August 11, 2011
and;
- OST-1045, Engineered Safety Features Actuation System (ESFAS) Train B Slave
Relay Test Quarterly Interval Modes 1-4 on August 19, 2011.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #481669, B CT Pump Suction Check Valve (1CT-72) Failed Acceptance
Criteria
- AR #482027, 1CT-72 (B CT Pump Suction Check Valve) Testing Methodology
needs to be Assessed
b. Findings
No findings were identified.
.2 In Service Testing (IST) Surveillance
a. Inspection Scope
The inspectors reviewed the performance of OST-1076, B Auxiliary Feedwater (AFW)
Pump Operability Test Quarterly Interval Modes 1-4 on July 18, 2011, to evaluate the
effectiveness of the licensees American Society of Mechanical Engineers (ASME)
Section XI testing program for determining equipment availability and reliability. This
surveillance satisfies the IST requirements for the following components throughout the
Enclosure
15
AFW system:
Valve
- 1AF-4, A AFW Pump Recirculation to CST Check Valve
- 1AF-110, Turbine Driven AFW Pump Recirculation to CST Check Valve
- 1CE-46, CST Suction Check Valve to B AFW Pump
- 1AF-49, A AFW Pump Flow Control Valve (FCV) to A Steam Generator (S/G)
- 1AF-201, A AFW Pump Line to A S/G Check Valve 1AF-54
- 1AF-54, A AFW Pump Line to A S/G Check Valve
- 1AF-202, B AFW Pump Line to B S/G Check Valve 1AF-92
- 1AF-92, B AFW Pump Line to B S/G Check Valve
- 1AF-203, A and B AFW Pump Common Line to C S/G Check Valve 1AF-73
- 1AF-73, A and B AFW Pump Common Line to C S/G Check Valve
- B AFW Pump
The inspectors evaluated selected portions of the following areas:
- Testing procedures and methods
- Acceptance criteria
- Compliance with the licensees IST program, TS, selected licensee commitments,
and code requirements
- Range and accuracy of test instruments
- Required corrective actions
b. Findings
No findings were identified.
.3 Containment Isolation Valve Testing
a. Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether
risk-significant systems and equipment were capable of performing their intended safety
function and to verify testing was conducted in accordance with applicable procedural
and TS requirements:
The inspectors observed in-plant activities and reviewed procedures to determine
whether: any preconditioning occurred; effects of the testing were adequately
Enclosure
16
addressed by control room personnel or engineers prior to the commencement of the
testing; acceptance criteria were clearly stated, demonstrated operational readiness, and
were consistent with the system design basis; plant equipment calibration was correct,
accurate, and properly documented; as left setpoints were within required ranges; and
the calibration frequency were in accordance with TSs, the UFSAR, procedures, and
applicable commitments; measuring and test equipment calibration was current; test
equipment was used within the required range and accuracy; applicable prerequisites
described in the test procedures were satisfied; test frequencies met TS requirements to
demonstrate operability and reliability; tests were performed in accordance with the test
procedures and other applicable procedures; test data and results were accurate,
complete, within limits, and valid; test equipment was removed after testing; where
applicable, test results not meeting acceptance criteria were addressed with an
adequate operability evaluation or the system or component was declared inoperable;
where applicable for safety-related instrument control surveillance tests, reference
setting data were accurately incorporated in the test procedure; prior procedure changes
had not provided an opportunity to identify problems encountered during the
performance of the surveillance or calibration test; equipment was returned to a position
or status required to support the performance of its safety functions; and all problems
identified during the testing were appropriately documented and dispositioned in the
corrective action program. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1EP6 Emergency Planning Drill Evaluation
a. Inspection Scope
The inspectors observed an emergency preparedness (EP) drill conducted on August
29, 2011, to verify licensee self-assessment of classification, notification, and protective
action recommendation development in accordance with 10 CFR 50, Appendix E.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR # 484957, Two Environmental Monitoring Teams not Manned for Drill
b. Findings
No findings were identified.
Enclosure
17
2. RADIATION SAFETY
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
Radiation Monitoring Instrumentation: During tours of the Reactor Auxiliary Building
(RAB), spent fuel pool areas, and Radiologically Controlled Area (RCA) exit point, the
inspectors observed installed radiation detection equipment including the following
instrument types: area radiation monitors (ARM), continuous air monitors, personnel
contamination monitors (PCM), small article monitors (SAM), portal monitors (PM), and
liquid and gaseous effluent monitors. The inspectors observed the physical location of
the components, noted the material condition, and compared sensitivity ranges with
UFSAR details.
In addition to equipment walk-downs, the inspectors observed source checks and alarm
setpoint testing of various portable and fixed detection instruments, including ion
chambers, teletectors, PCMs, SAMs, portal monitors, and a whole body counter. For the
portable instruments, the inspectors observed the use of a high-range calibrator and
discussed periodic output value testing with a health physics technician. The inspectors
reviewed the last two calibration records and evaluated alarm setpoint values for
selected ARMs, PCMs, portal monitors, SAMs, and effluent monitors. This included a
sampling of instruments used for post-accident monitoring such as containment high-
range ARMs and effluent monitor high-range noble gas channels. Radioactive sources
used to calibrate selected ARMs and effluent monitors were evaluated for traceability to
national standards. Calibration stickers on portable survey instruments and air samplers
were noted during inspection of storage areas for Aready-to-use@ equipment. The most
recent 10 CFR Part 61 analysis for dry active waste was reviewed to determine if
calibration and check sources are representative of the plant source term. The
inspectors also reviewed count room quality assurance records for gamma ray
spectroscopy equipment and liquid scintillation detectors.
Problem Identification and Resolution: The inspectors reviewed selected ARs in the
area of radiological instrumentation. The inspectors evaluated the licensees ability to
identify and resolve the issues in accordance with procedure CAP-NGGC-0200,
Condition Identification and Screening Process, Rev. 33. The inspectors also
evaluated the scope of the licensees internal audit program and reviewed recent
assessment results.
Effectiveness and reliability of selected radiation detection instruments were reviewed
against details documented in the following: 10 CFR Part 20; NUREG-0737,
Clarification of TMI Action Plan Requirements; Technical Specifications (TS) Section
3.3.3; UFSAR Chapters 11 and 12; and applicable licensee procedures. Documents
reviewed are listed in section RS05 of the report Attachment.
Enclosure
18
b. Findings
Introduction: The inspectors identified a Green NCV of 10 CFR 20.1501 for the failure to
periodically calibrate radiation monitoring equipment. Specifically, in 2004 the licensee
eliminated periodic calibrations for 64 radiation monitors used to evaluate the magnitude
of radiation levels and quantities of radioactive material.
Description: The inspectors noted that UFSAR Tables 11.5.2-2 and 12.3.4-1 provides
lists of radiation monitors that are included in the Radiation Monitoring System (RMS) for
effluent monitoring and area monitoring. Included in these tables are three RAB exhaust
effluent monitors (REM-01AV-3531, REM-01AV-3532A, and REM-01AV-3532B) and 61
area monitors that were designated as run-to-failure in 2004 and were removed from
the licensees periodic calibration program. As such, calibrations for the subject
monitoring equipment would only be scheduled following equipment failure or other
significant maintenance activities. Periodic response checks for most of these monitors
were also discontinued. Although these radiation monitors are no longer calibrated, they
are still used to evaluate radiological hazards. The inspectors noted that readouts from
these radiation detectors are continuously monitored for abnormal radiation levels by
Health Physics technicians at a central monitoring location. In addition, Section 11.5.2.3
of the UFSAR states that, The major function of the Radiation Monitoring System (RMS)
is to provide plant operations personnel and health physics personnel with both current
and historical measurements of the radiological conditions in certain areas and plant
systems during both normal and design basis conditions. In addition, this system
automatically produces alarms to warn plant personnel and in certain cases exerts
control action when unusual radiological conditions or equipment malfunctions occur.
The inspectors noted that the RAB exhaust effluent monitors are not final release point
monitors and that none of the 64 affected radiation monitors have any automatic
actuation functions.
Analysis: The inspectors determined that classifying radiation monitors as run-to-failure
and thereby eliminating periodic calibrations was a performance deficiency. This finding
was associated with the Occupational Radiation Safety Cornerstone and was greater
than minor because it adversely impacted the cornerstone objective to ensure the
adequate protection of worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Although
operational occurrences such as low sample line flow, loss of counts, detector high
voltage, or loss of communication alarms could lead to identification of significant
monitor problems, the failure to perform periodic calibrations and response checks could
impair the licensees ability to reliably quantify radiation levels in the plant environs and
in radioactivity released to the environment during normal and accident situations. This
finding was evaluated using IMC 0609, Appendix C, Occupational Radiation Safety SDP,
and was determined to be of very low safety significance (Green) because the finding is
not related to ALARA dose planning, did not result in an overexposure, and the ability to
assess dose was not compromised due to the use of appropriate personnel dosimetry
and frequent radiological surveys of RCA areas. In addition, none of the affected
Enclosure
19
radiation monitors have any automatic actuation functions. This finding is not indicative
of current licensee performance and therefore has no cross-cutting aspect.
Enforcement: 10 CFR 20.1501(a)(2) requires, in part, that licensees make surveys to
evaluate the magnitude and extent of radiation levels and quantities of radioactive
material. 10 CFR 20.1501(b) requires that the licensee shall ensure that instruments
and equipment used for quantitative radiation measurements be calibrated periodically
for the radiation measured. Contrary to this, from December 2004 to the present, the
licensee has failed to periodically calibrate 64 radiation monitors used to evaluate the
magnitude and extent of radiation levels and quantities of radioactive material. The
licensee has initiated immediate and long-term corrective actions including re-
assignment of all radiation monitors to a periodic calibration frequency and a design
change to eliminate radiation monitors that are redundant or infrequently used. Because
this violation was of very low safety significance and was entered into the licensees
corrective action program as AR #477569, this violation is being treated as an NCV,
consistent with Section 2.3.2 of the Enforcement Policy: NCV 05000400/2011004-02:
Failure to periodically calibrate radiation monitors.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
Event and Effluent Program Reviews: The inspectors reviewed the 2009 and 2010
Annual Radiological Effluent Release Report (ARERR) documents for consistency with
the requirements in the Offsite Dose Calculation Manual (ODCM) and TS details.
Routine and abnormal effluent release results and reports, as applicable, were reviewed
and discussed with responsible licensee representatives. Status of the radioactive
gaseous and liquid effluent processing equipment and activities, and changes thereto,
as applicable, described in the UFSAR and current ODCM were discussed with
responsible staff.
Walk-Downs and Observations: The inspectors walked down accessible areas of the
RAB to ascertain material condition and configuration of tanks, piping, valves, and
pumps used to process and discharge gaseous and liquid radioactive waste. To the
extent practical, the inspectors observed the material condition of abandoned liquid
waste processing equipment for indications of degradation or leakage that could
constitute a possible release pathway to the environment.
Sampling and Analyses: In addition to observing the collection of the samples from the
above walkdowns, the inspector observed the preparation of samples for analysis and
administrative processing for selected gaseous effluent release permits. The inspector
noted independent verification of the permit results and concurrent verification of
equipment manipulations performed to allow the release. The results of the chemistry
count rooms inter-laboratory comparison program were reviewed and discussed with
cognizant licensee personnel.
Enclosure
20
Dose Calculations: The inspectors discussed recent changes in reported dose values
relative to previous ARERR reporting periods with an emphasis placed on Carbon-14
radionuclide source term quantities and resultant doses. The inspectors reviewed and
evaluated a gaseous release and a liquid effluent release. The evaluations included
review and discussion of set point determinations and dose calculation summaries.
Dose calculations associated with potential releases were reviewed and discussed in
detail. Updated results for the most recent land use census data were evaluated against
assumptions used to calculate offsite dose results. In addition, the inspectors reviewed
selected abnormal release data and resultant dose calculations for 2009 and 2010.
Ground Water Protection Implementation: The licensees implementation of the Industry
Ground Water Protection Initiative was reviewed for changes since the last inspection.
Recent groundwater sampling results were reviewed. Licensee response, evaluation,
and follow-up to spills and leaks since the last inspection were discussed with cognizant
licensee representatives.
Problem Identification and Resolution: The inspectors reviewed selected Corrective
Action Program (CAP) documents in the areas of effluent processing and groundwater
protection. The inspectors evaluated the licensees ability to identify, characterize,
prioritize, and resolve the identified issues in accordance with CAP-NGGC-0205,
Condition Evaluation and Corrective Action Process, Rev. 12.
Effluent process and monitoring activities were evaluated against details and
requirements documented in UFSAR Sections 11 and 12; TS Sections 5.4.1
Procedures, 5.5 Programs and Manuals, and 5.6 Reporting Requirements; ODCM; 10
CFR Part 20; 10 CFR, Appendix I to Part 50; and approved licensee procedures. In
addition, ODCM and UFSAR changes since the last onsite inspection were reviewed
against the guidance in NUREG-1301 and RG 1.109, RG 1.21, and RG 4.1. Records
reviewed are listed in Sections 2RS7 and 4OA1.
b. Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program (REMP)
a. Inspection Scope
REMP Status and Results: The inspectors reviewed and discussed recent and
proposed changes applicable to Radiological Environmental and Meteorological
Monitoring program activities detailed in the UFSAR and ODCM. REMP sample results
presented in Annual Radiological Environmental Operating Report (AREOR) documents
issued for 2009 and 2010 were reviewed and discussed. REMP vendor laboratory
cross-check program results and procedural guidance for collection, processing, and
analysis of airborne particulate and iodine samples and broadleaf vegetation samples
Enclosure
21
were reviewed and discussed with knowledgeable personnel. Detection level
sensitivities as document within the AREOR for selected environmental media analyzed
by the offsite environmental laboratory were reviewed. The AREOR environmental
measurement results were reviewed for consistency with licensee ARERR data and
evaluated for radionuclide concentration trends. Licensee actions for missed airborne
monitoring samples were reviewed and discussed in detail. The inspectors discussed
analysis of water samples from onsite manholes and reviewed associated ODCM
requirements for the lower limit of detection. The inspectors discussed the contribution
to environmental iodine in air, water, and milk samples due to the Fukushima event and
actions taken to accurately quantify radionuclides in the environment attributable to
licensee operations.
Site Inspection: The inspectors observed and discussed implementation of selected
REMP monitoring and sample collection activities for atmospheric particulates and
iodine, direct radiation measurements, and broadleaf vegetation samples as specified in
the current ODCM and applicable procedures. The inspectors observed equipment
material condition and evaluated operability, including a review of flow rates and total
sample volume results, at seven atmospheric sampling stations and two composite
water sample locations. In addition, the inspectors discussed broadleaf vegetation and
milk sampling for selected ODCM locations. The impact of licensee routine releases on
offsite doses based on meteorological dispersion parameters and garden locations
identified in the most current land use census were reviewed in detail. Changes in
annual average atmospheric dispersion coefficients were discussed along with the
addition of new air samplers in three sectors which had the highest calculated particulate
and iodine deposition. Material condition and placement of selected environmental
thermo-luminescent dosimeters were observed. Actions for missed samples including
compensatory measures and/or availability of replacement equipment were discussed
with vendor technicians and knowledgeable licensee staff. In addition, sample pump
calibration and maintenance records for the installed environmental air monitoring
equipment were reviewed.
The inspectors observed the physical condition of the meteorological tower and
associated instruments and discussed equipment operability, maintenance history, and
backup power supplies with responsible licensee staff. For the meteorological
measurements of wind speed, wind direction, and temperature, the inspectors reviewed
applicable meteorological tower instrumentation semi-annual calibration records and
evaluated meteorological measurement data recovery for 2009 and 2010.
The inspectors reviewed ground and surface water sample results and discussed
proposed changes to the licensees groundwater monitoring program due to
replacement of the cooling tower blowdown line. The licensees 10 CFR 50.75(g)
decommissioning file was reviewed and discussed.
Identification and Resolution of Problems: The inspectors reviewed selected ARs in the
areas of radiological environmental monitoring and meteorological tower maintenance.
Enclosure
22
The inspectors evaluated the licensees ability to identify and resolve the issues in
accordance with CAP-NGGC-0200, Condition Identification and Screening Process,
Rev. 33.
Procedural guidance, program implementation, quantitative analysis sensitivities, and
environmental monitoring results were reviewed against 10 CFR Part 20; 10 CFR Part
50, and Appendix I to 10 CFR Part 50; TS Sections 6.8, Procedures and Programs, and
6.9, Reports; ODCM, Rev.22 and 23; RG 4.15, Quality Assurance for Radiological
Monitoring Programs (Normal Operation) - Effluent Streams and the Environment; and
the Branch Technical Position, An Acceptable Radiological Environmental Monitoring
Program - 1979. Licensee procedures and activities related to meteorological
monitoring were evaluated against the ODCM; RG 1.23, Meteorological Monitoring
Programs for Nuclear Power Plants, and ANSI/ANS-2.5-1984, Standard for Determining
Meteorological Information at Nuclear Power Sites. Documents reviewed are listed in
Section 2RS07 of the report Attachment.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
To verify the accuracy of the PI data reported to the NRC, the inspectors compared the
licensees basis in reporting each data element to the PI definitions and guidance
contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment
Performance Indicator Guideline.
Mitigating Systems Cornerstone
- Mitigating Systems Performance Index, Emergency AC Power
- Mitigating Systems Performance Index, Heat Removal System
- Mitigating Systems Performance Index, High Pressure Injection System
The inspectors sampled licensee submittals for the Mitigating Systems Performance
Index performance indicators listed above for the period from third quarter 2010 through
the second quarter 2011. The inspectors reviewed the licensees operator narrative
logs, issue reports, MSPI derivation reports, event reports and NRC Integrated
Inspection reports for the period to validate the accuracy of the submittals. The
inspectors reviewed the MSPI component risk coefficient to determine if it had changed
by more than 25 percent in value since the previous inspection, and if so, that the
change was in accordance with applicable NEI guidance. The inspectors also reviewed
Enclosure
23
the licensees issue report database to determine if any problems had been identified
with the PI data collected or transmitted for this indicator and none were identified.
Specific documents reviewed are described in the Attachment to this report.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #409271, Unexpected Indications on Opening Power Panel Breaker
- AR #445372, A EDG Overspeed Trip Pressure Regulator Leaking Air
- AR #436641, Several Oil Leaks on A CSIP Oil Cooler
Occupational Radiation Safety Cornerstone
The inspectors reviewed the Occupational Exposure Control Effectiveness PI results for
the Occupational Radiation Safety Cornerstone from December 2010 through August
2011. For the assessment period, the inspectors reviewed ED alarm logs for exposure
significant areas. The inspectors also reviewed licensee procedural guidance for
collecting and documenting PI data. Documents reviewed are listed in section 4OA1 of
the report Attachment.
Public Radiation Safety Cornerstone
The inspectors reviewed the Radiological Control Effluent Release Occurrences PI
results for the Public Radiation Safety Cornerstone from October 2010 through July
2011. For the assessment period, the inspectors reviewed cumulative and projected
doses to the public and AR documents related to Radiological Effluent Technical
Specifications/Offsite Dose Calculation Manual issues. The inspectors also reviewed
various calculations and release permits associated with the waste gas processing
system. Documents reviewed are listed in section 4OA1 of the Attachment.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of items Entered Into the Corrective Action Program
a. Inspection Scope
To aid in the identification of repetitive equipment failures or specific human performance
Enclosure
24
issues for follow-up, the inspectors performed frequent screenings of items entered into
the licensees corrective action program. The review was accomplished by reviewing
daily action request reports.
b. Findings
No findings were identified.
.2 Annual Sample: Review of Operator Workarounds (OWAs)
a. Inspection Scope
The inspectors evaluated the licensees implementation of their process used to identify,
document, track, and resolve operational challenges. Inspection activities included, but
were not limited to, a review of the cumulative effects of the OWAs on system availability
and the potential for improper operation of the system, for potential impacts on multiple
systems, and on the ability of operators to respond to plant transients or accidents.
The inspectors performed a review of the cumulative effects of OWAs. The inspectors
reviewed both current and historical operational challenge records to determine whether
the licensee was identifying operator challenges at an appropriate threshold, had
entered them into their corrective action program and proposed or implemented
appropriate and timely corrective actions which addressed each issue. Reviews were
conducted to determine if any operator challenge could increase the possibility of an
Initiating Event, if the challenge was contrary to training, required a change from long-
standing operational practices, or created the potential for inappropriate compensatory
actions. Daily plant and equipment status logs, degraded instrument logs, and operator
aids or tools being used to compensate for material deficiencies were also assessed to
identify any potential sources of unidentified operator workarounds.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
b. Findings
No findings were identified.
.3 Selected Issue Follow-up Inspection: Eight Significant Human Performance Events
a. Inspection Scope
The inspectors selected AR #441282, Eight Significant Events from Refueling Outage
(RFO) 16 Related to Human Performance, for detailed review. This AR explored the
Enclosure
25
behaviors that contributed to the series of events that occurred during RFO-16 and any
associated common causes. The inspectors reviewed this report to verify that the
licensee identified the full extent of the issue, performed an appropriate evaluation, and
specified and prioritized appropriate corrective actions. The inspectors evaluated the
report against the requirements of the licensees corrective action program as delineated
in corporate procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50,
Appendix B.
b. Findings
No findings were identified.
.4 Selected Issue Follow-up Inspection: A Chiller Tripped on Low Oil Pressure
a. Inspection Scope
The inspectors selected AR #475602, A Chiller Tripped on Low Oil Pressure, for
detailed review. This AR explored the potential causes of the A Chiller trip as well as
operations response, including compensatory actions. The inspectors reviewed this
report to verify that the licensee identified the full extent of the issue, performed an
appropriate evaluation, and specified and prioritized appropriate corrective actions. The
inspectors evaluated the report against the requirements of the licensees corrective
action program as delineated in corporate procedure CAP-NGGC-0200, Corrective
Action Program, and 10 CFR 50, Appendix B.
b. Findings
No findings were identified.
4OA3 Follow-up of Events
.1 (Closed) Licensee Event Report (LER) 05000400/2011-001-00, Containment Vacuum
Relief System Inoperable for Greater Than Time Allowed by Technical Specification
On April 12, 2011, at 100 percent power, CB-Z2SN, B Train Containment Vacuum
Relief tornado damper, was found inoperable during a function check. The damper was
stuck in an open position due to an incorrectly installed seal clamping bar which
prevented the blades from being moved. The failure of this damper to close caused the
Containment Vacuum Relief System to be inoperable. This condition may have existed
since May of 1999 caused by incorrectly performed maintenance on the damper which
was not discovered during periodic functional checks. This condition likely existed for
longer than allowed by TS and is reportable under 10 CFR 50.73(a)(2)(i)(B). Immediate
corrective actions were to perform maintenance and post-maintenance testing to return
the damper to operable, other tornado dampers were also inspected and repaired as
Enclosure
26
necessary. Additionally, a new procedure, PM-M0123 Tornado Damper Maintenance
and Testing, was written to prevent recurrence of this event.
This event was determined to be an inspector identified NCV of TS 6.8.1 and of very low
safety significance (Green). This NCV was previously documented and closed in NRC
Inspection Report 05000400/2011008 as NCV 05000400/2011008-10. This LER is
closed.
.2 (Closed) LER 05000400/2010-002-01, Manual Actuation of the Reactor Protection
System due to Hydrogen Seal Oil Leak
This LER was issued as a supplement to LER 05000400/2010-002-00 to discuss the
failure of a MSIV to fully close. This event was previously documented in NRC
Inspection Report 05000400/2010003. On November 15, 2009, with the unit at 100
percent power the licensee experienced a significant leak of the Hydrogen Seal Oil
(HSO) system that led to a manual reactor trip. Following the reactor trip the operators
made the decision to break condenser vacuum, which required the Main Steam Isolation
Valves (MSIVs) to be shut. The B steam generator MSIV failed to fully close on
demand from its control switch in the main control room, the MSIV was subsequently
closed by locally isolating instrument air to the valve. This condition is prohibited by TS
and reportable under 10 CFR 50.73(a)(2)(i)(B), as the MSIV was likely inoperable for a
period of time longer than allowed by TS. It is also reportable under 10 CFR 50.73
(a)(2)(v)(C) and 10 CFR 50.73 (a)(2)(v)(D).
The licensee determined the cause of the MSIV failure to fully shut was due to two
Solenoid Operated Shuttle Valves (SOVs), 1MS-82:006 SOV and 1MS-82:007 SOV,
failing to fully realign to vent air after de-energizing. Corrective actions were to replace
the two SOVs on 1MS-82 and also one additional SOV on 1MS-80 that was found to
have been manufactured in the same lot as the two that failed. The enforcement
aspects of this issue are discussed in Inspection Report 05000400/2010003.
The failure to report the event was determined to be a Severity Level IV, NCV of 10 CFR
50.73(b)(2)(ii) and was documented in NRC Inspection Report 05000400/2011008 as
NCV 05000400/2011008-01. This LER is closed.
.3 Event Notification (EN) 47171, Invalid Actuation of the TDAFW Pump
On June 21, 2011, the licensee experienced an invalid actuation of the TDAFW pump
which resulted in flowing water into the steam generators and a corresponding increase
in reactor power to 100.2 percent. This event was entered into the CAP as AR #472616.
The licensee reported this to the NRC via telephone which resulted in the generation of
this EN. This event was determined to be a Green NCV and is documented in section
1R19 of this inspection report.
Enclosure
27
.4 EN 47193, Notice of Unusual Event (NOUE) due to Seismic Disturbance
On August 23, 2011, the licensee declared an NOUE due to an earthquake felt at the
plant with confirmation by the National Earthquake Center. As a result, the licensee
entered their Seismic Disturbances Procedure, AOP-021. The plant continued to
operate at 100 percent power and experienced no damage to equipment. Following the
earthquake, the licensee determined that the seismic motion experienced at the plant
was within their design basis. The inspectors reviewed the licensees actions to
determine adequacy of the operators response. Additionally, the inspectors performed
walkdowns in the plant to identify any potentially earthquake related damage, with no
discrepancies noted.
The inspectors reviewed the following ARs associated with this event to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #484255, Emergency Response Organization Notification of Unusual Event
- AR #484330, Failed to Make Follow Up Notification of Unusual Event Termination
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with licensee
security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors' normal plant status reviews and inspection activities.
The inspectors reviewed the following ARs associated with this area to verify that the
licensee identified and implemented appropriate corrective actions:
- AR #477683, Security Tactical Drill Requirements not Met
- AR #485608, Control of Security Badge and Proximity Reader
- AR #485616, Project Compliance Due Date in Jeopardy
b. Findings
No findings were identified.
Enclosure
28
4OA6 Management Meetings
.1 Exit Meeting Summary
On October 19, 2011, the inspector presented the inspection results to Mr. William
Jefferson, Jr., and other members of the licensee staff. The inspectors confirmed that
proprietary information was not provided or examined during the inspection period.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
D. Corlett, Supervisor, Licensing/Regulatory Programs
J. Dufner, Director, Engineering
D. Griffith, Manager, Training
K. Holbrook, Manager, Support Services
W. Jefferson, Vice President Harris Plant
E. Kapopoulos, Plant General Manager
B. McCabe, Manager, Nuclear Oversight
M. Parker, Superintendent, Radiation Control
M. Robinson, Superintendent, Environmental and Chemistry
T. Slake, Manager, Security
J. Warner, Manager, Outage and Scheduling
F. Womack, Manager, Operations
NRC personnel
R. Musser, Chief, Reactor Projects Branch 4, Division of Reactor Projects, Region II
Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000400/2011004-01 NCV Inadvertent Actuation of Turbine Driven Auxiliary
Feedwater Pump Caused by Inadequate Procedure
(Section 1R19)05000400/2011004-02 NCV Failure to Periodically Calibrate Radiation Monitors.
(Section 2RS5)
Closed
05000400/2011-001-00 LER Containment Vacuum Relief System Inoperable for
Greater Than Time Allowed by Technical Specification
(Section 4OA3.1)
05000400/2010-002-01 LER Manual Actuation of the Reactor Protection System
due to Hydrogen Seal Oil Leak (Section 4OA3.2)
Attachment
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
- ORT-1415, Electric Unit Heater Check Monthly Interval
- OP-161.01, Operations Freeze Protection and Temperature Maintenance Systems
- AP-300, Severe Weather
- AP-301, Seasonal Weather Preparations and Monitoring
Section 1R04: Equipment Alignment
Partial System Walkdown
Containment Ventilation System:
- Procedure OP-168 Containment Ventilation System,
- Drawing 2165-S-0517, Simplified Flow Diagram Containment Ventilation System
Containment Spray System:
- Procedure OP-112, Containment Spray System,
- Drawing 2165-S-0550, Simplified Flow Diagram Containment Spray System
Section 1R05: Fire Protection
- FPP-001 Fire Protection Program Manual
Program
- FPP-013, Fire Protection - Minimum Requirements, Mitigating Actions and
Surveillance Requirements
- FPP-012-02-RAB261, Reactor Auxiliary Building Elevation 261 Fire Pre-Plan
- FPP-012-04-DBG, Diesel Generator Building Fire Pre-Plan
- FPP-012-01-CNMT, Containment Building Fire Pre-Plan
- FPP-012-03-FHB, Fuel Handling Building Fire Pre-Plan
- FPP-012-07-TB, Turbine Building Fire Pre-Plan
- FPP-012-06-WPB, Waste Processing Building Fire Pre-Plan
- FPP-012-08-SEC, Out Building Fire Pre-Plan
- FPP-012-09-LAF, Large Area Fire Pre-Plan
- FPP-012-02-RAB 236, Reactor Auxiliary Building Elevation 236 Fire Pre-Plan
- FPP-012-02-190-216, Reactor Auxiliary Building Elevations 190 and 216 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 324 Fire
Pre-Plan
Attachment
4
Section 1R11: Licensed Operator Requalification Program
Benchmark Tests
- SST-001, Steady State Accuracy and Stability Test, Performed 11/16/09, 12/15/10
- SST-002, Steady State Accuracy and Stability Test, Performed 11/16/09, 12/15/10
- SST-003, Steady State Accuracy Test, Performed 11/16/09, 12/15/10
- TT-001, Reactor Trip, Performed 10/10
Job Performance Measure (JPM) Packages
- Transfer Control to The ACP
- Reset Turbine Driven Aux Feedwater Pump
- Place Containment Cooling in the Maximum Cooling Mode
- Classify an Event - ALERT
General Documentation Reviewed
- Biennial written examination for 2010 - weeks 1 through 5
- Calculation E-5525, Safe Shutdown in Case of Fire
- Remedial Action Plan - 2009 - 2010
- Requal attendance records 2009-2010
- EOP-Users Guide, Part 4, Rev 29
- LERs 2009 to 2010
Procedures
- OSP-NGGC-1000, Fleet Conduct of Operations, Revision 3
- Operations Management Manual, OMM-001, Operations Administrative
Requirements, Rev 92
- Training Administrative Procedure (TAP) -403, Examination and Testing, Rev 19
- TAP 410, NRC License Examination Security Program, Rev 15
- TAP-412, Simulator Operations, Maintenance and Testing, Rev 8
- Training Program Procedure (TPP)-206 Training Program Procedure-Simulator Rev
10
- TPP- 306, Licensed Operator Continuing Training Program, Revision 20
- TRN-NGGC-0002, Performance Review and Remedial Training, Rev 0
- TRN-NGGC-0420, Conduct of Simulator Training and Evaluation, Rev 0,
- TRN-NGGC-0440, Rev 0
- TRN-NGGC-1000, Conduct of Training, Rev 3
- AOP- 004, Remote Shutdown
- HNP-E/ELEC-0001 Appendix 1 Compliance Assessment by Scenario
TRN-NGGC-1000, Conduct of Training, Rev 3
Attachment
5
Section 1R12: Maintenance Effectiveness
- NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance
at Nuclear Power Plants
- ADM-NGGC-0101, Maintenance Rule Program
Section 1R13: Maintenance Risk Assessments and Emergent Work Evaluation
- OMP-003, Outage Shutdown Risk Management
- OMM-001, Conduct of Operations
- WCP-NGGC-1000, Conduct of On-Line Work Management
- OPS-NGGC-1311, Protected Equipment
- WCM-001, On-line Maintenance
- ADM-NGGC-0006, Online Equipment Out of Service (EOOS) Models for Risk
Assessment
Section 1R15: Operability Evaluations
- OPS-NGGC-1305, Operability Determinations
Section 1R22: Surveillance Testing
- FSAR 3.11A, NUREG-0588 Comparison
- ISI-802, In-Service Testing of Pressure Relief Devices
2RS5: Radiation Monitoring Instrumentation
Procedures and Guidance Documents
- AOP-005, Radiation Monitoring System, Rev. 27
- HPP-500, Radiation Monitoring System Data Base Manual, Rev. 20
- HPS-NGGC-0005, Calibration of Portable Radiation/Contamination Survey
Instruments, Rev. 12
- CAP-NGGC-0200, Condition Identification and Screening Process, Rev. 33
Records and Data
- Work Order 01701027 01, 1EOF-E007 EOF Outside Air Intake Rad Monitor
Calibration, 2/19/10
- Work Order 00863982 01, 1EOF-E007 EOF Outside Air Intake Rad Monitor
Calibration, 3/7/08
- Work Order 01132751 01, RM-01CR-3589SA Containment High Range Accident
Monitor Calibration, 5/12/09
- Work Order 01530979 01, RM-01CR-3589SA Containment High Range Accident
Monitor Calibration, 11/11/10
- Work Order 01157530 01, RM-01CR-3590SB Containment High Range Accident
Monitor Calibration, 4/27/09
Attachment
6
- Work Order 01553034 01, RM-01CR-3590SB Containment High Range Accident
Monitor Calibration, 11/18/10
- Work Order 01409921 01, REM-21WL-3541 Waste Tanks Discharge Monitor
Calibration, 6/17/10
- Work Order 01024182 01, REM-21WL-3541 Waste Tanks Discharge Monitor
Calibration, 11/17/08
- Work Order 01175686 01, RM-21AV-3509-1SA Plant Vent Stack Accident Monitor
Channel Calibration, 12/8/09
- Work Order 01575509 01, RM-21AV-3509-1SA Plant Vent Stack Accident Monitor
Channel Calibration, 5/5/11
- GEM-5 No. 0711-102, Calibration Records, 4/2/10 and 4/5/11
- ARGOS No. 0510-016, Calibration Records, 1/13/09 and 1/9/10
- ARGOS No. 0510-013, Calibration Records, 1/14/09 and 1/11/10
- SAM-9 No. 142, Calibration Records, 5/25/10 and 5/25/11
- Eberline RO-20 No. 3130, Calibration Record, 5/31/11
- Ludlum 9-3 No. 278523, Calibration Record, 7/27/11
- Remball No. 27261, Calibration Record, 11/11/10
- Calibration Data Sheets, Model 89 Shepherd Calibrator, 2/16/10
- Cesium-137 Source No.86-001, Certificate of Gamma Standard Source
- High-purity Germanium Detector No. 1, Annual Efficiency Calibrations, 3/23/10 and
1/12/11
- Liquid Scintillation Detector 2100TR, Calibration, 8/28/09 and 8/19/10
- 10 CFR Part 61 Analysis, Dry Active Waste, 4/21/11
- HNP Shift Narrative Log, 8/16/11
CAP Documents
- H-RP-11-01, Assessment of HNP Radiation Protection, 7/11/11
Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment
Procedures, Guidance Documents, and Manuals
- AP-556, Effluent Management Program, Rev.7
- CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Rev. 12
- CHE-NGGC-0057, Groundwater Protection Program, Rev. 1
- CRC-240, Plant Vent Stack 1 Effluent Sampling, Rev.13
Attachment
7
- CRC-241, Turbine Building Vent Stack 3A Effluent Sampling, Rev. 17
- CRC-242, Waste Processing Building Vent Stack 5 Effluent Sampling, Rev.17
- CRC-243, Waste Processing Building Vent Stack 5a Effluent Sampling, Rev.14
- CRC-244, Containment Air And Condenser Vacuum Pump Effluent Sampling,
Rev.12
- CRC-245, Particulate And Iodine Grab Sampling On Wide Range Gas Monitors,
Rev. 8
- CRC-283, Reporting Radioactive Gaseous Releases, Rev.17
- CRC-284, Reporting Radioactive Liquid Releases, Rev.18
- EMP-012, Groundwater Monitoring Program, Rev. 2
- ERC-009, Handling Inoperable Monitors, Rev. 7
- EST-400, Engineered Safety Feature Air Filtration Testing, Rev. 17
- SHNPP Off-Site Dose Calculation Manual (ODCM), Rev. 23
Records and Data
- Count Room Interlaboratory Comparisons for 2009 and 2010
- EST-400, Engineered Safety Feature Air Filtration Testings, Rev. 17, E-6-1A-SA
AB Emergency Exhaust, Dated 10/28/10 and 03/31/11; E-6-1B-SB RAB Emergency
Exhaust, Dated 09/01/10 and 01/18/11
- Gaseous Radioactive Waste Release Permits: 110039.043.001.G, WGDT J - Batch
Gas, WPB Stack 5, Dated 03/01/11; 110045.043.002.G, WGDT J - Batch Gas, WPB
Stack 5, Dated 03/03/11; 110062.042.001.G, WGDT I - Batch Gas, WPB Stack 5,
Dated 04/04/11; 110110.011.026.G, PVS-1 Continuous, Plant Vent Stack 1, Dated
06/21/11; 110111.021.032.G, TBVS-3A Continuous, Turbine Building Vent Stack 3A,
Dated 06/21/11; 110152.042.003.G, WGDT I - Batch Gas, WPB Stack 5, Dated
08/24/11
- HNP Chemistry System Health Reports, 1st Quarter 2010 to 1st Quarter 2011
- HNP Radiological Environmental Monitoring Analysis Report for Groundwater,
Undated
- HNP Radiological Environmental Monitoring Gamma Isotopic Report for
Groundwater, Undated
- Liquid Radioactive Waste Release Permit 110019.002.004.L, Treated Laundry & Hot
Shower B,
Discharge from Cooling Tower, Dated 06/30/11
- Low-Level Radioactive Waste Analysis Data Sheets, Sample Types: Waste Oil, Low
A SRST Resin, DAW Comp. Filters, Filter Composite, Low A Resin, Low B
Resin; Sample Tracking Nos. 08R024194, 11R033251, 11R033252, 1111R033608,
11R033609; Dated 01/29/09, 01/04/10, 01/29/11, 04/21/11, 04/21/11, 05/03/11,
05/11/11; respectively
- PCHG-DESG, Engineering Changes: 0000062608R3, Replace the vent stack flow
rate monitor controls for the WPB Stack 5, WPB Stack 5A and Plant Vent Stack;
0000069988R3, Return the isokinetic sampling skids to operable by replacing the
current obsolete pumps and flow meters with new parts qualified by the RMS vendor;
and 0000073426R0, Develop design inputs and provide evaluations required for the
software application developed for the flow rate monitor controls upgrade for the
Plant Vent Stack
Attachment
8
- Selected Inoperable Monitor Tracking Sheets from 01/07/10 through 06/09/11
- SHNPP Annual Radioactive Effluent Release Reports, 2009 and 2010
- Tritium Concentration for Wells along CTBD Graph from Jan 2009 to June 2011
CAP Documents
- NEI 07-07, NEI Groundwater Protection Initiative, NEI Peer Assessment Report,
Harris, Dated 11/10/09
- Progress Energy, Report File No. H-EC-10-01, Serial No. HNOS10-020,
Assessment of Harris Environmental and Chemistry Section, Dated 04/06/10
Section 2RS7: Radiological Environmental Monitoring Program (REMP)
Procedures and Reports
- 2009 and 2010 Annual Radiological Environmental Operating Reports
- EVC-NGGC-0003, Radiological Environmental Monitoring Program for HNP, Rev. 10
- EVC-NGGC-0004, HNP land use census, Rev. 3
- EVC-NGGC-0009, Determination of Tritium in Aqueous Samples, Rev. 5
- EVC-NGGC-0010, Determination of Gross Alpha and Gross Beta Activities, Rev. 5
- EVC-NGGC-0011, Determination of Radioiodine in Milk and Water Samples, Rev. 6
- EVC-NGGC-0012, Preparation of Samples for Gamma Counting, Rev. 7
- Met Tower Calibrations for 10/23/09, 2/22/10, 7/28/10, and 3/15/11
- MPT-I0129, Meteorology Tower Equipment Calibration, Rev. 8
- Environmental Cross Check Results 1st Quarter 2010 through 1st Quarter 2011
- H-EC-10-01, Assessment of Harris Environmental and Chemistry Section, Dated
4/6/2010
- ERC-10-005, Selection of Cooling Tower Blowdown Wells for Long Term Sampling,
Rev. 0
- ERC-08-005, Evaluation of Systems, Structures, Components or Work Practices for
the Groundwater Protection Program Rev. 2
- 2010 HNP Land Use Census, 10/14/2010
Records and Data
- Met Tower Calibration, 10/23/09, 4/14/10, 7/28/10, and 3/15/11
- Report of Environmental Iodine Measurements for period 3/1/11 to 5/1/11 showing
Fukushima Japan contribution on 3/28-4/11/2011
- Air Sample Calibration Records, 10/23/09, 4/30/10, 10/21/10, and 4/14/11
Attachment
9
- Environmental Program Cross Checks for first quarter 2010 through first quarter
2011
CAP Documents
Section 4OA1: Performance Indicator Verification
- NEI 99-02, Regulatory Assessment Performance Indicator Guideline
- Calculation HNP-F/PSA-0068, NRC Mitigating System Performance Index Basis
Document for Harris Nuclear Plant
Section 4OA2: Identification and Resolution of Problems
- CAP-NGGC-0200, Corrective Action Program
- CAP-NGGC-0205, Condition Evaluation and Corrective Action Process
- CAP-NGGC-0206, Performance Assessment and Trending
- OPS-NGGC-1305, Operability Determinations
- OP-148, Essential Services Chilled Water System
- Drawing 5-S-0998, Multiple Sheets, HVAC Essential Services Chilled Water
- WO #1954435, A Chiller Compressor Oil Pressure Gauge
- WO #1954156, Investigate A Chiller Trip
- WO #1954435, Calibrate Agastat Relay
Section 4OA3: Event Follow-up
- AOP-021, Seismic Disturbances Procedure, Rev. 31
- AOP-021, Seismic Disturbances Procedure, Rev. 32
Attachment