IR 05000400/2007006

IR 05000400-07-006, on 07/30/2007 - 08/03/2007 and 08/13-17/2007, Shearon Harris, Unit 1, NRC Problem Identification and Resolution Inspection Report

ML072570275
Person / Time
Site:	Harris
Issue date:	09/14/2007
From:	Randy Musser NRC/RGN-II/DRP/RPB4
To:	Duncan R Carolina Power & Light Co
References
IR-07-006
Download: ML072570275 (19)

Text

September 14, 2007

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO.

05000400/2007006

Dear Mr. Duncan:

On August 17, 2007, the US Nuclear Regulatory Commission (NRC) completed an inspection at the Shearon Harris Nuclear Power Plant. The enclosed report documents the inspection results, which were discussed on August 17, 2007, with you and other members of your staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

On the basis of the samples selected for review, the inspectors concluded that in general, your corrective action program processes and procedures were effective; thresholds for identifying issues were appropriately low; and problems were properly evaluated and resolved within the problem identification and resolution program (PI&R). A safety conscious work environment was evident. However, the inspectors identified a few examples where corrective actions could have been more thorough.

The inspectors noted two issues involving aspects related to your security program. Specific details are documented in NRC Inspection Report 05000400/2007404.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document

CP&L

Room or from the Publicly Available Records (PARS) component of the 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 No.:

50-400 License No.:

NPF-63

Enclosure:

Inspection Report 05000400/2007006 w/Attachment: Supplemental Information

REGION II==

Docket Nos:

50-400 License Nos:

NPF-63 Report No:

05000400/2007006 Licensee:

Carolina Power & Light Company (CP&L)

Facility:

Shearon Harris Nuclear Power Plant, Unit 1 Location:

5413 Shearon Harris Road New Hill, NC 27652-0165 Dates:

July 30 - August 3 and August 13-17, 2007 Inspectors:

T. Morrissey, Senior Resident Inspector, Crystal River 3 (Lead Inspector)

M. Checkle, RII Allegations Coordinator (Week 1)

K. Davis, RII Security Inspector P. OBryan, Senior Resident Inspector, Harris J. Wallo, RII Senior Security Inspector (Week 2)

G. Williams, Resident Inspector, Catawba Approved by:

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

SUMMARY OF FINDINGS

IR 05000400/2007006; 07/30-08/03, 2007; 08/13-17, 2007; Shearon Harris Nuclear

Power Plant; Identification and Resolution of Problems.

The inspection was conducted by two Region II (RII) senior resident inspectors, a RII based senior security inspector, a resident inspector, a RII based security inspector and a RII based allegation coordinator. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Identification and Resolution of Problems The inspectors determined that in general, problems were properly identified, evaluated, prioritized, and corrected within the licensees problem identification and resolution inspection. Evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant conditions adverse to quality were comprehensive and detailed. Overall, corrective actions developed and implemented for issues were effective in correcting problems. However, the inspectors identified a few examples where corrective actions could have been more thorough.

The processes and procedures of the corrective action program (CAP) were generally adequate; thresholds for identifying issues were appropriately low, and in most cases, corrective actions were adequate to address conditions adverse to quality. Nuclear Assessment Section audits and departmental self-assessments were effective in identifying issues and directing attention to areas needing improvement.

Management emphasized the need for staff to identify and resolve issues using the CAP. Based on discussions and interviews with plant employees from various departments, the inspectors did not identify any reluctance to report safety concerns. A safety conscious work environment was evident.

The inspectors noted two issues involving aspects related to the security program.

Specific details are documented in NRC inspection report 05000400/2007404.

A.

Inspector Identified Findings None B.

Licensee Identified Findings None

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Effectiveness of Problem Identification

.1 Inspection Scope

The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems. A nuclear condition report (NCR) is initiated to document problems that are significant conditions adverse to quality (Priority 1), conditions adverse to quality (Priority 2),conditions adverse to quality with low significance (Priority 3), or improvement items (Priority 5). The inspectors selected NCRs for review which involved issues covering the seven cornerstones that reflect the essential safety aspects of facility operation as identified in the NRCs Reactor Oversight Process (ROP). The selected samples were taken from approximately 5900 NCRs that had been initiated by the licensee since July 2005 (coinciding with the last NRC baseline problem identification and resolution inspection (PI&R)) to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. The reviews primarily focused on issues associated with risk significant plant safety systems: emergency diesel generator (EDG), auxiliary feedwater (AFW), 125 volt DC power, emergency service water (ESW),essential services chilled water (ESCW), containment isolation valve (CIV) and reactor coolant and main steam power operated and safety relief valves systems. The inspectors reviewed NCRs, maintenance history, and selected completed work orders (WOs) for the systems and reviewed associated system health reports to verify that equipment deficiencies were being appropriately entered into the CAP. The inspectors conducted plant walkdowns of accessible equipment associated with the above systems to assess the material condition and to look for any deficiencies that had not been entered into the CAP. The inspectors reviewed the main control room (MCR) deficiency list and control room operator logs for the period July 1 through July 31, 2007, to verify that equipment deficiencies were entered into the CAP. The inspectors reviewed corrective actions associated with the findings documented in NRC inspection reports (IRs) issued since the last PI&R inspection. In addition to the system reviews, the inspectors selected a sample of NCRs that had been initiated by the following departments to ensure complete coverage of all cornerstones: operations, health physics, chemistry, maintenance, work controls, engineering, security, and emergency preparedness. The inspectors reviewed selected industry operating experience (OE)items, including NRC generic communications, to verify that OE items were appropriately evaluated for applicability and whether issues identified through these reviews were entered into the CAP. The inspectors reviewed licensee audits and self-assessments (focusing primarily on problem identification and resolution) to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP. The inspectors attended several plant daily status, unit evaluator and CAP meetings to observe CAP unit evaluator and management oversight functions in the corrective action process. The inspectors also interviewed personnel from operations, maintenance, engineering, security, health physics, chemistry, and emergency preparedness to evaluate their threshold for identifying issues and entering them into the CAP. Documents reviewed are listed in the

.

.2 Assessment

The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP. The threshold for problem evaluation was low based on observed samples, independent walkdowns, staff interviews and the number of items entered into the CAP. NCRs typically provided complete and accurate characterization of the subject issues. Equipment performance issues involving maintenance effectiveness were being identified at an appropriate level and entered into the CAP. Trending was generally effective in monitoring equipment performance.

However, the inspectors noted two issues involving aspects related to the security program. Specific details are documented in NRC inspection report 05000400/2007404.

The licensee was effective in evaluating internal and external industry operating experience items for applicability and entering issues into the CAP. Department self-assessments and audits performed by the Nuclear Assessment Section (NAS) were effective in identifying issues and entering the deficiencies into the CAP. Site management was actively involved in the CAP and focused attention on significant plant issues.

b.

Prioritization and Evaluation of Issues

.1 Inspection Scope

The inspection reviewed the NCRs, including root and apparent cause evaluations, site and departmental trend reports, and observed other activities as discussed in Section 4OA2.a to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspection was intended to verify that the licensee adequately determined the cause of the problems, including root cause analysis where appropriate, and adequately addressed operability, reportability, common cause, generic concerns, extent of condition and extent of cause. The review included the appropriateness of the assigned significance, the timeliness of resolutions, level of effort in the investigation, the scope and depth of the causal analysis. The review was also performed to verify that the licensee appropriately identified corrective actions to prevent recurrence and that those actions had been appropriately prioritized.

The inspectors also reviewed a sample of cancelled NCRs to verify they were cancelled for appropriate reasons. The inspectors also attended several plan of the day meetings, CAP unit evaluator meetings, CAP meetings and a Plant Nuclear Safety Committee (PNSC) meeting to determine if plant issues were being properly characterized, prioritized, assigned, and if appropriate management attention was applied to significant plant issues.

.2 Assessment

The inspectors determined that overall the licensee had appropriately assessed and prioritized issues. The priority level and department assignment for each NCR was determined during the CAP unit evaluator meeting. Each NCR was then later reviewed by management during the daily CAP meeting. This review was thorough and adequate consideration was given to system operability and plant risk. In addition, the inspectors, through attendance of one PNSC and review of prior PNSC meeting minutes, concluded that additional quality was added to the licensees CAP process by the PNSC. The inspectors concluded that evaluation of issues was generally comprehensive and technically adequate. The inspectors did find one example where an NCR that documented a deficient condition was inappropriately cancelled to another NCR that was later rejected. However, all corrective actions were properly completed.

c.

Effectiveness of Corrective Actions

.1 Inspection Scope

The inspectors reviewed a sample of NCRs, selected licensee effectiveness reviews, and work orders initiated to resolve NCRs to verify the licensee had identified and implemented timely and appropriate corrective actions to address problems. The inspectors verified that the corrective actions were properly assigned, documented, and tracked to ensure completion. The review was also conducted to verify the adequacy of corrective actions to address equipment deficiencies and maintenance rule (MR)functional failures of risk significant plant safety systems.

.2 Assessment

The inspectors determined that overall, corrective actions were effective in correcting plant problems. The effectiveness of corrective actions was correlated to good material condition of the systems reviewed. The mechanical systems inspected were generally free of water and oil leaks; and external corrosion. The inspectors identified that most corrective actions implemented by the licensee were appropriate for the severity and risk significance of the problem identified. However, the inspectors identified a few examples where corrective actions could have been more thorough.

• Two NCRs (191879 and 211525) were written addressing improper finger plate installation in two diaphragm valves (one containment isolation valve and the other a non-safety equipment drain valve). Since the contractor maintenance personnel who worked these valves were no longer on-site, no other corrective action other than repairing the valves were specified. As a result of inspector questioning, the licensee initiated NCR 242824 documenting additional actions to provide pre-outage training of valve technicians on this issue and to add additional detail to the preventative maintenance (PM) procedure on proper finger plate installation.

• The inspectors identified an example where the licensee developed an interim corrective action that was questionable in regard to its effectiveness. This corrective action was associated with a service water containment isolation check valve that had failed its local leak rate test (LLRT) during refueling outage RFO11 (NCR 146449). The interim corrective action PM to inspect, lubricate and clean the valve each refueling outage was put in place until an engineering change could be developed, approved and implemented. The valve passed its RFO12 LLRT, however, it was noted that the PM was performed prior to the LLRT. Since an as-found LLRT was not performed, the inspectors questioned whether the LLRT would have passed prior to performing the PM. In the subsequent refueling outage (RFO13), the PM was again performed prior to the LLRT, however in this instance, the licensee determined that the as-found LLRT would have not have passed based on the as-found condition of the valve. The long-term engineering change to replace the valve internals has been approved and scheduled for the RFO14 outage.

• After conducting a Priority 1 root cause investigation and taking corrective actions (NCR 160859) for Operations staff not promptly recognizing and responding to a degraded component in 2005, the Operations staff similarly failed to promptly recognize and respond to degraded equipment on two subsequent occasions in 2007 (NCRs 221803 and 228947). Although Operations did not promptly recognize and respond to the degraded equipment on these occasions, the delay did not result in the equipment being inoperable for greater than the technical specification allowed outage time.

d.

Assessment of Safety-Conscious Work Environment (SCWE)

.1 Inspection Scope

The inspectors conducted interviews with randomly selected members of the plant staff, including operations, maintenance, health physics, engineering, chemistry, and security personnel, to develop a general perspective of the safety-conscious work environment at the site and the willingness of personnel to use the CAP and employee concerns program (ECP). The interviews were also to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors also reviewed the licensees ECP which provides an alternate method to the CAP for employees to raise concerns and remain anonymous. The inspectors reviewed a select number of ECP reports completed since July 2005 for completeness, file documentation, response to the concerned individuals and response to recommended actions by station management, and to verify the investigations conducted were adequate. The inspectors also interviewed the ECP coordinator to gain insight into areas needing additional attention. The inspection included verification that concerns were being properly reviewed and identified deficiencies were being resolved in accordance with procedure REG-NCCC-0001, Employee Concerns Program.

.2 Assessment

In general, the inspectors determined that the Safety-Conscious Work Environment at the site appeared to be adequate, where people felt free to raise issues without fear of retaliation. The inspectors concluded that employees felt comfortable bringing up issues with management, and were aware of the other venues available for reporting safety concerns, such as the ECP.

The inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP, ECP, and Work Order System.

These methods were readily accessible to all employees. Licensee management encouraged employees to promptly identify nonconforming conditions. It was noted that the security organization had implemented an excellence plan which emphasized the importance of a safety conscious work environment through staff training and other actions.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues and felt that management wanted issues placed into the CAP for resolution. Site staff that had used the CAP felt that the program was effective in resolving issues and was a very effective tool in keeping track of issue resolution.

During review of ECP reports, the inspectors determined that the investigations conducted by the ECP were thorough, complete and the recommended corrective actions were appropriately focused to address the actions needed to resolve the individual concerns. It was noted that licensee management generally implemented recommended actions that resulted from ECP investigations and initiated condition reports in the CAP for any condition adverse to quality that had been identified in the file.

Some SCWE concerns were noted in the ECP files reviewed but they had been resolved and were not evident in the staff interviews. The inspectors also did not identify any reluctance to report safety concerns.

4OA6 Management Meetings

The inspectors presented the inspection results to Mr. R. Duncan, and other members of licensee management at the conclusion of the inspection on August 17, 2007. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Findlay, Superintendent, Security

D. Alexander, HNP Superintendent, Environmental and Chemical

D. Corlett, Supervisor - Licensing/Regulatory Programs

W. Saunders, HNP Superintendent, System Engineering

S. OConnor, Manager - Engineering

C. Burton, Director - Site Operations/Acting General Manager

C. Kamilaris, Manager - Nuclear Assessment

L. Morgan, Supervisor - Self Evaluation Unit

P. Morales, Employee Concerns Program

K. Rogers, Self Evaluation Unit OE Program

R. Hill, Self Evaluation Unit CAP

T. Natale, Manager - Outage and Scheduling

G. Simmons, Superintendent - Radiation Control

J. Warner, Operations Manager

T. Mitchell, Quality Assurance

NRC personnel

R. Musser, Chief, Reactor Projects Branch 4