IR 05000400/2019003

Integrated Inspection Report 05000400/2019003

ML19301A516
Person / Time
Site:	Harris
Issue date:	10/24/2019
From:	Bradley Davis Division Reactor Projects II
To:	Hamilton T Duke Energy Progress
Kroeger A
References
IR 2019003
Download: ML19301A516 (23)

Text

October 24, 2019

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000400/2019003

Dear Ms. Hamilton:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Shearon Harris Nuclear Power Plant. On October 14, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Harris.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Harris. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Bradley J. Davis, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket No. 05000400 License No. NPF-63

Enclosure:

As stated

Inspection Report

Docket Number:

05000400

License Number:

NPF-63

Report Number:

05000400/2019003

Licensee:

Duke Energy Progress, LLC

Facility:

Shearon Harris Nuclear Power Plant

Location:

New Hill, NC 27562

Inspection Dates:

July 01, 2019 to September 30, 2019

Inspectors:

S. Downey, Senior Reactor Inspector

C. Dykes, Health Physicist

D. Jackson, Allegations/Enforcement Specialist

R. Patterson, Senior Reactor Inspector

A. Patz, Resident Inspector

J. Rivera, Health Physicist

J. Zeiler, Senior Resident Inspector

Approved By:

Bradley J. Davis, Chief

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

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

List of Findings and Violations

Failure to Implement Effective Corrective Actions to Preclude Repetition of a Significant Condition Adverse to Quality Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000400/2019003-01 Open/Closed

[P.2] -

Evaluation 71153 A self-revealing Green non-cited violation (NCV) of 10CFR50, Appendix B, Criterion XVI,

Corrective Actions, was identified for the licensees failure to implement effective corrective actions to preclude repetition of a significant condition adverse to quality. Specifically, the licensee failed to adequately address turbine trip system failures involving mechanical binding (sticking) of turbine auto-stop trip (AST) solenoid operated valves (SOVs), resulting in repetitive instances where turbine trip engineered safety features actuation system (ESFAS)response times could not be met as required by Technical Specifications (TS).

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000400/2019-001-00 LER 2019-001-00 for Shearon Harris Nuclear Power Plant, Unit 1, Turbine Control System Auto-Stop Trip Solenoid Operated Valves Response Times Impacted 71153 Closed LER 05000400/2019-001-01 LER 2019-001-01 for Shearon Harris Nuclear Power Plant, Unit 1, Turbine Control System Auto-Stop Trip Solenoid Operated Valves Response Times Impacted 71153 Closed

PLANT STATUS

Unit 1 operated at or near rated thermal power until September 20, 2019, when a power coastdown was initiated in preparation for an upcoming refueling outage. The unit was operating at 93 percent rated thermal power at the end of the report period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Dorian on September 4-6, 2019.

External Flooding Sample (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated readiness to cope with external flooding for the following areas on September 3-6, 2019:

• Emergency diesel generator (EDG) building

• Rooftops and ground elevation flood doors of reactor auxiliary building (RAB),fuel handling building (FHB), turbine building (TB), and waste processing building (WPB)

71111.04Q - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1)

'A' essential services chilled water (ESCW) system while 'B' ESCW chiller was out-of-service due to high oil temperature trip and mechanical cleaning between July 15-17, 2019

(2) B residual heat removal (RHR) pump while A RHR pump was out-of-service for planned maintenance on July 25, 2019 (3)

'B' EDG while 'A' EDG was out-of-service due to emergent failure of room exhaust fan E-86A between August 22-24, 2019

71111.05A - Fire Protection (Annual)

Annual Inspection (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated fire brigade performance during a announced fire drill conducted on September 20, 2019. The fire drill scenario involved a hydrogen seal oil fire on TB elevation 261.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) RAB elevation 286 'A' train essential switchgear room, ventilation room, and battery room (fire zones 1-A-SWGRA, 1-A-BAL-J, and 1-A-BATA) on July 29, 2019

(2) RAB elevation 261 'A' and 'B' electrical penetration rooms, 'A' and 'B' ESCW chiller areas, and alternate seal injection and filter area (fire zones 1-A-EPA, 1-A-EPB, 1-A-4-CHLR, and 1-A-4-COMC) on August 20, 2019

(3) FHB elevation 261 electrical and ventilation equipment areas (fire zones 5-F-3-CHF-BAL, 5-F-3-CHFA, 5-F-3-CHFB, 5-F-3-DMNZ1, and 5-F-3-DMNZ2) on August 22, 2019

(4) RAB elevation 261 charcoal filter areas (1-A-4-CHFA and 1-A-4-CHFB) on August 30, 2019

(5) RAB elevation 261 steam tunnel area (fire zone 1-A-46-ST) on September 9, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) RAB elevation 261 on August 19, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a simulator scenario for training involving a large-break loss-of-coolant accident on July 9, 2019.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Alternate seal injection non-functional due to cooling issues on July 9, 2019 (2)

'B' ESCW chiller tripped on compressor high oil temperature on July 14, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated (Green) risk during unplanned outage of 'B' ESCW system following trip of

'B' ESCW chiller on July 14, 2019

(2) Elevated (Green) risk due to planned unavailability of the A RHR pump for preventive maintenance on July 25, 2019

(3) Elevated (Green) risk due to unplanned unavailability of the 'B' essential safeguards sequencer due to failure of relay 94LO/1169 on August 6, 2019

(4) Elevated (Green) risk due to planned unavailability of the 'B' and 'C' charging and safety injection pumps while swapping from 'B' to 'C' pump on August 13, 2019

(5) Elevated (Green) risk due to unplanned unavailability of the 'A' EDG due to failure of room exhaust fan E-86A on August 22, 2019

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Turbine control system (TCS) AST QuadVoter solenoid valve 1EH-159A failure on July 1, 2019 (Nuclear Condition Report (NCR) 02279964)

(2) Elevated amperage conditions on 'A' train ESCW chiller compressor motor due to suspected leakage past hot gas bypass valve on July 9, 2019 (NCR 02281075)

(3) Unexpected 'B' ESCW chiller trip on compressor high oil temperature on July 14, 2019 (NCR 02281819)

(4) Low emergency service water (ESW) flow from main reservoir to containment fan cooler air handling unit AH-2 during testing on July 19, 2019 (NCRs 02282820 and

===02283578)

(5) Failure of 'B' train essential safeguards sequencer thermal overload and torque switch bypass relay 94LO/1169 during testing on August 6, 2019 (NCR 02285575)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

=

The inspectors evaluated the following temporary or permanent modifications:

(1) EC 0000403358, Replace obsolete Technical Specification recorders

(2) EC 0000410353, Install Phase I Racks in 'D' spent fuel pool (SFP)

71111.19 - Post-Maintenance Testing

Post Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Work Order 20338057 instructions for pressure testing fire suppression piping in TB following temporary repair of broken piping on July 2, 2019

(2) Technical Procedure Testing (OPT)-1512, Train B Essential Chilled Water Turbopak Units Quarterly Inspection and Checks, following corrective maintenance on the 'B' ESCW chiller on July 18, 2019

(3) OPT-1538, Emergency Safeguards Sequencer System Test - Train B Quarterly Interval Modes 1-6, following replacement of failed 'B' train sequencer relay 94LO/1169 on August 8, 2019

(4) Operations Surveillance Test (OST)-1093, Chemical and Volume Control System/Safety Injection System Operability, Train B, Quarterly Interval, following planned maintenance on the 'B' charging and safety injection pump on August 14, 2019

(5) Operating Procedure (OP)-177, Diesel Generator Building HVAC System, Section 5.3, Diesel Generator Room Ventilation Start-Up, following replacement of failed 'A' EDG room exhaust fan E-86A on August 24, 2019

(6) OPT-1083, B-SB Train ESW Flow Verification/Balance, following chemical cleaning of service water side of 'B' component cooling water (CCW) heat exchanger on September 13, 2019

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) OPT-1082, A-SA Train ESW Flow Verification/Balance, on July 25, 2019

(2) OST-1086, 1B-SB Diesel Generator Operability Test, Semiannual Interval, Modes 1-6, on August 1, 2019

(3) OPT-1512, Essential Chilled Water Turbopak Units Quarterly Inspection/Checks Modes 1-6, on August 23, 2019

(4) OST-1191, Steam Generator PORV and Block Valve Operability Test, on September 9, 2019

Inservice Testing (IP Section 03.01) (1 Sample)

(1) EST-223, Insitu Main Steam Safety Valve Test Using Assist Device, on September 26, 2019

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (2 Samples)

The inspectors evaluated:

(1) A tabletop drill involving an earthquake during reactor refueling on September 16, 2019.

(2) An after-hours augmentation drill involving an anticipated transient without scram (ATWS) with loss of heat sink accident on September 18, 2019.

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) A simulator-based licensed operator training evolution involving a large-break loss-of-coolant accident on July 9,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Inspectors evaluated licensee performance in ensuring gaseous and liquid effluent processing systems are maintained to properly mitigate, monitor and evaluate radiological discharges to the public. Inspectors reviewed compensatory measures for out-of-service effluent monitors.

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

(1) Inspectors reviewed the following:

Systems Liquid waste system Gaseous waste system

Observed routine processing No routine processing available during the inspection period

Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed gaseous and liquid effluent monitor instrument calibrations by reviewing information not limited to but including alarm set points, periodicity, and National Institute of Standards Traceability for sources used. Information reviewed included but was not limited to the following:

(1) Effluent monitor calibrations I, MST-I0327, WASTE MONITOR TANKS DISCHARGE REM-3541 CAL, 05/16/16, 05/01/19 I, MST-I0407, Main Steam Line Monitor RM-3592 Calibration, 04/20/2018, 11/2/2016

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed radioactive effluent sampling and analysis activities.

(1) Radioactive Effluent Sampling and Analysis Activities Turbine Building Vent Stack sampling

Effluent Discharges None were available for review during this inspection

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed flow rates for effluent stack and related vent flow and surveillances.

Inspectors also reviewed maintenance and methodologies for one or two high-range effluent monitors (or other effluent/process monitor) relied on in emergency operating procedures for decision making.

(1) The inspectors reviewed the following:

Air Cleaning Systems E-13-1X-SB FHB Emergency Exhaust Surveillance, 02/16/2017; 09/12/2018 EPT - 400: Attachment 6,S-1-1B Containment Airborne Radioactivity Removal periodic test, 04/22/2018

High-Range Effluent Monitor I,MST-I0401/CM-10085, Containment High Range Accident Monitor Calibrations, 12/12/2018; 12/12/2016

Dose Calculations (IP Section 02.05) (1 Sample)

The inspectors reviewed required annual reports for changes, release permits and the offsite dose calculation manual for changes and results. The inspectors reviewed the following to assess public dose:

(1) The inspectors reviewed the following to assess public dose:

Liquid and Gaseous Discharge Permits

• G-2019-0090, 05/29/2019

• G-2019-0091, 05/29/2019

• G-2019-0092, 05/29/2019

• L-2019-0016, 05/30/2019

Annual Radiological Effluent Release Reports

• 2018 Shearon Harris Nuclear Power Plant Unit 1 Annual Radioactive Release Report

• 2017 Shearon Harris Nuclear Power Plant Unit 1 Annual Radioactive Release Report

Abnormal Gaseous or Liquid Tank Discharges

• G-2017-0214

71124.07 - Radiological Environmental Monitoring Program

Inspectors evaluated licensee performance in ensuring the Radiological Environmental Monitoring Program (REMP) is implemented in accordance with licensing documentation and the REMP is validating that if there is any dose to the public it is within the legal limits. Inspectors also reviewed the licensee's effort to continue to implement the Nuclear Energy Institute (NEI) Ground Water Protection Initiative (GPI).

Site Inspection (IP Section 02.01) (1 Sample)

The inspectors performed walkdowns of sampling stations, thermoluminescent locations and meteorological instrumentation. Inspectors also performed observations of preparation and collections of different environmental sample types. Inspectors reviewed sampling results and maintenance, calibration, quality control and groundwater records.

(1) Records reviewed, and samples observed included but were not limited to the following:

Walkdowns and calibration and maintenance record review:

• ENRAD Laboratories LV-1D Air Sampler Certificate of Calibration 09072, 4/2/18 and 4/10/19

• ENRAD Laboratories LV-1D Air Sampler Certificate of Calibration

===09083, 3/9/18 and 3/19/19

• ENRAD Laboratories LV-1D Air Sampler Certificate of Calibration 09089, 9/13/17 and 11/5/18

• TLD site no. 1 at 2.6 miles N

• TLD site no. 4 at 3.1 miles NNE

• TLD site no. 26 at 4.7 miles S

• ENRAD Laboratories Certificate of Calibration 09262, ISCO Model 3710 Portable Water Sampler, 9/17/18

Observed environmental sample collections and preparation:

• None were available for observation during this inspection

Missed sample, inoperable sampler, lost TLD or anomalous measurement:

• Composite water sampler location 26 inoperable for approximately 12 days in June 2018

• Air sampler location 47 inoperable for approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> in October 2017

• TLD location 33 was found missing from its designated location in the 4th quarter of 2017

Sampling program for the potential of licensed material entering ground water:

• Old Steam Generator Storage Building Sump

• Old Reactor Head Storage Building Sump

• Component Cooling Water System

Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02)===

(1) The inspectors reviewed the licensee's continuing implementation of the voluntary NEI Ground Water Protection Initiative.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) Unit 1 (July 1, 2018 - June 30, 2019)

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

(1) Unit 1 (July 1, 2018 - June 30, 2019)

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

(1) Unit 1 (July 1, 2018 - June 30, 2019)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1) Turbine-driven auxiliary feedwater pump tripped on starting after routine surveillance due to a failure of the turbine governor valve positioner (NCR 02253215)

(2) Multiple TCS AST QuadVoter solenoid valves failed to cycle during testing on April 16-17, 2019 (NCR 02269085)

71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

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

(1) LER 05000400/2019-001-00 and 05000400/2019-001-01, Turbine Control System Auto-Stop Trip Solenoid Operated Valves Response Times Impacted, on June 17, 2019 and September 16, 2019 (ADAMS Accession Nos. ML19168A008 and ML19259A071). The circumstances surrounding the LER and updated LER submittal is documented in report section Inspection Results.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

71007 - Reactor Vessel Head Replacement Inspection

Reactor Vessel Head Replacement Inspection (1 Sample 1 Partial)

(1) The inspectors evaluated the following engineering change packages to verify that design changes and modifications associated with the reactor vessel head replacement were properly screened and evaluated, if required, in accordance with Title 10, Code of Federal Regulations (CFR) 50.59:

1. EC 0000294345, Replacement Reactor Vessel Head (RRVH) and Insulation

Design and Installation, Revision 0

2. EC 0000294355, RRVH Project - Equipment Hatch and Interference Removal,

Revision 0

3. EC 0000294346, Control Rod Drive Mechanism (CRDM) and Digital Rod

Position Indicator (DRPI) Cable Design and Installation, Revision NEW A

4. EC 0000294347, RRVH Transport and Haul Path - Transport of Original

Reactor Vessel Head (ORVH) and RRVH to/from Reactor Containment Building to Storage, Revision 0

This sample was reviewed using IP 71111.17T, Evaluations of Changes, Tests, and Experiments, as guidance. The inspectors also reviewed key design aspects of the replacement reactor vessel head (RRVH) as well as provisions for a temporary containment opening using IP 71111.18 as guidance. In addition, the inspectors reviewed site documents and records to verify that the ASME Code requirements used to construct the RRVH were reconciled with those used to construct the original reactor vessel head; that the original ASME Code N-stamp documentation for the reactor vessel remains valid; and that the RRVH complies with the appropriate NRC rules and ASME requirements. Finally, the inspectors reviewed the procurement specification for the RRVH to verify that there is a contract requirement to maintain part identification and traceability during processing of the replacement head.

The review of these inspection items constitutes a completion of the inspection requirements of IP 71007, Steps 02.02.a.1 and 02.02.a.2.

(2)

(Partial)

The inspectors reviewed and observed aspects of the following RRVH activities on September 18-20, 2019:

• Preparations for RRVH haul route testing inside the protected area

• Initial lift of RRVH to upright position from hydraulic transporter using two crane lift system

• Preparations for removing RRVH from shipping container

INSPECTION RESULTS

Failure to Implement Effective Corrective Actions to Preclude Repetition of a Significant Condition Adverse to Quality Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000400/2019003-01 Open/Closed

[P.2] -

Evaluation 71153 A self-revealing Green non-cited violation (NCV) of 10CFR50, Appendix B, Criterion XVI, Corrective Actions, was identified for the licensees failure to implement effective corrective actions to preclude repetition of a significant condition adverse to quality. Specifically, the licensee failed to adequately address turbine trip system failures involving mechanical binding (sticking) of turbine auto-stop trip (AST) solenoid operated valves (SOVs), resulting in repetitive instances where turbine trip engineered safety features actuation system (ESFAS)response times could not be met as required by Technical Specifications (TS).

Description:

On April 16-17, 2019, the licensee performed testing of the four SOVs associated with the AST emergency turbine trip system and four SOVs associated with the Overspeed Protection Control (OPC) turbine trip system. During this testing, two of four AST SOVs (one in each of the two channels) failed to change position when their electrical trip solenoids were de-energized. With a failed SOV in both AST channels, the AST system was incapable of depressurizing the AST hydraulic header which would have prevented a turbine trip had an actual trip actuation demand signal been generated. As a result, this rendered inoperable, the turbine trip instrumentation channels on steam generator water level hi-hi, per TS 3.3.2, ESFAS Instrumentation, Function 5, since the required 2.5 second turbine trip ESFAS response time in accordance with TS surveillance requirement 4.3.2.2 would not have been satisfied. The significance of this event was mitigated by the successful testing and continued functionality of the OPC turbine trip system during the period that the AST system was non-functional. Specifically, had an actual turbine trip signal occurred, the turbine control system would have generated an additional, although delayed by 6-7 seconds, demand signal that would have energized the OPC turbine trip system and effectively tripped the main turbine.

The inspectors reviewed the licensees root cause evaluation for the AST SOV failures.

These failures were attributed to the same phenomenon that occurred June 29, 2018, involving the failure of SOVs in both AST channels due to sticking of the SOV pilot valves.

Forensic analysis and evaluation of the current failures identified several common mode failure issues that most likely contributed to sticking of the spool-type pilot valves in the SOVs. These issues included the following:

• There was buildup of small particles of oil contamination in the clearances of the SOV pilot valve sliding spool internals, a known industry phenomenon referred to as silting.

• The incorrect internal SOV pilot valve trip springs were installed. The need for the higher force spring was to provide greater trip margin and offset the vulnerability of sticking SOV pilot valves due to silting.

• Debris/contamination, including aluminum shavings, from either original valve manufacturing or modification installation was found within all the SOV assemblies.

• High SOV pilot valve electrical coil armature temperatures exceeding the Fyrquel recommended temperature limitation known to cause varnish film buildup leading to spool-type pilot valve sticking.

As part of the licensee's root cause evaluation, a review was conducted of the previous AST SOV failure on June 29, 2018, documented in NCR 02216793. The licensee concluded from this review that the previous root cause evaluation was ineffective at preventing the most recent failures. The previous root cause evaluation was determined to be too narrowly focused and did not validate assumptions through direct observations via forensics of the failed SOV slave and pilot valve internals nor adequately pursue causes other than the initial missed AST SOV testing frequency. The inspectors agreed with the licensees assessment of the previous evaluation since the evaluation missed the above-mentioned issues needed to properly address the common mode vulnerabilities with using the spool-type pilot valve SOVs in a Fyrquel hydraulic fluid application. Since the previous failure investigation was designated in the licensees corrective action program as a significant condition adverse to quality, the inspectors determined that the licensee had failed to implement adequate corrective actions to preclude repetition of a significant condition adverse to quality.

Corrective Actions: The licensees immediate corrective actions included manual cycling of the SOVs and repeated exercising to remove silting and varnish film buildup from the SOV pilot valve internals. In addition, the frequency for testing the AST SOVs was immediately increased from weekly to bi-weekly with each SOV being cycled five times during each test.

Subsequently, the SOV pilot valve trip actuation lower force springs were replaced with the originally intended higher force springs to increase trip margin, and the doors to the turbine enclosure housing where the AST SOVs were located were directed to be left open whenever possible to provide increased cooling. Planned corrective actions included more SOV pilot valve and assembly oil fluid flushing, as well as initiation of a design change to replace the spool-type pilot SOVs with poppet style SOVs that are known to be less susceptible to sticking from silting and the oil varnish phenomenon.

Corrective Action References: NCR 02269085

Performance Assessment:

Performance Deficiency: The licensees failure to implement corrective actions to preclude repetition of a significant condition adverse to quality involving degraded TS ESFAS response times for the turbine AST actuation function was a performance deficiency (PD).

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to preclude repetition of sticking AST SOVs rendered the turbine AST ESFAS function inoperable.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened by Exhibit 2, Mitigating Systems Screening Questions, under Section C, Reactivity Control Systems. The inspectors determined that a detailed risk evaluation was required since both channels of the turbine AST function were impacted rendering the system incapable of depressurizing the AST hydraulic header needed to generate an automatic turbine trip within the allowable TS response time (i.e., 2.5 seconds) for a steam generator hi-hi level turbine trip ESFAS actuation. A detailed risk evaluation of the PD was previously performed by a Region II Senior Reactor Analyst in accordance with NRC IMC 0609, Appendix A, during NRC review of the AST SOV failures that occurred previously on June 29, 2018. (See NCV 05000400/2018003-001 documented in NRC Integrated Inspection Report 05000400/2018003, dated October 26, 2018). The results of the NRCs previous risk evaluation determined the issue to be a Green finding of very low safety significance. The inspectors determined that this previous risk evaluation remained bounding for the current issue.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the root cause evaluation for the June 29, 2018 sticking turbine AST SOV failure was narrowly focused and failed to address outstanding system common mode vulnerabilities that existed with the AST SOVs that could impact their reliable operation.

Enforcement:

Violation: 10CFR50, Appendix B, Criterion XVI, Corrective Actions, requires in part, that, for significant conditions adverse to quality, measures shall assure that the cause of the condition is determined, and corrective action taken to preclude repetition.

Contrary to the above, from June 29, 2018 to April 16, 2019, the licensee failed to establish measures to assure that corrective action was taken to preclude repetition of a significant condition adverse to quality. Specifically, the licensee failed to adequately address sticking in turbine trip system AST SOVs, resulting in repetitive instances where turbine trip ESFAS response times could not be met as required by TS.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On October 14, 2019, the inspectors presented the integrated inspection results to Tanya Hamilton and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71007

Calculations

C-3597-110

RRVH Transport & Storage Beams

Revision 0

HNP-C/RVHR-

0003

Shearon Harris RVH Haul Route Evaluation

Revision 0

HNP-C/STRU-

1144

HNP Equipment Hatch Temporary Plates and Weld Analysis

Revision 0

HNP-C/STRU-

1148

Shearon Harris Waste Processing Building RVH Loading

Evaluation

Revision 0

Corrective Action

Documents

AR 02135952

RRVH and ORVH Rigging, Lifting and Transportation Into

and Out of Reactor Containment Building

Revision 0

Corrective Action

Documents

Resulting from

Inspection

AR 02284913

CRDM and DRPI Cable Bend Radius Installation Instruction

Revision 0

Drawings

1364-097748

Shearon Harris Unit 1 Equipment Hatch Modification

Revision 3

1447E94

Loop Integrated Head Package Cable Arrangement

Revision 0

4R6563

Cable Assembly DRPI - Shutdown

Revision C

6R6552-LX

Cable Assembly CRDM

Revision D

6R6562

Cable Assembly DRPI Control

Revision C

P-3597-190

RRVH Upending Drawing

Rev. D

SK-EC294347-

(001-004)

Framatome General Arrangement Upending RRVH

Revision 3

SK-EC294347-

017

Framatome Haul Route Offload Location to Hydraulic Gantry

Revision 6

Engineering

Changes

EC 0000294347

RRVH Transport and Haul Path

Rev. 0

Miscellaneous

CAR-SH-AS-001

Specification EBASCO Containment Liner, Air Locks, and

Hatch

Revision 12

HNP-E-0015

Integrated Head Package Prefabricated Cable Assemblies

Specification

Revision

NEW A

HNP-G-0009

Procurement Specification for the Replacement Reactor

Vessel Head

Revision 7

HNP-M-RVHR-

Control Rod Drive Mechanism Pressure Housing Assembly

Revision 0

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

0017

ASME III Class I Design Report

HNP-M/RVHR-

0013

ASME Section XI Code Reconciliation of the Replacement

Reactor Vessel Head Modified L106-A1 CRDM

Revision 0

HNP-M/RVHR-

0016

ASME Certified Design Report for Shearon Harris Unit 1

Replacement Reactor Vessel Closure Head

Revision 0

HNP-M/RVHR-

0018

Shearon Harris Unit 1 Reactor Vessel Closure Head &

RVLIS Piping Subassembly ASME Code Reconciliation

Revision 0

HNP-RVHR-0001

Certified Design Specification for Replacement Reactor

Vessel Closure Head for Duke Energy Shearon Harris Unit 1

Revision

NEW B

HNP-RVHR-0005

RVLIS and RVHVS Installation Piping Assemblies

Manufacturing Specification for Shearon Harris Unit 1 RRVH

Revision

NEW B

HNP-RVHR-002

Shearon Harris RRVCH CRDM Equipment Specification

Revision

NEW A

Procedures

50-9253449-000

Shearon Harris Unit 1 Outage Master Traveler

06/01/2019

RS-1482

Teledyne Acceptance Test Procedure for Commercial

Nuclear Cable Assemblies

Revision 0

TLR-19-025

Temporary Load Release (for upending RRVH)

9/9/2019

71111.01

Drawings

8-G-0033, sheet

Door Schedule Special Doors, Watertight, Wire Mesh &

Metal Partition

Rev. 11

Miscellaneous

Licensee

Response Letter

to NRC Near

Term Task Force

Review of

Fukushima Da-

Ichi Accident

Flood Hazard Reevaluation Report, Revision 1

4/1/2015

Licensee

Response Letter

to NRC Near

Term Task Force

Review of

Fukushima Dai-

Ichi Accident

Flood Hazard Reevaluation Report

3/12/2013

Procedures

AP-046

Control of Environmental Protective Features

Rev. 5

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AP-300

Severe Weather Response

Rev. 34

EPT-040

Flood Barrier Penetration Seal Visual Inspection

Rev. 1

71111.04Q Drawings

CPL-2165S-1308

Simplified Flow Diagram Safety Injection System

CPL-2165S-1310

Simplified Flow Diagram Safety Injection System Sheet 3

Unit 1

CPL-2165S-1324

Simplified Flow Diagram Residual Heat Removal System

Procedures

AD-OP-ALL-0201

Protected Equipment

Rev. 5

OP-111

Residual Heat Removal System

Rev. 63

OP-148

Essential Services Chilled Water System

Rev. 80

OP-155

Diesel Generator Emergency Power System

Rev. 89

71111.05A

Fire Plans

CSD-HNP-PFP-

TB

Turbine Building Pre-Fire Plan

Rev. 3

Procedures

AD-OP-ALL-0207

Fire Brigade Administrative Controls

Rev. 2

FPP-001

Fire Protection Program Manual

Rev. 44

FPP-002

Fire Emergency

Rev. 45

71111.05Q Corrective Action

Documents

Resulting from

Inspection

AR 02288370

Revision to Pre-Fire Plan CSD-HNP-PFP-FHB

08/22/2019

NCR 02291377

Transient combustible material found in the RCA by EAL

09/11/2019

Fire Plans

CSD-HNP-PFP-

FHB

Fuel Handling Building Pre-Fire Plan

Rev. 1

CSD-HNP-PFP-

RAB-261

Reactor Auxiliary Building Elevation 261 Pre-Fire Plan

Rev. 1

CSD-HNP-PFP-

RAV-286

Reactor Auxiliary Building Elevation 286 Pre-Fire Plan

Rev. 1

Miscellaneous

Fire Protection Permit and Impairment Log Entries

Procedures

AD-EG-ALL-1520

Transient Combustible Control

Rev. 12

FPP-001

Fire Protection Program Manual

Rev. 44

FPP-013

Fire Protection - Minimum Requirements, Mitigating Actions

and Surveillance Requirements

Rev. 100

71111.06

Calculations

PRA-F-E-0006

Reactor Auxiliary Building Unit 1 El. 261' Internal Flooding

Analysis

Rev. 4

71111.11Q Procedures

AD-OP-ALL-1000

Conduct of Operations

Rev. 15

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AD-TQ-ALL-0420

Conduct of Simulator Training and Evaluation

Rev. 15

EOP-E-0

Reactor Trip or Safety Injection

Rev. 12

EOP-E-1

Loss of Reactor or Secondary Coolant

Rev. 5

EOP-ES-1.3

Transfer to Cold Leg Recirculation

Rev. 4

OMM-001

Operations Administrative Requirements

Rev. 115

71111.12

Corrective Action

Documents

NCR 02259420

Alternate seal injection nonfunctional due to 1&2B recycle

monitor tank

2/25/2019

NCR 02281819

'B' ESCW chiller tripped on compressor high oil temperature

7/14/2019

Miscellaneous

DBD-320

Alternate Seal Injection System

Rev. 4

Procedures

AD-EG-ALL-1210

Maintenance Rule Program

Rev. 1

71111.13

Calculations

HNP-F/PSA-0119

Online Phoenix Model

Rev. 1

Procedures

AD-NF-ALL-0501

Electronic Risk Assessment Tool (ERAT)

Rev. 2

AD-WC-ALL-0200 On-Line Work Management

Rev. 14

AD-WC-ALL-0240 On-Line Risk Management Process

Rev. 1

AD-WC-ALL-0410 Work Activity Integrated Risk Management

Rev. 8

OP-107

Chemical and Volume Control System

Rev. 117

Work Orders

20147570

B-SB Chiller Tripped

7/14/2019

20317600

MPT-M0084, A RHR Motor Oil Change, Mechanical EQ

7/25/2019

20346400

Replace 'B' sequencer thermal overload and torque switch

bypass relay 94LO/1169

8/6/2019

20349380

Replace 'A' EDG room exhaust fan E-86A

8/22/2019

71111.15

Procedures

AD-OP-ALL-0105

Operability Determinations and Functionality Assessments

Rev. 4

71111.18

Corrective Action

Documents

Resulting from

Inspection

AR 02283561

Calculation 9-SAC-002A Not Issued

7/24/2019

Engineering

Evaluations

AR 02269973

50.59 Screening for EC 403358

4/25/2019

Miscellaneous

DBD-1000-V02

Environmental Qualification Design Basis Document

Rev. 11

NEI 96-07

Guidelines for 10 CFR 50.59 Evaluations Endorsed by

Regulatory Guide 1.187

Rev. 1

Procedures

AD-EG-ALL-1132

Preparation and Control of Design Change Engineering

Changes

Rev. 14

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AD-LS-ALL-0008

CFR 50.59 Review Process

Rev. 1

71111.19

Corrective Action

Documents

NCR 02281819

B-SB Chiller Tripped

7/14/2019

Procedures

PLP-400

Post Maintenance Testing

Rev. 64

Work Orders

20321229

OST-1093 - Operability of train "B" charging and safety

injection pump

8/14/2019

20322495

Essential Services Chilled Water Systems Operability

7/14/2019

20346400

Replace 'B' Sequencer Thermal Overload and Bypass Relay

94LO/1169

8/7-8/2019

20349380

'A' EDG exhaust room fan E-86A-SA motor replacement

8/24/2019

20351716

Chemical cleaning of 'B' CCW heat exchanger

9/13/2019

71111.22

Work Orders

20185982

OST-1086, Staggered Test, K610 SI Start Signal

8/01/2019

71114.06

Miscellaneous

Emergency

Preparedness

Drill Package

2019 ERO Augmentation Drill

FAD-HNP-EP-

EPEAL Matrix

Emergency Preparedness - Emergency Action Level Matrix

Rev. 2

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Rev. 7

Procedures

AD-EP-ALL-0105

Activation and Operation of the Technical Support Center

Rev. 3

AD-EP-ALL-0304

State and County Notifications

Rev. 1

AD-EP-ALL-0802

Conducting Drills and Exercises

Rev. 4

AD-EP-ALL-0803

Evaluation and Critique of Drills and Exercises

Rev. 4

AD-EP-HNP-0105 HNP Site Specific Technical Support Center Support

Rev. 0

EP-EAL

Emergency Action Levels

Rev. 18

PD-EP-ALL-0800

Drills and Exercises Program

Rev. 6

PEP-110

Emergency Classification and Protective Action

Recommendations

Rev. 28

PEP-230

Control Room Operations

Rev. 30

PEP-310

Notifications and Communications

Rev. 40

PLP-201

Emergency Plan

Rev. 70

71124.06

Corrective Action

Documents

2170854,

2169244,

2134678,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

200795,

Miscellaneous

ERC-009

2: Inoperable Monitor Tracking Sheet

Revision 1,

1/2018-

2/2018

Work Orders

13337885 01

I, MST-I0376/CM-I0085, Plant Vent Stack Accident Monitor

Channel Calibration

08/31/2015

20131381 01

I, MST-I0401/CM-I0085, Cont High Rang Accident Monitor

Calibration

2/12/16

71124.07

Corrective Action

Documents

AR 2243634

Cs-137 detected in REMP samples

11/14/2018

Miscellaneous

Annual MET Data Recovery for 2017 & 2018

Procedures

AD-CP-ALL-0017

Radiological Groundwater Protection

Rev. 2

Work Orders

211627 01

Met Tower Equipment Calibration

06/26/2018

288663 01

Met Tower Equipment Calibration

2/11/2019

71151

Miscellaneous

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

Rev. 7

Procedures

AD-EG-ALL-1217

Mitigating System Performance Index (MSPI)

Rev. 0

AD-PI-ALL-0700

Performance Indicators

Rev. 2

71152

Engineering

Changes

EC 0000275459

Turbine-Driven AFW Control System Digital Upgrade

Rev. 21

Procedures

AD-LS-ALL-0006

Notification/Reportability Evaluation

Rev. 2

AD-PI-ALL-0100

Corrective Action Program

Rev. 21

AD-PI-ALL-0101

Root Cause Evaluation

Rev. 6

PIC-I825

Terry Turbine Governor Control System Calibration

(Auxiliary Feedwater Pump)

Rev. 20

Work Orders

20307647

TDAFW pump tripped while starting during OST-1044

01/19/2019