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#REDIRECT [[IR 05000400/2011004]]
{{Adams
| number = ML113000409
| issue date = 10/27/2011
| title = IR 05000400-11-004, 05000400-11-502, 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
| author name = Musser R
| author affiliation = NRC/RGN-II/DRP/RPB4
| addressee name = Jefferson W
| addressee affiliation = Carolina Power & Light Co
| docket = 05000400
| license number = NPF-063
| contact person =
| document report number = IR-11-502, IR-11-004
| document type = Inspection Report, Letter
| page count = 42
}}
See also: [[see also::IR 05000400/2011502]]
 
=Text=
{{#Wiki_filter: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 hours,
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
        *  AR #484779, Siren System AC Power Outages, DC Power Remained Available
  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
  *    RAB, 190 Elevation, B RHR and CT Pump Room and Equipment Drain Pump
        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
    *  AR #479364, 1CH-54, Essential Services Chilled Water (ESCW) Make-up Tank B
        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 hours, 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:
      *  1AF-23, B AFW Pump Recirculation to Condensate storage tank (CST) Check
          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-50, A and B AFW Pumps Common FCV to C S/G
      *  1AF-51, B AFW Regulator Valve
      *  1AF-93, B AFW Isolation Valve
      *  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:
      * MST-I0656, Containment Vacuum Breaker (1CB-6) Functional Test
      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
    *  AR #490317, EP Drill Evaluator No-Show
    *  AR #486913, EP Drill Site Area Emergency Classification
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 #437073, A EDG Tripped on Low Jacket Water Pressure
    *  AR #445372, A EDG Overspeed Trip Pressure Regulator Leaking Air
    *  AR #467018, B EDG Test Circuit Relay Failure
    *  AR #413400, Control Switch for B MDAFW will not Spring Return to Normal
    *  AR #417336, Control Switch for TDAFW will not Spring Return to Normal
    *  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:
    *    AR #408027, June OWA KPI Yellow
    *    AR #412763, July OWA KPI Yellow
  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 #484042, Unusual Event Declaration and AOP-021 Entry
    *  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
        *  FIR-NGGC-0009, NFPA 805 Transient Combustibles And Ignition Source Controls
          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
      *  Isolate Ruptured SG - MSIV Will Not Close
      *  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
      *  Work request 496703
      *  HNP Shift Narrative Log, 8/16/11
CAP Documents
      *  H-RP-11-01, Assessment of HNP Radiation Protection, 7/11/11
      *  AR 381548
      *  AR 405099
      *  AR 477569
      *  AR 241895
      *  AR 165629
      *  AR 383155
      *  AR 404435
      *  AR 425878
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
      *  AR 442341
      *  AR 450249
      *  AR 457376
      *  AR 471041
      *  AR 480784
      *  AR 482470
      *  AR 481994
      *  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. HNOS 10-020,
          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
      *  AR 00309988
      *  AR 00393030
      *  AR 00374252
      *  AR 435924
      *  AR 436220
      *  AR 438362
      *  AR 441977
      *  AR 446861
      *  AR 456588
      *  AR 458543
      *  AR 460716
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
}}

Revision as of 08:37, 17 December 2019

IR 05000400-11-004, 05000400-11-502, 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
ML113000409
Person / Time
Site: Harris Duke Energy icon.png
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)
v • d • e


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 #484779, Siren System AC Power Outages, DC Power Remained Available

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;

on August 10, 2011; and

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:

Recycle System Area

  • RAB, 261 Elevation, Water Chiller Area A and B

Floor Drain Pump Room

  • RAB, 190 Elevation, B RHR and CT Pump Room and Equipment Drain Pump

Room

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 #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

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  • 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;

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  • 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;
  • 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 #479364, 1CH-54, Essential Services Chilled Water (ESCW) Make-up Tank B

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

  1. 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

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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:

Criteria

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:

  • 1AF-23, B AFW Pump Recirculation to Condensate storage tank (CST) Check

Valve

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
  • AR #490317, EP Drill Evaluator No-Show
  • AR #486913, EP Drill Site Area Emergency Classification

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

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 #437073, A EDG Tripped on Low Jacket Water Pressure
  • AR #467018, B EDG Test Circuit Relay Failure
  • AR #413400, Control Switch for B MDAFW will not Spring Return to Normal
  • AR #417336, Control Switch for TDAFW will not Spring Return to Normal
  • 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:

  • AR #408027, June OWA KPI Yellow
  • AR #412763, July OWA KPI Yellow

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 Notification47171, 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 #484042, Unusual Event Declaration and AOP-021 Entry
  • 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:

Section 1R05: Fire Protection

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-012-02-RAB 236, Reactor Auxiliary Building Elevation 236 Fire Pre-Plan

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

Job Performance Measure (JPM) Packages

  • Transfer Control to The ACP
  • Isolate Ruptured SG - MSIV Will Not Close
  • Place Containment Cooling in the Maximum Cooling Mode
  • Classify an Event - ALERT

General Documentation Reviewed

  • Biennial written examination for 2010 - weeks 1 through 5
  • Remedial Action Plan - 2009 - 2010
  • Requal attendance records 2009-2010
  • LERs 2009 to 2010

Procedures

  • 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
  • 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

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

Section 1R22: Surveillance Testing

  • 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

Calibration, 2/19/10

Calibration, 3/7/08

Monitor Calibration, 5/12/09

Monitor Calibration, 11/11/10

Monitor Calibration, 4/27/09

Attachment

6

Monitor Calibration, 11/18/10

Calibration, 6/17/10

Calibration, 11/17/08

Channel Calibration, 12/8/09

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
  • 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
  • HNP Shift Narrative Log, 8/16/11

CAP Documents

  • H-RP-11-01, Assessment of HNP Radiation Protection, 7/11/11

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
  • 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
  • Tritium Concentration for Wells along CTBD Graph from Jan 2009 to June 2011

CAP Documents

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

  • 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

  • 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
  • OP-148, Essential Services Chilled Water System
  • Drawing 5-S-0998, Multiple Sheets, HVAC Essential Services Chilled Water

Section 4OA3: Event Follow-up

  • AOP-021, Seismic Disturbances Procedure, Rev. 31
  • AOP-021, Seismic Disturbances Procedure, Rev. 32

Attachment

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