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Biennial Problem Identification and Resolution Inspection Report 05000400 2022011
	ML22201A091
Person / Time
Site:	Harris
Issue date:	07/20/2022
From:	Matthew Fannon; NRC/RGN-II/DRP/RPB4
To:	Haaf T; Duke Energy Progress
References
	IR 2022011
	Download: ML22201A091 (18)
	v • d • e

July 20, 2022

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000400/2022011

Dear Mr. Haaf:

On June 10, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Shearon Harris Nuclear Power Plant.

On June 9, 2022, the NRC inspectors discussed the results of this inspection with Ms. Kim Maza and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the sites problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No. 05000400 License No. NPF-63

Enclosure:

As stated

Inspection Report

Docket Number:

05000400

License Number:

NPF-63

Report Number:

05000400/2022011

Enterprise Identifier:

I-2022-011-0024

Licensee:

Duke Energy Progress, LLC

Facility:

Shearon Harris Nuclear Power Plant

Location:

New Hill, NC 27562

Inspection Dates:

May 23, 2022 to June 10, 2022

Inspectors:

S. Ninh, Senior Project Engineer

W. Pursley, Health Physicist

C. Smith, Resident Inspector

R. Taylor, Senior Project Engineer

A. Wilson, Senior Project Engineer (Team Lead)

Approved By:

Matthew S. Fannon, Chief

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

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

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

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

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

Main article: IP 71152

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of equipment aging issues.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B

1. Corrective Action Program Effectiveness

Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the corrective action program and there was a low threshold for entering issues into the corrective action program. This conclusion was based on a review of the requirements for initiating condition reports as described in licensee procedure AD-PI-ALL-0100, "Corrective Action Program," and managements expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues.

Problem Prioritization and Evaluation: Based on the review of condition reports, the inspectors concluded that problems were prioritized and evaluated in accordance with the condition report significance determination guidance in procedure AD-PI-ALL-0100. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted cause evaluations in compliance with the licensees corrective action program procedures and cause determinations were appropriate, and considered the significance of the issues being evaluated.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed effectiveness reviews to ensure corrective actions were properly implemented and were effective.

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees implementation of the corrective action program adequately supported nuclear safety.

2. Operating Experience

The inspectors determined that the station's processes for the use of industry and NRC operating experience information were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed.

3. Self-Assessments and Audits

The inspectors determined that the licensee effectively performed self-assessments and audits to identify issues at a low level, properly evaluate those issues, and resolve them commensurate with their safety significance. Self-assessments were generally detailed and critical. The inspectors verified that corrective action documents were initiated to document areas for improvement and findings resulting from self-assessments and verified that actions had been completed consistent with those recommendations. Quality assurance program audits appropriately assessed performance and identified areas for improvement.

4. Safety Conscious Work Environment

Based on safety culture interviews with plant personnel, reviews of the latest safety culture survey results, and interviews with employee concerns program personnel, the inspectors found no evidence of challenges to the safety conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

Minor Violation 71152B Minor Violation: During the inspectors' review of the maintenance rule program implementation, specifically the documentation of local leak rate test (LLRT) 1SP-40 Pressurizer Liquid Space Sample Valve (IRC), 1SP-41 Pressurizer Liquid Space Sample Valve (ORC), 1SP-84 Safety Injection System Accumulator C Sample Valve (IRC), and 1SP-85 Safety Injection System Accumulator "C" Sample Valve (ORC), the maintenance rule evaluations concluded that a functional failure had occurred for each penetration. The licensees evaluation concluded that the failures were representative of a Repetitive Maintenance Rule Functional Failure (MRFF). In accordance with procedure AD-EG-ALL-1210, Maintenance Rule Program, Rev. 2, step 5.6.2.4.b, a Maintenance Rule (a)(1)evaluation was required for a Repetitive MRFF. Contrary to this procedure requirement, the inspectors found that no Maintenance Rule (a)(1) evaluation was completed. AD-EG-ALL-1210 is used to establish a program for implementing and maintaining the NRC Maintenance Rule as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants. The inspectors determined the failure to accomplish step 5.6.2.4.b of AD-EG-ALL-1210 represents a violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.

Screening: The inspectors determined the performance deficiency was minor. This performance deficiency was screened in accordance with Inspection Manual Chapter (IMC)0612 Appendix B, Issue Screening Directions, dated October 1, 2021, and was determined to be of minor significance because when the Maintenance Rule (a)(1) evaluation was completed for the repetitive MRFF, it was concluded that the initial maintenance rule evaluations failed to take into account the LLRT leakage test failures of each penetration were not in excess of the administrative limits as defined in EST-212, Type C Local Leak Rate Test, and were evaluated as acceptable in Engineering Change 419545. Therefore, the licensee ultimately concluded that the LLRT failures should not be considered functional failures, and thus no unacceptable performance occurred, and the barrier integrity cornerstone objectives were not adversely affected.

Enforcement:

This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Residual Heat Removal (RHR) Breaker Failure Observation 71152B The inspectors reviewed Nuclear Condition Report (NCR) 02376252, originated on March 29, 2021, which documented a failure of the B RHR pump breaker during testing due to a termination that became loose over time and disconnected due to vibrations experienced during breaker cycling. The licensee had experienced a similar breaker failure in 2001, documented in NCR 29022, and recognized that the spade type connections had the potential of coming loose. Actions were initiated in 2001 due to the loose connection and a corrective action was implemented in PM-E0044, "480 VAC Siemens Type RLN(F) Load Center Breaker and Cubicle PM," that required the installation of Ty-Wraps near the connection point to reduce the probability of the connection from coming loose. The inspectors observed that the corrective actions implemented in 2001 did not prevent the failure of the RHR breaker in 2021. NCR 02376252 determined that PM-E0044 could be enhanced by directing the staff to ensure that spade type connections are confirmed to be tight to prevent slip on the connector. Additionally, a revision to PM-E0044 clarified that where the breaker frame is inaccessible Ty-Wraps are to be installed to fasten to adjacent wiring. The inspectors observed that NCR 02376252 did not clarify the as-found configuration of the Ty-Wraps installed on the RHR breaker connection that came loose. The inspectors observed that no similar failures have occurred since PM-E0044 has been revised with the updated guidance, however, the vendor design using slip on spade type connections is not optimum and that a design weakness still remains.

EXIT MEETINGS AND DEBRIEFS

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

On June 9, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Ms. Kim Maza and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective Action

Documents

212531

22505

23719

24273

232409

235891

258970

259418

263709

276765

288171

297861

297958

2300449

2311457

20227

21895

26566

2330396

2335154

2337926

2339383

2339968

2339978

2340658

2342424

2342816

2344303

2347273

2347492

2348031

2349762

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2350357

2351619

2353159

2353624

2354050

2354786

2355203

2355227

2356217

2356329

2359102

2359190

2359398

2359532

2360087

2360325

2360875

2361456

2361630

2362309

2363024

2363089

2364175

2366039

2366635

2369515

2369538

2372140

2372270

2374367

2374915

2376252

2379092

2379651

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2379780

2380375

2380478

2380481

2380777

2380884

2381326

2381331

2381665

2381927

2385454

2387102

2387573

2389593

2390237

2390439

2390732

2392028

2392806

2393021

2395124

2395876

2397219

2398689

2400230

2403501

2403733

2405601

2405765

2406828

2408631

2408989

2409078

2409079

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2409314

2410990

2411360

2411682

2411730

2412354

2413545

2413628

2413948

2417230

2417987

2418968

2419412

20239

20406

21858

22025

22807

22808

23085

23332

24516

26647

26973

28530

Missed Maintenance Rule (a)(1) Evaluation

Corrective Action

Documents

Resulting from

Inspection

2430708

NRC PI&R Inspection Observation

Engineering

Changes

EC 419545

Acceptability of Valves Exceeding LLRT Admin Limits Exiting

RFO-23

REVISION 0

ESR 9800571

Calculation HNP-C/STRS-1050, Evaluation of Permanent

Lead Shielding Installed on RHR Pump 1A

2/23/1998

Engineering

Evaluations

ESR-9900169

Evaluation of Permanent Lead Shielding Installed on RHR

Pump

01/28/2000

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EVAL-2020-HNP-

1065-00002161

EVAL-2020-HNP-

4085-00002154

EVAL-2020-HNP-

5015-00002157

EVAL-2021-HNP-

2085-00002177

EVAL-2021-HNP-

5145-00002175

EVAL-2021-HNP-

5175-00002173

Station Health Report - Emergency Diesel Generator and

Auxiliaries

2/31/2021

AD-EG-ALL-1207

Plant Health Process for Bridging Strategy for Refurbishment

of the Siemens, Model RLN, 480V Circuit Breakers

CSD-AD-ALL-

0004-01

CORRECTIVE ACTION PROGRAM REVIEW MEETING

REVISION 7

EVT-2085-2021-

00075447

Maintenance Rule Manager Event

EVT-5145-2021-

00075253

Maintenance Rule Manager Event

EVT-5175-2021-

00075457

Maintenance Rule Manager Event

MTG-2021-

00000291