IR 05000261/2004002
| ML040970020 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/02/2004 |
| From: | Fredrickson P NRC/RGN-II/DRP/RPB4 |
| To: | Moyer J Carolina Power & Light Co |
| References | |
| IR-04-002 | |
| Download: ML040970020 (37) | |
Text
ril 2, 2004
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2004002
Dear Mr. Moyer:
On March 13, 2004, the US Nuclear Regulatory Commission (NRC) completed an inspection at your H.B. Robinson reactor facility. The enclosed integrated inspection report documents the inspection findings, which were discussed on March 17, with Mr. Chris Burton 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. Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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/
Paul E. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23
Enclosure:
Inspection Report 05000261/2004002 w/Attachment: Supplemental Information
REGION II==
Docket No: 50-261 License No: DPR-23 Report No: 05000261/2004002 Licensee: Carolina Power and Light Company Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: December 14, 2003 - March 13, 2004 Inspectors: R. Hagar, Senior Resident Inspector D. Jones, Resident Inspector K. VanDoorn, Senior Reactor Inspector (Sections 1R02 & 1R17)
M. Scott, Senior Reactor Inspector (Sections 1R02 & 1R17)
M. Maymi, Reactor Inspector (Sections 1R02 & 1R17)
D. Mas-Penaranda, Reactor Inspector (Sections 1R02 & 1R17)
Approved by: P. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000261/2004-002;12/14/2003-3/13/2004; H.B. Robinson Steam Electric Plant, Unit 2;
Routine Integrated Report.
The report covered a three-month period of inspection by resident inspectors and an announced inspection by regional reactor inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July, 2000.
No findings were identified during this inspection period.
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at full rated thermal power, and operated at full power for the entire inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R02 Evaluation of Changes, Tests or Experiments
a. Inspection Scope
The inspectors reviewed selected samples of evaluations to confirm that the licensee had appropriately considered the conditions under which changes to the facility, the Updated Final Safety Analysis Report (UFSAR), or procedures, may be made and tests conducted, without prior NRC approval. The inspectors reviewed evaluations for four changes and additional information, such as calculations, supporting analyses, the UFSAR, and drawings to confirm that the licensee had appropriately concluded that the changes could be accomplished without obtaining a license amendment. These evaluations included the only three full evaluations conducted during the inspection period and one previous evaluation referenced by a current change. The four evaluations reviewed are listed in the Attachment.
The inspectors also reviewed samples of changes such as design changes, commercial grade dedication packages, material equivalency evaluations, a procedure change, a Technical Specification (TS) Bases change, and engineering technical reviews for which the licensee had determined that evaluations were not required. The purpose of this review was to confirm that the licensees conclusions to screen out these changes were correct and consistent with 10CFR50.59. The 16 screened out changes reviewed are listed in the Attachment.
The inspectors also reviewed a recent self-assessment of the 10CFR50.59 process and selected action requests/nonconformance reports (ARs) to confirm that problems were identified at an appropriate threshold, were entered into the corrective action process, and appropriate corrective actions had been initiated.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
a. Inspection Scope
Partial System Walkdowns The inspectors performed the following four partial system walkdowns, while the indicated structures, systems, and/or components (SSCs) were out-of-service for maintenance and testing:
System Walked Down SSC Out-of-Service Date Inspected Motor-driven auxiliary Steam-driven auxiliary 12/29/03 feedwater trains A and B feedwater Residual heat removal train A Residual heat removal train B 01/14/04 Motor-driven auxiliary Motor-driven auxiliary feedwater 01/29/04 feedwater train B and steam- train A driven auxiliary feedwater Motor-driven fire pump Engine-driven fire pump 02/23/04 To evaluate the operability of the selected trains or systems under these conditions, the inspectors compared observed positions of valves, switches, and electrical power breakers to the procedures and drawings listed in the Attachment.
Complete System Walkdown The inspectors conducted a detailed review of the alignment and condition of the A train of the motor-driven auxiliary feedwater system. To determine the proper system alignment, the inspectors reviewed the procedures, drawings, and the UFSAR section listed in the Attachment.
The inspectors walked down the system to verify that the existing alignment of the system was consistent with the correct alignment. Alignment activities reviewed during the walkdown included the following:
- Valves are correctly positioned and do not exhibit leakage that would impact the functions of any given valve.
- Electrical power is available as required.
- Major system components are correctly labeled, lubricated, cooled, ventilated, etc.
- Hangers and supports are correctly installed and functional.
- Essential support systems are operational.
- Ancillary equipment or debris does not interfere with system performance.
- Tagging clearances are appropriate.
- Valves are locked as required by the licensees locked valve program.
The inspectors reviewed the documents listed in the Attachment to verify that the ability of the system to perform its functions could not be affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, and other system-related issues tracked by the engineering department.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
For the six areas identified below, the inspectors reviewed the licensees control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures, to verify that those items were consistent with UFSAR Section 9.5.1, Fire Protection System, and UFSAR Appendix 9.5.A, Fire Hazards
Analysis.
The inspectors walked down accessible portions of each area and reviewed results from related surveillance tests, to verify that conditions in these areas were consistent with descriptions of the areas in the UFSAR.
Documents reviewed are listed in the Attachment.
The following areas were inspected:
Fire Zone(s) Description Control room Service water pump area B diesel generator room 25A & 25B Turbine building ground floor Battery room 25F & G Turbine building mezzanine and operating deck
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification
a. Inspection Scope
The inspectors observed licensed-operator performance during requalification simulator training for operating crew 4, to verify that operator performance was consistent with expected operator performance, as described in Dynamic Simulator Scenario Examination DSS-044, Revision 4. This examination tested the operators ability to respond to, in part, failure of a pressurizer level instrument, a steam generator tube leak, a loss of main condenser vacuum, a steam generator tube rupture, and failure of a steam generator power-operated relief valve. The inspectors focused on clarity and formality of communication, the use of procedures, alarm response, control board manipulations, group dynamics and supervisory oversight.
The inspectors observed the post-exercise critique, to verify that the licensee had identified deficiencies and discrepancies that occurred during the simulator training.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the six degraded SSC/function performance problems or conditions listed below, to verify the licensees appropriate handling of these performance problems or conditions in accordance with 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and 10 CFR 50.65, Maintenance Rule. Documents reviewed are listed in the Attachment. The problems/conditions and their corresponding ARs were:
Performance Problem/Condition AR Safety injection pump C bearing replacement 68240 Exceeding Maintenance Rule performance criteria for the control room 79406 emergency filtration system Exceeding Maintenance Rule performance criteria for the B steam 114505 generator power operated relief valve Simultaneous loss of both channels of residual heat removal pump 108878 room sump level indication Deepwell pump A exceeded its unavailability allowance 102997 Containment fan coolers low-flow alarm received unexpectedly 116960 During the review, the inspectors focused on the following:
- Appropriate work practices,
- Identifying and addressing common cause failures,
- Scoping in accordance with 10 CFR 50.65(b),
- Characterizing reliability issues (performance),
- Charging unavailability (performance),
- Trending key parameters (condition monitoring),
- 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and
- Appropriateness of performance criteria for SSCs/functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified (a)(1).
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
For the four time periods and emergent activities listed below, the inspectors reviewed the licensees risk assessments and the risk-management actions used by the licensee to manage risk. The inspectors verified that the licensee performed adequate risk assessments and implemented appropriate risk-management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk was promptly assessed, and that appropriate risk-management actions were promptly implemented. Documents reviewed are listed in the Attachment. The inspected periods included the following:
- January 3-9, including emergent work associated with problems in the rod control system and reactor coolant loop 1 temperature instrumentation
- January 16-23, including emergent work associated with the failure of a flow transmitter on the A main steam line and repairs to the control circuit of a pressurizer power-operated relief valve
- January 31 - February 6, including planned work on the A charging pump and all three circulating-water pumps
- March 8-12, including emergent work associated with a steam-generator level transmitter, rescheduling of maintenance work on an important motor-operated valve, and rescheduling of control-rod testing
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the operability determinations in the three ARs listed below:
- AR 99903, Non-Conservative Error in the Calculation of Available Net Positive Suction Head for Emergency Core Cooling System Pumps
- AR 92762, [Component Cooling Water] Autostart Consideration During Safeguards Sequencing
- AR 89619, [Residual Heat Removal] and [Safety Injection] Pump Room Cooling Fan Motors For these ARs, the inspectors assessed the validity of the operability determinations, the use and control of any necessary compensatory measures, and compliance with the TS.
The inspectors also verified that the operability determinations were made as specified by Procedure PLP-102, "Operability Determinations." In addition, the inspectors compared the justifications provided in the operability determinations to the requirements from the TS, the UFSAR, associated design-basis documents, and other applicable documents, to verify that operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R16 Operator Work-Arounds
a. Inspection Scope
The inspectors reviewed the following two operator workarounds to verify that they did not affect either the functional capability of the related system in responding to an initiating event, or the operators ability to implement abnormal or emergency operating procedures:
Number Description 04-03 Component cooling water flow indicator from charging pump oil return is out of service 03-011 Manual operation action required to ensure temperature does not exceed non-regenerative heat exchanger outlet temperature limit The inspectors reviewed the cumulative effects of the operator workarounds listed on the RNP Unit 2 Workaround Log dated 1/08/04 to verify that those effects could not increase an initiating event frequency, affect multiple mitigating systems, or affect the ability of operators to respond in a correct and timely manner to plant transients and accidents. Documents and operator workarounds reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications
a. Inspection Scope
The inspectors evaluated design change packages for eight modifications, in the Initiating Events, Mitigating Systems, and Barrier Integrity Cornerstone areas, to evaluate the modifications for adverse affects on system availability, reliability, and functional capability. The modifications and the associated attributes reviewed are as follows:
EC 50634, NIS Power Range Channel Sensitivity Upgrade Modification (Initiating Events, Mitigating Systems)
- Conformance to design basis
- Installation documentation
- Seismic considerations
- Functional test plan and results
- Plant procedure and drawing updating
- 10CFR50.59 screen EC-50764, Change of E1/E2 Breakers Long Time Pickup Setting (Mitigating Systems)
- Accident considerations
- Licensing documents update
- 10 CFR 50.59 screen
- Energy needs EC-47546, Improve IB power source to Allow Replacement of RPS Relays (Initiating Events, Mitigating Systems)
- Accident considerations
- Seismic considerations
- Licensing documents update
- 10 CFR 50.59 screen
- Energy needs EC 45497, Target Rock Valve Replacement (Initiating Events, Mitigating Systems, Barrier Integrity)
- Code and safety classification
- Replacement components are seismically qualified
- Materials/replacement components are compatible
- Control signals appropriate
- Post-modification testing for operability and design basis
- 10 CFR 50.59 screen EC 47637, Service Water Motor Replacement (Mitigating Systems)
- Heat removal requirements
- Materials/replacement components compatible
- Pressure boundary and design basis maintained
- Structural integrity for accident/event condition
- Post-modification testing for operability and design basis
- 10 CFR 50.59 screen EC 47140, Pressurizer Heaters Cables and Connections Replacement (Mitigating Systems, Barrier Integrity)
- Post-modification testing for operability and design basis
- Pressure boundary and design basis maintained
- Materials/replacement components are compatible
- 10 CFR 50.59 screen EC 44178, EDG Pressure and Temperature Switch Allowable Tolerance Expansion to Facilitate Extended EDG Maintenance Interval (Mitigating Systems)
- Updating review
- Control signals
- Failure modes bounded by existing analysis
- 10 CFR 50.59 screen EC 44213, Valves SI-870B and RHR-750 Actuator Modification to Increase Torque/Thrust Margin Requirements (Mitigating Systems)
- Failure modes bounded by existing analysis
- Updating review
- Seismic qualification
- 10 CFR 50.59 evaluation
- Post-modification testing
- Response time Documents reviewed included procedures, engineering calculations, modifications design and implementation packages, work orders, site drawings, corrective action documents, applicable sections of the UFSAR, supporting analyses, the TS, and design basis information.
The inspectors also reviewed the Engineering organization self-assessment program and recent results and trending to confirm that a viable self-critical process was in place for Engineering organization products. The inspectors also confirmed that problems were being handled appropriately using the Corrective Action Program, if applicable.
b. Findings
No findings of significance were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the five post-maintenance tests listed below, the inspectors witnessed the test and/or reviewed the test data, to verify that test results adequately demonstrated restoration of the affected safety functions described in the UFSAR and TS. Documents reviewed are listed in the Attachment. The tests included the following:
Related Procedure Title Maintenance Activity Date Inspected OST-151-3 Safety Injection System Calibration of pump December 16 Components Test - Pump discharge pressure C indicator OST-202 Steam Driven Auxiliary Calibration of several December 29 Feedwater System instruments & routine Component Test maintenance on several valves OST-701-9 Steam Generator Air regulator filter February 3 Blowdown System replacement on two Inservice Valve Test flow-control valves OST-910 Dedicated Shutdown Diesel Semi-annual February 10 Generator (Monthly) inspection, maintenance on several related instruments OP-306 Component Cooling Water Replacement of B February 25 component cooling water pump breaker The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:
- AR 87565, [Dedicated shutdown diesel generator] failed OST-910 acceptance criteria
- AR 108662, Voltage control problem with the [dedicated shutdown diesel generator]
during OST-910
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
For the seven surveillance tests identified below, the inspectors witnessed testing and/or reviewed the test data, to verify that the SSCs involved in these tests satisfied the requirements described in the TS, the UFSAR, and applicable licensee procedures, and that the tests demonstrated that the SSCs were capable of performing their intended safety functions. Documents reviewed are listed in the Attachment.
Test Procedure Title Date Inspected OST-701-8* V12-10 and V12-11 Inservice Valve Test December 29 OST-750-2 Control Room Emergency Ventilation January 8 System - Train B (Monthly)
OST-908-1** Comprehensive Flow Test for the January 12 Component Cooling Water Pumps MST-023 Safeguard Relay Rack Train B January 21 OST-005 Nuclear Instrumentation Power Range January 30 (Power Above P-8)
MST-020 Reactor Protection Logic Train A at Power February 18 OST-102 Chemical and Volume Control System Valve March 3 Test
- This procedure included testing of a large containment isolation valve.
- This procedure included inservice testing requirements.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed the performance indicators (PIs) identified below, to verify the accuracy of the reported PI data. For each PI, the inspectors evaluated the licensees basis for reporting the data against the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2. In addition, the inspectors interviewed licensee personnel associated with the PI data collection, evaluation, and distribution. Documents reviewed are identified in the Attachment.
Mitigating Systems Cornerstone For the Safety System Functional Failures PI, the inspectors reviewed licensee event reports, records of inoperable equipment, and Maintenance Rule records, to verify that the licensee had adequately accounted for the functional failures experienced in safety systems during the period from January, 2003 through December, 2003.
Barrier Integrity Cornerstone
- Reactor Coolant System Specific Activity
- Reactor Coolant System Leakage For the Reactor Coolant System (RCS) Specific Activity PI, the inspectors observed licensee sampling and analysis of reactor coolant system samples, and compared the licensee-reported performance indicator data with records developed by the licensee while analyzing previous samples, for the period from January, 2003 through December, 2003.
For the Reactor Coolant System Leak Rate Performance Indicator, the inspectors observed the performance of an RCS leakage evaluation and reviewed records of daily measures of RCS identified leakage, for the period from January, 2003 through December, 2003.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
Annual Sample Review
a. Inspection Scope
The inspectors conducted in-depth reviews of the ARs identified below:
- AR 89711, 20MW load reduction due to spurious turbine runback on April 5, 2003
- AR 105199, [self assessment] 77701 Issue 2 - Equipment Reliability The inspectors selected these ARs because AR 89711 relates specifically to the Initiating Events Cornerstone, and AR 105199 relates generally to the Mitigating Systems Cornerstone. Both were classified by the licensee as significant conditions adverse to quality.
The inspectors reviewed these reports to verify:
- complete and accurate identification of the problem in a timely manner;
- evaluation and disposition of performance issues;
- evaluation and disposition of operability and reportability issues;
- consideration of extent of condition, generic implications, common cause, and previous occurrences;
- appropriate classification and prioritization of the problem;
- identification of root and contributing causes of the problem;
- identification of corrective actions which were appropriately focused to correct the problem; and
- completion of corrective actions in a timely manner.
The inspectors also verified licensee compliance with the requirements of the licensees Corrective Action Program as described in Corporate Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings of significance were identified. However, during the review of AR 105199, the inspectors noted that not all corrective actions were appropriately focused to correct the problem. The inspectors noted that the investigation determined that the site prioritization process did not include some important activities associated with major projects and long-standing equipment concerns, and that two of the associated corrective actions implemented changes in the way the site prioritizes those activities.
However, these changes were implemented through private discussions, group meetings, and changes to informal charters, and not through changing any controlled document. Because these changes were not incorporated into a controlled document, the corrective actions are less likely to remain effective over time than if they had been incorporated into a controlled document.
4OA6 Meetings, Including Exit
An interim exit was conducted on January 30, 2004 to discuss the findings of the modifications/10CFR50.59 region based inspection. One proprietary document was reviewed but not retained by the inspector.
On March 17, 2004, the resident inspectors presented the integrated inspection results to Mr. Chris Burton and other members of his staff. The inspectors confirmed that proprietary information was not retained by the inspector.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- J. Adams, Supervisor, On-Line Scheduling
- M. Arnold, Superintendent, Shift Operations
- C. Baucom, Supervisor, Regulatory Support
- C. Burton, Director of Site Operations
- E. Caba, Superintendent, Design Engineering
- G. Cheatham, Radiation Protection Superintendent
- C. Church, Engineering Manager
- B. Clark, Manager - Training
- T. Cleary, Plant General Manager
- W. Farmer, Superintendent, Systems Engineering
- R. Howell, Supervisor, Emergency Preparedness
- T. Hubbard, Supervisor, Electrical/I&C Maintenance
- R. Ivey, Operations Manager
- E. Kapopoulos, Outage Management Manager
- V. Leeth, Work Week Manager
- J. Lucas, Manager, Support Services - Nuclear
- J. Stanley, Superintendent, Technical Services
- D. Stoddard, Maintenance Manager
- J. Thompson, Work Week Manager
- T. Tovar, Manager, Shift Operations
NRC personnel
- P. Fredrickson, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None