IR 05000261/2004007

IR 05000261-04-007, on 10/04/2004 - 10/08/2004 & 10/18/2004 - 10/22/2004, Carolina Power & Light Co, H. B. Robinson Steam Electric Plant Unit 2; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML043240447
Person / Time
Site:	Robinson
Issue date:	11/19/2004
From:	Fredrickson P NRC/RGN-II/DRP/RPB4
To:	Moyer J Carolina Power & Light Co
References
IR-04-007
Download: ML043240447 (21)

Text

November 19, 2004

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000261/2004007

Dear Mr. Moyer:

On October 22, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at the H. B. Robinson Steam Electric Plant Unit 2. The enclosed report documents the inspection findings, which were discussed on October 22, 2004, with you and other members of your staff during an exit meeting.

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

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the corrective action program. However, during the inspection, several examples of minor problems were identified, including conditions adverse to quality that were not identified for entry into the corrective action program, errors in performing cause evaluations, and corrective actions that were ineffectively tracked or had not occurred.

CP&L

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 Fredrickson Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23 cc w/encl: (See page 3)

CP&L

cc w/encl:

William G. Noll Director, Site Operations Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail Distribution Daniel G. Stoddard Plant General Manager Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail Distribution Chris L. Burton, Manager Performance Evaluation and Regulatory Affairs CPB 9 Electronic Mail Distribution C. T. Baucom, Supervisor Licensing/Regulatory Programs Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail Distribution J. F. Lucas, Manager Support Services - Nuclear Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail Distribution Henry J. Porter, Director Div. of Radioactive Waste Mgmt.

Dept. of Health and Environmental Control Electronic Mail Distribution R. Mike Gandy Division of Radioactive Waste Mgmt.

S. C. Department of Health and Environmental Control Electronic Mail Distribution Beverly Hall, Acting Director Division of Radiation Protection N. C. Department of Environment, Health and Natural Resources Electronic Mail Distribution Steven R. Carr Associate General Counsel - Legal Dept.

Progress Energy Service Company, LLC Electronic Mail Distribution John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128 Peggy Force Assistant Attorney General State of North Carolina Electronic Mail Distribution Chairman of the North Carolina Utilities Commission c/o Sam Watson, Staff Attorney Electronic Mail Distribution Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326 Public Service Commission State of South Carolina P. O. Box 11649 Columbia, SC 29211 Distribution w/encl: (See page 4)

CP&L

Distribution w/encl:

C. Patel, NRR RIDSNRRDIPMLIPB PUBLIC OFFICE DRP/RII DRP/RII DRS/RII SIGNATURE GTM EMD DAJ NAME GMacDonald:as E DiPaolo D Jones DATE 11/18/2004 11/18/2004 11/18/2004 E-MAIL COPY?

YES NO YES NO YES NO PUBLIC DOCUMENT YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: E:\\Filenet\\ML043240447.wpd

Enclosure U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No:

50-261 License No:

DPR-23 Report No:

05000261/2004007 Licensee:

Carolina Power & Light (CP&L)

Facility:

H. B. Robinson Steam Electric Plant, Unit 2 Location:

3581 West Entrance Road Hartsville, SC 29550 Dates:

October 4 - 8, 2004 (Week 1)

October 18 - 22, 2004 (Week 2)

Inspectors:

E. DiPaolo, Senior Resident Inspector, Brunswick (Lead Inspector)

G. MacDonald, Senior Project Engineer D. Jones, Resident Inspector Approved by:

Paul Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure

SUMMARY

OF ISSUES

IR 05000261/2004007; Carolina Power & Light Company; on 10/4/2004 - 10/22/2004; H. B.

Robinson Steam Electric Plant Unit 2; Biennial baseline inspection of the identification and resolution of problems.

The inspection was conducted by a senior resident inspector, a resident inspector, and a senior project engineer. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The licensee was effective at identifying problems at a low threshold and entering them into the Corrective Action Program (CAP). Managements involvement in the review of issues documented in the program was timely and appropriate. Self-assessments and audits of the CAP, and trend reviews were critical, thorough, and effective in identifying program deficiencies. Although not reflective of the general assessment into licensee problem identification, the inspectors identified a case where equipment deficiencies in a plant area were not being appropriately identified.

Prioritization and evaluation of problems in the CAP were effective. The technical adequacy and depth of evaluations, proposed corrective actions and timeliness were in a manner commensurate with the safety significance of the issue. The inspectors identified noteworthy deficiencies associated with five cause determinations. Although the inspector-identified discrepancies indicated some problems in the evaluation of issues, overall, this area of the program was considered effective. The licensee had identified the sites evaluation of issues as an area of program focus.

The CAP was effective in correcting problems consistent with the importance to safety of the issues. Effective management involvement in the process was evident. Outstanding corrective actions were tracked and delays in the implementation of corrective actions received the appropriate level of management attention. During the course of the inspection, the inspectors identified isolated problems with the implementation of corrective actions. However, these issues did not affect the overall assessment of corrective action implementation.

Individuals actively utilized the CAP and employee concerns program (ECP). Issues entered into the ECP received the appropriate level of management involvement. Management demonstrated sensitivity to organizational attitude toward the CAP and a safety conscious work environment. Based on discussions conducted with licensee employees and a review of station activities, site personnel felt free to report safety concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Effectiveness of Problem Identification

(1) Inspection Scope The inspectors reviewed action requests (ARs) selected across the seven cornerstones of safety listed in the Attachment to verify that problems being properly identified, appropriately characterized, and entered into the Corrective Action Program (CAP). The inspectors reviewed program documents which described the administrative process for documenting and resolving issues. For the assessment of the CAP, the inspectors focused on several risk significant systems which included the emergency diesel generators, component cooling water system, safety injection system, residual heat removal system, and nuclear service water system.

The inspectors reviewed a sampling of ARs that had been generated since the last problem identification and resolution inspection (August 2002).

The inspectors reviewed plant equipment issues associated with Maintenance Rule (a)(1) items, functional failures, maintenance preventable functional failures (MPFF),repetitive MPFFs, and system health reports associated with the focus systems to verify that problems were being identified. Plant walkdowns of the focus systems were performed to verify that no evident material condition problems existed that were not already identified.

During the inspection, the inspectors reviewed operator logs, operator turnover sheets, control room deficiency lists, temporary modification lists, and performed control room walkdowns to verify that equipment issues were entered into the CAP at an appropriate level. Issues identified in lower tier corrective action programs (e.g., plant observation program) were reviewed to verify that they were appropriately addressed. Industry operating experience (10CFR21 notices and NRC information notices) items were reviewed to verify that applicable issues were appropriately evaluated and addressed.

The inspectors audited several of the licensees Management Review Team Meetings, CAP Unit Evaluator Meetings, Plan-of-the-Day Meetings, and an Engineering CAP Rollup Meeting to determine the level of management involvement into issues and problems. This was also performed to gauge the effectiveness of the screening process in ensuring that problems were properly entered into the CAP.

The inspectors reviewed several self-assessments and audits of the CAP to verify that findings were being entered into the CAP and that appropriate corrective action was taken to resolve program deficiencies. Program trend reports and statistics were reviewed to verify that indicated trends were entered into the CAP at the appropriate level.

(2) Assessment No findings of significance were identified. Based on the sample selected, the inspectors determined that the licensee was identifying problems and entering them into the CAP at a very low threshold. Problems identified through industry experiences were properly addressed. The inspectors observed appropriate and timely management involvement in the review of the issues documented in the program.

Self-assessments, audits of the CAP, and trend reviews were critical, thorough, and effective in identifying deficiencies in the CAP. These deficiencies were routinely entered into the CAP and corrective actions were implemented.

Although not reflective of the general assessment of licensee problem identification, the inspectors identified a case where equipment deficiencies were not being appropriately identified. During walkdowns of nuclear service water structure underground power cable manholes, the inspectors identified conditions (e.g.,

accumulation of silt that clogged a drainage pipe, sump pump deficiencies, etc.) that affected proper drainage of water from the manholes. These conditions indicated improper preventive maintenance activities of these areas. Additionally, the condition of silt that resulted in a clogged drainage pipe had been previously identified during an NRC inspection for license renewal in May 2003. AR 94315 was generated at that time as a result of the observation. However, actions identified by the AR did not correct the condition. The licensee determined that inspection of nuclear service water structure power cable manholes were not contained in the preventive maintenance program and entered this issue into the CAP (AR 140998140998.

Additionally, the licensee generated AR 141982141982to address the lack of organizational ownership of the area or a program to inspect and maintain the manholes.

b.

Prioritization and Evaluation of Issues

(1) Inspection Scope The inspectors reviewed ARs listed in the Attachment to verify that the issues were properly prioritized and the cause evaluated in accordance with the procedural requirements of the CAP. The review included issues associated with previously identified violations of NRC requirements. The inspectors reviewed cause evaluations to verify that the evaluation was commensurate with the safety significance of the issue, and that the evaluation addressed operability, reportability, common cause, generic concerns, and extent of condition, where appropriate. For significant conditions adverse to quality, the inspectors checked that the licensee adequately identified the causes and corrective actions to prevent recurrence.

Documents reviewed are listed in the Attachment.

(2) Assessment No findings of significance were identified. In general, the licensees prioritization and evaluation of problems in the CAP were considered effective. The technical adequacy and depth of evaluations, as documented in individual ARs, were acceptable. The inspectors found that the licensee properly prioritized proposed corrective actions in a manner commensurate with the safety significance of the issue. Based on the total number of ARs reviewed during the inspection, the inspectors concluded that the licensees CAP was generally being effectively implemented with respect to evaluation of problems. However, the inspectors identified several deficiencies associated with individual cause determinations as shown below:

• Priority 2 ARs 75691 and 75489 were written for a test failure of safety injection (SI) system relief valve SI-871. The valve lifted with pressure marginally higher than allowable but had a significantly lower reseat pressure than design. The evaluation of the affect on system operability of the valves test failure did not address the affect of the low reseat pressure on past operability of the SI system. The relief valve protects the common SI and containment spray (CS)suction piping from overpressure. Highest system pressure would most likely occur during piggyback operation when the residual heat removal (RHR) pump provides flow to the CS/SI suction header. The valve relieves to the CS discharge header. The inspectors concluded that the affect on the SI system would be a potential loss of SI suction inventory to containment which would not be significant in piggyback mode when the sump was the suction supply.

• The licensee identified an increase in relief valve test failures before and during refueling outage (RO) 21. ARs were written to evaluate and fix the valve test failures. AR 74421 was written to investigate the trend of relief valve test failures, but this AR did not identify any corrective action other than to repair and retest the individual valves and expand the test scope as necessary.

There were additional activities identified which could impact relief valve performance, however they were all identified as enhancements not as corrective actions.

• A root cause evaluation associated with an inattentive employee documented in AR 61013 was not of sufficient depth to determine the actual root cause.

However, effective corrective actions were implemented to address the actual cause. The licensee indicated that root cause evaluations performed by the site organization which performed the evaluation had previously been identified as an area of weakness. The licensee had focused on improvements in the quality of root cause evaluation by the organization.

• A self-assessment of the motor monitoring program in 2000 identified a weakness that a minimum acceptance criterion for degraded direct-burial cables was not well established. This weakness in the program required motor cable determination to discern if the motor or the cable was degraded. The corrective actions of AR 26298, written as a result of the self-assessment, only addressed improvements in the motor monitoring program. No corrective actions were established to address the weakness of the degraded condition of the site direct-burial power cables or power cable acceptance criteria not being well established. The licensee determined that the corrective actions of AR 26298 were insufficient and generated AR 141988141988to evaluate the condition of the cables for acceptability.

• The root cause evaluation, as documented in AR 133713133713 associated with a failure of a Westinghouse Type BF66 Relay identified a manufacturing defect as the cause. This type relay is used throughout the reactor protection system.

The corrective action to prevent recurrence was limited to the replacement of 10 relays obtained within the same purchase order. The evaluation did not address approximately 300 installed relays which were constructed utilizing the same manufacturing techniques as the failed relay and, therefore, subject to the same type of manufacturing defect. Subsequently, information was provided by Westinghouse indicating that the relay failure may be isolated and not caused by a manufacturing defect. At the end of the inspection, the licensee was continuing to evaluate this issue.

Although the inspector-identified discrepancies indicated some problems in the evaluation of issues, overall, this area of the program was considered effective based on the number of ARs reviewed. The inspectors noted that the licensee had identified the sites evaluation of issues as an area of program focus.

c.

Effectiveness of Corrective Actions

(1) Inspection Scope The inspectors reviewed corrective actions to verify that the licensee had identified and implemented corrective actions associated with identified causes for the ARs listed in the Attachment. The timeliness of the corrective actions were reviewed to assess whether they were implemented or planned consistent with the importance to safety of the issues. The inspectors reviewed maintenance rework items, Maintenance Rule functional failures for focus systems, select canceled modifications, and select items from the operator workarounds list to verify that no inconsistencies existed with prior established corrective actions for issues. The inspectors verified that common causes and generic concerns were addressed where appropriate. The review included a sample of the oldest open ARs in the licensees database to verify that the planned dates for implementing corrective actions were justified and reasonable. Licensee followup of corrective action effectiveness associated with Priority 1 (significant condition adverse to quality) ARs was reviewed to verify appropriateness of the reviews. The inspectors also reviewed and assessed the adequacy of corrective actions associated with non-cited violations (NCVs) of regulatory requirements identified since the last problem identification and resolution inspection (August 2002).

(2) Assessment No findings of significance were identified. The inspectors determined that the licensees CAP was effective in correcting problems. Management involvement in the process was effective. The inspectors found that the age of outstanding corrective actions were tracked, the bases for delays in the implementation of corrective actions received the appropriate level of management attention, and that the delays were reasonable. Corrective actions for NCVs were determined to be adequate. During the course of the inspection, the inspectors identified some problems with the implementation of corrective actions as discussed below:

• AR 127517127517documented that a manufacturer-installed cylinder plug, which is a component of the indicator valve adapter, was left loose when installed on the B EDG. During the performance of a surveillance test, the plug was discharged while the engine was running. The inspectors identified that corrective actions to verify tightness of the manufacturer installed plugs following indicator valve adapter replacements were not implemented. AR 139413139413was written to revise the preventive maintenance procedure.

• AR 92949 evaluated two cases where relief valves lifted and failed to reseat as designed. One corrective action item was to revise relief valve nozzle and guide ring setting procedures to incorporate independent verification into the relief valve settings. Procedure CM-102 was revised to incorporate independent verification of the correct direction of rotation while setting the relief valve, but the revision did not incorporate independent verification of the final notch settings.

• AR 30516 was written to address conduit damage caused by gaps in pressurizer insulation. The effectiveness review of corrective actions associated with this AR was completed without corrective action to prevent recurrence being complete. The temporary insulation was still in place on the pressurizer, the mirror insulation had not yet been replaced with the Nukon blanket insulation. AR 140654140654was generated for resolution.

• AR 124697124697was written for incorrect piping utilized when implementing the CS/SI full flow test line modification. The incorrect pipe was replaced with the correct material. The AR identified two inappropriate acts which led to the use of the incorrect material. These were incorrect material reserved by the planner and failure by the craft to verify the material against the work package prior to installation. Corrective action only addressed the craft aspect through counseling and a stand-down to reestablish material verification standards. No corrective action was included to address the planning aspect of the failure.

• During maintenance of a nuclear service water valve motor-operator in 2002, megger readings as measured from the breaker, were less than established acceptance criteria. Subsequently, acceptable motor resistance readings were taken locally with the power cables determinated with satisfactory results. The investigation determined that the cause of the failure was due to buried cable moisture intrusion due to cable aging. Established criteria specified that the cables should have been replaced. However, the inspectors identified that no corrective action was pursued to correct or evaluate the degradation of the cable. Although direct buried cable insulation degradation is a known site problem, the issue has not been entered into the CAP. The site recognized that replacement of the cables will be a necessity to the long term continued operation of the plant. At the completion of the inspection, the site budget plan included replacement of the cables which was planned to commence in 2006.

Based on the plan to replace the cables, no violation of regulatory requirements was identified. AR 140969140969was initiated to develop a preventative maintenance process to ensure that cables are properly evaluated when disconnected from motors. The licensee also initiated AR 141988141988due to the failure of a previous evaluation (AR 26298) to establish acceptance criteria for cables when megger readings are less than the established acceptance criteria.

Although there were problems in implementing corrective actions as noted above, the inspectors determined that, overall, corrective actions were timely and effective consistent with the importance to safety of the issues based on the sample reviewed.

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope The inspectors questioned licensee personnel during interviews concerning their experience with the CAP to assess whether there were impediments to the establishment of a safety conscious work environment. Specifically, personnel were asked questions regarding any reluctance to initiate ARs and the adequacy of corrective action for identified issues. The inspectors interviewed the licensees Employee Concerns Program (ECP) representative to assess the adequacy of procedural control, tracking of concerns, and trending of issues. Several ECP issues and evaluations were reviewed with respect to maintaining and promoting a safety conscious work environment and to verify that issues affecting nuclear safety were being appropriately addressed. The inspectors assessed licensee management sensitivity to a safety-conscious work environment through inspection activities, discussions with management and licensee personnel, and attendance at various meetings. The inspectors interviewed several managers, attended several meetings, and reviewed several applicable corrective action documents to assess licensee management sensitivity to a safety conscious work environment.

Documents reviewed are listed in the Attachment.

(2) Assessment No findings of significance were identified. Individuals actively utilized the CAP and ECP as evidenced by the low threshold of issues entered into the programs. Issues entered into the ECP received the appropriate level of management involvement.

When issues became evident through either the ECP or CAP assessments, site management demonstrated sensitivity to organizational attitudes toward the CAP and a safety conscious work environment. In particular, CAP Assessment 76934 identified an assessment weakness that workers attitude toward the CAP had declined. The associated investigation, documented in AR 90592, was thorough and identified corrective actions to raise site personnel sensitivity in this area.

Additionally, an employee concern related to group dynamics and site culture was appropriately raised to senior management and properly investigated. The inspectors determined that a safety conscious work environment was evident at the site.

40A6 Meetings, Including Exit On October 22, 2004, the inspectors presented the inspection results to Mr. John Moyer and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

A. Cheatham, Radiation Protection Superintendent

C. Church, Engineering Manager

B. Clark, Manager - Nuclear Assessment Section

J. Huegel, Maintenance Manager

G Ludlam, Training Manager

D. Martrano, Performance Evaluation Section

W. Noll, Director of Site Operations

D. Stoddard, Plant General Manager

S. Wheeler, Lead Self Evaluation Specialist

D. Winters, Supervisor Plant Support Group

T. Lee, Employee Concerns

NRC personnel

P. Fredrickson, Chief, Reactor Projects Branch 4

L. Wert, Deputy Director, Division of Reactor Projects

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None.