IR 05000261/2005002
| ML051180305 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/28/2005 |
| From: | Fredrickson P NRC/RGN-II/DRP/RPB4 |
| To: | Moyer J Carolina Power & Light Co |
| References | |
| IR-05-002 | |
| Download: ML051180305 (35) | |
Text
April 28, 2005
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2005002
Dear Mr. Moyer:
On March 31, 2005, 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 April 13 with Mr. Bill Noll 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. On the basis of 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.:
Enclosure:
Inspection Report 05000261/2005002 w/Attachment: Supplemental Information
REGION II==
Docket No:
50-261 License No:
DPR-23 Report No:
05000261/2005002 Licensee:
Carolina Power & Light (CP&L)
Facility:
H. B. Robinson Steam Electric Plant, Unit 2 Location:
3581 West Entrance Road Hartsville, SC 29550 Dates:
January 1, 2005 - March 31, 2005 Inspectors:
R. Hagar, Senior Resident Inspector D. Jones, Resident Inspector G. Laska, Senior Operations Engineer (Section 1R11)
M. Bates, Operations Engineer (Section 1R11)
F. Wright, Senior Health Physicist (Section 2PS3)
R. Hamilton, Health Physicist (Sections 2OS3, 2PS1 and 4OA1)
Approved by:
P. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000261/2005-002; 01/01/2005-03/31/2005; H.B. Robinson Steam Electric Plant, Unit 2;
Routine Integrated Report.
The report covered a three month period of inspection by resident inspectors and announced inspections by regional operations engineers and health physicists. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
None B.
Licensee-identified Violations None
REPORT DETAILS
Summary of Plant Status The unit began the inspection period at full rated thermal power. On March 5, power was reduced to approximately 52 percent of full power to enable turbine valve testing and corrective maintenance on several components in secondary plant systems and the plant switchyard. The plant was returned to full power on March 6 and operated at full power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
==1R04 Equipment Alignment
a. Inspection Scope
Partial System Walkdowns:==
The inspectors performed the following three 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 Residual heat removal train B Residual heat removal train A January 27 Motor-driven auxiliary feedwater train A Motor-driven auxiliary feedwater train B January 31 Emergency diesel generator A Emergency diesel generator B March 2 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 B emergency diesel generator to verify that the existing alignment of the system was consistent with the correct alignment. To determine the correct system alignment, the inspectors reviewed the procedures, drawings, and the Updated Final Analysis Report (UFSAR) section listed in the Attachment. The inspectors also walked down the system.
During the walkdown, the inspectors reviewed the following:
- Valves were correctly positioned and did not exhibit leakage that would impact the functions of any given valve.
- Electrical power was available as required.
- Major system components were correctly labeled, lubricated, cooled, ventilated, etc.
- Hangers and supports were correctly installed and functional.
- Essential support systems were operational.
- Ancillary equipment or debris did not interfere with system performance.
- Tagging clearances were appropriate.
- Valves were locked as required by the licensees locked valve program.
- Breakers were correctly positioned.
- Cabinets, cable trays, and conduits were correctly installed and functional.
- Visible cabling appeared to be in good material condition.
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.
The inspectors reviewed the following action requests (ARs) associated with this area, to verify that the licensee identified and implemented appropriate corrective actions:
- AR 149258149258 DG-38B Found Out of Position During Rounds
- AR 96751, D [Instrument Air Compressor] Found Open Before Swapping
[Instrument Air Compressor]
b. Findings
No findings of significance were identified.
==1R05 Fire Protection
a. Inspection Scope
==
For the seven 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 Description 25F & 25G Turbine Building East/West Mezzanine and Operating Deck 25D Dedicated Shutdown Diesel Generator 9 & 10 North and South Cable Vault Station Battery Room
Diesel Generator A Room Yard Transformers E-1/E-2 Electrical Switchgear Room Also, to evaluate the readiness of the licensees personnel to prevent and fight fires, the inspectors observed fire brigade performance during the announced fire drill in the turbine building on February 7. The drill simulated an oil fire near the main turbine seal oil equipment.
b. Findings
No findings of significance were identified.
==1R11 Licensed Operator Requalification Biennial Review
a. Inspection Scope
==
During the week of February 14-18, 2005, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of simulator operating tests and job performance measures (JPMs) associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the licensee in implementing requalification requirements identified in 10 CFR 55, Operators Licenses. Evaluations were also performed to verify that the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure 71111.11, Licensed Operator Requalification Program. The inspectors also reviewed and evaluated the adequacy of the licensees simulation facility for use in operator licensing examinations. The inspectors observed two crews during the performance of the operating tests. Documentation reviewed included written examinations, JPMs, simulator scenarios, licensee procedures, on-shift records, licensed operator qualification records, watchstanding and medical records, simulator modification request records, performance test records, the feedback process, and remediation plans. The records were inspected against the criteria listed in Inspection Procedure 71111.11. Documents reviewed during the inspection are listed in the Attachment.
b. Findings
No findings of significance were identified.
Annual Review
a. Inspection Scope
On February 24, 2005, the licensee completed the comprehensive requalification biennial written examinations and annual operating tests, required to be given to all licensed operators by 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of the written examinations, individual operating tests, and the crew simulator operating tests. These results were compared to the thresholds established in NRC Inspection Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process.
b. Findings
No findings of significance were identified.
Quarterly Review
a. Inspection Scope
The inspectors observed licensed-operator performance during requalification simulator training for crew 5 to verify that operator performance was consistent with expected performance, as described in Dynamic Simulator Scenario Examination, DSS-016, Rev.
8. This training tested the operators ability to respond, in part, to the loss of the start-up
transformer, a reactor trip due to low frequency on the grid, and loss of all alternating current power. The inspectors focused on clarity and formality of communication, the use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. Documents reviewed are listed in the Attachment.
The inspectors observed the post-exercise critique to verify that the licensee 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 three 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 Auxiliary feedwater system relief valve AFW-13 failed to lift within the set pressure range 144512 The on/off indication for charging pump A was lost 139668 Steam driven auxiliary feedwater pump valve MS-V1-8C failed to fully open after breaker maintenance 137028 During the reviews, 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 five time periods and/or emergent activities listed below, the inspectors reviewed the licensees risk assessments and the risk-management actions used by the licensee to manage risk to verify that the licensee performed adequate risk assessments and implemented appropriate risk-management actions when required by 10CFR50.65(a)(4). For emergent work, the inspectors review was also to verify that any increase in risk was promptly assessed, and that appropriate risk-management actions were promptly implemented. Those periods included the following:
- the work week from January 29 - February 4, including emergent maintenance on switchyard breakers and troubleshooting on control rod control components
- the routine work week from February 19 - February 25
- the work week from February 26 - March 4, which included an extended outage of the B emergency diesel generator
- the work week from March 5 - March 11, which included a planned downpower to enable turbine valve testing and maintenance on switchyard transformers and a main circulating pump
- the work week from March 21 - March 25, which included emergent testing of a recently-installed deepwell pump
b. Findings
No findings of significance were identified.
==1R14 Personnel Performance During Nonroutine Plant Evolutions
a. Inspection Scope
==
During the two non-routine evolutions identified below, the inspectors observed plant instruments and operator performance to verify that the operators performed in accordance with the associated procedures and training:
- The downpower from 100% to 52% on March 5, to enable turbine valve testing and corrective maintenance on several components in secondary plant systems and the plant switchyard.
- The return to 100% power on March 6, following completion of the scheduled work.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
==1R15 Operability Evaluations
a. Inspection Scope
==
The inspectors reviewed Inservice Testing Performance Evaluation 05-06, Evaluate Stroke-time Deviations in a Containment Isolation Valve. The inspectors assessed the accuracy of this evaluation, the use and control of any necessary compensatory measures, and compliance with the Technical Specifications (TS). The inspectors reviewed this evaluation to verify that it was completed in accordance with Procedure TMM-004, Inservice Testing Program. The inspectors compared the justifications provided in this evaluation to the requirements in the TS, the UFSAR, and associated design-basis documents, to verify that operability was properly justified and the subject component or system remained available, such that no unrecognized increase in risk occurred.
b. Findings
No findings of significance were identified.
==1R16 Operator Work-Arounds
a. Inspection Scope
==
The inspectors reviewed the two operator workarounds identified below, 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.
- Workaround 04-18, Postulated Fire in Zone 19 or 20
- Workaround 04-14, Spurious [Reactor Coolant Pump] Thermal Barrier Low Flow Alarm Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
==1R17 Permanent Plant Modifications
a. Inspection Scope
==
The inspectors reviewed the modification described in Engineering Change 59037, Install Deepwell Pump D, to verify that:
- this modification did not degrade the design bases, licensing bases, and performance capabilities of risk significant SSCs,
- implementing this modification did not place the plant in an unsafe condition, and
- the design, implementation, and testing of this modification satisfied the requirements of Procedure EGR-NGGC-005, Engineering Change, and 10CFR50.
Appendix B, Criterion III, Design Control.
Documents reviewed are listed in the Attachment.
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 following tests were inspected:
Test Procedure Title Related Maintenance Activity Date Inspected OST-302-1 Service Water Pumps A and B Inservice Test Service water pump A motor replacement January 26 OST-202 Steam Drive Auxiliary Feedwater System Component Test Calibrate pressure gauge and troubleshoot steam leak February 21 OP-604 Diesel Generators A and B On emergency diesel generator B, connect piping to the jacket water cooler, calibrate pressure gauges, and replace a generator bearing insulation ring March 2 OST-252-1 Residual Heat Removal Pump B and Components Test Repair a service-water leak in the room cooler associated with residual heat removal pump B March 9 OST-401-1
[Emergency Diesel Generator] A Slow Speed Start On emergency diesel generator A, connect piping to the jacket water cooler and perform other maintenance March 16
b. Findings
No findings of significance were identified.
==1R22 Surveillance Testing
a. Inspection Scope
==
For the five surveillance tests identified below, the inspectors witnessed testing and/or reviewed the test data, to verify that the systems, structures, and components 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-201-1**
[Motor Driven Auxiliary Feedwater] System Component Test - Train A January 3 OST-401-2
[Emergency Diesel Generator] B Slow Speed Start January 4 SP-1516 Adjustment of [safety injection pump full flow test flow control] Valve SI-958 January 12 OST-701-5*
Reactor Coolant System Inservice Valve Test January 31 OST-101-1
[Chemical & Volume Control System]
Component Test Charging Pump A February 7
- This procedure included testing of a containment isolation valve.
- This procedure included inservice testing requirements.
The inspectors also reviewed AR 120414120414 Equipment Unavailability Associated with Surveillance Testing, to verify that the licensee identified and implemented appropriate corrective actions.
b. Findings
No findings of significance were identified.
==1R23 Temporary Plant Modifications
a. Inspection Scope
==
The inspectors reviewed the two temporary modifications described in the Engineering Changes (ECs) listed below to verify that the modifications did not affect the safety functions of important safety systems, and to verify that the modifications satisfied the requirements of 10CFR50, Appendix B, Criterion III, Design Control.
- EC 58495, HVH-7B Room Cooler Temporary Repair
- EC 60066, Disable APP-001-D1 [Reactor Coolant Pump] Thermal Barrier Low Flow Alarm Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
On March 22, the inspectors observed an emergency preparedness drill to verify licensee self-assessment of classification, notification, and protective action recommendation development in accordance with 10CFR50, Appendix E. The inspectors also attended the post-drill critique to verify that the licensee properly identified failures in classification, notification and protective action recommendation development activities. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety and Public Radiation Safety 2OS3 Radiation Monitoring Instrumentation and Protective Equipment
a. Inspection Scope
Area Radiation Monitoring and Post-Accident Sampling Systems The operability, availability, and reliability of selected direct area radiation monitors (ARM) and continuous air monitoring equipment used for routine and accident monitoring activities were reviewed and evaluated. The inspectors directly observed ARM equipment material condition, installed configurations (where accessible), and reviewed results of performance checks for selected monitors. Procedurally established alarm set-points were corroborated and performance check details were reviewed for selected ARM equipment. Current calibration data for selected radiation monitoring equipment listed in the Attachment were reviewed and discussed with responsible staff.
The inspectors evaluated Post Accident Sampling System (PASS) program activities.
The evaluation included observation of the material condition of PASS equipment/instrumentation, and discussions with licensee staff concerning current PASS sampling procedures.
Program guidance, performance activities, and equipment material condition for the direct radiation detection instrumentation and continuous air sampling equipment were reviewed against 10 CFR Part 20; 10 CFR 50, Appendix A, Criterion 60 and 64; UFSAR Section 12; and associated procedures. Radiation detection and sampling equipment required for use in accident monitoring also was reviewed against applicable sections of NUREG 0737, Clarification of TMI Action Plan Requirements, and RG 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision (Rev.) 3. Licensee guidance documents, records, and data reviewed within this inspection area are listed in the Attachment.
Personnel Survey Instrumentation Current program guidance, including calibration and operation procedures, and its implementation to maintain operability and accuracy of selected portable survey instruments, was reviewed and evaluated. Responsible staffs knowledge and proficiency regarding on-site instrumentation calibration activities were evaluated through observations, interviews, and record reviews. The inspectors interviewed a health physics (HP) supervisor regarding the licensees program for the use of electronic dosimeter (ED) equipment. The inspectors reviewed current calibration data for selected personnel survey instruments and assessed operability of various portable survey instruments staged or in use by the HP staff. The inspectors reviewed the calibrations for an Eberline teletector serial number (S/N) 37376 and an SAIC portable air sampler S/N 777037 that were used by health physics technicians (HPTs) providing job coverage of the spent fuel pool skimmer system filter change out.
The operability and sensitivity of the licensees small article monitor (SAM), personnel contamination monitor (PCM), and portal monitor (PM) equipment were reviewed and evaluated. The SAM, PCM and PM detectors that were reviewed included equipment staged at the RCA exit point. For selected SAM, PCM, and PM equipment, current calibration and recent operational/performance test surveillance data, as applicable, were evaluated. Inspectors also observed licensee staff performing monthly radiation response checks on selected equipment, and reviewed these checks against applicable procedures.
Licensee activities associated with personnel radiation monitoring instrumentation were reviewed against UFSAR Section 12, 10 CFR 20.1204 and 20.1501, and applicable licensee procedures listed in the Attachment.
Respiratory Protection - Self-Contained Breathing Apparatus (SCBA) The licensees respiratory protection program guidance and its implementation for SCBA equipment were evaluated. The number of staged SCBA units, including spare bottles, and their general material and operating condition were observed during tours of the control room, the operations support center, and the turbine building. The inspectors reviewed and evaluated current records associated with supplied air quality and maintenance of staged SCBA equipment. Proficiency and knowledge of staff responsible for maintaining SCBA equipment were evaluated through discussions and demonstration of an SCBA monthly functional test on selected units. The inspectors reviewed records of the training status for SCBA qualified individuals and observed storage and availability of prescription lens inserts for control room staff. The licensees capability for refilling and transporting air bottles to and from the control room during emergency situations was also discussed with cognizant licensee personnel.
Licensee activities associated with maintenance and use of SCBA equipment were reviewed against 10 CFR Part 20.1703; UFSAR Section 12; RG 8.15, Acceptable Programs for Respiratory Protection, Rev. 1; ANSI-Z88.2-1992, American National Standard Practices for Respiratory Protection; and applicable procedures as listed in the
.
Problem Identification and Resolution The inspectors reviewed internal assessments of Radiation Protection (RP) activities, focusing on findings related to area radiation monitoring equipment, portable radiation detection instrumentation, and respiratory protection program activities. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues. Specific corrective action program documents reviewed and evaluated are listed in the Attachment. Reviews of internal exposures exceeding 50 millirem (mrem) were also discussed with cognizant licensee personnel.
b. Findings
No findings of significance were identified.
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a. Inspection Scope
Effluent Processing Equipment The inspectors walked down accessible portions of the gaseous and liquid radioactive effluent processing systems including abandoned equipment. The abandoned liquid waste processing systems were evaluated for evidence of past or present leakage. The active liquid and gaseous processing equipment was evaluated for material condition. This evaluation included reviews of condition reports that had been generated in response to system problems and the system engineers system health reports for gaseous radioactive waste and liquid radioactive waste processing systems.
The inspectors walked down radiological effluent process monitors to evaluate their material condition. The reviewed documentation associated with these monitors included: out-of-service logs; condition reports and calibration records. The inspectors reviewed the system engineers system health reports associated with radiological monitoring systems.
The inspectors reviewed the calibration surveillance records for the following effluent monitors: R-11/12 containment vent air or plant stack, R-14 A-E plant stack, R-16 containment cooling water liquid, R-18 liquid waste disposal effluent, and R-19 A-C steam generator blowdown. The inspectors also reviewed the calibration records for the flow rate instrumentation for the plant vent, liquid rad waste and blowdown pathways.
Installed configuration, material condition, operability, and reliability for selected effluent sampling and monitoring equipment were reviewed against details documented in 10 CFR Part 20, the UFSAR, the ODCM, and RG 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants." Procedures and records reviewed during the inspection are listed in the Attachment.
Effluent Release Processing and Radiological Effluent Quality Control (QC) Activities The inspectors directly observed and evaluated licensee proficiency in effluent release processing. The evaluation included a review of effluent release procedural guidance.
The inspectors reviewed five release permits, including two batch liquid releases, a continuous liquid release, a batch gas release and a continuous gas release. This review included a comparison of pre-release to post-release dose calculation results and reconciliation of differences for each permit. The inspectors observed the preparation of one of the batch liquid release permits.
Gamma spectroscopy, liquid scintillation counting and low background alpha/ beta counting instrumentation QC activities were discussed with count room technicians and chemistry supervision. The inspectors reviewed records of daily QC checks, instrument statistical control charts and trending data for selected gamma spectroscopy detectors, liquid scintillation detectors and low background alpha/beta monitors. In addition, quarterly results of the radiochemistry cross-check program were discussed for calendar year (CY) 2002 through 2004. The inspectors also reviewed the 2002 and 2003 Annual Effluent Report to identify any anomalous releases. Reviewed documents are listed in the Attachment.
Observed task evolutions, offsite dose results, and count room activities were evaluated against RG 1.21 guidance, 10 CFR Part 20 requirements, Appendix I to 10 CFR Part 50 design criteria, UFSAR details, and ODCM requirements.
Problem Identification and Resolution Licensee corrective action program documents associated with effluent release activities were reviewed and assessed. The inspectors reviewed licensee self assessments for radiation monitoring systems, post maintenance testing of radiation monitoring systems, and gamma spectroscopy. The inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve the identified issues. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program
a. Inspection Scope
REMP Implementation The licensees Annual Radiological Environmental Operating Report for calendar year 2003 and REMP activities for 2004 were reviewed and discussed with cognizant licensee representatives. The inspectors discussed and evaluated the reported data for trends in radionuclide concentrations, anomalous/missing data, and land-use census information. QC activities and data for selected sample types listed in the report were reviewed and evaluated. Air sample pump air flow calibration data was also reviewed.
Equipment operational status and staff proficiency for implementing REMP activities were assessed through a review of records, observations of equipment material condition and operating characteristics, assessment of selected sample collection activities, and discussion of collection techniques for sample matrices not directly observed. Collection of weekly air particulate filters/charcoal cartridges and air flow rate determinations were observed at all sampling station locations. During observations of air sample collection, the inspectors evaluated the proficiency of collection staff and assessed the adequacy and implementation of selected collection techniques.
The inspectors also reviewed personnel qualifications to verify that the persons collecting environmental samples were qualified as required by licensee procedures.
REMP guidance, implementation, and results were reviewed against ODCM details and applicable procedures listed in the Attachment. Environmental laboratory activities including processing and analysis are performed at the Harris Environmental Monitoring Laboratory and were not reviewed during this inspection.
Meteorological Monitoring Program The inspectors toured the meteorological tower and its supporting instrumentation and observed the physical condition of the equipment.
The inspectors compared system generated data with data from the control room instrumentation. The data was also compared with the inspectors observations of wind direction and speed measured at the tower. The inspectors also assessed system reliability and data recovery. Meteorological tower siting was evaluated based on near-field obstructions, ground cover, proximity to the plant, and distance from terrain that could affect measurement accuracy. The meteorological tower data recovery for CY 2004 was greater than 90 percent as described in Section 2.3.3. of the UFSAR.
Licensee procedures and activities related to meteorological monitoring were evaluated for consistency with TSs, ODCM, UFSAR Section 2.3, Meteorology, and ANS/ANSI 3.11-2000, "Determining Meteorological Information at Nuclear Facilities." Licensees meteorological monitoring related procedures, reports and records reviewed during the inspection are listed in the Attachment.
Unrestricted Release of Materials from the Radiologically Controlled Area (RCA)
RP program activities associated with the unconditional release of potentially contaminated materials from RCA egress points were evaluated. The evaluation included a review of calibration records associated with the SAM equipment located at the RCA exit portal. The inspectors observed source checking of SAM equipment.
Source activity and radionuclides used for checks and equipment minimum detectable activities were discussed with an instrument technician. Provisions for monitoring hard-to-detect nuclides were also discussed. Section 2OS3 describes additional checks on the instrumentation used to control the release of radioactive material.
The inspectors reviewed radiation detection sensitivities to verify that they were consistent with NRC guidance in IE Circular 81-07, Control of Radioactively Contaminated Material, May 14, 1981, IE Information Notice 85-92, and the ODCM.
Documents reviewed are listed in the Attachment.
Problem Identification and Resolution Audits, self-assessments and selected licensee corrective actions associated with REMP, meteorological monitoring activities and unrestricted release of materials from the RCA were reviewed and discussed with responsible licensee representatives. The inspectors assessed the licensees ability to identify, characterize, prioritize, and resolve the identified issues. Corrective action program documents were reviewed and evaluated for effective corrective actions.
These documents are identified in the Attachment.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee submittals for the PI indicated below for the period of June 2003 through December 2004. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 2, were used to verify the basis in reporting for each data element.
Public Radiation Safety Cornerstone RETS/ODCM Radiological Effluents Occurrence PI The inspectors reviewed records used by the licensee to identify occurrences of quarterly doses from liquid and gaseous effluents in excess of the values specified in NEI 99-02 guidance. The records included the Annual Radiological Effluent Reports for CY 2003 and 2004, and release permits generated in 2005. The inspectors also interviewed licensee personnel that were responsible for collecting and reporting the PI data. In addition, licensee procedural guidance for classifying and reporting PI events was evaluated. Reviewed documents are listed in the Attachment.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
Routine Review of Action Requests
.1 Routine Review of ARs
To aid in the identification of repetitive equipment failures or specific human performance issues for followup, the inspectors performed frequent screenings of items entered into the licensees CAP. The review was accomplished by reviewing daily AR reports.
.2 Annual Sample Review
a. Inspection Scope
The inspectors selected AR 140240140240 Unanticipated [Technical Specification] Entry for HVE-19B, for detailed review. The inspectors selected this AR because it relates generally to the Barrier Integrity Cornerstone. The inspectors reviewed this report 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 reviewed this AR to verify licensee compliance with 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.
Documents reviewed by the inspectors are listed in the Attachment.
b. Observations and Findings
No findings of significance were identified.
4OA5 Other Activities
Reactor Pressure Vessel Lower Head Penetration Nozzles
a. Inspection Scope
To verify that the licensee had visually inspected the entire circumference of every penetration of the reactor vessel lower head in accordance with NRC Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity, the inspectors reviewed the licensee's docketed replies to that bulletin, interviewed the engineer who was responsible for the bottom-head inspection and the engineer who prepared the subject submittal, and reviewed the records developed by the licensee while completing that inspection. Documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified. The inspectors confirmed that the licensee had visually inspected the entire circumference of every penetration of the reactor vessel lower head during the previous refueling outage.
4OA6 Meetings, Including Exit
.1 Exit Meeting
On April 13, 2005, the resident inspectors presented the inspection results to Mr. Bill Noll and other members of his staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
.2 Annual Assessment Meeting Summary
On March 24, 2005, the NRCs Chief of Reactor Projects Branch 4, and Resident staff assigned to the H. B. Robinson Nuclear Plant met with Progress Energy - Carolina Power & Light (CP&L) to discuss the NRCs Reactor Oversight Process (ROP) and the Robinson annual assessment of safety performance for the period of January 1, 2004 -
December 31, 2004. Attendees included CP&L management, CP&L site staff, one member of the Hartsville, SC, City Council, and two reporters.
This meeting was open to the public. The NRCs presentation material used for the discussion is available from the NRCs document system (ADAMS) as accession number ML051100436. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Quarterly Integrated Inspection
Licensee personnel
- E. Caba, Engineering Superintendent
- A. Cheatham, Radiation Protection Superintendent
- C. Church, Engineering Manager
- R. Howell, Supervisor, Regulatory Support
- J. Huegel, Maintenance Manager
- R. Ivey, Operations Manager
- E. Kapopoulos, Outage Management Manager
- J. Lucas, Manager, Support Services - Nuclear
- G. Ludlum, Training Manager
- J. Moyer, Vice President, Robinson Nuclear Plant
- W. Noll, Director of Site Operations
- D. Stoddard, Plant General Manager
NRC personnel
- P. Fredrickson, Chief, Reactor Projects Branch 4
Annual Assessment Meeting Attendees
Licensee personnel
- J. Moyer, Vice President, Robinson Nuclear Plant
- W. Noll, Director of Site Operations
- D. Stoddard, Plant General Manager
- C. Baucom, Licensing Supervisor
- M. Taylor, Manager, Progress Energy
- D. McNeill, Robinson Communications
NRC Personnel
- P. Fredrickson, Chief, Reactor Projects, Branch 4
- R. Hagar, Robinson Senior Resident Inspector
- D. Jones, Robinson Resident Inspector
Other Personnel
- D. MacFarland, Hartsville S.C., City Council Member
- W. Jeffcoat, Staff Writer, Hartsville Manager
- T. Ward, Reporter, Florence Morning News
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None Previous Items
Closed
None
Discussed
None