IR 05000261/2006002
| ML061210399 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/30/2006 |
| From: | Fredrickson P NRC/RGN-II/DRP/RPB4 |
| To: | Walt T Carolina Power & Light Co |
| References | |
| IR-06-002 | |
| Download: ML061210399 (28) | |
Text
April 30, 2006
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2006002
Dear Mr. Walt:
On March 31, 2006, 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 12, with 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, the inspectors identified one issue of very low safety significance (Green). This issue was determined to involve a violation of NRC requirements.
However, because of its very low safety significance and because it has been entered into your Corrective Action Program, the NRC is treating this issue as a non-cited violation (NCV), in accordance with Section VI.A.1 of the NRCs Enforcement Policy. In addition, one licensee identified violation which was determined to be of very low safety significance is listed in Section 4OA7 of the enclosed report. If you contest any NCV in the enclosed report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the H.B. Robinson facility.
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 05000261/2006002 w/Attachment: Supplemental Information
REGION II==
Docket No:
50-261 License No:
DPR-23 Report No:
005000261/2006002 Facility:
H. B. Robinson Steam Electric Plant, Unit 2 Location:
3581 West Entrance Road Hartsville, SC 29550 Dates:
January 1, 2006 - March 31, 2006 Inspectors:
R. Hagar, Senior Resident Inspector D. Jones, Resident Inspector L. Mellen, Senior Reactor Inspector (Lead), (Sections 1R02 &
1R17)
M. Thomas, Senior Reactor Inspector, (Sections 1R02 & 1R17)
R. Taylor, Reactor Inspector, (Sections 1R02 & 1R17)
W. Fowler, Reactor Inspector Trainee, (Sections 1R02 & 1R17)
J. Quinones-Navarro, Reactor Inspector Trainee, (Sections 1R02 & 1R17)
M. Bates, Operations Engineer, (Section 1R11)
Approved by:
P. Fredrickson, Chief Reactor Projects Branch 4 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000261/2006002, 01/01/2006 - 03/31/2006, Carolina Power and Light Company; H.B.
Robinson Steam Electric Plant, Unit 2; Maintenance Effectiveness.
The report covered a three month period of inspection by resident inspectors and an announced inspection by several reactor inspectors. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.
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
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation of 10 CFR 50.65(a)(2) for failure to by 10 CFR 50.65(a)(1).
The finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
. This finding was of very low safety significance because it is not a design or qualification deficiency, does not represent an actual loss of safety function for a system or train, and is not risk significant due to a seismic, fire, flooding, or severe weather initiating event.. The cause of this finding is inattention to detail during validation and verification of assumptions made during the MR evaluations, and is therefore, identified as a performance aspect of the Human Performance cross-cutting area. (Section 1R12)
Licensee-Identified Violations
A violation of very low safety significance which was identified by the licensee was reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the Corrective Action Program. The violation and the licensees corrective action tracking number are listed in Section 4OA7 of this report.
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 Evaluations 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, Updated Final Safety Analysis Report (UFSAR), or procedures may be made, and tests conducted, without prior NRC approval. The inspectors reviewed evaluations for five 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. The five evaluations reviewed are listed in the Attachment.
The inspectors also reviewed samples of changes for which the licensee had determined that evaluations were not required, to confirm that the conclusions to screen out these changes were correct and consistent with 10 CFR 50.59. These changes were reviewed in the region II office. The 13 screened out changes reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
==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 Safety Injection Train B A Safety Injection Pump January 19 Service Water Train A C Service Water Pump February 7 Motor Driven Auxiliary Feedwater Train A and B Steam Driven Auxiliary Feedwater Pump February 28 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.
b. Findings
No findings of significance were identified.
==1R05 Fire Protection
a. Inspection Scope
==
For the six areas identified below, the inspectors reviewed the 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 25A/B turbine building east and west ground floor 25F/G turbine building east/west mezzanine and operating deck 25D dedicated shutdown diesel generator battery room diesel generator A room yard transformers
b. Findings
No findings of significance were identified.
==1R11 Licensed Operator Requalification Annual Review of Licensee Requalification Examination Results
==
a. Inspection Scope
On March 2, 2006, the licensee completed the requalification 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 individual operating tests, and the crew simulator operating tests. These results were compared to the thresholds established in 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
On February 15, the inspectors observed licensed-operator performance during requalification simulator annual examinations for two crews to verify that operator performance was consistent with expected operator performance, as described in Dynamic Simulator Scenario Examinations DSS-009 and DSS-010. The DSS-009 examination tested the operators ability to respond to the failure of a pressurizer spray valve, a reactor coolant pump seal failure, a reactor coolant system leak and a large break loss of coolant accident. The DSS-010 examination tested the operators ability to respond to the failure of a steam pressure channel, a leaking steam generator power operated relief valve, a steam leak and a faulted and ruptured steam generator. 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 two degraded SSC/function performance problems or conditions listed below to verify the 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 (MR). Documents reviewed are listed in the Attachment.
The problems/conditions and their corresponding action requests (ARs) were:
Performance Problem/Condition AR Valve CC-749A failure to actuate on demand 172161 Fuel oil transfer pump B failure 172281 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
Introduction The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65(a)(2) for failure to demonstrate that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance. Repetitive failures of a safety-related breaker that caused a performance criteria to be exceeded were not identified and, as a result, goal setting and monitoring was not conducted as required by 10 CFR 50.65(a)(1).
Description On May 23, 2004 and October 9, 2005 valve CC-749A failed to operate as required. Valve CC-749A is a normally closed valve that is required to open to allow component cooling water (CCW) flow through the A residual heat removal heat exchanger during emergency core cooling system containment sump recirculation.
Troubleshooting efforts for both valve failures determined that the cause was a tripped thermal overload in the associated breaker.
The licensee performed MR evaluations (AR 133282133282and 172161) for both valve failures and determined that neither event would be classified as an MR functional failure. After reviewing the licensees MR procedure, MR evaluations, and associated work requests, the inspectors questioned the determinations that the events were not MR functional failures. On February 28, 2006, the licensee initiated AR 185821185821and subsequently classified both events as MR functional failures. Because the additional failures resulted in the safety-related motor control center breakers (MCC) performance criteria being exceeded, the licensee classified the breakers as MR (a)(1) which requires monitoring against licensee established goals.
Analysis The finding is more than minor because it is associated with the equipment performance attribute and affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
The inspectors determined that the finding is of very low safety significance because it was not a design or qualification deficiency, did not represent an actual loss of safety function for a system or train, and was not risk significant due to a seismic, fire, flooding, or severe weather initiating event. The finding was related to the cross-cutting area of Human Performance because the root cause was determined to be a lack of validation and verification of assumptions made during Maintenance Rule evaluations.
Enforcement the performance of a safety-related breaker was not effectively controlled through the performance of appropriate preventive maintenance and breaker performance was not monitored against licensee-established goals. Specifically, the licensee failed to identify and account for repetitive failures of the safety-related breaker on May 23, 2004 and October 9, 2005, which demonstrated that the SSC was not being effectively controlled through appropriate preventative maintenance and, as a result, goal setting and monitoring was required, but not performed. Because the finding was of very low safety significance, and has been entered in the Corrective Action Program (CAP) (AR 185821185821, it is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000261/2006-01, Failure to Demonstrate Performance of Safety-Related Breaker Effectively Controlled.
==1R13 Maintenance Risk Assessments and Emergent Work Evaluation
a. Inspection Scope
==
For the four time periods listed below, the inspectors reviewed risk assessments and related activities to verify 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. Those periods included the following:
- The work week of January 9 - January 13, including scheduled maintenance on the dedicated shutdown diesel and associated bus
- The work week of January 17 - January 20, including scheduled maintenance on the A safety injection pump and emergent maintenance on the A CCW pump
- The work week of January 23 - January 27, including scheduled maintenance on the steam driven auxiliary feedwater pump and the A residual heat removal train
- The work week of March 13 - March 17, including scheduled maintenance on the A emergency diesel generator
b. Findings
No findings of significance were identified.
==1R15 Operability Evaluations
a. Inspection Scope
==
The inspectors reviewed the operability determination associated with AR 183489183489 Operability Determination needed for Flow Transmitters 1426A, B and C. This AR addressed the erratic indications of the steam driven auxiliary feedwater pump flow transmitters. The inspectors assessed the accuracy of the evaluation, the use and control of any necessary compensatory measures, and compliance with the Technical Specification (TS). The inspectors verified that the operability determination was made as specified by Procedure OPS-NGGC-1305, Operability Determinations. The inspectors compared the justifications provided in the determination to the requirements from the TS, the UFSAR, and associated design-basis documents to verify that operability was properly justified and the flow transmitters 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.
==1R17 Permanent Plant Modifications
a. Inspection Scope
==
The inspectors evaluated engineering change packages for seven modifications, in the Mitigating Systems and Barrier Integrity Cornerstone areas, to evaluate the modifications for adverse effects on system availability, reliability, and functional capability. The seven modifications and the associated attributes reviewed were as follows:
EC 52464 Replace Stack Monitor (Barrier Integrity)
- control signals
- energy needs
- flow paths
- installation records
- licensing basis
- materials/replacement components
- operations
- plant document updating EC 62245, Replace Rosemount Transmitter Model 1153 with 1154 for FT-497 (Mitigating Systems)
- control signals
- energy needs
- installation records
- licensing basis
- materials/replacement components
- operations
- plant document updating
- structural
- system flow requirements EC 52357, SW South Header Flow Instrument (Barrier Integrity)
- control signals
- energy needs
- installation records
- materials/replacement components
- operations
- plant document updating
- flow paths
- installation records
- materials/replacement components
- operations
- plant document updating
- process medium
- system flow requirements EC 41799, Polar Crane Power Supply (Barrier Integrity)
- control signals
- energy needs
- installation records
- licensing basis
- materials/replacement components
- operations
- plant document updating
- flow paths
- installation records
- materials/replacement components
- operations
- plant document updating
- process medium
- system flow requirements EC 58657, Appendix R Pressurizer PORV & Charging Pump Make-up Modification (Mitigating Systems)
- energy needs
- flow paths
- installation records
- licensing basis
- materials/replacement components
- operations
- plant document updating
- process medium
- system flow requirements
- timing delays For selected modification packages, the inspectors observed the as-built configuration.
Documents reviewed included procedures, engineering calculations, modification design and implementation packages, work orders, site drawings, corrective action documents, applicable sections of the UFSAR, TS, and design basis information.
The inspectors also reviewed selected ARs and an audit associated with modifications 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.
==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 witnessed/reviewed:
Test Procedure Title Related Maintenance Activity Date Inspected OP-301-1 Chemical and Volume Control System (Infrequent Operation)
Adjustment of packing gland on valve LCV-460B to stop leakage January 4 OST-202 Steam Driven Auxiliary Feedwater System Component Test Removal and reinstallation of hydramotor for flow control valve, FCV-6416 January 24 OST-206 Comprehensive Flow Test for the Steam Driven Auxiliary Feedwater Pump Repair of the discharge check valve, AFW-84 March 1 OST-401-1
[Emergency Diesel Generator] A Slow Speed Start Replace coils for air start solenoid valves DA-19A and DA-23A March 16 OST-303-1 Service Water Booster Pump A Test Disassembly and inspection of check valve SW-932 March 22 The inspectors reviewed an AR associated with this area, AR 174145174145 Testing of the Charging Pumps Back-Up Instrument Air Supply, to verify that the licensee identified and implemented appropriate corrective actions:
b. Findings
No findings of significance were identified.
==1R22 Surveillance Testing
a. Inspection Scope
==
For the three surveillance tests listed 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 MST-931-2 Testing of Emergency Diesel Generator B Protective Bypasses January 31 OST-352-4*
Comprehensive Flow Test for Containment Spray Pump B March 1 MST-005 Pressurizer Water Level Protection Channel Testing March 15
- This procedure included inservice testing requirements.
b. Findings
No findings of significance were identified.
==1R23 Temporary Plant Modifications
a. Inspection Scope
==
The inspectors reviewed the temporary modification described in Special Procedure, SP-1529, [Reactor Coolant System] to [Boron Injection Tank] Header Leak Path Determination, to verify that the modification did not affect the safety functions of important safety systems, and to verify that the modification satisfied the requirements of Procedure PLP-037, Conduct of Infrequently Performed Tests or Evolutions and Pre-Job Briefs, and 10 CFR 50, Appendix B, Criterion III, Design Control. 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 January 9, the inspectors observed an emergency preparedness drill to verify licensee self-assessment of classification, notification, and protective action recommendation development in accordance with 10 CFR 50, 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.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.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 CAP. The review was accomplished by reviewing daily AR reports.
.2 Annual Sample Review
a. Inspection Scope
The inspectors selected AR 178735178735 Blocked Appendix R Pathway, for detailed review.
The inspectors selected this AR because it relates specifically/generally to the Mitigating Systems 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 compliance with the requirements of the CAP as delineated in Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.
b. Observations and Findings
See Section 4OA7.
4OA5 Other
Implementation of Temporary Instruction (TI) 2515/165 - Operational Readiness of Offsite Power and Impact on Plant Risk
a. Inspection Scope
The objective of TI 2515/165, Operational Readiness of Offsite Power and Impact on Plant Risk, was to gather information to support the assessment of nuclear power plant operational readiness of offsite power systems and impact on plant risk. The inspectors evaluated licensee procedures against the specific offsite power, risk assessment and system grid reliability requirements of TI 2515/165. They also discussed the attributes with licensee personnel.
The information gathered while completing this TI was forwarded to the Office of Nuclear Reactor Regulation for further review and evaluation.
b. Findings
No findings of significance were identified
4OA6 Meetings, Including Exit
On April 12, 2006, the resident inspectors presented the inspection results to Mr. Bill Noll and other staff members. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
4OA7 Licensee-Identified Violations
The following finding of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
On December 13, 2005, the licensee discovered that a pathway used for fire-fighting was inaccessible when operations personnel unsuccessfully attempted to unlock and enter a security enclosure that provided access to security door 24. The pathway provides passage between a turbine building mezzanine area and the room that contains the CCW pumps, the CCW heat exchanges, and some service water piping.
The licensee subsequently determined that for a time period of approximately 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> that began on December 12 and ended on December 13, access was not provided through security door 24 to permit effective functioning of the fire brigade.
Because 10 CFR 50, Appendix R requires, in part, that access to permit effective functioning of the fire brigade be provided to all areas that contain or present an exposure fire hazard to SSCs important to safety, the inspectors determined that the circumstances described above constituted a violation of 10 CFR 50, Appendix R. This violation was more than minor because it affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, in that it affected protection of the CCW and SW systems against external factors (a fire). Because this finding related to fire protection defense-in-depth, the inspectors assessed its significance as described in NRC Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process. Based on this assessment, the finding was determined to be have a low degradation rating and thus was of very low safety significance (Green) because the fire brigade's performance and reliability will be only minimally impacted by the finding, and could reasonably be expected to display nearly the same level of effectiveness and reliability as it would in the absence of the finding. This NCV is in the CAP as AR 178735178735
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- R. Ivey, Operations Manager
- C. Church, Engineering Manager
- E. Caba, Engineering Superintendent
- B. Clark, Nuclear Assurance Manager
- J. Huegel, Maintenance Manager
- W. Noll, Director of Site Operations
- E. Kapopoulos, Outage and Scheduling Manager
- D. Stoddard, Plant General Manager
- W. Farmer, Engineering Superintendent
- J. Lucas, Manager, Support Services - Nuclear
- J. Moyer, Vice President, Robinson Nuclear Plant
- A. Cheatham, Radiation Protection Superintendent
- S. Wheeler, Supervisor, Regulatory Support
- G. Ludlam, Training Manager
- C. Castell, Licensing Engineer
- R. Supler, Electrical Design Engineer
- P. Fagan, Mechanical Design Engineer
NRC personnel
- P. Fredrickson, Chief, Reactor Projects Branch 4
- C. Ogle, Chief, Engineering Branch 1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Opened and Closed
Discussed
None