IR 05000261/2006004
| ML063030428 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/30/2006 |
| From: | Binoy Desai NRC/RGN-II/DRP/RPB4 |
| To: | Walt T Carolina Power & Light Co |
| References | |
| IR-06-004 | |
| Download: ML063030428 (25) | |
Text
ber 30, 2006
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2006004
Dear Mr. Walt:
On September 30, 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 October 11, 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\
Binoy Desai, Acting Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23
Enclosure:
Inspection Report 05000261/2006004 w/Attachment: Supplemental Information
ML063030428 OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE SON RCH2 DAJ2 by fax BBD for GAH2 by email RLM2 by email MAS1 by email NAME SNinh RHagar DJones JAustin AHutto RMonk MScott DATE 10/20/2006 10/24/2006 10/26/2006 10/26/2006 10/25/2006 10/24/2006 10/24/2006 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE RII:DRP SIGNATURE ECM2 by email NAME EMichel DATE 10/26/2006 11/ /2006 11/ /2006 11/ /2006 11/ /2006 11/ /2006 11/ /2006 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
CP&L 2
REGION II==
Docket No: 50-261 License No: DPR-23 Report No: 005000261/2006004 Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: July 1, 2006 through September 30, 2006 Inspectors: R. Hagar, Senior Resident Inspector D. Jones, Resident Inspector J. Austin, Brunswick Resident Inspector (Section 1R15)
A. Hutto, Oconee Resident Inspector (Sections 1R05 & 1R06)
R. Monk, Browns Ferry Resident Inspector (Sections 1R05,1R13
&1R19)
M. Scott, DRS Inspector, (Section 1R07)
E. Michel, DRS Inspector, (Section 1R07)
Approved by: Binoy Desai, Acting Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000261/2006-004, 07/01/2006 - 09/30/2006; H.B. Robinson Steam Electric Plant, Unit 2;
Routine Integrated Report.
The report covered a three month period of inspection by resident inspectors and two announced inspections by a regional senior health physics inspector and a regional senior reactor inspector. 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.
No findings were identified during this inspection period.
NRC-Identified and Self-Revealing Findings
None
Licensee-Identified Violations
None
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
1R04 Equipment Alignment
a. Inspection Scope
Partial System Walkdowns:
The inspectors performed the following two 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 B emergency diesel generator EDG A August 7 (EDG)
Instrument Air Train 2A and B Air Compressor D August 22 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 train A of the component cooling water system to verify that the existing alignment of the system was consistent with the required alignment. To determine the required system alignment, the inspectors reviewed the procedures, drawings, and the Updated Final Safety 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 locked valve program.
The inspectors reviewed the documents listed in the Attachment to verify that the ability of the system to perform its functions could not be affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, and other system-related issues tracked by the engineering department.
The inspectors reviewed the following action requests (ARs) associated with this area to verify that the licensee identified and implemented appropriate corrective actions:
- AR 172161, [Motor-operated valve] CC-749A [Component Cooling Water to A Residual Heat Removal heat exchanger] Failure to Actuate on Demand
- AR 167279, High [reactor coolant pump] seal temperatures received during
[surveillance test] OST-908
- AR 185821, Repetitive failures of [Motor-operated valve] CC-749A [Component Cooling Water to A Residual Heat Removal heat exchanger] during RO-22 and RO-23
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 G1/25 turbine building (ground floor)
A5/16 battery room A2/2 A diesel generator room 25E & F turbine building east & west mezzanine 25G turbine building operating deck 25D dedicated shutdown diesel generator
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
External Flooding The inspectors walked down the service water intake pits which contains risk-significant SSCs which are susceptible to flooding from external sources to verify that the area configuration, features, and equipment functions were consistent with the descriptions and assumptions used in UFSAR Section 9.2.1, Service Water, and in the supporting basis documents listed in the Attachment.
Internal Flooding Because the auxiliary building first floor hallway contains risk-significant SSCs which are susceptible to flooding from postulated pipe breaks, the inspectors checked all doors credited for flood control and also verified the staging of the door blocking devices in the operations cabinet in the contaminated tool room. The inspector also walked down the first floor hallway to verify that the area configuration, features, and equipment functions were consistent with the descriptions and assumptions used in Calculation RNP-F/PSA-0009, Assessment of Internally Initiated Flooding Events and in the supporting basis documents listed in the Attachment. The inspectors reviewed the operator actions credited in the analysis to verify that the desired results could be achieved using the plant procedures listed in the Attachment
b. Findings
No findings of significance were identified.
1R07 Biennial Heat Sink Performance
a. Inspection Scope
The inspectors reviewed inspection records, clean and inspect results, corrective action program documents, and other documentation to ensure that heat exchanger (HX)deficiencies that could mask or degrade performance were identified and corrected.
Procedures and records were also reviewed to verify that these were consistent with Generic Letter (GL) 89-13 licensee commitments, and industry guidelines. Risk significant heat exchangers (HX) reviewed included the Component Cooling Water (CCW) HXs, Emergency Diesel Generator (EDG) HXs, and the Motor-Driven Auxiliary Feed Water Oil Cooler HXs.
The inspectors reviewed HX inspection and cleaning work instructions, work maintenance history, and completed inspection records for all the safety related HXs selected. The documents were reviewed to verify inspection methods were consistent with industry standards, to verify HX design margins were being maintained, and to verify performance of the HXs under the current maintenance frequency was adequate.
The inspectors also reviewed general health of the service water system via review of design basis documents, system health reports, inservice testing requirements, heat exchanger performance testing calculations, and discussions with the service water (SW) system engineer. These documents were reviewed to verify the design basis was being maintained and to verify adequate SW system performance under current preventive maintenance, inspections, and test frequencies. The inspectors physically walked down accessible portions of the SW system including the EDG coolers, CCW coolers, SW discharge canal and Lake Robinson dam. The inspectors reviewed the dam inspection reports and spoke with environmental engineers regarding the health of Lake Robinson with respect to Zebra Mussels and Asiatic Clams.
The inspectors also verified SW system corrosion and degradation were being monitored and addressed via review of corrosion control program procedures, SW pipe replacement and material condition action plans, and discussions of coatings with applicable engineers. The inspectors reviewed samples of the licensees SW Project activities that are in progress for piping replacement over the next several years, or have been accomplished since the previous inspection.
Corrective action program documents, Action Reports (AR) were reviewed for potential common cause problems and problems which could affect system performance to confirm that the licensee was entering problems into the corrective action program and initiating appropriate corrective actions.
b. Findings
The inspectors found an issue during a review of the licensees ultimate heat sink configuration and operational controls. This issue is identified as follows:
Lake Robinson is the source of the ultimate heat sink for the Robinson nuclear plant (Unit 2). The lake is impounded by the Lake Robinson dam that serves both the nuclear plant and a fossil plant (Unit 1). The fossil Unit 1 staff controls the operation and maintenance of the Tainter gates (electrically moveable spillway gates) in the Lake Robinson dam. The gates are periodically cycled (opened and then closed) to ensure freedom of movement. During the cycling, the gates are at risk of continuing to open or failing to close, which could result in a dramatic lowering of lake level, the ultimate heat sink for the nuclear plant. The gates are subject to external events and other types of failures. A failed Tainter gate could lower lake level resulting in loss of supply to the nuclear Unit 2 Service Water (SW) pumps suction and therefore a loss of SW.
Licensing statements regarding the SW system are contained in a 1970 NRC issued safety evaluation (section 3.9.6). The statements described how the SW system would be used to shutdown the plant during a loss of the Robinson dam. At the time of the inspection it was unclear what procedure(s) contained or covered the evaluations statements and mitigation strategy.
The inspectors noted two procedures that address various degrees of loss of SW for the Unit 2 nuclear plant. With the loss of the Tainter gate(s), it was unclear to the inspectors how the heat sink function was to be met in light of procedure wording (mitigation strategy) and stated level of testing of newly installed SW support equipment.
The procedure and equipment qualification uncertainties could be a potential technical specification required procedure problem or an inability to meet heat sink functional needs, a design issue (10 CFR 50, Appendix B), in certain accident scenarios. This issue will require NRC review to determine if the installed equipment and procedures can provide for long term safe shutdown of Unit 2 upon loss of the ultimate heat sink.
Accordingly, this issue is left as an Unresolved Item (URI) 05000261/2006004, Verify Mitigation Capabilities for Loss of Heat Sink.
1R11 Licensed Operator Requalification
a. Inspection Scope
The inspectors observed licensed-operator performance during requalification simulator training for shift 1 to verify that operator performance was consistent with expected operator performance, as described in Operations Training guide LOCT-07-1. This training tested the operators ability to respond to a failed indicator of control-rod position, a turbine trip at low power level, and a steam generator tube rupture followed by a loss-of-coolant accident. 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
.
The inspectors discussed the post-exercise critique with the training staff 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. Documents reviewed are listed in the
.
The problems/conditions and their corresponding ARs were:
Performance Problem Condition AR Repetitive failures of main steam dump valves 158740 Steam Generator [power operated relieve valve] found out 158703 of calibration 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).
The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:
- 77525, [Pressure relief valve]1324B-2 failed to open due to bad [solenoid-operated valve] 20/17C
- 126344, Steam dump valve [Pressure relief valve]1324B-1 failed to open
- 160930, Number of functional failures exceeded the criteria
b. Findings
No findings of significance were identified.
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 August 5 - August 11, which included scheduled maintenance on the A motor-driven auxiliary feedwater system and an unplanned downpower to 90 percent of rated power and subsequent return to full power.
- The work week of August 12 - August 18, including emergent maintenance on boric acid pump A and startup transformer A during a B train work week.
- The work week of September 5 - September 8, which included scheduled maintenance on the A emergency diesel generator.
- The work week of September 18 - September 22, which included emergent maintenance on the B charging pump and A vacuum pump.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the operability determination and compensatory actions associated with AR 179678, which addressed the need to frequently drain the boric acid injection tank (BIT) header due to back leakage from the reactor coolant system.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the six 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 Technical Specification (TS).
Documents reviewed are listed in the Attachment.
The following tests were witnessed/reviewed:
Related Test Procedure Title Maintenance Activity Date Inspected OST-352-1 Containment Spray Inspection and testing July 5 Component Test - of pump breaker Train A 52/19A OST-108-1 Boric Acid Pump A Pin-hole weld repair on August 14 Inservice Inspection discharge piping OST-409-2 Emergency Diesel Replacement of air August 17 Generator B Fast start solenoids 19B Speed Start and 23B and starting air system maintenance OST-409-1 Emergency Diesel Modification of air start September 8 Generator A Fast system Speed Start OST-101-2 [Chemical and Replacement of valves September 20 Volume Control and packing on the B System] Component charging pump Charging Pump B Work Order Replace Alarm Modification of an September 25 667359-02 Switches in 52/21C alarm switch on the (Safety Injection shunt trip coil Pump A)
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
For the four surveillance tests listed 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
.
Test Procedure Title Date Inspected OST-202 Steam Driven Auxiliary Feedwater July 11 System Component Test CP-001 Chemistry Monitoring Program July 12 OST-251-2* [Residual Heat Removal] Pump B and July 26 Components Test OST-252-2 [Residual Heat Removal] System July 26 Valve Test - Train B
- This procedure included inservice testing requirements.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
On September 5 and September 18, the inspectors observed two emergency preparedness drills 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 critiques to verify that the licensee properly identified failures in classification, notification, and protective action recommendation development activities. Documents reviewed are listed in the
.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors verified the three PIs identified below. For each PI, the inspectors verified the accuracy of the PI data that had been previously reported to the NRC by comparing those data to the actual data, as described below. The inspectors also compared the basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 2. In addition, the inspectors interviewed licensee personnel associated with collecting, evaluating, and distributing these data.
Initiating Events Cornerstone
- Unplanned Scrams
- Scrams with Loss of Heat Removal
- Unplanned Power Changes For the period from the first quarter of 2005 through the first quarter of 2006, the inspectors reviewed a selection of licensee event reports, operator log entries, daily reports (including the daily CR descriptions), monthly operating reports, and PI data sheets to verify that the licensee had accurately identified the number of scrams and unplanned power changes greater than 20 percent that occurred during the subject period. The inspectors compared those numbers to the numbers reported by the licensee for the PI. The inspectors also reviewed the accuracy of the number of critical hours reported.
b. Findings
No findings of significance were identified.
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 Corrective Action Program (CAP). The review was accomplished by reviewing daily AR reports.
.2 Annual Sample Review
a. Inspection Scope
The inspectors selected AR 174081 ([Pressure control valve] PCV-1380 does not pass expected flow rate) for detailed review. The inspectors selected this AR because it relates specifically to operator workaround 05-12, which states that because a manual valve in the main steam system (MS-62) has failed in a closed position, another manual isolation valve (MS-61) is manually throttled and must therefore by manually closed following a reactor trip, to prevent an excessive cooldown of the reactor coolant system.
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
No findings of significance were identified.
4OA6 Meetings, Including Exit
On October 11, 2006, the resident inspectors presented the inspection results to Mr. W.
Noll and other members of his staff. A re-exit was conducted over the phone on October 11, 2006 to discuss the opening of the URI. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- N. Bach, Environmental &Chemical Superintendent
- D. Bailey, Sr. Nuclear Self Evaluation Special Regulatory Support
- C. Baucom, Licensing/Reg. Programs
- S. Brown, On-line Scheduling Supervisor
- C. Church, Operations Manager
- B. Clark, Nuclear Assurance Manager
- W. Farmer, Engineering Manager
- K. Jensen, Materials & Contract Services Superintendent
- J. Lucas, Manager, Support Services - Nuclear
- G. Ludlum, Training Manager
- W. Noll, Director of Site Operations
- G. Sanders, Sr. Engineer/Licensing
- T. Tovar, Radiation Protection Superintendent
NRC personnel
- B. Desai, Acting Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000261/2006-001 URI Verify Mitigation Capabilities for Loss of Heat Sink.
Closed
None Previous Items
Closed
.
None
Discussed
None