RNP-RA/13-0106, Reply to Notice of Violation; EA-13-129, Inspection Report 05000261/2013009

Reply to Notice of Violation; EA-13-129, Inspection Report 05000261/2013009

ML13301A077
Person / Time
Site:	Robinson
Issue date:	10/17/2013
From:	William Gideon Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-129, RNP-RA/13-0106 IR-13-009
Download: ML13301A077 (4)

Text

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Serial: RNP-RA/13-0106 OCT 1 '72013 ATTN: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 REPLY TO NOTICE OF VIOLATION; EA-13129 W&JSElINRPR 064im 00"M 0zm 03009

Reference:

Letter from V. M.McCree (NRC) to W. R. Gideon (Duke Energy Progress) dated September 19, H.B. Robinson Steam Electric Plant - Final Significance nOf Viton. and Assesmet Follow-Up

'" ietter,-N! ." qt*.i .. i0..261/2013009 Ladies and itl n. "

Ernclsed is the Duke Energy Progress, Inc., formerly known as Carolina Power and Light qoinpany, H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2 reply to the Notice of Vi1ation contained in the enclosure to your letter (EA-113-129) dated September 19, 2013.

There are no regulatory commitments made in this submitalf "you Oivaany questions regarding this submittal, please contact Mr. R. Hightower at (843) 857$4329.

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United States Nuploar Regulator. Commission Enclosure to Seal. RIp-lWl.3-0106 Pqge I os3

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H. W.ROBINSON.STEAI ELECTRIC PLANT, UNIT NO.2

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United States Nuclear Regulatory. Commission Enclosure to Serial: RNP-RA4W,13-0106 Page 2 of 3 Re@eagted Molation--,..-** *.

10OCFR 50.63 (cX2) statbs, in.par that the alternate AC power source, as defined in section 50.2, will'constitute acceptable capability to withstand station blackout provided an analysis is performed Which demonstrates that the plant has this capability from onset of the station blackout until the alternate AC source(s) and required shutdown equipment ar* started and.lined up to operate. H. B.

Robinson Steam Electric Plant (HBRSEP),-Unit No. 2 Blackout Coping Analysis Report 8S19-P-101, identifies the Dedicated Shutdown Diesel Generator (DSDG) as its alternate AC power source

,and specifies that HBRSEP, Unit No. 2 is required to cope for eight hours following a station blackout and that alternate AC power must be supplied within one hour to shut down equipment by the DSDG. Additionally, the DSDG Is required to provide emergency power during selected Fire Safe Shutdown (SSD) scenarios.

Contrary to the above, from August 28, to October 3, 2012, the licensee failed to have an alternate AC power source with acceptable capability to withstand station blackout for the required durations specified in Its coping analysis. Specifically, during surveillance testing of the DSDG on October 2, 2012, the OSDG automatically shut down on high engine temperature due to a failure of the radiator drive belts. The condition of the drive belts was significantly degraded, due in part to a lack of adequate Inspection, maintenance, and/or periodic replacement. Based on the failure of the DSDG and necessary repair time, this degraded condition would have prohibited the DSOG from supplying power to shutdown equipment within one hour following a station blackout and could have rendered the plant unable to cope for eight hours after a postulated station blackout or to provide emergency power for certain selected Fire SSD scenarios.

This violation Is associated with a White SOP finding.

Reajon for the Violation:

HBRSEP, Unit No. 2 has determined that there were two (2) root causes for the violation:

1. Preventative maintenance requirements did not exist for time based replacement of the DSDG radiator fan/motor drive belts.

2. Procedural guidance in CM-608, Alignment and Adjustment of Belt Driven Equipment, was insufficlent to guide workers to an adequate assessment of belt and sheave condition and belt tension.

Qorrective Steos Taken and Results Achieved:

HBRSEP, Unit No. 2 has taken the following corrective steps:

1. Established and implemented a new fime based belt replacement frequency (2 years) for the DSDG radiator fan. This was performed through Preventive Maintenance Request (PMR) 611399.

2. Developed and Implemented CM-608 procedure guidance changes for quantitative belt and sheave inspection criteria. This includes a requirement to use belt and sheave gauges to measure wear and a tenslometer to measure belt tension.

3. Developed Preventive Maintenance (PM) requirements for critical and Important belt driven equipment.

4. Completed Work Order 2146434 to replace the DSDG radiator drive motor (9 inch outer diameter) and fan (28 Inch outer diameter) sheaves.

HBRSEP, Unit No. 2 has signifticantly Improved material condition of the DSDG and has put Into place actions that will sustain the Improved condition. The DSDG radiator fan guard was modified to allow visual belt Inspections. A new motor mounting system allows the mechanics to more

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0106 Page 3 of 3 accurately adjust belt tension. The belts and sheaves have been replaced on the DSOG radiator fan. The belts are now on a two year Preventive Maintenance (PM) frequency for replacement.

The sheaves are on an eight year PM frequency for replacement HBRSEP, Unit No. 2 has also extended the Improved maintenance practices to belt driven equipment.

As previously noted, CM-808 has been revised to provide more prescriptive requirements for belt and sheave inspections. CM-608 is utilized for belt driven equipment The result is that the revisions to CM-608 are also applied when performing maintenance on other belt driven equipment.

Corrective Steos That Will Be Taken:

Revise PM-M-DSD-FAN-001, DS0 [Dedicated Shutdown Diesel] Cooling Tower Fan Inspection, procedure guidance to be consistent with CM-608 belt and sheave inspection criteria. This Is currently scheduled to be completed November 2013.

Develop and Implement the site level Preventive.Maintenance basis document for belt driven equipment. This is scheduled to be completed November 2013.

Date When Full Compliance Will Be Achieveed:

Full compliance was achieved October 3, 2012, upon completion of the DSDG radiator fan belt replacement and successful post maintenance testing of the DSDG.

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