IR 05000261/2015003
| ML15302A217 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/29/2015 |
| From: | Hopper G NRC/RGN-II/DRP/RPB4 |
| To: | Glover R Duke Energy Progress |
| Betty Hitchuk | |
| References | |
| IR 2015003 | |
| Download: ML15302A217 (21) | |
Text
UNITED STATES ctober 29, 2015
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2015003
Dear Mr. Glover:
On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your H. B. Robinson Steam Electric Plant, Unit 2. On October 15, 2015, the NRC inspectors discussed the results of this inspection with members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
No NRC-identified or self-revealing findings were identified during this inspection. However, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as non-cited violation NCV consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of the NCVs, 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 H. B. Robinson Steam Electric Plant, Unit 2. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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/
George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23
Enclosure:
IR 05000261/2015003 w/Attachment: Supplementary Information
REGION II==
Docket No: 50-261 License No: DPR-23 Report No: 005000261/2015003 Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: July 1, 2015 through September 30, 2015 Inspectors: K. Ellis, Senior Resident Inspector C. Scott, Resident Inspector E. Bousquet, Reactor Inspector, 1R04 Approved by: George T. Hopper, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000261/2015003, July 1, 2015, through September 30, 2015; Duke Energy Progress, Inc.,
H.B. Robinson Steam Electric Plant, Unit 2, Integrated Inspection Report.
The report covered a three-month period of inspection by resident inspectors and regional inspectors. There was one licensee identified violation documented in this report. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP) dated April 29, 2015. The cross-cutting aspects are determined using IMC 0310, Aspects within the Cross-Cutting Areas dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015. The NRCs program for overseeing the safe operations of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision
Licensee Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number is listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
The unit began the inspection period at 100 percent power and remained there through the end of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
a. Inspection Scope
Readiness to Cope with External Flooding The inspectors evaluated the licensees implementation of flood protection procedures and compensatory measures during impending conditions of flooding or heavy rains.
The inspectors reviewed the updated final safety analysis report and related flood analysis documents to identify those areas containing safety related equipment that could be affected by external flooding and their design flood levels. The inspectors also reviewed problem reports and corrective actions for past flooding events. Inspectors conducted a walkdown of the site boundary to further assess the adequacy of the design features relied upon to mitigate the effects of external flooding. In addition, the inspectors met with site engineering to discuss the Unit 1 demolition and its impact on external flood mitigation and site topography. Documents reviewed are listed in the to this report.
b. Findings
No findings were identified.
1R04 Equipment Alignment
a. Inspection Scope
.1 Partial Walkdown
The inspectors verified that critical portions of the selected systems were correctly aligned by performing partial walkdowns. The inspectors selected systems for assessment because they were a redundant or backup system or train, were important for mitigating risk for the current plant conditions, had been recently realigned, or were a single-train system. The inspectors determined the correct system lineup by reviewing plant procedures and drawings. Documents reviewed are listed in the Attachment.
The inspectors selected the following systems or trains to inspect:
- A Containment Spray pump
- A Deepwell Pump to service water booster pump for supplemental containment cooling
- Steam Driven Auxiliary Feedwater pump
- A EDG Fuel transfer pump
- A and B Motor Driven Auxiliary Feedwater pumps
.2 Complete Walkdown
The inspectors verified the alignment of the component cooling water system. The inspectors selected this system for assessment because it is a risk-significant mitigating system. The inspectors determined the correct system lineup by reviewing plant procedures, drawings, the updated final safety analysis report, and other documents.
The inspectors reviewed records related to the systems outstanding design issues, maintenance work requests, and deficiencies. The inspectors verified that the selected system was correctly aligned by performing a complete walkdown of accessible components.
To verify the licensee was identifying and resolving equipment alignment discrepancies, the inspectors reviewed corrective action documents, including condition reports and outstanding work orders. The inspectors also reviewed periodic reports containing information on the status of risk-significant systems, including maintenance rule reports and system health reports. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection (71111.05A/Q - 5 samples)
a. Inspection Scope
Quarterly Inspection The inspectors evaluated the adequacy of selected fire plans by comparing the fire plans to the defined hazards and defense-in-depth features specified in the fire protection program. In evaluating the fire plans, the inspectors assessed the following items:
- control of transient combustibles and ignition sources
- fire detection systems
- water-based fire suppression systems
- gaseous fire suppression systems
- manual firefighting equipment and capability
- passive fire protection features
- compensatory measures and fire watches
- issues related to fire protection contained in the licensees corrective action program The inspectors toured the following five fire areas to assess material condition and operational status of fire protection equipment. Documents reviewed are listed in the
.
- Component Cooling Water Pump Room, fire zone 5
- Auxiliary Building first floor, fire zone 7
- Emergency Switchgear (E1/E-2) Room, fire zone 20
- Control Room, fire zone 22
- Cable Spread Room, fire zone 19
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
Internal Flooding The inspectors reviewed related flood analysis documents and walked down the area(s)listed below containing risk-significant structures, systems, and components susceptible to flooding. The inspectors verified that plant design features and plant procedures for flood mitigation were consistent with design requirements and internal flooding analysis assumptions. The inspectors also assessed the condition of flood protection barriers and drain systems. In addition, the inspectors verified the licensee was identifying and properly addressing issues using the corrective action program. Documents reviewed are listed in the attachment.
- EDG Room
- AFW Pump Room
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
a. Inspection Scope
.1 Resident Inspector Quarterly Review of Licensed Operator Requalification
The inspectors observed an evaluated simulator scenario administered to an operating crew conducted in accordance with the licensees accredited requalification training program. The scenario evaluated the operators ability to respond to a reactor coolant leak, loss of instrument bus four, reactor trip and small break loss of coolant accident.
The inspectors assessed the following:
- licensed operator performance
- the ability of the licensee to administer the scenario and evaluate the operators
- the quality of the post-scenario critique
- simulator performance Documents reviewed are listed in the Attachment.
.2 Resident Inspector Quarterly Review of Licensed Operator Performance in the Actual
Plant/Main Control Room The inspectors observed licensed operator performance in the main control room on Unit 2 during a yellow risk condition due to the main feed regulator valves in manual on August 31, 2015 and September 10, 2015. The inspectors reviewed the operator performance and adherence to the operating procedures.
The inspectors assessed the following:
- use of plant procedures
- control board manipulations
- communications between crew members
- use and interpretation of instruments, indications, and alarms
- use of human error prevention techniques
- documentation of activities
- management and supervision Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors assessed the licensees treatment of the issues listed below to verify the licensee appropriately addressed equipment problems within the scope of the maintenance rule (10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants). The inspectors reviewed procedures and records to evaluate the licensees identification, assessment, and characterization of the problems as well as their corrective actions for returning the equipment to a satisfactory condition. The inspectors also interviewed system engineers and the maintenance rule coordinator to assess the accuracy of performance deficiencies and extent of condition.
Documents reviewed are listed in the Attachment.
- CR 756536, Engine Driven Fire Pump failed to develop required discharge pressure
- Evaluation of a(1) action plan associated with Appendix R Lights following repeated failures
- CR 1943491, Part 21 on NAMCO Limit Switches caused RG 1.97 instruments to exceed performance criteria
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed the maintenance activities listed below to verify that the licensee assessed and managed plant risk as required by 10 CFR 50.65(a)(4) and licensee procedures. The inspectors assessed the adequacy of the licensees risk assessments and implementation of risk management actions. The inspectors also verified that the licensee was identifying and resolving problems with assessing and managing maintenance-related risk using the corrective action program. Additionally, for maintenance resulting from unforeseen situations, the inspectors assessed the effectiveness of the licensees planning and control of emergent work activities.
Documents reviewed are listed in the Attachment.
- August 11-13, 2015, A Motor Driven Feedwater pump out of service for preplanned maintenance
- August 10, 2015, Qualitative Yellow risk condition with A Main Feedwater feed regulator valve in manual
- August 19, 2015, Qualitative Yellow risk condition with B Main Feedwater feed regulator valve in manual
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors selected the operability determinations or functionality evaluations listed below for review based on the risk-significance of the associated components and systems. The inspectors reviewed the technical adequacy of the determinations to ensure that technical specification operability was properly justified and the components or systems remained capable of performing their design functions. To verify whether components or systems were operable, the inspectors compared the operability and design criteria in the appropriate sections of the TSs and updated final safety analysis report (UFSAR) to the licensees evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with operability evaluations.
Documents reviewed are listed in the Attachment.
- CR 757786, Differences in fire protection acceptance criteria
- CR 749789, RWST outlet SI-864A failed to close
- CR 749341, CC-721A was found open during IST inspection
- CR 1952248, Damper will not open when HVS-6 start
- CR 752912, C SW Pump breaker failed to close during blackout sequence actuation
- CR 748734, A EDG output breaker tripped open during 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance test
b. Findings
(Opened) Unresolved item (URI): Failure of Refueling Water Storage Tank (RWST) Discharge Valve to Close on Demand
Introduction:
The inspectors identified an unresolved item associated with the failure of SI-864A, Reactor Water Storage Tank discharge valve to close on demand during surveillance testing. The URI is being opened to review the licensees cause evaluation and determine if a performance deficiency exist.
Description:
On 5/18/2015, with the plant in Mode 6, the A RWST discharge valve, SI864A failed to stroke close on demand, from the control board, during engineering surveillance testing. Troubleshooting revealed that the thermal overload relay within the breaker that supplies power to the MOV actuator was tripped, rendering the A emergency core cooling system train (ECCS) inoperable. Following discovery of this issue, maintenance personnel manually reset the thermal overload and cycled the valve closed. Additionally, the licensee replaced the thermal overload relay and performed post maintenance testing.
The licensee documented this issue in CR 749789 and initiated a cause evaluation. The exact time and cause of the tripped thermal overload relay for SI-864A is unknown at this time. Additional inspection time is required to review the licensees evaluation and determine if a performance deficiency exist. This issue will be identified as URI 05000261/2015003-01, Failure of Refueling Water Storage Tank (RWST) Discharge
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors either observed post-maintenance testing or reviewed the test results for the maintenance activities listed below to verify the work performed was completed correctly and the test activities were adequate to verify system operability and functional capability.
- WO 13345579-02, OST-201-1, MDAFW System Component Test -Train A following replacement of the FCV-1424-HO, A MDAFW discharge
- WO 122744064, OST-352-2, Containment Spray Component Test -Train B following limitorque preventive maintenance of SI-880D-MO, SI-880C-MO
- WO 01999564-01, OST-101-2, Chemical Volume and Control System Component Test Charging Pump B following replacement of suction relief valve
- WO 13322484-02, LP-355, Steam Generator #2 Level Channel 487 calibration protection channel II following FM-487 replacement
- WO 13309098, OST-402-1, EDG A Diesel Fuel Oil System Flow Test following replacement of a the A EDG fuel transfer pump
- WO 13404660, OST-202 Steam Driven Auxiliary Feedwater System Component Test following replacement of AFW-13, SDAFW pump steam relief valve
- WO 13540382, OST- 646 Fire Suppression Water System Engine Fire Pump Test following pump impeller adjustment The inspectors evaluated these activities for the following:
- Acceptance criteria were clear and demonstrated operational readiness.
- Effects of testing on the plant were adequately addressed.
- Test instrumentation was appropriate.
- Tests were performed in accordance with approved procedures.
- Equipment was returned to its operational status following testing.
- Test documentation was properly evaluated.
Additionally, the inspectors reviewed a sample of corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with post-maintenance testing. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the surveillance tests listed below and either observed the test or reviewed test results to verify testing adequately demonstrated equipment operability and met technical specification and licensee procedural requirements. The inspectors evaluated the test activities to assess for preconditioning of equipment, procedure adherence, and equipment alignment following completion of the surveillance.
Additionally, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with surveillance testing. Documents reviewed are listed in the Attachment.
Routine Surveillance Tests
- OST-409-2, EDG B Fast Speed Start
- OST-910, Dedicated Shutdown Diesel Generator (Monthly)
- OST-023, Monthly Surveillances RCS Leakrate
- OST-051, Reactor Coolant System Leakage Evaluation In-Service Tests (IST)
- OST-401-2, EDG B Slow Speed Start
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors observed the emergency preparedness drill conducted on September 23, 2015. The inspectors observed licensee activities in the simulator to evaluate implementation of the emergency plan, including event classification, notification, and protective action recommendations. The inspectors evaluated the licensees performance against criteria established in the licensees procedures. Additionally, the inspectors reviewed the post-exercise critique to assess the licensees effectiveness in identifying emergency preparedness weaknesses and verified the identified weaknesses were entered in the corrective action program. Documents reviewed are listed in the
.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed a sample of the performance indicator (PI) data, submitted by the licensee, for the Unit 1 and Unit 2 PIs listed below. The inspectors reviewed plant records compiled between April 1, 2014, and March 31, 2015, to verify the accuracy and completeness of the data reported for the station. The inspectors verified that the PI data complied with guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures. The inspectors verified the accuracy of reported data that were used to calculate the value of each PI.
In addition, the inspectors reviewed a sample of related corrective action documents to verify the licensee was identifying and correcting any deficiencies associated with PI data. Documents reviewed are listed in the Attachment.
Cornerstone: Initiating Events
- SCRAMS with complications
- unplanned SCRAMS
Cornerstone: Barrier Integrity
- reactor system coolant specific activity
Cornerstone: Mitigating Systems
- heat removal system
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
The inspectors screened items entered into the licensees CAP to identify repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed condition reports, attended screening meetings, or accessed the licensees computerized corrective action database.
.2 Annual Followup of Selected Issues
a. Inspection Scope
The inspectors conducted a detailed review of actions associated with Generic Letter 88-14, "Instrument Air Supply System Problems Affecting Safety-Related Equipment.
The inspectors evaluated the following attributes of the licensees actions:
- complete and accurate identification of the problem in a timely manner
- evaluation and disposition of operability and reportability issues
- consideration of extent of condition, generic implications, common cause, and previous occurrences
- classification and prioritization of the problem
- identification of any additional condition reports
- completion of corrective actions in a timely manner Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
(Closed) LER 2015-002-00, Pressurizer Power Operated Relief Valve (PORV) Limit Switches Qualified Life Exceeded Due to Miscalculation.
On February 18, 2015, it was determined that qualified life calculation for the NAMCO limit switches for the pressurizer PORVs was incorrect. These limit switches are used as Post Accident Monitoring (PAM) instrumentation to provide position indication of the PORV to the control room operators during a design basis accident (DBA), which is a requirement of TS 3.3.3. The qualified life calculation was revised on March 19, 2015 and revealed that the NAMCO limit switches were no longer qualified for their monitoring function during and following a DBA. This resulted in the function of PORV position being inoperable for a period of time greater than allowed by TS 3.3.3 PAM Instrumentation Limiting Condition for Operation (LCO). The licensee determined the cause of the miscalculated qualified life was a result of the calculation not being adequately checked by utility engineering personnel or by the person who performed the design verification. The licensee entered this issue in the corrective action program as CR 738953, implemented an interim standing instruction for alternate methods of monitoring PORV positon, and finally replaced the switches during refueling outage 29 which began May 12, 2015. The enforcement aspects of this violation are documented in section 4OA7. This LER is closed.
4OA5 Other Activities
.1 Operation of an Independent Spent Fuel Storage Installation (IP 60855.1)
a. Inspection Scope
The inspectors performed a walkdown of the onsite ISFSI. The inspectors reviewed changes made to the ISFSI programs and procedures, including associated 10 CFR 72.48, Changes, Tests, and Experiments, screens and evaluations to verify that changes made were consistent with the license or certificate of compliance. The inspectors also reviewed surveillance records to verify that daily surveillance requirements were performed as required by technical specifications. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On October 15, 2015, the resident inspectors presented the inspection results to Mr.
Glover and other members of the licensees staff. The inspectors confirmed that proprietary information was not retained by the inspectors or documented in this report.
4OA7 Licensee Identified Violations
The following finding of very low safety significance was identified by the licensee and is a violation of NRC requirements, and, consistent with the NRC Enforcement Policy, is being dispositioned as an NCV.
10 CFR 50.49, Environmental Qualification of electric equipment important to safety for nuclear power plants, states that each licensee shall establish a program for qualifying specified electric equipment. Section (e)
- (5) of 10 CFR 50.49 specifies, in part, that the licensee must replace or refurbish equipment at the end of its qualified life unless ongoing qualification demonstrates that the item has additional life. Contrary to the above, on February 18, 2015, the licensee determined that they failed to replace or refurbish the pressurizer PORV limit switches prior to the end of their qualified life, or by February 23, 2007. The licensee was also unable to demonstrate the limit switches had additional life. The licensee documented this condition in CR 738953. Following discovery of this condition, the licensee implemented an interim standing instruction for alternate methods of monitoring PORV positon, and finally replaced the switches during refueling outage 29 which began May 12, 2015. Using IMC 0609, Appendix A, SDP for Findings At-Power, the inspectors determined that this finding was of very low safety significance (Green) because the PORV maintained its operability although the finding affected its qualification.
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- C. Caudell, Regulatory Affairs
- J. Conder, Assistant Operations Training Manager
- T. Cosgrove, Plant General Manager
- S. Connelly, Licensing
- F. Giannone, Training Manager
- M. Glover, Site Vice President
- E. Hedderman, Chemistry Manager
- R. Hightower, Licensing/Reg. Programs Supervisor
- D. Hoffman, Nuclear Oversight Manager
- K. Holbrook, Operations Manager
- M. Pastva, Jr., Nuclear Regulatory Affairs
- S. Peavyhouse, Organizational Effectiveness Director
- J. Rackley, Training Supervisor
- C. Sherman, Radiation Protection Superintendent
- C. Spencer, Welding Engineer
NRC personnel
- G. Hopper, Chief, Reactor Projects Branch 4
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
Pressurizer Power Operated Relief Valve (PORV)
2015-002-00 LER Limit Switches Qualified Life Exceeded Due to Miscalculation
Opened
Failure of Refueling Water Storage Tank (RWST)
- 05000261/2015003-01 URI Discharge Valve to Close on Demand