IR 05000261/2019003
| ML19318F778 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/14/2019 |
| From: | Randy Musser NRC/RGN-II/DRP/RPB3 |
| To: | Kapopoulos E Duke Energy Progress |
| A. Wilson RGN-II/DRP | |
| References | |
| IR 2019003 | |
| Download: ML19318F778 (10) | |
Text
November 14, 2019
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000261/2019003
Dear Mr. Kapopoulos:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at H.B. Robinson Steam Electric Plant. On October 16, 2019, the NRC inspectors discussed the results of this inspection with Ms. Nicole Flippin, General Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2 of the Enforcement Policy.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects
Docket No. 05000261 License No. DPR-23
Enclosure:
As stated
Inspection Report
Docket Number:
05000261
License Number:
Report Number:
Enterprise Identifier:
I-2019-003-0017
Licensee:
Duke Energy Progress, LLC
Facility:
H.B. Robinson Steam Electric Plant
Location:
3581 West Entrance Road, Hartsville SC 29550
Inspection Dates:
July 1, 2019 to September 30, 2019
Inspectors:
A. Beasten, Resident Inspector
M. Fannon, Senior Resident Inspector Pwr/Tl
Approved By:
Randall A. Musser, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at H.B. Robinson Steam Electric Plant in
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified
non-cited violation is documented in report section: 71111.06.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Unit 2 began the inspection period at rated thermal power. On August 11, 2019, the unit
experienced an automatic reactor trip and turbine trip due to an electrical fault in the main
generator exciter. The unit was restarted on September 3, 2019 and was returned to rated
thermal power on September 6, 2019. The unit remained at or near rated thermal power for the
remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated readiness for impending adverse weather related to
Hurricane Dorian on September 1 through September 5, 2019
External Flooding Sample (IP Section 03.04) (1 Sample)
(1)
The inspectors evaluated readiness to cope with external flooding on
August 28, 2019
Lake Robinson dam and spillway tainter gates
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
(1)
Spent fuel pool cooling, including service water pumps 'C' and 'D' and 'A' component
cooling water pump, for less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time to boil on July 10, 2019
(2)
Steam driven auxiliary feedwater system during the 'B' motor driven auxiliary
feedwater train maintenance outage on July 17, 2019
(3)
Dedicated shutdown emergency diesel generator following the turbine and reactor trip
on August 13 through 15, 2019
(4)
Emergency bus E-1 equipment and components while the dedicated shutdown diesel
generator was out of service for planned overhaul on August 20, 2019
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated fire brigade performance on August 9, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
(1)
Fire zone 2, 'A' emergency diesel generator room, on July 2, 2019
(2)
Fire zone 3, safety injection pump room, on August 2, 2019
(3)
Fire zone 21, rod control room, on August 2, 2019
(4)
Fire zone 4, charging pump room, on August 6, 2019
(5)
Fire zone 8, boron injection tank room, on August 27, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Underground Cables (IP Section 02.02c.) (1 Sample)
(1)
(1) M-50A and M-50B, on June 18, 2019
(2) M-35 and M-36, on June 18, 2019
71111.07A - Heat Sink Performance
Annual Review (IP Section 02.01) (1 Sample)
(1)
The 'A' component cooling water heat exchanger
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the control
room during plant startup activities on September 3, 2019
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
(1)
Dedicated shutdown diesel generator following recent overhaul
(2)
Water cooled condensing unit '1B' following recent failure
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
(1)
'B' motor driven auxiliary feedwater system train maintenance outage on
July 17, 2019
(2)
Maintenance activities for the week of August 18, 2019, including the dedicated
shutdown diesel generator overhaul
(3)
Steam driven auxiliary feedwater system planned maintenance concurrent with MST-
021, Reactor Protection Logic Testing Train B, and MST-023, Safeguard Relay Rack
Train B, testing on September 10, 2019
(4)
230kV switchyard relay calibrations for the week of September 16, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (5 Samples)
(1)
Nuclear condition report (NCR) 2281205, 'A' safety injection pump seal water line
vibrations on July 10, 2019
(2)
NCR 2266397, 'B' emergency pressurization failing to meet acceptance criteria for
control room envelope on July 31, 2019
(3)
NCR 2277990, underground cable vault M-36 water level above grating and on
cables on July 31, 2019
(4)
NCR 2283402, debris found in motor vent screen of 'C' service water pump on
August 2, 2019
(5)
NCR 2283172, 'A' diesel generator air compressor unloader tower porting off air on
August 6, 2019
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
(1)
Work order (WO) 20224292, 'B' motor driven auxiliary feedwater train maintenance
outage on July 17, 2019
(2)
OST-908-4, Component Cooling Water Pump Test 'C', following planned
maintenance on the 'C' component cooling water pump on July 25, 2019
(3)
OP-306, Component Cooling Water System, following minor maintenance on the
'A' component cooling water pump on July 31, 2019
(4)
OP-602-1, DSDG Power Pack Replacement Break-In and Testing, following major
planned maintenance on August 23, 2019
(5)
WO 20240431, replace open limit switch on FCV-113A-LS-O, and WO 20240426,
replace open limit switch on FCV-113A-LS-C, on September 16, 2019
71111.22 - Surveillance Testing
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
(1)
OST-108-1, Boric Acid Pump 'A' Inservice Test, on July 8, 2019
(2)
SP-1506, Control Room Integrated In-Leakage Tracer Test, performed from
March 28-31, 2019, however the final report from the vendor was not issued until
July, 2019
Inservice Testing (IP Section 03.01) (1 Sample)
(1)
OST-151-3, Safety Injection Subsystem Components Test Pump 'C', on
September 23, 2019
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)
(1)
Unplanned scrams from July 1, 2018 to June 30, 2019
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
(1)
Unplanned power changes from July 1, 2018 to June 30, 2019
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
(1)
Heat removal systems (MS08) from July 1, 2018 to June 30, 2019
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
(1)
RCS activity (B101) from July 1, 2018 to June 30, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
(1)
NCR 2253155, Steam dumps group 1 loss of power MST-021
NCR 2147971, Bank 1 steam dump loss of indication
(2)
NCR 2256141, FCV-1424 remains open after stopping 'A' motor driven auxiliary
feedwater pump
71153 - Followup of Events and Notices of Enforcement Discretion
Personnel Performance (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated the licensees performance in response to a Unit 2
automatic reactor trip from rated thermal power due to a turbine trip that was a result
of a fault in the main generator exciter on August 11, 2019. A non-emergency event
report was submitted to the NRC (Event Notification 54212). The reactor trip was not
complex, with all systems responding normally post trip. The unit was restarted on
September 3, 2019 and was returned to rated thermal power on
September 6, 2019. The issue was placed in the corrective action program as NCR
2286376.
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 of CFR Part 50, Appendix B, Criterion III, Design Control, requires, in
part, that that measures shall be established to assure applicable regulatory requirements
and the design basis, as defined in section 50.2 and as specified in the license applications,
for those structures, systems, and components to which this appendix applies are correctly
translated into specifications, drawings, procedures, and instructions.
Contrary to the above, from June 18, 2018 to June 19, 2019, the licensee failed to maintain
Class 1E (safety-related) electrical cables in an environment for which they are
designed. Specifically, the low-voltage safety related cables associated with the A and B
service water pumps and power and limit switches were submerged in water, a condition for
which they are not qualified. The licensee took immediate actions to lower the water levels in
underground cable vaults where submerged cables were discovered and conduct pump-
downs of the safety-related underground cable vaults on an increased scheduled frequency.
Significance/Severity: Green. This performance deficiency was associated with the
Mitigating Systems Cornerstone. The performance deficiency was related to the equipment
reliability attribute and failure to maintain the cables in the environment for which they were
designed adversely impacted the cornerstone objective to ensure the availability, reliability,
and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the submergence of the safety-related cables adversely
impacted the service life of the cables and could cause the A train service water system to
be inoperable in the event a cable failed as a result of continuous submergence. The finding
screened as having very low safety significance (Green) because it did not represent an
actual loss of function in the service water system.
Corrective Action References: This issue was being tracked in the licensees corrective
action program by NCR 02277990.
Observation: Observation
The Inspectors reviewed the licensees response to a relay failure of the A motor driven
auxiliary feedwater (MDAFW) pump discharge flow control valve, NCR 02256147. On
February 5, 2019, following post-maintenance testing on the A MDAFW pump, FCV-1424
failed to close as expected when the pump was secured. FCV-1424 is a discharge flow
control valve that adjusts the flow from the MDAFW pump to the steam generators. The
failure was unrelated to maintenance activities that had occurred earlier that
day. Troubleshooting identified that the relay did not open when de-energized. Following
relay replacement, all tests were completed successfully.
The Inspectors questioned the licensees investigation into the failure. The relay was to be
sent offsite for failure analysis, however an onsite visual inspection was determined to be
sufficient. The inspection revealed that the number 2 normally closed contact was bent which
caused the relay to bind internally. The licensee concluded that the relay had been installed
with the bent contact bar and was therefore a manufacturing defect. No extent of condition
was performed as it was determined to be an isolated failure. Although this relay had been
purchased with 10 others from Westinghouse, the licensee had not notified Westinghouse of
the defect. Additionally, the other 10 relays had not been located or inspected.
Based on these inspector questions, NCR 02277990 was reopened on April 3, 2019, and the
failure cause was changed to inadequate relay installation. Although the installation
procedure contained instructions to verify that the contacts were aligned correctly both prior
to and after installation, the licensee initiated a procedure revision to clarify that all contacts
and should be inspected both before and after installation. Given this new information, the
inspectors questioned how the defect was introduced. The licensee maintained that it had
been installed with the defect. The inspectors also questioned the capability of the A
MDAFW pump to perform its intended safety function with a defective relay installed in the
system. The licensee maintained that the pump would perform its safety function since the
internal binding from the bent contact bar would not have prevented the relay from
energizing, and valve FCV-1424 would have performed its safety function. The inspectors
questioned the licensees operability conclusions given only a visual examination of the relay
and inquired to the status of the other 10 relays received in the same purchase order. An
extent of condition was performed on the B MDAFW pump and no issues were noted on that
relay. Work orders have been initiated to inspect the remaining relays installed in the plant.
In response to additional inspector questions, the licensee sent the relay out for forensic
testing in May, 2019. The testing could not replicate the failure, however there was evidence
of gouge marks on the bent contact that could have been caused by a screwdriver or other
tool used during installation. Based on the results of the forensics testing, the inspectors
concluded the licensees determination that the A MDAFW pump would have performed its
safety function was adequate. While the licensees final corrective actions were adequate,
the inspectors determined that the initial cause evaluation and investigative process lacked
technical rigor. The initial failure determination (manufacturing defect) proved to be incorrect
and was not challenged internally so no initial extent of condition was performed, and the
defective relay was replaced without further investigation or corrective action. Through
inspector follow-up the licensee subsequently applied the appropriate level of technical rigor
to the investigation.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure.
- On October 16, 2019, the inspectors presented the integrated inspection results to
Ms. Nicole Flippin, General Plant Manager, and other members of the licensee staff.