IR 05000261/2020010
| ML20078M212 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/18/2020 |
| From: | Randy Musser NRC/RGN-II/DRP/RPB3 |
| To: | Kapopoulos E Duke Energy Progress |
| References | |
| IR 2020010 | |
| Download: ML20078M212 (10) | |
Text
March 18, 2020
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2020010
Dear Mr. Kapopoulos:
On February 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your H. B. Robinson Steam Electric Plant and discussed the results of this inspection with Mr. David Hoffman and other members of your staff.
The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations were identified during this inspection.
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. Jr.
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000261 License No. DPR-23
Enclosure:
As stated
REGION II==
Inspection Report Enclosure Docket Number:
05000261 License Number:
DPR-23 Report Number:
05000261/2020010 Enterprise Identifier: I-2020-010-0018 Licensee:
Duke Energy Progress, LLC Facility:
H. B. Robinson Steam Electric Plant Location:
Hartsville, SC Inspection Dates:
February 10, 2020 to February 27, 2020 Inspectors:
J. Bundy, Operations Engineer M. Fannon, Senior Resident Inspector A. Patz, Resident Inspector, Harris, Team Leader C. Rapp, Senior Project Engineer J. Viera, Operations Engineer 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 a biennial problem identification and resolution 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted an in-depth review of the low head safety injection and residual heat removal system, the component cooling water system, and the auxiliary feedwater system.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B
1. Corrective Action Program Effectiveness
Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.
Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating Nuclear Condition Reports (NCRs) as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program, and managements expectation that employees were encouraged to initiate NCRs for any reason. Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of selected systems, the inspectors determined that deficiencies were being identified and placed in the CAP.
Prioritization and Evaluation of Issues: Based on the review of NCRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the NCR significance determination guidance in procedure AD-PI-ALL-0100. The inspectors determined that in general, adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and cause determinations were appropriate and considered the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate NCRs depending on the type and complexity of the issue consistent with the applicable cause evaluation procedures.
Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed performance indicators, NCRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
2. Operating Experience, Self-Assessments, and Audits
The inspectors examined the licensee's program for obtaining and using industry operating experience. This included review of procedure AD-PI-ALL-0400, "Operating Experience Program," selected corrective program action requests, and the licensees operating experience (OE) database to assess the effectiveness of how external and internal OE data was handled at the plant. Additionally, the inspectors selected OE documents such as NRC generic communications, licensee event reports, vendor notifications, and plant internal OE items which had been issued since March 2018 to verify whether the licensee had appropriately evaluated each notification for applicability to Robinson, and whether issues identified through these reviews were entered into the CAP.
The team determined that stations processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.
3. Safety-Conscious Work Environment
Based on a sample size of approximately 20 people interviewed from a cross-section of plant employees, the team found no evidence of challenges to a safety-conscious work environment. Employees interviewed appeared willing to raise nuclear safety concerns through at least one of the several means available.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 27, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. David Hoffman and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective
Action
Documents
Action
Requests
2156490, 02178980, 02192058,
2193484, 02194236, 02197606,
2197607, 02197748, 02198518,
202042, 02217759, 02218097,
222785, 02225270, 02228410,
231665, 02232982, 02237092,
239634, 02240328, 02242373,
242377, 02242426, 02242965,
243290, 02243912, 02249325,
250599, 02251957, 02252861,
253768, 02253792, 02255279,
255622, 02255623, 02258832,
261219, 02263625, 02266401,
274269, 02274616, 02274681,
276862, 02277085, 02277990,
278147, 02279133, 02281818,
281978, 02281986, 02292067,
298795, 02298836, 02300384,
2308401, 02308402, 02308558
Corrective
Action
Documents
Resulting from
Inspection
Error in OST-253, completed on 10/29/18
2/11/2020
WO 20090299 Could Not Be Located
2/13/2020
Engineering
Changes
Replace R-24-Rec
Revision 0
Crouse-Hinds Electrical Penetrations
Testing Documentation
Revision 0
Procedures
AD-EG-ALL-
21
Hot Work Permits
Revision 8
AD-OP-ALL-
202
Aggregate Operator Impact Assessment
Revision 2
AD-PI-ALL-
0100
Corrective Action Program
Revisions
through
AD-PI-ALL-
0101
Root Cause Evaluation
Revision 6
AD-PI-ALL-
0106
Cause Investigation Checklists
Revision 1
AD-PI-ALL-
0108
Performance Analysis
Revision 1
AD-SY-ALL-
0460
Managing Fatigue and Work Hour Limits
Revision 3
APP-051
Manholes M36 and M35 Sump Pump
Control Panel
Revision 4
FHP-003
Fuel Assembly Movement in the Spent Fuel
Pit
Revisions
and 58
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OMM-007
Equipment Inoperable Record
Revision
113
OST-251-1
RHR Pump A and Components Test,
completed on December 11, 2019
OST-251-2
RHR Pump B and Components Test,
completed on January 21, 2020
OST-252-1
RHR System Valve Test - Train A,
completed on December 11, 2019
OST-252-2
RHR System Valve Test - Train B,
completed January 21, 2020
OST-253A
A RHR Comprehensive Flow Test,
completed on November 29, 2018
OST-253B
B RHR Comprehensive Flow Test,
completed on November 13, 2018
PLP-069
Emergency Response Equipment
Responsibilities
Revision 31
Control Room Integrated In-Leakage Tracer
Test
Revision 8
Self-
Assessments
AD-SY-ALL-0460 Fatigue Rule Annual
Review for 2018
2/28/2019
AD-SY-ALL-0460 Annual Effectiveness
Review for 2019
01/21/2020
RNP-CHM-
1497.02-2018-
RNP Performance Trending Report -
Chemistry
2nd
Trimester
2018
RNP-MNT-
1497.-2-2018-2
Performance Trending Report -
Maintenance
2nd
Trimester
2018
RNP-OPS-
1497.02-2018-
RNP Operations Trending Report 1T-2018
06/07/2018
RNP-OPS-
1497.02-2018-
RNP Operations Trending Report 2T-2018
11/27/2018
RNP-OPS-
1497.02-2018-
RNP Operations Trending Report 3T-2018
2/07/2019
RNP-OPS-
1497.02-2019-
RNP Operations Trending Report 1T-2019
06/10/2019
RNP-OPS-
1497.02-2019-
RNP Operations Trending Report 2T-2019
10/14/2019
Work Orders
20016059, 20089935, 20211461,
224114, 20295857, 20296285, 20301885