IR 05000261/2024004
| ML25041A115 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/10/2025 |
| From: | Katie Mccurry NRC/RGN-II/DORS/PB2 |
| To: | Basta L Duke Energy Progress |
| References | |
| EPID I-2024-004-0022 IR 2024004 | |
| Download: ML25041A115 (1) | |
Text
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000261/2024004
Dear Laura Basta:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at H.B. Robinson Steam Electric Plant. On January 21, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant.
February 10, 2025 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Katherine H. McCurry, Chief Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000261 License No. DPR-23
Enclosure:
As stated
Inspection Report
Docket Number:
05000261
License Number:
Report Number:
Enterprise Identifier:
I-2024-004-0022
Licensee:
Duke Energy Progress, LLC
Facility:
H.B. Robinson Steam Electric Plant
Location:
Hartsville, SC
Inspection Dates:
October 01, 2024, to December 31, 2024
Inspectors:
J. Bell, Senior Health Physicist
J. Diaz-Velez, Senior Health Physicist
C. Dorman, Resident Inspector
S. Downey, Senior Reactor Inspector
E. Magnuson, Reactor Inspector
D. Restrepo, Health Physicist
J. Zeiler, Senior Resident Inspector
Approved By:
Katherine H. McCurry, Chief
Projects Branch 2
Division of Operating Reactor Safety
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.
List of Findings and Violations
Failure to Survey Containment Ductwork Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000261/2024004-01 Open/Closed
[H.11] -
Challenge the Unknown 71124.01 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 20.1501, Surveys and Monitoring, when the licensee failed to identify and appropriately control a high contamination area. Specifically, on November 19, 2024, the inspectors discovered that an area of the containment vessel readily accessible to personnel did not have current survey data. When surveyed, it was determined that this area was a high contamination area, requiring certain posting and controls per licensee procedure.
Failure to Implement Alpha Monitoring Program Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000261/2024004-02 Open/Closed
[H.8] -
Procedure Adherence 71124.01 The inspectors identified a Green finding and associated NCV of Technical Specification 5.4.1, Procedures, for the licensee's failure to implement several portions of its alpha monitoring procedure during work with a component having significant alpha contamination.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000261/2024010-01 Service Water Design Basis for Isolation of Passive Failures 71152B Closed
PLANT STATUS
Unit 2 began the inspection period operating at rated thermal power (RTP). On November 4, 2024, the unit was down powered to 90 percent (%) to conduct scheduled main steam safety valve (MSSV) testing. The unit remained at 90% power until November 5, 2024, when the unit was shutdown for a scheduled refueling outage. The unit was restarted on December 4, 2024, following the refueling outage and returned to RTP on December 9, 2024. The unit remained at or near RTP 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions associated with cold temperatures for the following systems and/or areas:
- motor driven auxiliary feedwater (MDAFW) and steam driven auxiliary feedwater (SDAFW) systems from December 4 through December 19, 2024
- turbine building freeze protection equipment on December 19, 2024
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'A' MDAFW pump and SDAFW pump while 'B' MDAFW pump was being tested in accordance with OST-201-1 on October 8, 2024 (2)
'A' spent fuel pool cooling (SFPC) pump and heat exchanger on October 25, 2024, while 'B' SFPC pump was out of service for emergent replacement of pump bearing and motor due to elevated vibrations
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)safety injection and containment spray pump room (fire zone 3) on October 14, 2024 (2)
'B' emergency diesel generator (EDG) room (fire zone 1) on October 22, 2024 (3)containment vessel all elevations (fire zone 24) during refueling outage R2R34 on November 11, 2024 (4)main steam safety valve (MSSV), main steam isolation valve, and steam generator power operated relief valve gallery area (fire zone 25G) on December 4, 2024 (5)auxiliary building pipe alley areas (fire zone 11) on December 18, 2024
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)
'A' component cooling water (CCW) heat exchanger cleaning, eddy current testing, and tube plugging during the weeks of November 17 and 24, 2024
===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation, and repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities in Unit 2 during refueling outage R2R34 from November 11 to 15, 2024.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified the following nondestructive examination and welding activities were performed appropriately:
(1)
- Liquid Penetrant Examination o
204/AWS-1-ATT, welded attachment, ASME Class 2 o
W-2, fitting to fitting weld, ASME Class 2. This included a review of the associated welding activities.
- Ultrasonic Examination o
107A/07, Loop B crossover leg pipe to elbow weld, ASME Class 1 o
107B/11, Loop C cold leg reactor coolant pump to pipe weld, ASME Class 1 o
122/3-RC-2501R-25, alternate charging pipe, ASME Class 1 o
Core barrel upper girth weld indications, ASME Core Support Structure
- Visual Examination o
Bare metal visual of reactor pressure vessel bottom-mounted instrumentation penetrations, ASME Class 1 o
EVT-1 and VT-3 of core barrel, ASME Core Support Structure PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection
Activities (IP Section 03.02) (1 Sample)
The inspectors verified the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:
(1)
- Ultrasonic examination of reactor vessel head nozzles and partial penetration welds, ASME Class 1
- Eddy current examination of the reactor vessel head RVLIS (Reactor Vessel Level Instrumentation System) penetration, ASME Class 1
- Eddy current examination of reactor pressure vessel head vent line penetration, ASME Class 1 PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors evaluated the licensees boric acid control program performance, which included the following activities:
(1)
- Boric Acid Walkdown - November 12, 2024
- Review of the following boric acid evaluations (by condition report number):
o Nuclear Condition Report (NCR) 0244653201 o
NCR 0245406802 o
NCR 0245433201 o
NCR 0247997201 o
NCR 0247997401
- Review of the following corrective actions performed for evidence of boric acid leaks that were identified (by work request (WR) number):
o WR 20235579 o
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
The licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." The inspector performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program and Licensed Operator Performance." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP
===71111.11.
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam completed on February 29, 2024.
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 the following activities:
- down power to 98.5 RTP and restoration to full power to conduct 'B' MDAFW pump testing on October 8, 2024
- shutdown to commence refueling outage R2R34 on November 4 and 5, 2024
- reactor restart and physics testing from refueling outage R2R34 on December 4 and 5, 2024 Licensed Operator Requalification Training/Examinations (IP Section 03.02)===
- (1) The inspectors observed and evaluated licensed operator simulator based just-in-time training for the upcoming refueling outage shutdown on October 23 and 24, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)engine driven fire pump failed during performance of surveillance test on May 16, 2024 (NCR 2516573)
(2)north service water header low pressure switch PSL-1616B failed to actuate during calibration testing on October 17, 2024 (NCR 2532041)
(3)control relay failure associated with the SDAFW pump undervoltage actuation circuitry during testing on November 27, 2024 (NCR 2536888)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)elevated risk (Green) during emergent troubleshooting to repair turbine overspeed trip protection solenoid valve EV-4459B and EV-4459D failures on October 7, 2024 (2)elevated risk (Yellow) during refueling outage R2R34 for reactor coolant system drain down to lowered inventory conditions to support disassembly and removal of the reactor vessel head on November 6, 2024 (3)elevated risk (Green) during refueling outage R2R34 for reactor restart activities on December 4 and 5, 2024 (4)elevated risk (Green) during planned replacement and testing of main control room containment pressure indicators for PI-951 and PI-950A on December 11, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2523518, 'B' service water pump horizontal pump vibration point in the alert range during testing with continued increasing trend identified on July 25, 2024
- (2) NCR 2532907, elevated pump/motor vibrations identified on 'B' SFPC pump on October 23, 2024
- (3) NCR 2535771, disposition of refueling outage R2R34 core barrel inservice inspection (ISI) examination results on November 17, 2024
- (4) NCR 2536888, high fan motor outboard bearing vibrations identified on containment cooling fan HVH-2 during testing on November 24, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following permanent modifications:
(1)engineering change (EC) 423857, reactor vessel core barrel upper girth weld flaw mitigation actions, implemented during refueling outage R2R34
- (2) EC 419005, motor driven and steam driven auxiliary feedwater flow indicating controller replacement for FIC-1424, FIC-1425, and FIC-6416, implemented during refueling outage R2R34
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage R2R34 activities from November 5, 2024, to December 6, 2024.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
- (1) OST-551-2, Turbine Trip Functional Test, following corrective maintenance to manually cycle turbine overspeed trip solenoid operated valves EV-4459B and EV-4459D on October 7, 2024
- (2) OST-201-2, MDAFW System Component Test - Train B, following periodic grease inspection of Limitorque actuator associated with valve AFW-V2-16C on October 8, 2024
- (3) Work Order 20692663 instructions to verify proper operation of 'B' SFPC pump and confirm adequate pump/motor vibrations and bearing temperatures, following motor and pump bearing replacement on October 31, 2024
- (4) EST-028, Main Steam Safety Valve Testing, following refueling outage refurbishment of MSSVs SV1-2A, SV1-4A, SV1-1B, SV1-1C, and SV1-3C on December 4, 2024
- (5) Work Order 20560861 instructions to calibrate and verify proper operation of containment pressure indicators PI-951 and PI-950A on the main control board, following indicator replacement on December 11, 2024
- (6) OP-301C, Chemical and Volume Control System Charging Pump C Operation, and OST-101-3, CVCS Component Test Charging Pump C, following primary seal leakage maintenance repairs on December 19, 2024
Surveillance Testing (IP Section 03.01) (5 Samples)
- (1) EST-124, Response Time Testing of Reactor Coolant System RTDs, on October 24, 2024
- (2) OST-163, Safety Injection Test and Emergency Diesel Generator Auto Start on Loss of Power and Safety Injection on November 6 and 7, 2024
- (3) OST-410, Emergency Diesel Generator A 24 Hour Load Test on November 22 and 23, 2024
- (5) EST-050, Refueling Startup Procedure on December 4 and 5, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) EST-028, Main Steam Safety Valve Testing on November 4, 2024
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) OST-933-5, Penetration 44 SI-891A (Containment Spray Header A Supply Line) Leakage Test on November 18,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers exiting the containment contaminated area (CA) during the refueling outage
- (2) Workers exiting the radiologically controlled area (RCA) during the refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Waste water demineralizer system filter change out (2)1SI-860A valve work in residual heat removal (RHR) pump pit
- (3) Reactor core barrel repair work activities
- (4) Reactor coolant filter change out High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
(1)
- 1 auxiliary sump room locked high radiation area (LHRA)
- (2) Reactor head storage LHRA
- (3) Waste holdup tank room LHRA
- (4) Radwaste bunker LHRA
- (5) Containment sump very high radiation area (VHRA)
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (2) Auxiliary Building Ventilation System
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Internal Dose Assessment exposure date 12/01/2022
- (2) Internal Dose Assessment exposure date 10/15/2024
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Declared Pregnant Worker #1 (030117767)
- (2) EDEX Multi-Pack IDs: 5651
- (3) EDEX Multi-Pack IDs: 5652
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) R-14 plant vent gas radiation monitor, channels C (normal range), D (mid-range), and E (high-range)
- (2) R-33 monitor building (building for R-14)
- (3) R-1 control room area radiation monitor
- (4) Telepoles, EnRad #07583, 02114, and 07505, radiologically controlled area
- (5) Ludlum 9-3, Ion Chamber, EnRad #2044, 10055, and 11433
- (6) R-18 liquid radwaste radiation monitor, located in the auxiliary building
- (7) R-6 area radiation monitor, located in the primary coolant sampling room (8)iCAM continuous air monitor, EnRad #13245, located in the auxiliary building
- (9) R-3 area radiation monitor, located in the auxiliary building
- (10) R-17 component cooling water area radiation monitor, located in the auxiliary building
Calibration and Testing Program (IP Section 03.02) (15 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Canberra, Argos 5AB, EnRad # 12905, calibrated on 07/24/2023 and 07/23/2024
- (2) Canberra, Argos 5AB, EnRad # 12906, calibrated on 07/24/2023 and 07/23/2024
- (3) Canberra, GEM 5, EnRad #13358, calibrated on 07/24/2023 and 07/22/2024
- (4) Canberra, GEM 5, EnRad #13357, calibrated on 07/24/2023 and 07/22/2024
- (5) Canberra, Cronos-4, EnRad #13622, calibrated on 11/13/2023 and 09/30/2024
- (6) Canberra, Cronos-4, EnRad #13620, calibrated on 11/13/2023 and 09/30/2024
- (7) R-32 A Containment High Range Radiation Monitor, calibrated 02/21/2021 and 02/17/2023
- (8) R-32 B Containment High Range Radiation Monitor, calibrated 02/21/2021 and 02/16/2023
- (9) Mirion Apex In-Vivo Fastscan RNPFS1 Whole-body counter, calibrated 05/17/2023 and 05/09/2024
- (10) Mirion Apex In-Vivo Fastscan RNPFS2 Whole-body counter, calibrated 05/17/2023 and 05/08/2024
- (11) ROTEM, Telepole, EnRad #07496 and 02128, calibrated 10/01/2024 and 01/23/2024 (respectively)
- (12) Thermo AMS-4 Continuous Air Monitor, EnRad #02255, and 10249, calibrated 03/14/2024 and 03/19/2024 (respectively)
- (13) Ludlum 9-3, Ion Chamber, EnRad #07665, and 12099, calibrated 09/10/2024
- (14) Canberra, iCAM, EnRad #13244, calibrated 02/06/2024
- (15) Ludlum 177, EnRad #07061, calibrated 06/03/2024 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) R-18 liquid radwaste radiation monitor, calibrated 11/10/2022 and 06/03/2024
- (2) R-14 plant vent gas radiation monitor, channels C (normal range), D (mid-range), and E (high-range), calibrated 11/17/2021 and 07/25/2023
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06)===
- (1) Unit 2 (October 1, 2023, through September 30, 2024)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 2 (October 1, 2023, through September 30, 2024)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) Unit 2 (July 28, 2023, through December 10, 2024)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) Unit 2 (July 28, 2023, through December 10, 2024)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Unscheduled unit down power to less than 50% RTP on June 5, 2024, due to MSSV SV1-1C being declared inoperable for nozzle ring set screw configuration issue (NCRs 2518479 and 2518504)
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in equipment reliability or human performance that might be indicative of a more significant safety issue. The inspectors did not identify a negative trend that could lead to a more significant safety issue.
INSPECTION RESULTS
Failure to Survey Containment Ductwork Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000261/2024004-01 Open/Closed
[H.11] -
Challenge the Unknown 71124.01 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 20.1501, Surveys and Monitoring, when the licensee failed to identify and appropriately control a high contamination area. Specifically, on November 19, 2024, the inspectors discovered that an area of the containment vessel readily accessible to personnel did not have current survey data. When surveyed, it was determined that this area was a high contamination area (HCA), requiring certain posting and controls per licensee procedure.
Description:
On November 19, 2024, inspectors were performing a walkdown of the Robinson containment vessel and found an unmarked door unlocked and readily accessible for personnel access. Opening the door revealed that it was an entrance to a large containment ventilation ductwork, about the height and width of a small corridor. The inspectors questioned site radiation protection personnel as to the radiological conditions within the ductwork. Radiation protection personnel were unable to locate recent survey data in response to the inquiry, so a radiation and contamination survey of the ductwork was performed. The survey revealed contamination levels within the ductwork consistently ranging from 200,000 to 250,000 dpm/100 cm2 of beta-gamma. Upon receipt of these survey results, it was recognized that, per licensee procedure AD-RP-ALL-0004, Radiological Posting and Labeling, the duct area meets the definition of an HCA. Previously, it had been considered a contaminated area (CA), being a part of containment which was posted as a CA in its entirely.
An HCA requires additional postings and controls per licensee procedure, including additional dress-out requirements. Upon completion of the survey and the identification of the area as an HCA, the site brought the area into compliance with these requirements in a timely manner.
Corrective Actions: The site performed a survey of the area in question. In consideration of the survey results, the site upgraded its posting and controls of the area to an HCA, including a step off pad and additional dress-out requirements. Additionally, it was recognized that this area was not included in licensee procedure HPP-002, Containment Vessel Surveillance Program, which specifies frequencies at which surveys of areas of containment are required.
A procedure revision request was initiated to add this area to procedure HPP-002.
Corrective Action References: NCR 02538277
Performance Assessment:
Performance Deficiency: The failure of the licensee to recognize, post, and control an HCA per licensee procedure AD-RP-ALL-0004 is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, this issue represents a weakness in the licensee's survey program which was significant enough to allow a hazard to exist unrecognized.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. Specifically, this violation was determined to be of very low safety significance (Green) because it was not associated with an overexposure, a substantial potential for overexposure, compromised ability to assess dose, or planning to receive as low as reasonably achievable (ALARA) doses.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the area in question was allowed to exist for some time without site personnel knowing or questioning the radiological conditions therein.
Enforcement:
Violation: 10 CFR 20.1501 states, in part, that each licensee shall make or cause to be made surveys of areas that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations or quantities of residual radioactivity, and the potential radiological hazards of the radiation levels and residual radioactivity detected.
Contrary to the above, on November 19, 2024, the NRC identified an area of the Robinson containment vessel accessible to personnel which did not have current survey information.
Upon surveying the area, it was identified that the area contained 200,000-250,000 dpm/100 cm2 of smearable contamination. This hazard was previously unknown to and not appropriately controlled by the licensee.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Implement Alpha Monitoring Program Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000261/2024004-02 Open/Closed
[H.8] -
Procedure Adherence 71124.01 The inspectors identified a Green finding and associated NCV of Technical Specification 5.4.1, Procedures, for the licensee's failure to implement several portions of its alpha monitoring procedure during work with a component with significant alpha contamination.
Description:
During refueling outage R2R34, licensee personnel performed maintenance on valve 1SI-860, a large containment sump recirculation suction valve located in the residual heat removal (RHR) pump pit. On November 16, 2024, the internals of 1SI-860 were removed for maintenance. This work constituted a system breach of the RHR system, which by licensee procedure, is considered to be alpha level II work. However, the work was performed on a non-alpha II radiological work permit (RWP), which is contrary to licensee procedure. The RWP stated that expected work conditions were less than 20 dpm/100cm2 alpha, and that work should be stopped if greater than expected contamination was encountered. Upon unbolting and removing the valve bonnet, radiation protection technicians surveyed the valve internals for contamination. The valve internals were also decontaminated in situ before being removed and bagged for transportation to the hot machine shop. The contamination surveys indicated significant alpha contamination--up to 1102 dpm and an alpha to beta gamma ratio of as low as 215, classifying the valve internals as an alpha level III component, the most significant ratio of alpha contamination. This was greater than expected alpha contamination per the RWP in use; however, at no point was work stopped due to elevated alpha contamination levels. A post decontamination survey was performed, indicating that beta-gamma contamination had been reduced significantly by the decontamination efforts (down to 10,000 dpm/100cm2 from 200,000 dpm/100cm2), however, this survey did not include taking alpha smears to verify the reduction in the alpha component of the contamination. This is contrary to licensee procedure AD-RP-ALL-2014, Work in Alpha Environments, which requires that if decontamination is used to take credit for reducing alpha level of an area or component, then a post decontamination survey for alpha must be performed and documented. At no time during the work with 1SI-860 internals was the component recognized by the site as an alpha level II or III hazard (with the site effectively taking credit for the above-mentioned decontamination efforts as justification for considering the work to be alpha level I). Because the alpha level status of the component post decontamination is unknown, it is impossible to know if certain controls, such as additional air sampling, labeling, and survey requirements, which are required by licensee procedure for higher alpha level work, were required to be in place. Workers at the RHR pit were wearing powered air purifying respirators during the work activity. After removal from the RHR pit, the licensee transported the valve internals to the hot machine shop, where welding and milling were performed on the valve stem. The component was then taken back to the RHR pit where it was reinstalled. At no time during this sequence of events was a documented alpha survey of the valve internals performed, nor were the internals recognized as an alpha level II or III hazard. There were no internal or external personnel contamination events identified as a result of this work.
Corrective Actions: NCR 02538405 was written. Alpha smear surveys have been conducted in the applicable work areas since the event, which have come back negative for alpha contamination.
Corrective Action References: NCR 02538405
Performance Assessment:
Performance Deficiency: The failure of the licensee to implement its procedure for work in alpha environments, AD-RP-ALL-2014, is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. Specifically, alpha contamination controls are required to be in place due to the hard to detect nature and high internal toxicity of alpha emitters. Without these controls in place, it raises the likelihood of an internal contamination event which is either difficult to detect or quantify, or significant in dose received.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. Specifically, this violation was determined to be of very low safety significance (Green) because it was not associated with an overexposure, a substantial potential for overexposure, compromised ability to assess dose, or ALARA planning.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, multiple elements of the licensee's alpha monitoring procedure and/or alpha characterization were either not understood or not followed.
Enforcement:
Violation: Per Technical Specification 5.4.1, Procedures, the site will develop, implement and maintain procedures for radiation protection including contamination control and RWPs.
Licensee procedure AD-RP-ALL-2014, Work in Alpha Environments, states, in part, that work in alpha II or III environments will be performed on an appropriate RWP and that if decontamination of a component with alpha activity is performed, then a post decontamination survey will be conducted to verify the reduction in alpha level. Contrary to the above, on November 16, 2024, the licensee performed an RHR system breach, which is considered alpha level II work per the site's alpha characterization, on an RWP which specifically excluded alpha level II work. The valve internals which were removed initially showed alpha level III contamination levels but were assumed to be alpha level I after decontamination, however the requisite post decontamination survey confirming the decrease in alpha level was not performed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Very Low Safety Significance Issue Resolution Process: Service Water Design Basis for Isolation of Passive Failures 71152B This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.
Description:
Unresolved item (URI)05000261/2024010-01 was opened regarding the passive failure design of the service water system and whether adequate flow would be assured to the minimum set of equipment following the failure of a pipe or valve body during the recirculation portion of an accident. Inspector follow-up actions included determining whether the normally open auxiliary building north and south supply header cross-connect valves, SW-18 and SW-19, were being used as supply header isolation valves that should have remote isolation capability per the Updated Final Safety Analysis Report (UFSAR)section 9.2.1.2. Additionally, inspectors were to evaluate statements in a 1993 Service Water System Operational Performance Inspection (SWSOPI) report (ML14182A250) to determine if any NRC staff positions were previously established concerning the accuracy of the licensee's translation of the design bases into procedures and drawings. The licensee provided inspectors with a position paper on these issues.
Licensing Basis: The licensee recognized that the subject manual valves, SW-18 and SW-19, were discussed in internal design related documents as being normally closed to satisfy passive failure design criteria prior to receiving an operating license; however, the facility has operated with these manual valves normally open since 1970 to aid with flow balancing between the serviced components such as containment air recirculation units and emergency diesel generators. No internal or external correspondence from the period of initial operation was located that explained the deviation or whether remote isolation capability should have been added to resolve the conflicting design and operational needs.
The licensees UFSAR describes the service water systems design basis as requiring two independent and redundant supply lines and that all supply header isolation valves are motor operated and controlled remotely via the control room. The licensees current procedure OP-903, Service Water System, and design drawings designate:
1. motor-operated valves SW-V6-12A and SW-V6-12D, located in the intake structure,
as South/North Service Water Header Supply valves;
2. motor-operated valves SW-V6-12B and SW-V6-12C, located in the intake structure,
as SW Pump Discharge Header Cross-Connect valves; and
3. manually operated valves SW-18 and SW-19, located in the auxiliary building, as
North & South Supply Header Cross-Connect (Chain Operated) valves.
A rupture upstream of SW-V6-12A and SW-V6-12D, requires closure of SW-V6-12B and SW-V6-12C in accordance with the licensee's procedure, AOP-022 for "Loss of Service Water," to begin separating the system into two independent headers. Similarly, SW-18 and SW-19 serve to cross-connect and isolate the north and south supply headers from each other in the auxiliary building, but the term "supply header isolation valve" was not used in licensee's procedures, nor explicitly defined in the UFSAR. In conclusion, the UFSAR did not specify the normal position of SW-18 and SW-19 or whether remote isolation capability was necessary for these valves. Additionally, since a performance deficiency was not established, review of the 1993 SWSOPI inspection report for any contrary staff positions was unnecessary.
Significance: For the purpose of the VLSSIR process, the inspectors screened the issue of concern through IMC 0609, Appendix A, and determined the issue of concern would likely be Green, very low safety significance, had a performance deficiency been identified since the service water system would maintain its PRA functionality when considering the viability of local operator recovery actions, the high capacity of the service water pumps, the low pressure of the system, and the ability to maintain flow for the most likely sized piping failures.
Corrective Action Reference: NCR 2510239 This item closes URI 05000261/2024010-01.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 21, 2025, the inspectors presented the integrated inspection results, including the URI closure, to Laura Basta and other members of the licensee staff.
- On November 15, 2024, the inspectors presented the baseline ISI inspection results to George Curtis, Plant Manager, and other members of the licensee staff.
- On December 12, 2024, the inspectors presented the radiation protection baseline inspection results to Laura Basta and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-WC-ALL-
230
Seasonal Readiness
Rev. 2
AP-015
Portable Heaters/Heating Devices Issuance and Inspection
Rev. 25
EDP-009
Freeze Protection Panels
Rev. 85
Procedures
Cold Weather Operation
Rev. 87
Auxiliary Feedwater System
Rev. 120
Procedures
Spent Fuel Pit Cooling and Purification System
Rev. 52
CSD-RNP-PFP-
AB2-0226-001
Auxiliary Building Elevation 226 Pre-Fire Plan
Rev. 3
CSD-RNP-PFP-
AB2-0246-001
Auxiliary Building Elevation 246 Pre-Fire Plan
Rev. 1
CSD-RNP-PFP-
CV2-0000-001
Containment Vessel Pre-Fire Plan
Rev. 1
Fire Plans
CSD-RNP-PFP-
TB2-0267-001
Turbine Building Elevation 267 Pre-Fire Plan
Rev. 0
AD-FP-ALL-1520
Transient Combustible Control
Rev. 2
AD-FP-ALL-1551
Fire Protection Impairments
Rev. 2
Fire Protection Systems Minimum Equipment and
Compensatory Measures
Rev. 40
Procedures
OMM-002
Fire Protection Manual
Rev. 59
Procedures
CM-201
Safety Related and Non-Safety Related Heat Exchanger
Maintenance
Rev. 61
'A' CCW heat exchanger eddy Current testing
11/19-
2/2024
Work Orders
'A' CCW heat exchanger cleaning and tube plugging
11/19-
2/2024
Miscellaneous
H.B. Robinson Unit 2 R2R34 Steam Generator Skipped
Inspection Cycle Assessment
Revision 0
180-9385555-000
H.B. Robinson Unit 2 Automated Phased Array Core Barrel
Examination
11/18/2024
180-9385599-000
Robinson Unit 2 (R2R34) RVCH Examination Final Report
11/14/2024
NDE Reports
PT-24-001
Liquid Penetrant Examination of 204/AWS-1-ATT, Welded
11/17/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
UT-24-002
Ultrasonic examination of 107B/11, Loop "C" Cold Leg RCP
to Pipe
11/17/2024
UT-24-004
Ultrasonic examination of 107A/07, Loop "B" Crossover Leg
Pipe to Elbow
11/14/2024
UT-24-005
Ultrasonic Examination of 122/3-RC-2501R-25, Pipe
11/17/2024
VT-24-009
Visual Examination of Bottom Mounted Instrumentation
11/11/2024
AD-OP-ALL-1000
Conduct of Operations
Rev. 25
Procedures
GP-006-1
Normal Plant Shutdown from Power Operation to Hot
Standby
Rev. 28
Procedures
AD-EG-ALL-1210
Rev. 5
AD-OP-ALL-0210
Operational Risk Management
Rev. 4
AD-WC-ALL-
200
On-Line Work Management
Rev. 22
AD-WC-ALL-
240
On-Line Risk Management Process
Rev. 6
AD-WC-ALL-
20
Shutdown Risk Management
Rev. 8
AD-WC-RNP-
20
Shutdown Safety Function Guidelines
Rev. 28
Procedures
CSD-WC-RNP-
240-00
Rev. 1
Procedures
AD-OP-ALL-0105
Rev. 7
AD-EG-ALL-1110
Design Review Requirements
Rev. 11
AD-EG-ALL-1122
Failure Modes and Effects Analysis and Single Failure
Analysis
Rev. 2
AD-EG-ALL-1132
Preparation and Control of Engineering Changes
Rev. 28
Procedures
AD-EG-ALL-1137
Engineering Change Product Selection
Rev. 12
FHP-003
Fuel Assembly Movement in the Spent Fuel Pool
Rev. 72
FMP-019
Fuel and Insert Shuffle
Rev. 61
GP-001
Fill and Vent of the Reactor Coolant System
Rev. 80
Procedures
GP-002
Cold Shutdown to Hot Subcritical at No Load TAVG
Rev. 151
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
GP-003
Normal Plant Startup from Hot Standby to Critical
Rev. 118
GP-005
Power Operations
Rev. 151
GP-006-1
Normal Plant Shutdown from Power Operation to Hot
Standby
Rev. 28
GP-007
Plant Cooldown from Mode 3 to Mode 5
Rev. 121
GP-008
Draining the Reactor Coolant System
Rev. 100
GP-009-3
Draining the Refueling Cavity with Fuel in the Reactor
Vessel
Rev. 20
GP-009-5
Adjusting Reactor Vessel Level After Refueling Cavity Drain
with Fuel in the Reactor
Rev. 14
GP-010
Refueling
Rev. 106
PLP-006-1
Containment Vessel Inspection and Closeout
Rev. 27
Procedures
PLP-033
Post-Maintenance Testing (PMT) Program
Rev. 70
Corrective Action
Documents
NCRs 02503852,
2509342,
2531877
NCR 2538275
NCR 2538276
NCR 2538277
Corrective Action
Documents
Resulting from
Inspection
NCR 2538405
AD-RP-ALL-0002
AD-RP-ALL-0004
Procedures
AD-RP-ALL-2014
RNP-M-
241117-3
Radiation
Surveys
RNP-M-
241120-17
Radiation Work
Permits (RWPs)
RWP 2518 Task
Corrective Action
Documents
NCR 02536300
Corrective Action
Documents
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
AD-RP-ALL-0003
Radiological Air Sampling
Revision 4
EST-023
Control Room Emergency Ventilation System
Revision 26
Procedures
HPP-RWT-002
Use of HEPA Filtration Units and Vacuum Cleaners
Revision 6
20515618 01
EST-023 Control Room Emergency Ventilation System Test
2/28/2022
Work Orders
20626148 01
EST-023 Control Room Emergency Ventilation System Test
11/20/2024
Corrective Action
Documents
NCRs 02451573,
2459047, and
2462962
Various
Corrective Action
Documents
NCRs 02450433,
2451577,
2453360,
2455457,
2471017,
2475086, and
2475472
Various
AD-EG-ALL-1217
Mitigating System Performance Indicator (MSPI)
Rev. 3
71151
Procedures
AD-PI-ALL-0700
Performance Indicators
Rev. 6
AD-PI-ALL-0100
Corrective Action Program
Rev. 30
Procedures
AD-PI-ALL-0106
Cause Investigation Checklists
Rev. 10