IR 05000261/2025002
| ML25203A185 | |
| Person / Time | |
|---|---|
| Site: | Robinson, 07200003  (DPR-023) |
| Issue date: | 07/24/2025 |
| From: | Matthew Fannon NRC/RGN-II/DORS/PB2 |
| To: | Basta L Duke Energy Progress |
| References | |
| IR 2025001 | |
| Download: ML25203A185 (1) | |
Text
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000261/2025002 AND 07200003/2025001
Dear Laura Basta:
On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at H.B. Robinson Steam Electric Plant. On July 17, 2025, the NRC inspectors discussed the results of this inspection with Winston Stewart 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.
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.
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.
July 24, 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, Matthew S. Fannon, Chief Projects Branch 2 Division of Operating Reactor Safety Docket Nos. 05000261, 07200003 License No. DPR-23
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000261 and 07200003
License Number:
Report Numbers:
05000261/2025002 and 07200003/2025001
Enterprise Identifier:
I-2025-002-0018 and I-2025-001-0093
Licensee:
Duke Energy Progress, LLC
Facility:
H.B. Robinson Steam Electric Plant
Location:
Hartsville, SC
Inspection Dates:
April 01, 2025, to June 30, 2025
Inspectors:
B. Bishop, Senior Project Engineer
B. Bowker, Senior Reactor Inspector
J. Bundy, Senior Operations Engineer
C. Dorman, Resident Inspector
K. Lei, Emergency Preparedness Inspector
W. Monk, Senior Reactor Inspector
A. Ponko, Senior Construction Project Inspector
M. Read, Senior Resident Inspector
J. Vasquez, Construction Project Inspector
J. Walker, Senior Emergency Preparedness Inspector
A. Wilson, Senior Project Engineer
J. Zeiler, Senior Resident Inspector
Approved By:
Matthew S. Fannon, 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. A licensee-identified non-cited violation is documented in report section: 71152S.
List of Findings and Violations
Failure to Follow Procedure Step During Reactor Coolant Pump (RCP) Seal Injection Filter Replacement Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2025002-01 Open/Closed
[H.4] -
Teamwork 71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a, Procedures, was identified for the licensees failure to perform a required step of ensuring the A seal injection filter was in service prior to isolating the B seal injection filter which led to isolation of seal injection to all three RCP seals for two minutes.
Failure to Establish and Implement Adequate Procedures to Perform License Renewal Aging Management Inspections of the Refueling Water Storage Tank (RWST) Anchorage System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000261/2025002-02 Open/Closed None (NPP)71152A The inspectors identified a Green finding and associated NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to ensure activities affecting quality were prescribed by documented instructions and procedures appropriate to the circumstance. Specifically, the licensee failed to ensure the instructions prescribed in procedure AD-EG-RNP-1213, RNP Specific Requirements for System Walkdowns, that implemented license renewal aging management periodic structures monitoring of the RWST, included inspection requirements of the tanks metal anchorage system. The lack of periodic monitoring led to active coating discrepancies and corrosion degradations not being identified and addressed in a timely manner.
Additional Tracking Items
None.
PLANT STATUS
Unit 2 began the inspection period operating at rated thermal power (RTP). On June 7, 2025, the unit was down powered to 17 percent to remove the turbine generator from service due to an emergent hydraulic fluid leak from the reservoir of the electro-hydraulic control (EHC)system. Following leak repairs, the unit was returned to RTP on June 10, 2025. The unit operated 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 prior to the onset of hot temperatures and potential summer heavy rains for the following systems:
- onsite emergency diesel generators (EDGs), emergency switchgear, and vital batteries between May 19-30, 2025
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'A' motor driven auxiliary feedwater (MDAFW) pump and the steam driven auxiliary feedwater pump while the 'B' MDAFW pump was out-of-service (OOS) for scheduled safety system maintenance on April 8, 2025 (2)
'B' safety injection (SI) pump while the 'A' SI pump was OOS for scheduled outboard bearing service water cooling preventive maintenance on April 22, 2025 (3)
'A' containment spray (CS) pump while 'B' CS pump was OOS for scheduled pump discharge motor operated valve Limitorque actuator grease inspection and thermal overload testing on May 8, 2025 (4)
'A' EDG while 'B' EDG was OOS for 2-year preventive maintenance on May 19, 2025, and 'B' EDG following restoration on May 21, 2025
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)dedicated shutdown diesel generator building 340 (fire zone 25D) on April 16, 2025 (2)cable spreading room (fire zone 19) and emergency switchgear room (fire zone 20)on April 29, 2025 (3)north and south cable vaults (fire zones 9 and 10) on May 8, 2025
- (4) EDG rooms (fire zones 1 and 2) from May 19-21, 2025 (5)boron injection tank room (fire zone 8) on June 2, 2025
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1)component cooling water (CCW) pump/heat exchanger and boric acid tank room (flood zone FLC050) on April 7, 2025
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (2 Samples)
The inspectors evaluated readiness and performance of:
(1)
'B' MDAFW pump lube oil heat exchanger during scheduled biennial inspection from April 8-9, 2025; and 'A' SI pump outboard bearing oil service water cooling inspection and flush on April 22, 2025 (2)
'B' EDG jacket water, lubricating oil, and aftercooler heat exchangers during scheduled 2-year EDG maintenance activities from May 19-20, 2025
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 risk significant activities:
- planned down power to 97.5 percent RTP to conduct 'A' MDAFW pump and system inservice pressure testing on April 29, 2025
- power range nuclear instrumentation system channel N-41, N-42, N-43, and N-44 quarterly channel operational testing on May 30-31, 2025
- operator actions to address a significant steam valve packing leak from condenser steam dump PRV-1324A-1 while operating at 20 percent RTP with the turbine offline on June 8, 2025
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification simulator evaluation on April 15, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)failure of reactor protection channel II of 'C' steam generator steam flow indicator FI-495 on May 20, 2025 [Nuclear Condition Report (NCR) 2555293]
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)
'B' EDG mechanical, instrumentation and control, electrical, and quality control activities [Work Orders (WOs) 20602085, 20615565, 20685784, 20664718,
===20540565] during scheduled 2-year preventive maintenance from May 19-21, 2025
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01)===
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 planned safety system preventive maintenance on the 'B' train MDAFW system on April 8, 2025 (2)elevated risk (Green) during planned preventive maintenance on the 'A' SI pump on April 22, 2025 (3)elevated risk (Green) during planned preventive maintenance on the 'B' EDG from May 19-22, 2025 (4)elevated risk (Green) during planned implementation of modification engineering change (EC) 421073, that rendered auxiliary feedwater flow to the 'A' steam generator inoperable/unavailable on May 28-29, 2025 (5)elevated risk (Green) during emergent unit down power to 18 percent RTP to remove the turbine from service and conduct turbine EHC fluid leak repairs on June 8-9, 2025
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2549999, unexpected automatic 'D' control bank insertion 2.5 steps on April 4, 2025
'B' chemical and volume control system (CVCS) charging pump discharge pressure indicator PI-152 on May 23, 2025
- (3) NCR 2550640, excessive corrosion and coating degradation identified on refueling water storage tank foundation anchorage system, review completed on May 30, 2025
- (4) NCR 2557083, boric acid degradation of flange bolts and nuts on CVCS letdown orifice outlet relief valve CVC-203A identified on June 5, 2025
- (5) NCR 2557273, significant steam leakage from packing area of condenser steam dump valves PRV-1324A-1, PRV-1324B-1, and PRV-1324B-2 while operating with turbine offline between June 7-9, 2025
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) EC 421073, replacement of automatic transfer switch (ATS) BS/V2-16A, for emergency/normal electrical power to AFW-V2-16A, the MDAFW header isolation valve to the 'A' steam generator, implemented on May 29, 2025
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-201-2, MDAFW System Component Test - Train B, following scheduled safety system maintenance on the 'B' MDAFW System on April 8, 2025
- (2) WO 20693521 instructions for restoration of 'C' CCW pump following scheduled pump lubrication preventive maintenance on April 15, 2025
- (3) OST-151-1, Safety Injection System Components Test Pump A, following scheduled outboard bearing oil service water cooling preventive maintenance on April 22, 2025
- (4) OST-352-2, Containment Spray Component Test - Train B, following scheduled 'B' CS pump valve preventive maintenance on May 8, 2025
- (5) OP-604-2, PM-008, and OST-401-2, testing of the 'B' EDG following scheduled infrequent 2-year preventive maintenance from May 21-22, 2025
- (6) WO 20556963 functional testing instructions and OST-703-2, Secondary Side Inservice Valve Test for Auxiliary Feedwater, following replacement of ATS under modification EC 421073 on May 29, 2025
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) OST-201-1, MDAFW System Component Test - Train A, on April 29, 2025
- (2) OST-005, Nuclear Instrumentation Power Range (Power Level Above P-8), on May 30-31, 2025
- (3) OST-010, Power Range Calorimetric During Power Operation, on June 9, 2025
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of June 9, 2025. This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) A simulator based licensed operator training scenario on April 15, 2025
71114.07 - Exercise Evaluation - Hostile Action (HA) Event
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise during the week of June 9, 2025. The exercise scenario began with a simulated airborne threat which met the conditions for declaration of an Alert. After impact to the fuel handling building, the conditions were met for declaration of a Site Area Emergency. As a result of the impact the spent fuel pool is damaged and the water level in the pool dropped below emergency action level threshold. The operating crew was unable to recover level, which led to a General Emergency classification. This allowed the Offsite Response Organizations to demonstrate their ability to implement emergency actions during a hostile action event.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03)===
- (1) Unit 2 (April 1, 2024, through March 31, 2025)
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
- (1) Unit 2 (April 1, 2024, through March 31, 2025)
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) Unit 2 (April 1, 2024, through March 31, 2025)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) April 1, 2024, through March 31, 2025.
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2024, through March 31, 2025.
EP04: Emergency Response Facility and Equipment Readiness (ERFER) (IP Section 02.14) (1 Partial)
(1)
(Partial)
This is a new NRC performance indicator, described in NEI 99-02, Revision 8 (ML24331A114). Licensees began collecting data for this performance indicator January 1, 2025. Therefore, at the time of inspection there was no quarterly data compiled and submitted to the NRC.
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)isolation of seal water injection flow to all three reactor coolant pumps during 'B' seal water filter replacement maintenance on January 6, 2025 (NCR 2539750)
(2)failure to conduct license renewal aging management structural inspections of RWST anchorage system (NCR 2550640)
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.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60859 - Independent Spent Fuel Storage Installation (ISFSI) License Renewal Inspection 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) 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-than-Class C Waste at Independent Spent Fuel Storage Installations (ISFSI) and for 10 CFR Part 71 Transportation Packagings."
Independent Spent Fuel Storage Installation (ISFSI) License Renewal Inspection===
- (1) The inspectors reviewed a sample of regulatory commitments, Aging Management Programs (AMPs), and Time-Limited Aging Analyses (TLAAs) associated with the licensees implementation of the Site-Specific License SNM-2502 and General license CoC 72-1004. The inspection took place from May 12 to 14, 2025. The inspectors observed activities, reviewed implementing documents, and conducted interviews with licensee staff to verify that the licensee completed the necessary actions to:
- (a) comply with the conditions stipulated in the renewed Certificate of Compliance and technical specifications; and
- (b) implement the AMPs and TLAAs as described in the NRC Safety Evaluation Reports (SERs) and Final Safety Analysis Report (FSAR) supplements.
The inspectors reviewed RNP-L/LR-0705, "Independent Spent Fuel Storage Installation (ISFSI) Aging Management Program for License Renewal" and 67009-AMPBD07, "Robinson Nuclear Plant Specific AMP Basis Document," which provide programmatic governance and implementation of the licensees site-specific and general license aging management programs. Additionally, while onsite the inspectors directly observed the external activities associated with the Horizontal Storage Module Aging Management Program for External and Internal Surfaces.
For those license renewal items that were not completed at the time of this inspection, the team verified that there was reasonable assurance that the items were on track for completion in accordance with an established implementation plan consistent with the conditions of the certificate of compliance, technical specifications, the NRC safety evaluation report, and the FSAR.
INSPECTION RESULTS
Failure to Follow Procedure Step During Reactor Coolant Pump (RCP) Seal Injection Filter Replacement Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2025002-01 Open/Closed
[H.4] -
Teamwork 71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a, Procedures, was identified for the licensees failure to perform a required step of ensuring the A seal injection filter was in service prior to isolating the B seal injection filter which led to isolation of seal injection to all three RCP seals for two minutes.
Description:
On January 6, 2025, maintenance technicians tasked with replacing the B seal injection filter manually isolated the B filter, which was the in-service filter. The Unit 2 control room received alarms indicating loss of all RCP seal injection. Two RCP seal injection flows lowered below the TS limit of 6 gallons per minute (gpm). The limiting condition for operation (LCO) for TS 3.4.17, CVCS, Condition E, requires a minimum of 6.0 gpm seal injection to each RCP seal. Control room operators entered the TS action statement to immediately restore the minimum seal injection flow to the RCP seals or be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. An operator was dispatched to the field and returned the valves that were operated back to their original positions and seal injection was restored thus clearing all alarms and exiting LCO 3.4.17, Condition E. The duration of the isolation lasted for approximately 2 minutes.
The licensees cause investigation determined the technicians incorrectly assumed, based on past experience, that operations personnel had previously aligned the in-service seal injection flow through the A seal injection filter. Contributing to the event, the work control Senior Reactor Operator (SRO) authorized the work order without asking if or ensuring the A RCP seal injection filter was in service. RCP seal injection filter changeouts had historically been performed by a different organizational team with support from licensed individuals with operations experience, and planning groups assigned responsibility to the appropriate groups to establish conditions prior to planned work. This was ultimately a change in how the maintenance was performed, who was assigned to the work tasks, and how information was shared between the different teams. The work order for the filter change out had assigned the procedure step to ensure the A RCP seal injection filter was in service to the maintenance team instead of the on-shift licensed operators. The inspectors determined that the ineffective communication between operations and maintenance resulted in the licensee inadvertently isolating RCP seal water injection flow. A continued loss of seal injection could have resulted in reactor coolant system water backflowing through the RCP seals leading to degradation of the safety-related #1 RCP seal. Neither the work control SRO nor the lead technician ensured that the A seal injection filter was in service, nor did they confer with the control room operators as to what the actual plant configuration was.
Corrective Actions: The licensee reviewed the processes and procedures for other filter changes to identify common gaps in conduct, revised work orders for other filter changes to include operations signatures for the work order step to ensure filter alignment, conducted a stand down with the entire maintenance organization to implement a new standing order that included use of additional human performance tools, and developed additional training and checklists for personnel to strengthen overall organizational cohesion and communications.
Corrective Action References: NCR 2539750, Maintenance Standing Order 25-001 and Plant Manager Council Standing Order 24-004, Revision 1
Performance Assessment:
Performance Deficiency: The licensee failed to follow instructions in accordance with work order task #20657045-01 to ensure that the A seal injection filter was in service prior to isolating the B seal injection filter.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, failure to place the A seal injection filter in service prior to isolating the B filter resulted in exceeding the LCO limit of 6 gpm minimum and a loss of RCP seal flow increasing the probability of a seal failure to the safety-related #1 RCP seal.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green) because the finding did not cause a reactor trip AND the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the licensee failed to communicate and ensure the A seal injection filter was in service prior to manually isolating the B filter.
Enforcement:
Violation: Technical Specification 5.4.1.a requires that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The work order task #20657045-01 stated, in part, to ensure the A seal injection filter is in service prior to isolating the B seal injection filter.
Contrary to this requirement, the work order task #20657045-01 was not performed as written. Specifically, on January 6, 2025, when performing work order task #20657045-01, the maintenance technicians failed to ensure the A seal injection filter was in service prior to isolating the B filter resulting in loss of flow to the RCP seals.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Establish and Implement Adequate Procedures to Perform License Renewal Aging Management Inspections of the Refueling Water Storage Tank (RWST) Anchorage System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000261/2025002-02 Open/Closed None (NPP)71152A The inspectors identified a Green finding and associated NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to ensure activities affecting quality were prescribed by documented instructions and procedures appropriate to the circumstance. Specifically, the licensee failed to ensure the instructions prescribed in procedure AD-EG-RNP-1213, RNP Specific Requirements for System Walkdowns, that implemented license renewal aging management periodic structures monitoring of the RWST, included inspection requirements of the tanks metal anchorage system. The lack of periodic monitoring led to active coating discrepancies and corrosion degradations not being identified and addressed in a timely manner.
Description:
While conducting routine inspections of visible portions of the RWST carbon steel anchorage system, including the 13/4 diameter carbon steel anchor chair brackets, studs, and associated hold-down nuts, the inspectors identified cracking, peeling, and missing coatings on the exterior of 10 of the 20 anchor studs and nuts that exposed active corrosion of the metal underneath. Of these ten anchors, corrosion on several of the stud hold-down nuts had progressed to a point where corrosion had built up rust layers and there was active wastage of metal ongoing up to what was estimated to be 1/4 of the surface area of one of the hold-down nuts. Also, the inspectors noted that for each of the 20 anchors, similar sheet metal insulation sheathing installed around the entire tank exterior was overlaid against and cut around each of the anchors. This metal sheathing only allowed visual examination of approximately 50-75 percent of the surface area of each anchor.
Due to concerns regarding the extent of general corrosion degradation identified that would typically manifest over a long period of time, the inspectors reviewed the Robinson license renewal aging management program commitments for monitoring plant structures such as the RWST. The Robinson Updated Final Safety Analysis Report (UFSAR) Section 18.1.23, Structures Monitoring Program, states that the program consists of inspection and monitoring of the condition of structures and structure component supports to ensure that aging degradation leading to loss of intended function will be detected and the extent of degradation can be determined. Based on review of the Robinson License Renewal Amendment, dated June 14, 2002, and the subsequent NRC License Renewal Safety Evaluation Report, dated January 20, 2004, the inspectors confirmed that the RWST anchorage system was within the scope of the aging management structures monitoring program committed to under UFSAR Section 18.1.23. However, when the inspectors requested past results of RWST periodic structures inspections, the licensee was unable to find any past documented performances over the past 11 years that included inspections of the RWST anchorage system.
The inspectors reviewed details of the licensees aging management program implementing procedures, including AD-EG-RNP-1650, License Renewal Aging Management Activities, which provided a cross-reference monitoring activity listing to the various license renewal aging management program commitments. The procedure stated that the structures monitoring program was implemented through the performance of procedures AD-EG-RNP-1214, Condition Monitoring of Structures, and AD-EG-RNP-1213, RNP Specific Requirements for System Walkdowns. The inspectors noted that procedure AD-EG-RNP-1214, did not include specific requirements to conduct periodic RWST anchorage system inspections. Instead, Attachment 4 of the procedure, titled License Renewal Structures and Cranes, stated that tank foundations (including the RWST) are examined by the respective system engineers in accordance with the guidance in procedure AD-EG-RNP-1213.
However, the specific guidance in procedure AD-EG-RNP-1213 only required inspection of the concrete/grout associated with the RWST foundation, not the anchorage system.
To determine whether the RWST anchorage system had ever been monitored under the license renewal aging management program, the inspectors reviewed historical aging management implementing procedure revisions from the time Robinson entered the period of extended operation (i.e., beyond the initial operating license term of 40 years) which was July 31, 2010. The inspectors discovered that the previous periodic structures monitoring program procedure, i.e., EGR-NGGC-0351, Performance Monitoring of Structures, had directed procedure TMM-104, System Walkdown Procedure, to conduct periodic RWST foundation inspections. Based on a review of TMM-104, adequate instructions were provided to inspect the condition of the RWST anchorage system as part of this RWST foundation inspection. TMM-104 was subsequently superseded in February 2010 by procedure EGR-NGGC-0026, System Walkdown Procedure, which included tank guidance criteria to inspect the RWST anchorage system. However, when this procedure was superseded by Revision 0 of AD-EG-RNP-1213, on September 11, 2014, the specific requirements to inspect the RWST anchorage system were omitted from AD-EG-RNP-1213 without adding the requirement for the RWST anchorage system to be inspected per procedure AD-EG-RNP-1214. Based on this, the inspectors determined the licensee had failed to provide adequate procedural requirements for monitoring the RWST anchorage system in accordance with commitments in the license renewal aging management program.
Corrective Actions: The licensee entered the issue into their corrective action program to revise the current aging management implementing procedures to ensure periodic inspections included the RWST anchorage system. An initial operability assessment concluded that based on the extent of coating/corrosion degradations observed, no immediate operability concern existed. Actions were initiated to address the current degradations and to schedule a more comprehensive civil engineering inspection of the RWST anchorage system that included the removal of the outer metal insulation sheathing currently impeding visual inspection of all surfaces of the anchor system metal components.
Corrective Action References: NCR 2550640, license renewal structural inspections for RWST not documented
Performance Assessment:
Performance Deficiency: The failure to include appropriate instructions for performing aging management periodic structural monitoring inspections of the RWST anchorage system in accordance with commitments of the license renewal aging management program was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to monitor and identify ongoing coating and corrosion degradation of the RWST anchorage system would lead to more significant corrosion degradation that could challenge the operability and capability of the RWST when performing its safety-related function.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2-Mitigating Systems Screening Questions, Section A, Mitigating SSCs and PRA Functionality, the inspectors determined the finding to be Green because the degraded condition of the RWST anchorage system did not affect operability or represent a loss of PRA functionality.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, procedure changes that removed specific instructions to conduct the corrosion and coating inspections of the RWST anchorage system occurred in 2014.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
The licensee established procedure AD-EG-RNP-1213, RNP Specific Requirements for System Walkdowns, as one of the principle implementing procedures for license renewal aging management program periodic structural monitoring inspections of the RWST anchorage system, an activity affecting quality.
Contrary to the above, from September 11, 2014, to the present, the licensee failed to ensure activities affecting quality were prescribed by documented instructions, procedures, or drawings, that were appropriate to the circumstances for conducting aging management periodic structural monitoring of the RWST anchorage system. Specifically, AD-EG-RNP-1213 failed to include instructions for inspecting the condition of the RWST anchorage system when completing the periodic monitoring of the RWST.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71152S 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: The NRC regulation in 10 CFR 20.1501 requires, 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. Licensee procedure HPP-001, Radiologically Controlled Area Surveillance Program, Revision 149, which ensures licensee compliance with 10 CFR 20.1501, requires weekly contamination area boundary surveys to be completed.
Contrary to the above, on February 18, 2025, the licensee identified that weekly contamination area boundary surveys, specifically at the spent fuel pool, were not performed during January 20-23, 2025, and February 7-9, 2025.
Significance/Severity: Green. This violation was determined to be of very low safety significance (Green) because it was not related to ALARA planning, did not result in an overexposure beyond regulatory limits, there was no substantial potential for overexposure, and the ability to assess dose was not compromised.
Corrective Action References: NCR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified that no proprietary information was retained or documented in this report.
- On May 14, 2025, the inspectors presented the ISFSI license renewal inspection results to Laura Basta and other members of the licensee staff.
- On June 12, 2025, the inspectors presented the emergency preparedness exercise inspection results to David Thompson and other members of the licensee staff.
- On July 17, 2025, the inspectors presented the integrated inspection results to Winston Stewart and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-OP-ALL-0120
Severe Weather Preparations and Considerations
Rev. 1
AD-OP-RNP-
20
Severe Weather Response
Rev. 0
Procedures
AD-WC-ALL-
230
Seasonal Readiness
Rev. 2
Safety Injection and Containment Vessel Spray System
Rev. 109
Auxiliary Feedwater System
Rev.121
OP-604-1
Diesel Generator A Operations
Rev. 15
Procedures
OP-604-2
Diesel Generator B Operations
Rev. 14
CSD-RNP-PFP-
AB2-0226-001
Auxiliary Building Elevation 226 Pre-Fire Plan
Rev. 1
Fire Plans
CSD-RNP-PFP-
PA-003
Protected Area Southeast Fire Pre-Plan
Rev. 2
AD-FP-ALL-1520
Transient Combustible Control
Rev. 2 and
Rev. 3
AD-FP-ALL-1522
Duties of a Compensatory Fire Watch
Rev. 4
Fire Protection Systems Minimum Equipment and
Compensatory Measures
Rev. 40
Procedures
OMM-002
Fire Protection Manual
Rev. 59
RNP-F/PSA-0009
Assessment of Internally Initiated Flood Events
Rev. 2
RNP-F/PSA-0104
RNP Internal Flooding PRA Partitioning and Walkdown
Rev. 0
RNP-F/PSA-0105
RNP Internal Flooding Analysis
Rev. 4
Calculations
RNP-M/MECH-
1881
Internal Flooding Evaluation for Reactor Auxiliary Building
Rev. 2
CM-201
Safety Related and Non-Safety Related Heat Exchanger
Maintenance
Rev. 61
Procedures
CM-632
EDG Heat Exchanger Maintenance
Rev. 24
'A' SI pump outboard bearing service water inspection and
flush
04/22/2025
Work Orders
Perform 'B' MDAFW Pump lube oil heat exchanger
maintenance and inspections
04/08 -
04/09/2025
Procedures
AD-OP-ALL-1000
Conduct of Operations
Rev. 26
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Maneuvering the Plant When Greater Than 25% Power
Rev. 75
Auxiliary Feedwater System
Rev. 121
OST-005
Nuclear Instrumentation Power Range (Power Level Above
P-8)
Rev. 44
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
Procedures
CSD-WC-RNP-
240-00
Rev. 1
Procedures
AD-OP-ALL-0105
Rev. 9
AD-EG-ALL-1132
Preparation and Control of Engineering Changes
Rev. 30
AD-EG-ALL-1158
Standard Digital Engineering Process
Rev. 2
Procedures
AD-EG-ALL-1903
Cyber Security Critical Systems and Critical Digital Assets
Identification and Assessment
Rev. 15
OP-604-2
Diesel Generator B Operations
Rev. 14
OST-401-2
EDG B Slow Speed Start
Rev. 91
PLP-033
Post-Maintenance Testing (PMT) Program
Rev. 70
Procedures
Emergency Diesel Generator Inspection Number 2 (24
Months)
Rev. 78
Work Orders
WOs 20640696,
20640697,
20640698,
20632395, and
20632396
Testing of 'B' CS pump motor operated discharge valves SI-
880C and SI-880D
05/08/2025
Duke Energy Common Emergency Plan
Rev. 5
Procedures
EP-RNP-EPLAN-
ANNEX
Duke Energy Robinson Emergency Plan Annex
Rev. 3
AD-EP-ALL-0101
Emergency Classification
Rev. 5
AD-EP-ALL-0105
Activation and Operation of the Technical Support Center
Rev. 13
Procedures
CSD-EP-RNP-
0101-02
EAL Wallchart
Rev. 003
Procedures
AD-PI-ALL-0100
Corrective Action Program
Rev. 30
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AD-PI-ALL-0106
Cause Investigation Checklists
Rev. 10
Work Orders
Replace 'B' seal water injection filter in SLW-INJ-FLT-B
01/06/2025