IR 05000261/2008002

IR 05000261-08-002 on 01/01 - 03/31/08 for H.B. Robinson, Unit 2, Maintenance Rick Assessment, Problem Identification & Resolution

ML081200532
Person / Time
Site:	Robinson
Issue date:	04/25/2008
From:	Randy Musser Division of Nuclear Materials Safety II
To:	Walt T Carolina Power & Light Co
References
IR-08-002
Download: ML081200532 (30)

Text

April 25, 2008

SUBJECT:

H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATED INSPECTION REPORT 05000261/2008002

Dear Mr. Walt:

On March 31, 2008, the US Nuclear Regulatory Commission (NRC) completed an inspection at your H.B. Robinson reactor facility. The enclosed integrated inspection report documents the inspection findings, which were discussed on April 2 with Mr. Eric McCartney and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the inspectors identified one issue of very low safety significance (Green) that was determined to involve a violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your Corrective Action Program (CAP), the NRC is treating this issue as a non-cited violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. The inspectors identified another issue that involved a violation of NRC requirements and whose risk significance is to be determined, as explained in the body of this report. If you deny either the non-cited violation or the violation whose risk is to-be-determined, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the H.B.

Robinson facility.

CP&L

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html http://www.nrc.gov/NRC/ADAMS/index.html. (The Public Electronic Reading Room).

Sincerely,

/RA/

Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket No.:

50-261 License No.: DPR-23

Enclosure:

Inspection Report 05000261/2008002 w/Attachment: Supplemental Information

REGION II==

Docket No:

50-261 License No:

DPR-23 Report No:

005000261/2008002 Facility:

H. B. Robinson Steam Electric Plant, Unit 2 Location:

3581 West Entrance Road Hartsville, SC 29550 Dates:

January 1, 2008 - March 31, 2008 Inspectors:

R. Hagar, Senior Resident Inspector E. Morris, Resident Inspector

Approved by:

R. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000261/2008002, Carolina Power and Light Company; on 01/01-03/31/2008; H.B.

Robinson Steam Electric Plant, Unit 2; Maintenance Risk Assessment, Problem Identification &

Resolution

The report covered a three month period of inspection by resident inspectors. Two violations were identified. The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using IMC 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green non-cited violation of 10 CFR 50.65(a)(4) for the failure of the licensee to perform a risk assessment on March 10, 2008, before establishing maintenance boundaries which removed a boric acid injection flow path from service. This finding was more than minor because it is related to a risk assessment and management issue where the licensee failed to consider risk significant systems, structures, or components and support systems that were unavailable during maintenance. The finding has a cross-cutting aspect in the area of Human Performance (H.3(a)) because the operations staff did not appropriately plan the work activity of establishing maintenance boundaries by incorporating risk insights of the sites risk model. (Section 1R13)

Identification and Resolution of Problems

TBD. The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion XVI, for the licensees failure in 2004 to determine the cause of a programmatic deficiency in foreign-material-exclusion controls, after that deficiency resulted in steam generator tube leakage. The significance of this violation is to be determined, pending completion of risk significance determination in accordance with IMC 0609, Appendix J. This finding is more-than-minor because it affects the Protection Against External Factors attribute of the Initiating Events Cornerstone, in that deficiencies in foreign-material-exclusion controls could allow foreign material to enter the steam generators, where the foreign material could initiate a steam generator tube rupture. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution (P.1(c)), because the licensee did not thoroughly evaluate a problem such that the resolution addressed the causes. (Section 4OA2.2)

Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status. The unit began the inspection period at full rated thermal power, and operated at full power until 10:00 p.m. on March 8 when power was reduced to 46 percent to enable maintenance on secondary-side components. The unit returned to full power at 2:32 a.m. on March 9 and remained at full power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

==1R04 Equipment Alignment

a. Inspection Scope

Partial System Walkdowns:

==

The inspectors performed the following four partial system walkdowns, while the indicated structures, systems, and/or components (SSCs) were out-of-service for maintenance and testing:

System Walked Down SSC Out of Service Date Inspected Motor-driven auxiliary feedwater trains Steam-driven auxiliary feedwater train January 22 B train of Residual Heat Removal A train of Residual Heat Removal January 28 B train Boric Acid Transfer A Boric Acid Pump February 7 Steam-driven auxiliary feedwater train A train of Motor-driven auxiliary feedwater March 18

To evaluate the operability of the selected trains or systems under these conditions, the inspectors compared observed positions of valves, switches, and electrical power breakers to the procedures and drawings listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R05 Fire Protection

a. Inspection Scope

==

For the five areas identified below, the inspectors reviewed the control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures to verify that those items were consistent with Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire Protection System, and UFSAR Appendix 9.5.A, Fire Hazards

Analysis.

The inspectors walked down accessible portions of each area and reviewed results from related surveillance tests to verify that conditions in these areas were consistent with descriptions of the areas in the UFSAR. Documents reviewed are listed in the

.

The following areas were inspected:

Fire Zone Description Yard Electrical Transformers Emergency Switchgear Room and Electrical Equipment Area Auxiliary Building Hallway (Ground Floor)

Unit 2 Cable Spreading Room Main Control Room

Also, to evaluate the readiness of personnel to prevent and fight fires, the inspectors observed fire brigade performance during the unannounced fire drill on February 11.

This drill simulated an oil fire associated with a bearing on the main turbine.

The inspectors reviewed the following action requests (ARs) associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• 233585, Fire protection compensatory actions not performed during surveillance test OST-163

• 265895, Crew failure of fire brigade drill

b. Findings

No findings of significance were identified.

==1R06 Flood Protection Measures

a. Inspection Scope

External Flooding

==

The inspectors walked down the auxiliary feedwater pump room which contains risk-significant SSCs which are susceptible to flooding from external sources to verify that the area configuration, features, and equipment functions were consistent with the descriptions and assumptions used in UFSAR Section 3.4, Water Level (Flood) Design, and in the supporting basis documents listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R11 Licensed Operator Requalification

a. Inspection Scope

==

On February 6 the inspectors observed licensed-operator performance during requalification simulator training for shift four to verify that operator performance was consistent with expected operator performance, as described in Dynamic Simulator Scenario Examination DSS-005. This training tested the operators ability to operate components from the control room, direct auxiliary operator actions, and determine the appropriate emergency action level classifications while responding to a pressurizer pressure channel failure, a steam generator tube leak, the loss of condenser vacuum, and a steam generator safety valve failing open. The inspectors focused on clarity and formality of communication, the use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. Documents reviewed are listed in the Attachment.

The inspectors observed the post-exercise critique to verify that the licensee identified deficiencies and discrepancies that occurred during the simulator training.

The inspectors reviewed the following AR associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• 249243, Auxiliary Operator exam review deleted greater than 10 percent of the exam questions

b. Findings

No findings of significance were identified.

==1R12 Maintenance Effectiveness

a. Inspection Scope

==

The inspectors reviewed the three degraded SSC/function performance problems or conditions listed below to verify the appropriate handling of these performance problems or conditions in accordance with 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and 10 CFR 50.65, Maintenance Rule. Documents reviewed are listed in the

.

The problems/conditions and their corresponding ARs were:

Performance Problem/Condition AR Dessicant In 'B' emergency diesel generator air compressor caused relief valve to lift 247687 Charging Pump B center plunger valve cracked 260133 Functional failures in Reactor Protection System components 250359

During the reviews, the inspectors focused on the following:

• Appropriate work practices,

• Identifying and addressing common cause failures,

• Scoping in accordance with 10 CFR 50.65(b),

• Characterizing reliability issues (performance),

• Charging unavailability (performance),

• Trending key parameters (condition monitoring),

• 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and

• Appropriateness of performance criteria for SSCs/functions classified (a)(2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified (a)(1).

b. Findings

No findings of significance were identified.

==1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

==

For the five time periods listed below, the inspectors reviewed risk assessments and related activities to verify that the licensee performed adequate risk assessments and implemented appropriate risk-management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk was promptly assessed, and that appropriate risk-management actions were promptly implemented. Documents reviewed are listed in the Attachment. Those periods included the following:

• January 7 - January 11, including preventative maintenance on instrument air compressor D and main feedwater flow instrument calibration

• January 21 - January 29, including maintenance on the Steam Driven Auxiliary Feedwater Pump and emergent shaft seal replacement on the A Residual Heat Removal Pump

• February 22 - February 25, including scheduled preventative maintenance on a boric acid transfer system flow control valve, FCV-113A, scheduled replacement of the B Motor Driven Auxiliary Feedwater pump control switch, and emergent work on the B Charging Pump discharge relief valve

• March 1 - March 7, including emergent work which involved disabling one boration flow path

• March 10 - March 14, including emergent work on boric acid transfer system flow control valve, FCV-113A, emergent work on C Service Water Pump, and scheduled maintenance on A Battery Charger

The inspectors reviewed the following AR associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• 238879, During work schedule development the plant risk profile did not include Auxiliary Feedwater Pump as being unavailable.

b. Findings

Introduction:

The inspectors identified a Green non-cited violation of 10 CFR 50.65(a)(4)for the licensees failure on March 10 to perform a risk assessment before establishing maintenance boundaries which removed a boric acid injection flow path from service. As a result of that failure, the licensee incorrectly determined that removing a boric acid injection path from service did not increase plant risk, while according to the sites risk-assessment model, removing a boric acid injection path from service increased plant risk from Green to Yellow.

Description:

On March 10 before authorizing maintenance boundaries to be established that included removing a boric acid injection flow path from service, the licensee failed to assess the increase in plant risk that resulted from this plant configuration. This failure was contrary to site procedure OMM-048, Work Coordination and Risk Assessment, which requires, in part, the use of the licensees risk-assessment methodology to perform an adequate risk review prior to authorizing maintenance boundaries to be established, and that designated licensee personnel remain cognizant of the safety significance of the plant configuration.

Analysis:

This finding was more than minor because it is related to a risk assessment and management issue where the licensee failed to consider risk significant systems, structures, or components and support systems that were unavailable during maintenance, in that the licensee failed to consider a boric acid injection flow path that was unavailable during maintenance. As directed by the Phase 1 worksheet in Manual Chapter 0609, Attachment 4, Table 3b, the significance of this finding was evaluated using Manual Chapter 0609, Appendix K. In accordance with Flowchart 1 of Appendix K, because this finding was not related to Risk Management Actions only and because the Risk Deficit was calculated to be less than 1.0E-6, this finding screened as Green. The finding has a cross-cutting aspect in the area of Human Performance because the operations staff did not appropriately plan the work activity of establishing maintenance boundaries by incorporating risk insights of the sites risk model. (H.3(a))

Enforcement:

10 CFR 50.65(a)(4) requires, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Furthermore, licensee procedure OMM-048, Work Coordination and Risk Assessment, requires, in part, the use of the licensees risk-assessment methodology to perform an adequate risk review prior to authorizing maintenance boundaries to be established, and that designated licensee personnel remain cognizant of the safety significance of the plant configuration. Contrary to the above, on March 10 before performing the maintenance activity of removing a boric acid injection path from service, the licensee failed to assess and manage the increase in risk that would result from that proposed maintenance activity, in that the licensee failed to assess that risk and consequently failed to recognize that this maintenance activity placed the plant in an increased-risk condition. Because this finding was of very low safety significance and has been entered into the licensees corrective action program as AR 269817269817 consistent with Section VI.A of the NRC Enforcement Policy, this violation is being treated as a non-cited violation, and is designated as NCV 05000261/2008002-01, Failure of the licensee to assess the increased risk resulting from removing a boric acid injection path from service.

==1R15 Operability Evaluations

a. Inspection Scope

==

The inspectors reviewed the five operability determinations associated with the documents listed below. The inspectors assessed the accuracy of the evaluations, the use and control of any necessary compensatory measures, and compliance with the Technical Specification (TS). The inspectors verified that the operability determinations were made as specified by Procedure OPS-NGGC-1305, Operability Determinations.

The inspectors compared the justifications provided in the determinations to the requirements from the TS, the UFSAR, associated design-basis documents to verify that operability was properly justified and the subject components or systems remained available, such that no unrecognized increase in risk occurred:

• AR 260817260817 Flow control valve, FCV-4702, failure to reposition

• AR 258148258148 Charging pump C speed control failure

• Work Request 319506, Hinge pins missing on Reactor Protection Safeguards cabinet doors

• AR 265319265319 [Residual Heat Removal] pump A tabwasher material

• Work Order 1299827, [Service Water Pump] C base bolt loose

b. Findings

No findings of significance were identified.

==1R18 Plant Modifications

==

.1 Permanent Plant Modifications

a. Inspection Scope

For the two Engineering Changes listed below, the inspectors reviewed the modifications to verify that:

• these modifications did not degrade the design bases, licensing bases, and performance capabilities of risk significant SSCs;

• implementing these modifications did not place the plant in an unsafe condition; and

• the design, implementation, and testing of these modifications satisfied the requirements of 10 CFR 50, Appendix B.

The modifications reviewed were:

• EC 67828, Redundant Solenoid for [Steam Driven Auxiliary Feedwater Pump]

Governor Air

• EC 68931, [Steam Driven Auxiliary Feedwater] Pump Low Discharge Pressure Trip Time Delay Setpoint Change

Documents reviewed are listed in the Attachment.

The inspectors reviewed the following ARs associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• 243770, Self-Assessment of the Auxiliary Feedwater System

• 246099, Errors found in preventive maintenance basis documents

• 247229, The requirements of [procedure] ADM-NGGC-0203 are not fully incorporated into [preventive maintenance] basis documents.

• 250383, [Auxiliary Feedwater] Self-Assessment 243770: Recommendations 3 -13

b. Findings

No findings of significance were identified.

.2 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the temporary modification described in Engineering Change 66762 to verify that the modification did not affect the safety functions of important safety systems, and that the modification satisfied the requirements of Procedure EGR-NGGC-005, Engineering Change, and 10 CFR 50, Appendix B, Criterion III, Design Control.

Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

==1R19 Post Maintenance Testing

a. Inspection Scope

==

For the six post-maintenance tests listed below, the inspectors witnessed the test and/or reviewed the test data to verify that test results adequately demonstrated restoration of the affected safety functions described in the UFSAR and TS. Documents reviewed are listed in the Attachment.

The following tests were witnessed/reviewed:

Test Procedure

Title Related Maintenance Activity

Date Inspected MMM-050 Predetermined Jumper or Wire Lifts to Support Various

[Preventive Maintenance] Routes Replace instrument air compressor D relay and pressure switch January 8 PM-035 Water Cooled Condensing Units WCCU-1A/1B Rebuild internals of service water flow control valve January 9 OP-402 Auxiliary Feedwater System Inspect the lubricating oil cooler on the steam driven auxiliary feedwater pump, and install a redundant solenoid on the pumps governor January 22 OST-251-1

[Residual Heat Removal] Pump A and Components Test Repair the pump shaft seal January 29 LP-361 Steam Generator Level (Steam Flow)

Channel 485 Replace card FM-485 to repair steam flow transmitter FT-485 February 21 OP-601

[Direct Current]

Supply System Replace capacitor for Battery Charger A March 12

The inspectors reviewed the following AR associated with this area to verify that the licensee identified and implemented appropriate corrective actions:

• 218863, delay returning Service Water Pump D to service due to leakage

b. Findings

No findings of significance were identified.

==1R22 Surveillance Testing

a. Inspection Scope

==

For the seven surveillance tests listed below, the inspectors witnessed testing and/or reviewed the test data to verify that the systems, structures, and components involved in these tests satisfied the requirements described in the TS, the UFSAR, and applicable licensee procedures, and that the tests demonstrated that the SSCs were capable of performing their intended safety functions. Documents reviewed are listed in the

.

Test Procedure Title Date Inspected OST-011 Rod Cluster Control Exercise & Rod Position Indication Monthly Interval January 4 EST-088*

Inservice Inspection Pressure Testing of Component Cooling Water System Inside the Auxiliary Building (Each ISI Inspection Period)

January 8 OST-101-2 Chemical Volume Control System Component Test Charging Pump B January 16 OST-206 Comprehensive Flow Test for the Steam Driven Auxiliary Feedwater Pump January 22 OST-202 Steam Driven Auxiliary Feedwater System Component Test February 19 OST-551-1 Turbine Valve Test March 9 OST-051**

Reactor Coolant System Leakage Evaluation (Every 72 Hours During Steady State Operation and Within 12 Hours After Reaching Steady State Operation)

March 19

• This procedure included inservice testing requirements.

• • This procedure was a Reactor Coolant System leakage detection surveillance.

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP7 Force-on-Force Drill Evaluation

a. Inspection Scope

On February 12 and in accordance with inspection procedure 71114-07, the inspectors observed the emergency preparedness component of a Force-on-Force security exercise to verify licensee self-assessment of classification, notification, and protective action recommendation development in accordance with 10 CFR 50, Appendix E during a simulated terrorist event.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors verified the PIs identified below. For each PI, the inspectors verified the accuracy of the PI data that had been previously reported to the NRC by comparing those data to the actual data, as described below. The inspectors also compared the basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Indicator Guideline, Rev. 4. In addition, the inspectors interviewed licensee personnel associated with collecting, evaluating, and distributing these data.

Cornerstone: Mitigating Systems

• Mitigating Systems, Heat Removal System

• Safety System Functional Failures

For these PIs and for the period from the first quarter of 2007 through the fourth quarter of 2007, the inspectors reviewed Licensee Event Reports, records of inoperable equipment, and Maintenance Rule records to verify that the licensee had accurately accounted for unavailability hours that the subject systems had experienced during the subject period. The inspectors also reviewed the number of hours those systems were required to be available and the basis for identifying unavailability hours.

Cornerstone: Barrier Integrity

• For the Reactor Coolant System Specific Activity PI, the inspectors observed sampling and analysis of reactor coolant system samples, and compared the reported performance indicator data with records developed by the licensee while analyzing previous samples, for the period from the first quarter of 2007 through the fourth quarter of 2007.

• For the Reactor Coolant System Leak Rate PI, the inspectors reviewed records of daily measures of RCS identified leakage, for the period from the first quarter of 2007 through the fourth quarter of 2007. As described in section 1R22 of this and other inspection reports, the inspectors also periodically inspected routine licensee determinations of RCS unidentified leakage.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Routine Review of ARs

To aid in the identification of repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed frequent screenings of items entered into the CAP. The review was accomplished by reviewing daily AR reports.

.2 Annual Sample Review

a. Inspection Scope

The inspectors selected the following two ARs for detailed review.

• 219424, [Emergency Response Organization] exercise performance not meeting management expectations, was selected because this AR relates specifically to the Emergency Preparedness Cornerstone.

• 234814, effectiveness review for Steam Generator tube leak investigation indicates ineffective corrective actions to prevent recurrence, was selected because this AR relates specifically to the Barrier Integrity Cornerstone.

The inspectors reviewed these reports to verify:

• complete and accurate identification of the problem in a timely manner;

• evaluation and disposition of performance issues;

• evaluation and disposition of operability and reportability issues;

• consideration of extent of condition, generic implications, common cause, and previous occurrences;

• appropriate classification and prioritization of the problem;

• identification of root and contributing causes of the problem;

• identification of corrective actions which were appropriately focused to correct the problem; and

• completion of corrective actions in a timely manner.

The inspectors also reviewed these ARs to verify compliance with the requirements of the CAP as delineated in Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

b. Observations and Findings

Introduction:

The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion XVI, for the licensees failure in 2004 to determine the cause of a programmatic deficiency in foreign-material-exclusion (FME) controls, after that deficiency resulted in steam generator tube leakage. The significance of this violation is to be determined, pending completion of risk significance determination in accordance with IMC 0609, Appendix J.

Description:

In 2004, the licensee identified a significant condition adverse to quality but did not determine the cause of that condition and did not take corrective action to preclude repetition, in that:

• In AR 115704115704 the licensee determined that one cause of steam generator tube leakage had been maintenance practices that resulted in substandard cleanliness.

• That cause (maintenance practices that resulted in substandard cleanliness) is evidence of deficiencies in the licensees foreign-material-exclusion (FME) control program.

• According to Attachment 1 of licensee procedure CAP-NGGC-0200, Corrective Action Program, a programmatic deficiency that is likely to cause a significant adverse condition or event is itself a significant adverse condition. Therefore, because the licensee considered steam generator tube leakage to be a significant adverse condition, and because FME programmatic deficiencies caused steam generator tube leakage, FME programmatic deficiencies were also a significant adverse condition.

• The licensee did not evaluate FME programmatic deficiencies in AR 115704115704 or in any other NCR since 2004.

Analysis:

This finding is unresolved pending completion of a significance determination.

Discussions were held with NRC headquarters technical staff and no immediate plant safety consequences were identified. The risk significance of this finding will be completed at the next available maintenance opportunity (testing interval) as discussed in inspection manual chapter 0609, Appendix J. This finding is more than minor because the violation can be viewed as the possible precursor to a significant event, in that the failure to correct programmatic deficiencies in FME controls could allow maintenance activities to introduce foreign material into the secondary-side fluid stream and from there into the steam generators, where the foreign material could become a possible precursor to tube degradation.

The finding has a cross-cutting aspect in the area of Problem Identification and Resolution because the licensee did not thoroughly evaluate a problem such that the resolution addressed the causes (P.1(c)), in that:

• in NCR 115704, the licensee identified that foreign materials in the steam generators had been the cause of primary-to-secondary leakage,

• the existence of foreign materials in the steam generators indicated a programmatic deficiency in FME controls, and

• in NCR 115704, the licensee did not thoroughly evaluate the problem of steam generator tube leakage such that the resolution of that problem addressed the cause of programmatic deficiencies in FME controls.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI requires, in part, that in the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, the licensee identified a significant condition adverse to quality but did not assure that the cause of the condition was determined and corrective action taken to preclude repetition, in that:

• During their investigation of AR 115704115704 the licensee determined that one root cause of steam generator tube leakage during RO-22 had been Maintenance work practices: substandard cleanliness.

• Maintenance work practices that resulted in substandard cleanliness were evidence of a programmatic deficiency (in FME controls) that caused a significant adverse condition (steam generator tube leakage).

• According to attachment 1 of CAP-NGGC-0200, a programmatic deficiency or adverse trend that is likely to cause a significant adverse condition or event is itself a significant adverse condition.

• For the significant adverse condition represented by an identified programmatic deficiency in FME controls, the licensee did not determine the cause of that condition, and therefore did not take action to preclude repetition.

The risk significance of this finding must be completed by NRC headquarters technical staff following the next available maintenance opportunity. Because this analysis was not complete at the end of this inspection period, the risk significance of this finding is to-be-determined. Pending determination of its risk significance as described above, this finding is designated as an unresolved item, and is designated as URI 05000261/2008002-01, Failure to determine the cause of and take corrective actions to preclude repetition of an identified programmatic deficiency in foreign-material-exclusion controls.

This violation is in the licensees CAP as NCR 272388.

4OA3 Event Follow-up

.1 Unexpected Actuation of a Steam Generator Power-Operated Relief Valve

a. Inspection Scope

On January 4 the power-operated relief valve on steam generator B unexpectedly opened due to a frozen pressure-sensing line and was subsequently closed by operator action before it caused a significant plant transient. The inspectors reviewed the circumstances associated with that event to:

determine whether the event posed an actual or potential hazard to public health and safety, property, or the environment, as defined in NRC Management Directive 8.3, NRC Incident Investigation Program;

verify that the control-room operators response to the event was appropriate and in accordance with procedures and training: and

verify that the licensee determined and adequately addressed the cause of the event.

Documents reviewed are listed in the Attachment.

b. Findings

The event did not pose an actual or potential hazard to public health and safety, property, or the environment. No findings of significance were identified.

4OA5 Other Activities

.1 (Closed) URI 05000261/2007006-02, Incorrect Degraded Grid Undervoltage Relays

Installed.

During the component design basis inspection (CDBI) conducted July 16 to August 17, 2007, an unresolved item (URI) was identified related to the failure of the licensee purchasing group to order degraded grid undervoltage relays that referenced the correct specification for the relays. The relays installed were not the relays that were specified for the initial installation. The relays (time delay element) that were specified to be purchased and installed were relays with a + 3% accuracy. This specification was not translated into the purchase order and relays with a + 10% accuracy were ordered and installed. The TS surveillance acceptance criteria for the installed relays are to demonstrate a + 7% accuracy. The relays have been in service for more than 16 years and have passed the surveillance requirements. The more than 16 years of successful in service surveillance results demonstrated the capability of the installed relays to satisfy all concerns with the exception of seismically induced drift. The concern was that if the relays installed were relays with + 10% accuracy, after a seismic event the maximum drift could occur and the relays would subsequently be outside the required TS acceptance criteria. This item was unresolved pending the licensees analysis to assess the acceptability of the installed relays following a seismic event and an NRC review of this analysis. This issue was entered into the licensees corrective action program as NCR 241618.

The licensee had Trentec conduct full-scale tests to address this issue, and documented results from those tests in a Trentec Certificate of Successful Test Completion for Definite Time Static Single Phase Relay - 27N UV. The inspectors reviewed the test results and associated analyses to verify that test results were accurately recorded, and that the analyses were consistent with test details. In addition, the inspectors verified that the relay tested was representative of the installed relays. The inspectors concluded that the testing performed demonstrated that electrical continuity and structural integrity were maintained and that the time delay element was found to be relatively insensitive to seismically induced drift. The inspectors concluded that a seismic event would not prevent the component from performing the intended safety function. This URI is therefore closed.

4OA6 Meetings, Including Exit

On April 2, 2008, the resident inspectors presented the inspection results to Mr. E. McCartney and other members of the plant staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

C. Baucom, Manager, Support Services - Nuclear

B. Clark, Training Manager

W. Farmer, Engineering Manager

J. Huegel, Maintenance Manager

E. Kapopoulos, Plant General Manager

J. Lucas, Nuclear Assurance Manager

J. Rhodes, Radiation Protection Superintendent

T. Tovar, Operations Manager

T. Walt, Vice President

S. Wheeler, Supervisor, Regulatory Support

NRC personnel

R. Musser, Chief, Reactor Projects Branch 4

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000261/2008002-01 URI Failure to determine the cause of and take corrective actions to preclude repetition of an identified programmatic deficiency in foreign-material-exclusion controls. (4OA2.2)

Closed

None

Opened &

Closed

05000261/2008002-01 NCV Failure of the licensee to assess the increased risk resulting from removing a boric acid injection path from service (1R13)

Closed

05000261/2007006-02 URI Incorrect Degraded Grid Undervoltage Relay Installed.

(4OA5)

Previous Items

Closed

None

Discussed

None