ML110630055

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Annual Assessment Letter (Report 05000261/2011001)
ML110630055
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 03/04/2011
From: Mccree V
Region 2 Administrator
To: Duncan R
Carolina Power & Light Co
Shared Package
ML110630051 List:
References
IR-11-001
Download: ML110630055 (7)


See also: IR 05000261/2011001

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

March 4, 2011

Carolina Power and Light Company

ATTN: Mr. Robert J. Duncan, II

Vice President

H.B. Robinson Steam Electric Plant Unit 2

3581 West Entrance Road

Hartsville, SC 29550

SUBJECT: ANNUAL ASSESSMENT LETTER - H. B. ROBINSON STEAM ELECTRIC

PLANT, UNIT 2 (REPORT 05000261/2011001)

Dear Mr. Duncan:

On February 9, 2011, the NRC staff completed its end-of-cycle performance review of the H. B.

Robinson Steam Electric Plant, Unit 2. The NRC reviewed the most recent quarterly

performance indicators (PIs) in addition to inspection results and enforcement actions from

January 1, 2010 through December 31, 2010. This letter informs you of the NRCs assessment

of your facility during this period and its plans for future inspections at your facility. This

performance review and enclosed inspection plan do not include security information. A

separate letter will include NRCs assessment of your performance in the Security Cornerstone

and its security-related inspection plan.

The NRC determined the performance at Robinson Unit 2 during the most recent quarter was

within the Degraded Cornerstone column of the NRCs Reactor Oversight Process (ROP) Action

Matrix because the Unplanned Scrams per 7000 Critical Hours performance indicator crossed

the threshold from Green to White in the third quarter of 2010, and three findings classified as

having low to moderate safety significance (White) were active in the Mitigating Systems

cornerstone. Two of the three White inspection findings were identified in the third quarter of

2010 and the third finding was identified in the fourth quarter of 2010. The first White finding

was identified for your failure to correct a condition adverse to quality in B Emergency Diesel

Generator output breaker 52/27B. The second White finding was identified for your failure to

adequately design and implement operator training based on learning objectives as required by

10 CFR 55.59(c), in that training lesson material failed to identify the basis of a procedural

action involving reactor coolant pump seal cooling in licensee procedure PATH-1, as required

by the definition of systems approach to training, Element 3 in 10 CFR 55.4. The third White

inspection finding was identified for your failure to adequately implement requirements of

multiple procedures required by Technical Specification 5.4.1, during a cooldown of the Reactor

Coolant System and subsequent safety injection after a reactor trip on March 28, 2010.

The performance of Robinson Unit 2 during the first and second quarter of 2010 was within the

Licensee Response Column of the NRCs ROP Action matrix because all inspection findings

were classified as having very low safety significance (Green) and all PIs indicated performance

at a level requiring no additional NRC oversight (Green). On November 12, 2010, the NRC

issued an assessment follow-up letter due to the Unplanned Scrams per 7000 Critical Hours

CP&L 2

performance indicator crossing the green-to-white threshold. As a result of our assessment

review, Robinson Unit 2 performance was assessed to be in the Regulatory Response Column

of the NRCs ROP Action Matrix. An additional assessment follow-up letter was issued on

January 31, 2011. The NRC updated its assessment of Robinson Unit 2 to be in the Degraded

Cornerstone Column of the NRCs Action Matrix, effective the third quarter of calendar year

2010 due to the three white findings in the Mitigating System Cornerstone.

On February 1, 2011 your staff notified the NRC of your readiness, as of March 11, 2011, for us

to conduct a supplemental inspection to review the actions taken to address the White

performance indicator. Therefore, in addition to ROP baseline inspections, the NRC plans to

conduct a supplemental inspection in accordance with Inspection Procedure 95001, Inspection

for One or Two White Inputs in a Strategic Performance Area, beginning on March 21 for the

review of the Unplanned Scrams per 7000 critical hours White performance indicator. Also, on

February 1, 2011, your staff notified the NRC of your readiness, as of May 9, 2011, for us to

conduct a supplemental inspection to review the actions taken to address three White

inspection findings. Therefore, the NRC plans to conduct a supplemental inspection in

accordance with Inspection Procedure 95002, Inspection for One Degraded Cornerstone or

Any Three White Inputs in a Strategic Performance Area, beginning on May 31 for the review of

these inspection findings.

The NRC identifies substantive cross-cutting issues (SCCIs) to communicate a concern with the

licensees performance in a cross-cutting area and to encourage the licensee to take

appropriate actions before more significant performance issues emerge. The NRC identified a

cross-cutting theme in the Resources component of the Human Performance cross-cutting area.

Specifically, four Green inspection findings were identified as having the cross-cutting aspect of

complete, accurate and up-to-date design documentation, procedures, and work packages, and

correct labeling of components, H.2(c). The NRC determined that an SCCI exists because the

NRC has a concern with your staffs progress in addressing the cross-cutting theme.

Specifically, your staffs actions have not yet proven effective in substantially mitigating the

cross-cutting theme as it relates to procedure quality. The SCCI will remain open until the NRC

has confidence that your corrective actions are sufficient, based in part on a reduction in the

number of findings below the SCCI threshold. The NRC will monitor your staffs progress in

addressing the SCCI during the 95002 supplemental inspection and we will perform focused

annual problem identification and resolution reviews of the actions to address this cross-cutting

theme.

The enclosed inspection plan lists the inspections scheduled through June 30, 2012. Routine

inspections performed by resident inspectors are not included in the inspection plan. The

inspections listed during the last nine months of the inspection plan are tentative and may be

revised at the mid-cycle performance review. The NRC provides the inspection plan to allow for

the resolution of any scheduling conflicts and personnel availability issues. The NRC will

contact you as soon as possible to discuss changes to the inspection plan should

circumstances warrant any changes.

Based on plant performance over the cycle, we plan to conduct the inspections as described

above in addition to the reactor oversight process (ROP) baseline inspections at your facility.

We also plan on conducting Temporary Instruction (TI) 2515/179, Verification of Licensee

Responses to NRC Requirements for Inventories for Materials Tracked in the National Source

Tracking System (NSTS).

CP&L 3

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be made 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 (the Public Electronic Reading Room).

Please contact Randall A. Musser at 404-997-4603 with any questions you may have regarding

this letter.

Sincerely,

/RA/

Victor M. McCree

Regional Administrator

Docket No.: 50-261

License No.: DPR-23

Enclosure: Robinson Inspection/Activity Plan

(03/01/2011 - 06/30/2012)

cc w/encl.: (See page 4)

_LTR: ML110630055 PKG: ML110630051 __ X SUNSI REVIEW COMPLETE

OFFICE RII:DRP RII:DRP RII:DRP RII:ORA RII:ORA

SIGNATURE JGW1 RAM RXC2 LXW1 VMM

NAME *JWorosilo *RMusser *RCroteau LWert VMcCree

DATE 02/28/2011 02/28/2011 02/28/2011 03/01/2011 03/03/2011

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

CP&L 4

cc w/encl.:

Division of Radiological Health S. D. West

TN Dept. of Environment & Conservation Superintendent Security

Electronic Mail Distribution H. B. Robinson Steam Electric Plant

Progress Energy

R. J. Duncan, II Electronic Mail Distribution

Vice President

H. B. Robinson Steam Electric Plant Unit 2 Joseph W. Donahue

Carolina Power & Light Company Vice President

Electronic Mail Distribution Nuclear Oversight

Carolina Power and Light Company

Sandra Threatt, Manager Electronic Mail Distribution

Nuclear Response and Emergency

Environmental Surveillance David T. Conley

Bureau of Land and Waste Management Associate General Counsel

Department of Health and Environmental Legal Dept.

Control Progress Energy Service Company, LLC

Electronic Mail Distribution Electronic Mail Distribution

Vacant John H. O'Neill, Jr.

Vice President Shaw, Pittman, Potts & Trowbridge

Nuclear Operations 2300 N. Street, NW

Carolina Power & Light Company Washington, DC 20037-1128

Electronic Mail Distribution

Susan E. Jenkins

Brian C. McCabe Director, Division of Waste Management

Manager, Nuclear Regulatory Affairs Bureau of Land and Waste Management

Progress Energy Carolinas, Inc. S.C. Department of Health and

Electronic Mail Distribution Environmental Control

Electronic Mail Distribution

Christos Kamilaris

Director Tom Cosgrove

Fleet Support Services Plant General Manager

Carolina Power & Light Company Carolina Power & Light Company

Electronic Mail Distribution Electronic Mail Distribution

Curt A. Castell Robert P. Gruber

Supervisor Executive Director

Licensing/Regulatory Programs Public Staff - NCUC

Carolina Power & Light Company 4326 Mail Service Center

Electronic Mail Distribution Raleigh, NC 27699-4326

B. C. White cc w/encl.: (continued next page)

Manager

Support Services - Nuclear

Carolina Power & Light Company

Electronic Mail Distribution

CP&L 5

cc w/encl.: (continued)

W. Lee Cox, III

Section Chief

Radiation Protection Section

N.C. Department of Environmental

Commerce & Natural Resources

Electronic Mail Distribution

Mark Yeager

Division of Radioactive Waste Mgmt.

S.C. Department of Health and

Environmental Control

Electronic Mail Distribution

Public Service Commission

State of South Carolina

P.O. Box 11649

Columbia, SC 29211

Chairman

North Carolina Utilities Commission

Electronic Mail Distribution

Senior Resident Inspector

U.S. Nuclear Regulatory Commission

H. B. Robinson Steam Electric Plant

2112 Old Camden Rd

Hartsville, SC 29550

CP&L 6

Letter to Robert Duncan from Victor M. McCree dated March 4, 2011

SUBJECT: ANNUAL ASSESSMENT LETTER - H. B. ROBINSON STEAM ELECTRIC

PLANT, UNIT 2 (REPORT 05000261/2011001)

Distribution w/encl.:

C. Evans, RII EICS

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