ML23041A227
| ML23041A227 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/13/2023 |
| From: | David Dumbacher NRC/RGN-II/DRP/RPB3 |
| To: | Basta L Duke Energy Progress |
| References | |
| IR 2022004 | |
| Download: ML23041A227 (24) | |
Text
February 10, 2023 Laura Basta Site Vice President H.B. Robinson Steam Electric Plant Duke Energy Progress, LLC 3581 West Entrance Road, RNPA01 Hartsville, SC 29550
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000261/2022004
Dear Laura Basta:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at H.B. Robinson Steam Electric Plant. On January 12, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. 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 violation or the significance or severity of the violation 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.
L. Basta 2
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, David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000261 License No. DPR-23
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Dumbacher, David on 02/10/23
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DRP/RPB3 RII/DRP/RPB3 RII/DRP/RPB3 RII/DRP/RPB3 NAME V. Gaffney J. Zeiler J. Hamman D. Dumbacher DATE 2/10/2023 2/10/2023 2/10/2023 2/10/2023
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
05000261 License Number:
DPR-23 Report Number:
05000261/2022004 Enterprise Identifier:
I-2022-004-0028 Licensee:
Duke Energy Progress, LLC Facility:
H.B. Robinson Steam Electric Plant Location:
Hartsville, SC Inspection Dates:
October 01, 2022 to December 31, 2022 Inspectors:
J. Bell, Health Physicist C. Fontana, Emergency Preparedness Inspector V. Gaffney, Resident Inspector P. Gresh, Emergency Preparedness Inspector B. Kellner, Senior Health Physicist B. Pursley, Health Physicist J. Rivera, Health Physicist S. Sanchez, Senior Emergency Preparedness Inspector M. Schwieg, Senior Reactor Inspector J. Walker, Emergency Response Inspector J. Zeiler, Senior Resident Inspector Approved By:
David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at H.B. Robinson Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Failure to identify and evaluate an indication in accordance with ASME Section XI code Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2022004-01 Open/Closed None (NPP) 71111.08P The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Code of Federal Regulation (CFR) 10 CFR Part 50.55a, "Codes and Standards," involving the licensee's failure to identify and evaluate a relevant indication in accordance with ASME Section XI code.
Additional Tracking Items None.
3 PLANT STATUS Unit 2 began the inspection period shutdown in Mode 5 for a forced outage to replace the 'C' reactor coolant pump (RCP) seal package due to excessive number (No.) 2 seal flow. The unit entered Mode 3 on October 2, 2022, following replacement of the 'C' RCP seal package. The unit was returned to Mode 5 on October 4, 2022, to replace the seal package on the 'B' RCP due to low No. 1 seal leakoff flow experienced during pump restart. Following repairs, the unit was restarted on October 10, 2022, and returned to rated thermal power (RTP) on October 12, 2022. On November 18-19, 2022, the unit was down-powered and shutdown for a planned refueling outage. The unit was restarted on December 29, 2022, following the refueling outage. On December 30, shortly after synchronizing to the grid, a turbine trip occurred due to a main generator lockout actuation. The unit remained offline in Mode 1 operating at 8 percent power at the end 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 seasonal cold temperatures for the following systems:
turbine driven auxiliary feedwater (TDAFW), motor driven auxiliary feedwater (MDAFW), and deepwell pump systems on October 18-19, 2022 Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending adverse weather from extreme cold temperatures on December 25-26, 2022 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (3 Samples)
4 The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'A' and 'B' MDAFW pumps following reactor restart for RCP seal replacement forced outage on October 11, 2022 (2)
'A' emergency diesel generator (EDG) during 'B' EDG room exhaust fan maintenance on November 8, 2022 (3)
'A' and 'B' spent fuel pool pumps and heat exchanger during full reactor core offload on December 12, 2022 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) containment vessel all elevations (fire zone 24) during forced outage shutdown conditions on October 2, 2022 (2) spent fuel pit, new fuel storage area, and spent fuel pool pump and heat exchanger areas (fire zone 28A) on November 3, 2022 (3) main steam safety valve (MSSV) and steam generator power operated relief valve gallery area (fire zone 25G) on November 18, 2022 (4) 4160 and 480 volt switchgear room (fire zone 25E) on November 28, 2022 (5) component cooling water (CCW) pump and heat exchanger room (fire zone 5) on December 16, 2022 71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1)
CCW pump and heat exchanger and boric acid tank room (flood zone FLC050) on December 13, 2022 71111.07A - Heat Exchanger/Sink Performance Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)
'B' CCW heat exchanger on December 16-17, 2022 71111.08P - Inservice Inspection Activities (PWR)
PWR Inservice Inspection Activities Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors reviewed the following In-service activities from November 28, 2022 to December 19, 2022:
5 03.01.a - Nondestructive Examination and Welding Activities.
Ultrasonic Examinations on Vessel Shell Welds
Ultrasonic examinations for RCP A Studs 1-24
Visual examinations of the Core Barrel and Thermal Shields
Welding activities and liquid penetrant examinations on Main Steam Weld overlay 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
Boric acid program corrective action reports.
RCP seal failure 71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 7, 2022, the inspector performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.
The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam completed on April 11, 2022.
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 reactor restart from a forced outage on October 10, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated an annual licensed operator requalification exam on October 18, 2022.
71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
6 (1) unit shutdown due to exceeding 'C' RCP No. 2 seal leakage flow requirements on September 24, 2022 [Nuclear Condition Report (NCR) 2443071]
(2) spent fuel pool building exhaust air handling unit fan HVE-15A failed surveillance testing on November 1, 2022 (NCR 2448035)
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
(1) boric acid leakage from 'B' RCP main flange identified on October 24, 2021 (NCR 2402785) 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1) elevated risk (Green) during forced outage R2F33B for reactor coolant system (RCS) drain down to 32 percent pressurizer level with 'B' RCP on its backseat on October 4-7, 2022 (2) elevated risk (Green) during forced outage R2F33B for reactor criticality activities on October 10, 2022 (3) elevated risk (Yellow) during refueling outage R2R33 for RCS drain down to lowered inventory conditions to disassemble and remove the reactor vessel head on November 22-23, 2022 (4) elevated risk (Green) during refueling outage R2R33 for reactor restart activities on December 29, 2022 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 2443909, 'B' RCP No. 1 seal leakoff flow decreased below minimum value during startup on October 2, 2022 (2)
NCR 2444458, multiple broken studs in containment vessel liner panel on October 6, 2022 (3)
NCR 2402785, Assignment 36, postponement of 'B' RCP flange gasket leak repair on October 26, 2022 (4)
NCR 2448208, 'B' MDAFW pump discharge flow control valve FCV-1425 stroke time testing trending high on November 3, 2022 (5)
NCR 2451316, linear circumferential indication observed on interior of reactor vessel core barrel during ASME Section XI inservice visual examinations on November 30, 2022
7 71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) engineering change (EC) 421907, temporary modification to restore functionality of post-accident containment water level transmitter LT-801 (2)
EC 421996, temporary modification to install single wall thimble tube for incore thimble at location N-10 71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
(1)
Work Order (WO) 20491981, leakage checks on 'C' RCP following seal replacement on October 9, 2022 (2)
EST-022, Spent Fuel Pool Exhaust System Fan HVE-15A, following carbon filter replacement for fuel handling building exhaust fan HVE-15A on November 2, 2022 (3)
CM-769, Anticipated Transient Without Scram Mitigation System Actuation Circuitry (AMSAC) Testing, following replacement of failed power supply associated with 'B' AMSAC circuit on November 18, 2022 (4)
OST-302-1, Service Water Pumps A & B Inservice Test, following repair of south service water header check valve SW-545 on December 12, 2022 (5)
CM-201, Safety Related and Non-Safety Related Heat Exchanger Maintenance, leakage testing of 'B' CCW heat exchanger following tube cleaning and eddy-current testing on December 17, 2022 (6)
WO 20515275, testing following refueling outage refurbishment and/or replacement of four MSSVs on December 27, 2022 (7)
EST-028, Main Steam Safety Valve Testing, following troubleshooting of unexpected opening of 'C' MSSV during turbine trip event on December 30, 2022 71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (2 Samples 1 Partial)
(1)
The inspectors evaluated forced outage R2F33B to replace the 'C' and 'B' RCP seal packages from October 1-10, 2022.
(2)
The inspectors evaluated refueling outage R2R33 activities from November 19, 2022 to December 30, 2022.
(3)
(Partial)
The inspectors evaluated forced outage R2F34A activities associated with an automatic turbine trip that occurred shortly after synchronizing to the grid due to a main generator lockout actuation from December 30, 2022 to December 31, 2022.
8 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
(1)
EST-082, ISI Pressure Testing of AFW System, for 'B' MDAFW pump on November 9, 2022 (2)
EST-028, Main Steam Safety Valve Testing, on November 18, 2022 (3)
OST-163, Safety Injection Test and Emergency Diesel Generator Auto Start on Loss of Power and Safety Injection, on November 20-21, 2022 Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1)
OST-933-28, Penetration 48 SI-895V and SI-898F (SI High Head Test Line) Leakage Test, on December 3, 2022 71114.02 - Alert and Notification System Testing Inspection Review (IP Section 02.01-02.04) (1 Sample)
(1)
The inspectors evaluated the maintenance and testing of the alert and notification system during the week of October 31, 2022.
71114.03 - Emergency Response Organization Staffing and Augmentation System Inspection Review (IP Section 02.01-02.02) (1 Sample)
(1)
The inspectors evaluated the readiness of the Emergency Response Organization during the week of October 31, 2022.
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 October 31, 2022. This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
(1)
The inspectors evaluated the maintenance of the emergency preparedness program during the week of October 31, 2022.
9 RADIATION SAFETY 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards during the Robinson Unit 2 refueling outage (R2R33).
Instructions to Workers (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards during R2R33.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
(1)
Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA) at the main control point during the refueling outage R2R33.
(2)
Workers exiting the RCA during refuel outage R2R33.
(3)
Licensee surveys of potentially contaminated material at the Unit 2 equipment hatch during refueling outage R2R33.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1)
ALARA Plan for RO-33 Thimble Cutting Activities, RWP 2667 Task 4 (2)
RWP # 2518, RO-33 MOV Testing Activities, Task 19, RHR-752B-MO; Remove /
Install Actuator (3)
RWP # 2542, RO-33 Core Barrel Movement Activities, Task #2, Core Barrel Move from Vessel to Stand High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
(1)
Locked High Radiation Area (LHRA) at Unit 2 reactor coolant pump cubicle "B" inside the reactor containment building.
(2)
LHRA in the radwaste building 1st and 2nd level on bunker (3)
LHRA controls at the Waste Holdup Tank room (4)
LHRA controls at the Spent Resin Storage Tank Room (5)
LHRA controls at the RCS filter access room
10 Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
(1)
The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements during R2R33.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)
Control Room Emergency Ventilation System Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1)
DOP Test Results for HEPA Air Handling Unit - HU-500 #4, 04/23/2022 (2)
DOP Test Results for Vacuum Cleaner - Shop Vac #1802, 07/03/2022 Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1)
The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment Source Term Characterization (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
(1)
Reviewed Whole Body Count (WBC) records for investigational counts for a medical administration.
(2)
Reviewed WBC records for one potential internal investigation [Individual alarmed and unable to clear Personnel Contamination Monitor]
11 Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)
Reviewed records for one previously declared pregnant worker.
(2)
Reviewed records for one currently declared pregnant worker.
71124.05 - Radiation Monitoring Instrumentation Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)
R-32A/B Containment High Range Monitor (2)
R-14C/D/E Plant Vent Stack Monitor (3)
R-18 Liquid Waste Disposal Monitor (4)
GEM-5 portal monitor at RCA entry/exit ENRAD # 13357 (5)
Gooseneck air sampler ENRAD # 10180 at open equipment hatch (6)
Ludlum 3030P smear counter ENRAD # 03731 at RCA entry/exit (7)
ARM R-6 primary sampling room (8)
ARM R-2, containment low range monitor (9)
CRONOS-4 small article monitor at RCA entry/exit ENRAD # 13622 (10)
ARGOS-5AB personnel contamination monitor at RCA entry/exit ENRAD # 12905 Calibration and Testing Program (IP Section 03.02) (13 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
(1) 2022 Calibration Record for Whole body Counters RNPFS1 and RNPFS2 (May 2022)
(2)
GEM-5 Portal Monitor ENRAD # 13623, 11/21/2021 and 11/15/2022 (3)
Cronos-4 Small Article/Equipment Monitor ENRAD # 13621, 11/21/2021 and 11/14/2022 (4)
Argos-5AB Personnel Contamination Monitor, ENRAD # 12905, 8/2/2021 and 8/2/2022 (5)
Ludlum Model 177 Count Rate meter with frisker probe, ENRAD # 07212, 3 /9/2021 and 3/14/2022 (6)
Ludlum 3030P Alpha Beta Smear Counter, ENRAD # 03731,1/2 5/2 021 and 8/25/2022 (7)
Telepole II Extendable GM Dose Rate Meter, ENRAD # 13817, 8/26/2022 (8)
Telepole II Extendable GM Dose Rate Meter, ENRAD # 16103, 8/26/2022 (9)
Ludlum Model 9-3 Ion Chamber Dose Rate Meter, ENRAD # 12050, 4/1/2021 and 9/27/2022 (10)
Goose Neck Low Volume Air Sampler, ENRAD # 11416, 8/12/2020 and 10/7/2022 (11)
Canberra iCAM Alpha Beta Continuous Air Sampler, ENRAD # 13280, 2/22/2021 and 10/20/2022 (12)
Containment High Range Radiation Monitor R-32A - Calibrations under Work Order (WO) # 2015162 02, 10/17/2018 and WO # 20370913 02, 12/4/2020
12 (13)
Containment High Range Radiation Monitor R-32B - Calibrations under WO # 20151625 02, 10/17/2018 and WO # 20370914 02, 12/4/2020 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
(1)
R-14, Plant Vent Stack Monitor, Work Order #s 20415057 and 20309498 (2)
R-18, Liquid Waste Disposal Monitor, Work Order #s 20365656 and 20468846 OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
(1)
Unit 2 (October 1, 2021 through September 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
(1)
Unit 2 (July 1, 2021 through September 30, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1)
November 30, 2021 through November 30, 2022 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)
May 6, 2021 through November 30, 2022 EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
(1)
April 1, 2021, through June 30, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
(1)
April 1, 2021, through June 30, 2022 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
(1)
April 1, 2021, through June 30, 2022 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
13 The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)
NCR 2433409, leak in underground firewater piping 71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02) (1 Sample)
(1)
The inspectors reviewed the licensees corrective action program and equipment performance databases for potential adverse trends in repetitive equipment reliability issues that might be indicative of a more significant safety issue. The inspectors identified an adverse trend in the performance of RCP seals, which is discussed in the inspection results section of this report.
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated an automatic turbine trip due to a lockout actuation signal generated on the main generator and licensee's performance on December 30, 2022.
INSPECTION RESULTS Failure to identify and evaluate an indication in accordance with ASME Section XI code Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2022004-01 Open/Closed None (NPP) 71111.08P The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Code of Federal Regulation (CFR) 10 CFR Part 50.55a, "Codes and Standards," involving the licensee's failure to identify and evaluate a relevant indication in accordance with ASME Section XI code.
==
Description:==
In December 2022, the licensee performed a 10-year VT-3 examination on the Core Barrel and identified a 12-inch relevant indication on the Core Barrel upper girth weld. The Core Barrel is described in Robinson UFSAR as a Safety Related structure subject to ASME Section XI requirements.
The licensee conducted a more detailed examinations which included enhanced visual and ultrasonic evaluations and determined that the 12-inch indication was a thru-wall crack with a 92 percent depth. Additionally, the licensee identified four other indications along the core barrel upper girth weld.
The licensee contracted with Westinghouse to perform an analytical evaluation on each of these indications and determined that the 12-inch indication did not require immediate corrective actions and was acceptable for continued service until the next refueling cycle through 2024. However, one indication required corrective actions to repair prior to continued service. The licensee performed the required repairs prior to startup.
14 The licensee reviewed the previous VT-3 examination conducted in 2012 and determined that the 12-inch indication was not reportable due to lighting, camera resolution, and oxide build up on the indication. The high-definition cameras and lighting used presently makes the ability to discern indications more reliable. The licensee initiated NCR 2451316 to document this issue.
The inspectors reviewed the 2012 video recording and disagreed with the licensee determination. It appeared the 12-inch indication was clearly visible. Consequently, the inspector concluded that the licensee had an opportunity in 2012 and had failed to identify a relevant indication and evaluate for continued service in accordance with ASME Section XI Subsection IWC-3122.3 listed below:
ASME Section XI Subsection IWC-3122.3, Acceptance by Analytical Evaluation, states that a component whose examination detects flaws that exceed the acceptance standards of Table IWC-3410-1 is acceptable for continued service without a repair / replacement activity if an analytical evaluation, as described in IWC-3600, meets the acceptance criteria of IWC-3600. The area containing the flaw shall be subsequently reexamined in accordance with IWC-2420(b) and (c).
Corrective Actions: The licensee evaluated the core barrel indications in accordance with ASME Section XI code.
Corrective Action
References:
NCR 2453581 NRC violation for 2012 core barrel indication Performance Assessment:
Performance Deficiency: The licensees failure to identify and evaluate a relevant indication in accordance with ASME Section XI requirements was a performance deficiency. Specifically, the licensee failed to identify and evaluate a 12-inch indication on the Core Barrel during the 2012 VT-3 examination.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment 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, the failure to identify and disposition of a relevant indication could lead to the failure of the Core Barrel upper girth weld and an increase in core bypass flow.
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 assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as very low safety significance (Green) because the inspectors answered all Inspection Manual Chapter 0609, Appendix A, exhibit 1, Initiating Events Screening Questions "no."
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.
15 Enforcement:
Violation: 10 CFR 50.55a requires the licensee to comply with the requirements of the latest edition and addenda of the ASME Section XI Code.
The 1995 edition of ASME Section XI, Subsection IWB-3520.2, Visual Examination VT-3, states that any relevant indication shall require corrective actions in meeting the requirements of IWB-3122 prior to return to service.
The 1995 edition of ASME Section XI, Subsection IWC-3122.3, Acceptance by Analytical Evaluation, states that a component whose examination detects flaws that exceed the acceptance standards of Table IWC-3410-1 is acceptable for continued service without a repair / replacement activity if an analytical evaluation, as described in IWC-3600, meets the acceptance criteria of IWC-3600. The code also states that area containing the flaw shall be subsequently reexamined in accordance with IWC-2420(b) and (c).
Contrary to the above, during the code required examination in 2012, the licensee failed to identify a relevant indication on the Core Barrel upper girth weld. As a result, the licensee performed neither the required analytical evaluation to determine the acceptance for continued service, nor determined subsequent reexamination required by ASME Section XI Subsection IWC-3122.3. As a result, the Core Barrel upper girth weld indication was not evaluated until December 2022, at which point, an evaluation was conducted, and a determination was made to allow continued operation until the next refueling outage planned for 2024.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend Review 71152S The inspectors focused the semi-annual trend review on repetitive equipment performance issues that led to operationally impacted conditions. The review nominally considered the 6-month period of July 2022 through December 2022, although some examples may have extended beyond those dates when the scope of the trend warranted. The inspectors compared their results with the licensees analysis of trends.
As a result of the review, the inspectors noted a negative trend in equipment performance challenges associated with RCP seals. Seal performance problems with the A RCP seal were previously documented in NRC Inspection Report 05000261/2022011, dated July 19, 2022, involving an NRC-identified Green finding and associated Non-Cited Violation of Technical Specification 5.4.1(a), Procedures. Specifically, the licensee had failed to establish adequate preventive maintenance procedures for replacing the RCP seal injection filters based on the prescribed vendor recommended replacement frequency. This caused inadequate filtration through the RCP seal injection system resulting in the October 18, 2021, forced outage to replace the A RCP seal package due to excessive No. 2 seal flow. Licensee corrective actions to address the A RCP forced outage included changing the periodicity of the seal injection filter replacement from a time-based frequency versus seal flow pressure differential and scheduling the replacement of the C and B RCP seal packages, which were susceptible to same seal injection vulnerability to the upcoming scheduled November 2022 refueling outage. However, prior to the refueling outage, continued seal performance issues associated with the C RCP seal occurred in September
16 2022, and with the B RCP in October 2022. As a result, a forced outage had to be implemented from September 24, 2022, through October 10, 2022, to replace the seal packages for the C and B RCPs. These RCP seal performance issues were documented in the following licensee NCRs:
- NCR 2443071, Unit shutdown due to C RCP No. 2 seal exceeding AOP-018 threshold greater than 1.1 gpm on September 24, 2022
- NCR 2443909, B RCP No. 1 seal leakoff below minimum requirements during pump restart on October 4, 2022 The licensee acknowledged the existence of continued equipment reliability issues with the RCP seals. As a result of the recent RCP seal performance issues and forced outage to replace the C and B RCP seals, a root cause investigation (RCI) was initiated as part of NCR 2443909 to understand the cause of the C and B seal performance issues, as well as evaluate the seal issues experienced over the past year in aggregate. At the conclusion of the inspection period, the licensees RCI was still ongoing and scheduled to be completed January 31, 2023. The inspectors will review the results of the licensees RCI upon completion. In the interim, the inspectors determined that licensee actions to address degrading C and B RCP seal performance issues were consistent with abnormal operating procedures. An appropriate interim corrective action was taken to shutdown the unit to replace the RCP seals prior to more substantial degradation occurring, that could have challenged safe plant operation. The inspectors did not identify any findings as a result of this inspection.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On January 12, 2023, the inspectors presented the integrated inspection results to newly appointed Site Vice President (VP) Laura Basta and other members of the licensee staff.
On December 21, 2022, the inspectors presented the NRC 2022 Radiation Protection Inspection results to Nicole Flippin, Site VP, and other members of the licensee staff.
On December 19, 2022, the inspectors presented the In-service inspection exit meeting inspection results to Nicole Flippin, Site VP, and other members of the licensee staff.
On November 3, 2022, the inspectors presented the Emergency Preparedness Program Inspection results to Laura Basta and other members of the licensee staff.
THIRD PARTY REVIEWS Inspectors reviewed the World Association of Nuclear Operators (WANO) peer evaluation report that was issued during the inspection period.
17 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date AP-015 Portable Heaters/Heating Devices Issuance and Inspection Rev. 25 AP-058 Seasonal Readiness Rev. 4 EDP-009 Freeze Protection Panels Rev. 80 71111.01 Procedures OP-925 Cold Weather Operation Rev. 80 Drawings 5379-1485 Spent Fuel Pit Cooling System Flow Diagram Rev. 31 OP-202 Safety Injection and Containment Vessel Spray System Rev. 106 OP-604-1 Diesel Generator A Operations Rev. 4 71111.04 Procedures OP-910 Spent Fuel Pit Cooling and Purification System Rev. 50 CSD-RNP-PFP-AB2-0226-001 Auxiliary Building Elevation 226 Pre-Fire Plan Rev. 0 CSD-RNP-PFP-CV2-0000-001 Containment Vessel Pre-Fire Plan Rev. 0 CSD-RNP-PFP-FB2-0226-001 Fuel Handling Building Elevation 226 Pre-Fire Plan Rev. 0 CSD-RNP-PFP-TB2-0242-001 Turbine Building Elevation 242 Pre-Fire Plan Rev. 2 Fire Plans CSD-RNP-PFP-TB2-0267-001 Turbine Building Elevation 267 Pre-Fire Plan Rev. 0 AD-FP-ALL-1520 Transient Combustible Control Rev. 0 71111.05 Procedures OMM-002 Fire Protection Manual Rev. 57 RNP-F/PSA-0009 Assessment of Internally Initiated Flood Events Rev. 4 RNP-F/PSA-0104 RNP Internal Flooding PRA Plant Partitioning and Walkdown Data Rev. 0 71111.06 Calculations RNP-F/PSA-0105 RNP Internal Flooding Analysis Rev. 3 Procedures CM-201 Safety Related and Non-Safety Related Heat Exchanger Maintenance Rev. 60 WO 20515207
'B' CCW heat exchanger cleaning and inspection 12/16/2022 71111.07A Work Orders WO 20515212
'B' CCW heat exchanger ECT 12/17/2022 Corrective Action Documents NCR 2450435 ISI Visual Examination of CRDM Seismic Support Structure 11/22/2022 71111.08P Drawings 02-0836591-B HB Robinson TWS Scan Plan 0
18 Inspection Procedure Type Designation Description or Title Revision or Date ARC-806 Welding Qualifications Hastings, Addison 09/20/2022 PT-22-001 PT Exam on Thermal Coupling 12/02/2022 UT-21-001 UT Calibration/Examination RCP B Main Flange Studs 1-24 10/27/2021 UT-22-002 UT Calibration/Examination RCP A Main Flange Studs 1-25 11/30/2022 VT-22-006 CRDM Seismic Support Structure 11/25/2022 NDE Reports WT-224547-01 Welding Traveler 11/23/2022 NDE-NE-ALL-6405 Utilization of PDI-UT-5 Generic Procedure for the Straight Beam Ultrasonic Examination of Bolts and Studs 2
Procedures NDE-NE-ALL-7302 VT-3 Visual Examination of Component Supports 3
71111.11Q Procedures AD-TQ-ALL-0420 Conduct of Simulator Training and Evaluation Rev. 19 AD-EG-ALL-1210 Maintenance Rule Program Rev. 4 71111.12 Procedures AD-EG-ALL-1650 License Renewal Aging Management Rev. 4 AD-WC-ALL-0200 On-Line Work Management Rev. 20 AD-WC-ALL-0240 On-Line Risk Management Process Rev. 3 AD-WC-ALL-0420 Shutdown Risk Management Rev. 7 AD-WC-RNP-0420 Shutdown Safety Function Guidelines Rev. 20 CSD-WC-RNP-0240-00 RNP ERAT Guidance Rev. 0 71111.13 Procedures OMM-048 Work Coordination and Risk Management Rev. 70 71111.18 Procedures AD-EG-ALL-1132 Preparation and Control of Design Change Engineering Changes Rev. 22 Engineering Evaluations Reactivity Manipulation Plan R2F33B RCP C Seal Outage Startup Rev. 1 GP-001 Fill and Vent of the Reactor Coolant System Rev. 77 GP-002 Cold Shutdown to Hot Subcritical At No Load TAVG Rev. 147 GP-003 Normal Plant Startup From Hot Standby to Critical Rev. 115 GP-005 Power Operation Rev. 144 GP-007 Plant Cooldown From Mode 3 to Mode 5 Rev. 116 GP-008 Draining the Reactor Coolant System Rev. 98 71111.20 Procedures PLP-006-1 Containment Vessel Inspection and Closeout Rev. 20 71124.01 Corrective Action NCR 2451573 Contaminated individual released from site 12/1/2022
19 Inspection Procedure Type Designation Description or Title Revision or Date Documents NCR 2451283 Missing Rad Material Labels 11/30/2022 NCR 2451572 Scaffold Ladder Tag 12/01/2022 Corrective Action Documents Resulting from Inspection NCR 2451573 Contaminated Individual 12/01/2022 Robinson Nuclear Plant Technical Specifications Robinson Nuclear Plant Technical Specifications, Section 5.7.2, High Radiation Areas Amendment No. 212 Miscellaneous Sample ID 309620_1 RHR Pit Particulate and Iodine Air Sample 12/1/2022 AD-RP-ALL-0002 Radiation and Contamination Surveys Rev. 2 AD-RP-ALL-0004 Radiological Posting and Labeling Revision 6 AD-RP-ALL-0005 Access Controls for High and Locked High Radiation Areas Revision 1 AD-RP-ALL-2017 Access Controls to Very High Radiation Areas and Supplemental Access Controls for HRA and LHRA Revision 8 Procedures PD-RP-ALL-0001 Radiation Worker Responsibilities Revision 14 RNP-M-20221201-10 Valve 752B Disassembly - RHR Pump Room 12/1/2022 Radiation Surveys RNP-M-20221201-15 RHR Pump Room 12/1/2022 Radiation Work Permits (RWPs)
RWP 2510, Task 3
Miscellaneous Maintenance Activities - Low Radiological Risk Revision 28 115S0816006289 Functional Test results of SCBA Regulator/Reducer in Kit
- 16 8/16/2021 Calibration Records 115S0817004101 Functional Test results of SCBA Regulator/Reducer in Kit
- 19 8/16/2021 Corrective Action Documents NCR #s: 02358936, 02371987, 02407150, 02426893, and 02429122.
Various Corrective Action Documents Resulting from Inspection NCR 2453079 AD-RP-ALL-6002 Procedure Revision Request (PRR) to clarify that H. B. Robinson uses Scott Air-Pak Model 4,5 and that non fire brigade SCBA maintenance and operation is completed per site procedure RST-023 not AD-RP-ALL-6002 guidance.
12/14/2022 71124.03 Engineering AD-RP-ALL-2019, TEDE-ALARA Evaluation Worksheet for RWP 2518, Task 11/28/2022
20 Inspection Procedure Type Designation Description or Title Revision or Date Evaluations 19 [work on valve RHR-752B wearing respiratory protection]
BAUER SCBA Compressor Laboratory Report, Compressed Air/Gas Quality Testing Results for quarterly samples obtained between 1/19/2021 and 7/19/2022 Various Miscellaneous BAUER SCBA Compressor Cascade Cylinder 1
Laboratory Report, Compressed Air/Gas Quality Testing Results for samples on 1/19/2021 and 1/19/2022 Various AD-RP-ALL-0003 Radiological Air Sampling Revision 4 AD-RP-ALL-7008 APEX InVivo Whole Body Counter Operation, Quality Checks and Data Review Revision 5 HPP-RESP-005 Sampling of Breathing Air Supplies Revision 3 RST-003 Emergency Kit Inventory Revision 64 Procedures RST-023 Respirator Inspection and Inventory Revision 35 WO 20370687 EST-023, Control Room Emergency Ventilation System Test, Revision 25 11/20/2020 WO 20212875 EST-023, Control Room Emergency Ventilation System Test, Revision 25 11/06/2018 Work Orders WO 20505105 Reperform EST-019, Leak Test of Carbon Filters for HVE-5A/B, [Auxiliary Building Emergency Exhaust Fans]
01/24/2022 Calculations DAW 2021 Nuclide Distribution Report 7/29/2021 Corrective Action Documents NCR #s: 02358936, 02371987, 02414248, 02426893, and 02429122.
Various Robinson Nuclear Power Plant - DLR/SRD Correlations for 2nd Semi-Annual 2021 Monitoring Period [DLR/ED mismatch]
02/28/2022 Miscellaneous NVLAP LAB CODE: 100505-0 Duke Energy Dosimetry Laboratory, Ionizing Radiation Dosimetry Certificate of Accreditation to ISO/IEC 17025:2005 for the following periods:
2020-04-01 through 2021-03-31, 2021-04-01 through 2022-03-31, and 2022-04-01 through 2023-03-31 Various AD-RP-ALL-4021 Investigation of Unusual Dosimetry Occurrence or Possible Overexposure Revision 0 71124.04 Procedures CSD-RP-ALL-Robinson Passive Whole-Body Sensitivity Study Revision 3
21 Inspection Procedure Type Designation Description or Title Revision or Date 4006 RNP-M-20211203-1 ISFSI 7P Annual Survey 12/14/2021 RNP-M-20211203-2 ISFSI 24P Annual Survey 12/6/2021 Radiation Surveys RNP-M-20221109-2 Level 3 Containment Entry at 100% Power for Drone Flight 11/09/2022 NCR 02451576 Error in R-18 Cal 12/01/2022 Corrective Action Documents Resulting from Inspection NCR 02451577 As found testing not performed 12/01/2022 OST-021 Daily Surveillances Revision 50 Procedures PLP-100 Technical Requirements Manual Revision 58 20151625 Containment High Range Rad Monitor Calibration Package 10/21/2018 71124.05 Work Orders 20468846 R-18 Liquid Waste Disposal Radiation Monitor Calibration Package 09/21/2022 AD-EG-ALL-1217 Mitigating System Performance Index (MSPI)
Rev. 3 71151 Procedures AD-PI-ALL-0700 Performance Indicators Rev. 5