ML16118A265

NRC Problem Identification and Resolution Inspection Report 2016007, March 7 11, 2016 and March 21 24, 2016

ML16118A265
Person / Time
Site:	Robinson
Issue date:	04/27/2016
From:	Masters A Reactor Projects Branch 7
To:	Glover R Duke Energy Progress
References
IR 2016007
Download: ML16118A265 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 27, 2016 Richard Michael Glover Site Vice President H. B. Robinson Steam Electric Plant Duke Energy 3581 West Entrance Road, RNPA01 Hartsville, SC 29550

SUBJECT:

H.B. ROBINSON STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2016007

Dear Mr. Glover:

On March 24, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution biennial inspection at your H.B. Robinson Steam Electric Plant, Unit 2 and discussed the results of this inspection with you and other members of your staff.

Additionally, on April 14, 2016, a re-exit meeting was conducted via teleconference with Mr. S. Connelly, and other members of your staff to discuss the final results of the inspection.

The inspection team documented the results of this inspection in the enclosed inspection report.

Based on the inspection samples, the inspection team determined that your staffs implementation of the corrective action program was adequate to support nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the plants process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into plant programs, processes, and procedures. The team determined that your staffs performance in each of these areas was adequate to support nuclear safety.

Additionally, the team determined that your plants management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available.

The team did not identify any findings or violations of more than minor significance.

M. Glover 2 In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Anthony D. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket No.: 50-261 License No.: DPR-23

Enclosure:

Inspection Report 05000261/2016007 w/

Attachment:

Supplemental Information cc Distribution via ListServ

ML16118A265 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DCI RII:DRP RI:DRP RII:DRP RII:DRP SIGNATURE JSD via email DXW4 CDJ1 via email NSL2 GFS1 via email GTHh ADM2 NAME JDodson DJackson CJones NStaples GStock GHopper AMasters DATE 4/19/16 4/21/16 4/18/16 4/25/16 4/18/16 4/25/16 4/27/16 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

R. Glover 3 Letter to R. Glover from Anthony D. Masters dated April 27, 2016

SUBJECT:

H.B. ROBINSON STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2016007 DISTRIBUTION:

S. Price, RII L. Gibson, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMRobinson Resource

U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 50-261 License No.: DRP-23 Report No.: 05000261/2016007 Licensee: Duke Energy Progress, Inc.

Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: March 7 - 11, 2016 March 21 - 24, 2016 Inspectors: D. Jackson, Project Engineer, Team Leader C. Jones, Senior Construction Inspector N. Staples, Senior Project Inspector G. Stock, Resident Inspector, Region I J. Dodson, Senior Project Engineer Approved by: Anthony D. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY

OF FINDINGS IR 05000261/2016007; March 7 - 24, 2016; H.B. Robinson Steam Electric Plant, Unit 2; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by four regional inspectors and a resident inspector. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee effectively identified problems and entered them into the corrective action program (CAP) for resolution. Generally, prioritization and evaluation of issues were adequate, cause evaluations were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.

The inspectors determined that overall audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. The licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the CAP. The licensee appropriately incorporated industry and internal operating experience in its cause evaluations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns and to use the CAP to resolve those concerns.

No findings of more than minor significance were identified.

REPORT DETAILS

4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution

.1 Corrective Action Program Effectiveness

a. Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed NCRs that had been issued between May 2014 and February 2016, including a detailed review of selected NCRs associated with the following risk-significant systems: emergency diesel generators, dedicated shutdown diesel generator, DC sources, high head safety injection system, and service water system. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process, the inspectors selected a representative number of NCRs that were identified and assigned to the major plant departments, including organizational effectiveness, emergency preparedness, health physics, and security. These NCRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed.

The inspectors conducted plant walk-downs of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed NCRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-related equipment issues.

Control room reviews were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP. The inspectors reviewed operator workarounds and operator burden screenings and verified compensatory measures were implemented for deficient equipment.

The inspectors conducted a detailed review of selected NCRs to assess the adequacy of the root cause, apparent cause, and quick cause evaluations of the problems identified.

The inspectors reviewed these evaluations against the issues discussed in the NCRs and the guidance in licensee procedures, AD-PI-ALL-0101, Root Cause Evaluations, AD-PI-ALL-0102, Apparent Cause Evaluations, and AD-PI-ALL-0103, Quick Cause Evaluations. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent of condition, and extent of cause, as required.

4 The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence for significant conditions adverse to quality. The inspectors reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended the Centralized Screening Team meetings, where NCRs were screened for significance, to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold. The inspectors also attended various plant meetings to observe management oversight functions of the corrective action process. These included CAP Review meetings, and Performance Improvement Oversight Committee meetings. Documents reviewed are listed in the Attachment.

b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating NCRs as described in licensee procedure AD-PI-ALL-0100, Corrective Action Program, and managements expectation that employees were encouraged to initiate NCRs for any reason. Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that deficiencies were being identified and placed in the CAP.

Problem Prioritization and Evaluation Based on the review of NCRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the NCR significance determination guidance in procedure AD-PI-ALL-0100. The inspectors determined that in general, adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that plant personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used to evaluate NCRs depending on the type and complexity of the issue consistent with the applicable cause evaluation procedures.

In addition, the team identified a performance deficiency associated with the licensees problem prioritization and evaluation. This issue was screened as minor in accordance with Inspection Manual Chapter (IMC) 0612 Appendix B, Issue Screening.

• The inspectors determined that the licensees failure to implement the requirements for a nonconforming condition was a performance deficiency.

Procedure AD-OP-ALL-0105, Operability Determinations and Functionality

5 Assessments, required an immediate determination of operability upon discovery of a degraded or nonconforming condition. For a nonconforming condition, an evaluation and determination of applicable compensatory actions were required.

However, on April 8, 2015, the licensee failed to implement the requirements for a nonconforming condition as required by procedure AD-OP-ALL-0105. Root Cause Evaluation 729926 identified a nonconforming condition involving an inadequate post-modification test of the reactor protection system (RPS). Specifically, the licensee determined that a newly installed trip input to the RPS had not been completely verified by appropriate post-modification testing. As a result, a supplemental trip input to the reactor trip breakers remained in service without the required evaluation and/or applicable compensatory actions. The performance deficiency was determined to be minor because no failure scenarios were identified which would inhibit a trip input to the RPS in response to a safety injection signal.

Additionally, the licensee was tracking the development and implementation of an adequate post-modification test as NCR 729926. This issue has been documented in the licensees CAP as NCR 2013211.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The team reviewed performance indicators, NCRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

In addition, the team identified a performance deficiency associated with the licensees effectiveness of corrective actions. This issue was screened as minor in accordance with IMC 0612 Appendix B, Issue Screening.

• The inspectors determined that the failure to adequately implement corrective actions was a performance deficiency. Two examples were identified:

o Licensee procedure AD-PI-ALL-0100, Corrective Action Program, Section 5.12.3.a.1, states that corrective actions may not be closed to future tense activities. Additionally, Section 5.13, requires that the licensee determine if the action has been completed and verify the completed action is adequately documented to support the results, to approve and close the corrective action. However, for NCR 668755, the licensee completed and approved the corrective action (CORR-1) to a future action discussed in CORR-2. The corrective action (CORR-2) was then marked as completed and approved in the CAP database without being adequately implemented.

This resulted in the updated training procedures not incorporating all the corrective action items as required. The performance deficiency was determined to be minor because there was no safety impact on fire brigade training or response. This issue has been documented in the licensees CAP as NCR 2012807.

6 o Licensee procedure AD-PI-ALL-0100, Section 5.9.4, states in part that the responsible manager or designee, should ensure action assignments are generated in accordance with the evaluation. However, the team determined that RCE 752138 did not ensure action assignments were generated in accordance with the evaluation. Specifically for NCR 752138, the CAPR was to revise procedure AD-EG-ALL-1132, Preparation and Control of Design Change and Engineering Changes, to require written justification when deviating from vendor specifications; however the CAPR was not entered into or assigned in the corrective action program database. As a result, the procedure had not been revised. The performance deficiency was determined to be minor because the effectiveness review action item (originally due July 2016) most likely would have revealed that the CAPR was not completed. This issue has been documented in the licensees CAP as NCR 2011186.

c. Findings No findings were identified.

.2 Use of Operating Experience

a. Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience (OE), reviewed licensee procedure AD-PI-ALL-0400, Operating Experience Program, and reviewed the licensees OE database to assess the effectiveness of how external and internal OE information was used to prevent similar or address recurring problems at the plant. Licensee evaluations of selected OE documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), issued since June 2014, were reviewed to determine if the licensee had appropriately evaluated each notification for applicability to the H.B. Robinson Steam Electric Plant, Unit 2, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.

b. Assessment Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening OE for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of the document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in root cause and apparent cause evaluations in accordance with licensee procedures.

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c. Findings No findings were identified.

.3 Self-Assessments and Audits

a. Inspection Scope The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensees audits and self-assessments. Additionally, the inspectors reviewed audits and self-assessments to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedures AD-PI-ALL-0300, Self-Assessment and Benchmark Programs. The inspectors also verified the audits and assessments were consistent with the NRCs assessment of the licensees CAP. Documents reviewed are listed in the Attachment.

b. Assessment The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that NCRs were created to document all areas for improvement and findings resulting from the self-assessments and verified that actions were completed consistently with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the NCRs reviewed that were initiated as a result of adverse trends.

c. Findings No findings were identified.

.4 Safety-Conscious Work Environment

a. Inspection Scope During the course of the inspection, the team assessed the plants safety-conscious work environment through review of the plants Employee Concerns Program (ECP) and interviews with various department personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate. Both informal discussions and formal individual interviews with plant employees, were used to develop a general perspective of the safety-conscious work environment at the site and to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The team also reviewed the sites most recent safety culture assessment. Documents reviewed are listed in the Attachment.

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b. Assessment Based on the interviews conducted and the NCRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

c. Findings No findings were identified.

4OA6 Meetings, Including Exit On March 24, 2016, the inspectors presented the inspection results to Mr. Glover and other members of the site staff. The inspectors confirmed that proprietary information was not retained by the inspectors or documented in this report.

On April 14, 2016, the inspectors conducted a re-exit meeting via teleconference with Mr. S. Connelly, and other members of your staff to discuss the final results of the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee personnel:

K. Burian, Performance Improvement C. Caudell, Regulatory Affairs S. Connelly, Regulatory Affairs Manager, Acting D. Hall, Nuclear Oversight D. Hoffman, Director of Organizational Effectiveness M. Hughes, Maintenance P. Morales, Employee Concerns Coordinator (Harris)

R. Perkins, Maintenance T. Pilo, Emergency Preparedness Manager L. Smith, Operations NRC personnel:

K. Ellis, Senior Resident Inspector C. Scott, Resident Inspector LIST OF REPORT ITEMS Opened and Closed None Closed None Discussed None Attachment

LIST OF DOCUMENTS REVIEWED Procedures:

AD-DC-ALL-0201, Development and Maintenance of Controlled Procedure Manual Procedures, Rev. 15 AD-EG-ALL-1132, Preparation and Control of Design Change Engineering Changes, Rev. 3 AD-EG-ALL-1155, Post Modification Testing, Rev. 1 AD-EG-ALL-1320, Predictive Maintenance, Rev. 0 AD-LS-ALL-0003, NRC Audit and Inspection Activities, Rev. 3 AD-MN-ALL-0002, Foreign Material Exclusion, Rev. 5 AD-MN-ALL-005, Nuclear Planning, Rev. 11 AD-OP-ALL-0105, Operability Determinations and Functionality Assessments, Rev. 2, AD-PI-ALL-0003, Change Management, Rev. 3 AD-PI-ALL-0105, Effectiveness Reviews, Rev. 1 AD-PI-ALL-0400, Operating Experience Program, Rev, 2, AD-SY-ALL-0460, Managing Fatigue and Work Hour Limits, Rev. 0 AD-TQ-ALL-0640, Review and Evaluation of Supplemental Personnel Qualifications, Rev. 4 AD-WC-ALL-0210, Work Request Initiation, Screening, Prioritization and Classification, Rev. 5 ADM-NGGC-0110, Oversight of Contractors, Shared Resources, Vendors and Technical Representatives (Supplemental Personnel), Rev. 15 AOP-022, Loss of Service Water, Rev. 35 AOP-022-BD, Basis Document, Loss of Service Water, Rev. 35 OST-020, Shiftly Surveillances, Rev. 57 OST-163, Safety Injection Test and Emergency Diesel Generator Auto Start on Loss of Power and Safety Injection (Refueling), Rev. 67, completed 6/22/2015 PLP-061, Special Nuclear Material Control and Accounting, Rev. 19 PM-008, Emergency Diesel Generator Inspection Number 2 (24 Months), Rev. 71 REG-NGCC-013, Evaluating and Reporting of Defects and Noncompliance in Accordance with 10 CFR 21, Rev. 5 SP-1527, North Service Water Header Inspection, Rev. 17 Nuclear Condition Reports:

618769, 653370, 654789, 664223, 668755, 671656, 677704, 682126, 686277, 687061, 687398, 688793, 688816, 689644, 691835, 692551, 698782, 701126, 701692, 702783, 708540, 709590, 711429, 714792, 714858, 714875, 715032, 716046, 717850, 718008, 724286, 725330, 725330, 725333, 725455, 725645, 726167, 728030, 728095, 728490, 728666, 728962, 729260, 729397, 729926, 730021, 730754, 730804, 730912, 733381, 733792, 736170, 737613, 738953, 740247, 740529, 743041, 743653, 743731, 744556, 745403, 745494, 746346, 747690, 747950, 749085, 749789, 749836, 750519, 750679, 750841, 750869, 751040, 752138, 754912, 756549, 757545, 758721, 758740, 759987, 760353, 1932048, 1932050, 1938518, 1938531, 1941394, 1957216, 1964652, 1965520, 1965692, 1966539, 1966795, 1967082, 1970196, 1972402, 1981085, 1984226, 1984228, 1992364, 1993873, 2001614 Action Requests:

422989, 465406, 618771, 633207, 640902, 642282, 649806, 663140, 665574, 675465, 683591, 683695, 684198, 684498, 702171, 703338, 722314, 746916, 750848, 754233

3 Work Orders:

2007193-01, 2047219, 2047223, 2066875, 10055270, 10055271, 12037023-01, 12291565, 13312543, 13312552, 13312554, 13312556, 13312557-01, 13312559-01, 13312560, 13312562, 13312563-01, 13312566-01, 13312570, 13312571-01, 13312573-01, 13312574, 13313501, 13313522, 13313866, 13313867, 13316415, 13344212, 13366353, 13420252, 13423288, 13433352, 13438130, 13438132, 13448109, 13472068, 13525414, 13526948, 13532803, 13540808, 13540808, 13540810, 20008608, 20021211-01, 20034481, 20044500-01 Audits and Self-Assessments:

2015-RNP-EP-01, Robinson Emergency Preparedness Audit R-EP-14-02, Robinson Nuclear Plant Emergency Preparedness Performance Review SAST 687398 SAST 719531 SAST 724497 SAST 731606 Miscellaneous Documents:

DBD R87038, Design Basis Document Safety Injection System, Rev. 0 Drawing 8190628, Control Wiring Diagram, Sheet No. 155, Rev. 11 Drawing SK-94830-W-2000, Containment Spray System Flowmeter FIT-949, Sht 1, Rev. 0 Drawing 5379-3251, Rev. 11, Reactor Protection System, Sheet 13 of 14 Drawing HBR2-9717, Rev. 6, Fire Area/Zone Locations, Sheet 1 Drawing HBR2-10428, Rev. 5, Reactor Aux. Bldg. El. 226-0 Cable Tray Layout (S)

Drawing HBR2-10449, Rev. 1, Cable Spread Room Reactor Aux. Bldg. El. 242- 6 Cable Tray Layout Drawing HBR2-10427, Rev. 7, Reactor Aux. Bldg. El. 226-0 Cable Tray Layout (N)

EC 300503, UFSAR Updates for Post Renewed License-Newly Identified SCCs, Rev. 0 EC 67840, Permanent Flow Indicator for SI Pump Test Line EC 94830, FIT-949 CV Spray Flow NAOH Indicating Transmitter Replacement, Rev. 8 EC 79035, Rev. 0, RO-27 Cable Toning Safe Shutdown Update EC 99431, Rev. 0, Evaluate the Current Configuration of the DC Electrical Distribution System and the Reactor Protection System to Ensure Both Systems are still Operable, dated 2/3/2015 EC 94830, FIT-949 CV Spray Flow NAOH Indicating Transmitter Replacement, Rev. 8 EC 66508, Replace SST-2F and SST-2G EC 84562, Concrete Pieces Located in the B CCW HX Service Water Side Inlet EGR-NGGC-0034 Attachment 1, Margin Issue Evaluation, Rev. 0 G-190199, Service & Cooling Water System Flow Diagram, Rev. 80 LER 2015-001, Rev. 0, Reactor Protection and DC Electrical System Inoperability Due to Inadvertent Parallel Connection of Safety Trains, dated 3/30/2015 Letter LTR-0270-0043-0004, Rev. 1, from MPR Associates, Inc. to Duke Energy, Robinson Motor Operated Potentiometer Failure Analysis, dated April 29, 2014 ODP Reference Guide, Rev. 2 RNP-10-0408, Original Installed Diaphragm Seal Isolator Obsolete RNP-11-0406, Refurbish SI Pump C Motor RNP-L/LR-0113, System Screening Safety Injection System, Rev. 2 RNP-L/LR-0313, Aging Management Review Safety Injection System, Rev. 5 SD-004, Service Water, Rev. 14 System Health Report 2080, Safety Injection, Q1 through Q4-2015 System Health Report 2080, Safety Injection, Q2 through Q4-2014 Westinghouse Memorandum File 10-1080

4 NCRs written as a result of this inspection:

2008466, 2016 PI&R inspection Concern, Battery Room Grounding 2008683, 2016 PI&R Inspection CR Traceability for Resolution 2008668, 2016 PI&R Inspection RNP ECP Docs not IAW AD-NO-ALL-0202 2009243, 2016 PI&R Inspection CV Spray A Pump Oil Particulate Levels 2009264, 2016 PI&R Inspection CV Spray Pump B Oil Particulate Levels 2009661, 2016 PI&R Inspection - Regulatory Reporting Vulnerability 2009688, 2016 PI&R Inspection Concern, PMT Following LCO 3.0.3 2011186, 2016 PI&R Inspection: RCE 752138 CAPR not entered into CAS 2011625, 2016 PI&R Inspection CR Improperly Screened as NOT CAP 2011631, 2016 PI&R Inspection: Public Address System in Building 110 2012807, 2016 PI&R Inspection: CORR 668755-25 Incorrectly Implemented 2012993, 2016 PI&R Inspection PA Systems in Bldgs 110, 115 & 105 OOS 2013211, 2016 PI&R Inspection NCON Not generated in CR 729926 2013533, 2016 PI&R Inspection Issue Closeout CRs Not Generated 2013534, 2016 PI&R Inspection Employee Concerns Box OOS 2013539, 2016 PI&R Inspection Comp Measures Not Implemented Timely 2013896, 2016 NRC PI&R Inspection Drawing Issues 2013923, 2016 NRC PI&R Inspection Documentation Issue CVC-204B