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| issue date = 06/10/2014
| issue date = 06/10/2014
| title = IR 05000261-14-008; on 04/21/2014 - 05/05-08/2014; H.B. Robinson Steam Electric Plant, Unit 2; Biennial Inspection of the Problem Identification and Resolution Program
| title = IR 05000261-14-008; on 04/21/2014 - 05/05-08/2014; H.B. Robinson Steam Electric Plant, Unit 2; Biennial Inspection of the Problem Identification and Resolution Program
| author name = Rose S D
| author name = Rose S
| author affiliation = NRC/RGN-II/DRP/RPB7
| author affiliation = NRC/RGN-II/DRP/RPB7
| addressee name = Gideon W R
| addressee name = Gideon W
| addressee affiliation = Duke Energy Progress, Inc
| addressee affiliation = Duke Energy Progress, Inc
| docket = 05000261
| docket = 05000261
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 10, 2014  
{{#Wiki_filter:June 10, 2014


Mr. William Vice President - Robinson Plant Duke Energy Progress, Inc.
==SUBJECT:==
H.B. ROBINSON STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2014008


H. B. Robinson Steam Electric Plant Unit 2 3581 West Entrance Road
==Dear Mr. Gideon:==
On May 8, 2014, 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 Mr. R. Glover and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.


Hartsville, South Carolina 29550
Based on the inspection samples, the inspection team determined that your staffs implementation of the corrective action program supported 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 stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.


SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2014008
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 station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.


==Dear Mr. Gideon:==
Finally, the team determined that your stations 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.
On May 8, 2014, 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 Mr. R. Glover and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection


report.
However, the enclosed inspection report discusses one NRC-identified finding of very low safety significance (Green) identified during this inspection. This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or the significance of this NCV, 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, U.S.


Based on the inspection samples, the inspection team determined that your staff's implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staff's performance was adequate to support nuclear safety.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the H.B. Robinson facility.


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 station programs, processes, and procedures. The team determined that your station's performance in each of these areas supported nuclear safety.
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 (PARS) component of the NRC's 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/


Finally, the team determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the team's observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available.
Steven D. Rose, Branch Chief Reactor Projects Branch 7 Division of Reactor Projects


However, the enclosed inspection report discusses one NRC-identified finding of very low safety significance (Green) identified during this inspection. This finding was determined to involve a violation of NRC requirements. The NRC is treati ng this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or the significance of this NCV, 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, U.S.
Docket Nos.: 50-261 License Nos.: DPR-23


Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the H.B. Robinson facility.
===Enclosure:===
Inspection Report 05000261/2014008 w/Attachment: Supplemental Information


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 NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Managem ent System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
REGION II==
Docket No.:  


Sincerely,
50-261
/RA/ Steven D. Rose, Branch Chief Reactor Projects Branch 7


Division of Reactor Projects Docket Nos.: 50-261 License Nos.: DPR-23  
License No.:
DRP-23  


Enclosure: Inspection Report 05000261/2014008 w/Attachment: Supplemental Information
Report No.:
05000261/2014008  


cc Distribution via ListServ
Licensee:


_________________ ____ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRP RII:DRS RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE JGW /RA/ RRR /RA/ Via email Via email Via email Via email GTH /RA/ SDR /RA/ NAME JWorosilo RRodriguez NStaples MSingletary JDodson DJackson GHopper SRose DATE 06/09/2014 06/06/2014 06/05/201 06/05/2014 06/05/2014 06/05/2014 06/09/2014 06/09/2014 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO Letter to from Steven D. Rose dated June 10, 2014 SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2014008
Duke Energy Progress, Inc.


DISTRIBUTION
Facility:  
: S. Price, RII L. Douglas, RII OE Mail RIDSNRRDIRS


PUBLIC RidsNrrPMRobinson Resource
H. B. Robinson Steam Electric Plant, Unit 2


Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Location:


==REGION II==
3581 West Entrance Road
Docket No.: 50-261


License No.: DRP-23
Hartsville, SC 29550


Report No.: 05000261/2014008
Dates:  


Licensee: Duke Energy Progress, Inc.
April 21 - 25, 2014 May 5 - 8, 2014


Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550
Inspectors:  


Dates: April 21 - 25, 2014 May 5 - 8, 2014
J. Worosilo, Senior Project Engineer, Team Leader R. Rodriguez, Senior Project Engineer N. Staples, Senior Project Inspector M. Singletary, Reactor Inspector (training)
J. Dodson, Senior Project Engineer D. Jackson, Project Engineer


Inspectors: J. Worosilo, Senior Project Engineer, Team Leader R. Rodriguez, Senior Project Engineer N. Staples, Senior Project Inspector M. Singletary, Reactor Inspector (training)
Approved by:
J. Dodson, Senior Project Engineer D. Jackson, Project Engineer Approved by: Steven D. Rose, Branch Chief, Reactor Projects Branch 7  
Steven D. Rose, Branch Chief, Reactor Projects Branch 7 Division of Reactor Projects


Division of Reactor Projects Enclosure  
Enclosure  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000261/2014008; April 21 - May 8, 2014; H.B. Robinson Steam Electric Plant, Unit 2; Biennial Inspection of the Problem Identification and Resolution Program.
IR 05000261/2014008; April 21 - May 8, 2014; H.B. Robinson Steam Electric Plant, Unit 2;  


The inspection was conducted by three senior project engineers, one senior project inspector, a project engineer, and a reactor inspector. One finding of very low safety significance (Green) was identified during this inspection. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using IMC 0609, "Significance Determination Process," dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Aspects Within Cross Cutting Areas," dated December 19, 2013.
Biennial Inspection of the Problem Identification and Resolution Program.


All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "R eactor Oversight Process," Revision 5.
The inspection was conducted by three senior project engineers, one senior project inspector, a project engineer, and a reactor inspector. One finding of very low safety significance (Green)was identified during this inspection. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using IMC 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross Cutting Areas, dated December 19, 2013.


Identification and Resolution of Problems
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.


The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for probl ems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner. However, the team did identify deficiencies in the areas of identification of problems and effectiveness of corrective actions.
Identification and Resolution of Problems


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. Operating experience usage was found to be generally acceptable and integrated into the licensee's processes for performing and managing work, and plant operations.
The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems 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. However, the team did identify deficiencies in the areas of identification of problems and effectiveness of corrective actions.
 
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. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.


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 to management and use the CAP to resolve those concerns.
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 to management and use the CAP to resolve those concerns.


===NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===
===Cornerstone: Initiating Events===
===Cornerstone: Initiating Events===
Green: The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality regarding steam generator tube leakage due to poor maintenance practices. Specifically, on February 27, 2014, the C steam generator showed indications of a primary to secondary tube leak due to foreign material that was introduced during the fall 2013 refueling outage. As immediate corrective actions, on March 7, 2014, the licensee shutdown the plant and repaired the leak. This violation was entered into the licensees CAP as nuclear condition reports (NCRs) 683695, 683593, and 683591.


Green:  The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," for the licensee's failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality regarding steam generator tube leakage due to poor maintenance practices. Specifically, on February 27, 2014, the "C" steam generator showed indications of a primary to secondary tube leak due to foreign material that was introduced during the fall 2013 refueling outage. As immediate corrective actions, on March 7, 2014, the licensee shutdown the plant and repaired the leak. This violation was entered into the licensee's CAP as nuclear condition reports (NCRs) 683695, 683593, and 683591.
The licensees failure to implement appropriate corrective actions to address poor worker practices to prevent recurrence of a steam generator tube leak was a performance deficiency.


The licensee's failure to implement appropriate corrective actions to address poor worker practices to prevent recurrence of a steam generator tube leak was a performance deficiency.
The finding was more than minor because it was associated with the initiating events cornerstone equipment performance attribute and it 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, foreign material entered the steam generator and damaged a steam generator tube, which increased the likelihood of a steam generator tube rupture. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012.


The finding was more than minor because it was associated with the initiating events cornerstone equipment performance attribute and it 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, foreign material entered the steam generator and damaged a steam generator tube, which increased the likelihood of a steam generator tube rupture. The inspectors screened this finding using IMC 0609, Appendix A, "The Significant Determination Process (SDP) For Findings At-Power," dated June 19, 2012. The finding screened as Green per Section D of Exhibit 1, "Initiating Events Screening Questions," because testing showed that the affected steam generator tube could sustain three times the differential pressure across the tube during normal full power and that the steam generator did not violate the accident leakage performance criterion. The performance deficiency does not have a cross cutting aspect because the last revision of the root cause evaluation was completed in 2011 and it is not indicative of current licensee performance.
The finding screened as Green per Section D of Exhibit 1, Initiating Events Screening Questions, because testing showed that the affected steam generator tube could sustain three times the differential pressure across the tube during normal full power and that the steam generator did not violate the accident leakage performance criterion. The performance deficiency does not have a cross cutting aspect because the last revision of the root cause evaluation was completed in 2011 and it is not indicative of current licensee performance.


(Section 4OA2.1.c)
(Section 4OA2.1.c)
Line 112: Line 121:
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Problem Identification and Resolution==
==4OA2 Problem Identification and Resolution==
===.1 Corrective Action Program Effectiveness===
===.1 Corrective Action Program Effectiveness===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's CAP procedures which described the administrative process for initiating and re solving problems primarily use of 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 June 2012 and April 2014, including a detailed review of selected NCRs associated with the following risk-significant systems: auxiliary feedwater, reactor protection system, and alternating current (AC) distribution system. 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. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRC's Reactor Oversight Process (ROP), the inspectors selected a representative number of NCRs that were identified and assigned to the major plant departments, including emergency preparedness, health physics, chemistry, and security. These NCRs were reviewed to assess each department's threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective  
The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily use of 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 June 2012 and April 2014, including a detailed review of selected NCRs associated with the following risk-significant systems: auxiliary feedwater, reactor protection system, and alternating current (AC) distribution system. 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. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of NCRs that were identified and assigned to the major plant departments, including emergency preparedness, health physics, chemistry, 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. The inspectors reviewed selected NCRs, verified corrective actions were implemented, and attended 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.


actions. The inspectors reviewed select ed NCRs, verified corrective actions were implemented, and attended 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 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-dependent issues.


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-dependent issues.
Control room walk-downs were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP. Operator workarounds and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.


Control room walk-downs were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP. Operator workarounds and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the  
The inspectors conducted a detailed review of selected NCRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the issues discussed in the NCRs and the guidance in licensee procedure CAP-NGGC-0205, Condition Evaluation and Corrective Action Process. 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.


field.
The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.


The inspectors conducted a detailed review of selected NCRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the issues discussed in the NCRs and the guidance in licensee procedure CAP-NGGC-0205, "Condition Evaluation and Corrective Action Process."  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. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.
The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.


The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP. 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 reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.


The inspector's reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRC's assessment of the licensee's CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Work Ownership Committee (WOC) meetings and Performance Improvement Oversight Committee (PIOC) meetings.
The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Work Ownership Committee (WOC) meetings and Performance Improvement Oversight Committee (PIOC) meetings.


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.


b. Assessment Problem Identification
b.


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 procedures CAP-NGGC-0200, "Condition Identification and Screening Process," management's expectation that employees were encouraged to initiate NCRs for any reason, and the relatively few number of deficiencies identified by inspectors during plant walkdowns not already entered into the CAP. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
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 procedures CAP-NGGC-0200, Condition Identification and Screening Process, managements expectation that employees were encouraged to initiate NCRs for any reason, and the relatively few number of deficiencies identified by inspectors during plant walkdowns not already entered into the CAP. 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 system deficiencies were being identified and placed in the CAP.
Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.


The team identified a performance deficiency associated with the licensee's problem identification of issues. This issue was screened as minor in accordance with IMC 0612 Appendix B, "Issue Screening."
The team identified a performance deficiency associated with the licensees problem identification of issues. This issue was screened as minor in accordance with IMC 0612 Appendix B, Issue Screening.
* During the review of NCR 605058, the inspectors identified a performance deficiency for failure to identify a condition adverse to quality associated with deficiencies of post maintenance testing (PMT) of reactor protection and safeguards relays. The failure to properly identify that procedure PLP-033, "Post Maintenance Testing Program," did not provide measures to ensure that full functional test were developed for reactor protection and safeguards relays was a performance deficiency. This performance deficiency was considered minor because the safety related functions of the identified safety related relays affected were being verified via operation surveillance test (OST) procedures. This issue has been documented  
* During the review of NCR 605058, the inspectors identified a performance deficiency for failure to identify a condition adverse to quality associated with deficiencies of post maintenance testing (PMT) of reactor protection and safeguards relays. The failure to properly identify that procedure PLP-033, Post Maintenance Testing Program, did not provide measures to ensure that full functional test were developed for reactor protection and safeguards relays was a performance deficiency. This performance deficiency was considered minor because the safety related functions of the identified safety related relays affected were being verified via operation surveillance test (OST) procedures. This issue has been documented as NCRs 0685848, 0683751, 0686111 and 0685871.


as NCRs 0685848, 0683751, 0686111 and 0685871.
Problem Prioritization and Evaluation


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 CAP-NGGC-0200.


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 CAP-NGGC-0200. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that adequate consideration was given to system or component operability and associated plant risk.


The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensee's 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 CAP-NGGC-0205.
The inspectors determined that station 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 CAP-NGGC-0205.


Effectiveness of Corrective Actions
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 and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, NCRs, and effectiveness reviews demonstrated 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.
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 and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, NCRs, and effectiveness reviews demonstrated 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.


However, the team identified one example where the licensee failed to take adequate corrective actions to preclude repetition. This issue is described below in the "Findings" section, Section 4OA2.1.c of this report as "Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak."
However, the team identified one example where the licensee failed to take adequate corrective actions to preclude repetition. This issue is described below in the Findings section, Section 4OA2.1.c of this report as Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak.


In addition, the team identified a performance deficiency associated with the licensee's effectiveness of corrective actions. This issue was screened as minor in accordance with IMC 0612 Appendix B, "Issue Screening."
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.
* Procedure CAP-NGGC-0205, "Condition Evaluation and Corrective Action Process," Section 9.2 "Corrective Action Plan," states that: "A corrective action (CORR) shall not be closed to a lower tier assignment type.The inspectors identified three examples of inadequate closure of CORRs to lower tier assignments. Specifically, NCRs 645821-12 and 635420-5 were closed to procedure revision requests (PRRs) and NCR 640903-3 was closed to a training request form (TRF). The closing of the CORRs to lower tier assignments was a performance deficiency. This performance deficiency was minor because even though the PRRs are still open they are scheduled to be completed prior to the affected procedures being used. Also, the TRF was completed and determined that no training was required. This issue has been documented as NRC 686121.
* Procedure CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Section 9.2 Corrective Action Plan, states that: A corrective action (CORR) shall not be closed to a lower tier assignment type. The inspectors identified three examples of inadequate closure of CORRs to lower tier assignments. Specifically, NCRs 645821-12 and 635420-5 were closed to procedure revision requests (PRRs)and NCR 640903-3 was closed to a training request form (TRF). The closing of the CORRs to lower tier assignments was a performance deficiency. This performance deficiency was minor because even though the PRRs are still open they are scheduled to be completed prior to the affected procedures being used. Also, the TRF was completed and determined that no training was required. This issue has been documented as NRC 686121.


====c. Findings====
====c. Findings====
=====Introduction:=====
=====Introduction:=====
The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," for the licensee's failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality regarding steam generator tube leakage due to poor maintenance practices.
The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality regarding steam generator tube leakage due to poor maintenance practices.


=====Description:=====
=====Description:=====
On January 8, 2004, the licensee documented a significant condition adverse to quality regarding evidence of a minor primary to secondary side leakage. The licensee initiated NCR 115704 and performed a root cause evaluation (RCE). In Revision 1 of the RCE, the licensee determined that one of the root causes of the steam generator tube leak was poor maintenance work practices. To address this root cause, the licensee implemented the following CAPR:
On January 8, 2004, the licensee documented a significant condition adverse to quality regarding evidence of a minor primary to secondary side leakage.
* CAPR 115704-17: Revise as necessary ADM-NGGC-0110, "Oversight of Contractors, Shared Resources, Vendors, and Technical Representatives," to include this action request subject matter, for review, in the maintenance services orientation package for secondary maintenance every outage.
 
The licensee initiated NCR 115704 and performed a root cause evaluation (RCE). In Revision 1 of the RCE, the licensee determined that one of the root causes of the steam generator tube leak was poor maintenance work practices. To address this root cause, the licensee implemented the following CAPR:
* CAPR 115704-17: Revise as necessary ADM-NGGC-0110, Oversight of Contractors, Shared Resources, Vendors, and Technical Representatives, to include this action request subject matter, for review, in the maintenance services orientation package for secondary maintenance every outage.


On June 9, 2010, during an effectiveness review per NCR 115704-20; the licensee determined that poor worker practices were not effectively addressed by the CAPRs.
On June 9, 2010, during an effectiveness review per NCR 115704-20; the licensee determined that poor worker practices were not effectively addressed by the CAPRs.


The licensee performed an adverse condition investigation to evaluate the ineffective corrective actions (NCR 403879). As a result of the investigation, the licensee determined that the following CAPR was going to be added to the original RCE (NCR 115704 Rev.3, completed on August 9, 2011) to address poor maintenance work practices:
The licensee performed an adverse condition investigation to evaluate the ineffective corrective actions (NCR 403879). As a result of the investigation, the licensee determined that the following CAPR was going to be added to the original RCE (NCR 115704 Rev.3, completed on August 9, 2011) to address poor maintenance work practices:
* CAPR 115704-23: Provide training to address poor foreign material exclusion (FME) performance in accordance with the INPO letter on "Causal Analysis for Foreign Material Intrusion Events."
* CAPR 115704-23: Provide training to address poor foreign material exclusion (FME)performance in accordance with the INPO letter on Causal Analysis for Foreign Material Intrusion Events.


Root Cause 115704 Revision 3 also added the following CAPR and CORRs to address poor work practices:
Root Cause 115704 Revision 3 also added the following CAPR and CORRs to address poor work practices:
* Revise procedure MNT-NGGC-007, "Forei gn Material Exclusion Program," to address foreign material created by the degradation of plant equipment differently from FME issues caused during the maintenance activity in process.
* Revise procedure MNT-NGGC-007, Foreign Material Exclusion Program, to address foreign material created by the degradation of plant equipment differently from FME issues caused during the maintenance activity in process.
* CORR 115704-30: Revise existing FME training to include a dynamic learning activity (DLA) that incorporates FME recognition, reinforces notification for loss of FME controls and include risk awareness.
* CORR 115704-30: Revise existing FME training to include a dynamic learning activity (DLA) that incorporates FME recognition, reinforces notification for loss of FME controls and include risk awareness.
* CORR 115704-31: Formalized oversight of contractor FME performance during work on open secondary systems. Oversight must be documented and include unannounced field inspections of logs and plant systems while work is in progress.
* CORR 115704-31: Formalized oversight of contractor FME performance during work on open secondary systems. Oversight must be documented and include unannounced field inspections of logs and plant systems while work is in progress.


The inspectors identified the following issues with the licensee's corrective actions listed  
The inspectors identified the following issues with the licensees corrective actions listed above:
 
above:
* CAPR 115704-17 was not adequately implemented. The maintenance orientation package was revised, however procedure ADM-NGGC-0110 was not revised; therefore the action completed was not pragmatic and was not carried into the last refueling outage in fall 2013.
* CAPR 115704-17 was not adequately implemented. The maintenance orientation package was revised, however procedure ADM-NGGC-0110 was not revised; therefore the action completed was not pragmatic and was not carried into the last refueling outage in fall 2013.
* CAPR 115704-23 was canceled and no other CAPR was initiated to address the root cause associated with poor maintenance practices.
* CAPR 115704-23 was canceled and no other CAPR was initiated to address the root cause associated with poor maintenance practices.
* The licensee intended to implement a CAPR to revise procedure MNT-NGGC-007; however, this CAPR was never properly implemented in the CAP. The changes in the procedure were implemented as part of several PRRs, outside of RCE 115704, Revision 3. The changes did not address the poor worker practices root cause.
* The licensee intended to implement a CAPR to revise procedure MNT-NGGC-007; however, this CAPR was never properly implemented in the CAP. The changes in the procedure were implemented as part of several PRRs, outside of RCE 115704, Revision 3. The changes did not address the poor worker practices root cause.
* CORR 115704-30 was not implemented as written. A DLA was developed for monitoring of foreign materials that are not "immediately retrievable" (FME-1). However, the DLA didn't included FME recognition, notification for loss of FME controls and risk awareness.
* CORR 115704-30 was not implemented as written. A DLA was developed for monitoring of foreign materials that are not immediately retrievable (FME-1).
 
However, the DLA didnt included FME recognition, notification for loss of FME controls and risk awareness.
* CORR 115704-31 was not implemented as written. There was no documentation that this action was carried forward pragmatically into future refueling outages. Also, there was no documentation in the closure of oversight of non-outage activities.
* CORR 115704-31 was not implemented as written. There was no documentation that this action was carried forward pragmatically into future refueling outages. Also, there was no documentation in the closure of oversight of non-outage activities.


Based on the issues identified above, the inspectors determined that the licensee did not have adequate CAPRs in place to address the poor worker practices root cause identified in RCE 115704.
Based on the issues identified above, the inspectors determined that the licensee did not have adequate CAPRs in place to address the poor worker practices root cause identified in RCE 115704.


On February 27, 2014, the "C" steam generator showed indications of a primary to secondary tube leak. On March 7, 2014, the licensee shutdown the plant and repaired the leak. The licensee identified that the leak was caused by a loose part. The licensee conducted a cause evaluation and determined that the foreign material was introduced during replacement of a feedwater piping upstream of the "C" steam generator during the fall 2013 refueling outage.
On February 27, 2014, the C steam generator showed indications of a primary to secondary tube leak. On March 7, 2014, the licensee shutdown the plant and repaired the leak. The licensee identified that the leak was caused by a loose part. The licensee conducted a cause evaluation and determined that the foreign material was introduced during replacement of a feedwater piping upstream of the C steam generator during the fall 2013 refueling outage.


=====Analysis:=====
=====Analysis:=====
The licensee's failure to implement appropriate corrective actions to address poor worker practices to prevent recurrence of a steam generator tube leak was a performance deficiency. The finding was more than minor because it was associated with the initiating events cornerstone equipment performance attribute and it 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, foreign material entered the steam generator and damaged a steam generator tube, which increased the likelihood of a steam generator tube rupture.
The licensees failure to implement appropriate corrective actions to address poor worker practices to prevent recurrence of a steam generator tube leak was a performance deficiency. The finding was more than minor because it was associated with the initiating events cornerstone equipment performance attribute and it 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, foreign material entered the steam generator and damaged a steam generator tube, which increased the likelihood of a steam generator tube rupture.


The inspectors screened this finding using IMC 0609, Appendix A, "The Significant Determination Process For Findings At-Power," dated June 19, 2012. The finding screened as Green per Section D of Exhibit 1, "Initiating Events Screening Questions," because testing showed that the affected steam generator tube could sustain three times the differential pressure across the tube during normal full power and that the steam generator did not violate the accident leakage performance criterion. The performance deficiency does not have a cross cutting aspect because the last revision of the root cause evaluation was completed in 2011 and it is not indicative of current licensee performance.
The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section D of Exhibit 1, Initiating Events Screening Questions, because testing showed that the affected steam generator tube could sustain three times the differential pressure across the tube during normal full power and that the steam generator did not violate the accident leakage performance criterion. The performance deficiency does not have a cross cutting aspect because the last revision of the root cause evaluation was completed in 2011 and it is not indicative of current licensee performance.


=====Enforcement:=====
=====Enforcement:=====
10 CFR 50 Appendix B Criterion XVI, "Corrective Actions," states in part, for significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, the licensee did not take appropriate corrective actions to preclude repetition for a significant condition adverse to quality that was identified in January 18, 2004, regarding steam generator tube leak due to poor worker practices. Specifically, on February 27, 2014, the "C" steam generator had a primary to secondary tube leak which the licensee determined to be due to foreign material that was introduced by poor worker practices (FME controls) during replacement of feedwater piping upstream of the "C" steam generator during the fall 2013 refueling outage. As immediate corrective actions, on March 7, 2014, the licensee shutdown the plant and repaired the leak. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensee's corrective action program as NCRs 683695, 683593, and 683591. NCV 05000261/2014008-01, "Failure to Take Adequate  
10 CFR 50 Appendix B Criterion XVI, Corrective Actions, states in part, for significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, the licensee did not take appropriate corrective actions to preclude repetition for a significant condition adverse to quality that was identified in January 18, 2004, regarding steam generator tube leak due to poor worker practices. Specifically, on February 27, 2014, the C steam generator had a primary to secondary tube leak which the licensee determined to be due to foreign material that was introduced by poor worker practices (FME controls) during replacement of feedwater piping upstream of the C steam generator during the fall 2013 refueling outage. As immediate corrective actions, on March 7, 2014, the licensee shutdown the plant and repaired the leak. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as NCRs 683695, 683593, and 683591. NCV 05000261/2014008-01, Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak.
 
Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak."


===.2 Use of Operating Experience===
===.2 Use of Operating Experience===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors examined licensee programs for reviewing industry operating experience (OE) , reviewed licensee procedure CAP-NGGC-0202, "Operating Experience and Construction Experience Program," reviewed the licensee's operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since June 2012 to verify whether the licensee had appropriately evaluated each notification for applicability to the Robinson Nuclear plant, and whether issues identified through these reviews were entered into the CAP.
The inspectors examined licensee programs for reviewing industry operating experience (OE), reviewed licensee procedure CAP-NGGC-0202, Operating Experience and Construction Experience Program, reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since June 2012 to verify whether the licensee had appropriately evaluated each notification for applicability to the Robinson Nuclear plant, and whether issues identified through these reviews were entered into the CAP.


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.


b. Assessment
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 by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. Operating experience issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in root cause evaluations in accordance with licensee procedure CAP-NGGC-0205.
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 by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. Operating experience issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in root cause evaluations in accordance with licensee procedure CAP-NGGC-0205.
Line 218: Line 230:


===.3 Self-Assessments and Audits===
===.3 Self-Assessments and Audits===
====a. Inspection Scope====
====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 licensee's audits and self-assessments, and 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 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 licensee's audits and self-assessments, and 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.


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.


b. Assessment
b.
 
Assessment  


The inspectors determined that the scopes of assessments and audits were adequate.
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 inspector's 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.
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====
====c. Findings====
Line 234: Line 247:


===.4 Safety-Conscious Work Environment===
===.4 Safety-Conscious Work Environment===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors interviewed several on-site workers regarding their knowledge of the CAP at the Robinson Steam Electric Plant and their willingness to write NCRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors review ed the licensee's Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were properly reviewed and that identified deficiencies were resolved and entered into the CAP when appropriate.
The inspectors interviewed several on-site workers regarding their knowledge of the CAP at the Robinson Steam Electric Plant and their willingness to write NCRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were properly reviewed and that identified deficiencies were resolved and entered into the CAP when appropriate.


Documents reviewed are listed in the Attachment.
Documents reviewed are listed in the Attachment.


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.
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 samp le 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.
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====
====c. Findings====
No findings were identified.
No findings were identified.


{{a|4OA6}}
{{a|4OA6}}
 
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==
On May 8, 2014, the inspectors presented the inspection results to Mr. R. Glover and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.
On May 8, 2014, the inspectors presented the inspection results to Mr. R. Glover and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.


ATTACHMENT:
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee personnel===
===Licensee personnel===
:  
:  
Line 272: Line 287:
: [[contact::D. Hall]], Nuclear Oversight  
: [[contact::D. Hall]], Nuclear Oversight  
: [[contact::R. Hightower]], Regulatory Affairs Manager  
: [[contact::R. Hightower]], Regulatory Affairs Manager  
: [[contact::K. Holbrook]], Operations Manager
: [[contact::K. Holbrook]], Operations Manager  
: [[contact::K. Shepard]], PI Corrective Action Coordinator  
: [[contact::K. Shepard]], PI Corrective Action Coordinator  
: [[contact::L. Smith]], Operations Specialist  
: [[contact::L. Smith]], Operations Specialist  
Line 286: Line 301:


==LIST OF REPORT ITEMS==
==LIST OF REPORT ITEMS==
===Opened and Closed===
: 05000261/2014008-01 NCV


===Opened and Closed===
Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak (Section 4OA2.1.c)  
: 05000261/2014008-01 NCV  Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition
Adverse to Quality Associated with the Steam Generator Tube Leak (Section 4OA2.1.c)  


===Closed===
===Closed===
: None
None  
 
===Discussed===
===Discussed===
None  
None  


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
===Procedures===
 
:
: ADM-NGGC-01010, "Maintenance Rule Program," Rev. 23
: ADM-NGGC-0114, "Plant Health Process," Rev. 6
: AD-NO-ALL-0202, "Employee Concerns Program," Rev. 0
: AD-PI-ALL-0300, "Self-Assessment and Benchmark Program," Rev. 0
: CAP-NGGC-0200, "Condition Identification and Screening Process," Rev. 32 and 39
: CAP-NGGC-0205, "Condition Evaluation and Corrective Action Process," Rev. 18
: CAP-NGGC-0206, "Performance Assessment and Trending", Rev. 7
: CAP-NGGC-1000, "Conduct of Performance Improvement", Rev. 12
: CP-DSL-402, "Diesel Fuel Oil Storage Tank Sampling," Rev. 3
: MNT-NGGC-0007, "Foreign Material Exclusion Program," Rev. 11
: MST-011, "Reactor Protection Logic Train "A" and "B" at "0" Power," Rev. 38
: MST-022, "Safeguard Relay Rack Train "A"," Rev. 22
: NCP-G-0001, "Common Diesel Fuel Oil (Grade 2-D) Testing Specification," Rev. 5
: OP-509-1, "Condensate Polishing System Operations," Rev. 30
: OPS-NGCC-1316, "Aggregate Risk Impact Assessment Program," Rev. 4
: PLP-009, H.B. Robinson Training Program, Rev. 44 and 48
: PLP-033, "Post-Maintenance Testing (PMT) Program," Rev. 61
: PM-047, "Emergency Lighting System Unit Load Test," Rev. 6
: PM-E-480V-SWGR-E1, "480 Volt Bus E1 Inspection and Cleaning," Rev. 1
: PM-E-480V-SWGR-E2, "480 Volt Bus E2 Inspection and Cleaning," Rev. 0
: PM-E-DSD-UPS-001, "Dedicated Shutdown UPS Battery Service Test," Rev. 2
: PM-E-ELS-ELGHT-001, "Self-Contained Exide DC Emergency Lighting System," Rev. 0
: PM-E-ELS-ELGHT-002, "Self-Contained Dual-Lite DC Emergency Lighting System," Rev. 0
: WCP-NGGC-0300, "Work Request Initiation, Screening, Prioritization and Classification," Rev. 8
: Nuclear Condition Reports (NCRs)
:
: 603293,
: 606050,
: 598612,
: 571349,
: 569285,
: 631694,
: 630056,
: 558425,
: 557582,
: 654789,575063,
: 555925,
: 575063,527203,632032,605058,634988,650354,566888,577409,583446,599559,
: 585193,634509,578570,
: 524523,
: 559717,
: 115704,
: 272388,
: 398133,
: 398609,
: 403879,
: 424086,
: 671333,
: 479702,
: 559717,
: 560424,
: 563382,
: 581998,
: 622399,
: 530799,
: 588616,
: 530799,
: 588616,
: 530255,
: 542877,
: 553018,
: 570201,
: 572255,
: 573576,
: 580944 ,
: 588746,
: 600522 ,
: 600994,
: 614384,
: 615097,
: 624347,
: 639301,
: 640903,
: 641850,
: 642296,
: 642296,
: 643321,
: 645450,
: 649126,
: 650618,
: 654474,
: 663140,
: 673320,
: 641850,
: 535930,
: 540954,
: 576663,
: 530741,
: 544317,
: 544323,
: 569362,
: 535537,
: 535926,
: 545638,
: 545666,
: 548318,
: 550552,
: 554432,
: 560424,
: 565574,
: 566094,
: 567517,
: 567632,
: 567824,
: 568749,
: 572491,
: 573278,
: 573542,
: 575956,
: 575463,
: 586339,
: 589708,
: 591864,
: 595700,
: 601201,
: 603357,
: 604039,
: 605562,
: 605969,
: 606896,
: 609125,
: 613668,
: 616743,
: 616749,
: 625637,
: 633266,
: 634738,
: 635185,
: 635420,
: 638367,
: 639146,
: 641474,
: 645821 
===Work Orders===
(WO)
:
: 11603433,
: 1888894-01,
: 1943470-01,
: 1943479-02,
: 2049110-06,
: 2047344-01,
: 21001450-01,
: 2101439-03,
: 02107714,
: 2116022-01,
: 2116022-02,
: 2137343-01,
: 2137343-02,
: 2270198-01,
: 283890-01
: Attachment Audits and Self-Assessments
:
: 576270, "Self-Assessment of CAP (CAP-NGGC-0200,
: CAP-NGGC-0205) and Trending
: Program (CAP-NGGC-0206)," July 2013
: 576461, "Quick Hit Self-Assessment: Emergency Preparedness"
: 593597, "Quick Hit Self-Assessment: Perform a Quick Hit Self-Assessment on a Safety Topic"
: R-EP-12-01, "Assessment of Emergency Preparedness," 2/12/2013
: R-EP-13-01, "Assessment of Emergency Preparedness," 2/28/2014 R-NCS-12-01, "Assessment of Nuclear Safety Culture," 11/28/2012 
===Miscellaneous Documents===
: 4Q13 Organizational Effectiveness Quarterly Trend Report
: 4Q13 Site Quarterly Trend Report 5379-3232, Safeguards System, Sht. 6, Rev.34 B-190628, Control Wiring Diagram Pressurizer Relief Valve
: PCV-456, Sht. 119, Rev. 28
: BWB Site Orientation Package for R228
: EC91447R1, Temperature Evaluation for
: MCC-24 Auxiliaries
: EC91611, DS Diesel Generator Ambient Temperature Evaluation February 2014, Operations Trend Roll-up Report
: High Safety Significant Maintenance Rule Functional Failures - June 1, 2012 to March 4, 2014
: January 2014, Engineering Trend Roll-up Report Maintenance Rule System (a)(1) Action Plans - Since 6/1/2012
: Maintenance Services Contractor/Shared Resources Orientation, Rev. 10 and 14 
===Procedure===
: Revision Request:
: 664164 Q1-2014, 1045/1080 - Reactor Protection and Nuclear Excore Instrumentation - System Health Report
: Q3-2013, 1045/1080 - Reactor Protection and Nuclear Excore Instrumentation - System Health Report System 3065 Aux Feedwater System - System Health Report System Health Report, 5175/5170 - AC Distribution System, Q1-2014 System Health Report, 5175/5170 - AC Distribution System, Q4-2013
: NCRs written as part of this inspection:
: 683009, 2014 NRC PI&R: Continued Issues with Canceling WR/WO/WP
: 683335, Some Delays were Encountered in the PI&R Response Team
: 683387, NRC PI&R Team Lost Internet Access
: 683591, 2014 PI&R, Corrective Action not Implemented as Written
: 683593, 2014 PI&R, Corrective Action not Implemented as Written
: 683695, 2014 PI&R, Corrective Action not Implemented as Written
: 683751, 2014 NRC PI&R: Inappropriate CORR Closure
: 685635, 2014 NRC PI&R:
: RCE 115704 Failed to Properly Document CAPR
: 685848, 2014 PI&R,
: PLP-033 Rigor of Doc for Relay PMT Waiver
: 685871, 2014 PI&R, No Programmatic Actions in Place
: 685971, 2014 NRC PI&R: CAPR
: 530799-15 Closed Inappropriately
: 686019, Monthly Aggregate Assessments not Completed
: 686104, 2014 NRC PI&R: TRF (NON-CAP ACTION) Not Completed as Written
: 686111, 2014 PI&R, New Discovery Items Identified During CA
: 686121, 2014 NRC PI&R: Inappropriate CORRS Issued from Evals
: 686148, 2014 NRC PI&R: Inadequate EOC Documentation in
: QCE 639146-03 
: Attachment
: 686149, 2014 NRC PI&R: CAPR in
: 588616 is not Defined
: 686190, 2014 NRC PI&R: Failure to Identify EC Review Issue
: 686209, 2014 NRC PI&R: Numerous Issues Identified Regarding CAPRS
: 686436, 2014 NRC PI&R: No Definitive CAPR to Address FME Implemented
}}
}}

Latest revision as of 20:25, 10 January 2025

IR 05000261-14-008; on 04/21/2014 - 05/05-08/2014; H.B. Robinson Steam Electric Plant, Unit 2; Biennial Inspection of the Problem Identification and Resolution Program
ML14162A121
Person / Time
Site: Robinson 
Issue date: 06/10/2014
From: Steven Rose
Reactor Projects Branch 7
To: William Gideon
Duke Energy Progress
References
IR-14-008
Download: ML14162A121 (19)


Text

June 10, 2014

SUBJECT:

H.B. ROBINSON STEAM ELECTRIC PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2014008

Dear Mr. Gideon:

On May 8, 2014, 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 Mr. R. Glover and other members of your staff. 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 supported 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 stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station 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 station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.

Finally, the team determined that your stations 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.

However, the enclosed inspection report discusses one NRC-identified finding of very low safety significance (Green) identified during this inspection. This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or the significance of this NCV, 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, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the H.B. Robinson facility.

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 (PARS) component of the NRC's 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/

Steven D. Rose, Branch Chief Reactor Projects Branch 7 Division of Reactor Projects

Docket Nos.: 50-261 License Nos.: DPR-23

Enclosure:

Inspection Report 05000261/2014008 w/Attachment: Supplemental Information

REGION II==

Docket No.:

50-261

License No.:

DRP-23

Report No.:

05000261/2014008

Licensee:

Duke Energy Progress, Inc.

Facility:

H. B. Robinson Steam Electric Plant, Unit 2

Location:

3581 West Entrance Road

Hartsville, SC 29550

Dates:

April 21 - 25, 2014 May 5 - 8, 2014

Inspectors:

J. Worosilo, Senior Project Engineer, Team Leader R. Rodriguez, Senior Project Engineer N. Staples, Senior Project Inspector M. Singletary, Reactor Inspector (training)

J. Dodson, Senior Project Engineer D. Jackson, Project Engineer

Approved by:

Steven D. Rose, Branch Chief, Reactor Projects Branch 7 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000261/2014008; April 21 - May 8, 2014; H.B. Robinson Steam Electric Plant, Unit 2;

Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by three senior project engineers, one senior project inspector, a project engineer, and a reactor inspector. One finding of very low safety significance (Green)was identified during this inspection. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using IMC 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross Cutting Areas, dated December 19, 2013.

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 was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems 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. However, the team did identify deficiencies in the areas of identification of problems and effectiveness of corrective actions.

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. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.

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 to management and use the CAP to resolve those concerns.

NRC-Identified and Self-Revealing Findings

Cornerstone: Initiating Events

Green: The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality regarding steam generator tube leakage due to poor maintenance practices. Specifically, on February 27, 2014, the C steam generator showed indications of a primary to secondary tube leak due to foreign material that was introduced during the fall 2013 refueling outage. As immediate corrective actions, on March 7, 2014, the licensee shutdown the plant and repaired the leak. This violation was entered into the licensees CAP as nuclear condition reports (NCRs) 683695, 683593, and 683591.

The licensees failure to implement appropriate corrective actions to address poor worker practices to prevent recurrence of a steam generator tube leak was a performance deficiency.

The finding was more than minor because it was associated with the initiating events cornerstone equipment performance attribute and it 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, foreign material entered the steam generator and damaged a steam generator tube, which increased the likelihood of a steam generator tube rupture. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012.

The finding screened as Green per Section D of Exhibit 1, Initiating Events Screening Questions, because testing showed that the affected steam generator tube could sustain three times the differential pressure across the tube during normal full power and that the steam generator did not violate the accident leakage performance criterion. The performance deficiency does not have a cross cutting aspect because the last revision of the root cause evaluation was completed in 2011 and it is not indicative of current licensee performance.

(Section 4OA2.1.c)

REPORT DETAILS

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 use of 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 June 2012 and April 2014, including a detailed review of selected NCRs associated with the following risk-significant systems: auxiliary feedwater, reactor protection system, and alternating current (AC) distribution system. 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. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of NCRs that were identified and assigned to the major plant departments, including emergency preparedness, health physics, chemistry, 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. The inspectors reviewed selected NCRs, verified corrective actions were implemented, and attended 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 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-dependent issues.

Control room walk-downs were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP. Operator workarounds and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected NCRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the issues discussed in the NCRs and the guidance in licensee procedure CAP-NGGC-0205, Condition Evaluation and Corrective Action Process. 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.

The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

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 reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Work Ownership Committee (WOC) meetings and Performance Improvement Oversight Committee (PIOC) 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 procedures CAP-NGGC-0200, Condition Identification and Screening Process, managements expectation that employees were encouraged to initiate NCRs for any reason, and the relatively few number of deficiencies identified by inspectors during plant walkdowns not already entered into the CAP. 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 system deficiencies were being identified and placed in the CAP.

The team identified a performance deficiency associated with the licensees problem identification of issues. This issue was screened as minor in accordance with IMC 0612 Appendix B, Issue Screening.

  • During the review of NCR 605058, the inspectors identified a performance deficiency for failure to identify a condition adverse to quality associated with deficiencies of post maintenance testing (PMT) of reactor protection and safeguards relays. The failure to properly identify that procedure PLP-033, Post Maintenance Testing Program, did not provide measures to ensure that full functional test were developed for reactor protection and safeguards relays was a performance deficiency. This performance deficiency was considered minor because the safety related functions of the identified safety related relays affected were being verified via operation surveillance test (OST) procedures. This issue has been documented as NCRs 0685848, 0683751, 0686111 and 0685871.

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 CAP-NGGC-0200.

The inspectors determined that adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station 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 CAP-NGGC-0205.

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 and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, NCRs, and effectiveness reviews demonstrated 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.

However, the team identified one example where the licensee failed to take adequate corrective actions to preclude repetition. This issue is described below in the Findings section, Section 4OA2.1.c of this report as Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak.

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.

  • Procedure CAP-NGGC-0205, Condition Evaluation and Corrective Action Process, Section 9.2 Corrective Action Plan, states that: A corrective action (CORR) shall not be closed to a lower tier assignment type. The inspectors identified three examples of inadequate closure of CORRs to lower tier assignments. Specifically, NCRs 645821-12 and 635420-5 were closed to procedure revision requests (PRRs)and NCR 640903-3 was closed to a training request form (TRF). The closing of the CORRs to lower tier assignments was a performance deficiency. This performance deficiency was minor because even though the PRRs are still open they are scheduled to be completed prior to the affected procedures being used. Also, the TRF was completed and determined that no training was required. This issue has been documented as NRC 686121.

c. Findings

Introduction:

The team identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality regarding steam generator tube leakage due to poor maintenance practices.

Description:

On January 8, 2004, the licensee documented a significant condition adverse to quality regarding evidence of a minor primary to secondary side leakage.

The licensee initiated NCR 115704 and performed a root cause evaluation (RCE). In Revision 1 of the RCE, the licensee determined that one of the root causes of the steam generator tube leak was poor maintenance work practices. To address this root cause, the licensee implemented the following CAPR:

  • CAPR 115704-17: Revise as necessary ADM-NGGC-0110, Oversight of Contractors, Shared Resources, Vendors, and Technical Representatives, to include this action request subject matter, for review, in the maintenance services orientation package for secondary maintenance every outage.

On June 9, 2010, during an effectiveness review per NCR 115704-20; the licensee determined that poor worker practices were not effectively addressed by the CAPRs.

The licensee performed an adverse condition investigation to evaluate the ineffective corrective actions (NCR 403879). As a result of the investigation, the licensee determined that the following CAPR was going to be added to the original RCE (NCR 115704 Rev.3, completed on August 9, 2011) to address poor maintenance work practices:

  • CAPR 115704-23: Provide training to address poor foreign material exclusion (FME)performance in accordance with the INPO letter on Causal Analysis for Foreign Material Intrusion Events.

Root Cause 115704 Revision 3 also added the following CAPR and CORRs to address poor work practices:

  • Revise procedure MNT-NGGC-007, Foreign Material Exclusion Program, to address foreign material created by the degradation of plant equipment differently from FME issues caused during the maintenance activity in process.
  • CORR 115704-30: Revise existing FME training to include a dynamic learning activity (DLA) that incorporates FME recognition, reinforces notification for loss of FME controls and include risk awareness.
  • CORR 115704-31: Formalized oversight of contractor FME performance during work on open secondary systems. Oversight must be documented and include unannounced field inspections of logs and plant systems while work is in progress.

The inspectors identified the following issues with the licensees corrective actions listed above:

  • CAPR 115704-17 was not adequately implemented. The maintenance orientation package was revised, however procedure ADM-NGGC-0110 was not revised; therefore the action completed was not pragmatic and was not carried into the last refueling outage in fall 2013.
  • CAPR 115704-23 was canceled and no other CAPR was initiated to address the root cause associated with poor maintenance practices.
  • The licensee intended to implement a CAPR to revise procedure MNT-NGGC-007; however, this CAPR was never properly implemented in the CAP. The changes in the procedure were implemented as part of several PRRs, outside of RCE 115704, Revision 3. The changes did not address the poor worker practices root cause.
  • CORR 115704-30 was not implemented as written. A DLA was developed for monitoring of foreign materials that are not immediately retrievable (FME-1).

However, the DLA didnt included FME recognition, notification for loss of FME controls and risk awareness.

  • CORR 115704-31 was not implemented as written. There was no documentation that this action was carried forward pragmatically into future refueling outages. Also, there was no documentation in the closure of oversight of non-outage activities.

Based on the issues identified above, the inspectors determined that the licensee did not have adequate CAPRs in place to address the poor worker practices root cause identified in RCE 115704.

On February 27, 2014, the C steam generator showed indications of a primary to secondary tube leak. On March 7, 2014, the licensee shutdown the plant and repaired the leak. The licensee identified that the leak was caused by a loose part. The licensee conducted a cause evaluation and determined that the foreign material was introduced during replacement of a feedwater piping upstream of the C steam generator during the fall 2013 refueling outage.

Analysis:

The licensees failure to implement appropriate corrective actions to address poor worker practices to prevent recurrence of a steam generator tube leak was a performance deficiency. The finding was more than minor because it was associated with the initiating events cornerstone equipment performance attribute and it 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, foreign material entered the steam generator and damaged a steam generator tube, which increased the likelihood of a steam generator tube rupture.

The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section D of Exhibit 1, Initiating Events Screening Questions, because testing showed that the affected steam generator tube could sustain three times the differential pressure across the tube during normal full power and that the steam generator did not violate the accident leakage performance criterion. The performance deficiency does not have a cross cutting aspect because the last revision of the root cause evaluation was completed in 2011 and it is not indicative of current licensee performance.

Enforcement:

10 CFR 50 Appendix B Criterion XVI, Corrective Actions, states in part, for significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, the licensee did not take appropriate corrective actions to preclude repetition for a significant condition adverse to quality that was identified in January 18, 2004, regarding steam generator tube leak due to poor worker practices. Specifically, on February 27, 2014, the C steam generator had a primary to secondary tube leak which the licensee determined to be due to foreign material that was introduced by poor worker practices (FME controls) during replacement of feedwater piping upstream of the C steam generator during the fall 2013 refueling outage. As immediate corrective actions, on March 7, 2014, the licensee shutdown the plant and repaired the leak. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as NCRs 683695, 683593, and 683591. NCV 05000261/2014008-01, Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak.

.2 Use of Operating Experience

a. Inspection Scope

The inspectors examined licensee programs for reviewing industry operating experience (OE), reviewed licensee procedure CAP-NGGC-0202, Operating Experience and Construction Experience Program, reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since June 2012 to verify whether the licensee had appropriately evaluated each notification for applicability to the Robinson Nuclear plant, 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 by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. Operating experience issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in root cause evaluations in accordance with licensee procedure CAP-NGGC-0205.

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 licensee's audits and self-assessments, and 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.

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

The inspectors interviewed several on-site workers regarding their knowledge of the CAP at the Robinson Steam Electric Plant and their willingness to write NCRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were properly reviewed and that identified deficiencies were resolved and entered into the CAP when appropriate.

Documents reviewed are listed in the Attachment.

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 May 8, 2014, the inspectors presented the inspection results to Mr. R. Glover and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Anderson, Performance Improvement Manager
C. Caudell, Regulatory Affairs
S. Connelly, Licensing Lead
T. Cosgrove, Plant Manager
H. Curry, Training Manager
D. Douglas, Maintenance Manager
P. Fagan, Engineering Director
W. Farmer, Major Projects Interface
R. Glover, Director of Site Operations
S. Greenwood, Supply Chain Manager
D. Hall, Nuclear Oversight
R. Hightower, Regulatory Affairs Manager
K. Holbrook, Operations Manager
K. Shepard, PI Corrective Action Coordinator
L. Smith, Operations Specialist
T. White, Employee Concerns Coordinator
S. Williams, Chemistry Manager
C. Wilson, Regulatory Affairs

NRC personnel

K. Ellis, Senior Resident Inspector
C. Scott, Resident Inspector
S. Rose, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened and Closed

05000261/2014008-01 NCV

Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Steam Generator Tube Leak (Section 4OA2.1.c)

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED