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Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant. | Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant. | ||
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant.January 31, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. | If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant. | ||
January 31, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. | |||
Sincerely, David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000261 License No. DPR-23 | Sincerely, David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000261 License No. DPR-23 | ||
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==Inspection Report== | ==Inspection Report== | ||
Docket Number: 05000261 | Docket Number: | ||
05000261 License Number: | |||
License Number: DPR-23 | DPR-23 Report Number: | ||
05000261/2023004 Enterprise Identifier: | |||
Report Number: 05000261/2023004 | I-2023-004-0022 Licensee: | ||
Duke Energy Progress, LLC Facility: | |||
Enterprise Identifier: I-2023-004-0022 | H.B. Robinson Steam Electric Plant Location: | ||
Hartsville, SC Inspection Dates: | |||
Licensee: Duke Energy Progress, LLC | October 01, 2023 to December 31, 2023 Inspectors: | ||
V. Gaffney, Resident Inspector J. Zeiler, Senior Resident Inspector Approved By: | |||
Facility: H.B. Robinson Steam Electric Plant | David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects | ||
Location: Hartsville, SC | |||
Inspection Dates: October 01, 2023 to December 31, 2023 | |||
Inspectors: V. Gaffney, Resident Inspector J. Zeiler, Senior Resident Inspector | |||
Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects | |||
=SUMMARY= | =SUMMARY= | ||
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===List of Findings and Violations=== | ===List of Findings and Violations=== | ||
Failure to Declare Pressurizer Power Operated Relief Valve Inoperable During Maintenance Results in a Condition Prohibited by Technical Specification Cornerstone Significance Cross-Cutting Report | Failure to Declare Pressurizer Power Operated Relief Valve Inoperable During Maintenance Results in a Condition Prohibited by Technical Specification Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000261/2023004-01 Open/Closed | ||
[H.13] - | |||
Consistent Process 71152A NRC inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.11, Pressurizer Power Operated Relief Valves (PORVs), Condition A, for the licensee's failure to declare PCV-456, the A train pressurizer PORV, inoperable when conducting plant maintenance that isolated the dedicated nitrogen accumulator for PCV-456 operation. Specifically, isolating the nitrogen accumulator resulted in the inability to successfully complete TS Surveillance Requirement (SR) 3.4.11.3 and TS SR 3.4.11.4, to demonstrate the accumulators and associated piping could supply sufficient nitrogen to operate the PORVs. | |||
===Additional Tracking Items=== | ===Additional Tracking Items=== | ||
Type Issue Number Title Report Section Status LER 05000261/2023-001-00 Unit 2, Condition Prohibited | Type Issue Number Title Report Section Status LER 05000261/2023-001-00 Unit 2, Condition Prohibited by Technical Specification Due to Missed Entry into Limiting Condition for Operation 71153 Closed | ||
=PLANT STATUS= | =PLANT STATUS= | ||
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===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)=== | ===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)=== | ||
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas: | The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas: | ||
(1)auxiliary building elevation 262 'C' battery room enclosure (fire zone 34) on October 30, 2023 (2)radwaste building, all elevations (fire zone 35) on October 31, 2023 | |||
: (3) SW intake and pumps and 'B' deepwell pump areas (fire zones 29 and 42) on November 9, 2023 (4)auxiliary building pipe alley areas (fire zone 11) on November 13, 2023 (5)auxiliary building elevation 226 'B' emergency diesel generator (EDG) room (fire zone 1) on December 6, 2023 | |||
: (3) SW intake and pumps and 'B' deepwell pump areas (fire zones 29 and 42) on November 9, 2023 | |||
==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance== | ==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance== | ||
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===Maintenance Effectiveness (IP Section 03.01) (2 Samples)=== | ===Maintenance Effectiveness (IP Section 03.01) (2 Samples)=== | ||
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function: | The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function: | ||
(1)degraded safety relief valve for the starting air compressor associated with the 'B' EDG requires replacement [nuclear condition report (NCR) 2468490] | |||
(2)failure of regulator valve, PCV-3, to maintain normal nitrogen supply pressure to the | |||
'A' pressurizer PORV, PCV-456 (NCR 2475694) | |||
==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | ==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | ||
===Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)=== | ===Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)=== | ||
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed: | The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed: | ||
(1)elevated risk (Green) during planned blowdown of sensing lines for 'B' SW system header pressure on October 17, 2023 (2)elevated risk (Green) during 'B' steam generator level channel 485 calibration requiring associated main feedwater regulating valve to be in manual operation on October 31, 2023 (3)elevated risk (Green) during planned corrective maintenance to replace 'A' CVCS charging pump valves and packing on November 6-7, 2023 (4)elevated risk (Green) during planned corrective maintenance to replace degraded oil cooler for the 'A' MFP on November 27-28, 2023 | |||
==71111.15 - Operability Determinations and Functionality Assessments== | ==71111.15 - Operability Determinations and Functionality Assessments== | ||
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==71111.18 - Plant Modifications== | ==71111.18 - Plant Modifications== | ||
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample) | Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample) | ||
The inspectors evaluated the following temporary or permanent modifications: | The inspectors evaluated the following temporary or permanent modifications: | ||
(1)engineering change (EC) 423421, temporary modification to reroute SW system cooling return from 'A' MFP lube oil cooler due to cooler tube leakage | |||
==71111.24 - Testing and Maintenance of Equipment Important to Risk== | ==71111.24 - Testing and Maintenance of Equipment Important to Risk== | ||
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==OTHER ACTIVITIES - BASELINE== | ==OTHER ACTIVITIES - BASELINE== | ||
===71151 - Performance Indicator Verification | ===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: | ||
The inspectors verified licensee performance indicators submittals listed below: | |||
MS07: High Pressure Injection Systems (IP Section 02.06)=== | MS07: High Pressure Injection Systems (IP Section 02.06)=== | ||
{{IP sample|IP=IP 71151|count=1}} | {{IP sample|IP=IP 71151|count=1}} | ||
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{{IP sample|IP=IP 71152|count=1}} | {{IP sample|IP=IP 71152|count=1}} | ||
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues: | The inspectors reviewed the licensees implementation of its corrective action program related to the following issues: | ||
(1)reportability evaluation for missed entry into TS 3.4.11 LCO (NCRs 2480117, | |||
===2476348, and 2475694) | ===2476348, and 2475694) 71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)=== | ||
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)=== | |||
{{IP sample|IP=IP 24763|count=1}} | {{IP sample|IP=IP 24763|count=1}} | ||
: (1) The inspectors reviewed the licensees corrective action program, maintenance rule database, operational equipment deficiencies database, and plant action register summary database for potential adverse trends in equipment reliability that might be indicative of a more significant safety issue. The inspectors did not identify a negative trend that could lead to a more safety significant safety issue. | : (1) The inspectors reviewed the licensees corrective action program, maintenance rule database, operational equipment deficiencies database, and plant action register summary database for potential adverse trends in equipment reliability that might be indicative of a more significant safety issue. The inspectors did not identify a negative trend that could lead to a more safety significant safety issue. | ||
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==INSPECTION RESULTS== | ==INSPECTION RESULTS== | ||
Failure to Declare Pressurizer Power Operated Relief Valve Inoperable During Maintenance Results in a Condition Prohibited by Technical Specification Cornerstone Significance Cross-Cutting Report | Failure to Declare Pressurizer Power Operated Relief Valve Inoperable During Maintenance Results in a Condition Prohibited by Technical Specification Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000261/2023004-01 Open/Closed | ||
[H.13] - | |||
Consistent Process 71152A NRC inspectors identified a Green finding and associated NCV of TS LCO 3.4.11, Pressurizer PORVs, Condition A, for the licensee's failure to declare PCV-456, the A train pressurizer PORV, inoperable when conducting plant maintenance that isolated the dedicated nitrogen accumulator for PCV-456 operation. Specifically, isolating the nitrogen accumulator resulted in the inability to successfully complete TS Surveillance Requirement (SR) 3.4.11.3 and TS SR 3.4.11.4, to demonstrate the accumulators and associated piping could supply sufficient nitrogen to operate the PORVs. | |||
=====Description:===== | =====Description:===== | ||
On June 12, 2023, with Unit 2 operating at 100% RTP, the licensee identified a nitrogen gas leak in containment because of the failure of pressure regulator valve PCV-3, which normally provides ~95 psig nitrogen supply motive force to operate PCV-456. Licensee troubleshooting determined the pressure setpoint for PCV-3 had failed high (local pressure gauge in containment was reading ~127 psig) resulting in its downstream nitrogen supply relief valve, OPP-17, lifting at its design setpoint of 125 psig and discharging nitrogen into the containment atmosphere. At 4:41 PM on June 12, 2023, the licensee terminated the nitrogen leak by shutting nitrogen isolation valve OPP-25, located directly upstream of PCV-3. However, shutting OPP-25 not only isolated the normal nitrogen supply to PCV-456 that is supplied from outside containment, but also the nitrogen from the dedicated nitrogen accumulator tank located inside containment. | On June 12, 2023, with Unit 2 operating at 100% RTP, the licensee identified a nitrogen gas leak in containment because of the failure of pressure regulator valve PCV-3, which normally provides ~95 psig nitrogen supply motive force to operate PCV-456. Licensee troubleshooting determined the pressure setpoint for PCV-3 had failed high (local pressure gauge in containment was reading ~127 psig) resulting in its downstream nitrogen supply relief valve, OPP-17, lifting at its design setpoint of 125 psig and discharging nitrogen into the containment atmosphere. At 4:41 PM on June 12, 2023, the licensee terminated the nitrogen leak by shutting nitrogen isolation valve OPP-25, located directly upstream of PCV- | ||
===3. However, shutting OPP-25 not only isolated the normal nitrogen supply to PCV-456 that is=== | |||
supplied from outside containment, but also the nitrogen from the dedicated nitrogen accumulator tank located inside containment. | |||
Upon review of the licensees actions on the morning of June 13, 2023, the inspectors noted that the operators had not declared PCV-456 inoperable, as expected, when isolating its nitrogen accumulator and had not entered the associated TS 3.4.11 action requirements for an inoperable pressurizer PORV. When questioned regarding the basis for the decision, the operators stated that PCV-456 remained operable since its backup instrument air supply was still available to operate PCV-456. Isolating the accumulator nitrogen supply to PCV-456 resulted in the inability to meet TS SR 3.4.11.3 and TS SR 3.4.11.4, which requires the pressurizer PORVs and their related flow path solenoid air control and check valves to be capable of being operated through a complete cycle using nitrogen from the dedicated accumulators. In accordance with TS SR 3.0.1, failure to meet a surveillance, such as SRs 3.4.11.3 and 3.4.11.4, whether experienced during the performance of the surveillance or between performances of the surveillance is considered a failure to meet the associated TS LCO. There was no TS SR that required verification that the pressurizer PORVs can be operated on the backup instrument air supply system. The licensee continued to operate with the nitrogen accumulator isolated to PCV-456 without implementing the TS LCO 3.4.11 action requirements until 11:11 AM on June 14, 2023, at which time maintenance actions were implemented to replace the degraded PCV-3 valve. Following replacement of PCV-3, OPP-25 was reopened which restored the nitrogen accumulator supply to PCV-456. | Upon review of the licensees actions on the morning of June 13, 2023, the inspectors noted that the operators had not declared PCV-456 inoperable, as expected, when isolating its nitrogen accumulator and had not entered the associated TS 3.4.11 action requirements for an inoperable pressurizer PORV. When questioned regarding the basis for the decision, the operators stated that PCV-456 remained operable since its backup instrument air supply was still available to operate PCV-456. Isolating the accumulator nitrogen supply to PCV-456 resulted in the inability to meet TS SR 3.4.11.3 and TS SR 3.4.11.4, which requires the pressurizer PORVs and their related flow path solenoid air control and check valves to be capable of being operated through a complete cycle using nitrogen from the dedicated accumulators. In accordance with TS SR 3.0.1, failure to meet a surveillance, such as SRs 3.4.11.3 and 3.4.11.4, whether experienced during the performance of the surveillance or between performances of the surveillance is considered a failure to meet the associated TS LCO. There was no TS SR that required verification that the pressurizer PORVs can be operated on the backup instrument air supply system. The licensee continued to operate with the nitrogen accumulator isolated to PCV-456 without implementing the TS LCO 3.4.11 action requirements until 11:11 AM on June 14, 2023, at which time maintenance actions were implemented to replace the degraded PCV-3 valve. Following replacement of PCV-3, OPP-25 was reopened which restored the nitrogen accumulator supply to PCV-456. | ||
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Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | ||
Minor Performance Deficiency 71152A Failure to Conduct Maintenance Rule Evaluation of Nitrogen Accumulator Pressure Control Valve PCV-3 Failure | Minor Performance Deficiency 71152A Failure to Conduct Maintenance Rule Evaluation of Nitrogen Accumulator Pressure Control Valve PCV-3 Failure Minor Performance Deficiency: During the inspectors review of NCRs 2475694, 2476348, and 2480117 that documented the failure of the nitrogen pressure regulator valve PCV-3 to the A train pressurizer PORV PCV-456, it was noted that the maintenance rule screening section of NCR 2476348 had required a maintenance rule evaluation to be performed since this incident involved a maintenance rule high safety significant (HSS) system. However, the inspectors identified that a formal maintenance rule task assignment was not created in the NCR, and as a result, a maintenance rule evaluation to determine whether a maintenance rule functional failure (MRFF) had occurred due to the failure of PCV-3, had not been performed. In accordance with procedure AD-EG-ALL-1210, Maintenance Rule Program, Rev. 5, step 5.4.1.1.a, failures involving HSS systems and components are assigned maintenance rule evaluations in the licensees corrective action program to determine whether a MRFF occurred. Contrary to this procedure requirement, the inspectors found that no MRFF evaluation was performed because of the failure to create an action assignment in the NCR. | ||
Minor Performance Deficiency: During the inspectors review of NCRs 2475694, 2476348, and 2480117 that documented the failure of the nitrogen pressure regulator valve PCV-3 to the A train pressurizer PORV PCV-456, it was noted that the maintenance rule screening section of NCR 2476348 had required a maintenance rule evaluation to be performed since this incident involved a maintenance rule high safety significant (HSS) system. However, the inspectors identified that a formal maintenance rule task assignment was not created in the NCR, and as a result, a maintenance rule evaluation to determine whether a maintenance rule functional failure (MRFF) had occurred due to the failure of PCV-3, had not been performed. In accordance with procedure AD-EG-ALL-1210, Maintenance Rule Program, Rev. 5, step 5.4.1.1.a, failures involving HSS systems and components are assigned maintenance rule evaluations in the licensees corrective action program to determine whether a MRFF occurred. Contrary to this procedure requirement, the inspectors found that no MRFF evaluation was performed because of the failure to create an action assignment in the NCR. | |||
Screening: The inspectors determined the performance deficiency was minor. The licensee created the maintenance rule evaluation assignment for engineering to conduct the required maintenance rule evaluation as part of NCR 2475694. When the MRFF evaluation was subsequently completed, the licensee concluded that a MRFF did not occur as a result of the failure of PCV-3. The licensee issued NCR 2488245 to document this performance deficiency. | Screening: The inspectors determined the performance deficiency was minor. The licensee created the maintenance rule evaluation assignment for engineering to conduct the required maintenance rule evaluation as part of NCR 2475694. When the MRFF evaluation was subsequently completed, the licensee concluded that a MRFF did not occur as a result of the failure of PCV-3. The licensee issued NCR 2488245 to document this performance deficiency. | ||
Observation: Lack of Pressurizer PORV Testing Using Backup Instrument Air 71152A | Observation: Lack of Pressurizer PORV Testing Using Backup Instrument Air System 71152A As part of the inspectors review of NCRs 2475694, 2476348, and 2480117 that documented the failure of the nitrogen pressure regulator supply valve PCV-3 to the A train pressurizer PORV PCV-456, a detailed review of the pneumatically operated PORVs and their pneumatic supplies was performed. The Robinson pressurizer PORVs are designed with the capability to be operated with normal nitrogen piped from outside containment, nitrogen from a dedicated pressurized accumulator tank located inside containment, or from the normal instrument air system that is supplied from outside containment. The inspectors learned that surveillance test procedure OST-930, Control System Component Test for PCV-455C and PCV-456, Rev. 22, cycles each of the PORVs every 24 months using their nitrogen accumulators to meet TS SR 3.4.11.3 and TS 3.4.11.4. Additionally, operating procedure OP-006, Pressurizer PORV Pneumatic System/LTOPP, Rev. 49, provides instructions for testing and placing the PORVs in service during shutdown conditions when the PORVs provide their RCS low temperature overpressure protection safety function. However, the inspectors identified that neither of these two procedures operated the PORVs using the backup instrument air system, nor could the licensee identify any other procedure that accomplished this action. While OP-006 isolated the nitrogen supply to the PORVs, allowing a mechanical valve to open and admit instrument air to the solenoid air control valves of the PORVs, the procedure only verified via a local pressure gauge reading, that instrument air was aligned. The inspectors expressed concerns regarding the lack of actual testing to demonstrate that instrument air could operate the PORVs if the normal or accumulator nitrogen system was unavailable. To address the inspectors concerns, the licensee initiated a procedure change revision (via AR 2492994) for OST-930, that added actions to exercise the PORVs using the instrument air system. The licensee planned to conduct this revised testing to demonstrate the capability of the instrument air system to operate the PORVs prior to any upcoming plant shutdown conditions that relied on the PORVs for RCS overpressure protection. | ||
==EXIT MEETINGS AND DEBRIEFS== | ==EXIT MEETINGS AND DEBRIEFS== | ||
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=DOCUMENTS REVIEWED= | =DOCUMENTS REVIEWED= | ||
Inspection Type Designation Description or Title Revision or | Inspection | ||
Procedure | |||
71111.01 Procedures AP-058 Seasonal Readiness Rev. 4 | Type | ||
71111.01 Procedures EDP-009 Freeze Protection Panels Rev. 84 | Designation | ||
71111.01 Procedures OP-925 Cold Weather Operation Rev. 82 | Description or Title | ||
71111.01 Procedures PM-059 Freeze Protection for Safety Related or Fire Protection | Revision or | ||
Date | |||
71111.01 | |||
Procedures | |||
AP-058 | |||
Seasonal Readiness | |||
Rev. 4 | |||
71111.01 | |||
Procedures | |||
EDP-009 | |||
Freeze Protection Panels | |||
Rev. 84 | |||
71111.01 | |||
Procedures | |||
OP-925 | |||
Cold Weather Operation | |||
Rev. 82 | |||
71111.01 | |||
Procedures | |||
PM-059 | |||
Freeze Protection for Safety Related or Fire Protection | |||
Circuits | Circuits | ||
71111.04 Procedures OP-301B Chemical and Volume Control System Charging Pump B | Rev. 21 | ||
71111.04 | |||
Procedures | |||
OP-301B | |||
Chemical and Volume Control System Charging Pump B | |||
Operation | Operation | ||
71111.04 Procedures OP-301C Chemical and Volume Control System Charging Pump C | Rev. 6 | ||
71111.04 | |||
Procedures | |||
OP-301C | |||
Chemical and Volume Control System Charging Pump C | |||
Operation | Operation | ||
71111.04 Procedures OP-402 Auxiliary Feedwater System Rev. 116 | Rev. 7 | ||
71111.04 Procedures OP-403 Feedwater System Rev. 64 | 71111.04 | ||
71111.05 Fire Plans CSD-RNP-PFP- | Procedures | ||
OP-402 | |||
Auxiliary Feedwater System | |||
Rev. 116 | |||
71111.04 | |||
Procedures | |||
OP-403 | |||
Feedwater System | |||
Rev. 64 | |||
71111.05 | |||
Fire Plans | |||
CSD-RNP-PFP- | |||
AB2-0226-001 | AB2-0226-001 | ||
71111.05 Fire Plans CSD-RNP-PFP- | Auxiliary Building Elevation 226 Pre-Fire Plan | ||
Rev. 1 | |||
71111.05 | |||
Fire Plans | |||
CSD-RNP-PFP- | |||
AB2-0262-001 | AB2-0262-001 | ||
71111.05 Fire Plans CSD-RNP-PFP- | Auxiliary Building ELEV 262 Pre-Fire Plan | ||
Rev. 0 | |||
71111.05 | |||
Fire Plans | |||
CSD-RNP-PFP- | |||
PA-006 | PA-006 | ||
71111.05 Fire Plans CSD-RNP-PFP- | Protected Area Switchyard and Intake Pre-Fire Plan | ||
Rev. 1 | |||
71111.05 | |||
Fire Plans | |||
CSD-RNP-PFP- | |||
RW-0226-001 | RW-0226-001 | ||
71111.05 Procedures AD-FP-ALL-1520 Transient Combustible Control Rev. 1 | Radwaste Building Pre-Fire Plan | ||
71111.05 Procedures FP-012 Fire Protection Systems Minimum Equipment and | Rev. 0 | ||
71111.05 | |||
Procedures | |||
AD-FP-ALL-1520 | |||
Transient Combustible Control | |||
Rev. 1 | |||
71111.05 | |||
Procedures | |||
FP-012 | |||
Fire Protection Systems Minimum Equipment and | |||
Compensatory Actions | Compensatory Actions | ||
71111.11Q Engineering Reactivity | Rev. 36 | ||
71111.11Q | |||
Engineering | |||
Evaluations | |||
Reactivity | |||
Management | |||
Plan | Plan | ||
71111.11Q Procedures AD-TQ-ALL-0068 Licensed Operator Continuing Training Program Rev. 13 | RNP Unit 2 Cycle 34 November 2023 MFP-A Oil Cooler | ||
71111.11Q Procedures AD-TQ-ALL-0230 Licensed Operator Requalification Annual and Biennial | Repair | ||
Rev. 0 | |||
71111.11Q | |||
Procedures | |||
AD-TQ-ALL-0068 | |||
Licensed Operator Continuing Training Program | |||
Rev. 13 | |||
71111.11Q | |||
Procedures | |||
AD-TQ-ALL-0230 | |||
Licensed Operator Requalification Annual and Biennial | |||
Exam Development | Exam Development | ||
71111.11Q Procedures AD-TQ-ALL-0420 Conduct of Simulator Training and Evaluation Rev. 19 | Rev.12 | ||
71111.11Q Procedures OP-105 Maneuvering the Plant When Greater Than 25% Power Rev. 74 | 71111.11Q | ||
71111.12 Corrective Action NCR 2488245 NRC inspector identified failure to conduct required | Procedures | ||
AD-TQ-ALL-0420 | |||
Conduct of Simulator Training and Evaluation | |||
Rev. 19 | |||
71111.11Q | |||
Procedures | |||
OP-105 | |||
Maneuvering the Plant When Greater Than 25% Power | |||
Rev. 74 | |||
71111.12 | |||
Corrective Action | |||
Documents | |||
NCR 2488245 | |||
NRC inspector identified failure to conduct required | |||
maintenance rule evaluation of nitrogen supply to | |||
09/26/2023 | |||
Inspection | Inspection | ||
71111.12 Procedures AD-EG-ALL-1210 Maintenance Rule Program Rev. 5 | Procedure | ||
71111.13 Procedures AD-WC-ALL-0200 On-Line Work Management Rev. 21 | Type | ||
71111.13 Procedures AD-WC-ALL-0240 On-Line Risk Management Process Rev. 4 | Designation | ||
71111.13 Procedures CSD-WC-RNP- | Description or Title | ||
Revision or | |||
Date | |||
Resulting from | |||
Inspection | |||
pressurizer PORV issue | |||
71111.12 | |||
Procedures | |||
AD-EG-ALL-1210 | |||
Maintenance Rule Program | |||
Rev. 5 | |||
71111.13 | |||
Procedures | |||
AD-WC-ALL-0200 | |||
On-Line Work Management | |||
Rev. 21 | |||
71111.13 | |||
Procedures | |||
AD-WC-ALL-0240 | |||
On-Line Risk Management Process | |||
Rev. 4 | |||
71111.13 | |||
Procedures | |||
CSD-WC-RNP- | |||
240-00 | 240-00 | ||
71111.13 Procedures OMM-048 Work Coordination and Risk Assessment Rev. 71 | RNP ERAT Guidance | ||
71111.15 Procedures AD-OP-ALL-0105 Operability Determinations Rev. 7 | Rev. 1 | ||
71111.18 Procedures AD-EG-ALL-1132 Preparation and Control of Design Change Engineering | 71111.13 | ||
Procedures | |||
OMM-048 | |||
Work Coordination and Risk Assessment | |||
Rev. 71 | |||
71111.15 | |||
Procedures | |||
AD-OP-ALL-0105 | |||
Operability Determinations | |||
Rev. 7 | |||
71111.18 | |||
Procedures | |||
AD-EG-ALL-1132 | |||
Preparation and Control of Design Change Engineering | |||
Changes | Changes | ||
71111.18 Procedures AD-EG-ALL-1137 Engineering Change Product Selection Rev. 12 | Rev. 26 | ||
71111.18 Work Orders WO 20633040 Installation of temporary modification EC 423421 11/8/2023 | 71111.18 | ||
71111.24 Procedures PLP-033 Post-Maintenance Testing (PMT) Program Rev. 70 | Procedures | ||
71151 Corrective Action | AD-EG-ALL-1137 | ||
Documents | Engineering Change Product Selection | ||
Rev. 12 | |||
71111.18 | |||
Work Orders | |||
WO 20633040 | |||
Installation of temporary modification EC 423421 | |||
11/8/2023 | |||
71111.24 | |||
Procedures | |||
PLP-033 | |||
Post-Maintenance Testing (PMT) Program | |||
Rev. 70 | |||
71151 | |||
Corrective Action | |||
Documents | |||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
NCR 2496591 | |||
Documents | Incorrect maximum reactor coolant dose equivalent iodine | ||
value reported in April 2023 | |||
2/4/2023 | |||
71151 | |||
Corrective Action | |||
Documents | |||
Resulting from | Resulting from | ||
Inspection | Inspection | ||
71151 Procedures AD-EG-ALL-1217 Mitigating System Performance Index (MSPI) Rev. 3 | NCR 2498962 | ||
71151 Procedures AD-PI-ALL-0700 Performance Indicators Rev. 6 | NRC identified incorrect maximum reactor coolant dose | ||
equivalent iodine value reported for month of August 2023 | |||
2/21/2023 | |||
71151 | |||
Procedures | |||
AD-EG-ALL-1217 | |||
Mitigating System Performance Index (MSPI) | |||
Rev. 3 | |||
71151 | |||
Procedures | |||
AD-PI-ALL-0700 | |||
Performance Indicators | |||
Rev. 6 | |||
}} | }} | ||
Latest revision as of 20:38, 24 November 2024
| ML24030A542 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/31/2024 |
| From: | David Dumbacher Division Reactor Projects II |
| To: | Basta L Duke Energy Progress |
| References | |
| IR 2023004 | |
| Download: ML24030A542 (16) | |
Text
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - INTEGRATED INSPECTION REPORT 05000261/2023004
Dear Laura Basta:
On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at H.B. Robinson Steam Electric Plant. On January 24, 2024, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at H.B. Robinson Steam Electric Plant.
January 31, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000261 License No. DPR-23
Enclosure:
As stated
Inspection Report
Docket Number:
05000261 License Number:
DPR-23 Report Number:
05000261/2023004 Enterprise Identifier:
I-2023-004-0022 Licensee:
Duke Energy Progress, LLC Facility:
H.B. Robinson Steam Electric Plant Location:
Hartsville, SC Inspection Dates:
October 01, 2023 to December 31, 2023 Inspectors:
V. Gaffney, Resident Inspector J. Zeiler, Senior Resident Inspector Approved By:
David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at H.B. Robinson Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Declare Pressurizer Power Operated Relief Valve Inoperable During Maintenance Results in a Condition Prohibited by Technical Specification Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000261/2023004-01 Open/Closed
[H.13] -
Consistent Process 71152A NRC inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.11, Pressurizer Power Operated Relief Valves (PORVs), Condition A, for the licensee's failure to declare PCV-456, the A train pressurizer PORV, inoperable when conducting plant maintenance that isolated the dedicated nitrogen accumulator for PCV-456 operation. Specifically, isolating the nitrogen accumulator resulted in the inability to successfully complete TS Surveillance Requirement (SR) 3.4.11.3 and TS SR 3.4.11.4, to demonstrate the accumulators and associated piping could supply sufficient nitrogen to operate the PORVs.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000261/2023-001-00 Unit 2, Condition Prohibited by Technical Specification Due to Missed Entry into Limiting Condition for Operation 71153 Closed
PLANT STATUS
Unit 2 began the inspection period at rated thermal power (RTP). On November 27, 2023, the unit was down powered to 50 percent (%) to remove the 'A' main feedwater pump (MFP) from service to replace its oil cooler which developed a cooling water tube leak. Following replacement of the oil cooler and restart of the 'A' MFP, the unit returned to RTP on November 28, 2023. The unit remained at or near RTP for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of and during cold temperatures for the following systems:
- service water (SW) system on November 16, 2023
- refueling water storage tank on December 19, 2023
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) 'B' and 'C' chemical and volume control system (CVCS) charging pumps while 'A' CVCS charging pump was out of service for corrective maintenance to replace degraded valves and packing on November 6-7, 2023
- (2) 'B' MFP and the auxiliary feedwater system while the 'A' MFP was out of service for corrective maintenance to replace the oil cooler on November 28, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)auxiliary building elevation 262 'C' battery room enclosure (fire zone 34) on October 30, 2023 (2)radwaste building, all elevations (fire zone 35) on October 31, 2023
- (3) SW intake and pumps and 'B' deepwell pump areas (fire zones 29 and 42) on November 9, 2023 (4)auxiliary building pipe alley areas (fire zone 11) on November 13, 2023 (5)auxiliary building elevation 226 'B' emergency diesel generator (EDG) room (fire zone 1) on December 6, 2023
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
The licensee completed the annual requalification operating examinations and biennial written examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." The inspector performed an in-office review of the overall pass/fail results of the individual operating examinations, the crew simulator operating examinations, and the biennial written examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program and Licensed Operator Performance." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam completed on March 31, 2023 and the biennial written examinations completed on March 31, 2023.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a planned unit down power to 50% RTP to replace the oil cooler associated with the 'A' MFP on November 27, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification simulator evaluation on November 14, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)degraded safety relief valve for the starting air compressor associated with the 'B' EDG requires replacement [nuclear condition report (NCR) 2468490]
(2)failure of regulator valve, PCV-3, to maintain normal nitrogen supply pressure to the
'A' pressurizer PORV, PCV-456 (NCR 2475694)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)elevated risk (Green) during planned blowdown of sensing lines for 'B' SW system header pressure on October 17, 2023 (2)elevated risk (Green) during 'B' steam generator level channel 485 calibration requiring associated main feedwater regulating valve to be in manual operation on October 31, 2023 (3)elevated risk (Green) during planned corrective maintenance to replace 'A' CVCS charging pump valves and packing on November 6-7, 2023 (4)elevated risk (Green) during planned corrective maintenance to replace degraded oil cooler for the 'A' MFP on November 27-28, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) NCR 2490097, degraded 'A' pressurizer backup group heater, circuit 5, identified during testing on October 11, 2023
- (2) NCR 2493460, 'A' MFP lube oil cooler heat exchanger tube leakage into SW system on November 6, 2023
- (3) NCRs 2451740 and 2493039, fuel assembly growth measurements exceeded vendor fuel design specification limits, review completed on November 30, 2023
- (4) NCR 2493180, missed offsite dose calculation manual channel calibration of flow rate monitor for containment air and plant vent radiation monitors R-11 and R-12, review completed on December 5, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)engineering change (EC) 423421, temporary modification to reroute SW system cooling return from 'A' MFP lube oil cooler due to cooler tube leakage
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
- (1) OWP-017, Service Water, following preventive maintenance on 'B' SW system header pressure instrumentation on October 17, 2023
- (2) OP-301A, Chemical and Volume Control System Charging Pump A Operation, Section 6.3.3, Charging Pump 'A' Break-in After Packing Replacement, following maintenance repairs to the 'A' CVCS charging pump on November 7, 2023
- (3) Work Order (WO) 20633455 instructions to conduct functional test of 'A' MFP oil cooler, following replacement on November 28, 2023
- (4) OP-903, Service Water System, Section 6.2.1, Swapping Service Water Booster Pumps, following preventive maintenance on 'B' service water booster pump on December 18, 2023
- (5) WO 20642045 instructions to confirm reinstallation of pump motor breaker fuses, following replacement of lube oil in the inboard and outboard pump bearings associated with the 'A' safety injection pump on December 27, 2023
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) OST-551-1, Turbine Valve Test, on November 27-28, 2023
- (2) OST-401-1, EDG A Slow Speed Start, on December 6, 2023
- (3) OST-303-2, Service Water Booster Pump B Test, on December 18, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) OST-101-1, CVCS Component Test Charging Pump A, on November 7,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06)===
- (1) Unit 2 (October 1, 2022 through September 30, 2023)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) Unit 2 (October 1, 2022 through September 30, 2023)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)reportability evaluation for missed entry into TS 3.4.11 LCO (NCRs 2480117,
2476348, and 2475694) 71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program, maintenance rule database, operational equipment deficiencies database, and plant action register summary database for potential adverse trends in equipment reliability that might be indicative of a more significant safety issue. The inspectors did not identify a negative trend that could lead to a more safety significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000261/2023-001-00, Condition Prohibited by Technical Specification Due to Missed Entry into Limiting Condition for Operation (ADAMS Accession No.
ML23222A257). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 711152A. This LER is closed.
INSPECTION RESULTS
Failure to Declare Pressurizer Power Operated Relief Valve Inoperable During Maintenance Results in a Condition Prohibited by Technical Specification Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000261/2023004-01 Open/Closed
[H.13] -
Consistent Process 71152A NRC inspectors identified a Green finding and associated NCV of TS LCO 3.4.11, Pressurizer PORVs, Condition A, for the licensee's failure to declare PCV-456, the A train pressurizer PORV, inoperable when conducting plant maintenance that isolated the dedicated nitrogen accumulator for PCV-456 operation. Specifically, isolating the nitrogen accumulator resulted in the inability to successfully complete TS Surveillance Requirement (SR) 3.4.11.3 and TS SR 3.4.11.4, to demonstrate the accumulators and associated piping could supply sufficient nitrogen to operate the PORVs.
Description:
On June 12, 2023, with Unit 2 operating at 100% RTP, the licensee identified a nitrogen gas leak in containment because of the failure of pressure regulator valve PCV-3, which normally provides ~95 psig nitrogen supply motive force to operate PCV-456. Licensee troubleshooting determined the pressure setpoint for PCV-3 had failed high (local pressure gauge in containment was reading ~127 psig) resulting in its downstream nitrogen supply relief valve, OPP-17, lifting at its design setpoint of 125 psig and discharging nitrogen into the containment atmosphere. At 4:41 PM on June 12, 2023, the licensee terminated the nitrogen leak by shutting nitrogen isolation valve OPP-25, located directly upstream of PCV-
3. However, shutting OPP-25 not only isolated the normal nitrogen supply to PCV-456 that is
supplied from outside containment, but also the nitrogen from the dedicated nitrogen accumulator tank located inside containment.
Upon review of the licensees actions on the morning of June 13, 2023, the inspectors noted that the operators had not declared PCV-456 inoperable, as expected, when isolating its nitrogen accumulator and had not entered the associated TS 3.4.11 action requirements for an inoperable pressurizer PORV. When questioned regarding the basis for the decision, the operators stated that PCV-456 remained operable since its backup instrument air supply was still available to operate PCV-456. Isolating the accumulator nitrogen supply to PCV-456 resulted in the inability to meet TS SR 3.4.11.3 and TS SR 3.4.11.4, which requires the pressurizer PORVs and their related flow path solenoid air control and check valves to be capable of being operated through a complete cycle using nitrogen from the dedicated accumulators. In accordance with TS SR 3.0.1, failure to meet a surveillance, such as SRs 3.4.11.3 and 3.4.11.4, whether experienced during the performance of the surveillance or between performances of the surveillance is considered a failure to meet the associated TS LCO. There was no TS SR that required verification that the pressurizer PORVs can be operated on the backup instrument air supply system. The licensee continued to operate with the nitrogen accumulator isolated to PCV-456 without implementing the TS LCO 3.4.11 action requirements until 11:11 AM on June 14, 2023, at which time maintenance actions were implemented to replace the degraded PCV-3 valve. Following replacement of PCV-3, OPP-25 was reopened which restored the nitrogen accumulator supply to PCV-456.
The licensee reviewed the inspectors concern regarding the operability conclusion and determined that, in accordance with TS SR 3.0.1, TS LCO 3.4.11, Condition A should have been entered for an inoperable PORV when the nitrogen accumulator to PCV-456 was initially isolated due to being unable to meet SR 3.4.11.4. LCO 3.4.11, Condition A, required that within one hour, the associated block valve to PCV-456 be closed. The licensee determined that not entering the LCO and completing the required action resulted in a condition prohibited by TS. This condition was determined to be reportable to the NRC in accordance with 10 CFR 50.73(a)(2)(i)(B) and required the submittal of a LER.
Corrective Actions: The licensee entered the inspectors concern that PCV-456 had not been declared inoperable on June 13, 2023, when its nitrogen accumulator was initially isolated into their corrective action program as NCR 2476348. The licensee submitted LER 05000261/2023-001-00, Condition Prohibited by Technical Specification Due to Missed Entry into Limiting Condition for Operation, on August 10, 2023. To address the specific operator weaknesses identified from this issue, the licensee planned to provide additional training to the operators on the specific SRs associated with TS 3.4.11 and TS SR 3.0.1, as well as revise and enhance the guidance in the TS Bases and operations equipment out of service procedures to ensure PORV operability requirements are clearer.
Corrective Action References: NCRs 2480117, 2476348, and 2475694
Performance Assessment:
Performance Deficiency: The licensees failure to adequately assess that isolating the nitrogen accumulator to PCV-456 rendered the valve TS inoperable and the subsequent failure to enter the applicable action requirements of TS 3.4.11 LCO, Condition A, constituted a performance deficiency that was within the licensees ability to have foreseen and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to recognize that isolating the nitrogen accumulator to PCV-456 could adversely affect the valves capability to perform its safety function during certain design-basis accident scenarios, resulted in the licensees failure to implement the TS LCO action requirements.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because it did not result in the loss of PCV-456 safety function for greater than its 72-hour TS allowed outage time, only affected the A pressurizer PORV, and the redundant B train pressurizer PORV, PCV-455C, remained operable for the entire duration that PCV-456 was isolated from its nitrogen accumulator.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the operators failed to factor into account all relevant TS surveillance requirements, pressurizer PORV nitrogen and instrument air system licensing basis and operational information, when concluding that PCV-456 remained operable when isolating its nitrogen accumulator.
Enforcement:
Violation: Robinson Unit 2 TS SR 3.4.11.3 and 3.4.11.4 required the nitrogen accumulators to be capable of operating the pressurizer PORVs and their related flow path solenoid air control and check valves through a complete cycle in Modes 1, 2, and 3. TS Surveillance Requirement 3.0.1 required that surveillance requirements shall be met during the Modes or other specified conditions of applicability for individual LCOs. Failure to meet a surveillance, whether such failure is experienced during the performance of the surveillance or between performances of the surveillance, shall be failure to meet the LCO. TS LCO 3.4.11, Condition A, contained required action A.1 to be taken for an inoperable pressurizer PORV still capable of being manually cycled that included closing within one hour, the associated block valve to the inoperable PORV.
Contrary to the above, between 4:41 PM on June 12, 2023, and 11:11 AM on June 14, 2023, pressurizer PORV PCV-456 was not capable of being cycled with its nitrogen accumulator supply in accordance with SR 3.4.11.3 and 3.4.11.4 while in Mode 1 and the required action of LCO 3.4.11, A.1, was not completed within the required completion time.
The disposition of this finding and associated violation closes LER 05000261/2023-001-00.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Performance Deficiency 71152A Failure to Conduct Maintenance Rule Evaluation of Nitrogen Accumulator Pressure Control Valve PCV-3 Failure Minor Performance Deficiency: During the inspectors review of NCRs 2475694, 2476348, and 2480117 that documented the failure of the nitrogen pressure regulator valve PCV-3 to the A train pressurizer PORV PCV-456, it was noted that the maintenance rule screening section of NCR 2476348 had required a maintenance rule evaluation to be performed since this incident involved a maintenance rule high safety significant (HSS) system. However, the inspectors identified that a formal maintenance rule task assignment was not created in the NCR, and as a result, a maintenance rule evaluation to determine whether a maintenance rule functional failure (MRFF) had occurred due to the failure of PCV-3, had not been performed. In accordance with procedure AD-EG-ALL-1210, Maintenance Rule Program, Rev. 5, step 5.4.1.1.a, failures involving HSS systems and components are assigned maintenance rule evaluations in the licensees corrective action program to determine whether a MRFF occurred. Contrary to this procedure requirement, the inspectors found that no MRFF evaluation was performed because of the failure to create an action assignment in the NCR.
Screening: The inspectors determined the performance deficiency was minor. The licensee created the maintenance rule evaluation assignment for engineering to conduct the required maintenance rule evaluation as part of NCR 2475694. When the MRFF evaluation was subsequently completed, the licensee concluded that a MRFF did not occur as a result of the failure of PCV-3. The licensee issued NCR 2488245 to document this performance deficiency.
Observation: Lack of Pressurizer PORV Testing Using Backup Instrument Air System 71152A As part of the inspectors review of NCRs 2475694, 2476348, and 2480117 that documented the failure of the nitrogen pressure regulator supply valve PCV-3 to the A train pressurizer PORV PCV-456, a detailed review of the pneumatically operated PORVs and their pneumatic supplies was performed. The Robinson pressurizer PORVs are designed with the capability to be operated with normal nitrogen piped from outside containment, nitrogen from a dedicated pressurized accumulator tank located inside containment, or from the normal instrument air system that is supplied from outside containment. The inspectors learned that surveillance test procedure OST-930, Control System Component Test for PCV-455C and PCV-456, Rev. 22, cycles each of the PORVs every 24 months using their nitrogen accumulators to meet TS SR 3.4.11.3 and TS 3.4.11.4. Additionally, operating procedure OP-006, Pressurizer PORV Pneumatic System/LTOPP, Rev. 49, provides instructions for testing and placing the PORVs in service during shutdown conditions when the PORVs provide their RCS low temperature overpressure protection safety function. However, the inspectors identified that neither of these two procedures operated the PORVs using the backup instrument air system, nor could the licensee identify any other procedure that accomplished this action. While OP-006 isolated the nitrogen supply to the PORVs, allowing a mechanical valve to open and admit instrument air to the solenoid air control valves of the PORVs, the procedure only verified via a local pressure gauge reading, that instrument air was aligned. The inspectors expressed concerns regarding the lack of actual testing to demonstrate that instrument air could operate the PORVs if the normal or accumulator nitrogen system was unavailable. To address the inspectors concerns, the licensee initiated a procedure change revision (via AR 2492994) for OST-930, that added actions to exercise the PORVs using the instrument air system. The licensee planned to conduct this revised testing to demonstrate the capability of the instrument air system to operate the PORVs prior to any upcoming plant shutdown conditions that relied on the PORVs for RCS overpressure protection.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 24, 2024, the inspectors presented the integrated inspection results to Laura Basta and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
AP-058
Seasonal Readiness
Rev. 4
Procedures
EDP-009
Freeze Protection Panels
Rev. 84
Procedures
Cold Weather Operation
Rev. 82
Procedures
Freeze Protection for Safety Related or Fire Protection
Circuits
Rev. 21
Procedures
Chemical and Volume Control System Charging Pump B
Operation
Rev. 6
Procedures
Chemical and Volume Control System Charging Pump C
Operation
Rev. 7
Procedures
Auxiliary Feedwater System
Rev. 116
Procedures
Feedwater System
Rev. 64
Fire Plans
CSD-RNP-PFP-
AB2-0226-001
Auxiliary Building Elevation 226 Pre-Fire Plan
Rev. 1
Fire Plans
CSD-RNP-PFP-
AB2-0262-001
Auxiliary Building ELEV 262 Pre-Fire Plan
Rev. 0
Fire Plans
CSD-RNP-PFP-
PA-006
Protected Area Switchyard and Intake Pre-Fire Plan
Rev. 1
Fire Plans
CSD-RNP-PFP-
RW-0226-001
Radwaste Building Pre-Fire Plan
Rev. 0
Procedures
AD-FP-ALL-1520
Transient Combustible Control
Rev. 1
Procedures
Fire Protection Systems Minimum Equipment and
Compensatory Actions
Rev. 36
Engineering
Evaluations
Reactivity
Management
Plan
RNP Unit 2 Cycle 34 November 2023 MFP-A Oil Cooler
Repair
Rev. 0
Procedures
AD-TQ-ALL-0068
Licensed Operator Continuing Training Program
Rev. 13
Procedures
AD-TQ-ALL-0230
Licensed Operator Requalification Annual and Biennial
Exam Development
Rev.12
Procedures
AD-TQ-ALL-0420
Conduct of Simulator Training and Evaluation
Rev. 19
Procedures
Maneuvering the Plant When Greater Than 25% Power
Rev. 74
Corrective Action
Documents
NCR 2488245
NRC inspector identified failure to conduct required
maintenance rule evaluation of nitrogen supply to
09/26/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
pressurizer PORV issue
Procedures
AD-EG-ALL-1210
Rev. 5
Procedures
AD-WC-ALL-0200
On-Line Work Management
Rev. 21
Procedures
AD-WC-ALL-0240
On-Line Risk Management Process
Rev. 4
Procedures
CSD-WC-RNP-
240-00
Rev. 1
Procedures
OMM-048
Work Coordination and Risk Assessment
Rev. 71
Procedures
AD-OP-ALL-0105
Rev. 7
Procedures
AD-EG-ALL-1132
Preparation and Control of Design Change Engineering
Changes
Rev. 26
Procedures
AD-EG-ALL-1137
Engineering Change Product Selection
Rev. 12
Work Orders
Installation of temporary modification EC 423421
11/8/2023
Procedures
PLP-033
Post-Maintenance Testing (PMT) Program
Rev. 70
71151
Corrective Action
Documents
Resulting from
Inspection
NCR 2496591
Incorrect maximum reactor coolant dose equivalent iodine
value reported in April 2023
2/4/2023
71151
Corrective Action
Documents
Resulting from
Inspection
NCR 2498962
NRC identified incorrect maximum reactor coolant dose
equivalent iodine value reported for month of August 2023
2/21/2023
71151
Procedures
AD-EG-ALL-1217
Mitigating System Performance Index (MSPI)
Rev. 3
71151
Procedures
AD-PI-ALL-0700
Performance Indicators
Rev. 6