IR 05000261/2007005

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January 25, 2008

Carolina Power and Light CompanyATTN:Mr. Tom WaltVice President - Robinson PlantH. B. Robinson Steam Electric Plant Unit 2 3851 West Entrance Road Hartsville, SC 29550

SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATEDINSPECTION REPORT 05000261/2007005

Dear Mr. Walt:

On December 31, 2007, the US Nuclear Regulatory Commission (NRC) completed aninspection at your H.B. Robinson reactor facility. The enclosed integrated inspection reportdocuments the inspection findings, which were discussed on January 3, 2008, with you and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.Based on the results of this inspection, the inspectors identified one issue of very low safetysignificance (Green). This issue was determined to involve a violation of NRC requirements.

Additionally two licensee-identified violations which were determined to be of very low safety significance are listed in Section 40A7 of this report. However, because of their very low safety significance and because they have been entered into your corrective action program (CAP),

the NRC is treating these issues as non-cited violations (NCV), in accordance with Section VI.A.1 of the NRC's Enforcement Policy. If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-

0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement,United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the H.B. Robinson facility.

CP&L2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Randall A. Musser, ChiefReactor Projects Branch 4 Division of Reactor ProjectsDocket No.:50-261License No.:DPR-23

Enclosure:

Inspection Report 05000261/2007005

w/Attachment:

Supplemental Informationcc w\encls: See page 3 CP&L2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Randall A. Musser, ChiefReactor Projects Branch 4 Division of Reactor ProjectsDocket No.:50-261License No.:DPR-23

Enclosure:

Inspection Report 05000261/2007005

w/Attachment:

Supplemental Informationcc w\encls: See page 3G PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLEG SENSITIVE G NON-SENSITIVEADAMS: G YesACCESSION NUMBER:_________________________OFFICERII:DRPRII:DRPRII:DRPRII:DRPSIGNATURERCH2 by faxEDM by faxGRWRAMNAMEBHagarEMorrisGWilsonRMusserDATE01/25/200801/25/200801/17/200801/25/20081/ /20081/ /20081/ /2008 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO OFFICIAL RECORD COPY DOCUMENT NAME: C:\FileNet\ML080250145.wpd CP&L3cc w/encl:Eric McCartney Director, Site Operations Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 Electronic Mail DistributionErnest J. Kapopoulos, Jr.Plant General Manager Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail DistributionScott D. WestSuperintendent - Security Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail DistributionPaul Fulford, ManagerPerformance Evaluation and Regulatory Affairs PEB 5 Electronic Mail DistributionC. T. Baucom, ManagerSupport Services - Nuclear Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 Electronic Mail DistributionHenry J. Porter, DirectorDiv. of Radioactive Waste Mgmt.

Dept. of Health and Environmental Control Electronic Mail DistributionR. Mike GandyDivision of Radioactive Waste Mgmt.

S. C. Department of Health and Environmental Control Electronic Mail DistributionBeverly Hall, Chief RadiationProtection Section N. C. Department of Environment, Health and Natural Resources Electronic Mail DistributionDavid T. ConleyAssociate General Counsel - Legal Dept.

Progress Energy Service Company, LLC Electronic Mail DistributionSupervisor, Licensing/Regulatory ProgramsCarolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, SC 29550John H. O'Neill, Jr.Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128Chairman of the North Carolina Utilities Commission c/o Sam Watson, Staff Attorney Electronic Mail DistributionRobert P. GruberExecutive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326Public Service CommissionState of South Carolina P. O. Box 11649 Columbia, SC 29211 CP&L4Report to Tom Walt from Randall A. Musser dated January 25, 2008.

SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC INTEGRATEDINSPECTION REPORT 05000261/2007005Distribution w/encl:M. Vaaler, NRR C. Evans (Part 72 Only)

L. Slack, RII EICS OE Mail (email address if applicable)

RIDSNRRDIRS PUBLICNRC Resident InspectorU.S. Nuclear Regulatory Commission 2112 Old Camden Rd Hartsville, SC 29550 EnclosureU. S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket No:50-261License No:DPR-23 Report No:005000261/2007005 Facility:H. B. Robinson Steam Electric Plant, Unit 2 Location:3581 West Entrance RoadHartsville, SC 29550Dates:October 1, 2007, through December 31, 2007 Inspectors:R. Hagar, Senior Resident InspectorE. Morris, Resident InspectorApproved by:R. Musser, ChiefReactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000261/2007-005, Carolina Power and Light Company; 10/1/07-12/31/07; H.B. Robinson SteamElectric Plant, Unit 2; Maintenance Effectiveness.The report covered a three-month period of inspection by resident inspectors. One NRC identifiednon-cited violation (NCV) was identified. The significance of most findings is indicated by their color(Green, White, Yellow, Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated July 2006.A.NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVIfor the licensee's failure in 2005 to determine the cause of a failure of the steam-driven auxiliary feedwater pump to start, thereby allowing a subsequent similar failure in 2007. The performance deficiency was more than minor because it affected the equipmentperformance attribute of the Mitigating Systems cornerstone. Specifically, the performance deficiency decreased the reliability of the SDAFW pump by increasing the probability that the pump's governor air supply solenoid valve would fail to open on demand. This finding was determined to have very low safety significance because it was not a design or qualification deficiency and did not represent the loss of a system safety function. This finding has a cross-cutting aspect in the area of Human Performance because the licensee did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety (H.2.c), in that the licensee did not ensure that resources were available and adequate to produce a complete investigation for a significant condition adverse to quality.

(Section 1R12)

B. Licensee-Identified Violations

Two violations of very low safety significance which were identified by the licensee were reviewedby the inspectors. Corrective actions taken or planned by the licensee have been entered into the

Corrective Action Program. These violations and corrective action tracking numbers are listed in

Section 40A7 of this report.

Enclosure

REPORT DETAILS

Summary of Plant Status The unit began the inspection period at rated thermal power, and operated atfull power for the entire inspection period.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R01Adverse Weather Protection

a. Inspection Scope

After the licensee completed preparations for low temperatures, the inspectors walked down theservice water pumps, auxiliary feedwater system, and safety injection system. These systems were selected because their safety related functions could be affected by adverse weather.

The inspectors reviewed documents listed in the Attachment, observed plant conditions, and evaluated those conditions using criteria documented in Procedure AP-008, Cold WeatherPreparations. Documents reviewed are listed in the Attachment.The inspectors reviewed the following action request (AR) associated with this area to verifythat the licensee identified and implemented appropriate corrective actions:*AR 227883, Freeze protection for Service Water Pump components under clearancegreater than 30 days.

b. Findings

No findings of significance were identified.1R04Equipment Alignment

a. Inspection Scope

Partial System WalkdownsThe inspectors performed the following three partial system walkdowns, while the indicatedstructures, systems, and/or components (SSCs) were out-of-service for maintenance and testing:System Walked DownSSC Out of ServiceDate InspectedSteam Driven AuxiliaryFeedwater trainA Motor Driven AuxiliaryFeedwater pumpOctober 4B Service Water BoosterPump trainA Service Water BoosterPumpOctober 22

B Instrument Air CompressorTrainA Instrument AirCompressorOctober 29To evaluate the operability of the selected trains under these conditions, the inspectorscompared observed positions of valves, switches, and electrical power breakers to the procedures and drawings listed in the Attachment. The inspectors also walked down the trains.

During the walkdowns, the inspectors reviewed the following:*Valves were correctly positioned and did not exhibit leakage that would impact the functionsof any given valve.*Electrical power was available as required.

• Major system components were correctly labeled, lubricated, cooled, ventilated, etc.

• Hangers and supports were correctly installed and functional.

• Essential support systems were operational.

• Ancillary equipment or debris did not interfere with system performance.

• Tagging clearances were appropriate.

• Valves were locked as required by the locked valve program.The inspectors reviewed the documents listed in the Attachment to verify that the ability of thesystem to perform its functions could not be affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, and other system-related issues tracked by the engineering department.The inspectors reviewed the following AR associated with this area to verify that the licenseeidentified and implemented appropriate corrective actions:*AR 228308, Low cooling water flow to circulating water pumps

b. Findings

No findings of significance were identified.1R05Fire Protection

a. Inspection Scope

For the six areas identified below, the inspectors reviewed the control of transient combustiblematerial and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures to verify that those items were consistent with Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire Protection System, and UFSAR Appendix9.5.A, Fire Hazards

Analysis.

The inspectors walked down accessible portions of each area and reviewed results from related surveillance tests to verify that conditions in these areas were consistent with descriptions of the areas in the UFSAR. Documents reviewed are listed in the

.

The following areas were inspected:Fire ZoneDescription20Emergency Switchgear Room and Electrical Equipment Area26Yard Transformers 7Auxiliary Building Hallway (Ground Floor)1Diesel Generator "B" Room 25FTurbine Building East & West Mezzanine 25GTurbine Building Operating DeckThe inspectors reviewed the following AR associated with this area to verify that the licenseeidentified and implemented appropriate corrective actions:*AR 211614, Emergency Diesel Generator CO2 system flex hose kinked

b. Findings

No findings of significance were identified.1R11Licensed Operator Requalification

a. Inspection Scope

On December 11, the inspectors observed licensed-operator performance during requalificationsimulator training for crew one to verify that actual operator performance was consistent with expected operator performance, as described in Exercise Guide LOCT 04-5. This training tested the operators' ability to operate components from the control room, direct auxiliary operator actions, and determine the appropriate emergency action level classifications while responding to a pressurizer level transmitter failure, high vibrations on the main turbine, a steam line break inside containment, and the failure of the safety injection pumps. The inspectors focused on clarity and formality of communication, the use of procedures, alarm response, control board manipulations, group dynamics, and supervisory oversight. The inspectors observed the post-exercise critique to verify that the licensee identifieddeficiencies and discrepancies that occurred during the simulator training.Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the two degraded SSC/function performance problems or conditionslisted below to verify the appropriate handling of these performance problems or conditions in accordance with 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and 10 CFR 50.65, Maintenance Rule. Documents reviewed are listed in the Attachment. The problems/conditions and their corresponding ARs were:Performance Problem/ConditionAR(s)Surveillance test failure of RMS-2 after air solenoid replacement222904223595Unplanned unavailability of the [steam driven auxiliary feedwater] pump242583During the reviews, the inspectors focused on the following:*Appropriate work practices,*Identifying and addressing common cause failures,

• Scoping in accordance with 10 CFR 50.65(b),

• Characterizing reliability issues (performance),

• Charging unavailability (performance),

• Trending key parameters (condition monitoring),

• 10 CFR 50.65(a)(1) or (a)(2) classification and reclassification, and

• Appropriateness of performance criteria for SSCs/functions classified (a)(2) and/orappropriateness and adequacy of goals and corrective actions for SSCs/functions classified (a)(1).

b. Findings

Introduction:

On August 8, 2005, the steam-driven auxiliary feedwater (SDAFW) pump failed tostart during a routine surveillance test. At the time, the frequency at which the licensee had been testing the pump (once per quarter) was not consistent with monthly testing that had been recommended by the vendor of the pump governor's air supply solenoid valve. The licensee determined the failure to be a significant condition adverse to quality, and initiated AR 165893165893to investigate it. The investigation team identified two "most likely" causes of the failure, but did not review the testing frequency and did not identify a root cause. The licensee implemented corrective actions to address the most-likely causes. No corrective action changed the frequency at which the SDAFW pump was tested.On August 12, 2007, the SDAFW pump again failed to start during a routine surveillance test. The licensee addressed that failure in AR 242583242583 The investigation report for AR 242583242583stated that the August 12, 2007, failure had been a repeat of the August 8, 2005, failure, and

that the cause of both failures had been sticking of the pump's governor air supply solenoidvalve. The report also stated that the cause of the valve sticking was that the licensee had not been cycling that valve as frequently as the valve vendor had recommended. Corrective actions described in the report included revising the monthly surveillance procedure to require starting the SDAFW pump every month. The August 12, 2007, event was therefore a result of the licensee's failure to determine the cause of the August 8, 2005 event and their consequential failure to take effective action to preclude repetition.Description: The performance deficiency in these circumstances is the licensee's failure toidentify the cause of the August 8, 2005, event. The licensee determined that event to be a significant condition adverse to quality, and for a significant condition adverse to quality, 10 CFR 50, Appendix B, Criterion XVI requires, in part, that the licensee determine the cause of the condition and take corrective action to preclude repetition. The licensee's failure to identify the cause of the August 8, 2005, event and their consequential failure to take corrective action to preclude repetition allowed a similar failure to occur on August 12, 2007.Analysis: The performance deficiency was more than minor because it is associated with theequipment performance attribute of the Mitigating Systems cornerstone. Specifically, the performance deficiency allowed a continuation of the licensee's failure to cycle the governor air supply solenoid valve in accordance with the vendor's recommendation, which increased the probability that the valve would fail to open on demand, and thereby decreased the reliability of the SDAFW pump. Using the Phase 1 worksheet in Manual Chapter 0609, Appendix A, this performance deficiency was determined to have very low safety significance because it was not a design or qualification deficiency and did not represent the loss of a system safety function.

This finding has a cross-cutting aspect in the area of Human Performance, because the licensee did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety (H.2.c), in that the licensee did not ensure that resources were available and adequate to produce a complete investigation for a significant condition adverse to quality.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI requires, in part, that the measuresestablished for identifying and correcting conditions adverse to quality shall, for significant conditions adverse to quality, assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, following a failure of the SDAFW pump to start on August 8, 2005, an event determined by the licensee to be a significant condition adverse to quality and documented in AR 165893165893 the licensee failed to identify the cause of the condition, and therefore failed to take corrective action to preclude repetition. Specifically, the licensee failed to discover that the frequency at which they were testing the SDAFW pump (at that time, once every 3 months) was longer than the frequency at which the vendor of the SDAFW pump governor air supply solenoid valve recommended that the valve be cycled to prevent sticking (once every 31 days). Consequently, the licensee failed to change the frequency of cycling the SDAFW pump governor air supply solenoid valve to a frequency that would prevent sticking of that valve, and on August 12, 2007, the SDAFW pump failed to start in circumstances that were essentially identical to those in 2005. Because this finding was of very low safety significance and has been entered into thelicensee's corrective action program as AR 258487258487 consistent with Section VI.A of the NRC

Enforcement Policy, this violation is being treated as a non-cited violation, and is designated asNCV 05000261/2007005-01, "Failure to determine the cause of a failure of the steam-driven auxiliary feedwater pump to start". 1R13Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

For the four time periods listed below, the inspectors reviewed risk assessments and relatedactivities to verify that the licensee performed adequate risk assessments and implemented appropriate risk-management actions when required by 10 CFR 50.65(a)(4). For emergent work, the inspectors also verified that any increase in risk was promptly assessed, and that appropriate risk-management actions were promptly implemented. Documents reviewed are listed in the Attachment. Those periods included the following:*November 2 - 11, including scheduled maintenance on the B motor driven auxiliary pump.

• December 3 - 7, including emergent work on the A coolant charging pump.

• December 10 - 14, including scheduled maintenance on the C service water pump andemergent work on the C component cooling water pump.*December 17 - 21, including scheduled maintenance on the B coolant charging pump, Aservice water booster pump, and calibration of pressurizer protection channels.

b. Findings

No findings of significance were identified.1R15Operability Evaluations

a. Inspection Scope

The inspectors reviewed the two operability determinations associated with the ARs listedbelow. The inspectors assessed the accuracy of the evaluations, the use and control of any necessary compensatory measures, and compliance with the Technical Specification (TS). The inspectors verified that the operability determinations were made as specified by Procedure OPS-NGGC-1305, Operability Determinations. The inspectors compared the justifications provided in the determinations to the requirements from the TS, the UFSAR, and associated design-basis documents to verify that operability was properly justified and the subject components or systems remained available, such that no unrecognized increase in risk occurred:*AR 252880, [Dedicated Shutdown Diesel Generator] ventilation fan "A" pulley and belt felloff shaft.

• AR 251953, Potential impact on meteorological tower wind measurements due to proximityof Unit 1 Fly Ash Silo.Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.1R19Post Maintenance Testing

a. Inspection Scope

For the five post-maintenance tests listed below, the inspectors witnessed the test and/orreviewed the test data to verify that test results adequately demonstrated restoration of the affected safety functions described in the UFSAR and TS. Documents reviewed are listed in the Attachment.The following tests were witnessed/reviewed:Test ProcedureTitleRelatedMaintenance ActivityDate InspectedOST-201-1[Motor DrivenAuxiliary Feedwater]

Component Test -

Train AComplete preventivemaintenance on the A motor driven auxiliary feedwater pump oil coolerOctober 4OST-910Dedicated ShutdownDiesel Generator (Monthly)Complete preventivemaintenance on the dedicated shutdown diesel October 18MST-023Safeguard RelayRack Train "B"Replace test switch forPC-951B(X2T)containment hi-hi pressure bistable November 19OST-908Component CoolingSystem Component TestReplace a seal on theC component cooling system pumpDecember 11OST-303-1Service WaterBooster Pump A TestRepair a seal leak onthe A service water booster pumpDecember 20The inspectors reviewed the following AR associated with this area to verify that the licensee

identified and implemented appropriate corrective actions:*AR 222882, post maintenance test leak check not documented for containment spray pumpB

b. Findings

No findings of significance were identified.1R22Surveillance Testing

a. Inspection Scope

For the five surveillance tests listed below, the inspectors witnessed testing and/or reviewed thetest data to verify that the systems, structures, and components involved in these tests satisfied the requirements described in the TS, the UFSAR, and applicable licensee procedures, and that the tests demonstrated that the SSCs were capable of performing their intended safety functions. Documents reviewed are listed in the Attachment.Test ProcedureTitleDate InspectedOST-352-2Containment Spray Component Test-Train BOctober 11OST-251-1*[Residual Heat Removal] Pump A andComponents Test - Train ANovember 1OST-051**Reactor Coolant System LeakageEvaluation (Every 72 Hours During Steady State Operation and Within 12 Hours of Reaching Steady State Operation)November 8OST-014[LLRT] of Personnel Air Lock DoorSeals (Within Three Days of Entry When CV Integrity is Required)November 15OST-409-2[Emergency Diesel Generator] "B"Fast Speed StartDecember 5*This procedure included inservice testing requirements.** This procedure was a Reactor Coolant System leakage detection surveillance.

b. Findings

No findings of significance were identified.

Cornerstone:

Emergency Preparedness1EP6 Drill Evaluation

a. Inspection Scope

On October 9, the inspectors observed an emergency preparedness drill to verify licensee self-assessment of classification, notification, and protective action recommendation development in accordance with 10 CFR 50, Appendix E. The inspectors also attended the post-drill critique to verify that the licensee properly identified failures in classification, notification and protective action recommendation development activities. Documents reviewed are listed in the

.

b. Findings

No findings of significance were identified.4.OTHER ACTIVITIES 4OA1Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors verified the PIs identified below. For each PI, the inspectors verified theaccuracy of the PI data that had been previously reported to the NRC by comparing those data to the actual data, as described below. The inspectors also compared the licensee's basis in reporting each data element to the PI definitions and guidance contained in NEI 99-02,

"Regulatory Assessment Indicator Guideline," Rev. 4. In addition, the inspectors interviewed licensee personnel associated with collecting, evaluating, and distributing these data.Initiating Events Cornerstone*Unplanned Scrams*Scrams with Loss of Heat Removal

• Unplanned Power ChangesFor the period from the third quarter of 2006 through the second quarter of 2007, the inspectorsreviewed a selection of licensee event reports, operator log entries, daily reports (including the daily CR descriptions), monthly operating reports, and PI data sheets to verify that the licensee had accurately identified the number of scrams and unplanned power changes greater than 20 percent that occurred during the subject period. The inspectors compared those numbers to the numbers reported by the licensee for the PI. The inspectors also reviewed the accuracy of the number of critical hours reported, and the licensee's basis for crediting normal heat removal capability for each of the reported reactor scrams.

Mitigating Systems Cornerstone*Emergency AC Power*High Pressure Safety Injection

• Cooling Water Systems

• Safety System Functional FailuresFor the Emergency AC Power, High Pressure Safety Injection, and Cooling Water Systems, theinspectors reviewed the mitigating systems performance indicators for the first time during this quarter, and therefore extended the review period from the second quarter of 2006 through the second quarter of 2007. The Safety System Functional Failures PI had been reviewed last year, so its review period extended only from the third quarter of 2006 through the second quarter of 2007. For these PIs and during these periods, the inspectors reviewed Licensee Event Reports (LERs), records of inoperable equipment, and Maintenance Rule records to verify that the licensee had accurately accounted for unavailability hours that the subject systems had experienced during the subject period. The inspectors also reviewed the number of hours those systems were required to be available and the licensee's basis for identifying unavailability hours.

b. Findings

No findings of significance were identified.4OA2Identification and Resolution of Problems.1Routine Review of ARsTo aid in the identification of repetitive equipment failures or specific human performanceissues for followup, the inspectors performed frequent screenings of items entered into the CAP. The review was accomplished by reviewing daily AR reports..2Annual Sample Review

a. Inspection Scope

The inspectors selected AR 234632234632([Leading Edge Flow Monitor] uncertainty analysis change)for detailed review. The inspectors selected this AR because it relates specifically to operator workaround 07-02, which required control room operators to continuously monitor two computer data points to verify proper operation of the higher accuracy primary heat balance calculation instrumentation. The inspectors reviewed this report to verify:*complete and accurate identification of the problem in a timely manner;*evaluation and disposition of performance issues;

• evaluation and disposition of operability and reportability issues;

• consideration of extent of condition, generic implications, common cause, and previousoccurrences;*appropriate classification and prioritization of the problem;

• identification of root and contributing causes of the problem;*identification of corrective actions which were appropriately focused to correct the problem; and*completion of corrective actions in a timely manner.The inspectors also reviewed this AR to verify compliance with the requirements of the CAP asdelineated in Procedure CAP-NGGC-0200, Corrective Action Program, and 10 CFR 50, Appendix B. Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings of significance were identified..3Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the CAP and associated documents to identify trends thatcould indicate the existence of a more significant safety issue. The inspector's review focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.1, licensee trending efforts, and licensee human performance results. The inspector's review nominally considered the six month period of June, 2007, through December, 2007, although some examples expanded beyond those dates when the scope of the trend warranted. The review included issues documented outside the normal CAP in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the latest monthly and quarterly trend reports. Corrective actions associated with a sample of the issues identified in the trend reports were reviewed for adequacy. The specific documents reviewed are listed in the Attachment.The inspectors also evaluated the trend reports against the requirements of the CAP asspecified in 10 CFR 50, Appendix B, Criterion XVI, and in Procedures CAP-NGGC-0200, Corrective Action Program, CAP-NGGC-0206, Corrective Action Program Trending and

Analysis.

b.Assessment and ObservationsNo findings of significance were identified. The inspectors evaluated trending methodology andobserved that the licensee had performed a detailed review. The licensee routinely reviewed cause codes, involved organizations, key words, and system links to identify potential trends in their CAP data. The inspectors compared the licensee process results with the results of the inspectors' daily screening, and did not identify any discrepancies or potential trends in the CAP data that the licensee had failed to identify.

OA5Other Activities.1Operation of an Independent Spent Fuel Storage Installation (ISFSI) (IP 60855.1)

a. Inspection Scope

The inspectors performed a walkdown of the two ISFSIs on site (reference dockets 72-3 and72-60). The inspectors also reviewed changes made to programs and procedures and their associated 10 CFR 72.48 screens and/or evaluations to verify that changes made were consistent with the license or Certificate of Compliance; reviewed records to verify that the licensee has recorded and maintained the location of each fuel assembly placed in the ISFSIs; and reviewed surveillance records to verify that daily surveillance requirements were performed as required by technical specifications. Documents reviewed are listed in the attachment.

b. Findings

No findings of significance were identified..2(Closed) URI 05000261/2007003-01, Work Affecting Emergency Core Cooling Sump Piping inthe Absence of Foreign Material Exclusion ControlsIn inspection report 2007003, this issue had been identified for a failure to follow procedures,which resulted in the introduction of foreign material into piping between the emergency core cooling system (ECCS) reactor building sump and residual heat removal pumps A and B. This issue had been designated as an unresolved item pending further investigation to determine whether and to what extent the subject debris could affect safety functions during a postulated event that includes recirculation flow from the ECCS sump.During the current inspection period, the licensee conducted full-scale tests to address thisissue, and documented results from those tests in Engineering Change 68283, Testing and Analysis of [Robinson Nuclear Plant] Residual Heat Removal Pump Debris Tolerance. The inspectors observed those tests to verify that the tests replicated the system components and system configuration that existed in the plant, that debris used in the tests was similar to that found in the ECCS piping, and that test flow rates were similar to those that would have occurred during accident sequences that required water to flow through the piping where the debris was found. The inspectors also reviewed results from those tests and associated analyses to verify that test results were accurately recorded, and that the analyses were consistent with test details. In addition, the inspectors evaluated test and analysis results to determine whether and how the debris could have affected either an RHR pump or a downstream ECCS component. The inspectors concluded that although the debris could have been entrained in the flow, it would not have credibly produced any effect that would have prevented either the RHR pumps or a downstream ECCS component from performing their safety functions. This URI is therefore closed. However, these circumstances include a licensee-identified violation. That violation is described below in section 4OA7.2.

OA6 Meetings, Including ExitOn January 3, 2008, the resident inspectors presented the inspection results to Mr. Tom Waltand other members of his staff.

The inspectors confirmed that proprietary information had not been provided or examined during the inspection.4OA7 Licensee-Identified ViolationsThe following violations of very low safety significance (Green) were identified by the licenseeand are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a Non-Cited Violations (NCV)..1Unplanned Equipment Out of Service Orange RiskOn October 17, the licensee discovered that an inadequate risk evaluation had been performedon October 4 for maintenance that affected the A motor-driven auxiliary feedwater pump and its flow control valve. The licensee had initially determined that the plant configuration required for that maintenance would constitute a Yellow risk condition, based on recognizing that they expected to remove from service both the pump and its flowpath to the A steam generator.

However, to establish the required clearance boundaries, the licensee actually removed from service not only the pump and its flowpath to the A steam generator, but also the flowpath from the pump to the B steam generator. The licensee subsequently determined that the resulting plant configuration (with a motor-driven auxiliary feedwater pump and two injection paths out of service) had constituted an Orange Risk condition, and that they had not recognized that at the time.10 CFR 50.65 (a)(4) requires, in part, that before performing maintenance activities, thelicensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The inspectors determined that the circumstances described above constituted a violation of 10 CFR 50.65 (a)(4) because in those circumstances, the licensee failed to assess and manage the increase in risk that resulted from the maintenance activities.

In accordance with Manual Chapter 0612, Appendix B, this violation was more than minor because the licensee risk assessment failed to consider components of the auxiliary feedwater system that were unavailable during maintenance. Because this finding related to managing and assessing maintenance risk, the inspectors assessed its significance as described in NRC Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. The incremental core damage probability deficit for this condition was determined not to exceed 1.0E-6 and therefore screened as a "Green Finding" utilizing Flowchart 1 of Appendix K. This violation is in the CAP as AR 251128251128.2Work Affecting Emergency Core Cooling Sump Piping in the Absence of Foreign MaterialExclusion ControlsOn April 2, 2007, in response to NRC Information Notice 2006-20, "Foreign Material Found inthe Emergency Core Cooling System," and in conjunction with licensee actions to resolve Generic Safety Issue 191, "Assessment of Debris Accumulation on PWR Sump Performance,"

the licensee used a remote video camera to visually inspect the two suction lines between the

emergency core cooling system (ECCS) sump and residual heat removal (RHR) pumps A andB. Inspection of the first line revealed a piece of wire approximately 30 inches long, and inspection of the second line revealed a stainless steel insulation band and other smaller items of metallic debris. The licensee's investigation of this event is documented in the significant adverse condition investigation report associated with AR 230613230613 That report states that the sump piping had previously been opened during refueling outage 18 (in 1998), when work was performed under Work Request/Job Order (WR/JO) 97-AEUU4, an instruction that, in part, directed workers to establish a foreign material exclusion area (FMEA) prior to removing the screens which separated the ECCS sump from its associated piping. The report further states that contrary to the instruction in that WR/JO, workers had performed work in the ECCS sump on March 8, 1998, before they established foreign-material exclusion controls on March 9, 1998.The circumstances described above constitute a violation of 10 CFR 50, Appendix B, CriterionV, which requires, in part, that activities affecting quality be conducted in accordance with documented instructions of a type appropriate to the circumstances. Work conducted on the ECCS sumps during refueling outage 18 was an activity affecting quality and Work Request/Job Order (WR/JO) 97-AEUU4 was an instruction of a type appropriate to the circumstances of completing that work. Contrary to the above and during refueling outage 18, workers performed work in the ECCS sump before they established foreign-material exclusion controls. This finding is more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone, in that foreign material in the ECCS sump suction lines degraded the performance of systems that respond to initiating events to prevent core damage. Using the Phase 1 worksheet in Manual Chapter 0609, Appendix A, this finding was determined to have very low safety significance because it was not a design or qualification deficiency and did not represent the actual loss of a safety function. This issue is in the licensee's CAP as AR 230613230613 Attachment: Supplemental Information

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

C. Baucom, Manager, Support Services - Nuclear

B. Clark, Training Manager

W. Farmer, Engineering Manager

J. Huegel, Maintenance Manager

E. Kapopoulos, Plant General Manager

J. Lucas, Nuclear Assurance Manager

J. Rhodes, Radiation Protection Superintendent

T. Tovar, Operations Manager

T. Walt, Vice President

S. Wheeler, Supervisor, Regulatory Support

NRC personnel

R. Musser, Chief, Reactor Projects Branch 4

A-2Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

OpenedNoneClosed05000261/2007003-01URIWork Affecting Emergency Core Cooling Sump Pipingin the Absence of Foreign Material Exclusion ControlsOpened &

Closed

05000261/FIN-2007005-01NCVFailure to Determine the Cause of a Failure of theSteam-Driven Auxiliary Feedwater Pump to StartPrevious Items ClosedNoneDiscussedNone

A-3Attachment

LIST OF DOCUMENTS REVIEWED

1R01Adverse Weather ProtectionProceduresAP-008, Cold Weather Preparations, Rev. 15AP-015, Portable Heaters/Heating Devices, Rev. 13

PM-076, Electric Unit Heaters and Steam Unit Heaters, Rev. 7

EDP-009, Freeze Protection Panels, Rev. 30

OP-925, Cold Weather Operation, Rev. 381R04Equipment AlignmentSteam Driven Auxiliary Feedwater trainOWP-001, Auxiliary Feedwater, Rev. 43Drawing G-190197, Feedwater Condensate and Air Evacuation System Flow Diagram, Sheet 1 of 4,Rev. 77Drawing G-190197, Feedwater Condensate and Air Evacuation System Flow Diagram, Sheet 4 of 4,Rev. 55B Service Water Booster Pump trainOWP-017, Service Water, Rev. 52Drawing G-190199, Service & Cooling Water System Flow Diagram, Sheet 7 of 15, Rev. 38B Instrument Air Compressor trainOP-905, Instrument and Station Air System, Rev. 97Drawing G-190200, Instrument and Station Air System Flow Diagram, Sheet 2 of 10, Rev. 331R05Fire ProtectionSections of UFSAR Appendix 9.5.1A3.1.5.5, Fire Zone 20 - Emergency Switchgear Room and Electrical Equipment Area3.7.8, Fire Zone 26 - Yard Transformers

3.1.3.1 - Fire Zone 7 - Auxiliary Building Hallway (Ground Floor)

3.1.1 - Fire Zone 1 - Diesel Generator "B" Room

3.10.7 - Fire Zone 31 - Refueling Water Storage Tank

3.10.8 - Fire Zone 32 - Primary Water Storage Tank

3.8.1 - Fire Zone 30 - Diesel Oil Storage Tank

3.7.6 - Fire Zone 25F - Turbine Building West Mezzanine

3.7.7 - Fire Zone 25G - Turbine Building Operating DeckProcedures; results from the following completed testsOST-602, Unit 2 Fire Water System Flowpath Verification (Monthly) and Valve Cycling (Annually), Rev.43, 9/30/07OST-610, Unit 2 Portable Fire Extinguishers, Fire Hose Stations and Houses (Monthly), Rev. 47,10/13/07

A-4AttachmentOST-611-1, Low Voltage Fire Detection and Actuation System Zone 1& 2 (Simi-Annual), Rev. 6, dated8/28/07OST-611-11, Low Voltage Fire Detection and Actuation System Zones 19 & 20 (Semi-Annual), Rev. 5,dated 6/10/07OST-611-6, Low Voltage Fire Detection and Actuation System Zone 11 & 13 (Semi-Annual), Rev. 5,dated 6/30/07OST-611-7, Low Voltage Fire Detection and Actuation System Zone 12 (Semi-Annual), Rev. 3, dated6/9/07OST-620, Carbon Dioxide Suppression System Weight Test (Semi-Annual), Rev. 24, dated 7/25/07

OST-621, Diesel Generator CO2 System Cylinder Weight Test (Semi-Annual), Rev. 23, dated 9/15/07

OST-624, Fire Damper Inspection (18-Month), Rev. 21, dated 6/3/07

OST-627, Function Test of the Emergency Diesel Generator CO2 Cardox Suppression System(Annual), Rev. 29, dated 1/29/07OST-628, Function Test of the Halon 1301 System (Annual), Rev 21, dated 9/5/06

OST-630, Halon 1301 Suppression System Weight Test (Semi-Annual), Rev. 28, dated 7/24/07 and7/25/07OST-642, Main Transformer Deluge System Flow Test (Annually), Rev 16, dated 4/18/07 and 4/22/07

OST-643, Startup/Auxiliary Transformer Deluge System Flow Test (Annually), Rev. 19, dated 6/5/07

OST-645, Turbine Lube Oil Deluge System Flow Test, Rev. 17, 6/4/07Other documentsWork Order

1052259, Water motor gong did not sound during

OST-642Work Order

1075883, Water motor gong did not sound during

OST-643

1R11Licensed Operator RequalificationTAP-409, Conduct of Simulator Training and Evaluation, Rev. 19LOCT 04-5, Full Scope Scenario, Rev. 11R12Maintenance EffectivenessAction Requests165893, Steam-driven [auxiliary feedwater] pump trip222904, Extended [limiting condition for operation] time for R-11/12 due to

RMS-2 failure

23595, Potential rework of

RMS-2 solenoid EV-1726

2583, Unplanned unavailability of the [steam driven auxiliary feedwater] pumpProceduresResults from

OST-701-11, Radiation Monitoring Inservice Valve Test, Rev. 8, dated 2/19/07

Maintenance Rule DocumentsFor system 7005 Radiation Monitoring:*Event list for previous 18 months

• Scoping and Performance Criteria For system 3065, auxiliary feedwater system

• Event list for previous 18 months

• Scoping and Performance Criteria

A-5Attachment*Performance SummaryOther Documents[Engineering Disposition] 67723, [steam driven auxiliary feedwater] pump trip on low dischargepressureShift operating logs, 8/10/2007- 8/13/2007

[Engineering Change] 61907, [steam driven auxiliary feedwater pump] maintenance documentation1R13Maintenance Risk Assessments and Emergent Work EvaluationProcedures

OMM-048, Work Coordination and Risk Assessment, Rev. 30

ADM-NGGC-0006, Online [Equipment out of Service] Models For Risk Assessment, Rev. 5

OMM-001-2, Shift Routines and Operating Practices, Rev. 51 1R15Operability EvaluationsAR

252880, [Dedicated Shutdown Diesel Generator] ventilation fan "A" pulley and belt fell off shaftProcedure

OP-602, Dedicated Shutdown System, Rev. 45

Control-room operator logs, 10/31/2007 - 11/01/2007

Engineering Service Request

9800435, [Dedicated Shutdown Diesel Generator] Intake Damper FailureMode Evaluation, Rev. 0Engineering Service Request

9400556, [Dedicated Shutdown Diesel Generator] [Heating, Ventilation,and Air Conditioning], Rev. 0Condition Report 98-01115, Damper actuators on the Dedicated Shutdown Diesel Generator were notfunctioning on demand by the control circuitAR

251953, Potential impact on meteorological tower wind measurements due to proximity of Unit 1Fly Ash SiloUFSAR section 2.3.2 - Local Meteorology

UFSAR section 1.8 - Conformance to NRC Regulatory Guides1R19Post Maintenance TestingMST-023, Safeguard Relay Rack Train "B", Rev. 18OST-201-1, [Motor Driven Auxiliary Feedwater] Component Test - Train A, Rev. 26

OST-303-1, Service Water Booster Pump A Test, Rev. 5

OST-908, Component Cooling System Component Test, Rev. 64

OST-910, Dedicated Shutdown Diesel Generator (Monthly), Rev. 42

OWP-015, Reactor Protection and Safeguards RPS, Rev. 22

PLP-033, Post-Maintenance Testing Program, Rev. 39

Work Order

1123464-04,

PC-951B(X2T) test switch #9 train B; check voltage and replace1R22Surveillance TestingProceduresOST-051, Reactor Coolant System Leakage Evaluation (Every 72 Hours During Steady StateOperations and Within 12 Hours of Reaching Steady State Operation), Rev. 38

A-6AttachmentOST-251-1, [Residual Heat Removal] Pump A and Components Test - Train A, Rev. 19OST-352-2, Containment Spray Component Test- Train B, Rev. 29

OST-014, [Local Leak Rate Test] of Personnel Air Lock Door Seals (Within Three Days of Entry When[Containment Vessel] Integrity is Required), Rev. 13OST-409-2, [Emergency Diesel Generator] "B" Fast Speed Start, Rev. 341EP6 Drill EvaluationEmergency Response Organization Exercise, October 9, 2007Emergency Operating Procedure logic diagram

PATH-1, Rev. 18

Emergency Action Level diagram

EAL-1, Rev. 15

Emergency Action Level diagram

EAL-2, Rev. 20

NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 54OA1Performance Indicator VerificationCalculation

RNP-F-PSA-0057, NRC Mitigating System Performance Index (MSPI) Basis Document,Rev. 4Procedure

REG-NGGC-0009, NRC Performance Indicators and Monthly Operating Report Data, Rev.7Procedure

ADM-NGGC-0101, Maintenance Rule Program, Rev. 20

Licensee Event Report 2007-001-00, Reactor Trip Due to a Loose Wire in the Main TransformerMonitoring CircuitryMaintenance Rule event reports that cover the previous 18 months, for the following systems:1000 (Containment Isolation Valve)

1080 (Reactor Protection)

2005 (Reactor Coolant)

2045 (Residual Heat Removal)

2060 (Chemical and Volume Control)

2080 (Safety Injection)

2116 (Post Accident Monitoring)

4060 (Service Water System)

4080 (Component Cooling Water)

5095 (Emergency Diesel Generator)

235 (Electrical - [Direct Current] System)

6135 (Instrument Air)

6140 (Station Air)

7105 (Spent Fuel)

20 ([Heating, Ventilation, and Air Conditioning] - Control Room Area4OA2Identification and Resolution of ProblemsAction RequestsAR

234632 [Leading Edge Flow Monitor] uncertainty analysis change ProceduresCAP-NGGC-0200, Corrective Action Program, Rev. 19

A-7AttachmentCAP-NGGC-0206, Corrective Action Program Trending and Analysis, Rev. 2OMM-001-8, Control of Equipment and System Status, Rev. 37

Corrective Action Program Trend ReportsSite-Wide Analysis of Condition Reports for Performance Trends, July 1 - September 30, 2007

[Environmental & Chemistry] and [Radiation Control] CAP Rollup & Trend Analysis September 2007

Maintenance CAP Rollup & Trend Analysis, September 2007

Operations CAP Rollup & Trend Analysis, September 2007

Outage & Scheduling CAP Rollup & Trend Analysis, September 2007

Plant Support Group CAP Rollup & Trend Analysis, May, June, July, August, and September 20074OA5Other Activities.1

Independent Spent Fuel Storage InstallationProceduresOST-021, Daily Surveillance, Rev. 20FMP-004, Special Nuclear Material (SNM) Inventory, Rev. 22

REG-NGGC-0010, 10

CFR 50.59 and Selected Regulatory Reviews, Rev. 10

NGGM-PM-0028, Transnuclear NUHOMS Dry Fuel Storage Program Manual, Rev. 0

OM-NUH24PTH-118, NUHOMS System Operations Manual, Rev. 0

AOP-028, [Independent Spent Fuel Storage Installation] Abnormal Events, Rev. 6Other DocumentsCertificate of Compliance No. 1004, Standardized NUHOMS Horizontal Modular Storage System

.2

Work Affecting Emergency Core Cooling Sump Piping in the Absence of Foreign Material ExclusionControlsSections of Engineering Change 68283, ECCS Recirculation Debris Impact Assessment,

R.0Attachment A, Testing and Analysis of RNP Residual Heat Removal Pump Debris ToleranceAppendix A, Flowserve Analytical Report Appendix B, Test Specification Appendix C, Test Loop Description Appendix D, Wyle Labs Test Plan Appendix E-1, Initial and Final Test Article Inspection Results Appendix E-2, Initial Test Article Hydraulic Performance Test Appendix E-3, Debris Test Documentation and Results Appendix E-4, Motor Monitoring During Debris Testing Appendix E-5, Vibration Measurements during Debris Testing Appendix E-6, Final Test Article Hydraulic Performance Test Appendix E-7, RNP Analytical Evaluation of RHR Debris Transport Velocity Appendix E-8, RHR Pump Test Statistical Analysis Results Appendix E-9, Description of Debris used during Debris Testing Appendix E-10, IST Hydraulic Performance Evaluation of RHR Pump Performance and Correlation ofWyle Laboratory Results to RNP Test Data

A-8AttachmentOther DocumentsAR

230613, Assignment 16, ECCS Emergency Sump Debris Past Operability DeterminationDBD/R87038/SD0, Design Basis Document - Safety Injection System4OA7Licensee-identified ViolationsAR

251128, Unplanned Equipment Out of Service Orange RiskAR

230613, Foreign material found in Emergency Core Cooling System