IR 05000261/2022011
| ML22199A244 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/19/2022 |
| From: | David Dumbacher NRC/RGN-II/DRP/RPB3 |
| To: | Flippin N Duke Energy Progress |
| Hamman J | |
| References | |
| IR 2022011 | |
| Download: ML22199A244 (19) | |
Text
July 19, 2022
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000261/2022011
Dear Ms. Flippin:
On June 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your H.B. Robinson Steam Electric Plant. On June 29, 2022, 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.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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 violations or the significance or severity of the violations 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.
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:
Report Number:
Enterprise Identifier:
I-2022-011-0033
Licensee:
Duke Energy Progress, LLC
Facility:
H.B. Robinson Steam Electric Plant
Location:
Hartsville, SC
Inspection Dates:
May 30, 2022 to June 27, 2022
Inspectors:
J. Dolecki, Senior Resident Inspector
V. Gaffney, Resident Inspector
J. Hamman, Senior Project Engineer
D. Parent, Project Engineer
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 a biennial problem identification and resolution 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. A licensee-identified non-cited violation is documented in report section: 71152
List of Findings and Violations
Boric Acid Leak on Reactor Coolant Pump (RCP) Main Flange due to Inadequate Control of Measuring and Test Equipment (M&TE)
Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2022011-01 Open/Closed None (NPP)71152B A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specifications (TS) 5.4.1.a, Procedures, was identified when the licensee (Duke) failed to establish and implement procedures to control M&TE appropriate to the circumstances.
Specifically, the licensee failed to properly control, calibrate, and adjust M&TE used to measure the reactor coolant pump (RCP) main flange stud length stretch via a datum rod to maintain accuracy. As a result, on October 24, 2022, a boric acid leak was identified on the 'B'
RCP main flange due to relaxing of the studs and the corresponding loss of preloading to the RCP casing joint.
Failure to Establish Preventive Maintenance (PM) Activities that can Affect Safety-Related Equipment at Recommended Frequency Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2022011-02 Open/Closed
[P.1] -
Identification 71152B The inspectors identified a Green finding and associated NCV of TS 5.4.1(a), Procedures, when Duke failed to establish written procedures for PM activities that can affect the performance of safety-related equipment at recommended specified frequencies. Specifically,
Duke failed to establish a PM procedure to replace the RCPs seal injection filter at the recommended specified frequency stated in the applicable vendor manual. As a result, on October 18, 2021, operators shutdown Unit 2 in accordance with an abnormal operating procedure (AOP) due to A RCP seal leak caused by inadequate filtration through seal injection.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of beyond-design basis systems, structures, and components (SSCs), emergency diesel generators, auxiliary feedwater system, component cooling water system, reactor protection system, and safety-related AC power.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Boric Acid Leak on Reactor Coolant Pump (RCP) Main Flange due to Inadequate Control of Measuring and Test Equipment (M&TE)
Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2022011-01 None (NPP)71152B Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specifications (TS) 5.4.1.a, Procedures, was identified when the licensee (Duke) failed to establish and implement procedures to control M&TE appropriate to the circumstances.
Specifically, the licensee failed to properly control, calibrate, and adjust M&TE used to measure the reactor coolant pump (RCP) main flange stud length stretch via a datum rod to maintain accuracy. As a result, on October 24, 2022, a boric acid leak was identified on the
'B' RCP main flange due to relaxing of the studs and the corresponding loss of preloading to the RCP casing joint.
Description:
RCPs provide forced RCS flow to remove and transfer heat generated in the reactor core. The RCP components and the associated joints are to be installed such that the RCP performs reliably, and the RCS remains intact (barrier integrity), to limit the potential for a loss of RCS inventory. Component joints are made by welding, bolting, rolling, or pressure loading. As such, maintaining these joints due to normal operational wear or mechanical deterioration is essential. Duke uses maintenance work procedures PM-453, Reactor Coolant Pump Main Flange Stud Stretch Measurements and Stud Retention Procedure, and CM-013, Reactor Coolant Pump, Disassembly and Reassembly of Pump to ensure adequate installation and maintenance of the RCP to, in part, prevent RCS leakage.
Specifically, in the case of the RCP main flange studs, these procedures are used to ensure each of the 24 studs are appropriately measured and stretched to crush the gasket and provide a full metal-to-metal contact at the main flange joint, thus preventing leakage at the joint. The main flange stud stretch is determined by comparing the length of a stretched stud to its unstretched baseline value, with a datum rod serving as the measuring device. As such, if a change occurs to either a stud or datum rod then a new baseline measurement must be made.
On October 24, 2022, while Unit 2 was in Mode 5 (cold shutdown) for a forced outage to address the degraded A RCP #2 seal, Duke operators identified an unexpected and significant quantity of boric acid (approximately 10-30 gallons) on the B RCP main flange area. Duke subsequently removed the boric acid and identified material loss on five out of the 24 B RCP main flange studs. As a result, the leak from the RCS cleanup and associated repair extended the duration of the reactor shutdown.
Duke performed a root cause evaluation (RCE) which determined the root cause to be inadequate control and documentation of the datum rod length used to measure main flange stud length stretch. In other words, Duke determined that the M&TE used to measure whether the RCP main flange was adequately sealing to prevent RCS leakage was not being controlled and calibrated effectively. Duke stated that since stud length stretch measurements were introduced in 1995 there has been no controls in place to ensure the M&TE datum rod length was properly calibrated and controlled.
Based on the information above, inspectors concluded the established instructions for controlling the M&TE used to measure RCP stud length stretch were not commensurate to the risk significance of ensuring an adequate RCP main flange joint seal to prevent a boric acid leak and corresponding material loss to impacted components.
Corrective Actions: Following the identification of boric acid accumulation on the B RCP main flange area, Duke cleaned the area and identified five degraded RCP studs caused by the leak. These degraded studs were replaced, and all studs were re-stretched and re-baselined to the procedurally specified range. Duke performed a visual inspection and took photos of the A and C RCPs as part of an extent of condition and did not identify boric acid deposits. Duke generated nuclear condition report (NCR) 02402785 to perform a RCE and initiate corrective actions. NCR 02402785 corrective actions included initiating a revision to maintenance procedures PM-453 and CM-013 PM to ensure the datum rod length is measured and recorded prior to each performance. Additionally, Duke
- (2) installed temporary covers on the A and B RCP main flange studs as defense-in-depth to mitigate boric acid corrosion, and
- (3) established an adverse condition monitoring plan (ACMP) to monitor RCS unidentified leakage, containment atmospheric tritium, and boric acid deposit color.
Duke generated NCR 02433015 to document this violation.
Corrective Action References: NCRs 02402785 and 02433015
Performance Assessment:
Performance Deficiency: Inspectors determined the failure to establish written procedures to control the M&TE that measures RCP main flange stud length stretch was a performance deficiency because it was reasonably within the licensees ability to foresee and correct and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to establish a work instruction for M&TE to accurately measure RCP stud length stretch did not limit the likelihood of an event and challenged the critical safety function of maintaining the RCS intact. This performance deficiency was compared to examples within IMC 0612, Appendix E, "Examples of Minor Violations," effective January 1, 2021, and determined example 4.c to have similarities.
Specifically, because of inadequate measurement, the licensee did not identify that RCP main flange stud stretch data was inadequate to maintain a seal and, as a result, prevent boric acid leakage and associated material loss caused by the boric acid.
Significance: The inspectors assessed the significance of the finding using Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the inspectors utilized IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions. Inspectors determined the finding was of very low safety significance (Green) because, after a reasonable assessment of degradation, the finding did not result in exceeding the RCS leak rate for a small LOCA (leakage in excess of normal makeup) or have likely affected other systems used to mitigate a LOCA (e.g., Interfacing System LOCA).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Duke TS for the Robinson nuclear plant 5.4.1.a, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in regulatory guide (RG) 1.33, Revision 2, Appendix A. RG 1.33, Appendix A, Section 8.a states, in part, that procedures of a type appropriate to the circumstances should be provided to ensure that tools, gauges, instruments, controls, and other M&TE devices are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy. The licensee established M&TE, including a datum rod, for work activities on the RCP within procedures PM-453 and CM-013 to, in part, meet this requirement.
Contrary to the above, from approximately 1995 to 2021, maintenance work procedures PM-453 and CM-013 on the RCP main flange, which forms the safety-related RCS boundary for barrier integrity, did not provide controls of the M&TE to ensure the RCP main flange stud length stretch was measured accurately and the main flange was sealed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Establish Preventive Maintenance (PM) Activities that can Affect Safety-Related Equipment at Recommended Frequency Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000261/2022011-02 Open/Closed
[P.1] -
Identification 71152B The inspectors identified a Green finding and associated NCV of TS 5.4.1(a), Procedures, when Duke failed to establish written procedures for PM activities that can affect the performance of safety-related equipment at recommended specified frequencies. Specifically, Duke failed to establish a PM procedure to replace the RCPs seal injection filter at the recommended specified frequency stated in the applicable vendor manual. As a result, on October 18, 2021, operators shutdown Unit 2 in accordance with an abnormal operating procedure (AOP) due to A RCP seal leak caused by inadequate filtration through seal injection.
Description:
RCPs provide forced RCS flow to remove and transfer heat generated in the reactor core. RCP seals are relied upon to maintain the RCS intact (barrier integrity), to limit the potential for a loss of RCS inventory. Each of Robinson Unit 2s 3 RCPs contain three seals which, during normal operation, operators observe about 3.0 gallons-per-minute (gpm)
- 1 seal leakage and less than 0.01-0.03 gpm #2 seal leakage. The RCP seal injection system is designed to cool the RCP components and maintain RCS barrier integrity. The RCP seal injection supply lines have two parallel filters (SLW-INJ-FLT-A and -B) with one normally in-service to ensure particulates are removed so they do not affect the performance of the RCP components, including the seals. Up until Fall 2021, Duke was replacing these filters using a condition-based (pressure drop) strategy.
From September 3 to October 18, 2021, Duke operators identified and responded to elevated A RCP #2 seal leakage. Specifically, while performing the daily RCS leakage test required by TS 3.4.13, operators identified and monitored elevated RCP #2 seal leak through a rate of change within the reactor coolant discharge tank (RCDT). Duke generated an adverse condition monitoring plan (ACMP) and an operational decision-making (ODM) document to monitor and establish continency actions to respond to increasing identified leakage. With the
- 2 seal degraded, as stated in the ODM, the ability to effectively monitor the RCS barrier integrity performance of the #1 seal via the safety-related leak-off flow indications are impacted and would introduce additional operator actions to process radwaste from the RCDT and to makeup to the RCS. As such, when the licensee-established threshold of 1.1 gpm stated in AOP-018, Reactor Coolant Pump Abnormal Condition, the ODM, and in alignment with the original equipment manufacturer recommendation, operators commenced shutdown and were offline October 18, 2021 at 18:18.
Duke performed a RCE which determined the RCP #2 seal failed due to particulate material deposition on and behind a component within the #2 seal, the double delta channel seal (DDCS). Duke determined the mostly likely cause is inadequate PM strategy on the seal injection filters. Specifically, Duke determined the established PM strategy to replace the RCPs seal injection supply lines filters (SLW-INJ-FLT-A and -B) on the condition-based strategy (i.e., when pressure drop across the filter is about 20 PSID) in accordance with CM-502, Filter Cartridge Maintenance, was not adequate in ensuring the reliability of the filters and corresponding seal injection portion of the RCP.
RG 1.33, Revision 2, Appendix A, Sections 9.a and 9.b state, in part, that maintenance activities that can affect the performance of safety-related equipment, including the replacement of filters, should be properly pre-planned and performed in accordance with written procedures appropriate to the circumstances. Dukes maintenance procedure CM-502, Filter Cartridge Maintenance, and associated work orders were established to, in part, meet this requirement for the RCP seal injection system. Specifically, Duke uses CM-502 to perform maintenance activities on the RCP seal injection system to ensure the RCS fluid is clear of foreign materials in order to maintain and monitor the performance of RCPs and the corresponding safety-related RC barrier integrity.
Duke uses AD-EG-ALL-1202, Preventive Maintenance and Surveillance Testing Administration, to plan and revise PM tasks and frequencies, such as those established in maintenance procedure CM-502. AD-EG-ALL-1202 directs the use of the vendor manuals, PM templates, and operating experiences to develop and maintain a maintenance strategy, including specific tasks and frequencies recommended to ensure equipment reliability. The licensee considers the RCPs as critical components because their failure can result in a reactor trip or power changes greater than 20%; therefore, these components are to have the highest reliability goal and PM strategies. The inspectors noted Duke did not have a plant-specific PM template for RCPs and instead rely on vendor manual information.
Inspectors determined that the seal injection filters, which can affect the performance of safety-related RCS barrier integrity and the corresponding RCP seal #1 performance monitoring, were installed for longer than recommended by the vendor manual without an accompanying plant-specific technical basis. The degraded filter was installed for approximately 8.3 years (from May 2013 to October 2021) instead of being replaced in accordance with the controlled vendor manuals recommended time-based frequency of each refueling outage (e.g., every 18-24 months). Further, the inspectors determined the licensees RCE failed to recognize the vendor manual included this recommendation and, as a result, previously consider it for inclusion in the PM strategy.
Based on the information above, the inspectors determined the maintenance strategy for the RCPs seal injection filters to be inadequate because it was not effective in maintaining the performance and monitoring of the RCP seals and limiting the likelihood of an initiating event.
Corrective Actions: Duke generated NCR 02396736 to document elevated identified leakage to the RCDT, which was later determined to be caused by the A RCP #2 seal. NCR 02396736 also captures the ACMP and ODM. The AOP-018 entry at 0.5 gpm was captured in NCR 02399406. Following the #2 seal leakage exceeding 1.1 gpm, AOP-018 directed operators to shut down the reactor. Once shutdown, Duke replaced the #2 seal and sent it out for further investigation. The filter cartridge was not investigated due to radiological dose.
Duke generated NCR 02402792 to perform a causal analysis (root cause evaluation) and initiate corrective actions. NCR 02402792 corrective actions included initiating a revision to the PM strategy to include time-based RCP seal injection filter replacement. Additionally, Duke has scheduled to replace the #2 seals for B and C RCPs (work orders 20491980 and 20491981).
Duke generated NCR 02433017 to capture this violation.
Corrective Action References: NCRs 02396736, 02399406, and 02402792
Performance Assessment:
Performance Deficiency: The inspectors identified that Dukes failure to establish written maintenance procedures that can affect the performance of safety-related equipment at the vendor manuals recommended specified frequency was a performance deficiency because it was reasonably within the licensee's ability to foresee and correct 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 Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, inadequate maintenance procedures resulted in exceeding a licensee established AOP limit and resulted in operators performing a reactor shutdown. The performance deficiency was evaluated against IMC 0612, Appendix E, Examples of Minor Issues," effective January 1, 2021. The inspectors determined this conclusion to be similar to examples 4.b and 13.a because the licensees failure to translate vendor manual filter replacement schedules into maintenance procedures caused a transient or initiating event.
The licensee failed to perform an engineering analysis to justify a deviation from the vendor manual recommended actions.
Significance: The inspectors assessed the significance of the finding using Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, the inspectors utilized IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions. Inspectors determined the finding was of very low safety significance (Green) because the finding did not cause a reactor trip AND the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Duke failed to identify the controlled vendor manual included a recommended RCP seal injection filter replacement frequency strategy and consider its inclusion into their PM strategies.
Enforcement:
Violation: Duke TS for the Robinson nuclear plant 5.4.1(a), Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in RG 1.33, Appendix A. RG 1.33, Revision 2, Appendix A, Section 9.a states, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. RG 1.33, Appendix A, Section 9.b states, in part, that preventive maintenance schedules should be developed to specify inspection or replacement of parts that have a specific lifetime. The licensee established procedure CM-502 and work orders to, in part, meet this regulatory requirement.
Contrary to the above, until the forced outage in October 2021, Duke failed to properly pre-plan and implement procedures for maintenance activities that can affect the performance of safety-related equipment at the vendor manual recommended specified frequency.
Specifically, Duke failed to properly pre-plan the performance of RCP seal injection filter replacements at the vendor manual recommended replacement frequency such that the monitoring capability of the #1 seal leakage was maintained, enabling the operators to verify the safety function of the RCS barrier integrity.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71152B This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: 10 CFR 50, Appendix B, Criterion XV, states, in part, that measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. The licensee identified two examples in which they failed to prevent deficient or non-conforming parts from being installed in the plant. First, as stated in NCR 02428690, the relays that provide the under-voltage protection schematic for E1/E2 bus must be qualified as PQL-1 (Safety-Related). Contrary to the above, in 2015 and 2017, PQL-3 (augmented quality) relays were installed in these safety-related applications. This condition was identified by the licensee during planning for the Fall 2022 refueling outage relay replacement work orders. As part of their corrective actions, the licensee updated and scheduled the Fall 2022 refueling outage work orders with the appropriate, conforming PQL-1 (safety-related) relays. Second, as stated in NCR 02369694, in 2015, the licensee identified that a 10 CFR Part 21 hold on specific A200 contactors/starters that are continuously energized was required. A200 contactors/starters are used in motor control centers to ensure power is provided to various loads. Contrary to the above, in 2016, the 10 CFR Part 21 hold was removed which subsequently permitted four A200 contactors/starters to be installed in the plant, two of them in continuously energized applications, where the Part 21 applies. In 2019, during a test of one of the contactors/starters, the issue with the A200 contactors/starters was revealed when the components failed to open when power was removed. As part of the corrective actions, the licensee reinstated the 10 CFR Part 21 hold to the A200 contactors/starters and scheduled work orders to replace the affected contactors/starters in the field.
Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609 Appendix A, Significance Determination Process for Findings At-Power. The performance deficiency was associated to the mitigating systems cornerstone. The issue was compared to examples on IMC 0612 Appendix E, example 5.c and it was determined to be more than minor because incorrect parts were installed in the field and, in the case of the contactors/starters component, a failure occurred.
Corrective Action References: Duke generated NCR 02433019 to document this violation.
Minor Violation 71152B Minor Violation: Inspectors identified multiple instances in which the licensee failed to consider a situation, circumstance, action, or incident as a condition adverse to quality (CAQ).
Two examples are documented in this report. First, as documented in NCR 02402792, the licensee categorized the A RCP seal #2 degradation, which ultimately led to the shutdown of Unit 2, as not a CAQ because the #2 seal is non-safety related. Inspectors determined this issue should have screened to a CAQ and put in the CAP. Specifically, inspectors determined this issue was consistent with AD-PI-ALL-0100, example 2.2.2 of what is a CAQ of because this condition has the potential to inhibit or has inhibited the performance of the safety-related RCP #1 seal leak off indications. Second, as documented in NCR 02429788, the licensee categorized the failure of the containment temperature reference junction, CVY9073A, as not a CAQ because it is a non-safety-related instrument and other methods are available to measure containment temperature. The inspectors determined this issue should have been screened to a CAQ and put in the CAP. Specifically, inspectors determined this issue met the definition of a CAQ within AD-PI-ALL-0100 because this instrument is used to satisfy TS surveillance requirement 3.6.5.1 (verify containment average air temperature is within limits);therefore, the instrument affects activities subject to TSs.
Robinson generated NCR 02433020 to document this violation.
Screening: The inspectors determined the performance deficiency was minor. 10 CFR 50 Appendix B, Criterion XVI, "Corrective Actions," states, in part, that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are to be promptly identified. Duke uses AD-PI-ALL-0100, Corrective Action Program, to, in part, meet this requirement. Contrary to this, in multiple examples from 2020 to 2022, the licensee failed to promptly identify equipment deficiencies as CAQs.
Based on a review of the items discussed above, the inspectors did not identify a performance deficiency of more than minor significance because a cornerstone objective was not impacted. Inspectors determined that in these instances the failure to identify CAQ did not result in a failure to promptly correct the condition.
Enforcement:
This failure to comply with 10 CFR 50, Appendix B, Criterion XVI constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Weakness in Identifying CAQs 71152B In the area of problem identification, the team identified a weakness in screening NCRs as CAQs. Specifically, the inspectors identified two examples, as shown below, in which the licensee failed to promptly identify a CAQ in accordance with AD-PI-ALL-0100, "Corrective Action Program." The disposition of this issue is in Results section of this inspection report.
NCR 02402792: Elevated 'A' RCP #2 seal leakage exceeding AOP-018 limit resulting in shutting down the reactor
NCR 02429788: failed containment temperature reference junction impacting the ability to satisfy TS surveillance requirement 3.6.5.1, verify average containment air temperature is within limits Although the identified examples did not result in inadequate corrective actions, the inspectors stated if a potentially adverse trend develops and is left uncorrected then a potentially more risk significant safety concern could occur.
Observation: Weakness in Evaluating Quality Assurance Problem 71152B In the area of problem evaluation, the team identified a weakness in evaluating and documenting the cause of a problem to limit the potential of recurrence. Specifically, the inspectors identified two examples, as shown below, in which the licensee failed to evaluate the cause of a quality control error that permitted deficient or non-conforming parts to be installed in the plant. The disposition of this issue is in Results section of this inspection report.
NCR 02428690: Several augmented quality under-voltage protection relays were installed in safety-related applications in 2015 and 2017.
NCR 02369694: a 10 CFR Part 21 hold on A200 contactors/starters was issued in 2015. In 2016 this Part 21 parts hold was removed which allowed for four of these A200 contactors/starter to be installed in plant, two of the in continuously energized applications, where the Part 21 applies.
The inspectors challenged the licensees approach to not perform causal evaluations of these problems. The inspectors determined that without an appropriate evaluation the cause cannot be concluded to be a human performance error or historic issue.
Observation: Weakness in Procedures for Problem Identification 71152B In the area of problem identification, the team identified a weakness in the quality of procedure directions used to screen an NCR as a CAQ or non-CAQ. Specifically, the team identified the following examples of sections within AD-PI-ALL-0100, Corrective Action Program, which were not adequately written to ensure licensee personnel appropriately and consistently screen NCRs:
Posting Protected Train equipment: The inspectors identified that within Guidelines for Determining Condition Adverse to Quality non-CAQ examples section the failure to properly post Protected Train equipment is listed as non-CAQ. The posting of protected equipment is considered a common risk management action (RMA) to, in part, maintain compliance with 10 CFR 50.65(a)(4). As a result, the inspectors determined that following this guidance would lead to erroneously categorize nonconformance with an NRC regulation as non-CAQ which is contrary to AD-PI-ALL-0100, Attachment 2, Step 2.1. Duke initiated procedure revision request (PRR)02431828 to revise this non-CAQ example.
ALARA planning and controls: The inspectors identified that within Guidelines for Determining Condition Adverse to Quality CAQ examples section a condition adversely affecting performance of ALARA planning and controls is listed as CAQ.
ALARA planning and controls are utilized to conform to 10 CFR 20.1003. The inspectors determined that this example was not adequately written to include sufficient guidance to ensure licensee personnel understand what constitutes an adverse performance of ALARA planning and controls. As a result of inspectors raising concerns with this guidance, the licensee provided a statement on how this guidance is applied. The inspectors determined the licensees statement included a significant amount of clarification and guidance that was not included in the guidance.
Robinson initiated PRR 02431828 to clarify this CAQ example.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 29, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Nicole Flippin and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RNP-M/MECH-
1882
Internal Flooding Displacement Evaluation for Reactor
Auxiliary Building
Revision 3
Calculations
RNP-M/MECH-
1883
Internal Flooding Analysis Reactor Auxiliary Building
Revision 2
2310720
Incorrect procedure revision in 4 kV room
01/14/2020
2320152
Checklist - two examples of 50.59 applicability
determinations performed incorrectly for for clearances
hanging for over 60 days
03/18/2020
2339593
Checklist - NRC identified potential trend in breaker
operation and maintenance
08/07/2020
2357635
Checklist - individual received dose alarm
11/24/2020
2365244
Checklist - MCC-6(17B), R-20, BREAKER CONTACTOR
STICKING
2/11/2021
2369694
Part 21 parts hold removed on A200 Contactors/Starters at
RN
2/11/2021
2372104
concern with inappropriately changing the Biasi CHF limit
without NRC approval
03/01/2021
2379164
Protected equipment line up service water pump D
04/20/2021
2379647
NRC cybersecurity inspection - PMMD USB hard drives
04/23/2021
2396736
2399406
2402792
'A' reactor coolant pump no. 2 seal degraded, AOP-018
entry, and reactor shutdown (root cause evaluation)
2402785
'B' reactor coolant pump flange stud boric acid degradation
(root cause evaluation)
10/24/2021
2403256
performance deficiency noted during Target Set baseline
inspection
10/27/2021
2428690
PQL 3 (Augmented Quality) relays installed in safety-related
05/24/2022
2428718
Dry Fuel Campaign Original Dose estimate exceeded by
67%
06/02/2022
2429788
Troubleshoot/Repair RTD-2 CV Temperature Reference
Junction
06/02/2022
Corrective Action
Documents
2430016
'B' EDG AIR COMPRESSOR CONTINUOUS UNLOADING
06/07/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AFTER AUTO START
CR 00520969
EDG 'B' VOLTAGE REGULATOR FAILURE
03/01/2012
CR 02326430
EDG B STBY LUBE OIL RECIRC PMP DEGRADED
WIRING AT MOTOR
04/22/2020
CR 02333929
CR 02378612
21 NRC MS8 Cyber Sec-Unused protocol not disabled on
04/15/2021
CR 02378657
21 NRC MS8 Cyber Security Inspection - USB media
converter
04/16/2021
CR 02380616
21 NRC MS8 Cyber Security Ins-Unnecessary
Service/Software
04/30/2021
CR 02416880
Failed Fuel Injector #11 on "A" EDG
2/21/2022
CR 02417400
PI-4507A CONSISTENLY INDICATES LOW CRANKCASE
PRESSURE
2/24/2022
2433015
NRC non-cited violation for 'B' RCP flange leakage
06/29/2022
2433017
NRC non-cited violation for 'A' RCP seal degradation
06/29/2022
2433019
LIV for installation of non-conforming parts
06/29/2022
Corrective Action
Documents
Resulting from
Inspection
2433020
Minor violation due to CR screening
06/29/2022
Engineering
Changes
EDG Fuel Injection Pump Thread Engagement Concern
Revision 0
System Health Report Emergency Diesel Generators and
Auxiliaries
Fourth
Quarter 2021
System Health Report Safety Injection
Fourth
Quarter 2021
Operational Equipment Deficiencies List
06/07/2022
RNP Operations Shift Turnover Report
06/24/22022
29-564-46
Chemical and Volume Control System Instruction Manual for
Nuclear Plant Filters
010
Miscellaneous
Adverse
Condition
Monitoring and
Contingency
Planning
Elevated flow to Reactor Coolant Drain Tank
09/07/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2396736
Standard Technical Specifications - Westinghouse Plants:
Bases
Operational
Decision Making
2396736
Elevated 'A' RCP No. 2 Seal Leak Off
09/28/2021
AD-EG-ALL-1202
Preventive Maintenance and Surveillance Testing
Administration
AD-EG-ALL-1209
System Health Reports and Notebooks
AD-MN-ALL-0006
Fluid Leak Management
AD-OP-ALL-0105
AD-OP-ALL-0201
Protected Equipment
AD-OP-ALL-0202
Aggregate Operator Impact Assessment
Revision 4
AD-OP-RNP-
205
Operator Time Critical Action Program
Revision 4
AD-PI-ALL-0100
Corrective Action Program
AD-PI-ALL-0105
Effectiveness Reviews
AD-PI-ALL-0106
Cause Investigation Checklists
AD-PI-ALL-0400
Operating Experience Program
AD-QC-ALL-0101
Quality Control Inspection Program for Modifications and
Maintenance Activities
AD-RP-ALL-9000
ALARA Program
AD-WC-ALL-
210
Work Request Initiation, Screening, Prioritization and
Classification
Reactor Coolant Pump Abnormal Conditions
CM-013
REACTOR COOLANT PUMP, DISASSEMBLY AND
REASSEMBLY OF PUMP
CM-013
REACTOR COOLANT PUMP, DISASSEMBLY AND
REASSEMBLY OF PUMP
CM-502
Filter Cartridge Maintenance
OMM-001
RNP Conduct of Operations
OST-021
Daily Surveillances
Procedures
REACTOR COOLANT PUMP MAIN FLANGE STUD
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
STRETCH MEASUREMENTS AND STUD RETENSION
PROCEDURE
REACTOR COOLANT PUMP MAIN FLANGE STUD
STRETCH MEASUREMENTS AND STUD RETENSION
PROCEDURE
Self-Assessments 02301280-05
Clearance and Tagging Self Assessment
09/17/2020
13304118
Bench test 480V bus E2 undervoltage protection aux relay
2/27/2015
224077
20371408
Inspect Emergency Diesel Generator B Cooling Water
Expansion Joints
2/21/2020
20451996
Replace motor control center 5(7J)-42/O starter
06/05/2021
20451997
Replace motor control center 6(17B)-42/O starter
2/02/2022
20491980
'B' reactor coolant pump no. 2 seal replacement in Fall 2022
refueling outage
20491981
'C' reactor coolant pump no. 2 seal replacement in Fall 2022
refueling outage
Work Orders
20539572
rplace 480V bus E1 undervoltage protection aux relay in fall
22 outage