IR 05000261/2020012
| ML20274A286 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/30/2020 |
| From: | Scott Shaeffer NRC/RGN-II/DRS/EB2 |
| To: | Kapopoulos E Duke Energy Carolinas |
| References | |
| IR 2020012 | |
| Download: ML20274A286 (13) | |
Text
September 30, 2020
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT - FIRE PROTECTION TEAM INSPECTION REPORT 05000261/2020012
Dear Mr. Kapopoulos:
On September 17, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at H.B. Robinson Steam Electric Plant and 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.
No findings or violations of more than minor significance were identified during this inspection.
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,
/RA/
Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 05000261 License No. DPR-23
Enclosure:
Inspection Report
Docket Number: 05000261 License Number: DPR-23 Report Number: 05000261/2020012 Enterprise Identifier: I-2020-012-0005 Licensee: Duke Energy Facility: H.B. Robinson Steam Electric Plant, Unit 2 Location: Hartsville, SC Inspection Dates: August 24, 2020 to September 17, 2020 Inspectors: E. Coffman, Reactor Inspector L. Jones, Senior Reactor Inspector W. Monk, Senior Reactor Inspector (Lead Inspector)
D. Strickland, Reactor Inspector Approved By: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team inspection at H.B. Robinson Steam Electric Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
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 industry standards.
REACTOR SAFETY
71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
The inspectors verified that the following systems credited in the approved fire protection program (FPP) could perform their licensing basis function:
- (1) Fire Prevention Component - Combustible Controls and Hot Work Programs a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walk-down inspection to identify equipment alignment discrepancies.
Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with Fire Protection equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
- (2) Suppression System - North and South Cable Vault CO2 System a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walk-down inspection to identify equipment alignment discrepancies.
Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with Fire Protection equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
- (3) Safe-Shutdown System - Train A and B Service Station Batteries and Chargers a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walk-down inspection to identify equipment alignment discrepancies.
Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with Fire Protection equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
- (4) Safe-Shutdown System - Turbine Driven Auxiliary Feedwater Pump a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walk-down inspection to identify equipment alignment discrepancies.
Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with Fire Protection equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the following fire protection program administrative controls were implemented in accordance with the sites current licensing basis:
- (1) Administrative Program #1 - NFPA 805 Monitoring Program
- (2) Administrative Program #2 - Fire Brigade Drills and Training Program
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
The inspectors verified the following:
a. Changes to the approved Fire Protection Program (FPP) did not constitute an adverse effect on the plant's ability to safely shutdown post-fire.
b. The adequacy of the design change modification.
c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d. The FPP documents and Post-Fire SSD operating procedures affected by the changes were updated.
- (1) Plant Modification #1 - EC 400502 - Hagan Room Suppression System
- (2) Plant Modification #2 - EC 410844 - Intumastic 285 for CSR and E1/E2 SGWRs Cable Trays
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
On September 17, 2020, the inspectors presented the NRC fire protection inspection results to Ernest J. Kapopoulos, the Site V.P. and other members of the licensee's staff. The inspectors verified no proprietary information was retained nor documented in this report.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Calculations DPC -1435.00- Basis Calculation for AD-EG-ALL-1520 Procedure - Rev. 9
00-0008 Transient Combustible Control
RNP-M/BMRK- CODE COMPLIANCE EVALUATION FOR NFPA 72E Rev. 7
1006
RNP-M/BMRK- CODE COMPLIANCE EVALUATION NFPA 72 - NATIONAL Rev. 8
1014 FIRE ALARM CODE
RNP-M/BMRK- CODE COMPLIANCE EVALUATION NFPA 2001 - Rev. 2
1019 STANDARD ON CLEAN AGENT FIRE EXTINGUISHING
SYSTEMS
Corrective Action NCR 2140661 A CCW PUMP FIRE WRAP IS DAMAGED 8/1/2017
Documents
NCR 2168412 FDR-4 WILL NOT CLOSE AUTOMATICALLY 11/29/2017
NCR 2170060 FDR-115 FIRE DOOR FAILS TO LATCH CLOSED FROM 12/5/2017
ABOUT 10"
NCR 2174763 BAT-CHRGR-C HOT SPOT IDENTIFIED 1/3/2018
NCR 2175086 FIRE DOOR #6 WILL NOT CLOSE PROPERLY 1/4/2018
NCR 2193563 FDR-6 DOES NOT CLOSE WHEN RELEASED FROM 6"- 3/22/2018
10" OPEN
NCR 2199899 REPAIR FIRE DOOR FDR-117 4/19/2018
NCR 2202453 MCC-A(1M) Breaker will not close 4/30/2018
NCR 2207733 Cable Discrepancy in RNP-E-6.004 5/21/2018
Inspection Type Designation Description or Title Revision or
Procedure Date
NCR 2236532 HAGAN RM FW SUPERVISORY AIR PRESSURE SWITCH 10/10/2018
NOT OPERATING
NCR 2240082 FIRE DOOR FDR-18 WILL NOT CLOSE 10/30/2018
NCR 2242167 Incipient Fire Detector Failures 11/8/2018
NCR 2266959 FDR-107 (FIRE DOOR, DOUBLE ROOM 105 NORTH 4/5/2019
WALL)
NCR 2269436 FIRE DOOR 22 IS NOT CLOSING PROPERLY 4/22/2019
NCR 2271622 2019 NRC DBAI: W1-71 Regarding Station Batteries D/E 5/7/2019
NCR 2273464 PENETRATION NEEDS TO BE SEALED IN BLDG 469 5/20/2019
NCR 2299820 FIRE DOOR 16 DOES NOT CLOSE ON ITS OWN 10/29/2019
NCR 2300027 CCW PUMP A FIRE WRAP TORN 10/30/2019
NCR 2300028 FIRE DOOR 16 NEEDS REPAIRS 10/30/2019
NCR 2320227 Gaps between TS SR 4.8.2.1 and maintenance procedures 3/10/2020
NCR 2323631 FP-92 (HAGAN ROOM) VENT PORT LEAKING, FP-92 IS 4/2/2020
NOW ISOLATED
Corrective Action CR 2345780 2020 NRC FP - Superseded Calculation Reference 8/25/2020
Documents
Resulting from CR 2346045 2020 RNP FP: OST-922 not Revised when PM Freq 8/26/2020
Inspection Changed
CR 2346231 2020 RNP FP: FP-013 not revised to reflect PM freq change 8/27/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
CR 2346315 2020 RNP FP: OST-620-1 and OST-620-2 Incorrect PM 8/27/2020
Frequency
CR 2348950 2020 NRC FP - Pair of Fire Brigade gloves found out of date 9/16/2020
PRR 2346043 OST-922 Procedure Revision for PM Frequency Change 8/26/2020
PRR 2346227 OST-620 Procedure Revision for PM Frequency Change 8/27/2020
WR 20183895 TAPE EXPOSED LEADS IN NORTH CABLE VAULT 9/16/2020
Engineering EC 400502 Install Gaseous Fire Suppression System in the Hagan Rev. 17
Changes Room
EC 408500 Switchgear Building #469, Fire Area G6Fire Zone 51C2 rev. 41
PENSEAL Installations
EC 410844 Repair Fire Retardant Cable Tray Coating in E1/E2 Rev. 1
Safeguards Room and Cable Spread Room
EC 413577 BRE Installation Non-CPE Fire Protection Program / Plant Rev. 0
Impact Review Form
Fire Plans CSD-RNP-PFP- AUXILIARY BUILDING ELEV 226 PRE-FIRE PLAN Rev. 0
AB2-0226-001
CSD-RNP-PFP- AUXILIARY BUILDING ELEV 246 PRE-FIRE PLAN Rev. 0
AB2-0246-001
CSD-RNP-PFP- TURBINE BUILDING ELEV 226 PRE-FIRE PLAN Rev. 0
TB2-0226-001
Miscellaneous 2020-07-001 TRANSIENT COMBUSTIBLE PERMIT - 200 Gal Tote in 1/15/2020
Diesel Rooms
Inspection Type Designation Description or Title Revision or
Procedure Date
EP 20-0004 Darlington County Fire Dept. MOU with Robinson Nuclear 2/3/2020
Plant
Manual # 728- Battery Vendor Manual Battery Installation and Operating Rev. 3
147-75 Instructions
NFPA 805 Transition to 10 CFR 50.48(c) - NFPA 805 Rev. 1
Transition Report
Robinson Unit 2 Fire Protection Rev. 28
UFSAR Section
9.5.1
Training Informational Handout for Contingent Workers 3/20/2018
Document
TTC1636-N Duke Energy Environmental, Health and Safety Overview 3/26/2018
Procedures AD-EG-ALL-1139 TEMPORARY CONFIGURATION CHANGES Rev. 1
AD-EG-ALL-1501 FIRE PROTECTION CHANGE PROCESS Rev. 2
AD-EG-ALL-1502 FIRE PROTECTION IMPACT SCREENING FOR PLANT Rev. 1
DESIGN CHANGES
AD-EG-ALL-1503 FIRE PROTECTION PERFORMANCE MONITORING AND Rev. 2
OTHER PROGRAM ELEMENTS
AD-EG-ALL-1520 TRANSIENT COMBUSTIBLE CONTROL Rev. 13
AD-EG-ALL-1521 HOT WORK PERMITS Rev. 8
AD-EG-ALL-1522 DUTIES OF A COMPENSATORY FIRE WATCH Rev. 12
AD-EG-ALL-1523 TEMPORARY IGNITION SOURCE CONTROL Rev. 1
Inspection Type Designation Description or Title Revision or
Procedure Date
AD-EG-RNP- LICENSE RENEWAL AGING MANAGEMENT ACTIVITIES Rev. 3
1650
AD-HS-ALL-0113 HYDROGEN SAFE WORK PRACTICES Rev. 1
AD-LS-ALL-0007 Applicability Determination Process Rev. 18
AD-OP-ALL-0207 FIRE BRIGADE ADMINISTRATIVE CONTROLS Rev. 3
AD-TQ-ALL-0086 FIRE BRIGADE AND HAZMAT TRAINING Rev. 5
OMM-002 FIRE PROTECTION MANUAL Rev. 55
OP-601 DC Supply System Rev. 64
OST-611-10 LOW VOLTAGE FIRE DETECTION AND ACTUATION Rev. 14
SYSTEM DETECTION ZONE 10 SOUTH CABLE VAULT
OST-622 FIRE SUPPRESSION WATER SYSTEM MOTOR DRIVEN Rev. 32
FIRE PUMP TEST
OST-632 UNIT 2 FIRE SUPPRESSION WATER SYSTEM FLOW Rev. 27
TEST
OST-639 FIRE EQUIPMENT MONTHLY INVENTORY Rev. 41
OST-646 FIRE SUPPRESSION WATER SYSTEM ENGINE DRIVEN Rev. 39
FIRE PUMP TEST
OST-696 CLEAN AGENT SUPPRESSION SYSTEM ANNUAL 12/12/2019
TESTING HAGAN ROOM
Inspection Type Designation Description or Title Revision or
Procedure Date
OST-922 Dedicated Shutdown Equipment Identification Audit Rev. 32
PLP-049 FUSE CONTROL PROGRAM Rev. 13
RNP-M/MECH- Evaluation of Permanent Storage Areas Rev. 0
1937
Work Orders WO 20091747 FDR-4 WILL NOT CLOSE AUTOMATICALLY 11/29/2017
WO 20151618 Clean Battery Cell Connection on B station Battery 11/01/2018
WO 20170793 EL, CALIBRATE BATTERY CHARGER A1 VOLTAGE AND 06/02/2017
CURRENT METERS
WO 20196591 BAT-CHRGR-A-1, CHECK/CAL POS & NEG GND ALARM 05/31/2018
SETPOINT
WO 20212371 Perform MST-920-B on B Station Battery (MOD Perf Test) 10/29/2018
WO 20322838 INSPECTION OF BATTERY CELL CONNECTIONS ON "B" 10/31/2019
STATION BATTERY
11