IR 05000261/2020012

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Fire Protection Team Inspection Report 05000261/2020012
ML20274A286
Person / Time
Site: Robinson Duke Energy icon.png
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

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

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N.05 Calculations

DPC -1435.00-

00-0008

Basis Calculation for AD-EG-ALL-1520 Procedure -

Transient Combustible Control

Rev. 9

RNP-M/BMRK-

1006

CODE COMPLIANCE EVALUATION FOR NFPA 72E

Rev. 7

RNP-M/BMRK-

1014

CODE COMPLIANCE EVALUATION NFPA 72 - NATIONAL

FIRE ALARM CODE

Rev. 8

RNP-M/BMRK-

1019

CODE COMPLIANCE EVALUATION NFPA 2001 -

STANDARD ON CLEAN AGENT FIRE EXTINGUISHING

SYSTEMS

Rev. 2

Corrective Action

Documents

NCR 2140661

A CCW PUMP FIRE WRAP IS DAMAGED

8/1/2017

NCR 2168412

FDR-4 WILL NOT CLOSE AUTOMATICALLY

11/29/2017

NCR 2170060

FDR-115 FIRE DOOR FAILS TO LATCH CLOSED FROM

ABOUT 10"

2/5/2017

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"-

10" OPEN

3/22/2018

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

Procedure

Type

Designation

Description or Title

Revision or

Date

NCR 2236532

HAGAN RM FW SUPERVISORY AIR PRESSURE SWITCH

NOT OPERATING

10/10/2018

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

WALL)

4/5/2019

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

NOW ISOLATED

4/2/2020

Corrective Action

Documents

Resulting from

Inspection

CR 2345780

20 NRC FP - Superseded Calculation Reference

8/25/2020

CR 2346045

20 RNP FP: OST-922 not Revised when PM Freq

Changed

8/26/2020

CR 2346231

20 RNP FP: FP-013 not revised to reflect PM freq change

8/27/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CR 2346315

20 RNP FP: OST-620-1 and OST-620-2 Incorrect PM

Frequency

8/27/2020

CR 2348950

20 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

Changes

EC 400502

Install Gaseous Fire Suppression System in the Hagan

Room

Rev. 17

EC 408500

Switchgear Building #469, Fire Area G6Fire Zone 51C2

PENSEAL Installations

rev. 41

EC 410844

Repair Fire Retardant Cable Tray Coating in E1/E2

Safeguards Room and Cable Spread Room

Rev. 1

EC 413577

BRE Installation Non-CPE Fire Protection Program / Plant

Impact Review Form

Rev. 0

Fire Plans

CSD-RNP-PFP-

AB2-0226-001

AUXILIARY BUILDING ELEV 226 PRE-FIRE PLAN

Rev. 0

CSD-RNP-PFP-

AB2-0246-001

AUXILIARY BUILDING ELEV 246 PRE-FIRE PLAN

Rev. 0

CSD-RNP-PFP-

TB2-0226-001

TURBINE BUILDING ELEV 226 PRE-FIRE PLAN

Rev. 0

Miscellaneous

20-07-001

TRANSIENT COMBUSTIBLE PERMIT - 200 Gal Tote in

Diesel Rooms

1/15/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EP 20-0004

Darlington County Fire Dept. MOU with Robinson Nuclear

Plant

2/3/2020

Manual # 728-

147-75

Battery Vendor Manual Battery Installation and Operating

Instructions

Rev. 3

NFPA 805

Transition Report

Transition to 10 CFR 50.48(c) - NFPA 805

Rev. 1

Robinson Unit 2

UFSAR Section

9.5.1

Fire Protection

Rev. 28

Training

Document

Informational Handout for Contingent Workers

3/20/2018

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

DESIGN CHANGES

Rev. 1

AD-EG-ALL-1503

FIRE PROTECTION PERFORMANCE MONITORING AND

OTHER PROGRAM ELEMENTS

Rev. 2

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

Procedure

Type

Designation

Description or Title

Revision or

Date

AD-EG-RNP-

1650

LICENSE RENEWAL AGING MANAGEMENT ACTIVITIES

Rev. 3

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

SYSTEM DETECTION ZONE 10 SOUTH CABLE VAULT

Rev. 14

OST-622

FIRE SUPPRESSION WATER SYSTEM MOTOR DRIVEN

FIRE PUMP TEST

Rev. 32

OST-632

UNIT 2 FIRE SUPPRESSION WATER SYSTEM FLOW

TEST

Rev. 27

OST-639

FIRE EQUIPMENT MONTHLY INVENTORY

Rev. 41

OST-646

FIRE SUPPRESSION WATER SYSTEM ENGINE DRIVEN

FIRE PUMP TEST

Rev. 39

OST-696

CLEAN AGENT SUPPRESSION SYSTEM ANNUAL

TESTING HAGAN ROOM

2/12/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OST-922

Dedicated Shutdown Equipment Identification Audit

Rev. 32

PLP-049

FUSE CONTROL PROGRAM

Rev. 13

RNP-M/MECH-

1937

Evaluation of Permanent Storage Areas

Rev. 0

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

CURRENT METERS

06/02/2017

WO 20196591

BAT-CHRGR-A-1, CHECK/CAL POS & NEG GND ALARM

SETPOINT

05/31/2018

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"

STATION BATTERY

10/31/2019