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:
Report Number:
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
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
TAPE EXPOSED LEADS IN NORTH CABLE VAULT
9/16/2020
Engineering
Changes
Install Gaseous Fire Suppression System in the Hagan
Room
Rev. 17
Switchgear Building #469, Fire Area G6Fire Zone 51C2
PENSEAL Installations
rev. 41
Repair Fire Retardant Cable Tray Coating in E1/E2
Safeguards Room and Cable Spread Room
Rev. 1
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
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
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
FDR-4 WILL NOT CLOSE AUTOMATICALLY
11/29/2017
Clean Battery Cell Connection on B station Battery
11/01/2018
EL, CALIBRATE BATTERY CHARGER A1 VOLTAGE AND
CURRENT METERS
06/02/2017
BAT-CHRGR-A-1, CHECK/CAL POS & NEG GND ALARM
SETPOINT
05/31/2018
Perform MST-920-B on B Station Battery (MOD Perf Test)
10/29/2018
INSPECTION OF BATTERY CELL CONNECTIONS ON "B"
STATION BATTERY
10/31/2019