ML031320011

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IR 05000261-03-008, on March 31 - April 4, 2003, H.B. Robinson Unit 2, Hartsville, South Carolina. License Renewal Inspection Program, Scoping & Screening
ML031320011
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 05/08/2003
From: Casto C
Division Reactor Projects II
To: Moyer J
Carolina Power & Light Co
References
IR-03-008
Download: ML031320011 (35)


See also: IR 05000261/2003008

Text

May 8, 2003

Carolina Power & Light Company

ATTN:

Mr. J. W. Moyer

Vice President

H. B. Robinson Steam Electric Plant Unit 2

3581 West Entrance Road

Hartsville, SC 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT - NRC INSPECTION REPORT

50-261/03-08

Dear Mr. Moyer:

On October 25, 2002, the NRC completed an inspection regarding the application for license

renewal for your Robinson facility. The enclosed report documents the inspection findings,

which were discussed on April 4, 2003, with you and other members of your staff in an exit

meeting open for public observation at the Hartsville Memorial Library.

The purpose of this inspection was an examination of activities that support the application for a

renewed license for the Robinson facility. The inspection consisted of a selected examination

of procedures and representative records, and interviews with personnel regarding the process

of scoping and screening plant equipment to select equipment subject to an aging management

review. For a sample of plant systems, inspectors performed visual examination of accessible

portions of the systems to observe any effects of equipment aging.

The inspection concluded that the scoping and screening portion of the license renewal

activities were conducted as described in the License Renewal Application and that

documentation supporting the application is in an auditable and retrievable form. With the

exception of the items identified in this report, your scoping and screening process was

successful in identifying those systems, structures, and components required to be considered

for aging management.

In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document Room

or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).



CP&L

Should you have any questions concerning this letter, please contact Caudle Julian at

404-562-4603.

Sincerely,

\\RA\\

Charles A Casto, Director

Division of Reactor Safety

Docket Nos:. 50-261

License Nos:. DPR-23

cc: See page 3

3

CP&L

cc:

Mr. William D. Johnson

Vice President and Corporate Secretary

Carolina Power & Light Company

Post Office Box 1551

Raleigh, NC 27602

Ms. Peggy Force

Assistant Attorney General

State of North Carolina

Post Office Box 629

Raleigh, NC 27602

U.S. Nuclear Regulatory Commission

Resident Inspectors Office

H. B. Robinson Steam Electric Plant

2112 Old Camden Road

Hartsville, SC 29550

Mr. T. P. Cleary

Plant General Manager

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant, Unit

No. 2

3581 West Entrance Road

Hartsville, SC 29550

Mr. Chris L. Burton

Director of Site Operations

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant, Unit

No. 2

3581 West Entrance Road

Hartsville, SC 29550

Public Service Commission

State of South Carolina

Post Office Drawer 11649

Columbia, SC 29211

Mr. C. T. Baucom

Supervisor, Licensing/Regulatory Programs

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant

Unit No. 2

3581 West Entrance Road

Hartsville, SC 29550

Ms. Beverly Hall, Acting Director

N.C. Department of Environment

and Natural Resources

Division of Radiation Protection

3825 Barrett Dr.

Raleigh, NC 27609-7721

Mr. Robert P. Gruber

Executive Director

Public Staff - NCUC

4326 Mail Service Center

Raleigh, NC 27699-4326

Mr. R. Mike Gandy

South Carolina Department of Health

and Environmental Control

Division of Radioactive Waste Management

2600 Bull Street

Columbia, SC 29201

Mr. James W. Holt, Manager

Performance Evaluation and

Regulatory Affairs CPB 7

Carolina Power & Light Company

Post Office Box 1551

Raleigh, NC 27602-1551

Mr. John H. ONeill, Jr.

Shaw, Pittman, Potts & Trowbridge

2300 N Street, NW.

Washington, DC 20037-1128

Mr. B. L. Fletcher III

Manager - Regulatory Affairs

Carolina Power & Light Company

H. B. Robinson Steam Electric Plant

Unit No. 2

3581 West Entrance Road

Hartsville, SC 29550-0790

Mr. Alan P. Nelson

Nuclear Energy Institute

1776 I Street, NW., Suite 400

Washington, DC 20006-3708

4

CP&L

cc cont:

Talmage B. Clements

Manager - License Renewal

Carlina Power and Light Company

410 South Wilmington Street

Raleigh, NC 27602

Mr. Roger A. Stewart

Carolina Power and Light Company

H. B. Robinson Steam Electric Plant, Unit

No. 2

3581 West Entrance Road

Hartsville, SC 29550

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No:

50-261

License No:

DPR-23

Report No:

50-261/03-08

Licensee:

Carolina Power and Light Company (CPL)

Facility:

H. B. Robinson Steam Electric Plant, Unit 2

Location:

3581 West Entrance Road

Hartsville, SC 29550

Dates:

March 31 - April 4, 2003

Inspectors:

W Bearden, Reactor Inspector

M. Maymi, Reactor Inspector

R. Moore, Reactor Inspector

M. Scott, Reactor Inspector

K. Van Doorn, Reactor Inspector

H. Wang, Operations Engineer, NRR

Approved by:

Caudle Julian

Team Leader

Division of Reactor Safety

TABLE OF CONTENTS

Summary of Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

I

Report Details . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

I.

Inspection Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

II.

Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

A. Evaluation of Scoping and Screening of Mechanical Systems . . . . . . . . . . . . 1

1. Reactor Coolant System (RCS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2. Chemical and Volume Control System . . . . . . . . . . . . . . . . . . . . . . . . 3

3. Spent Fuel Pool Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

4. Residual Heat Removal System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

5. Safety Injection System (SI) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

6. Diesel Generator System (DG) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

7. Dedicated Shutdown Diesel Generator . . . . . . . . . . . . . . . . . . . . . . . . 4

8. EOF/TSC Security Diesel Generator . . . . . . . . . . . . . . . . . . . . . . . . . . 4

9. Fuel Oil System (FO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

10. Component Cooling Water (CCW) . . . . . . . . . . . . . . . . . . . . . . . . . . 5

11. Service Water (SW)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

12. Instrument and Service Air (IA, SA) . . . . . . . . . . . . . . . . . . . . . . . . . . 5

13. Containment Spray (CS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

14. Auxiliary Feedwater System (AFW) . . . . . . . . . . . . . . . . . . . . . . . . . . 6

15. Main Feedwater System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

16. Containment Isolation System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

17. Post Accident Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

18. Heating, Ventilation, and Air Conditioning . . . . . . . . . . . . . . . . . . . . . 7

19. HVAC - Containment Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

20. HVAC - Control Room Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

21. HVAC - Fuel Handling Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

22. Emergency Diesel Generator Room CARDOX System . . . . . . . . . . . 8

23. HVAC - Radwaste Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

24. HVAC - Turbine Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

B. Evaluation of Scoping and Screening of Electrical Systems . . . . . . . . . . . . . . 8

C. Evaluation of Scoping and Screening of Structural Components . . . . . . . . . 10

1. Reactor Containment Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

2. Switchyard Relay Building, Switchyard and Transformer Structures . 10

3. Reactor Auxiliary Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

4. Pipe Restraint Tower . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5. Plant Vent Stack . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

6. Intake Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

7. East Personnel Access Portal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

8. West Personnel Access Portal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

9. Security Emergency Diesel Generator Building . . . . . . . . . . . . . . . . . 13

10. Fuel Handling Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

11. Electrical Manholes and Duct Banks . . . . . . . . . . . . . . . . . . . . . . . . 13

12. Reservoir and Dam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

13. Tech Support Center/Emergency Operations Facility . . . . . . . . . . . 14

14. Concrete Trenches . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

15. Tank Foundations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

D. Evaluation of Scoping and Screening of Fire Protection Systems

. . . . . . . . 15

E. Visual Observations of Plant Equipment in Containment . . . . . . . . . . . . . . . 15

Attachment 1 Supplemental Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Attachment 2 H. B. Robinson License Renewal Inspection Plan . . . . . . . . . . . . . . . . . . . . . . . . 22

Attachment 3 List of Acronyms Used . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

I

SUMMARY OF FINDINGS

IR 05000261-03-08; 3/31-4/4/20032; Carolina Power and Light Company, H. B. Robinson Steam

Electric Plant, Unit 2. License Renewal Inspection Program, Scoping and Screening.

This inspection of License Renewal (LR) activities was performed by six regional office

engineering inspectors, and one staff member from the office of Nuclear Reactor Regulation.

The inspection program followed was NRC Manual Chapter 2516 and NRC Inspection Procedure 71002. This inspection did not identify any findings as defined in NRC Manual Chapter 0612.

The overall conclusion of this inspection was that the license renewal scoping and screening

process was successful. The inspection did reveal the following discrepancies in the applicants

supporting documentation.

Three examples were identified where there was an inconsistency between the application, the

boundary drawing, and the calculation that supports the applicants conclusion. The applicant

wrote a plant Action Request (AR) number 89349 to initiate corrective action to correct the

inconsistencies.

Regarding the auxiliary feedwater system, the inspectors questioned why the backup Deep Well

water supply was not in scope for license renewal. NRR has asked the same question via a

Request for Additional Information (RAI). Inspectors will review the applicants answer to the RAI

during a future inspection.

Regarding the diesel fuel oil system, applicants calculation RNP-L/LR-0006 states that the unit 1

fuel oil tanks and piping used to transfer oil to unit 2 for long term operation of the emergency

diesel generators are in scope. However the boundary drawings didnt depict the transfer piping

as being in scope. The inspectors concluded that the piping should be in scope. The applicant

acknowledged the inspectors comments and will resolve the discrepancy.

Applicants calculation RNP-L/LR-0396 was intended to explain the process used for scoping and

screening of Criterion 2 piping. Criterion 2 are cases where non-safety related piping (NSR)

located in the vicinity of safety related (SR) components might cause damage to SR components

if they failed due to aging. The inspectors had extensive discussion with the applicant to

understand the process and to agree with the applicants conclusions. However calculation 0396

did not clearly describe the process or conclusions and inspectors identified several minor errors

in the calculation. The inspectors stated that the applicant should revise calculation 0396 to more

clearly explain their process and conclusions.

The inspectors identified several instances where the applicants proposed responses to NRR

written RAI questions appeared to be unclear or incomplete. The applicant agreed to consider

the inspectors comments when completing their response to the RAIs.

In walking down plant systems and examining plant equipment the inspectors found no significant

adverse conditions and it appears plant equipment was being maintained adequately.

1

Report Details

I.

Inspection Scope

This inspection was conducted by NRC Region II inspectors and members of the NRR staff to

interview applicant personnel and to examine a sample of documentation which supports the

license renewal application (LRA). This inspection reviewed the results of the applicants scoping

of plant systems and screening of components within those systems to identify the list of

components that need evaluation for aging management. The team selected a sample of plant

systems, structures, and components (SSC) from the LRA scoping results to verify the adequacy

of the applicants scoping and screening documentation and implementation activities. For the

selected in-scope systems/structures, the associated boundary drawings, and the active/passive

and short/long lived determinations of the selected SSCs were reviewed to confirm the accuracy

of the applicants results. In addition to the in-scope systems and structures, some systems that

the applicant had determined not to be in scope for license renewal were selected for inspection.

The inspectors reviewed supporting documentation and interviewed applicant personnel to

confirm the accuracy of the LRA conclusions. The SSCs selected for review during this

inspection are listed in Attachment 2 to this report. For a sample of plant systems, inspectors

performed visual examination of accessible portions of the systems to observe any effects of

equipment aging.

II.

Findings

A. Evaluation of Scoping and Screening of Mechanical Systems

The inspectors evaluated the applicants scoping and screening process for mechanical

components by reviewing a number of plant systems that the applicant determined to be within

the scope of license renewal (LR). The applicant performed scoping at the system level by first

identifying safety-related mechanical systems via review of the equipment data base (EDB). In

addition, through review of the EDB and other license basis information, non-safety-related

mechanical systems which could adversely affect safety-related systems were identified and

systems committed to support the five NRC regulated events in 54.4(a)(3) were identified.

After system scoping, screening was accomplished by: establishment of LR system boundaries

by creating from official station drawings highlighted license renewal boundary flow diagram

drawings: identifying components and component groups subject to an aging management

review using a list of all passive, long-lived, mechanical components; and identification of

intended function(s) of each mechanical component. The screening process and results were

documented in individual system LR Screening Calculations.

Subsequent to the initial LR application, additional NRC guidance was issued for consideration of

the effects of NSR systems on SR systems, such as via spray, leakage, pipe whip, jet

impingement, flooding, and displacement/falling. The inspectors reviewed the applicants

methodology for inclusion of NSR mechanical systems in scope which could affect SR systems.

In addition, the inspectors conducted field walkdowns in various areas of the plant containing SR

systems to observe for NSR systems to confirm appropriate NSR systems had been included for

LR aging management. During these walkdowns the inspectors also observed equipment

material condition. Additional walkdowns are planned for subsequent inspections. The

applicants methodology consisted of: determining all areas where SR and NSR systems were

located; considering all NSR systems within these areas to be in scope for LR; evaluating via

2

documentation and walkdowns which NSR systems could damage SR systems for screening

considerations. For those systems which had portions which were NSR of the same

materials/environs as the SR portion and had existing credited aging management programs, the

applicant simply added the NSR portion of the system for specific areas as requiring aging

management via the existing program. For a few cases the applicant screened in a portion of a

NSR system as requiring aging management, e.g. a portion of the Potable Water System which

was located near some SR switchgear. No significant material condition problems were noted

during the field observations and the inspectors concluded that the applicant had added the

appropriate NSR equipment for aging management.

Applicants calculation RNP-L/LR-0396 was intended to explain the process used for scoping and

screening of Criterion 2 piping. Criterion 2 are cases where non-safety related piping located in

the vicinity of safety related components might cause damage to SR components if they failed

due to aging. The inspectors review of the applicants calculation disclosed that it was not clear

in some cases regarding which NSR portions of systems were added for aging management.

The inspectors had extensive discussion with the applicant to understand the process and to

agree with the applicants conclusions. However calculation 0396 did not clearly describe the

process or conclusions and inspectors identified several minor errors in the calculation. This

document was in error regarding the addition of the equipment in the Spent Fuel Pit Room for

aging management and listing portions of the Auxiliary Steam System as being in containment.

The inspectors stated that the applicant should revise calculation 0396 to more clearly explain

their process and conclusions. The applicant initiated Action Request (AR) No. 89608 to track

correction/clarification of this document.

Areas containing the following systems/structures were observed for appropriate

scoping/screening for NSR effects on SR systems:

Chemical and Volume Control System

Spent Fuel Pool Cooling System

Chemical Feed System (partial)

Component Cooling Water System

Auxiliary Feedwater System

Containment Isolation System

The following mechanical systems were reviewed:

1. Reactor Coolant System (RCS) [including Reactor Vessel and Internals; Reactor Vessel Level

Instrumentation/Inadequate Core Cooling Monitor (ICCM) System; Steam Generator (SG); and

two SG associated pressure boundary systems, Steam Generator Blowdown and Chemical Feed]

These systems are designed to contain and support the nuclear fuel, contain the reactor coolant,

and transfer heat produced in the reactor to the steam and power conversion systems for the

production of electricity. The applicant essentially considered all of the RCS, Reactor Internals,

ICCM System, and SGs to be in scope of LR except for some components not required for the

LR function. The systems associated with SGs for pressure boundary purposes were also

included in scope of LR. The inspectors reviewed LR boundary drawings, design basis

information, the Updated Final Safety Analysis Report (UFSAR), engineering documentation,

system/structure scoping worksheets, screening calculations, and station blackout flow path

drawings. The inspectors also conducted field observations of portions of the Chemical Feed

System. The inspectors concluded that the applicant had performed scoping and screening for

3

these systems and identified the mechanical components subject to aging management in

accordance with the methodology described in the LRA and the rule.

2. Chemical and Volume Control System

The Chemical and Volume Control System functions to provide reactor coolant pump seal

injection, maintain proper RCS inventory, adjust RCS boron concentration, maintain RCS

chemistry control, and RCS degasification. Essentially all of the system has been included for LR

aging management due to being SR or NSR affecting SR systems. The inspectors reviewed LR

boundary drawings, design basis information, the UFSAR, system/structure scoping worksheets,

and screening calculations. The inspectors also conducted field observations of the system. The

inspectors concluded that the applicant had performed scoping and screening for this systems

and identified the mechanical components subject to aging management in accordance with the

methodology described in the LRA and the rule.

3. Spent Fuel Pool Cooling System

The Spent Fuel Pool Cooling System functions to remove decay heat from the spent fuel pool

and to maintain pool water chemistry which are not functions for LR. Portions are credited for

postulated fires and station blackout. The applicant included the portions of the system for fires

and station blackout, the portion of the system which interfaces with Component Cooling Water,

and NSR portions in the Safety Injection Pump Room and Demineralizers Room for aging

management. The inspectors reviewed the LR boundary drawing, design basis information,

system/structure scoping worksheets, and screening calculations. The inspectors also conducted

field observations of the system. The inspectors concluded that the applicant had performed

scoping and screening for this systems and identified the mechanical components subject to

aging management in accordance with the methodology in the LRA and the rule.

4. Residual Heat Removal System

The Residual Heat Removal System functions to remove heat from the RCS during normal plant

shutdown conditions, provides borated water to RCS during a design basis accident, and

recirculates water from the containment sump during a postulated loss of coolant accident.

Essentially all of this system was determined to require aging management. The inspectors

reviewed LR boundary drawings, system/structure scoping worksheets, and screening

calculations. The inspectors concluded that the applicant had performed scoping and screening

for these systems and identified the mechanical components subject to aging management in

accordance with the methodology described in the LRA and the rule.

5. Safety Injection System (SI)

The SI system provides adequate emergency core cooling following a postulated design basis

accident. The SI system performs the funtions of : passive accumulator injection, active safety

injection, and residual heat removal recirculation of water from the containment sump. The

primary purpose of the system is to deliver cooling water to the reactor core in the event of a loss-

of-coolant accident. The system also provides a source of borated water for reactivity control. The

applicant included all of the safety related portion of the system in scope for license renewal. The

inspectors reviewed the system scoping and screening documents, license renewal boundary

drawings, the UFSAR, and the SI system description. The inspectors also performed a walkdown

of accessible portions of the system. The inspectors concluded that the applicant had performed

4

scoping and screening for the SI system in accordance with the methodology described in the

H.B. Robinson LRA and the rule.

6. Diesel Generator System (DG)

The DG system provides AC power to the onsite electrical distribution system in case normal AC

power is lost to assure the capability for a safe plant shutdown. The DG support systems include

the Starting Air Subsystem, Lube Oil Subsystem, Jacket Water Cooling Subsystem, Scavenging

Air Subsystem, Scavenging Air Cooling Subsystem, Diesel Engine Fuel Oil Subsystem, and the

Diesel Exhaust Subsystem. Mechanical components included in the LR scope for aging

management review included heat exchangers, regulators, pumps, filters, strainers, exhaust

silencer, tanks, flow orifices and elements, valves, piping, tubing and fittings. The inspectors

reviewed the system scoping and screening documents, license renewal boundary drawings, the

UFSAR, and the DG system description. The inspectors also performed a walkdown of

accessible portions of the system. The inspectors concluded that the applicant had performed

scoping and screening for the DG system in accordance with the methodology described in the

H.B. Robinson LRA and the rule.

7. Dedicated Shutdown Diesel Generator (DSDG)

The DSDG provides an alternate AC power source to assure the capability for safe plant

shutdown following a fire or total loss of all AC power (Station Blackout). The skid-mounted, self-

contained DSDG is a component of the Dedicated Shutdown Electrical System. The inspectors

reviewed the system scoping and screening documents, license renewal boundary drawings, the

UFSAR, and the DSDG system description. The inspectors also performed a walkdown of

accessible portions of the system.

The inspectors observed that the screening calculation RNP-L/LR-0115 and the license renewal

application says that an air filter and two relief valves on the air start system are in scope for

license renewal. But a note in the calculation says the filter and valves are not in LR scope and

the components are not shown as being in scope on the boundary drawing. This is a

contradiction that the applicant included in AR 89349 to resolve.

8. EOF/TSC Security Diesel Generator

The EOF/TSC Security Diesel Generator provides backup electrical power to the Emergency

Operations Facility/Technical Support Center Building and security systems upon loss of the

normal power supplies. The backup electrical power supplied to security lighting in outside areas

is relied on for performance of actions required for fire protection safe shutdown, thus the diesel

is in the scope of LR. Mechanical components included in the LR scope for aging management

review included filters, radiator, exhaust silencer, heaters, ductwork, valves, piping, tubing and

fittings. The inspectors reviewed the system scoping and screening documents, license renewal

boundary drawings, and the EOF/TSC Security Diesel Generator system description. The

inspectors concluded that the applicant had performed scoping and screening for the system in

accordance with the methodology described in the Robinson LRA and the rule.

9. Fuel Oil System (FO)

The FO System supplies fuel oil to the Emergency Diesel Engines, the Dedicated Shutdown

Diesel Engine, and the Diesel Engine-Driven Fire Pump from fuel oil storage tanks on site. The

FO System also provides fuel oil to the EOF/TSC Security Diesel Generator. The FO system

5

provides a fuel oil storage capacity sufficient to operate the Emergency Diesel Generators at full

load for a period of seven days in accordance with Technical Specification requirements if oil can

be transfered from Unit 1 storage tanks to Unit 2. The inspectors reviewed the system scoping

and screening documents, license renewal boundary drawings, Technical Specification Bases,

and an operating procedure. The inspectors also performed a walkdown of some portions of the

system.

Regarding the diesel fuel oil system, applicants calculation RNP-L/LR-0006 says that the unit 1

fuel oil tanks and piping used to transfer oil to unit 2 for long term operation of the emergency

diesel generators are in scope. However the boundary drawings didnt depict the transfer piping

as being in scope. Also calculation RNP-L/LR-0121 reflects that the transfer piping is not in

scope. The inspectors stated their opinion that the piping should be in scope. The applicant

agreed to consider the inspectors comments and resolve the discrepancy.

10. Component Cooling Water (CCW)

This closed loop cooling system removes heat from several safety-related systems, non-safety

systems, and components. At the service water to component cooling heat exchanger heat is

removed by the cooler Service Water. With minor exception, the entire system is within license

renewal scope. The inspectors examined the portions of the system not included in scope and

detailed system drawings indicating component locations that were not in scope to verify that

those portions would not have adverse interaction with other nearby systems. The inspectors

reviewed the license renewal boundary drawings, system descriptions, applicable UFSAR

sections, scoping calculations, and application details. The inspectors determined that the

system was appropriately scoped in the application and associated boundary drawings.

11. Service Water (SW)

SW is a open cycle cooling loop that removes heat from various safety-related systems, non-

safety-related systems, and components. With normal exceptions (turbine building, air

compressor systems cooling, and auxiliary boiler heat loads), the system is within scope under

license renewal. The inspectors reviewed the license renewal boundary drawings, system

descriptions, applicable UFSAR sections, scoping calculations, and application details. The

inspectors determined that the system was appropriately scoped in the application and

associated boundary drawings.

12. Instrument and Service Air (IA, SA)

These air systems provide air for normal system operations and outage uses. Their critical

functions for other off normal conditions identified during the licensee renewal scoping review are

pressure boundary interface for other systems and containment penetration integrity. Off-normal

gas motive force for critical component operation (e.g., steam generator power operated relief

valves) is provided by nitrogen systems, the not-in-scope instrument air, or by instrument air

contained in pressurized accumulators isolated by check valves (e.g., main steam isolation

valves). The inspectors reviewed the license renewal boundary drawings, system descriptions,

applicable UFSAR sections, generic interface documents, scoping calculations, and application

details. The inspectors determined that the systems were appropriately scoped in the application

and associated boundary drawings.

6

13. Containment Spray (CS)

The CS system in conjunction with the Containment Air Recirculation System limit the

temperature and pressure in containment following a steam line break or loss of coolant accident

to less than design values. The CS systems pumps and spray nozzles can deluge the

containment with borated water combine with educted sodium hydroxide during its injection

phase. The system can be cooled by the residual heat removal system for long term containment

cooling. The inspectors reviewed the license renewal boundary drawings, system descriptions,

applicable UFSAR sections, scoping calculations, and applications details. The inspectors

determined that the systems were appropriately scoped in the application and associated

boundary drawings.

14. Auxiliary Feedwater System (AFW)

This system supplies feedwater to the steam generators when normal feedwater sources are not

available. The components included in the LR scope for aging management review included the

Condensate Storage Tanks as the normal water source and the service water system as the

safety related, assured source. The Deep Well pumps are an alternate source referenced in the

UFSAR. The inspectors questioned why the Deep Well pumps and piping were not included in

the LR scope. The applicants position was that this equipment does not provide a safety related

water source and therefore does not meet the LR scoping criteria. This issue is addressed in RAI

2.3.3.8-1 and 2.3.4.9-1 which is presently under review by the NRC.

Other in scope equipment is identified in LRA table 2.3-29. The inspectors reviewed the

applicants identification and resolution of criterion 2 (NSR equipment potentially affecting LR in-

scope equipment) related to the AFW system, field verified these conditions where possible, and

concluded the resolutions were acceptable. The inspectors reviewed the system scoping and

screening documents, design basis information, applicable UFSAR sections and the system

boundary drawings. The inspectors concluded that the applicant had performed scoping and

screening for this system in accordance with the LRA and the Rule.

15. Main Feedwater System

The main feedwater system provides pre-heated, high pressure feedwater to the steam

generators under normal operating conditions. The license renewal function of the system is to

provide isolation of the feedwater and steam generator blow down following a postulated loss of

coolant or steam line break event. The components identified as within LR scope and requiring

aging management review are identified in Table 2.3-28 of the application. The inspectors

reviewed the system scoping and screening documents, design basis information, applicable

UFSAR sections, and boundary drawings. The inspectors concluded the Applicant had

performed scoping and screening for this system in accordance with the LRA and the Rule.

16. Containment Isolation System

The Containment Isolation System is an engineered safety feature that provides for the closure

integrity of containment penetrations in the event of a reactor accident to prevent leakage of

uncontrolled or unmonitored radioactive materials to the environment. The following systems

have only the license renewal function of containment isolation:

Post Accident Hydrogen

Service Air System

7

Process/Area Radiation Monitoring

Containment Pressure Relief

Containment Vacuum Breaker

Containment Purge

Containment Vapor and Pressure Sampling

Liquid Waste Processing

Penetration Pressurization Local Leak Rate Test

Isolation Valve Seal Water.

Table 2.3-6 of the Application identified the components of these systems which are in scope for

LR and require aging management review. The inspectors reviewed the system scoping and

screening documents, design basis information, applicable UFSAR sections and the boundary

drawings. The inspectors reviewed the Criterion 2 (NSR equipment potentially affecting LR in-

scope equipment) related to these systems and concluded the identification and resolution of

Criterion 2 equipment was acceptable. The inspectors concluded that the applicant had

performed scoping and screening for this system in accordance with the LRA and the Rule.

17. Post Accident Sampling

The Post Accident Sampling System provides a means to remotely collect, analyze, and dilute,

reactor coolant and containment atmosphere samples. The only component within the LR scope

is the sample heat exchanger which is cooled by the Component Cooling System and is included

in application Table 2.3-9 as an in-scope component in that system. The inspectors reviewed the

system scoping and screening documents, design basis information, applicable UFSAR sections

and the boundary drawings. The inspectors concluded that the applicant had performed scoping

and screening for this system in accordance with the LRA and the Rule.

18. Heating, Ventilation, and Air Conditioning (HVAC) - Auxiliary Building

This system provides heat removal of equipment spaces to ensure proper operation of safety

related equipment in the Auxiliary Building. The system components included in the scope of LR

and requiring aging management review are identified in Table 2.3-18 of the application. The

inspectors reviewed the system scoping and screening documents, design basis information,

applicable UFSAR sections and the boundary drawings. The inspectors concluded that the

applicant had performed scoping and screening for this system in accordance with the LRA and

the Rule.

19. HVAC - Containment Building (Containment Air Re-circulation Cooling System)

This system functions as an independent back up for the Containment Spray System to limit the

temperature and pressure that could be experienced in containment following a loss-of-coolant or

steam line break event to less than the design values. Heat removed by the system is

transferred to the Service Water System via four air handling unit heat exchangers. The system

components included in the scope of LR and requiring aging management review are identified in

Table 2.3-5 of the Application. The inspectors reviewed the system scoping and screening

documents, design basis information, applicable UFSAR sections and the boundary drawings.

The inspectors concluded that the applicant had performed scoping and screening for this system

in accordance with the LRA and the Rule.

8

20. HVAC - Control Room Area

This system provides heating, ventilation, cooling, filtration, air intake and exhaust isolation during

normal operation and following a design basis event. The system consists of an environmental

control system and an air clean up system. The system components included in the scope of LR

and requiring aging management review are identified in Table 2.3-19 of the application. The

inspectors reviewed the system scoping and screening documents, design basis information,

applicable UFSAR sections and the boundary drawings. The inspectors concluded that the

applicant had performed scoping and screening for this system in accordance with the LRA and

the Rule.

21. HVAC - Fuel Handling Building

This system provides ventilation and heat removal for the fuel handling building and filters

exhaust air from the building. The system components included in the scope of LR and requiring

aging management review are identified in Table 2.3-20 of the Application. The inspectors

reviewed the system scoping and screening documents, design basis information, applicable

UFSAR sections and the boundary drawings. The inspectors concluded that the applicant had

performed scoping and screening for this system in accordance with the LRA and the Rule.

22. Emergency Diesel Generator Room CARDOX System

This system is a high pressure carbon dioxide fire suppression system to extinguish a fire in the

diesel generator rooms. The system is automatically actuated from heat sensors located in the

rooms and is supplied from nineteen 75-pound CO2 cylinders located outside the room. The

system components included in the scope of LR and requiring aging management review are

identified in Table 2.3-21 of the application. The inspectors reviewed the system scoping and

screening documents, design basis information, and applicable UFSAR sections and observed

the material condition of the equipment in the plant. The inspectors concluded that the applicant

had performed scoping and screening for this system in accordance with the LRA and the Rule.

23. HVAC - Radwaste Facility

This system provides ventilation and heating for the radwaste facility The inspectors reviewed the

system description in the UFSAR, flow diagrams, and discussed the system function with the

applicant staff. There were no functions of the system that met the criteria for LR scoping. The

inspectors concluded that there was adequate basis for exclusion of this system from the LR

scope.

24. HVAC - Turbine Building

This system provides air conditioned and filtered air to the enclosed utility spaces under the

turbine concrete pedestal including the RCA access area which is located in the turbine building.

The inspectors reviewed the system description in the UFSAR, flow diagrams, and discussed the

system function with the applicant staff. The inspectors concluded that there was adequate basis

for exclusion of this system from the LR scope.

B. Evaluation of Scoping and Screening of Electrical Systems

The inspectors observed that the scoping and screening of electrical systems employed

significantly different methods than the mechanical or structural disciplines. During this

9

inspection the inspectors reviewed an Engineering Evaluation report RNP-L/LR-0120, Rev. 3,

3/12/03, Electrical Component Screening for License Renewal for H.B. Robinson - Unit 2. The

procedure described how the applicant accomplished scoping and screening of electrical

commodities to determine those needing an aging management review.

The method used to determine which electrical and I&C components are subject to an aging

management review was organized based on component commodity groups. The primary

difference in this method versus the one used for mechanical systems and structures is the order

in which the component scoping and screening steps are performed. This method was selected

for use with the electrical and I&C components since most electrical and I&C components are

active, thus, the applicant concluded that this method provided the most efficient means for

determining electrical and I&C components that require an aging management review. The

method is consistent with the industry guidance documented in NEI 95-10.

Electrical/I&C component commodity groups associated with electrical, I&C, and mechanical

systems within the scope of license renewal were identified. This step included a complete

review of design drawings and electrical/I&C component commodity groups in the plant

component database. A description and function for each of the electrical/I&C component

commodity groups were identified. The electrical/I&C component commodity groups that perform

an intended function without moving parts or without a change in configuration or properties

[screening criterion of 10 CFR 54.21(a)(1)(i)] were identified. For the resulting passive

electrical/I&C component commodity groups, component commodity groups that are not subject

to replacement based on a qualified life or specified time period [screening criterion of 10 CFR 54.21(a)(1)(ii)] were identified as requiring an aging management review. Electrical and I&C

component commodity groups included in the 10 CFR 50.49 Environmental Qualification (EQ)

Program were considered to be subject to replacement based on qualified life, and thus

eliminated from the list. Next certain passive, long-lived electrical/I&C component commodity

groups that do not support license renewal system intended functions were eliminated. Finally

the in-scope equipment identified as requiring an aging management review were compared to

the NRCs Generic Aging Lessons Learned report to ensure that differences are valid and

justified. The resulting list of electrical and I&C component commodity groups subject to an aging

management review was:

1) Bus Duct - Isolated Phase (Iso-Phase), Non- segregated 4.16 KV and 480 V bus duct

2) Non-EQ Electrical / I&C penetration Assemblies - 28 total - all manufactured by Crouse-Hinds.

3) Non-EQ Insulated Cables and Connectors - All plant systems and structures - includes splices,

fuse blocks, connectors and terminal blocks.

4) Passive Electrical Switchyard Commodities - Credited for restoration of offsite power when

recovering from an SBO event - includes iso-phase bus duct, non-segregate 480 V bus duct, high

voltage insulators, switchyard bus, and transmission conductors. The inspectors found the

methodology and the conclusions reached by the applicant to be satisfactory.

In a response to an NRC RAI concerning recovery from Station Blackout (SBO), the applicant

stated that consistent with the NRC position, the additional structural components included in the

scope of license renewal as meeting the scoping criteria of 10 CFR 54.4(a)(3) for restoration of

offsite power are as follows:

Building 175: Switchyard Relay Building

10

Isolated phase bus duct yard support structures

Switchyard and transformer structures

4 KV non-segregated bus duct yard support

The inspector found that the proposed response to RAI 2.5.2-1 regarding fuse holders needed

clarification and enhancement to reflect information contained in the applicants Calculation No.

RNP-L/LR-0390, Attachment S, Evaluation of fuse holders, Revision 1.

C. Evaluation of Scoping and Screening of Structural Components

1. Reactor Containment Building

The Reactor Containment Building is a seismic class I structures with a steel lined concrete

vertical cylinder, a hemispherical dome, and a flat base mat which is supported on piles. The

Reactor Containment Building houses the reactor vessel, reactor coolant system, and other

safety related systems. The entire building was concluded to be within the scope of license

renewal. Procedure EGR-NGGC-0502, System/Structure Scoping for License Renewal,

describes the scoping process. Calculation RPN-L/LR-0007, System/Structure Scoping for

License Renewal, performs the actual scoping for all systems and structures. Attachments to

Calculation RPN-L/LR-007 are called System/Structure Scoping Worksheets which list the

scoping results for all systems and structures. Attachment 166 lists the scoping results of the

Reactor Containment Building.

Calculation RPN-L/LR-0104, License Renewal Screening - Containment Structure Internal and

External Structural Components, addresses the screening of the Reactor Containment Structure,

Internal Structural Components, and the External Structural Components. Procedure EGR-

NGGC-0506, Civil/Structural Screening and Aging Management Review for License Renewal,

describes the screening process. Attachment 1 to Calculation RPN-L/LR-0104 addresses the

detailed screening of the commodities, namely the concrete, the steel, the pipe piles, the steel

liner, the penetration assemblies, post tension system, liner insulation, cathodic protection

system, and component supports. Attachments 1.1 and 1.2 list the components and structural

commodity screening matrix, respectively. Only active and components or structures without a

safety intended function are screened out. The inspectors agreed with this assessment.

2. Switchyard Relay Building, Switchyard and Transformer Structures

The Switchyard and Transformers together with the Switchyard Relay building were originally

assessed to not be within the scope of license renewal by the applicant as contained in Table 2.2-

2 of the LRA. In response to RAI 2.5.1-1, the applicant, due to SBO considerations, determined

that these structures are within the scope of license renewal.

11

Attachments 145 and 146 to Calculation RPN-L/LR-0007 list the scoping results of the Switchyard

Relay Building and the Switchyard and Transformer Structures, respectively. The Switchyard

Relay Building is a prefabricated metal building with doors supported on a concrete slab. The

Switchyard and Transformer Structures include those which support electrical equipment in the

Switchyard and Transformer System. Civil structures include the concrete foundations and

supporting steel structures for all electrical equipment, towers, poles, and the switchyard cable

trenches. In addition, underground electrical conduit and yard electrical panels are also included.

Attachment 32 to Calculation RPN-L/LR-0103, License Renewal Screening - Structures and

Structural Components, describes that the Switchyard and Transformer Structures are outside of

the plant but relied upon for restoration of offsite power to support SBO. The electrical equipment

includes part of the 230KV and 115KV switchyards, the overhead lines to the plant, the main,

start-up and unit auxiliary transformers. The civil/structural components include the concrete

foundations to all the electrical equipment and the steel supports. Attachment 32.2 lists the

structure commodity screening matrix.

Attachment 34 to Calculation RPN-L/LR-0103 describes the Switchyard Relay Building which

houses and supports the batteries which provide 125V DC to equipment in the switchyard.

Figure 34.1 depicts the locations of the structure and Attachment 34.2 lists the structure

commodity screening matrix for the Switchyard Relay Building. The inspectors concurred with

the assessment. The inspectors walked down the in scope portion of the switchyard structures

and structural components and found they are in good material condition.

3. Reactor Auxiliary Building

The Reactor Auxiliary Building (RAB) is a reinforced concrete seismic class I structure supported

on a piling foundation. It includes the control room, and the diesel generator room. The RAB

also includes the RHR room, the radiation monitor room, and the waste evaporation enclosure.

Attachment 211 of Calculation RPN-L/LR-0007 describes that the RAB has several intended

safety functions and the entire building is within the scope of license renewal.

Attachment 01 of Calculation RPN-L/LR-0103 contains the screening process and results. The

structural components screening matrix are listed in Attachment 1.1 and the structural commodity

screening matrix appears in Attachment 1.2. Figure 1.1 through 1.4 depict the evaluation

boundary of the RAB. The process screened out the station C battery enclosure, the elevator

on the east side of the RAB, and the external stairways as not requiring an aging management

review. The inspectors agreed with this decision.

4. Pipe Restraint Tower

Attachment 208 of Calculation RPN-L/LR-0007 describes the Pipe Restraint Tower as a structural

steel frame supported by a reinforced concrete foundation. It provides access to components

and pipe whip restraint in case of a high energy line break outside the containment for the main

steam and feedwater lines. The Pipe Restraint Tower supports the main steam safety relief and

12

isolation valves and the feedwater isolation valves. The applicant determined that the entire Pipe

Restraint Tower is within the scope of license renewal. The only commodities screened out are

stairs and ladders, jet impingement barriers, and snubbers. The inspectors concurred with this

assessment.

5. Plant Vent Stack

Attachment 224 of Calculation RPN-L/LR-0007 briefly describes that the plant Vent Stack is a 4-

6" diameter ventilation stack located at east quadrant of the Reactor Containment Building. The

stack is supported on the Reactor Auxiliary Building roof and braced from the Reactor

Containment Building by a structural steel frame at a higher elevation. Drawing CAR-2767G-211

depicts that the stack is made of 3/16" carbon steel (A36) and there is no safety related

equipment located in the proximity of the stack. The failure of the stack will not damage any

safety related structure or component. The stack itself is non-safety related and does not

perform any license renewal intended function. The applicant correctly assesses that the Plant

Vent Stack is not within the scope of license renewal. The inspectors walked down the vicinity of

the Plant Vent Stack and agreed with the applicants assessment.

6. Intake Structure

The Robinson Intake Structure is a seismic class I reinforced concrete structure. The structure

consists of three separate bays and supports four safety related service water pumps, three non-

safety related circulating water pumps, and three non-safety related fire pumps. There are three

traveling screens in each bay to remove debris from the intake water. Stop logs, fine, and rough

screens (trash racks) were designed but never were installed due to the cleanliness of the lake

water. The lake water is acid in nature with average pH values varied from 4.6 to 6.4 (measured

from 1985 to 1999) which makes it difficult to grow vegetation. The applicant assesses the Intake

Structure, in Attachment 132 of Calculation RPN-L/LR-0007, to be within the scope of license

renewal due to the fact that the structure performs several license renewal intended safety

functions. In Attachment 4.2 of Calculation RPN-L/LR-0103, the applicant only screens out a few

commodities that do not have to perform an intended safety function. The inspectors concurred

in the assessment. The inspectors walked down the Intake Structure. Most of the structure is

underwater. The above water portion of the structure looked very clean and is in good condition.

7. East Personnel Access Portal

The East Personnel Access Portal was used during construction. After the West Personnel

Access Portal was established, the East Personnel Access Portal was closed and abandoned.

The applicant determined that the East Personnel Access Portal is not within the scope of license

renewal. The inspectors agreed with the assessment.

13

8. West Personnel Access Portal

The West Personnel Access Portal is a prefabricated metal structure with a reinforced concrete

foundation. The West Personnel Access Portal is assessed to be within the scope of license

renewal because it houses and supports electrical equipment which controls and operates the

security lighting. A portion of the security lighting is credited for a fire protection function.

Therefore, the entire structure is in scope and nothing is being screened out within the evaluation

boundary of the structure. The inspectors concurred with this determination.

9. Security Emergency Diesel Generator Building

The Security Emergency Diesel Generator Building is a steel and concrete block structure on a

reinforced concrete foundation. This structure was scoped into the rule for fire protection

because the applicant received from the NRC an exemption from using 8-hour battery lighting

based on the use of security lighting. The security lighting is backed by the security diesel

generator, therefore the entire security lighting system and its supports are all within the scope of

license renewal. Attachment 12.2 of Calculation RPN-L/LR-0103 lists the structural commodities

that require an aging management review. The inspectors concurred with this decision.

10. Fuel Handling Building

The Fuel Handling Building (FHB) is comprised of three adjacent buildings and a super structure,

which supports the spent fuel cask handling machine. The three buildings are the Spent Fuel Pit

Heat Exchanger Room, the Hot Machine Shop, and the Fuel Handling Building, The FHB

performs many license renewal intended functions such as shelter and support for safety related

and non-safety related systems and components. The entire FHB is concluded to be within the

scope of license renewal. The only commodities being screened out are facilities associated with

the new fuel handling and storage and active components as listed in Attachment 3.2 of

Calculation RPN-L/LR-0103. The inspectors agreed with this assessment.

11. Electrical Manholes and Duct Banks

This group includes all yard electrical manholes and duct banks. Only three electrical manholes

are scoped into the rule. They are manholes #35 and #36 and an unnumbered electrical

manhole located west of the Unit 1 Administration Building. There are two manholes at the

Intake Structure and they are considered as part of the Intake Structure. Electrical manholes and

duct banks associated with the security lighting system are scoped and screened separately.

The cables from manholes 35 and 36 are buried directly without duct banks. The manhole are

constructed with reinforced concrete. Commodities associated with these three manholes all

require aging management review. There are no duct banks associated with these structures.

The inspectors concurred with this assessment.

14

12. Reservoir and Dam

The reservoir (Lake Robinson) is a 2200-acre impoundment which provides plant cooling for

normal and emergency situations. It also supplies water for fire protection and is the ultimate

heat sink for the plant. The earth dam has a vertical clay core and supporting shell of compacted

sand. Rip rap protection is provided on the upstream side. There are a spillway, gates, and

valves provided for down stream water release. The applicant determined that the dam and

reservoir are within the scope of license renewal. Figure 13.1 of Attachment 13 to Calculation

RPN-L/LR-0103 depicts the evaluation boundary of the dam and reservoir and Attachment 13.2

lists all the structural commodities that require aging management review. The inspectors

concurred with this determination.

13. Tech Support Center/Emergency Operations Facility (TSC/EOF)

The TSC/EOF Training Building is a reinforced concrete structure used for training, offices, and is

an emergency management facility during plant accidents but does not perform any license

renewal intended safety functions. The applicant assessed that the TSC/EOF is not within the

scope of license renewal. The inspectors agreed with this assessment.

14. Concrete Trenches

This structure is the reinforced concrete trench between the Turbine Building and the Condensate

Storage Tank. The trench continues inside the Turbine Building concrete floor slab and this

portion of the trench is reviewed together with the Turbine Building. The trench is within the

scope of license renewal because it supports and protects safety related and non-safety related

equipment. Figure 24.1 of Attachment 24 to Calculation RPN-L/LR-0103 shows the structure

evaluation boundary. The inspectors concurred with the applicants decision.

15. Tank Foundations

The foundations of the safety related Condensate Storage Tank (CST) and the Refueling Water

Storage Tank (RWST) are reinforced concrete ring structures with a thickness of 3'-6" and a

depth of 5'-0" as they are described in Attachments 128 and 126 of Calculation RPN-L/LR-0007,

respectively. The applicant assessed that the tank foundations are within the scope of license

renewal because they provide structural support to safety related equipment. The evaluation

boundary for the CST foundation is shown in Figure 16.1 0f Attachment 16 to Calculation RPN-

L/LR-0103 and for the RWST foundation is in Figure 15.1 of Attachment 15. The screening

results are listed in Attachments 16.2 and 15.2 of Calc. RPN-L/LR-0103 for the CST and RWST

foundations, respectively. The inspectors walked down the CST foundation and found that the

structure is in good material condition. The inspectors found that the applicants assessment

was acceptable.

15

D. Evaluation of Scoping and Screening of Fire Protection Systems

Fire protection features and commitments are described in detail in the Robinson UFSAR. The

systems and structures at Robinson that support either fire protection design or safe shutdown

following a fire are considered within the scope of license renewal. Those items providing fire

suppression, fire detection, and electrical power supply to that equipment are classified Quality

class B-03 in the EDB. So any system with components classified as B-03 was considered in

scope. Also, safe shutdown components credited in analyses to comply with 10 CFR 50,

Appendix R, are included in the Appendix R Component Database. This database was also used

to identify systems in scope for license renewal. In addition, structures credited in the definition

of fire areas and zones were considered in scope.

The inspectors examined boundary diagrams which show the evaluation boundaries for the

portions of fire protection systems that the applicant concluded are within the scope of license

renewal. The inspectors found no significant discrepancies in the fire protection equipment

highlighted as being in LR scope on the boundary drawings. The inspectors did observe that the

fire protection boundary drawings HBR2-8255LR series sheets 1 through 6 contained a minor

error. The reference to the fire protection screening calculation should have been RNP-L/LR-

0139 instead of RNP-L/LR-0129 which appears on the drawings. The applicant included this

issue in AR 89349 for corrective action.

E. Visual Observations of Plant Equipment in Containment

NRC performed visual inspections of the interior of the Robinson containment on October 24,

2002 during a refueling outage. This included observation of accessible portions of plant SSCs

and electrical cable inside the containment to observe material condition and inspect for aging

conditions that might not have been previously recognized and addressed in the LRA. The

following is a partial list of equipment observed:

FW system piping

personnel and equipment hatches

SGs B and C, including supports

CS spray headers and piping

ventilation ducting

electrical cable

B and C reactor coolant pump cubicles/loop rooms

reactor coolant system piping

CC system piping and valves

containment electrical penetrations

excess letdown heat exchanger

16

reactor vessel head

reactor coolant drain collection tank and piping

pressurizer relief tank

pressurizer surge line and whip restraint

containment pipe penetration area

containment sump area

containment HVAC units

The observations of general material conditions included: inspection of piping components for

evidence of leaks or corrosion, inspection of coatings (piping, tanks, and structural components),

and inspection of electrical cable for indications of deterioration. The material condition of the

Robinson containment was good and no significant aging management issues were identified.

The inspectors could not inspect the steel containment liner due to the unique design of the

Robinson containment. Specifically most of the liner is covered by insulation panels.

Exit Meeting Summary

The results of this inspection were discussed on April 4, 2003, with members of the CPL staff in

an exit meeting open for public observation at the Hartsville Memorial Library. The applicant

acknowledged the findings presented and presented no dissenting comments.

17

ATTACHMENT 1

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Applicant

C. Baucom, Supervisor Licensing

C. Burton, Director Site Operations

T. Cleary, Plant General Manager

T. Clements, Manager Licens Renewal

M. Heath, Supervisor License Renewal

D. McNeill, Supervisor Communications

J. Fletcher, Manager Nuclear Support Services

J. Moyer, Robinson Site Vice President

R. Stewart, Supervisor License Renewal

S. Tally, Mechanical Engineer

NRC

C. Casto, Director Division of Reactor Safety

M. Cora, Project Manager

B. Desai, Senior Resident Inspector

D. Jones, Resident Inspector

S. Mitra, Project Manager

Public

M. Gandy, South Carolina Department of Health

and Environmental Control

LIST OF DOCUMENTS REVIEWED

License Renewal Boundary Drawings

5379-1971LR, Reactor Coolant System Flow Diagram, Sheet 1 Rev. 0, Sheet 2 Rev. 1

18

HBR2-9067LR, Reactor Vessel Level Indicator Switches Flow Diagram, Rev. 0

G-190204CLR, Chemical Feed System Flow Diagram, Rev. 1

G-190234LR, Steam Generator Blowdown and Wet Layup System Flow Diagram, Rev. 1

5379-685LR, Chemical and Volume Control System Purification and Make-Up Flow Diagram,

Sheets 1 & 2 Rev. 1

5379-1485LR, Spent Fuel Pit Cooling System Flow Diagram, Rev. 1

5379-1484LR, Residual Heat Removal System Flow Diagram, Rev. 1

HBR2-8606LR, Sheet 2, Nitrogen Supply System Flow Diagram, Rev. 15

HBR-7063LR, Sheet 1, Flow Diagram Legend, Rev. 13

HBR2-6490LR, Sheet 1, Containment Vapor and Pressure Sampling System Flow Diagram, Rev.

13

G-190199LR, Sheet 1, Service & Cooling Water System Flow Diagram, Rev. 63

G-190199LR, Sheet 2, Service & Cooling Water System Flow Diagram, Rev. 62

5379-376LR, Sheet 1, Component Cooling Water system Flow Diagram, Rev. 34

5379-376LR, Sheet 3, Component Cooling Water system Flow Diagram, Rev. 22

5379-376LR, Sheet 4, Component Cooling Water system Flow Diagram, Rev. 31

G-190261LR, Sheet 1, Penetration Pressurization Flow Diagram, Rev. 26

G-190261LR, Sheet 4, Penetration Pressurization Flow Diagram, Rev. 31

G-190304LR, HVAC - Turb. Fuel , Aux., Reactor & Radwaste Bldgs., sheets 1, 2, 3 & 4, Rev. 1

G-190197LR, Feedwater, Condensate & Air Evacuation System Flow Diagram, sheets 1,3, & 4,

Rev. 1

G-190202LR, Primary & Make-Up Water System Flow Diagram, sheet 3 0f 7, Rev. 0

HBR2-6933LR, Post Accident containment Venting and H2 Recombiner System Flow Diagram,

Rev. 1

5379-920LR, Liquid Waste Disposal System Flow Diagram, sheet 3 of 8, Rev. 0

G-190200LR, Instrument and Station Air System Flow Diagram, sheets 2,3, 5,and 9, Rev. 1

5379-353LR, Primary Sampling System Flow Diagram, Rev. 1

HBR2-8261LR, Post Accident Sample Station Flow Diagram, sheet 1 of 2, Rev. 1

G-190204ALR, Emergency Diesel Generator System Flow Diagram, Sh. 1-3, Rev. 1

G-190204DLR, Fuel Oil System Flow Diagram, Sh. 1-3, Rev. 2, 1, 1

5379-1082LR, Safety Injection System Flow Diagram, Sh. 1-5, Rev. 1, 2, 1, 0, 0

HBR2-8679LR, Dedicated Shutdown Emergency Diesel Generator System Flow Diagram, Sh. 1-

2, Rev. 1, 1

HBR2-8255LR, Fire Protection System, Sh. 1-6

19

Plant Drawings

HBR2-11390, Appendix R and Station Blackout Safe-Shutdown Analysis Flowpath/Boundary

Diagram, Sheet 1 Rev. 3 and Sheet 3 and 12 Rev. 2

A-190301, Sheet 3A (TYP), Main Steam Isolation Valve V1-3A, Rev. 6

HBR2-10618, Sheets 141, 142, Inservice Inspection Drawing Component Coolant System, Rev 3

G-190190, General arrangement Reactor Auxiliary Building - Plans, Rev. 23

G-190272, Reactor Component Cooling Water System Piping Plan, Rev. 11

CAR-2762G-211, Reactor Auxiliary Building Vent Stack Modification, Rev 0

HBR2-9800, Plot Plan, Rev 7

License Renewal Calculations

RNP-L/LR-0003, Fire Protection System/Structure Scoping for License Renewal, Rev. 1

RNP-L/LR-0004, Station Blackout (SBO) System/Structure Scoping for License Renewal, Rev. 3

RNP-L/LR-0006, Non-Safety-Related Equipment Affecting Safety-Related Equipment - License

Renewal System/Structure Scoping, Rev. 2

RNP-L/LR-0007, System/Structure Scoping for License Renewal, Rev. 3

RNP-L/LR-0396, Screening and Aging Management Review Criterion 2 Piping, Rev. 2

RNP-L/LR-0144, System Screening-Reactor Coolant System, Rev. 1

RNP-L/LR-0154, System Screening-Reactor Vessel and Internals, Rev. 0

RNP-L/LR-0153, System Screening-Reactor Vessel Level Indicator Switches, Rev. 0

RNP-L/LR-0155, System Screening-Steam Generator, Rev. 0

RNP-L/LR-0138, System Screening-Steam Generator Blowdown System, Rev. 1

RNP-L/LR-0130, System Screening-Chemical and Volume Control System, Rev. 2

RNP-L/LR-0105, System Screening-Spent Fuel Pool Cooling System, Rev. 0

RNP-L/LR-0112, System Screening-Residual Heat Removal System, Rev. 0

RNP-L/LR-0113, System Screening - Safety Injection System, Rev. 2

RNP-L/LR-0116, System Screening - Diesel Generator System, Rev. 1

RNP-L/LR-0115, System Screening - Dedicated Shutdown Diesel System

RNP-L/LR-0117, System Screening - Fuel Oil System, Rev. 1

RNP-L/LR-0143, System Screening - EOF/TSC Security Emergency Diesel Generator, Rev. 0

RNP-L/LR-0121, License Renewal Mechanical Systems Evaluation Boundaries, Rev. 5

RNP-L/LR-0107, Instrument Air System Screening Calculation, Rev. 0

RNP-L/LR-0132, Component Cooling Water System Screening Calculation, Rev. 2

20

RNP-L/LR-0137, Service Water System Screening Calculation, Rev. 0

RNP-L/LR-0145, System Screening - Containment Pressure Relief System, Rev. 1

RNP-L/LR-0146, Containment Vacuum Breaker System Screening Calculation, Rev. 0

RNP-L/LR-0148, System Screening - Containment Purge System, Rev. 0

RNP-L/LR-0136, System Screening - Primary and Demineralized Water Make-up System, Rev. 1

RNP-L/LR-0129, System Screening - AFW System, Rev. 2

RNP-L/LR-0126, System Screening - Post Accident Sampling System, Rev. 0

RNP-L/LR-0128, System Screening - Primary Sampling System, Rev. 1

RNP-L/LR-0140, System Screening - EDG CARDOX System, Rev. 1

RPN-L/LR-0124, License Renewal - Identification of Civil Commodity Types and Bulk Screening

Criteria, Rev. 3

RPN-L/LR-0103, License Renewal Screening - Structures and Structural Components, Rev. 2

RPN-L/LR-0104, License Renewal Screening - Containment, Rev. 1

RNP-L/LR-0120, Electrical Component Screening for License Renewal for H.B. Robinson - Unit

2 Rev. 3

RNP-L/LR-0390, Evaluation of fuse holders, Rev. 1

License Renewal Procedures

EGR-NGGC-0501, Nuclear Plant License Renewal Program, Rev. 5

EGR-NGGC-0502, System/Structure Scoping for License Renewal, Rev. 3

EGR-NGGC-0503, Mechanical Component Screening for License Renewal, Rev. 5

EGR-NGGC-0506, Civil/Structural Screening and Aging Management Review for License

Renewal, Rev. 3

System Descriptions

SD-002, Safety Injection System, Rev. 10

SD-005, Emergency Diesel Generators, Rev. 7

SD-056, Dedicated Shutdown System and TSC/EOF/PAP Diesel Generator System, Rev. 2

DBD/R87038/SD32, Design Base Document - Auxiliary Feedwater System, Rev. 6

SD-043, System Description - Diesel Generator Fire Suppression System, Rev.1

SD-015, System Description - Sampling System, Rev. 4

SD-019, System Description - Radiation Monitoring System Rev. 4

DBD/R87038/SD36. Design Base Document - Post Accident HVAC Systems, Rev. 6

21

SD-023, Waste Disposal System, Rev. 3

SD-037, Containment HVAC, Rev.5

Plant Procedures

OP-909, Fuel Oil System, Rev. 30

Support References

Robinson Nuclear Plant License Renewal Application, 6/17/02

H. B. Robinson Updated Final Safety Analysis Report

Technical Specifications Bases Section B 3.8.3, Diesel Fuel Oil and Starting Air

Generic Interface Document GID/90-181/00/RCI, Appendix A Individual Pentration Evaluations,

Revision 2

22

ATTACHMENT 2

H. B. Robinson

LICENSE RENEWAL INSPECTION PLAN

LICENSE RENEWAL SCOPING RESULTS

FOR MECHANICAL SYSTEMS

System Name

System in License

Renewal Scope?

Auxiliary Feedwater (AFW)

Yes

Chemical and Volume Control System

Yes

Component/Closed Cooling Water System

Yes

Containment Pressure Relief System (CVPRS)

Yes

Containment Purge System (CV PUR)

Yes

Containment Spray

Yes

Containment Vacuum Breaker System (CV VBS)

Yes

Containment Vapor and Pressure Sampling System

Yes

Dedicated Shutdown Diesel Generator (DSD)

Yes

Diesel Generator System (DIESEL)

Yes

Emergency Diesel Generator Car Dox System (CARDOX)

Yes

EOF/TSC Security Emergency Diesel Gen. (EOF DG)

Yes

Fire Protection CO2 System (CO2)

Yes

Fuel Oil System (FO)

Yes

Halon Supply System (HALON)

Yes

HVAC Auxiliary Building (HVAC)

Yes

HVAC Containment Building System (HVAC)

Yes

HVAC Control Room Area (HVAC)

Yes

HVAC Fuel Handling Building (HVAC)

Yes

HVAC Radwaste Building (HVAC)

No

HVAC Turbine Building (HVAC)

No

Instrument Air System (IA)

Yes

Isolation Valve Seal Water System (IVSW)

Yes

Liquid Waste Processing System (WDS)

Yes

23

Post Accident Hydrogen System

Yes

Post Accident Sampling System

Yes

Process/Area Radiation Monitoring System (RMS)

Yes

Reactor Coolant System (RC)

Yes

Reactor Vessel and Internals System

Yes

Residual Heat Removal System (RHR)

Yes

Rx Vessel Level Instrumentation / ICCM System

Yes

Safety Injection System

Yes

Service Water System (SW)

Yes

Site Fire Protection System (SFPS)

Yes

Spent Fuel Pool Cooling System (SFPCS)

Yes

Steam Generator

Yes

24

H. B. Robinson

LICENSE RENEWAL INSPECTION PLAN

LICENSE RENEWAL SCOPING RESULTS

FOR STRUCTURES

Structure Name

Structure in License

Renewal Scope?

Bldg 175: Switchyard Relay Building

No

Bldg 200: Reactor Containment Building

Yes

Bldg 205: Reactor Auxiliary Building

Yes

Bldg 300: West Personnel Access Portal (PAP)

Yes

Bldg 310: EOF/TSC Security Emergency Diesel

Generator Building

Yes

Bldg 355: East Personnel Access Portal (PAP)

No

Bldg 410: Tech Support Center/Emergency Operations

Facility (TSC/EOF)

No

Bldg N/A: Intake Structure

Yes

Bldg N/A: Plant Vent Stack

No

Bldg 215, 220, and 225: Fuel Handling Building

Yes

Concrete Trenches

Yes

Electrical Manholes and Duct Banks

Yes

Pipe Restraint Tower

Yes

Reservoir and Dam

Yes

Switchyard and Transformers

No

Tank Foundation: Condensate Storage

Yes

Tank Foundation: Refueling Water Storage Tank

Yes

25

H. B. Robinson

LICENSE RENEWAL INSPECTION PLAN

LICENSE RENEWAL SCOPING RESULTS FOR

ELECTRICAL/I&C SYSTEMS

System Name

System in License

Renewal Scope?

125 V DC Battery/Charger/Distribution System

Yes

208/120 VAC Distribution System

Yes

4 KV AC Distribution System (4KV)

Yes

480 V AC Distribution System (480 VAC)

Yes

Dedicated Shutdown System (DSS)

Yes

Emergency Communications System

No

FCC Licensed Portable Radios (P RAD)

Yes

Fire Alarm Console Computer (FAC)

Yes

Post Accident Monitoring System

Yes

Site Fire Detection System (SFDS)

Yes

Site Grounding System (S GND)

No

Switchyard and Transformer System (SWTR)

No

26

ATTACHMENT 3

LIST OF ACRONYMS USED

AC

Alternating Current

AFW

Auxiliary Feedwater System

AMR

Aging Management Review

AR

Action Request

CCW

Component Cooling Water System

CPL

Carolina Power and Light Company

CS

Containment Spray System

CST

Condensate Storage Tank

CVCS

Chemical and Volume Control System

DG

Diesel Generator

DSDG

Dedicated Shutdown Diesel Generator

ECCS

Emergency Core Cooling Systems

EDB

Equipment Data Base

EQ

Environmental Qualification Program

FHB

Fuel Handling Building

FO

Fuel Oil System

FW

Feedwater System

HVAC

Heating Ventilation and Air Conditioning

IA

Instrument Air

ICCM

Inadequate Core Cooling Monitor System

LR

License Renewal

LRA

License Renewal Application

NSR

Non Safety Related

NRR

NRC Office of Nuclear Reactor Regulation

RAB

Reactor Auxiliary Building

RAI

Request for Additional Information

RCS

Reactor Coolant System

RV

Reactor Vessel

RWST

Refueling Water Storage Tank

SBO

Station Blackout Event

27

SFPC

Spent Fuel Pool Cooling System

SA

Service Air System

SG

Steam Generator

SI

Safety Injection

SR

Safety Related

SSC

Systems, Structures, and Components

SW

Service Water System

UFSAR

Updated Final Safety Analysis Report