ML15342A205

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Regulatory Audit in Support of License Amendment Request to Adopt NFPA 805
ML15342A205
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 01/08/2016
From: Martha Barillas
Plant Licensing Branch II
To: Benjamin Beasley
Plant Licensing Branch II
Barillas M
References
CAC MF2746
Download: ML15342A205 (5)


Text

January 8, 2016 MEMORANDUM TO: Benjamin G. Beasley, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Martha Barillas, Project Manager /RA/

Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 -

REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 (CAC NO. MF2746)

Staff from the U.S. Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, Division of Risk Assessment, will conduct an audit to support its review of the H. B. Robinson Steam Electric Plant Unit No. 2 license amendment request to adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants. The audit will occur at the Duke Energy office located in Charlotte, North Carolina, on January 26 and January 27, 2016. The audit plan is enclosed.

Docket No. 50-261

Enclosure:

Audit Plan

ML15342A205 OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/LA NRR/DRA/AFPB/BC NAME DGalvin MBarillas BClayton AKlein (LRonewicz for)

DATE 1/05/2016 1/05/2016 12/16/2015 1/06/2016 OFFICE NRR/DRA/APLA/BC NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME SRosenberg BBeasley MBarillas DATE 1/06/2016 1/08/2016 1/08/2016 AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 DOCKET NO. 50-261

1.0 BACKGROUND

By letter dated September 16, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13267A211), Duke Energy Progress, Inc., the licensee, for the H. B. Robinson Steam Electric Plant Unit No. 2, submitted a license amendment request (LAR) to adopt a new fire protection licensing basis that complies with the requirements of Title 10 of the Code of Federal Regulations, Sections 50.48(a) and (c); the guidance in Regulatory Guide 1.205, Revision 1, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants; and National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition).

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete its review of the LAR regarding the related probabilistic risk assessment (PRA). On November 20, 2015, the NRC staff e-mailed the licensee a request for additional information (RAI) in draft form (ADAMS Accession No. ML15324A328). The NRC staff has determined that it needs to review the methods and models related to the RAI. The staff determined that the most efficient manner to review the methods and models is to review them at the licensees office in Charlotte, North Carolina.

NRRs Office Instruction LIC-111, Regulatory Audits (ADAMS Accession No. ML082900195),

states that a regulatory audit is a planned licensed or regulation-related activity that includes the examination of primarily non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.

2.0 REGULATORY AUDIT BASIS The regulatory bases for this audit are 10 CFR 50.48; RG 1.205, Revision 1; and NFPA 805 (2001 Edition). Additional approved guidance used by the licensee is documented in the LAR.

3.0 REGULATORY AUDIT SCOPE The scope of this regulatory audit is to:

  • Provide the NRC staff a comprehensive understanding of the PRA methods and models that the licensee is proposing to use in response to all PRA RAIs.
  • Review supporting documentation for PRA models and Fire Modeling (FM).

Enclosure

  • Establish an understanding of the draft RAIs provided to the licensee on November 20, 2015 to allow the staff to issue clear request for information and for the licensee to provide quality and timely responses.
  • Establish an understanding of proposed resolution(s) of the audit plan review areas listed in the table below.

4.0 INFORMATION NECESSARY FOR THE AUDIT The information necessary for the audit includes:

  • Access to licensee personnel and/or contractors familiar with the PRA model and FM.
  • Access to all PRA and FM related information and support from licensee staff and contractors in identifying and retrieving relevant documents.

5.0 TEAM ASSIGNMENTS The audit will be conducted by NRC staff from the Office of Nuclear Reactor Regulation, Division of Risk Assessment, PRA Licensing Branch and Fire Protection Branch. The audit team may consult with their contractors from the Pacific Northwest National Laboratories (PNNL) and the Southwest Research Institute (SwRI)/Center for Nuclear Waste Regulatory Analyses (CNWRA) via teleconference. The NRC audit team members will consist of Daniel ONeal, Stephen Dinsmore, Harold Barrett, Leslie Fields (Audit Lead), Alex Klein, Garill Coles (PNNL, NRC Consultant), and Marc Janssens (SwRI/CNWRA, NRC Consultant).

The table below shows the audit schedule.

Audit Milestones and Schedule Activity Timeframe Comments Travel Day 1/25 Discussion and resolution of final RAI responses 1/26- 1/27 (1.5 Onsite Audit Discussion and resolution of any remaining fire PRA safety days) evaluation sections Travel Day 1/27 (afternoon)

Regulatory Audit Team and Assignments SRP 9.5.1.2 Audit Plan Review Areas Lead Support Section Operations guidance for fire modeling performance-III.3.2.2 H. Barrett G. Coles (via phone) based method III.5.3-5.6 Risk assessments D. ONeal S. Dinsmore III.5.1 PRA technical adequacy D. ONeal S. Dinsmore III.5.2 Defense-in-depth and safety margins Team Team

6.0 LOGISTICS This regulatory audit is planned for January 26-27, 2016, to be held at Duke Energy offices in Charlotte, North Carolina. This is a followup audit to establish an understanding of an area where the staff has identified potential concerns to allow the staff to issue clear and final RAIs and for the licensee to provide quality and timely responses. The audit is also intended to establish an understanding of proposed resolutions to the staff concerns. Therefore, the NRC staff is not planning on holding formal entrance and exit meetings. Technical discussions will be held daily.

7.0 SPECIAL REQUESTS The regulatory audit team will require the following to support the regulatory audit:

  • Private conference room(s) with telephone conferencing capability to support the discussions and review.
  • Wired and/or wireless internet access.

8.0 DELIVERABLES After the audit, the NRC staff will finalize the RAI(s) provided in draft form to the licensee on November 20, 2015. The staff will issue an audit report within 90 days of the completion of the audit.