ML21342A212

Security Baseline Inspection Report 05000261/2021404

ML21342A212
Person / Time
Site:	Robinson
Issue date:	12/08/2021
From:	Scott Shaeffer NRC/RGN-II/DRS/EB2
To:	Remick J Duke Energy Progress
References
IR 2021404
Download: ML21342A212 (9)

See also: IR 05000261/2021404

Text

December 8, 2021

Mr. Jeffrey Remick

Director, Nuclear Plant Security

Duke Energy Progress, LLC

3581 Robinson Steam Electric Plant

3581 West Entrance Road (RNPA12)

Hartsville, SC 29550

SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - SECURITY BASELINE

INSPECTION REPORT 05000261/2021404

Dear Mr. Remick:

On October 29, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at H.B. Robinson Steam Electric Plant. On October 27, 2021, the NRC inspectors 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.

One finding of very low security significance (Green) is documented in this report. This finding

involved a violation of NRC requirements. We are treating this violation as a non-cited violation

(NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this

inspection report, you should provide a response within 30 days of the date of this inspection

report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional

Administrator, Region II; the Director, Office of Enforcement; the Director, Office of Nuclear

Security and Incident Response; and the NRC Resident Inspector at H.B. Robinson Steam

Electric Plant.

J. Remick 2

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:

As stated

cc w/ encl: Distribution via LISTSERV

ML21342A212

X Non-Sensitive X Publicly Available

X SUNSI Review

Sensitive Non-Publicly Available

OFFICE RII/DRS RII/DRS

NAME D. Strickland S. Shaeffer

DATE 12/06/2021 12/08/2021

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000261

License Number: DPR-23

Report Number: 05000261/2021404

Licensee: Duke Energy Progress, LLC

Facility: H.B. Robinson Steam Electric Plant

Location: Hartsville, SC

Inspection Dates: October 25, 2021 to October 29, 2021

Inspectors: D. Strickland, Reactor Inspector

Approved By: Scott M. Shaeffer, Chief

Engineering Branch 2

Division of Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting a security baseline 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

Failure to Identify all Target Set Supporting Element Locations

Cornerstone Significance Cross-Cutting Report

Aspect Section

Security Green None 71130.14

NCV 05000261/2021404-01

Open

An NRC identified Green NCV of 10 CFR 73.55(f)(1) was identified with for the licensees

failure to identify all target set element locations of a target set as required by site procedures.

Additional Tracking Items

None.

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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) 2201, Security Inspection Program for

Commercial Nuclear Power Reactors. 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

standards.

SAFEGUARDS

71130.14 - Review of Power Reactor Target Sets

The inspectors evaluated the Security Target Set Program. The following elements were

evaluated:

Review of Power Reactor Target Sets (1 Sample)

(1) [List requirements: 02.02 (a-d, f), 02.03, 02.04 (a-b), 02.05]

Power Reactor Target Sets (1 Sample)

Section 02.01 Review of Events and Logs

The inspector reviewed any licensee event reports, safeguards log entries, and

corrective action program entries since the last Target Set inspection that concern the

target set identification, development, and maintenance program.

Section 02.02 Target Set Identification and Development Process Review

The inspector assessed the licensee's documentation and maintenance of the

process used to develop and identify complete and accurate target sets as required

by 10 CFR Part 73 by reviewing applicable portions of procedures and samples of

records and conducting interviews with responsible personnel and plant employees.

Section 02.03 Verification of Target Sets Changes

The inspector reviewed changes to the licensees documented target sets since the

last Target Set inspection. The inspector verified that any design modifications and

procedure or configuration changes that have occurred were appropriately

documented in the site's target sets.

Section 02.04 Verification of Complete and Accurate Target Sets

The inspector interviewed licensee personnel and reviewed a sample of target sets

for reactor operation and for modes other than operation. The inspector reviewed

assumptions used in the licensees development of its target sets.

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Section 02.05 Physical Protection Program Review

The inspector verified that the licensee performed a review of target sets for

accuracy, completeness, and applicability at least every 24 months and as otherwise

required, documented the results and recommendations, and entered findings in the

sites corrective action program (CAP).

INSPECTION RESULTS

Failure to Identify all Target Set Supporting Element Locations

Cornerstone Significance Cross-Cutting Report

Aspect Section

Security Green None 71130.14

NCV 05000261/2021404-01

Open

An NRC identified Green NCV of 10 CFR 73.55(f)(1) was identified with for the licensees

failure to identify all target set element locations of a target set as required by site

procedures.

Description: Licensee procedure AD-SY-ALL-0130, Development and Maintenance of

Target Sets Revision 1, establishes the requirements, responsibilities, and administrative

process for identification, analysis, revision and maintenance of Robinson's target set

program to meet the requirements found in 10 CFR 73.55. According to the Target Set

Information Worksheet Template provided in AD-SY-ALL-0130, the licensee is required to

document the locations of target set element locations that would be both identifiable and

accessible by an adversary.

On October 26, 2021, while the NRC inspectors were performing walkdowns of target set

elements, the team observed that the licensee did not identify all locations of a supporting

target set element from which an adversary could compromise it. The new locations would

be identifiable and accessible by an adversary and was therefore required to be documented

in the Target Set Notebook.

Following discussions with the licensee, the inspectors noted the deficiencies in the target

sets would not result in any changes to the licensees protective strategy.

Corrective Actions: The licensee entered the deficiency into their correction action program

as CR-02403256

Performance Assessment:

Performance Deficiency: Failure to document and maintain the process used to develop and

identify target sets, to include the site-specific analysis and methodologies used to determine

and group the target set equipment or elements

Screening: The inspectors determined the performance deficiency was more than minor

because if left uncorrected, it would have the potential to lead to a more significant safety

concern. Specifically, the failure to identify all TS component locations may lead the security

force to not place protection priority on specific plant areas. And an adversary attack at these

locations could lead to core damage.

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Significance: The inspectors assessed the significance of the finding using Appendix E, Part

I, Baseline Security SDP for Power Reactors. The inspectors determined that the finding

met the criteria in section 8.0, Evaluating Target Set Findings (Figure 6) since all target set

findings are screened IAW this section and with the Figure 6 SDP flow chart. The licensee did

not adequately document and maintain the process used to develop Target Sets as described

in section 8.04 of the SDP. Specifically, the finding was screened to green because the

licensees process did not identify target set supporting elements and/or locations as

described in section 8.04(a).

Cross-Cutting Aspect: None

Enforcement:

Violation: 10 CFR 73.55(f)(1) states that the licensee shall document and maintain the

process used to develop and identify target sets, to include the site-specific analysis and

methodologies used to determine and group the target set equipment or elements

Contrary to the above, the licensee failed to adequately implement the requirements of 10

CFR 73.55(f)(1). Specifically, the licensee failed to maintain the process used to develop

target sets by not including all target set element locations that could be compromised by an

adversary.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 27, 2021, the inspectors presented the security baseline inspection results

to Jeffrey Remick and other members of the licensee staff.

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DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.14 Corrective Action 02217937 07/11/2018

Documents 02403141 10/26/2021

Engineering CSD-SY-RNP- 10/25/2021

Evaluations 0130-02

Procedures AD-SY-ALL-0120 1

AD-SY-ALL-0130 3

AOP-034 31

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