ML21342A212
| 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
X
SUNSI Review
X
Non-Sensitive
Sensitive
X
Publicly Available
Non-Publicly Available
OFFICE
RII/DRS
RII/DRS
NAME
D. Strickland
S. Shaeffer
DATE
12/06/2021
12/08/2021
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000261
License Number:
Report Number:
Enterprise Identifier: I-2021-404-0006
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
2
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
Aspect
Report
Section
Security
Green
Open
None
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.
3
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.
4
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
Aspect
Report
Section
Security
Green
Open
None
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.
5
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.
6
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
02217937
07/11/2018
02403141
10/26/2021
Engineering
Evaluations
CSD-SY-RNP-
0130-02
10/25/2021
Procedures
AD-SY-ALL-0120
1
AD-SY-ALL-0130
3
31