ML23235A055

Notification of an Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000261/2023010) and Request for Information (RFI)

ML23235A055
Person / Time
Site:	Robinson
Issue date:	08/23/2023
From:	Daniel Bacon Division of Reactor Safety II
To:	Basta L Duke Energy Progress
References
IR 2023010
Download: ML23235A055 (1)

See also: IR 05000261/2023010

Text

August 23, 2023

Laura Basta

Site Vice President

H. B. Robinson Steam Electric Plant

Duke Energy Progress, LLC

3581 West Entrance Road, RNPA11

Hartsville, SC 29550

SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 - NOTIFICATION OF AN

NRC FIRE PROTECTION TEAM INSPECTION (FPTI) (NRC INSPECTION

REPORT 05000261/2023010) AND REQUEST FOR INFORMATION (RFI)

Dear Laura Basta:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC),

Region II staff will conduct a fire protection team inspection at the H. B. Robinson Steam

Electric Plant, Unit 2 in October 2023. The inspection team will be led by Mr. Philipp Braaten, a

Senior Reactor Inspector from the NRC Region II Office. The inspection team will be comprised

of three inspectors from the NRC Region II office. The inspection will be conducted in

accordance with Inspection Procedure 71111, Attachment 21N.05, Fire Protection Team

Inspection, the NRCs baseline fire protection inspection procedure.

On August 22, 2023, Mr. Braaten contacted Mark Hubbard of your staff and, our respective

staffs confirmed arrangements for a two-week inspection. The schedule for the inspection is as

follows:

Week 1 of inspection: October 16 - 20, 2023

Week 2 of inspection: October 30 - November 3, 2023

The team lead and senior reactor analyst will work with your staff prior to the start of the

inspection to select the scope of structures, systems, and components for evaluation; identify

additional documents needed to support the inspection; and obtain unescorted access.

The enclosure to this letter provides an initial list of the documents the team will need for their

review. We request that your staff transmit copies of the documents listed in the enclosure to

the NRC Region II office for team use in preparation for the inspection. Please send this

information so that it will arrive in the NRC Region II office by the dates listed in the enclosure

During the weeks leading up to the inspection, the team leader will discuss with your staff the

following inspection support administrative details: (1) office space size and location; (2)

specific documents requested to be made available to the team in their office spaces; (3)

arrangements for reactor site access (including radiation protection training, security, safety,

and fitness for duty requirements); and (4) the availability of knowledgeable plant staff and

licensing organization personnel to serve as points of contact during the inspection; (5) the

details for COVID-19 precautions and site policies for COVID-19 (masks, social distancing,

temperature checks, etc.).

L. Basta 2

We request that during the on-site inspection weeks you ensure that copies of analyses,

evaluations, or documentation regarding the implementation and maintenance of the station fire

protection program, including the success path necessary to achieve and maintain the nuclear

safety performance criteria, be readily accessible to the team for their review. Of specific

interest for the fire protection portion of the inspection are those documents which establish that

your fire protection program satisfies NRC regulatory requirements and conforms to applicable

NRC and industry fire protection guidance (i.e., fire protection compliance assessment

documents). Also, personnel should be available at the site during the inspection who are

knowledgeable regarding those plant systems required to achieve and maintain safe and stable

plant conditions, including the electrical aspects of the nuclear safety capability assessment,

reactor plant fire protection systems and features, and the station fire protection program and its

implementation.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget under control

number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

This letter and its enclosure 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Your cooperation and support during this inspection will be appreciated. If you have questions

concerning this inspection or the inspection teams information or logistical needs, please

contact Philipp Braaten, the team lead inspector, in the Region II office at (404) 997-4651 or

philipp.braaten@nrc.gov or me at (404) 997-4551.

Sincerely,

Signed by Bacon, Daniel

on 08/23/23

Daniel Bacon, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-261

License No. DPR-23

Enclosures:

Fire Protection Team Inspection

Document Request

cc w/enclosure: via ListServ

ML23235A055

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive Non-Publicly Available

OFFICE RII/DRS RII/DRS

NAME P. Braaten D. Bacon

DATE 08/23/23 08/23/23

Fire Protection Team Inspection Document Request

The initial request for information (i.e., first RFI) concentrates on providing the inspection team

with the general information necessary to select appropriate samples to develop a site-specific

inspection plan. The first RFIs requested information is specified below in items A.1 thru A.22,

and is requested to be provided by September 8, 2023, or sooner, to facilitate the selection of

the specific items that will be reviewed during the onsite inspection weeks.

Electronic format is the preferred format, except where specifically noted. If electronic files are

made available via a secure document management service, then the remote document access

must allow inspectors to download, save, and print the documents in the NRCs regional office.

If a secure document management service is utilized, it is recommended that a separate folder

be used corresponding to each item listed below. Documents should be identified by both

document number and name. Electronic media on compact disc or paper records (hard copy)

are also acceptable.

The inspection team will examine the returned documentation from the first RFI and

identify/select specific samples to provide a more focused follow-up request to develop the

second RFI. The inspection team will submit the specific selected samples to your staff by

September 15, 2023. We request that the additional information provided from the second RFI

be made available by October 6, 2023.

This document request is based on typical documents that a generic plant might have. As such,

this generic document request is not meant to imply that any specific plant is required to have all

of the listed documents. It is recognized that some documents listed below may not be

available for your plant. In addition, the document titles listed below are based on typical

industry document names; your plant-specific document titles may vary.

A. DESIGN AND LICENSING BASIS DOCUMENTS

A.1 The current version of the Fire Protection Program and Fire Hazards

Analysis

A.2 Post-fire Nuclear Safety Capability, Systems, and Separation Analysis

(NSCA) and the supporting calculations that demonstrate acceptable plant response.

A.3 Fire PRA Summary Report, and list of Fire PRA calculations

A.4 NFPA 805 Transition Report, developed in accordance with NEI 04-02

A.5 List of post-fire safe shutdown systems and components (i.e., safe

shutdown equipment list).

A.6 List of fire areas with automatic fire suppression systems

A.7 List, with descriptions, of design change packages performed since the last

fire protection team inspection associated with fire protection or post-fire safe

shutdown systems.

Enclosure

A.8 List, with descriptions, of any fire protection program changes and

evaluations (not limited to Generic Letter 86-10 evaluations) performed since the last

fire protection team inspection

A.9 Fire Protection System(s) Design Basis Document.

A.10 List of applicable NFPA codes and standards and issuance dates (i.e.,

codes of record).

A.11 A list or document identifying any deviations from the NFPA codes of

record.

A.12 Facility Operating License.

A.13 Technical Specifications (electronic format only).

A.14 Updated Final Safety Analysis Report (electronic format only).

A.15 COPY of NRC Safety Evaluation Reports that form the licensing basis for:

Fire Protection Program; and

Post-fire Nuclear Safety Capability

A.16 COPY of NRC approved exemptions for plant fire protection and post-fire

nuclear safety capability features.

A.17 COPY of exemption requests submitted but not yet approved for plant fire

protection and post-fire nuclear safety capability features.

A.18 LIST of nuclear safety capability design changes completed in the last

three years (including their associated 10 CFR 50.59 and NFPA 805 plant change

evaluations).

A.19 List of the top 25 highest fire CDF scenarios for each unit

A.20 List of the top 25 highest fire LERF scenarios for each unit

A.21 From your most recent PRA including external events and fires:

Two risk rankings of components from your site-specific PRA: one sorted by

Risk Achievement Worth (RAW), and the other sorted by Birnbaum Importance

A list of the top 500 cut-sets

A.22 Copy of the Quality Assurance Program Manual (including specific fire

protection QA manual, if applicable)

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