ML23235A055
| 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
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.).
August 23, 2023
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,
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
Signed by Bacon, Daniel
on 08/23/23
xSUNSI Review
x
Non-Sensitive
Sensitive
x
Publicly Available
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
Enclosure
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.
2
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:
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)