IR 05000261/2010007

IR 05000261-10-007, on 03/15 - 19/2010 and 03/29 - 4/1/2010, H.B. Robinson Steam Electric Plant, Unit 2; Fire Protection

ML102250047
Person / Time
Site:	Robinson
Issue date:	08/11/2010
From:	Nease R NRC/RGN-II/DRS/EB2
To:	Mccartney E Carolina Power & Light Co
References
IR-10-007
Download: ML102250047 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ust 11, 2010

SUBJECT:

ROBINSON NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000261/2010007

Dear Mr. McCartney:

On April 1, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your H.B. Robinson Steam Electric Plant Unit 2. The enclosed inspection report documents the inspection results, which were discussed with you and other members of your staff. Following completion of additional review in the Region II office, another exit meeting was held by telephone on May 13, 2010 and June 29, 2010 with Garrett Sanders and other members of your staff to discuss the final disposition of the inspection results.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRC's

"Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS

CP&L 2 is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA Rebecca L. Nease, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-261 License Nos.: DPR-23

Enclosure:

Inspection Report 05000261/2010007 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-261 License Nos.: DPR-23 Report Nos.: 05000261/2010007 Licensee: Carolina Power & Light Facility: H.B. Robinson Steam Electric Plant, Unit 2 Location: Hartsville, South Carolina Dates: March 15 - 19, 2010 (Week 1)

March 29 - April 2, 2010 (Week 2)

Inspectors: S. Walker, Senior Reactor Inspector (Lead Inspector)

P. Braxton, Reactor Inspector F. Ehrhardt, Senior Operations Examiner (first week only)

P. Fillion, Senior Reactor Inspector (March 29 & 30 only)

R. Rodriguez, Senior Reactor Inspector (first week only)

L. Suggs, Reactor Inspector G. Wiseman, Senior Reactor Inspector Approved by: Rebecca L. Nease, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000261/2010-007; 03/15 - 19/2010 and 03/29 - 4/1/2010; H.B. Robinson Steam Electric

Plant, Unit 2; Fire Protection.

This report covers an announced two-week period of inspection by a triennial fire protection team composed of seven regional inspectors. No findings of significance were identified. The United States Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

None

Licensee Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R05 Fire Protection

This report presents the results of a triennial fire protection inspection of the H.B.

Robinson Steam Electric Plant (RNP) Unit 2. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05TTP, Fire Protection-National Fire Protection Association (NFPA) 805 Transition Period (Triennial), dated December 24, 2009. The objective of the inspection was to review a minimum sample of 3 risk-significant fire areas to verify implementation of the fire protection program (FPP) and to verify site specific implementation of at least one B.5.b mitigating strategy as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The three fire areas (FAs) and associated fire zones (FZs) were selected after reviewing available risk information as analyzed by a Senior Reactor Analyst from Region II, previous inspection results, plant walk downs of fire areas, relational characteristics of ignition sources to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD)of the reactor. In selecting the B.5.b mitigating strategy sample, the team reviewed licensee submittal letters, safety evaluation reports, licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-05 of the IP specifies a minimum sample size of three fire areas and one B.5.b implementing strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure. The specific FAs/FZs chosen for review were:

FA 5 (FZ 16), Train A/Train B Battery Room

FA G1 (FZ 25E), 4160 V & 480 V Switchgear Area in Turbine Building

FA A3 (FZ 7), Auxiliary Building Hallway The team evaluated the licensee=s FPP against applicable requirements, including RNP Unit 2 Renewed Operating License Condition 3.E, Fire Protection; Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix R, Fire Protection Program For Nuclear Power Facilities Operating Prior To January 1, 1979; 10 CFR 50.48; commitments to Appendix A of Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1; RNP Updated Final Safety Analysis Report (UFSAR); related NRC safety evaluation reports (SERs); and plant Technical Specifications. The review of the B.5.b mitigating strategies was based on the RNP Unit 2 B.5.b submittal letters, related NRC Safety Evaluation Reports, licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports.

The team evaluated all areas of this inspection, as documented below, against these requirements. Specific licensing basis documents reviewed are listed in the Attachment.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the Appendix R Safe Shutdown Analysis (SSA) and the dedicated shutdown procedures (DSP) to verify that equipment required for post-fire safe shutdown was adequately protected from fire damage in accordance with 10 CFR Part 50, Appendix R Section III.G.2. The reviews were performed to verify that hot and cold shutdown could be achieved and maintained from the main control room (MCR) with and without the availability of offsite power for postulated fires in FA G1, FZ 25E. The inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation, and support system functions. The team reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage.

Methodology The team selected a sample of SSD components that were required to be operable for post-fire safe shutdown for a postulated fire in the selected FA/FZ. The team reviewed the component cable routing (i.e., power and/or control circuits by fire area) to determine if the SSD components could be potentially damaged and made inoperable by a fire in the selected FAs/FZs. The selected sample of SSD components included in the review is listed in the Attachment. As for those fire areas where the licensee had implemented operator manual actions (OMAs) in lieu of cable raceway protection per 10 CFR Part 50, Appendix R, Section III.G.2, the inspectors verified the OMAs were feasible utilizing the guidance of Attachment 2 to IP 71111.05TTP.

Operational Implementation The team reviewed the adequacy of the DSPs utilized for post-fire SSD from the MCR for a postulated fire in FA G1, FZ 25E. The review was performed to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain SSD conditions. The team assessed the timeliness of the operators in identifying and assessing the initial plant conditions, response to suspected fire, and subsequent actions credited afterwards. The team performed a walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The inspectors verified the licensee personnel credited for procedure implementation had procedures available, were trained on implementation, and were available in the event a fire occurred. The team also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits. The team reviewed and walked down applicable sections of the following fire response DSPs:

• DSP-001, Alternate Shutdown Diagnostic

• DSP-015, Hot Shutdown from the Control Room with a Fire in the Turbine Building

b. Findings

No findings of significance were identified.

.02 Passive Fire Protection

a. Inspection Scope

For the selected FAs/FZs, the team evaluated the adequacy of fire barrier walls, ceilings, floors, mechanical and electrical penetration seals, fire doors, and fire dampers. Where applicable, the team examined installed configurations to the approved construction details, and supporting fire endurance test data, which established the fire resistance ratings of the selected fire barriers. The team reviewed licensee evaluations of the non-standard fire barrier penetration seals for FA A3 (FZ 7) and FA 5 (FZ 16). In addition, the team reviewed licensing bases documentation, such as NRC Safety Evaluation Reports (SERs) and deviations from NRC regulations, to verify that passive fire protection features met license commitments.

The team inspected the material condition and as-built configuration of accessible passive fire barriers surrounding and within the FZs selected for review to evaluate the adequacy of the fire resistance in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, and Appendix A of BTP APCSB 9.5-1. The team reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the seal material was of the appropriate fire rating. A sample of completed surveillance and maintenance procedures for selected fire doors, fire dampers, and penetration seals was reviewed to ensure that these passive fire barrier features were properly inspected and maintained. Additionally, the team verified that the as-built configurations met the engineering design, standard industry practices, and were properly evaluated or qualified by appropriate fire endurance tests. The fire protection features included in the review are listed in the Attachment.

b. Findings

No findings were identified.

.03 Active Fire Suppression

a. Inspection Scope

The teams review of active fire suppression included the fire detection systems, fire protection water supply system, automatic fire suppression systems and manual fire fighting fire hose and standpipe systems. The inspection of fire detection systems included a review and walk-down of the as-built configuration of the systems as compared to the applicable NFPA standard. In general, the acceptance criteria applied to active fire suppression systems were contained in applicable codes and standards listed in the Attachment as modified by the design basis documents.

The team inspected the material condition, and operational lineup of fire detection and fire suppression systems through in-plant observation of systems, design and testing of the sprinkler systems in reference to the applicable NFPA codes and standards. The team also reviewed the detection and suppression methods for the category of fire hazards in the selected FAs/FZs. The locations of sprinkler heads in FZ 7 were checked for obstructions, which consisted of reviewing the system layout drawings against the field installation. The redundancy of fire protection water sources and fire pumps to fulfill their fire protection function to provide adequate flow and pressure to hose stations and automatic suppression systems were reviewed as compared to licensing basis requirements. Additionally, the team performed inspections of smoke control equipment availability and condition, hose station locations, hose lengths, and nozzle types.

Particular attention was given to location and capacity of hose stations and approach routes to the FZs. The hose stations, as designated in the pre-fire plans for the selected FZs, were reviewed to assess whether adequate reach and coverage was provided.

The team reviewed and walked down operational aspects of the fire detection system such as the location of panels and alarms. The team compared the detector layout drawings against actual detector field locations, NFPA Code 72E, Automatic Fire Detectors, spacing, and placement requirements. The testing and maintenance program and its implementation for the fire detection system were also reviewed. Specific fire brigade attributes evaluated were:

(1) staffing, training, and response strategies; (2)utilization of pre-fire planning;

(3) fitness for duty and qualification training;

(4) equipment lockers, offsite fire department communications, and staging procedures; and (5)personal protective equipment and emergency lighting. The team reviewed fire drill critique reports that transpired over the last 12 months at or in the vicinity of the selected FZs to assess the fire brigade readiness to respond to any and all fires that may occur.

The team supplemented the documentation reviews by discussions with persons responsible for fire brigade performance.

The team examined the fire brigade staging and dress-out areas to assess the operational readiness of fire fighting and smoke control equipment. The fire brigade personal protective equipment, self-contained breathing apparatuses (SCBAs) and SCBA cylinder refill capability were checked for adequacy and functionality. The team walked down the selected FZs to compare the associated fire fighting pre-plan strategy drawings with as-built plant conditions and fire response procedures. This was done to verify that fire fighting pre-plan strategies and drawings were consistent with the fire protection features and pertinent information was provided to fire brigade members to identify potential effects to plant and personnel safety, and to facilitate suppression of an exposure fire that could impact SSD capability.

b. Findings

No findings were identified.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team evaluated whether the automatic fixed sprinkler systems or manual fire fighting activities could adversely affect the credited SSD equipment, inhibit access to alternate shutdown equipment, and/or adversely affect the local operator actions required for SSD in the selected fire areas. With regard to the fixed automatic pre-action sprinkler system in the Unit 2 Hallway (FZ 7), the team considered consequences of a pipe break, and inadvertent system actuation. The team also checked that sprinkler system water would either be contained in the fire affected area or be safely drained off.

The team addressed the possibility that a fire in one FZ could lead to activation of an automatic suppression system in another FZ through the migration of smoke or hot gases, and thereby adversely affect SSD. Air flow paths out of the selected FZs were reviewed to verify that inter-area migration of smoke or hot gases would not inhibit necessary operator actions. This portion of the inspection was carried out through a combination of walk-downs, drawings, and records review.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

The team verified that the licensees alternative shutdown methodology properly identified the components and systems necessary to achieve and maintain SSD conditions for a fire in FA 5 (FZ 16) and in FA A3 (FZ 7) in accordance with 10 CFR Part 50, Appendix R Section III.G.3. The team reviewed the licensees UFSAR, SSA, DSPs, emergency operating procedures (EOP), and other supporting documents for postulated fires in the selected FA/FZs. The reviews focused on ensuring that the required functions for post-fire SSD and the corresponding equipment necessary to perform those functions were included in the procedures. The team also made a comparison of the SSA and the SSD procedures with regard to credited SSD equipment to verify that the two were consistent.

The team assessed the timeliness of the operators in identifying and assessing the initial plant conditions, response to suspected fire, and subsequent actions credited afterwards.

The inspectors verified the licensee personnel credited for procedure implementation had procedures available, were trained on implementation, and were available in the event a fire occurred. Reviews included verification that alternative shutdown could be accomplished with or without offsite power.

Operational Implementation The team reviewed the training lesson plans of licensed and non-licensed operators to verify that the training reinforced the shutdown methodology in the SSA, DSPs, and EOPs for the selected FZs. The team also conducted interviews and reviewed shift manning procedures to verify that personnel required for SSD using alternative shutdown systems and procedures were available onsite, exclusive of those assigned as fire brigade members.

The team performed tabletop reviews of post-fire SSD procedure DSP-002, Hot Shutdown Using the Dedicated/Alternate Shutdown System and also performed a walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team checked whether the SSD procedures included steps to prevent or mitigate the consequences of spurious operations. The team walked down the in-plant location of all operator actions specified in the DSP procedures with operations personnel to evaluate the expected ambient conditions, relative difficulty and operator familiarization associated with each operator action. The team reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The team reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.

b. Findings

No findings were identified.

.06 Circuit Analyses

a. Inspection Scope

This segment is suspended for plants in transition, because a more detailed review of cable routing and circuit analysis will be conducted as part of the fire protection program transition to NFPA 805. However, to support this inspection, a limited scope review of a select sample of SSD components was conducted to verify that the existing fire response procedures were adequate for a postulated fire in any of the selected FAs.

The cables examined were based upon a list of SSD components selected by the team.

The team reviewed the electrical control wiring diagrams and identified the cables associated with the SSD components and examined in detail the cable routing and potential for fire damage and the effects on the circuit. The specific components reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team reviewed plant communication capabilities to evaluate the availability of the communication systems to support plant personnel in the performance of local operator manual actions to achieve and maintain SSD conditions. The team reviewed safe shutdown procedures, the safe shutdown analysis and associated documents to verify an adequate method of communications would be available to plant personnel and fire brigade following a fire. The team also reviewed the communication systems available at different locations within the plant that would be relied upon to support fire event notification and fire brigade fire fighting activities to verify their availability. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns. In addition, the team reviewed the electrical power supplies and cable routing for the communication systems to verify that the plant telephones, portable radios, and mini-cell phones would be available to support the operators in the conduct and coordination of their required duties during a fire.

The team inspected the contents of designated emergency storage lockers and reviewed the alternate shutdown procedure to verify that dedicated alternative shutdown communications system was available, operable, and adequate for the performance of designated activities.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team reviewed the emergency lighting system required to support plant personnel during the performance of manual actions required to achieve and maintain hot shutdown conditions, and for illuminating access and egress routes to the areas where manual actions are required. The locations and positioning of emergency lights were observed during a walk-through of Procedure DSP-002, Revision 41, Hot Shutdown Using the Dedicated/Alternate Shutdown System, and during review of manual actions implemented for the selected fire areas to provide reasonable assurance of illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post fire safe shutdown. The team verified that the battery power supplies were rated for at least an eight-hour capacity. The team also verified that the emergency lighting units were maintained in accordance with the manufacturer recommendations, tested and performed maintenance in accordance with plant procedures and industry practices. The team validated that the emergency lighting system was scoped into the licensees Maintenance Rule Program. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

09. Cold Shutdown Repairs

a. Inspection Scope

10 CFR 50, Appendix R, III.G.1(b) allows repairs to be made to equipment needed to achieve and maintain cold shutdown that was damaged by a fire provided that such equipment can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the fire.Section III.L.5 requires that material for such repairs shall be readily available on site and procedures shall be in effect to implement such repairs. The team reviewed the licensees procedures to determine whether repairs were required to achieve cold shutdown and independently verify that the equipment, tools, and supplies used for the repairs following a fire were available and accessible. Using procedure DSP-012, Revision 12, Pressurizer Power Operated Relief Valve Control/Power Repair Procedure and DSP-008, Revision 9, Residual Heat Removal Pump Repair Procedure, the team evaluated whether these components could be repaired in the time frames specified in their design and licensing basis. The procedures were reviewed for completeness and clarity. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The team reviewed the administrative controls for out-of-service, degraded, and/or inoperable fire protection features (e.g., detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing SSD functions or capabilities). The team reviewed selected items on the fire protection impairment list and compared them with the FZs selected for inspection. The compensatory measures that had been established in these zones were compared to those specified for the applicable fire protection feature in fire protection procedure FP-012, Revision 12, Fire Protection Systems Minimum Equipment and Compensatory Measures. The team checked that the risk associated with removing the fire protection feature from service was properly assessed and adequate compensatory measures were implemented in accordance with the approved FPP. Additionally, the team reviewed the licensees short term compensatory measures (compensatory fire watches) to verify that they were adequate to compensate for a degraded function or feature until appropriate corrective actions were taken and that the licensee was effective in returning the equipment to service in a reasonable period of time. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

11. Control of Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the administrative control of combustible materials and ignition sources. Plant administrative procedures were reviewed to determine if adequate controls were in place to control the handling of in-situ and transient combustibles in the plant. The team walked down numerous areas in the plant, including the selected FZs, for control of combustible materials, storage of in-plant materials, transient combustibles and general housekeeping. The team reviewed controls on the potential ignition sources of welding and grinding.

Reviews of flow diagrams and engineering calculations associated with the A and B battery room (FZ 16) heating, ventilation, and air conditioning (HVAC) systems. This review was done to verify that systems used to accomplish safe shutdown would not be inhibited by potential hazardous hydrogen gas concentrations and fire in the battery room. The team performed fire model calculations, using NRC recommended computer codes, to estimate the rate of hydrogen generation in the battery room and the ventilation systems effectiveness. This review was performed to ensure that hydrogen gas concentrations generated by the station batteries remained below explosive limits.

b. Findings

No findings were identified.

.12 B.5.b Inspection Activities

a. Inspection Scope

The team reviewed, on a sampling basis, the licensees external spent fuel pool mitigation measures for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the strategies, and equipment was properly staged and maintained. The team requested and reviewed maintenance records of required equipment. Through discussions with plant staff, review of documentation, and plant walk-downs, the team verified the engineering basis to establish reasonable assurance that the makeup capacity could be provided for the minimum time using the specified equipment and water sources. The team reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply. Additionally, the team reviewed printed and video drill records of the implementation of the selected strategies. The team performed a walk-down of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures were available and maintained. In the presence of licensee staff, the team conducted an independent audit and inventory of required equipment and a visual inspection of the dedicated credited power source.

The team reviewed training records of the licensees staff to verify that operator training/familiarity with the strategy objectives and implementing guidelines was accomplished according to the established training procedures.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

a. Inspection Scope

The team reviewed recent independent licensee fire protection program audits for thoroughness, completeness and conformance to requirements. Requirements for the independent audits are contained in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, Generic Letter 82-21, Technical Specifications for Fire Protection Audits, and the licensees Updated Final Safety Analysis Report, Section 17, Quality Assurance. The team reviewed Nuclear Assessment Section Audit RNAS-08-022, dated April 17, 2008, and Self Assessment Report No. 311294-03, completed October 8, 2009.

The team also reviewed corrective action program documents, including completed corrective actions documented in selected action requests (ARs) and operating experience program documents, to ascertain whether industry-identified fire protection problems actually or potentially affecting RNP were appropriately entered into, and resolved by, the corrective action program process. Items included in the review were NRC Information Notices, industry or vendor-generated reports of defects and non-compliances submitted pursuant to 10 CFR 21, and vendor information letters. The team evaluated the effectiveness of the corrective actions for the identified issues. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

4OA3 Event Follow-Up

(Discussed) Licensee Event Report (LER) 05000261/2008-01, Unprotected Post-Fire Safe Shutdown Cables and Related Non-Feasible Local Manual Operator Actions This LER describes a situation where an Appendix R local operator action for alternate shutdown would have been delayed or prevented due to an improper lock configuration on a gate between the Radwaste Building and the auxiliary boiler. It also involved the lock configuration control and human error issues.

The team reviewed the facts of the subject LER as well as NRC guidance, and evaluations and analysis conducted by the licensee. The inspectors reviewed the licensees immediate corrective actions to ensure proper action was taken to prevent recurrence. In addition, the team reviewed the licensees root cause evaluation to ensure a thorough assessment was performed. This LER will remain open pending completion of the inspectors review of the technical impacts the delayed operator action would have had on the safe shutdown strategy.

4OA5 Other Activities

.1 (Discussed) Unresolved Item (URI)05000261/2004006-03, Appendix R Safe Shutdown

Vulnerabilities The team reviewed the facts of the subject URI as well as evaluations and corrective actions taken by the licensee. The NRC inspection team conducted onsite interviews with appropriate licensee staff and reviewed Engineering Change 58657R12, Condition Reports NCR 11308 and AR 136517136517 and associated plant drawings and procedures to verify that corrective actions were adequately implemented. Additional corrective actions and plant modifications are planned to occur during the licensee revalidation process as they transition the existing fire protection licensing basis to 10CFR 50.48(C),

NFPA 805. This URI will remain open pending final review by the inspectors of these additional corrective actions and modifications.

.2 (Discussed) Unresolved Item (URI)05000261/2004006-04, Inadequate Corrective

Actions For Appendix R Safe Shutdown Vulnerabilities This URI is associated with NRI 05000261/2004006-03 discussed above.

The team reviewed the facts of the subject URI as well as existing operating experience, NRC guidance and evaluations and analysis conducted by the licensee.

In addressing the concern regarding inadequate corrective actions taken for the Appendix R safe shutdown vulnerabilities identified above, the licensee conducted an adverse condition investigation (AR 136517136517 and concluded that given the combination of conservative assumptions applied in NCR 11308, the mitigating factors not credited in the NCR (some of which are credited in the current licensing basis of the plant) and the influential factors associated with the postulated fire induced circuit failures, the initial compensatory measures provided adequate assurance that the core would remain covered. In the case of the Power Operated Relief Valves (PORVs), it was shown by calculation and a simulator run that the manual actions to remove power and close the valves can be achieved prior to core uncovery with no resulting core damage.

Additionally, the NRC inspection team concluded that once operators take the actions in FP-001 and DSP-002 to close the pressurizer PORVs and associated block valves, the re-opening of the block valve(s) would constitute a multiple spurious operation.

Furthermore, once the pressurizer PORVs are closed and de-energized, the reopening of its associated block valve would have no additional adverse consequence. This issue will remain open pending closure of the associated URI (URI 05000261/2004006-03)discussing the technical aspects of this finding.

4OA6 Meetings, Including Exit

On April 1, 2010, the inspection team leader presented the preliminary inspection results to Mr. E. McCartney, Site Vice President, and other members of the licensees staff. The license acknowledged the results. A re-exit was conducted with the licensees staff on May 13, 2010 and June 29, 2010, to discuss the final disposition of the inspection results. The licensee also confirmed that proprietary information was not provided or examined during the inspection.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

G. Sanders, Licensing Contact

C. Castel, Licensing Supervisor

B. McCabe, Regulatory Affairs Manager

J. Ertman, Corporate Fire Protection Supervisor

B. Gerwe, Fire Protection Manager

W. Farmer, Engineering Manager

K. Jensen, Maintenance Manager

S. Saunders, Plant General Manager

J. Lucas, Nuclear Assurance Manager

S. West, Security Manager

J. Rhodes, Radiation Protection Superintendent

K. Jones, Operations Manager

E. McCartney, Vice President

NRC personnel

D. Bollock, Resident Inspector, H.B. Robinson Steam Electric Plant

J. Hickey, Senior Resident Inspector, H.B. Robinson Steam Electric Plant

R. Nease, Chief, Engineering Branch 2, Division of Reactor Safety, Region II