ML14245A566
| ML14245A566 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/28/2014 |
| From: | Scott Shaeffer NRC/RGN-II/DRS/EB2 |
| To: | William Gideon Duke Energy Progress |
| References | |
| IR-2014-007 | |
| Download: ML14245A566 (12) | |
See also: IR 05000261/2014007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
August 28, 2014
William R. Gideon, Vice President
H.B. Robinson Steam Electric Plant
3581 West Entrance Road
Hartsville, SC 29550
SUBJECT: H. B. ROBINSON STEAM ELECTRIC PLANT- NOTIFICATION OF TRIENNIAL
FIRE PROTECTION BASELINE INSPECTION AND REQUEST FOR
INFORMATION (NRC INSPECTION REPORT NO. 05000261/2014007)
Dear Mr. Gideon
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
staff will conduct a triennial fire protection baseline inspection at H. B. Robinson Nuclear Plant,
Unit 2. The inspection team will be led by Mr. Gerald Wiseman, a Senior Reactor Inspector
from the NRC Region II Office. The team will be composed of personnel from the NRC Region
II Office. The inspection will be conducted in accordance with IP 71111.05T, the NRC's baseline
fire protection inspection procedure, dated January 31, 2013.
On August 25, 2014, during a conversation between Mr. Richard Hightower, of your Regulatory
staff, and Mr. Wiseman, our respective staffs confirmed arrangements for a three-day
information gathering onsite visit and a two-week onsite inspection. The schedule for the
inspection is as follows:
- Information gathering visit: September 30 - October 3, 2014
- Week 1 of onsite inspection: October 20 - 24, 2014
- Week 2 of onsite inspection: November 3 - 7, 2014
The purposes of the information gathering visit are to obtain information and documentation
needed to support the inspection, to become familiar with the Robinson Nuclear Plant fire
protection program, fire protection features, post-fire safe shutdown capabilities, plant layout,
mitigating strategies to address Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)
(2); and, as necessary, obtain plant specific site access training and badging for unescorted site
access.
Experience has shown that this inspection is resource intensive for both the NRC inspectors
and your staff. In order to minimize the impact to your onsite resources and to ensure a
productive inspection, we have enclosed a request for documents (in Enclosures 1 and 2)
needed for this inspection. It is important that all of these documents are up to date, and
complete, in order to minimize the number of additional documents requested during the
preparation, and/or the onsite portions of the inspection. The inspection team will try to
minimize your administrative burden by specifically identifying those documents required for
W. Gideon 2
inspection preparation. Also, the team leader will contact you with any additional specific
document requests prior to the information gathering visit.
During the information gathering visit, the team will also discuss the following inspection support
administrative details: office space; specific documents to be made available to the team in their
office space; arrangements for unescorted site access (including radiation protection training,
security, safety and fitness for duty requirements); and the availability of knowledgeable plant
engineering, operations and licensing organization personnel to serve as points of contact
during the inspection.
We request that during the inspection weeks you ensure that copies of analyses, evaluations or
documentation regarding the implementation and maintenance of the Robinson fire protection
program, including post-fire safe shutdown capability, 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. For the B.5.b portion of the
inspection, those documents implementing your mitigating strategies and demonstrating the
management of your commitments for the strategies are of specific interest. Also, personnel
should be available at the site during the inspection that are knowledgeable regarding those
plant systems required to achieve and maintain safe shutdown conditions from inside and
outside the control room (including the electrical aspects of the relevant post-fire safe shutdown
analyses), reactor plant fire protection systems and features, and the Robinson 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, 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.
In accordance with 10 CFR 2.390 of the NRC Rules and Practices, a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publically Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.hmtl (the Public Electronic Reading Room).
W. Gideon 3
Your cooperation and support during this inspection will be appreciated. If you have questions
concerning this inspection, or the inspection team's information or logistical needs, please
contact Mr. Gerald Wiseman, the team leader, in the Region II Office at (404) 997-4542 or
me at (404) 997-4521.
Sincerely,
/RA/
Scott M. Shaeffer, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No.: 50-261
License No.: DPR-23
Enclosures: 1. Triennial Fire Protection Inspection Support Documentation
2. Mitigating Strategies Support Documentation
cc: Distribution via Listserv
_ML14245A566______________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED
OFFICE RII:DRS RII:DRP RII:DRS
SIGNATURE GRW GTH1 SMS
NAME WISEMAN HOPPER SHAEFFER
DATE 8/28/2014 8/28/2014 8/28/2014
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
Triennial Fire Protection Inspection Supporting Documentation
The documents and information requested below should generally be made available to the
inspection team during the on-site information gathering visit for the team's use both on-site and
off-site during the inspection. Electronic format is the preferred media, except where specifically
noted, if readily available (The preferred file format is searchable .pdf files). If electronic media
is made available via an internet based remote document management system, then the remote
document access must allow inspectors to download, save, and print the documents in the
NRC's regional office. Electronic media on compact disc or paper records (hard copy) are
acceptable. At the end of the inspection, the documents in the team's possession will not be
retained.
Approximately three weeks before the on-site information gathering visit, the following
documents should be made available to the team leader for review in the regional office:
- Post-fire Safe Shutdown or Alternative Shutdown Analysis (request A.1)
- Fire Hazards Analysis (request A.2)
- Individual Plant Examination for External Events (Fire Chapter ONLY) (request A.3)
Based on review of the above three documents, the team leader will identify a preliminary list of
fire areas being considered for inspection prior to the on-site information gathering visit. During
the information gathering visit, or shortly thereafter, the fire areas selected for inspection will be
determined.
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 Post-fire Safe Shutdown or Alternative Shutdown Analysis.
A.2 Fire Hazards Analysis.
A.3 Individual Plant Examination for External Events (IPEEE) (Fire Chapter ONLY),
including:
- Results of any post-IPEEE reviews; and
- LIST of actions taken or plant modifications performed in response to the IPEEE
results.
A.4 Fire Protection Program and/or Fire Protection Plan.
Enclosure 1
2
A.5 LIST of post-fire safe shutdown or alternative shutdown systems (i.e., safe shutdown
equipment list).
A.6 Fire Protection System Design Basis Document.
A.7 Post-fire Safe Shutdown or Alternative Shutdown Design Basis Document.
A.8 LIST of applicable NFPA codes and standards and issuance dates (i.e., codes of
record).
A.9 LIST of deviations from NFPA codes of record.
A.10 NFPA Compliance Review Report.
A.11 Report or evaluation that compares the fire protection program to the NRC Branch
Technical Position (BTP) 9.5-1 Appendix A.
A.12 Electronic copy of licensee submittals and NRC safety evaluation reports that are
specifically listed in the facility operating license for the approved fire protection
program.
A.13 NRC Safety Evaluation Reports for fire protection program and post-fire safe
shutdown or alternative shutdown features.
A.14 NRC approved exemptions for plant fire protection and post-fire safe shutdown or
alternative shutdown features.
A.15 Exemption requests submitted but not yet approved for plant fire protection and post-
fire safe shutdown or alternative shutdown features.
A.16 Facility Operating License (electronic format only).
A.17 Technical Specifications (electronic format only).
A.18 Technical Requirements Manual (electronic format only).
A.19 Updated Final Safety Analysis Report (electronic format only).
B. GENERAL PLANT DESIGN DOCUMENTS
B.1 Piping and instrumentation diagrams (P&IDs) and legend list for post-fire safe
shutdown or alternative shutdown systems (C-size paper drawings and electronic
copy).
B.2 P&IDs and legend list for fire protection systems, including fire water supply, water
suppression sprinklers & deluge, and CO2 and Halon systems (C-size paper
drawings and electronic copy).
3
B.3 AC and DC electrical system single line diagrams, from off-site power down to the
highest safety-related bus level (typically 4kV, EDG bus) (C-size paper drawings and
electronic copy ).
B.4 Single line diagrams for motor control centers (MCCs) that supply post-fire safe
shutdown or alternative shutdown loads (only for selected fire areas) (C-size paper
drawings and electronic copy ).
B.5 Equipment location drawings which identify the physical plant locations of post-fire
safe shutdown or alternative shutdown equipment (C-size paper drawings and
electronic copy).
B.6 Plant layout drawings which identify: (C-size paper drawings and electronic copy)
- Plant fire area boundaries;
- Combustible control zone drawings;
- Areas protected by automatic fire suppression and detection; and
- Locations of fire protection equipment.
C. CLASSICAL FIRE PROTECTION
C.1 Fire protection program implementing procedures (e.g., administrative controls,
surveillance testing, fire brigade).
C.2 LIST of calculations and engineering analyses, studies, or evaluations for the fire
protection system, including the fire water system.
C.3 Hydraulic calculation or analysis for fire protection water system in the selected fire
areas.
C.4 Last two completed surveillance's records of fire protection features in the selected
fire areas (detection, suppression, damper inspections, damper tests, penetration
inspections, barrier inspections, etc.).
C.5 LIST of routine tests, surveillances, and preventive maintenance on fire pumps,
including pump controllers and batteries.
C.6 Last two completed annual fire pump pressure and flow tests.
C.7 Last two completed monthly and/or quarterly fire pump tests.
C.8 Last two completed fire loop flow tests and loop flushes.
C.9 CO2 and Halon initial discharge testing and calculations that determined appropriate
concentrations and soak or hold times can be achieved (only for selected fire areas).
C.10 Last five hot work permits (at power).
C.11 Last five transient combustible permits (at power).
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C.12 For Fire Brigade Drills, provide the following:
- Last drill critique for a drill with off-site fire department support;
- Summary of any unsatisfactory drill performance items for last three years; and
- Last unannounced drill critique by a qualified individual independent of the
licensee's staff.
C.13 For fire brigade equipment provide the following:
- Procedure for inventory and inspection; and
- Most recent inspection and inventory results.
C.14 Fire Brigade Medical Evaluations and Qualifications, including self-contained
breathing apparatus (SCBA) and training lesson plans.
C.15 Electronic copy of the mutual aid agreement for the first-due local fire department
that is currently in effect.
C.16 Flooding analysis for selected fire areas which demonstrates:
- a fire water pipe break in the selected fire areas, wont affect safe shutdown (SSD)
capability for equipment in the selected fire areas;
- a fire water pipe break in an adjacent fire area, wont affect SSD capability for
equipment in the selected fire areas;
- hydrostatic rating of any floor penetration seals installed within the fire areas that
are credited with keeping water from leaking into fire areas below.
C.17 Pre-fire plans for the selected fire areas and their adjacent fire areas.
C.18 For Emergency Lighting Units (ELU), provide the following:
- LIST of Preventive Maintenance tasks, frequencies, and bases;
- Most recently performed monthly or quarterly functional test;
- Most recently performed battery discharge performance test; if applicable
- ELU battery loading analysis;
- vendor manual(s);
- results of black-out testing (if performed);
- Maintenance Rule program information related to the ELU, if applicable; and
- Compensatory measures taken when ELU are out of service.
C.19 Impairment Log (for period of 3 months before the start of inspection), for fire
protection features that are out of service.
C.20 LIST of Fire Protection screening reviews since the last inspection for recent design
changes, modifications, or temporary modifications (e.g., a Generic Letter 86-10
review that screened out).
C.21 LIST of fire protection system design changes completed in the last three years
(including their associated 10 CFR 50.59 and Generic Letter 86-10 evaluations).
C.22 LIST of penetration seal work, re-work, or installation activities, in the last three years.
C.23 LIST of fire wrap work, re-work, or installation activities, in the last three years.
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C.24 Fire protection system health reports for the two most recent years.
C.25 Fire protection program health report for the two most recent years.
C.26 Emergency lighting system health reports for the two most recent years.
C.27 Licensee evaluation of industry operating experience, related to the Fire Protection
Program for the three most recent years.
D. ELECTRICAL
D.1 Identify whether the cables in the selected fire areas are predominantly Thermoset or
Thermoplastic. Specifically identify any Thermoplastic cable in the selected fire
areas.
D.2 Breaker and fuse coordination calculation for post-fire safe shutdown or alternative
shutdown equipment (only for selected fire areas).
D.3 Administrative or configuration control procedures that govern fuse replacement (e.g.,
fuse control procedures).
D.4 Maintenance procedures that verify breaker over-current trip settings to ensure
coordination remains functional, for post-fire safe shutdown or alternative shutdown
equipment.
D.5 Electrical system health reports for the two most recent years.
D.6 Last completed preventive maintenance of those components as tested from the safe
shutdown or alternative shutdown panel.
D.7 Schematic or elementary diagrams for circuits to be reviewed, as requested by
inspector (C-size paper drawings and electronic copy).
D.8 Cable routing for components and equipment credited for post-fire safe shutdown or
alternative shutdown (only for selected fire areas).
D.9 LIST of post-fire safe shutdown or alternative shutdown design changes completed,
since the last inspection.
E. SPURIOUS FIRE INDUCED CIRCUIT FAULTS
E.1 LIST of identified fire induced circuit failure configurations (only for selected fire
areas).
E.2 Multiple Spurious Operation (MSO) Expert Panel Report.
E.3 Corrective actions for fire-induced circuit failures, both single and multiple spurious
actuations for the selected fire areas.
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F. OPERATIONS
F.1 LIST of calculations and engineering analyses, studies, or evaluations for the safe
shutdown or alternative shutdown methodology.
F.2 LIST of licensed operator Job Performance Measures (JPMs) for operator manual
actions required by post-fire safe shutdown or alternative shutdown.
F.3 LIST of non-licensed operator training associated with post-fire safe shutdown or
alternative shutdown manual actions which would be performed by a non-licensed
operator (including JPMs, in-field training walkdowns, simulations, or initial
qualification).
F.4 LIST of lesson plans for post-fire safe shutdown or alternative shutdown training for
licensed and non-licensed operators.
F.5 For operator manual actions (OMAs) provide the following:
- Manual Action Feasibility Study;
- Operator Time Critical Action Program;
- Time lines for time-critical OMAs; and
- Time line validations.
- Environmental and habitability evaluations for post-fire operator manual actions
(temperature, smoke, humidity, SCBAs, etc.).
F.6 Thermal hydraulic calculation or analysis that determines the time requirements for
time-critical manual operator actions.
F.7 Operating procedures for post-fire safe shutdown from the control room with a
postulated fire in the selected fire areas.
F.8 Operating procedures for post-fire safe shutdown or alternative shutdown from
outside the control room.
F.9 For safe shutdown equipment and tools, provide the following:
- Procedure for inventory and inspection; and
- Most recent inspection and inventory results.
F.10 LIST of procedures that implement Cold Shutdown Repairs.
F.11 For Cold Shutdown Repairs, provide the following:
- Procedure for inventory and inspection (i.e., needed tools, material, etc.); and
- Most recent inspection and inventory results.
F.12 Calculation or analysis that demonstrates pressurizer level will remain within the
indicating range for a PWR, or reactor water level will remain above the top of active
fuel for a BWR, at the safe shutdown or alternative shutdown panel, in accordance
with the requirements of 10 CFR 50 Appendix R III.L performance goals.
F.13 For Radio communications, provide the following:
- Communications Plan for fire fighting and post-fire safe shutdown manual actions;
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- Repeater locations;
- Cable routing for repeater power supply cables;
- Radio coverage test results; and
- Radio Dead Spot locations in the plant.
F.14 NRC approved exemption requests for operator manual actions for
10 CFR 50 Appendix R III.G.2 fire areas.
F.15 Exemption requests submitted but not yet approved, for operator manual actions for
10 CFR 50 Appendix R III.G.2 fire areas.
G. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS
G.1 Corrective actions for fire-induced circuit failures (including but not limited to NRC
IN 92-18), both single and multiple spurious actuations (only for selected fire areas).
G.2 Corrective actions associated with post-fire safe shutdown or alternative shutdown
G.3 Internal and external self-assessments, peer assessments, and audits of fire
protection activities for the last three years.
G.4 Internal and external self-assessments, peer assessments, and audits of post-fire
safe shutdown or alternative shutdown capabilities for the last three years.
G.5 LIST of condition reports for the fire protection system for the last three years.
G.6 LIST of condition reports for emergency lighting units for the last three years.
G.7 LIST of condition reports for post-fire safe shutdown (SSD) or alternative shutdown
(ASD) issues for the last three years. This includes issues affecting the SSD or ASD
analysis, fire hazards analysis, SSD or ASD operating procedures and/or training,
timeline evaluations for operator actions, and supporting engineering evaluations,
analysis, or calculations.
G.8 LIST of all Generic Letter 86-10 evaluations.
G.9 Electronic copy of all Generic Letter 86-10 evaluations performed in the last three
years.
G.10 All fire loading calculations and evaluations performed (only for selected fire areas
and their adjacent fire areas)
Mitigating Strategies Supporting Documentation
H. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS
H.1 LIST of all changes to regulatory commitments made to meet the requirements of
Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2).
H.2 LIST of procedures and guidelines that were revised or generated to implement the
mitigating strategies. These could be extensive damage mitigation guidelines
(EDMGs), severe accident management guidelines (SAMGs), emergency operating
procedures (EOPs), abnormal operating procedures (AOPs), etc.
H.3 A matrix that shows the correlation between the mitigation strategies identified in
Nuclear Energy Institute 06-12, Revision 2, "B.5.b Phase 2 & 3 Submittal Guideline,"
issued December 2006, and the site-specific procedures or guidelines that are used
to implement each strategy.
H.4 LIST of engineering evaluations or calculations that were used to verify the
engineering bases for the mitigating strategies.
H.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow
diagrams for systems relied upon in the mitigating strategies. These could be the
type used for training (C-size paper drawings and electronic copy).
H.6 LIST of modification packages or summary descriptions of modifications with
simplified drawings, for necessary facility changes to implement the mitigating
strategies.
H.7 LIST of routine tests, surveillances, and preventive maintenance for equipment and
tools needed to implement 10 CFR 50.54(hh)(2) strategies.
H.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies,
provide the following:
- Procedures for inventory, testing, and inspection; and
- Most recent inspection, inventory, and testing results.
- Copies of the last two completed performance tests, surveillances, and
preventative maintenance performed on the pumps, including the pump
controllers and batteries.
H.9 LIST of 10 CFR 50.54(hh)(2) strategies, if any, which have implementing details that
differ from that documented in the submittals or the safety evaluation report.
H.10 Site general arrangement drawings that show the majority of buildings and areas
referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings and electronic
copy).
H.11 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2)
H.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments)
required to implement any mitigating strategies.
Enclosure 2