HB ROBINSON RENEWAL | LIFE EXTENSION
Renewed licence Both initial and subsequent licence requirements for
power reactors are based on two principles: ● The regulatory process is adequate to ensure that the licensing bases of all currently operating plants maintain an acceptable level of safety with the possible exception of the detrimental ageing effects on the functions of certain systems, structures, and components and a few other safety related issues during the period of extended operation.
● The plant specific licensing basis must be maintained during the renewal term in the same manner, and to the same extent, as during the original licensing term.
Active equipment is adequately monitored and maintained
by existing programmes and is not subject to an aging management review (AMR), because ageing effects can be readily identified and corrected through existing programmes. A licence renewal applicant must identify SCs subject to an AMR, which are those that perform an intended function without moving parts, or without a change in configuration or properties, and are not subject to replacement based on a qualified life or specified time period. The applicant must demonstrate that the effects of ageing will be adequately managed and the SC functions will be maintained during extended operation. The NRC staff evaluated the applicant’s
AMRs for components subject to one in six SC categories: ● Reactor vessel, internals and reactor coolant system ● Engineered safety features ● Auxiliary systems ● Steam and power conversion systems ● Supports for containments, structures, and components ● Electrical and instrumentation and controls.
An example of the licence application examination was
concerned with the Dry Agent Suppression System. This gaseous fire suppression system is designed to support safe plant shutdown and is used in specific switchgear relay rooms and in the Hagan Relay Room adjacent to the control room. Components of the fire suppression system are passive and long-lived, so they are subject to an AMR. Extensive review by the NRC staff was followed by a
virtual audit with Duke staff to discuss fire protection scoping and screening topics. The staff discussed breakout session audit questions, interviewed Duke personnel and examined supporting documentation. During the discussion, Duke staff addressed NRC staff’s questions about whether various Dry Agent Suppression System components were within the scope of SLR and subject to
an AMR. These components included: ● Clean agent fire suppression system storage bottle ● Pressure regulator ● Accumulator ● Valve body ● Clean agent distribution manifold.
These components are replaced based on condition
monitoring in accordance with approved facility procedures and are treated as consumables; therefore, they are not subject to an AMR. However, they remain part of Robinson’s maintenance programme, which includes periodic functional testing at the required frequency. Duke staff indicated that the Robinson clean agent system does not include pressure regulator or
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Table 1: Timeline of the HB Robinson licence renewal programme Milestone
Receive Subsequent Licence Re-newalApplication (SLRA) Publish Letter – SLRA Availability
Publish Letter – Docketing Acceptance/Rejection and Opportunity for Hearing
Publish Federal Register Notice FRN – Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping
Environmental Scoping Period Ends
Deadline for Filing Hearing Requests and Petitions for Intervention
Issue Draft Supplemental Environmental Impact Statement (SEIS)
Draft SEIS Comment Period Ends Issue Final SEIS
US Environmental Protection Agency FRN Published – Availability of Final SEIS
Issue Safety Evaluation Report Decision – Director, Office of Nuclear Reactor Regulation
accumulator. However, their valve body and distribution manifold are required for compliance with fire protection regulations and subject to an AMR. Clean agent cylinders for the Dry Agent Fire Suppression System undergo regular inspection and replacement as required by NFPA 2001 and therefore are not subject to an AMR. The NRC staff concluded that HR Robinson appropriately identified the Dry Agent Suppression System components within the scope of SLR and the system components subject to an AMR. In its final report the NRC staff compared 48 AMPs (nine new and 39 existing) with the NUREG 2191 GALL-SLR Report. It found 15 consistent with GALL-SR, 28 consistent with enhancement, three consistent with exception and one
Scheduled Actual 04/2025
04/2025 05/2025 05/2025 06/2025 07/2025 12/2025 01/2026 03/2026 03/2026 04/2026 04/2026
04/01/2025 04/08/2025 04/28/2025 05/22/2025 06/23/2025 07/07/2025 12/22/2025 02/23/2026 03/12/2026 03/20/2026 04/01/2026 04/23/2026
HB Robinson is the second nuclear facility in Duke Energy’s fleet to receive a second licence renewal after Oconee Nuclear Station received its second renewal in March 2025. Source: ANS
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