IR 05000250/2013007
| ML13219A155 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/07/2013 |
| From: | Mark King NRC/RGN-II/DRS/EB2 |
| To: | Nazar M Florida Power & Light Co |
| References | |
| IR-13-007 | |
| Download: ML13219A155 (29) | |
Text
August 7, 2013
SUBJECT:
TURKEY POINT NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION (REPORT NO. 05000250/2013007 AND 05000251/2013007)
Dear Mr. Nazar:
On June 28, 2013, The U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Turkey Point Nuclear Plant, Units 3 and 4. The enclosed inspection report documents the inspection results, which were discussed with Mr. M. Kiley and other members of your staff on June 28, 2013.
The inspection examined activities conducted under your license as they related 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.
The enclosed report documents one NRC-identified finding of very low safety significance (Green) that was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Turkey Point Nuclear Plant.
You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRCs 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 NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov./reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, RA
Michael F. King, Chief Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-250, 50-251 License Nos.: DPR-31, DPR-41
Enclosures:
Inspection Report 05000250/2013007, 05000251/2013007 Supplemental Information
REGION II==
Docket Nos:
50-250, 50-251
License Nos:
Report Nos.:
05000250/2013007 and 05000251/2013007
Licensee:
Florida Power & Light Company (FPL)
Facility:
Turkey Point Nuclear Plant, Units 3 and 4
Location:
Dates:
June 10-14, 2013 (Week 1)
June 24-28, 2013 (Week 2)
Inspectors:
G. Wiseman, Senior Reactor Inspector (Lead Inspector)
P. Braxton, Reactor Inspector
R. Fanner, Reactor Inspector
Accompanying O. López, Senior Reactor Inspector (Training)
Personnel:
M. Singletary, Reactor Inspector (Training)
Approved by:
Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000250/2013-007, 05000251/2013-007; 06/10-14/2013 and 06/24-28/2013; Turkey Point
Nuclear Plant, Units 3 and 4; Fire Protection (Triennial).
This report covers an announced two-week triennial fire protection inspection by a team of three regional inspectors and two inspectors in training. One Green non-cited violation (NCV) was identified. The significance of inspection findings is indicated by their color (Green, White,
Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Rev. 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
An NRC-identified non-cited violation (NCV) of Turkey Point Unit 3 operating license condition (OLC) 3.D, Fire Protection, was identified for the failure to ensure that structural steel that was part of a fire barrier for fire zone (FZ) 104 was provided with a three-hour rated fire proofing as required by the approved fire protection program. The licensee entered the issue into their corrective action program as AR-1886074 and supplemented existing hourly fire watch patrol compensatory measures in FZ 104.
Failure to comply with the requirements of the Turkey Point Fire Protection Program for ensuring that structural steel that was part of a fire barrier was provided with a three-hour fire proofing was a performance deficiency. The performance deficiency was more than minor because it adversely affected the Mitigating Systems cornerstone objective of protection against external events. The inspectors determined the finding to be of very low safety significance (Green) because it was determined, through independent calculations, that the affected structural fireproofing in FZ 104 would provide more than 20 minutes of fire endurance despite the lack of fire test results or engineering evaluations documenting the fire rating of the structural steel fire proofing. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance.
(Section 1R05.02)
Licensee Identified Violations
None
.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R05 Fire Protection
This report documents the results of a triennial fire protection inspection of the Turkey Point Nuclear Plant (TPN) Units 3 and 4. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial),dated January 31, 2013. The objective of the inspection was to review a sample of four risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP) as described in Appendix 9.6A of the TPN Updated Final Safety Analysis Report (UFSAR),
Administrative Procedure (ADM) 0-ADM- 016, Fire Protection Program, Appendix R Safe Shutdown Analysis (SSA) 5160-M-772, and to review site specific implementation of one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walkdowns of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports (SERs),licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports (IRs). Section 71111.05-05 of the IP specifies a minimum sample size of three FAs/Fire Zones (FZs) and one B.5.b mitigating strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of four FAs/FZs and one B.5.b mitigating strategy. The FAs/FZs chosen were identified as follows:
1. Unit 4 Fire Area R, FZ 61, Reactor Control Rod Equipment and Motor Control Center 4B
Room
2. Unit 3 Fire Area W, FZ 70, 4160V Switchgear 3B Room
3. Unit 3 Fire Area OD, FZ 86, Main Transformer and Startup Transformer
4. Unit 3 Fire Area LL, FZ104, DC Equipment 3A Room
For each of the selected FAs/FZs, the inspectors evaluated the licensees FPP against applicable NRC requirements and licensee design basis documents. Applicable licensing and design basis documents reviewed by the inspectors are listed in the Attachment to this report.
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
For the selected FAs/FZs, the inspectors performed physical walkdowns to observe:
- (1) the material condition of fire protection systems and equipment;
- (2) the storage of permanent and transient combustibles;
- (3) the proximity of fire hazards to cables relied upon for SSD;
- (4) the potential environmental impacts, if any, on credited operator manual actions (OMAs) to the areas adjacent to the FA/FZ, and
- (5) the licensees implementation of procedures and processes for limiting fire hazards, housekeeping practices, and compensatory measures for inoperable or degraded fire protection systems and credited fire barriers.
Methodology For the selected FAs/FZs, the inspectors evaluated the potential for the effect from the fire event on credited actions specified by licensee procedures. The inspectors reviewed the Turkey Point Unit 3 & 4 UFSAR, Appendix 9.6A, STD-M-006, Engineering Guidelines for Fire Protection for Turkey Points Units 3 & 4, and conduit and cable tray routing information by FA, as well as, conducted field walkdowns of the cable routing to confirm that at least one train of redundant cables routed in the FA/FZ were adequately protected from fire damage or the licensees analysis determined that the fire damage would not prohibit safe plant shutdown. The inspectors reviewed the TPN SSA for the selected FAs/FZs and compared it to the off-normal operating procedures (ONOPs) to verify that cables and equipment credited to provide reactivity control, reactor coolant makeup, reactor heat removal, process monitoring and support functions for post-fire SSD in the SSA and applicable procedures were adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability.
Operational Implementation The inspectors reviewed 0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions, and applicable references to other off-normal procedures to verify that the shutdown methodology properly identified the systems and components necessary to achieve and maintain post-fire SSD. The inspectors performed walkdowns of the procedural actions based upon the FAs/FZs selected to assess the implementation of the SSD strategy and human factors attributes associated with them. The inspectors reviewed licensee records, which specified the shift staffing from randomly selected dates, to ensure the proper staffing levels existed to implement actions specified by licensee procedures. The inspectors reviewed licensee-training material to ensure licensed and non-licensed operators were being trained based upon the current plant configuration.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The inspectors walked down the selected FAs/FZs to evaluate the adequacy of the fire resistance of barrier enclosure walls, ceilings, floors, and structural steel support fire proofing protection. This evaluation also included fire barrier concrete block walls, penetration seals, fire doors, fire dampers, and the Thermo-Lag electrical raceway fire barrier systems to ensure that at least one train of SSD equipment would be maintained free of fire damage. Construction detail drawings were reviewed as necessary. Where applicable, the inspectors observed the installed barrier assemblies and compared the as-built configurations to the approved construction details; supporting fire endurance test data; licensing basis commitments; and standard industry practices. The inspectors also performed independent fire resistance calculations to validate the fire resistance of selected structural steel fire proofing components.
b. Findings
Introduction:
The inspectors identified a Green non-cited violation (NCV) of Renewed Operating License Condition (OLC) 3.D, Fire Protection, for the failure to ensure that structural steel that was part of a fire barrier was provided with a three-hour rated fire proofing as required by the approved FPP.
Description:
Fire Area LL was the Unit 3 DC Equipment Room and was a single zone area comprised of FZ 104. FZ 104 was bounded on the floor, ceiling and walls by a three-hour rated fire barrier. The ceiling was constructed of reinforced concrete supported by fireproofed structural steel.
The FPP requirements for structural steel fire proofing were described in Section 3.11.4 of UFSAR Appendix 9.6A. The licensee was required to provide a three-hour fireproofing to all structural steel supporting or forming a part of an identified fire zone or area fire barrier in order to maintain its integrity. The structural steel fireproofing designs were required to comply with standard details and designs tested by Underwriter Laboratories (UL) for a three-hour fire rating.
The required fireproofing thickness for structural steel members smaller than those tested by UL was determined in accordance with instructions contained in the UL Fire Resistance Directory - 1984 Edition. In addition, Specification 5177-265-A-149, Technical Specification for Furnishing and Delivery of Cementitious Fire Proofing for Florida Power and Light Company, Revision (Rev) 1, required the manufacturer to provide calculations for determining fireproofing requirements and recommend fireproofing thickness for beam and columns sizes less than those UL tested.
At the time of the inspection, the licensee was unable to provide UL listing data, fire tests results, or engineering calculations demonstrating that the installed fireproofing in FZ 104 was sufficient to meet the FPP fire resistance requirements. The inspectors reviewed Drawing 5610-A-181, Fire Proofing & Installation Guidelines, Rev. 8 and Calculation M12-202-11, Temperature Response of I-Beams with Steel Attachments, Rev. 2 to independently estimate the fire resistance of selected fireproofed beam and column sizes. The inspectors used the methodology described in NUREG 1805, Chapter 17, Calculating the Fire Resistance of Structural Steel Members, dated December 2004. Based on the reviewed documentation and independent calculations, the inspectors determined that the structural steel fire proofing for FZ 104 had an indeterminate fire resistance rating instead of the required three hours.
Analysis:
The licensees failure to ensure that structural steel that was part of a fire barrier was provided with a three-hour fire proofing as required by the approved FPP was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
The significance of this finding was evaluated using IMC 0609, Appendix F, "Fire Protection Significance Determination Process, dated February 28, 2005, because the performance deficiency affected fire protection defense-in-depth strategies involving fire confinement. The finding was assigned a Moderate degradation rating (in accordance with IMC 0609, Appendix F, 2) since the inspectors determined that some substantial credit could be given despite the lack of fire test results or engineering evaluation documenting the fire rating of the structural steel fire proofing. Question 5 of IMC 0609, Appendix F, Task 1.3.2 screened the finding to very low safety significance (Green) since the inspectors determined that the affected structural fireproofing would provide more than 20 minutes of fire endurance. This determination was based on the methodology described in NUREG 1805, Chapter 17, Calculating the Fire Resistance of Structural Steel Members. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding occurred in the past (original plant fireproofing designs) and was not indicative of current licensee performance.
Enforcement:
OLC 3.D of the Renewed Facility Operating License No. DPR-31 states, that Florida Power and Light shall implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for Turkey Point Units 3 and 4 and as approved in the Safety Evaluation Report dated March 21, 1979. Section 3.11.4 of UFSAR Appendix 9.6A states, in part, that all structural steel supporting or forming a part of an identified fire zone or area fire barrier, is provided with three-hour rated fireproofing in order to maintain its integrity. The structural steel fireproofing designs shall comply with standard details and designs tested by UL for a three-hour fire rating. The required fireproofing thickness for structural steel members smaller than those tested by UL is determined in accordance with instructions contained in the UL Fire Resistance Directory - 1984 Edition.
Contrary to the above, on June 28, 2013, the licensee failed to ensure that structural steel supporting or forming a part of identified fire barrier in FZ 104 was provided with three-hour rated fireproofing. Specifically, the licensee was unable to provide UL listing data, fire tests results, or engineering calculations demonstrating that the installed structural steel fireproofing in FZ 104 was sufficient to meet the FPP fire resistance requirements. The licensee entered the deficiency into their corrective action program as AR-1886074 and supplemented existing hourly fire watch patrol compensatory measures in FZ 104. This violation is being treated as an NCV, consistent with section 2.3.2 of the NRC Enforcement Policy. NCV 05000250/2013007-01, Failure to ensure that structural steel that was part of a fire barrier was provided with a three-hour fireproofing.
.03 Active Fire Protection
a. Inspection Scope
The inspectors reviewed the redundancy of fire protection water sources and fire pumps to confirm they were installed in accordance with the National Fire Protection Association (NFPA)codes of record to satisfy the applicable separation, design requirements, and licensing basis requirements of the TPN FPP and Appendix 9.6A of the UFSAR. The inspectors performed in-plant observations of the material condition and operational lineup for the operation of the fire water pumps and fire protection water supply distribution piping including, manual fire hose and standpipe systems for the selected FA/FZs. Using operating and valve cycle/alignment procedures as well as engineering drawings, the inspectors examined the electric motor-driven and the diesel-driven fire pumps and accessible portions of the fire main piping system to evaluate operational status, consistency of as-built configurations with engineering drawings, and to verify correct system valve lineups (i.e. position of valves). The inspectors also examined portions of the licensees SSA and select electrical circuit routing drawings outlining the fire water pumps power and pressure start capability to verify that the fire water system would be available to support fire brigade response activities during power block fire events.
The inspectors compared the fire detection and fire suppression systems for the selected FAs/FZs to the applicable NFPA Standard(s) by reviewing design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The inspectors reviewed selected fire protection vendor equipment specifications, drawings, and engineering calculations to determine whether the fire detection and suppression methods were appropriate for the types of fire hazards that existed in the selected FAs/FZs. During plant walkdowns, the inspectors observed the placement of the fire hose stations, fire extinguishers, fire hose nozzle types, and fire hose lengths, as designated in the firefighting pre-plan strategies, to verify they were not blocked and adequate reach and coverage was provided consistent with the firefighting strategies and FPP documents. The inspectors reviewed completed periodic surveillance testing and maintenance program procedures for the fire detection and suppression systems and compared them to the operability, testing, and compensatory measures requirements of procedure 0-ADM-016.3, Fire Protection Impairments. This review was to assess whether the test program was sufficient to validate proper operation of the fire detection and suppression systems in accordance with their design requirements.
Aspects of fire brigade readiness were reviewed, including but not limited to, the fire brigades personal protective equipment, self-contained breathing apparatuses, portable communications equipment, and other fire brigade equipment to determine accessibility, material condition and operational readiness of equipment. During plant walkdowns, the inspectors compared firefighting pre-plan strategies to existing plant layout and equipment configurations and to fire response ONOPs for the selected FAs/FZs. This was done to verify that firefighting pre-fire plan strategies and drawings were consistent with the fire protection features and potential fire conditions within the area and also to determine if appropriate information was provided to fire brigade members to facilitate suppression of an exposure fire that could impact the SSD strategy.
b. Findings
No findings were identified.
04. Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The inspectors evaluated whether water-based manual firefighting activities could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local OMAs required for SSD in the selected FAs/FZs. The inspectors reviewed available documentation related to flooding analysis from fire protection activities as well as potential flooding through unsealed concrete floor cracks. The inspectors also performed independent calculations of inter-area migration of water under fire doors to validate feasibility of selected OMAs in adjacent plant areas.
Firefighting pre-plan strategies; fire brigade training procedures; fire damper locations; heating, ventilation and air conditioning (HVAC) drawings; and, fire response procedures were reviewed to verify that inter-area migration of ventilation of gaseous heat and smoke was addressed and access to safe shutdown equipment and OMAs would not be inhibited by smoke migration from one area to adjacent plant areas used to accomplish SSD.
b. Findings
No findings were identified.
.05 Alternative Shutdown Capability
a. Inspection Scope
No fire zones selected were credited as alternative shutdown capability for a postulated fire. In cases where local OMAs are credited in lieu of Appendix R III.G.2 cable protection of SSD components, the inspectors performed walk-throughs of the procedures to verify that the OMAs were feasible.
b. Findings
No findings were identified.
.06 Circuit Analyses
Inspection Scope
The inspectors reviewed UFSAR 9.6A, Fire Protection Program Report, system flow diagrams, and the TPN post-fire SSA to verify that the licensee had identified both required and associated circuits that may impact post-fire SSD for the selected FAs/FZs. On a sample basis, the inspectors verified that the cables of equipment specified in the SSA essential equipment list required for achieving and maintaining shutdown conditions, in the event of a fire in the selected fire zones, had been properly identified. In addition, the inspectors reviewed cable routing information for credited equipment/components and verified that these cables had either been adequately protected from the potentially adverse effects of fire damage or analyzed to show that fire induced faults (e.g. hot shorts, open circuits, and shorts to ground) would not prevent post-fire safe shutdown. The inspectors reviewed the licensees electrical coordination study to determine if power supplies were susceptible to fire damage, which would potentially affect the credited components for the FAs/FZs chosen for review. The specific components reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The inspectors reviewed the communication capabilities required to support plant personnel in the performance of OMAs to achieve and maintain SSD, as credited in the TPN UFSAR, Appendix 9.6A, and Section 3.8. The inspectors performed plant walkdowns with the licensees operations staff to assess the credited method of communications used to complete safe shutdown actions as specified in post-fire SSD procedures for the selected FAs/FZs. The inspectors assessed the operators ability to communicate based upon completed actions by requesting licensee operations staff to perform radio checks during the walkdowns from applicable control locations. The inspectors assessed if communications were possible given the background noise from plant equipment to determine if this would deter the operators ability to implement the response strategy within the time required by the plant feasibility analysis. The inspectors also verified that portable radio communications and fixed emergency communication systems were available, operable, and adequate for the performance of designated activities to support fire event notification and fire brigade firefighting activities.
Additionally, the inspectors verified that the design and location of communications equipment, such as repeaters and transmitters, would not cause a loss of communications during a fire.
The inspectors reviewed preventive maintenance and surveillance test records and vendor manuals to verify that the communication equipment was being properly maintained and tested.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The inspectors reviewed maintenance and design aspects of the fixed 8-hour battery pack emergency lighting units (ELUs) required by 10 CFR 50 Appendix R, Section III.J and the TPN approved FPP. The inspectors performed plant walkdowns of the post-fire SSD procedures for the selected FAs/FZs to observe the placement and coverage area of the ELUs required to illuminate operator access and egress pathways, and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. In some instances, operations personnel performed onsite tests of the ELUs to verify operation. The inspectors also reviewed the availability of portable 8-hour battery powered emergency lights located in storage lockers in select plant locations. The portable 8-hour battery powered emergency lights were credited in the licensees FPP for operator access and egress routes, and to perform the OMAs required by plant fire response procedures. The inspectors also reviewed completed surveillance and maintenance tests to verify that adequate surveillance testing was in place. The manufacturers information and vendor manuals for the fixed and portable 8-hour battery pack ELUs were reviewed to verify that the battery power supplies were rated with at least an 8-hour capacity.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The inspectors interviewed licensee personnel and reviewed both the UFSAR Appendix 9.6A and the SSA to verify that the licensee had evaluated the need for cold shutdown repairs. The inspectors determined that the licensee did not take credit for repairs to cold shutdown components in order to achieve cold shutdown.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection Scope
- (1) Compensatory Measures for Degraded Fire Protection Components
The inspectors reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features (e.g. detection and suppression systems and passive fire barriers) to verify that short-term compensatory measures adequately compensated for the degraded function or feature until appropriate corrective actions could be taken.
- (2) Operator Manual Actions as Compensatory Measures for Safe Shutdown
The TPN post-fire SSD methodology utilized OMAs to address fire-induced circuit failures, which could potentially prevent operation or cause maloperation of equipment needed to achieve and maintain post-fire SSD conditions. The NRC specified in the Federal Register (71 FR 11169); dated March 6, 2006, that OMAs are acceptable as compensatory measures for corrective actions contingent upon the OMAs being feasible. If the OMAs used were consistent with the enforcement guidance in EGM 98-02 in combination with the criteria specified in IP 71111.05T the actions met the basis for adequacy and appropriateness of compensatory measures to restore compliance. In the case of TPN, the corrective actions to restore compliance involved adoption of NFPA 805 through 10 CFR 50.48(c). In this instance, by letter to NRC dated November 15, 2005 (ML053290175), Florida Power & Light Company submitted a letter of intent to transition the current licensing basis to NFPA 805 Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, 2001 Edition, (NFPA 805 Rule) in accordance with the requirement in Title 10 of the Code of Federal Regulations Part 50.48(c) (CFR 50.48(c)) for Turkey Point Nuclear Plant Units 3 and 4.
The inspectors reviewed licensee operator manual actions feasibility calculations PTN-ENG-SEMS-03-045 which initially documented OMAs for Turkey Point Units 3 & 4 as well as supplemental calculation PTN-FPER-13-001. In cases where local OMAs were credited in lieu of cable protection of SSD equipment, the inspectors reviewed and performed walkdowns of those applicable OMAs as specified by 0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions to verify that the OMAs were feasible utilizing the guidance of NRC IP 71111.05T, paragraph 02.02.j.2. A list of SSD components examined for cable routing is included in the Attachment.
b. Findings
No findings were identified.
.11 Review and Documentation of Fire Protection Program Changes
a. Inspection scope
The inspectors reviewed a sample of FPP changes made between January 2010 and March 2013 to assess the licensees effectiveness and to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse effect on the ability to achieve SSD.
b. Findings
No findings were identified.
.12 Control of Combustibles and Ignition Sources
a. Inspection Scope
The inspectors conducted tours of numerous plant areas that were important to reactor safety, including the selected FAs/FZs, to verify the licensees implementation of FPP requirements as described in the TPN Fire Protection Program and administrative procedure 0-ADM-016.1, Transient Combustible and Flammable Substances Program. For the selected FAs/FZs, the inspectors evaluated generic fire protection training; fire event history; the potential for fires or explosions; the combustible fire load characteristics; and, the potential exposure fire severity to determine if adequate controls were in place to maintain general housekeeping consistent with the UFSAR, administrative procedures, and other FPP procedures. The inspectors also performed independent calculations to validate that the licensee had adequate controls against hydrogen explosion in the batteries rooms adjacent to FZ 104. There were no hot work activities ongoing within the selected fire areas during the inspection and observation of this activity could not be performed.
b. Findings
No findings were identified.
.13 B.5.b Inspection Activities
a. Inspection Scope
The inspectors reviewed, on a sample basis, the licensees external makeup to the spent fuel pool strategy. The inspectors verified that the guidelines were feasible, personnel were trained to implement the strategy, and equipment was properly staged and maintained to ensure the licensee staff provided an adequate response to large fires and explosions specified by the guidelines. The inspectors requested and reviewed the inventory of equipment; maintenance records of required equipment; job performance measures and requests to view the physical location of the equipment to ensure all attributes would be available based upon the chosen strategy. The inspectors performed walk downs 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, calibrated, maintained, and tested in accordance with the licensees B.5.b program procedures.
Through discussions with licensee staff, review of applicable documentation, and plant walkdowns, the inspectors verified the engineering assumptions credited with responding to this type of an event were reasonable. The inspectors reviewed engineering calculations to assess the water makeup capacity required by the strategy and concluded there was reasonable assurance that specified requirements could be met using the specified equipment and credited water sources listed in the implementation guidelines. The inspectors reviewed completed training records of the licensees staff to verify that personnel were trained and familiar with the applicable strategy objectives and implementing guidelines. In instances where records for potential responders were not available, the inspectors performed interviews of licensee personnel.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed a sample of licensee independent audits, self-assessments, and system/program health report for thoroughness, completeness and conformance to FPP 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 Nuclear Quality Assurance Plan.
The inspectors also reviewed CAP documents, including completed corrective actions documented in selected Action Requests (ARs) and operating experience program documents, to ascertain whether industry identified fire protection issues (actual or potential) affecting TPN were appropriately entered into the corrective action program for resolution. Items included in the operating experience program effectiveness review were NRC Information Notices, Regulatory Issue Summaries (RISs), industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters. The inspectors evaluated the effectiveness of the corrective actions for the identified issues. The documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On June 28, 2013, the lead inspector presented the preliminary inspection results to Mr. M.
Kiley, TPN Site Vice President, and other members of the licensees staff, who acknowledged the results. Proprietary information is not included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Conrad, St. Lucie Fire Protection Engineer
- O. Hanek, Licensing Engineer
- M. Kiley, Site Vice President
- A. Lay, Non-Licensed Operator
- E. McCartney, Site General Manager
- K. Mohindroo, Engineering Manager
- V. Molina, Fire Protection Engineer
- J. Pallin, Maintenance Director
- J. Patterson, Fire Protection Coordinator
- V. Rubano, Fire Protection Chief Engineer
- C. Rossi, Quality Assurance Supervisor
- B. Thaker, Appendix R Engineer
- B. Tomonto, Licensing Manager
- M. Wayland, Operations Director
NRC Personnel
- T. Hoeg, Senior Resident Inspector, TPN
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None
Opened and Closed
- 05000250/2013007-01 NCV Failure to ensure that structural steel that was part of a fire barrier was provided with a three-
hour fire proofing (Section 1R05.02)
Discussed
None
SUPPLEMENTAL INFORMATION
LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section 1RO5.02-Passive Fire Barriers)
Fire Barriers Floors/Walls/Ceiling Identification Description Masonry Block Wall Construction FZ70 to FZ71
Fire Door Identification
Description Door D-070-1
FZ70 to FZ88 Door D-070-3
FZ70 to FZ71 Door D-061-1
FZ61 to FZ79 Door D-098-2
FZ104 to FZ98 Door D-104-2
FZ104 to FZ101
Fire Damper Identification
FZ104 to FZ101
Electrical Raceway Fire Barrier System Identification Description Conduit B-3J 1618
FZ104 Conduit B-4J 1607
FZ104 Conduit 3A064
FZ104
Structural Steel Fireproofing Identification Spray-Applied Cementitious Fireproofing (Albi Duraspray) FZ104
LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1R05.01 / 1R05.03 / 1R05.05 / 1R05.06)
E-16F, DC/ Inverter Room A/C Unit (South Unit)
E-16D, DC/ Inverter Room A/C Unit (Common Unit)
FCV-3(4)-113A, Boric Acid Flow to Blender FCV-3(4)-113B, Borated Water Charging Pump Suction LCV-4-115A, Letdown to VCT/HT Divert Valve LCV-3-115A, Letdown to VCT/HT Divert Valve MOV-4-716B, CCW to RCP Thermal Barrier Supply Isolation Valves 3P201A, Charging Pump 3A 4P201A, Charging Pump 4A 4P201C, Charging Pump 4C MOV-3-536, Unit 3 Pressurizer Relief Isolation Valve MOV-4-536, Unit 4 Pressurizer Relief isolation Valve 3AA21, 4160V Supply Breaker for Condensate Pump 3A 3P201A, Charging Pump 3A Control 3P201B, Charging Pump 3C Control 4P201A, Charging Pump 4A Control 4P201C, Charging Pump 4C Control 4RTA, Reactor Trip Breaker 4RTB, Reactor Trip Breaker
Instruments FT-3-1401B, AFW Flow to S/G A FT-3-1447B, AFW Flow to S/G B FT-3-1458B, AFW Flow to S/G C LT-3-460, Pressurizer Level Transmitter LT-3-477, Steam Generator Level Transmitter LT-3-487, Steam Generator Level Transmitter LT-3-497, Steam Generator Level Transmitter LT-3-722, Steam Generator Level Transmitter PT-3-1607, SG B Steam Pressure Transmitter