IR 05000263/2020011
| ML20091L304 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/31/2020 |
| From: | Paul Zurawski Engineering Branch 3 |
| To: | Conboy T Northern States Power Co |
| References | |
| IR 2020011 | |
| Preceding documents: |
|
| Download: ML20091L304 (11) | |
Text
March 31, 2020
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000263/2020011
Dear Mr. Conboy:
On February 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Monticello Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Monticello Nuclear Generating Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Paul J. Zurawski, Acting Chief Engineering Branch 3 Division of Reactor Safety
Docket No. 05000263 License No. DPR-22
Enclosure:
As stated
Inspection Report
Docket Number:
05000263
License Number:
Report Number:
Enterprise Identifier: I-2020-011-0016
Licensee:
Northern States Power Company, Minnesota
Facility:
Monticello Nuclear Generating Plant
Location:
Monticello, MN
Inspection Dates:
January 27, 2020 to February 14, 2020
Inspectors:
M. Domke, Reactor Inspector
J. Robbins, Acting Sr. Resident Inspector
A. Shaikh, Senior Reactor Inspector
Approved By:
Paul J. Zurawski, Acting Chief
Engineering Branch 3
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Monticello Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Maintain Adequate Fire Protection System Functional Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000263/2020011-01 Open/Closed None (NPP)71111.21N.
The inspectors identified a finding of very-low safety significance and associated violation of Technical Specification 5.4.1.d, Fire Protection Program Implementation", for the licensees failure to maintain a fire protection program procedure. Specifically, the licensee failed to maintain Procedure 0266, Fire Pumps Simulated Auto-Actuation and Capability Test by failure to include acceptance criteria in the procedure that accounted for piping degradation since piping installation that demonstrated fire protection system functionality.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
===71111.21N.05 - Fire Protection Team Inspection (FPTI)
SSC Credited for Fire Prevention, Detection, Suppression, or Post-Fire SSD Review (IP Section 03.01)===
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
- (1) Division II RHR Pumps
- (2) Fire Area 8 (Cable Spreading Room) Fire Dampers and Smoke Detectors
- (3) Fire Suppression System Fire Pumps ( Diesel, Electric, and Screenhouse)
- (4) Fire Area 8 (Cable Spreading Room) Post-Fire SSD
Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (1) Combustible Control Program
Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors verified the following:
a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
b. The adequacy of the design modification, if applicable.
c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.
- (1) Generic Letter 86-10 Evaluation for Cable Spreading Room Fire Damper Fire Resistance Rating
INSPECTION RESULTS
Failure to Maintain Adequate Fire Protection System Functional Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000263/2020011-01 Open/Closed
None (NPP)71111.21N.05 The inspectors identified a finding of very-low safety significance and associated violation of Technical Specification 5.4.1.d, Fire Protection Program Implementation", for the licensees failure to maintain a fire protection program procedure. Specifically, the licensee failed to maintain Procedure 0266, Fire Pumps Simulated Auto-Actuation and Capability Test by failure to include acceptance criteria in the procedure that accounted for piping degradation since piping installation that demonstrated fire protection system functionality.
Description:
The Monticello Nuclear Generating Plant fire protection program is described in AWI.08.01.00, Rev. 23 Fire Protection Program Plan, and Section 4.8.5, Implementing Documents, lists the documents that implement the fire protection program. Ops Manual B.08.05-05, Fire Protection - System Operation, is listed under Section 4.8.5 of AWI.08.01-00 as an implementing document. Ops Manual B.08.05-05, Rev. 78, Section B, Fire Suppression Water Supply System, states, in part, that any two of the fire water pumps, including automatic initiation logic, SHALL be capable of delivering sufficient flow and pressure to satisfy the demand (including hose stream) of the most demanding water based suppression system and that the ability to meet this requirement is demonstrated by satisfactory completion of surveillance 0266, Fire Pumps Simulated Auto-Actuation and Capability Test.
During review of the work orders for the last performed fire pump and fire water flow tests, the inspectors identified that the acceptance criteria in the procedure associated with the fire pump test relied on historic data and assumptions. Specifically, procedure 0266, which was performed to satisfy the requirements of Ops Manual B.08.05-05 and ensure the functionality of the fire protection system pumps and auto-initiation logic contained acceptance criteria in step 96 that assumed original plant conditions. Step 96 requires the plotted fire pump curves (flow vs. pressure) to lie above all the fire suppression demand points in order to ensure functionality of the fire protection system pumps to deliver fire suppression water to the most limiting suppression loads at the site. These suppression demand points were predetermined from original plant hydraulic analysis of the fire protection suppression system. In order to obtain a suppression demand point (pump flow at specific required discharge pressure) for a particular fire area, the total frictional losses incurred along sections of piping delivering the fire water from the discharge of the fire pump up to the suppression load sprinkler heads must be calculated and subtracted from the pump's discharge pressure. The methodology for calculating total frictional losses over the length of piping is described in National Fire Protection Association (NFPA) 13, "Standard of Installation of Sprinkler Systems" and uses an equation (Williams-Hazen) that contains a piping roughness factor also known as the coefficient of friction or C-factor. The inspectors determined that the licensee had implemented the coefficient of friction values (C-factors) as described in NFPA 13 for all the suppression system demand points and these C-factors assume nominal pipe with some degradation equivalent to a few years of service. However, the inspectors noted that although the C-factor would further degrade over time, the licensee had not changed or adjusted the C-factors over the 50+ years since installation from the values specified in the installation standard NFPA 13. The inspectors questioned the validity of the licensee's assumption that no further degradation has occurred over 50 years since installation. If the C-factor assumed further degradation of piping since installation then the calculated frictional losses would increase along the piping from the pump's discharge up to the suppression load point and hence, the suppression demand points for each fire area would increase since the pump would now have to overcome those frictional pressure losses from its discharge up to the suppression load point. Therefore, the plotted pump curves as determined from procedure 0266 could inadvertently lie below the re-calculated suppression demand points and potentially adversely impact the functionality of the fire pumps to deliver required flow and pressure to the most limiting suppression loads on site. The licensee entered the inspectors' concerns into its corrective action program and leveraged a third-party vendor to perform a hydraulic analysis of its fire suppression system taking into consideration corrosion effects from installation to present. In the report, the licensee calculated the current expected C-factors for each fire area that are used in step 96 of procedure 0266 taking into consideration corrosion effects and compared these expected C-factors to the most limiting C-factor that the fire suppression system can tolerate. The EDG room provided the most limiting C-factor for the site at 92 and the expected calculated C-factor considering corrosion since installation was above 92 but below the NFPA 13 specified value. The inspectors reviewed the vendor's report as provided by the licensee and did not identify any additional questions.
Corrective Actions: The licensee entered the inspectors' concern into its corrective action program (CAP) and implemented immediate corrective actions that included performing a detailed fire protection suppression system hydraulic calculation to determine system margins and limits. Subsequent to this immediate corrective action, the licensee intends to revise procedure 0266 to include appropriate margin and limits as detailed in the hydraulic calculation performed.
Corrective Action References: AR 501000037221 - 2020 FP Insp: Fire Flow Test Concerns
Performance Assessment:
Performance Deficiency: The Inspectors determined that the licensees failure to maintain procedure 0266, "Fire Pumps Simulated Auto-Actuation and Capability Test", by not including acceptance criteria that accounted for piping degradation since installation of the piping was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to maintain procedure 0266 by not including acceptance criteria that accounted for piping degradation since installation of piping, resulted in a deficient procedure that could have resulted in the acceptance of fire pump performance that would not be able to satisfy the required flow and pressure demand of the most demanding water based suppression system and therefore, adversely impacted the functionality of the fire protection suppression system.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors screened the finding using IMC 0609, Appendix F, Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet, dated May 02, 2018. The inspectors answered YES to Question 1.4.3.A, Would adequate fire water capacity (flow at required pressure) still be available for protection of equipment important to safe shutdown in the most limiting location onsite? Therefore, the inspectors determined that the finding screened as having a very-low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Technical Specification 5.4.1.d requires, in part, that, written procedures shall be established, implemented, and maintained covering the Fire Protection Program implementation. Document AWI.08.01.00, Rev. 23 Fire Protection Program Plan, Section 4.8.5, Implementing Documents, lists the documents that implement the fire protection program onsite at Monticello and includes Ops Manual B.08.05-05, Fire Protection - System Operation as an implementing document. Ops Manual B.08.05-05, Rev. 78, Section B, Fire Suppression Water Supply System, states, in part, that any two of the fire water pumps, including automatic initiation logic, SHALL be capable of delivering sufficient flow and pressure to satisfy the demand (including hose stream) of the most demanding water based suppression system and that the ability to meet this requirement is demonstrated by satisfactory completion of surveillance 0266, Fire Pumps Simulated Auto-Actuation and Capability Test.
Contrary to the above, since April 1978 to June 14, 2018, the licensee failed to maintain procedure 0266 that implemented the Fire Protection Program requirement in the Ops Manual B.08.05-05 to verify that the fire pumps would be capable of delivering sufficient flow and pressure to satisfy the demand of the most demanding water based suppression system.
Specifically, procedure 0266 did not contain acceptance criteria that accounted for piping degradation since initial installation to verify that the fire protection water system could satisfactorily complete the flow and pressure requirements in procedure 0266.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 27, 2020, the inspectors presented the triennial fire protection inspection results to Mr. T. Conboy, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.05 Calculations05-084
Fire Load Calculation Sheet, 1A - RHR "B" and Core
Spray Pump Room, Division II
2B
16-073
4kV Coordination Study
0A
Corrective Action
Documents
033247
Fire Induced MSIV Operation
05/18/2004
039865
Fire Induced Damage in CSR or CR may Result in
Deadheading B RHR Pump
07/13/2005
500001445615
Fire Panel Fuse Rating Inspection
09/05/2014
500001530637
2016 FP FSA: CSR Same Fire Area as Admin
08/04/2016
500001547508
CV-1995 did not Open on a Shutdown of 12 RHR Pump
01/14/2017
500001549276
Fuse Installed at C-739/FUSE-7 Does Not Match Print
2/01/2017
501000019560
3rd Party Testing Issues-Obs EQ Project
11/13/2018
501000032124
Teledyne #13, "A" RHR Room
09/21/2019
Corrective Action
Documents
Resulting from
Inspection
501000037099
20 FP Insp: Complex Question Requires > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
01/29/2020
501000037221
20 FP Insp: Fire Flow Test Concerns
01/30/2020
501000037402
20 FP Insp: Editorial Error in USAR-J
2/10/2020
501000037518
Inspection Management Concerns
2/09/2020
501000037619
20 FP Insp: Update USAR Reference
2/12/2020
501000037630
20 FP Insp: Editorial Error FPEE-19-001
2/12/2020
501000037730
20 FP Insp: Surveillance Signature Question
2/13/2020
Engineering
Changes
0000016838
11, 12, 13 & 14 RHR Pump Cable Replacement
05/30/2013
245
Replace Agastat EGPD Relays Identified during RFO26
25092
Relay Replacement for EGP Relays Model EGPD004 and
EGPI004
601000000328
Upgrade Cable Spreading Room Fire Dampers
6DOCGMO21876
- 13 RHR Pump Motor Replacement
04/04/2013
93Q200
- 12 RHR Motor Replacement
Engineering
Evaluations
0067-0107-LTR-
005
MNGP Fire Protection System Piping Hydraulic Analysis
Review - Effect of Fire Main Corrosion on System
Capability
FPCR-19-009
B.08.05-05 STRIDE Frequency
09/12/2019
FPEE-19-001
Cable Spreading Room Fire Damper Fire Resistance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Rating
FPEE-19-002
Addition of Cable Spreading Room to Control Room Fire
Area VIII
MT-2018-ASD-13
STRIDE to Extend the Frequency of the Alternate
Shutdown System (ASDS) Cycle Functional Test
Miscellaneous
9759
Combustible Control Permit
01/13/2020
9762
Combustible Control Permit
01/13/2020
9766
Combustible Control Permit
01/22/2020
Safety Evaluation
by the Office of
Nuclear Reactor
Regulation
Hot Short Issue Associated with Information Notice 92-18
07/02/1993
Procedures
266
Fire Pumps Simulated Auto-Actuation and Capability Test
AWI-08.01.01
Fire Prevention Practices
4850-604-PM
2-604, 12 RHR Pump Relay Maintenance, Calibration,
and Test Tripping
4850-608-PM
2-608, 12 RHRSW Pump Relay Maintenance,
Calibration, and Test Tripping
FP-PE-CC-01
Combustible Control
FP-PE-FP-01
Fire Protection Regulatory Review
Ops Man C.4-C
Shutdown Outside Control Room
OWI-03.07
Time Critical Operator Actions
Monticello Surveillance Test Intervals
Work Orders
00440885
P-202C/MTR, Motor Overhaul
05/09/2014
00550280
OPS-FIR, 0266 Fire Pumps Simulation Auto-Actuation
and Capability Test
2/15/2016
28620 01
OPS-FIR, 0328 Halon System Functional Test
2/01/2017
700020731-0010
Cable Spreading Room Halon System
2/02/2018
700022709-0010
Fire Pumps Simulated Auto-Actuation and Capability Test
06/14/2018
700032132-0010
Fire Protection System Flow Test
09/13/2018
700045838-0010
Fire Protection System Flow Test
09/14/2019