IR 05000269/2013007

IR 05000269-13-007, 05000270-13-007, 05000287-13-007; 07/22/2013 - 08/09/2013; Oconee Nuclear Station Units 1, 2, and 3; Fire Protection - NFPA 805 (Triennial)

ML13268A071
Person / Time
Site:	Oconee
Issue date:	09/23/2013
From:	Mark King NRC/RGN-II/DRS/EB2
To:	Batson S Duke Energy Corp
Linda Gruhler for Joyce Calloway
References
IR-13-007
Download: ML13268A071 (42)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 23, 2013

SUBJECT:

OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000269/2013007, 05000270/2013007, 05000287/2013007 AND APPARENT VIOLATIONS

Dear Mr. Batson:

On August 9, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oconee Nuclear Station, Units 1, 2, and 3. The enclosed inspection report documents the inspection results, which were discussed with you and other members of your staff on August 9, 2013. Following completion of additional post-inspection analysis of the inspection findings and review of additional information by the NRC in the Region II office, a final exit was held by telephone with you and other members of your staff on September 23, 2013, to provide an update on changes to the preliminary inspection findings.

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 team reviewed selected procedures and records, observed activities, and interviewed personnel.

Two NRC-identified findings related to compliance with the requirements of the approved fire protection program, which have potential safety significance greater than very low significance, were identified during this inspection. However, the significance determination has not been completed. These findings were determined to involve apparent violations of NRC requirements. The first finding involved two examples where the Oconee fire probabilistic risk assessment failed to address all ignition sources and targets as risk contributors associated with potentially risk significant fire scenarios. The second finding involved failure to comply with the Fire Protection License Condition for a change to the approved fire protection program related to control of transient fire loads without obtaining prior NRC approval. The NRC has also determined that a traditional enforcement violation occurred associated with the second finding.

The severity level of the traditional enforcement violation will be assigned based on the significance determination of the associated finding. These findings did not present immediate safety concerns because they were entered into your corrective action program and compensatory measures were implemented in the form of additional roving fire watches in the fire areas/fire zones that were impacted.

S. Baton 2 Additionally, the report documents two NRC-identified findings of very low safety significance (Green), which were also determined to involve violations of NRC requirements. However, because of the very low safety significance of these violations and because they were entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest these NCVs, 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 Oconee Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, RII, and the NRC Resident Inspector at the Oconee Nuclear Station.

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.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55

Enclosure:

Inspection Reports 05000269/2013007, 05000270/2013007, 05000287/2013007 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55 Report Nos.: 05000269/2013007, 05000270/2013007, 05000287/2013007 Licensee: Duke Energy Carolinas, LLC Facility: Oconee Nuclear Station, Units 1, 2 and 3 Location: Seneca, SC 29672 Dates: July 22-26, 2013 (Week 1)

August 5-9, 2013 (Week 2)

Inspectors: M. Thomas, Senior Reactor Inspector (Lead Inspector)

P. Braxton, Reactor Inspector (Week 2)

J. Dymek, Reactor Inspector J. Eargle, Senior Reactor Inspector J. Montgomery, Reactor Inspector R. Rodriguez, Senior Project Inspector S. Sanchez, Senior Reactor Inspector (Week 1)

D. Terry-Ward, Construction Inspector (Training)

Approved by: Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000269/2013007, 05000270/2013007, 05000287/2013007; 07/22/2013 - 08/09/2013;

Oconee Nuclear Station Units 1, 2, and 3; Fire Protection - NFPA 805 (Triennial)

This report covers an announced two-week triennial fire protection inspection by a team of seven regional inspectors and one inspector in training. Two Apparent Violations (one with an associated traditional enforcement violation) and two Green non-cited violations were identified.

The significance of inspection findings is indicated by their color (i.e., greater than Green, or 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 July 9, 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.

Cornerstone: Mitigating Systems

TBD: An NRC-identified Apparent Violation (AV) was identified for the licensees failure to comply with the requirements of 10 CFR 50.48(c) and National Fire Protection Association Standard 805 (NFPA 805). The Oconee fire probabilistic risk assessment (Fire PRA) failed to address the risk contributions associated with all potentially risk significant fire scenarios. This finding does not represent an immediate safety concern because the licensee entered the issue in the corrective action program as Problem Investigation Program (PIP) O-13-08059 and PIP O-13-08061 and implemented fire watches as compensatory measures.

Failure to comply with the requirements of 10 CFR 50.48(c) and NFPA 805 to address the risk contributions associated with all potentially risk significant fire scenarios was a performance deficiency. This performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone objective of protection against external events (i.e., fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be potentially greater than

Green.

Therefore, further analysis is required to assess the significance of the finding. The cause of this finding was determined to have a cross-cutting aspect of H.4(c) in the Work Practices component of the Human Performance area because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported. (Section 1R05.06)

TBD. An NRC-identified Apparent Violation (AV) and associated traditional enforcement violation of Oconee Nuclear Station Renewed Facility Operating License Condition 3.D for Units 1, 2, and 3 was identified for the licensees failure to implement and maintain in effect all provisions of the approved fire protection program (FPP) that comply with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. The licensee made a change to the approved FPP involving control of combustible materials when the definition of transient fire loads was revised to exclude fire retardant scaffolding materials as transient fire loads, which would not require the licensee to track these items as combustible fire loads. The licensee also failed to submit the FPP change to the NRC for review and approval prior to implementation which impacted the ability of the NRC to perform its regulatory oversight function. The licensee entered this issue into the corrective action program as Problem Investigation Program O-13-08584. This finding did not represent an immediate safety concern because the licensee implemented compensatory measures in the form of combustible tracking impairments and fire watches in the high safety significant fire zones which contained the scaffolding.

Failure to comply with Oconee Operating License Condition 3.D for a change to the approved FPP involving control of fire retardant scaffolding materials was a performance deficiency. This performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external events (i.e. fire), and it adversely affected the cornerstone objective in that the change to the FPP had the potential to adversely affect the ability to achieve and maintain safe and stable plant conditions due to the increased transient fire load in the affected fire zones. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), Attachment 4,

Initial Characterization of Findings, which determined that an IMC 0609 Appendix F,

Fire Protection Significance Determination Process, review was required as the finding affected fire prevention and administrative controls. The performance deficiency applied to most fire zones within the plant because the licensee stopped tracking the use of the fire retardant scaffolding materials. The team determined that a systematic plant-wide assessment effort was beyond the intended scope of the fire protection SDP. Therefore additional analysis is required to assess the significance of this finding. The cause of this finding was determined to have a cross-cutting aspect of H.1(b) in the Decision-Making component of the Human Performance area because the licensee used non-conservative assumptions in the decision making associated with this FPP change.

Additionally, the licensees failure to submit the FPP change to the NRC was a traditional enforcement violation. The severity level of the traditional enforcement violation will be assigned based on the significance determination of the associated finding. (Section 1R05.14)

Green.

An NRC-identified Green non-cited violation (NCV) of Oconee Nuclear Station Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D and NFPA 805 was identified for the licensees modification of five fire doors from their tested configurations without performing engineering equivalency evaluations. The licensee entered this issue into the corrective action program as Problem Investigation Program O-13-06900, and declared the door nonfunctional and implemented fire watches in accordance with Selected License Commitment 16.9.5 Fire Barriers.

The licensees modification of fire doors from their tested configuration without performing engineering equivalency evaluations was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external events (i.e., fire)and it adversely affected the cornerstone objective in that the modifications performed on the five fire doors adversely affected the capability of the doors to provide the required level of fire resistance. The finding was determined to be of very low safety significance (Green) because the fire doors would have either provided a two-hour or greater fire endurance rating, or would have provided a minimum of 20 minutes fire endurance protection; and the fixed fire ignition sources, and combustible or flammable materials, were positioned such that the degraded fire doors would not have been subjected to direct flame impingement. A cross-cutting aspect was not assigned because the performance deficiency did not reflect current licensee performance.

(Section 1R05.02)

Green.

An NRC-identified Green non-cited violation (NCV) of Oconee Nuclear Station Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D was identified for the licensees failure to follow procedures for the control of transient combustible materials. The team identified five examples where the licensee failed to follow procedure Nuclear System Directive (NSD) 313, Control of Transient Fire Loads, in that unapproved combustible materials were stored in fire areas/fire zones without proper evaluation and without appropriate compensatory actions being implemented.

The licensee entered these issues into the corrective action program as Problem Investigation Program documents O-13-07896, O-13-07897, O-13-07989, O-13-08051, and O-13-08459; and initiated immediate corrective actions to remove the unapproved combustibles from the identified fire areas/fire zones.

The licensees failure to follow procedure NSD 313 for storage of transient combustibles in fire areas/fire zones was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the reactor safety mitigating systems cornerstone attribute of protection against external events (i.e. fire),

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 finding was determined to be of very low safety significance (Green) because it only affected the ability to reach and maintain cold shutdown conditions. The cause of this finding was determined to have a cross-cutting aspect of H.4(b) in the Work Practices component of the Human Performance area, because the licensee did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures. (Section 1R05.15.b (1))

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 (TFPI) at the Oconee Nuclear Station (ONS), Units 1, 2, and 3. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05XT, Fire Protection - NFPA 805 (Triennial), issued January 31, 2013. Additionally, IP 71111.17T, Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications, issued March 5, 2013, was used to review a sample of engineering changes (EC). These ECs were associated with completion of the transition to full compliance with 10 CFR 50.48(c) in accordance with the transition license condition. The objective of the inspection was to review a minimum sample of two risk-significant Fire Areas (FAs)/Fire Zones (FZs) to verify implementation of the ONS Fire Protection Program (FPP). An additional objective was 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. Section 71111.05-05 of the IP specifies a minimum sample size of two FAs/FZs and one B.5.b mitigating strategy for addressing large fires and explosions. The team selected four FAs based on available risk information as analyzed onsite by a senior reactor analyst from Region II, data obtained from in-plant walkdowns regarding potential ignition sources, location and characteristics of combustibles, and location of equipment needed to achieve and maintain the reactor in a safe and stable condition. Other considerations for selecting the FAs were the relative complexity of the post-fire safe shutdown (SSD) procedures, information contained in FPP documents, and results of prior NRC TFPIs. 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. This inspection fulfilled the requirements of the procedure by selecting a sample of four FAs and one B.5.b mitigating strategy.

FA Turbine Building/FZ 19, Unit 1 Main Feedwater Pump Area is a performance based FA. Focus on fire scenario involving main feedwater pump 1B fire and nonsuppression.

FA BH12/FZ 45, Units 1 and 2 Block House is a performance based FA. Focus on fire scenario involving a transient fire at riser Q-100.

FA CT4/FZ 46, CT-4 Block House is a deterministic based FA. Focus primarily on classical fire protection features such as detection and suppression.

FA Auxiliary Building/FZ 106, Unit 1 Cable Room is a performance based FA which involves shutdown from a primary control station. Focus on fire scenario N1 involving a Control Rod Drive (CRD) Trans/logic cabinet severe fire.

For each of the selected FAs/FZs, the team evaluated the licensees FPP against applicable NRC requirements and licensee design basis documents. Documents reviewed by the team are not listed in the following sections are listed in the Attachment

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team examined ONS fire response Abnormal Procedures (APs) and compared them to the NFPA 805 Nuclear Safety Capability Assessment (NSCA) and Fire Risk Evaluation (FRE), systems flow diagrams, and other design basis documents to determine if equipment required to achieve post-fire safe and stable plant conditions was properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50.48(c) and the ONS approved FPP. Cable routing information was reviewed for a selected sample of SSD components to verify that either the associated cables would not be damaged for the selected FAs/FZs fire scenarios or the licensees analysis determined that the fire damage would not prohibit achieving safe and stable plant conditions. A list of SSD components examined for cable routing is included in the Attachment. The specific fire response APs reviewed are listed in the

.

The team reviewed applicable sections of the APs for the selected FAs/FZs and fire scenarios to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe and stable plant conditions. The team performed in-plant walk-throughs of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team 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 one operator recovery action and selected operator defense-in-depth 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.

.02 Passive Fire Protection

a. Inspection Scope

The team conducted walkdown inspections and examined the material condition and as-built configuration of accessible passive barriers both surrounding and within the FAs selected for review to evaluate the adequacy of their fire resistance in accordance with NFPA 805 calculations. Fire barriers inspected included masonry walls, poured concrete ceilings, floors and walls and installed mechanical and electrical penetration seals, fire doors and fire dampers. The team compared the as-built installed barrier configurations to the approved construction details and supporting fire endurance test data, which established the rating of the fire barriers. Fire doors and dampers were examined for attributes such as their material condition, clearances, proper operation, Underwriters Laboratory (UL) labels on the door and frame, and the method of attachment to the rated barrier. Doors were examined to verify that modifications had not been performed to void their UL listing. The team reviewed licensing basis documentation such as 10CFR 50.48(a), 10CFR50.48(c) and the NRC NFPA 805 Safety Evaluation Report (SER) to verify that passive fire protection features met licensing commitments. In addition, a sample of completed surveillances and maintenance procedures for selected fire doors, fire dampers and penetration seals were reviewed to ensure that these passive barriers were being properly inspected and maintained. The passive barriers reviewed are listed in the Attachment.

b. Findings

Introduction:

An NRC-identified Green NCV of Oconee Nuclear Station Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D and NFPA 805 was identified for the licensees modification of fire doors from their tested configurations without performing engineering equivalency evaluations.

Description:

Fire door 602A was located in a three-hour fire barrier separating the Unit 1 and 2 Control Room Air Handing Room in the Auxiliary Building (Fire Area 119), and the Unit 1 Upper Surge Tank Area of the Turbine Building (Fire Area 43). The team identified that the door had been modified in 1995 by the licensee under work order 95016605.

The modification consisted of inserting a pin into the hole where the manufacturer provided door hardware was located, and welding a stainless steel plate to the pin and the door. Additionally, a piece of angled steel was welded to the pin on the other side of the door to prevent the door from opening.

The door was procured as a three-hour assembly, and was labeled by Underwriters Laboratory (UL) meaning that the manufacturer received certification of the door through specified testing. Field modifications beyond the scope of prescriptive allowances by the labeling agency or manufacturer typically result in the decertification of the fire door.

The licensee did not perform an engineering equivalency evaluation to support the modification. This type of evaluation was required to address the effects of welding a fire rated assembly and obtain an evaluation or concurrence from the manufacturer or UL. Additionally, the team noted that NFPA 80, Fire Doors and Other Opening Protectives, required that when fire doors were no longer used for ingress and egress, that the opening shall be filled with construction equivalent to that of a wall. For these reasons, the team concluded that the licensee lacked reasonable assurance that the three-hour ratings of the doors were maintained.

The licensee entered this issue into the CAP as PIP O-13-06900, and declared fire door 602A as nonfunctional and implemented fire watches in accordance with Selected License Commitment (SLC) 16.9.5 Fire Barriers. Additionally, the license performed an extent of condition and identified an additional four doors that were modified without performing engineering equivalency evaluations. The licensee captured these issues with the additional four doors in PIP O-13-07343 and declared the doors as nonfunctional and implemented fire watches in accordance with SLC 16.9.5.

Analysis:

The licensees modification of fire doors from their tested configuration without performing engineering equivalency evaluations was a performance deficiency. The performance deficiency was more than minor because it adversely affected the Mitigating Systems cornerstone attribute of Protection Against External Events and adversely affected the cornerstone objective in that the modifications performed on the five fire doors adversely affected their capability to provide the required level of fire resistance. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, which determined that, an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated February 28, 2005, review was required as the finding involved the ability to confine a fire. The team evaluated the finding using the guidance in IMC 0609, Appendix F. Using the Phase 1 Qualitative Screening Approach, the finding was assigned a category of Fire Confinement. The team utilized step 1.3 Initial Qualitative Screening, task 1.3.1 Qualitative Screening For All Finding Categories to determine the finding to be of very low safety significance (Green) because the fire doors would have either provided a two-hour or greater fire endurance rating, or would have provided a minimum of 20 minutes fire endurance protection; and fixed fire ignition sources, and combustible or flammable materials, were positioned such that the degraded fire doors would not have been subject to direct flame impingement. A cross-cutting aspect was not assigned because the performance deficiency did not reflect current licensee performance.

Enforcement:

Oconee Nuclear Station Units 1, 2, and 3 Renewed Operating License Condition 3.D stated, in part, that Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(c) and NFPA 805. NFPA 805 section 3.11.3 stated, in part, that penetrations in fire barriers shall be provided with listed fire-rated door assemblies having a fire resistance consistent with the designated fire resistance rating of the barrier. Additionally, Oconee Nuclear Station Units 1, 2, and 3 License Condition 3.D stated, in part, that the licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements (including section 3.11) are acceptable because the alternative is adequate for the hazard. Contrary to the above, since 1995 the licensee failed to provide fire door assemblies having a rating of the barrier, and failed to perform engineering equivalency evaluations to demonstrate that the alternative was adequate for the hazard. Specifically, the licensee modified fire doors from their listed configurations without performing engineering equivalency evaluations. The licensee entered this issue into their CAP as PIPs O-13-06900 and O-13-07343 and declared the doors nonfunctional and implemented fire watches as compensatory measures. This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000269, 270, 287/2013007-01, Modifications to Fire Doors did not Receive Engineering Equivalency Evaluations.

.03 Active Fire Protection

a. Inspection Scope

The team reviewed the licensees fire detection systems, manual and automatic water-based fire suppression systems and firefighting standpipe and hose systems protecting the selected FAs. Fire brigade pre-plans, training and fire response procedures for these areas were also reviewed. The team reviewed the adequacy of the design, installation and operation of the fire detection and alarm systems to promptly detect fires in the selected fire areas and to annunciate to the fire alarm control panel in the control room. The review included walkdowns of as-built configurations and an examination of the type of detectors, detector spacing, the licensees technical evaluations of the detectors location relative to ignition sources, room geometry and fixed obstructions to assess whether the areas were protected in accordance with code of record requirements. Evaluations for variances from deterministic requirements (VFDR) for non-standard detector installation were reviewed. The team also reviewed the licensees fire alarm response procedures, fire protection design basis document (DBD),

NFPA 805 License Amendment Request (LAR) submittals and associated an NRC NFPA 805 SER to verify that the fire detection and alarm systems for the selected FAs were installed in accordance with the design and licensing basis for the plant.

The team inspected the material condition, operational configuration, design and testing of the manual sprinkler system in the cable spreading room (FZ 106) and water spray systems protecting the Main Feedwater Pump (FZ 19) and CT-4 transformer (FZ 46).

This review consisted of reviewing the system layout drawings and calculations against field installations and performing confirmatory field walkdowns to check sprinkler head and water spray nozzles for proper orientation and clearance from obstructions to the water spray patterns. The team also reviewed code compliance evaluations to determine if there were any outstanding code deviations for these systems.

The team reviewed the firefighting pre-plans and fire response procedures for the selected FAs to determine if appropriate information was provided to fire brigade members to facilitate suppression activities. These plans were reviewed and confirmed by field walkdowns to verify that they accurately reflected current plant configurations and firefighting equipment locations. These walkdowns also confirmed that fire hose and extinguisher access was properly maintained throughout the plant. The team evaluated whether the fire response procedures and pre-plans could be implemented as intended and that they addressed equipment important to safety, ventilation of heat and smoke from a fire and drainage/runoff from installed fixed fire suppression systems and manual hose streams. Additionally, fire brigade drill records for recently run drills in each area were reviewed to confirm drill scenarios addressed specific hazards to likely be encountered in the areas and to verify actual fire brigade response times supported the fire brigade response time performance basis criteria. A walkdown of staged fire brigade personal protective equipment (PPE) was performed, with gear selected for inspection for its proper physical condition. An operating shift fire brigade was randomly selected to confirm that all members were currently qualified with regard to their medical and fire brigade training records. Current mutual aid agreements with local outside fire departments response to the plant in a fire emergency were reviewed as well as drill records for outside department participation for a postulated fire event.

b. Findings

No findings were identified.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team inspected the selected FAs to evaluate whether the ability to achieve the nuclear safety performance criteria could be adversely affected due to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. The team addressed the possibility that a fire in one FA could lead to the migration of smoke or hot gasses to other plant areas. Airflow paths out of the selected fire areas were reviewed to verify that inter-area migration of smoke or hot gases would not inhibit necessary local operator recovery actions required for the selected FAs. The team also evaluated whether the manual firefighting activities could adversely affect the credited nuclear safety equipment and/or adversely affect local operator recovery actions for the selected fire areas. Additionally, the team checked that the firefighting water would either be contained in the fire affected area or be safely drained off through floor drains or stairwells. A review of potential flooding through unsealed floor cracks and absorption of water through penetration seals to areas beneath the selected FAs was conducted. This portion of the inspection was carried out through a combination of walkdowns, and reviews of drawings, calculations and installation records. Documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

.05 Shutdown from a Primary Control Station

a. Inspection Scope

For postulated fire scenarios in FZs 19, 45, and 106, which may impair main control room (MCR) functions, the licensee credited shutdown from primary control stations to achieve safe and stable plant conditions. This would involve transferring plant controls from the MCR to the standby shutdown facility (SSF). The team reviewed electrical schematics to verify that circuits for SSD equipment, which could be damaged due to fire, were isolated by disconnect switches and by swapping power supplies for selected MCCs. The team reviewed the SSF transfer switch testing methodology to assess the functionality of the isolation feature of the transfer switches. The team also reviewed the licensees FPP, system flow drawings, electrical drawings, and other supporting documents. The reviews focused on ensuring that the required functions for post-fire safe and stable conditions and the corresponding equipment necessary to perform those functions were included in the fire response and abnormal procedures. The review included assessing whether safe and stable plant conditions from the primary control stations outside the MCR could be implemented and that transfer of control from the MCR to the SSF could be accomplished in accordance with procedures. This review also included verification that safe and stable conditions could be achieved and maintained from the primary control station both with and without the availability of offsite power.

b. Findings

No findings were identified.

.06 Circuit Analysis

a. Inspection Scope

The team reviewed the NSCA licensee circuit analysis documents, flow diagrams, and electrical schematics to verify that the licensee properly identified circuits that could impact the ability to achieve and maintain safe and stable conditions. The team performed a walkdown of the selected FAs to independently verify the assumptions and results of the licensees fire scenario development analysis. The team verified, on a sample basis, that the licensee properly identified cables and equipment required to achieve and maintain safe and stable conditions, i.e. hot standby, for the selected fire scenarios in the selected fire areas. The team verified that cables associated with safe shutdown-related equipment were protected from the adverse effects of fire damage or were analyzed to show that fire induced cable faults would not prevent shutdown to safe and stable conditions. The team reviewed flow diagrams for safe shutdown systems to assess the licensees review of potential flow diversions or maloperations that may impact nuclear safety performance criteria. The team also reviewed, on a sample basis, coordination study documents and one EC package for 600V MCC 3XB and 250/125VDC Distribution Center 3DP-F3CL to ensure proper coordination existed between load and incoming supply breakers. For the sample of components selected, the team reviewed piping and instrumentation drawings, electrical schematics, and wiring diagrams to identify power, control, and instrumentation cables necessary to support safe shutdown equipment operation. In addition, the team reviewed cable routing information to verify that fire protection features were in place to satisfy the requirements specified in the fire protection license basis. Specific components reviewed by the team are listed in the Attachment.

b. Findings

Introduction:

An NRC-identified AV of 10 CRF 50.48(c) and NFPA 805 Section 2.4.3.2 was identified for the licensees failure to address in their fire probabilistic safety analysis (also referred to as fire probabilistic risk assessment (PRA)) the risk contributions associated with all potentially risk-significant fire scenarios for a given FA/FZ.

Description:

During the walkdown of the Unit 1 Cable Room fire scenario AB106N1, the team identified several electrical cabinets that the licensee screened out as being well-sealed and/or were excluded from the evaluation as ignition sources without adequate documentation to support the basis for exclusion. The team asked the licensee to open electrical control cabinets and found that the control rod drive system logic cabinet was not well-sealed because of an open/unsealed penetration on top. The team questioned the licensees justification for excluding the ventilated cabinet from the fire scenarios.

The licensee informed the inspection team that they were not aware of the open/unsealed penetration because the cabinet was not opened during their initial fire scenario development walkdown. Additionally, the team found other electrical cabinets that were not well sealed but were excluded from the fire scenario development and a 600V breaker that was susceptible to high energy arching faults excluded from the fire scenario without adequate technical basis for being excluded. Based on the licensees responses for the exclusions of the various electrical cabinets, the team requested a walkdown of the Unit 1 Equipment Room scenario AB095B1. The walkdown of the Unit 1 Equipment Room scenario resulted in the team identifying two additional electrical cabinets that were excluded without adequate technical basis.

Analysis:

The licensees failure to include potentially high risk fire scenarios by incorrectly screening out electrical cabinets that were considered as well-sealed and/or excluded without adequate technical basis was a performance deficiency. This performance deficiency was more than minor because it impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (i.e. fire) to prevent undesirable consequences.

The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, which determined that, an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated February 28, 2005, review was required because it affected the ability to reach and maintain safe and stable conditions in case of a fire. However, because the finding preliminarily had a delta core damage frequency > 1E-6, a Phase 3 analysis is required to determine the safety significance of this finding. This finding does not represent an immediate safety concern because the licensee entered the issue in the corrective action program and implemented fire watches as compensatory measures.

The cause of this finding was determined to have a cross-cutting aspect of H.4(c) in the Work Practices component of the Human Performance area because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported.

Enforcement:

Oconee Nuclear Station, Unit 1 Renewed Facility Operating License Condition 3.D required the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805, as specified in the NRC safety evaluation report (SER) dated December 29, 2010. NFPA 805 Section 2.4.3.2 stated that the probabilistic safety assessment (Fire PRA) evaluation shall address the risk contribution associated with all potentially risk-significant fire scenarios.

Contrary to the above, since April 2012 the licensee failed to address the risk contribution of all ignition sources and targets associated with potentially risk significant fire scenarios during the initial fire scenario development resulting in potentially underestimating post-fire safe shutdown risk. The licensee initiated corrective action documents PIPs O-13-08059 and O-13-08061 to update the Fire PRA scenarios to explicitly describe the treatment of the questionable electrical cabinets and cable trays in the zone of influence (ZOI). Pending safety significance determination, this apparent violation is identified as AV 05000269/2013007-02, Failure to Identify Ignition Sources and Targets During Initial Fire Scenario Development.

.07 Communications

a. Inspection Scope

The team walked down sections of procedures for shutdown from the SSF to verify that portable radio communications and fixed emergency communication systems remained available, operable, and adequate for the performance of designated activities.

Additionally, the team verified the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team discussed system design, testing, and maintenance with engineering personnel.

The team reviewed the adequacy of the communication system to support plant personnel in the performance of alternative post-fire safe-shutdown functions and fire brigade duties. Selected fire brigade drill evaluation/critique reports were reviewed to assess proper operation and effectiveness of the fire brigade command post portable radio communications during fire drills and to identify any history of operational or performance problems with radio communications during fire drills. In addition, the team verified the radio battery usage ratings for the fire brigade radios stored and maintained on charging stations. The team also reviewed vendor data sheets and current test data for the portable handheld radios to ensure that the documented test data met the manufacturers acceptance criteria. Specific components reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team reviewed the adequacy of the emergency lighting units (ELUs) used to support plant personnel during post-fire safe shutdown for the selected FAs/FZs. The team performed plant walkdowns and observed the placement and coverage area of fixed 8-hour battery pack emergency lights credited for SSD, to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. The team reviewed maintenance and test procedures and completed test records of ELU battery 8-hour capacity tests to ensure that they were sized, tested, and maintained consistent with vendor guidance, license requirements, and licensee commitments. The specific documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The nuclear safety goal is provided in NFPA 805 to establish reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition. The licensee defines safe and stable conditions as maintaining reactor coolant temperature at or below hot standby conditions, or fuel coolant temperature less than boiling. The licensee does not require transitioning to cold shutdown to achieve the safe and stable condition, and therefore does not require cold shutdown repairs to be implemented.

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 passive fire barriers). The compensatory measures that had been established in these areas were compared to those specified in the FPP for the applicable fire protection feature.

The team verified that the risk associated with removing the fire protection feature from service was properly assessed and the compensatory measures were implemented in accordance with the approved FPP. The team reviewed impairment and compensatory measures forms for fire watch tours for selected FAs and compared them to security badge access transaction reports to confirm fire watch rounds were being properly performed within the allowable time frame. Hourly and roving watch personnel were interviewed to ascertain that their duties and responsibilities were properly understood.

Additionally, the team reviewed compensatory measures described in the licensees letter dated March 11, 2013, which the licensee was implementing to reduce the potential fire related risk and to recover a portion of the risk benefit that remains unrealized until implementation of the protected service water (PSW) system modifications are completed. To verify the implementation of these actions, the team:

Reviewed completed hot work permits to verify that a fire protection engineers approval was required for all hot work in high safety significant fire zones.

Reviewed the enhanced compensatory measures added to the on-line work prioritization controls (WPM 601) for hydrogen and oil leaks.

Reviewed shift staffing logs to verify the increased fire brigade staffing.

Reviewed the fire brigade response procedure to verify that guidance was included to utilize a pre-staged diesel driven pump to charge the HPSW system if HPSW pumps are OOS or fail.

Reviewed the procedure for operation of a Hale portable pump as a compensatory measure when the normal fire water system (HPSW) is out of service or unavailable.

Reviewed the procedure for operation of the SSF diesel generator to ensure that guidance was included to take compensatory measures during periods of time when planned or unplanned SSF unavailability will exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. These compensatory measures included:

o adding additional operators to each shifts staffing to provide resources for prompt initiation of steam generator feed using the staged portable diesel driven pump; o protecting the HPSW pumps and breaker, ASW switchgear, and the alternate units emergency feedwater supply valves; o performing thermal imaging scan of risk significant 4KV main feeder bus duct sections; o not allowing hot work in HSS zones without both the fire protection engineers and operations shift managers approval; and o maximizing the readiness of the portable pump for steam generator feed.

b. Findings

No findings were identified.

.11 Radiological Release

a. Inspection Scope

The team reviewed possible radiological release paths to any unrestricted area due to the direct effects of fire suppression activities for each of the selected FZs. Appendix I of the DBD, Radioactive Release Summary, was reviewed for each FZ. FZs 6, 45 and 46 were outside the Radiological Control Area and were concluded to not have any possible release path. Fire Zone 106, Unit 1 Cable Room, had floor drains routed to the radwaste processing system. Fire pre-plans addressed ventilation paths and specified monitoring of contamination levels of smoke. Fire brigade training reinforced pre-plan use and satisfied performance requirements of NFPA 805 for radioactive release.

b. Findings

No findings were identified.

.12 Non Power Operations

a. Inspection Scope

One of the requirements in NFPA 805 was for licensees to implement FPP controls during non-power operational modes. Although ONS did not enter an outage during the inspection period, the team reviewed plant calculations, procedures, and analyses that defined the key safety functions required to maintain the plant in a safe and stable condition during non-power operational modes. The team also noted that where the licensee had identified specific areas or pinch points where one or more key safety functions could be affected, the licensee had identified additional actions which would need to be taken during high-risk evolutions in the locations of the pinch points where key safety functions could be lost. The team noted that the licensee had not completed all of the items related to non-power operations due to the delay in completion of the PSW system modifications, which was discussed in previous NRC enforcement actions dated July 1, 2013.

b. Findings

No findings were identified.

.13 Monitoring Program

a. Inspection Scope

The team reviewed procedure EDM-253 NFPA 805 Monitoring Program, to verify that a monitoring program was established to ensure that the availability and reliability of the fire protection systems and features credited in the performance-based analyses are maintained and to assess the performance of the FPP in meeting the performance criteria in accordance with NFPA 805. The licensee established performance monitoring groups that provide a link between components and functions that are monitored together. The items in scope were being monitored for performance based on the established criteria as part of the normal engineering health reporting process. The team reviewed several fire protection system health reports to verify that the monitoring program ensures that the assumptions in the engineering analysis remain valid. The team also verified that the monitoring program instituted appropriate corrective actions to return availability, reliability, and performance of systems that fall outside of established levels.

b. Findings

No findings were identified.

.14 Plant Change Evaluation

a. Inspection Scope

Due to the need for ONS to have an industry full-scope peer review of its Fire PRA and to resolve the findings of that peer review, in accordance with license amendment dated December 29, 2010, ONS is not allowed to self-approve quantitative risk-informed fire protection program changes, except those implementation items needing a plant change evaluation as part of the Transition License Condition.

The NRC safety evaluation does allow ONS to make changes to the plant during transition as long as those changes do not result in an increase in plant risk and do not impact mandatory fire protection requirements contained in NFPA 805 Chapter 3. The team reviewed procedure Nuclear System Directive (NSD) 320 Guidance for Performing Licensing Review of Proposed Changes to the Fire Protection Program, to verify that the licensee had a program to determine if a change to the approved FPP could be made without prior NRC approval. The licensee stated that no changes had been made to the approved FPP which required a plant change evaluation and thus, did not provide the team with any plant change evaluations to review during the inspection.

b. Findings

Introduction:

An NRC-identified AV and associated traditional enforcement violation of ONS Renewed Facility Operating License Condition 3.D for Units 1, 2, and 3 was identified for the licensees failure to implement and maintain in effect all provisions of the approved FPP that comply with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. The licensee made a change to the approved FPP involving the control of combustible materials, when the definition of transient fire loads was revised in procedure NSD 313 to exclude fire retardant scaffolding materials as transient fire loads. This finding did not represent an immediate safety concern because the licensee implemented compensatory measures in the form of combustible tracking impairments and fire watches in the high safety significant fire zones which contained the scaffolding.

Description:

During walkdowns of the selected FAs/FZs the team noted that many elevated scaffold work platforms were constructed of fire retardant wood planking or plywood. NSD 313, Control of Transient Fire Loads, stated, in part, that the following items are not considered transient fire loads when used as indicated.

Fire retardant treated wood that is installed as part of in-place scaffold or temporary damming.

Fire retardant mesh/netting that is installed as part of in-place scaffolding or FME installation.

In place/installed fire retardant plastic sheeting that meets the requirements of NFPA 701 large scale test or equivalent.

These materials were excluded from various ONS offset and quantity restrictions associated with transient fire loads. The document revision section for Revision 10 to NSD 313 dated September 27, 2011, stated; Revised the definition of Transient Fire Load to exclude the fire retardant treated wood installed as part of in-place scaffolding, fire retardant mesh/netting installed as part of in-place scaffolding and in-place fire retardant plastics. These were previously exempt from approval areas. It was always the intent to exempt these items from consideration as a Transient Fire Load due to their difficulty to ignite and low flame spread rating. The team noted that neither of these categories of materials met the NFPA 805 definition of a Non-Combustible Material, which stated; A material that, in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion or release flammable vapors when subjected to heat.

The team requested the FPP change evaluation which justified the changes to the combustible control program procedure (NSD 313) of the approved FPP which excluded these items from the program. The licensee responded that no NSD 320, change evaluation was performed at the time of the NSD 313 procedure revision, and that a subsequent audit identified the discrepancy (documented in PIP G-11-01663, dated November 14, 2011) which resulted in the NSD 320 change evaluation being performed after the fact. The team reviewed the after the fact change evaluation (documented on NSD 320, Form 320-1, Fire Protection Program Change Review Form) which stated that the proposed change did not adversely affect the ability to achieve and maintain SSD in the event of a fire and NRC approval of the change was not required because the proposed change satisfied applicable fire protection regulatory requirements and the proposed change satisfied the fire protection licensing basis. Form 320-1 evaluation question Does the proposed change meet the requirements of NFPA 805, Chapter 3?

was answered not applicable (N/A).

The team concluded that the after the fact NSD 320 change evaluation was inadequate because it failed to recognize that such a program element self-approval did not meet ONS Fire Protection License Condition 3.D. The license condition states, in part, that the licensee is not allowed to self-approve quantitative risk-informed fire protection program changes except those implementation items needing a plant change evaluation as part of the Transition License Condition or NFPA 805 Chapter 3 element Section(s)3.8 through 3.11 only. The change to the transient combustible program was made to NFPA 805 Chapter 3 element Section 3.3 which required prior NRC approval.

Because fire retardant materials used for scaffolding was excluded from the requirements of NSD 313, Oconee offset and quantity restrictions over the use of these materials was not maintained. Licensee walkdowns performed immediately after the inspection revealed that approximately 50,000 lbs. of fire retardant wood was distributed through 56 fire zones of the three units.

Analysis:

Failure to comply with ONS Operating License Condition 3.D for a change to the approved FPP involving control of fire retardant scaffolding materials was a performance deficiency. This performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external events (i.e. fire), and it negatively affected the cornerstone objective in that the change to the FPP had the potential to adversely affect the ability to achieve and maintain safe and stable plant conditions due to the increased transient fire load in the affected FZs. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated February 28, 2005, review was required as the finding involved fire prevention and administrative controls. The team evaluated the finding using the guidance in IMC 0609, Appendix F, to assess the significance of the licensees change to their FPP. The finding applied to most FZs within the plant because the licensee stopped tracking the use of fire retardant scaffolding materials used throughout the plant. IMC 0609, Appendix F, Assumptions and Limitations states in part that the Fire Protection SDP Phase 2 approach is intended to support the assessment of known issues only in the context of an individual fire area.

A systematic plant-wide assessment effort is beyond the intended scope of the fire protection SDP. Therefore, an SDP Phase 3 analysis is required to assess the significance of this finding. The cause of this finding was determined to have a cross-cutting aspect of H.1(b) in the Decision-Making component of the Human Performance area because the licensee used non-conservative assumptions in the decision making associated with this FPP change.

Additionally, the licensees failure to submit the FPP change to the NRC was determined to impede the regulatory process in accordance with the NRC Enforcement Manual guidance for traditional enforcement because the FPP change required NRC review and approval prior to implementation. The severity level of the traditional enforcement violation will be assigned based on the significance determination of the associated finding.

Enforcement:

ONS Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D states in part, that the licensee shall implement and maintain in effect all provisions of the approved FPP that comply with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. License Condition 3.D further states, in part, that the licensee is not allowed to self-approve quantitative risk-informed FPP changes except those implementation items needing a plant change evaluation as part of the Transition License Condition or NFPA 805 Chapter 3 element section(s) 3.8 through 3.11 only.

Contrary to the above, on September 27, 2011, the licensee self-approved quantitative risk-informed FPP changes that were not implementation items for the Transition License Condition or NFPA 805 Chapter 3 sections 3.8 through 3.11. The licensee failed to comply with the requirements of ONS Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D for a change to the approved FPP involving the control of combustible materials. Procedure NSD 313, Control of Transient Fire Loads, Revision 10, excluded fire retardant treated wood, netting and plastics (installed as part of in-place scaffolding) from procedural offset and quantity restriction requirements. This change to the combustible control program required prior NRC approval because it affected NFPA 805 Chapter 3 element 3.3. The licensees failure to submit the FPP change to the NRC for review and approval impacted the ability of the NRC to perform its regulatory oversight function. The licensee entered this issue into the corrective action program as PIP O-13-08584 and performed site wide walkdowns to quantify the amount and location of all fire retardant materials used for in-place scaffolding and initiated additional roving fire watches in all affected high safety significant FZs that had not been covered by the existing fire watch rounds. This violation is being treated as an AV, consistent with Section 2.3.2 of the Enforcement Policy. AV 05000269, 270, 287/2013007-03, Fire Protection Program Change did not Meet Oconee License Condition Requirements for NFPA 805 Chapter Three.

.15 Control of Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the administrative control of combustible materials and ignition sources to verify that the FPP performance requirements of NFPA 805 Chapter 3 were satisfied. Plant administrative procedures were reviewed to determine if adequate controls were in place to control the potential ignition sources of welding and grinding and the handling of transient combustibles in the plant. The team walked down numerous areas in the plant, including the selected FAs, for control of combustible materials, storage of in-plant materials, transient combustibles, and general housekeeping. The team verified that containers with combustibles were UL or Factory Mutual listed. The team observed work activities involving cutting, welding and grinding for adherence to plant procedures. Hot work fire watch personnel were interviewed to ascertain that their duties and responsibilities were properly understood.

b. Findings

(1)

Introduction:

An NRC-identified Green NCV of Oconee Nuclear Station Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D was identified for the licensees failure to follow procedures for the control of transient combustible materials. The team identified five examples where the licensee failed to follow procedure NSD 313 Control of Transient Fire Loads, Rev. 13, in that, unapproved combustible materials were stored in FAs/FZs without proper evaluation and without appropriate compensatory actions being implemented.

Description:

Procedure NSD 313 established the minimum requirements for the control of transient fire loads in safety-related and power-production areas at ONS.

The provisions of the procedure were intended to minimize the introduction of transient fire loads, and reduce the fire hazards involved with the handling, use, and storage of combustibles. To accomplish this, procedure NSD 313 required that form NSD 313-2, Transient Fire Load Evaluation Form be completed for transient combustibles being stored in the fire areas/zones listed in Table 313.1, Required Compensatory Actions for Transient Combustible Storage. By completing form NSD 313-2, the licensee ensured that transient combustibles were properly identified, quantified, tracked, and that the proper compensatory actions listed in Table 313.1 were implemented. Additionally, procedure NSD 313 required that the licensee post a copy of form NSD 313-2 at the storage location of transient combustibles.

The team identified the following examples of unapproved combustibles being stored in the plant without being properly evaluated in accordance with procedure NSD 313.

Example 1: The team identified that the area in front of Fire Door 104 was labeled as a permanent storage area as documented in PIP O-12-2837. Upon review of the PIP, the team identified unapproved combustibles, in the form of mop heads were stored in this area and not evaluated under the NSD 313 procedure.

Example 2: The team identified that the area in front of Fire Door 105 was labeled as a permanent storage area as documented in PIP O-12-2837. Upon review of the PIP, the team identified unapproved combustibles, in the form of a plastic cart, a plastic bag, rope, a small piece of treated wood, and other miscellaneous combustibles, which were being stored in this area, were not evaluated under the PIP for permanent storage. The team noted that the licensee had documented a request to store these unapproved combustibles in this permanent storage area in PIP O-13-07672. The team determined that although the request was documented, the licensee had not completed the evaluation of the unapproved combustibles prior to storing them in this area.

Example 3: The team identified that unapproved combustibles in the form of hard hats, plastic carts, and other miscellaneous combustibles were being stored in auxiliary building room 109.

Example 4: The team identified that unapproved combustibles in the form of plastic bags of used protective clothing, dry active waste, and other miscellaneous combustibles were being stored in auxiliary building room 304.

Additionally, the room was posted with signage that stated Fire Regulations No Combustible Material Storage in This Area.

Example 5: The team identified that unapproved combustibles in the form of black rubber matting were being stored in the CT4 Block House.

The team determined that the licensee did not complete form NSD 313-2, which resulted in the unapproved combustibles being stored without being properly identified, quantified, tracked, and without implementing the appropriate compensatory measures listed in Table 313.1. The licensee captured these issues in their CAP as PIPs O-13-07896, O-13-07897, O-13-07989, O-13-08051, and O-13-08459. Additionally, the licensee initiated immediate corrective actions to remove all the unapproved combustibles from the areas identified.

Analysis:

The licensees failure to follow procedure NSD 313 and subsequent storage of unapproved combustibles in fire areas/zones without proper evaluation and without appropriate compensatory actions being implemented was a performance deficiency. The performance deficiency was more than minor because it adversely affected the Mitigating Systems cornerstone attribute of Protection Against External Events and adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated June 2, 2011, 4, Initial Characterization of Findings, dated June 19, 2012, which determined that, an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated February 28, 2005 was required as the finding involved a failure to adequately implement fire prevention and administrative controls for transient combustible materials. The team evaluated the finding using the guidance in IMC 0609, Appendix F. Using the Phase 1 Qualitative Screening Approach, the finding was assigned a category of Fire Prevention and Administrative Controls. The team used step 1.3 Initial Qualitative Screening, task 1.3.1 Qualitative Screening for All Finding Categories to determine the finding to be of very low safety significance (Green) because it only affected the ability to reach and maintain cold shutdown conditions. The cause of this finding was determined to have a cross-cutting aspect of H.4

(b) in the Work Practices component of the Human Performance area because the licensee did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures.

Enforcement:

Oconee Nuclear Station Units 1, 2, and 3 Renewed Facility Operating License Condition 3.D states, in part, that Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(c) and NFPA 805. NFPA 805 section 3.3.1.2 requires that procedures for the control of transient combustibles shall be developed and implemented, and that these procedures include program elements such as; combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials. Oconee implemented this NFPA requirement through procedure NSD 313 Control of Transient Fire Loads. Procedure NSD 313 required that form NSD 313-2, Transient Fire Load Evaluation Form, be completed for transient combustibles being stored in the fire areas/zones listed in Table 313.1. Contrary to the above, since approximately July 8, 2013, the licensee failed to complete form NSD 313-2 when unapproved transient combustibles were stored in fire areas/zones listed in Table 313.1. This resulted in transient combustibles being stored in fire areas/zones without the appropriate compensatory (i.e. tracking impairments or fire watches) actions being implemented.

When the issues were identified, the licensee removed all the transient combustibles that were not evaluated using form NSD 313-2, and entered the issues into their CAP as PIPs O-13-07897, O-13-07896, O-13-07989, O-13-08051, and O-13-08459.

This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000269, 270, 287/2013007-04, Failure to Evaluate Unapproved Combustibles In Accordance With Procedures)

(2)

Introduction:

The team identified an unresolved item (URI) involving a Liquefied Petroleum Gas (LPG) storage tank. The tank was not anchored and was not provided with excess flow valves. Postulated fire or explosion involving the tank contents could have a possible adverse impact on structures, systems or components important to safety.

Description:

The team identified an unsecured 500 gallon (water capacity) LPG storage tank in the Transformer Yard adjacent to the CT1 transformer and the Unit 1 Turbine Building. The LPG storage tank sat on four concrete blocks and did not appear to have an excess flow control valve installed to prevent a large release of propane gas from a ruptured supply line to the Auxiliary Boiler. The licensee had previously identified these problems in PIPs O-06-01385, O-08-02163, O-11-10119 and O-13-03819. Initially, a work request was written to secure the tank but it was later closed without the work being performed. Subsequently, an engineering change request was initiated to address the issue but was never approved. In ONS License Amendment 64 for Unit Nos. 1 and 2 and License Amendment 61 for Unit 3, each units license was amended to state, in part, that The licensee is authorized to proceed and is required to complete modifications identified in Table 3.1 of the NRCs Fire Protection SER dated August 11, 1978. The modifications shall be completed on the schedule specified in Table 3.1. SER Section 3.1.7, states, Propane tanks located outside of the turbine building will be anchored and provided with excess flow valves. Table 3.1 states in part, The modification will be completed by the end of the first refuel outage for any unit which occurs after 6 months from the date of issuance of this Safety Evaluation. A letter from Duke Power Company to the NRC dated June 29, 1979 stated, in part that, The required modification had been completed. When questioned about the current configuration of the tank, the licensee stated that since the transition to their approved NPFA 805 FPP all prior FPP SERs and commitments have been superseded in their entirety by the revised license condition and that the tank was in compliance with the requirements of NFPA 805, Section 3.3.7.1 for the storage of flammable gases located outdoors. Offset distances from the tank to structures, systems or components were judged by the licensee to be sufficient to prevent adverse impact from fires or explosions. The team did not agree with this position and stated that the ONS April 14, 2010 License Amendment Request (LAR) did not address the tank or the non-compliance with the license amendment requirement of 1978. The NRC has requested additional information from the licensee to determine if a prior change to the license, made before the transition to NFPA 805, allowed the tank to remain in its current location without the originally required modifications; and, to determine if the tank had, at one time, been in compliance, but had been improperly relocated under a work order performed in 1986.

This issue is unresolved pending NRC review of additional information requested to determine if the issue of concern constitutes a violation of NRC requirements. This issue is identified as URI 05000269, 270, 287/2013007-05, Non-Compliance to License Condition Requiring Modifications to LPG Tank was not Identified During Transition to NFPA 805.

.16 B.5.b Mitigating Strategy

a. Inspection Scope

The team reviewed on a sample basis, the licensees preparedness to handle large fires or explosions by reviewing the spent fuel pool external makeup mitigating strategy. To verify that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54 (hh)(2), the team: 1) reviewed procedures to ensure that they were being maintained and were adequate; and 2) performed walkdowns with licensee staff to ensure that the actions were feasible, the required equipment was properly staged, and that the staff was properly trained. The team also reviewed maintenance and testing records of equipment to ensure that the equipment was being maintained consistent with vendor recommendations and licensee requirements.

b. Findings

No findings were identified.

1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications

a. Inspection Scope

The team reviewed a sample of permanent plant modifications related to fire protection and/or the licensees transition to NFPA 805. The following permanent plant modifications were reviewed:

EC# 0000104433, NFPA 805 Modification To Eliminate Breaker Coordination Issues EC# 0000101763, Vital I&C Cable Tray Path Miscellaneous Interferences - Fire Protection EC# 0000103607, Fire Detection Elements For PSW-Related Engineering Changes EC# 0000100886, Auxiliary Building Ventilation System Interferences With Vital I&C Cable Tray EC# 0000110111, Modify Unit 1/2 Blockhouse Ventilation Fans EC# 0000101190, SAS Antenna EC# 0000095477, Improve Seismic Ruggedness Of HPSW The team reviewed procedures, engineering calculations, circuit breaker coordination studies, modification design and implementation packages, work orders, one line diagrams, connection diagrams, corrective action documents, and supporting analyses.

The teams review verified that changes resulting from the modifications were adequately incorporated in licensing and design basis documents and associated plant procedures. The team performed plant walkdowns of a sample of these modifications and selected aspects of each were discussed with engineering personnel.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

The team reviewed recent independent licensee audits for thoroughness, completeness and conformance to FPP requirements. Guidance for the independent audits are contained in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, and Generic Letter 82-21, Technical Specifications for Fire Protection Audits.

The team also reviewed other CAP documents, including completed corrective actions documented in selected PIPs and operating experience program documents, to ascertain whether industry identified fire protection issues (actual or potential) affecting ONS were appropriately entered into the CAP for resolution. Items included in the operating experience program effectiveness review were NRC information notices, regulatory guides, regulatory issues summary, industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters. The team 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 August 9, 2013, the lead inspector presented the preliminary inspection results to Mr.

S. Batson, ONS Site Vice President, and other members of the licensees staff, who acknowledged the results. Following completion of additional reviews in the Region II office, another exit meeting was held by telephone with Mr. Batson and other members of the licensees staff on September 23, 2013, to provide an update on changes to the preliminary inspection findings. The licensee acknowledged the findings. Proprietary information is not included in this IR.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Alter, Regulatory Affairs Manager

M. Bailey, Reactor and Electrical Systems Engineering Manager

S. Batson, Site Vice President

E. Burchfield, Engineering Manager

B. Carroll, PRA Supervisor

T. Cheslak, Fleet Fire Protection Engineer

C. Eflin, Operations Safe Shutdown Engineer

J. Ertman, Fleet Fire Protection Supervisor

P. Fisk, Operations Manager

D. Goforth, NFPA 805 Program Manager

A. Holder, Fleet Fire Protection Engineer

J. Kemp, Fire Protection Engineer

T. Patterson, Safety Assurance Manager

S. Perry, Regulatory Affairs

T. Ray, Station Manager

R. Rishel, PRA Group Manager

R. Robinson, Senior Nuclear Specialist, Operations

E. Simbles, Erin Fire PRA Manager

J. Smith, Regulatory Affairs

C. Sweely, Senior Specialist, Areva Fire Protection

B. Weaver, PRA Engineer

A. Wells, Engineering Programs Supervisor

NRC Personnel

J. Bartley, Chief, Projects Branch 1, Division of Reactor Projects, Region II

H. Barrett, Senior Fire Protection Engineer, Fire Protection Branch, NRR

N. Childs, Resident Inspector

H. Christensen, Deputy Director, Division of Reactor Safety, Region II

G. Croon, Resident Inspector

E. Crowe, Senior Resident Inspector

K. Ellis, Resident Inspector

M. King, Chief, Engineering Branch 2, Division of Reactor Safety, Region II

A. Klein, Chief, Fire Protection Branch, NRR

LIST OF REPORT ITEMS

Opened

05000269/2013007-02 AV Failure to Identify Ignition Sources and Targets During Initial Fire Scenario Development (Section 1R05.06)

05000269, 270, 287/2013007-03 AV Fire Protection Program Change did not Meet Oconee License Condition Requirements for NFPA 805 Chapter Three (Section 1R05.14)

05000269, 270, 287/2013007-05 URI Non-Compliance to License Condition Requiring Modifications to LPG Tank was not Identified During Transition to NFPA 805 (Section 1R05.15.b(2))

Opened and Closed

05000269, 270, 287/2013007-01 NCV Modifications to Fire Doors did not Receive Engineering Equivalency Evaluations (Section 1R05.02)

05000269, 270, 287/2013007-04 NCV Failure to Evaluate Unapproved Combustibles in Accordance With Procedures (Section 1R05.15.b (1))

SUPPLEMENTAL INFORMATION LIST OF FIRE BARRIERS INSPECTED (Refer to Report Section 1R05.02 - Passive Fire Barriers)

Fire Barrier Floors/ Walls/ Ceiling Identification Description Concrete Walls, Floor and Ceiling Unit 1 CSR (FA 106)

Block Wall BH1/2 (FA 45) / CT4 (FA 46)

Fire Damper Identification Description 1FPS-PN-1KS-6 Unit 1 CSR (FA 106)

1FPS-PN-1NF-13 Unit 1 CSR (FA 106)

1FPS-PN-1NF-15 Unit 1 CSR (FA 106)

1FPS-PN-1PE-10 Unit 1 CSR (FA 106)

Fire Door Identification Description TB 11-R34 BH1/2 (FA 45) / CT4 (FA 46)

AB 08-401A CSR 403 / Stairwell 401A TB 01-T13 U1 HPSW Enclosure Penetration Seal Identification Description 1-M-7-10 CRS Floor 1-M-7-18 CRS Floor 1-M-7-21 CSR Floor 1-CF-57 CSR Floor 1-CF-60 CSR Floor Section 1R05.06: List of Safe Shutdown Components Inspected Valves Description 1HP-939 LDST to Emergency Sump MOV 1HP-940 LDST to Emergency Sump MOV 1FDW-347 1B S/G Inlet Block Valve On Emergency Header 1CCW-269 A S/G Feedwater Control Valve 1RC-4 Pressurizer Power Relief Block Valve 1HP-426 RC Letdown to Spent Fuel Pool 1SF-82 Spent Fuel Pool to RC Makeup Suction Valve 1HP-398 RC Makeup Pump to RCP Seals Block Valve 1HP-417 RC Makeup Pump Recirc to SFP 1HP-405 RC Makeup Pump Test Valve 1MS-82 MS Supply to 2A TDEFWP 1MS-84 MS Supply 2B to TDEFDWP 1HP-3 1A Letdown Cooler Outlet 1HP-4 1B Letdown Cooler Outlet 1HP-20 RCP Seal Return (Inside RB)

1MS-87 ---

1MS-93 ---

Pumps Description 1HP-PU0002 1B HPI Pump Other SSF Pressurizer Heater Group B, Bank 2