Text

IR 05000331-12-007 (Drs); 01/11/2012-01/27/2012, and 02/06/2012-2/10/2012; Duane Arnold Energy Center (Daec); Triennial Fire Protection Baseline Inspection
	ML12066A262
Person / Time
Site:	Duane Arnold
Issue date:	03/07/2012
From:	Hironori Peterson; Operations Branch IV
To:	Wells P; NextEra Energy Duane Arnold
	George Hausman
References
	IR-12-007
	Download: ML12066A262 (23)
	v • d • e

rch 7, 2012

SUBJECT:

DUANE ARNOLD ENERGY CENTER TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000331/2012007(DRS)

Dear Mr. Wells:

On February 10, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Duane Arnold Energy Center (DAEC). The enclosed inspection report documents the inspection results, which were discussed on February 10, 2012, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating this issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of the Non-Cited-Violation, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -

Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Duane Arnold Energy Center. In accordance with 10 CFR 2.390 of the NRC's "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 System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Hironori Peterson, Acting Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-331 License No. DPR-49

Enclosures:

Inspection Report 05000331/2012007(DRS)

w/Attachment: Supplemental Information

REGION III==

Docket No: 050000331 License No: DPR-49 Report No: 05000331/2012007(DRS)

Licensee: NextEra Energy Duane Arnold, LLC Facility: Duane Arnold Energy Center (DAEC)

Location: Palo, IA Dates: January 11-27, 2012, and February 6-10, 2012 Inspectors: George M. Hausman, Senior Reactor Inspector, Lead Benny Jose, Senior Reactor Inspector Mohammad Munir, Reactor Inspector Robert A. Winter, Reactor Inspector David G. Passehl, Senior Reactor Analyst Approved by: Hironori Peterson, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000331/2012007 (DRS); 01/11/2012-01/27/2012, and 02/06/2012-02/10/2012; Duane

Arnold Energy Center (DAEC); Triennial Fire Protection Baseline Inspection.

This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. One (Green) finding was identified by the inspectors.

The finding was considered a Non-Cited Violation (NCV) of U.S. Nuclear Regulatory Commission (NRC) regulations. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be (Green) or be assigned a severity level after NRC management review. The cross-cutting aspects, if any, were determined using IMC 0310, Components Within the Cross-Cutting Areas. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events

Green.

The inspectors identified a finding of very low safety significance and associated NCV of Title 10, Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III,

Design Control, for the failure to check the adequacy of design for flammable gas bottles installed in the reactor building and their impact on safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and the resulting fire or explosion at the installed locations could impact nearby safety-related structures, systems, or components. The licensee entered this issue into their corrective action program to review the placement of the flammable gas bottles.

The inspectors determined that the finding was more than minor because the finding was associated with the Initiating Events cornerstone attribute of Protection against External Factors (Fire) and affected the cornerstones objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was of very low safety significance due to the low fire initiating frequency and the availability of remaining mitigating systems. This finding did not have a cross-cutting aspect because the finding was not representative of current performance. (Section 1R05.11b)

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection

Main article: IP 71111.05T

The purpose of the fire protection triennial baseline inspection was to conduct a design based, plant specific, risk-informed, onsite inspection of the licensees fire protection programs defense-in-depth elements used to mitigate the consequences of a fire. The fire protection program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:

preventing fires from starting;

rapidly detecting, controlling and extinguishing fires that do occur;

providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and

taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.

The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants fire protection program, post-fire safe shutdown systems and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a fire protection program that:

(1) provided adequate controls for combustibles and ignition sources inside the plant;

(2) provided adequate fire detection and suppression capability;

(3) maintained passive fire protection features in good material condition;

(4) established adequate compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, systems or features;

(5) ensured that procedures, equipment, fire barriers, and systems exist so that the post-fire capability to safely shut down the plant was ensured;

(6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and

(7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees problem identification and resolution program.

In addition, the inspectors review and assessment focused on the licensees post-fire safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspectors review and assessment also focused on the licensees B.5.b related license conditions and the requirements of Title 10, Code of Federal Regulations (CFR) 50.54(hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.

The fire zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire zones selected constitute four samples and the B.5.b mitigating strategy selected constitutes one sample as defined by Inspection Procedure (IP) 71111.05T.

Fire Area Fire Zone Description 1G31 A EDG [Emergency Diesel Generator] Room 08H (East) Turbine Building - Elevation 757-6 TB1 A EDG Day Tank Room 08J Turbine Building - Elevation 757-6 1D2 West Battery Room 10B Control Building - Elevation 757-6 CB2 1A4 West Essential Switchgear [SWGR] Room 10E (Division II) Control Building - Elevation 757-6

.1 Protection of Safe Shutdown Capabilities

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected.

The inspectors ensured that applicable separation requirements of Section lll.G of 10 CFR Part 50, Appendix R and the licensee's design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.

b. Findings

No findings of significance were identified.

.2 Passive Fire Protection

.5 Alternative Shutdown Capability

a. Inspection Scope

The inspectors reviewed the licensees systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.

The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training, as well as consistency between the operations shutdown procedures and any associated administrative controls.

b. Findings

No findings of significance were identified.

.6 Circuit Analyses

a. Inspection Scope

The inspectors verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the inspectors verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.

The inspectors' review considered fire and cable attributes, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.

The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.

The inspectors reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. Additionally, the inspectors reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.

b. Findings

No findings of significance were identified.

.7 Communications

Introduction:

The inspectors identified a finding of very low safety significance (Green)and associated Non-Cited Violation (NCV) of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, for the failure to check the adequacy of design for flammable gas bottles installed in the reactor building and their impact on safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and the resulting fire or explosion at the installed locations could impact nearby safety-related structures, systems, or components.

Description:

In response to NUREG-0737, Clarification of TMI [Three Mile Island]

Action Plan Requirements,Section II.F.1.6, Containment Hydrogen, dated October 31, 1980, the licensee initiated a modification to their post accident containment air monitoring system. A Design Change Request (DCR) 934, Installation of Containment Hydrogen and Oxygen [H2O2] Analyzer, dated October 8, 1981, made changes to the plants existing H2O2 analyzer system. The H2O2 analyzer system utilized installed hydrogen and oxygen gas bottles for the 1C218 A and B Primary Containment H2O2 Analyzer Panels. Both H2O2 analyzer panels hydrogen and oxygen gas bottles were located in the reactor buildings Fire Area RB1 in Fire Zone 02A North CRD [Control Rod Drive] Module Area and Fire Zone 02B South CRD Module Area on the 757-foot 6-inch elevation. The two compressed hydrogen gas bottles and two compressed oxygen bottles installed at each location were used as reagents for the H2O2 analyzer panels. The DCR did not consider the potential consequences of the failure of the compressed gas bottles at the installed locations and the resulting fire or explosion on nearby safety-related structures, systems, or components. A fire hazards evaluation or safety evaluation was not found that addressed the flammable gas bottles installed location in any of the DCRs provided by the licensee and reviewed by the inspectors.

The hydrogen bottles present a fire and an explosion hazard. According to Table 2-7.1 of the Society of Fire Protection Engineers (SFPE) Handbook of Fire Protection Engineering (Fourth Edition) hydrogen has a lower flammability limit of 4 and an upper flammability limit of 75 percent. This means that a hydrogen mixture of between 4 and 75 percent will burn. At each of the flammable gas bottles location, one hydrogen bottle had a mixture of 50 percent hydrogen and 50 percent nitrogen; the second had a mixture of 18 percent hydrogen and 82 percent nitrogen and both oxygen bottles were 100 percent. Each of the hydrogen and oxygen bottles had a regulator attached to the discharge. However, if a piece of equipment or some object were to hit the regulator it could fail, cause a spark, and ignite the flammable gas. A fire from one or more of the flammable gas bottles could damage safety-related cables and an explosion could additionally damage other nearby safety-related equipment.

The approved fire protection program has three primary tiers that constitute defense-in-depth. These include preventing and minimizing the effects of fires, detecting and suppressing fires, and safe shutdown. Each of the three tiers has regulatory requirements needed for compliance with General Design Criterion 3. In addition, the impact to safe shutdown capability is not the only consideration when evaluating a plant change. The change must still satisfy the regulatory requirement of 10 CFR 50.48(a) by having a program satisfying Criterion 3 of 10 CFR Part 50, Appendix A. Criterion 3 specifies a program such that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. A fire hazards evaluation or safety evaluation for the flammable gas bottles was not found in any of the DCRs reviewed.

As a result, the inspectors concluded that the licensee failed to check the adequacy of the design for the flammable gas bottles installed locations and their impact on safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and a resulting fire or explosion at the installed locations could impact the defense-in-depth strategies for the licensees fire protection program.

The licensee entered this issue into their corrective action program as Action Request (AR) 01732154, Evaluate Flammable Gas Cylinders within the Vital Areas, dated February 7, 2012, to review the placement of the flammable gas bottles.

Analysis:

The inspectors determined that the failure to evaluate the impact of the flammable gas bottles installed locations near safety-related cables and safety-related equipment was contrary to 10 CFR Part 50, Appendix B, Criterion III, Design Control, and was a performance deficiency. The inspectors determined that the finding was more than minor because the finding was associated with the Initiating Events cornerstone attribute of Protection against External Factors (Fire) and affected the cornerstones objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Specifically, the installed locations of the flammable gas bottles could have resulted in damage to safety-related cables and safety-related equipment if the gas bottles were to ignite or explode. As a result, the licensees fire protection programs defense-in-depth strategies for the affected fire zones were degraded.

In accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 0609.04, Phase I - Initial Screening and Characterization of Findings, Table 3b the inspectors determined the finding degraded the fire protection defense-in-depth strategies. Therefore, screening under IMC 0609, Appendix F, Fire Protection Significance Determination Process, was required. The inspectors determined that the finding impacted the Fire Prevention and Administrative Controls category.

Based on review of IMC 0609, Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various Fire Protection Program Elements, the inspectors determined the degradation rating to be high because of the flammable gases being more flammable than low flashpoint combustibles and there being a significant fire hazard associated with release of the gas. The Duration Factor was 1.0 based on the duration of the degradation being greater than 30 days per Table 1.4.1, Duration Factors. An overall fire frequency of 1.3E-3 per year was calculated for the flammable gas bottles based on information from IMC 0609, Appendix F, Attachment 4, Fire Ignition Source Mapping Information: Fire Frequency, Counting Instructions, Applicable Fire Severity Characteristics, and Applicable Manual Fire Suppression Curves.

The conditional core damage probability (CCDP) from Table 2.1.1, Total Unavailability Values for SSD [Safe Shutdown] Path Based Screening CCDP, included a screening value of 1E-2, which was conservative. The Region III Senior Reactor Analyst used the Duane Arnold Energy Center (DAEC) Standard Plant Analysis Risk (SPAR) Model, Version 8.16, and Systems Analysis Programs for Hands-on Integrated Reliability Evaluations (SAPHIRE), Version 8.0.7.17 to calculate a CCDP of 2.7E-7. The Senior Reactor Analyst assumed that a fire due to failure of the flammable gas bottles would result in a reactor trip. Based on the above CCDP and frequency values, the risk associated with this finding is very low (Green).

The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

Contrary to the above, from October 8, 1981, through February 10, 2012, the licensee failed to check the adequacy of design for flammable gas bottles installed in the reactor building and their impact on safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and the resulting fire or explosion at the installed locations could impact nearby safety-related structures, systems, or components.

Because this violation was of very low safety significance and it was entered into the licensees corrective action program as AR 01732154, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000331/2012007-01(DRS), Flammable Gas Bottles Installed in the Reactor Building).

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The inspectors reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed. The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.

b. Findings

No findings of significance were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that:

procedures were being maintained and adequate;

equipment was properly staged, maintained, and tested;

station personnel were knowledgeable and could implement the procedures; and

additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b related equipment.

The inspectors reviewed the licensees B.5.b related license conditions and evaluated the selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections.

The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions, and damage assessment activities identified in Table A.3-1 of the Nuclear Energy Institute (NEI) 06-12, B.5.b Phase II and Phase III Submittal Guidance, Revision 2 are evaluated each time due to the mitigation strategies scenario selected.

NEI 06-12, Revision 2, Section Licensee Strategy (Table)

BWR [Boiling Water Reactor] Enhancement Strategy No. 2 DC

[Direct Current] Power Supplies to Allow Depressurization of RPV 3.4.2

[Reactor Pressure Vessel] and Injection with Portable Pump (see Table A.5-2)

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

Main article: IP 71152

a. Inspection Scope

The inspectors reviewed the licensees corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the fire protection program at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

The inspectors presented the inspection results to Mr. Peter Wells and to other members of the licensee staff on February 10, 2012. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

S. Catron, Manager Licensing

Z. Cloe, Design Engineer

D. Curtland, Plant General Manager

J. Dubois, Engineering Programs Manager

G. Ellis, Fire Protection Supervisor

T. Erger, Operations Assistant Manager - Work Management

P. Hansen, Performance Improvement Manager

R. Hanson, Fire Protection Engineer

R. Harter, Work Management - Site Manager

B. Hendrickson, Senior System Engineer

J. Hoogland, Assistant Operating Engineer- Reactor Operator

B. Murrell, Principle Licensing Engineering Analyst

G. Pry, Operations Manager

M. Robins, Nuclear Station Plant Equipment Operator (NSPEO)

R. Schmidt, Senior Security Analyst

J. Schwertfeger, Security Supervisor

N. Sternowski, Operations Unit Supervisor

R. Sullivan, Fire Protection Coordinator/Fire Marshal

L. Swenzinski, Regulatory Affairs

R. Wheaton, Maintenance Director

P. Wells, Site Vice-President

Nuclear Regulatory Commission

L. Haeg, Senior Resident Inspector

R. Murray, Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000331/2012007-01(DRS) NCV Flammable Gas Bottles Installed in the Reactor Building (Section 1R05.11b)

Closed

05000331/2012007-01(DRS) NCV Flammable Gas Bottles Installed in the Reactor Building (Section 1R05.11b)

Discussed

None.

Attachment

LIST OF DOCUMENTS REVIEWED

IR 05000331/2012007

Text

SUBJECT:

Dear Mr. Wells:

Enclosures:

SUMMARY OF FINDINGS

NRC-Identified

Cornerstone: Initiating Events

Licensee-Identified Violations

REPORT DETAILS

REACTOR SAFETY

1R05 Fire Protection

.1 Protection of Safe Shutdown Capabilities

a. Inspection Scope

b. Findings

.2 Passive Fire Protection

a. Inspection Scope

b. Findings

.3 Active Fire Protection

a. Inspection Scope

b. Findings

.4 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

b. Findings

.5 Alternative Shutdown Capability

a. Inspection Scope

b. Findings

.6 Circuit Analyses

a. Inspection Scope

b. Findings

.7 Communications

a. Inspection Scope

b. Findings

.8 Emergency Lighting

a. Inspection Scope

b. Findings

.9 Cold Shutdown Repairs

a. Inspection Scope

b. Findings

.10 Compensatory Measures

a. Inspection Scope

b. Findings

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

b. Findings

Introduction:

Description:

Analysis:

Enforcement:

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

b. Findings

.13 B.5.b Inspection Activities

a. Inspection Scope

b. Findings

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

a. Inspection Scope

b. Findings

4OA6 Management Meetings

Exit Meeting Summary

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

Closed

Discussed

LIST OF DOCUMENTS REVIEWED

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