IR 05000338/2012012

IR 05000338-12-012, 05000339-12-012, on 11/26-30/2012 and 12/10-14/2012, North Anna Power Station, Units 1 & 2, Fire Protection (Triennial)

ML13024A334
Person / Time
Site:	North Anna
Issue date:	01/23/2013
From:	Mark King NRC/RGN-II/DRS/EB2
To:	Heacock D Virginia Electric & Power Co (VEPCO)
References
IR-12-012
Download: ML13024A334 (33)

Text

UNITED STATES ary 23, 2013

SUBJECT:

NORTH ANNA POWER STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000338/2012012 AND 05000339/2012012

Dear Mr. Heacock:

On December 14, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your North Anna Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed with Mr. E. Hendrixson and other members of your staff on December 14, 2012.

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

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

The report documents one NRC-identified finding of very low safety significance (Green), which was also determined to involve a violation of NRC requirements. However, because of the very low safety significance of this issue and because it was entered into your corrective action program, the NRC is treating this as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the North Anna Power 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.: 50-338, 50-339 License Nos.: NPF-4, NPF-7

Enclosure:

Inspection Report 05000338/2012012, 05000339/2012012 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-338, 50-339 License Nos: NPF-4, NPF-7 Report Nos.: 05000338/2012012, 05000339/2012012 Licensee: Virginia Electric and Power Company (VEPCO)

Facility: North Anna Power Station, Units 1 & 2 Location: Mineral, Virginia Dates: November 26-30, 2012 (Week 1)

December 10-14, 2012 (Week 2)

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

D. Mas, Reactor Inspector J. Montgomery, Reactor Inspector G. Wiseman, Senior Reactor Inspector Approved by: Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000338/2012012, 05000339/2012012; 11/26-30/2012 and 12/10-14/2012; North Anna

Power Station, Units 1 and 2; Fire Protection (Triennial)

This report covers an announced two-week triennial fire protection inspection by a team of four regional inspectors. One Green non-cited violation was identified. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White,

Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, ASignificance 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 June 7, 2012. Findings for which the SDP does not apply may be Green or be assigned a severity level after U.S. Nuclear Regulatory Commission (NRC) management review. 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

Green.

An NRC identified non-cited violation of 10 CFR 50, Appendix R, Section III.J, and the North Anna Power Station (NAPS) approved Fire Protection Program, was identified for the licensees failure to install fixed emergency lighting units (ELUs) in all areas where local operator manual actions (OMAs) were being performed to support post-fire safe shutdown (SSD). Specifically, a fixed ELU was not installed in the Unit 1 auxiliary building in the vicinity where an OMA to close valve 1-CC-757 was specified by fire contingency action (FCA) procedures for a fire in the main control room (MCR) or the Unit 1 emergency switchgear room (ESWGR). The licensee entered this issue in the corrective action program as condition reports 499353 and 500023.

The licensees failure to comply with the requirements of 10 CFR 50, Appendix R,

Section III.J, and the NAPS approved FPP, was a performance deficiency. The finding was more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire), and it negatively affected the objective of ensuring the reliability and capability of systems that respond to initiating events. Specifically, the finding had the potential to affect the feasibility of performing the OMA required for SSD in the event of a fire in either the MCR or ESGR-1. Using IMC 0609, Appendix F, Fire Protection SDP Phase 1 Qualitative Screening Approach, Step 1.3, the inspectors concluded that the finding, given its low degradation rating, was of very low safety significance (Green) because the FCA procedures required the operators performing the SSD actions to carry a portable lantern, and the operators had a high likelihood of completing the tasks using the portable lanterns. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. (Section 1R05.08)

Licensee Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R05 Fire Protection

This report documents the results of a triennial fire protection inspection of the North Anna Power Station (NAPS), Units 1 and 2. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), dated October 28, 2011. The objective of the inspection was to review a minimum sample of three risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP) as described in Section 9.5.1 of the NAPS Updated Final Safety Analysis Report (UFSAR) and the NAPS 10 CFR 50 Appendix R Report; and to review site specific implementation of at least one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walk-downs of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports (SERs), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports (IRs). Section 71111.05-02 of the IP specifies a minimum sample size of three FAs/Fire Zones and one B.5.b mitigating strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of three FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:

1. Fire Area 2, Main Control Room (MCR)2. Fire Area 5-2, Unit 2 Normal Switchgear Room 3. Fire Area 6-1, Unit 1 Emergency Switchgear Room (ESWGR)

For each of the selected fire areas, the inspectors evaluated the licensee=s FPP against the applicable NRC requirements and licensee design basis documents. Applicable design basis documents reviewed by the inspectors are listed in the Attachment to this report.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

Methodology For the selected FAs, the inspectors performed physical walk-downs to observe:

(1) the material condition of fire protection systems and equipment;

(2) the storage of permanent and transient combustibles;

(3) the proximity of fire hazards to cables relied upon for SSD; and

(4) the licensees implementation of procedures and processes for limiting fire hazards, housekeeping practices, and compensatory measures for inoperable or degraded fire protection systems and credited fire barriers.

Cable routing information by FA was reviewed for a selected sample of SSD components to verify that the associated cables would not be damaged by a fire in the selected fire areas or the licensees analysis determined that the fire damage would not prohibit safe plant shutdown. The inspectors reviewed conduit and cable-tray layout drawings, as well as field walk downs of the cable routing to confirm that at least one train of redundant cables routed in the FA were adequately protected from fire damage. The inspectors reviewed the NAPS Appendix R Report for the selected FAs and compared it to the fire contingency action (FCA) procedures, emergency procedures, and abnormal procedures to verify that cables and equipment credited for post-fire SSD in the Appendix R Report and applicable procedures were adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability. In cases where local operator manual actions (OMAs) were credited in-lieu of cable protection of SSD equipment, the inspectors reviewed the OMAs to verify that the OMAs were feasible utilizing the guidance of NRC IP 71111.05T, paragraph 02.02.j.2. A list of SSD components examined for cable routing is included in the Attachment.

Operational Implementation The inspectors reviewed applicable sections of FCA procedures, emergency procedures, and abnormal procedures to verify that the shutdown methodology properly identified the systems and components necessary to achieve and maintain SSD conditions. The inspectors performed a walk-through of FCA procedure steps to verify implementation and human factors adequacy of the procedures. The inspectors verified that licensee personnel credited for procedure implementation had procedures available, were trained on implementation, and were available in the event a fire occurred. The inspectors also reviewed selected operator 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. An unresolved item (URI) involving a postulated fire scenario in which the service water (SW) pumps for both units could be compromised due to a single fire in FA 6-1 (Unit 1 ESWGR) is discussed in Section 1R05.06 of this IR.

.02 Passive Fire Protection

a. Inspection Scope

The inspectors observed the material condition and as-built configurations of accessible fire barriers surrounding and within the FAs selected for review to evaluate the adequacy of the fire resistance in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, and Appendix A of NRC Branch Technical Position (BTP) APCSB 9.5-1.

Fire barriers in use included masonry block walls, poured concrete walls, ceilings, floors, mechanical and electrical penetration seals, doors, fire dampers, structural steel fire proofing, and ventilation duct raceway fire barrier protection. Where applicable, the inspectors observed the installed barrier assemblies and compared the as-built configurations to the approved construction details; supporting fire endurance test data; licensing basis commitments; and standard industry practices. The inspectors verified barrier configurations were either properly evaluated or qualified by appropriate fire endurance tests.

The inspectors also reviewed fire loading calculations to verify that the potential exposure fire severity and fire duration used by the licensee was appropriate for determining the fire resistive rating of the fire barriers. The overall criterion applied to this element of the inspection was that the passive fire barriers had the capability to contain fires for one hour or three hours as applicable. Also, a sample of completed surveillance and maintenance procedures for selected fire walls, fire doors, fire dampers, and penetration seals were reviewed to ensure that these passive fire barriers were being properly inspected and maintained. The fire protection features included in the review are listed in the Attachment.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

The inspectors reviewed the redundancy of fire protection water sources and fire pumps to fulfill their fire protection function to provide adequate flow and pressure to hose stations and automatic suppression systems to compare to licensing basis requirements of 10 CFR 50, Appendix R and Appendix A of BTP APCSB 9.5-1. The inspectors performed in-plant observations of the material condition and operational lineup for the operation of the fire water pumps and fire protection water supply distribution piping including, manual fire hose and standpipe systems for the selected FAs. Using operating and valve alignment procedures as well as engineering drawings, the inspectors examined the diesel-driven fire pump and accessible portions of the fire main piping system to evaluate operational status, consistency of as-built configurations with engineering drawings, and to verify correct system valve lineups (i.e. position of valves).

The inspectors compared the fire detection and fire suppression systems for the selected fire areas to the applicable National Fire Protection Association (NFPA)

Standard(s) by reviewing design documents and observing their as-installed configurations as part of performing the in-plant walk downs. The inspectors reviewed selected fire protection vendor equipment specifications, drawings, and engineering calculations to determine whether the fire detection and suppression methods were appropriate for the types of fire hazards that existed in the selected FAs. The automatic carbon dioxide (CO2) gaseous fire extinguishing system was inspected in conjunction with the associated heat and smoke detection systems for the Unit 2 normal switchgear room (FA 5-2). The inspectors reviewed the CO2 systems vendor equipment specifications, drawings, and engineering calculations to determine whether the fire detection and suppression methods were appropriate for the types of fire hazards that exist in the FA. The manually actuated Halon system installed in the Unit 1 ESWGR and relay room (FA 6-1) was also reviewed.

The inspectors reviewed and walked-down operational aspects of the manual standpipe and fire hose system to verify adequate design and installation in the selected FAs.

During plant tours, the inspectors observed interior fire hose nozzle types, fire brigade nozzles, and the placement of the fire hose stations and extinguishers, as designated in the fire fighting pre-plan strategies, to verify they were not blocked and adequate reach and coverage was provided consistent with the fire fighting strategies and FPP documents.

The inspectors reviewed completed periodic surveillance, testing and maintenance program procedures for the fire detection and suppression systems and compared them to the testing and maintenance requirements of the NAPS FPP and Technical Requirements Manual (TRM). This review was to assess whether the test program was sufficient to validate proper operation of the fire detection and suppression systems in accordance with their design requirements.

Aspects of fire brigade readiness were reviewed, including but not limited to, personal protective and smoke control equipment availability and condition, training, fire drills, daily staffing levels of fire brigade personnel, fire fighting pre-plan strategy planning, emergency lighting, fitness for firefighting duty of brigade members. During plant walk downs, the inspectors compared fire fighting pre-plan strategies to existing plant layout and equipment configuration and to fire response procedures for the selected FAs. This was done to verify that fire fighting pre-fire plan instructions and drawings were consistent with the fire protection features and potential fire conditions within the area and also to determine if appropriate information was provided to fire brigade members to facilitate suppression of an exposure fire that could impact the SSD strategy. The inspectors also assessed the condition of fire fighting and smoke control equipment by inspecting equipment located at fire brigade staging and dress out areas to verify that fire fighting pre-fire plan instructions and drawings were consistent with the fire protection features and potential fire conditions described in the approved FPP.

b. Findings

No findings were identified.

04. Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The inspectors evaluated whether water-based manual fire fighting activities or installed manual Halon 1301 or automatic CO2 gaseous fire extinguishing systems could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local operator actions required for SSD in the selected FAs. The inspectors reviewed documentation related to flooding analysis from fire protection activities as well as potential flooding through unsealed concrete floor cracks.

Fire fighting pre-plan strategies; fire brigade training procedures; heating, ventilating and air conditioning (HVAC) drawings; and, fire response procedures were also reviewed to verify that inter-area migration of water or ventilation of gaseous fire extinguishing agents or heat and smoke was addressed and would not adversely affect SSD equipment or the performance of OMAs. The inspectors performed in-plant observations of flood barriers 1-BLD-FLW-5 and 1-BLD-FLW-7 and floors in the Unit 1 ESWGR (FA 6-1) to verify barrier integrity. Additionally, the inspectors reviewed NAPS evaluations addressing concerns identified in NRC Information Notice (IN) 1988-60, Inadequate Design and Installation of Watertight Penetration Seals and IN 2003-08, Potential Flooding through Unsealed Concrete Floor Cracks.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

Methodology For a postulated fire in FA-2 (MCR) and FA 6-1 (Unit 1 ESWGR), the licensee credited alternative shutdown capability (the capability to achieve SSD outside the MCR, a requirement for areas where redundant trains of equipment required for hot shutdown were located in the same FA and may be subject to damage from a single fire, from fire suppression activities, or from the rupture or inadvertent operation of fire suppression systems). The inspectors reviewed UFSAR Section 9.5.1, the NAPS Appendix R Report, and corresponding FCA procedures to ensure that appropriate controls provided reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. The inspectors reviewed a sample of completed surveillance testing records to ensure the circuits credited for the alternate control stations were isolated based on transfer from the MCR. The inspectors also reviewed electrical elementary diagrams outlining the control transfer capability to verify that the system would function to electrically isolate from the MCR, and that testing adequately demonstrated operability of the system. In cases where local OMAs were credited in lieu of cable protection of SSD components, the inspectors performed a walk-through of the procedures to verify that the OMAs were feasible. Reviews also included verification that alternative shutdown could be accomplished with or without offsite power.

Operational Implementation The inspectors reviewed selected training materials for licensed and non-licensed operators to verify the training reinforced the shutdown methodology in the NAPS Appendix R Report and FCAs for FA-2 and FA 6-1. The inspectors also reviewed shift turnover logs and shift manning to verify that personnel required for SSD using alternative shutdown systems and procedures were available onsite, exclusive of those assigned as fire brigade members.

The inspectors performed a walk-through of procedure steps with operations personnel to assess the implementation and human factors adequacy of the procedures and shutdown strategy, evaluate the expected ambient conditions, relative difficulty and operator familiarization associated with each OMA. The inspectors reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The inspectors reviewed selected operator 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

A finding related to emergency lighting to support a SSD OMA is discussed in Section

1R05 .08 of this IR.

.06 Circuit Analyses

a. Inspection Scope

The inspectors reviewed the licensees UFSAR, NAPS FPP, system flow diagrams, post-fire procedures, operator training material, and applicable information to gain an understanding of the licensees SSD strategy. The inspectors reviewed credited components specified in the NAPS Appendix R Report for meeting the SSD function.

The inspectors reviewed cable routing information for credited components to determine if these components would be impacted by a fire within the chosen FAs. Additionally, a review was conducted of routing information for credited active fire protection components (i.e., electric motor-driven fire water pump, diesel-driven fire water pump, fire protection Halon and CO2 gaseous fire extinguishing systems valve controls, HVAC system controls, and manual fire brigade smoke removal) to determine if a fire in the selected FAs would impact them and the credited defense-in-depth systems. The circuitry associated with the electric motor-driven fire pumps controls and automatic functions was reviewed to determine if the desired start logic would function as designed and would not be vulnerable to fire damage. In instances where questions arose regarding potential fire induced circuit failures to cables, the inspectors performed a more detailed review by evaluating the credited resolution. The inspectors reviewed the licensees evaluations for spurious circuit failure scenarios (single and/or multiple)specified in the circuit analysis to determine if the sample list of components challenged the assumptions made in the NAPS Appendix R Report. The inspectors reviewed the licensees electrical coordination study to determine if power supplies were susceptible to fire damage, which would potentially affect the credited components for the FAs chosen for review. The specific components reviewed are listed in the Attachment.

b. Findings

Introduction:

The inspectors identified a URI involving a postulated fire scenario in which the service water (SW) pumps for both units could be compromised due to a single fire in FA 6-1 (Unit 1 ESWGR). The licensee initiated condition report (CR) 500152 to evaluate this potential vulnerability.

Description:

The SSD methodology described in the NAPS Appendix R Report for a postulated fire in FA 6-1 credited alternative shutdown capability by using Unit 2 charging pumps (via a manual cross-tie between Unit 1 and Unit 2) and the Unit 2 SW pumps to achieve post-fire SSD for the fire-affected Unit 1 and the unaffected Unit 2.

The NAPS SW system is shared between Units 1 and 2 and has a combined total of four SW pumps. The inspectors reviewed cable routing information for the SW pumps, and noted that control cables for all four SW pumps were routed through FA 6-1. During further review of the SW pump circuits and discussions with licensee personnel, it was determined that a postulated fire in the Unit 1 ESWGR could potentially affect the SW pumps control circuits in Unit 2. A fire in the Unit 1 ESWGR could create a hot short in the control circuit cables located in the fire affected Unit 1 ESWGR that could energize the trip coil for the SW pumps of the unaffected Unit 2. The hot short could potentially shut down the running SW pumps and prevent the other SW pumps from starting. This could prevent the unaffected Unit 2 SW pumps from providing SW flow for both the fire affected Unit 1 and the unaffected Unit 2. The inspectors determined that, by not ensuring the credited SW pumps remained free of fire damage, the licensee failed to ensure that alternative shutdown capability would be maintained for a postulated fire scenario in FA 6-1. This condition may not be in compliance with 10 CFR 50, Appendix R, Sections III.G.3 and III.L.1. This issue was discussed with licensee personnel who initiated CR 500152 to assess this service water pumps control circuit vulnerability. The licensee determined that this condition was only possible during a postulated fire in either units ESWGR. Subsequent to the onsite inspection, the licensee documented its Reasonable Assurance of Safety (RAS) for this issue in CR 500152-RAS 219. The licensee indicated in RAS 219 that it was unlikely that one fire would adversely affect the emergency busses on the fire affected Unit 1 as well as the conduit for the unaffected Unit 2 SW pumps such that a loss of all four SW pumps would occur. The licensee implemented hourly roving fire watches in each units ESWGR while this issue was being evaluated. This issue is unresolved pending further NRC review of the licensees information and assessment to determine if a credible fire scenario could result in the loss of all four service water pumps due to a single fire in the Unit 1 ESWGR. This issue is identified as URI 05000338, 339/2012012-01, Loss of Service Water for a Postulated Fire in Unit 1 ESWGR.

.07 Communications

a. Inspection Scope

The inspectors reviewed the communication capabilities required to support plant personnel in the performance of OMAs to achieve and maintain SSD, as credited in Section 3.5.10 of the NAPS Appendix R Report. The inspectors reviewed preventative maintenance and surveillance test records to verify that the communications equipment was being properly maintained. The inspectors also verified that the design and location of communications equipment, such as repeaters and transmitters, would not cause a loss of communications during a fire. The inspectors inspected the contents of designated emergency storage lockers and reviewed the FCA procedure to verify that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The inspectors reviewed maintenance and design aspects of the fixed 8-hour battery pack emergency lighting units (ELUs) required by 10 CFR 50 Appendix R, Section III.J and the licensees approved FPP. The inspectors performed plant walkdowns of the post-fire SSD procedures for the selected FAs to observe the placement and coverage area of the ELUs throughout the selected FAs. The inspectors also evaluated the adequacy of the ELUs to illuminate access and egress pathways, and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. The inspectors reviewed preventive maintenance procedures and completed surveillance tests to verify that adequate surveillance testing was in place.

b. Findings

Introduction:

An NRC identified Green non-cited violation (NCV) of 10 CFR 50, Appendix R, Section III.J, and the NAPS approved FPP was identified for the licensees failure to install fixed emergency lighting units (ELUs) in all areas where local OMAs were being performed to support post-fire SSD. Specifically, ELUs were not installed in the Unit 1 auxiliary building in the vicinity where a local OMA to close valve 1-CC-757 was specified by procedures 0-FCA 1 and 1-FCA-2, to support post-fire SSD for a fire in the MCR or the Unit 1 ESWGR, respectively.

Description:

The inspectors reviewed and walked down applicable sections of procedure 0-FCA-1, Control Room Fire, to review the procedural guidance and assess the local operator actions in support of SSD in the event of a MCR fire. During the walkdown of 0-FCA-1, the inspectors noted that an ELU was not installed in the vicinity of valve 1-CC-757 (CC return from RCP Thermal Barrier), located in the Unit 1 Auxiliary Building penetration area. For a MCR fire that could cause a loss of RCP seal cooling, the procedure directed operators to locally close this valve. The inspectors noted that procedure 0-FCA-1 contained steps to locally manipulate other valves in the immediate vicinity of 1-CC-757, and the procedure stated that the area where those valves were located was not supported by emergency lighting. The inspectors reviewed procedure 1-FCA-2, Emergency Switchgear Room Fire (for FA 6-1) and determined that local closure of this valve was also required for SSD for a fire in the Unit 1 ESWGR.

The inspectors concluded that the feasibility of this action would be challenged if normal lighting was lost and no ELU was available. The inspectors noted that the licensee=s FPP (as referenced by UFSAR Section 9.5.1, Fire Protection System, and described in the NAPS Appendix R Report) stated that emergency lighting was provided in all areas needed for operation of SSD equipment. Additionally, Table 3-1 of the Appendix R Report contained a list of components that are required for post-fire SSD of the plant, and whether emergency lighting was required for those components. Valve 1-CC-757 was included in Table 3-1, and the table indicated that emergency lighting was required for this component. The inspectors concluded that the failure to install ELUs to support the OMAs in the auxiliary building required by procedures 0-FCA-1 and 1-FCA-2 did not comply with 10 CFR 50, Appendix R, Section III.J, and the licensees approved FPP.

The licensee initiated CR 499353 and CR 500023 to address this ELU issue.

Analysis:

The licensees failure to install ELUs for local OMAs, as required by 10 CFR 50, Appendix R, Section III.J, and the approved FPP, was a performance deficiency.

The finding was more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire),and it negatively affected the objective of ensuring the reliability and capability of systems that respond to initiating events. Specifically, the finding had the potential to affect the feasibility of performing OMAs required for SSD in the event of a fire in either the MCR or the Unit 1 ESWGR.

Because this issue was related to fire protection, the inspectors used the guidance of IMC 0609, Appendix F, Fire Protection Significance Determination Process. The inspectors determined that this finding was in the post-fire SSD category. Using IMC 0609, Appendix F, Fire Protection SDP Phase 1 Qualitative Screening Approach, Step 1.3, the inspectors concluded that the finding, given its low degradation rating, was of very low safety significance (Green) because the FCA procedures required the operators performing the SSD actions to carry a portable lantern, and the operators had a high likelihood of completing the tasks using the portable lanterns.

The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. This condition has existed since at least 1982 when the licensees post-fire SSD methodology for alternative shutdown was submitted to the NRC.

Enforcement.

10 CFR 50.48(b)(1) requires that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of 10 CFR 50, Appendix R, Sections III.G, III.J, and III.O. Appendix R,Section III.J, specifies that emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto. The licensees approved FPP (which included the NAPS Appendix R Report, as referenced by UFSAR Section 9.5.1, Fire Protection System) described how the station complied with the requirements of 10 CFR 50, Appendix R. Table 3-1 of the NAPS Appendix R Report stated that Valve 1-CC-757 was required for SSD and emergency lighting was required to support local operation of the valve.

Contrary to the above, on December 14, 2012, the inspectors identified that the licensee did not meet the requirements of 10 CFR 50, Appendix R, Section III.J, or the NAPS FPP, in that 8-hour battery-powered ELUs were not installed in sections of the Unit 1 Auxiliary Building penetration area where post-fire SSD OMAs were required.

Specifically, there was not an ELU installed in the vicinity of valve 1-CC-757 in the auxiliary building where procedures 0-FCA-1 and 1-FCA-2 directed operators to close the valve locally in the event of a MCR fire or a Unit 1 ESWGR fire. This condition has existed since at least 1982 when the licensees post-fire SSD methodology for alternative shutdown was submitted to the NRC. This violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy because it was of very low safety significance and was entered into the licensee=s corrective action program as CR 499353 and CR 500023. This finding is identified as NCV 05000338, 339/2012012-02, Emergency Lighting Not Installed as Required by 10 CFR 50 Appendix R Section III.J.

.09 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the NAPS FPP and FCA procedures to verify that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs after a fire event assuming no offsite power was available. The inspectors verified that the fire damage repair procedures were current and adequate and repair parts and equipment were being stored and maintained onsite. The inspectors toured the NAPS Warehouse Appendix R Storage area, where cold shutdown fire damage repair equipment, tools, and cables were stored to examine the material condition of the tools and equipment stored in the designated storage area. The inspectors reviewed licensee inventory records to verify that repair parts and equipment were maintained in accordance with the applicable attachments in electrical preventive maintenance procedures. The inspectors reviewed the inventory inspection work order records and compared them to the equipment and tool lists to verify that all required replacement parts and equipment were being accounted for and were available for use.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The inspectors reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features (e.g. detection and suppression systems and passive fire barriers). A sample of completed fire watch logs and records of recent and active fire protection features impairments were reviewed. The compensatory measures that had been established in these areas were compared to those specified for the fire protection feature in the applicable TRM. The inspectors 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 applicable TRM and approved FPP.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection scope

The inspectors reviewed a sample of FPP changes made between October 2009 and November 2012 to assess the licensees effectiveness and to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse affect on the ability to achieve SSD.

b. Findings

No findings were identified.

.12 Control of Combustibles and Ignition Sources

a. Inspection Scope

The inspectors conducted tours of numerous plant areas that were important to reactor safety, including the selected fire areas, to verify the licensees implementation of fire protection requirements as described in fleet administrative procedures CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, and CM-AA-FPA-101, Control of Combustible and Flammable Materials. For the selected fire areas, the inspectors evaluated generic fire protection training; fire event history; the potential for fires or explosions; the combustible fire load characteristics; and, the potential exposure fire severity to determine if adequate controls were in place to maintain general housekeeping consistent with the UFSAR, administrative procedures, and other FPP procedures. The inspectors verified that containers with combustibles were Underwriters Laboratories (UL) or Factory Mutual (FM) listed. There were no hot work activities ongoing within the selected fire areas during the inspection so that observation of this activity could not be performed.

b. Findings

No findings were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed, on a sample basis, the licensees spent fuel pool external makeup mitigation measures for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the strategy, and equipment was properly staged and maintained. The inspectors requested and reviewed inventory and maintenance records of required equipment. Through discussions with plant staff, review of documentation, and plant walk-downs, the inspectors verified the engineering basis to establish reasonable assurance that the makeup capacity could be provided using the specified equipment and water sources. The inspectors reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply to the portable pumping equipment. The inspectors performed a walk-down of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures were available, calibrated and maintained. In the presence of licensee staff, the inspectors conducted an independent audit and inventory of required equipment and a visual inspection of the dedicated credited power and water sources. The inspectors reviewed training records of the licensees staff to verify that operator training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures. The inspectors verified, by review of records and physical inspection, that B.5.b equipment was currently being properly stored, maintained, and tested in accordance with the licensees B.5.b program procedures.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed recent independent licensee audits for thoroughness, completeness and conformance to FPP requirements. Requirements for the independent audits are contained in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, Generic Letter 82-21, Technical Specifications for Fire Protection Audits, and the licensees Nuclear Quality Assurance Plan. Specifically, fire protection system health reports for 2011 and 2012 were reviewed. Audits of the fire protection program reviewed were SAR 001946, dated July 12, 2012; and SAR 001720, dated August 29, 2012.

The inspectors also reviewed corrective action program documents, including completed corrective actions documented in selected CRs and operating experience program documents, to ascertain whether industry identified fire protection issues (actual or potential) affecting NAPS were appropriately entered into the corrective action program for resolution. Items included in the operating experience program effectiveness review were NRC Information Notices, industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters. The inspectors evaluated the effectiveness of the corrective actions for the identified issues.

The documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On December 14, 2012, the lead inspector presented the preliminary inspection results to Mr. E. Hendrixson and other members of the licensees staff, who acknowledged the findings. Proprietary information is not included in this IR.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

G. Bischof, Site Vice President

M. Crist, Plant Manager

P. Cameron, Senior Safety Specialist, Safety and Loss Prevention

R. Fleshman, Supervisor, Safety and Loss Prevention

E. Hendrixson, Director, Nuclear Engineering

J. Leberstien, Technical Consultant, Licensing

J. Martin, Corporate Fire Protection

W. Miller, North Anna Appendix R Coordinator

R. Page, Technical Consultant, Licensing

J. Slattery, Assistant Manager, Operations

W. Smith, Fire Protection Engineer

D. Struckmeyer, Supervisor, Engineering Programs

D. Taylor, Nuclear Oversight Specialist

D. Tolete, Corporate Fire Protection

NRC personnel

R. Clagg, Resident Inspector, NAPS

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

G. Kolcum, Senior Resident Inspector, NAPS

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000338, 339/2012012-01 URI Loss of Service Water for a Postulated Fire in Unit ESWGR (Section 1R05.06)

Opened and Closed

05000338, 339/2012012-02 NCV Emergency Lighting Not Installed as Required by CFR 50 Appendix R Section III.J (Section 1R05.08)

Closed

None

Discussed

None

SUPPLEMENTAL INFORMATION LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section 1RO5.03- Passive Fire Barriers)

Fire Barriers Floors/Walls/Ceiling Identification Description Concrete Block Wall Construction Fire Area 5-2 to Fire Area 5-1 Ceiling and Roof Construction Fire Area 5-2 to Roof Fire Damper Identification Description 01-FP-FDMP-1014 Fire Area 6-1 to Fire Area 6-2 01-FP-FDMP-1041 Fire Area 6-1 to Fire Area 7-D-1 01-FP-FDMP-1010 Fire Area 2 to Fire Area 6-1 2-FP-FDMP-1026 Fire Area 5-2 to Roof Fire Door Identification Description S-07-1 Fire Area 5-2 to Turbine Bldg.

S-07-3 Fire Area 5-2 to Fire Area 5-1 S-54-8 Fire Area 6-2 to Fire Area 6-1 S-54-5 Fire Area 6-2 to Fire Area 3-1 S-76-44 Fire Area 2 to Stairway S-76-26 Fire Area 2 to Turbine Bldg.

Fire Barrier Penetration Seal Identification Description Bus Duct Penetrations (Column line 8) Fire Area 5-2 to Fire Area 5-1 Conduit 1CC 944NR1 (Column line 8) Fire Area 5-2 to Fire Area 5-1 Fire Proofing Insulation Identification Description Steel Beam Sprayed-on Fireproofing Fire Area 5-2 to Fire Area 5-1 (Column line 8)

LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1R05.01 / 1R05.05 / 1R05.06)

1-CH-FI-1130B 1-CH-FI-1127B 1-CH-FI-1124B 1-CH-MOV-1373 1-HV-F42 2-HV-F42 1-FP-HS-19 1-SW-MOV-108B 2-SW-MOV-208B 1-RC-MOV-1535 1-RC-PCV-1456 1-CH-FCV-1122 1-SW-P-1A 1-SW-P-1B 1-MS-TV-111A 1-MS-TV-111B Electric Fire Pump (control room switch)

Diesel Fire Pump (control room switch)

2-CH-FCV-2122 2-CH-HCV-2310 2-RC-PCV-2456 2-RC-PCV-2455C 2-SW-P-1A 2-SW-P-1B 2-SW-P-4 2-SW-MOV-215A 2-SW-MOV-215B 2-SW-MOV-217 2-SW-TCV-202A 2-SW-TCV-202B 2-SW-TCV-202C 2-MS-TV-211A 2-MS-TV-211B