Text

IR 05000341-02-008 (Drs); Detroit Edison Company; on 11/19-12/6/02, Fermi Power Plant; Unit 2. Fire Protection Triennial
	ML030070265
Person / Time
Site:	Fermi
Issue date:	01/03/2003
From:	Gardner R; NRC/RGN-III/DRS/EEB
To:	O'Connor W; Detroit Edison
References
	IR-02-008
	Download: ML030070265 (28)
	v • d • e

January 3, 2003

SUBJECT:

FERMI POWER PLANT NRC INSPECTION REPORT 50-341/02-08(DRS)

Dear Mr. OConnor:

On December 6, 2002, the NRC completed an inspection at your Fermi Power Plant. The enclosed report documents the inspection findings which were discussed on December 6, 2002, 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. Specifically, this inspection focused on the triennial fire protection baseline inspection.

Based on the results of this inspection, the inspectors identified two issues of very low safety significance (Green). The issues were determined to involve violations of NRC requirements.

However, because of the very low safety significance and because the issues have been entered into your corrective action program, the NRC is treating these issues as Non-Cited Violations, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest the violations or significance of the Non-Cited Violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Fermi 2 Nuclear Power Plant. In accordance with 10 CFR Part 2.790 of the NRC's Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by Roger Lanksbury Acting For/

Ronald N. Gardner, Chief Electrical Engineering Branch Division of Reactor Safety Docket Nos. 50-341 License Nos. DPR-43 Enclosure:

NRC Inspection Report 50-341/02-08(DRS)

cc w/encl:

N. Peterson, Director, Nuclear Licensing P. Marquardt, Corporate Legal Department Compliance Supervisor R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Monroe County, Emergency Management Division Emergency Management Division MI Department of State Police

SUMMARY OF FINDINGS

IR 05000341-02-08(DRS); Detroit Edison Company; on 11/19-12/6/02, Fermi Power Plant;

Unit 2. Fire Protection Triennial.

The inspection was conducted by a team of three Region III specialist inspectors. The inspection identified two Green Non-Cited Violations (NCVs). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A.

Inspector Identified Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified that the licensee failed to have adequate procedures in effect for alternative shutdown in accordance with their license conditions. Specifically, performance of necessary actions to conduct an alternative shutdown would have required operators to perform steps contrary to the emergency operating procedures. The failure to have adequate procedures in effect for alternative shutdown is a violation of a license condition.

This issue was greater than minor because the conflict between procedures could result in operator delay and confusion for performance of necessary alternative shutdown steps. The finding was determined to be of very low safety significance, i.e., Green, because the finding did not affect a fire protection feature and interviews with operators indicated that they would take the necessary actions. Because the finding was of very low safety significance, and the finding was captured in the licensees corrective action system, this finding is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (Section 1R05.5.b.1).

Green.

The inspectors identified that the licensee failed to promptly correct identified deficiencies in the alternative shutdown procedure which specified safe shutdown actions to be taken in the event of a fire in an affected fire area.

Specifically, the alternative shutdown procedure which specified operator actions in the event of a fire in fire area 11ABE relied upon operator actions to be taken in the same area. As such, operators may not have been able to perform the directed actions due to exposure to the fire, the actions may not have been effective due to fire damage, and the carbon dioxide fire suppression system for the area could have been adversely affected. The failure to take prompt corrective actions is a violation of a license condition.

The issue was greater than minor because specified actions may not have been effectively accomplished and a fire protection feature was affected. The finding was determined to be of very low safety significance, i.e., Green, because there were no identified fire damage scenarios which would require alternative shutdown. Because the finding was of very low safety significance, and the finding was captured in the licensees corrective action system, this finding is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (Section 4OA2.b.1).

REPORT DETAILS

Summary of Plant Status

Unit 2 was operated at or near full power throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection

Main article: IP 71111.05

The purpose of this inspection was to review the Fermi fire protection program for selected risk-significant fire areas. Emphasis was placed on verifying 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 inspection was performed in accordance with the Nuclear Regulatory Commissions (NRCs) new regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The inspectors used the Fermi 2 Individual Plant Examination (External Events) (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire areas chosen for review during this inspection were:

01AB, Auxiliary Building Basement 02AB, Auxiliary Building Mezzanine/Cable Tray Area 11ABE, 3rd Floor DC/MCC [Direct Current/Motor Control Center] Area For each of these fire zones, the inspection was focused on the fire protection features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of license commitments, and changes to the fire protection plan.

.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown

The guidelines established by Branch Technical Position (BTP), Chemical Engineering Branch (CMEB) 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1),required the licensee to provide fire protection features that were capable of limiting fire damage to structures, systems, and components (SSCs) important to safe shutdown.

The SSCs that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features that were capable of limiting fire damage to the SSCs so that:

One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and

Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

General Description of Fermi 2s Safe Shutdown Paths and Capability The licensees safe shutdown methodology relied upon the identification of those components necessary and available to achieve and maintain hot shutdown conditions following a fire condition. Once identified for all plant areas, the licensee selected the components necessary to achieve and maintain the reactor in a hot shutdown condition which could be operated from the main control room or which could be operated locally and were not within the fire affected area. The methodology further identified those components necessary to achieve and maintain cold shutdown assuming limited repairs.

The licensee also identified an alternate or dedicated shutdown capability for fire conditions that affected the main control room and other areas requiring alternative or dedicated shutdown capability. For each of these areas, the licensee relied upon the operators use of the dedicated shutdown panels and local operator actions to ensure that the reactor could be brought to and maintained in a hot shutdown status.

a. Inspection Scope

The inspectors reviewed the plant systems required to achieve and maintain post-fire safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for each fire zone selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included the fire protection safe shutdown analysis.

The inspectors also reviewed the operators ability to perform the necessary manual actions for achieving safe shutdown, including a review of procedures, accessibility of safe shutdown equipment, and the available time for performing the actions.

The inspectors reviewed the final safety analysis report (FSAR), as updated, and the licensees engineering and/or licensing justifications (e.g., NRC guidance documents, license amendments, technical specifications, safety evaluation reports, exemptions, and deviations) to determine the licensing basis.

b. Findings

No findings of significance were identified.

.2 Fire Protection of Safe Shutdown Capability

The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraphs (2)(a) and (3), required separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. If the guidelines cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the licensees safe shutdown analysis to ensure that at least one post-fire safe shutdown success path was available in the event of a fire. This included a review of manual actions required to achieve and maintain hot shutdown conditions and make the necessary repairs to reach cold shutdown within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The inspectors also reviewed procedures to verify that adequate direction was provided to operators to perform these manual actions. Factors, such as timing, access to the equipment, and the availability of procedures, were considered in the review.

The inspectors also evaluated the adequacy of fire suppression and detection systems, fire area barriers, penetration seals, and fire doors to ensure that at least one train of safe shutdown equipment was free of fire damage. To do this, the inspectors observed the material condition and configuration of the installed fire detection and suppression systems, fire barriers, and construction details and supporting fire tests for the installed fire barriers. In addition, the inspectors reviewed license documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, fire hazard analysis (FHA) reports, safe shutdown analysis, and National Fire Protection Association (NFPA) codes to verify that the fire barrier installations met license commitments.

b. Findings

No findings of significance were identified.

.3 Post-fire Safe Shutdown Circuit Analysis

The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1), required that SSCs important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Options for providing this level of fire protection were delineated in BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (2). Where the protection of systems whose function was required for hot shutdown did not satisfy BTP CMEB 9.5-1, Section C.5.b, Paragraph (2), an alternative or dedicated shutdown capability and its associated circuits, was required to be provided that was independent of the cables, systems, and components in the area. For such areas, BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (3),specifically required the alternative or dedicated shutdown capability to be physically and electrically independent of the specific fire areas and capable of accommodating post-fire conditions where offsite power was available and where offsite power was not available for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

a. Inspection Scope

On a sample basis, the inspectors investigated the adequacy of separation provided for the power and control cabling of redundant trains of shutdown equipment. This investigation focused on the cabling of selected components in systems important for safe shutdown. The inspectors review also included a sampling of components whose inadvertent operation due to fire may adversely affect post-fire safe shutdown capability.

The purpose of this review was to determine if a single exposure fire, in one of the fire areas selected for this inspection, could prevent the proper operation of both safe shutdown trains.

The team reviewed the licensees fuse/breaker coordination analysis for the 4.16 kiloVolt and 480 Volt alternating current (AC) switchgear required for post-fire safe shutdown and the vital low-voltage AC and DC buses. The purpose of this review was to verify that selective coordination exists between branch circuit protective devices (fuses, breakers, relays, etc.) and the bus feeder breaker/fuse to ensure that in the event of a fire-induced short circuit, the fault is isolated before the feeder device trips. In addition, a review of the licensees fuse replacement procedure was conducted to determine if adequate administrative controls existed to prevent the inadvertent substitution of incorrectly sized fuses in critical circuits.

b. Findings

No findings of significance were identified.

.4 Alternative Safe Shutdown Capability

The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1), required the licensee to provide fire protection features that were capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Specific design features for ensuring this capability were provided in BTP CMEB 9.5-1, Section C.5.b, Paragraph (2). Where compliance with the separation criteria of BTP CMEB 9.5-1, Section C.5.b, Paragraphs

(1) and

(2) could not be met, BTP CMEB 9.5-1, Section C.5.b, Paragraph

(3) and Section C.5.c, required an alternative or dedicated shutdown capability be provided that was independent of the specific fire area under consideration. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those predicted for a loss of normal AC power, and the fission product boundary integrity must not be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).

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.

b. Findings

No findings of significance were identified.

.5 Operational Implementation of Alternative Shutdown Capability

The guidelines established by BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (2)(d), required that the process monitoring function should be capable of providing direct readings of the process variables needed to perform and control the functions necessary to achieve reactivity control, reactor coolant makeup, and decay heat removal.

a. Inspection Scope

The inspectors performed a walkdown of a sample of the actions defined in Procedure 20.000.18, Control of the Plant from the Dedicated Shutdown Panel, which was the procedure for performing a plant alternative shutdown from outside the control room.

The inspectors conducted the walkdown to verify that operators could reasonably be expected to perform the procedure actions within the identified applicable plant shutdown time requirements and that equipment labeling was consistent with the procedure.

The inspectors reviews of the adequacy of communications and emergency lighting associated with these procedures are documented in Sections 1R05.6 and 1R05.7 of this report.

b. Findings

b.1 Failure to Have Adequate Procedures in Effect for Alternative Shutdown The inspectors identified that the licensee failed to have adequate procedures in effect for alternative shutdown in accordance with their license conditions. This issue was considered to be of very low safety significance and was dispositioned as a Green Non-Cited Violation (NCV).

Based on interviews with licensed operators and review of operating procedures, the inspectors determined that operators could potentially be using Emergency Operating Procedure (EOP) 29.100.01, Sheet 2, Primary Containment Control, and Abnormal Operating Procedure (AOP) 20.000.18 simultaneously. In addition, licensed operators informed the inspectors that EOP 29.100.01 took precedence over AOP 20.000.18.

Step DWT-5 of EOP 29.100.01, Sheet 2, directed operators to isolate emergency equipment cooling water (EECW) to and from the drywell. Step W of AOP 20.000.18 directed operators to unisolate EECW to the drywell. Although the actions of AOP 20.000.18 were necessary and correct, they were in conflict with those of EOP 29.100.01. Consequently, operator confusion and delay could occur in performance of those actions. During interviews with licensed operators, the licensed operators indicated that they would unisolate EECW to the drywell as required by AOP 20.000.18. However, the inspectors determined that by doing so, operators would be performing steps contrary to EOP 29.100.01, a procedure required by Technical Specification 5.4.1.b. Performing actions contrary to EOP 29.100.01 would be in violation of Technical Specification 5.4.1, which required, in part, that written procedures for EOPs be implemented. As such, the licensee would be in the position of operating under 10 CFR 50.54(x), which allows reasonable actions to be taken that depart from a technical specification in an emergency when the action is necessary to protect the health and safety of the public and no action consistent with license conditions and technical specifications which can provide adequate or equivalent protection is immediately apparent. The inspectors considered the necessity of operating under 10 CFR 50.54(x) to perform alternative shutdown actions to be equivalent to not having procedures in effect to implement alternative shutdown capability.

License condition 2.C(9) of the facility operating license stated, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report (FSAR) for the facility.

Section 9A.3 of the FSAR for the facility, as updated, stated, in part, that an alternative shutdown system had been designed and installed to meet the technical requirements of 10 CFR Part 50, Appendix R, Sections III.G.3 and L. Appendix R of 10 CFR Part 50, Section III.L.3 stated, in part, that procedures shall be in effect to implement alternative and dedicated shutdown capability. Contrary to the above, procedures were not in effect for implementing alternative shutdown capability in that actions necessary to implement alternative shutdown capability were in conflict with EOP steps.

In accordance with Inspection Manual Chapter (IMC) 0612, the inspectors determined that the issue was more than minor because the finding was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems reactor safety cornerstone and affected the mitigating systems objective. In accordance with IMC 0609, Appendix A, the inspectors performed a Significance Determination Process (SDP) Phase 1 screening and determined that the finding degraded the Fire Protection portion of the Mitigation Systems Cornerstone. As such, screening under IMC 0609, Appendix F, was required. Based on review of IMC 0609, Appendix F, the inspectors determined that the finding did not require a Phase 2 analysis because no fire protection feature was affected. In addition, although the procedure conflict could result in delay and confusion, the inspectors determined that operators would likely perform the correct actions based on interviews of licensed operators. As such, this finding was considered to be of very low safety significance (i.e., Green). The failure to have adequate procedures in effect for alternative shutdown was a violation of a Fermi 2 license condition (2.C(9)). This violation was associated with a finding that was characterized by the Significance Determination Process as having very low risk significance (i.e., Green) and was being treated as a Non-Cited Violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. This violation was in the licensees corrective action program as Condition Assessment Resolution Document (CARD) 02-19225 (NCV 50-341/02-08-01).

b.2 Actions Specified in Affected Fire Area A finding relating to the licensees failure to promptly correct a procedure which specified safe shutdown actions in an affected fire area was identified and is discussed in Section 4OA2.b.

.6 Communications

The guidelines established by BTP CMEB 9.5-1, Section C.5.g, Lighting and Communication, Paragraph (4), required that a portable communications system be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of the plant security force. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage.

a. Inspection Scope

The inspectors reviewed the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.

b. Findings

No findings of significance were identified.

.7 Emergency Lighting

The guidelines established by BTP CMEB 9.5-1, Section C.5.g, Lighting and Communication, Paragraph (1), required that fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual 8-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas.

a. Inspection Scope

The inspectors performed a walkdown of a sample of the actions defined in plant procedures used to control local equipment operations. As part of the walkdowns, the inspectors verified that sufficient emergency lighting existed for access and egress to areas and for performing necessary equipment operations.

b. Findings

No findings of significance were identified.

.8 Cold Shutdown Repairs

The guidelines established by BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (5), required that equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.

a. Inspection Scope

The inspectors reviewed the licensees procedures to determine if any repairs were required to achieve cold shutdown.

b. Findings

No findings of significance were identified.

.9 Fire Barriers and Fire Zone/Room Penetration Seals

The guidelines established by BTP CMEB 9.5-1, Section C.5.a, Building Design, Paragraph (3), required that penetration seal designs be qualified by tests that are comparable to tests used to rate fire barriers.

a. Inspection Scope

The inspectors reviewed the test reports for 3-hour rated barriers installed in the plant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with tested configuration.

b. Findings

No findings of significance were identified.

.10 Fire Protection Systems, Features, and Equipment

The guidelines established by BTP CMEB 9.5-1 required that fire protection systems, features and equipment were designed in accordance with the following:

Fire Protection Systems, Features and Equipment BTP CMEB 9.5-1 Section BTP CMEB 9.5-1 Title Fire Brigade Capabilities C.3 Fire Brigade Passive Fire Protection Features C.5.a Building Design Fire Detection System C.6.a Fire Detection Fire Suppression System C.6.b Fire Protection Water Supply Systems C.6.c Water Sprinkler and Hose Standpipe Systems Manual Fire Fighting Equipment C.6.f and C.3 Portable Extinguishers and Fire Brigade

a. Inspection Scope

The inspectors reviewed the material condition, operations lineup, operational effectiveness, and design of fire detection systems, fire suppression systems, manual fire fighting equipment, fire brigade capability, and passive fire protection features. The inspectors reviewed deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, and FHA reports to ensure that selected fire detection systems, carbon dioxide systems, portable fire extinguishers, and hose stations were installed in accordance with their design, and that their design was adequate given the current equipment layout and plant configuration.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that adequate compensatory measures were put in place by the licensee for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features. The inspectors also conducted reviews to verify that short term compensatory measures were adequate to compensate for a degraded function or feature until appropriate corrective actions were taken.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES (OA)

4OA2 Identification and Resolution of Problems

The guidelines established by BTP CMEB 9.5-1, Section C.4, Quality Assurance [QA]

Program, Paragraph h, required that measures be established to ensure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformances, are promptly identified, reported, and corrected.

a. Inspection Scope

The inspectors reviewed a selected sample of condition reports associated with Fermi 2s fire protection program to verify that the licensee had an appropriate threshold for identifying issues. The inspectors evaluated the effectiveness of the corrective actions for the identified issues.

b. Findings

- Failure to Promptly Correct Procedure Which Specified Safe Shutdown Actions in Affected Fire Area The inspectors identified that the licensee failed to promptly correct, as required by a Fermi 2 license condition, a procedure which specified safe shutdown actions in an affected fire area This issue was considered to be of very low safety significance and was dispositioned as a Green NCV.

The licensee identified that their safe shutdown analyses inappropriately took credit for actions performed in fire area 11ABE. Specifically, AOP 20.000.18, the procedure for alternative shutdown, specified actions to be taken in event of a fire in fire area 11ABE.

However, AOP 20.000.18 directed operators to take actions in fire area 11ABE (i.e., the an area potentially affected by fire.) The inspectors noted that 10 CFR Part 50, Appendix R, Section III.L.3, required, in part, that alternative shutdown capability be independent of the specific fire area. The license was committed to 10 CFR Part 50, Appendix R, Section III.L by license condition. The licensee documented this issue in their corrective action program on CARDs 00-15865 and 00-15866, dated June 16, 2000. The CARDs specifically identified that area 11ABE could potentially be filled with smoke, carbon dioxide (CO2), and heat. As such, operators might not be able to perform the actions specified by the procedure. The CARDs identified that spurious events could occur as a result of not being able to perform the actions specified by the procedure. As a compensatory measure, the licensee instituted hourly fire watches.

CARD 00-15865 was closed on February 26, 2001, although resolution of the analysis issues and compensatory measures remained open on CARD 00-15866. The actions of CARD 00-15866, which included actions to resolve associated analysis issues, were transferred to CARD 99-17222, a broader scope CARD related to NRC Information Notice 99-17, Problems With Post-Fire Safe Shutdown Analysis, on December 13, 2001. Corrective actions were subsequently rolled into CARD 02-11747, initiated in May 2002.

During this inspection, the inspectors noted that the procedural steps and associated cautions for actions taken in fire area 11ABE were essentially the same as those in the June 2000 version of the procedure when the licensee had originally identified the issue.

No substantive corrective actions had been taken to correct the procedure. The inspectors noted that self-contained breathing apparatus had been provided in nearby locations for the operators. However, even if an operator were able to perform the actions specified by the procedure, the inspectors noted that the actions may not be effective due to fire damage. In addition, fire area 11ABE was protected by a CO2 system which required that a tight envelope be maintained for the required soak time in order for the CO2 to be effective in extinguishing the fire. However, having an operator perform the procedure steps would have required the operator to breach the CO2 envelope for the fire area thereby impacting the effectiveness of the CO2 system.

As a result of the inspectors raising the above issues and the timeliness of the licensees corrective actions, the licensee initiated CARD 02-19401 and revised AOP 20.000.18 during this inspection. The revised procedure was issued on November 27, 2002, and directed operators to perform actions outside of fire area 11ABE if the fire was in fire area 11ABE.

Section 2.C.9 of the Fermi 2 Facility Operating License stated, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report (FSAR) for the facility.

Section 9A of the FSAR, as updated, outlined the licensee commitments for fire protection. Section 9A.5 of the FSAR, as updated, provided a point-by-point comparison with Appendix A to NRC Branch Technical Position APCSB 9.5-1, dated August 23, 1976. Position c.8 listed in Section 9A.5 of the FSAR, as updated, identified the NRC position regarding quality assurance requirements for corrective action. The licensee response was that this item is included in the quality assurance program.

Section 17 of the FSAR, as updated, is the quality assurance program for the licensee.

Section 17.2.16 of the FSAR, as updated, established the quality assurance requirements for corrective action. Section 17.2.16 of the FSAR, as updated, stated, in part, that measures are established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected. Contrary to the above, the licensee failed to promptly correct AOP 20.000.18 which directed actions which potentially could not have been accomplished, potentially could have been ineffective, and could have adversely affected the operability of an installed fire suppression system. Although inadequacies associated with AOP 20.000.18 were originally identified on June 16, 2000, the inadequacies were not corrected as of November 26, 2002.

In accordance with Inspection Manual Chapter (IMC) 0612, the inspectors determined that the issue was more than minor because the finding was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems reactor safety cornerstone and affected the mitigating systems objective. In accordance with IMC 0609, Appendix A, the inspectors performed a Significance Determination Process (SDP) Phase 1 screening and determined that the finding degraded the Fire Protection portion of the Mitigation Systems Cornerstone. As such, screening under IMC 0609, Appendix F, was required. Based on Figure 4-1 of IMC 0609, Appendix F, the finding was determined to affect fixed suppression capability. Under the screening criteria for Figure 4-3 of IMC 0609, Appendix F, the inspector determined that the fixed suppression system was affected. As such, a Phase 2 analysis was required. Although there was equipment in the fire area, the equipment present was of relatively low voltage and did not have openings in the top which could allow a fire to propagate to cables along the room ceiling. Additionally, the licensees institution of fire watches ensured that there were no transient combustibles stored in the room. Consequently, the inspectors were not able to postulate a fire damage scenario for Phase 2. As such, this finding was determined to be of very low safety significance (i.e., Green). The failure to promptly correct the procedure for alternative shutdown was a violation of a Fermi 2 license condition (2.C(9)). This violation was associated with a finding that was characterized by the Significance Determination Process as having very low risk significance (i.e., Green) and was being treated as a Non-Cited Violation (NCV),consistent with Section VI.A.1 of the NRC Enforcement Policy. This violation was in the licensees corrective action program (NCV 50-341/02-08-02).

4OA6 Meetings

Exit Meeting The inspectors presented the inspection results to Mr. W. OConnor and other members of licensee management at the conclusion of the inspection on December 6, 2002. The licensee acknowledged the findings presented. No proprietary information was identified.

KEY POINTS OF CONTACT Licensee W. OConnor, Vice-President, Nuclear Generation D. Cobb, Plant Manager K. Burke, Supervisor, Nuclear Performance Engineering R. Johnson, Supervisor, Nuclear Licensing R. Libra, Director, Nuclear Engineering J. Moyers, Manager, Nuclear Quality Assurance S. Peterman, Manager, Operations N. Peterson, Manager, Nuclear Licensing S. Stasek, Director, Nuclear Assessment J. Thorson, Acting Manager, Nuclear Performance Engineering NRC R. Gardner, Chief, Electrical Engineering Branch, Region III J. Larizza, Resident Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-341/02-08-01 NCV Failure to Have Adequate Procedures for Alternative Shutdown in Effect 50-341/02-08-02 NCV Failure to Take Prompt Corrective Actions to Correct Identified Deficiencies in Alternative Shutdown Procedure Closed 50-341/02-08-01 NCV Failure to Have Adequate Procedures for Alternative Shutdown in Effect 50-341/02-08-02 NCV Failure to Take Prompt Corrective Actions to Correct Identified Deficiencies in Alternative Shutdown Procedure LIST OF ACRONYMS USED AC Alternating Current ADAMS Agencywide Documents Access and Management System AOP Abnormal Operating Procedure BTP Branch Technical Position CARD Condition Assessment Resolution Document CFR Code of Federal Regulations CMEB Chemical Engineering Branch CO2 Carbon Dioxide DC Direct Current DRS Division of Reactor Safety EECW Emergency Equipment Cooling Water EOP Emergency Operating Procedure FHA Fire Hazard Analysis FSAR Final Safety Analysis Report IMC Inspection Manual Chapter IPEEE Individual Plant Examination of External Events IR Inspection Report LLC Limited Liability Company MCC Motor Control Center NFPA National Fire Protection Association NRC United States Nuclear Regulatory Commission OA Other Activities PARS Publicly Available Records QA Quality Assurance SDP Significance Determination Process SSC Structure, System, or Component LIST OF

DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection, including

documents prepared by others for the licensee. Inclusion on this list does not imply that NRC

inspectors reviewed the documents in their entirety, but rather that selected sections or portions

of the documents were evaluated as part of the overall inspection effort. Inclusion of a

document in this list does not imply NRC acceptance of the document, unless specifically stated

in the inspection report.

CARDs Reviewed

99-15137

Licensee response to NRC Notice 99-17;

Problems associated with Post-Fire Safe-

Shutdown Circuit Analysis

May 8, 2002

99-17222

Identified issue in which 20.000.18 does not isolate

P5000F154 for all Dedicated Shutdown Fire Zones

October 27, 1999

00-15865

Procedural discrepancies that may prevent or

negate actions required for 20.000.18

June 21, 2002

00-15866

Lack of analysis supporting stripping of DC supply

to RHR Complex during implementation of

20.000.18

June 16, 2002

01-17245

NFPA 13 Sprinkler system discrepancies.

July 19, 2001

01-17246

Audit Finding: Wet sprinkler system pressure is

high for several areas in the Reactor Bldg.

July 24, 2001

2-11059

Pendant Sprinkler installed without return bend as

required by NFPA 13 in Aux Bldg 1st Fl Mezzanine

and cable tray area.

February 26, 2002

2-11747

Fire Protection Program Improvements.

August 14, 2002

2-12387

NFPA 13 requirements for spare sprinklers are not

met.

July 10, 2002

2-12388

The FP Self Assessment NFPA 13 1980 Ed. Code

compliance review has a concern that the

hydraulic reference points on the fire protection

system are not the same as those used in DC-

5713.

July 6, 2002

2-12399

Some sprinklers have protection areas in excess

of the limits specified by NFPA 13.

April 25, 2002

2-12403

Spacing of some branch lines end sprinklers is

greater than what is allowed by NFPA 13.

April 25, 2002

2-12404

Inadequacies exist in sprinkler coverage for cable

trays.

April 25, 2002

2-12412

Valve N2000F636 operator has been rotated 180°

and is not operable from the floor

May 2, 2002

2-13702

Electric Fire Pump starts cause Fire System flange

leakage.

April 16, 2002

2-19161

FP-AB-3-14f Fire Protection Pre-Plan Section 6.2

identifies fewer ventilation dampers closing than

28.502.07 or 28.501.02 when CO2 system initiates

November 21,

2002

2-21263

Discrepancy between FP-AB-3-14f and 23.501.02

with regards to CO2 soak time

November 26,

2002

2-21266

Determine if the fire detection installation in

UFSAR fire zone 1AB, control air compressor

room is required to conform to the NFPA 72E 1974

Ed. criteria for high ceiling

December 2, 2002

CARDs Initiated as a Result of this Inspection

2-19164

Evaluate effectiveness of fire detectors in 11AB

November 11,

2002

2-19224

Procedure 20.000.18 Enhancement

November 2, 2002

2-19225

EOP interaction with post fire shutdown using AOP

20.000.18

November 22,

2002

2-19401

Untimely corrective actions for Zone 11AB fire

scenario

November 26,

2002

2-19497

Fire protection program with regards to UFSAR

Chapter 17

December 4, 2002

2-21271

In various areas in Fire Zone 2AB, cable trays

installed above the sprinklers

December 6, 2002

2-21272

The fire test information available for review for 3M

M20A/CS195 fire barriers is insufficient

December 4, 2002

Engineering Evaluations

EVAL-DE0035-

Evaluation of Fermi 2 Wet Pipe Sprinkler Systems

for Compliance with the requirements of NFPA-13,

Standard for the Installation of Sprinkler Systems

Revision 0

EVAL-DE0035-

Evaluation of Fermi 2 Wet Pipe Sprinkler Systems

for Compliance with the Requirements of NFPA-

13.

Revision 0

EVAL-DE0027-

Evaluation of Fermi 2 Wet Pipe Sprinkler Systems

for Compliance with the Requirements of NFPA-

13.

Revision 0

Fire Protection Self-Assessment

May 31, 2002

TSR-30217

Time to Void EECW in Drywell During Dedicated

Shutdown

Revision 0

Drawings

6E721-2808-12A