IR 05000346/2004009
| ML043200562 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/15/2004 |
| From: | Grobe J NRC/RGN-III |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| References | |
| IR-04-009 | |
| Download: ML043200562 (30) | |
Text
November 15, 2004
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REPORT NO. 05000346/2004009(DRS)
Dear Mr. Bezilla:
On October 25, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed a fire protection triennial baseline inspection at your Davis-Besse Nuclear Power Station. The enclosed report documents the inspection finding which was discussed with you and other members of your staff.
The inspection examined the effectiveness of activities conducted under your license as they related to the implementation of your NRC-approved fire protection program for selected risk-significant fire areas. The inspection consisted of a selected examination of design drawings, calculations, analyses, procedures, audits, field walkdowns, and interviews with personnel.
Based on the results of this inspection, one issue was reviewed under the NRC traditional enforcement process and determined to be a Severity Level IV violation of NRC requirements.
However, because this violation was of very low safety significance and because the issue was entered into your corrective action program, the NRC is treating this finding as a Non-Cited Violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy.
If you contest the subject or severity of the NCV in this report, 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 20555-0001; with copies to the Regional Administrator, NRC - RIII, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector Office at the Davis-Besse Nuclear Power Station. In accordance with 10 CFR Part 2.390 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/
John A. Grobe, Chairman Davis-Besse Oversight Panel Docket No. 50-346 License No. NPF-3 Enclosure:
Inspection Report 05000346/2004009(DRS)
w/ Attachment: Supplemental Information cc w/encl:
The Honorable Dennis Kucinich G. Leidich, President - FENOC J. Hagan, Senior Vice President Engineering and Services, FENOC L. Myers, Chief Operating Officer, FENOC Plant Manager Manager - Regulatory Compliance M. OReilly, Attorney, FirstEnergy Ohio State Liaison Officer R. Owen, Administrator, Ohio Department of Health Public Utilities Commission of Ohio President, Board of County Commissioners of Lucas County C. Koebel, President, Ottawa County Board of Commissioners D. Lochbaum, Union Of Concerned Scientists J. Riccio, Greenpeace P. Gunter, N.I.R.S.
SUMMARY OF FINDINGS
IR 05000346/2004009(DRS); 08/30/2004 - 10/25/2004; Davis-Besse Nuclear Power Station;
Baseline Triennial Fire Protection Baseline and Special Inspection.
This report covers an announced baseline triennial fire protection inspection and an announced special inspection. The inspection was conducted by Region III inspectors. One Severity Level IV Non-Cited Violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, 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 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 and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Severity Level IV. The team identified that the licensee did not provide complete information to the NRC in a licensing submittal dated December 21, 2000. Specifically, the licensee did not identify that previously submitted licensing correspondence, dated March 15, 1989, regarding the basis for not protecting ventilation system cables, was no longer accurate. The licensee planned to submit correspondence to the NRC to provide complete information.
Because the issue potentially impacted the NRCs ability to perform its regulatory function, this finding was evaluated with the traditional enforcement process. The finding was determined to be more than minor because the regulatory process could have been impacted and the licensee had a clear opportunity to identify and correct the error. The finding was determined to be of very low safety significance because the licensee had a technically sound analysis which justified not protecting the ventilation system cables. This finding was determined to be a Severity Level IV Non-Cited Violation of 10 CFR 50.9. (Section 1R05.10)
Licensee-Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of this inspection was to review the Davis-Besse Nuclear Power Station 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 NRC reactor oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The team used the Davis-Besse Nuclear Power Station Individual Plant Examination for External Events along with insights gained during plant walkdowns to choose risk-significant areas for detailed inspection and review. The fire areas chosen for review during this inspection were:
Fire Area Description of Fire Area Reviewed BF Service Water Pump Area T
Component Cooling Water (CCW) Pump Room The above two areas were selected based on risk insights and that two separate shutdown strategies were used for the CCW pump room (fire area T). As such, the team considered these two inspection samples as equivalent in complexity to three samples as specified in the fire protection inspection procedure.
For each of these fire areas, the inspectors focused on the fire protection features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of licensee commitments, and changes to the fire protection program.
.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
Title 10 CFR Part 50, Appendix R,Section III.G.1, required the licensee to provide fire protection features that were capable of limiting fire damage to structures, systems, and components important to safe shutdown. The structures, systems, and components that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features. These features were required to be capable of limiting fire damage to the structures, systems, and components so that:
- One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) was free of fire damage; and
- Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) could be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Specific design features for ensuring this capability were specified by 10 CFR Part 50, Appendix R,Section III.G.2.
a. Inspection Scope
The team 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 team 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 team reviewed the Updated Safety Analysis Report (USAR) 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
Title 10 CFR Part 50, Appendix R,Section III.G.2, required separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a three hour rating. If the requirements 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 (10 CFR Part 50, Appendix R,Section III.G.3).
a. Inspection Scope
For each of the selected fire areas, the team 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The team 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 team 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 accomplish this, the team 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 team reviewed license documentation, such as fire code deviations, detector placement drawings, fire house station drawings, smoke removal plans, fire hazard analysis reports, safe shutdown analyses, and the National Fire Protection Association 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
Title 10 CFR Part 50, Appendix R,Section III.G.1, required that structures, systems, and components 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 10 CFR Part 50, Appendix R,Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R,Section III.G.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, 10 CFR Part 50, Appendix R,Section III.L.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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
a. Inspection Scope
On a sample basis, the team evaluated the adequacy of separation provided for the power and control cabling of redundant trains of shutdown equipment. This inspection focused on the cabling of selected components in systems important for safe shutdown.
The teams 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.
b. Findings
No findings of significance were identified.
.4 Alternative Safe Shutdown Capability
Title 10 CFR Part 50, Appendix R,Section III.G.1, required that structures, systems, and components 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 10 CFR Part 50, Appendix R,Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R,Section III.G.2, an alternative or dedicated shutdown capability independent of the area under consideration, was required to be provided. 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 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 team 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 team 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 Shutdown Capability
Title 10 CFR Part 50, Appendix R,Section III.L.2.d, required that the process monitoring function should be capable of providing direct readings of the process variables necessary to perform and control the functions necessary to achieve reactivity control, reactor coolant makeup, and decay heat removal.
a. Inspection Scope
The team reviewed a sample of the actions outlined in procedure DB-OP-02501, Serious Station Fire. The team verified that operators could reasonably be expected to perform the procedure actions within the identified applicable plant shutdown time requirements and that the actions were consistent with the plant safe shutdown analyses.
b. Findings
No findings of significance were identified.
.6 Communications
For a fire in an alternative shutdown fire area, control room evacuation is required and a unit shutdown is performed from outside the control room. Radio communications are relied upon to coordinate plant shutdown and for fire fighting. Title 10 CFR Part 50, Appendix R,Section III.H., required that equipment provided for the fire brigade include emergency communications equipment.
a. Inspection Scope
The team 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
Title 10 CFR Part 50, Appendix R,Section III.J., required that emergency lighting units with at least an 8-hour battery power supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
a. Inspection Scope
The team performed a walkdown of a sample of the actions defined in procedures DB-OP-02501, Serious Station Fire, and DB-OP-02519, Serious Control Room Fire.
As part of the walkdowns, the team focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations.
b. Findings
No findings of significance were identified.
.8 Cold Shutdown Repairs
Title 10 CFR Part 50, Appendix R,Section III.L.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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.
a. Inspection Scope
The team reviewed the licensees procedures to determine if any repairs were required to achieve cold shutdown. The team determined that the licensee did require repair of some equipment to reach cold shutdown based on the safe shutdown methods used.
The team reviewed the procedures for adequacy.
b. Findings
No findings of significance were identified.
.9 Fire Barriers and Fire Zone/Room Penetration Seals
Title 10 CFR Part 50, Appendix R,Section III.M, required that penetration seal designs be qualified by tests that are comparable to tests used to rate fire barriers.
a. Inspection Scope
The team reviewed the test reports for three-hour rated barriers installed in the plant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with the tested configuration. In addition, the team reviewed the fire loading for selected areas to ensure that existing barriers would not be challenged by a potential fire.
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems, Features, and Equipment
a. Inspection Scope
The team 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 team reviewed deviations, detector placement drawings, fire hose station drawings, and fire hazard analysis reports to ensure that selected fire detection systems, sprinkler 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
- (1) Incomplete Information Provided to NRC in Licensing Submittal
Introduction:
The team identified that the licensee failed to provide complete information to the NRC in a licensing submittal. Specifically, the licensee did not identify that previously submitted licensing correspondence regarding the basis for not protecting ventilation system cables was no longer accurate. The issue was considered to be of very low safety significance and was dispositioned as a Severity Level IV Non-Cited Violation (NCV).
Description:
In a letter dated March 15, 1989, the licensee informed the NRC that manual actions were not required to respond to the potential failure of ventilation circuits in the CCW pump room. The licensee had concluded that the CCW pump in the room, required for safe shutdown, would remain operable in the event of the loss of the ventilation system for the room. The basis for this conclusion was that CCW pumps would be operable with ambient temperatures of up to 185 degrees (E) Fahrenheit (F)and that the automatic wet-pipe sprinkler system located in the room had sprinkler heads which actuated at 165EF which would cool the air in the room. The NRC referenced the March 15, 1989, letter as part of the May 30, 1991, safety evaluation for fire protection measures.
In March 1990, the sprinkler system in the CCW pump room was modified under modification 89-0079, Appendix R Sprinkler System Upgrade, to bring the system into National Fire Protection Associated code compliance. As a result of the modification, the sprinkler heads would actuate at 212EF instead of the previous 165EF.
The license performed an analysis (Effect of a Fire in Room 328 on CCW Pump Availability, dated May 18, 1990) and determined that the ambient temperatures for the operating CCW pump would still be less than 185EF without the ventilation system. The licensees analysis did not take credit for actuation of the sprinklers. The team did not identify any concerns with respect to the licensees analysis.
In July 2000, the NRC performed a Safety System Design and Performance Capability inspection of the CCW system (Inspection Report 05000346/2000007(DRS)). During this inspection, the NRC identified that the bases for an existing exemption for lack of separation were no longer applicable and documented a NCV. As a corrective action, the licensee submitted a request, dated December 21, 2000, to amend the 10 CFR Part 50, Appendix R,Section III.G.2 exemption for lack of separation in the CCW pump room. The December 21, 2000, correspondence stated that a March 15, 1989, letter to the NRC noted the manual operator actions to establish temporary ventilation in the CCW pump room in the event of a fire was no longer considered necessary since the CCW pumps would not overheat despite the fire and postulated loss of the CCW pump room ventilation.
By letter dated December 26, 2002, the NRC updated the exemption for the CCW pump room in response to the licensees December 21, 2000, request. As part of the exemption, the NRC stated:
On March 15, 1989, the licensee submitted a letter postulating the loss of CCW room ventilation due to a fire and the effect on the CCW pumps. From the manufacturers data, the licensee determined that the maximum room temperature the pumps could remain operational was 185EF. The licensee concluded that since the sprinkler system operated at 165EF, the sprinkler system would keep the pumps from reaching 185EF, allowing the pumps to remain operational. Therefore, the licensee concluded the CCW room ventilation was not necessary for SSD [safe shutdown] and fire wrap on the associated cabling for the ventilation system was no longer necessary.
During this inspection, the team considered the information provided in the December 21, 2000, correspondence to be accurate. However, the team noted that the December 21, 2000, correspondence did not identify that the basis for concluding that ventilation system circuits did not need to be protected had changed. Specifically, the correspondence did not identify that the sprinkler system had been modified resulting in a different sprinkler actuation temperature and that the licensee no longer relied upon the sprinkler system to provide cooling.
Since the information provided by the licensee in the March 15, 1989, letter was cited as a basis for the exemption, the team concluded that the basis for concluding that the ventilation cables were not required to be protected was material to the licensing action.
In addition, the team determined that the December 26, 2002, letter from the NRC presented a clear opportunity for the licensee to identify that incomplete information had been submitted to the NRC. The licensee did not take actions to correct the mis-communication.
Analysis:
The team considered that the failure to provide complete material information in a submittal to the NRC was a performance deficiency. The failure to provide information complete and accurate in all material respects potentially impacted the NRCs ability to perform its regulatory function.
Because violations of 10 CFR 50.9 are considered to be violations that potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Significance Determination Process (SDP).
Typically, the Severity Level would be assigned after consideration of appropriate factors for the particular regulatory process violation in accordance with the NRC Enforcement Policy. However, the SDP is used, if applicable, in order to consider the associated risk significance of the finding prior to assigning a severity level. Using IMC 0612, Appendix B, Issue Dispositioning Screening, and Section IX of the NRC Enforcement Policy, the team determined that the finding was more than minor because it involved information provided to the NRC for a licensing action and could have impacted the regulatory process. In addition, the licensee had failed to take appropriate corrective action when there was a clear opportunity to identify and correct the error.
The team considered the licensees conclusion that fire wraps were no longer needed on cables for the CCW pump room ventilation system to be technically sound. As such, the team determined that it is reasonable that the requested licensing action may have been approved if the licensee had provided materially complete information to the NRC.
Consequently, the team concluded that the finding was of very low safety significance.
The team concluded that the finding did not impact any of the reactor safety cornerstones and that the SDP was not applicable.
Enforcement:
Title 10 CFR 50.9 requires, in part, that information provided to the NRC by a licensee be complete in all material respects. Contrary to the above, on December 21, 2000, the licensee provided information to the NRC by docketed correspondence which was not complete in all material respects. Specifically, the December 21, 2000, correspondence referred to a March 15, 1989, letter from the licensee as providing a basis for not protecting cables associated with the ventilation system for the CCW pump room. However, the licensee failed to identify that the rationale for not protecting cables associated with the CCW pump room ventilation had changed since the issuance of the March 15, 1989, letter. Specifically, the March 15, 1989, letter provided the rationale that a 165EF actuation of the sprinkler system would maintain ambient temperatures for the operating CCW pump below 185EF. However, at the time of the December 21, 2000, submittal, the rationale had changed because the sprinkler system had been modified to actuate at 212EF and subsequent analyses performed by the licensee no longer relied upon actuation of the sprinkler system for providing cooling. The result of this violation was determined to be of very low safety significance; therefore, this violation of 10 CFR 50.9 was classified as a Severity Level IV violation. This Severity Level IV violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NRC 05000346/2004009-01). The licensee entered the issue into their corrective action program as Condition Report 04-05695 and planned to submit correspondence to the NRC to provide complete information.
.11 Compensatory Measures
a. Inspection Scope
The team 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 team also reviewed the adequacy of short term compensatory measures 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
a. Inspection Scope
The team reviewed the corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to fire protection at an appropriate threshold and entering them in the corrective action program. The team reviewed selected samples of condition reports, work orders, design packages, and fire protection system non-conformance documents.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
.1 Review of Actions to Address Thermo-Lag Issues (93812, 71152)
a. Inspection Scope
The team reviewed a sample of the licensees implementation of Thermo-Lag fire barrier corrective actions which were required by NRC Confirmatory Order dated June 22, 1998. The teams review included modifications, safe shutdown analysis, evaluations, licensee correspondence with the NRC, and new fire barrier installations. The teams review specifically included:
Licensing Correspondence referenced by the June 22, 1998, Confirmatory Order; Modification 95-0056, Resolution to Thermo-Lag Fire Barrier Deficiencies; and Modification 96-0005, Modify the CCW Pump Breaker Logic to Delete the Low Flow/High Temperature Trip Function.
b.
Observations The team confirmed that the licensee did not take credit for Thermo-Lag as a fire barrier to satisfy NRC regulatory requirements for fire protection (i.e., 10 CFR 50.48 and 10 CFR Part 50, Appendix R). Based on discussions with licensee engineering personnel, the team understood that the licensee did use Thermo-Lag for protecting structural steel in the building housing the station black-out diesel generator outside of the plant. The station black-out diesel generator, and associated building, was not credited in the USAR and, as such, was not considered part of the plant. The team determined that this use of Thermo-Lag was not contrary to the confirmatory order because the use was purposes other than satisfying NRC regulatory requirements for fire protection.
The team noted that some of the earlier licensee correspondence indicated that all Thermo-Lag fire barrier material would be removed. The team identified that for cases where cables were still required to be protected, the Thermo-Lag fire barrier materials had been removed and replaced with a qualified alternative fire barrier, consistent with the earlier licensee correspondence. However, subsequent to the earlier licensee correspondence, the licensee had performed either engineering evaluations and/or modifications obviating the need for some cables having Thermo-Lag fire barriers to continue to be protected by a qualified fire barrier for some cases. As such, the licensee abandoned some Thermo-Lag fire barriers in place. The licensee had informed the NRC that some Thermo-Lag fire barriers would be abandoned in place by telephone conversations on November 5, 1997, and June 1, 1998; and in the January 25, 1999, letter informing NRC of the final closeout regarding resolution of Thermo-Lag issues.
For cases where installed Thermo-Lag fire barriers were abandoned in place, the licensee evaluated the impact of installed Thermo-Lag fire barriers upon the ampacity for affected cables. In addition, the licensee included the weight of installed Thermo-Lag material in fire loading calculations.
c. Findings
No findings of significance were identified.
4OA6 Meeting(s)
.1 Exit Meeting
The lead inspector presented the preliminary inspection results to Mr. M. Bezilla and other members of licensee management at the conclusion of onsite inspection activities on September 17, 2004. The lead inspector presented the final inspection results telephonically to Mr. Bezilla and other members of licensee management at the conclusion of the inspection activities on October 25, 2004. The licensee identified proprietary material reviewed during the inspection. The licensee acknowledged that this material had been returned.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Bezilla, Site Vice-President
- B. Allen, Director, Plant Operations
- A. Baker, Operations
- P. Boulder, Design Engineering
- J. Grabnar, Manager, Design Engineering
- G. LeBlanc, Design Engineering
- S. Loehlein, Director, Station Engineering
- K. Ostrowski, Manager, Operations
- M. Murtha, Design Engineering
- V. Patton,Operations
- D. Staudt, Operations
- D. Wuokko, Supervisor, Regulatory Compliance
- G. Wolf, Regulatory Compliance
Nuclear Regulatory Commission
- J. Lara, Chief, Electrical Engineering Branch, Region III
- C. Pederson, Director, Division of Reactor Safety, Region III
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000346/2004009-01 NCV Incomplete Information Provided to NRC in Licensing Submittal (1R05.10)
Discussed
None.