IR 05000346/2013008

IR 05000346-13-008; 02/25/2013; 04/30/2013; Davis-Besse Nuclear Power Station; Routine Triennial Fire Protection Baseline Inspection

ML13130A161
Person / Time
Site:	Davis Besse
Issue date:	05/10/2013
From:	Robert Daley Engineering Branch 3
To:	Lieb R FirstEnergy Nuclear Operating Co
Ronald Langstaff
References
EA-13-102 IR-13-008
Download: ML13130A161 (26)

Text

May 10, 2013

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000346/2013008

Dear Mr. Lieb:

On April 5, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Davis-Besse Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on April 5, 2013, with Mr. B. Boles, Director, Site Operations, and on April 30, 2013, with Mr. J. Hook, Manager, Design Engineering, 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.

Two NRC-identified findings were discovered during this inspection. These findings were determined to involve a violation of NRC requirements. The inspectors have screened these violations and determined that they warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues and Section 12.01(b) of Inspection Manual Chapter 0305, Operating Reactor Assessment Program.

Additionally, a licensee identified-violation is also listed in Section 4OA7 of this report.

If you contest the subject or severity of the Non-Cited-Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at Davis-Besse Nuclear Power Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Davis-Besse Nuclear Power Station. In accordance with 10 CFR 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 System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-346 License No. NFP-3

Enclosure:

Inspection Report 05000346/2013008 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-346 License No: NFP-3 Report No: 05000346/2013008 Licensee: FirstEnergy Nuclear Generation, LLC Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: February 25 - April 30, 2013 Inspectors: R. A. Langstaff, Senior Reactor Inspector, Lead A. K. Dahbur, Senior Reactor Engineer R. A. Winter, Reactor Engineer Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

IR 05000346/2013008; 02/25/2013 - 04/30/2013; Davis-Besse Nuclear Power Station; Routine

Triennial Fire Protection Baseline Inspection.

This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings None

Licensee-Identified Violations

Violations of very low safety significance or Severity Level IV that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees Corrective Action Program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection

The licensee was in transition to National Fire Protection Association (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated by 10 CFR 50.48(c). The NFPA 805 standard establishes a comprehensive set of requirements for Fire Protection Programs at nuclear power plants. The standard incorporates both deterministic and risk-informed, performance-based concepts. The deterministic aspects of the standard are comparable to traditional requirements. However, the transition to a risk-informed, performance-based Fire Protection Program requires an in-depth nuclear safety circuit analysis for equipment identified for nuclear safety functions such as safe shutdown.

Because the conversion and licensing process to NFPA 805 was expected to identify and address a variety of issues that were normally the subject of the triennial fire protection baseline inspection, the U.S. Nuclear Regulatory Commission (NRC) modified the Enforcement Policy for licensees in transition to NFPA 805. As part of the transition to NFPA 805, certain findings not associated with findings of high safety significance that meet the four criteria established by Section A of the NRC's Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48),receive enforcement discretion in accordance with the NRC's Enforcement Policy.

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

• preventing fires from starting;

• rapidly detecting, controlling and extinguishing fires that do occur;

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

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

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

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

(2) provided adequate fire detection and suppression capability;

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

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

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

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

(7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees Problem Identification and Resolution Program.

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

The fire areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas selected constituted three inspection samples and the B.5.b mitigating strategies selected constituted two inspection samples, respectively, as defined in Inspection Procedure 71111.05T.

Fire Area Rooms Description 102, 103, 104, 104A, 106, 106A, 107, 108, 109, 109A, 110, 110A, 111, 112, 114, 115, Various Rooms including Emergency Core A 115CC, 116, 117, Cooling System Pump Room 1-2 117A, 119, 120, 121, 122, 123, 124, 125, 126, 127E, 236, 314, 314CC F 238 Auxiliary Feedwater Pump Room 1-2 Diesel Generator 1-2 Room J 319, 319A, 320A Day Tank 1-2 Room

.2 Protection of Safe Shutdown Capabilities

a. Inspection Scope

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

The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire safe shutdown analysis and procedures.

b. Findings

No findings of significance were identified.

.3 Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments.

The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area.

The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings of significance were identified.

.4 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.

b. Findings

No findings of significance were identified.

.5 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.

b. Findings

No findings of significance were identified.

.6 Alternative Shutdown Capability

a. Inspection Scope

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

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

b. Findings

No findings of significance were identified.

.7 Circuit Analyses

a. Inspection Scope

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

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

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

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

The inspectors verified for cables that are important to SSD, but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either

(1) determined that there is not a credible fire scenario (through fire modeling),

(2) implemented feasible and reliable manual actions to assure SSD capability, or

(3) performed a circuit fault analysis demonstrating no potential impact on SSD capability exists.

b. Findings

(1) Un-Fused Direct Current Ammeter Circuit

Introduction:

The following finding that affects 10 CFR 50.48 was identified by the NRC and was a violation of NRC requirements. This finding has been screened and determined to warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues.

The inspectors identified a violation of 10 CFR 50.48(b) and 10 CFR Part 50, Appendix R, Section III.G.3 for the licensees failure to provide electrical protection for common enclosure associated circuits to ensure that one train of systems and components is free of fire damage during a fire. Specifically, the licensee failed to provide electrical protection (i.e., fuses) for the control room ammeter circuits associated with the batteries and battery chargers to a prevent secondary fire due to thermal and/or arcing affects from damaged ammeter cables outside the fire area.

Description:

The original plant wiring design for the station batteries and battery charger ammeter circuits contained a shunt in the current flow from each direct current station battery or charger. Two Institute of Electrical and Electronics Engineers (IEEE) standard 383 qualified leads were bolted to the shunt bar and connected to the ammeter in the control room. The small difference in voltage between the two taps on the shunt was enough to deflect the ammeter gauge in the control room when current flows from the battery or charger through the shunt. The ammeter wiring attached to the shunt did not have fuses. If one of the ammeter wires shorted to ground at the same time as another direct current (DC) wire from the opposite polarity on the same battery, a ground loop through the un-fused ammeter cable could occur. Thermal and/or arcing effects from the damaged ammeter cable could cause a secondary fire or damage adjacent cables located at some point along the path of the ammeter cable outside the fire area that may be required for safe shutdown thereby resulting in a loss of the associated safe shutdown function/capability.

The licensee entered this issue into their corrective actions program as Condition Report (CR) 2013-02965 Un-fused DC Ammeter Circuits, dated February 28, 2013, and initiated hourly fire watches in fire areas where these cables were routed; Cable Spreading Room (Fire Area DD), Electrical Penetration Room (Fire Area DF), Low Voltage Switchgear Rooms (Fire Areas X and Y), and Heater Bay Room (Fire Area II).

The licensee also completed an investigation summary report and concluded that these ammeters cables were not routed in the same trays with safe shutdown cables in these fire areas. However, the inspectors were still concerned that fire-induced damage of the ammeter cables, due to a fire in either the control room (Fire Area FF) or cable spreading room (Fire Area DD), could cause a secondary fire in the credited safe shutdown area (i.e., Fire Areas X or Y). A secondary fire in either the low voltage switchgear rooms could cause damage to cables or equipment required for safe shutdown thereby resulting in loss of the safe shutdown capability. The Fire Hazard Analysis Report (FHAR) credited Train 1 for the safe shutdown method in the event of a fire in either the control room or cable spreading room. Damaged ammeter cables could cause a secondary fire in a low voltage switchgear room (Fire Area Y) which contained Train 1 safe shutdown cables and components that were required for alternative shutdown capability.

This condition was previously identified at other nuclear power stations as reported by Licensee Event Reports (LERs). The licensee at Davis-Besse Nuclear Power Station concluded that this condition was not reportable because it would not result in loss of any safe shutdown functions that were not already assumed lost by the safe shutdown analysis.

Analysis:

The inspectors determined that the failure to ensure that the alternative shutdown capability and its associated circuits remained free of fire damage during a fire was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.G.3 and was a performance deficiency. Specifically, the licensees failure to provide electrical protection for the station batteries and the battery charger ammeter circuits resulted in not ensuring safe shutdown systems and components would be free of fire damage in the event of a fire. Shorts to ground on the ammeter circuits could have resulted in a secondary fire or damage to safe shutdown cables located outside of the fire area in the event of a fire in the control room or cable spreading room.

The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to provide electrical protection to non-safe shutdown circuits associated with the battery charger ammeters could have resulted in a secondary fire which damaged safe shutdown cables and complicated safe shutdown of the plant in the event of a fire in the control room or cable spreading room.

The licensee completed a quantitative risk assessment evaluation for this issue using the methodology contained in IMC 0609, Appendix F, Fire Protection Significance Determination Process, because the finding was fire protection-related and the licensee was in transition to NFPA 805. The licensees evaluation concluded that the finding was not associated with a finding of high safety significance based on a bounding analysis which showed that the increase in Core Damage Frequency due to the un-fused ammeter circuits issue was 4.96 x 10-5 per year. The inspectors reviewed the evaluation and concluded that it was appropriate.

Cross-cutting aspects are not addressed for findings which warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues.

Enforcement:

Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to 10 CFR Part 50, including specifically the requirements of Sections III.G, III.J, and III.O. Appendix R,Section III.G.3 requires, in part, that 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 where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of Section III.G.2 of Appendix R. Fire Areas Fire Areas DD and FF were fire areas which required alternative or dedicated shutdown capability.

Contrary to the above, as of February 28, 2013, the licensee failed to provide alternative shutdown capability free of fire damage in the event of a fire in Fire Areas DD and FF.

Specifically, the licensee failed to provide electrical protection for battery charger ammeter circuits to prevent a secondary fire and damage to safe shutdown cables or components located outside the fire area (i.e., low voltage switchgear rooms) in the event of a fire in the control room or the cable spreading room.

The licensee is in transition to NFPA 805 and; therefore, the NRC-identified violation was evaluated in accordance with the criteria established by Section A of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for a licensee in NFPA 805 transition. The inspectors determined that for this violation:

(1) the licensee would have identified the violation during the scheduled transition to 10 CFR 50.48(c);

(2) the licensee had established adequate compensatory measures within a reasonable time frame following identification and would correct the violation as a result of completing the NFPA 805 transition;

(3) the violation was not likely to have been previously identified by routine licensee efforts; and

(4) the violation was not willful. The finding also met additional criteria established in Section 12.01.b of Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program. In addition, in order for the NRC to consider granting enforcement discretion the violation must not be associated with a finding of high safety significance (i.e., Red). Therefore, the licensee performed a risk evaluation following the guidelines in IMC 0609, Appendix F, and determined that this issue was not associated with a finding of high safety significance. The inspectors reviewed this evaluation and found it acceptable. In addition, the licensee entered this issue into their Corrective Action Program as CR-2013-02965. As a result, the inspectors concluded that the violation met all four criteria established by Section A and the NRC was exercising enforcement discretion to not cite this violation in accordance with the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues.

.8 Communications

a. Inspection Scope

The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.

The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.

b. Findings

No findings of significance were identified.

.9 Emergency Lighting

a. Inspection Scope

The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the licensees procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available onsite. The inspectors also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available onsite and properly staged.

b. Findings

(1) Failure to Provide Procedure for Cold Shutdown Repair:

Introduction:

The following finding that affects 10 CFR 50.48 was identified by the NRC and is a violation of NRC requirements. This finding has been screened and determined to warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues.

The inspectors identified a finding of very low safety significance and associated violation of 10 CFR Part 50, Appendix R, Section III.L.5 for the licensees failure to have a repair procedure in effect for closing a valve in the event of a fire in two fire areas.

Specifically, there was a potential for the valve actuator to be damaged in the event of a fire. The safe shutdown procedure for a fire in the two fire areas did not provide instruction on how to close the valve if valve actuator damage had occurred.

Description:

Note 37 for Fire Areas DD (cable spreading room) and FF (control room)within Section 4.0 of the Fire Hazard Analysis Report identified that Decay Heat Pump 1 Borated Water Storage Tank Suction Valve DH 2733 was normally open and required closure prior to cool down using decay heat removal. The note stated that the valve actuator may be damaged due to the torque or limit switches being potentially bypassed due to a hot short. The note indicated that if valve actuator damage occurred, procedures instructed plant personnel to remove the actuator and mechanically close the valve.

Procedure DB-OP-02519, Serious Control Room Fire, Revision 17, provided operators guidance for addressing a severe fire in Fire Areas DD and FF, including guidance for transitioning to cool down using decay heat removal. Step 4.i.5 of Procedure DB-OP-02519 directed operators to verify that Valve DH 2733 was closed. However, Procedure DB-OP-02519 did not provide instructions indicating that the valve actuator could be damaged and that removal of the actuator and mechanical closure of the valve may be required. Moreover, it was not clear to the inspectors how mechanical closure of the valve would be accomplished once the actuator had been removed. Valve closure would have required driving the exposed valve stem inward to close the valve.

Calculation C-ME-049.02-119 MOV Thrust/Torque Calculation for DH 2733, determined that 4,218 pounds of thrust was required to overcome stem packing friction alone. Based on the calculated thrust value and the configuration of the valve with the actuator removed, the inspectors determined that mechanically closing the valve was not a simple task. The inspectors concluded that the lack of instructions for closing the valve when there is damage to the actuator could result in operational complications and delay reaching cold shutdown in the event of a fire in Fire Areas DD and FF.

The licensee entered this issue into their Corrective Action Program as CR-2013-04512 Post Fire Safe-Shutdown Repair Does not have Detailed Procedure, dated March 26, 2013, to determine the proper level of detail and repair instructions needed for their safe shutdown procedures.

Analysis:

The inspectors determined that the failure to have a repair procedure in effect for closing a valve in the event of a fire in two fire areas was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.L.5 and was a performance deficiency.

Specifically, there was a potential for the valve actuator to be damaged in the event of a fire. The safe shutdown procedure for a fire in the two fire areas did not provide instruction on how to close the valve if valve actuator damage had occurred.

The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the lack of instructions for closing the valve when there is damage to the actuator could result in operational complications and delay reaching cold shutdown in the event of a fire in two fire areas.

In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase I - Initial Characterization of Findings, Table 3, the inspectors determined that the finding affected the ability to reach or maintain safe shutdown conditions in case of a fire. Therefore, screening under IMC 0609, Appendix F was required. The inspectors determined that the finding affected the post-fire safe shutdown finding category and only affected the ability to reach and maintain cold shutdown conditions. Therefore, the inspectors determined that the finding screened as having very low safety significance (Green) in Task 1.3.1 of IMC 0609, Appendix F.

Cross-cutting aspects are not addressed for findings, which warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues.

Enforcement:

Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix R, Section III.G.Section III.L of 10 CFR Part 50, Appendix R, specifies implementation of alternative or dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.5 of 10 CFR Part 50, Appendix R, states, in part, that the fire damage to equipment and systems shall 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 /> and that procedures shall be in effect to implement such repairs. Fire Areas DD and FF were fire areas which required alternative or dedicated shutdown capability.

Contrary to the above, as of March 26, 2013, the licensee did not have a repair procedure in effect to close Valve DH 2733 in the event of a fire in alternative shutdown Fire Areas DD and FF. Specifically, due to the potential for the valve actuator torque and limit switches being bypassed due to a hot short during a fire in either Fire Area DD or Fire Area FF, the valve actuator could be damaged. In the event of valve actuator damage, the valve could only be closed by driving the valve stem inward with the valve actuator removed. Abnormal Procedure DB-OP-02519 did not provide instructions how to close Valve DH 2733 in the event that the valve actuator had been damaged.

The licensee is in transition to NFPA 805 and; therefore, the NRC-identified violation was evaluated in accordance with the criteria established by Section A of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for a licensee in NFPA 805 transition. The inspectors determined that for this violation:

(1) the licensee would have identified the violation during the scheduled transition to 10 CFR 50.48(c);

(2) the licensee had established adequate compensatory measures within a reasonable time frame following identification and would correct the violation as a result of completing the NFPA 805 transition;

(3) the violation was not likely to have been previously identified by routine licensee efforts; and

(4) the violation was not willful. The finding also met additional criteria established in Section 12.01.b of Inspection Manual Chapter (IMC) 0305. In addition, in order for the NRC to consider granting enforcement discretion the violation must not be associated with a finding of high safety significance (i.e., Red). Therefore, the inspectors determined that this issue was associated with a finding of very low safety significance (Green) per Task 1.3.1 of IMC 0609, Appendix F. In addition, the licensee entered this issue into their Corrective Action Program as, CR-2013-04512. As a result, the inspectors concluded that the violation met all four criteria established by Section A and the NRC was exercising enforcement discretion to not cite this violation in accordance with the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues.

.11 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions or capabilities). The inspectors also conducted a review of 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.

.12 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire safe shutdown analysis and procedures.

b. Findings

No findings of significance were identified.

.13 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

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

b. Findings

No findings of significance were identified.

.14 B.5.b Inspection Activities

a. Inspection Scope

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

• Procedures were being maintained and adequate;

• Equipment was properly staged, maintained, and tested;

• Station personnel were knowledgeable and could implement the procedures; and

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

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

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

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

Section 3.3.3 Manual Operation of Turbine-Driven (or Diesel-Driven) Auxiliary Feedwater Pump (A.4-3)3.3.6 Containment Flooding with Portable Pump (A.4-6)

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

a. Inspection Scope

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

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On April 5, 2013, the inspectors presented the preliminary inspection results to Mr. B. Boles, Director, Site Operations, and other members of the licensee staff.

On April 30, 2013, the inspectors presented the final inspection results to Mr. J. Hook, Manager, Design Engineering, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

• Section 6.4.2.a of Procedure DB-FP-00005, Fire Brigade, Revision 17, permitted table-top exercises to be credited for fire drills. License Condition 2.C(4) requires the licensee to implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Safety Analysis Report (USAR). Section 9.5.1 of the USAR states that the FHAR is incorporated in the USAR by reference. In Appendix D, Compliance Matrix to Appendix A, of the FHAR, the licensee indicated that they complied with Position B5.b of NRC-Guidelines of Appendix A to Branch Technical Position 9.5-1 with respect to fire drills. Position B5.(b) stated fire brigades must operate as a team, drills provide fire brigades the opportunity to test itself in the major areas of the plant, drills should include the simulated use of equipment, and drills permit supervising personnel to evaluate the effectiveness of communications. The use of table-top exercises for drills did not allow for training as a team, testing themselves in major areas of the plant, simulating use of equipment in each area, and evaluating the effectiveness of communications. The inspectors determined that this issue was licensee identified because, at the time of the inspection, the licensee was in the process of reviewing the conduct of fire drills as documented by CR-2013-03331, Review of NRC Inspection Report issued for Kewaunee Power Station related to Fire Brigade Drills, dated March 7, 2013. The inspectors determined that the issue was of very low safety significance using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, because the licensee took only minimal credit for table-top exercises.

Specifically, in the prior year, 2012, the licensee took credit for only one table-top exercise involving three individuals for a drill. Each of the shift crews had participated in drills in the plant each quarter during 2012. The licensee had entered this issue into their Corrective Action Program as CR-2013-04610, NRCFP2013: NRC Observations on Fire Drills and Pre-Fire Plans and planned to revise their procedure to be consistent with their licensing basis.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Lieb, Site Vice President

D. Blakely, Supervisor, Design Engineering

B. Boles, Director, Site Operations

K. Byrd, Director, Site Engineering

G. Halnon, Director, Regulatory Affairs

J. Hook, Manager, Design Engineering

P. McCloskey, Manager, Regulatory Compliance

M. Murtha, Fire Protection Engineer, Design Engineering

V. Patton, Fire Marshal, Operations

J. Ross, Fire Protection Engineer, Design Engineering

V. Wadsworth, Sr. Engineering Specialist, Regulatory Compliance

G. Wolf, Supervisor, Regulatory Compliance

Nuclear Regulatory Commission

D. Kimble, Senior Resident Inspector

LIST OF ITEMS

Opened, Closed, and Discussed

None.

Attachment