IR 05000348/2008006
| ML081350629 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/13/2008 |
| From: | Sandra Walker NRC/RGN-II/DRS/EB2 |
| To: | Jerrica Johnson Southern Nuclear Operating Co |
| References | |
| IR-08-006 | |
| Download: ML081350629 (31) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
May 13, 2008
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000348/2008006 AND 05000364/2008006
Dear Mr. Johnson:
On April 4, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection findings, which were discussed on that date with Cheri Collins 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.
This report documents three NRC-identified findings of very low safety significance (Green)
which were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest any 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, Region II; the Director, Office of Enforcement, United States Nuclear regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Crystal River Unit 3 site.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the
SNC 2 Publicly Available Records 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/
Shakur A. Walker, Acting Chief, Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8
Enclosure:
Inspection Report 05000348/2008006 and 05000364/2008006 w/Attachment; Supplemental Information
REGION II==
Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Report Nos.: 05000348/2008006 and 05000364/2008006 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Joseph M. Farley Nuclear Plant Location: 7388 North State Highway 95 Columbia, Alabama 36319 Dates: March 10 - 14, 2008 (Week 1)
March 31 - April 4, 2008 (Week 2)
Inspectors: N. Merriweather, Senior Reactor Inspector (Lead Inspector)
R. Fanner, Reactor Inspector D. Merzke, Senior Reactor Inspector G. Wiseman, Senior Reactor Inspector Approved by: Shakur Walker, Acting Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000348/2008-006, 05000364/2008-006; 03/10 - 14/2008 and 03/31 - 4/4/2008;
Joseph M. Farley Nuclear Plant, Units 1 & 2; Triennial Fire Protection Inspection.
This report covers an announced two-week triennial fire protection inspection by a team of four regional inspectors. Three Green non-cited violations (NCVs) were 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 NRC's 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-Revealing Findings
Cornerstone: Mitigating Systems
- Green: The team identified a non-cited violation of Technical Specification 5.4.1,
Procedures, in that Units 1 and 2 post-fire safe shutdown abnormal operating procedures AOP 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room, and AOP 28.2, Fire in the Control Room, credited diagnostic instrumentation that would have been potentially unreliable due to fire damage from a postulated fire in the control room or cable spreading room. The finding was entered into the licensees corrective action program as Condition Report 2005103665.
This issue is a performance deficiency because the safe shutdown procedure relies on an indication which was not protected from fire damage. The finding is more than minor because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and it affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors assessed the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process. The finding was assigned a low degradation rating because it was determined to be a minor procedural deficiency that is compensated by operator experience or familiarity. Because the finding was assigned a low degradation rating, the team determined that this finding was of very low safety significance (Green). (Section 1R05.06)
- Green: The team identified a non-cited violation of Farley Unit 2 Operating License Condition 2.C.(6), for the licensees failure to fully implement the approved fire protection program, in that emergency lighting units (ELUs) were not installed in all areas where local operator manual actions were required to support post-fire safe shutdown. Specifically, the team determined that there were no ELUs installed to illuminate the front panels of the Reactor Coolant Pump (RCP) switchgear, located in the Train A switchgear room, where post-fire safe shutdown local operator manual actions were required to trip the RCP 4160 Volt alternating current breakers. The finding was entered into the licensees corrective action program under Condition Reports 2008103335, 336, and 337.
The finding is greater than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e.,
fire) and it affects the cornerstone attribute of ensuring reliability and capability of systems that respond to initiating events. Specifically, the finding adversely affected the ability to perform local operator manual actions required to achieve and maintain safe shutdown conditions following a fire in the cable spreading room. The inspectors assessed the finding using IMC 0609, Appendix F, Fire Protection Significance Determination Process. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights, which operators are directed to carry with them by procedure while performing local actions. (Section 1R05.09)
- Green: The team identified a non-cited violation of Farley Unit 2 Operating License Condition 2.C.(6), for the licensees failure to fully implement test control requirements incorporated in approved plant procedures associated with the periodic testing of emergency lighting units. As a consequence, condition reports (CRs) were not initiated as required, when battery conductance measurements did not meet acceptance criteria. The finding was entered into the licensees corrective action program as Condition Report 2008103290.
This issue is a performance deficiency because the licensee did not properly document ELU test failures on CRs for trending and evaluation in accordance with the surveillance test procedures. The finding involved systems or components (i.e.,
emergency lights) required for post-fire safe shutdown of the reactor. The finding is greater than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the cornerstone attribute of ensuring reliability and capability of systems that respond to initiating events. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights, which operators are directed to carry with them by procedure while performing local actions. (Section 1R05.09)
Licensee-Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R05 Fire Protection
This report presents the results of a triennial fire protection inspection for a plant in transition to National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. By letter dated February 14, 2008, the licensee informed the NRC of their intent to transition the fire protection program at the Joseph M. Farley Nuclear Plant (FNP) to NFPA 805 in accordance with 10 CFR 50.48(c). This inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05TTP, Fire Protection-NFPA 805 Transition Period (Triennial). The objective of the inspection was to review the FNP fire protection program (FPP) implementation based on a review of a selected sample of risk-significant fire areas. The team selected three fire areas for detailed review to examine the licensees implementation of the FPP. The three fire areas chosen were selected based on risk insights from the licensees Individual Plant Examination for External Events (IPEEE), information contained in FPP documents, results of prior NRC triennial fire protection inspections, and in-plant tours by the team.
Section 71111.05-05 of the IP specifies a minimum sample size of three fire areas.
Detailed inspection of these three fire areas fulfills the procedure completion criteria.
The areas chosen were:
Elevation 139 foot South West (SW) Quadrant
- FA 1-88, FZs 88A thru F, Unit 1 Turbine Building North Elevation 155 foot The team evaluated the licensees FPP against applicable requirements, including Operating License Conditions 2.C.(4) (for Unit 1) and 2.C.(6) (for Unit 2); Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Appendix R; 10 CFR 50.48; commitments to Appendix A of Branch Technical Position Auxiliary and Power Conversion Systems Branch 9.5-1; NFPA Codes of record; the fire protection program document and the fire hazards analysis described in the FNP Updated Final Safety Analysis Report (UFSAR); related NRC safety evaluation reports (SERs); and plant Technical Specifications. The team evaluated each selected FA and/or FZ against these requirements. The specific documents reviewed by the team are listed in the
.
.01 Post-Fire Safe Shutdown From Main Control Room (Normal Shutdown)
a. Inspection Scope
Methodology The team reviewed applicable portions of the Farley Units 1 and 2 post-fire safe shutdown analysis (SSA), 10 CFR Part 50 Appendix R Fire Protection Program for Operating Nuclear Power Plants, Sec. III.G, III.J, and III.O (Design Drawing A359071),abnormal operating procedures (AOPs), piping and instrumentation drawings (P&IDs),applicable electrical one-line drawings, the UFSAR, and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from the main control room (MCR) for postulated fires in FA 2-41, FZ-41-A; and FA 1-88, FZs 88A through F. This review also included verification that shutdown from the MCR could be performed both with and without the availability of offsite power. Plant walkdowns were performed to verify that the plant configuration was consistent with that described in the fire hazards analysis (FHA) and SSA. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation, and support system functions. The team reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage.
Operational Implementation The team reviewed the adequacy of procedures utilized for post-fire safe shutdown (SSD) and performed a walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.
The team reviewed and walked down applicable sections of fire response procedure AOP 29.1, Plant Stabilization in Hot Standby and Cooldown Without A Train AC or DC Power, for FA 2-41, FZ 41-A.
The team reviewed local operator manual actions to ensure that the actions could be implemented in accordance with plant procedures in the times necessary to support the SSD method for the applicable FA and to verify that those actions met the criteria in 2 of NRC IP 71111.05TTP. The team reviewed CR 2006108310, Southern Nuclear Operating Companys Position for Operator Manual Actions Related to 10 CFR Part 50 Appendix R, as Described in NRC Regulatory Information Summary (RIS) 2006-010, to verify that the licensee had identified operator manual actions for post-fire SSD in 10 CFR 50, Appendix R Section III.G.2 designated areas and had plans in place to keep CR 2006108310 open to assess and track resolution of the manual action issue as part of the plant-wide risk evaluation for transition to NFPA 805.
b. Findings
No findings of significance were identified.
.02 Protection of Safe Shutdown Capabilities
a. Inspection Scope
For the selected FA/FZs, the team evaluated the potential for fires, the combustible fire load characteristics, and the potential exposure fire severity. The team reviewed the FNP UFSAR Appendix 9B, FHA, procedure FNP-0-SOP-0.4, Fire Protection Program Administration; and, selected plant administrative procedures which established and implemented controls and practices to prevent fires and to control the storage of permanent and transient combustible materials and ignition sources. This review was conducted to determine if the licensees commitments, as established in the FPP licensing basis documents, were satisfied and whether the licensee was taking reasonable precautions to prevent fires from starting. The team also reviewed selected licensee fire incident reports, maintenance procedures, housekeeping inspection reports, and general employee training covering control of ignition sources and transient combustibles. These reviews were accomplished to ensure that the licensee had properly evaluated in-situ combustible fire loads, controlled hot-work activities, and limited transient fire hazards in a manner consistent with the plant administrative and FPP procedures. Additionally, the team walked down the selected plant FA/FZs to observe whether programmatic procedures for limiting fire hazards, waste collection, housekeeping practices, and cleanliness conditions were being implemented consistent with the updated UFSAR, administrative procedures, and other FPP procedures. The specific documents reviewed are listed in the Attachment.
Through a combination of design information review and in-plant inspection, the team assessed whether the licensees SSA properly evaluated SSD capability as compared to the separation and design requirements of Appendix R,Section III.G. The team performed reviews aimed at determining whether at least one train of SSD equipment was protected from fire damage. For example, in FA 2-41, five cable raceways (cable trays and conduits) located directly above 600V Load Center 2A and its associated transformer (raceways AE27, AEF33, AHL464, AHL462, and BG258) could be subject to damage due to a fire which could start at the load center or the transformer. Therefore, the team reviewed the function of all the cables routed in those raceways in terms of their importance to SSD. In addition, the routing of cables for selected equipment utilized in the shutdown procedures for FA 2-40 was reviewed.
b. Findings
No findings of significance were identified.
.03 Passive Fire Protection
a. Inspection Scope
For the selected FA/FZs, the team evaluated the adequacy of fire barrier walls, ceilings, floors, mechanical and electrical penetration seals, fire doors, fire dampers, and protected structural steel. The team reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the seal material was of the appropriate fire rating and that the as-built configurations met the engineering design, standard industry practices and were either properly evaluated or qualified by appropriate fire endurance tests which established the ratings of fire barriers. The team also reviewed licensee evaluations of non-standard fire barrier penetration seals for the selected FA/FZs. In addition, the team reviewed license documentation, such as NRC SERs, and exemptions from NRC regulations to verify that passive fire protection features met license commitments.
The team walked down accessible portions of the selected FA/FZs to observe material condition and the adequacy of design of fire area boundaries to ensure they were appropriate for the fire hazards in the area. Also, engineering change documentation and relevant installation, and test qualification records related to installed Meggitt Safety Systems Incorporated (MSSI) Mineral Insulated (MI) fire-rated control cables in lieu of Kaowool fire barrier wraps for protection of certain SSD diesel generator control circuits in FAs 2-41 and 2-42 were reviewed. This was accomplished to verify that the selected MI cable raceways met their design and licensing basis. The documents included in the reviews of the selected fire protection features are listed in the Attachment.
b. Findings
No findings of significance were identified.
.04 Active Fire Protection
a. Inspection Scope
The team reviewed the fire protection water supply system, operational valve lineups, cable routing information, and system availability associated with the electric motor-driven fire pump, the diesel engine-driven fire pumps, and, fire main piping system.
Using operating and valve alignment procedures as well as engineering drawings, the team examined selected fire pumps and accessible portions of the fire main piping system to evaluate material condition, consistency of as-built configurations with engineering drawings, and to verify correct system valve lineups. The fire protection water delivery and supply components that were shared between the units were reviewed to assess if they could be damaged or inhibited by fire-induced failures of electrical power supplies or control circuits. In addition, the team reviewed periodic surveillance procedures for the fire pumps and fire main loop to assess whether the test program was sufficient to validate proper operation of the fire protection water supply system in accordance with its design requirements. The fire protection components inspected are listed in the Attachment.
The appropriateness of detection and suppression methods for the category of fire hazards in the selected areas was evaluated. With respect to FA 2-40, the team compared detector layout drawings, ceiling beam location drawings, ceiling beam schedule drawings and actual field locations of detectors against the NFPA 72E code of record (1975 edition) for detector spacing and placement requirements. The direct application carbon dioxide (CO2) system within the FA 2-41 switchgear and load center cabinets was evaluated. The closed head cable tray water spray systems and manually operated total flooding CO2 system in FA 2-40 were inspected. Additionally, the inspectors reviewed the surveillance test procedures for the detection and alarm systems to determine compliance with UFSAR Section 9B, Attachment C, Table 9B.C-1.
Fire hose and standpipe systems were evaluated from source to discharge device to verify that adequate pressure was available at hose nozzles where 100 feet of fire hose was being used. During plant walkdowns, the team observed placement of the fire hoses and fire extinguishers to verify they were not blocked and were consistent with the FZ data sheets and FPP documents. The team also reviewed the fire brigade staging and dress-out areas to assess the operational readiness of fire fighting and smoke control equipment. The fire brigade personal protective equipment, self-contained breathing apparatuses (SCBAs) and SCBA cylinder refill capability were reviewed for adequacy and functionality. In addition, the team reviewed operator and fire brigade staffing, fire emergency brigade response reports, offsite fire department communications and staging procedures, FZ data sheets, fire brigade qualification training, and the fire brigade drill program procedures. Seven fire brigade response-to-drill scenarios and associated brigade drill evaluations/critiques that transpired over the last 3 years were reviewed. The overall criterion applied to this portion of the inspection was that the fixed manual fire brigade suppression had the capacity and capability to suppress credible fires in the selected FA/FZs. The documents included in the reviews are listed in the Attachment.
b. Findings
No findings of significance were identified.
.05 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews (heating, ventilation, and air conditioning (HVAC) system drawings, configuration drawings of electrical raceways and safe shutdown components, and building drain system drawings) and in-plant walk downs to verify that redundant trains of systems required for hot shutdown were not subject to damage from fire suppression activities or from the rupture, or inadvertent operation of, fire suppression systems. The team considered the effects of water, drainage, heat, hot gasses, and smoke that could potentially damage all redundant trains or inhibit access to alternate shutdown equipment or performance of alternate safe shutdown operator actions. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
.06 Post-Fire SSD From Outside the Main Control Room (Alternative Shutdown)
a. Inspection Scope
Methodology The team reviewed applicable portions of the Farley Units 1 and 2 alternative shutdown analysis, 10 CFR Part 50 Appendix R Fire Protection Program for Operating Nuclear Power Plants Alternative Shutdown Capability (Design Drawing A-350970, Rev. 13), the UFSAR, the AOPs, P&IDs, electrical drawings, and other supporting documents for postulated fires in FA 2-40, FZ 40-A. The reviews focused on ensuring that the required functions for post-fire SSD and the corresponding equipment necessary to perform those functions were included in the procedures. The review included assessing whether hot and cold shutdown from outside the MCR could be implemented, and that transfer of control from the MCR to the dedicated shutdown control stations could be accomplished.
This review also included verification that shutdown from outside the MCR could be performed both with and without the availability of offsite power.
Plant walkdowns were performed to verify that the plant configuration was consistent with that described in the SSA. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation, and support system functions. The team reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The team also followed up on the issues identified in Unresolved Item (URI) 05000348, 364/2005006-001, Fire Procedure Did Not Identify the Appropriate Diagnostic Instruments as it related to procedures AOP 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room, and AOP 28.2, Fire in the Control Room.
Operational Implementation The team reviewed the training lesson plans for licensed and non-licensed operators to verify that the training reinforced the shutdown methodology in the SSA and AOPs for the selected FA. The team also reviewed shift turnover logs and shift manning to verify that personnel required for SSD using the alternative shutdown systems and procedures were available on-site, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire SSD and performed a walk-through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.
Time critical actions reviewed included: electrical power distribution alignment, establishing control at the dedicated shutdown control stations, establishing reactor coolant makeup, and establishing decay heat removal. The team reviewed and walked down applicable sections of AOP 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room.
The team also reviewed the periodic test procedures and test records of the alternative shutdown transfer capability, and instrumentation and control functions, to ensure the tests were adequate to verify the functionality of the alternative shutdown capability.
Electrical schematics were reviewed to verify that circuits for SSD equipment, which could be damaged due to fire, were isolated by disconnect switches and by swapping power supplies for selected Motor Control Centers (MCCs). In addition, the team reviewed wiring diagrams for instrumentation located on the dedicated shutdown control stations to verify that necessary process monitoring was available as required by 10 CFR 50, Appendix R, Section III.L.
b. Findings
Introduction:
The team identified a Green non-cited violation of Technical Specification 5.4.1, Procedures, for Units 1 and 2, in that post-fire safe shutdown procedures AOP 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room, and AOP 28.2, Fire in the Control Room, were inconsistent with the SSA in that they credited diagnostic instrumentation that would have been potentially unreliable due to fire damage from a postulated fire in the cable spreading room or MCR. The finding was entered into the licensees corrective action program as CR 2005103665.
Description:
The following discussion centers on Unit 2 procedures for a fire in the cable spreading room or MCR, however, it is also applicable to Unit 1. For a fire in the Unit 2 cable spreading room, procedure AOP 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room, would be utilized to safely shutdown the plant from the dedicated Hot Shutdown Panels (HSPs). The procedure steps are also applicable to AOP 28.2, Fire in the Control Room. The procedures direct operators to trip the RCPs in the event seal injection and component cooling water (CCW) flow to the RCP thermal barrier heat exchangers are lost, or if charging flow is lost with, RCP seal leakoff less than 2.5 gallons per minute. Additionally, Step 7.1 of AOP 28.1 or step 8.1 of AOP 28.2, states to check any selected instrument air compressor is running.
The licensee stated, and the team verified, that if main control board (MCB) indication is lost for CCW flow, local indicator Q2P17FISH3045 in the 121 ft boron thermal regeneration chiller room is available to determine if CCW flow is available to the thermal barrier heat exchangers. Loss of the operating train of charging could be determined by indication of charging flow at the HSP using flow indicator FI-122B, which is electrically isolated, and thus, free from fire damage due to a fire in the cable spreading room or control room. The licensee further states, that with a loss of charging flow, as indicated at the HSP, seal cooling, and thus, seal leakoff, is considered lost. If indication for an operable instrument air compressor is not available at the MCB, an operator can locally determine if an air compressor is running. Additionally, both AOPs state that if it cannot be determined if a Unit 2 air compressor can be placed in service and the 1C air compressor is available, then align the 1C air compressor to Unit 2. Finally, the licensee states that if MCB indication for RCP seal injection flow is lost, then local indication (Q2E21FI130B, Q2E21FI127B, and Q2E21FI124B), located in the 121 ft piping penetration room, is available. The team determined that these local flow indicators are remote indicators which receive a signal from the individual flow transmitters for each RCP seal injection line. The team determined that cables for these local flow indicators pass through the cable spreading room and the main control room, are subject to fire damage, and therefore, the flow indicators would be considered unreliable. Loss of seal injection flow and CCW flow to the thermal barrier heat exchangers requires that operators trip the RCPs and isolate RCP seals and thermal barriers as described in the AOP, in order to prevent damage to the RCP seals, resulting in a potential loss of coolant accident. If CCW flow is available, as determined by the local flow indicator, then isolation of the RCP seals is not required. If CCW flow is lost, operators would check seal injection flow using potentially unreliable indicators. If the seal injection flow indicators fail low, then operators would determine that seal injection is lost, and perform the seal isolation procedure. If the flow indicator fails high, then operators would have to recognize that the indicators are unreliable, and conservatively assume that seal injection flow is lost, requiring isolation of the seals.
Analysis:
This issue is a performance deficiency because the safe shutdown procedure relies on an indication which is not protected from fire damage. The finding is more than minor because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and it affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors assessed the finding using IMC 0609, Appendix F, Fire Protection Significance Determination Process. The finding was assigned a low degradation rating because it was determined to be a minor procedural deficiency that is compensated by operator experience or familiarity.
Because the finding was assigned a low degradation rating, the team determined that this finding was of very low safety significance (Green).
Enforcement:
Technical Specification 5.4.1 states that written procedures shall be established, implemented, and maintained covering the activities in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Regulatory Guide 1.33, Appendix A, Section 6.v, requires procedures for combating emergencies such as plant fires. AOP 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room, and AOP 28.2, Fire in the Control Room, provided instructions necessary to achieve and maintain post-fire SSD of Farley Units 1 and 2 in the event SSD could not be performed from the MCR due to a fire in the cable spreading room or control room.
Contrary to the above, on April 4, 2008, AOP 28.1 and AOP 28.2 were identified to be inconsistent with the SSA for the fire areas, in that, they both credited the use of RCP seal injection flow indicators that would potentially be unreliable for fires in the MCR and cable spreading room. This problem has existed in the procedures for many years.
Because this finding is of very low safety significance and was entered into the licensees corrective action program (CR 2005103665), this finding is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. This finding is identified as NCV 05000348, 364/2008006-01, Fire Procedure Credits Unreliable Indication.
.07 Circuit Analyses
a. Inspection Scope
This segment is suspended for plants in transition because a more detailed review of cable routing and circuit analysis will be conducted as part of the fire protection program transition to NFPA 805. However, the team did review the cable routing for a select sample of SSD and fire protection equipment to assess the adequacy of the licensees fire response procedures in the selected fire areas. The cable routing information was reviewed to determine if the SSD equipment was routed outside the fire area of concern or protected from fire damage. The components reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
.08 Communications
a. Inspection Scope
The team reviewed the plant communications systems that would be relied upon to support fire event notification and fire brigade fire fighting activities. The team also reviewed selected fire brigade drill evaluation/critique reports to assess proper operation and effectiveness of the fire brigade command post portable radio communications during fire drills and identify any history of operational or performance problems with radio communications during fire drills. In addition, the team verified the radio battery usage ratings for the fire brigade radios stored and maintained on charging stations.
b. Findings
No findings of significance were identified.
.09 Emergency Lighting
a. Inspection Scope
The team reviewed the adequacy of the emergency lighting used to support plant personnel in the performance of alternative safe shutdown functions outlined in the fire response procedures. The team reviewed documentation to determine if adequate emergency lighting equipment would be available consistent with the licensing basis.
The team also reviewed emergency lighting maintenance and test records to ensure lighting was adequately sized, maintained, and tested consistent with license requirements.
In addition, the team observed whether emergency exit lighting was provided for personnel evacuation pathways to the outside exits as identified in the NFPA 101, Life Safety Code, and the Occupational Safety and Health Administration (OSHA) Part 1910, Occupational Safety and Health Standards. This review also included examination of whether backup ELUs were provided for the primary and secondary fire emergency equipment storage locker locations and dress-out areas in support of fire brigade operations should power fail during a fire emergency.
b. Findings
1) Areas Where Operator Manual Actions (OMAs) Are Performed Did Not Have Emergency Lighting Units (ELUs) Installed
Introduction:
The team identified a Green non-cited violation of Farley Unit 2 Operating License Condition 2.C.(6), for the licensees failure to fully implement the approved fire protection program, in that ELUs were not installed in all areas where local operator manual actions were required to support post-fire safe shutdown. Specifically, the team determined that there were no ELUs installed to illuminate the front panels of the RCP switchgear, located in the Train A switchgear room, where post-fire safe shutdown local operator manual actions were required to trip the RCP 4160 Volt alternating current breakers.
Description:
The team reviewed and walked down applicable sections of fire response procedure FNP-2-AOP- 28.1, Fire or Inadvertent Fire Protection System Actuation in the Cable Spreading Room, to review the procedural guidance and assess the local operator manual actions in support of safe shutdown operation in the event of a fire in the Unit-2 cable spreading room. FNP-2-AOP- 28.1, Step 18, states to locally trip all RCPs. In order to perform this step, an operator is required to open the breaker door, verify the breaker is open by observing the mechanical indicator, open the DC control power breaker, and pull the fuse block, invert it, and replace the fuse block. During the walkdown, the team noted that there was no ELU installed to illuminate the area around the breakers for RCP 2B and 2C. A subsequent blackout test confirmed there was insufficient light available for an operator to safely perform this step. Additionally, the lighting for RCP 2A was installed so far away that the upper half of the breaker containing the fuse block was not illuminated.
The team determined that this action would not be feasible if normal lighting were lost and no ELUs were available. The team noted that the licensees FPP (Section 3.K of UFSAR Appendix 9B) stated that for all areas except the Main Control Room, emergency lighting units with an 8-hour battery pack are provided in all areas needed for the operator to perform safe shutdown functions. The team determined that not having ELUs installed to support the operator manual actions required by Procedure FNP-2-AOP- 28.1 did not comply with the FPP. The licensee initiated three CRs 2008103335, 336, and 337 to address the ELU issues.
Analysis:
The finding is greater than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the cornerstone attribute of ensuring reliability and capability of systems that respond to initiating events. Specifically, the finding adversely affected the ability to perform local operator manual actions required to achieve and maintain SSD conditions following a fire in the cable spreading room. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights, which operators are directed to carry with them by procedure while performing local actions.
Enforcement:
FNP Unit 2 Operating License Condition 2.C.(6) requires the licensee to implement and maintain in effect all provisions of the approved FPP, as described in the UFSAR. The approved FPP is documented in UFSAR Appendix 9B, Fire Protection Program. UFSAR Appendix 9B, Section 3.K, Requirements for Emergency Lighting, states that for all areas except the Main Control Room, emergency lighting units with an 8-hour battery pack are provided in all areas needed for the operator to perform safe shutdown functions.
Contrary to the above, on April 4, 2008, an ELU was discovered not installed in an area where post-fire SSD components were being operated. Because this finding is of very low safety significance and was entered into the licensees corrective action program (CRs 2008103335, 336, 337), this finding is being treated as an NCV, consistent with Section VI.A.1 of the NRCs Enforcement Policy. This finding is identified as NCV 05000364/2008006-02, Areas Where OMAs Are Performed Did Not Have ELUs Installed.
2) ELU Test Failures Were Not Documented In CRs As Required by Procedure
Introduction:
The team identified a Green NCV of FNP Unit 2 Operating License Condition 2.C.(6), for the licensees failure to fully implement test control requirements incorporated in approved plant procedures associated with the periodic testing of ELUs.
As a consequence, condition reports were not initiated as required, when battery conductance measurements did not meet acceptance criteria.
Description:
The team reviewed the surveillance test records on ELUs for the past three years. The test control requirements and acceptance criteria were specified in test procedure FNP-2-FSP-311, Semi-annual Maintenance and Testing of Emergency Lighting, Version 8.0 dated 9/7/2006. From a review of the records, it was determined that several deficiencies occurred where procedural guidance was not followed. The procedure stated in step 7.6, that , if a light fixture does not meet the acceptance criteria or is found defective, then investigate and repair the fixture and generate a CR. The team found multiple examples where a CR was required to be generated but had not been. The specific instances were:
ELU 2034, tested 11/2/06, low conductance test reading, below 400 mhos acceptance criteria (215 mhos), no CR written, FSP data sheet states battery replaced.
ELU 2193, tested 11/2/06, illumination test unsatisfactory, no CR or record of battery replacement; however, records indicate ELU tested satisfactory on 6/1/07 (WO2060198401).
ELU 2163, tested 11/2/06, low conductance test reading, below 400 mhos acceptance criteria (320 mhos), no CR written, FSP data sheet states battery replaced.
ELU 2186, tested 11/2/06, low conductance test reading, below 400 mhos acceptance criteria (250 mhos), no CR written, FSP data sheet states battery replaced.
ELU 2191, tested 11/2/06, low conductance test reading, below 400 mhos acceptance criteria (180 mhos), no CR written, no documentation of battery replacement.
This issue was entered into the licensees corrective action program as CR 2008103290.
Analysis:
This issue is a performance deficiency because the licensee did not properly document ELU test failures on CRs for trending and evaluation in accordance with the periodic ELU test procedures. The finding involved systems or components (i.e.,
emergency lights) required for post-fire safe shutdown of the reactor. The finding is greater than minor because it is associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e., fire) and it affects the cornerstone attribute of ensuring reliability and capability of systems that respond to initiating events. The team determined that this finding was of very low safety significance (Green) because the operators had a high likelihood of completing the task using flashlights, which operators are directed to carry with them by procedure while performing local actions.
Enforcement:
FNP Unit 2 Operating License Condition 2.C.(6) requires the licensee to implement and maintain in effect all provisions of the approved FPP, as described in the UFSAR. The approved FPP is documented in UFSAR Appendix 9B, Fire Protection Program. UFSAR Appendix 9B, Section 9B.2.5.2, Inspection, Test, and Test Control, states that plant procedures incorporate the inspection, test and test control requirements. Plant procedure FNP-2-FSP-311, Semi-annual Maintenance and Testing of Emergency Lighting, Version 8.0 dated September 7, 2006, provides instructions for maintenance and testing of emergency light fixtures. The procedure stated, in step 7.6, that if a light fixture does not meet the acceptance criteria or is found defective, then investigate and repair the fixture and generate a CR.
Contrary to the above, on April 4, 2008, the team identified multiple examples where the licensee failed to initiate CRs for ELUs that did not meet conductance acceptance criteria. Specifically, ELUs 2034, 2193, 2163, 2186 and 2191 failed conductance testing on November 2, 2006, and a CR was not generated as required by procedure FNP-2-FSP-311. Because this finding is of very low safety significance (Green) and has been entered into the licensees CAP (CRs 2008103290 and 2008103314), this violation is being treated as an NCV consistent with Section VI.A of the NRC Enforcement Policy.
This finding is identified as NCV 05000364/2008006-03, ELU Test Failures Were Not Documented In CRs As Required By Procedure.
.10 Cold Shutdown Repairs
a. Inspection Scope
The team reviewed the licensees SSA to determine if any repairs were necessary to achieve cold shutdown. AOP 28.1 describes methods for repairing equipment, following a fire, needed to bring the unit from hot standby to cold shutdown. The team inspected the fire damage repair kit and inventoried the contents in accordance with station procedure EIP-16, Emergency Equipment and Supplies, and verified that the replacement equipment was appropriately labeled, maintained in good condition, and that a sufficient quantity of materials were available to successfully accomplish all required repairs.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The team reviewed the administrative controls for out-of-service (OSS), degraded, and/or inoperable, fire protection features (e.g., detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing SSD functions or capabilities). The team reviewed selected CRs on the fire protection impairment log and compared them with the FA/FZs selected for inspection. The compensatory measures that had been established in the FA/FZs were compared to those specified for the applicable fire protection feature to verify that the risk associated with removing the fire protection feature from service was properly assessed and adequate compensatory measures were implemented in accordance with the approved fire protection program. Additionally, the team reviewed the licensee=s short term compensatory measures (compensatory fire watches) to verify that they were adequate to compensate for a degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The team reviewed corrective action program documents, including completed corrective actions documented in selected CRs, and operating experience program (OEP)documents to verify that industry-identified fire protection problems potentially or actually affecting FNP were appropriately entered into, and resolved by, the corrective action program process. Items included in the OEP effectiveness review were NRC RIS, Generic Letters (GLs), Information Notices (INs), industry or vendor-generated reports of defects and noncompliance under 10 CFR Part 21, and vendor information letters. The team also reviewed Quality Assurance (QA) audits of the FPP, self-assessments, and the latest FPP Health Reports for fire protection systems and components. These reviews were to verify that the licensee was identifying issues related to this inspection area at an appropriate threshold and correcting them in a timely manner. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
(Closed) URI 05000348, 364/2005006-01, Fire Procedure Did Not Identify the Appropriate Diagnostic Instruments This URI identified that diagnostic instrumentation needed to perform symptomatic fire response procedures was not identified in procedures, nor was it analyzed to ensure that it would be unaffected by fire damage. The licensee provided additional information to the inspection team which identified the local diagnostic instrumentation that would be relied upon to accomplish fire response procedures leading to safe shutdown. The team reviewed the additional information, reviewed the cable routing for the instruments identified, discussed the procedure with licensee operators, walked down the local instrumentation, and evaluated the required safe shutdown operator actions. One Green NCV was identified and it is discussed in Section 1R05.06. The URI is closed.
4OA6 Meetings, Including Exit
On April 4, 2008, the lead inspector presented the inspection results to Cheri Collins, Plant Manager, and other members of the licensees staff. The licensee acknowledged the findings. Proprietary information is not included in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- B. Badham, Engineering Services Supervisor
- R. Bayne, Performance Analysis Supervisor
- J. Cheney, Senior Engineer
- C. Collins, Plant Manager
- D. Davidson, Fire Marshal
- R. Federico, Operations
- J. Hayes, Training
- P. Hayes, Engineering Director
- J. Hunter, Operations Superintendent Support
- J. Lattner, Corporate Fire Protection Supervisor
- H. Mahan, Principle Licensing Engineer
- D. McKinney, Farley Corporate Licensing Supervisor
- B. Moore, Site Support Manager
- B. Oldfield, QA Supervisor
- C. Price, Fire Protection Engineer
- C. Rose, Operations
- J. Seay, Licensing Engineer
- R. Smith, Engineering Services Supervisor
- C. Thornell, Maintenance Manager
NRC Personnel
- E. Crowe, Senior Resident Inspector
- S. Sandal, Resident Inspector
- S. Walker, Acting Chief, Engineering Branch 2, Division of Reactor Safety, Region II
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
- 05000348, 364/2008006-01 NCV Fire Procedure Credits Unreliable Indication (Section 1R05.06)
- 05000364/2008006-02 NCV Areas Where OMAs Are Performed Did Not Have ELUs Installed (Section 1R05.09)
- 05000364/2008006-03 NCV ELU Test Failures Were Not Documented In CRs As Required By Procedure (Section 1R05.09)
Closed
- 05000348, 364/2005006-01 URI Fire Procedure Did Not Identify the Appropriate Diagnostic Instruments (Section 4OA5)