IR 05000348/2014009
| ML14259A198 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/15/2014 |
| From: | Scott Shaeffer Division of Reactor Safety II |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2014009 | |
| Download: ML14259A198 (27) | |
Text
September 15, 2014
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC TRIENNIAL FIRE
PROTECTION INSPECTION REPORT 05000348/2014009 AND
Dear Mrs. C. Gayheart:
On August 1, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed a baseline triennial fire protection inspection at your Joseph M. Farley Nuclear Plant Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on that date with you and other members of your staff.
The inspection examined activities conducted under your license as they related to safety and compliance with the Commissions rules and regulations and with the condition of your license.
The team reviewed selected procedures and records, observed activities, and interviewed personnel.
The enclosed report documents one NRC-identified finding of very low safety significance (Green) that was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the violation or significance of this NCV, you should provide a response with 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Farley Nuclear Plant.
If you disagree with a cross-cutting aspect assignment 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 II, and the NRC Resident Inspector at the Farley Nuclear Plant.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov./reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Scott M. Shaeffer, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8
Enclosure:
Inspection Report 05000348/2014009 and 05000364/2014009 w/Attachment: Supplementary Information
REGION II==
Docket Nos.:
50-348, 50-364 License Nos.:
05000348/2014009 and 05000364/2014009 Licensee:
Southern Nuclear Operating Company, Inc. (SNC)
Facility:
Joseph M. Farley Nuclear Plant (FNP)
Location:
7388 North State Highway 95
Columbia, Alabama 36319 Dates:
Week 1 of onsite inspection: July 14-18, 2014 Week 2 of onsite inspection: July 28-August 1, 2014
Inspectors:
J. Dymek, Reactor Inspector
J. Montgomery, Reactor Inspector
M. Singletary, Reactor Inspector
M. Thomas, Senior Reactor Inspector
G. Wiseman, Senior Reactor Inspector (Lead Inspector)
Accompanying
Personnel:
W. Monk, Reactor Inspector (Training)
Approved by:
Scott M. Shaeffer, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000348/2014009, 05000364/2014009; 07/14-18/2014 and 07/28-08/01/2014; Farley
Nuclear Plant, Units 1 and 2; Fire Protection (Triennial).
This report covers an announced two-week triennial fire protection inspection by a team of five regional inspectors and one inspector in training. One Green non-cited violation was identified.
The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
An NRC-identified non-cited violation (NCV) of Unit 2 Operating License Condition (OLC) 2.C. (6), Fire Protection, was identified for the failure to ensure that a fire door that was part of a fire barrier was provided with a 3-hour labeled door as required by 10 CFR 50.48 and the approved Fire Protection Program (FPP). Fire Area 2-20, Auxiliary Building Corridor is required to be separated from Fire Area 2-21, Unit 2 Train B Switchgear Room, by 3-hour rated fire barriers. The inspectors observed that fire door 2219, in the wall separating these two fire areas, was installed with a Underwriters Laboratory (UL) label fastened to it, identifying it as a 1.5-hour rating rather than a labeled 3-hour rated fire door. The licensee entered these issues into the corrective action program (CAP) as CRs 814872, 843303 and 840832, and implemented an hourly roving fire watch in the affected Fire Areas as a compensatory measure,
LCO No. 2-2014-0111.
The licensees failure to ensure that fire door 2219 was a functional UL labeled Class A 3-hour door, as required by the approved FPP, was determined to be a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding was evaluated using IMC 0609, Appendix F, "Fire Protection Significance Determination Process, dated September 20, 2013 because the performance deficiency affected fire protection defense-in-depth strategies involving fire confinement. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the inspectors determined that the finding was of very low safety significance (Green) at Task 1.4.3, Question B, because the barrier door (as evidenced by a UL door label of 1.5-hours) will provide a 1-hour or greater fire endurance rating. A Cross Cutting Aspect of H.12, Avoiding Complacency was assigned to this finding because individuals did not recognize or plan for the possibility of mistakes, issues or risk during the fire doors receipt inspection, installation and post-installation surveillance (Section 1R05.02).
Licensee Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R05 Fire Protection
This report documents the results of a triennial fire protection inspection of the Farley Nuclear Plant (FNP) Units 1 and 2. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), dated January 31, 2013. The objective of the inspection was to review a sample of four risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP) as described in Appendix 9.B of the FNP Updated Final Safety Analysis Report (UFSAR), Nuclear Management Instruction (NMI) NMP-ES-035 Fire Protection Program, and FNP Units 1 and 2 post-fire safe shutdown analysis (SSA), A-350971. Another objective of the inspection was to review site specific implementation of one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walkdowns of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports (SERs), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports (IRs). Section 71111.05-05 of the IP specifies a minimum sample size of three FAs and one B.5.b mitigating strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of four FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:
1. FA 2-12, U2 Hot Shutdown Panel Room, Auxiliary Building (Room 2254)
2. FA 2-15, U2 Communications Room, Auxiliary Building (Room 2202)
3. FA 2-21, U2 Train B Switchgear Rooms, Auxiliary Building (Rooms 2229 and 2233)
4. FA 2-35, U2 Train A Electrical Pen Rooms, Auxiliary Building (Rooms 2333 and 2347)
For each of the selected FAs, the inspectors evaluated the licensees FPP against applicable NRC requirements and licensee design basis documents. Applicable licensing and design basis documents reviewed by the inspectors are listed in the Attachment to this report.
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The inspectors reviewed applicable portions of FNP Units 1 and 2 post-fire safe shutdown analysis (SSA) A-350971, Joseph M. Farley Nuclear Plant Units 1 & 2 10 CFR Part 50 Appendix R Fire Protection Program, Rev. 36, abnormal operating procedures (AOPs),standard operating procedures (SOPs), piping and instrumentation drawings (P&IDs),applicable electrical one-line drawings, component cable routing information, the FNP Updated UFSAR, and other supporting documents to verify that post-fire SSD could be achieved and maintained from the main control room (MCR) for a postulated fire in FA 2-12, FA 2-15, FA 2-21, or FA 2-35. The 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 inspectors reviewed the systems and components credited for SSD from the MCR to verify that one train would remain free from fire damage.
Section III.G.2 of 10 CFR Part 50, Appendix R, specifies the separation and design requirements for protecting one train of cables and equipment necessary to achieve and maintain SSD conditions from fire damage when redundant trains are located within the same fire area. Instances where the separation requirements of Section III.G.2 were not met and local operator manual actions (OMAs) were utilized by the licensee in lieu of cable protection, the inspectors verified that the unapproved OMAs for the selected FAs were entered in the licensees correction action program (CAP) for resolution. For OMAs not previously approved by the NRC, the licensee committed to adopt National Fire Protection Association (NFPA)
Standard NFPA 805 and resolve the OMA issue during transition of the FNP fire protection licensing basis to the performance based standard of 10 CFR 50.48 (c). The inspectors reviewed calculation SE-C051326701-007, Post-Fire Manual Action Feasibility Analysis, Rev. 2, to verify that the unapproved OMAs for the selected FAs had been identified by the licensee and entered in the CAP as compensatory measures during the transition to NFPA 805.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The inspectors walked down the selected FAs to evaluate the adequacy of the fire resistance of barrier enclosure reinforced concrete ceilings, floors, and walls. This evaluation also included fire barrier penetration seal, fire door, and fire damper assemblies to ensure that at least one train of SSD equipment would be maintained free of fire damage. Construction detail drawings were reviewed as necessary. Where applicable, the inspectors observed the installed barrier assemblies and compared the as-built configurations to the approved construction details, supporting fire endurance test data, licensing basis commitments, and standard industry practices. The inspectors also performed independent fire scenario radiant heat exposure calculations to validate the fire resistance of selected fire barrier assemblies. The passive barriers reviewed are listed in the Attachment.
b. Findings
Introduction:
The inspectors identified a Green non-cited violation (NCV) of Unit 2 Operating License Condition (OLC) 2.C. (6), Fire Protection, for the failure to ensure that a fire door that was part of a fire barrier was provided with a 3-hour labeled door as required by 10 CFR 50.48 and the approved Fire Protection Program (FPP). Fire Area 2-20, Auxiliary Building Corridor is required to be separated from Fire Area 2-21, Unit 2 Train B Switchgear Room, by 3-hour rated fire barriers. The inspectors observed that fire door 2219, in the wall separating these two fire areas, was installed with a Underwriters Laboratory (UL) label fastened to it, identifying it as a 1.5-hour rating rather than a 3-hour rating.
Description:
During the inspection of the selected fire areas the inspectors noted that fire door 2219 separating Fire Area 2-20 (Auxiliary Building Corridor, Room 2228) from Fire Area 2-21 (Train B Switchgear Room, Room 2229) was installed with a UL door label of 1.5-hour fire rating when a 3-hour fire rated door was required. UFSAR 9B, Attachment A, Fire Hazards Analysis for Fire Area 2-21 states that an UL Class A door (No. 2219), rated for 3-hours exists between Fire Area 2-20 and Fire Area 2-21. The failure to install a 3-hour fire door could affect the fire protection defense in depth strategy involving the confinement of fires that do occur because it could allow smoke and heat to migrate beyond the room of fire origin and affect adjacent fire areas. In 2012, the licensee determined that 3-hour rated fire door 2219 could not be effectively repaired due to separation of the door skin from the top channel/ rib structure as well as internal weld failures and failure of the lower door hinge mounting plate. Purchase Order (PO) SNA 10039281 was initiated which required that the replacement door be Type A, 3-hour rated and that the vendor coordinate an onsite visit to measure the existing door as required to facilitate manufacture of the door. The door was sent from the manufacturer to the vendor as a generic fire door. The vendor was then to modify the door to fit the existing door frame and fasten a label with the doors fire rating. This arrangement is allowed by UL at authorized manufacturing facilities when done in accordance with ULs Follow-up Service requirements. The door sent from the vendor to FNP was affixed with a 1.5-hour UL door label. The door received a material receipt inspection, but this inspection did not identify the discrepancy between the 1.5-hour label and the 3-hour label requirement specified on the PO and the receipt inspection report. The door was installed under a plant work order (WO) SNC73736 even though the WO identified the door as a Class A 3-hour rated door. Since September 10, 2012, the door had been relied upon the provide separation of redundant electrical circuits required for safe shutdown in the event of a fire. Additionally, the door had undergone several functional inspections that likewise did not identify the door label discrepancy.
Analysis:
The licensees failure to ensure that fire door 2219 was a functional UL labeled Class A 3-hour door, as required by the approved FPP, was determined to be a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
The significance of this finding was evaluated using IMC 0609, Appendix F, "Fire Protection Significance Determination Process, dated September 20, 2013 because the performance deficiency affected fire protection defense-in-depth strategies involving fire confinement. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the inspectors determined that the finding was of very low safety significance (Green) at Task 1.4.3, Question B, because the barrier door (as evidenced by a UL door label of 1.5-hours) will provide a 1-hour or greater fire endurance rating.
A Cross Cutting Aspect of H.12, Avoiding Complacency was assigned to this finding because individuals did not recognize or plan for the possibility of mistakes, issues or risk during the fire doors receipt inspection, installation and post-installation surveillance. The licensee entered these issues into the corrective action program (CAP) as CRs 814872, 843303 and 840832, and implemented an hourly roving fire watch in the affected Fire Areas as a compensatory measure, LCO No. 2-2014-0111.
Enforcement:
10 CFR 50.48 (a)(1) states, in part, that each holder of an operating license issued under this part of this chapter must have a fire protection plan that satisfies Criterion 3 of Appendix A to this part. This fire protection plan must describe the overall fire protection program for the facility. Farley Operating License Condition 2.C.
- (6) for Unit 2 states in-part that the licensee shall implement and maintain in effect, all provisions of the approved Fire Protection Program, as described in the UFSAR. UFSAR 9B.1.1.1 states this appendix has been developed to document the evaluation of the FNP fire protection program against Appendix A to BTP APCSB 9.5-1 and Appendix R to 10 CFR Part 50. UFSAR 9B, Attachment A, Fire Hazards Analysis for Fire Area 2-21 states that an UL Class A door (No. 2219), rated for 3-hours exists between Fire Area 2-20 and Fire Area 2-21. In addition, UFSAR 9B.2.5.1, Design Control and Procurement Document Control, states in part, that plant procedures ensure that qualified personnel perform and document reviews of the adequacy of fire protection and quality requirements as stated in procurement documents. In the case of door 2219, the architectural door schedule, purchase order, material receipt inspection report and the installation WO each identified the door as a Type A 3-hour fire door.
Contrary to the above, on September 10, 2012, the licensee did not maintain in effect all provisions of the approved FPP, in that, door 2219 with a UL label fastened to it, identifying it as a 1.5-hour door was installed in the Appendix R 3-hour barrier between Fire Area 2-20 and Fire Area 2-21. Specifically, the licensee during replacement of a damaged fire door for FA 2-21, installed a 1.5-hour labeled door which did not meet the 10 CFR 50.48, UFSAR FPP nor 10 CFR Part 50 Appendix R requirements for separation of systems required for safe shutdown.
The licensee entered the deficiency into their CAP as CRs 814872, 843303 and 840832; and, supplemented existing hourly fire watch patrol compensatory measures in the affected FAs.
This violation is being treated as an NCV, consistent with section 2.3.2 of the NRC Enforcement Policy and is identified as NCV 05000364/2014009-01, Installation of 1.5-hour UL Labeled Fire Door in a Required 3-hour Fire Barrier on Unit 2.
.03 Active Fire Protection
a. Inspection Scope
The inspectors reviewed the redundancy of fire protection water sources and fire pumps to confirm that they were installed in accordance with the National Fire Protection Association (NFPA) codes of record to satisfy the applicable separation, design requirements, and licensing basis requirements of the FNP FPP. Current fire protection system health reports were reviewed and discussed with personnel knowledgeable in the operation and maintenance of these systems. The inspectors performed in-plant observations of the material condition and operational lineup for the operation of the fire water pumps and fire protection water supply distribution piping which included manual fire hose and standpipe systems for the selected FAs.
Using operating and valve cycle/alignment procedures as well as engineering drawings, the inspectors examined the fire pumps and accessible portions of the fire main piping system to verify the operational status and the alignment of system valves; and to verify the consistency of as-built configurations with engineering drawings. The inspectors also examined portions of the licensees SSA and select electrical circuit routing drawings outlining the fire water pumps power and pressure start capability to verify that the fire water system would be available to support fire brigade response activities during power block fire events.
The inspectors compared the fire detection and fire suppression systems for the selected FAs to the applicable NFPA Standard(s) by reviewing design documents and observing their as-installed configurations during in-plant walkdowns. The inspectors reviewed selected fire protection vendor equipment specifications, drawings, and engineering calculations to determine whether the fire detection and suppression methods were appropriate for the types of fire hazards that existed in the selected FAs. During plant walkdowns, the inspectors observed the placement of the fire hose stations, fire extinguishers, fire hose nozzle types, and fire hose lengths, as designated in the firefighting pre-plan strategy data sheets, to verify that they were accessible and that adequate reach and coverage was provided. The inspectors reviewed completed periodic surveillance testing and maintenance program results and verified the 12-year and 5-year hydrostatic tests; 6-year service test dates of a sample of ABC type fire extinguishers; and electrically safe test dates of a sample of carbon dioxide type fire extinguishers. Additionally, the inspectors reviewed completed periodic surveillance testing and maintenance program procedures for the fire detection and suppression systems and compared them to the operability, testing, and compensatory measures. This review was to assess whether the test program was sufficient to validate proper operation of the fire detection and suppression systems in accordance with their design requirements.
Aspects of fire brigade readiness were reviewed, including but not limited to, the fire brigades personal protective equipment, self-contained breathing apparatuses, portable communications equipment, and other fire brigade equipment to determine accessibility, material condition, and operational readiness of equipment. During plant walkdowns, the inspectors compared firefighting pre-plan drawings to existing plant layout and equipment configurations and to fire response AOIs for the selected FAs. This was done to verify that firefighting pre-fire plan drawings (data sheets) were consistent with the fire protection features and potential fire conditions within the area. The inspectors also verify that appropriate information was provided to fire brigade members to facilitate suppression of an exposure fire that could impact the SSD strategy. An operating shift of the fire brigade was randomly selected to confirm that all members were currently qualified with regard to their medical and fire brigade training records.
Current mutual aid agreements with local outside fire departments were also reviewed. Specific documents reviewed by the inspectors are listed in the Attachment.
b. Findings
No findings were identified.
04. Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The inspectors evaluated whether water-based manual firefighting activities could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local OMAs required for SSD in the selected FAs. The inspectors reviewed available documentation related to flooding analysis from fire protection activities as well as potential flooding through unsealed concrete floor cracks. The inspectors also performed independent calculations of inter-area migration of water under fire doors to validate feasibility of selected OMAs in adjacent plant areas.
Firefighting pre-plan strategies; fire brigade training procedures; fire damper locations; heating, ventilation and air conditioning (HVAC) drawings; and, fire response procedures were reviewed to verify that inter-area migration of ventilation of gaseous heat and smoke was addressed. The inspectors also verified access to safe shutdown equipment and OMAs would not be inhibited by smoke migration from one area to adjacent plant areas used to accomplish SSD. Specific documents reviewed by the inspectors are listed in the Attachment.
b. Findings
No findings were identified.
.05 Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)
a. Inspection Scope
The licensee did not credit alternative shutdown capability for any of the fire areas selected. However, FA 2-12 and FA 2-15 contained the hot shutdown panels (HSP) that the licensee credits for their alternative shutdown strategy for Unit 2. The inspectors reviewed the circuit design of the components that can be controlled from the HSP, to determine if a fire in FA 2-12 or FA 2-15 could adversely impact operators ability to control these components from the control room. The scope of the inspectors circuit analysis review is documented in Section
==1R05.06 of this report.
b. Findings
No findings were identified.
==
.06 Circuit Analyses
Inspection Scope
The inspectors reviewed Farleys Fire Area Hazard Analysis, Safe Shutdown Function Primary Component Report, and system flow diagram drawings to verify that the licensee had identified required and associated circuits that may impact post-fire SSD for the selected FAs. The inspectors also reviewed cable routing information for these credited components to determine if these cables had either been adequately protected from the potentially adverse effects of fire damage or analyzed to show that fire induced faults would not prevent post fire SSD. The inspectors conducted walk downs of the chosen FAs to help determine if the credited components relied upon for SSD would still be available given a fire in the chosen FAs.
Additionally, a review was conducted of routing information for credited active fire protection components (i.e., electric motor-driven fire water pumps, and fire protection water motor operated valves (MOV) controls to determine if a fire in the selected FAs would impact the credited defense-in-depth systems. The inspectors reviewed the licensees evaluations for spurious circuit failure scenarios (single and/or multiple) specified in the circuit analysis to determine if the sample list of components challenged the assumptions made in the SSA. The inspectors reviewed the licensees electrical coordination study to determine if power supplies were susceptible to fire damage, which would potentially affect the credited components for the FAs chosen for review. The specific components reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The inspectors reviewed plant communication capabilities to evaluate the availability of the sound powered phone system to support plant personnel in the performance of OMAs to achieve and maintain SSD, as credited in the FNP UFSAR, Appendix 9B, Section 4.1.18. The inspectors also reviewed the communication systems available at different locations within the plant that would be relied upon to support fire event notification and fire brigade firefighting activities to verify their availability at different locations. Additionally, the inspectors assessed the operators ability to communicate based upon observation of a licensee-conducted communications test with the sound powered phone systems and fire brigade portable radios.
The inspectors reviewed the cable routing for the plant phone system to ensure that the required communication systems remained functional following a fire in the selected FAs. The inspectors reviewed preventive maintenance and surveillance test records to verify that the communication equipment was being properly maintained and tested. Specific documents reviewed by the team are listed in the Attachment.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The inspectors reviewed design and maintenance aspects of the fixed 8-hour battery pack emergency lighting units (ELUs) required by 10 CFR Part 50 Appendix R, Section III.J and the FNP approved FPP. The inspectors performed plant walk downs of the post-fire SSD procedures for the selected FAs to observe the placement and coverage area of the ELUs required to illuminate operator access and egress pathways, and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. 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 an emergency. In some instances, operations personnel performed onsite tests of the ELUs to verify operation. In areas with less than adequate lighting, it was verified that the licensee incorporated the appropriate compensatory measures in order to complete SSD actions. The inspectors also reviewed completed test records of ELU battery 8-hour capacity tests to ensure that they were sized, tested, rated for at least an 8-hour capacity and maintained consistent with vendor guidance, license requirements, and licensee commitments. The inspectors reviewed vendor manuals to ensure that the ELUs were being maintained consistent with the manufacturers recommendations and verified the battery storage conditions and maintenance practices were also being followed in accordance with the vendor manuals. Specific documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The inspectors reviewed FNP-0-AOP-29.0, Plant Fire to determine if any repairs were necessary to achieve cold shutdown. For the selected FAs, SSD procedure AOP 29.2, Plant Stabilization in Hot Standby and Cooldown Without B Train AC or DC Power describes equipment necessary to repair and operate structures, systems, and components needed to bring the unit from hot standby to cold shutdown. The inspectors reviewed procedure EIP-16, Emergency Equipment and Supplies, which listed storage locations of this equipment. The inspectors reviewed surveillances and verified through observation that the repair materials were available on the site. Specific documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection Scope
- (1) Compensatory Measures for Degraded Fire Protection Components
The inspectors reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features (e.g. detection and suppression systems, and passive fire barriers) to verify that short-term compensatory measures were adequate for the degraded function or feature until appropriate corrective actions could be taken. The inspectors reviewed impairment and compensatory measures forms for fire watch tours to confirm they were being performed within the allowable time frames.
- (2) Operator Manual Actions as Compensatory Measures for Safe Shutdown
The inspectors reviewed applicable sections of the FNP SSA, calculation SE-C051326701-007, and procedure FNP-0-AOP-29.0, Plant Fire, to identify OMAs credited for SSD. In cases where local OMAs were credited in lieu of cable protection or separation of SSD equipment, the inspectors performed walk downs of those applicable OMAs to verify that the OMAs were feasible, utilizing the guidance of NRC IP 71111.05T, paragraph 02.02.j.2.
b. Findings
No findings were identified.
.11 Review and Documentation of Fire Protection Program Changes
a. Inspection scope
The inspectors reviewed a sample of fire protection system modifications and changes made between January 2012 and January 2014 to assess the licensees effectiveness and to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse effect on the ability to achieve SSD. Design change documents reviewed by the inspectors are listed in the Attachment.
b. Findings
No findings were identified.
.12 Control of Combustibles and Ignition Sources
a. Inspection Scope
The inspectors conducted tours of numerous plant areas that were important to reactor safety, including the selected FAs, to verify the licensees implementation of FPP requirements as described in the FNP FPP and administrative procedure FNP-0-ACP-35.2 Flammable Material and Combustible Material Control For the selected FAs, the inspectors evaluated generic fire protection training; fire event history; the potential for fires or explosions; the combustible fire load characteristics; and the potential exposure fire severity to determine if adequate controls were in place to maintain general housekeeping consistent with the UFSAR, administrative procedures, and other FPP procedures. There were no hot work activities ongoing within the selected FAs during the inspection and observation of this activity could not be performed.
b. Findings
No findings were identified.
.13 B.5.b Inspection Activities
a. Inspection Scope
The inspectors reviewed, on a sample basis, the licensees mitigation measures to provide makeup to the refueling water storage tank (RWST) utilizing the B.5.b portable pump for large fires and explosions. To verify that the licensee continued to meet the requirements of their B.5.b license condition and 10 CFR 50.54 (hh)(2), the inspectors reviewed applicable procedures to ensure that they were adequate and were being maintained; equipment was properly staged and was being maintained and properly tested; and plant personnel received training on implementation of the strategy. The inspectors performed a walk down of the procedure with licensee personnel to verify that the actions were feasible. Specific documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed a sample of licensee independent audits, self-assessments, and system/program health report for thoroughness, completeness and conformance to FPP requirements described in Appendix 9.B of the FNP UFSAR. The inspectors also reviewed CAP documents, including completed corrective actions and operating experience program documents, to ascertain whether industry identified fire protection issues (actual or potential)affecting FNP were appropriately entered into the corrective action program for resolution.
Items included in the operating experience program effectiveness review were NRC Information Notices, Regulatory Issue Summaries, industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters. The inspectors evaluated the effectiveness of the corrective actions for the identified issues. The documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On August 1, 2014, the inspectors presented the preliminary inspection results to Mrs. C. Gayheart, Site Vice President, and other members of the licensees staff, who acknowledged the results. Proprietary information is not included in this inspection report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Andrews, FNP Maintenance Director
- M. Barefield, FNP Fire Protection Systems Engineer
- C. Comfort, SNC Fleet Programs Manager
- D. Enfinger, Corrective Action Program Supervisor
- K. Etheridge, FNP Supply Chain Superintendent
- C. Gayheart, FNP Site Vice President
- J. Lattner, SNC Fleet Programs Engineer
- C. Westberry, NFPA 805 Project Manager
- T. Youngblood, FNP Engineering Director
NRC Personnel
- P. Niebaum, Senior Resident Inspector
- K. Miller, Resident Inspector
- S. Shaeffer, Chief, Engineering Branch 2, Division of Reactor Safety, Region II
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
None
Opened and Closed
Discussed
None
NCV Installation of 1.5-hour UL Labeled Fire Door in a Required 3-hour Fire Barrier on Unit 2 (Section 1R05.02)
SUPPLEMENTAL INFORMATION
LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section 1RO5.02-Passive Fire Barriers)
Passive Fire Barriers Assemblies Description Walls, Floor and Ceilings
Unit 2 Hot Shutdown Panel Rm. (FA 2-12)
Unit 2 Communications Rm. (FA 2-15)
Unit 2 Train B Switchgear Rms. (FA 2-21)
Unit 2 Train A Electrical Penetration Rm. (FA 2-35)
Fire Damper Identification
Description 2-139-120-05
Fire Door Identification
Description 209
Penetration Seals
Description 06-121-12
LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1R05.01 / 1R05.03 / 1R05.05 / 1R05.06)
MOV-8000A, PORV Block Valve N23M001B-B 2B MDAFW Pump MOV-3209A, MDAFW Pump 1A Intake MOV-8133A, Charging Pump Discharge Header Isolation P19C001C-N 2C Service Air Compressor SV-3369AC-A, Main Steam Isolation MO-1, MO-2, MO-3, MO-4, Fire Main Isolation Valves MOV-3764D, AFW to S/G B MOV-3406, TDAFW Pump Trip Throttle Valve MOV-8106, Charging Pump Miniflow Header Isolation MOV-8107, Charging Pump to RCS Isolation MOV-8108, Charging Pump to RCS Isolation LCV-115B, RWST to Charging Pump Suction P-003-N, Electric Driven Fire Pump SV-2214B, Reactor Vessel Head Vent Valve P17M001A-B, 2A CCW Pump E21M001C-B 2C Charging Pump Breaker ED-14