IR 05000361/2013007

IR 05000361-13-007 and 05000362-13-007, on 10/03/13, San Onofre Nuclear Generating Station, Units 2 and 3, NRC Fire Protection Inspection Report

ML13311B007
Person / Time
Site:	San Onofre
Issue date:	11/07/2013
From:	Geoffrey Miller NRC/RGN-IV/DRS/EB-2
To:	Peter Dietrich Southern California Edison Co
References
EA-10-191 IR-13-007
Download: ML13311B007 (13)

Text

UNITE D S TATE S NUC LEAR REGULATOR Y C OMMI SSI ON ber 7, 2013

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -

NRC FIRE PROTECTION INSPECTION REPORT 05000361/2013007 AND 05000362/2013007

Dear Mr. Dietrich:

On October 3, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your San Onofre Nuclear Generating Station, Units 2 and 3. The inspection covered the implementation of your fire protection program. The enclosed inspection report documents the inspection results, which were discussed on October 3, 2013, with Mr. T. Palmisano, Vice President, Decommissioning and Regulatory Affairs, and other members of your staff.

On June 12, 2013, Southern California Edison submitted a Certification of Permanent Cessation of Power Operations to the NRC, certifying that San Onofre Nuclear Generating Station, Units 2 and 3, had permanently ceased power operations (ML131640201). On June 28 and July 22, 2013, Southern California Edison certified that all fuel had been permanently removed from the Unit 2 and 3 reactors, respectively (ML13183A391 and ML13204A304). Effective July 23, 2013, the NRCs oversight of your licensed activities was being conducted under the provisions in Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program. The objectives of IMC 2561 are to verify that decommissioning activities are being conducted safely, that spent fuel is safely stored onsite or transferred to another licensed location, and that site operations and licensee termination activities are in conformance with applicable regulatory requirements, licensee commitments, and management controls.

This 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 inspection of your fire protection program was performed to verify that the capability of fire prevention, detection, and mitigation features were sufficient to ensure that decommissioning activities can be performed safely and that the spread of contamination can be minimized and controlled in the event of a fire. The inspector reviewed selected procedures and records, performed walkdowns of plant areas and equipment, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified. The NRC also determined that the corrective actions implemented to address the deficiencies leading to violation 2010007-01 (EA-10-191) associated with your fire protection program were adequate to address the technical issues. Violation (05000361/05000362-2010007-01), Failure to Ensure at Least One Train of Equipment Necessary to Achieve Hot Shutdown Conditions is Free of Fire Damage, is closed.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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/

Geoffrey Miller, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-361, 50-362 License Nos.: NPF-10; NPF-15

Enclosure:

NRC Inspection Report 05000361/2013007 and 05000362/2013007 w/Attachment: Supplemental Information

REGION IV==

Dockets: 05000361, 05000362 Licenses: NPF-10, NPF-15 Report: 05000361/2013007, 05000362/2013007 Licensee: Southern California Edison Company Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hwy.

San Clemente, California Dates: October 1 through 4, 2013 Inspector: S. Graves, Senior Reactor Inspector, Engineering Branch 2 Approved By: Geoffrey Miller, Chief Engineering Branch 2 Division of Reactor Safety-1- Enclosure

EXECUTIVE SUMMARY

Southern California Edison

San Onofre Nuclear Generating Station, Units 2 and 3 (Inspection Report 05000361/05000362 - 2013007)

The report covered a one-week period of onsite inspection by a region-based inspector. No findings were identified.

By letter, dated June 12, 2013, Southern California Edison provided certification of permanent cessation of power operations for San Onofre Nuclear Generating Station, Units 2 and 3. With this certification, the fire protection program at San Onofre Nuclear Generating Station (SONGS) transitioned to a program meeting the requirements of 10 CFR 50.48(f) for licensees that have submitted the certifications required under 10 CFR 50.82, Termination of License.

SONGS was required to maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials.

This inspection was performed to evaluate, in part, the adequacy and implementation of the licensee's Fire Protection Program. The inspection assessed the status and capability of fire protection at SONGS to verify that the capability of fire prevention, detection, and mitigation features were sufficient to ensure that decommissioning activities can be performed safely and that the spread of contamination can be minimized and controlled in the event of a plant fire.

This inspection also reviewed licensee corrective actions taken in response to Violation 2010007-01 (EA-10-191) described in NRC Inspection Report 05000361/2010007; 05000362/2010007.

NRC-Identified Findings and Self-Revealing Findings

No Findings were identified.

Licensee-Identified Violations

None

REPORT DETAILS

Specific documents reviewed during this inspection are listed in the attachment.

1. Fire Protection Program Procedures

1.1 Inspection Scope The inspector verified that the licensee had developed technically adequate plans and procedures to implement the Fire Protection Program, including procedures to control transient and fixed combustible materials, housekeeping, administrative controls, hot work, ventilation, and communications. The inspector reviewed the licensee's fire protection plan, fire hazards analysis, and fire protection procedures to understand the licensee's fire protection strategy and facility fire hazards and to ascertain whether the fire plans and procedures reflect the current status of the decommissioning facility and licensed conditions.

1.2 Observations and Findings No findings of significance were identified.

1.3 Conclusions The licensee had technically adequate plans and procedures. The licensee is in the process of decommissioning and had developed a fire protection program procedure which provided appropriate guidance for meeting their required defense-in-depth programmatic elements during the decommissioning process.

2. Fire Protection Systems and Equipment

2.1 Inspection Scope The inspector verified the proper installation, operability, and maintenance of fire protection systems and equipment by performing walkdowns and holding discussions with licensee fire protection staff.

The inspector conducted plant tours to observe and assess the storage of combustibles and flammables and to assess whether field conditions accurately reflected licensee fire analyses, assumptions, and procedure requirements. The inspector walked down the plant fire suppression water system including fire pumps, fire water storage tanks, associated piping and valves to ascertain whether firefighting equipment and stations were properly maintained, inventoried, and ready for use. The inspector reviewed standpipes and hose stations, portable fire extinguishers and fire wrapped equipment for material condition and functionality. The inspector evaluated the licensees criteria for determining fire barrier functionality and inspected cable trays and conduits, penetration seals, fire doors and dampers to ensure adequate protection and functionality. The walkdowns also included fire detection and suppression systems to assess whether installed systems were effectively maintained, surveillances performed, and capable of performing their intended function.

The inspector walked down the spent fuel pool cooling systems to determine the systems susceptibility to damage from fire.

2.2 Observations and Findings No findings of significance were identified.

2.3 Conclusions The licensees fire protection systems and equipment were in good working order. No material condition issues were identified. The licensee maintains three fire pumps and two fire water storage tanks in operational condition. Spent fuel pool equipment was in operation and was appropriately protected. Fire detection and suppression systems, including portable fire extinguishers, were operational and were being maintained in accordance with licensee procedures and requirements and were appropriate for plant conditions.

3. Fire Brigade

3.1 Inspection Scope The inspector conducted interviews to ascertain the effectiveness of site firefighting training and qualifications. The licensee had plans to transition from a dedicated fire department to a fire brigade composed of trained plant staff members. The inspector reviewed the licensees transition plans for the fire brigade and training and qualification program. The inspector interviewed the licensees Fire Marshal and discussed brigade composition, firefighting equipment and continuing offsite support and availability.

3.2 Observations and Findings No findings of significance were identified.

3.3 Conclusions The licensee had an on-site professional fire department which provided firefighting services. The licensee expects to transition to a fire brigade structure in the future and had begun developing plans and training documents to facilitate the transition. The licensee had agreements in place with offsite support for emergency response, including firefighting capabilities and regularly trained with the offsite responders.

4. (Closed) VIO 05000361/05000362 2010007-07, Failure to Ensure At Least One Train

of Equipment Necessary to Achieve Hot Shutdown Conditions Is Free of Fire Damage (EA 10-191)

The inspector reviewed the licensees corrective actions taken to address violation 05000361/362-2010007-01 associated with Enforcement Action EA-10-191.

The violation was written to address the failure to complete corrective actions and restore compliance with License Condition 2.C(14), which required the licensee to implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Fire Hazards Analysis through Revision 3. The violation was cited because the noncompliance had been previously identified and documented in NRC Inspection Report 05000361/2007008 and 05000362/2007008 and compliance had not been restored by the expiration of enforcement discretion, described in Enforcement Guidance Memorandum 07-004.

The inspector reviewed the violation and licensee corrective actions, walked down the equipment and interviewed licensee staff responsible for the fire protection program.

The licensee had placed the cabling associated with the safe shutdown equipment in conduit and wrapped that conduit in a two-hour fire wrap material. The combination of conduit and fire-wrapping resulted in a three-hour barrier between the safe shutdown equipment cabling and a potential fire in the area. Upon transitioning to IMC 2561, the licensee was no longer required to maintain the capability to safely shut down the reactor. The corrective actions met the requirements of the licensees fire protection program fire hazards analysis and regulatory requirements; therefore, this violation is closed.

5.

Exit Meeting Summary

On October 3, 2013, the inspector presented the results of the inspection to Mr. T. Palmisano, Vice President - Decommissioning and Regulatory Affairs, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector verified that no proprietary information was retained by the inspector.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Partial List of Persons Contacted

B. Metz Fire Marshal

D. Arai Fire Protection Program Engineer

D. Evans Manager of Security

J. Miller Operations Shift Manager

J. Davis Operations Manager

M. Ingram Security Officer

M. Shackelford Nuclear Training Division Supervisor

O. Flores Director of Nuclear Oversight

R. Corbett Director of Performance Improvement

R. Pettus Nuclear Regulatory Affairs Technical Specialist

T. McCool Plant Manager

T. Palmisano Vice President - Decommissioning and Regulatory Affairs

Inspection Procedures Used

64704 Fire Protection Program

71801 Decommissioning Performance and Status Review at Permanently Shutdown

Reactors

Items Opened, Closed, and Discussed

Opened

None

Opened and Closed

None

Closed

05000361/362-2010007-01 VIO Failure to Ensure at Least One Train of Equipment

Necessary to Achieve Hot Shutdown Conditions is Free of

Fire Damage (Section 4) (EA-10-191)

Discussed

None

Attachment

TABLES OF