IR 05000382/2009006

IR 05000382-09-006, on 04/27/2009 - 05/22/2009, Entergy Operations, Inc; Waterford 3 Steam Electric Station; Triennial Fire Protection Team Inspection and Enforcement Discretion

ML091820044
Person / Time
Site:	Waterford
Issue date:	07/01/2009
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Kowalewski J Entergy Operations
References
EA-09-171 IR-09-006
Download: ML091820044 (28)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N uly 1, 2009

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000382/2009006 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Kowalewski:

On May 22, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford 3 facility. The enclosed inspection report documents the inspection results, which were discussed in an exit meeting with Mr. K. Nichols, Director, Engineering, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspection identified one violation of very low safety significance (Green). However, because of the very low safety significance and because the finding was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with the NRC Enforcement Policy. The inspection identified two violations that met the criteria for enforcement discretion for plants transitioning to National Fire Protection Association 805, as specified in the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). If you contest the non-cited violation in this report, you should provide a written response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at the Waterford 3 facility. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Senior Resident Inspector at the Waterford 3 facility. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

Entergy, Inc. -2-In accordance with 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 Publicly Available Records (PARS) component of the NRC's 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,

Sincerely,

/RA/

Neil O'Keefe, Chief Engineering Branch 2 Division of Reactor Safety Docket: 50-382 License: NPF-38

Enclosure:

Inspection Report No. 05000382/2009006 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000382 License: NPF-38 Report: 05000382/2009006 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy. 18 Killona, LA Dates: April 27 through May 22, 2009 Inspectors: G. Pick, Senior Reactor Inspector, Engineering Branch 2 S. Alferink, Reactor Inspector, Engineering Branch 2 B. Correll, Reactor Inspector, Engineering Branch 2 E. Uribe, Reactor Inspector, Engineering Branch 2 Z. Bailey, Nuclear Safety Professional Development Program Engineer Accompanying D. Andrukat, Fire Protection Engineer, Office of New Reactors Personnel:

Approved By: Neil O'Keefe, Chief Engineering Branch 2 Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

IR 05000382/2009006; 04/27/2009 - 05/22/2009; Entergy Operations, Inc; Waterford 3 Steam

Electric Station; Triennial Fire Protection Team Inspection The report covered a two-week triennial fire protection team inspection by Region IV specialist inspectors. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609,

"Significance Determination Process." Findings for which the significance determination process (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.

Cornerstone: Mitigating Systems

Green.

The team identified a non-cited violation of License Condition 2.C.9 for the failure to identify conditions adverse to the fire protection program, as required by Procedure UNT-005-013, "Fire Protection Program," Revision 10.

Specifically, during required inspections of the material condition of the sprinkler system, the licensee failed to identify several instances of either bent or misaligned sprinkler head deflector plates, which were not protected as required by National Fire Protection Association 13-1976, "Standard for the Installation of Sprinkler Systems."

The failure to identify a condition adverse to fire protection was a performance deficiency. This deficiency was more than minor since, if left uncorrected, the finding would become a more significant safety concern in that the number of damaged sprinklers would continue to increase. The team evaluated the significance of this finding using Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process." The deficiency involved the Fixed Fire Protection Systems category. Using Appendix F, Attachment 2,

"Degradation Rating Guidance Specific to Various Fire Protection Program Elements," the team determined that the deficiency had low degradation since less than 10 percent of the heads in the affected fire area were nonfunctional, a functional head remained within 10 feet of the combustibles of concern, and the system remained nominally code compliant. This finding screened as having very low safety significance (Green) in Phase 1. This finding has a cross-cutting aspect in the area of human performance associated with resources because the procedure used to inspect the condition of these sprinklers did not contain specific criteria for identifying unacceptable sprinkler conditions H.2(c)

(Section 1R05.04.b.1).

Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (71111.05TTP)

The NRC conducted a triennial fire protection inspection in accordance with NRC Inspection Procedure 71111.05TTP, "Fire Protection-NFPA Transition Period (Triennial)," at the Waterford 3 facility. The licensee committed to adopt a risk informed fire protection program in accordance with National Fire Protection Association 805, "Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants," 2001 Edition. At the time of this inspection, the licensee had not yet completed the program transition. The inspection team evaluated the implementation of the approved fire protection program in selected risk-significant areas, with an emphasis on the procedures, equipment, fire barriers, and systems that ensure the post-fire capability to safely shut down the plant.

Inspection Procedure 71111.05TTP requires the selection of three to five fire areas for review. The inspection team used the fire hazards analysis and the Waterford 3 Individual Plant Examination of External Events to select the following four risk-significant fire areas for review:

• Fire Area RAB 5 Electrical Penetration Room A

• Fire Area RAB 6 Electrical Penetration Room B

• Fire Area RAB 27 Communications Room

• Fire Area RAB 39 -35' Auxiliary Building Corridor Areas The team evaluated the licensee's fire protection program using applicable requirements, which included plant Technical Specifications, License Condition 2.C.9, NRC safety evaluations, 10 CFR 50.48, and Branch Technical Position 9.5-1. The team also reviewed related documents that included the Final Safety Analysis Report, the fire hazards analysis, and the post-fire safe shutdown analysis.

Specific documents reviewed by the team are listed in the attachment. The team completed four inspection samples.

.01 Shutdown From Outside Main Control Room

a. Inspection Scope

The team reviewed the post-fire safe shutdown analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and other supporting documents to verify that hot and cold shutdown conditions could be achieved and maintained for fires in areas where the post-fire safe shutdown strategy relies upon manipulating shutdown equipment from outside the control room. The team verified that hot and cold shutdown conditions could be achieved and maintained, with or without offsite power available. The team also verified that the post-fire safe shutdown

analysis properly identified the components and systems needed to achieve and maintain post-fire safe shutdown conditions.

b. Findings

No findings of significance were identified.

.02 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the piping and instrumentation diagrams, post-fire safe shutdown equipment list, post-fire safe shutdown design basis documents, and the post-fire safe shutdown analysis to verify that the licensee properly identified the components and systems necessary to achieve and maintain post-fire safe shutdown conditions for fires in the selected fire areas. The team observed operator walk downs of the procedures used for achieving and maintaining safe shutdown in the event of a fire to verify that the procedures properly implemented the post-fire safe shutdown analysis provisions.

For each of the selected fire areas, the team reviewed the separation of redundant post-fire safe shutdown cables, equipment, and components located within the same fire area. The team also reviewed the method used to meet the requirements of 10 CFR 50.48; Branch Technical Position 9.5-1, Appendix A; and 10 CFR Part 50, Appendix R, Section III.G. Specifically, the team evaluated whether at least one post-fire safe shutdown success path remained free of fire damage in the event of a fire.

In addition, the team verified that the licensee met applicable license commitments.

b. Findings

No findings of significance were identified.

.03 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe the material condition and configuration of the installed fire area boundaries (including walls, fire doors, and fire dampers) and verify that the fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.

The team reviewed installation, repair, and qualification records for a sample of penetration seals to ensure the fill material possessed an appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design.

The team reviewed license basis documentation, such as NRC safety evaluation reports and deviations from NRC regulations and the National Fire Protection Association codes, to verify that fire protection features met license commitments.

b. Findings

No findings of significance were identified.

.04 Active Fire Protection

a. Inspection Scope

Fire Detection and Suppression For the selected fire areas, the team evaluated the adequacy of fire suppression and detection systems. The team reviewed the material condition, operational configuration, and design of the installed fire detection and suppression systems and compared it to licensing basis documentation and deviations from NRC regulations to verify that fire suppression and detection systems met license commitments. The team verified that the licensee had installed, tested, and maintained the automatic and manual suppression and detection systems in accordance with the National Fire Protection Association codes of record.

The team performed a walk down of accessible portions of the fire detection and suppression systems in the selected fire areas. The team also performed a walk down of major system support equipment in other areas (e.g., fire pumps) to assess the material condition of these systems and components. The team reviewed the electric and diesel fire pump flow and pressure tests to verify that the pumps met their design requirements.

Fire Brigade The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if licensee had provided sufficient information to fire brigade members and plant operators to identify post-fire safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. In addition, the team inspected fire brigade equipment to determine operational readiness for fire fighting.

The team observed an unannounced fire drill, conducted on April 29, 2009, and the subsequent drill critique using the guidance contained in Inspection Procedure 71111.05AQ, "Fire Protection Annual/Quarterly." The team observed fire brigade members fight a simulated fire in Battery Room AB, located in the Control Building. The team verified that the licensee identified problems, openly discussed them in a self-critical manner at the drill debrief, and identified appropriate corrective actions.

The team evaluated the following specific attributes:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses;

(3) employment of appropriate fire fighting techniques;

(4) sufficient fire fighting equipment taken to the scene;

(5) effectiveness of fire brigade leader communications, command, and control;

(6) search for victims and propagation of the fire into other areas;

(7) smoke removal operations;

(8) utilization of pre-planned strategies;

(9) adherence to the pre-planned drill scenario; and

(10) drill objectives.

.1 Failure to Identify Conditions Adverse to Fire Protection

Introduction.

The team identified a non-cited violation of License Condition 2.C.9 for the failure to identify conditions adverse to the fire protection program, as required by Procedure UNT-005-013, "Fire Protection Program," Revision 10. Specifically, during required inspections of the material condition of the sprinkler system, the licensee failed to identify several instances of either bent or misaligned sprinkler head deflector plates, which were not protected as required by National Fire Protection Association 13-1976, "Standard for the Installation of Sprinkler Systems."

Description.

During plant walk downs in Fire Area RAB 39, the team identified six instances of either bent or misaligned sprinkler head deflector plates that were located in walkways and subject to damage because of their low height. Damaged or misaligned deflector plates could affect the spray pattern and area in which water reached the floor, resulting in decreased ability to control a fire because of reduced area-wide coverage.

Technical Requirements Manual Surveillance Requirement 4.7.10.2.C requires the licensee to examine the physical condition of the sprinkler system in safety areas every 18 months. The licensee performed the surveillance using Procedure MM-003-021, "Sprinkler System Inspection (Safety Areas)," Revision 8. The team determined Procedure MM-003-021 specified evaluating the acceptability of the sprinkler systems.

However, the procedure did not contain any specific information regarding the appropriate physical condition or arrangement of the deflector plates. The team determined that maintenance personnel assigned to perform the inspections had not received any specific training related to the proper configuration of sprinkler heads.

Licensee management stated that their intent was to have the maintenance personnel write condition reports so that the fire protection specialists could evaluate the unusual conditions.

The licensee had completed Procedure MM-003-021 on October 14, 2008, in accordance with Work Order 51654794. The team determined that the inspections found the physical condition of all of the sprinkler heads acceptable.

The licensee was committed to National Fire Protection Association 13-1976 for their sprinkler systems. National Fire Protection Association 13-1976, Section 3-15.8, "Guards and Shields," specified, "sprinkler systems which are so located as to be subject to mechanical injury (in either the upright or the pendent position) shall be protected with approved guards." The team noted that all but one of the damaged sprinkler heads were missing the required guards.

Analysis.

The failure to identify a condition adverse to fire protection was a performance deficiency. This deficiency was more than minor since, if left uncorrected, the finding would become a more significant safety concern in that the number of damaged sprinklers would continue to increase. The team evaluated the significance of this finding using Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process." The deficiency involved the Fixed Fire Protection Systems category. Using Appendix F, Attachment 2, "Degradation Rating Guidance Specific to Various Fire Protection Program Elements," the team determined that the deficiency had low degradation since less than 10 percent of the heads in the affected fire area were

nonfunctional, a functional head remained within 10 feet of the combustibles of concern, and the system remained nominally code compliant. This finding screened as having very low safety significance (Green) in Phase 1.

This finding has a cross-cutting aspect in the area of human performance associated with resources because the procedure used to inspect the condition of these sprinklers did not contain specific criteria for identifying unacceptable sprinkler conditions H.2(c).

The team considered this important because maintenance personnel performing the inspections had no specific training that would allow them to identify unacceptable sprinkler heads.

Enforcement.

License Condition 2.C.9 states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the Safety Evaluation Report. Final Safety Analysis Report, Section 9.5.1.3.1.C states that the fire protection program quality assurance program is documented in Procedure UNT-005-013, "Fire Protection Program." Procedure UNT-005-013, Section 5.8.8, states that conditions adverse to the fire protection program will be identified and corrected in accordance with Procedure EN-LI-002, "Corrective Action Process." Procedure EN-LI-002 requires that personnel document adverse conditions in condition reports.

Contrary to the above, on October 14, 2008, the licensee failed to implement a provision of the approved fire protection program, as specified in their Final Safety Analysis Report and plant procedures. Specifically, the licensee failed to generate a condition report and fix six bent or misaligned sprinkler head deflector plates that could have affected suppression capability required to cover the entire area. This finding does not qualify for enforcement discretion as described in the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)" since this finding should have been identified by normal surveillance or quality assurance activities.

Because this finding is of very low safety significance and has been entered into the corrective action program (Condition Report 2009-02033), this finding is being treated as a non-cited violation, consistent with the NRC Enforcement Policy:

NCV 05000382/2009006-01, Failure to identify conditions adverse to fire protection.

.2 Failure to Provide Area-wide Sprinkler Coverage as Required in an Appendix R,

Section III.G.2.c Fire Area

Introduction.

The team identified a violation of License Condition 2.C.9 for failure to protect post-fire safe shutdown equipment against fire damage, as required by 10 CFR Part 50, Appendix R, Section III.G.2. Specifically, in Fire Area RAB 39 the licensee failed to provide area-wide sprinkler coverage that complied with the requirements in National Fire Protection Association 13-1976. As required in Appendix R,Section III.G.2.c, redundant trains within the same fire area must be protected with detection and an automatic fire suppression system when redundant post-fire safe shutdown equipment is protected with 1-hour fire barriers. The team determined this violation met the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)" conditions for receiving enforcement discretion (EA-09-171).

Description.

During plant walk downs of Fire Area RAB 39 (-35-foot corridor area) to review compliance with National Fire Protection Association 13-1976, the team identified three examples of failures to provide the required area-wide sprinkler coverage.

• Sprinkler heads installed closer than the allowed 6-foot minimum spacing.

When the first sprinkler actuates this short span allows spray to contact an adjacent sprinkler keeping it cool enough to preventing actuation.

• No sprinkler coverage for the area under a large ceiling equipment hatch.

• Ceiling sprinklers were blocked in four separate locations by large ventilation ducts and cable trays that exceeded the 4-foot limit below obstacles and resulted in less than area-wide coverage. Because of offsetting heights of the obstructions, the team determined that a fire would not produce a plume or a ceiling jet that would activate the existing sprinklers in the following circumstances:

o Two parallel cable trays and a large diameter pipe adjacent to the emergency feedwater pump rooms, o Piping, cable trays, ductwork, and structural support members in the narrow passageway in front of the elevator, o Six cable trays and one duct that outside of Stair 6, and o Two parallel cable trays outside of the Train B heat exchanger room and above an open storage locker containing plastic covered radiological protective blankets.

As immediate corrective actions, the licensee initiated Fire Impairment 2009-145, which established a continuous fire watch in the fire area, and entered this issue into the corrective action program as Condition Report 2009-01986.

The team determined that Fire Area RAB 39 had redundant post-fire safe shutdown trains routed through the area. As specified in 10 CFR Part 50, Appendix R, Section III.G.2.c, an area containing redundant post-fire safe shutdown trains has adequate protection so long as one train has a 1-hour rated fire barrier wrap with detection and fixed fire suppression.

The team determined the licensee had not installed some sprinklers in Fire Area RAB 39 in accordance with National Fire Protection Association 13-1976, as required by Final Safety Analysis Report, Section 9.5.1.3.1.E.3.(c). The failure to provide area-wide sprinkler coverage in a fire area that contained redundant trains of post-fire safe shutdown equipment resulted in a failure to meet the requirements of their license. From review of the scope of their National Fire Protection Association 805 conversion, the team confirmed that the licensee had actions scheduled for evaluating each fire area for compliance with the National Fire Protection Association codes.

Analysis.

Failure to provide area-wide sprinkler coverage in accordance with National Fire Protection Association 13-1976 for a fire area with 1-hour fire barriers was a performance deficiency. The team determined that this finding was more than minor

because it is associated with the protection against external factors attribute of the mitigating systems cornerstone and adversely affected the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because this violation meets the discretion criteria of the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)" for a noncompliance identified during the transition to National Fire Protection Association 805, the team determined that discretion to take no enforcement action is appropriate at this time, as described in the Enforcement Policy. The team reviewed the risk assessment for the fire area and determined that the licensee demonstrated that the risk was less than high safety significance (Red). Specifically, the team determined that the fixed and transient fire sources would not generate sufficient heat to cause fire damage that rendered the systems incapable of performing their safety function.

Enforcement.

License Condition 2.C.9 states that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through and as approved in the Safety Evaluation Report. Final Safety Analysis Report, Section 9.5.1.3.1.E.3.(c) specified that the licensee would install sprinklers in accordance with National Fire Protection Association 13-1976. National Fire Protection Association 13-1976, Section 4-4.13 specified, in part, sprinklers shall be installed beneath ducts that create obstructions over 4 feet wide. The licensee committed to the technical requirements of 10 CFR Part 50, Appendix R, by letter dated November 10, 1981. Appendix R,Section III.G.2.c specifies that the licensee must provide detection and area-wide suppression when the separation requirements for redundant post-fire safe shutdown trains are being met using a 1-hour fire barrier.

Contrary to the above, from initial licensing through May 22, 2009, the licensee failed to implement and maintain in effect all provisions of their approved fire protection program, as required by 10 CFR Part 50, Appendix R, Section III.G.2. Specifically, the team identified that the licensee failed to ensure a redundant post-fire safe shut train with a 1-hour fire wrap had adequate protection. The licensee failed to provide area-wide sprinkler coverage under obstructions, under a large ceiling equipment hatch and failed to prevent wetting of sprinkler heads as required by National Fire Protection Association 13-1976.

Because the licensee committed to adopting National Fire Protection Association 805 and changing their fire protection program license basis to comply with 10 CFR 50.48(c),this issue is eligible for the enforcement discretion described in the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, the team determined that the licensee:

(1) would have evaluated this issue during the conversion to National Fire Protection Association 805,

(2) had entered this issue into their corrective action program and implemented appropriate compensatory measures,

(3) would not have likely identified this through routine licensee efforts, and

(4) had not committed the error willfully. The team determined that this violation meets the criteria for enforcement discretion for plants in transition to a risk-informed, performance-based fire protection program as allowed per 10 CFR 50.48(c) (EA-09-171). Since all the criteria were met, the NRC is exercising enforcement discretion for this issue and documenting the issue as a finding:

FIN 05000382/2009006-02, Failure to provide area wide sprinkler coverage as required in an Appendix R,Section III.G.2.c fire area.

.05 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed plant walk downs and document reviews to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:

• A fire in one of the selected fire areas would not directly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage all redundant post-fire safe shutdown trains.

• A fire in one of the selected fire areas or the inadvertent actuation or rupture of a fire suppression system would not directly cause damage to all redundant trains (e.g., sprinkler-caused flooding of other than the locally affected train).

• Adequate drainage is provided in areas protected by water suppression systems.

b. Findings

No findings of significance were identified.

.06 Alternative Shutdown Capability

a. Inspection Scope

Review of Methodology The team reviewed the post-fire safe shutdown analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and other supporting documents. The team reviewed these documents to determine whether hot and cold shutdown could be achieved and maintained from outside the control room for fires that require evacuation of the control room, with or without offsite power available.

The team conducted plant walk downs to verify that the plant configuration remained consistent with the description contained in the post-fire safe shutdown and fire hazards analyses. The team focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions.

The team also verified that the systems and components credited for post-fire safe shutdown would remain free from fire damage. Finally, the team verified that the transfer of control from the control room to the alternative shutdown location would not be affected by fire-induced circuit faults.

Review of Operational Implementation The team verified that the licensed and non-licensed operators received training on alternative shutdown procedures. The team also verified that sufficient personnel to perform post-fire safe shutdown actions are trained and available onsite at all times, exclusive of those assigned as fire brigade members.

The team performed a timed walkthrough of the post-fire safe shutdown procedure with licensed and non-licensed operators to determine the adequacy of the procedure and to evaluate their ability to implement the procedure. The team evaluated whether the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time-critical actions verified included restoring electrical power, establishing control at the remote shutdown and local shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.

The team reviewed the time-critical manual actions identified by the licensee needed to support alternate shutdown from outside the control room, including the calculations and analyses that provided the bases for these critical times. The review compared the simulated completion times recorded during the procedure walk through to the analytical values to verify that the operators could implement the procedure as intended.

The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to verify that the tests are adequate to demonstrate the functionality of the alternative shutdown capability.

b. Findings

Introduction.

The team identified a violation of License Condition 2.C.9 related to the capability to complete required manual actions, following a control room fire, because of potential fire damage to some motor-operated valves. Specifically, the licensee failed to evaluate the susceptibility of fire damaging circuits in motor-operated valves that needed to be manually operated for post-fire safe shutdown. The licensee did not recognize that the circuits could cause the valves to become stuck. The team determined licensee personnel would not be able to reposition motor-operated valves as specified in plant procedures. The team determined this violation met the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)"conditions for receiving enforcement discretion (EA-09-171).

Description.

The licensee implemented their alternative shutdown for a control room fire in accordance with Procedure OP-901-502, "Evacuation of Control Room and Subsequent Plant Shutdown," Revision 16. Procedure OP-901-502, Attachment 2, Step 4, required that operators close Valves MS-119A/B, Train A/B main steam isolation valve upstream drip pot startup drain valves, to prevent uncontrolled cool down of the plant. Also, Attachment 4, Step 5, required that operators open Valves BAM-113A/B, Train A/B boric acid make-up tank gravity feed valves, to provide a source of borated water to the reactor coolant system. The team determined that both attachments required operators to use the motor-operated valve hand wheel to manually reposition these valves in the event of a spurious actuation resulting from fire damage. The licensee identified these actions as time-critical in the event of a control room evacuation.

Information Notice 92-18, "Potential for Loss of Remote Shutdown Capability during a Control Room Fire," described the potential for fire damage to motor-operated valves to prevent operation following a control room evacuation. The information notice described that a valve without thermal overloads could be damaged and not be operated after a control room evacuation. The industry information further described the potential need to rewire circuits to ensure that a hot short would not bypass the torque and limit switches whether a valve had thermal overloads or not. Further, the information notice provided diagrams indicating how a circuit would allow damage and how to rewire the circuit to ensure the torque and limit switches continue to function if a hot short were to occur.

The licensee documented their evaluation of Information Notice 92-18 in an internal memorandum dated March 17, 1993. The licensee evaluated whether the forces generated by the motor-actuator at locked rotor current, which would trip the thermal overload, exceeded forces the licensee determined would be needed to fail the motor-operated valve weak link under accident conditions. The licensee had performed valve weak link calculations so that they could modify the valves to withstand the forces generated under accident conditions. The team determined from interviews and review of the evaluation that these calculations demonstrated the motor-operated valves would not cause the failure of the pressure boundary. The licensee did not determine whether the forces generated with the motor-actuator at locked rotor torque would push the valve disc in the seat such that operators could not reposition the valve using the manual hand wheel. This condition would result if a hot short bypassed the torque switch, which could occur under the current control circuit configuration.

The team determined that the licensee did not ensure that the required post-fire safe shutdown valves would remain functional as a result of a fire-induced hot short. The team determined that it was possible that the valve disc would be driven into the valve seat with such force that mechanical damage would occur and the valve would not be able to be repositioned, as required by post-fire safe shutdown procedures. The licensee documented this deficiency in Condition Reports 2009-02249 and 2009-02472.

The team verified that the licensee had scheduled an evaluation of Information Notice 92-18 during their transition to National Fire Protection Association 805. After the team identified the deficiency in the existing evaluation, the licensee initiated the following actions:

(1) confirming the population of post-fire safe shutdown valves affected;

(2) performing further evaluations to determine whether they could open the valves manually using the hand wheel;

(3) for any valve unable to be opened, the licensee will identify routing of the control cables through the plant; and

(4) after identifying the cable routing, the licensee will use fire modeling to identify if the valves would be subjected to fire damage. The team determined the licensee will perform a risk evaluation, if needed, to total all contributions to core damage that result from this performance deficiency.

Analysis.

The failure to ensure that safe shutdown equipment could be operated as required during control room fire events was a performance deficiency. The team determined that this finding was more than minor because it is associated with the protection against external factors attribute of the mitigating systems cornerstone and adversely affected the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because this violation meets the

discretion criteria of the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)" for a noncompliance identified during the transition to National Fire Protection Association 805, the team determined that discretion to take no enforcement action is appropriate at this time, as described in the Enforcement Policy.

Enforcement.

License Condition 2.C.9 states "EOI shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the Safety Evaluation Report."

Final Safety Evaluation Report, Section 9.5.1.4.1 specifies alternate shutdown capability is provided that meets the criteria of Appendix R, Sections III.G.3 and III.L.

Section III.L.3 specifies, in part, procedures shall be in effect to implement the alternative shutdown capability. Procedure OP-901-502, Attachment 2, Step 4, directs operators to close Valves MS-119A/B using the manual hand wheel. Attachment 4, Step 5 direct operators to open Valves BAM-113A/B. Contrary to the above, from February 1993 through May 22, 2009, the licensee failed to implement the requirements of License Condition 2.C.9, as specified in Final Safety Analysis Report, Section 9.5.1.4.1 and Appendix R,Section III.L.3. Specifically, the licensee failed to ensure that valves susceptible to fire damage could be manually operated as specified in Procedure OP-901-502, which implemented their alternate shutdown capability.

Because the licensee committed to adopting National Fire Protection Association 805 and changing their fire protection program license basis to comply with 10 CFR 50.48(c),this issue is eligible for the enforcement discretion described in the "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, although identified by the team, the licensee:

(1) would have evaluated this issue during the conversion to National Fire Protection Association 805,

(2) had entered this issue into their corrective action program and implemented appropriate compensatory measures,

(3) would not have likely identified this through routine licensee efforts, and

(4) had not committed the error willfully. The team determined that this violation meets the criteria for enforcement discretion for plants in transition to a risk-informed, performance-based fire protection program as allowed per 10 CFR 50.48(c) (EA-09-171). Since all the criteria were met, the NRC is exercising enforcement discretion for this issue and documenting the issue as a finding:

FIN 05000382/2009006-03, Failure to ensure post-fire safe shutdown valves could be operated.

.07 Circuit Analysis

This segment of inspection is suspended for plants in transition to a risk-informed fire protection program in accordance with National Fire Protection Association 805.

Therefore, the team did not evaluate this area.

.08 Communications

a. Inspection Scope

The team inspected the contents of designated emergency storage lockers and reviewed the alternative shutdown procedure to verify that portable radio communications and fixed emergency communications systems remained available, operable, and adequate for the performance of designated activities. The team verified

the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team also verified that the design and location of communications equipment such as repeaters and transmitters would not cause a loss of communications during a fire. The team discussed system design, testing, and maintenance with engineering personnel.

The team reviewed the adequacy of the communication system to support plant personnel in the performance of alternative post-fire safe shutdown functions and fire brigade duties. The review verified that the licensee established and maintained in working order primary and backup communications. Further, the team evaluated the environmental impacts such as ambient noise levels, coverage patterns, and clarity of reception. The team reviewed that the electrical power supplies and cable routing for the phone system would allow them to remain functional following a fire in the control room and other fire areas.

b. Findings

No findings of significance were identified.

.09 Emergency Lighting

a. Inspection Scope

The team reviewed the portion of the emergency lighting system required for alternative shutdown to verify that it was adequate to support the performance of manual actions required to achieve and maintain hot shutdown conditions and to illuminate access and egress routes to the areas where manual actions would be required. The team evaluated the locations and positioning of the emergency lights during a walkthrough of the alternative shutdown procedure.

The team verified that the licensee installed emergency lights with an 8-hour capacity, maintained the emergency light batteries in accordance with manufacturer recommendations, and tested and performed maintenance in accordance with plant procedures and industry practices. The team also reviewed the location of the emergency lights for a sample of areas to determine the adequacy of emergency lighting during control room evacuation events.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team verified that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs. Using these procedures, the team evaluated whether these components could be repaired in time to bring the plant to cold shutdown within the time frames specified in their design and licensing bases. The team verified that the repair

equipment, components, tools, and materials needed for the repairs were available and accessible on site.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

Out-of-Service Equipment The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing post-fire safe shutdown functions). The team also verified that the short-term compensatory measures compensated for the 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.

Manual Actions On December 21, 2005, the licensee committed to transition to National Fire Protection Association 805, 2001 Edition, in accordance 10 CFR 50.48(c). The post-fire safe shutdown methodology includes the use of operator manual actions in place of compliance with the requirements of 10 CFR Part 50, Appendix R, Section III.G.2.

Section III.G.2 establishes a combination of physical barriers, spatial separation, fire detection and automatic suppression systems to protect redundant trains of post-fire safe shutdown equipment located within the same fire area. The licensee implemented operator manual actions because of their failure to comply with the requirements described in Section III.G.2. During the period of reanalysis and transition to a fire protection program based on National Fire Protection Association 805, manual actions may be acceptable as compensatory measures if they are feasible and reliable.

The team used the guidance in Inspection Procedure 71111.05TTP, Enclosure 2, to assess whether the licensee had established feasible manual actions that could be reliably completed. The team reviewed Procedure OP-901-524, "Offnormal Procedure Fire in Areas Affecting Safe Shutdown," Revision 3, for the selected fire areas. The team conducted walkthroughs with qualified plant operators of the manual actions. The team verified that the operators could perform all actions using the current plant procedures. The team also conducted a tabletop walkthrough with operators to review the interaction between the fire emergency procedures and the other procedures, which they would use during a plant shutdown following a fire.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

[OA]

4OA2 Identification and Resolution of Problems

Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team selected a sample of condition reports associated with the fire protection program to verify that the licensee had an appropriate threshold for identifying deficiencies. In addition, the team reviewed the corrective actions proposed and implemented to verify that they were effective in correcting identified deficiencies.

b. Observations and Findings

The team selected the diesel-driven fire pumps as a component to perform a detailed review. The team reviewed the performance history for the last 10 years. From review of the condition reports the team determined that the licensee continued to have troubles with diesel fire pump batteries and chargers. The licensee determined in 1999 that the charger had issues with the electrolytic capacitors, which resulted in overcharging and premature failure of the batteries. The team further determined that circuit breaker issues challenged operability of the diesel-driven fire pumps. The team concluded that the licensee addressed an apparent pattern of problems as isolated incidents with regards to the diesel-driven fire pumps and the related battery circuits on both pumps for an extended period of time.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the inspection results to Mr. K. Nichols, Director, Engineering, and other members of the licensee staff at an exit meeting on May 22, 2009. The licensee acknowledged the findings presented. The inspectors returned all proprietary information reviewed during this inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Becker, Fire Protection Engineer

B. Briner, Technical Specialist IV, Component Engineering

C. Fugate, Assistant Manager, Operations

D. Gallodoro, Senior Engineer, Design Engineering

M. Haydel, Programs Engineering Supervisor

B. Hardin, Supervisor, Control Room

J. Hoss, Senior Engineer

J. Kowalewski, Vice President of Operations

B. Lanka, Manager, Design Engineering

T. Moore, Senior Maintenance Specialist

R. Murillo, Manager, Licensing

K. Nicholas, Director, Engineering

J. Pollock, Licensing Engineer

B. Proctor, Manger, Systems Engineering

R. Putnam, Manager, Engineering Programs and Components

P. Wood, Supervisor, Control Room

NRC Personnel

M. Ashlee, Enforcement Coordinator, Office of Nuclear Reactor Regulation

P. Bonnett, Senior Reactor Analyst, Inspection Programs Branch, Office of Nuclear Reactor

Regulation

M. Haire, Senior Enforcement Specialist, Office of the Regional Administrator, Region IV

ITEMS OPENED AND CLOSED

Opened and Closed

05000382/2009006-01 NCV Failure to identify conditions adverse to fire protection

(Section 1R05.04.b.1)05000382/2009006-02 FIN Failure to provide area wide sprinkler coverage as required

in an Appendix R,Section III.G.2.c fire area

(Section 1R05.04.b.2)05000382/2009006-03 FIN Failure to ensure post-fire safe shutdown valves could be

operated (Section 1R05.06.b)

Attachment