IR 05000387/2020012
| ML20301A482 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/27/2020 |
| From: | Glenn Dentel Engineering Region 1 Branch 2 |
| To: | Berryman B Susquehanna |
| Dentel G | |
| References | |
| IR 2020012 | |
| Download: ML20301A482 (15) | |
Text
October 27, 2020
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000387/2020012 AND 05000388/2020012
Dear Mr. Berryman:
On October 8, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Susquehanna Steam Electric Station, Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Susquehanna Steam Electric Station, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, X /RA/
Signed by: Glenn T. Dentel
Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety
Docket Nos. 05000387 and 05000388 License Nos. NPF-14 and NPF-22
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000387 and 05000388
License Numbers:
Report Numbers:
05000387/2020012 and 05000388/2020012
Enterprise Identifier: I-2020-012-0006
Licensee:
Susquehanna, LLC
Facility:
Susquehanna Steam Electric Station, Units 1 and 2
Location:
Berwick, PA
Inspection Dates:
September 21, 2020 to October 8, 2020
Inspectors:
C. Bickett, Senior Reactor Inspector
E. DiPaolo, Senior Reactor Inspector
D. Kern, Senior Reactor Inspector
Approved By:
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Susquehanna Steam Electric Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Diesel-Driven Fire Pump 3-Hour Fire Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000387,05000388/2020012-01 Open/Closed None (NPP)71111.21N.05 The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of Unit 1 License Condition 2.C.(6) and Unit 2 License Condition 2.C.(3) for failure to implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Review Report (FPRR) for the facility and as approved by the NRC. Specifically, Susquehanna failed to enclose the diesel-driven fire pump within a 3-hour rated fire enclosure as described in the FPRR.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
===71111.21N.05 - Fire Protection Team Inspection (FPTI)
Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===
The inspectors verified that the following systems credited in the approved fire protection program could perform their licensing basis function:
- (1) Fire Protection Water Supply System
- (2) Residual Heat Removal System
- (3) Automatic Depressurization System/Safety-Relief Valves
- (4) Fire Barrier System
Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the following fire protection program administrative controls were implemented in accordance with the current licensing basis:
- (1) Combustible Control Program
- (2) Fire Watch Program
Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors reviewed the following changes to ensure that they did not constitute an adverse effect on the ability to safely shutdown post-fire and to verify that fire protection program documents and procedures affected by the changes were updated:
- (1) Engineering Change 1544685, Fire Pump Replacement
INSPECTION RESULTS
Inadequate Diesel-Driven Fire Pump 3-Hour Fire Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000387,05000388/2020012-01 Open/Closed
None (NPP)71111.21N.05 The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of Unit 1 License Condition 2.C.(6) and Unit 2 License Condition 2.C.(3) for failure to implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Review Report (FPRR) for the facility and as approved by the NRC. Specifically, Susquehanna failed to enclose the diesel-driven fire pump within a 3-hour rated fire enclosure as described in the FPRR.
Description:
Both the motor-driven and diesel-driven fire pumps are located in close proximity within the Circulating Water Pump House. The diesel-driven fire pump is located inside an enclosure that was described by the SSES FPRR to be 3-hour fire rated to prevent both fire pumps from being damaged by a single fire, thus affecting their capability to provide fire protection water during an event. During a tour of the Circulating Water Pump House, the team observed a gap, approximately 1-inch wide, in the junction of the diesel-driven fire pump enclosure cinder block wall and the Circulating Water Pump House interior wall. The gap was filled with an unknown board-type material that resembled polystyrene. The team questioned whether the gap and material were depicted on fire barrier drawings of the enclosure.
Construction drawings of the Circulating Water Pump House showed the diesel-driven fire pump enclosure walls were 3-hour fire rated but did not depict or note the gap or the filler material. The team noted that the drawings specified the rooms ceiling was a poured concrete slab with a gap between the slab and Circulating Water Pump House wall. That gap was specified to be filled with a compressible material.
Susquehanna sampled the filler material, concluded it was most likely polystyrene, and that the material was combustible. As a result, the team concluded that Susquehanna failed to enclose the diesel-driven fire pump within a 3-hour rated fire enclosure as described in the FPRR, and both fire pumps were not assured protection from being damaged by a single fire.
Corrective Actions: Susquehanna declared the diesel-driven fire pump room fire barrier non-functional and established an hourly fire watch as a compensatory measure. Susquehanna performed an evaluation of the configuration per NRC Generic Letter 86-10. That evaluation concluded the deficient condition did not negatively impact the barriers ability to prevent a single fire from disabling both the motor-driven and diesel-driven fire pumps.
Corrective Action References: CR-2020-13254 and CR-2020-13799
Performance Assessment:
Performance Deficiency: The team determined that the failure to enclose the diesel-driven fire pump within a 3-hour fire rated enclosure, as described in Section 4.1 of the SSES FPRR, was a performance deficiency that was within Susquehannas ability to foresee and correct.
As a result, both fire pumps (i.e., the motor-driven fire pump and the diesel-driven fire pump)were not assured protection from being damaged by a single fire.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to enclose the diesel-driven fire pump within a 3-hour rated enclosure did not assure that both fire pumps were protected from being damaged by a single fire which could have affected their capability to provide fire protection water during a fire event. In addition, this finding is more than minor because it was similar to Example 3.g of IMC 0612, Appendix E, Examples of Minor Issues. Regardless of the final operability or functionality, the as-found condition was such that there was reasonable doubt with respect to the availability, reliability or capability of systems.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Appendix F was applicable in this case because the finding was associated with fire water supply systems. This issue screened as Green in Step 1.4.3 because adequate fire water capacity was still available for protection of equipment important to safe shutdown in the most limiting location onsite. Susquehanna performed a detailed evaluation of the arrangement in the Circulating Water Pump House.
The evaluation concluded that the deficient condition did not negatively impact the degraded fire barriers ability to prevent a single fire from disabling both the motor-driven and diesel-driven fire pumps. In addition, the site is equipped with a backup diesel-driven fire pump, remote to the Circulating Water Pump House, that could be placed in service per plant operating procedures.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The installation of the non-fire rated material used as a fire barrier was performed during the construction of the diesel-driven fire pump enclosure. Although a periodic inspection is performed on Circulating Water Pump House fire barriers, the scope of the inspection was to visually identify degradation that could prevent barriers from meeting their design function. The inspectors concluded that identification of incorrect fire barrier material was beyond the scope of the periodic inspection.
Enforcement:
Violation: Unit 1 License Condition 2.C.(6) and Unit 2 License Condition 2.C.(3), in part, requires Susquehanna Nuclear, LLC to implement and maintain in effect all provisions of the approved fire protection program as described in the FPRR for the facility and as approved by the NRC. SSES FPRR, Section 4.1, Fire Protection Water Supply System, stated that the diesel-driven fire pump is enclosed within a 3-hour fire rated enclosure which prevents both fire pumps (i.e., the motor-driven fire pump and the diesel-driven fire pump)from being damaged by a single fire.
Contrary to the above, since July 17, 1982, the effective date of the Unit 1 operating license, until September 24, 2020, when the issue was entered into the corrective action program, Susquehanna failed to enclose the diesel-driven fire pump within a 3-hour fire rated fire enclosure which prevents both fire pumps from being damaged by a single fire.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 8, 2020, the inspectors presented the triennial fire protection inspection results to Mr. Brad Berryman and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N.05 Calculations
EC-013-0852
Evaluation for Identification and Disposition of Appendix R
Section III.G Non-Compliant Cables
Revision 1
EC-013-1031
Documentation to Support Qualification of the Penetration
Seal Installation at SSES
Revision 3
EC-013-1040
Combustible Loading Data for Input to CRIMP
Revision 5
EC-013-1040
Combustible Loading Data for Input to CRIMP
Revision 5
EC-013-1873
Operator Manual Actions Feasibility Analysis
Revision 4
EC-018-0843
SSES 10 CFR 50 Appendix R Compliance Manual
Revision 47
EC-083-0660
Number of Open SRVs Required in Shutdown Cooling
Revision 1
EC-PUPC-20400
EPU Task Report T0400 - Containment System Response
Revision 5
EC-THYD-1064
MAAP Analysis of Appendix R Scenarios
Revision 3
Corrective Action
Documents
CR 2018-08886
CR-2016-22822
CR-2017-19925
CR-2018-02016
CR-2018-06103
CR-2018-07710
CR-2018-14540
CR-2018-16833
CR-2018-17185
CR-2019-04113
CR-2019-12711
CR-2019-13600
CR-2020-07321
CR-2020-11023
CR-2020-12789
NCR 87-0898
Corrective Action
Documents
Resulting from
Inspection
AR-2020-12955
AR-2020-13012
AR-2020-13081
AR-2020-13149
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AR-2020-13241
AR-2020-13247
CR-2020-13030
CR-2020-13032
CR-2020-13103
CR-2020-13229
CR-2020-13230
CR-2020-13254
CR-2020-13270
CR-2020-13271
CR-2020-13419
CR-2020-13439
CR-2020-13570
CR-2020-13756
CR-2020-13771
CR-2020-13779
CR-2020-13782
CR-2020-13783
CR-2020-13851
CR-2020-13896
CR-2020-13899
CR-2020-13912
Drawings
D-107415
Fire Protection Engine Driven Fire Pump Control Scheme
0S1401, Sheet 1
Revision 12
D-193314
Circuit Breaker Interruption Impact Diagram 208/120V AC
Panel 1Y629, Sheet 54
Revision 7
E-105012, Sheet
Circulating Water Pumphouse Water Treatment Building
Fire Protection
Revision 5
E-105566
Circulating Water Pumphouse and Water Treatment
Building Sections and Details
Revision 3
E-106227,
Sheets 1, 2, 3,
and 6
Fire Protection System
Revision 61
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
E-266
Motor Driven Fire Pump 0P512 and Jockey Fire Pump
0P543, Sheets 1 and 2
Revision 14
E-690, Sheet 1
Appendix R Safe Shutdown Manual Actions List
Revision 8
Engineering
Changes
Fire Pump Replacement Project
Revision 9
Engineering
Evaluations
86-10 Fire Hazards Analysis Evaluation for Diesel-Driven
Fire Pump Fire Barrier Gap
10/06/2020
Fire Protection Screening Document 00109, Fire Pump
Replacement
01/16/2015
Maintenance Rule Evaluation 0S573 (Back-up Diesel
Driven Fire Pump) Charge Air Cooler Gasket Leak
07/16/2020
50.59 SD 02291
Maintaining Door 571D in the Open Position
Revision 0
C-1072
Specification for the Inspection of Fire Barriers for
Compliance with PPL Susquehanna LLC Technical
Requirements Manual
Revision 6
CR 1198879
Evaluation of NRC Information Notice 2009-29, Potential
Failure of Fire Water Supply Pumps to Automatically Start
Due to a Fire
E-1012
Electrical Separation Criteria
Revision 2
EC-013-1027
Technical Evaluation of Fire Barrier Surveillance
Requirements
Revision 8
Engineering
Investigate the Physical Separation of Cable for 0P512
and 0P511
01/31/2007
FPSD 00160
Fire Protection Program Screen for Maintaining Door 571R
in the Open Position
Revision 0
SSES-1-LI-012-
ME-002-R0
Fire Pump Upgrade Replacement Project-Code
Compliance Review
Revision 0
Miscellaneous
Vendor Manual 0S573M JU/JW/JX Models Electronic
Engines for Fire Pump Applications
March 2017
Susquehanna Steam Electric Station Fire Protection
Review Report
Revision 24
Time Critical and Time Sensitive Operator Action
Validation per NDAP-QA-0343
2016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
TCOA Event #34 Validation
10/05/2020
Vendor Technical Manual-Torna Tech-Operation,
Installation and Maintenance for Diesel Engine Fire Pump
Controller, Model GPD
9502-09
TRAK2000 Cable Management System (CRIMP) Software
Verification & Validation Results Report
Revision 20
IEEE Trial-Use Standard Criteria for Separation of Class
1E Equipment and Circuits
IEEE Standard Criteria for Independence of Class 1E
Equipment and Circuits
LDCN 5331
Fire Water Treatment Technical Change
01/05/2018
NFPA 20-1974
Centrifugal Fire Pumps
OT-013-019
Diesel Driven Fire Pump 0P511 Performance Test
August 2019
OT-013-020
Motor Driven Fire Pump 0P512 Performance Tes
January
2019
OT-013-021
Backup Diesel Driven Fire Pump 0P592 Performance Test
June 2020
PT-013-042
Month Inspection of Non-Reg Fire Rated
Assemblies/Barrier
Revision 8
SO-013-001
Monthly Diesel and Motor Driven Fire Pump Run
August 2020
SO-013-001B
Monthly Backup Diesel Fire Pump Run
August 2020
EC 1544685 Partial 3 Initial Field Acceptance Testing
October
2016
EC 1544685 Partial 2 Initial Field Acceptance Testing
October
2016
EC 1544685 Partial 1 Initial Field Acceptance Testing
December
2015
TRM 3.7.3
Suesquehanna Unit 1 Technical Requirements Manual,
Fire Protection
03/31/2006
Procedures
RHR Abnormal Operating Procedure
Revision 4
Core Spray Abnormal Operating Procedure
Revision 2
DC-OP-011
Post-Fire Recovery Actions
Revision 18
EO-100-030
Unit 1 Response to Station Blackout
Revision 40
LA-0526-001
Diesel Fire Pump Control Panel 0C526
Revision 5
NDAP-QA-0101
Document Review
Revision 8
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NDAP-QA-0343
Time Critical and Time Sensitive Operator Actions
Revision 4
NDAP-QA-0440
Control of Transient Combustible/Hazardous Materials
Revision 23
NDAP-QA-0443
Firewatch Procedure
Revision 17
NDAP-QA-0446
Fire Barrier Program
Revision 11
NDAP-QA-0449
Revision 19
NSEP-AD-0440
Fire Protection Program License Renewal Program Basis
Document
Revision 23
ON-013-001
Response to Fire
Revision 50
ON-SDC-101
Loss of Shutdown Cooling
Revision 4
OP-013-001
Fire Protection System
Revision 61
OP-013-003
Backup Fire Protection System
Revision 35
24-Month Inspection of Common Fire Rated Penetration
Seals
Revision 13
Month Inspection of Unit Common Fire Barriers
Revision 12
Month Inspection of Common Fire Doors
Revision 14
Month Inspection of Fire Windows/Fire Dampers and
Associated Hardware
Revision 7
Unit 1 24 Month Inspection of Fire Rated Penetration
Seals
Revision 12
Month Inspection of Unit 1 Fire Barriers
Revision 14
Month Inspection of Unit 1 Fire Doors
Revision 12
Unit 2 24 Month Inspection of Fire Rated Penetration
Seals
Revision 11
Month Inspection of Unit 2 Fire Barriers
Revision 14
Month Inspection of Unit 2 Fire Doors
Revision 13
SO-100-007
Daily Operations Surveillance
09/17/2020
SO-200-007
Unit 2 Daily Operations Surveillance
09/16/2020
Self-
Assessments
Fire Protection Program Self-Assessment
08/10/2020
Work Orders
RTSV 1910271
RTSV 1910555
RTSV 1910555
RTSV 1996346
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RTSV 2004186
RTSV 2072714
RTSV 2077949
RTSV 2170087
RTSV 2184813