IR 05000391/2014612

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IR 05000391/2014612, on 12/19/2014, Watts Bar Nuclear Plant, Unit 2, Construction Fire Protection Program Inspection
ML15034A211
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 02/02/2015
From: Scott Shaeffer
NRC/RGN-II/DRS/EB2
To: Skaggs M
Tennessee Valley Authority
References
IR 2014612
Download: ML15034A211 (43)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 2, 2015

SUBJECT:

WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION FIRE PROTECTION PROGRAM INSPECTION, NRC INSPECTION REPORT NO. 05000391/2014612

Dear Mr. Skaggs:

On December 19, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of construction activities at your Watts Bar Unit 2 reactor facility. The enclosed inspection report documents the inspection results, which were discussed on December 19, 2014, with you and other members of your staff.

This inspection examined the licensees readiness in the area of fire protection, fire safe shutdown procedures, and operator manual actions to support future licensing. The majority of the items reviewed were not currently required under the existing Watts Bar Unit 2 construction permit. Items identified and described in this report which the NRC determined as not meeting the Unit 1/Unit 2 As-Constructed Fire Protection Report require corrective actions. The NRC staff will evaluate your resolution for these items during subsequent inspections.

Based on the results of this inspection, no findings were identified during this inspection.

In accordance with 10 Code of Federal Regulations (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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have questions concerning this letter, please contact us.

Sincerely,

/RA/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-391 Construction Permit No: CPPR-92

Enclosure:

Inspection Report 05000391/2014612 w/Attachment

REGION II==

Docket No: 50-391 Construction Permit No: CPPR-92 Report No: 05000391/2014612 Applicant: Tennessee Valley Authority (TVA)

Facility: Watts Bar Nuclear Plant, Unit 2 Location: Spring City, TN 37381 Dates: October 20 - 24, 2014 November 17 - 21, 2014 December 15 - 19, 2014 Inspectors: O. López-Santiago, Senior Reactor Inspector D. Jones, Senior Reactor Inspector R. Fanner, Reactor Inspector P. Braxton, Reactor Inspector M. Singletary, Reactor Inspector J. Dymek, Reactor Inspector E. Patterson, Resident Inspector Approved by: S. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

This team inspection included aspects of engineering and construction activities performed by

TVA associated with the Watts Bar Nuclear (WBN) Plant Unit 2 construction project. This report covered a three-week period of inspections in the areas of operational readiness activities (Fire Protection), and follow-up of other activities. The inspection program for Unit 2 construction activities is described in Nuclear Regulatory Commission (NRC) Inspection Manual Chapter (IMC) 2517, Watts Bar Unit 2 Construction Inspection Program. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be found at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html.

Inspection Results

  • No findings were identified in the fire protection area. However, the inspectors were unable to accomplish all the inspection objectives due to observations identified regarding feasibility and reliability of operator manual actions; validation of technical basis for fire safe shutdown procedures; lack of surveillance procedures for some fire protection features; degraded fire penetrations; and completion of work related to the installation of Unit 2 Containment fire protection features, emergency lights, and emergency communication equipment. Items identified and described in this report which the NRC determined as not meeting the Unit 1/Unit 2 As-Constructed Fire Protection Report require corrective actions. The NRC staff will evaluate your resolution for these items during subsequent inspections.
  • The inspectors concluded that issues pertaining to several open items, including two Bulletins, one Generic Letter, and one construction deficiency report have been appropriately addressed for WBN Unit 2. These items are closed.

REPORT DETAILS

Summary of Plant Status

During the inspection period covered by this report, Tennessee Valley Authority (TVA)performed construction completion and preoperational testing activities on safety-related systems and continued engineering design activities of the Watts Bar Nuclear (WBN) Plant, Unit 2 (U2).

III.

OPERATIONAL READINESS ACTIVITIES F. 1 Fire Protection This inspection was conducted in accordance with applicable portions of Inspection Procedures (IPs) 64704 - Fire Protection Program; 64100 - Post-fire Safe Shutdown, Emergency Lighting and Oil Collection Capability at Operating and Near-Term Operating Reactor Facilities; and 71111.05T - Fire Protection (Triennial) as a guidance document. The objective of the inspection was to review a sample of fire risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP) as described in the Watts Bar Nuclear Plant Unit 1/Unit 2 As-Constructed Fire Protection Report (FPR). The FAs were selected 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. The FAs chosen were identified as follows:

  • FA 29, Room 757.0-A22, 125-V Vital Battery Board Room IV (Analysis Volume (AV) -

055)

  • FA 31, Room 757.0-A24, 6.9 KV & 480-V Shutdown Board Room B (AV-057)
  • FA 48, Room 692.0-C9, Communications Room (AV-076 & AV-076A)
  • FA 60, Room 711.IPS - Electrical Board Room, 480-V Board Room (AV-089)
  • FA 42, Room 772.0-A12, 480-V Transformer Room 2A (AV-069)

In addition, the inspection included a review of fire protection features added for Unit 2 operation to verify that installation was in compliance with the As-Constructed FPR and applicable National Fire Protection Association (NFPA) Codes.

F.1.1 Postfire Safe Shutdown, Emergency Lighting and Oil Collection Capability at Operating and Near-Term Operating Reactor Facilities (IP 64100)02.01 Section III.G.2, Redundant Train Safe Shutdown Capability 1. Protection of Redundant Train Safe Shutdown Capability

a. Inspection Scope

The inspectors reviewed the piping and instrumentation diagrams, safe shutdown analysis, and safe shutdown equipment list to verify that the shutdown methodology had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for equipment in the fire areas/analysis volumes selected for review. For each of the selected fire areas/analysis volumes, the inspectors reviewed the adequacy of separation and protection provided for the redundant train of cables and equipment required to achieve and maintain hot shutdown conditions.

On a sample basis, the inspectors verified that the systems and equipment identified by the licensee as being required to achieve and maintain hot shutdown conditions would remain free of fire damage in the event of a fire in the selected fire areas/ analysis volumes. Specifically, the inspectors evaluated the adequacy of electrical independence, physical separation, and fire protection features provided for cables and equipment needed to assure the operation of systems that were relied on to achieve and maintain hot shutdown conditions in the event of a fire. The evaluation included a review of cable routing data for a sample of components. The specific components selected for review are listed in the attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that protection of redundant train safe shutdown capability was ready for implementation as described in the As-Constructed FPR.

2. Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The inspectors verified that redundant trains of systems required for hot shutdown, including dual unit shutdown, which were located in the same fire area, were not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. The inspectors evaluated whether manual water-based firefighting activities from fires within the selected FAs could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local operator actions required for SSD. The inspectors reviewed calculations of suppression system discharge, drainage capacity of floor drains and estimated water accumulations relative to the submergence of electrical equipment. Fire Strategies (pre-fire plans); fire brigade training procedures, and abnormal procedures for fire events were also reviewed to verify that inter-area migration of water would not adversely affect SSD equipment or the performance of operator manual actions. Walkdowns of the selected FAs were performed to confirm that drains were open and free of debris and that electrical equipment was curbed or elevated where submergence was possible.

b. Observations and Findings

The inspectors noted that pre-fire plans for the selected FAs did not address strategies for managing water runoff during and after fire events to ensure that fire SSD equipment was not adversely impacted. The licensee entered this condition in their corrective action program as PER 969435.

No findings were identified.

c. Conclusions

The inspectors concluded that equipment necessary for SSD would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.

3. Circuit Analyses

a. Inspection Scope

The inspectors reviewed the licensees post-fire safe shutdown analysis and the As-Constructed FPR to verify that the licensee had identified both required and associated circuits that may impact SSD. On a sample basis, the inspectors verified that the cables of equipment required for achieving and maintaining safe shutdown conditions, in the event of fire in the selected FAs, had been properly identified. In addition, the inspectors verified that these cables had either been adequately protected from the potentially adverse effects of fire damage, mitigated with approved manual operator actions, or analyzed to show that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent SSD. In order to accomplish this, the inspectors reviewed electrical schematics and cable routing data for power and control cables associated with each of the selected components. In addition, on a sample basis, the adequacy of circuit protective coordination for the safe shutdown systems electrical power and instrumentation busses were evaluated. A review of the licensees fuse replacement procedure was conducted to determine if adequate administrative controls exist to prevent the inadvertent substitution of incorrectly sized fuses in critical circuits.

Additionally, a review was conducted of cable routing information for the motor drive fire pumps. The components reviewed are listed in the attachment.

The inspectors also reviewed logic diagrams and circuitries of the diesel generators to verify that postulated spurious signals would not prevent the diesels from performing their function if needed to safely shutdown the plant.

b. Observations and Findings

No findings were identified.

c. Conclusions

Based upon the review of protection of circuit required for safe shutdown, the inspectors concluded that the reviewed activities were ready for implementation as described in the As-Constructed FPR.

4. Cold Shutdown Repairs

a. Inspection Scope

The inspectors sought to review the licensee procedures, equipment, and materials credited for repairing components required for cold shutdown. The inspectors sought to review and verify that repair equipment, components, tools, and materials (e.g., pre-cut cable connectors with prepared attachment lugs) were available and accessible on site to plant personnel.

b. Observations and findings No findings were identified.

c. Conclusions

At the time of the inspection, the licensee had not developed procedures to incorporate cold shutdown repairs. This inspection item will remain open until inspection activities are conducted to verify adequacy of cold shutdown repairs procedures.

5. Manual actions as compensatory measures for SSD

a. Inspection Scope

For the selected FAs, the inspectors reviewed the applicable attachments specified in Procedure 0-AOI 30.2, Fire Safe Shutdown, Rev. 0 to assess the applicable information to relevant design requirements specified in calculations, the As-Constructed FPR, training material, and other applicable reference materials. The inspectors reviewed applicable job performance measures (JPM) to assess the training aspects of operators.

The inspectors verified a subset of operator manual actions (OMAs) to determine if these were feasible and reliable. To assess the feasibility and reliability of the OMAs, the inspectors used the guidance provided in IP 71111.05T, paragraph 02.02.j.2, and NUREG/CR 1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire.

b. Observations and Findings

The inspectors identified multiple observations with the reviewed procedures regarding lack of technical basis for procedure steps, verification and validation of analysis assumptions, and inadequate flow down of design requirements to the procedures. The identified observations included:

  • Calculation EPMSMC110292, Section 4.0, Assumptions, stated in part the basis for establishing natural circulation cooldown from hot standby to cold shutdown. The calculation specified a cooldown rate of 17 degrees Fahrenheit per hour yet procedure 0-AOI-30.2 C28, Step 26.2.2 specified a rate of 25 degrees Fahrenheit.

The inspectors identified that this inconsistency did not have a technical basis. The licensee captured this condition in the corrective action program as PER 970586.

  • Job performance measure, 3-OT-JPMA047C006023847, Operate Steam Generator (S/G) #1 AND #2 TD AFW LCVS (Locally With N2) Per SOI- 3.02, Performance Step: [2.6], directed the performer to check pressure indicator, 1-PI-3-400D and to verify that pressure was within 85 to 95 psig. This JPM supported the auxiliary feedwater system description, WBN-SDD-N3-3B-4002. The reviewed procedure did not provide clear actions to throttle the level control valves (LCVs) associated with auxiliary feedwater. System description WBN-SDD-N3-3B-4002 stated that the operator must go to one of the emergency control stations just outside the South Main Steam Valve Room and manually align the high pressure nitrogen bottles and associated piping to take local manual control of the LCVs.
  • Procedure 0-AOI-30.2 C.30, Step 13.4 required the operator to control S/G flow to S/Gs #1 and #2 using 0-LIC-3-164 and 0-LIC-3-156. The procedure did not provide steps to take local manual control of the LCVs.

The licensee captured these conditions in the corrective action program as PER 914685.

  • Calculation EDQ00099920090016, Rev 2, Appendix R - Units 1 & 2 Manual Action Requirements, Section B.21, stated in part that the Watts Bar Appendix R analysis did not support liquid letdown through the pressurizer power operated relieve valves (PORVs) since adequate pressure control for maintaining subcooling margin for natural circulation cooldown was difficult. The calculation further stated that the head vents should be used for reactor coolant system (RCS) letdown and the pressurizer PORVs should be used for RCS pressure control only. The inspectors identified the following:
  • Procedure 0-AOI-30.2 C.30, Step 22 directed operators to use the A train pressurizer PORV to control pressure for Unit 1 and Unit 2. However, 0-AOI-30.2 C.30, Step 23 and Step 24 allowed operators to use either A or B head vents or A train pressurizer PORVs for RCS letdown control.
  • Procedure 0-AOI-30.2 C28, Step 27 directed operators to use the A train pressurizer PORV to control RCS pressure for Unit 1 and Unit 2. However, 0-AOI-30.2 C28, Step 28.2 gave the operator the option to use the PORV for RCS letdown.

The licensee captured these conditions in the corrective action program as PER 960956.

  • The licensee did not provide suitable procedural guidance for operating the emergency raw cooling water (ERCW) system during fire events at the Intake Pumping Station. The inspectors determined that Procedure 0-AOI-30.2, C.62, did not provide specific guidance on which ERCW pumps to operate. The additional guidance was required because pumps on both trains would be unavailable because of postulated fire damage. The licensee captured this condition in the corrective action program as PER 960916.

No findings were identified.

c. Conclusions

The inspectors concluded that manual actions as compensatory measures for SSD were not ready for implementation as described in the As-Constructed FPR. Additional inspection activities are required to verify adequacy of corrective actions and extent of condition reviews conducted by the licensee.

02.02 Sections III.G.3 and III.L, Alternate and Dedicated Shutdown 1. Alternate Shutdown Capability

a. Inspection Scope

The inspectors verified that WBN Dual Unit's alternative shutdown methodology had properly identified the systems and components necessary to achieve and maintain SSD. The inspectors reviewed the As-Constructed FPR, FHA, the licensees plant procedures, system flow diagrams, electrical drawings, and other supporting documents for postulated fires in the Control Building. The inspectors also conducted a walkdown of the Auxiliary Control Room (ACR) and interviewed the licensee about the differences between Unit 1 and Unit 2 ACRs. The review included assessing whether hot shutdown from outside the main control room (MCR) could be implemented, and that transfer of control from the MCR to the ACR could be accomplished. The inspectors also verified that electrical isolation was provided for the ACR from the MCR. In addition, the inspectors evaluated the effect of fires to the new digital control system for pressurizer level control and charging / letdown controls.

b. Observations and Findings

No findings were identified.

c. Conclusions

Based upon the review of alternate shutdown capability, the inspectors concluded that the reviewed activities were ready for implementation as described in the As-Constructed FPR.

2. Cold Shutdown Repairs

a. Inspection Scope

and Findings The inspectors sought to review the licensee procedures, equipment, and materials credited for repairing components required for cold shutdown. The inspectors sought to review and verify that repair equipment, components, tools, and materials (e.g., pre-cut cable connectors with prepared attachment lugs) were available and accessible on site to plant personnel.

b. Conclusions

At the time of the inspection, the licensee had not developed procedures to incorporate cold shutdown repairs. This inspection item will remain open until inspection activities are conducted to verify adequacy of cold shutdown repairs procedures.

3. Manual actions as compensatory measures for SSD

a. Inspection Scope

For the selected FAs, the inspectors reviewed Procedure 0-AOI-30.1, Plant Fires, Rev. 0 and the applicable attachments specified in Procedure 0-AOI 30.2, Fire Safe Shutdown, Rev. 0 to assess the applicable information to relevant design requirements specified in calculations, the As-Constructed FPR, training material, and other applicable reference materials. The inspectors selected a subset of OMAs to determine if these were feasible and reliable. To assess the feasibility and reliability of the OMAs, the inspector used the guidance provided in IP 71111.05T, paragraph 02.02.j.2, and NUREG/CR 1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire.

b. Observations and Findings

The licensee developed a new series of abnormal operating instructions (AOIs) to achieve safe shutdown conditions for Units 1 and 2 during fire events. The AOIs included required performance times for specified operator actions; the licensee determined the performance times in Calculation EDQ00099920090016, Appendix R -

Units 1 & 2 Manual Action Requirements, Rev. 3. The inspectors identified the following observations that were associated with the fire AOIs and Calculation EDQ00099920090016:

  • The procedural guidance provided to recall Auxiliary Unit Operators (AUOs) to the MCR during fire events would not provide reasonable assurance that the AUOs would be promptly recalled to MCR. Specifically, the inspectors determined that the fire verification methodology as described in the As-Constructed FPR was not effectively translated into procedure 0-AOI-30.1, Plant Fires. The licensee submitted a correction to this observation in a revision to the As-Constructed FPR (ADAMS Accession No. ML15010A054.)
  • The licensee incorrectly calculated a parameter associated with the cold leg accumulators. The inspectors determined that the licensee did not consider instrument uncertainty when determining the minimum pressure for isolating the cold leg accumulators. The non-conservative value was translated into Procedure 0-AOI-30.2, Appendix D, Rev. 0. The licensee captured this condition in the corrective action program as PER 967401.
  • The guidance in Procedure AOI 30.2, C.69 would not assure that main feedwater isolation and bypass valves would be closed within the calculated time when evacuating the main control room during a fire event. The licensee captured this condition in the corrective action program as PER 967896.
  • The licensee did not provide suitable guidance for reducing RCS inventory in the fire procedures. The procedures allowed RCS inventory letdown via the pressurizer PORV which was different from the design output in Calculation EDQ00099920090016. The licensee captured this condition in the corrective action program as PER 962419.
  • The cooldown criteria in the AOIs were different than the criteria stated in Calculation EDQ00099920090016. The licensee captured this condition in the corrective action program as PER 970586.
  • The procedural guidance provided to control RCS pressure would not ensure that the pressure would be greater than the shut-off head of the safety injection pumps for one hour. The inspectors noted that Calculation EDQ00099920090016 assumed that plant cool down and depressurization would not be initiated prior to 60 minutes.
  • The licensee did not provide suitable procedural guidance for maintaining sub-cooling margin. The inspectors determined that that the magnitude of the required sub-cooling margin that was listed in the fire procedures - combined with the lack of detailed guidance for achieving plant cooldown and depressurization - would result in many of the Calculation EDQ00099920090016 computations being invalidated. The licensee captured this condition in the corrective action program as PER 969421.
  • The licensee incorrectly calculated in Calculation EDQ00099920090016 an operator action performance time associated with preventing SG overfill. The inspectors determined that the license did not account for steam generator water level instrument uncertainty and incorrectly assumed a constant steam flow from the SG safety relief valve. The licensee captured this condition in the corrective action program as PER 972134.
  • The licensee did not provide suitable procedural guidance for cold overpressure protection system when abandoning the main control room. The inspectors noted that Procedure C.69 included a note that stated that the cold overpressure mitigation system would not be available from the auxiliary control room. The licensee did not include any alternative guidance or compensatory measures in the procedure for the loss of the system. The licensee captured this condition in the corrective action program as PERs 972066 and 970587.
  • The licensee did not state the time requirement for an action associated with starting and loading the emergency diesel generators in procedure C. 69. The inspectors noted that a 340 seconds time critical action (WBN-SDD-N3-82-4002, Standby Diesel Generator System, Rev. 17) was not translated into the fire procedure.

Additionally, a supporting calculation that determined the 340 seconds requirement must be re-performed because it could not be located by the licensee. The licensee captured this condition in the corrective action program as PER 824165.

  • The licensee did not provide suitable procedural guidance for solid plant operations when abandoning the main control room. The inspectors determined that guidance in the fire procedure conflicted with other design requirements. During the inspection, the licensee noted that the safe shutdown analysis did not rely on solid plant operations; and plans to remove solid plant operations from the procedure.

The licensee captured this condition in the corrective action program as PER 972060.

  • The licensee did not provide suitable procedural guidance for operating the reactor vessel vent throttle valves. The inspectors noted that document WBN-SDD-N3-68-4001, Reactor Coolant System, Rev. 31, stated that reactor vessel vent throttle valves shall be opened slowly such that it takes a minimum of five
(5) seconds for the valve opening stroke to be completed. The inspectors determined that this guidance was not translated into the fire AOIs. The licensee captured this condition in the corrective action program as PER 969430.

No findings were identified.

c. Conclusions

The inspectors concluded that manual actions as compensatory measures for SSD were not ready for implementation as described in the As-Constructed FPR. Additional inspection activities are required to verify adequacy of corrective actions and extent of condition reviews conducted by the licensee.

02.03 Section III.J, Emergency Lighting

a. Inspection Scope

The As-Constructed FPR, Part II, Section 12.7 states that in accordance with the requirements of 10 CFR 50 Appendix R, Section III.J, eight-hour emergency battery pack lighting is provided in areas required for manual operation of safe shutdown equipment and in the access/egress routes to these areas. Additionally, the FPR states that operators carry an alternate battery lighting (portable hand held lantern) when they are directed to perform a required OMA based upon the fire effects.

The inspectors sought to review installation, design aspects, and maintenance of the fixed 8-hour battery pack emergency lighting units required by 10 CFR 50 Appendix R, Section III.J and the As-Constructed FPR. The inspectors walked down steps of the post-fire SSD procedures for the selected FAs to observe the placement and coverage area of the lights required to illuminate operator access and egress pathways, and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD.

b. Observations and Findings

The inspectors were informed by the licensee that Watts Bar Unit 2 has numerous areas in which the battery powered emergency lights are either missing or inadequate. The licensee is currently in the process of installing new eight - hour emergency lighting units. The installation is being done under DCN-54871.

No findings were identified.

c. Conclusions

At the time of the inspection, the licensee had not completed the installation of required emergency lighting units required for Dual Unit operations. This inspection item will remain open until inspection activities are conducted to verify the installation and adequacy of emergency lighting units and as part of the follow-up inspection for CDR 83-

61.

02.04 Section III.O, Oil Collection Systems for Reactor Coolant Pumps (RCP)

a. Inspection Scope

The inspectors sought to verify that the design and installation of the RCPs oil collection system was in compliance with Section III.O of Appendix R.

b. Observations and Findings

The licensee informed the inspectors that the RCPs oil collection system was currently being installed and tested to ensure compliance with Section III.O of Appendix R. The work is being done as part of the corrective actions for CDR 81-88 and CDR 84-32.

No findings were identified.

c. Conclusions

At the time of the inspection, the licensee had not completed the installation of the oil collection system for the reactor coolant pumps. This inspection item will remain open until inspection activities are conducted to verify the installation of the reactor coolant pumps oil collection system units.

F.1.2 Fire Protection Program (IP 64704)02.02/03 Procedures to Implement the Entire Fire Protection Program 1. Combustible Material Control, Housekeeping, and Fire Hazard Reduction

a. Inspection Scope

The inspectors verified that the control of transient combustibles program was revised to incorporate Dual Unit operations. 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 As-Constructed FPR, and Procedures NPG-SPP-18.4.7, Control of Transient Combustibles, Rev. 5 and TI-211, Fire Protection, Rev. 6. 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 As-Constructed FPR and administrative procedures.

The inspectors observed the licensee perform an inspection of transient combustibles in the Auxiliary Building in accordance with TI-211. The inspectors also reviewed a sample of transient combustible permits for Unit 2 activities to verify adequate implementation of the program.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the combustible control program was ready for implementation as describe in the As-Constructed FPR.

2. Administration / Fire Control Capabilities

a. Inspection Scope

The inspectors verified that fire protection equipment added for Unit 2 operation was included in the operating requirements (ORs) described in Part II of the As-Constructed FPR. 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 NPG-SPP-18.4.6, Control of Fire Protection Impairments, Rev 5 to verify that the impairment program was revised to incorporate Dual Unit operations.

The inspectors reviewed a sample of impairment permits for Unit 2 to verify adequate implementation of the program and to evaluate the adequacy of compensatory measures. The inspectors also reviewed impairment and compensatory measures forms for fire watches tours to confirm they were being performed within the allowable time frames. Hourly and roving fire watch personnel were interviewed to ascertain that their duties and responsibilities were properly understood.

b. Observations and Findings

The inspectors noted that the licensee did not prescribe appropriate compensatory measures for all fire areas adversely affected by the unavailability of the diesel driven fire pump. The licensee determined in the FHA that several fire areas would have inadequate fire suppression capability with the diesel fire pump out-of-service. As a result, the As-Constructed FPR prescribed compensatory measures for these fire areas.

The inspectors determined that the licensee did not identify a fire in the Control Building as an area that also required compensatory measures. The As-Constructed FPR stated that all motor driven fire pumps would be adversely affected in a Control Building fire.

The As-Constructed FPR, Part II, 14.2.1 did not list the Control Building as an area that required enhanced compensatory measures.

The licensee entered this issue in their corrective action program as PER 966670. The licensee committed to revise the appropriate 0-AOI-30.1 and 30.2 procedures to ensure the electric fire pumps remain running or are restarted as appropriate once the transfer switches are placed in the AUX position. The licensee stated that the electric fire pumps could be made available by operation of the transfer switches and associated start switches in the 480V Shutdown boards located in the Auxiliary Building. In addition, the licensee stated that the As-Constructed FPR needed be revised to address the availability of the motor driven fire pumps after transfer switch operation. Through the review of electrical and block diagrams, the inspectors validated that the motor driven fire pumps could be started from the respective 480V Shutdown boards located in the Auxiliary Building.

No findings were identified.

c. Conclusions

Based upon the review of the fire impairment program, the inspectors concluded that the program needed to be revised to address the availability of the motor driven fire pumps for fires in the Control Building. This inspection item will remain open until the corrective actions related to PER 966670 are implemented.

3. Fire Risk Maintenance Evolutions

a. Inspection Scope

The inspectors reviewed Procedure NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work), Rev. 3 and the As-Constructed FPR to verify that the hot work program was revised to incorporate Dual Unit operations. The inspectors also reviewed Procedure FPT013.000, Fire Protection Training, Rev.1 and associated attachments. The inspectors observed on going hot work activities for Unit 2 and reviewed a sample of hot work permits for Unit 2 to verify adequate implementation of the program.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors determined that the hot work program was ready for implementation as described in the As-Constructed FPR.

4. Ventilation

a. Inspection Scope

The inspectors reviewed firefighting pre-plan strategies; fire brigade training procedures; fire damper locations; HVAC drawings; and fire response procedures to verify that inter-area migration of hot gases and smoke was addressed and accessed that it did not have an adverse impact on safe shutdown equipment and OMAs. Field walk-downs of selected dampers were performed to verify their installation was performed in accordance with manufacturers requirements and that the dampers were in proper operating condition.

b. Observations and Findings

The inspectors noted that Part II, Section 8.3.62 of the As-Constructed FPR stated that OMA 1016 was feasible and reliable because the licensee demonstrated that there was adequate time available (margin) for the AUO to reliably perform this action. The licensee also stated that there were not any environmental factors that could adversely impact the OMA; and that local indication for monitoring nitrogen cylinder pressure and regulator adjustment were available. The action involved the operation of the SG PORV to control secondary pressure and to provide a controlled means of removing decay heat. The licensee also determined that the action must be initiated at 60 minutes after the reactor is tripped.

The OMA is required for a fire in the 6.9KV & 480V Shutdown BD RM B (757.0-A24) and performed in the 480V Shutdown BD RM 2A (757.0-A21), which is adjacent to room 757.0A-24. These two rooms are located in different fire areas. During plant walkdowns, the inspectors noted that two fire dampers were installed in the wall separating both rooms and that they were installed very close to the floor (~1 foot from the floor). The inspectors performed fire modeling to determine if the dampers would close quick enough to prevent fire propagation and smoke migration from 757.0-A24 to 757.0-A21. The inspectors noted that it would require a significant fire for the dampers to close, but there was reasonable assurance that they will close to prevent fire propagation to the adjacent room. However, the inspectors noted that a significant amount of smoke will migrate through the dampers. The inspectors determined that smoke and the reduced visibility could prevent accessing the necessary equipment and hinder successful performance of the OMA.

The licensee acknowledged that they did not account for smoke migration in their analysis to ensure that it will not affect performance of the OMA. The licensees review indicated that the demonstration of 100% margin bounded uncertainties related to smoke migration and other unknowns (e.g. increased noise levels from the fire, the operation of suppression equipment, and from personnel shouting instructions; water on the floor possibly delaying personnel movements; obstruction from charged fire hoses; increased heat and humidity resulting from fire-induced loss of heating, ventilation, and air conditioning (heat stress); or too many people getting in each others way).

In addition, Part V, Section 2.1 of the As-Constructed FPR, stated that a robust defense-in-depth fire prevention/protection program provided additional assurance that OMAs were both feasible and reliable. The inspectors determined that the licensee could not take credit for a robust defense-in-depth fire prevention/protection program because the location of the dampers will allow smoke migration that could prevent performance of the OMA. The licensee did not consider all of the applicable environmental factors that could adversely impact the performance of the OMA. Additionally, the licensee did not recognize that they needed to implement the acceptance criteria related to environmental factors as described in Section 2.1.2.2.b of Part V. Section 2.1.2.2.b stated, in part, The 100% time margin or performance time plus uncertainty allowances from paragraph 1.a and 1.b above ensures adequate time to reach the control location and perform the action. Additional time margin must be included for OMAs required for a fire in an area lacking robust defense-in-depth fire prevention/protection. Based on the above information, the inspectors determined that OMA 1016 was not feasible and reliable. The licensee entered this issue in their corrective action program as PER 967466 and committed to perform an extent of condition review to determine if there were other OMAs that could be adversely impacted by smoke migration.

No findings were identified.

c. Conclusions

Based on the inspection activities related to the above section, the inspectors determined that OMA 1016 was not ready for implementation as described in the As-Constructed FPR. Additional inspection activities are required to verify corrective actions related to PER 967466 and to review the extent of condition analysis.

5. Emergency Communications

a. Inspection Scope

The guidelines established by BTP CMEB 9.5-1, Section D.5. Lighting and Communication, requires that a communications system should be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown.

Also fixed repeaters installed to permit use of portable radio communication units should be protected from exposure fire damage. The As-Constructed FPR, Part II, Section 12.8 states that the in-plant radio signal will be the primary means of communication for performing manual actions and for the fire brigade use. Additionally, an alternate (emergency) communication system (sound powered phones with headsets) is provided.

The inspectors sought to verify that communication capabilities were adequate to support plant personnel in the performance of OMAs to achieve and maintain SSD, and the fire brigade. The inspectors sought to perform walkdowns to assess the credited method of communications used to complete safe shutdown actions as specified in post-fire SSD procedures for the selected FAs. The inspectors also sought to verify that the design and location of communications equipment, such as repeaters and transmitters, would not cause a loss of communications during a fire.

b. Observations and Findings

During the inspection, the inspectors observed a fire drill involving the Control Building 24v/48v Battery Room. The inspectors observed that the radio communication equipment between fire brigade members was intermittent and affected brigade response. The licensee entered this issue in their corrective action program as PER969442. The licensee informed the inspectors that the communication system on Unit 2 was currently being installed and tested to support dual unit shutdown. The work is being done under DCN-60384-A.

No findings were identified.

c. Conclusions

At the time of the inspection, the licensee had not completed the installation of the new communication system. This inspection item will remain open until inspection activities are conducted to verify the installation and adequacy of the communication system per DCN 60384-A.

02.04 Installation, Operability, and Maintenance of Fire Protection Systems and Equipment 1. Passive Fire Protection

a. Inspection Scope

The inspectors walked down the selected FAs to evaluate the adequacy of the fire resistance of barrier enclosure walls, ceilings, and floors. This evaluation also included fire barrier reinforced concrete, penetration seals, fire doors, fire dampers, and the Thermo-Lag electrical raceway fire barrier systems to ensure that at least one train of SSD equipment would be maintained free of fire damage. Construction detail drawings were reviewed as necessary to verify the fire barriers met the requirements and licensee commitments. 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; As-Constructed FPR; and standard industry practices.

b. Observations and Findings

During the walkdowns of Unit 2 only areas, the inspectors noted three penetrations (A0006AM, A1405AM, A0220AM) in the safety injection pump room 2B-B that were degraded and in need of repair. The inspectors also could not verify that fire door A-130 (Unit 2 Ventilation and Purge Air Room) was a 3 - hour rated door as required by the As-Constructed FPR, because the door did not have a fire rating label attached. The licensee stated that prior to turning over any Unit 2 areas for operation, TI-338, Unit 2 Area Turnover Supporting Operational Readiness, Rev. 11 will be performed. The purpose of TI -338 is to provide assurance that the Unit 2 areas ready to be turned over to operations will support plant operational requirements. As part of the TI, the licensee will perform visual inspections to verify that Unit 2 areas comply with fire protection requirements and fire protection features are in compliance with the FPP.

The inspectors reviewed surveillance procedures implementing Testing and Inspection Requirements (TIR) described in Part II of the As-Constructed FPR to verify that passive fire protection equipment added for Unit 2 operations was included in the TIRs. The inspectors noted that surveillance procedure 0-SOI-13.01, Fire Detection System, Rev.

0, did not include some of the fire dampers added for Unit 2 operations. The licensee acknowledged the observation and entered the issue in their corrective action program as PER 960445.

No findings were identified.

c. Conclusions

The inspectors determined that passive fire protection features were not ready for implementation as described in the As-Constructed FPR. Additional inspection activities are required to verify corrective actions related to PER 967466 and observations related to Unit 2 fire barriers.

2. Active Fire Protection

a. Inspection Scope

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 strategies, to verify that they were accessible and that adequate reach and coverage was provided. 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.

b. Observations and Findings

The inspectors reviewed surveillance procedures implementing TIRs described in Part II of the As-Constructed FPR to verify that active fire protection equipment added for Unit 2 operations were included in the TIRs. The inspectors identified that the surveillance procedures for fire alarm panels: -623, -625, -628, and -629 were not updated to include the additional detectors required for Dual Unit operation. The licensee acknowledged the observations and entered the issue in their corrective action program as PER 954084.

At the time of the inspection, work related to the installation of fire protection features in the Unit 2 Reactor Building Annulus was not completed. The following EDCRs still need to be completed in order to close the inspection activities related to active fire suppression:

  • 54655 - Install fire detectors, additional sprinklers in the U2 Rx Bldg Annulus.

Install flame detectors on the RCPs

  • 53587 - Relocate hose station 2-SPV-26-1207 and delete hose station 2-SPV-26-1203. Replace sprinkler heads in the Annulus previously plugged No findings were identified.

c. Conclusions

The inspectors determined that active fire protection features were not ready for implementation as described in the As-Constructed FPR. Additional inspection activities are required to verify corrective actions related to PER 967466 and verify adequate completion of EDCRs 54655 and 53587.

02.05 Readiness of the Licensees Personnel to Fight Fires

a. Inspection Scope

Aspects of fire brigade readiness, training, qualifications, and responsibilities 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 strategies 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 strategies and drawings 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 designated and qualified with regard to their medical and fire brigade training records. Current mutual aid agreements with local outside fire departments were also reviewed. Additionally, an announced fire drill involving the Control Building 24v/48v Battery Room was observed.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the reviewed activities related to the above section were ready for implementation as described in the As-Constructed FPR.

02.06 Adequacy of the Licensees System for Conducting Programmatic Changes Necessitated by Quality Assurance (QA) Audit Results, Generic Deficiencies, or Licensee Events 1. Review and Documentation of FPP Changes

a. Inspection Scope

The inspectors verified that changes made to the FPP related to Unit 2 were performed in accordance with applicable regulations; did not constitute an adverse effect on the ability to safely shutdown Unit 1; and did not decrease the effectiveness of the overall FPP. Specifically, the inspectors verify that reviewed changes to the FPP did not adversely affect the ability to achieve and, maintain safe shutdown in the event of a fire and the changes comply with applicable codes and standards.

The inspectors reviewed a sample of design change documents, system flow diagrams, calculations, and interviewed the licensee to determine if the changes to the FPP were appropriately implemented. The modifications reviewed are listed in the attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the reviewed activities related to the above section of the inspection procedure conformed to the applicable regulatory requirements.

2. Audits, Inspections, and Assessments

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 the FPP requirements.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the reviewed activities related to the above section of the inspection procedure conformed to the applicable regulatory requirements.

02.07 Effectiveness of Licensee Controls - Identification and Resolution of Problems

a. Inspection Scope

The inspectors verified that the licensee was identifying issues related to fire protection at an appropriate threshold and entering the issues in the corrective action program. For a sample of selected issues documented in the corrective action program, the team verified that the corrective actions were appropriate. The inspectors assessed the attributes of timeliness and cause determination to ensure that proposed corrective actions addressed the apparent cause, reportability, and operability determination. The inspectors reviewed operating experience from various sources to assess the licensees response consistent with program procedures.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the reviewed activities related to the above section of the inspection procedure conformed to the applicable regulatory requirements.

IV.

OTHER ACTIVITES OA.1.1 (Closed) Bulletin No. 1992-01: Failure of Thermo-Lag 330 Fire Barrier System to Maintain Cabling in Wide Cable Trays and Small Conduits Free from Fire Damage; Bulletin No. 1992-01 (Supplement 1): Failure of Thermo-Lag 330 Fire Barrier System to Perform Its Specified Fire Endurance Function; Generic Letter 1992-08:

Thermo-Lag 330-1 Fire Barriers (IP 35007)

a. Inspection Scope

Background: GL 92-08 informed licensees of failures in fire barrier system endurance and ampacity derating tests, installation procedures, and as-built configuration discrepancies associated with the Thermal Science, Incorporated (TSI), St. Louis, Missouri, Thermo-Lag 330-1 electrical raceway fire barrier system (ERFBS) that was installed to protect safe shutdown capability. The NRC initiated a series of small scale fires test for a sample of ERFBS and issued the results of the TU Electric and NRC fires tests in Bulletins 92-01, Failure of Thermo-Lag 330 Fire Barrier System to Maintain Cabling in Wide Cable Trays and Small Conduits Free form Fire Damage, June 24, 1992, and 92-01 Supplement 1, Failure of Thermo-Lag 330-1 Fire Barrier system to Perform its Specified Fire Endurance Function, August 28, 1992. NRC Inspection Reports 05000391/2013609 (ADAMS Accession No. ML13353A599), 050003912013615 (ADAMS Accession No. ML13310A820), and 050003912014607 (ADAMS Accession No. ML14274A076) describes additional background information, Unit 1 and Unit 2 corrective actions, and additional NRC inspection activities for Unit 2.

Inspection Activities: The inspectors reviewed the work procedures of the ERFBS thermo-lag 330-1 material installations for conduits 1B1049F, OMC557A, and 2PLC5369A to verify that the installation activities were completed in accordance with G-98, Installation, Modification, and Maintenance of Electrical Raceway Fire Barrier Systems, revision 9 and the approved drawings. The inspectors also reviewed ampacity de-rating, and combustible loading calculations to verify that the addition of the Thermo-lag material to the conduits were included in the revised design analysis, were adequate and completed in accordance with the approved procedures. In addition, the inspectors reviewed the Thermo-lag 330-1 material test reports to verify the material density and shear strength test results were in compliance with the design requirements.

Documents reviewed for this inspection are listed in the attachment.

b. Observations and Findings

No findings were identified.

c. Conclusion Bulletin No. 1992-01, Bulletin No. 1992-01 (Supplement 1), and Generic Letter 1992-08 are closed. Thermo-Lag material installations are ongoing to meet the requirements of the approved Fire Protection Report for Unit 2. The Thermo-Lag fire barrier material installations were installed in accordance with the approved procedures and design controls were in place to address the original historical ERFBS material and installation issues.

OA.1.2 (Closed) CDR 391/84-32: Inadequate Separation of Redundant Cables Near Floor Openings (IP 35007)

a. Inspection Scope

Background: The deficiency was initially reported to the NRC on July 20, 1984, as NCR WBN MEB 8430 in accordance with 10 CFR 50.55(e). The issue was documented as CDR 390/84-36 for Unit 1 and CDR 391/84-32 for Unit 2.

The deficiency concerned the auxiliary building floor openings that were not provided with adequate protection features to meet 10 CFR 50, Appendix R, Section III.G.2, separation and fire protection requirements for redundant safe shutdown components.

The specific areas of concern in the auxiliary building were: 1) open stairwells 5 and 6 connecting auxiliary building elevations 692.0 ft., 713.0 ft., and 737.0 ft. at columns A4-A5/S-T and A11-A12/S-T; 2) the 10 ft. by 12 ft. steel equipment hatch (normally closed)in the hoist way between auxiliary building elevations 757.0 ft. and 772.0 ft. at columns A12-A13/S-T; and 3) three unprotected ventilation duct penetrations through the two hour-rated reinforced concrete floor between auxiliary building elevations 692.0 ft., 713.0 ft., and 737.0 ft.

The concern was that, if the nonconforming condition was not corrected, a single exposure fire from an affected redundant cable or an intervening combustible in one area could produce effects that could adversely affect another redundant cable of a safe shutdown system in another area. This could adversely affect the ability to achieve and maintain safe shutdown of the plant.

In a letter from TVA to the NRC, dated September 19, 1984, the applicant stated: TVA will install water curtains designed in accordance with NFPA Standard 13-1983, Section 4-4.8.2, around the affected stairwell and hatch openings. Fire dampers rated at 1-1/2 hours will be installed in the affected duct penetrations. The applicant also noted: All Unit 1 redesign and construction modifications will be accomplished per ECN 5087.

To address the corrective actions for both Unit 1 and Unit 2, the applicant installed fire dampers in the auxiliary building in the following locations: 1-ISD-31-3995 (elevation 713.0 ft. at column A6/S), 1-ISD-31-3996 (elevation 737.0 ft. at column A5/S), and 2-ISD-31-3988 (elevation 713.0 ft. at column A10/S). Also, the applicant installed water curtains in the following locations: 1) open stairwell 3 connecting auxiliary building elevations 692.0 ft., 713.0 ft., and 737.0 ft. at column A8/U-V; 2) the 8 ft. by 16 ft.

equipment hatch openings located below elevations 713.0 ft., 737.0 ft., and 757.0 ft. at column A8/U-W; 3) the 10 ft. by 12 ft. steel equipment hatch (normally closed) in the hoist way between auxiliary building elevations 757.0 ft. and 772.0 ft. at columns A12-A3/S-T, and 4) at the auxiliary building elevator door openings located below elevations 713.0 ft., 737.0 ft., and 757.0 ft. at column A8/T. All of the water curtains are listed in the Fire Protection Report, Part VII - Deviations and Evaluations, Section 2.6.3.1.

For Unit 1 the NRC closed CDR 390/84-36 in IR 50-390/85-09 (ADAMS Accession No.

ML082190704), noting that the applicants final report was dated September 19, 1984, with the supplemental report dated February 6, 1985. During the time period from February 19 - 22, 1985, the inspectors reviewed the installation of the auxiliary building water curtains and three new fire dampers: 1-ISD-31-3995 (elevation 713.0 ft. at column A6/S), 1-ISD-31-3996 (elevation 737.0 ft. at column A5/S), and 2-ISD-31-3988 (elevation 713.0 ft. at column A10/S).

Inspection Activities: The NRC documented the review of Unit 2 inspection actions in IR 50-391/2013-604 (ML13179A079). The inspection report stated that remaining actions to close this item were to implement the corrective actions associated with PER 726637 to clarify the applicable code for water curtain installations identified by NCR WBN MEB 8430 and verify the as-built condition meets the approved NFPA code of record.

The inspectors verified that the corrective action associated with PER 726637 was implemented. As a corrective action, procedure G-73, Installation, Modification, and Maintenance of the Fire Protection Systems and Features was revised to clarify that the code of record is the standard as documented in the approved FPR. In addition, the revision included that any new installation or modification not installed in accordance to the code of record will be installed in accordance with the most recent edition of the Code at the time the work is performed. The inspectors also verified that the as-built water curtains met NFPA 13 Standard -1975 edition as described in the As-Constructed Fire Protection Report.

b. Observations and Findings

No findings were identified.

c. Conclusion This item is closed.

V.

MANAGEMENT MEETINGS X1

Exit Meeting Summary

An exit meeting was conducted on December 19, 2014, to present inspection results to Mr. Skaggs and other members of his staff. The inspectors identified that no proprietary information had been received during the inspection and none would be used in the inspection report. The applicant acknowledged the observations, and provided no dissenting comments.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Applicant personnel

M. Skaggs, TVA - Senior Vice President
J. Sterchi, Fire Marshall
C. Brush, Appendix R Consultant
J. Ricks, WBN Design Engineer - Electrical
E. Haston, WBN Design Engineer - Fire Protection
J. ODell, WBN Licensing
T. Morgan, WBN Licensing
H. Baldner, WBN Licensing
J. Bushnell, WBN Licensing
B. Crouch, WBN Engineering
H. Baldner, TVA - Regulatory Compliance
M. Marinac, WBN Operations

INSPECTION PROCEDURES USED

IP 35007 Quality Assurance Program Implementation During Construction and Pre-

Construction Activities

IP 64100 Postfire Safe Shutdown, Emergency Lighting and Oil Collection Capability

at Operating and Near-Term Operating Reactor Facilities

IP 64704 Fire Protection Program

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

1992-01 BL Failure of Thermo-Lag 330 Fire Barrier System to Maintain Cabling in Wide Cable Trays and Small Conduits Free from Fire Damage (Section OA.1.1)

1992-01 (Supplement 1) BL Failure of Thermo-Lag 330 Fire Barrier System to Perform Its Specified Fire Endurance Function (Section OA.1.1)

1992-08 GL Thermo-Lag 330-1 Fire Barriers (Section OA.1.1)

391/84-32 CDR Inadequate Separation of Redundant Cables Near Floor Openings (Section OA.1.2)

Discussed

64100 IP Postfire Safe Shutdown, Emergency Lighting and Oil Collection Capability at Operating and Near-Term Operating Reactor Facilities (Section F.1.1)

64704 IP Fire Protection Program (Section F.1.2)

LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section F.1.2)

Fire Barriers Floors/Walls/Ceiling Identification Description Barrier Description/Identification Fire Areas

  • FA 29, 125-V Vital Battery BD RM IV
  • FA 31, 6.9 KV & 480-V Shutdwn BD RM B Reinforced Concrete Walls, Floors & Ceiling * FA 48, Communications Room
  • FA 42, 80-V Transformer RM 2A Fire Door Identification Description Door Number Room 1 Room 2 A169 757.0-A22 757.0-A24 A190 772.0-A11 772.0-A12 A45 692.0-A25 692.0-A24 A76 713.0-A19 713.0-A20 A130 737.0-A9 737.0-A10 A192 737.0-A9 737.0-A14 A43 692.0-A23 692.0-A1 A46 692.0-A26 692.0-A1 A42 692.0-A22 692.0-A1 A39 692.0-A19 692.0-A1 A40 692.0-A20 692.0-A1 A77 713.0-A19 713.0-A21 Fire Damper Identification Description Damper Number Room 1 Room 2 0-ISD-31-2785 757.0-A22 757.0-A24 0-ISD-31-4622 757.0-A22 757.0-A21 0-ISD-31-2780 757.0-A23 757.0-A24 0-ISD-31-2782 757.0-A23 757.0-A24 0-ISD-31-2785 757.0-A22 757.0-A24 0-ISD-31-4623 757.0-A24 757.0-A21 0-ISD-31-4624 757.0-A24 757.0-A21 0-ISD-31-4625 757.0-A24 757.0-A21 2-ISD-31-2500 757.0-A17 772.0-A10 2-ISD-31-3884 757.0-A17 757.0-A16 0-ISD-31-2772 757.0-A1 757.0-A24 2-ISD-31-2930 692.0-A24 692.0-A25 2-ISD-31-3929 692.0-A25 713.0-A19 2-ISD-31-3927 713.0-A19 713.0-A29 0-ISD-31-2771 757.0-A1 757.0-A24 Pen Seals, ERFBS, Thermo Lag Description Rooms of Fire Areas PS69D, PS118, PS120, PS121 480 V Shutdn Brd Transformer RM A0006AM, A1405AM, A0220AM SI Pump Room 2B-B Cable 2PP675A ERFBS 6.9V Shutdn Brd RM A Cable 1B13F ERFBS 480 V Shutdn Brd RM A Cable 1B18F ERFBS 480 V Shutdn Brd RM A Cable 2PP687A ERFBS 6.9V Shutdn Brd RM A Cable 2PL5392A ERFBS 6.9V Shutdn Brd RM A Cable 2PL5394A ERFBS 6.9V Shutdn Brd RM A

LIST OF COMPONENTS REVIEWED (Refer to Report Section F.1.1)

Component No. Description 0-BD-236-4-G 125V Vital Battery Board IV 1-BD-211-A-A 6900V Shutdown Board 1A-A 1-DG-82-A-A Unit 1 Train A Diesel Generator 1-DG-82-B-B Unit 1 Train B Diesel Generator 1-FCV-67-66-A Emerg DSL H/X 1A1 & 1A2 Supp FM HDR 1A 1-FCV-67-67-B Emerg DSL H/X 1B1 & 1B2 Supp FM HDR 1A 1-FCV-72-21B Unit 1 RWST to CS Pump 1B-B Suction 1-FCV-72-22A Unit 1 RWST to CS Pump 1A-A Suction 1-FCV-74-21B Unit 1 RHR Pump 1B-B Suction 1-FCV-74-3-A Unit 1 RHR Pump 1A-A Suction 1-HTR -68-341A Unit 1 Pressurizer Heater Backup Group 1A-A 1-LCV-62-132A Unit 1 VCT Outlet Isolation Valve 1-LI-68-320F Unit 1 Pressurizer Level Indicator 1-LI-68-339A Unit 1 Pressurizer Level Indicator 1-MTR-62-108A Charging Pump 1A-A 1-PCV-68-340-A Unit 1 Train A Pressurizer PORV 2-BD-211-B-B 6.9 kV Shutdown Board 2B-B 2-BD-212-A1-A 480V Shutdown Board 2A1-A 2-BD-212-A2-A 480V Shutdown Board 2A2-A 2-DG-82-A-A Unit 2 Train A Diesel Generator 2-DG-82-B-B Unit 2 Train B Diesel Generator 2-FCV-1-17A Unit 2 Steam Flow Aux FWP Isolation Valve 2-FCV-1-18B Unit 2 Steam Flow Aux FWP Isolation Valve 2-FCV-67-66-A Emerg DSL H/X 2A1 & 2A2 Supp FM HDR 1A 2-FCV-67-67-B Emerg DSL H/X 2B1 & 2B2 Supp FM HDR 1A 2-HTR-68-341A Unit 2 Pressurizer Heater Backup Group 1A-A 2-LCV-62-133B Unit 2 VCT Outlet Isolation Valve 2-LI-3-39 Unit 2 SG Level (Loop1)

2-LI-3-52 Unit 2 SG Level (Loop 2)

2-LI-63-50 Unit 2 RWST Level Indicator 2-LI-68-320F Unit 2 Pressurizer Level Indicator 2-LI-68-339A Unit 2 Pressurizer Level Indicator 2-LIC-3-156-A Unit 2 SG #2 Level Indicator Controller 2-LIC-3-164-A Unit 2 SG #1 Level Indicator Controller 2-MCC-213-A1-A Reactor MOV BD 2A1-A 2-MCC-213-A2-A Reactor MOV BD 2A2-A 2-MTR-3-118-A Unit 2 Motor Driven AFW Pump A-A 2-MTR-62-104B Charging Pump 2B-B 2-PCV-68-334B Unit 2 Train B Pressurizer PORV 2-PCV-68-340-A Unit 2 Train A Pressurizer PORV HS-68-333A PORV 340A Block Valve LI-3-164C S/G level indicator O-XS-26-1-A Fire Pump 1A-A (motor driven)

LIST OF DOCUMENTS REVIEWED