IR 05000400/2005007

IR 05000400-05-007, on 08/15 - 19/2005 and 08/29 - 09/02/2005; Shearon Harris Nuclear Power Plant, Unit 1; Triennial Fire Protection Inspection

ML052900122
Person / Time
Site:	Harris
Issue date:	10/14/2005
From:	Payne D NRC/RGN-II/DRS/EB2
To:	Scarola J Carolina Power & Light Co
References
IR-05-007
Download: ML052900122 (28)

Text

October 14, 2005

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000400/2005007

Dear Mr. Scarola:

On September 2, 2005, the Nuclear Regulatory Commission (NRC) completed an inspection at the Shearon Harris Nuclear Power Plant. The enclosed report documents the inspection results, which were discussed on September 2, 2005, with you and other members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

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

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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).

Sincerely,

/RA/

D. Charles Payne, Chief Engineering Branch 2 Division of Reactor Safety Docket No.:

50-400 License No.:

NPF-63

Enclosure:

NRC Inspection Report No. 05000400/2005007 w/Attachment: Supplemental Information

REGION II==

Docket No:

50-400 License No:

NPF-63 Report No:

05000400/2005007 Licensee:

Carolina Power & Light Company (CP&L)

Facility:

Shearon Harris Nuclear Power Plant, Unit 1 Location:

5413 Shearon Harris Road New Hill, NC 27562 Dates:

August 15 - 19, 2005 (Week 1)

August 29 - September 2, 2005 (Week 2)

Inspectors:

R. Aiello, Senior Operations Engineer, (Week 2 only)

F. Baxter, Electrical Engineer (Contractor)

R. Fanner, Reactor Inspector M. Thomas, Senior Reactor Inspector, (Lead Inspector)

G. Wiseman, Senior Reactor Inspector Accompanying T. Harrison, Fire Protection Co-op (Week 1 only)

Personnel:

Approved by:

D. Charles Payne, Chief Engineering Branch 2 Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000400/2005-007; 08/15 - 19/2005 and 08/29 - 09/02/2005; Shearon Harris Nuclear Power Plant, Unit 1;

Triennial Fire Protection Inspection.

This report covers an announced two-week period of inspection by four regional inspectors and one contractor. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, Reactor Oversight Process Revision 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

None

Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection

The purpose of this inspection was to review the Shearon Harris Nuclear Power Plant (SHNPP) fire protection program (FPP) for selected risk-significant fire areas. The inspection was performed in accordance with the U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP)71111.05T, Fire Protection (Triennial), dated 02/18/2005, as modified for a plant in transition to National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. The NRC reduced the scope of this inspection by not specifically targeting safe shutdown circuit configurations for inspection.

Emphasis was placed on verification that procedures, including local manual operator actions, for post-fire safe shutdown (SSD) and the fire protection features provided for the selected areas met NRC requirements. The inspection was also performed in accordance with the NRC Reactor Oversight Process (ROP), using a risk-informed approach for selecting the fire areas and attributes to be inspected. The selection of risk-significant fire areas to be evaluated during this inspection considered the licensees Individual Plant Examination for External Events, information contained in FPP documents, results of prior NRC triennial inspections, and observations noted during in-plant tours.

The fire areas chosen for review during this inspection were:

• Safe Shutdown Analysis (SSA) Fire Area 1-A-BAL-B (B2)/Fire Zone 1-A-4-CHLR, Water Chiller Area B, 261 foot elevation reactor auxiliary building (RAB). In the event of a significant fire in this area, safe shutdown of the unit would be achieved from the main control room (MCR) with additional local manual operator actions in various areas of the plant.

• SSA Fire Area 1-A-BAL-C/Fire Zone 1-A-5-HVB, Switchgear Ventilation Room B, 286 foot elevation RAB. In the event of a significant fire in this area, safe shutdown of the unit would be achieved from the MCR with additional local manual operator actions in various areas of the plant.

• SSA Fire Area 12-A-CR/Fire Zone 12-A-6-CR1, Main Control Room, 305 foot elevation RAB. In the event of a significant fire in this area, evacuation of the MCR could be required and alternative shutdown would be achieved from the auxiliary control panel.

• SSA Fire Area 12-A-CRC1/Fire Zone 12-A-6-PICR1, Control Room Complex, Process Instrument Cabinet Room, 305 foot elevation RAB. In the event of a significant fire in this area, evacuation of the MCR could be required and alternative shutdown would be achieved from the auxiliary control panel.

For each of the selected fire areas, the team evaluated the licensees FPP against applicable requirements including Title 10 of the Code of Federal Regulations (10 CFR) 50.48; Operating License NFP-63, Operating License Condition 2.F, FPP; Updated Final Safety Analysis Report (UFSAR);

Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1 (NUREG-0800),

Guidelines for Fire Protection for Nuclear Power Plants, Rev. 2, July 1981; related NRC Safety Evaluation Reports (SERs) in NUREG 1038; NFPA codes; and plant Technical Specifications (TS).

The team evaluated all areas of this inspection, as documented below, against these requirements.

.01 Fire Protection of Safe Shutdown Capability

a. Inspection Scope

The team reviewed selected portions of the site FPP, fire hazards analysis (FHA), SSA, selected maintenance work orders, and the plant smoking policy. The team also reviewed selected portions of the administrative fire prevention and combustible hazards control procedures that establish and implement controls and practices to prevent fires and control the use and storage of permanent and transient combustible materials and ignition sources. These reviews were performed to verify that the licensees commitments, as established in the fire protection licensing basis documents, were satisfied.

For the selected fire areas/zones, the team evaluated the potential for fires, the combustible fire load characteristics, and the potential exposure fire severity. These evaluations were conducted to verify the effectiveness of the fire prevention program and to identify any maintenance or material condition problems related to fire incidents. The documents reviewed are listed in the Attachment.

The team walked down the selected plant fire areas/zones to observe:

(1) the material condition of fire protection systems and equipment;

(2) the storage of permanent and transient combustible materials; and

(3) the licensees implementation of the programmatic procedures for limiting fire hazards, combustible waste collection, housekeeping practices, and cleanliness conditions. These reviews were performed to verify that the licensee was maintaining the fire protection systems, had properly evaluated in-situ combustible fire loads, controlled hot-work activities, and limited transient fire hazards consistent with the UFSAR, administrative procedures, and other FPP procedures.

The team reviewed criteria in the licensees engineering department standards and design control procedures to verify that plant changes were adequately reviewed for the potential impact on the FPP.

The team performed an independent technical review of the licensees Engineering Service Request 9900046 documentation completed to justify the use of non treated wood timbers (dunnage) in the plant in lieu of fire retardant chemically treated wood. This review was performed to verify that the modification was performed consistent with plant design control procedures and the FPP.

b. Findings

No findings of significance were identified.

.02 Passive Fire Protection - Fire Barriers and Fire Area/Zone/Room Penetration Seals

a. Inspection Scope

The team reviewed the selected fire areas/zones to verify the adequacy of the fire resistance of fire barrier enclosure walls, ceilings, floors, fire barrier mechanical and electrical penetration seals, fire doors, and fire dampers in accordance with licensee commitments to BTP CMEB 9.5-1. The review was performed to verify that at least one train of SSD equipment was free of fire damage. This was accomplished by observing the material condition and configuration of the installed fire barrier features, as well as reviewing procurement specifications, construction detail drawings, engineering evaluations and fire endurance tests for the installed fire barrier features, to verify that the as-built configurations met design requirements, license commitments, standard industry practices and were either properly evaluated or qualified by appropriate fire endurance tests. In addition, the team reviewed a summary of surveillance and maintenance procedures for selected passive fire barrier features to verify these were properly inspected, maintained, and met the licensing and design bases as described in licensee submittals, NRC SERs, and UFSAR Section 9.5.1.2.2. The fire protection features included in the review are listed in the Attachment.

b. Findings

No findings of significance were identified.

.03 Active Fire Protection

a. Inspection Scope

The team reviewed the selected fire areas/zones to verify the adequacy of the design, installation, and operation of the automatic detection and alarm system to actuate in the early stages of a fire. This included walkdowns of the systems and evaluation of the fire response for the types of installed detectors, as shown on location drawings, to verify that the areas were protected by a fire detection system in accordance with the design requirements of BTP CMEB 9.5-1 and NFPA Codes of Record (COR) requirements.

The team reviewed the adequacy of the design and installation of the fixed multi-cycle pre-action sprinkler system for the Unit 1 chiller area (Fire Zone 1-A-4-CHLR). The team reviewed original suppression system specifications, hydraulic calculations for the suppression system, sprinkler installation drawings, sprinkler response data, and NFPA 13, Standard for the Installation of Sprinkler Systems, to verify that the fire suppression system met the design and licensing basis as described in licensee submittals, NRC SERs and the UFSAR, and that the system could perform its intended function in the event of a fire within the room enclosure.

The team also reviewed the periodic surveillance testing performed on the sprinkler system, including the interfacing fire detection systems, to verify the systems were properly inspected and maintained.

The manual portable extinguishers and the suppression standpipe and fire hose systems were reviewed to verify adequate design, installation, and operation in the selected fire areas/zones. During plant walkdowns, the team observed interior fire hose nozzle types and the placement of the fire hose stations and extinguishers to verify they were not blocked and were consistent with design drawings, the fire fighting plans and FPP documents. The team also reviewed engineering evaluations and flow/pressure calculations to verify that sufficient pressure and flow volume were available to produce electrically safe and effective fire hose operation within the nozzle manufacturers specified flow range.

Additionally, the team checked a sample of fire hose lengths to verify they could reach potential fire affected equipment and components within the selected fire areas/zones in support of manual fire brigade fire fighting efforts.

The team reviewed flow diagrams, design basis specifications, engineering technical evaluations for NFPA code deviations, and operational valve lineup procedures of the motor-driven fire pump, the diesel-driven fire pump, and the fire protection water supply system. Using operating and valve alignment procedures, the team inspected selected fire pumps and portions of the fire main piping system to verify material condition, consistency of as-built configurations with engineering drawings, and correct system valve lineups. In addition, the team performed an independent technical review of Engineering Change (EC) 50147 documentation completed to support a modification to the diesel-driven fire pump controller to provide an auto-start capability of the pump upon loss of power to the battery chargers. The review was performed to verify that the modification was performed consistent with plant design control procedures and NFPA COR requirements.

The team reviewed the routing of power and control cables for the electric powered fire pump and the control and annunciator cables for the diesel driven fire pump to verify that the cables for the fire pumps were routed such that fire damage to the cables would not prevent the delivery of water for fire suppression. The team also reviewed the fuel oil, lube oil, and starting batteries for the diesel driven fire pump to verify that the lube and fuel oil were suitable for cold weather operation, and that the batteries would be capable of providing sufficient cranking power for the engine.

The team reviewed operator and fire brigade staffing, initial and continuing qualification course training materials, and fire drill program procedures to verify appropriate training was being conducted for the station firefighting personnel. Additionally, the team reviewed post-drill summary records of fire drills performed in the previous two-year period to verify the effectiveness of fire brigade response to simulated fire emergencies and to verify that drills were being conducted in risk significant areas.

The team inspected the fire emergency equipment storage locations and dress-out areas, fire brigade protective ensembles, self-contained breathing apparatuses (SCBA), and various fire brigade equipment to verify operational readiness for fire fighting. Three fire brigade protective ensembles were physically checked for cleanliness and dryness; heat damage, fabric damage, thread or seam damage, discoloration, cracks or tears, and worn areas. The team also reviewed the SCBA breathing air compressor and storage cylinders to verify that the onsite reserve supply of breathing air for recharging SCBA air bottles met the license commitments described in the UFSAR.

The team reviewed the fire pre-plan strategies for the selected fire areas/zones and fire response procedures to verify that appropriate information was provided to fire brigade members to identify potential effects to plant safety and personnel safety and to facilitate suppression of an exposure fire that could impact SSD capability. The team walked down the selected fire areas/zones to compare the associated fire pre-plan drawings with as-built plant conditions and fire response procedures. This was done to verify that fire fighting pre-plans and drawings were consistent with the fire protection features and potential fire conditions described in the fire hazards analysis. The team also evaluated whether the fire response procedures and fire pre-plans for the selected fire areas/zones could be implemented as intended. Additionally, the team assessed the adequacy of the off-site fire fighting assistance including entry into the plant area, communications, emergency dosimetry, and fire equipment usage.

b. Findings

No findings of significance were identified.

.04 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team reviewed UFSAR Section 9.4.5, post-fire SSD procedures, selected fire fighting pre-plan procedures, and heating, ventilation, and air conditioning system drawings and design basis specifications for a selected sample of equipment to verify smoke purge/removal system capability for a fire in the selected fire areas/zones. This review was conducted to assess the systems fire vulnerability (if electrical power supplies or control circuits could be damaged or inhibited by fire-induced failures) and to verify that access to remote shutdown equipment and operator manual actions for SSD would not be inhibited by smoke migration from one area to adjacent plant areas.

The team performed document reviews and in-plant walkdowns to evaluate the material condition of concrete floors, floor drain systems, and the physical configuration of fixed fire suppression equipment and components in the selected fire areas/zones. These reviews were performed to verify that water from an inadvertent fire suppression system rupture, from the effects of a fire event, fire fighting activities, or from leakage from fire suppression systems could cause damage that could significantly impair safety systems.

b. Findings

No findings of significance were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

The team reviewed the licensees SSA and walked down the selected fire areas to verify the adequacy of the licensees strategy for alternative shutdown for a fire in the MCR or control room complex. The team also reviewed selected surveillance tests to verify that the licensee performed periodic operational tests of the alternative shutdown transfer capability and instrumentation and control functions, and that the tests were adequate to prove the functionality of the alternative shutdown capability.

b. Findings

No findings of significance were identified.

.06 Operational Implementation of Safe Shutdown Capability

a. Inspection Scope

The team reviewed the operational implementation of the SSD strategy that would be used during a significant fire in any of the selected fire areas. The team interviewed training and operations personnel, reviewed lesson plans, job performance measures, plant procedures, and training records for licensed and non-licensed operators. These reviews were performed to verify that: 1) the procedures were available for immediate use; 2) the operators could reasonably be expected to perform the procedures, including local manual operator actions, within applicable shutdown time requirements; 3) the local manual operator actions in place for fire areas requiring SSD from the MCR met the criteria listed in NRC IP 71111.05T; 4) the training program for operators included local manual operator actions relied on for SSD from the MCR or from the alternate shutdown locations; 5)personnel required to achieve and maintain the plant in hot standby following a fire could be provided from normal onsite staff, exclusive of the fire brigade; and 6) the licensee conducted periodic operational tests of the alternate shutdown transfer capability and instrumentation and control functions. The team reviewed and/or walked down applicable sections of the following fire response abnormal operating procedures (AOP):

• AOP-004, Remote Shutdown, Rev. 36

• AOP-036, Safe Shutdown Following a Fire, Rev. 37 and Rev. 38

• AOP-036.03, Fire Area: 1-A-BAL-B, Rev. 0 and Rev. 1

• AOP-036.04, Fire Areas: 1-A-BAL-C, 1-A-BAL-D, 1-A-BAL-F, 1-G, FPYARD, Rev. 0 and Rev. 1

• AOP-036.05, Fire Areas: 1-A-CSRA, 1-A-CSRB, Rev. 0 and Rev. 1

b. Findings

Introduction:

The team identified an unresolved item (URI) related to the abnormal operating procedure used to achieve SSD from the MCR in the event of a fire in certain fire areas where all reactor coolant pump (RCP) seal cooling could be interrupted. The safe shutdown strategy and related fire response procedures may not be adequate to ensure safe shutdown of the plant for a fire in Fire Areas 1-A-BAL-B (B2) or 1-A-CSRB. The licensees fire response procedures may not preclude RCP seal damage because the AOPs did not include guidance from Westinghouse, the RCP seal vendor for SHNPP, regarding time limitations for restoring cooling to the RCP seals. Failure to follow the vendor guidance could result in RCP seal package failure and could cause a seal loss-of-coolant accident and failure of the specified safe shutdown strategy.

Description:

Procedure AOP-036, Rev. 37 was written to safely shut down the unit from the MCR in the event of a significant fire in certain fire areas. SSA Fire Area 1-A-BAL-B (B2) was one of the fire areas where shut down would be achieved from the MCR with additional local manual operator actions performed in various areas of the plant. Revision 37 was the revision of record for AOP-036 at the beginning of this inspection. Revision 38 to AOP-036, which was issued prior to the second week of the inspection, subdivided the procedure by fire areas (i.e., AOP-036.01, -036.02, -036.03, etc.).

Procedures AOP-036 and AOP-036.03 included local manual operator actions to restore component cooling water (CCW) to the thermal barrier cooler, if a fire in SSA Fire Area 1-A-BAL-B (B2) resulted in the loss of all cooling to the RCP seals. The team noted that the previous NRC triennial fire protection inspection (IRs 05000400/2002011 and 05000400/2003007) identified a Green finding where a significant fire in Fire Area 1-A-BAL-B (B2) could result in the loss of all RCP seal cooling.

Westinghouse previously stated in various technical guidance documents (Technical Bulletin TB-04-22, dated 11/17/2004 and 08/09/2005) that cooling to the RCP seals should be restored within 13 minutes in the event of a loss of all RCP seal cooling. The Westinghouse guidance further stated that RCP seal cooling should not be restored if it takes more than 13 minutes. Restoration of seal cooling after 13 minutes using charging pump seal injection may result in cold thermal shock of the seal and possibly cause increased seal leakage which could lead to a seal loss-of-coolant accident. If seal cooling is restored using CCW to the thermal barrier cooler, water hammer may occur and possibly compromise the integrity of the CCW system. If the CCW system is damaged, then plant shutdown after a fire may not be possible in all scenarios. The licensee stated that they were performing a Manual Action Feasibility Study to validate the manual operator actions specified in the SSA and incorporated into the SSD AOPs. The team observed that the feasibility study was in progress and had not been completed at the conclusion of this inspection. Based on the Manual Action Feasibility Study for Fire Area 1-A-BAL-B (B2), the time to restore RCP seal cooling (via CCW thermal barrier cooling)was 17 minutes and 39 seconds. This time exceeded the 13 minutes specified by Westinghouse. The team also noted that AOP-036 and AOP-036.03 did not include procedural guidance or cautions (for any of the applicable fire areas where all RCP seal cooling could be lost due to a fire) to alert operators about the Westinghouse time limitations for restoring cooling to the RCP seals.

The team discussed this observation with licensee personnel and subsequent to this inspection, the licensee revised AOP-036 and the related AOP-036 series to add a caution alerting the operators not to restore RCP seal cooling if it could not be accomplished within 13 minutes.

The team walked down sections of AOP-036 applicable to Fire Area 1-A-BAL-B (B2) with licensee operations personnel. During this walkdown, the team observed that the time to restore CCW thermal barrier cooling to the RCP seals was less than the 17 minutes and 39 seconds noted in the licensees Manual Action Feasibility Study but more than the 13 minutes specified by Westinghouse. Based on observations from the teams walkdown, the licensee revised AOP-036 procedural steps to reduce the time for some of the actions. Additionally, the licensee evaluated the opening requirement for Valve 1CC-252 (CCW to the thermal barrier cooler) to determine flow adequacy for RCP seal cooling. These additional actions resulted in the licensee making a determination that RCP seal cooling could be restored within the 13 minutes specified by Westinghouse. The team determined that the licensees additional actions were appropriate to address the issue for Fire Area 1-A-BAL-B (B2).

The team noted that the licensee had identified eight fire areas (1-A-BAL-B (B1), 1-A-BAL-B (B2), 1-A-BAL-B (B3), 1-A-CSRA, 1-A-CSRB, 1-A-EPA, 1-A-EPB 1-A-SWGRB) where all RCP seal cooling could be lost due to a significant fire in the applicable fire area. The licensee had prepared modifications EC-52769 and EC-60436 to resolve this issue for some of the fire areas. These ECs are scheduled to be implemented during refueling outage RF-13 in the spring of 2006. The team further noted that, in addition to Fire Area 1-A-BAL-B (B2), the licensee had performed the Manual Action Feasibility Study for Fire Area 1-A-CSRB, Cable Spread Room B. The feasibility study indicated that the time to restore CCW thermal barrier cooling to the RCP seals for Fire Area 1-A-CSRB was 18 minutes and 30 seconds. The licensee did not perform any additional reviews of the safe shutdown strategy for Fire Area 1-A-CSRB during this inspection. The team noted that the licensee revised the applicable SSD procedure for Fire Area 1-A-CSRB (AOP-036.05) subsequent to this inspection to alert the operators regarding the time limitations for restoring RCP seal cooling following a loss of all seal cooling.

Analysis and

Enforcement:

Pursuant to the Commissions Enforcement Policy and NRC Manual Chapter 0305, under certain conditions fire protection findings at nuclear power plants that transition their licensing bases to 10 CFR 50.48©) are eligible for enforcement and ROP discretion. The Enforcement Policy and ROP also state that the finding must not be evaluated as Red. On June 10, 2005, the licensee submitted a letter to the NRC stating its intent to transition to 10 CFR 50.48©). The finding discussed above is greater than minor because it is associated with the ability to achieve safe shutdown of the unit following a fire in Fire Area 1-A-BAL-B (B2) or Fire Area 1-A-CSRB and affects the initiating event and mitigating systems cornerstone objectives. This issue is unresolved pending further NRC review to determine if it meets the criteria for discretion per the NRC Enforcement Policy and ROP. This issue will be tracked as URI 05000400/2005007-01, Fire Response Procedures May Not Be Adequate To Prevent RCP Seal Failure and Subsequent Seal Loss of Coolant Accident For a Fire in Certain Fire Areas.

.07 Communications for Performance of Fire Fighting Capability and Safe Shutdown

a. Inspection Scope

The team reviewed the various plant communication systems to verify the licensees ability to provide adequate communications to coordinate the shutdown of the unit and fire brigade duties.

Communications that could be available during a fire included a private automatic branch exchange telephone system, a voice paging system, a sound powered intercom system, and a radio system. The team reviewed the licensees portable radio channel features to verify that the system and its repeaters were protected from exposure fire damage. The team walked down selected sections of the post-fire SSD procedures and reviewed the communications equipment to verify availability for the personnel performing the procedure. The team also reviewed the periodic testing of the site fire alarm and paging systems; maintenance checklists for the sound-powered phone circuits and amplifiers; and inventory surveillance of post-fire SSD operator equipment to verify that the maintenance/surveillance test program for the communications systems was sufficient to verify proper operation of the systems.

b. Findings

No findings of significance were identified.

.08 Emergency Lighting for Performance of Fire Fighting Capability and Safe Shutdown

a. Inspection Scope

The team observed emergency exit lighting for personnel evacuation pathways to the outside exits as specified in the NFPA 101, Life Safety Code, and the Occupational Safety and Health Administration Part 1910, Occupational Safety and Health Standards. This review also included examination of backup emergency lighting for the primary and secondary fire emergency equipment storage locker locations and dress-out areas in support of fire brigade operations should power fail during a fire emergency.

The team reviewed the design and operation of self contained battery powered emergency lighting units (ELUs) as described in UFSAR Sections 9.5.1.2.3.e and 9.5.3. The team performed plant walkdowns of selected local manual actions defined in the post-fire SSD procedures to verify that the ELUs were aimed correctly for adequate illumination to allow performance of the actions required by the procedures. The team inspected emergency lighting features along access and egress pathways used during SSD activities for adequacy and personnel safety.

The locations and identification numbers on the ELUs were compared to design lighting drawings to confirm the as-built configuration. The team also reviewed the manufacturers information to verify that the battery power supplies were rated with at least an 8-hour capacity.

The team reviewed lighting layout drawings, individual lighting fixture circuits and lighting panel details for selected areas to assess if the lighting circuits and sources used for the areas were diverse such that a fire in one of the areas would not affect the lighting required for safe shutdown operations in any of the other areas.

b. Findings

No findings of significance were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team reviewed licensee FPP procedures and information to verify that, for damaged equipment, the licensee did not rely on repairs and had no credited repair procedures. Cold shutdown repairs were not credited at SHNPP.

b. Findings

No findings of significance were identified.

.10 Compensatory Measures

a. Inspection Scope

The team reviewed the administrative controls for out-of-service, degraded, and/or inoperable, fire protection features. The team reviewed selected active items on the fire protection status reports and compared them with the fire areas/zones selected for inspection. The compensatory measures that had been established in these areas/zones were compared to those specified for the applicable fire protection feature to verify that the risk associated with removing the fire protection feature from service was properly assessed and adequate compensatory measures were implemented in accordance with the approved fire protection program. Additionally, the team reviewed the licensees short term compensatory measures (fire watches) to verify that they were adequate to compensate for a degraded SSD function or fire protection feature until appropriate corrective actions were taken.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

The team reviewed a sample of corrective action program (CAP) action requests (ARs) resulting from fire, smoke, sparks, arcing, and equipment overheating incidents for the previous two-year period.

Additionally, selected fire brigade responses, emergencies and incidents, and fire safety inspection reports were reviewed. These reviews were conducted to verify that the licensee was identifying fire protection-related issues at an appropriate threshold and entering those issues into the corrective action program and to assess the frequency of fire incidents, trends in fire precursors, and effectiveness of the fire prevention program and any maintenance-related or material condition problems related to fire incidents.

The team also reviewed other CAP documents, including completed corrective actions documented in selected ARs, and operating experience program (OEP) documents to verify that industry-identified fire protection problems potentially or actually affecting SHNPP were appropriately entered into the CAP for resolution. Items included in the OEP effectiveness review were NRC Information Notices, industry and/or vendor-generated reports of defects and noncompliances under 10 CFR Part 21, and vendor information letters/technical bulletins. In addition, the inspectors reviewed a sample of the fire protection program audits and self-assessments which the licensee performed in the previous two-year period. The inspectors evaluated the effectiveness of the corrective actions for the identified issues.

The documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On September 2, 2005, the lead inspector presented the inspection results to Mr. J. Scarola, and other members of his staff. Proprietary information is not included in this inspection report.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

G. Attarian, Chief Engineer

D. Baksa, Supervisor, Equipment Performance

J. Briggs, Superintendent, Environmental and Chemical

D. Corlett, Supervisor, Licensing/Regulatory Programs

R. Duncan, Director, Site Operations

J. Ertman, Principal Engineer, Chief Engineering Section

M. Fletcher, Manager, Fire Protection Program

W. Gurganious, Manager, Training

C. Kamilaris, Superintendent, Operations Training

J. Kunzmann, Safe Shutdown Program Manager

T. Maness, Supervisor, Fire Protection Focus Team

L. Martin, Superintendent, Design Engineering

B. McCabe, Supervisor, Corporate Regulatory Affairs

E. McCartney, Plant General Manager

S. McCoy, Senior Licensing Engineer

T. Natale, Manager, Outage and Scheduling

J. Nobles, Operations Fire Protection

S. OConnor, Manager, Engineering

S. Radford, Maintenance Superintendent

B. Rhodes, Operations Support, Fire Protection Focus Team

J. Scarola, Site Vice President

R. Varner, Supervisor, Nuclear Assessment Section

M. Wachtel, Fire Protection Focus Team

M. Wallace, Licensing Specialist

M. Weber, Superintendent, Operations Support

K. Williams, Fire Protection Program Manager, Crystal River 3

E. Wills, Operations Manager

NRC personnel

P. Fredrickson, Chief, Reactor Projects Branch 4, Division of Reactor Projects

V. McCree, Director, Division of Reactor Safety

R. Musser, Senior Resident Inspector

P. OBryan, Resident Inspector

C. Payne, Chief, Engineering Branch 2, Division of Reactor Safety

LIST OF ITEMS

Opened

05000400/2005007-01 URI Fire Response Procedures May Not Be Adequate To Prevent RCP Seal Failure and Subsequent Seal Loss of Coolant Accident For a Fire in Certain Fire Areas (Section 1R05.06.b)

Opened and Closed

None

Closed

None

Discussed

None

SECTION 1R05.02 LIST OF FIRE BARRIER FEATURES INSPECTED IN RELATION TO SAFE SHUTDOWN SEPARATION REQUIREMENTS Floors/Walls/Ceilings Description Wall With Embedded Fire Zone 1-A-5-HVB to Fire Zone 1-A-CSRB Junction Box B1711 S4 Fire Dampers Description AV-FDAS-41-1 Fire Zone 1-A-5-HVB to Fire Zone 1-A-ACP AV-FDAS-48-1 Fire Zone 1-A-5-HVB to Fire Zone 1-A-SWGRB AV-FDAS-49-1 Fire Zone 1-A-5-HVB to Fire Zone 1-A-SWGRB CZ-FDAM-4-1 Fire Zone 12-A-6-CR1 to Fire Zone 12-A-6-ARP1 CZ-FDAM-5-1 Fire Zone 12-A-6-CR1 to Fire Zone 12-A-6-ARP1 Fire Doors Description D251 Fire Zone 1-A-5-HVB to Fire Zone 1-A-SWGRB D252 Fire Zone 1-A-5-HVB to Stairway D459 Fire Zone 12-A-6-CR1 to Fire Zone 1-A-6-COMA D461 Fire Zone 1-A-6-COMA to Air Lock D467 Fire Zone 12-A-6-CR1 to Fire Zone 12-A-6-ARP1 D468 Fire Zone 12-A-6-CR1 to Fire Zone 12-A-6-CR D476 Fire Zone 12-A-6-PICR1 to Fire Zone 12-A-6-IRR Fire Barrier Penetration Seals Description P4403, Typical GS-1 Fire Zone 1-A-5-HVB wall to Fire Zone 1-A-46-ST H423, Typical ML-1 Fire Zone 12-A-6-PICR1 wall to Fire Zone 12-A-6-IRR H424, Typical EC-1 Fire Zone 12-A-6-PICR1 wall to Fire Zone 12-A-6-IRR E546A, Typical EC-2 Fire Zone 12-A-6-PICR1 floor to Fire Zone 1-A-CSRB E563, Typical EL-2 Fire Zone 12-A-6-PICR1 floor to Fire Zone 1-A-CSRA E837, Typical EC-2 Fire Zone 1-A-4-CHLR manhole to Fire Zone FPYARD