IR 05000413/2017009
| ML17271A271 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/20/2017 |
| From: | Scott Shaeffer NRC/RGN-II/DRS/EB2 |
| To: | Simril R Duke Energy Carolinas |
| References | |
| IR 2017009 | |
| Download: ML17271A271 (25) | |
Text
UNITED STATES eptember 20, 2017
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1, AND 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000413/2017009 &
Dear Mr. Simril,
On August 10, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Catawba Nuclear Station, Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
The NRC inspectors did not identify and finding or violation of more than minor significance.
In accordance with 10 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 Website at http://www.nrc.gov./reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35, NPF-52
Enclosure:
Inspection Reports 05000413/2017009 and 05000414/2017009 w/Attachment:
Supplemental Information
REGION II==
Docket Nos: 50-413 and 50-414 License Nos.: NPF-35 & NPF-52 Report Nos.: 05000413/2017009 and 05000414/2017009 Licensee: Duke Energy Carolinas, LLC Facility: Catawba Nuclear Station, Units 1 and 2 Location: York, SC 29745 Dates: July 24 - July 28, 2017 (Week 1)
August 7 - August 10, 2017 (Week 2)
Inspectors: P. Braaten, Reactor Inspector J. Dymek, Reactor Inspector R. Fanner, Senior Reactor Inspector (Lead Inspector)
W. Monk, Reactor Inspector Approved by: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY
IR 05000413/2017009 and 05000414/2017009; 07/24/2017 - 07/28/2017 and 08/07/2017 -
08/10/2017; Catawba Nuclear Station Units 1 and 2; Fire Protection - NFPA 805 (Triennial)
This report covers an announced two-week triennial fire protection inspection by a team of four regional inspectors.
No findings of more than minor significance were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R05 Fire Protection
This report documents the results of a Triennial Fire Protection Inspection (TFPI) at the Catawba Nuclear Station (CNS), Units 1and 2. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05XT, Fire Protection - NFPA 805 (Triennial), issued January 31, 2013. Additionally, IP 71111.17T, Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications, issued January 1, 2017, was used to review a sample of engineering changes (EC). These changes were associated with licensing commitments made to complete the transition to 10 CFR 50.48(c). The objective of the inspection was to review a minimum sample of two risk-significant Fire Areas (FAs)/Fire Zones (FZs) to verify implementation of the Catawba Fire Protection Program (FPP). An additional objective was to review site specific implementation of one mitigating strategy credited with meeting the 10 CFR 50.54 (hh)requirements. These requirements are based on Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b). In addition, the team also reviewed the storage, maintenance, and testing of B.5.b mitigating equipment. The team leader performed an information gathering visit with the senior reactor analyst (SRA) and selected three FAs based on available risk information, data obtained from in-plant walkdowns regarding potential ignition sources, location and characteristics of combustibles, and location of equipment needed to achieve and maintain the reactor in a safe and stable condition. Other considerations for selecting the FAs were the relative complexity of the post-fire safe shutdown (SSD) procedures, information contained in FPP documents, and results of prior NRC TFPIs. In selecting the B.5.b mitigating strategy sample, the team reviewed licensee submittal letters, safety evaluation reports (SER), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. This inspection fulfilled the requirements of the inspection procedure based upon the sample selection of three FAs and one B.5.b mitigating strategy.
- Standby Shutdown Facility (SSF) - [Deterministic]
- Fire Area 10, Unit 1 Battery Room - [Performance Based]
- Fire Area 12, Unit 2, Electrical Penetration Room - [Performance Based]
For each of the selected FAs, the team evaluated the licensees FPP against applicable NRC requirements and design basis documents. Documents reviewed by the team for the following sections are listed in the Attachment section of the report.
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team examined the CNS fire response Abnormal Procedures (APs) and compared them to the NFPA 805 Nuclear Safety Capability Assessment (NSCA), Fire Risk Evaluations (FREs), systems flow diagrams, and other program documents, to determine if equipment required to achieve post-fire safe and stable plant conditions were properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50.48(c) and the CNS approved FPP commitments. The team requested and reviewed cable routing information for a selected sample of SSD components to verify that cables would not be damaged for the selected FAs fire scenarios or the licensees analysis determined that the fire damage would not prohibit achieving safe and stable plant conditions. A list of SSD components examined is included in the Attachment.
The team reviewed applicable sections of the APs for the selected FAs and fire scenarios to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe and stable plant conditions. The team performed in-plant walk-throughs of procedure steps to ensure the implementation and adequacy of human factors of applicable steps within the procedures. The team verified the licensee personnel credited for procedure implementation could respond in the event that a fire occurred, had valid procedures available, and were trained on their implementation based upon the respective samples. The team also reviewed credited recovery actions as well as operator actions that take place at primary control stations (PCSs) to ensure the feasibility and reliability of the actions. The specific fire response APs reviewed are also listed in the Attachment.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team conducted walkdown inspections and examined the material condition and as-built configuration of accessible passive barriers both surrounding and within the FAs selected for review to evaluate the adequacy of their fire resistance in accordance with NFPA 805 calculations. Fire barriers inspected included masonry walls, poured concrete ceilings, floors and walls and installed mechanical and electrical penetration seals, fire doors and fire dampers. The team compared the as-built installed barrier configurations to the approved construction details and supporting fire endurance test data, which established the rating of the fire barriers. Fire doors and dampers were examined for attributes such as their material condition, clearances, and proper operation, Underwriters Laboratory (UL) labels on the door and frame, and the method of attachment to the rated barrier. Doors were examined to verify that no modifications had been performed to void their UL listing. Fire dampers were confirmed to be capable of closing under air flow conditions or that ventilation could be secured before the damper could attempt to close under postulated fire conditions. The team reviewed licensing basis documentation such as 10CFR 50.48(a), 10CFR50.48(c) and the NRC NFPA 805 SER to verify that passive fire protection features met licensing commitments.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The team reviewed the licensees installed fire detection systems, water-based fire suppression systems and firefighting standpipe and hose systems protecting the selected FAs. The team reviewed the adequacy of the design, installation and operation of the fire detection and alarm systems to promptly detect fires in the selected fire areas and to annunciate to the fire alarm control panel in the control room. The review included walkdowns of as-built configurations and an examination of the type of detectors, detector spacing, the licensees technical evaluations of the detectors location relative to ignition sources, room geometry and fixed obstructions to assess whether the areas were protected in accordance with code of record requirements. The team also reviewed the licensees fire alarm response procedures, fire protection design basis document (DBD), NFPA 805 License Amendment Request (LAR) submittals and associated NRC NFPA 805 SER to verify that the fire detection and alarm systems for the selected FAs were installed in accordance with the design and licensing basis for the plant.
The team reviewed the material condition of the credited fire pumps, the underground water distribution system and its associated isolation valves, the newly installed water treatment system and heat tracing installed for freeze protection of piping exposed to outside weather. The team reviewed the appropriateness of compensatory measures for a fire pump that had been recently removed for refurbishment. The team reviewed the firefighting pre-plans and fire response procedures for the selected FAs to determine if appropriate information was provided to fire brigade members to facilitate suppression activities. These plans were reviewed and confirmed by field walkdowns to verify that they accurately reflected current plant configurations and firefighting equipment locations. These walkdowns also confirmed that fire hose and extinguisher access was properly maintained throughout the plant. The team evaluated whether the fire response procedures and pre-plans could be implemented as intended and that they addressed equipment important to safety, ventilation of heat and smoke from a fire and drainage/runoff from installed fixed fire suppression systems and manual hose streams.
Additionally, fire brigade drill records for recently run drills in each area were reviewed to confirm drill scenarios addressed specific hazards to likely be encountered in the areas and to verify actual fire brigade response times supported the fire brigade response time performance basis criteria. A walkdown of staged fire brigade personal protective equipment (PPE) was performed, with gear selected for inspection for its proper physical condition. An operating shift fire brigade was randomly selected to confirm that all members were currently qualified with regard to their medical and fire brigade training records. Current mutual aid agreements with local outside fire departments response to the plant in a fire emergency were reviewed as well as drill records for outside department participation for a postulated fire event. In addition, the inspectors witnessed a backshift fire drill postulating a fire in charging pump room 1A on the 543 elevation of the Auxiliary Building.
b. Findings
No findings were identified.
.04 Protection from Damage from Fire Suppression Activities
a. Inspection Scope
The team inspected the selected FAs to evaluate whether the ability to achieve the nuclear safety performance criteria could be adversely affected due to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. The team addressed the possibility that a fire in one FA could lead to the migration of smoke or hot gasses to other plant areas. The team also evaluated whether the manual firefighting activities could adversely affect the credited nuclear safety equipment and/or adversely affect local operator recovery actions for the selected fire areas. Additionally, the team checked that the firefighting water would either be contained in the fire affected area or be safely drained off through floor drains or stairwells. A review of potential flooding through unsealed floor cracks and absorption of water through penetration seals to areas beneath the selected FAs was conducted. This portion of the inspection was carried out through a combination of walkdowns, and reviews of drawings, calculations and installation records. Documents reviewed by the team are listed in the Attachment.
b. Findings
No findings were identified.
.05 Shutdown from a Primary Control Station
a. Inspection Scope
For postulated fire scenarios in FA 10, which may impair main control room (MCR)functions, the licensee credited shutdown from primary control stations (PCSs) to achieve safe and stable plant conditions. This would involve transferring plant controls from the MCR to the Standby Shutdown Facility (SSF). The inspectors verified that the credited strategy would accomplish the safety goals of NFPA 805 and that the required systems would be available given a fire event in FA 10. Additionally, the inspectors assessed the transfer function of affected circuits to ensure that the transfer would isolate any potential spurious operation.
b. Findings
No findings were identified.
.06 Circuit Analysis
a. Inspection Scope
The team assessed whether the licensee identified the structures, systems and components (SSCs) important to meeting the 10 CFR 50.48 requirements were consistent with the established licensing basis. The team reviewed the licensees updated final safety analysis report (UFSAR), the licensees circuit analysis documents, NSCA, post-fire procedures, electrical schematics, and system flow diagram drawings to gain an understanding of the SSD strategy. For the selected FAs, the team verified that the licensee had properly identified the required and associated circuits that could impact the ability to achieve and maintain safe and stable conditions. The team performed walk-downs of the selected FAs and independently verified the assumptions and results of the licensees fire scenario development analysis. The team verified, on a sample basis, that the licensee properly identified cables and equipment required to achieve and maintain safe and stable conditions, i.e. hot standby, for the selected fire scenarios in the selected FAs. The team verified that cables associated with safe shutdown-related equipment were protected from the adverse effects of fire damage or were analyzed to show that fire induced cable faults (e.g. hot shorts, open circuits, and shorts to ground) would not prevent shutdown to safe and stable conditions. In order to accomplish this, the team reviewed flow diagrams for safe shutdown systems, electrical schematics and cable routing data for power and control cables associated with each of the selected components to assess the licensees review of potential flow diversions or maloperations that may impact the nuclear safety performance criteria.
The team also reviewed electrical coordination, cable routing drawings, electrical one-line diagrams, component block diagrams, penetration and conduit plan drawings, and electrical control wiring diagrams for the selected SSD components to determine if these cables had either been adequately protected from the potential adverse effects of fire damage or analyzed to show that fire induced faults would not prevent post-fire SSD and then the associated risk scenario was incorporated into the licensees Fire PRA.
In addition, the team reviewed cable routing information to verify that fire protection features were in place to satisfy the requirements specified in the fire protection licensing basis and the licensees evaluations for spurious circuit failure scenarios (single and/or multiple) specified in the circuit analysis to determine if the sample list of components challenged the assumptions made in the SSD analysis. The specific components and references reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The inspectors reviewed plant communication capabilities to evaluate the availability of their sound powered phone, telephone/page, and portable radio systems to support plant personnel in the performance of recovery actions to achieve and maintain SSD, as credited in the CNS UFSAR, Section 9.5.1, Fire Protection. The team performed plant walk-downs with the licensees operations staff to assess the credited method of communications used to complete SSD actions as specified in post-fire SSD procedures for the selected FAs. Specifically, the team walked down sections of procedures for shutdown from the SSF to verify that portable radio communications and fixed emergency communication systems remained available, operable, and adequate for the performance of designated activities. Additionally, the team verified the capability of the communication systems to support the operators in the conduct and coordination of their required firefighting and SSD actions.
The team reviewed the adequacy of the communication system to support plant personnel in the performance of alternative post-fire safe-shutdown functions and fire brigade duties. The inspectors also reviewed the communication systems available at different locations within the plant that would be relied upon to support fire event notification and fire brigade firefighting activities to verify their availability at those locations. The team also verified that the electrical power source for the emergency sound powered phone system would allow it to remain functional following a fire in the selected FAs. Additionally, the team assessed the operators ability to communicate based upon observation of a licensee-conducted communications test with the emergency circuit sound powered phones in the selected FAs.
The team reviewed cable routing for the radio system including the associated repeaters to ensure that the required communication system remained functional following a fire in the selected FAs. Additionally, a walk-down of the Fire Brigade Storage Room and SSF was conducted to verify the material condition status of the Fire Brigades and SSD teams communication equipment. The team reviewed completed preventive maintenance and surveillance test records to verify that the communication equipment was being properly maintained and tested.
The team observed a licensee conducted fire drill in the Auxiliary Building on July 27, 2017 to assess the adequacy of communication used to respond to a probable fire while fully dressed out in protective ensembles. Specific documents reviewed by the team are listed in the Attachment.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The inspectors verified the adequacy of the plants emergency lighting systems through review of design and maintenance aspects and inspection walk-downs of the fixed 8-hour battery pack emergency lighting units (ELUs), as required by the CNS FSAR and licensees approved FPP. Specifically, the team reviewed the adequacy of the ELUs used to support plant personnel during post-fire safe shutdown for the selected FAs.
The team performed plant walk-downs and observed the placement and coverage area of fixed 8-hour battery pack emergency lights credited for SSD, to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. The inspectors reviewed preventive maintenance procedure IP/0/B/3540/002, "Emergency Battery Lighting Periodic Maintenance and Testing," Revision 41 to verify that adequate surveillance testing was in place. The inspectors reviewed the completed 8-hour capacity test records to verify that the ELUs were capable of meeting their mission time.
Additionally, the inspectors reviewed the ELU vendor manual to ensure that the ELUs were being maintained consistent with the manufacturers recommendations and maintenance practices were also being followed in accordance with the vendor guidance. Specific documents reviewed by the team are listed in the Attachment.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The nuclear safety goal provided in NFPA 805 is to establish reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition. The licensee defines safe and stable conditions as maintaining reactor coolant temperature at or below hot standby conditions, or fuel coolant temperature less than boiling. The licensee does not require transitioning to cold shutdown to achieve the safe and stable condition, and therefore does not require cold shutdown repairs to be implemented.
b. Findings
No findings 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 (e.g., detection and suppression systems and passive fire barriers). The team assessed the compensatory measures that had been established in the associated FAs against the FPP requirements for the applicable fire protection feature. The team verified that the risk associated with removing the fire protection feature from service was properly assessed and compensatory measures implemented were adequate consistent with new licensing basis requirements and the approved FPP.
b. Findings
No findings were identified.
.11 Radiological Release
a. Inspection Scope
The team reviewed possible radiological release paths to any unrestricted area due to the direct effects of fire suppression activities for each of the selected FAs. The inspectors reviewed the assumptions and methodology listed in their transition LAR to ensure that no radiological release would occur as a result of firefighting activities for fires in the inspected fire areas.
b. Findings
No findings were identified.
.12 Non Power Operations
a. Inspection Scope
One of the requirements in NFPA 805 was for licensees to implement FPP controls during non-power operational modes. Although CNS did not enter an outage during the inspection period, the team reviewed plant calculations, procedures, and analyses that defined the key safety functions required to maintain the plant in a safe and stable condition during non-power operational modes. The team also noted that where the licensee had identified specific areas or pinch points where one or more key safety functions could be affected, the licensee had identified additional actions, which would need to be taken during high-risk evolutions in the locations of the pinch points where key safety functions could be lost.
b. Findings
No findings were identified.
.13 Monitoring Program
a. Inspection Scope
The NFPA 805 requirements require a monitoring program to monitor plant performance as it applies to fire risk. The team reviewed procedure AD-EG-ALL-1503, NFPA 805 Monitoring, Rev. 1 to verify that a monitoring program was established to ensure that the availability and reliability of the fire protection systems and features credited in the performance-based analyses are maintained and to assess the performance of the FPP in meeting the performance criteria in accordance with NFPA 805. The team assessed the licensee establishment of performance monitoring groups that provided a link between components and functions. The team assessed that the items in scope were being monitored using the established performance based criteria as part of the normal engineering health reporting process. The team reviewed several fire protection system health reports to verify that the monitoring program ensured that the assumptions in the engineering analysis remain valid. The team also verified that the monitoring program instituted an appropriate process for implementing and tracking corrective actions to return availability, reliability, and performance of systems that fall outside of established levels.
b. Findings
No findings were identified.
.14 Plant Change Evaluation
a. Inspection Scope
The licensee stated that no changes had been made to the approved FPP, which required a plant change evaluation and thus, did not provide the team with any plant change evaluations to review during the inspection.
b. Findings
No findings were identified.
.15 B.5.b Mitigating Strategy
a. Inspection Scope
The team reviewed on a sample basis, the licensees preparedness to handle large fires or explosions by reviewing a selected mitigating strategy. The team verified the licensee continued to meet the requirements of their license condition and the 10 CFR 50.54 (hh)requirements, by: 1) reviewing procedures to ensure that they were being maintained and were adequate for the chosen strategy; and 2) performing walkdowns with licensee staff to ensure that the actions were feasible, and 3) ensuring the required equipment was properly staged, and 4) performance of interviews to verify that the staff was properly trained. The team also reviewed completed maintenance and testing records of equipment used within the strategy to ensure that the equipment was being maintained and was available consistent with vendor recommendations and licensee requirements.
b. Findings
No findings were identified.
1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications
a. Inspection Scope
The team reviewed a sample of plant modifications related to fire protection and/or the licensees transition to the NFPA 805. These modifications consisted of programmatic additions outside the previous licensing basis, replacement of obsolete equipment, and specific commitments made by the licensee based upon the NRC approval of the licensee transition to the 50.48(c) requirements. The team reviewed procedures, engineering calculations, circuit breaker coordination studies, engineering changes (ECs), work orders, one line diagrams, connection diagrams, corrective action documents, and applicable supporting analyses. The teams review assessed that changes resulting from the modifications were adequately incorporated in design basis documents and other associated plant procedures. The team performed plant walkdowns of a sample of these modifications. The team conducted interviews of plant personnel on selected aspects of changes with licensee personnel. The documents reviewed by the team are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The team reviewed a sample of recent independent licensee audits, condition reports, and self-assessments reports for thoroughness, completeness and conformance to FPP requirements. Guidance for the independent audits are contained in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, and Generic Letter 82-21, Technical Specifications for Fire Protection Audits.
The team also reviewed other corrective action program (CAP) documents, including completed corrective actions and operating experience program documents, to ascertain whether industry identified fire protection issues (actual or potential) affecting CNS were appropriately entered into the CAP for resolution. Items included in the operating experience program effectiveness review were NRC information notices, regulatory guides, regulatory issues summary, industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters.
The team evaluated the effectiveness of the corrective actions for the identified issues.
The documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On August 10, 2017, the inspection team leader presented the inspection results to Mr.
Tom Simril and other members of the licensees staff. The licensee acknowledged the results. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- T. Simril, Site Vice President
- S. Andrews, Sr. Licensing Engineer
- J. Brady, Fleet Regulatory Affairs
- T. Byrne, Fleet Regulatory Affairs
- T. Cheslak, Lead Engineer
- R. Cornwell, Lead Engineering
- C. Curry, Plant Manager
- T. Enos-Sylla, Sr. PRA Engineer
- J. Ertman, Risk Informed Functional Area Manager
- B. Felker, Engineering & Programs Supervisor
- C. Fletcher, Regulatory Affairs Manager
- M. Hogan, Engineering & Programs Supervisor
- L. Keller, Engineering General Manager
- A. Miller, Nuclear CR Supervisor
- T. Owusa, Regulatory Affairs
- B. Pryce, Engineering & Design Support
- L. Sweely, Engineering & Programs Safe Shutdown
NRC Personnel
- J. Austin, Sr. Resident Inspector
- C. Scott, Resident Inspector
SUPPLEMENTAL INFORMATION
Section 1R05.06: List of Safe Shutdown Components Inspected
Component Identification Description
0RYPUA Main Fire Pump A
0RYPUB Main Fire Pump B
0RYPUC Main Fire Pump C
1PMTR0279 Main Fire Pump Motor A
1PMTR0099 Main Fire Pump Motor B
1PMTR0100 Main Fire Pump Motor C
2VX PLHRA 2A H2 Recombiner Power Panel
1NV PUACC 1A Chemical and Volume Control Charging (NV) Pump
1NV PUBCC 1B Chemical and Volume Control Charging (NV) Pump
1NC VA0032B U1 Pressurizer PORV #1
1NC VA0034A U1 Pressurizer PORV #2
1NC VA0036B U1 Pressurizer PORV #3
1SV VA0019 1A Steam Generator PORV
2NC P5164 U2 Pressurizer Level Channel #1
2NC P5153 U2 Pressurizer Level Channel #2
2NC P5174 U2 Pressurizer Level Channel #3
1CFPUA U1 Main Feed Water Pump A
1CFPUB U1 Main Feed Water Pump B