IR 05000424/2015007

IR 05000424/2015007, 05000425/2015007; on 07/13-17/2015 - 07/27-31/2015; Vogtle Electric Generating Plant, Units 1 and 2; Fire Protection (Triennial)

ML15257A385
Person / Time
Site:	Vogtle
Issue date:	09/14/2015
From:	Scott Shaeffer NRC/RGN-II/DRS/EB2
To:	Taber B Southern Nuclear Operating Co
References
IR 2015007
Download: ML15257A385 (30)

Text

UNITED STATES September 14, 2015

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000424/2015007 AND 05000425/2015007

Dear Mr. Taber:

On July 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed with Mr. D. Myers and other members of your staff on July 31, 2015.

NRC Inspectors documented two findings of very low safety significance (Green) in this report.

These findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. If you contest these NCVs or their significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Vogtle Electric Generating Plant. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II; and the NRC Resident Inspector at the Vogtle Electric Generating Plant.

In accordance with Title 10 of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management 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.: 05000424, 05000425 License Nos.: NPF-68 and NPF-81

Enclosure:

Inspection Report 05000424/2015007 and 05000425/2015007 w/Attachment: Supplementary Information

REGION II==

Docket Nos.: 50-424, 50-425 License Nos.: NPF-68, NPF-81 Report Nos.: 05000424/2015007 and 05000425/2015007 Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA 30830 Dates: July 13 - 17, 2015 (Week 1)

July 27 - 31, 2015 (Week 2)

Inspectors: J. Dymek, Reactor Inspector W. Monk, Reactor Inspector J. Montgomery, Senior Reactor Inspector M. Thomas, Senior Reactor Inspector (Lead Inspector)

Accompanying K. Hamburger, Fire Protection Engineer (NSPDP), NRC Office of Personnel: Nuclear Regulatory Research, Fire Research Branch Approved by: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000424/2015007, 05000425/2015007; 07/13/2015 - 07/31/2015; Vogtle Electric

Generating Plant, Units 1 and 2; Fire Protection (Triennial)

The report covers an announced two-week triennial fire protection inspection by a team of four regional inspectors. Two Green non-cited violations were identified. The significance of inspection findings are indicated by their color (i.e., Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green.

An NRC-identified Green non-cited violation of Vogtle Units 1 and 2 Operating License Conditions 2.G, was identified for the licensees failure to ensure that fire doors V22108L1A67,

V12111L1238, and V12111L1A41 in 3-hour rated fire barriers were fully closed and latched, as required by the approved fire protection program (FPP) and National Fire Protection Association (NFPA) Code 80-1983, Fire Doors and Windows (Vogtle NFPA Code of Record). The licensee took corrective actions and declared fire door V22108L1A67 inoperable and established a roving fire watch. The inoperable door was entered into the licensees corrective action program as condition report (CR) 10067247 and was repaired the next day. For doors V12111L1238 and V12111L1A41, the licensee immediately removed materials that were interfering with the latching of the doors and entered these into their corrective action program as CR 10096004 and CR10096008 respectively. Because these two conditions were corrected as soon as they were brought to the licensees attention by the inspectors, no fire watch was required to be established.

The licensees failure to ensure the three fire doors were fully closed and latched as required by the approved FPP and NFPA Code 80-1983 was determined to be a performance deficiency.

This performance deficiency was more than minor because it affected the reactor safety mitigating systems cornerstone attribute of protection against external events (i.e., fire) and adversely affected the fire protection defense-in-depth element involving fire confinement and control of fires that do occur to protect systems important to safety. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review was required as the finding involved the ability to confine a fire. The finding category of Fire Confinement was assigned, based upon that element of the FPP being impacted. Using IMC 0609, Appendix F,

Attachment 1, Fire Protection Significance Determination Process Worksheet, the inspectors determined that the finding was of very low safety significance (Green) at Task 1.4.3, Question C, based upon observation that a fully functioning, automatically actuated, fire suppression system was installed on both sides of fire doors V12111L1238 and V12111L1A41 and on one side of fire door V22108L1A67. The inspectors determined that the finding had a cross-cutting aspect of Procedure Adherence in the Human Performance area because individuals did not follow processes and procedures for ensuring that fire doors were properly closed and latched after passing through the doors [H.8]. [Section 1R05.02.b(1)]

Green.

An NRC-identified Green non-cited violation of Vogtle Unit 1 Operating License Condition 2.G was identified for the licensees failure to identify and repair degraded fire penetration seal 1-11-759A, as required by the approved fire protection program (FPP). The licensee took corrective actions to declare the penetration seal inoperable, entered the issue in their corrective action program as condition report 10102010 and established a roving fire watch.

The licensees failure to identify and repair the degraded fire penetration seal 1-11-759A was a performance deficiency. This performance deficiency was more than minor because it affected the reactor safety mitigating systems cornerstone attribute of protection against external events (i.e., fire) and adversely affected the fire protection defense-in-depth element involving fire confinement and control of fires that do occur to protect systems important to safety. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609,

Significance Determination Process, Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review was required as the finding involved the ability to confine a fire. The finding category of Fire Confinement was assigned, based upon that element of the FPP being impacted. Using the criteria contained in IMC 0609 Appendix F, Attachment 2, Table A2.2, the inspectors concluded that the seal degradation level was low because the silicone foam seal depth and a fully intact damming board on one side of the barrier would have been sufficient to provide at least two hours of fire resistance. In addition, it was noted that the fire zones on each side of the degraded fire penetration seal were protected with an automatic fire suppression system. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the inspectors determined that the finding was of very low safety significance (Green) at Task 1.4.3, Question C. The inspectors determined that the finding had a cross-cutting aspect of Avoid Complacency in the Human Performance area because individuals inspecting the seals failed to recognize and plan for the possibility of the penetration seal being damaged. [H.12] [Section 1R05.02.b(2)]

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 Vogtle Electric Generating Plant (VEGP), Units 1 and 2. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), issued January 31, 2013. The objective of the inspection was to review a minimum sample of 3 risk-significant fire areas (FAs) to verify implementation of the VEGP fire protection program (FPP). An additional objective was to review site specific implementation of a minimum of one mitigating strategy from 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), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The FAs chosen for review were selected based on available risk information as analyzed by a Region II senior reactor analyst, data obtained during plant walk downs regarding potential ignition sources, location and characteristics of combustibles, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. Other considerations for selecting the FAs were the relative complexity of the post-fire SSD procedures, information contained in FPP documents, and results of prior NRC TFPIs. In selecting the B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports, licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-05 of the IP specifies a minimum sample size of three FAs and one B.5.b mitigating strategy for addressing large fires and explosions.

This inspection fulfilled the requirements of the IP by selecting four FAs and one B.5.b mitigating strategy. The FAs chosen were:

• Unit 1 Fire Area 1-CB-LA-N/Fire Zone 94: Unit 1 Train A Auxiliary Relay Room and HVAC Chase Room

• Unit 1 Fire Area 1-CB-LA-G/Fire Zone 103: Unit 1 Train A Shutdown Panel Room

• Unit 1 Fire Area 1-CB-L1-A/Fire Zone 105-1: Unit 1 Main Control Room (MCR)

• Unit 1 Fire Area 1-CB-L2-B/Fire Zone 120: Unit 1 Train B Cable Spreading Room The inspectors evaluated the licensees FPP against applicable requirements, including Renewed Operating License Condition 2.G; Title 10 of the Code of Federal Regulations, Part 50.48 (10 CFR 50.48); commitments to NRC Branch Technical Position (BTP)

Chemical Engineering Branch (CMEB) 9.5-1; VEGP Updated Final Safety Analysis Report (UFSAR); related NRC safety evaluation reports (SERs) including all applicable supplements; and plant Technical Specifications. The inspectors evaluated all areas of this inspection, as documented below, against these requirements. The B.5.b mitigating strategy selected for review was spent fuel pool external makeup. Specific licensing and design basis documents reviewed by the inspectors are listed in the Attachment.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The inspectors reviewed the licensees Fire Event Safe Shutdown Evaluation (FESSE)referenced in the UFSAR Chapter 9; the licensees fire hazards analysis (FHA); plant procedures; piping and instrumentation drawings (P&IDs); electrical drawings; and other supporting documents. The inspectors selected a sample of SSD systems to evaluate the licensees ability to safely shut down the plant in the event of a fire. The inspectors performed in-plant inspections to verify that the plant configuration was consistent with that described in the FESSE. The inspectors reviewed the licensees shutdown methodology to verify that it properly identified the components and systems necessary to achieve and maintain SSD conditions for postulated fires resulting in shutdown from the MCR. The inspectors reviewed conduit and cable tray drawings, as well as field walk-downs of the cable routing to confirm that at least one train of redundant cables routed in the fire zones (FZs) was adequately protected from fire damage. The inspectors focused their inspection activities on systems specified in the FESSE for reactivity control, reactor coolant makeup, and decay heat removal; as well as process monitoring instrumentation and necessary support systems, such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.

The inspectors reviewed and performed a walkthrough of procedure steps used for post-fire SSD to ensure the technical and human factors adequacy of the procedures. The inspectors verified the licensee personnel credited for performance of procedures were available in the event a fire occurred. The inspectors also verified that the credited licensee personnel had procedures available, and were trained on implementation. The inspectors reviewed and walked down applicable sections of procedure 17103-C, Annunciator Response Procedures for Fire Alarm Computer. The inspectors reviewed operator actions to ensure these actions could be implemented in accordance with plant procedures in a manner necessary to support the SSD method for the applicable FA/FZ.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

For the selected FAs, the inspectors verified the adequacy of fire walls, ceilings, floors, mechanical and electrical penetration seals, fire doors, and fire dampers. The inspectors walked down accessible portions of the selected FAs to observe material condition of the passive barriers and to identify degradation or non-conformances. The inspectors compared the installed configurations to the approved construction details and supporting fire endurance test data to assure that the respective fire barriers met the requirements of Branch Technical Position CMEB 9.5.1, Fire Protection for Nuclear Power Plants. In addition, the inspectors reviewed licensing bases documentation to verify that passive fire protection features met license commitments. A sample of completed surveillance and maintenance procedures for selected fire doors, fire dampers, and penetration seals were reviewed to ensure that these passive fire barriers were being properly inspected and maintained. Specific barriers reviewed are listed in the Attachment.

b. Findings

(1) Failure to Ensure Plant Fire Doors Were Fully Closed and Latched

Introduction:

An NRC-identified Green non-cited violation (NCV) of Vogtle Units 1 and 2 Operating License Conditions 2.G, was identified for the licensees failure to ensure that fire doors V22108L1A67, V12111L1238, and V12111L1A41 in 3-hour rated fire barriers were fully closed and latched, as required by the approved fire protection program (FPP)and National Fire Protection Association (NFPA) Code 80-1983, Fire Doors and Windows (Vogtle NFPA Code of Record).

Description:

During a walkdown of Vogtle Unit 2 performed by a NRC Senior Resident Inspector on May 8, 2015, it was observed that fire door V22108L1A67, would not close and securely latch. The door was located at Unit 2, Level A between the Auxiliary Building Central Area and Auxiliary Building Wing Area. The door would not latch because the concealed vertical rod within the door had loosened and would not align and engage the door frame properly. The licensee did not initiate corrective actions until the following day when fire door V22108L1A67 was declared inoperable, a fire protection limiting condition for operation (LCO) was created, and an hourly roving fire watch was established. The door was repaired before the end of that days shift, the fire protection LCO was closed, and the roving fire watch was terminated. During a walkdown on July 14, 2015, NRC inspectors observed that fire door V12111L1238 would not close and securely latch. This door was located at Unit 1, Level 2, between Cable Spreading Room B and the Control Building Corridor. The door would not latch due to masking tape being placed across both the latch bolt and the strike plate as part of preparation for painting the door. After the issue was identified by the NRC inspectors, licensee personnel promptly removed the masking tape covering the door hardware, which allowed the door to close and latch securely. The licensee entered the issue in their corrective action program as CR 10096004. A fire watch was not required because the door was returned to an operable condition during the inspection walkdown. During the same walkdown on July 14, 2015, the inspectors observed that a second fire door, V12111L1A41, also would not close and securely latch. This door is located at Unit 1, Level A, between Shutdown Room Train B and Control Building Train B Corridor. The door would not latch due to a worn rubber seal becoming lodged in the door strike plate.

The seal had been installed to prevent a fire suppression agent (Halon) from leaking past the fire door gap between the active and passive leafs of door V1211L1A41 during a Halon system discharge. After the issue was identified by the inspectors, licensee personnel promptly cut away the rubber seal material, which allowed door V1211L1A41 to close and latch securely. The licensee entered the issue in their corrective action program as CR 10096008. A fire watch was not required because the door was returned to an operable condition during the inspection walkdown. A completely new seal was installed before the end of the inspection.

Analysis:

The licensees failure to ensure three fire doors were closed and securely latched as required by the approved FPP and NFPA Code 80-1983 was a performance deficiency. This performance deficiency was more than minor because it affected the reactor safety mitigating systems cornerstone attribute of protection against external events (i.e., fire) and adversely affected the fire protection defense-in-depth element involving fire confinement and control of fires that do occur to protect systems important to safety. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review was required as the finding involved the ability to confine a fire. The finding category of Fire Confinement was assigned, based upon that element of the FPP being impacted. Using IMC 0609, Appendix F, 1, Fire Protection Significance Determination Process Worksheet, the inspectors determined that the finding was of very low safety significance (Green) at Task 1.4.3, Question C, based upon inspector observations that a fully functioning, automatically actuated, fire suppression system was installed on one side of fire door V22108L1A67 and on both sides of fire doors V12111L1238 and V12111L1A41. The inspectors determined that the finding had a cross-cutting aspect of Procedure Adherence in the Human Performance area because individuals did not follow processes and procedures for ensuring that fire doors were properly closed and latched after passing through the doors [H.8].

Enforcement:

Vogtle Unit 1 and Unit 2 Operating License Condition(s) 2.G require that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR for the facility, as approved in the SER (NUREG-1137) through Supplement 5 for Unit 1 and Supplement 9 for Unit 2. The approved FPP is documented in UFSAR Section 9.5.1 and associated Appendices 9A and 9B. UFSAR Section 9.5.1.2.1.2 states in part that, Door assemblies through fire barriers have fire ratings commensurate with those required of the fire barrier and These doors are either self-closing or automatic closing types or are normally secured closed. NFPA 80-1983 Fire Doors and Windows (VEGP FPP Code of Record) Section 2-8.7.1 states that The door shall swing easily and freely and shall be equipped with a closing device to cause the door to close and latch each time it is opened. UFSAR Table 9.5.1-9, Exception to NFPA Codes states that compliance to NPFA 80-1983, Fire Doors and Windows, Section 2-8.7.1, is met because Personnel are trained on the proper use of doors to ensure they are fully closed and latched following use.

Furthermore, Vogtle Unit C Standard for Use of Doors, Rev. 10 Section 3.1 states, It is the responsibility of all individuals (SNC personnel and contractors) to properly use doors, not abuse them. Proper use involves ensuring that the door is properly positioned after passing through it. For most doors this involves verifying the door is closed and latched.

Contrary to the above, the licensee did not implement all provisions of the approved FPP as described in the VEGP UFSAR. On May 8, 2015, NRC inspectors identified that the licensee failed to ensure that fire door V22108L1A67, would close and securely latch and similarly on July 14, 2015, fire doors V12111L1238 and V12111L1A41 would not close and securely latch either, thereby causing the associated fire barriers to be less than the required fire resistance rating. Because the finding was of very low safety significance and it was entered in the licensees corrective action program as CR 10067247, CR 10096004 and CR 10096008, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. NCV 05000424/2015007-01 and 05000425/2015007-01, Failure to Fully Close and Latch Plant Fire Doors.

(2) Failure to Identify and Repair a Degraded Fire Penetration Seal

Introduction:

An NRC-identified Green NCV of Vogtle Unit 1 Operating License Condition 2.G was identified for the licensees failure to identify and repair degraded fire penetration seal 1-11-759A, as required by the approved fire protection program (FPP).

Description:

During a walkdown of the Unit 1 Cable Tunnel, the inspectors identified Control Building penetration seal 1-11-759A was missing a portion of 1-inch thick damming board on the Cable Tunnel side of the barrier. The penetration seal was part of a three-hour fire barrier which separated cable raceway between the Cable Tunnel and the Control Building Corridor on Level A of the Control Building. As viewed from the Cable Tunnel, the 18-inches high by 18-inches wide penetration was missing a portion of 1-inch thick damming board in proximity to several cables running through the penetration that had been abandon in place. Per penetration seal detail M0101 (Drawing AX1AG11-00011), a 1-inch thick damming board was required to be intact on both sides of the barrier. In addition, the interior of the seal was to contain a minimum of 7-inches of silicone foam. The licensee inspected the integrity of penetration seals for fire barriers on an 18-month interval, and the inspectors noted that the penetration was last inspected on January 27, 2015, during the performance of Procedure 29114-C, Fire Boundaries and Fire Rated Penetration Seal 18-Month Visual Inspection, and work order SNC447848, 18-month Fire Area Boundaries Visual Inspection. The licensees inspection did not identify any discrepancies for the inspection. Since the licensee did not identify any work activities that may have damaged the seal since completion of the most recent inspection, it was reasonable to assume that the deficiency was missed during the surveillance performed on January 27, 2015. After the issue was identified by the NRC inspectors, licensee personnel evaluated the condition, declared the fire penetration seal inoperable, entered the issue in their corrective action program as CR 10102010 and established a roving fire watch in accordance with Fire Protection Plan, Table 9.5.1-10, Section 7.3.

Analysis:

The licensees failure to identify and repair damaged fire penetration seal 1-11-759A was a performance deficiency. This performance deficiency was more than minor because it affected the reactor safety mitigating systems cornerstone attribute of protection against external events (i.e., fire) and adversely affected the fire protection defense-in-depth element involving fire confinement and control of fires that do occur to protect systems important to safety. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review was required as the finding involved the ability to confine a fire. The finding category of Fire Confinement was assigned, based upon that element of the FPP being impacted.

Using the criteria contained in IMC 0609 Appendix F, Attachment 2, Table A2.2, the inspectors concluded that the seal degradation level was low because the silicone foam seal depth and a fully intact damming board on one side of the barrier would have been sufficient to provide at least two hours of fire resistance. In addition, it was noted that the fire zones on each side of the degraded fire penetration seal were protected with an automatic fire suppression system. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the inspectors determined that the finding was of very low safety significance (Green) at Task 1.4.3, Question C.

The inspectors determined that the finding had a cross-cutting aspect of Avoid Complacency in the Human Performance area because individuals inspecting the seals failed to recognize and plan for the possibility of the penetration seal being damaged

[H.12].

Enforcement:

Vogtle Unit 1 Operating License Condition 2.G requires that the licensee implement and maintain in effect all provisions of the approved FPP as described in the UFSAR for the facility, as approved in the NRC SER (NUREG-1137) through Supplement 9. The approved FPP is documented in UFSAR Section 9.5.1 and associated Appendices 9A and 9B. UFSAR Appendix 9B, Section C.5.a, Building Design, states, in part, that penetration seals shall be used to seal openings through fire barriers that separate fire areas. The seal shall provide a fire resistance rating at least equal to the barrier itself.

Contrary to the above, on July 28, 2015, the inspectors identified that the licensee failed to implement the approved fire protection program in that they did not seal an opening through a fire barrier for cabling that had been abandon in place. Specifically, the licensee failed to identify and correct a degraded cable penetration seal in the 3-hour rated wall between the Cable Tunnel and the Control Building Corridor that was missing a portion of 1-inch thick damming board. This caused the penetration seal to be less than the required 3-hour fire rating. Because the finding was of very low safety significance and it was entered into the licensees corrective action program as CR 10102010, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. NCV 05000424/2015007-02, Failure to Identify and Repair a Degraded Fire Penetration Seal.

.03 Active Fire Protection

a. Inspection Scope

For the selected FAs, the inspectors performed in-plant observations to verify the material condition and operational lineup of the fire protection water supply; automatic water and Halon fire suppression systems, manual fire hose and standpipe systems and installed fire extinguishers. The inspectors reviewed engineering drawings and specifications to verify that the as-built configuration of fire suppression equipment was adequately maintained. Internal standpipe and hose stations, and heat and smoke detection systems were reviewed against specifications, drawings and engineering calculations to verify that the fire detection and suppression methods were appropriate for the types of fire hazards that existed in the FAs. The inspectors also verified that the suppression equipment met applicable NFPA standards. The inspectors reviewed completed surveillance testing and maintenance procedures to verify that the equipment was adequately maintained. The inspectors reviewed fire fighting pre-plans to verify that the strategies were adequate. The inspectors observed the fire brigade staging and dress out areas to assess the condition of fire fighting and smoke control equipment. In addition, the inspectors verified the capabilities of the fire brigade by reviewing staffing, qualification, and training records. The Letters of Agreement with off-site emergency responders were reviewed to verify the availability of additional resources to combat fires.

b. Findings

No findings were identified.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The inspectors evaluated whether manual water-based fire fighting activities or heat and smoke migration 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. Fire Strategies (pre-fire plans); fire brigade training procedures; heating, ventilating and air conditioning (HVAC) drawings; and abnormal procedures for fires were also reviewed to verify that inter-area migration of water or the ventilation of heat and smoke were addressed and would not adversely affect SSD equipment or the performance of operator manual actions. Calculations and analysis addressing the inadvertent operation or postulated failure of water based suppression systems, including water hammer from rapid system depressurization were also reviewed to determine impact on SSD equipment.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

Methodology The licensee credited an alternative shutdown capability for a postulated fire in FZ 105-1. The inspectors reviewed UFSAR Section 9.5.1, the Control Room Safe Shutdown Evaluation, and corresponding abnormal procedures to ensure that appropriate controls provided reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. In cases where local operator manual actions (OMA) were credited in lieu of cable protection of SSD components, the inspectors performed a walk-through of the procedures to determine if the operators could reasonably be expected to perform the alternative safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedures.

The inspectors reviewed applicable P&IDs to gain an understanding of credited equipments flow path and function. The inspectors reviewed applicable licensee calculations to ensure the alternative shutdown methodology properly identified systems and components to achieve and maintain safe-shutdown for the FAs selected for review.

The inspectors reviewed procedures, work orders, and completed surveillances to verify that the alternative shutdown transfer capability was periodically tested. Additionally, the inspectors reviewed electrical schematics and one line diagrams to ensure that the transfer of safe shutdown control functions to the alternate shutdown facility included sufficient instrumentation to safely shutdown the reactor. This review also included verification that shutdown from outside the main control room could be performed both with and without the availability of offsite power.

Operational Implementation The inspectors reviewed procedure 18038-1, Operation from Remote Shutdown Panels, Version 33.7, to verify the adequacy of this procedure to mitigate a fire in FZ 105-1. The inspectors reviewed selected training materials for licensed and non-licensed operators to verify that training reinforced the shutdown methodology that is utilized in the FPP and abnormal procedures for fires.

The inspectors performed a walk-through of selected procedure steps with operations personnel to assess the implementation and human factors adequacy of the procedures and shutdown strategy to evaluate the ambient conditions, difficulty, and operator familiarization associated with selected OMAs. The inspectors reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The inspectors reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.

b. Findings

No findings were identified.

.06 Circuit Analysis

a. Inspection Scope

The inspectors reviewed the licensees FPP referenced in the UFSAR Chapter 9, which included the FHA, FESSE, plant procedures, and system P&IDs to verify that the licensee had identified required and associated circuits that may impact post-fire SSD for the selected FA/FZs. This review included assessing the potential for flow diversion paths, loss of function, or other scenarios that would adversely impact the plants ability to achieve and maintain SSD conditions. The inspectors reviewed the licensees post-fire SSD procedures and compared them with the post-fire SSD analysis and component separation analysis for the selected FAs/FZs.

The inspectors then reviewed a representative sample of the credited SSD components in the selected FA/FZs to verify that the components specified in the post-fire SSD procedures were available for a postulated fire and met their SSD function. The inspectors also reviewed cable routing information and electrical control wiring diagrams for these selected SSD components to determine if these cables had either been adequately protected from the potentially adverse effects of fire damage or analyzed to show that fire induced faults would not prevent post-fire SSD. Specifically, this review analyzed whether identified combinations of individual circuit conductors which, if shorted together due to fire damage, could cause spurious operation or non-operation.

The inspectors conducted walkdowns in the selected FAs/FZs to determine if the credited components relied upon for SSD would still be available given a fire in the FA/FZs. For instances where cables traversed through the selected FAs/FZs, the inspectors performed more detailed circuit analysis to verify fire induced damage would not adversely impact the credited SSD methodology.

Additionally, a review was conducted of routing information for credited active fire protection and SSD components to determine if a fire in the selected FA/FZs would impact the credited defense-in-depth systems. The inspectors reviewed 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 SSA. The inspectors reviewed the licensees electrical coordination study calculations to determine if power supplies were susceptible to fire damage, which would potentially affect the credited components for the FAs/FZs selected for review. The specific components and references reviewed are listed in the

.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The inspectors reviewed the communication capabilities (telephone/page, PABX and sound powered phones (SPP) systems) required to support plant personnel in the performance of OMAs to achieve and maintain SSD, as credited in UFSAR Section 9.5.2. The inspectors verified the capability of the SPP system, and verified that cables for communication equipment would not be affected by a fire in the selected FAs/FZs.

The inspectors reviewed preventative maintenance and surveillance test records to verify that the communication equipment was being properly maintained. Additionally, the inspectors assessed the operators ability to communicate based upon observation of a licensee-conducted communications test with the SSD SPPs and fire brigade radios. The inspectors also verified that the design and location of communications equipment, such as repeaters and transmitters, would not cause a loss of communications during a fire.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The inspectors reviewed maintenance and design aspects of the fixed 8-hour battery pack emergency lighting units (ELUs) required by the licensees FPP. The inspectors performed plant walkdowns of the post-fire SSD procedures for the selected FAs/FZs to observe the placement and coverage area of the ELUs throughout the selected FAs/FZs. The inspectors also evaluated the adequacy of the ELUs to illuminate access and egress pathways, and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. Licensee personnel performed in-plant functional tests of the ELUs providing light for OMAs listed in the post-fire SSD procedures for the selected FAs/FZs to verify ELU operation. The inspectors reviewed preventive maintenance procedures and completed surveillance tests to verify that adequate surveillance testing was in place. The inspectors reviewed vendor manuals to ensure that the ELUs were being maintained consistent with manufacturers recommendations.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the FHA, UFSAR and plant procedures for responding to fires and implementing SSD activities in order to determine if any repairs were required to achieve cold shutdown. One system and two rooms were identified has having potential repairs required to achieve cold shutdown.

The licensee had designated the Train B Emergency Diesel Generator Fuel Oil Transfer Pumps for potentially requiring repair, in the form of a control circuit emergency jumper, in order to reach cold shutdown based on the SSD methodology implemented.

The inspectors verified that the jumper was readily available and that the procedure to install it was adequate. The licensee had also designated the CB-313 Chiller Room and CB-226 Auxiliary Relay Room for potentially requiring repair, in the form of setting up temporary ventilation, in order to reach cold shutdown based on the SSD methodology implemented. The inspectors verified that the exhaust fans and temporary blowers were readily available and that the procedure to set them up was adequate.

The inspectors also evaluated whether cold shutdown could be achieved within the required time period using the licensees procedures and repair methods to walk-down the cold shutdown repair actions. Specific documents reviewed by the inspectors are listed in the Attachment.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

Compensatory Measures for Degraded Fire Protection Components 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 impairment and compensatory measures forms for fire watch tours to confirm they were being performed within the allowable time frames.

Operator Manual Actions as Compensatory Measures for Safe Shutdown The inspectors reviewed applicable sections of Calculation X4C2301S026, Fire Event Safe Shutdown Evaluation (FESSE) Control Building, Calculation X4C2301S311, VEGP Multiple Spurious Operations Analysis, and Procedure 17103-C, Annunciator Response Procedures for Fire Alarm Computer, to identify OMAs credited for SSD. In cases where local OMAs were credited in lieu of cable protection or separation of SSD equipment, the inspectors performed walk downs of those applicable OMAs to verify that the OMAs were feasible, utilizing the guidance of NRC IP 71111.05T, paragraph 02.02.j.2.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The inspectors reviewed modifications associated with the FPP to verify that changes were in accordance with the fire protection license condition and had no adverse effect on the ability to achieve SSD. Modifications reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The inspectors conducted walkdowns of numerous plant areas that were important to reactor safety, including the selected FAs, to verify the licensees implementation of fire protection requirements as described in procedures 92015-C, Use, Control and Storage of Flammable/Combustible Materials, NMP-ES-035-007, Fleet Hot Work Instructions and NMP-ES-035-012, Fire Protection Work Reviews. The inspectors verified that the licensee had properly evaluated transient fire hazards, controlled hot-work activities, and maintained general housekeeping consistent with administrative control procedures and the fire hazards analysis. For the selected FAs, the inspectors evaluated the potential for fires and explosions, and potential fire severity. Fire watch and craft personnel were interviewed for familiarity with job requirements. No hot work was observed as part of the inspection activities within the selected fire areas.

b. Findings

No findings were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed, on a sample basis, the licensees mitigation measures for spent fuel pool external makeup utilizing the portable pump for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the strategies, and equipment was properly staged and maintained. The inspectors reviewed the licensees established program, applicable SERs and submittals which supported the elements outlined by the license condition. The inspectors reviewed inventory, surveillance testing, and maintenance records of required equipment to verify that the licensee continued to meet the requirements of their B.5.b license condition and 10 CFR 50.54 (hh)(2). Through discussions with plant staff, documentation review, and plant walkdowns, the inspectors verified the engineering basis to establish reasonable assurance that the makeup capacity could be provided using the specified equipment and water sources. The inspectors reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply.

The inspectors performed a walk-down of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures was available and maintained. The inspectors reviewed training records of the licensees staff to verify that operations and security personnel training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed a sample of recent licensee independent audits, CRs, self-assessments, and system/program health reports for thoroughness, completeness and conformance to FPP requirements described in the VEGP UFSAR and FPP. The inspectors also reviewed Corrective Action Program (CAP) documents, including completed corrective actions documented in selected CRs, to verify that fire protection deficiencies were adequately identified, evaluated, and that appropriate corrective actions were implemented. The CRs were reviewed with regard to the attributes of timeliness and apparent cause determination to ensure that proposed corrective actions addressed the apparent cause, reportability and operability determinations. In addition, operating experience program documents were also reviewed to verify that industry-identified fire protection problems, potentially or actually affecting VEGP were appropriately entered into and resolved by the CAP process and the inspectors evaluated the effectiveness of the corrective actions for the identified issues. Specific documents reviewed by the inspectors are listed in the Attachment. Specifically, the ELU System 10 CFR 50.65 a(1) Maintenance Rule Status Plan was reviewed and found to be adequate based on the licensee has complied with 10 CFR 50.65 a(1) by taking adequate corrective actions. Specifically, the licensee has placed the system in a(1)status, set ELU System maintenance performance goals, examined their MR performance criteria definition, and has adequate maintenance corrective actions in place. CRs were entered into the CAP for ELU functional failures and discharge test failures. The inspectors determined the Status Plan to be adequate in order to return the system to a(2) status in a timely manner.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On July 31, 2015, the lead inspector presented the preliminary inspection results and findings to Mr. D. Myers, VEGP Plant Manager, and other members of the licensees staff. The licensee acknowledged the findings. Proprietary information is not included in this inspection report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baker, Security Manager

B. Coker, Engineering Programs Manager

J. Covington, Fire Protection Engineer

R. Daniel, Fire Marshall

B. Frey, Maintenance Director

G. Gunn, Regulatory Affairs Manager

S. Harris, Work Control Manager

J. Hemena, Engineering Programs Supervisor

J. Klecha, Operations Director

J. Lattner, Principal Fire Protection Engineer

R. Linebarger, Fire Protection (Units 3 and 4)

K. Morrow, Licensing Engineer

D. Myers, Plant Manager

A. Parton, Nuclear Oversight Manager

J. Singleton, Fire Protection Engineer

J. Summy, Engineering Director

D. Sutton, Site Projects Manager

M. Sykes, Safe Shutdown Engineer

J. Thomas, Work Management Director

K. Walden, Licensing Engineer

NRC Personnel

A. Alen, Resident Inspector

M. Cain, Senior Resident Inspector

S. Shaeffer, Chief, Engineering Branch 2, Division of Reactor Safety, Region II

LIST OF REPORT ITEMS

Opened and Closed

05000424, 425/2015007-01 NCV Failure to Fully Close and Latch Plant Fire Doors (Section 1R05.02.b(1))

05000424/2015007-02 NCV Failure to Identify and Repair a Degraded Fire Penetration Seal (Section 1R05.02.b(2))