IR 05000498/2014008
| ML14295A263 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/21/2014 |
| From: | Greg Werner NRC/RGN-IV/DRS/EB-2 |
| To: | Koehl D South Texas |
| Werner G | |
| References | |
| IR 2014008 | |
| Download: ML14295A263 (30) | |
Text
ber 21, 2014
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000498/2014008 AND 05000499/2014008
Dear Mr. Koehl:
On September 25, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The team documented the results of this inspection in the enclosed inspection report.
An NRC team of inspectors documented one finding of very low safety significance (Green) in this report. Further, a licensee-identified violation that was determined to be of very low safety significance is documented in this report. Both of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of the violations in this report, you should provide a written 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 IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2.
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, 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 NRC's Agencywide Documents Access and Management 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/
Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Dockets: 50-498; 50-499 Licenses: NPF-76; NPF-80
Enclosure:
Inspection Report No 05000498/2014008 AND 05000499/2014008 w/Attachment: Supplemental Information
REGION IV==
Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report Nos.: 05000498/2014008 and 05000499/2014008 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: September 8 through 25, 2014 Team Leader: Greg Pick, Senior Reactor Inspector, Engineering Branch 2 Inspectors: Brian Larson, Senior Operations Examiner, Operations Branch Steven Alferink, Reactor Inspector, Engineering Branch 2 Brian Correll, Reactor Inspector, Engineering Branch 2 Nicholas Hernandez, Resident Inspector Approved By: Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety-1- Enclosure
SUMMARY OF FINDINGS
IR 05000498/2014008, 05000499/2014008; 09/08 - 09/25/2014; South Texas Project Electric
Generating Station, Units 1 and 2; Triennial Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors from Region IV. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one licensee-identified violation of very low safety significance. The significance of inspection findings is indicated by their color (i.e., Green, White, Yellow, or Red) and determined using Inspection Manual Chapter 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The team identified a non-cited violation of Technical Specification 6.8.1.d for the failure to implement and maintain written procedures for fire protection program implementation. Specifically, the licensee failed to have procedures for and to flow test the portions of the underground piping that supplied water to the diesel generator buildings since the initial startup test. The licensee initiated actions to perform the flow testing within two months and entered the deficiency into their corrective action program as Condition Report 14-17098.
The failure to conduct flow testing of the entire underground fire protection piping loop was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors attribute (fire) and adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to performance test the underground fire protection piping loops supplying the emergency diesel generator buildings for both units did not demonstrate the continued capability to deliver adequate flow and pressure to the fire suppression systems supplying those buildings.
The team evaluated the finding using Inspection Manual Chapter 0609, Appendix F,
Fire Protection Significance Determination Process, because it affected fire protection defense-in-depth strategies involving fire water supply. Using Appendix F, the team determined that the finding screened to very low safety significance. Specifically, the finding did not prevent the reactor from achieving safe shutdown since only one safe shutdown train would be affected at a time. Since these underground fire protection piping loops had not been flow tested since initial installation and nothing caused the licensee to reevaluate the test, the team determined that this failure did not reflect current performance. (Section 1R05)
Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection
This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure 71111.05T, Fire Protection (Triennial), at the South Texas Project Electric Generating Station, Units 1 and 2. The inspection team evaluated the implementation of the approved fire protection program in selected risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and systems that ensure the post-fire capability to safely shutdown the plant.
Inspection Procedure 71111.05T requires the selection of three to five fire areas and one or more mitigating strategies for review. The inspection team used the fire hazards analysis section of the South Texas Project Electric Generating Station, Units 1 and 2 Individual Plant Examination of External Events to select the following four risk-significant fire areas (inspection samples) for review:
Fire Area Fire Zone Description Z032 Relay cabinet room Z034 Control room Z147 Locker rooms and clothing issue Z046 Train C electrical penetration area Z050 Corridor, offices, CAS battery room and electrical equipment Z052 Train C ESF switchgear room Z047 Cable Spreading Room The inspection team evaluated the licensees fire protection program using the applicable requirements, which included plant Technical Specifications, Operating License Condition 2.E, NRC safety evaluations, 10 CFR 50.48, and Branch Technical Position 9.5-1. The team also reviewed related documents that included the Updated Final Safety Analysis Report, Section 9.5; the fire hazards analysis; and the post-fire safe shutdown analysis. Specific documents reviewed by the team are listed in the attachment.
Four fire area inspection samples and one mitigating strategy sample were completed.
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the piping and instrumentation diagrams, safe shutdown equipment list, safe shutdown design basis documents, and the post-fire safe shutdown analysis to verify that the licensee properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for fires in the selected fire areas. The team observed walk downs of the procedures used for achieving and maintaining safe
shutdown in the event of a fire to verify that the procedures properly implemented the safe shutdown analysis provisions.
For each of the selected fire areas, the team reviewed the separation of redundant safe shutdown cables, equipment, and components located within the same fire area. The team also reviewed the licensees method for meeting the requirements of 10 CFR 50.48; Branch Technical Position 9.5-1, Appendix A; and 10 CFR Part 50, Appendix R, Section III.G. Specifically, the team evaluated whether at least one post-fire safe shutdown success path remained free of fire damage in the event of a fire.
In addition, the team verified that the licensee met applicable license commitments.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe the material condition and configuration of the installed fire area boundaries (including walls, fire doors, and fire dampers) and verify that the electrical raceway fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.
The team reviewed installation, repair, and qualification records for a sample of penetration seals to ensure the fill material possessed an appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected fire areas. The team verified the automatic detection systems and the manual and automatic suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association code of record or approved deviations and that each suppression system was appropriate for the hazards in the selected fire areas.
The team performed a walkdown of accessible portions of the detection and suppression systems in the selected fire areas. The team also performed a walkdown of major system support equipment in other areas (e.g., fire pumps and Halon supply systems) to assess the material condition of these systems and components.
The team reviewed the electric and diesel fire pumps flow and pressure tests to verify that the pumps met their design requirements. The team also reviewed the halon suppression functional tests to verify that the system capability met the design requirements.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. In addition, the team inspected fire brigade equipment to determine operational readiness for fire fighting.
The team observed an unannounced fire drill and subsequent drill critique on September 23, 2014, using the guidance contained in Inspection Procedure 71111.05AQ, Fire Protection Annual/Quarterly. The team observed fire brigade members fight a simulated fire in the electrical auxiliary building. The team verified that the licensee identified problems, openly discussed them in a self-critical manner at the drill debrief, and identified appropriate corrective actions. Specific attributes evaluated were:
- (1) proper wearing of turnout gear and self-contained breathing apparatus; (2)proper use and layout of fire hoses;
- (3) employment of appropriate fire fighting techniques;
- (4) sufficient fire fighting equipment was brought to the scene; (5)effectiveness of fire brigade leader communications, command, and control;
- (6) search for victims and propagation of the fire into other areas;
- (7) smoke removal operations; (8)utilization of pre-planned strategies;
- (9) adherence to the pre-planned drill scenario; and
- (10) drill objectives.
b. Findings
Introduction.
The team identified a Green non-cited violation of Technical Specification 6.8.1.d for the failure to implement and maintain written procedures for fire protection program implementation. Specifically, the licensee failed to have procedures for and to flow test the portions of the underground piping that supplied water to the diesel generator buildings since the initial startup test. The licensee initiated actions to perform the flow testing within two months and entered the deficiency into their corrective action program as Condition Report 14-17098.
Description.
The team reviewed the underground fire protection piping loop flow testing conducted in accordance with their fire protection program. Procedure 0PGP03-ZF-0018, Fire Protection System Functionality Requirements, Revision 17, specified that the licensee shall perform flow testing at least once every 3 years in accordance with Chapter 8, Section 17 of the Fire Protection Handbook, 17th Edition, published by the National Fire Protection Association. As specified in the Fire Protection Handbook, Chapter 8, Section 17, the hydrant flow tests (i.e., underground fire protection piping) are used to determine the adequacy and reliability of the water system. Specifically, the flow tests determine, in part, the rate at which water is available at specific locations within the distribution system and verify the accuracy of distribution models. The licensee flow tested the underground fire protection piping loops both inside and outside the protected area using Procedure 0PTP03-FP-0105, Fire Protection System Flow Test, Revision 8.
Calculation MC 6285, Fire Protection Underground Loop, Revision 0, provided the distribution model for the underground fire protection piping and other flow arteries at the plant. Calculation MC 6285 determined the available pressure at specific nodes given the design flow rate in the underground fire protection piping. The team noted that the flow calculation determined the flow and pressures distributed through all of the underground legs and not just the outer loop. During discussions with licensee personnel, the team questioned why they did not test the underground fire protection piping routed to the diesel generator buildings and the deluge valve houses in each unit and questioned the purpose of the testing.
Based on review of Calculation MC 6285, review of Procedure 0PTP03-FP-0105, and discussions with licensee personnel, the team determined that the licensee had not conducted full flow testing of the underground portions of the main fire protection piping loop that supplied the diesel generator buildings in each unit since the original startup tests in 1986. Consequently, the failure to demonstrate the adequacy and reliability of the water flow supplied to the diesel generator buildings was a performance deficiency.
The licensee documented the failure to properly perform flow testing in Condition Report 14-17098.
Analysis.
The failure to conduct flow testing of the entire underground fire protection piping loop was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors attribute (fire) and adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to performance test the underground fire protection piping loops supplying the emergency diesel generator buildings for both units did not demonstrate the continued capability to deliver adequate flow and pressure to the fire suppression systems supplying those buildings.
The team evaluated the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because it affected fire protection defense-in-depth strategies involving fire water supply. Using Appendix F, the team determined that the finding screened to very low safety significance. Specifically, the finding did not prevent the reactor from achieving safe shutdown since only one safe shutdown train would be affected at a time. Since these underground fire protection piping loops had not been flow tested since initial installation and nothing caused the licensee to reevaluate the test, the team determined that this failure did not reflect current performance.
Enforcement.
Technical Specification 6.8.1.d specifies that written procedures shall be established, implemented, and maintained for Fire Protection Program implementation.
Procedure 0PGP03-ZF-0018, Fire Protection System Functionality Requirements, Revision 17, Step 4.2.3.7 specified the licensee will perform system flow testing at least every 3 years in accordance with Chapter 8, Section 17 of the Fire Protection Handbook, 17th Edition, which specifies testing of the system to ensure water is available and within limits of the firemain distribution model. Contrary to the above, since original testing in 1986, the licensee failed to implement and maintain the Procedure 0PTP03-FP-0105, Fire Protection Flow Test, for the flow test for the underground fire protection piping loop by testing all portions of the piping. Specifically, the licensee failed to flow test
portions of the underground fire protection piping that serviced the diesel generator buildings. The licensee initiated actions to perform flow testing on that portion of the system.
Because this violation was of very low safety significance and has been entered into the corrective action program as Condition Report 14-17098, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000498;05000499/2014008-01, Inadequate Loop Flow Test.
.04 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed plant walkdowns and document reviews to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified:
- A fire in one of the selected fire areas would not directly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains.
- A fire in one of the selected fire areas or the inadvertent actuation or rupture of a fire suppression system would not directly cause damage to all redundant trains (e.g., sprinkler-caused flooding of other than the locally affected train).
- Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings were identified.
.05 Alternative Shutdown Capability
a. Inspection Scope
Review of Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the updated final safety analysis report, and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that require evacuation of the control room, with or without offsite power available.
The team conducted plant walk downs to verify that the plant configuration was consistent with the description contained in the safe shutdown and fire hazards analyses. The team focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions.
The team also verified that the systems and components credited for shutdown would remain free from fire damage. Finally, the team verified that the transfer of control from the control room to the alternative shutdown location would not be affected by fire induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Review of Operational Implementation The team verified that licensed and non-licensed operators received training on alternative shutdown procedures. The team also verified that sufficient personnel to perform a safe shutdown were trained and available onsite at all times, exclusive of those assigned as fire brigade members.
The team performed a timed walk down of the alternative shutdown procedure for Unit 1 with licensed and non-licensed operators to determine the adequacy of the procedure.
The team verified that the operators could reasonably be expected to perform specific actions within the time required to maintain plant parameters within specified limits.
Time critical actions that were verified included restoring electrical power, establishing control at the remote shutdown and local shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.
The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to verify that the tests were adequate to demonstrate the functionality of the alternative shutdown capability.
b. Findings
No findings were identified.
.06 Circuit Analysis
a. Inspection Scope
The team reviewed the post-fire safe shutdown analysis to verify that the licensee identified the circuits that may impact the ability to achieve and maintain safe shutdown.
The team verified, on a sample basis, that the licensee properly identified the cables for equipment required to achieve and maintain hot shutdown conditions in the event of a fire in the selected fire areas. The team verified that these cables were either adequately protected from the potentially adverse effects of fire damage or were analyzed to show that fire-induced circuit faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown.
The teams evaluation focused on the cables of selected components from the auxiliary feedwater, chemical volume and control, essential service water, main steam atmospheric vent, and main steam isolation systems. For the sample of components selected, the team reviewed electrical elementary and block diagrams and identified power, control, and instrument cables necessary to support their operation. In addition, the team reviewed cable routing information to verify that fire protection features were in place as needed to satisfy the separation requirements specified in the fire protection license basis. Specific components reviewed by the team are listed in the attachment.
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The team inspected the contents of designated emergency storage lockers and reviewed the alternative shutdown procedure to verify that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities. The team verified the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team 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. The team discussed system design, testing, and maintenance with the system engineer.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The team reviewed the portion of the emergency lighting system required for alternative shutdown to verify that it was adequate to support the performance of manual actions required to achieve and maintain hot shutdown conditions and to illuminate access and egress routes to the areas where manual actions would be required. The team evaluated the locations and positioning of the emergency lights during a walk down of the alternative shutdown procedure.
The team verified that the licensee installed emergency lights with an 8-hour capacity, maintained the emergency light batteries in accordance with manufacturer recommendations, and tested and performed maintenance in accordance with plant procedures and industry practices.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The team verified that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs. Using these procedures, the team evaluated whether these components could be repaired in time to bring the plant to cold shutdown within the time frames specified in their design and licensing bases. The team verified that the repair
equipment, components, tools, and materials needed for the repairs were available and accessible on site.
b. Findings
This licensee does not implement any cold shutdown repairs.
.10 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing safe shutdown functions). The team also verified that the short-term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
The team reviewed operator manual actions credited for achieving hot shutdown for fires that do not require an alternative shutdown. The team verified that operators could reasonably be expected to perform the actions within the applicable shutdown time requirements. The team reviewed these operator manual actions using the guidance contained in NUREG-1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire, dated October 2007.
b. Findings
No findings were identified.
.11 Review and Documentation of Fire Protection Program Changes
a. Inspection Scope
The team reviewed changes to the approved fire protection program. The team verified that the changes did not constitute an adverse effect on the ability to safely shutdown.
b. Findings
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The team reviewed the licensees approved fire protection program, implementing procedures, and programs for the control of ignition sources and transient combustibles.
The team assessed the licensees effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The team performed plant walk downs to independently verify that transient combustibles and
ignition sources were being properly controlled in accordance with the administrative controls.
b. Findings
No findings were identified.
.13 Alternative Mitigation Strategy Inspection Activities
a. Inspection Scope
The team reviewed the licensees implementation of guidance and strategies intended to maintain or restore core, containment, and spent fuel pool cooling capabilities under the circumstances associated with the potential loss of large areas of the plant due to explosions or fire as required by 10 CFR 50.54(hh)(2).
The team verified that the licensee maintained and implemented adequate procedures, maintained and tested equipment necessary to properly implement the strategies, and ensured station personnel were knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure the availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verify the availability of on-site vehicles capable of towing the portable pump. The team assessed the off-site ability to obtain fuel for the portable pump and foam used for firefighting efforts. The strategy and procedure selected for this inspection sample included Procedure 0POP10-ZO-EDMG, Extensive Damage Mitigation Guideline, Revision 4.
One mitigating strategy sample was completed.
b. Findings
No findings were identified.
OTHER ACTIVITIES
[OA]
4OA2 Identification and Resolution of Problems
Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team selected a sample of condition reports associated with the licensee's fire protection program to verify that the licensee had an appropriate threshold for identifying deficiencies. The team reviewed the corrective actions proposed and implemented to verify that they were effective in correcting identified deficiencies. The team evaluated the quality of recent engineering evaluations through a review of condition reports, calculations, and other documents during the inspection. The team also reviewed a sample of condition reports that were generated as a result of the last triennial fire protection inspection.
b. Findings
No findings were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion
.1 (Discussed) Violation 05000498; 05000499/2012007-01: Failure to Timely Correct
Conditions Adverse to Fire Protection During the 2005 triennial fire protection inspection, the team identified a concern with the assumptions used in the thermal hydraulic analysis that determined the time available for operators to perform time critical actions during an alternative shutdown. This issue was closed as a non-cited violation in 2006. In response to this violation, the licensee submitted a license amendment request in 2008 to request approval to credit the actions performed in the control room prior to evacuation during an alternative shutdown. The licensee subsequently withdrew this request in 2008.
The licensee resubmitted the license amendment request in 2011. During the 2011 triennial fire protection inspection, the team documented a non-cited violation (NCV 05000498;05000499/2011006-01) of License Condition 2.E for the failure to implement timely corrective actions for this issue. The licensee subsequently withdrew this request in 2011.
During the 2012 problem identification and resolution inspection, the team issued a cited violation (05000498;05000499/2012007-01) of License Condition 2.E for this issue. As corrective action for this violation, the licensee submitted a third license amendment request in 2013.
During the current inspection, the team identified one additional example of a control room fire scenario where the backup actions performed in the plant may not be performed within the allowable time. This scenario involved a single spurious actuation that disabled thermal barrier cooling to the running reactor coolant pumps followed by operator actions to secure the centrifugal charging pumps and terminate seal injection.
The team was concerned that the operator action to trip the reactor coolant pumps may occur too late after the charging pumps were secured. The team noted that the license amendment request, if approved, would resolve this scenario because the licensee would be able to credit the action to trip the reactor coolant pumps in the control room prior to evacuation.
The team determined that this issue was a violation of License Condition 2.E. This violation constitutes an additional example of non-cited Violation 05000498;05000499/2011006-01, and is not being cited individually. Corrective actions for this additional example are expected to be taken in conjunction with corrective actions for Violations 05000498;05000499/2011006-01 and 05000498;05000499/2012007-01.
During the current inspection, the team reviewed the license amendment request and the compensatory measures the licensee implemented during the review process for the license amendment request. The team performed a timed walk down of the alternative shutdown procedure and verified that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits, assuming the license amendment request was approved. Since the
third license amendment request was in the review process, the team could not close the 2012 violation.
.2 (Closed) Licensee Event Report (LER) 05000498; 499/2013-003-00: Unanalyzed
Condition - Direct Current Ammeter Circuits without Overcurrent Protection This licensee event report documented that the licensee had installed non-safety-related ammeters on the main control board without circuit protection. Because of the lack of circuit protection, a fire affecting a non-safety-related circuit could create a secondary fire in another area of the plant. The licensee had confirmed safety-related circuits were properly protected and required no modifications.
The team performed a detailed review of the information related to this deficiency. The team reviewed drawings, design documents, and discussed the event with plant personnel to gain an understanding of the actions taken to address the deficiency. The team verified that the licensee established appropriate compensatory measures and corrective actions.
The licensee documented this deficiency in their corrective action program as Condition Report 13-11633 and initiated actions to review the applicable circuits. The licensee determined that seven non-safety-related circuits had insufficient electrical circuit protection. As compensatory measures, the licensee established roving fire watches in the fire areas where they had routed the circuits.
The team reviewed the circuit modifications completed in Unit 1 and verified that they corrected the deficiency. The licensee continued to implement roving fire watches in Unit 2 until they complete the modifications, which were scheduled for April 2015. The team discussed the enforcement related to this deficiency in Section 4OA7.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented the inspection results to Dennis L. Koehl, President and Chief Executive Officer, and other members of the licensee staff at an exit meeting on September 25, 2014. The licensee acknowledged the findings presented.
The team verified that they retained no proprietary information or documented in this report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements that meets the criteria of Section 2.3.2.a of the NRC Enforcement Policy for being dispositioned as a non-cited violation.
Unanalyzed Condition - Direct Current Ammeter Circuits without Overcurrent Protection On October 31, 2013, Licensee Event Report 05000498; 05000499/2013-003 described an unanalyzed condition wherein a fire in non-safety-related control room instruments could cause a secondary fire because of a lack of circuit protection. License Condition 2.E specifies, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment No. 55 and the Fire Hazards Analysis Report through Amendment No. 7. Section 1.5.2 of the Fire Hazards Analysis Report states that only one fire originating from a single source is assumed to occur at a time.
Contrary to the above, since initial construction, the licensee failed to implement the fire protection program that ensured that only one fire originating from a single source will occur at one time. Specifically, the licensee failed to ensure that direct current ammeter circuits were properly protected to prevent secondary fires from initiating in other areas of the plant during a control room fire event. The performance deficiency was more than minor because, if left uncorrected, it could have become a more risk significant fire concern. Since this involved a control room fire, a senior reactor analyst performed a detailed risk evaluation that concluded the fire had very low risk significance. The licensee documented this issue in their corrective action program as Condition Report 13-11633. This violation is also discussed in Section 4OA3.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Berg, Manager, Design Engineering - Test and Programs
- R. Butler, Operations Support
- F. Cox, Safe Shutdown Design Engineer
- D. Dayton, Systems Engineer, Emergency Lighting
- T. Frahm, Manager, Unit 1 Operations
- C. Georgeson, Supervisor, Electrical Design Engineering
- R. Gonzales, Senior Licensing Engineer
- R. Lacey, Electrical Design Engineer
- M. Murray, Manager, Regulatory Affairs
- S. Rosales, Electrical Design Engineer
- R. Savage, Engineering Specialist
- G. Schinzel, Design Engineer
- D. Shook, Fire Marshall
- D. Wiegand, Fire Protection Systems Engineer
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000498; NCV Inadequate Loop Flow Test
Closed
- 05000498; Unanalyzed Condition - Direct Current Ammeter Circuits LER
- 05000499/2013-003-00 without Overcurrent Protection
Discussed
- 05000498; Failure to Timely Correct Conditions Adverse to Fire NCV
- 05000499/2011006-01 Protection
-1- Attachment