IR 05000528/2015008
| ML16036A189 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/05/2016 |
| From: | Greg Werner NRC/RGN-IV/DRS/EB-2 |
| To: | Edington R Arizona Public Service Co |
| References | |
| IR 2015008 | |
| Preceding documents: |
|
| Download: ML16036A189 (42) | |
Text
February 5, 2016
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000528/2015008; 05000529/2015008; AND 05000530/2015008
Dear Mr. Edington:
On January 15, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The NRC discussed the results of this inspection with Mr. D. Mims, Senior Vice President, Regulatory Affairs and Oversight, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report, which involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the violation 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 Palo Verde Nuclear Generating Station.
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 James F. Drake Acting for/
Gregory E. Werner, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-528, 50-529, 50-530 License Nos. NPF-41, NPF-51, NPF-74
Enclosure:
NRC Inspection Report 05000528/2015008, 05000529/2015008, and 05000530/2015008 w/Attachment: Supplemental Information
REGION IV==
Docket:
05000528, 05000529, 05000530 License:
NPF-41, NPF-51, NPF-74 Report Nos.:
05000528/2015008, 05000529/2015008, 05000530/2015008 Licensee:
Arizona Public Service Company Facility:
Palo Verde Nuclear Generating Station Location:
5801 South Wintersburg Road Tonopah, AZ 85354 Dates:
December 14, 2015, through January 15, 2016 Team Leader:
G. Pick, Senior Reactor Inspector, Engineering Branch 2 Inspectors:
N. Okonkwo, Reactor Inspector, Engineering Branch 2 E. Uribe, Reactor Inspector, Inspection Program and Assessment Team J. Watkins, Reactor Inspector, Engineering Branch 2 Accompanying Personnel:
J. Tice, Project Engineer, Branch D, Division of Reactor Projects Approved By:
Gregory E. Werner Chief, Engineering Branch 2 Division of Reactor Safety
- 2 -
SUMMARY
IR 05000528/2015008, 05000529/2015008, 05000530/2015008; 12/14/2015 - 01/15/2016; Palo
Verde Nuclear Generating Station Units 1, 2, and 3; Triennial Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors from Region IV. One finding, which was a non-cited violation, was documented. The significance of inspection findings are indicated by their color (i.e., Green, White, Yellow, or Red) and determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the 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 4.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
The team identified a Green non-cited violation of License Conditions 2.C.7, 2.C.6, and 2.F for Units 1, 2, and 3, respectively, because the licensee had not established criteria for determining when a fire main loop had degraded and had not properly tested all portions of the fire main loop. Specifically, the licensee had not established a differential pressure that would initiate actions to evaluate the cause for a degradation and the licensee had not determined the flow through individual flow paths in their auxiliary and control buildings. The licensee documented these issues in Condition Reports 15-00513 and 16-00686 and initiated actions to correct the procedure and perform the flow test of the individual loops.
The team identified a performance deficiency related to the procedure used to test their fire main loop. Specifically, the licensee had not established criteria for determining a degraded fire main loop and had not properly tested all portions of the fire main loop.
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 test the fire main loops inside the control/auxiliary building separately and failure to establish appropriate acceptance criteria affected the ability to demonstrate the continued capability to deliver adequate flow and pressure to the fire suppression systems.
The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. The inspectors determined that an IMC 0609,
Appendix FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Fire Protection Significance Determination Process, dated September 20, 2013, review was required as the finding affected the ability to reach and maintain safe shutdown conditions in case of a fire. Using IMC 0609, Appendix F, Attachment 1, Fire
Protection Significance Determination Process Worksheet, dated September 20, 2013, the finding was screened as a Green finding of very low safety significance in accordance with Task 1.4.7, Fire Water Supply, Question A. The inspectors determined that although the licensee failed to test portions of the fire main system in accordance with code requirements, the inspectors determined that at least 50 percent of required fire water capacity would be available based on the testing is done with only one fire pump in service and there are three available fire pumps. Since these fire main loops inside the control/auxiliary building had not been monitored for pressure changes when flow tested since initial testing and nothing caused the licensee to reevaluate the test, the team determined that this failure did not reflect current performance.
(Section 1R05.05.b)
Licensee-Identified Violations
None
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 Palo Verde Nuclear Generating Station. The 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 team used the fire hazards analysis section of the Palo Verde Individual Plant Examination of External Events to select the following four risk-significant fire areas (inspection samples) for review:
Fire Zone
Description
5A
Train A Engineered Safety Features Switchgear Room 9A
Train A Battery Room Remote Shutdown Room A Upper Cable Spreading Room
The team evaluated the licensees fire protection program using the applicable requirements, which included plant Technical Specifications, Operating License Conditions 2.C.7, 2.C.6, and 2.F, NRC safety evaluations, 10 CFR 50.48, and Branch Technical Position 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants. 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 two mitigating strategy samples 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 walk down of accessible portions of the detection and suppression systems in the selected fire areas. The team also performed a walk down 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 and carbon dioxide suppression functional tests to verify that the systems 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 firefighting.
The team observed an unannounced fire drill and subsequent drill critique on January 12, 2016, 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 control building upper cable spreading room cable chase. 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 firefighting techniques;
- (4) sufficient firefighting 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 License Conditions 2.C.7, 2.C.6, and 2.F for Units 1, 2, and 3, respectively, because the licensee had not established criteria for determining when a fire main loop had degraded and had not properly tested all portions of the fire main loop. Specifically, the licensee had not established a differential pressure that would initiate actions to evaluate the cause for a degradation and the licensee had not determined the flow through individual flow paths in their auxiliary and control buildings.
Description.
The team reviewed the method used by the licensee to test their underground fire loop to ensure that they had flow tested all portions, as required by their licensing basis. The licensee annually tested their fire main loop in accordance with Procedure 14FT-0FP04, Annual Fire Water Loop Test, Revision 21. The team determined that this test also met the requirements specified in Technical Requirements Manual Surveillance Requirement 3.11.101.16, which requires that the licensee perform a flow test of the fire suppression water system in accordance with Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition, published by the National Fire Protection Association every 3 years. The team determined that the licensee had established a test configuration that isolated and established a constant flow through each individual section of their fire main loop and monitored for degrading delta-pressure between the pump discharge and return.
The team compared the test configurations in the procedure to the underground fire main loops detailed in their drawings. The team identified that the flow paths through the turbine building and through the control and auxiliary buildings did not get individually flow tested in the same manner as the other fire main loops located underground. The licensee indicated that they would detect a change in the pressure drop from combined loops located in the turbine or the control/auxiliary buildings and initiate actions to investigate the change in pressure at their fire pump.
In addition, the team determined that the procedure did not list any acceptance criteria for initiating actions for evaluating whether degradation existed. The team determined that their licensing basis specified flow paths through buildings to be treated the same as fire main loops located underground. The team determined that Procedure 14FT-0FP04 did not properly test the fire main loops inside the control/auxiliary buildings consistent with their test method for their underground fire main loops. Further, the procedure failed to specify any acceptance criteria that would indicated a degraded fire loop. The licensee documented these deficiencies in Condition Reports 15-00513 and 16-00686, respectfully.
The team determined that Updated Final Safety Analysis Report, Section 9.5.1.3, specified the primary evaluation of the compliance of the plant design with applicable regulatory and industry standards was presented in Appendix 9B, Fire Protection Evaluation Report. Fire Protection Evaluation Report, Table 9B.3-1, Comparison of Palo Verde Nuclear Generating Station to Appendix A of NRC Branch Technical Position APCSB 9.5-1, Section E.3.(a), Water Sprinklers and Hose Standpipe Systems, specified that headers inside buildings, when provided, are considered an extension of the fire main loop. Also, Section C.5, Test and Test Control, specified that the licensee included their testing requirements in their Operations Quality Assurance Plan, Appendix F.1. Section 17.2F.1.3.2.6, Test and Test Control, specified, in part, The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted upon. In addition, Section 17.2F.1.3.2.6.B, specified, in part, for periodic testing, that equipment will properly function and continue to meet design criteria.
Analysis.
The team identified a performance deficiency related to the procedure used to test their fire main loop. Specifically, the licensee had not established criteria for determining a degraded fire main loop and had not properly tested all portions of the fire main loop. 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 test the fire main loop inside the control/auxiliary building separately and failure to establish appropriate acceptance criteria affected the ability to demonstrate the continued capability to deliver adequate flow and pressure to the fire suppression systems.
The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. The inspectors determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, review was required as the finding affected the ability to reach and maintain safe shutdown conditions in case of a fire. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013, the finding was screened as a Green finding of very low safety significance in accordance with Task 1.4.7, Fire Water Supply, Question A. The inspectors determined that although the licensee failed to test portions of the fire main system in accordance with code requirements, the inspectors determined that at least 50 percent of required fire water capacity would be available based on the testing is done with only one fire pump in service and there are three available fire pumps. Since these fire main loops inside the control/auxiliary building had not been monitored for pressure changes when flow tested since initial testing and nothing caused the licensee to reevaluate the test, the team determined that this failure did not reflect current performance.
Enforcement.
License Conditions 2.C.7, 2.C.6, and 2.F for Units 1, 2, and 3, respectively, specify that, APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11. Updated Final Safety Analysis Report, Table 9B.3-1, Comparison of Palo Verde Nuclear Generating Station to Appendix A of NRC Branch Technical Position APCSB 9.5-1, Section C.5, Test and Test Control specified, that the licensee included their requirements in their Operations Quality Assurance Plan. Operations Quality Assurance Plan, Section 17.2F.1.3.2.6, Test and Test Control, specified, in part, The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted upon. Also, Table 9B.3-1, Section E.3.(a), Water Sprinklers and Hose Standpipe Systems, specified that headers inside buildings, when provided, are considered an extension of the yard main loop.
Technical Requirements Manual, Surveillance Requirement 3.11.101.16 requires that the licensee perform a flow test of the fire suppression water system in accordance with Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition, published by the National Fire Protection Association. Procedure 14FT-0FP04, Annual Fire Water Loop Test, provided the guidance for conducting the test. Procedure 14FT-0FP04 identified the purpose of the procedure was to provide monitoring information on the condition of the fire water loops and to detect degrading flow characteristics from one year to the next.
Contrary to the above, from original plant licensing to January 15, 2016, the licensee failed to meet the requirements related to performing a test that established results that could be acted upon and for testing all portions of their fire main loops. Specifically, the licensee
- (1) did not establish acceptance criteria that identified when the test revealed degradation in the fire main loop and
- (2) did not test the individual paths inside their control/auxiliary building consistent with their testing of the fire main loop located underground.
Because this violation was of very low safety significance and has been entered into the corrective action program as Condition Reports 15-00513 and 16-00686, and the licensee initiated actions to correct the procedure and perform the flow test, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000528; 05000529; and 05000530/2015008-01, Inadequate Loop Flow Test Procedure.
.04 Protection from Damage from Fire Suppression Activities
a. Inspection Scope
The team performed plant walk downs 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 on-site 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 2 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 timeframes 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
No findings were identified.
.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 a sample of fire protection program changes to the approved fire protection program issued since our last inspection in February 2013. 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. During this inspection, the team assessed the relationship between the transient combustible controls and the point where the licensee decides to include them in their combustible loading calculations.
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 equipment used to implement the mitigating strategies to ensure the availability and material readiness of the equipment. The strategies selected for this inspection sample included:
- Makeup to the condensate storage tank
- Makeup to the refueling water storage tank
Two mitigating strategy samples were 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.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented the inspection results to Mr. D. Mims, Senior Vice President, Regulatory Affairs and Oversight, and other members of the licensee staff at an exit meeting on January 15, 2016. The licensee acknowledged the findings presented.
The team verified that no proprietary information was retained by the team or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Agazzi, Team Leader, Fire Protection
- G. Andrews, Director, Nuclear Regulatory Affairs
- R. Beamon, Electrician
- J. Boothroyd, Section Leader, Engineering, Fire Protection
- G. Cameron, Section Leader, Regulatory Affairs and Oversight
- D. Code, Team Leader, Fire Protection, Electrical Maintenance
- D. Crane, Consulting Engineer, Fire Protection
- P. Custodio, Senior Engineer, Fire Protection
- D. Dallago, Engineer II, Fire Protection
- R. Doyle, Senior Design Engineer
- K. Foster, Department Leader, Fire Protection
- C. Gallegos, Engineer III, System Engineering
- D. Horton, Section Leader Fire Protection
- M. Lacal, Vice President, Regulatory Affairs and Oversight
- M. Laughlin, General Manager Site Support
- B. Lee, Senior Technical Specialist, Fire Protection
- J. Lim, Senior Compliance Engineer
- N. Lossing, Section Leader, System Engineering
- B. Mathieu, Senior Nuclear Auxiliary Operator
- M. McGhee, Department Leader, Regulatory Affairs
- D. Mims, Senior Vice President, Regulatory Affairs and Oversight
- F. Oreshack, Senior Consulting Engineer, Regulatory Affairs and Oversight
- W. Parra, Electrician
- M. Pryor, Information Technology Field Service Technician
- A. Ruiz, Engineer II, Civil Design Engineer
- J. Scott, Nuclear Training Instructor, Fire Department
- J. Samuels, Electrical Engineer, Fix-it Now Team
- D. Sollars, Manager, Unit Operations
- C. Thiele, Department Leader, Nuclear Engineering
- G. Timothy, Control Room Supervisor
- C. Wandell, Consulting Civil Design Engineer
NRC Personnel
- C. Peabody, Senior Resident Inspector
- D. Reinert, Resident Inspector
- D. You, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000528,
- 05000529,
- 05000530/2015008-01 NCV Inadequate Flow Test Procedure (Section 1R05.03-6)