IR 05000036/2010007

NRC Triennial Fire Inspection Report 0500036-10-007 and 05000362-10-007 and Notice of Violation

ML102740149
Person / Time
Site:	San Onofre, 05000036
Issue date:	09/30/2010
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Sheppard J Southern California Edison Co
References
EA 10-191, FOIA/PA-2011-0157 IR-10-007
Download: ML102740149 (33)

Text

September 30, 2010

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION - NRC TRIENNIAL FIRE INSPECTION REPORT 05000361/2010007 and 05000362/2010007 AND NOTICE OF VIOLATION

Dear Mr. Sheppard:

On August 16, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the San Onofre Nuclear Generating Station. The enclosed inspection report documents the inspection results, which were discussed during an onsite debrief on July 2, 2010, with Mr. A. Hochevar, Station Manager, and in a telephonic exit meeting on August 16, 2010, with Mr. R. Ridenoure, Senior Vice President and Chief Nuclear Officer, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the NRC has identified an issue that was evaluated under the risk significance determination process as having very low safety significance (green).

The NRC has also determined that a violation was associated with this issue. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC=s Web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).@]

UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125

Southern California Edison Company

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The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because of your failure to correct a significant noncompliance with your License Condition 2.C.(14), Fire Protection, within the time period for enforcement discretion as described in NRC Enforcement Guidance Memorandum 07-004.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice of Violation when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In addition, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. NRC is treating this violation as a noncited violation (NCV)

consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest the noncited violation or its significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to: (1)

the Regional Administrator, Region IV, 612 East Lamar Blvd., Arlington, TX 76011-4125; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) NRC Resident Inspector at the San Onofre Nuclear Generating Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC=s document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Neil OKeefe, Chief Engineering Branch 2 Division of Reactor Safety

Docket No. 50-361, 50-362 License No. NPF-10, NPF-15

Enclosures:

1. Notice of Violation 2. Inspection Report No. 05000361/2010007 and 05000362/2010007 w/Enclosure:

Southern California Edison Company

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REGION IV==

Docket:

50-361, 50-362 License:

NPF-10, NPF-15 Report Nos.:

05000361/2010007 and 05000362/2010007 Licensee:

Southern California Edison Company Facility:

San Onofre Nuclear Generating Station, Units 1 and 2 Location:

5000 S Pacific Coast Hwy San Clemente, California Dates:

June 14 through August 16, 2010 Team Leader:

J. Mateychick, Senior Reactor Inspector, Engineering Branch 2 Inspectors:

S. Alferink, Reactor Inspector, Engineering Branch 2 I. Anchondo, Reactor Inspector, Plant Support Branch 2 N. Okonkwo, Reactor Inspector, Engineering Branch 2 E. Uribe, Reactor Inspector, Engineering Branch 2 Accompanying Personnel:

S. Marquez, Nuclear Safety Professional Development Program, Engineering Branch 2 Approved By:

Neil OKeefe, Branch Chief Engineering Branch 2 Division of Reactor Safety

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Enclosure

SUMMARY OF FINDINGS

IR05000361/2010007 and 05000362/2010007; June 14, 2010, through August 16, 2010;

Southern California Edison Company; San Onofre Nuclear Generating Station, Units 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 Green finding, which was a cited violation, was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. The crosscutting aspect was determined using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The team identified a cited violation of License Condition 2.C(14), Fire Protection, for failure to correct a noncompliance. Specifically, Inspection Report 05000361;362/2007008 documented a noncompliance involving the failure to ensure that at least one train of safe shutdown equipment would remain free from fire damage in each fire area. The NRC exercised discretion not to cite this violation at that time because the licensee met the criteria described in Enforcement Guidance Memorandum 98-002, Revision 2, and Supplement 2 to that revision. Enforcement Guidance Memorandum 07-004 superseded Enforcement Guidance Memorandum 98-002 and required licensees to complete corrective actions for noncompliances related to post-fire operator manual actions by March 6, 2009. This violation is being cited due to the failure to complete corrective actions and restore compliance within the required time. This finding was entered into the licensees corrective action program as Notification NN 200940265.

The failure to promptly restore adequate fire protection and/or separation of required safe shutdown systems was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events in order to prevent undesirable consequences. Because the violation involved multiple fire areas, the team could not evaluate this issue using Phase 2 of Inspection Manual Chapter 0609, Appendix F, and a Phase 3 significance determination process risk assessment was performed by a senior reactor analyst. The finding was determined to have very low risk significance (Green), with a delta-CDF of 3.2E-8/yr, because of a combination of the availability of long recovery times for feasible operator manual actions and low-probability fire damage scenarios in the nine fire areas with fire sources which could potentially damage cables of required safe shutdown components. This finding involved a cross-cutting aspect in the decision-making component in the human performance area because the licensee failed to make a risk-significant decision using a systematic process when considering the scheduling of corrective actions H.1(a) (Section 1R05.01)(EA 10-191).

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee was 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 (71111.05TTP)

This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure 71111.05TTP, Fire Protection-NFPA Transition Period (Triennial), at the San Onofre Nuclear Generating Station. The licensee committed to adopt a risk informed fire protection program in accordance with National Fire Protection Association (NFPA) 805, but has not yet completed the program transition. 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 71111.05TTP requires the selection of three to five fire areas for review. The inspection team used the fire hazards analysis section of the San Onofre Nuclear Generating Station Individual Plant Examination of External Events to select the following three risk-significant fire areas (inspection samples) for review:

• Fire Area 2-AC-9-5

Cable Spreading Room

• Fire Area 2-AC-50-29 Auxiliary Building, Lobby/Motor Control Area

• Fire Area 2-DG-30-158 Diesel Generator Room A

The inspection team evaluated the licensees fire protection program using the applicable requirements, which included plant Technical Specifications, Operating License Condition 2.C.(14), NRC safety evaluations, 10 CFR 50.48, and Branch Technical Position 9.5-1. The team also reviewed related documents that included the Final Safety Analysis Report (FSAR), 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. Three inspection samples were completed.

.1 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 walkdowns 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. The team focused on the critical functions that must be ensured in order to achieve and maintain post-fire safe shutdown conditions.

For the sample 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 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

Introduction.

The team identified a Green, cited violation of License Condition 2.C(14),

Fire Protection, for failure to correct a noncompliance. Specifically, Inspection Report 05000361;362/2007008 documented a noncompliance involving the failure to ensure that at least one train of safe shutdown equipment would remain free from fire damage in each fire area. The NRC exercised discretion not to cite this violation at that time because the licensee met the criteria described in applicable Enforcement Guidance Memoranda. During this inspection, the team identified that the licensee failed to restore compliance by March 6, 2009, as required.

Discussion. On July 24, 2007, the NRC documented in Inspection Report 05000361/2007008 and 05000362/2007008 that the licensee was relying on operator manual actions to restore equipment required to achieve and maintain a safe shutdown condition in the event of fire because they had failed to ensure that at least one train of safe shutdown equipment was free of fire damage in each fire area. This was identified as a noncompliance with License Condition 2.C(14), Fire Protection. The NRC exercised discretion not to cite this violation at that time because the licensee met the criteria described in Enforcement Guidance Memorandum (EGM) 98-002, Revision 2, and Supplement 2 to that revision. EGM 07-004, issued on June 30, 2007, superseded EGM 98-002 and required licensees to initiate corrective actions and implement compensatory measures for noncompliances related to post-fire operator manual actions, excluding those for multiple-spurious actuations, by September 6, 2007, and to complete corrective actions by March 6, 2009. This issue was placed into the corrective action program under Action Request 070600585 and supplemented the manual actions with compensatory measures in the form of hourly fire watches.

During this inspection, the team requested that the licensee provide the status of the corrective actions for the existing identified noncompliances subject to EGM 07-004.

The licensee indicated the understood that the period of discretion was extended until they completed their transition to a risk-informed fire protection program under NFPA 805, since they had committed to adopt such a program after the violation was identified.

Further, the licensee intended to use the processes allowed under NFPA 805 to address the issues, rather than to restore compliance under their existing fire protection program.

The team determined that the licensee had failed to meet the conditions of the applicable enforcement discretion, and that the timing of their commitment to adopt a risk-informed fire protection program would not change the required time to restore compliance, or allow using risk-informed methods to address the issue. The following discussion briefly summarizes the applicability of the enforcement guidance.

Enforcement Guidance Memorandum 98-002 provided enforcement guidance pertaining to noncompliances involving fire induced circuit failures. This guidance allowed exercising discretion while the generic issue was addressed with industry, provided that the noncompliances were entered into the corrective action program and compensatory

measures put in place. In 2007, the fire protection inspection team identified that the licensee=s safe shutdown analysis relied upon manual actions to mitigate the effects of fire damage to redundant trains of safe shutdown equipment, rather than ensuring that one train of this equipment was free of fire damage. The NRC issued an apparent violation of License Condition 2.C(14) for this issue, and exercised enforcement discretion because the licensee met the criteria described in EGM 98-002, Revision 2, and Supplement 2 to that revision.

EGM 98-002, Revision 2, Supplement 2 stated that the discretionary period would be extended until the Commission approves a new enforcement discretion policy for circuit failure issues. EGM 07-004, issued on June 30, 2007, superseded EGM 98-002 and required licensees to initiate corrective actions and implement compensatory measure for noncompliances related to post-fire operator manual actions, excluding those for multiple-spurious actuations, by September 6, 2007, and to complete those corrective actions by March 6, 2009.

On March 28, 2008, the licensee submitted their letter of intent to adopt a risk-informed fire protection program under NFPA 805. However, the NRCs Interim Enforcement Discretion Policy allowed enforcement discretion for existing identified noncompliances only for licensees that submitted a letter of intent to transition to 10 CFR 50.48(c) by December 31, 2005. After December 31, 2005, this enforcement discretion was not available for existing identified noncompliances, and the requirements of 10 CFR 50.48(b) (and other requirements in fire protection license conditions) are to be enforced in accordance with normal enforcement practices.

The team concluded that the licensee failed to restore these noncompliances by the date required per EGM 07-004, and submitting a letter of intent to adopt a risk-informed fire protection program after December 31, 2005 did not qualify these NRC-identified noncompliances, which existed at the time of this commitment letter, to be covered by enforcement discretion under the NRCs Interim Enforcement Discretion Policy. This issue was entered into the licensees corrective action program as Notification NN 200940265.

Analysis.

The failure to promptly restore adequate fire protection and/or separation of required safe shutdown systems was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events in order to prevent undesirable consequences.

Because the violation involved multiple fire areas, the team could not evaluate this issue using Phase 2 of Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, so a Phase 3 significance determination process risk assessment was performed by a senior reactor analyst.

The team identified components required for post-fire safe shutdown that were operated using manual actions to restore the required safe shutdown function due to potential fire damage. The team performed walk-downs of the cables associated with the credited pumps, valves, and electrical switchgear to identify possible fire sources that might damage those cables. The team identified potential fire source-target combinations and provided this information to the senior reactor analyst.

A total of nine fire scenarios in five fire areas were identified where the use of operator manual actions in lieu of protecting the equipment from fire damage added to the core damage frequency. In five of the fire scenarios, the time frame available to perform the actions exceeded 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and, in the absence of deficiencies associated with procedures or training, the analyst dismissed them from the risk quantification. The other four fire scenarios were assessed based on the fire frequency, the conditional core damage probability result of the SPAR model for the equipment targeted by the fire, credit for automatic detection and suppression, and the human error probability for the manual actions as determined by the SPAR-H method of assigning performance shaping factors. The overall result was a delta-CDF of 3.2E-8/yr. Therefore, the finding was determined to have very low risk significance (Green).

This finding involved a cross-cutting aspect in the decision-making component in the human performance area because the licensee failed to make a risk-significant decision using a systematic process when considering the scheduling of corrective actions

H.1(a).

Enforcement.

License Condition 2.C(14) Fire Protection, states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Fire Hazards Analysis through Revision 3 and as approved in the NRC staffs Safety Evaluation Report dated February 1981. The requirement of 10 CFR 50, Appendix R, Section III.G is that one train of equipment necessary to achieve and maintain hot shutdown conditions remain free of fire damage. The use of local operator manual actions were specifically submitted and approved by the NRC for alternative shutdown areas, as well as for one fire area (Fire Area 2-AC-50-29). For other nonalternative shutdown areas, the fire protection program was approved based upon compliance with the requirements of 10 CFR 50, Appendix R, Section III.G.1 or III.G.2.

Contrary to this requirement, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Fire Hazards Analysis through Revision 3. Specifically, the licensee failed to ensure that one train of equipment necessary to achieve and maintain hot shutdown conditions would remain free of fire damage.

Because the licensee failed to correct this violation within the allowed enforcement discretion period, this violation is being treated as a cited violation, consistent with the NRC Enforcement Policy,Section VI.A.1, which states, in part, that a cited violation requiring a formal written response from a licensee will be considered if the licensee failed to restore compliance within a reasonable time after a violation was identified. The NRC Enforcement Manual further explains that the purpose of this criterion is to emphasize the need to take appropriate action to restore compliance in a reasonable period of time once the licensee becomes aware of the violation, and take compensatory measures until compliance is restored when compliance cannot be reasonable restored within a reasonable period of time. The licensee had compensatory measures in place; however, compliance had not been restored.

This violation is identified as VIO 05000361/2010007-01 and 05000362/2010007-01, Failure to Ensure At Least One Train of Equipment Necessary to Achieve Hot Shutdown Conditions Is Free of Fire Damage. (EA 10-191)

.2 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.

.3 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 manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the NFPA 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 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, conducted on July 1, 2010, and the subsequent drill critique 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 Unit 3 diesel generator 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 preplanned drill scenario; and

(10) drill objectives.

b. Findings

No findings were identified.

.4 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 that:

• 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.

.5 Alternative Shutdown Capability

a. Inspection Scope

Review of Methodology

The team reviewed the safe shutdown analysis, fire hazards analysis, operating procedures, piping and instrumentation drawings, electrical drawings, FSAR, and other supporting documents to verify that hot and cold shutdown could be achieved and maintained for fires in areas where the licensees post-fire safe shutdown strategy relied on manipulating shutdown equipment from outside the control room. The team verified that hot and cold shutdown could be achieved and maintained with or without offsite power available.

The team conducted plant walkdowns 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. Specifically, the team verified that electrical isolation from the control room would occur to ensure fire-induced circuit faults would not affect alternative shutdown capabilities (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 nonlicensed operators received training on the alternative shutdown procedure. The team also verified that a sufficient number of personnel, exclusive of those assigned as fire brigade members, are trained and available onsite at all times to perform an alternative shutdown.

The team reviewed the adequacy of the procedures utilized for alternative shutdown and performed an independent walkthrough of the procedure to ensure the adequacy of implementation. The team also verified that the operators could be reasonably expected to perform specific short-term actions within the time required to maintain plant parameters within specified limits. Some of the short-term actions verified include the restoration of alternating current electrical power, establishing control at the remote shutdown panel, establishing reactor coolant makeup, and establishing decay heat removal.

The team reviewed periodic surveillance testing of the alternative shutdown transfer capability, including transfer and isolation of 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.

.6 Circuit Analysis

a. Inspection Scope

This segment of the inspection is suspended for plants in transition to a risk-informed fire protection program in accordance with NFPA 805. Therefore, the team did not evaluate this area.

b. Findings

No findings were identified.

.7 Communications

a. Inspection Scope

The team reviewed the adequacy of the communication systems to support plant personnel in the performance of alternative shutdown functions and fire brigade duties.

The team evaluated the environmental impacts such as ambient noise levels, coverage patterns, and clarity of reception. The team verified that the design and location of communications equipment such as repeaters, private branch exchanges, and transmitters would not cause a loss of communications during a fire.

The team also verified the contents of designated 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.

b. Findings

No findings were identified.

.8 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 safe 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 fixed emergency lights during walkthroughs of the alternative shutdown procedures.

The team verified that the licensee installed emergency lights with an 8-hour capacity, maintained the emergency light batteries in both fixed and portable configurations in accordance with manufacturer recommendations, and tested and performed maintenance in accordance with plant procedures and industry practices.

b. Findings

No findings were identified.

.9 Cold Shutdown Repairs

a. Inspection Scope

The team reviewed the licensees safe shutdown analysis and plant procedures for responding to fires and implementing safe shutdown activities in order to determine if any repairs were required in order to achieve cold shutdown. The updated fire hazards analysis report identified repairs to replace two instruments needed to support operations of the shutdown cooling system that might be damaged by fire. The repairs were potentially required in order to reach cold shutdown based on the safe shutdown methodology implemented.

The team verified that the replacement instruments, fittings and tools were available and calibrated, and the procedure to install them would work as intended. The team also evaluated whether cold shutdown could be achieved within the required time using the licensees procedures and repair methods.

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.

b. Findings

No findings were identified.

.11 B.5.b Inspection Activities

a. Inspection Scope

The team reviewed the licensees implementation of guidance and strategies intended to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire as required by Section B.5.b of the Interim Compensatory Measures Order, EA-02-026, dated February 25, 2002, and 10 CFR 50.54(hh)(2).

The team reviewed licensees strategies to verify that they continued to maintain and implement procedures, maintain and test equipment necessary to properly implement the strategies, and ensure station personnel are knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verify the availability of onsite vehicles capable of towing the portable pump. The team assessed the offsite ability to obtain fuel for the portable pump, and foam used for firefighting efforts. The strategies and procedures selected for this inspection sample included:

• SOG-EO-0014, "Firewater to Plant Systems-Condensate Storage Tank (CST)

Make-up," Revision 1

• SO23-V-5.100, Engineering Procedure, Revision 1, Attachment 11, Makeup to Condensate Storage Tanks (CSTs)

b. Findings

A licensee-identified violation related to B.5.b is discussed in Section 4OA7 of this report. No other 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. In addition the team reviewed the corrective actions proposed and implemented to verify that they were effective in correcting identified deficiencies. The team also 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

Debrief Meeting Summary

The team presented the preliminary inspection results to Mr. A. R. Hochevar, Station Manager, and other members of the licensee staff at a debrief meeting on July 2, 2010.

The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identified.

Exit Meeting Summary

The team presented the inspection results to Mr. R. T. Ridenoure, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff at an exit meeting on August 16, 2010. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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 which meets the criteria of Section VI of the NRC Enforcement Policy, for being dispositioned as a noncited violation.

License Condition 2.C(26) and 2.C(27), Mitigation Strategy License Condition, for Units 2 and 3 respectively, requires the licensee to develop and maintain strategies for addressing large fires and explosions. One strategy relied on a skid mounted pump with a non-collapsible hose to provide makeup for the reactor water storage tank. Contrary to the above, on June 9, 2010, the licensee identified during a flow/pressure test that the strategy was unavailable because the hose was not rated for the system pressure and uncoupled during the test. The finding is greater than minor because a strategy was unavailable and unrecoverable, as defined by Inspection Manual Chapter 0609, Appendix L, B.5.b Significance Determination Process. The finding is Green because the failure to assess the adequacy of fire fighting assets would have caused an unrecoverable unavailability of only one mitigating strategy. The issue was entered into the licensees corrective action program as Nuclear Notifications (NN) 200960081 and 200959384.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Abesamis, Design Engineering

J. Appel, Engineer, Licensing

D. Arai, Maintenance/Systems Engineering

A. Bates, Manager, Systems Engineering

D. Bauder, Site Vice President and Station Manager

K. Brockman, Consultant

J. Carnes, Fire Department

G. Chung, Probabalistic Risk Assessment

L. Conklin, Manager, Nuclear Regulatory Affairs

G. Cook, Manager, Compliance

R. Corbett, Director, Performance Improvement

J. Dahl, Shift Manager, Operations

A. Dharmapal, Licensing

M. DeMarco, Site Representative, San Diego Gas & Electric

A. Dharmapal, Nuclear Oversight

D. Ensminger, Manager, Site Emergency Preparedness

F. Giaco, Supervisor, Design Engineering

A. Hochevar, Station Manager

M. Hojati, Manager, Design Engineering

E. Hubley, Director, Maintenance

A. Kline, Operations

G. Kline, Senior Director, Engineering

B. MacKissock, Director, Operations

J. Madigan, Director, Recovery Projects

M. McBrearty, Project Manager, Nuclear Regulatory Affairs

T. McCool, Plant Manager

J. McGaw, Manager, Maintenance/Systems Engineering

A. Ockert, Maintenance/Systems Engineering

T. O'Meara, Manager, Nuclear Safety Culture

R. Richter, Supervisor, Maintenance/Systems Engineering

R. Ridenoure, Senior Vice President and Chief Nuclear Officer

S. Root, Project Manager, Nuclear Regulatory Affairs

C. Ryan, Manager, Maintenance

S. Ryba, Project Manager, Performance Improvement

R. St. Onge, Director, Nuclear Regulatory Affairs

D. Spires, Director, Work Control

M. Steinkamp, Manager, Operations

C. Vadoli, Design Engineering

B. Wallace, Director, Nuclear Training

NRC personnel

G. Warnik, Senior Resident Inspector

J. Reynoso, Resident Inspector

E. Ruesch, Resident Inspector

- 2 -

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000361 and

05000362/2010007-01 VIO Failure to Ensure At Least One Train of Equipment Necessary to Achieve Hot Shutdown Conditions Is Free of Fire Damage (Section 1R05) (EA 10-191)