Text

Triennial Fire Protection Inspection Report 05000263/2017007 (AAS)
	ML17234A730
Person / Time
Site:	Monticello
Issue date:	08/21/2017
From:	Robert Daley; NRC/RGN-III
To:	Gardner P; Northern States Power Company, Minnesota
References
	IR 2017007
	Download: ML17234A730 (20)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

August 21, 2017

Mr. Peter A. Gardner

Site Vice President

Monticello Nuclear Generating Plant

Northern States Power Company, Minnesota

2807 West County Road 75

Monticello, MN 55362-9637

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANTTRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000263/2017007

Dear Mr. Gardner:

On July 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial

Fire Protection Inspection at your Monticello Nuclear Generating Plant. The enclosed

inspection report documents the inspection results, which were discussed on July 14, 2017,

with Mr. P. Gardner 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.

The NRC inspectors documented one finding of very-low safety significance (Green) in this

report. This finding was determined to involve a violation of NRC requirements. However,

because of its very-low safety significance and because the issue was entered into your

Corrective Action Program, the NRC is treating the issue as a Non-Cited Violation in

accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the violation or significance of this Non-Cited Violation, you should provide

a response within 30 days of the date of this inspection report, with the basis for your denial,

to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,

DC 20555 0001; with copies to the Regional Administrator, Region III; the Director, Office of

Enforcement; and the NRC resident inspector at the Monticello Nuclear Generating Plant.

P. Gardner -2-

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket No. 50-263

License No. DPR-22

Enclosure:

Inspection Report 05000263/2017007

cc: Distribution via LISTSERV

P. Gardner -3-

Letter to Peter A. Gardner from Robert C. Daley dated August 21, 2017

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANTTRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000263/2017007

DISTRIBUTION:

Jeremy Bowen

RidsNrrDorlLpl3

RidsNrrPMMonticello

RidsNrrDirsIrib Resource

Cynthia Pederson

DRPIII

DRSIII

ROPreports.Resource@nrc.gov

ADAMS Accession Number ML17234A730

OFFICE RIII RIII RIII RIII

NAME IKhan for RDaley

AShaikh:cl

DATE 08/17/17 08/21/17

OFFICIAL RECORD COPY

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-263

License No: DPR-22

Report No: 05000263/2017008

Licensee: Xcel Energy, Northern States Power Company (Operator)

Facility: Monticello Nuclear Generating Plant

Location: Monticello, MN

Dates: June 12 - July 14, 2017

Inspectors: I. Hafeez, Reactor Inspector

I. Khan, Reactor Inspector

A. Shaikh, Senior Reactor Inspector (Lead)

Approved by: Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Enclosure

SUMMARY

Inspection Report 05000263/2017007; 06/12/2017-07/14/2017; Monticello Nuclear Generating

Plant; Routine Triennial Fire Protection Baseline Inspection.

This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection

was conducted by Region III inspectors. One finding was identified by the inspectors. The

finding was considered a Non-Cited Violation of U.S. Nuclear Regulatory Commission (NRC)

regulations. The significance of most findings is indicated by their color (i.e., greater than

Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process, dated April 29, 2015. Cross-cutting aspects were

determined using IMC 0310, Aspects 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. All violations of NRC requirements are dispositioned in

accordance with the NRCs Enforcement Policy dated November 1, 2016. The NRCs program

for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.

Cornerstone: Initiating Events

Green. The inspectors identified a finding of very-low significance (Green) and an

associated Non-Cited Violation of License Condition 2.C.4 of the Monticello Nuclear

Generating Plant, Unit No. 1, Renewed Facility Operating License for implementing an

alternative compensatory measure that was adverse to safety shutdown. Specifically,

the licensee approved the installation of a temporary fuel oil pump, in lieu of a

continuous fire watch, which reduced the defense in depth of the Fire Protection

Program.

The inspectors determined that the use of a temporary fuel oil pump in the event of

a fire, in lieu of a continuous fire watch, constituted an adverse change to the Fire

Protection Program, was contrary to License Condition 2.C.4 and a performance

deficiency. The performance deficiency was more-than-minor because it affected the

Protection Against External Factors attribute of the Initiating Events Cornerstone and

adversely affected the cornerstone objective to limit the likelihood of events that upset

plant stability and challenge critical safety functions during shutdown as well as power

operations. Specifically, the use of the alternative compensatory measure reduced the

defense in depth of the Fire Protection Program by failing to provide compensatory

measures to reduce the likelihood of occurrence of a fire and failing to provide prompt

detection of a fire. In accordance with IMC 0609, Significance Determination Process,

Attachment 0609.04, Initial Characterization of Findings, Table 2 the inspectors

determined the finding affected the Initiating Events cornerstone. The finding degraded

fire protection defense-in-depth strategies, and the inspectors determined, using

Table 3, that it could be evaluated using Appendix F, Fire Protection Significance

Determination Process. The inspectors determined that the finding represented a

low degradation and was screened as having very-low safety significance (Green) in

Task 1.3.1 of IMC 0609, Appendix F, because repair activities were in place that would

have maintained safe shutdown (SSD) conditions and were reasonably achievable.

This finding had a cross-cutting aspect in the Conservative Bias component of the

Human Performance cross-cutting area. Specifically, the licensee implemented an

alternate compensatory measure that only focused on the emergency diesel generator

operability and hence, the post-SSD strategy of the plant without considering the

2

defense in depth requirements of their Fire Protection Program to prevent, detect,

and suppress a fire that could affect equipment needed for SSD of the plant.

(Section 1R05.11b)

3

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection (71111.05T)

The purpose of the Fire Protection Triennial Baseline Inspection was to conduct a

design-based, plant specific, risk-informed, onsite inspection of the licensees Fire

Protection Programs defense-in-depth elements used to mitigate the consequences

of a fire. The Fire Protection Program shall extend the concept of defense-in-depth to

fire protection in plant areas important to safety by:

preventing fires from starting;

rapidly detecting, controlling and extinguishing fires that do occur;

providing protection for structures, systems, and components important to safety

so that a fire that is not promptly extinguished by fire suppression activities will

not prevent the safe-shutdown (SSD) of the reactor plant; and

taking reasonable actions to mitigate postulated events that could potentially

cause loss of large areas of power reactor facilities due to explosions or fires.

The inspectors evaluation focused on the design, operational status, and material

condition of the reactor plants Fire Protection Program, post-fire SSD systems, and

B.5.b mitigating strategies. The objectives of the inspection were to assess whether

the licensee had implemented a Fire Protection Program that: (1) provided adequate

controls for combustibles and ignition sources inside the plant; (2) provided adequate

fire detection and suppression capability; (3) maintained passive fire protection features

in good material condition; (4) established adequate compensatory measures for

out-of-service, degraded or inoperable fire protection equipment, systems or features;

(5) ensured that procedures, equipment, fire barriers and systems exist so that the

post-fire capability to safely shutdown the plant was ensured; (6) included feasible and

reliable operator manual actions when appropriate to achieve SSD; and (7) identified fire

protection issues at an appropriate threshold and ensured these issues were entered

into the licensees Problem Identification and Resolution Program.

In addition, the inspectors review and assessment focused on the licensees post-fire

SSD systems for selected risk-significant fire areas. Inspector emphasis was placed on

determining that the post-fire SSD capability and the fire protection features were

maintained free of fire damage to ensure that at least one post-fire SSD success path

was available. The inspectors review and assessment also focused on the licensees

B.5.b-related license conditions and the requirements of Title 10 of the Code of Federal

Regulations (CFR), Part 50.54 (hh)(2). Inspector emphasis was to ensure that the

licensee could maintain or restore core cooling, containment, and spent fuel pool cooling

capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of

power reactor facilities due to explosions or fires. Documents reviewed are listed in the

Attachment to this report.

4

The fire areas and fire zones and B.5.b mitigating strategies selected for review during

this inspection are listed below and in Section 1R05.13. The fire areas and fire zones

selected constituted four inspection samples and the B.5.b mitigating strategies selected

constituted two inspection samples, respectively, as defined in Inspection

Procedure 71111.05T.

Fire Area Fire Zone Description

II 1A Residual Heat Removal and Core Spray Pump Room, Division II

I 1B Residual Heat Removal and Core Spray Pump Room, Division I

I 2B Control Rod Drive Hydraulic Control Unit Area

X 30 Turbine Operating Floor

.1 Protection of Safe Shutdown Capabilities

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the fire hazards analysis,

SSD analysis, and supporting drawings and documentation to verify that SSD

capabilities were properly protected.

The inspectors also reviewed the licensees design control procedures to ensure that

the process included appropriate reviews and controls to assess plant changes for any

potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis

and procedures.

b. Findings

No findings of significance were identified.

.2 Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers,

penetration seals, fire doors, electrical raceway fire barriers, and fire-rated electrical

cables. The inspectors observed the material condition and configuration of the

installed barriers, seals, doors, and cables. The inspectors reviewed approved

construction details and supporting fire tests. In addition, the inspectors reviewed

license documentation, such as U.S. Nuclear Regulatory Commission (NRC) Safety

Evaluation Reports, and deviations from NRC Regulations and the National Fire

Protection Association standards to verify that fire protection features met license

commitments.

The inspectors walked down accessible portions of the selected fire areas to observe

material condition and the adequacy of design of fire area boundaries (including walls,

fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the

area.

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The inspectors reviewed the installation, repair, and qualification records for a sample of

penetration seals to ensure the fill material was of the appropriate fire rating and that the

installation met the engineering design.

b. Findings

No findings of significance were identified.

.3 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression

and detection systems. The inspectors observed the material condition and

configuration of the installed fire detection and suppression systems. The inspectors

reviewed design documents and supporting calculations. In addition, the inspectors

reviewed license basis documentation, such as, NRC Safety Evaluation Reports,

deviations from NRC Regulations, and National Fire Protection Association standards

to verify that fire suppression and detection systems met license commitments.

b. Findings

No findings of significance were identified.

.4 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

For the selected fire areas, the inspectors verified that redundant trains of systems

required for hot shutdown would not be subject to damage from fire suppression

activities or from the rupture or inadvertent operation of fire suppression systems

including the effects of flooding. The inspectors conducted walkdowns of each of the

selected fire areas to assess conditions such as the adequacy and condition of floor

drains, equipment elevations, and spray protection.

b. Findings

No findings of significance were identified.

.5 Alternative Shutdown Capability

a. Inspection Scope

The inspectors reviewed the licensees systems required to achieve alternative SSD to

determine if the licensee had properly identified the components and systems necessary

to achieve and maintain SSD conditions. The inspectors also focused on the adequacy

of the systems to perform reactor pressure control, reactivity control, reactor coolant

makeup, decay heat removal, process monitoring, and support system functions.

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The inspectors conducted selected area walkdowns to determine if operators could

reasonably be expected to perform the alternate SSD procedure actions and that

equipment labeling was consistent with the alternate SSD procedure. The review also

looked at operator training as well as consistency between the operations shutdown

procedures and any associated administrative controls.

b. Findings

No findings of significance were identified

.6 Circuit Analyses

a. Inspection Scope

The inspectors verified that the licensee performed a post-fire SSD analysis for the

selected fire areas and the analysis appropriately identified the structures, systems, and

components important to achieving and maintaining SSD. Additionally, the inspectors

verified that the licensee's analysis ensured that necessary electrical circuits were

properly protected and that circuits that could adversely impact SSD due to hot shorts,

shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure

spurious actuations would not prevent SSD.

The inspectors' review considered fire and cable attributes, potential undesirable

consequences, and common power supply/bus concerns. Specific items included the

credibility of the fire threat, cable insulation attributes, cable failure modes, and

actuations resulting in flow diversion or loss of coolant events.

The inspectors also reviewed cable raceway drawings for a sample of components

required for post-fire SSD to verify that cables were routed as described in the cable

routing matrices.

The inspectors reviewed circuit breaker coordination studies to ensure equipment

needed to conduct post-fire SSD activities would not be impacted due to a lack of

coordination. Additionally, the inspectors reviewed a sample of circuit breaker

maintenance records to verify that circuit breakers for components required for post-fire

SSD were properly maintained in accordance with procedural requirements.

The inspectors verified for cables that are important to SSD, but not part of the

success path, and that do not meet the separation/protection requirements of

Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the

cable failure modes. In addition, the inspectors have verified that the licensee has

either: (1) determined that there is not a credible fire scenario (through fire modeling),

(2) implemented feasible and reliable manual actions to assure SSD capability, or

(3) performed a circuit fault analysis demonstrating no potential impact on SSD

capability exists.

b. Findings

No findings of significance were identified.

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.7 Communications

a. Inspection Scope

The inspectors reviewed, on a sample basis, the adequacy of the communication system

to support plant personnel in the performance of alternative SSD functions and fire

brigade duties. The inspectors verified that plant telephones, page systems, sound

powered phones, and radios were available for use and maintained in working order.

The inspectors reviewed the electrical power supplies and cable routing for these

systems to verify that either the telephones or the radios would remain functional

following a fire.

b. Findings

No findings of significance were identified.

.8 Emergency Lighting

a. Inspection Scope

The inspectors performed a plant walkdown of selected areas in which a sample of

operator actions would be performed in the performance of alternative SSD functions.

As part of the walkdowns, the inspectors focused on the existence of sufficient

emergency lighting for access and egress to areas and for performing necessary

equipment operations. The locations and positioning of the emergency lights were

observed during the walkdown and during review of manual actions implemented for

the selected fire areas.

b. Findings

No findings of significance were identified.

.9 Cold Shutdown Repairs

a. Inspection Scope

The licensee did not credit any repairs in order to achieve cold shutdown. Therefore, no

reviews were performed by the inspectors for this procedure section.

b. Findings

No findings of significance were identified.

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.10 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that compensatory measures were in place

for out-of-service, degraded or inoperable fire protection and post-fire SSD equipment,

systems, or features (e.g., detection and suppression systems, and equipment, passive

fire barriers, pumps, valves or electrical devices providing SSD functions or capabilities).

The inspectors also conducted a review of the adequacy of short term compensatory

measures to compensate for a degraded function or feature until appropriate corrective

actions were taken.

b. Findings

No findings of significance were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The inspectors reviewed changes to the approved Fire Protection Program to verify that

the changes did not constitute an adverse effect on the ability to safely shutdown. The

inspectors also reviewed the licensees design control procedures to ensure that the

process included appropriate reviews and controls to assess plant changes for any

potential adverse impact on the Fire Protection Program and/or post-fire SSD analysis

and procedures.

b. Findings

Implementation of Inadequate Alternate Compensatory Measure for Degraded Fire

Barrier

Introduction: The inspectors identified a finding of very-low significance (Green) and

associated Non-Cited Violation (NCV) of License Condition 2.C.4 of the Monticello

Nuclear Generating Plant, Unit No. 1, Renewed Facility Operating License. The

licensee implemented an alternative compensatory measure that was determined to be

adverse to safety shutdown. Specifically, the licensee approved the installation of a

temporary fuel oil pump, in lieu of a continuous fire watch, which reduced the defense in

depth of the Fire Protection Program.

Background: The inspectors reviewed Fire Protection Engineering Evaluation (FPEE)

FPEE-14-002, Revision 2, Establish Alternate Compensatory Measures for the

replenishment of Emergency Diesel Generator (EDG) Fuel Oil and Alternate Nitrogen,

which approved an alternative compensatory measure for a non-conforming fire barrier

in Fire Area 15E. Fire Area 15E contains redundant SSD Equipment, diesel fuel oil

transfer pumps P-11 and P-77, without separation as required by Section III.G.2 of

10 CFR Part 50, Appendix R. This issue was identified during the 2014 Triennial Fire

Protection Inspection (Inspection Report 05000263/2017008), and the licensee entered

this issue into the Corrective Action Program (CAP) as CAP 01394150, NRC TIA 2012-03

Final Response EDG Fuel Oil Supply. The inspectors reviewed Operations Manual

Section B.08.05-05 Step G.2 and determined it required a continuous fire watch to be

established in Fire Area 15E due to the condition described in CAP 01394150. The

9

inspectors reviewed FPEE-14-002 and determined that this evaluation approved

installation of a temporary fuel oil pump in the event of a fire in lieu of a continuous fire

watch. The inspectors determined that this alternative compensatory measure failed to

meet the objectives of a continuous fire watch, namely reducing the likelihood of the

occurrence of a fire and providing prompt detection of a fire. The use of the alternative

compensatory measure reduced the defense in depth of the Fire Protection Program,

and, therefore, was determined to be adverse to SSD.

Analysis: License Condition 2.C.4 states that NSPM may make changes to the

approved Fire Protection Program without prior approval of the Commission only if

those changes would not adversely affect the ability to achieve and maintain SSD in

the event of a fire. The inspectors determined that the use of a temporary fuel oil pump

in the event of a fire, in lieu of a continuous fire watch, constituted an adverse change

to the Fire Protection Program, was contrary to License Condition 2.C.4 and a

performance deficiency. Specifically, the alternative compensatory measure reduced

the defense in depth of the Fire Protection Program by failing to provide a means to

reduce the likelihood of a fire and failing to provide for detection of a fire. The inspectors

determined that the performance deficiency was more-than-minor because it affected

the Protection Against External Factors attribute of the Initiating Events Cornerstone and

adversely affected the cornerstone objective to limit the likelihood of events that upset

plant stability and challenge critical safety functions during shutdown as well as power

operations. Specifically, the use of the alternative compensatory measure reduced the

defense in depth of the Fire Protection Program by failing to provide compensatory

measures to reduce the likelihood of occurrence of a fire and failing to provide prompt

detection of a fire.

In accordance with Inspection Manual Chapter 0609, Significance Determination

Process, Attachment 0609.04, Initial Characterization of Findings, Table 2 the

inspectors determined the finding affected the Initiating Events cornerstone. The finding

degraded fire protection defense-in-depth strategies, and the inspectors determined,

using Table 3, that it could be evaluated using Appendix F, Fire Protection Significance

Determination Process. The inspectors determined that the finding represented a low

degradation and was screened as having very-low safety significance (Green) in

Task 1.3.1 of Inspection Manual Chapter 0609, Appendix F, because repair activities

were in place that would have maintained SSD conditions and were reasonably

achievable. The licensee entered this issue into the CAP as CAP 501000000439,

2017 FP TRI: Inappropriate Alt Comp Meas. The licensee implemented a modification

in 2015 to install a permanent fire barrier to provide separation between diesel oil pumps

P-11 and P-77.

This finding had a cross-cutting aspect in the Conservative Bias component of the

Human Performance cross-cutting area. Specifically, the licensee implemented an

alternate compensatory measure that only focused on the EDG operability and hence,

the post-SSD strategy of the plant without considering the defense in depth requirements

of their Fire Protection Program to prevent, detect, and suppress a fire that could affect

equipment needed for SSD of the plant.

Enforcement: License Condition 2.C.4 states that NSPM may make changes to the

approved Fire Protection Program without prior approval of the Commission only if those

changes would not adversely affect the ability to achieve and maintain SSD in the event

of a fire.

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Contrary to the above, from April 23, 2014, to July 1, 2015, the licensee implemented an

alternative compensatory measure that adversely affected the ability to achieve and

maintain SSD in the event of a fire. Specifically, the alternative compensatory measure

reduced the defense in depth of the Fire Protection Program by failing to provide a

means to reduce the likelihood of a fire and failing to provide detection for a fire.

Because this violation was of very-low safety significance and it was entered into

the licensees CAP as Action Request 501000000439, this violation is being treated

as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000263/2017007-01, Inappropriate Alternative Compensatory Measure)

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The inspectors reviewed the licensee's procedures and programs for the control of

ignition sources and transient combustibles to assess their effectiveness in preventing

fires and in controlling combustible loading within limits established in the fire hazards

analysis. A sample of hot work and transient combustible control permits were also

reviewed. The inspectors performed plant walkdowns to verify that transient

combustibles and ignition sources were being implemented in accordance with

the administrative controls.

b. Findings

No findings of significance were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees preparedness to handle large fires or explosions

by reviewing selected mitigating strategies. This review ensured that the licensee

continued to meet the requirements of their B.5.b-related License Conditions and

10 CFR 50.54(hh)(2) by determining that:

procedures were being maintained and adequate;

equipment was properly staged, maintained, and tested;

station personnel were knowledgeable and could implement the procedures; and

additionally, inspectors reviewed the storage, maintenance, and testing of

B.5.b-related equipment.

The inspectors reviewed the licensees B.5.b-related License Conditions and evaluated

selected mitigating strategies to ensure they remain feasible in light of operator training,

maintenance/testing of necessary equipment and any plant modifications. In addition,

the inspectors reviewed previous inspection reports for commitments made by

the licensee to correct deficiencies identified during performance of Temporary

Instruction 2515/171 or subsequent performances of these inspections.

The B.5.b mitigating strategies selected for review during this inspection are listed

below. The offsite and onsite communications, notifications/emergency response

organization activation, initial operational response actions and damage assessment

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activities identified in Table A.3-1 of Nuclear Energy Institute 06-12, B.5.b Phase II

and III Submittal Guidance, Revision 2, are evaluated each time due to the mitigation

strategies scenario selected.

NEI 06-12,

Revision 2, Licensee Strategy (Table)

Section

3.4.10 Portable Sprays (Table A.8-5.10)

3.4.5 Makeup to Condensate Storage Tank (Table A.8-5.5)

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems (71152)

a. Inspection Scope

The inspectors reviewed the licensees CAP procedures and samples of corrective

action documents to verify that the licensee was identifying issues related to the Fire

Protection Program at an appropriate threshold and entering them in the CAP. The

inspectors reviewed selected samples of condition reports, design packages, and fire

protection system non-conformance documents.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 3, 2017, the inspectors presented the inspection results to Mr. P. Gardner,

and other members of the licensee staff. The licensee acknowledged the issues

presented. The inspectors confirmed that none of the potential report input discussed

was considered proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION

12

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Kouba, Regulatory Affairs Engineer

B. Dixon, Engineering Supervisor

M. Lingenfelter, Site Engineering Director

A. Ward, Regulatory Affairs Manager

P. Young, Program Engineering Manager

P. Nordmeir, Fire Protection Program Owner/Fleet Lead

J. Johnson, Fire Protection Systems Engineer

P. Gardner, Site Vice President

U.S. Nuclear Regulatory Commission

R. Daley, Branch Chief, EB3

D. Krause, Resident Inspector

P. Zurawski, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000263/2017007-01 NCV Inadequate Fire Barrier Inspection Procedure

(Section 1R05.2b)

Closed

05000263/2017007-02 NCV Implementation of Inadequate Alternate Compensatory

Measure for Degraded Fire Barrier (Section 1R05.11b)05000263/2017007-01 NCV Inadequate Fire Barrier Inspection Procedure

(Section 1R05.2b)

Discussed

None

LIST OF ACRONYMS USED

CAP Corrective Action Program

CFR Code of Federal Regulations

EDG Emergency Diesel Generator

IMC Inspection Manual Chapter

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

SSD Safe Shutdown

Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

CALCULATIONS

Number Description or Title Revision

05-084 Combustible Loading Calculation 002A

CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION

Number Description or Title Date

501000000439 2017 Fire Protection Inappropriate Alt Comp Measure 07/10/2017

501000000489 2017 Fire Protection 0275-02 description error 07/11/2017

501000000492 2017 Fire Protection Inspection Battery Room Door Testing 07/11/2017

501000000146 2017 Fire Protection Inspection Fire hose Hydrostatic Test 06/28/2017

501000000232 2017 Fire Protection Inspection Operators Had Trouble 06/28/2017

Locating ASDS Panel Keys

01560947 2017 Fire Protection Inspection Location Description for RHR 06/13/2017

Aux Compressor

015660992 2017 Fire Protection Inspection USAR J.05 Typo 06/13/2017

501000000338 Grout Installation Fire Watch Requirements 07/05/2017

501000000416 8053 Procedure has Incorrect Terminology 07/05/2017

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED DURING INSPECTION

Number Description or Title Date

01427709 Crack in Fire Penetration FZ-3395 04/21/2014

01426153 Fire Hazard Found in Reactor Building 04/09/2014

01426122 Combustible Loading Issues Identified in B RHR Room 04/09/2014

01426116 Fire Penetrations Have Cosmetic Cracks 04/09/2014

01488072 Radio dead-zone areas in the Plant need to be identified 07/13/2015

DRAWINGS

Date or

Number Description or Title

Revision

NH-36246 Residual Heat Removal(A) 03/20/2012

NH-36248 Core Spray(A) 03/20/2012

NH-85509 P&ID Service Condensate System Radwaste Building 80

NQ-193744-1-1 Plant Administration Building Fire Main B

NX-16991-14 Fire Hazards Analysis, Plan View Administration Building A

Elevation 928-0

NX-7823-4-11C 11 RHR CTMT Spray INBD ISOL MO-2029, Scheme B3333 76

NX-7905-46-14E 11 RHR CTMT Spray OTBD ISOL MO-2020, Scheme B3339 78

NX-7905-46-15E 11 RHR CTMT Spray INBD ISOL MO-2022, Scheme B3709 76

2

DRAWINGS

Date or

Number Description or Title

Revision

NX-7905-46-16 Residual Heat Removal System Elementary Diagram (10-6) 77

FS-0014 Nelson Firestop Concrete Floor or Wall Cables 3

FS-0001 Nelson Firestop Concrete Floor or Wall Metallic Pipe or 2

Conduit

FS-0008 Nelson Firestop Concrete Floor or Wall Metallic Pipe or 4

Conduit

NQ-158852 Schematic of Pre-Action Fire Protection Systems A

PROCEDURES

Date or

Number Description or Title

Revision

0275-03 Fire Door Inspection 41

0273-02 Fire Barrier Wall, Damper and Floor Inspection 40

2204 Plant Shutdown 70

2B4328-A1 Cable and Raceway Information System Electrical Cable 06/28/2017

Schedule from C-03 to C-292

A.8-05.05 Make Up to CST 5

A.8-05.10 Portable Sprays 6

B.03.04-05 Operations Manual Section: Residual Heat Removal System 83

B3309-C03/1 Cable and Raceway Information System Electrical Cable 06/28/2017

Schedule from C-03 to C-292

B3333-C41/1 Cable and Raceway Information System Electrical Cable 06/27/2017

Schedule from B3309 to C-03

C41-JX105D/3 Cable and Raceway Information System Electrical Cable 06/27/2017

Schedule from C-41 to JX105D

0275-02 Fire Barrier Wall, Damper, and Floor Inspection 40

0275-03 Fire Door Inspections 41

1216-01 Fire Door Inspections 58

4024-PM Fire Door Maintenance 52

A.3-02-C Fire Zone 2-C West HCU Area Strategy A.3-02-C 12

A.3-02-B Fire Zone 2-B West HCU Area Strategy A.3-02-C 13

0274 Fire Hose Hydrostatic Test - Interior Hose Stations 30

C.4-B.08.05.A Plant Fire 32

8053 Fire Barrier Penetration Sealing and Visual Inspection 35

8053-01 Fire Barrier Penetration Utility Sealing 11

A.8-01.01 Extensive Damage Mitigation Strategy Overview 7

A.8-03.01 Initial Response Actions 5

A.8-05.05 Make Up to CST 5

A.8-03.01 Initial Response Actions 5

A.8-05.10 Portable Sprays 6

3

WORK ORDERS

Date or

Number Description or Title

Revision

00532058 IC-V-EF-31, Inspect, Clean and Test Smoke Detector 8

00532057 IC-RE-1, Inspect, Clean and Test Smoke Detector 8

00551198 OSP-FIR-1489; B.5.b Quarterly Equipment Inventory 04/25/2017

00553313 OPS-FIR, 1216-01 Fire Door Inspections- Daily 04/25/2017

00548794 OSP-P507 Engine Run Test, #12 Portable Diesel Water 06/07/2017

Pump

00548793 OSP-P507 Engine Run Test, #11 Portable Diesel Water 03/23/2017

Pump

00548397 Quarterly PM for Portable Diesel Generator 03/08/2017

00540051-01 1061 EMERG LIGHTING QTRLY OPER ABILITY TEST 09/27/2016

00549800-01 1061 EMERG LIGHTING QTRLY OPER ABILITY TEST 03/07/2017

00553313-01 1216-01 Fire Door Inspections - Daily 05/30/2017

0054946-01 PM 4024 (Inspect Fire Doors - Accessible Only) 02/13/2017

00533867-01 0275-02 Fire Barrier Wall/Damper/Flr Insp-SCAF 04/10/2017

00502605-01 0275-03 Fire Door Inspections 05/16/2016

00491058-01 0275-02 Fire Barrier Wall/Damper/Flr Insp-Scaf 04/04/2015

00463677-01 MECH-FIR, 0274 Fire Hose Hydro Test Interior Hose STA 11/14/2014

0034403 0275-01 Fire Barrier Penetration Vis Insp 05/19/2009

00414101 ENG-FIR, ENG 0275-01 Fire Barrier Penetration Seal Vis 05/14/2011

Insp

00441332-01 0275-01 Fire Barrier Penetration Seal Vis Insp 03/21/2013

00491059-01 0275-01 Fire Barrier Penetration Seal Vis Insp 04/11/2015

00470489-01 Inspect/Repair Fire Penetration RB-516 in A RHR Room 12/21/2012

00546861-01 P-507 - OSP-FIR-0609 Pump Flow Test 05/30/2017

00553371-01 P-507 - OSP-FIR-0609 Engine Run Test 05/30/2017

00551198-01 1490 - B.5.B Equipment Quarterly Inventory 04/19/2017

ML17234A730

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