ML19120A459

Triennial Fire Protection Inspection Plan

ML19120A459
Person / Time
Site:	Oconee
Issue date:	04/30/2019
From:	Rodney Fanner Division of Reactor Safety II
To:
References
IR 2019012
Download: ML19120A459 (9)

Text

OCONEE TRIENNIAL FIRE PROTECTION INSPECTION PLAN Report No.:

05000269/2019012, 05000270/2019012, AND 05000287/2019012 Inspection of:

Oconee Nuclear Plant Unit 1, 2, and 3 Inspection Dates:

Information Gathering Visit: April 8 - 11, 2019 Week 1 of onsite inspection: May 20 - 24, 2019 Week 2 of onsite inspection: June 3 - 7, 2019 Type of Inspection:

Fire Protection (Triennial) - IP 71111.05XT Planned Inspection Hours: 240 per IP 71111.05XT - Assuming no complex findings Inspectors:

R. Fanner - Lead Inspector E. Coffman - Lead Operations/E-lights/Comms W. Monk - Lead Electrical D. Terry-Ward - Classical Fire Protection & B.5.b Inspection Procedure and Objectives: The inspection will be performed per Inspection Procedure (IP) 71111.05XT, Fire Protection (Triennial) - Issued January 31, 2013. The objectives of the inspection are to evaluate the design, operational status, and material condition of the licensees Fire Protection Program (FPP) for selected Fire Areas (FA) and to verify that B.5.b mitigating strategies are feasible.

Risk-Informed Inspection Assistance: G. Macdonald, Senior Reactor Analyst, DRP BR 7, discussed the risk rankings of the plant fire areas with the lead inspector during the information gathering site visit. Based on those discussions, and walkdowns of Unit 1 and 2, the following FAs were selected for review:

Protected Service Water (PSW) - Deterministic AB092_F1, Control Battery Charger 2CA - Performance Based AB092_H1, Control Battery Charger 2CS - Performance Based U3TB29_B1, 3TC Switchgear - Performance Based U3TB06_C4, Main FDW Pump 3B Fire - Performance Based U2AB081_B, Performance Based (Transient Fire)

U2TB15, Main FDW Pump 2A Fire - Performance Based The B.5.b mitigating strategy selected for review is: Manual Operation of TDEFDWP Projects Branch Chief/Senior Resident Inspector (SRI) perspective and comments:

Residents provided some feedback on fire protection program at site and corrective actions Allegation Awareness: J. Worsolio, Senior Project Engineer stated that team may want to focus on any aging management of the fire protection program. Should be sensitive to CRs initiated based on fleet issues.

Division Director Perspective:

Outstanding Items to Be Reviewed for Closure: None.

2 Detailed Inspection Schedule:

Preparation in RII Office: May 6 - 9, 2019 Onsite NRC Team Room: TBD Entrance Meeting: Monday, May 20, 2019 @ 1:30 PM Daily Debrief Meetings: TBD (Mon.-Thurs.) 4:00 pm in conference room 2B Pre-Exit Final Debrief Meeting: TBD Exit Meeting: TBD In Charge of Exit: Rodney Fanner TFPI Team Contact Information:

Oconee Resident Office: SRI: Mr. E. Crowe (864)-882-6927 Onsite NRC Team Room: TBD Lodging During Inspection: R. Fanner - TBD in Clemson, SC; Team members in the Clemson, SC area Licensee Contact Information:

Mr. Samuel Adams: Sr. Nuclear Engineer (864)-873-3348 Branch Chief's Instructions:

Continue to focus on licensees ability to identify and correct issues that are not in keeping with fire protection commitments.

Attachments:

Pertinent inspector information and assignments are listed in the Attachments.

1. Inspector Assignments

2. Previously Inspected Fire Areas

3. Previous inspection results

4. Due Dates for Documentation Approving Branch Chief: ________________________

S. Shaeffer, Branch Chief, EB2 Date Copies Provided (e-mail):

DRS/EB2 Branch Chief: S. Shaeffer DRP Branch Chief: F. Ehrhardt DRS Branch Files: S:\\DRS\\Eng Branch 2\\Plans\\Oconee_2019012 TFPI Plan.docx Senior Project Engineer: J. Worosilo Senior Reactor Analyst: S. Freeman Inspection Team: William Monk, Ellery Coffman, and Denise Terry-Ward

ML19120A459 __

SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII/ DRS RII/ DRS SIGNATURE RJF2 SMS NAME RFANNER SSHAEFFER DATE 4/30/2019 4/30/2019 E-MAIL COPY?

YES NO YES NO

INSPECTOR ASSIGNMENTS Procedure 71111.05XT Inspection Requirements (Bold: Consolidate inputs for section) 02.02 Fire Protection Inspection Requirements (

a. Protection Of Safe Shutdown Capabilities: [Fanner, Monk, Coffman, Terry-Ward,]

b. Passive Fire Protection: [Terry-Ward]

c. Active Fire Protection: [Terry-Ward]

d. Protection From Damage From Fire Suppression Activities: [Terry-Ward]

e. Shutdown from a Primary Control Station

1. Methodology: [Coffman, Monk]

Sample functions: Added after Ops and Electrical collaboration

2. Operational Implementation: [Coffman, Monk]

f.

Circuit Analyses: [Monk, Coffman]

Response to IN 2014-010, Potential Circuit Failure-Induced Secondary Fires or Equipment Damage

g. Communications:

1. Operations: [Coffman, Monk]

2. Fire Brigade: [Terry-Ward, Fanner]

h. Emergency Lighting: [Coffman, Fanner]

i.

Cold Shutdown Repairs: [Terry-Ward, Coffman]

j.

Compensatory Measures:

1. Compensatory measures for degraded fire protection features: [Terry-Ward, Fanner]

2. Manual actions as compensatory measures for SSD: [Coffman, Monk, Fanner]

k. Radiological Release: [Terry-Ward, Fanner]

l.

Non-power Operations: [Coffman, Monk, ]

m. Monitoring Program: [Fanner]

n. Plant Change Evaluation: [Monk, Coffman, Terry-Ward, Fanner]

02.03 B.5.b Inspection Activities: [Terry-Ward, Fanner]

02.04 Identification and Resolution of Problems: [Fanner, All]

PREVIOUSLY INSPECTED FIRE AREAS IR 2002-003 FZ Description 34 Unit 1 Turbine Building 106 Unit 1 Cable Spreading Room 108 Unit 1 East Penetration Room SSF Safe Shutdown Facility IR 2005-007 FZ Description 10 through 18, 30-33, 33A, 37, 40, 41 Unit 2 Turbine Building 92 Unit 2 Equipment Room 102 Unit 2 West Penetration Room IR 2008-007 FZ Description 89 Unit 3 Equipment Room 101 Unit 3 Cable Spreading Room 112 Unit 3 Control Room IR 2013-007 FA Description Perf. Based or Determ.

Scenario 19 Unit 1 Main Feedwater Pump Area PB Fire involving main feedwater pump 1B and non-suppression 45 Units 1 & 2 Block House PB Transient fire at riser Q-100 46 CT-4 Block House DB Classical FP features 106 Unit 1 Cable Room PB CRD Trans/logic cabinet severe fire IR 2016-007 FZ 33 Unit 2 6900/4160 Volt Switchgear PB Focus on scenario C12TD Switchgear Severe Fire FZ 105 Unit 2 Cable Room PB Focus on scenario J3CRD V Reg/Xfmr Fire FZ 103 Unit 2 East Penetration Room PB Focus on scenario B1MCC 2XH Severe Fire FZ KEO Keowee Hydro Station DB This is a deterministic fire area. Focus on fixed suppression system

PAST PLANT PERFORMANCE:

TFPI reports:

From 2016 report Green. The NRC identified a Green NCV of 10 CFR 50.48(c) and National Fire Protection Association Standard (NFPA) 805, Section 2.4.2.4 for the licensees failure to perform an adequate engineering analysis to determine the effects of fire on the ability to achieve the nuclear safety performance criteria, and consequently, did not add an associated variation from deterministic requirements (VFDR) into the Fire probabilistic risk assessment (PRA).

Specifically, the licensees Nuclear Safety Capability Assessment (NSCA) failed to identify cables in the turbine building (TB) that could prevent the operation of the High Pressure Injection (HPI) Pumps. This item was entered into the corrective action program (CAP) as action request (AR) 02011673, and the licensee implemented compensatory measures in the form of hourly fire watches.

The performance deficiency (PD) was more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e. fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, the licensees failure to analyze the effects of fire damage on the HPI cables in the TB could result in fire damage adversely affecting the ability to achieve and maintain safe and stable conditions. Using the guidance of IMC 0609, App. F, the finding was screened as Green because the finding did not affect the ability to reach and maintain a stable plant condition within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a fire event (Task 1.4.5-B). A cross cutting aspect in the area of Human Performance, Consistent Process because the licensee did not use a consistent, systematic approach to make decisions, and did not incorporate appropriate risk insights (H.13). (Section 1R05.06)

From 2013 report TBD: An NRC-identified Apparent Violation (AV) was identified for the licensees failure to comply with the requirements of 10 CFR 50.48(c) and National Fire Protection Association Standard 805 (NFPA 805). The Oconee fire probabilistic risk assessment (Fire PRA) failed to address the risk contributions associated with all potentially risk significant fire scenarios. This finding does not represent an immediate safety concern because the licensee entered the issue in the corrective action program as Problem Investigation Program (PIP) O-13-08059 and PIP O-13-08061 and implemented fire watches as compensatory measures.

Failure to comply with the requirements of 10 CFR 50.48(c) and NFPA 805 to address the risk contributions associated with all potentially risk significant fire scenarios was a performance deficiency. This performance deficiency was determined to be more than minor because it was associated with the Mitigating Systems cornerstone objective of protection against external events (i.e., fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be potentially greater than Green. Therefore, further analysis is required to assess the significance of the finding. The cause of this finding was determined to have a crosscutting aspect of H.4(c) in the Work Practices component of the Human Performance area because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported. (Section 1R05.06)

2 TBD. An NRC-identified Apparent Violation (AV) and associated traditional enforcement violation of Oconee Nuclear Station Renewed Facility Operating License Condition 3.D for Units 1, 2, and 3 was identified for the licensees failure to implement and maintain in effect all provisions of the approved fire protection program (FPP) that comply with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. The licensee made a change to the approved FPP involving control of combustible materials when the definition of transient fire loads was revised to exclude fire retardant scaffolding materials as transient fire loads, which would not require the licensee to track these

DUE DATES FOR DOCUMENTATION Information gathering Wednesday, April 9-11, 2019 Onsite 1 Monday, May 20 - 24, 2019 Onsite 2 Monday, June 3 - 7, 2019 Exit Meeting TBD Notification Letter Friday, February 20, 2019 Report inputs to TL Friday, June 21, 2019 Draft Report to team and Peer Review Friday, June 28, 2019 Feedback to TL (team and Peer)

Friday, July 6, 2019 TL address comments and forward to BC Friday, July 10, 2019 Report Due Monday, July 22, 2019

2 SAMPLE FINDING DEVELOPMENT Ensure you refer to IMC 0609, Appendix F, Attachment 2 for finding significance characterization.

1.4.1 Fire Prevention and administrative Controls The plant combustible material controls program Other administrative controls such as work permit programs Hot work fire watches Roving or periodic fire watches (other than in category 1.4.2, below)

Training programs 1.4.2 Fixed Fire Protection Systems Fixed fire detection systems Fixed fire suppression systems (automatic or manual)

Fire watches posted as a compensatory measure for a fixed fire protection system outage or degradation 1.4.3 Fire Confinement Fire barrier elements that separate one fire area from another Penetration seals Water curtains Fire and/or smoke dampers Fire doors 1.4.4 Localized Cable or Component Protection Passive physical features installed for the thermal/fire protection of cables, cable raceways, or individual components Raceways or component fire barriers (e.g., cable wraps)

Radiant heat shields protecting a component or cable Spatial separation (e.g., per App. R Section III.G.2 1.4.5 Post-fire Safe Shutdown (SSD Systems or functions identified in the post-fire SSD analysis Systems or functions relied upon for post-fire SSD Post-fire SSD component list (e.g., completeness)

Post-fire SSD analysis (e.g., completeness)

Post-fire plant response procedures Operator manual actions Alternate shutdown (e.g., control room abandonment)

Circuit failure modes and effects (e.g., spurious operation issues) 1.4.6 Manual Firefighting Hose Station Fire Extinguishers Fire pre-plans 1.4.7 Fire Water Supply Fire pumps, yard loop piping, and water sources