IR 05000275/2009008

IR 05000275-09-008; 05000323-09-008; on 07/06/2009 07/23/2009; Pacific Gas and Electric Company; Diablo Canyon Power Plant, Units 1 and 2; Triennial Fire Protection Team Inspection

ML092540205
Person / Time
Site:	Diablo Canyon
Issue date:	09/10/2009
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Conway J Pacific Gas & Electric Co
References
FOIA/PA-2011-0221 IR-09-008
Download: ML092540205 (26)

Text

September 10, 2009 John Senior Vice President &

Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 3 Mail Code 104/6/601 Avila Beach, CA 93424

SUBJECT: DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000275/2009008; 05000323/2009008

Dear Mr. Conway:

On July 23, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant. The enclosed inspection report documents the inspection results, which were discussed in an exit meeting with Mr. James R. Becker, Site Vice President, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The team reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspection identified one violation of very low safety significance (Green). However, because of the very low safety significance and because the finding was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with the NRC Enforcement Policy. If you contest the noncited 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 Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at the Diablo Canyon Power Plant facility.

In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the Diablo Canyon Power Plant facility. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 Pacific Gas and Electric Company - 2 -

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Neil O'Keefe, Chief Engineering Branch 2 Division of Reactor Safety Dockets: 50-275; 50-323 Licenses: DPR-80; DPR-82

Enclosure:

NRC Inspection Report 05000275/2009008; 05000323/2009008 w/Attachment: Supplemental Information

REGION IV Dockets: 50-275; 50-323 Licenses: DPR-80; DPR-82 Report: 05000275/2009008; 05000323/2009008 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, California Dates: July 6 through July 23, 2009 Inspectors: J. Mateychick, Senior Reactor Inspector S. Graves, Senior Reactor Inspector R. Rodriguez, Senior Reactor Inspector D. Livermore, Nuclear Systems Engineer

Accompanying Personnel: Z. Bailey, Reactor Inspector NSPDP S. Marquez, Reactor Inspector NSPDP Approved By: Neil O'Keefe, Chief Engineering Branch 2 Division of Reactor Safety

- 2 - Enclosure

SUMMARY OF FINDINGS

IR 05000275/2009008; 05000323/2009008; 07/06/2009 - 07/23/2009; Pacific Gas and Electric Company; Diablo Canyon Power Plant, Units 1 and 2; Triennial Fire Protection Team Inspection

The report covered a 2-week triennial fire protection team inspection. One Green noncited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's 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.

An NRC-identified noncited violation of License Condition 2.C.(4), "Fire Protection," was identified in that post-fire safe shutdown Procedure CP M-10, "Fire Protection of Safe Shutdown Equipment," Revision 20, was not consistent with the calculation M-928, "10 CFR 50 Appendix R Safe Shutdown Analysis," for Fire Area 3-CC, containment penetration rooms. Specifically, certain time-critical operator manual actions identified in the safe shutdown analysis were not incorporated into Procedure CP M-10 such that there was assurance that the actions would be completed within the times assumed in the safe shutdown analysis. A fire in Fire Area 3-CC may cause a spurious actuation of Atmospheric Dump Valves PCV-19 and PCV-20. The safe shutdown analysis recommends failing closed Atmospheric Dump Valves PCV-19 and PCV-20 by manually isolating their air supply (instrument air, backup air, and nitrogen) and then venting the supply line to avoid excessive plant cooldown. Procedure CP M-10, "Fire Protection of Safe Shutdown Equipment," Revision 20, did not include the steps to perform these actions.

The inspectors determined that failing to incorporate post-fire safe shutdown actions to prevent an excessive cooldown due to fire induced spurious opening of atmospheric dump valves in the post-fire safe shutdown operating procedure was a performance deficiency. This finding is more than minor because it is associated with the reactor safety mitigating systems cornerstone attributes of protection against external events, (i.e., fire), and procedure quality. This finding was found to be of very low safety significance (Green) consistent with the guidance in Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," and its attachments. This finding has a crosscutting aspect in the Resources component of the Human Performance area because the procedure was not complete and up to date in accordance with the safe shutdown analysis, H.2(c).

B. Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (71111.05TTP)

The NRC conducted a triennial fire protection inspection in accordance with NRC Inspection Procedure 71111.05TTP, "Fire Protection-NFPA Transition Period (Triennial)," at the Diablo Canyon Power Plant. The licensee committed to adopt a risk informed fire protection program in accordance with National Fire Protection Association (NFPA) 805, "Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants," 2001 Edition. At the time of this inspection, the licensee had 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 shut down 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 and the Diablo Canyon Power Plant Individual Plant Examination of External Events to select the following four fire areas in Unit 2 for review:

• Fire Area 3-CC, Containment Penetration Rooms (all levels)

• Fire Area 7B, Cable Spreading Room

• Fire Area 20, 12 kV Switchgear and Cable Spreading Room

• Fire Area TB-10, (Turbine Building) Fire Zone 23-A, F Bus 4 kV Cable Spreading Room

• Fire Area TB-10, Fire Zone 24-A, F Bus 4 kV Switchgear Room The team evaluated the licensee's fire protection program using applicable requirements, which included plant Technical Specifications, License Condition 2.C.(4), 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, the fire hazards analysis, and the post-fire safe shutdown analysis.

Specific documents reviewed by the team are listed in the attachment. The team completed four inspection samples.

.1 Shutdown From Outside Main Control Room

a. Inspection Scope

The team reviewed the post-fire safe shutdown analysis in calculation M-928, "10 CFR 50 Appendix R Safe Shutdown Analysis," Operating Procedures OP AP-8A "Control Room Inaccessibility - Establishing Hot Standby," and OP AP-8B "Control Room Inaccessibility - Hot Standby to Cold Shutdown," piping and instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and other supporting documents to verify that hot and cold shutdown conditions could be achieved and maintained for fires in areas where the post-fire safe shutdown strategy relies upon manipulating shutdown equipment after evacuation of the control room.

The team focused on the following functions that must be available to achieve and maintain safe shutdown conditions:

$ Reactivity control capable of achieving and maintaining cold shutdown reactivity conditions,

$ Reactor coolant makeup capable of maintaining the reactor coolant inventory,

$ Reactor heat removal capable of achieving and maintaining decay heat removal, $ Supporting systems capable of providing other services necessary to permit extended operation of equipment necessary to achieve and maintain hot shutdown conditions, $ Verify that a safe shutdown can be achieved and maintained with and without off-site power.

The team verified that hot and cold shutdown conditions could be achieved and maintained with or without offsite power available. The team also verified that the post-fire safe shutdown analysis properly identified the components and systems needed to achieve and maintain post-fire safe shutdown conditions.

b. Findings

No findings of significance were identified.

.2 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed local operator manual actions to ensure that the actions could be implemented in accordance with plant procedures in the times necessary to support the post-fire safe shutdown method for the applicable fire area and to verify that those actions met the criteria in Enclosure 2 of NRC Inspection Procedure 71111.05TTP. Specifically, the team reviewed and walked down applicable sections of fire response procedure CP M-10, "Fire Protection of Safe Shutdown Equipment," Revision 20, for Fire Areas 3-CC (all levels), 20, and TB-10 to ensure the implementation and human factors adequacy of the procedure.

The inspectors reviewed cable routing data for a sample of safe shutdown components that had associated cables routed through the selected fire areas. The inspectors reviewed the electrical schematics and connection wiring diagrams to determine if the operator manual actions credited in Procedure CP M-10 for those components were adequate. The components and documents reviewed are listed in the Attachment.

The team also reviewed corrective action documents Action Request A0645338, "NRC URI on Manual Actions," and A0620761, "Manual Actions - Substantive with Documentation," to verify that the licensee had identified operator manual actions for post-fire safe shutdown in 10 CFR 50, Appendix R, Section III.G.2 designated areas and had plans in place to keep Action Requests open to assess and track resolution of the manual action issue as part of the plant-wide risk evaluation for transition to NFPA 805.

b. Findings

Safe Shutdown Procedure Not Consistent With Safe Shutdown Analysis

Introduction.

The team identified a violation of License Condition 2.C.(4), in that post-fire safe shutdown Procedure CP M-10, "Fire Protection of Safe Shutdown Equipment," Revision 20, was not consistent with the Calculation M-928, "10 CFR 50 Appendix R, Safe Shutdown Analysis," for Fire Area 3-CC, containment penetration rooms. Specifically, certain time-critical operator manual actions stated in the safe shutdown analysis were not incorporated into Procedure CP M-10 such that there was assurance that the actions would be completed within the times assumed in the safe shutdown analysis.

Description.

The team reviewed applicable sections of fire response Procedure CP M-10 to assess the procedural guidance for operation from the Main Control Room in the event of a fire in Fire Area 3-CC. As part of Diablo Canyon Power Plant transition to NFPA 805, the licensee credited several operator manual actions as compensatory measures for missing or degraded fire barriers. These operator manual actions will remain in place until they have been evaluated as part of the NFPA 805 transition. During review and walk down of Procedure CP M-10, the team noted that time critical operator manual actions specified in the safe shutdown analysis to locally fail close Atmospheric Dump Valves PCV-19 and PCV-20 were not incorporated into Procedure CP M-10.

A fire in Fire Area 3-CC may affect control cables, which can cause a spurious opening of Atmospheric Dump Valves PCV-19 and PCV-20. The safe shutdown analysis recommends failing closed valves PCV-19 and PCV-20 by manually isolating their air supply (instrument air, backup air, and nitrogen) and then venting the supply line to avoid excessive plant cooldown. This was a time-critical operator action because spurious opening of these valves could lead to the pressurizer level decreasing off scale low within 30 minutes. The team determined that lack of guidance could lead to an uncontrolled cooldown of the reactor coolant system which would complicate the shutdown evolution. Upon discovery of this procedural deficiency, the licensee initiated Notification SAPN 50253971 and revised Procedure CP M-10 to add the operator action.

Analysis.

The inspectors determined that failing to incorporate post-fire safe shutdown actions to prevent an excessive cooldown due to fire induced spurious opening of atmospheric dump valves in the post-fire safe shutdown operating procedure was a performance deficiency. This finding is more than minor because it is associated with the reactor safety mitigating systems cornerstone attributes of protection against external events, (i.e., fire), and procedure quality. The team determined that although Procedure CP M-10 did not incorporate the operator action specified in the safe shutdown analysis, it was likely that the operator would have recognized the need for the actions. Additionally, there was a low likelihood of fires which could cause the type of cable damage that would challenge the procedure weaknesses. Fire Area 3-CC is the electrical and mechanical penetration area for the Unit 2 containment and contains very low combustible materials and very few fixed ignition sources. Transient combustibles are strictly controlled as well. In consideration of the above, the finding was found to be of very low safety significance (Green) consistent with the guidance in Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," and its attachments. This finding has a crosscutting aspect in the Resources component of the Human Performance area because the procedure was not complete and up to date in accordance with the safe shutdown analysis H.2(c).

Because the licensee committed to adopting NFPA 805 and are changing their Fire Protection Program license basis to comply with 10 CFR 50.48.(c), these manual actions were to remain in effect as compensatory measures until the issue was resolved and compliance restored. Calculation M-928, "10 CFR 50 Appendix R Safe Shutdown Analysis," Revision 16, lists the manual actions credited on a fire area basis to compensate for component and cable losses.

Enforcement.

Diablo Canyon License Condition 2.C

(4) requires that the licensee shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in Revision 5 to the Final Safety Analysis Report Update, in Pacific Gas and Electric Company's December 6, 1984, Appendix R Analysis Report, and in the NRC staff's Fire Protection Evaluation in Safety Evaluation Reports Supplements 8, 9, 13, 23, and 27 to the Diablo Canyon Safety Evaluation Report. Final Safety Analysis Report Update, Appendix 9.5A, "Fire Hazards Analysis," states that the plant can be safely shutdown in the event of a fire in Fire Area 3-CC and states that operators may fail close Atmospheric Pump Valves PCV-19 and PCV-20 using manual actions. The Calculation M-928, "10 CFR 50 Appendix R Safe Shutdown Analysis," section for Fire Area 3-CC, containment penetration rooms, specified that Atmospheric Dump Valves PCV-19 and PCV-20 be failed closed to mitigate spurious opening.

Contrary to the above, Procedure CP M-10, "Fire Protection of Safe Shutdown Equipment," Revision 20, did not include the operator manual actions specified in Calculation M-928 to locally fail close Atmospheric Dump Valves PCV-19 and PCV-20. This condition has existed since at least October 14, 2008, when Procedure CP M-10, Revision 20, was issued. Although the licensee committed, prior to December 31, 2005, to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is not exercising enforcement discretion for this issue in accordance with the NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)." Specifically, this issue would have been expected to be identified and addressed by routine licensee quality assurance activities associated with correcting the susceptibility to excessive cooldown due to fire damage. Because this finding is of very low safety significance and was entered into the licensee's corrective action program (SAPN 50253971), this finding is being treated as a noncited violation, consistent with Section VI.A.1 of the NRC's Enforcement Policy. NCV 05000275/2009008-01, "Safe Shutdown Procedure Not Consistent With Safe Shutdown

Analysis.

"

.3 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 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.

The team reviewed license basis documentation, such as NRC safety evaluation reports and deviations from NRC regulations and the National Fire Protection Association codes, to verify that fire protection features met license commitments.

b. Findings

No findings of significance were identified.

.4 Active Fire Protection

a. Inspection Scope

Fire Detection and Suppression For the selected fire areas, the team evaluated the adequacy of fire suppression and detection systems. The team reviewed the material condition, operational configuration, and design of the installed fire detection and suppression systems and compared it to licensing basis documentation and deviations from NRC regulations to verify that fire suppression and detection systems met license commitments. The team verified that the licensee had installed, tested, and maintained the automatic and manual suppression and detection systems in accordance with the National Fire Protection Association codes of record.

The team performed a walk down of accessible portions of the fire 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) to assess the material condition of these systems and components. The team reviewed the fire pump 0-1 and 0-2 flow and pressure tests to verify that the pumps met their design requirements.

Fire Brigade

The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if licensee had provided sufficient information to fire brigade members and plant operators to identify post-fire 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 9, 2009, 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 Fire Area TB-10, Fire Zone 24-A, F Bus 4 kV Switchgear Room, located in the Turbine 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. The team evaluated the following specific attributes:

(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 taken 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 No findings of significance were identified.

.5 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 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 post-fire 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 of significance were identified.

.6 Alternative Shutdown Capability

a. Inspection Scope

Review of Methodology

The team reviewed the post-fire safe shutdown analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and other supporting documents. The team reviewed these documents to determine whether 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 remained consistent with the description contained in the post-fire 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 post-fire safe 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.

Review of Operational Implementation The team verified that the licensed and non-licensed operators received training on alternative shutdown procedures. The team also verified that sufficient personnel to perform post-fire safe shutdown actions are trained and available onsite at all times, exclusive of those assigned as fire brigade members.

The team performed a timed walkthrough of the post-fire safe shutdown procedure with licensed and non-licensed operators to determine the adequacy of the procedure and to evaluate their ability to implement the procedure. The team evaluated whether the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time-critical actions were verified including restoring electrical power, establishing control at the remote shutdown and local shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.

The team reviewed the time-critical manual actions identified by the licensee needed to support alternate shutdown from outside the control room, including calculation M-944, "10 CFR 50 Appendix R Alternate Shutdown Methodology - Time and Manpower Study/Safe Shutdown System Considerations," Revision 4, that provided the bases for these critical times. The review compared the simulated completion times recorded during the procedure walk through to the analytical values to verify that the operators could implement the procedure as intended.

The team also reviewed the operability and periodic testing of the alternative shutdown transfer capability, instrumentation, and control functions. The team selected a centrifugal charging pump circuit for in-depth review of the isolation capability from outside the control room. This review included circuit review, isolation device coordination and functionality, and reviews of surveillance tests demonstrating the isolation capability of the control circuits to verify that the tests are adequate to demonstrate the functionality of the alternative shutdown capability.

b. Findings

No findings of significance were identified.

.7 Circuit Analysis

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

.8 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 remained 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 engineering personnel.

The team reviewed the adequacy of the communication system to support plant personnel in the performance of alternative post-fire safe shutdown functions and fire brigade duties. The review verified that the licensee established and maintained in working order primary and backup communications and that communication equipment necessary for alternate safe shutdown support was properly categorized in the corrective action program. Further, the team evaluated the environmental impacts such as ambient noise levels, coverage patterns, and clarity of reception. The team verified that the electrical power supplies and cable routing for the phone system would allow them to remain functional following a fire in the control room and other fire areas.

b. Findings

No findings of significance were identified.

.9 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 walkthrough of the alternative shutdown procedure.

The team verified that the licensee installed emergency lights with an 8-hour capacity, maintained the emergency battery-operated lights in accordance with manufacturer and industry recommendations, and tested and performed maintenance in accordance with plant procedures and industry practices. The team also reviewed the location of the emergency lights for a sample of areas to determine the adequacy of emergency lighting during control room evacuation events.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team verified that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs. Using these procedures, the team evaluated whether these components could be repaired in time to bring the plant to cold shutdown within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools, and materials needed for the repairs were available and accessible on site.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

Out-of-Service Equipment

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 post-fire 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.

Manual Actions The licensee has committed to transition to National Fire Protection Association 805, 2001 Edition, in accordance 10 CFR 50.48(c). The post-fire safe shutdown methodology includes the use of operator manual actions in place of compliance with the requirements of 10 CFR Part 50, Appendix R, Section III.G.2.Section III.G.2 establishes a combination of physical barriers, spatial separation, fire detection and automatic suppression systems to protect redundant trains of post-fire safe shutdown equipment located within the same fire area. The licensee implemented operator manual actions because of their failure to comply with the requirements described in Section III.G.2 (This is discussed in NRC Inspection Report 05000275/2006009; 05000373/2006009). During the period of reanalysis and transition to a fire protection program based on National Fire Protection Association 805, manual actions may be acceptable as compensatory measures if they are feasible and reliable.

The team reviewed the licensee's treatment of operator manual actions as compensatory measures because of their commitment to adopt National Fire Protection Association (NFPA) 805. These manual actions were to remain in effect as compensatory measures until the issue was resolved and compliance restored or until they have been evaluated acceptable as part of the NFPA 805 transition.

b. Findings

See Section 1R05.02 of this report for a finding associated with compensatory actions.

No other findings of significance 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 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.

b. Findings

No findings of significance were identified.

4OA6 Meetings

Exit Meeting Summary

The team presented the inspection results to Mr. James R. Becker, Site Vice President, and other members of the licensee staff at an exit meeting on July 23, 2009. The licensee acknowledged the findings presented. The team confirmed that they returned all proprietary information reviewed during this inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Bailey, Supervisor, Engineering

S. Baker, NFPA 805 Project Manager

J. Becker, Site Vice President

T. Bennett, Manager, Outage Scheduling

T. Chitwood, Shift Manager, Operations

G. Corsiglia, Lighting Systems Engineer

F. dePeralta-Meister, Fire Protection Consultant

S. Dunlap, Supervisor, Engineering

S. Ellis, Fire Captain

J. Fields, Auditor, Quality Assurance

M. Ginn, Manager, Emergency Planning

J. Gregerson, Fire Protection Consultant

W. Guldemond, Director, Site Services

D. Hampshire, Superintendent, Fire Protection

C. Harbor, Maintenance Director

S. Hamilton, Supervisor, Regulatory Services

J. Haynes, Supervisor, Operations

D. Hromyak, Fire Protection System Engineer

P. Johnson, Supervisor, Electrical Design Engineering

K. Johnston, Performance Manager, Operations

S. Ketelsen, Manager, Regulatory Services

T. King, Director, Outage Management

M. McCoy, Engineer, Regulatory Services

C. Paris, Fire Chief

L. Parker, Acting Manager, Regulatory Services

D. Peterson, Director, Quality Verification

K. Peters, Station Director

D. Powell, Systems Engineer

M. Sharp, Supervisor, Balance of Plant Engineering

H. Singh, Senior Engineer, Electrical Design Engineering

B. Waggener, Fire Protection Engineer

S. Westcolt, Director, Engineering

M. Wright, Manager, Mechanical Engineering

NRC Personnel

M. Peck, Senior Resident Inspector

T. Brown, Resident Inspector

Attachment ITEMS OPENED AND CLOSED

Opened and Closed

05000275/2009008-01 NCV Safe Shutdown Procedure Not Consistent With Safe Shutdown Analysis (1R05.02)