IR 05000348/2018011: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
(12 intermediate revisions by the same user not shown)
Line 1: Line 1:
{{Adams
{{Adams
| number = ML18094A782
| number = ML18256A251
| issue date = 04/03/2018
| issue date = 09/11/2018
| title = Joseph M. Farley Nuclear Plant - Notification of Conduct of a Triennial Fire Protection Baseline Inspection - U.S. Nuclear Regulatory Commission Inspection Report Nos. 05000348/2018011 and 05000364/2018011
| title = NRC Triennial Fire Protection Inspection (Team) Report 05000348/2018011 and 05000364/2018011
| author name = Shaeffer S M
| author name = Shaeffer S
| author affiliation = NRC/NRR
| author affiliation = NRC/RGN-II/DRS/EB2
| addressee name = Madison D
| addressee name = Madison D
| addressee affiliation = Southern Nuclear Operating Co, Inc
| addressee affiliation = Southern Nuclear Operating Co, Inc
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = IR 2018011
| document report number = IR 2018011
| document type = Inspection Plan, Letter
| document type = Inspection Report, Letter
| page count = 12
| page count = 15
}}
}}


Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 4, 2018  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ber 11, 2018


Mr. Dennis Madison Site Vice President
==SUBJECT:==
 
JOSEPH M. FARLEY NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION (TEAM) REPORT NOS. 05000348/2018011 AND 05000364/2018011
Southern Nuclear Operating Company, Inc.
 
Joseph M. Farley Nuclear Plant P.O. Drawer 470, BIN B500 Ashford, AL 36312
 
SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT - NOTIFICATION OF CONDUCT OF A TRIENNIAL FIRE PROTECTION BASELINE INSPECTION - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NOS. 05000348/2018011 AND 05000364/2018011


==Dear Mr. Madison:==
==Dear Mr. Madison:==
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC) staff will conduct a triennial fire protection baseline inspection at your Joseph M. Farley Nuclear Plant, Units 1 and 2, in July 2018. The inspection will be conducted in accordance with IP 71111.05XT, dated January 31, 2013, the NRC's baseline fire protection inspection procedure for plants that have transitioned their fire protec tion program to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c). The inspection team will be led by Mr. William Monk, a Reactor Inspector from the NRC Region II Office. The team will be composed of personnel from the Region II Office.
On August 2, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Farley Nuclear Plant, Units 1 and 2, and the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this NFPA 805 Triennial Fire Protection Inspection (TFPI) are documented in the enclosed report.
 
On April 3, 2018, during communications between Mr. Gene Surber and Mrs. Mandy Ludlam of your staff and Mr. Monk, our respective staffs confirmed arrangements for a three-day information gathering onsite visit and a two-week onsite fire protection inspection. The schedule for the inspection is as follows:
 
* Information gathering visit: June 5-7, 2018
* Week 1 of onsite inspection: July 16-20, 2018
* Week 2 of onsite inspection: July 30-August 3, 2018 The purposes of the information gathering visit are to obtain information and documentation needed to support the inspection, to become familiar with the Farley Nuclear Plant's fire protection program, fire protection features, post-fire safe shutdown capabilities, plant layout, mitigating strategies to address 10 CFR 50.54(hh)(2), and, as necessary, obtain plant specific site access training and badging for unescorted site access. The types of documents the team will be reviewing during conduct of the inspection are listed in Enclosures 1 and 2. Please contact Mr. Monk at (404) 997-4579 prior to preparing copies of the materials listed in the Enclosures. The inspection team will try to minimize your administrative burden by specifically identifying those documents required for inspection preparation.
 
During the information gathering visit, the team will also discuss the following inspection support administrative details: office space; specific documents to be made available to the team in their office space; arrangements for unescorted site access (including, as necessary, radiation protection training, security, safety and fitness for duty requirements); and the availability of knowledgeable plant engineering and licensing organization personnel to serve as points of contact during the inspection.
 
We request that during the onsite inspection weeks you ensure that copies of analyses, evaluations or documentation regarding the implementation and maintenance of the Farley fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for their review. Of specific interest for the fire protection portion of the inspection are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance (i.e. fire protection compliance assessment documents). For the 10 CFR 50.54(hh)(2) portion of the inspection, those documents implementing your mitigating strategies and demonstrating the management of your commitments for the strategies are of specific interest. Also, personnel should be available at the site during the inspection who are knowledgeable regarding those plant systems required to achieve and maintain safe shutdown conditions from inside and outside the control room (including the electrical aspects of the relevant post-fire safe shutdown analyses), reactor plant fire protection systems and features, and the Farley fire protection program and its implementation.
 
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, under control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Offi ce of Management and Budget control number.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Your cooperation and support during this inspection will be appreciated. If you have questions concerning this inspection, or the inspection team's information or logistical needs, please contact Mr. Monk, the team leader, in the Region II Office at (404) 997-4579, or me at (404) 997-4521.
 
Sincerely,/RA/ Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety
 
Docket Nos.: 50-348; 50-364
 
License Nos.: NPF-2, NPF-8
 
===Enclosures:===
1. Triennial Fire Protection Inspection Supporting Documentation 2. Mitigating Strategies Supporting Documentation
 
cc: Distribution via ListServ
 
___ ML __ ____ __ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS SIGNATURE WRM1 SMS NAME MONK SHAEFFER DATE 4/3/2018 4/3/2018 E-MAIL COPY? YES NO YES NO YES N YES NO YES NO YES NO YES NO Enclosure 1 Triennial Fire Protection Inspection Supporting Documentation The documents and information requested below should generally be made available to the inspection team during the on-site information gathering visit for the team's use both on-site and off-site during the inspection. Electronic format is the preferred media, except where specifically noted. If electronic media is made available via an internet based remote document management system, then the remote document access must allow inspectors to download, save, and print the documents in the NRC's regional office. Electronic media on compact disc or paper records (hard copy) are acceptable. At the end of the inspection, the documents in the team's possession will not be retained.
 
Approximately three weeks before the on-site information gathering visit, the following documents should be made available to the team leader for review in the regional office:
 
* Post-fire Nuclear Safety Capability, Systems, and Separation Analysis (request A.1)
* Fire Hazards Analysis and/or NFPA 805 Design Basis Document (request A.2)
* Fire Probabilistic Risk Assessment (PRA) Summary Document or full PRA Document (request A.3)
* NFPA 805 Transition Report, developed in accordance with NEI 04-02 (request A.4)
* Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3) (request A.5)
* Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4) (request A.6)
* Analysis that demonstrates nuclear safe ty performance criteria can be achieved and maintained for those areas that require recovery actions (request A.7)
* List of the top 25 highest CDF scenarios for each unit
* List of the top 25 highest LERF scenarios for each unit
* Status of committed modifications and implementation items listed in Attachment S of the NFPA 805 Transition Report Based on review of the above ten documents, the team leader should identify a preliminary list of fire areas being considered for inspection prior to the on-site information gathering visit.
 
During the information gathering visit, or shortly thereafter, the fire areas selected for inspection will be determined.
 
This document request is based on typical documents that a generic plant might have. As such, this generic document request is not meant to imply that any specific plant is required to have all of the listed documents. It is recognized that some documents listed below may not be available for your plant. In addition, the document titles listed below are based on typical industry document names; your plant specific document titles may vary.
 
2 A. DESIGN AND LICENSING BASIS DOCUMENTS A.1 Post-fire Nuclear Safety Capability, Systems, and Separation Analysis.
 
A.2 Fire Hazards Analysis and/or NFPA 805 Design Basis Document.
 
A.3 Fire PRA Summary Document or full PRA Document (if summary document not available).
 
A.4 NFPA 805 Transition Report, developed in accordance with NEI 04-02.
 
A.5 Fire Risk Evaluations (i.e., NFPA 805 Section 2.4.3).
 
A.6 Plant Change Evaluations (i.e., NFPA 805 Section 2.4.4).
 
A.7 Analysis that demonstrates nuclear sa fety performance criteria can be achieved and maintained for those areas that require recovery actions.
 
A.8 Fire Protection Program and/or Fire Protection Plan.
 
A.9 LIST of post-fire safe shutdown components (i.e., safe shutdown equipment list).
 
A.10 Fire Protection System Design Basis Document.
 
A.11 LIST of applicable NFPA codes and standards and issuance dates (i.e., codes of record). A.12 LIST of deviations from (a) NFPA codes of record, or (b) NFPA 805 fundamental fire protection program and design elements (i.e., NFPA 805, Chapter 3).
 
A.13 NFPA Compliance Review Report.
 
A.14 Report or evaluation that compares the fire protection program to the NRC Branch Technical Position (BTP) 9.5-1 Appendix A.
 
A.15 COPY of licensee submittals and NRC safety evaluation reports that are specifically listed in the facility operating license for the approved fire protection program.
 
A.16 COPY of NRC Safety Evaluation Reports that form the licensing basis for:
* Fire Protection Program; and
* Post-fire Nuclear Safety Capability.
 
A.17 COPY of NRC approved exemptions for plant fire protection and post-fire nuclear safety capability features.
 
A.18 COPY of exemption requests submitted but not yet approved for plant fire protection and post-fire nuclear safety capability features.
 
A.19 LIST of nuclear safety capability design changes completed in the last three years (including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations).
 
A.20 Facility Operating License.
 
3 A.21 Technical Specifications (electronic format only).
 
A.22 Technical Requirements Manual (electronic format only).
 
A.23 Updated Final Safety Analysis Report - UFSAR (electronic format only).
 
B. GENERAL PLANT DESIGN DOCUMENTS B.1 Piping and instrumentation diagrams (P&IDs) and legend list for systems used to achieve and maintain nuclear safety performance criteria for: (C-size paper drawings
& electronic format):
* Fires outside the main control room; and
* Fires in areas requiring recovery actions at other than primary control stations.
 
B.2 P&IDs and legend list for fire protection systems, including fire water supply, water suppression sprinklers & deluge, and CO2 and Halon systems (C-size paper drawings & electronic format).
 
B.3 Yard layout drawings for underground fire protection buried piping (C-size paper drawings & electronic format).
 
B.4 AC and DC electrical system single line di agrams, from off-site power down to the highest safety-related bus level (typically 4kV, EDG bus) (C-size paper drawings &
electronic format).
 
B.5 Single line diagrams for motor control centers (MCCs) that supply post-fire nuclear safety component loads (only for selected fire areas) (C-size paper drawings & electronic format).
 
B.6 Equipment location drawings which identify the physical plant locations of post-fire nuclear safety capability equipment (electronic format).
 
B.7 Plant layout drawings which identify: (electronic format):
* Plant fire area boundaries;
* Combustible control zone drawings;
* Areas protected by automatic fire suppression and detection; and
* Locations of fire protection equipment.
 
C. CLASSIC FIRE PROTECTION DOCUMENTS C.1 COPY of fire protection program implementing procedures (e.g., administrative controls, surveillance testing, and fire brigade).
 
C.2 LIST of calculations and engineering analyses, studies, or evaluations for the fire protection system, including the fire water system.
 
C.3 Hydraulic calculation or analysis for fire protection water system.
 
C.4 Last two completed surveillance's of fire protection features in the selected fire areas (detection, suppression, damper inspections, damper tests, penetration inspections, barrier inspections, etc.).
 
4 C.5 LIST of routine tests, surveillances, and preventive maintenance on fire pumps, including pump controllers and batteries.
 
C.6 Last two completed annual fire pump pressure and flow tests.
 
C.7 Last two completed monthly and/or quarterly fire pump tests.
 
C.8 Last two completed fire loop flow tests and loop flushes.
 
C.9 CO2 and Halon initial discharge testing or calculation that determined appropriate concentrations and soak or hold times can be achieved (only for selected fire areas).
 
C.10 Last five hot work permits (at power).
 
C.11 Last five transient combustible permits (at power).
 
C.12 For Fire Brigade Drills, provide the following:
* Last five fire brigade drill critiques;
* Last drill critique for a drill with off-site fire department support;
* Last unannounced drill critique;
* Last back-shift drill critique;
* Dates, shifts, and locations of unannounced drills for last three years;
* Summary of any unsatisfactory drill performance items for last three years; and
* Last unannounced drill critique by a qualified individual independent of the licensee's staff.
 
C.13 For fire brigade equipment provide the following:
* Procedure for inventory and inspection;
* Most recent inspection and inventory results.
 
C.14 Fire Brigade Qualifications, including self-contained breathing apparatus (SCBA) and training lesson plans.
 
C.15 COPY of the mutual aid agreement for the "first-due" local fire department that is currently in effect.
 
C.16 COPY of the evaluation or analysis of the effects of fire suppression activities on the ability to achieve the nuclear safety performance criteria (only for selected fire areas),
including:
* An automatic or manually actuated suppression system, due to a fire in a single location, will not indirectly cause damage to the success path; and
* inadvertent actuation or rupture of a suppression system will not indirectly cause damage to the success path; and
* demonstration of adequate drainage for areas protected by water suppression systems; * hydrostatic rating of any floor penetration seals installed within the fire areas that are credited with keeping water from leaking into fire areas below.
 
C.17 Pre-fire plans for all fire areas.
 
5 C.18 For Emergency Lighting Units (ELU), provide the following:
* COPY of performance based emergency lighting assessments;
* LIST of Preventive Maintenance tasks, frequencies, and bases;
* Most recently performed monthly or quarterly functional test;
* Most recently performed battery discharge performance test;
* ELU battery loading analysis;
* Vendor manual(s) for on-site inspector use;
* Results of black-out testing (if performed);
* Maintenance Rule program information related to the ELU; and
* Compensatory measures taken when ELU are out of service.
 
C.19 Impairment Log (at start of inspection), for fire protection features that are out of service. C.20 Three Fire Protection screening reviews for recent design changes, modifications, or temporary modifications (i.e., an NFPA 805 plant change evaluation that screened out). C.21 LIST of penetration seal work, re-work, or installation activities, in the last three years.
 
C.22 LIST of fire wrap work, re-work, or installation activities, in the last three years.
 
C.23 Fire protection system health reports for the two most recent quarters.
 
C.24 Fire protection program health report for the two most recent quarters.
 
C.25 Emergency lighting system health reports for the two most recent quarters.
 
C.26 LIST of fire protection system design changes completed in the last three years (including their associated 10 CFR 50.59 and NFPA 805 plant change evaluations).
 
C.27 LIST of fire protection system NFPA 805 engineering equivalency evaluations completed in the last three years.
 
C.28 Licensee evaluation of industry operating experience, such as:
(specific items to be selected by the inspector)
* NRC IN 2005-03, Inadequate Design and Installation of Seismic-Gap Fire Barriers;
* NRC IN 2006-22, Ultra-Low Sulfur Diesel Fuel Oil Usage, for diesel fire pump;
* NRC IN 2009-02, Bio-Diesel Fuel Oil Usage, for diesel fire pump; and
* NRC IN 2009-29, Fire Pumps Fail to Start due to a Fire.
 
C.29 COPY of any test, surveillance, or maintenance procedure (current revision), including any associated data forms, for any requested "last performed" test, surveillance, or maintenance.
 
D. ELECTRICAL DOCUMENTS D.1 Identify whether the cables in the selected fire areas are predominantly Thermoset or Thermoplastic. Specifically identify any Thermoplastic cable in the selected fire
 
areas.
 
6 D.2 Nuclear safety circuit coordination analysis for fuse and breaker coordination of nuclear safety capability components.
 
D.3 Administrative or configuration control procedures that govern fuse replacement (e.g., fuse control procedures).
 
D.4 Maintenance procedures that verify breaker over-current trip settings to ensure coordination remains functional, for post-fire nuclear safety capability components.
 
D.5 Electrical system health reports for the two most recent quarters.
 
D.6 Last surveillance demonstrating operability of those components operated from the primary control stations.
 
D.7 LIST of post-fire nuclear safety capability system and component design changes completed, in the last three years.
 
D.8 LIST of identified fire induced circuit failure configurations (only for selected fire areas). E. OPERATIONS DOCUMENTS E.1 LIST of calculations and engineering analyses, studies, or evaluations for the nuclear safety capability methodology.


E.2 LIST of licensed operator Job Performance Measures (JPMs) for operator actions required to achieve and maintain post-fire nuclear safety performance criteria.
NRC inspectors documented one finding of very low safety significance (Green) in this report.


E.3 LIST of non-licensed operator training associated with non-licensed operator actions to achieve and maintain post-fire nuclear safety performance criteria (including JPMs, in-field training walkdowns, simulations, or initial qualification).
This finding involved a violation of NRC requirements. The NRC is treating the violation as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRCs Enforcement Policy.


E.4 Lesson plans for post-fire nuclear safety capability training for licensed and non-licensed operators.
If you contest this violation or significance of this NCV, 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 II; the Director, Office of Enforcement; and the NRC Resident Inspector at the Farley Nuclear Plant. 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.


E.5 For recovery actions and defense-in-depth actions, provide the following:
Sincerely,
* Manual Action Feasibility Study;
/RA/
* Operator Time Critical Action Program;
Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8
* Time lines for time-critical recovery actions; and
* Time line validations.


E.6 If applicable, thermal hydraulic calculation or analysis that determines the time requirements for recovery actions and defense-in-depth actions.
===Enclosure:===
Inspection Report 05000348/2018011 and 05000364/2018011


E.7 Operating procedures to achieve and maintain nuclear safety performance criteria from the control room, with a postulated fire in the selected fire areas.
==Inspection Report==
Docket Number(s): 50-348, 50-364 License Number(s): NPF-2, NPF-8 Report Number(s): 05000348/2018011 and 05000364/2018011 Enterprise Identifier: I-2018-011-0022 Licensee: Southern Nuclear Operating Company, Inc. (SNC)
Facility: Joseph M. Farley Nuclear Plant, Units 1 and 2 Location: Ashford, AL 36312 Inspection Dates: Week 1 of onsite inspection: July 16 - 20, 2018 Week 2 of onsite inspection: July 30 - August 2, 2018 Inspectors: J. Dymek, Reactor Inspector L. Jones, Senior Reactor Inspector W. Monk, Reactor Inspector (Team Leader)
N. Staples, Senior Reactor Inspector Accompanying Personnel: T. Sippel, Fuel Facility Inspector (Training, Week 1 Only)
Approved By: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety (DRS)
1  Enclosure


E.8 Operating procedures to achieve and maintain nuclear safety performance criteria from outside the control room, with a postulated fire in the control room, cable spreading room, or any area requiring recovery actions (other than recovery actions performed in the control room or primary control stations).
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Southern Nuclear


7 E.9 For safe shutdown equipment and tools, provide the following:  
Companys performance by conducting an announced team TFPI at the Farley Nuclear Plant,
* Procedure for inventory and inspection; and
Units 1 and 2, in accordance with the NRC Reactor Oversight Process. The Reactor Oversight Process (ROP) is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified findings and violations are summarized in the table below.
* Most recent inspection and inventory results.


E.10 LIST of procedures that implement Cold Shutdown Repairs.
List of Findings and Violations Failure to ensure fire barrier penetrations (including fire dampers) in fire zones protecting safety-related areas shall be functional in accordance with NFPA 805 Section 3.11.3, Fire Barrier Penetrations Cornerstone            Significance                                Cross-Cutting Report Aspect            Section Mitigating            Green                                        H.8, Procedure 71111.05XT Systems                NCV 05000348-364/2018011-01                  Adherence        - 02.02b Closed The NRC identified a Green finding and associated non-cited violation (NCV) of the Farleys Renewed Operating License Condition 2.C.(4) - Fire Protection for U1 and 2.C.(6) - Fire Protection for U2. This finding was identified for failure to maintain all provisions of the approved FPP, as described in NFPA 805, 2001 Edition to ensure that all fire barrier penetrations (including fire dampers) in fire zones protecting safety-related areas shall be functional. The functional failure of the two fire dampers in the A and B SWIS Battery Rooms was a performance deficiency and determined to be more-than-minor because it affected the Reactor Safety Mitigating Systems cornerstone attribute of protection against external factors, a fire, and it affected the fire protection Defense in Depth (DID) strategies involving the confinement of fires and to protect systems important to safety. Additionally, if left uncorrected, the issue could potentially lead to a more significant safety concern during fire events.


E.11 For Cold Shutdown Repairs, provide the following:
=INSPECTION SCOPES=
* Procedure for inventory and inspection (i.e., needed tools, material, etc.); and
* Most recent inspection and inventory results.


E.12 For Radio communications, provide the following:  
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The team reviewed the selected procedures and records, observed activities, and interviewed plant personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and industry standards.
* Communications Plan for firefighting and post-fire recovery actions and DID actions; * Repeater locations;
* Cable routing for repeater power supply cables;
* Radio coverage test results; and  
* Radio Dead Spot locations in the plant.


E.13 Environmental and habitability evaluations for post-fire recovery actions and defense-
==REACTOR SAFETY==
in-depth actions (temperature, smoke, humidity, SCBAs, etc.).
F. ADMINISTRATIVE CONTROL, OVERSIGHT, AND CORRECTIVE ACTION PROGRAMS F.1 Corrective actions for fire-induced circui t failures (including but not limited to NRC IN 92-18), both single and multiple spurious actuations (only for selected fire areas).


F.2 Corrective actions associated with operator actions to achieve and maintain post-fire nuclear safety performance criteria.
===71111.05XT - NPFA 805 Fire Protection (Triennial)
The team evaluated applicable fire protection licensing commitments from July 16, 2018 to August 2, 2018 by review of the following:
Fire Protection Inspection Requirements ===
{{IP sample|IP=IP 71111.05|count=3}}
The team evaluated fire protection program implementation in the following selected areas:
1) FA 1-041, Train A SWGR and Load Center Rooms                  (Performance Based Area)2) FA 076, SWIS 5KV SWGR A and East Stairs                        (Performance Based Area)3) FA 1-018, Aux Building DC SWGR                                (Performance Based Area)


F.3 Self assessments, peer assessments, and audits of fire protection activities for the last three years.
===B.5.b Inspection Activities (1 Sample)===
The team evaluated the feasibility of the following B.5.b Mitigating Strategies:
1) The team reviewed the strategy for manual operation of the Turbine Driven AFW (TDAFW) Pump strategy


F.4 Self assessments, peer assessments, and audits of post-fire nuclear safety capability methodology for the last three years.
==OTHER ACTIVITIES - BASELINE==
INSPECTION RESULTS Cornerstone            Significance                              Cross-cutting      Report Aspect            Section Mitigating            Green Finding                            H.8, Procedure    71111.05XT-Systems                50-348, 50-364/2018011-01                Adherence          02.02b Closed The NRC identified a Green finding and associated non-cited violation (NCV) of the licensees Fire Protection Program (FPP) and NPFA 805, Section 3.11.3, Fire Barrier Penetrations, for the licensees failure to ensure functional fire dampers, 1-188-332-01 and 1-188-332-02 in the A and B SWIS Battery Rooms.


F.5 LIST of open and closed condition reports for the fire protection system for the last three years.
=====Description:=====
Fire Dampers 1-188-332-01 and 1-188-332-02 in the A and B SWIS Battery Rooms were improperly installed per their design drawing U164049 and the B train Battery Room fire damper failed to shut when conducting a surveillance drop test on 7/20/2018. Specially, the angle clip bracket was not installed with the 90 degree leg pointed away from the damper skirt, which caused the damper skirt to not drop and seal off the barrier penetrations between the battery rooms (Deterministic fire areas) and SWIS Switchgear Rooms (Performance-Based fire areas).


F.6 LIST of fire event analysis reports for the last three years.
Additionally, according to drawing U164049, DAF-P-5990 Fire Damper with Optional SRD (Smoke Release Device), Note 1 states: Although construction is per these drawings, the damper will not be UL Label if equipped with the SRD. In the case of Fire Dampers 1-188-332-01 and 1-188-332-02, all four 1 1/2 hour rated curtain-type fire dampers were equipped with SRDs and fusible links, not electro-thermal links (ETLs). SRDs are not UL listed/labeled, but ETLs are UL listed/labeled. The referenced electrical elementary design drawings reflected use of ETLs, not SRDs.


F.7 LIST of open and closed condition reports for ELUs for the last three years.
The improper fire damper installations and damper functional failure did not meet the licensees Fire Protection Program (FPP) nor NPFA 805 Section 3.11.3, Fire Barrier Penetrations, which states passive fire protection devices such as dampers shall conform with the following NFPA standard, NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems. NFPA 90A, Code of Record 1973 states in section 905, Construction of Fire Dampers, Approved fire dampers shall have the following performance characteristics:
a) They shall be arranged to close automatically in event of abnormal high temperature.


F.8 LIST of open and closed condition reports for post-fire nuclear safety capability issues for the last three years. This includes issues affecting the NSCA, fire hazards analysis, NFPA 805 design basis, fire risk evaluations, plant change evaluations, post-fire operating procedures and/or training, timeline evaluations for operator actions, and supporting engineering evaluations, analysis, or calculations.
b) They shall provide the maximum practical barrier to passage of air when in the closed position.


F.9 LIST of procedures that control the configuration of the fire protection program, features, and post-fire nuclear safety capability methodology and system design.
Corrective Action(s): In response to the inspection discovery, the licensee promptly initiated condition reports to resolve the equipment deficiencies and conducted an extent of condition review throughout the plant.


F.10 Site procedure governing the NFPA 805 Monitoring Program.
Corrective Action Reference(s): This issue is being tracked in the licensees corrective action program (CAP) by condition reports:
* CR 10516723, NRC Inspector Identified Damper 1-188-332-02 Was Not Installed Correctly, 7/18/2018
* CR 10517136, Incorrect Fire Damper Installation - EOC, 7/19/2018
* CR 10517257, Damper Inspection Request for EOC, 7/20/2018
* CR 10517472, SWIS Battery Room B Fire Damper Failed Drop Test, 7/20/2018
* CR 10520516, 2018 NRC TFPI - Non-UL Listed Fire Damper, 7/30/2018


Enclosure 2 Mitigating Strategies Supporting Documentation G. 10 CFR 50.54(hh)(2) MITIGATING STRATEGIES DOCUMENTS G.1 LIST of all changes to regulatory commitments made to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2).
=====Performance Assessment:=====
Performance Deficiency: The licensees failure to ensure the fire dampers were functional, as required by the approved Fire Protection Program and NPFA 805 was determined to be a performance deficiency (PD).


G.2 LIST of procedures and guidelines that were revised or generated to implement the mitigating strategies. These could be extensive damage mitigation guidelines (EDMGs), severe accident management guidelines (SAMGs), emergency operating procedures (EOPs), abnormal operating procedures (AOPs), etc.
Screening: This performance deficiency was determined to be more-than-minor because it affected the Reactor Safety Mitigating Systems cornerstone attribute of protection against external factors, a fire, and it affected the fire protection DID strategies involving the confinement of fires and to protect systems important to safety. Specifically, the failure to ensure functional fire dampers could affect the fire protection DID strategy involving the confinement of fires because it could allow smoke and heat to migrate beyond the room and affect adjacent fire areas (FAs). Additionally, if left uncorrected, the issue could potentially lead to a more significant fire propagation safety concern.


G.3 A matrix that shows the correlation between the mitigation strategies identified in Nuclear Energy Institute 06-12, Revision 2, "B.5.b Phase 2 & 3 Submittal Guideline," issued December 2006, and the site-specific procedures or guidelines that are used to implement each strategy.
Significance: The team assessed the finding using NRC Inspection Manual Chapter 0609, Significance Determination Process (SDP), Attachment 4, Initial Characterization of Findings, and determined the Mitigating Systems cornerstone was impacted and that a IMC 0609, Appendix F, Fire Protection SDP review was required as the finding involved the ability to confine a fire. The team further assessed the finding using NRC Inspection Manual Chapter 0609, Appendix F, Attachment 1, Fire Protection SDP Worksheet, and determined the finding to be of very low safety significance (Green) based upon Step 1.4.4, Question E, based upon if a fire were to spread from one fire area to another due to the degraded fire barriers, no additional targets would be damaged in the fire areas that could impact the credited safe shutdown strategy.


G.4 LIST of engineering evaluations or calculations that were used to verify the engineering bases for the mitigating strategies.
Cross-Cutting Aspect: The team assessed the issue for cross-cutting aspects using IMC 0310, Aspects Within Cross Cutting Areas, and concluded this deficiency was indicative of current licensee performance because the fire dampers were last inspected in September 2017. Per IMC 0310, a cross cutting aspect of H.8, Procedure Adherence was assigned to this finding because individuals performing the fire damper surveillances did not fully follow the surveillances procedures and work instructions. Specially, the fire damper surveillance inspection procedure states under the Acceptance Criteria section, No damage or missing hardware exists on the damper as determined by a visual inspection and the wires and links are properly attached.


G.5 Piping and instrumentation diagrams (P&ID) and legend list or simplified flow diagrams for systems relied upon in the mitigating strategies. These could be the type used for training (C-size paper drawings).
=====Enforcement:=====
NPFA 805 Section 3.11.3, Fire Barrier Penetrations, required passive fire protection devices such as dampers shall conform with the following NFPA standard, NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems. NFPA 90A, Code of Record 1973, Section 905, Construction of Fire Dampers, required that approved fire dampers shall have the following performance characteristics:
a) They shall be arranged to close automatically in event of abnormal high temperature.


G.6 LIST of modification packages or summary descriptions of modifications with simplified drawings, for necessary facility changes to implement the mitigating
b) They shall provide the maximum practical barrier to passage of air when in the closed position.


strategies.
Contrary to the above, since the plants commercial operational date until July 2018, the licensee failed to ensure that fire dampers 1-188-332-01 and 1-888-332-02 were functional and that they met the requirements of NFPA 90A, to functionally shut during the conditions of a fire.


G.7 LIST of routine tests, surveillances, and preventive maintenance for equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies.
Disposition: This violation is being treated as an NCV consistent with Section 2.3.2a of the NRC Enforcement Policy.


G.8 For equipment and tools needed to implement 10 CFR 50.54(hh)(2) strategies, provide the following:
==EXIT MEETINGS AND DEBRIEFS==
* Procedures for inventory and inspection; and  
The team verified no proprietary nor safeguards information was retained or documented in this report. Additionally, the team confirmed that proprietary and safeguards information was controlled to protect from public disclosure. On August 2, 2018, the lead inspector and team presented the NFPA 805 TFPI results to the Site Vice President, Mr. Dennis Madison, and other members of the Farley Nuclear Plant staff.
* Most recent inspection and inventory results.


G.9 LIST of 10 CFR 50.54(hh)(2) strategies, if any, which have implementing details that differ from that documented in the submittals or the safety evaluation report.
THIRD PARTY REVIEWS The team did not perform any reviews of the Institute of Nuclear Power Operations (INPO)reports nor any other third party documents during the inspection period.


G.10 Site general arrangement drawings that show the majority of buildings and areas referenced in 10 CFR 50.54(hh)(2) documents (C-size paper drawings).
KEY POINTS OF CONTACT Licensee Personnel Gene Surber, Licensing Supervisor Mandy Ludlam, Licensing Engineer Hilliard Cooper, Fire Protection Manager Meredith Smith, Fire Protection Program Engineer Kim Wilson, Fire Protection Engineer Robert Chandler, Site Fire Marshall NRC Personnel P. Niebaum, Senior Resident Inspector K. Miller, Resident Inspector S. Shaeffer, Chief, Engineering Branch 2, DRS, Region II LIST OF COMPONENTS REVIEWED Component ID          Description Q1E21P0002B          1B Charging/HHSI Pump N1E21HIK122          Charging Flow Indication Q1B31V0053            U1 A/B PORV Q1E21LCV115B          Excess Letdown Valve Q1N23HV3227B          Train B MDAFW Pump Q1P17P001B            Train B CCW Pump Q1N1PV3371B          Main Steam Atmosphere Relief Valve Q1B31V0061            Pressurizer PORV Q2R16B0006            4.16KV Switchgear Bus 2D Q1E13PT0952          Unit 2 Containment Pressure Transmitter QSR42B0523B          125VDC SWIS Battery 2 N1B31LI0461          Pressurizer Level Channel 3 N1B31LI0459Z          Pressurizer Level Indicator LI-459Z N1B21TI0410          RCS Cold Leg Temperature Indicator N1N11LI0477A          Steam Generator 1A Wide Range Level Indicator LI-477A N1N11LI0497A          Steam Generator 1C Wide Range Level Indicator LI-497A N1C55NI0031B          Source Range Count Rate Indicator NI-31B


G.11 Training records, training matrix, and lesson plans related to 10 CFR 50.54(hh)(2).
=DOCUMENTS REVIEWED=


G.12 Copies of memoranda of understanding (MOU) (e.g., with local fire departments) required to implement any mitigating strategies.
Licensing Basis, Design Basis, & Regulatory
DWG A-181805, NFPA 805 Fire Protection Program Design Basis Document, Rev. 1
Joseph M. Farley Nuclear Plant License Amendment Request to Adopt NFPA-805 Performance
Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001
Edition), 9/25/2012
Safety Evaluation Report, Joseph
: [[contact::M. Farley Nuclear Plant]], Units 1 And 2 - Issuance Of
Amendments Related To NFPA 805 Supplement (CAC Nos. MG0094, MG0095; EPID N
: [[contact::O.
L-2017-LLA-0261)]], 11/01/2017
Safety Evaluation Report, Joseph
: [[contact::M. Farley Nuclear Plant]], Units 1 And 2 - Issuance Of
Amendments Related To NFPA 805 Supplement (CAC Nos. MF7617 And MF7618),
10/17/2016
Southern Nuclear Operating Company Alabama Power Company Docket No. 50-348 Joseph
: [[contact::M.
Farley Nuclear Plant]], Unit 1 Renewed Facility Operating License No. NPF-2
Southern Nuclear Operating Company Alabama Power Company Docket No. 50-364 Joseph
: [[contact::M.
Farley Nuclear Plant]], Unit 2 Renewed Facility Operating License No. NPF-8
Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding
License Amendment Request for Transition to 10 CFR 50.48(c) NFPA 805 Performance
Based Standard for Fire Protection for Light Water Reactor Generating Plants, Attachment S -
Modifications and Implementation Items
Farley Nuclear Plant, UFSAR Chapter 9, Section 9.5.1, Fire Protection System, Rev. 26
Calculations
ARC 4.3.1, Compliance Assessment by Scenario, 6/15/2018
F-RIE-FIREPRA-U00-017, NFPA 805 Transition Risk Results for Farley, 2/16/2018
NMP-ES-035-006-F06, NFPA 805 Change Evaluation - U1/U2 FLEX Communications &
Gaitronics Upgrades, Version 2.0
Enclosure
NMP-ES-035-006-F06, NFPA 805 Change Evaluation - Main Turbine (DEH) Controls Upgrade,
Version 1.0
SE-C051326701-008, NFPA 805 Fire Risk Evaluations, Rev. 2
SE-C051326701-008, Attachment - FRE for Unit 1 Fire Area 1-018, Auxiliary Building DC
Switchgear Room, Rev. 0
SE-C051326701-010, Nuclear Safety Capability Assessment  Fire Area Compliance
Assessment, Rev. 4
SE-C051326701-011, Recovery Action Feasibility Evaluation, Rev. 0
SE-C051326701-012, NFPA 805 Defense in Depth (DID) Recovery Actions, Rev. 2
SM-C051326701-007, NFPA Code Conformance Review, Version 1.0
SM-C051326701-011, Fire Suppression Effects Analysis, Version 1.0
SM-1081426001-001, B.5.b Mitigation Strategy Flow Verification, Dated March 2012
TE-707175, Evaluation of Farley Triennial Fire Distribution System Flow Test, FNP-0-FSP-53,
11/22/2013
Procedures
FNP-0-AOP-29.0, Abnormal Operating Procedure - Plant Fire, Rev. 51.0
FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 76-100, Version 1.0
FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 51-75, Version 1.0
FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 1-25, Version 1.0
FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 26-50, Version 1.0
FNP-1-ECP-0.0, Emergency Contingency Procedure - Loss of All AC Power, Rev. 30
FNP-0-EIP-16.0, Emergency Equipment and Supplies, VERSION 72.0
FNP-0-EIP-16.0-F05, Checklist E Control Room Storage Locker, Version 1.0
FNP-0-EIP-16.0-F26, Fire Fighting Equipment (OPS) Checklist, Version 1.0
FNP-0-EIP-16.0-F40, Smoke Removal Equipment, Version 1.0
FNP-1-FPP-1.0, Unit 1 Auxiliary Building Pre-Fire Plan, Version 1.0
FNP-0-FPP-2.0, Protected Area Pre-Fire Plans, Version 1.0
FNP-0-FPP-3.0, Owner Controlled Area Pre-Fire Plan, Version 2.0
FNP-1-FPP-3.0, Unit 1 Containment Pre-Fire Plan, Version 1.0
FNP-0-FSP-201.1, No. 1 Diesel Driven Fire Pump Functionality Test, Version 21.0
FNP-0-FSP-201.3, Motor Driven Fire Pump Functionality Test, Version 12.0
FNP-0-FSP-203.2, #1 Diesel Driven Fire Pump Functional Test, Version 10.0
FNP-0-FSP-203.4, Motor Driven Fire Pump Functional Test (Pump Flow Test), Version 11.0
FNP-0-FSP-203.5, #1 Diesel Driven Fire Pump Functional Test (Pump Flow Test),
Version 14.0
FNP-0-FSP-300.0, Fire Pump Diesel Starting Battery Monthly Inspection, Version 5.1
FNP-0-FSP-301, Fire Pump Diesel Starting Battery Quarterly Inspection, Version 8.0
FNP-0-SOP-0.4, Fire Protection Operability And LCO Requirements, Rev. 104
FNP-1-AOP-28.0, Control Room Inaccessibility, Version 18, Dated April 2018
NP-1-FSP-65.0A, Fire Dampers Functional Inspection Aux. Building - Diesel Building - Service
Water Building Train A, Version 5.0
FNP-1-FSP-65.0B, Fire Dampers Functional Inspection Aux. Building - Diesel Building -
Service Water Building Train B, Version 5.0
FNP-1-SOP-58.0, Auxiliary Building HVAC System, Version 80, Dated March 2018
FNP-1-SOP-62.0, Emergency Air System, Version 26, Dated April 2015
NMP-05-007-003, Standing Order - Fire Protection LCOs Peer Check Requirement, 7/11/2018
NMP-CH-002, Chemical Control Program, Version 12.2, 5/24/18
NMP-CH-002-003, Chemical Storage Areas, Version 9.0, 6/14/18
NMP-EP-402, Plant Farley Emergency Management Guideline (EMG), VERSION 14.1
NMP-EP-402, Manual Operation of TDAFW, Att. 7, Version 14.1
Enclosure
NMP-EP-402, Temporary Instrumentation Installation, Att. 12, Version 14.1
NMP-EP-402, B.5.b Pump and Accessories, Att. 13, Version 14.1
NMP-ES-027-001, NFPA 805 Program, Version 9.0
NMP-ES-035-001, Fire Protection Program Implementation, Version 13.1
NMP-ES-035-003, Fleet Hot Work Instruction, Version 7.0
NMP-ES-035-007, Fleet Fire Watch Instruction, Version 4.1
NMP-ES-035-009, Quarterly Fire Safety Inspection, Version 4.0
NMP-ES-035-010, Fire Brigade, Version 5.0
NMP-ES-035-014, Fleet Transient Combustible Controls, Version 2.1
NMP-ES-035-GL01, Fire Protection Program Guideline, Version 3.0
NMP-OS-007-001, Conduct of Operations Standards and Expectations, Version 16.2
NMP-TR-425, Fire Drill Program, Version 8.0
NMP-TR-426, Fire Training Program, Version 5.1
Plant Modifications
DCP SNC459687, NFPA 805: U1 Cable and Raceway Fire Protection, Version 8.0
DCP SNC834134, SWIS Security Enhancements Project - NFPA 805 Change Evaluation,
Version 2.0
Miscellaneous Documents
A-181017, J. M. Farley Nuclear Plant Unit 1 / 2 Functional System Description-Fire Protection
System, Revision 43
American Warming and Ventilating, Inc., Mod. DAF-D-8403, U.L. Classified Type A Excel Fire
Damper, Revision E
Chemical Product Storage Permit, NMP-CH-002-03, Attachment 1, SWIS, 6/15/2015
Elsie Type A and Type B Fusible Link Vendor Data Sheet, 7/30/2018
EVAL-F-R45-03207, U1 R45-FO1 Emergency Lights, 4/8/2018
Farley Nuclear Plant Occurrence Report (OR) 1-98-017, Fire Damper Failed to Indicate Closed,
1/22/1998
Information Notice No. 89-52: Potential Fire Damper Operational Problems, June 8, 1989
Information Notice No. 83-69: Improperly Installed Fire Dampers at Nuclear Power Plants,
October 21, 1983
Maintenance Rule Expect Panel Meeting #18-06, 4/03/2018
Maintenance Rule Expect Panel Meeting #18-09, 6/22/2018
National Fire Protection Association (NFPA) 80, Fire Doors and Windows 1973 Code of Record
NFPA 600, Standard for Industrial Fire Brigades, 2000 Edition
NMP-ES-035-009-F01, Quarterly Fire Inspection Report Form, Q1 2018
NMP-ES-035-009-F01, Quarterly Fire Inspection Report Form, Q2 2018
RER SNC629964, RG 1.75 Marinite RER, Version 2.0
Request from Bechtel Eastern Power Company to American Warming and Ventilating Company
Entitled Evaluation of Fire Damper Installation, (SS-1102-54), March 21, 1988
S-FP-PP-10100-07.1, Fire Training / Introduction to Fire Fighting, Rev. 7.1
TE 1009817, Take to the MREP: Tracking CR per NMP-GM-027-001, 4/17/2018
Work Orders
WO SNC593970, FNP-1-FSP-307.0 - Zone 1A-32 - U1 A-Train Smoke Detector - Biennial
Operability and Adjustment, 6/10/2016
WO SNC517737, FNP-1-FSP-65.0A - A-Train Rad Waste HVAC Fire Damper Inspection,
8/5/2016
WO SNC578376, FNP-1-FSP-63.07 - Visual Inspection of Various AB Fire Barrier Penetrations,
10/29/2016
Enclosure
WO SNC719665, 1-2A Diesel Fire Roll-up Door, Rev. 1
WO SNC789081, FNP-0-FSP-201.3 - Motor Driven Fire Pump Operability Test, 11/19/2016
WO SNC806975, Addition of Fire Extinguishers for NFPA 10 Code Compliance, 3/22/2017
WO SNC822613, FNP-0-FSP-203.4 - Motor Driven Fire Pump Functional Test, 4/27/2017
WO SNC538103, Perform FNP-1-FSP-65.0A Data Sheet (A-Train) Visual Inspect, 9/22/2017
WO SNC958335, Incorrect Fire Damper Installation - EOC, 7/23/2018
Condition Reports Reviewed during inspection
CR 10043210, Fire Watch Required, 3/19/2015
CR 10509998, Equipment Check Deficiency
CR 10051606, Re-evaluate Postulated Hot Short Event, 4/07/2015
CR 10517355, Update for AOP FNP-0-EIP-16.0-F26
CR 10149000, Note Added to FNP-0-SOP-0.4, 11/19/2015
CR 10149001, 1-2A Diesel INOP MRULE MPFF, 11/19/2015
CR 10168712, NFPA 805 Potential License Condition Compliance Issue, 1/14/2016
CR 10170805, Impact Review for DCP SNC692210, 1/20/2016
CR 10172987, Risk Evaluation Needed for Three DCPs, 1/25/2016
CR 10207202, Combustibles Storage in a Level A Area Unapproved, 4/07/2016
CR 10281867, Fire PRA Qualifications NFPA 805 LAR Requirements, 10/04/2016
CR 10318639, NOS Fire Protection Identified Findings, 1/14/2017
CR 10356518, NFPA 805 Circuit Supervision Design for Dry Chemical Suppression (2A-120),
4/20/2017
CR 10431122, Fire Extinguishers, 11/15/2017
CR 10442490, NFPA 805 Implementation, 12/24/2017
CR 10445795, AOP-29 Procedure Revision, 1/04/218
CR 10448087, Unanalyzed Condition Identified During NFPA 805 Transition, 1/09/2018
CR 10454233, MRule Unavailability Hours Exceeded for Sprinkler Systems, 1/25/2018
CR 10461010, Fire Extinguisher Hydro Date, 2/12/2018
CR 10464796, Fire Extinguishers, 2/22/2018
CR 10465621, Generate WOs for Fusible Link (ETL) Replacements, 2/23/2018
CR 10466131, HSS Fire Dampers Nonfunctional Due to Expired FSP, 2/26/2018
CR 10466136, LSS Fire Dampers Non Functional, 2/26/2018
CR 10470738, FPA Database Used to Track and Manage FP LCOs in Inadequate, 3/10/2018
CR 10483183, Tracking CR per NMP-GM-027-001, 4/17/2018
CR 10489319, Breaker in Cubicle N2R17BKRFC52R Oversized for the Application, 5/03/2018
CR 10494496, NFPA 805 S-3 Item 31, 5/17/2018
CR 10497446, WOs Needed to Perform Partial FNP-1-FSP-307.0 on Multiple FP Systems,
5/25/2018
CAR 256103, Document Comp. Measures Taken, 4/23/2015
CAR 260875, Pre-Start Check on 1-2A Diesel Fire Roll-up Door, 12/11/2015
CAR 272312, 1-2A EDG Day Tank Room Fire Damper Closing Due to Failed Fusible Link,
2/14/2017
Condition Reports Written Due to this Inspection
CR 10516257, Dirt Dauber Nest in Vent Line of No. 2 Diesel Fire Pump Fuel Oil Tank,
7/17/2018
CR 10516269, Conduit Labeling Error at SWIS, 7/17/2018
CR 10516551, NMP-ES-035-GL01 Contains Directions and Instructions Not IAW NMP-AP-001,
7/18/2018
CR 10516553, Farley Fire Preplan Guidance, 7/18/2018
CR 10516573, Revise NMP-ES-035-001, Fire Protection Program Implementation, 7/18/2018
Enclosure
CR 10516702, Typo in FRE Calculation SE-C051326701-008, 7/18/2018
CR 10516723, NRC Inspector Identified Damper 1-188-332-02 Was Not Installed Correctly,
7/18/2018
CR 10516728, In-correct Version of Fire Pre-plans in Fire Brigade Ready Room, 7/18/2018
CR 10516948, EIP-16 Checklist C Found Expired Batteries, 7/19/2018
CR 10517133, FNP-0-SOP-0.4 Needs to be Clarified, 7/19/2018
CR 10517136, Incorrect Fire Damper Installation - EOC, 7/19/2018
CR 10517262, FNP-0-EIP-16 Checklist EOC Inspection, 7/20/2018
CR 10517257, Damper Inspection Request for EOC, 7/20/2018
CR 10517355, Procedure Revision Request for FNP-0-AOP-29, 7/20/2018
CR 10517472, SWIS Battery Room B Fire Damper Failed Drop Test, 7/20/2018
CR 10520516, 2018 NRC TFPI - Non-UL Listed Fire Damper, 7/30/2018
CR 10520806, Bolt Missing on Electrical Panel in MCR, 7/31/2018
CR 10520912, SSD Equipment Extension Cord Removed from Service, 7/31/2018
CR 10520916, NRC TFPI 2018 - Work Order Closed Inappropriately, 7/31/2018
CR 10521312, Issues Noted with Emergency Light PMs, 8/1/2018
CR 10521359, B.5.b Test Gauges Found Out of Calibration, 8/2/2018
CR 10521560, 2018 NRC TFPI CR - Fire Damper Technical Evaluation Needed, 8/2/2018
Drawings
A-177539, Grounding - Details and Notes, Rev. 2
D-170331,
: [[contact::J.M. Farley Nuclear Plant - Unit 1 & 2]], Outdoor Concrete-Service Water Intake
Structure, General Arrangement, Version 1.0
D-170343,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Fire Protection Piping, Pump House & Tanks
Plans & Details, Revision 10
D-177001, U1 Single Line Electrical Auxiliary System (Emergency 4160 & 600 V), Rev. 23
D-170366, Fire Protection P&ID - Yard Mains, Rev. 47
D-170366, Fire Protection P&ID - Pump House, Rev. 14
D-170366,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Fire Protection, P & ID, Pump & Engine Details,
Sheet 1, Version 1.0
D-170366,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Fire Protection, P & ID, Pump House & Yard
Mains, Version 1.0
D-170381,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Fire Protection P&ID, High Pressure Carbon
Dioxide, Sheet 1,Version 1.0, Revision 0
D-170381,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Fire Protection P&ID, High Pressure Carbon
Dioxide, Sheet 3,Version 1.0, Revision 0
D-170384, Fire Protection P&ID - Low Pressure Carbon Dioxide, Rev. 17
D-170385, Fire Protection P&ID - High Pressure Carbon Dioxide, Rev. 5
D-172099, D-170381,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Fire Protection, Thermostat
Installation-600v Switchgear, Revision 0
D-175011,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], HVAC P&ID Radwaste Area System, Aux. Bldg.
Plan at El. 121-0, Revision 0
D-175030,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], HVAC Process Flow Diagram, Non-Rad Area &
Electrical Shop Rooms, Version 1.0
D-175115,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], HVAC System, Aux. Bldg. Plan at El. 121-0,
Version 1.0
D-175048,
: [[contact::J.M. Farley Nuclear Plant - Unit 1 & 2]], Service Water Intake Structure, HVAC-P&ID,
Revision 1
D-170332,
: [[contact::J.M. Farley Nuclear Plant - Unit 1 & 2]], Mechanical-Service Water Intake Structure,
General Arrangement of Heat & Ventilation Systems- Floor Plan Section & Details, Rev. 22
D-205619, P&ID Chemical & Volume Control System, Rev. 4
Enclosure
D-350857,
: [[contact::J.M. Farley Nuclear Plant - Unit 1]], Aux. Bldg. Concrete-Penetration Seals @ El.
21-0, Version 1.0
DAF-D-2217, Trap Door Fire Dampers, Rev. G
DAF-D-2217, Type DAF-P-2217 Trap Door Fire Dampers, Rev. H
DAF-D-8403, DAF P-5990
: [[contact::U.L. Classified Type A Excel Fire Damper]], Rev. 3
DAF-D-8406, UL Classified DAF-P-5990 Fire Damper with Factory Supplied Sleeves, Rev. D
Enclosure
}}
}}

Latest revision as of 10:02, 2 November 2019

NRC Triennial Fire Protection Inspection (Team) Report 05000348/2018011 and 05000364/2018011
ML18256A251
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 09/11/2018
From: Scott Shaeffer
NRC/RGN-II/DRS/EB2
To: Madison D
Southern Nuclear Operating Co
References
IR 2018011
Download: ML18256A251 (15)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 11, 2018

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION (TEAM) REPORT NOS. 05000348/2018011 AND 05000364/2018011

Dear Mr. Madison:

On August 2, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Farley Nuclear Plant, Units 1 and 2, and the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this NFPA 805 Triennial Fire Protection Inspection (TFPI) are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating the violation as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRCs Enforcement Policy.

If you contest this violation or significance of this NCV, 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 II; the Director, Office of Enforcement; and the NRC Resident Inspector at the Farley Nuclear Plant. 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/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8

Enclosure:

Inspection Report 05000348/2018011 and 05000364/2018011

Inspection Report

Docket Number(s): 50-348, 50-364 License Number(s): NPF-2, NPF-8 Report Number(s): 05000348/2018011 and 05000364/2018011 Enterprise Identifier: I-2018-011-0022 Licensee: Southern Nuclear Operating Company, Inc. (SNC)

Facility: Joseph M. Farley Nuclear Plant, Units 1 and 2 Location: Ashford, AL 36312 Inspection Dates: Week 1 of onsite inspection: July 16 - 20, 2018 Week 2 of onsite inspection: July 30 - August 2, 2018 Inspectors: J. Dymek, Reactor Inspector L. Jones, Senior Reactor Inspector W. Monk, Reactor Inspector (Team Leader)

N. Staples, Senior Reactor Inspector Accompanying Personnel: T. Sippel, Fuel Facility Inspector (Training, Week 1 Only)

Approved By: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety (DRS)

1 Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Southern Nuclear

Companys performance by conducting an announced team TFPI at the Farley Nuclear Plant,

Units 1 and 2, in accordance with the NRC Reactor Oversight Process. The Reactor Oversight Process (ROP) is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified findings and violations are summarized in the table below.

List of Findings and Violations Failure to ensure fire barrier penetrations (including fire dampers) in fire zones protecting safety-related areas shall be functional in accordance with NFPA 805 Section 3.11.3, Fire Barrier Penetrations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green H.8, Procedure 71111.05XT Systems NCV 05000348-364/2018011-01 Adherence - 02.02b Closed The NRC identified a Green finding and associated non-cited violation (NCV) of the Farleys Renewed Operating License Condition 2.C.(4) - Fire Protection for U1 and 2.C.(6) - Fire Protection for U2. This finding was identified for failure to maintain all provisions of the approved FPP, as described in NFPA 805, 2001 Edition to ensure that all fire barrier penetrations (including fire dampers) in fire zones protecting safety-related areas shall be functional. The functional failure of the two fire dampers in the A and B SWIS Battery Rooms was a performance deficiency and determined to be more-than-minor because it affected the Reactor Safety Mitigating Systems cornerstone attribute of protection against external factors, a fire, and it affected the fire protection Defense in Depth (DID) strategies involving the confinement of fires and to protect systems important to safety. Additionally, if left uncorrected, the issue could potentially lead to a more significant safety concern during fire events.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The team reviewed the selected procedures and records, observed activities, and interviewed plant personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and industry standards.

REACTOR SAFETY

===71111.05XT - NPFA 805 Fire Protection (Triennial)

The team evaluated applicable fire protection licensing commitments from July 16, 2018 to August 2, 2018 by review of the following:

Fire Protection Inspection Requirements ===

Main article: IP 71111.05

The team evaluated fire protection program implementation in the following selected areas:

1) FA 1-041, Train A SWGR and Load Center Rooms (Performance Based Area)2) FA 076, SWIS 5KV SWGR A and East Stairs (Performance Based Area)3) FA 1-018, Aux Building DC SWGR (Performance Based Area)

B.5.b Inspection Activities (1 Sample)

The team evaluated the feasibility of the following B.5.b Mitigating Strategies:

1) The team reviewed the strategy for manual operation of the Turbine Driven AFW (TDAFW) Pump strategy

OTHER ACTIVITIES - BASELINE

INSPECTION RESULTS Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green Finding H.8, Procedure 71111.05XT-Systems 50-348, 50-364/2018011-01 Adherence 02.02b Closed The NRC identified a Green finding and associated non-cited violation (NCV) of the licensees Fire Protection Program (FPP) and NPFA 805, Section 3.11.3, Fire Barrier Penetrations, for the licensees failure to ensure functional fire dampers, 1-188-332-01 and 1-188-332-02 in the A and B SWIS Battery Rooms.

Description:

Fire Dampers 1-188-332-01 and 1-188-332-02 in the A and B SWIS Battery Rooms were improperly installed per their design drawing U164049 and the B train Battery Room fire damper failed to shut when conducting a surveillance drop test on 7/20/2018. Specially, the angle clip bracket was not installed with the 90 degree leg pointed away from the damper skirt, which caused the damper skirt to not drop and seal off the barrier penetrations between the battery rooms (Deterministic fire areas) and SWIS Switchgear Rooms (Performance-Based fire areas).

Additionally, according to drawing U164049, DAF-P-5990 Fire Damper with Optional SRD (Smoke Release Device), Note 1 states: Although construction is per these drawings, the damper will not be UL Label if equipped with the SRD. In the case of Fire Dampers 1-188-332-01 and 1-188-332-02, all four 1 1/2 hour rated curtain-type fire dampers were equipped with SRDs and fusible links, not electro-thermal links (ETLs). SRDs are not UL listed/labeled, but ETLs are UL listed/labeled. The referenced electrical elementary design drawings reflected use of ETLs, not SRDs.

The improper fire damper installations and damper functional failure did not meet the licensees Fire Protection Program (FPP) nor NPFA 805 Section 3.11.3, Fire Barrier Penetrations, which states passive fire protection devices such as dampers shall conform with the following NFPA standard, NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems. NFPA 90A, Code of Record 1973 states in section 905, Construction of Fire Dampers, Approved fire dampers shall have the following performance characteristics:

a) They shall be arranged to close automatically in event of abnormal high temperature.

b) They shall provide the maximum practical barrier to passage of air when in the closed position.

Corrective Action(s): In response to the inspection discovery, the licensee promptly initiated condition reports to resolve the equipment deficiencies and conducted an extent of condition review throughout the plant.

Corrective Action Reference(s): This issue is being tracked in the licensees corrective action program (CAP) by condition reports:

  • CR 10516723, NRC Inspector Identified Damper 1-188-332-02 Was Not Installed Correctly, 7/18/2018
  • CR 10517136, Incorrect Fire Damper Installation - EOC, 7/19/2018
  • CR 10517257, Damper Inspection Request for EOC, 7/20/2018
  • CR 10517472, SWIS Battery Room B Fire Damper Failed Drop Test, 7/20/2018
  • CR 10520516, 2018 NRC TFPI - Non-UL Listed Fire Damper, 7/30/2018
Performance Assessment:

Performance Deficiency: The licensees failure to ensure the fire dampers were functional, as required by the approved Fire Protection Program and NPFA 805 was determined to be a performance deficiency (PD).

Screening: This performance deficiency was determined to be more-than-minor because it affected the Reactor Safety Mitigating Systems cornerstone attribute of protection against external factors, a fire, and it affected the fire protection DID strategies involving the confinement of fires and to protect systems important to safety. Specifically, the failure to ensure functional fire dampers could affect the fire protection DID strategy involving the confinement of fires because it could allow smoke and heat to migrate beyond the room and affect adjacent fire areas (FAs). Additionally, if left uncorrected, the issue could potentially lead to a more significant fire propagation safety concern.

Significance: The team assessed the finding using NRC Inspection Manual Chapter 0609, Significance Determination Process (SDP), Attachment 4, Initial Characterization of Findings, and determined the Mitigating Systems cornerstone was impacted and that a IMC 0609, Appendix F, Fire Protection SDP review was required as the finding involved the ability to confine a fire. The team further assessed the finding using NRC Inspection Manual Chapter 0609, Appendix F, Attachment 1, Fire Protection SDP Worksheet, and determined the finding to be of very low safety significance (Green) based upon Step 1.4.4, Question E, based upon if a fire were to spread from one fire area to another due to the degraded fire barriers, no additional targets would be damaged in the fire areas that could impact the credited safe shutdown strategy.

Cross-Cutting Aspect: The team assessed the issue for cross-cutting aspects using IMC 0310, Aspects Within Cross Cutting Areas, and concluded this deficiency was indicative of current licensee performance because the fire dampers were last inspected in September 2017. Per IMC 0310, a cross cutting aspect of H.8, Procedure Adherence was assigned to this finding because individuals performing the fire damper surveillances did not fully follow the surveillances procedures and work instructions. Specially, the fire damper surveillance inspection procedure states under the Acceptance Criteria section, No damage or missing hardware exists on the damper as determined by a visual inspection and the wires and links are properly attached.

Enforcement:

NPFA 805 Section 3.11.3, Fire Barrier Penetrations, required passive fire protection devices such as dampers shall conform with the following NFPA standard, NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems. NFPA 90A, Code of Record 1973, Section 905, Construction of Fire Dampers, required that approved fire dampers shall have the following performance characteristics:

a) They shall be arranged to close automatically in event of abnormal high temperature.

b) They shall provide the maximum practical barrier to passage of air when in the closed position.

Contrary to the above, since the plants commercial operational date until July 2018, the licensee failed to ensure that fire dampers 1-188-332-01 and 1-888-332-02 were functional and that they met the requirements of NFPA 90A, to functionally shut during the conditions of a fire.

Disposition: This violation is being treated as an NCV consistent with Section 2.3.2a of the NRC Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The team verified no proprietary nor safeguards information was retained or documented in this report. Additionally, the team confirmed that proprietary and safeguards information was controlled to protect from public disclosure. On August 2, 2018, the lead inspector and team presented the NFPA 805 TFPI results to the Site Vice President, Mr. Dennis Madison, and other members of the Farley Nuclear Plant staff.

THIRD PARTY REVIEWS The team did not perform any reviews of the Institute of Nuclear Power Operations (INPO)reports nor any other third party documents during the inspection period.

KEY POINTS OF CONTACT Licensee Personnel Gene Surber, Licensing Supervisor Mandy Ludlam, Licensing Engineer Hilliard Cooper, Fire Protection Manager Meredith Smith, Fire Protection Program Engineer Kim Wilson, Fire Protection Engineer Robert Chandler, Site Fire Marshall NRC Personnel P. Niebaum, Senior Resident Inspector K. Miller, Resident Inspector S. Shaeffer, Chief, Engineering Branch 2, DRS, Region II LIST OF COMPONENTS REVIEWED Component ID Description Q1E21P0002B 1B Charging/HHSI Pump N1E21HIK122 Charging Flow Indication Q1B31V0053 U1 A/B PORV Q1E21LCV115B Excess Letdown Valve Q1N23HV3227B Train B MDAFW Pump Q1P17P001B Train B CCW Pump Q1N1PV3371B Main Steam Atmosphere Relief Valve Q1B31V0061 Pressurizer PORV Q2R16B0006 4.16KV Switchgear Bus 2D Q1E13PT0952 Unit 2 Containment Pressure Transmitter QSR42B0523B 125VDC SWIS Battery 2 N1B31LI0461 Pressurizer Level Channel 3 N1B31LI0459Z Pressurizer Level Indicator LI-459Z N1B21TI0410 RCS Cold Leg Temperature Indicator N1N11LI0477A Steam Generator 1A Wide Range Level Indicator LI-477A N1N11LI0497A Steam Generator 1C Wide Range Level Indicator LI-497A N1C55NI0031B Source Range Count Rate Indicator NI-31B

DOCUMENTS REVIEWED

Licensing Basis, Design Basis, & Regulatory

DWG A-181805, NFPA 805 Fire Protection Program Design Basis Document, Rev. 1

Joseph M. Farley Nuclear Plant License Amendment Request to Adopt NFPA-805 Performance

Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001

Edition), 9/25/2012

Safety Evaluation Report, Joseph

M. Farley Nuclear Plant, Units 1 And 2 - Issuance Of

Amendments Related To NFPA 805 Supplement (CAC Nos. MG0094, MG0095; EPID N

O.

L-2017-LLA-0261), 11/01/2017

Safety Evaluation Report, Joseph

M. Farley Nuclear Plant, Units 1 And 2 - Issuance Of

Amendments Related To NFPA 805 Supplement (CAC Nos. MF7617 And MF7618),

10/17/2016

Southern Nuclear Operating Company Alabama Power Company Docket No. 50-348 Joseph

M.

Farley Nuclear Plant, Unit 1 Renewed Facility Operating License No. NPF-2

Southern Nuclear Operating Company Alabama Power Company Docket No. 50-364 Joseph

M.

Farley Nuclear Plant, Unit 2 Renewed Facility Operating License No. NPF-8

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding

License Amendment Request for Transition to 10 CFR 50.48(c) NFPA 805 Performance

Based Standard for Fire Protection for Light Water Reactor Generating Plants, Attachment S -

Modifications and Implementation Items

Farley Nuclear Plant, UFSAR Chapter 9, Section 9.5.1, Fire Protection System, Rev. 26

Calculations

ARC 4.3.1, Compliance Assessment by Scenario, 6/15/2018

F-RIE-FIREPRA-U00-017, NFPA 805 Transition Risk Results for Farley, 2/16/2018

NMP-ES-035-006-F06, NFPA 805 Change Evaluation - U1/U2 FLEX Communications &

Gaitronics Upgrades, Version 2.0

Enclosure

NMP-ES-035-006-F06, NFPA 805 Change Evaluation - Main Turbine (DEH) Controls Upgrade,

Version 1.0

SE-C051326701-008, NFPA 805 Fire Risk Evaluations, Rev. 2

SE-C051326701-008, Attachment - FRE for Unit 1 Fire Area 1-018, Auxiliary Building DC

Switchgear Room, Rev. 0

SE-C051326701-010, Nuclear Safety Capability Assessment Fire Area Compliance

Assessment, Rev. 4

SE-C051326701-011, Recovery Action Feasibility Evaluation, Rev. 0

SE-C051326701-012, NFPA 805 Defense in Depth (DID) Recovery Actions, Rev. 2

SM-C051326701-007, NFPA Code Conformance Review, Version 1.0

SM-C051326701-011, Fire Suppression Effects Analysis, Version 1.0

SM-1081426001-001, B.5.b Mitigation Strategy Flow Verification, Dated March 2012

TE-707175, Evaluation of Farley Triennial Fire Distribution System Flow Test, FNP-0-FSP-53,

11/22/2013

Procedures

FNP-0-AOP-29.0, Abnormal Operating Procedure - Plant Fire, Rev. 51.0

FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments76-100, Version 1.0

FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 51-75, Version 1.0

FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 1-25, Version 1.0

FNP-0-SOP-29.3, Reliable Equipment During a Plant Fire Attachments 26-50, Version 1.0

FNP-1-ECP-0.0, Emergency Contingency Procedure - Loss of All AC Power, Rev. 30

FNP-0-EIP-16.0, Emergency Equipment and Supplies, VERSION 72.0

FNP-0-EIP-16.0-F05, Checklist E Control Room Storage Locker, Version 1.0

FNP-0-EIP-16.0-F26, Fire Fighting Equipment (OPS) Checklist, Version 1.0

FNP-0-EIP-16.0-F40, Smoke Removal Equipment, Version 1.0

FNP-1-FPP-1.0, Unit 1 Auxiliary Building Pre-Fire Plan, Version 1.0

FNP-0-FPP-2.0, Protected Area Pre-Fire Plans, Version 1.0

FNP-0-FPP-3.0, Owner Controlled Area Pre-Fire Plan, Version 2.0

FNP-1-FPP-3.0, Unit 1 Containment Pre-Fire Plan, Version 1.0

FNP-0-FSP-201.1, No. 1 Diesel Driven Fire Pump Functionality Test, Version 21.0

FNP-0-FSP-201.3, Motor Driven Fire Pump Functionality Test, Version 12.0

FNP-0-FSP-203.2, #1 Diesel Driven Fire Pump Functional Test, Version 10.0

FNP-0-FSP-203.4, Motor Driven Fire Pump Functional Test (Pump Flow Test), Version 11.0

FNP-0-FSP-203.5, #1 Diesel Driven Fire Pump Functional Test (Pump Flow Test),

Version 14.0

FNP-0-FSP-300.0, Fire Pump Diesel Starting Battery Monthly Inspection, Version 5.1

FNP-0-FSP-301, Fire Pump Diesel Starting Battery Quarterly Inspection, Version 8.0

FNP-0-SOP-0.4, Fire Protection Operability And LCO Requirements, Rev. 104

FNP-1-AOP-28.0, Control Room Inaccessibility, Version 18, Dated April 2018

NP-1-FSP-65.0A, Fire Dampers Functional Inspection Aux. Building - Diesel Building - Service

Water Building Train A, Version 5.0

FNP-1-FSP-65.0B, Fire Dampers Functional Inspection Aux. Building - Diesel Building -

Service Water Building Train B, Version 5.0

FNP-1-SOP-58.0, Auxiliary Building HVAC System, Version 80, Dated March 2018

FNP-1-SOP-62.0, Emergency Air System, Version 26, Dated April 2015

NMP-05-007-003, Standing Order - Fire Protection LCOs Peer Check Requirement, 7/11/2018

NMP-CH-002, Chemical Control Program, Version 12.2, 5/24/18

NMP-CH-002-003, Chemical Storage Areas, Version 9.0, 6/14/18

NMP-EP-402, Plant Farley Emergency Management Guideline (EMG), VERSION 14.1

NMP-EP-402, Manual Operation of TDAFW, Att. 7, Version 14.1

Enclosure

NMP-EP-402, Temporary Instrumentation Installation, Att. 12, Version 14.1

NMP-EP-402, B.5.b Pump and Accessories, Att. 13, Version 14.1

NMP-ES-027-001, NFPA 805 Program, Version 9.0

NMP-ES-035-001, Fire Protection Program Implementation, Version 13.1

NMP-ES-035-003, Fleet Hot Work Instruction, Version 7.0

NMP-ES-035-007, Fleet Fire Watch Instruction, Version 4.1

NMP-ES-035-009, Quarterly Fire Safety Inspection, Version 4.0

NMP-ES-035-010, Fire Brigade, Version 5.0

NMP-ES-035-014, Fleet Transient Combustible Controls, Version 2.1

NMP-ES-035-GL01, Fire Protection Program Guideline, Version 3.0

NMP-OS-007-001, Conduct of Operations Standards and Expectations, Version 16.2

NMP-TR-425, Fire Drill Program, Version 8.0

NMP-TR-426, Fire Training Program, Version 5.1

Plant Modifications

DCP SNC459687, NFPA 805: U1 Cable and Raceway Fire Protection, Version 8.0

DCP SNC834134, SWIS Security Enhancements Project - NFPA 805 Change Evaluation,

Version 2.0

Miscellaneous Documents

A-181017, J. M. Farley Nuclear Plant Unit 1 / 2 Functional System Description-Fire Protection

System, Revision 43

American Warming and Ventilating, Inc., Mod. DAF-D-8403, U.L. Classified Type A Excel Fire

Damper, Revision E

Chemical Product Storage Permit, NMP-CH-002-03, Attachment 1, SWIS, 6/15/2015

Elsie Type A and Type B Fusible Link Vendor Data Sheet, 7/30/2018

EVAL-F-R45-03207, U1 R45-FO1 Emergency Lights, 4/8/2018

Farley Nuclear Plant Occurrence Report (OR) 1-98-017, Fire Damper Failed to Indicate Closed,

1/22/1998

Information Notice No. 89-52: Potential Fire Damper Operational Problems, June 8, 1989

Information Notice No. 83-69: Improperly Installed Fire Dampers at Nuclear Power Plants,

October 21, 1983

Maintenance Rule Expect Panel Meeting #18-06, 4/03/2018

Maintenance Rule Expect Panel Meeting #18-09, 6/22/2018

National Fire Protection Association (NFPA) 80, Fire Doors and Windows 1973 Code of Record

NFPA 600, Standard for Industrial Fire Brigades, 2000 Edition

NMP-ES-035-009-F01, Quarterly Fire Inspection Report Form, Q1 2018

NMP-ES-035-009-F01, Quarterly Fire Inspection Report Form, Q2 2018

RER SNC629964, RG 1.75 Marinite RER, Version 2.0

Request from Bechtel Eastern Power Company to American Warming and Ventilating Company

Entitled Evaluation of Fire Damper Installation, (SS-1102-54), March 21, 1988

S-FP-PP-10100-07.1, Fire Training / Introduction to Fire Fighting, Rev. 7.1

TE 1009817, Take to the MREP: Tracking CR per NMP-GM-027-001, 4/17/2018

Work Orders

WO SNC593970, FNP-1-FSP-307.0 - Zone 1A-32 - U1 A-Train Smoke Detector - Biennial

Operability and Adjustment, 6/10/2016

WO SNC517737, FNP-1-FSP-65.0A - A-Train Rad Waste HVAC Fire Damper Inspection,

8/5/2016

WO SNC578376, FNP-1-FSP-63.07 - Visual Inspection of Various AB Fire Barrier Penetrations,

10/29/2016

Enclosure

WO SNC719665, 1-2A Diesel Fire Roll-up Door, Rev. 1

WO SNC789081, FNP-0-FSP-201.3 - Motor Driven Fire Pump Operability Test, 11/19/2016

WO SNC806975, Addition of Fire Extinguishers for NFPA 10 Code Compliance, 3/22/2017

WO SNC822613, FNP-0-FSP-203.4 - Motor Driven Fire Pump Functional Test, 4/27/2017

WO SNC538103, Perform FNP-1-FSP-65.0A Data Sheet (A-Train) Visual Inspect, 9/22/2017

WO SNC958335, Incorrect Fire Damper Installation - EOC, 7/23/2018

Condition Reports Reviewed during inspection

CR 10043210, Fire Watch Required, 3/19/2015

CR 10509998, Equipment Check Deficiency

CR 10051606, Re-evaluate Postulated Hot Short Event, 4/07/2015

CR 10517355, Update for AOP FNP-0-EIP-16.0-F26

CR 10149000, Note Added to FNP-0-SOP-0.4, 11/19/2015

CR 10149001, 1-2A Diesel INOP MRULE MPFF, 11/19/2015

CR 10168712, NFPA 805 Potential License Condition Compliance Issue, 1/14/2016

CR 10170805, Impact Review for DCP SNC692210, 1/20/2016

CR 10172987, Risk Evaluation Needed for Three DCPs, 1/25/2016

CR 10207202, Combustibles Storage in a Level A Area Unapproved, 4/07/2016

CR 10281867, Fire PRA Qualifications NFPA 805 LAR Requirements, 10/04/2016

CR 10318639, NOS Fire Protection Identified Findings, 1/14/2017

CR 10356518, NFPA 805 Circuit Supervision Design for Dry Chemical Suppression (2A-120),

4/20/2017

CR 10431122, Fire Extinguishers, 11/15/2017

CR 10442490, NFPA 805 Implementation, 12/24/2017

CR 10445795, AOP-29 Procedure Revision, 1/04/218

CR 10448087, Unanalyzed Condition Identified During NFPA 805 Transition, 1/09/2018

CR 10454233, MRule Unavailability Hours Exceeded for Sprinkler Systems, 1/25/2018

CR 10461010, Fire Extinguisher Hydro Date, 2/12/2018

CR 10464796, Fire Extinguishers, 2/22/2018

CR 10465621, Generate WOs for Fusible Link (ETL) Replacements, 2/23/2018

CR 10466131, HSS Fire Dampers Nonfunctional Due to Expired FSP, 2/26/2018

CR 10466136, LSS Fire Dampers Non Functional, 2/26/2018

CR 10470738, FPA Database Used to Track and Manage FP LCOs in Inadequate, 3/10/2018

CR 10483183, Tracking CR per NMP-GM-027-001, 4/17/2018

CR 10489319, Breaker in Cubicle N2R17BKRFC52R Oversized for the Application, 5/03/2018

CR 10494496, NFPA 805 S-3 Item 31, 5/17/2018

CR 10497446, WOs Needed to Perform Partial FNP-1-FSP-307.0 on Multiple FP Systems,

5/25/2018

CAR 256103, Document Comp. Measures Taken, 4/23/2015

CAR 260875, Pre-Start Check on 1-2A Diesel Fire Roll-up Door, 12/11/2015

CAR 272312, 1-2A EDG Day Tank Room Fire Damper Closing Due to Failed Fusible Link,

2/14/2017

Condition Reports Written Due to this Inspection

CR 10516257, Dirt Dauber Nest in Vent Line of No. 2 Diesel Fire Pump Fuel Oil Tank,

7/17/2018

CR 10516269, Conduit Labeling Error at SWIS, 7/17/2018

CR 10516551, NMP-ES-035-GL01 Contains Directions and Instructions Not IAW NMP-AP-001,

7/18/2018

CR 10516553, Farley Fire Preplan Guidance, 7/18/2018

CR 10516573, Revise NMP-ES-035-001, Fire Protection Program Implementation, 7/18/2018

Enclosure

CR 10516702, Typo in FRE Calculation SE-C051326701-008, 7/18/2018

CR 10516723, NRC Inspector Identified Damper 1-188-332-02 Was Not Installed Correctly,

7/18/2018

CR 10516728, In-correct Version of Fire Pre-plans in Fire Brigade Ready Room, 7/18/2018

CR 10516948, EIP-16 Checklist C Found Expired Batteries, 7/19/2018

CR 10517133, FNP-0-SOP-0.4 Needs to be Clarified, 7/19/2018

CR 10517136, Incorrect Fire Damper Installation - EOC, 7/19/2018

CR 10517262, FNP-0-EIP-16 Checklist EOC Inspection, 7/20/2018

CR 10517257, Damper Inspection Request for EOC, 7/20/2018

CR 10517355, Procedure Revision Request for FNP-0-AOP-29, 7/20/2018

CR 10517472, SWIS Battery Room B Fire Damper Failed Drop Test, 7/20/2018

CR 10520516, 2018 NRC TFPI - Non-UL Listed Fire Damper, 7/30/2018

CR 10520806, Bolt Missing on Electrical Panel in MCR, 7/31/2018

CR 10520912, SSD Equipment Extension Cord Removed from Service, 7/31/2018

CR 10520916, NRC TFPI 2018 - Work Order Closed Inappropriately, 7/31/2018

CR 10521312, Issues Noted with Emergency Light PMs, 8/1/2018

CR 10521359, B.5.b Test Gauges Found Out of Calibration, 8/2/2018

CR 10521560, 2018 NRC TFPI CR - Fire Damper Technical Evaluation Needed, 8/2/2018

Drawings

A-177539, Grounding - Details and Notes, Rev. 2

D-170331,

J.M. Farley Nuclear Plant - Unit 1 & 2, Outdoor Concrete-Service Water Intake

Structure, General Arrangement, Version 1.0

D-170343,

J.M. Farley Nuclear Plant - Unit 1, Fire Protection Piping, Pump House & Tanks

Plans & Details, Revision 10

D-177001, U1 Single Line Electrical Auxiliary System (Emergency 4160 & 600 V), Rev. 23

D-170366, Fire Protection P&ID - Yard Mains, Rev. 47

D-170366, Fire Protection P&ID - Pump House, Rev. 14

D-170366,

J.M. Farley Nuclear Plant - Unit 1, Fire Protection, P & ID, Pump & Engine Details,

Sheet 1, Version 1.0

D-170366,

J.M. Farley Nuclear Plant - Unit 1, Fire Protection, P & ID, Pump House & Yard

Mains, Version 1.0

D-170381,

J.M. Farley Nuclear Plant - Unit 1, Fire Protection P&ID, High Pressure Carbon

Dioxide, Sheet 1,Version 1.0, Revision 0

D-170381,

J.M. Farley Nuclear Plant - Unit 1, Fire Protection P&ID, High Pressure Carbon

Dioxide, Sheet 3,Version 1.0, Revision 0

D-170384, Fire Protection P&ID - Low Pressure Carbon Dioxide, Rev. 17

D-170385, Fire Protection P&ID - High Pressure Carbon Dioxide, Rev. 5

D-172099, D-170381,

J.M. Farley Nuclear Plant - Unit 1, Fire Protection, Thermostat

Installation-600v Switchgear, Revision 0

D-175011,

J.M. Farley Nuclear Plant - Unit 1, HVAC P&ID Radwaste Area System, Aux. Bldg.

Plan at El. 121-0, Revision 0

D-175030,

J.M. Farley Nuclear Plant - Unit 1, HVAC Process Flow Diagram, Non-Rad Area &

Electrical Shop Rooms, Version 1.0

D-175115,

J.M. Farley Nuclear Plant - Unit 1, HVAC System, Aux. Bldg. Plan at El. 121-0,

Version 1.0

D-175048,

J.M. Farley Nuclear Plant - Unit 1 & 2, Service Water Intake Structure, HVAC-P&ID,

Revision 1

D-170332,

J.M. Farley Nuclear Plant - Unit 1 & 2, Mechanical-Service Water Intake Structure,

General Arrangement of Heat & Ventilation Systems- Floor Plan Section & Details, Rev. 22

D-205619, P&ID Chemical & Volume Control System, Rev. 4

Enclosure

D-350857,

J.M. Farley Nuclear Plant - Unit 1, Aux. Bldg. Concrete-Penetration Seals @ El.

21-0, Version 1.0

DAF-D-2217, Trap Door Fire Dampers, Rev. G

DAF-D-2217, Type DAF-P-2217 Trap Door Fire Dampers, Rev. H

DAF-D-8403, DAF P-5990

U.L. Classified Type A Excel Fire Damper, Rev. 3

DAF-D-8406, UL Classified DAF-P-5990 Fire Damper with Factory Supplied Sleeves, Rev. D

Enclosure

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000348/2018011&oldid=2042267"