IR 05000390/2015010

IR 05000390/2015010, 04/27/2015 - 05/01/2015, 08/24-28/2015, Watts Bar Nuclear Plant, Unit 1, Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial)

ML15287A022
Person / Time
Site:	Watts Bar
Issue date:	10/12/2015
From:	Scott Shaeffer NRC/RGN-II/DRS/EB2
To:	Skaggs M Tennessee Valley Authority
References
IR 2015010
Download: ML15287A022 (20)

Text

UNITED STATES ober 12, 2015

SUBJECT:

WATTS BAR NUCLEAR PLANT UNIT 1 & 2 - NRC TRIENNAL FIRE PROTECTION INSPECTION; AND NRC DUAL UNIT FIRE PROTECTION PROGRAM REVIEW (REPORT NO. 05000390/2015010 & 05000391/2015615)

Dear Mr. Skaggs:

On August 28, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of Watts Bar Nuclear (WBN) Plant Unit 1 & 2 Fire Protection Program. The enclosed inspection report documents the inspection results, which were discussed with you and other members of your staff.

This was a follow-up inspection that examined aspects of the sites fire protection program to ensure compliance with proposed dual unit operating license requirements. The previous inspection was documented in Inspection Report 05000391/2014612 (ADAMS Accession No.

ML15034A211). Additionally, this report records the completion of the triennial fire protection inspection for Units 1 and 2 for the triennial period 2014 - 2016.

No findings were identified during this inspection.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/ reading-rm/adams.html. Should you have questions concerning this letter, please contact me at (404) 997-4521.

Sincerely,

/RA/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-390; 50-391 License No.: NPF-90 Construction Permit No: CPPR-92

Enclosure:

Inspection Report 05000390/2015010, 05000391/2015615 w/Attachment: Supplementary Information

REGION II==

Docket No: 50-390, 50-391 License No.: NPF-90 Construction Permit No: CPPR-92 Report No: 05000390/2015010 & 05000391/2015615 Applicant: Tennessee Valley Authority Facility: Watts Bar Nuclear Plant, Units 1 & 2 Location: Spring City, TN 37381 Dates: August 10 - 14, 2015 August 19 - 21, 2015 August 24 - 28, 2015 Inspectors: O. López-Santiago, Senior Reactor Inspector D. Jones, Senior Reactor Inspector R. Fanner, Senior Reactor Inspector J. Dymek, Reactor Inspector W. Monk, Resident Inspector Approved by: S. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000390/2015010, 04/27/2015-05/01/2015, 08/24-28/2015, Watts Bar Nuclear Plant, Unit 1,

Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial).

IR 05000391/2015615; 08/10-14/2015, 08/19-21/2015, and 08/24-28/2015; Watts Bar Nuclear Plant, Unit 2; IP 64100, Post Fire Safe Shutdown, Emergency Lighting and Oil Collection Capability at Operating and Near-Term Operating Reactor Facilities; IP 64704, Fire Protection Program; and IP 71111.05T, Fire Protection (Triennial). This report covered a four-week period of inspections and was performed by five Region II inspectors.

This report documents a follow-up inspection that examined aspects of the sites fire protection program to ensure compliance with proposed dual unit operating license requirements. The previous inspection was documented in Inspection Report 05000391/2014612 (ADAMS Accession No. ML15034A211). The inspection program for Unit 2 construction activities is described in Nuclear Regulatory Commission (NRC) Inspection Manual Chapter (IMC) 2517,

Watts Bar Unit 2 Construction Inspection Program. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be found at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html. The inspection team has substantially completed fire protection program inspection activities for dual unit operation. Additionally, this report records the completion of the triennial fire protection inspection for Unit 1.

Inspection Results No findings were identified

REPORT DETAILS

III.

OPERATIONAL READINESS ACTIVITIES F. 1 Fire Protection Inspection Report (IR) 05000391/2014612 (ADAMS Accession No. ML15034A211), dated February 2, 2015, documented a three week inspection of the Unit 2 fire protection program that occurred from October - December, 2014. IR 05000391/2014612 stated that some fire protection program areas required additional inspection, the objective of this inspection was to inspect those areas. Unless otherwise noted, the inspection team verified that deficiencies that were discussed in the IR 05000391/2014612 were appropriately dispositioned by the licensee.

The reviewed fire areas (FAs) were the same as those previously evaluated.

• FA 29, Room 757.0-A22, 125-V Vital Battery Board Room IV (Analysis Volume (AV) -

055)

• FA 31, Room 757.0-A24, 6.9 KV & 480-V Shutdown Board Room B (AV-057)

• FA 48, Room 692.0-C9, Communications Room (AV-076 & AV-076A)

• FA 60, Room 711.IPS - Electrical Board Room, 480-V Board Room (AV-089)

• FA 42, Room 772.0-A12, 480-V Transformer Room 2A (AV-069)

Additionally, the inspection activities documented in this IR, IR 05000391/2014612 (ADAMS Accession No. ML15034A211), and IR 05000391/2015603 (ADAMS Accession No.

ML15124A921) meet the minimum sample requirements for IP 71111.05T. The IP specified a minimum sample size of three fire areas and one B.5.b implementing strategy for addressing large fires and explosions. The following table lists the location of documentation that was credited for the completion of IP 71111.05T inspection requirements.

IP 71111.05T Inspection Requirements Section 02.02: Fire Protection Inspection IR 0500391/2014612 Requirements a. Protection Of Safe Shutdown Capabilities Section F.1.1, 02.01 b. Passive Fire Protection Section F.1.2, 02.04 c. Active Fire Protection Section F.1.2, 02.04 d. Protection from Damage from Fire Suppression Section F.1.1, 02.01 Activities e. Alternate Shutdown Capability Section F.1.1, 02.02 f. Circuit Analyses Section F.1.1, 02.01 g. Communications Sections F.1.2, 02.03 & 02.05 h. Emergency Lighting Section F.1.1, 02.03 i. Cold Shutdown Repairs Sections F.1.1, 02.01 & 02.02 j. Compensatory Measures Sections F.1.1, 02.01 & 02.02 and F.1.2, 02.03 k. Review and Documentation of FPP Changes Section F.1.2, 02.06 l. Control of Transient Combustibles and Ignition Section F.1.2, 02.03 Sources Section 02.04: Identification and Resolution of IR 0500391/2014612 Problems:

a. CAP items Section F.1.2, 02.07 b. Audits/Self Assessments Section F.1.2, 02.06 Section 02.03: B.5.b Inspection Activities IR 05000391/2015603 Section OA.1.3 F.1.1 Postfire Safe Shutdown, Emergency Lighting and Oil Collection Capability at Operating and Near-Term Operating Reactor Facilities (IP 64100)02.01 Section III.G.2, Redundant Train Safe Shutdown Capability 1. Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the As-Constructed FPR, associated licensee procedures and observed the staging of equipment and materials that were credited for repairing components required for cold shutdown during fire events. These activities were performed to verify that repair equipment, components, tools, and materials (e.g., pre-cut cable connectors with prepared attachment lugs) were available and accessible to plant personnel during fire events.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the cold shutdown repairs as described in the As-Constructed FPR were adequate for dual unit operation. The inspectors noted that the licensee had not staged some of the required equipment, components, tools, and materials. The inspection team determined that this item does not require additional inspection because the licensees program was adequate to ensure that the remaining items would be procured and staged in a timely manner.

2. Manual Actions as Compensatory Measures for SSD

a. Inspection Scope

For the selected FAs, the inspectors reviewed applicable corrective action documents, the revised As-Constructed FPR, revised calculations, and revised fire safe shutdown (FSSD) procedures to verify that a subset of operator manual actions (OMAs) were feasible and reliable. Additionally, the inspectors performed walk-throughs of selected FSSD procedures. To assess the feasibility and reliability of the OMAs, the inspectors used the guidance provided in IP 71111.05T, paragraph 02.02.j.2, and NUREG/CR 1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire and the draft NRC Safety Evaluation Report (SER).

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the licensee had adequately assessed and implemented procedural guidance for the manual actions as compensatory measures for SSD that were described in the As-Constructed FPR. The inspectors concluded that this item was adequate for dual unit operation.

02.02 Sections III.G.3 and III.L, Alternate and Dedicated Shutdown 1. Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the As-Constructed FPR, associated licensee procedures and observed the staging of equipment and materials that were credited for repairing components required for cold shutdown during fire events. These activities were performed to verify that repair equipment, components, tools, and materials (e.g., pre-cut cable connectors with prepared attachment lugs) were available and accessible to plant personnel during fire events.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the cold shutdown repairs as described in the As-Constructed FPR were adequate for dual unit operation. The inspectors noted that the licensee had not yet received or staged some of the required equipment, components, tools, and materials. The inspection team determined that this item does not require additional inspection because the licensees program was adequate to ensure that the remaining items would be procured and staged in a timely manner.

2. Manual Actions as Compensatory Measures for SSD

a. Inspection Scope

For the selected FAs, the inspectors reviewed applicable corrective action documents, the revised As-Constructed FPR, revised calculations, and revised fire safe shutdown (FSSD) procedures to verify that a subset of operator manual actions (OMAs) were feasible and reliable. Additionally, the inspectors performed walk-throughs of selected FSSD procedures. To assess the feasibility and reliability of the OMAs, the inspectors used the guidance provided in IP 71111.05T, paragraph 02.02.j.2, and NUREG/CR 1852, Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire and the draft NRC Safety Evaluation Report (SER).

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that the licensee had adequately assessed and implemented procedural guidance for the manual actions as compensatory measures for SSD that were described in the As-Constructed FPR. The inspectors concluded that this item was adequate for dual unit operation.

02.03 Section III.J, Emergency Lighting a. Observation At the time of the inspection, the licensee had not completed the installation of emergency lighting units required for Dual Unit operations.

b. Conclusions

This inspection item will remain open until inspection activities are conducted to verify the installation and adequacy of emergency lighting units; and as part of the follow-up inspection for CDR 83-61.

F.1.2 Fire Protection Program (IP 64704)02.02/03 Procedures to Implement the Entire Fire Protection Program 1. Ventilation

a. Inspection Scope

The inspectors assessed the adequacy of corrective actions associated with PER 967466, which involved the potential for smoke migration to adversely affect Unit 2 operator manual actions that were credited in the dual unit fire protection program.

b. Observations and Findings

As a corrective action, the licensee created DCN 65097 to install backdraft dampers for smoke mitigation between the 6.9 KV shutdown board rooms and the 480VAC shutdown board rooms. The licensee also revised procedure 0-AOI-30.1 to include new operators requirements to remove the HVAC system from service to ensure closure of the backdraft dampers. However, the inspectors noted that the licensee did not consider whether the cables associated with the HVAC system were independent from the affected FAs to ensure there were no adverse effects to the operation of the backdraft dampers (i.e. spurious operation of the HVAC fans). The licensee provided additional details regarding the feasibility and reliability of the affected OMA. The action, OMA 1016, involved the local operation of the SG PORV which was used to control secondary plant pressure and to provide a method of removing decay heat.

The licensee stated that the operator sent to perform OMA 1016 would don a self-contained breathing apparatus (SCBA) if any smoke entered the area designated for performing the OMA. The licensee also assumed that credible plant fires will be suppressed in 60 minutes. Thus, the performance of the OMA could begin at 60 minutes to account for fire suppression activities to have completely suppressed the fire.

The licensee also stated that there was 75 minutes for the operator to perform the OMA.

Based on the proceduralized operator actions to secure the ventilation system at the onset of a fire event and the available time to perform the OMA, the NRC staff concluded that these OMAs were acceptable.

No findings were identified.

c. Conclusions

The inspectors concluded that the licensee adequately addressed the issue described in PER 967466. Therefore, the inspectors determined that the ventilation was adequate for dual unit operation.

2. Emergency Communications

a. Inspection Scope

The inspection team requested and observed testing of the Unit 2 communication system in selected areas of the plant. This activity was performed to verify that the communication system was installed in accordance with the design change package (DCN 60384-A), and that the system functioned as described in the As-Constructed FPR. Additionally, the inspectors performed a review of the corrective actions associated with PER 969442.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors concluded that emergency communications as described in the As-Constructed FPR were adequate for dual unit operation. The inspectors noted that the sites corrective program had open actions to resolve deficiencies identified during testing and initial operations of the system. These deficiencies were tracked by PERs 990235, 993736, 1005588, and 1010577. The inspection team determined that this item does not require additional inspection because the licensees corrective action program was adequate to ensure that the deficiencies would be resolved in a timely manner.

02.04 Installation, Operability, and Maintenance of Fire Protection Systems and Equipment 1. Active Fire Protection a. Observation At the time of the inspection, work related to the installation of Unit 2 reactor coolant pump fire protection features was not completed. This inspection activity will be performed after the licensee completes the applicable installation activities in EDCR 54655.

b. Conclusions

This item will remain open until inspection activities are conducted to verify that Unit 2 RCP fire protection features were installed in accordance with design documents and the As-Constructed Fire Protection Report. The inspection will include a review of the associated installation package (EDCR 54655) and a review of corrective actions associated with PERs 1025119 and 1084922.

IV. OTHER ACTIVITES OA.5 (Opened) Unresolved ltem (URl)05000290/2015010-01, 420 Minute Operator Manual Action to Provide Source Range Monitoring Capability

Introduction:

The inspectors identified an unresolved item associated with a fire protection safe shutdown OMA that established a time requirement of 420 minutes to provide a functional source range monitor.

Description:

The inspection team noted that procedure 1-AOI-30.2 C36, Fire Safe Shutdown Room 737-A1A, Rev. 0005 included a 420 minute operator manual action (OMA) to establish a functional source range monitor. The OMA was listed as OMA 649 in Calculation EDQ00099920090016, Appendix R - Unit 1 & 2 Manual Action, Rev. 4.

The inspectors also noted the following:

• Westinghouse Owners Group letter, WOG-05-36 (dated 01/28/2005), Section 6.2, Long Term Cold Shutdown Capability, stated that typical instrumentation to achieve a shutdown condition during Appendix R event included the source range monitors.

• Technical Specification 3.3.1.L required an operable source range neutron flux channel in Modes 3, 4, and 5; and stipulated that positive reactivity additions (such as plant cooldown) be suspended when the instrument was inoperable.

• Procedure 1-AOI-30.2, Fire Safe Shutdown, Rev. 0005, Step 5.3.15, stated that at least one channel of nuclear instrumentation indication must be available to monitor shutdown neutron population.

• Procedure 1-AOI-30.2 C36 included a note that stated that RCS cooldown should not be initiated until source range monitoring capability can be assured.

• Procedure 1-AOI-30.2 C36 directed operators to depressurize and cooldown - an action that was typically required at 60 - 75 minutes.

The 420 minute OMA would allow shutdown and subsequent cooldown of the reactor plant without operators having the ability to monitor neutron population. The licensee contended that OMA 649 was part of the sites licensing bases and thus the capability to monitor source range was not required until 420 minutes. The inspection team determined that this issue required additional inspection because the licensee did not provide an alternative method to monitor neuron population and did not provide adequate restrictions to prevent cooldown activities until monitoring capability was restored. Additionally, the OMA conflicted with the technical specification requirements for source range availability.

The issue is unresolved pending additional review to determine if a performance deficiency exists. Required actions to resolve this issue include a detailed review of applicable docketed licensing bases correspondence; consultation with NRRs fire protection and technical specification branches; and an assessment to determine the applicable fire areas if the issue is to be determined to be a more-than-minor performance deficiency. This issue will be tracked as URI 05000290/2015010-01, 420 Minute Operator Manual Action to Provide Source Range Monitoring Capability.

OA.6 Exit Meeting Summary. An exit meeting was conducted on August 28, 20115, to present inspection results to Mr. Skaggs and other members of his staff. The inspectors identified that no proprietary information had been received during the inspection and none would be used in the inspection report. The applicant acknowledged the observations, and provided no dissenting comments.

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Applicant personnel

M. Skaggs, TVA - Senior Vice President

J. Sterchi, Fire Marshall

C. Brush, Appendix R Consultant

J. Ricks, WBN Design Engineer - Electrical

E. Haston, WBN Design Engineer - Fire Protection

J. ODell, WBN Licensing

T. Morgan, WBN Licensing

H. Baldner, WBN Licensing

J. Bushnell, WBN Licensing

B. Crouch, WBN Engineering

H. Baldner, TVA - Regulatory Compliance

M. Marinac, WBN Operations

INSPECTION PROCEDURES USED

IP 71111.05T Fire Protection (Triennial)

IP 64100 Post Fire Safe Shutdown, Emergency Lighting and Oil Collection

Capability at Operating and Near-Term Operating Reactor Facilities

IP 64704 Fire Protection Program

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000390/2015010-01 URI 420 Minute Operator Manual Action to Provide Source Range Monitoring Capability [IVOA.5]

Closed

None

Discussed

None