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| issue date = 11/15/2016
| issue date = 11/15/2016
| title = NRC Triennial Fire Protection Inspection Report 05000275/2016008 and 05000323/2016008
| title = NRC Triennial Fire Protection Inspection Report 05000275/2016008 and 05000323/2016008
| author name = Werner G E
| author name = Werner G
| author affiliation = NRC/RGN-IV/DRS/EB-2
| author affiliation = NRC/RGN-IV/DRS/EB-2
| addressee name = Halpin E D
| addressee name = Halpin E
| addressee affiliation = Pacific Gas & Electric Co
| addressee affiliation = Pacific Gas & Electric Co
| docket = 05000275, 05000323
| docket = 05000275, 05000323
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:November 15, 2016
[[Issue date::November 15, 2016]]


Mr. Edward D. Halpin, Senior Vice President
==SUBJECT:==
 
DIABLO CANYON POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000275/2016008 AND 05000323/2016008
Generation and Chief Nuclear Officer Pacific Gas and Electric Company
 
Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424
 
SUBJECT: DIABLO CANYON POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000275/2016008 AND 05000323/2016008


==Dear Mr. Halpin:==
==Dear Mr. Halpin:==
On October 20, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2, and discussed the results of this inspection with Mr. J. Nimick, Senior Director, Nuclear Services, and other members of your staff. The results of this inspection are documented in the enclosed report.
On October 20, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2, and discussed the results of this inspection with Mr. J. Nimick, Senior Director, Nuclear Services, and other members of your staff. The results of this inspection are documented in the enclosed report.


No NRC-identified or self-revealing findings were identified during this inspection. However, the team documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating th is violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection. However, the team documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.


If you contest the violation or significance of the violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Diablo Canyon Power Plant.
If you contest the violation or significance of the violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Diablo Canyon Power Plant.


This letter, its enclosure, and your response (if any) will be made available for public inspection  
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.
 
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,
Sincerely,
/RA/ Gregory E. Werner, Chief Engineering Branch 2  
/RA/
Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-275 and 50-323 License Nos. DPR-80 and DPR-82


Division of Reactor Safety
===Enclosure:===
 
Docket Nos. 50-275 and 50-323 License Nos. DPR-80 and DPR-82
 
Enclosure:
Inspection Report No. 05000275/2016008 and 05000323/2016008, w/Attachment:
Inspection Report No. 05000275/2016008 and 05000323/2016008, w/Attachment:
Supplemental Information  
Supplemental Information


cc w/enclosure: Electronic Distribution
REGION IV==
Dockets: 05000275 and 05000323 Licenses: DPR-80 and DPR-82 Report Nos.: 05000275/2016008 and 05000323/2016008 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, CA Dates: October 3 to October 20, 2016 Team Leader: S. Alferink, Reactor Inspector, Engineering Branch 2 Team: S. Graves, Senior Reactor Inspector, Engineering Branch 2 J. Mateychick, Senior Reactor Inspector, Engineering Branch 2 S. Makor, Reactor Inspector, Engineering Branch 2 E. Uribe, Project Engineer, Inspection Program and Assessment Team D. Loveless, Senior Reactor Analyst, Plant Support Branch 2 Accompanying B. Metzger, Fire Protection Engineer, Office of Nuclear Reactor Personnel: Regulation, Division of Risk Assessment, Fire Protection Branch Approved By: Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Enclosure


=SUMMARY=
=SUMMARY=
IR 05000275/2016008 and 05000323/2016008; 10/03/2016 - 10/20/2016; Diablo Canyon Power Plant; Triennial Fire Protection Team Inspection.
IR 05000275/2016008 and 05000323/2016008; 10/03/2016 - 10/20/2016; Diablo Canyon
 
Power Plant; Triennial Fire Protection Team Inspection.


The report covers a two-week triennial fire protection team inspection by specialist inspectors from Region IV. One licensee-identified finding, which was a non-cited violation, was documented. The significance of inspection findings is indicated by their color (i.e., Green,
The report covers a two-week triennial fire protection team inspection by specialist inspectors from Region IV. One licensee-identified finding, which was a non-cited violation, was documented. The significance of inspection findings is indicated by their color (i.e., Green,
White, Yellow, or Red) and determined using Inspection Manual Chapter 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated August 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.
White, Yellow, or Red) and determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated August 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.


===A. NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===


===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===


None
None


===B. Licensee-Identified Violations===
===Licensee-Identified Violations===


A violation of very low safety significance that was identified by the licensee has been reviewed by the team. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and the corrective action tracking number are listed in Section 4OA7 of this report.
A violation of very low safety significance that was identified by the licensee has been reviewed by the team. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the corrective action tracking number are listed in Section 4OA7 of this report.


=REPORT DETAILS=
=REPORT DETAILS=


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
{{IP sample|IP=IP 71111.05XT}}
{{IP sample|IP=IP 71111.05XT}}
This report presents the results of a triennial fire protection team inspection conducted at the Diablo Canyon Power Plant in accordance with NRC Inspection Procedure 71111.05XT, "Fire Protection - NFPA 805 (Triennial)," dated January 31, 2013. The team reviewed the licensee's fire protection program against the requirements of National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated by Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c). The NFPA 805 standard establishes a comprehensive set of requirements for fire protection programs at nuclear power plants. The standard incorporates both deterministic and risk-informed, performance-based concepts. The inspection team evaluated the implementation of the approved fire protection program in selected risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and systems that ensure the plant can achieve and maintain a safe and stable  
This report presents the results of a triennial fire protection team inspection conducted at the Diablo Canyon Power Plant in accordance with NRC Inspection Procedure 71111.05XT, Fire Protection - NFPA 805 (Triennial), dated January 31, 2013. The team reviewed the licensees fire protection program against the requirements of National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated by Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c). The NFPA 805 standard establishes a comprehensive set of requirements for fire protection programs at nuclear power plants. The standard incorporates both deterministic and risk-informed, performance-based concepts. The inspection team evaluated the implementation of the approved fire protection program in selected risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and systems that ensure the plant can achieve and maintain a safe and stable condition.
 
condition.
 
Inspection Procedure 71111.05XT requires the selection of three to five fire areas and one or more mitigating strategies for review. The team used the fire hazards analysis section of the Diablo Canyon Power Plant NFPA 805 fire probabilistic risk assessment to select the following five risk-significant fire areas (inspection samples) for review:


Fire Area Description Category 3-CC Containment Penetration Rooms (All Elevations) Performance-Based 6-B-1 Battery, Inverter, and Switchgear Room (Bus F) Performance-Based 6-B-2 Battery, Inverter, and Switchgear Room (Bus G) Performance-Based 6-B-3 Battery, Inverter, and Switchgear Room (Bus H) Performance-Based 7B Cable Spreading Room Primary Control Station The team evaluated the licensee's fire protection program using the applicable requirements, which included the plant Technical Specifications, Operating License Conditions 2.C.(4) and 2.C.(5), NRC safety evaluations, 10 CFR 50.48, and NFPA 805. The team also reviewed related documents that included the Final Safety Analysis Report (FSAR), Section 9.5.1; the nuclear safety capability assessment; and the fire
Inspection Procedure 71111.05XT requires the selection of three to five fire areas and one or more mitigating strategies for review. The team used the fire hazards analysis section of the Diablo Canyon Power Plant NFPA 805 fire probabilistic risk assessment to select the following five risk-significant fire areas (inspection samples) for review:
Fire Description                               Category Area 3-CC       Containment Penetration Rooms (All Elevations)         Performance-Based 6-B-1       Battery, Inverter, and Switchgear Room (Bus F)         Performance-Based 6-B-2       Battery, Inverter, and Switchgear Room (Bus G)         Performance-Based 6-B-3       Battery, Inverter, and Switchgear Room (Bus H)         Performance-Based 7B         Cable Spreading Room                                   Primary Control Station The team evaluated the licensees fire protection program using the applicable requirements, which included the plant Technical Specifications, Operating License Conditions 2.C.(4) and 2.C.(5), NRC safety evaluations, 10 CFR 50.48, and NFPA 805.


safety analysis. Specific documents reviewed by the team are listed in the attachment.
The team also reviewed related documents that included the Final Safety Analysis Report (FSAR), Section 9.5.1; the nuclear safety capability assessment; and the fire safety analysis. Specific documents reviewed by the team are listed in the attachment.


Five fire area inspection samples and one mitigating strategy sample were completed.
Five fire area inspection samples and one mitigating strategy sample were completed.
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The team reviewed the nuclear safety capability assessment, piping and instrumentation diagrams, and fire response procedures to verify that a safe shutdown success path, free of fire damage, would be available to meet the nuclear safety goals, objectives, and performance criteria in the event of a fire under any plant operational mode or configuration.
The team reviewed the nuclear safety capability assessment, piping and instrumentation diagrams, and fire response procedures to verify that a safe shutdown success path, free of fire damage, would be available to meet the nuclear safety goals, objectives, and performance criteria in the event of a fire under any plant operational mode or configuration.


The team reviewed applicable sections of the fire response procedures for the selected fire areas and their associated fire scenarios to verify that the shutdown methodology  
The team reviewed applicable sections of the fire response procedures for the selected fire areas and their associated fire scenarios to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe and stable plant conditions.
 
properly identified the components and systems necessary to achieve and maintain safe and stable plant conditions.


The team performed a walkdown of the procedure to verify that recovery actions credited  
The team performed a walkdown of the procedure to verify that recovery actions credited to achieve the nuclear safety performance criteria were feasible. The team evaluated the feasibility of the recovery actions against the criteria established in the licensees fire protection program as approved in the safety evaluation report. Specifically, the team verified that licensee personnel credited for procedure implementation had procedures available, were trained on implementation, and were available in the event a fire occurred. The team also verified that the operators could reasonably be expected to perform the recovery actions within the time required to maintain plant parameters within specified limits.
 
to achieve the nuclear safety performance criteria were feasible. The team evaluated the feasibility of the recovery actions against the criteria established in the licensee's fire protection program as approved in the safety evaluation report. Specifically, the team verified that licensee personnel credited for procedure implementation had procedures available, were trained on implementation, and were available in the event a fire occurred. The team also verified that the operators could reasonably be expected to perform the recovery actions within the time required to maintain plant parameters within specified limits.


====b. Findings====
====b. Findings====
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The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected fire areas. The team verified the automatic detection systems and the manual and automatic suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association code of record or approved deviations and that each suppression system was appropriate for the hazards in the selected fire areas.
The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected fire areas. The team verified the automatic detection systems and the manual and automatic suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association code of record or approved deviations and that each suppression system was appropriate for the hazards in the selected fire areas.


The team performed a walkdown of accessible portions of the detection and suppression systems in the selected fire areas and t he major system support equipment in other areas (e.g., fire pumps, carbon dioxide supply systems, and hose stations) to assess the material condition, design, and operational lineup, operational availability, and operational effectiveness of these systems and components.
The team performed a walkdown of accessible portions of the detection and suppression systems in the selected fire areas and the major system support equipment in other areas (e.g., fire pumps, carbon dioxide supply systems, and hose stations) to assess the material condition, design, and operational lineup, operational availability, and operational effectiveness of these systems and components.


The team reviewed flow and pressure tests for electric fire pumps 0-1 and 0-2 and the raw water reservoir to verify that the pumps and gravity-fed water supply systems met their design requirements. The team also reviewed the suppression system functional tests to verify that the system capability met the design requirements.
The team reviewed flow and pressure tests for electric fire pumps 0-1 and 0-2 and the raw water reservoir to verify that the pumps and gravity-fed water supply systems met their design requirements. The team also reviewed the suppression system functional tests to verify that the system capability met the design requirements.
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In addition, the team inspected fire brigade equipment to determine operational readiness for fire fighting.
In addition, the team inspected fire brigade equipment to determine operational readiness for fire fighting.


The team observed an unannounced fire drill and subsequent drill critique on October 19, 2016, using the guidance contained in Inspection Procedure 71111.05AQ, "Fire Protection Annual/Quarterly," dated September 30, 2010. The team observed fire brigade members fight a simulated fire in the Unit 2 12kV switchgear room (Fire Area 20). The team verified that the licensee identified problems, openly discussed them in a self-critical manner at the drill debrief, and identified appropriate corrective actions. Specific attributes evaluated were:
The team observed an unannounced fire drill and subsequent drill critique on October 19, 2016, using the guidance contained in Inspection Procedure 71111.05AQ, Fire Protection Annual/Quarterly, dated September 30, 2010. The team observed fire brigade members fight a simulated fire in the Unit 2 12kV switchgear room (Fire Area 20). The team verified that the licensee identified problems, openly discussed them in a self-critical manner at the drill debrief, and identified appropriate corrective actions. Specific attributes evaluated were:
: (1) proper wearing of turnout gear and self-contained breathing apparatus;
: (1) proper wearing of turnout gear and self-contained breathing apparatus;
: (2) proper use and layout of fire hoses;
: (2) proper use and layout of fire hoses;
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====b. Findings====
====b. Findings====
A licensee-identified non-cited violation in this inspection area is documented in Section
A licensee-identified non-cited violation in this inspection area is documented in       Section 4OA7 of this report.
{{a|4OA7}}
==4OA7 of this report.==


===.04 Protection from Damage from Fire Suppression Activities===
===.04 Protection from Damage from Fire Suppression Activities===
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====a. Inspection Scope====
====a. Inspection Scope====
Review of Methodology  
Review of Methodology The team reviewed the nuclear safety capability assessment, procedures, piping and instrumentation drawings, electrical drawings, and other supporting documents to verify that the licensee can achieve and maintain safe and stable plant conditions from the primary control station in the event a fire required evacuation of the control room.
 
The team reviewed the nuclear safety capability assessment, procedures, piping and instrumentation drawings, electrical drawings, and other supporting documents to verify that the licensee can achieve and maintain safe and stable plant conditions from the primary control station in the event a fire required evacuation of the control room.
 
The team verified that the nuclear safety capability assessment properly identified the


components and systems necessary to meet the nuclear safety performance criteria for the fire area selected. Specifically, the team determined the adequacy of the systems selected to meet the criteria for reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries, and process monitoring. For the primary control station, which was analyzed using a performance-based approach, the team verified that the analysis included a consideration of all the necessary cables and equipment associated with operation and control of both alternating current
The team verified that the nuclear safety capability assessment properly identified the components and systems necessary to meet the nuclear safety performance criteria for the fire area selected. Specifically, the team determined the adequacy of the systems selected to meet the criteria for reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries, and process monitoring. For the primary control station, which was analyzed using a performance-based approach, the team verified that the analysis included a consideration of all the necessary cables and equipment associated with operation and control of both alternating current
: (ac) and direct current
: (ac) and direct current
: (dc) power supplies.
: (dc) power supplies.
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The team verified that the transfer of command and control from the control room to the primary control station would be unaffected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for shutdown control circuits).
The team verified that the transfer of command and control from the control room to the primary control station would be unaffected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for shutdown control circuits).


Review of Operational Implementation  
Review of Operational Implementation The team verified that the training program for licensed and non-licensed operators included the procedures for achieving and maintaining safe and stable plant conditions, including any necessary recovery actions. The team also verified that sufficient personnel required to achieve and maintain safe and stable plant conditions were properly trained and were available at all times among the normal on-site staff, exclusive of the fire brigade.
 
The team verified that the training program for licensed and non-licensed operators included the procedures for achieving and maintaining safe and stable plant conditions, including any necessary recovery actions. The team also verified that sufficient personnel required to achieve and maintain safe and stable plant conditions were properly trained and were available at all times among the normal on-site staff, exclusive of the fire brigade.


The team performed a timed walkdown of the procedure for shutdown from outside of the control room on Unit 2 with licensed and non-licensed operators to determine the adequacy of the procedure. The team verified that the recovery actions taken were feasible and that operators could reasonably be expected to implement the procedure within the applicable time requirements to achieve the nuclear safety performance criteria. The team evaluated the feasibility of the recovery actions using the criteria established in the licensee's approved fire protection program.
The team performed a timed walkdown of the procedure for shutdown from outside of the control room on Unit 2 with licensed and non-licensed operators to determine the adequacy of the procedure. The team verified that the recovery actions taken were feasible and that operators could reasonably be expected to implement the procedure within the applicable time requirements to achieve the nuclear safety performance criteria. The team evaluated the feasibility of the recovery actions using the criteria established in the licensees approved fire protection program.


The team also verified that the licensee conducted periodic operational tests of the transfer and isolation capability and instrumentation and control functions used for transferring control from the main control room to the primary control station and other locations where recovery actions would be performed. The team verified that the tests were adequate to prove the functionality of the primary control stations' capability to meet performance criteria and achieve and maintain safe and stable plant conditions.
The team also verified that the licensee conducted periodic operational tests of the transfer and isolation capability and instrumentation and control functions used for transferring control from the main control room to the primary control station and other locations where recovery actions would be performed. The team verified that the tests were adequate to prove the functionality of the primary control stations capability to meet performance criteria and achieve and maintain safe and stable plant conditions.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the nuclear safety capability assessment to verify that the licensee identified the circuits required for nuclear safety functions and protected these circuits in accordance with the deterministic approach or provided an appropriate level of protection based on the results of an analysis using an acceptable risk-informed, performance-based approach. The team verified, on a sample basis, that the licensee properly identified circuits that may impact the nuclear safety performance criteria. The team verified that these circuits were either adequately protected from the potentially adverse effects of fire damage or were analyzed to show that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not affect the capability to meet the nuclear safety performance criteria. The team verified that the licensee's analyses considered potential spurious operations due to fire-induced cable faults.
The team reviewed the nuclear safety capability assessment to verify that the licensee identified the circuits required for nuclear safety functions and protected these circuits in accordance with the deterministic approach or provided an appropriate level of protection based on the results of an analysis using an acceptable risk-informed, performance-based approach. The team verified, on a sample basis, that the licensee properly identified circuits that may impact the nuclear safety performance criteria. The team verified that these circuits were either adequately protected from the potentially adverse effects of fire damage or were analyzed to show that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not affect the capability to meet the nuclear safety performance criteria. The team verified that the licensees analyses considered potential spurious operations due to fire-induced cable faults.


The team focused on cables from the following components:
The team focused on cables from the following components:
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====a. Inspection Scope====
====a. Inspection Scope====
The team inspected the designated emergency communication radios and storage locations and reviewed the procedure for shutdown from outside of the control room to verify that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities. The team verified the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team also verified that the design and location of communications equipment such as repeaters and transmitters would not cause a loss of communications during a fire. The team discussed system design, testing, and maintenance with the system engineer.
The team inspected the designated emergency communication radios and storage locations and reviewed the procedure for shutdown from outside of the control room to verify that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities.
 
The team verified the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team also verified that the design and location of communications equipment such as repeaters and transmitters would not cause a loss of communications during a fire. The team discussed system design, testing, and maintenance with the system engineer.


====b. Findings====
====b. Findings====
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* The illumination was sufficient for operators to perform the required recovery actions for a shutdown from outside the control room.
* The illumination was sufficient for operators to perform the required recovery actions for a shutdown from outside the control room.
* The operability testing and maintenance of the emergency lighting followed licensee procedures and accepted industry practice.
* The operability testing and maintenance of the emergency lighting followed licensee procedures and accepted industry practice.
* The emergency lighting batteries were maintained consistent with the manufacturer's recommendations.
* The emergency lighting batteries were maintained consistent with the manufacturers recommendations.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and success path equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing nuclear safe ty functions or capabilities for meeting performance criteria) necessary to achieve and maintain safe and stable plant conditions. The team also verified that the short-term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and success path equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing nuclear safety functions or capabilities for meeting performance criteria) necessary to achieve and maintain safe and stable plant conditions. The team also verified that the short-term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.


The licensee identified multiple variations from deterministic requirements during the development of the risk-informed, performance-based fire protection program which required plant modifications to resolve. License Conditions 2.C.(5) and 2.C.(4),
The licensee identified multiple variations from deterministic requirements during the development of the risk-informed, performance-based fire protection program which required plant modifications to resolve. License Conditions 2.C.(5) and 2.C.(4),
"Fire Protection," for Units 1 and 2, respectively, discuss the transition period. The license conditions require these modifications to be completed by the end of refueling outages 1R20 (April/May 2017) for Unit 1 and 2R20 (February/March 2018) for Unit 2.
Fire Protection, for Units 1 and 2, respectively, discuss the transition period. The license conditions require these modifications to be completed by the end of refueling outages 1R20 (April/May 2017) for Unit 1 and 2R20 (February/March 2018) for Unit 2.


The license conditions require the licensee to maintain appropriate compensatory  
The license conditions require the licensee to maintain appropriate compensatory measures in place until completion of the modifications. The licensees compensatory measures consisted of hourly fire watches and the continued use of the post-fire safe shutdown procedures developed under the previous deterministic fire protection program. The team reviewed the compensatory measures and found the compensatory measures to be adequate.
 
measures in place until completion of the modifications. The licensee's compensatory measures consisted of hourly fire watches and the continued use of the post-fire safe shutdown procedures developed under the previous deterministic fire protection program. The team reviewed the compensatory measures and found the compensatory measures to be adequate.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team verified that the licensee provided reasonable assurance that a fire would not result in a radiological release that adversely affects the public, plant personnel, or the environment. The team also verified that the licensee determined that any radiation release to any unrestricted area resulting from fire suppression activities (but not  
The team verified that the licensee provided reasonable assurance that a fire would not result in a radiological release that adversely affects the public, plant personnel, or the environment. The team also verified that the licensee determined that any radiation release to any unrestricted area resulting from fire suppression activities (but not involving fuel damage) was as low as reasonably achievable and would not exceed applicable 10 CFR Part 20 limits. The team verified that the licensee analyzed the radioactive release on a fire area basis. The team walked down the selected fire zones and verified that the pre-fire plan tactics and instructions were consistent with the potential radiological conditions identified in the analyses.
 
involving fuel damage) was as low as reasonably achievable and would not exceed applicable 10 CFR Part 20 limits. The team verified that the licensee analyzed the radioactive release on a fire area basis. The team walked down the selected fire zones and verified that the pre-fire plan tactics and instructions were consistent with the potential radiological conditions identified in the analyses.


====b. Findings====
====b. Findings====
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The team verified that the licensee had developed a draft monitoring program to ensure that the availability and reliability of the fire protection systems, structures, and components credited in the performance-based analyses are maintained and to assess the performance of the fire protection program in meeting the nuclear safety performance criteria.
The team verified that the licensee had developed a draft monitoring program to ensure that the availability and reliability of the fire protection systems, structures, and components credited in the performance-based analyses are maintained and to assess the performance of the fire protection program in meeting the nuclear safety performance criteria.


The team noted that the licensee was in the transition period and was not required to have a monitoring program fully implemented until April 14, 2017. The team verified that the draft monitoring program ensured the assumptions in the engineering analyses remained valid with the possible exception of the condition described in the draft Frequently Asked Question 10-0059. The licensee stated that they intended to address the conclusions of this frequently asked question prior to full program implementation. The team determined that the licensee had not yet developed established levels of availability, reliability, and performance in accordance with its license condition.
The team noted that the licensee was in the transition period and was not required to have a monitoring program fully implemented until April 14, 2017. The team verified that the draft monitoring program ensured the assumptions in the engineering analyses remained valid with the possible exception of the condition described in the draft Frequently Asked Question 10-0059. The licensee stated that they intended to address the conclusions of this frequently asked question prior to full program implementation.
 
The team determined that the licensee had not yet developed established levels of availability, reliability, and performance in accordance with its license condition.


====b. Findings====
====b. Findings====
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The team reviewed the following change:
The team reviewed the following change:
* DDP-1000025244-000-00, "Incipient Detection"
* DDP-1000025244-000-00, Incipient Detection


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the licensee's implementation of guidance and strategies intended to maintain or restore core, containment, and spent fuel pool cooling capabilities under the circumstances associated with the potential loss of large areas of the plant due to explosions or fire as required by 10 CFR 50.54(hh)(2).
The team reviewed the licensees implementation of guidance and strategies intended to maintain or restore core, containment, and spent fuel pool cooling capabilities under the circumstances associated with the potential loss of large areas of the plant due to explosions or fire as required by 10 CFR 50.54(hh)(2).


The team verified that the licensee implemented and maintained adequate procedures, maintained and tested equipment necessary to properly implement the strategies, and ensured station personnel were knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure the availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verified the availability of on-site vehicles capable of towing the portable pump. The team assessed the off-site ability to obtain fuel for the portable pump and foam used for fire fighting efforts. The strategy and procedure selected for this inspection sample  
The team verified that the licensee implemented and maintained adequate procedures, maintained and tested equipment necessary to properly implement the strategies, and ensured station personnel were knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure the availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verified the availability of on-site vehicles capable of towing the portable pump. The team assessed the off-site ability to obtain fuel for the portable pump and foam used for fire fighting efforts. The strategy and procedure selected for this inspection sample included:
 
* Extensive Damage Mitigation Guideline EDG-12, Start Diesel Generator Without DC Power
included:
* Extensive Damage Mitigation Guideline EDG-12, "Start Diesel Generator Without DC Power"


====b. Findings====
====b. Findings====
Line 310: Line 282:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
 
{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities==
==4OA5 Other Activities==


Line 323: Line 294:
The team presented the inspection results to Mr. J. Nimick, Senior Director, Nuclear Services, and other members of the licensee staff at an exit meeting on October 20, 2016. The licensee acknowledged the finding presented.
The team presented the inspection results to Mr. J. Nimick, Senior Director, Nuclear Services, and other members of the licensee staff at an exit meeting on October 20, 2016. The licensee acknowledged the finding presented.


The team verified that no proprietary information was retained by the team or documented in  
The team verified that no proprietary information was retained by the team or documented in this report.
 
this report.


{{a|4OA7}}
{{a|4OA7}}
Line 331: Line 300:


The following licensee-identified violation of NRC requirements was determined to be of very low safety significance and met the NRC Enforcement Policy criteria for being dispositioned as a non-cited violation.
The following licensee-identified violation of NRC requirements was determined to be of very low safety significance and met the NRC Enforcement Policy criteria for being dispositioned as a non-cited violation.
* License Conditions 2.C.(5) for Unit 1 and 2.C.(4) for Unit 2 state, in part, that the licensee shall implement and maintain all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request, dated June 26, 2013, and as approved in the safety evaluation, dated April 14, 2016. Section 3.2.3 of Attachment A of the license amendment request states, in part:  
* License Conditions 2.C.(5) for Unit 1 and 2.C.(4) for Unit 2 state, in part, that the licensee shall implement and maintain all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request, dated June 26, 2013, and as approved in the safety evaluation, dated April 14, 2016. Section 3.2.3 of Attachment A of the license amendment request states, in part:
 
Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:
Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:
Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.
Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.


Equipment Control Guideline 18.1, "Fire Suppression Systems/Fire Suppression Water Systems," provided the requirements to demonstrate the operability of the fire suppression water system. Equipment Control Guideline Surveillance Requirement 18.1.10 required the licensee to perform a flow test of the fire suppression water system in accordance with Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition. Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition, stated, in part, that tests should be conducted in such a way that the available flow and pressure at high value or hazardous areas can be determined  
Equipment Control Guideline 18.1, Fire Suppression Systems/Fire Suppression Water Systems, provided the requirements to demonstrate the operability of the fire suppression water system. Equipment Control Guideline Surveillance Requirement 18.1.10 required the licensee to perform a flow test of the fire suppression water system in accordance with Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition. Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition, stated, in part, that tests should be conducted in such a way that the available flow and pressure at high value or hazardous areas can be determined readily.
 
readily.


Contrary to the above, prior to October 20, 2016, the licensee failed to implement all provisions of the approved fire protection program. Specifically, during the flow tests, the licensee failed to establish surveillance test procedures that measured pressure values for one of the three fire suppression water subsystems using the methodology in Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition.
Contrary to the above, prior to October 20, 2016, the licensee failed to implement all provisions of the approved fire protection program. Specifically, during the flow tests, the licensee failed to establish surveillance test procedures that measured pressure values for one of the three fire suppression water subsystems using the methodology in Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition.


The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened in accordance with Inspection Manual Chapter 0609, Appendix F, dated September 20, 2013. The finding was determined to be of very low safety significance (Green) in Task 1.4.7, "Fire Water Supply," Question A. Although the licensee did not measure and record fire main pressure, they did measure flow and it was greater than 50 percent of the required capacity. The finding was entered into the licensee's corrective action program as  
The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened in accordance with Inspection Manual Chapter 0609, Appendix F, dated September 20, 2013. The finding was determined to be of very low safety significance (Green) in Task 1.4.7, Fire Water Supply, Question A. Although the licensee did not measure and record fire main pressure, they did measure flow and it was greater than 50 percent of the required capacity. The finding was entered into the licensees corrective action program as Notifications NN 50853684 and NN 50863322.
 
Notifications NN 50853684 and NN 50863322.


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 351: Line 315:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::A. Arsene]], Engineer, Fire Protection Engineering  
: [[contact::A. Arsene]], Engineer, Fire Protection Engineering
: [[contact::A. Chitwood]], Shift Manager, Operations  
: [[contact::A. Chitwood]], Shift Manager, Operations
: [[contact::D. Ensminger]], Chief, Fire Department  
: [[contact::D. Ensminger]], Chief, Fire Department
: [[contact::L. Fusco]], Manager, Engineering  
: [[contact::L. Fusco]], Manager, Engineering
: [[contact::J. Gregerson]], Engineer, Fire Protection Engineering  
: [[contact::J. Gregerson]], Engineer, Fire Protection Engineering
: [[contact::D. Hampshire]], Supervisor, Fire Protection Engineering  
: [[contact::D. Hampshire]], Supervisor, Fire Protection Engineering
: [[contact::H. Hamzehee]], Manager, Regulatory Services  
: [[contact::H. Hamzehee]], Manager, Regulatory Services
: [[contact::A. Heffner]], NRC Interface, Regulatory Services  
: [[contact::A. Heffner]], NRC Interface, Regulatory Services
: [[contact::D. Hromyak]], Engineer, Fire Protection Engineering  
: [[contact::D. Hromyak]], Engineer, Fire Protection Engineering
: [[contact::K. Johnston]], Director, Operations  
: [[contact::K. Johnston]], Director, Operations
: [[contact::S. Maze]], Beyond Design Basis Owner, Emergency Services  
: [[contact::S. Maze]], Beyond Design Basis Owner, Emergency Services
: [[contact::M. McCoy]], NRC Interface, Regulatory Services  
: [[contact::M. McCoy]], NRC Interface, Regulatory Services
: [[contact::J. Morris]], Supervisor Compliance, Regulatory Services  
: [[contact::J. Morris]], Supervisor Compliance, Regulatory Services
: [[contact::J. Nimick]], Senior Director, Nuclear Services  
: [[contact::J. Nimick]], Senior Director, Nuclear Services
: [[contact::M. Penner]], Assistant Chief, Fire Department  
: [[contact::M. Penner]], Assistant Chief, Fire Department
: [[contact::M. Shepard]], Senior Engineer, PRA  
: [[contact::M. Shepard]], Senior Engineer, PRA
: [[contact::B. Waggener]], Engineer, Fire Protection Engineering  
: [[contact::B. Waggener]], Engineer, Fire Protection Engineering
: [[contact::T. Wernet]], Assistant Chief, Fire Department  
: [[contact::T. Wernet]], Assistant Chief, Fire Department
: [[contact::B. Wong]], Engineer, Fire Protection Engineering  
: [[contact::B. Wong]], Engineer, Fire Protection Engineering


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


None  
None


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
===Calculations===
: Number Title Revision/
: Date 134A-DC-T Associated Circuit Analysis - Fire Protection 2 134-DC Cable Data Worksheet, Auxiliary Feedwater Pump 2-3 October 12, 2007 333-DC Fuse Selection Criteria 0 335-DC Emergency Lightning and Communication 12
: 9000041846 NFPA 805 Monitoring Program - Scoping Evaluation Draft
: 9000041847 NFPA 805 Monitoring Program - Quantitative Screening Calculation Draft
: 9000041848 NFPA 805 Monitoring Program - Risk Target Value Determination Draft
: CF3.ID4 Att. 4 Nuclear Safety Capability Assessment 1 F.3.5 Probabilistic Risk Assessment, Development of Fire-
: Induced Risk Model
: F.3.11b Main Control Room Fire Modeling 3 M-1023 Cable Spreading CO
: Retention Time Verification Calculation
: M-1176 NFPA 805 Radioactive Release Review 0 M-1177 Nuclear Safety Capability Assessment 1 M-657 Document the Change in Inspection Requirements for Fire Barriers
: M-670 Penetration Seals 0 M-997 Fire Barrier Penetration Seals - Qualification of Designs 12
===Condition Reports===
(Notifications)
: 50035799
: 50035804
: 50035805
: 50035806
: 50035807
: 50035808
: 50294777
: 50356411
: 50401036
: 50541581
: 50541606
: 50687017
: 50701039
: 50774214
: 50826030*
: 50853684
: 50862125
: 50863322*
: 50873080
: 50874060*
: 50874061*
: 50874151
: 50874157*
: 50874259
: 50874454*
: 50874458*
: 50874459*
: 50874530*
: 50874531*
: 50874534*
: 50874538*
: 50874539*
: 50874551*
: 50874552*
: 50874554*
: 50874555*
: 50874561*
: 50874562*
: 50874728*
: 50874861*
: 50874862*
: 50875312*
: 50875452
: 50875509*
: 50875594*
: 50875682*
: 50875683*
: 50875684*
: 50875685*
: 50875686*
: 50875688*
: 50875689*
: 50875700*
: 50875701*
: 50875702*
: 50875703*


*Issued as a result of inspection activities.
===Drawings===
: Number Title Revision
: 102010, Sheet 3 Residual Heat Removal System 52
: 106718, Sheet 11 Yard Loop 173
: 106718, Sheet 13 Containment Structure Unit 1 20
: 106718, Sheet 14 Containment Structure Unit 2 24
: 106718, Sheet 17 Containment Structure Unit 2 146
: 106718, Sheet 2 Yard Loop 173
: 108001, Sheet 1 Piping Schematic Legend 12
: 108001, Sheet 2 Piping Schematic Legend 12
: 108001, Sheet 3 Piping Schematic Legend 11
: 108003, Sheet 1 Feedwater System 52
: 108003, Sheet 2 Feedwater System 7
: 108003, Sheet 3 Feedwater System 81
: 108003, Sheet 4 Feedwater System 67
: 108004, Sheet 3 Turbine Steam Supply System 86
: 108004, Sheet 5 Turbine Steam Supply System 101
: 108004, Sheet 7 Turbine Steam Supply System 92
===Drawings===
: 108008, Sheet 1 Chemical & Volume Control System 85
: 108008, Sheet 3 Chemical & Volume Control System 105
: 108008, Sheet 4 Chemical & Volume Control System 86
: 108008, Sheet 4 Chemical & Volume Control System 111
: 108009, Sheet 1 Safety Injection System 46
: 108009, Sheet 4 Safety Injection System 77
: 108009, Sheet 5 Safety Injection System 63
: 108012, Sheet 3 Containment Spray System 27
: 108014, Sheet 1 Component Cooling Water System 51
: 108014, Sheet 5 Component Cooling Water System 49
: 108014, Sheet 7 Component Cooling Water System 36
: 108018, Sheet 2 Yard Loop 45
: 108018, Sheet 3 Unit 1 Fuel Handling Building - Fire Water Pumps 20
: 108018, Sheet 4 Turbine Building Unit 2 Wet & Deluge Automatic Fire Sprinkler System
: 108018, Sheet 4A Turbine Building Unit 2 Wet & Deluge Automatic Fire Sprinkler System
: 108018, Sheet 5 Unit Two Fuel Handling Building 28
: 108018, Sheet 6 Carbon Dioxide Fire Protection System Hazard Spray System 37
: 108018, Sheet 6A Carbon Dioxide Fire Protection System Hosereels 35
: 108018, Sheet 7 Containment Structure 40
: 109803 Steam Generator 1 Auxiliary Feedwater Supply
: LC-86 0
: 109803 Steam Generator 4 Auxiliary Feedwater Supply
: LC-89 0
: 109803 Steam Generator 3 Auxiliary Feedwater Supply Functional Loop Diagram 
===Drawings===
: 109803 Steam Generator 4 Auxiliary Feedwater Supply
: LC-89 Functional Loop Diagram
: 109808 Functional Loop Diagram - Charging to Regenerative Heat Exchanger
: 109808 Functional Loop Diagram - Charging Header Flow Control
: FCV-128
: 109809, Sheet 3 Charging to Regenerative HX Functional Loop Diagram 3
: 109809, Sheet 19 Charging Header Flow Control
: FCV-128 5
: 111906 Auxiliary Building Elev. 128', 154' & 164' 6
: 111906 Auxiliary Building Elev. 115', Unit 2 9
: 111906 Auxiliary Building Elev. 115', Unit 1 and 2 10
: 111906 Auxiliary Building Elev. 100' 7
: 111906 Auxiliary Building Elev. 85 8
: 111906, Sheet 21 Fire Protection Drawing, Auxiliary Building Elev. 115' 10
: 111906, Sheet 25 Fire Protection Drawing, Auxiliary Building Elev. 128', 154', & 164'
: 4008751 Electrical Schematic Diagram Charging Pump No. 23 9
: 4010037 Schematic Diagram120V Nuclear Instrument AC
: System 0
: 437510 Electrical Diagram of Connections Hot Shutdown Control Panel
: 437518 Electrical Single Line Diagram for Station Auxiliaries 41
: 438145, Sheet 1 Firewater System Power Block Perimeter 38
: 438147, Sheet 1 Firewater System Profile 16
: 438149, Sheet 1 Fire Water System Profile 16
: 441220 Electrical Single Line Diagram for Station Auxiliaries 29
: 441220, Sheet 1 Single Line Diagram For Station Auxiliaries 29
===Drawings===
: 441237, Sheet 1 Single Line Meter and Relay Diagram 480 Volt System Bus Section 2F
: 441238, Sheet 1 Single Line Meter and Relay Diagram 480 Volt System Bus Section 2G
: 441239, Sheet 1 Single Line Meter and Relay Diagram 480 Volt System Bus Section 2H
: 441240, Sheet 1 Single Line Meter and Relay Diagram 125V D.C.
: System 46
: 441301
: LCV 110 Steam Gen. 21 Aux Feedwater Supply 0
: 441301
: LCV 110 Steam Gen. 21 Aux Feedwater Supply 19
: 441302 Electrical Schematic Diagram Auxiliary Feedwater Pump
: 21
: 441324 Schematic Diagram CVCS Motor Operated Valves New
: 441325 Schematic Diagram Component Cooling System Motor Operated valves
: 445290 Electrical Single Line Meter and Relay Diagram 120V
: Instrument AC System
: 500662 Electrical Conduit Layout Plan Below Elevation 140'-0" Area "H" 45
: 502689 Diagram of Connections Below Elev.112'-0" Area FE &
: FW 13
: 502941 Cable Tray and Conduit Layout Plan Below El. 115'-0" Area GE & GW
: 509603 Electrical Conduit Layout Plan at Elev. 127'-4" Area "H" 22
: 516943 Electrical Conduit Layout Plan Below El. 140'-0" Area "H" 34
: RA-13 Radiological Control Area (RC), Elevation 85 foot 8
: RA-15 Radiological Control Area (RC), Elevation 85 foot 7
: RA-17 Radiological Control Area (RC), Elevation 85 foot 9
: TB-14 Turbine Building, Elevation 85 foot 10 
: Engineering Evaluations (FHARE)
: Number Title Revision 12 Winch Cable Penetrations for Post-LOCA Sampling Room Shield Wall
: 13 Unique Blockout Penetration Seal Through Barrier Between the Unit-2 Turbine /Containment Penetration
: Areas 3 26 Non-Rated Barriers 3 80 Fire Dampers Installed at Variance with Manufacturer's Instructions
: 91 Non-Rated Barrier Between Fire Area/Zone 3BB (3CC)
and 3-P-2 (3-V-2)
: 95 Justification of Excessive Gaps on Fire Doors 0 97 Containment Electrical Penetrations 0 100 Block Walls Structurally Modified with Columns, Beams and Steel Plates
: 104 Fireproofing on Structural Steel for Block Walls 1
: Fire Impairments
: 1-TS-15-0437 2-TS-14-0251 
===Miscellaneous Documents===
: Number Title Revision/
: Date
: 2013 Fire Protection Audit August 8, 2013
: Fire Protection System Health Report - Unit 1, First Quarter March 31, 2016
: Fire Protection System Health Report - Unit 1, Second Quarter June 30, 2016
: Fire Protection Program Health Report - Unit 2, Second Quarter August 8, 2016
===Miscellaneous Documents===
: Fire Protection System Health Report - Unit 2, First Quarter March 31, 2016
: Letter from California Department of Forestry and Fire Protection - 2016 Operating Plan for On-Site Fire and
: Rescue Response at Diablo Canyon Nuclear Power
: Plant June 2, 2016 030010-RPT-01 NFPA 805 Monitoring Program Phase 2: Qualitative Review Results Draft 10083-J-JPG Specification for Furnishing and Delivering Manual/Auto Station for Diablo Canyon Power Plant
: Unit 1 & 2
: January 10, 2011 Design Criteria
: Memorandum S-18 Fire Protection System 22
: Design Criteria
: Memorandum T-13 Appendix R Fire Protection 7A
: FAQ 07-0030 Establishing Recovery Actions 5
: Final Safety Analysis Update, Appendix 9.5A Fire Hazards Analysis 22 Lesson No. R151C4 Penetration Seal/HELB 0A
: NRC Letter ML16035A441
: Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance With 10
: CFR 50.48(c) (CAC Nos. MF2333 AND MF2334)
: April 14, 2016 Operations Policy Operations Watchstander and Supervisor Expectations March 10, 2016 P1890-002-004 Diablo Canyon Power Plant Fire Protection Code Conformance Review
: PG&E Letter DCL-
: 13-065 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001
: Edition) June 26, 2013 R2044-001-3CC85 Detailed Fire Modeling Report - Fire Compartment 3-CC-85 2
===Miscellaneous Documents===
: R2165-007-001 NFPA 805 Risk Informed Performance Based Fire Risk Evaluations
: R2165-043-001 NFPA 805 Effects of Fire Suppression Activities Review 2 Ross 2171A89132 Single Solenoid Pilot Valve Installation and Maintenance Manual N/A
: Modifications Number Title Revision
: 1000024816 Design to Re-route Circuits 230D, 230D3, 230D4, and
: 230D5 out of Fire Area 5-B-4 to Ensure
: FCV-95 is Unaffected at the Control Room due to a Fire in Fire
: Area 5-B-4
: 1000024939 Replacement Vital 480V MCC Cubicles and Circuit Breakers in Bus 2G
: 1000025004 Unit 2 NFPA 805 Hot Shutdown Panel Modifications 0
: 1000025194 Establish a New Maintenance Modification Drawing (MMD) which is Essentially an "On-the-Shelf" Design Change which can be Used on As-Needed Basis
: 1000025261 Replace Circuit G12H14 Wire E12 Using a Spare Wire from Circuit GSP29 Located in Cubicle SHG11
: 2000001367 Unit 2 NFPA 805 Hot Shutdown Panel (HSDP)
: Upgrade 0
: 2000001368 NFPA 805 Hot Shutdown Panel Upgrade 0
: Plant Change Evaluations
: DDP 1000025244 
===Procedures===
: Number Title Revision AR PK10-10 Annunciator Response Fire Detected 7A AWP E-028 PRA Model Maintenance and Upgrades 2
===Procedures===
: CP M-10 Fire Protection of Safe Shutdown Equipment 37 CP M-10 (Unit 2) Fire Protection of Safe Shutdown Equipment 35 CP M-6 Fire 35
: EDDG-05 Fuse Control Program 0
: EDMG
: EDG-12 Start Diesel Generator Without DC Power 1
: EDMG
: EDG-14 EDMG Equipment Annual Inventory 3
: MA1.DC54 Conduct of Maintenance 11 MP E-41.1A Maintenance of Westinghouse
: DB-50 480V Circuit Breakers 35 MP E-62.2A Maintenance of General Electric 12kV Power-VAC
: Circuit Breakers
: MP E-62.5A Maintenance of Cutler Hammer 12kV
: AM-VR Vacuum Circuit Breakers
: MP E-63.6A Maintenance of SF6 4kV Circuit Breakers 24A MP E-64.1A Molded Case Circuit Breaker Testing 42 MP E-64.5A Maintenance of ABB,
: ITE-Type K-3000 Circuit Breakers 8 MP E-64.6A Maintenance of ABB K-Line Circuit Breakers 42 MP E-64.6C Post Overhaul Inspection of ABB K-Line Circuit Breakers 0 MP E-67.5A Testing and Maintenance of Battery Operated Lights Inside Power Block
: OM8.ID2 Fire System Impairment 19
: OM8.ID4 Control of Flammable and Combustible Materials 25
: OM8.ID5 Fire Protection Program Administration 0
: OM8.ID6 Fire Protection Change Evaluation 0A
: OM8.ID17 NFPA 805 Fire Protection Monitoring Program Draft OP A-4A:I Pressurizer - Make Available 25 OP
: AP-8A (Unit 2) Control Room Inaccessibility - Establishing Hot 31
===Procedures===
: Standby OP C-2:II Main Steam and Steam Dump System - Local Operation of Steam Dumps
: OP K-2C Fire Protection Network Operation 43
: PMT 08.38 Hot Shutdown Panel (HSDP) NFPA 805 Modifications Functional Tests
: STP M-63C Fire Water System Functional Test of the Fuel Handling and Radwaste Buildings
: STP M-63E Fire Water System Yard Loop Flush 7 STP M-69A Monthly Fire Extinguisher Station Inspection Inside the Protected Area
: STP M-70B Inspection and Testing of Fire Dampers 18 STP M-70D Inspection of Fire Barriers, Rated Enclosures, Credited Cable Tray Fire Stops, and Equipment Hatches
: STP M-70D Inspection of Fire Barriers, Rated Enclosures, Credited Cable Tray Fire Stops, and Equipment Hatches
: STP M-71 Firewater System Flow Test 9 STP P-AFW-23 Routine Surveillance Test of Motor-Driven Auxiliary Feedwater Pump 2-3
: STP P-CCP-23 Routine Surveillance Test of Centrifugal Charging Pump 2-3 5A STP P-FPP-A01 Fire Pump 0-1 Performance Test 5 STP P-FPP-A01 Fire Pump 0-1 Performance Test 6 STP P-FPP-A02 Fire Pump 0-2 Performance Test 6 STP P-FPP-A02 Fire Pump 0-2 Performance Test 7
: STP P-FPP-A03 Fire Pump 0-3 Performance Test 12
: STP P-FPP-A04 Fire Pump 0-4 Performance Test 13
: STP P-FPP-A04 Fire Pump 0-4 Performance Test 14
===Procedures===
: STP P-FPP-B01 Fire Pump 0-1 Routine Surveillance 12 STP P-FPP-B02 Fire Pump 0-2 Routine Surveillance 13 STP P-FPP-B03 Fire Pump 0-3 Routine Surveillance 9A STP P-FPP-B04 Fire Pump 0-4 Routine Surveillance 8A
: STP V-2U3D Exercising SG No. 3 AFW Supply Valves
: LCV-108 and
: LCV-115 10 STP V-2U4D Exercising SG No. 4 AFW Supply Valves
: LCV-109 and
: LCV-113 10
: TQ1.DC12 Fire Brigade and Emergency Response Training 14
: RiskMan Probabilistic Risk Assessment Sequences
: ZXU2RNCI Sequence 1 ZXU2RNCI Sequence 2 ZXU2RNCI Sequence 3
: ZXU2RNCI Sequence 4
: ZXU2RNCI Sequence 5
: ZXU2RNCI Sequence 6 ZXU2RNCI Sequence 7 ZXU2RNCI Sequence 8 ZXU2RNCI Sequence 9
: ZXU2RNCI Sequence 10
: ZXU2RNCI Sequence 11
: ZXU2RNCI Sequence 12 ZXU2RNCI Sequence 13 ZXU2RNCI Sequence 14 ZXU2RNCI Sequence 15
: ZXU2RNCI Sequence 16
: Vendor Documents Number Title Revision
: NUS-A228MA AMS826 Operation & Maintenance Manual 4 
===Work Orders===
: 64062002
: 64066747
: 64096685
: 64096686
: 64099553
: 64101178
: 64102233
: 64105328
: 64108872
: 64109461
: 64110352
: 64123318
: 64123928
: 64131502
: 64132473
: 64137386
: 64152013
: 64152028
: 64152191
: 64152372
: 64152382
}}
}}

Latest revision as of 18:06, 19 December 2019

NRC Triennial Fire Protection Inspection Report 05000275/2016008 and 05000323/2016008
ML16321A443
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/15/2016
From: Greg Werner
NRC/RGN-IV/DRS/EB-2
To: Halpin E
Pacific Gas & Electric Co
References
IR 2016008
Download: ML16321A443 (30)
v • d • e


Text

November 15, 2016

SUBJECT:

DIABLO CANYON POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000275/2016008 AND 05000323/2016008

Dear Mr. Halpin:

On October 20, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2, and discussed the results of this inspection with Mr. J. Nimick, Senior Director, Nuclear Services, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection. However, the team documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Diablo Canyon Power 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/

Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-275 and 50-323 License Nos. DPR-80 and DPR-82

Enclosure:

Inspection Report No. 05000275/2016008 and 05000323/2016008, w/Attachment:

Supplemental Information

REGION IV==

Dockets: 05000275 and 05000323 Licenses: DPR-80 and DPR-82 Report Nos.: 05000275/2016008 and 05000323/2016008 Licensee: Pacific Gas and Electric Company Facility: Diablo Canyon Power Plant, Units 1 and 2 Location: 7 1/2 miles NW of Avila Beach Avila Beach, CA Dates: October 3 to October 20, 2016 Team Leader: S. Alferink, Reactor Inspector, Engineering Branch 2 Team: S. Graves, Senior Reactor Inspector, Engineering Branch 2 J. Mateychick, Senior Reactor Inspector, Engineering Branch 2 S. Makor, Reactor Inspector, Engineering Branch 2 E. Uribe, Project Engineer, Inspection Program and Assessment Team D. Loveless, Senior Reactor Analyst, Plant Support Branch 2 Accompanying B. Metzger, Fire Protection Engineer, Office of Nuclear Reactor Personnel: Regulation, Division of Risk Assessment, Fire Protection Branch Approved By: Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000275/2016008 and 05000323/2016008; 10/03/2016 - 10/20/2016; Diablo Canyon

Power Plant; Triennial Fire Protection Team Inspection.

The report covers a two-week triennial fire protection team inspection by specialist inspectors from Region IV. One licensee-identified finding, which was a non-cited violation, was documented. The significance of inspection findings is indicated by their color (i.e., Green,

White, Yellow, or Red) and determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated August 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

None

Licensee-Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the team. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and the corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection

Main article: IP 71111.05XT

This report presents the results of a triennial fire protection team inspection conducted at the Diablo Canyon Power Plant in accordance with NRC Inspection Procedure 71111.05XT, Fire Protection - NFPA 805 (Triennial), dated January 31, 2013. The team reviewed the licensees fire protection program against the requirements of National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as incorporated by Title 10 of the Code of Federal Regulations (10 CFR) 50.48(c). The NFPA 805 standard establishes a comprehensive set of requirements for fire protection programs at nuclear power plants. The standard incorporates both deterministic and risk-informed, performance-based concepts. The inspection team evaluated the implementation of the approved fire protection program in selected risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and systems that ensure the plant can achieve and maintain a safe and stable condition.

Inspection Procedure 71111.05XT requires the selection of three to five fire areas and one or more mitigating strategies for review. The team used the fire hazards analysis section of the Diablo Canyon Power Plant NFPA 805 fire probabilistic risk assessment to select the following five risk-significant fire areas (inspection samples) for review:

Fire Description Category Area 3-CC Containment Penetration Rooms (All Elevations) Performance-Based 6-B-1 Battery, Inverter, and Switchgear Room (Bus F) Performance-Based 6-B-2 Battery, Inverter, and Switchgear Room (Bus G) Performance-Based 6-B-3 Battery, Inverter, and Switchgear Room (Bus H) Performance-Based 7B Cable Spreading Room Primary Control Station The team evaluated the licensees fire protection program using the applicable requirements, which included the plant Technical Specifications, Operating License Conditions 2.C.(4) and 2.C.(5), NRC safety evaluations, 10 CFR 50.48, and NFPA 805.

The team also reviewed related documents that included the Final Safety Analysis Report (FSAR), Section 9.5.1; the nuclear safety capability assessment; and the fire safety analysis. Specific documents reviewed by the team are listed in the attachment.

Five fire area inspection samples and one mitigating strategy sample were completed.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the nuclear safety capability assessment, piping and instrumentation diagrams, and fire response procedures to verify that a safe shutdown success path, free of fire damage, would be available to meet the nuclear safety goals, objectives, and performance criteria in the event of a fire under any plant operational mode or configuration.

The team reviewed applicable sections of the fire response procedures for the selected fire areas and their associated fire scenarios to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe and stable plant conditions.

The team performed a walkdown of the procedure to verify that recovery actions credited to achieve the nuclear safety performance criteria were feasible. The team evaluated the feasibility of the recovery actions against the criteria established in the licensees fire protection program as approved in the safety evaluation report. Specifically, the team verified that licensee personnel credited for procedure implementation had procedures available, were trained on implementation, and were available in the event a fire occurred. The team also verified that the operators could reasonably be expected to perform the recovery actions within the time required to maintain plant parameters within specified limits.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe the material condition and configuration of the installed fire area boundaries (including walls, fire doors, and fire dampers) and verify that the electrical raceway fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.

The team reviewed installation, repair, and qualification records for a sample of penetrations and openings to verify the fill material possessed an appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design.

The team also reviewed completed surveillance and maintenance records for selected fire dampers, fire doors, and fire barrier seals to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected fire areas. The team verified the automatic detection systems and the manual and automatic suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association code of record or approved deviations and that each suppression system was appropriate for the hazards in the selected fire areas.

The team performed a walkdown of accessible portions of the detection and suppression systems in the selected fire areas and the major system support equipment in other areas (e.g., fire pumps, carbon dioxide supply systems, and hose stations) to assess the material condition, design, and operational lineup, operational availability, and operational effectiveness of these systems and components.

The team reviewed flow and pressure tests for electric fire pumps 0-1 and 0-2 and the raw water reservoir to verify that the pumps and gravity-fed water supply systems met their design requirements. The team also reviewed the suppression system functional tests to verify that the system capability met the design requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify the success path necessary to achieve and maintain the nuclear safety performance criteria and to facilitate suppression of a fire that could impact the ability to achieve and maintain safe and stable plant conditions.

In addition, the team inspected fire brigade equipment to determine operational readiness for fire fighting.

The team observed an unannounced fire drill and subsequent drill critique on October 19, 2016, using the guidance contained in Inspection Procedure 71111.05AQ, Fire Protection Annual/Quarterly, dated September 30, 2010. The team observed fire brigade members fight a simulated fire in the Unit 2 12kV switchgear room (Fire Area 20). The team verified that the licensee identified problems, openly discussed them in a self-critical manner at the drill debrief, and identified appropriate corrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;
(2) proper use and layout of fire hoses;
(3) employment of appropriate firefighting techniques;
(4) sufficient firefighting equipment was brought to the scene;
(5) effectiveness of fire brigade leader communications, command, and control;
(6) search for victims and propagation of the fire into other areas;
(7) smoke removal operations;
(8) utilization of pre-planned strategies;
(9) adherence to the pre-planned drill scenario; and
(10) drill objectives.

b. Findings

A licensee-identified non-cited violation in this inspection area is documented in Section 4OA7 of this report.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team performed a plant walkdown and reviewed documents to verify that one success path necessary to achieve and maintain the nuclear safety performance criteria would be maintained free of fire damage by a single fire. Specifically, the team verified:

  • A fire in one of the selected fire areas would not indirectly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage the success path necessary to achieve and maintain the nuclear safety performance criteria.
  • A fire in one of the selected fire areas that may result in the use of a manually activated fire suppression system would not indirectly cause damage to the success path necessary to achieve and maintain the nuclear safety performance criteria.
  • The inadvertent actuation of an automatic or manual fire suppression system or the rupture of a fire suppression system would not indirectly cause damage to the success path necessary to achieve and maintain the nuclear safety performance criteria.
  • Adequate drainage was provided in areas protected by water suppression systems.

b. Findings

No findings were identified.

.05 Shutdown from a Primary Control Station

a. Inspection Scope

Review of Methodology The team reviewed the nuclear safety capability assessment, procedures, piping and instrumentation drawings, electrical drawings, and other supporting documents to verify that the licensee can achieve and maintain safe and stable plant conditions from the primary control station in the event a fire required evacuation of the control room.

The team verified that the nuclear safety capability assessment properly identified the components and systems necessary to meet the nuclear safety performance criteria for the fire area selected. Specifically, the team determined the adequacy of the systems selected to meet the criteria for reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries, and process monitoring. For the primary control station, which was analyzed using a performance-based approach, the team verified that the analysis included a consideration of all the necessary cables and equipment associated with operation and control of both alternating current

(ac) and direct current
(dc) power supplies.

The team verified that the transfer of command and control from the control room to the primary control station would be unaffected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for shutdown control circuits).

Review of Operational Implementation The team verified that the training program for licensed and non-licensed operators included the procedures for achieving and maintaining safe and stable plant conditions, including any necessary recovery actions. The team also verified that sufficient personnel required to achieve and maintain safe and stable plant conditions were properly trained and were available at all times among the normal on-site staff, exclusive of the fire brigade.

The team performed a timed walkdown of the procedure for shutdown from outside of the control room on Unit 2 with licensed and non-licensed operators to determine the adequacy of the procedure. The team verified that the recovery actions taken were feasible and that operators could reasonably be expected to implement the procedure within the applicable time requirements to achieve the nuclear safety performance criteria. The team evaluated the feasibility of the recovery actions using the criteria established in the licensees approved fire protection program.

The team also verified that the licensee conducted periodic operational tests of the transfer and isolation capability and instrumentation and control functions used for transferring control from the main control room to the primary control station and other locations where recovery actions would be performed. The team verified that the tests were adequate to prove the functionality of the primary control stations capability to meet performance criteria and achieve and maintain safe and stable plant conditions.

b. Findings

No findings were identified.

.06 Circuit Analysis

a. Inspection Scope

The team reviewed the nuclear safety capability assessment to verify that the licensee identified the circuits required for nuclear safety functions and protected these circuits in accordance with the deterministic approach or provided an appropriate level of protection based on the results of an analysis using an acceptable risk-informed, performance-based approach. The team verified, on a sample basis, that the licensee properly identified circuits that may impact the nuclear safety performance criteria. The team verified that these circuits were either adequately protected from the potentially adverse effects of fire damage or were analyzed to show that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not affect the capability to meet the nuclear safety performance criteria. The team verified that the licensees analyses considered potential spurious operations due to fire-induced cable faults.

The team focused on cables from the following components:

  • CCW-2-FCV-356-DO, reactor coolant pump barrier component cooling water return valve
  • CVCS-2-8108, charging line isolation motor-operated valve
  • E-2-PY23-AV, vital instrument alternating current distribution panel For the sample of components selected, the team reviewed process and instrumentation drawings and electrical elementary and block diagrams, and the team identified power, control, and instrument cables necessary to support their operation. In addition, the team reviewed cable routing information to verify that fire protection features were in place as needed to satisfy the separation requirements specified in the fire protection license basis.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team inspected the designated emergency communication radios and storage locations and reviewed the procedure for shutdown from outside of the control room to verify that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities.

The team verified the capability of the communication systems to support the operators in the conduct and coordination of their required actions. The team also verified that the design and location of communications equipment such as repeaters and transmitters would not cause a loss of communications during a fire. The team discussed system design, testing, and maintenance with the system engineer.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team reviewed the emergency lighting provided, both in fixed and portable form, along access and egress routes and at control stations, plant parameter monitoring locations, and recovery action locations. The team verified that the emergency lighting was adequate for operators to perform the required recovery actions during a walkdown of the procedure for shutdown from outside of the control room. Specifically, the team verified:

  • The battery power supplies had a capacity sufficient to support recovery actions necessary to meet the nuclear safety performance criteria.
  • The illumination was sufficient for operators to perform the required recovery actions for a shutdown from outside the control room.
  • The operability testing and maintenance of the emergency lighting followed licensee procedures and accepted industry practice.
  • The emergency lighting batteries were maintained consistent with the manufacturers recommendations.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team determined that the licensee did not credit cold shutdown repairs to meet the nuclear safety performance criteria. The team reviewed the nuclear safety capability assessment and interviewed licensee personnel and determined that the licensee does not require transitioning to cold shutdown to achieve a safe and stable plant condition.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and success path equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing nuclear safety functions or capabilities for meeting performance criteria) necessary to achieve and maintain safe and stable plant conditions. The team also verified that the short-term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.

The licensee identified multiple variations from deterministic requirements during the development of the risk-informed, performance-based fire protection program which required plant modifications to resolve. License Conditions 2.C.(5) and 2.C.(4),

Fire Protection, for Units 1 and 2, respectively, discuss the transition period. The license conditions require these modifications to be completed by the end of refueling outages 1R20 (April/May 2017) for Unit 1 and 2R20 (February/March 2018) for Unit 2.

The license conditions require the licensee to maintain appropriate compensatory measures in place until completion of the modifications. The licensees compensatory measures consisted of hourly fire watches and the continued use of the post-fire safe shutdown procedures developed under the previous deterministic fire protection program. The team reviewed the compensatory measures and found the compensatory measures to be adequate.

b. Findings

No findings were identified.

.11 Radiological Release

a. Inspection Scope

The team verified that the licensee provided reasonable assurance that a fire would not result in a radiological release that adversely affects the public, plant personnel, or the environment. The team also verified that the licensee determined that any radiation release to any unrestricted area resulting from fire suppression activities (but not involving fuel damage) was as low as reasonably achievable and would not exceed applicable 10 CFR Part 20 limits. The team verified that the licensee analyzed the radioactive release on a fire area basis. The team walked down the selected fire zones and verified that the pre-fire plan tactics and instructions were consistent with the potential radiological conditions identified in the analyses.

b. Findings

No findings were identified.

.12 Non-Power Operations

a. Inspection Scope

The plant did not enter an outage during the inspection. However, the team verified that the licensee performed the following activities:

  • Defined higher risk evolutions that are performed during outages.
  • Defined the key safety functions required to maintain the plant in a safe and stable condition during non-power operational modes.
  • Performed the nuclear safety capability assessment during non-power operations and defined specific pinch points where one or more key safety functions could be lost.
  • Established additional fire protection defense-in-depth actions to be taken during higher risk evolutions in the locations of the pinch points where key safety functions could be lost.

b. Findings

No findings were identified.

.13 Monitoring Program

a. Inspection Scope

The team verified that the licensee had developed a draft monitoring program to ensure that the availability and reliability of the fire protection systems, structures, and components credited in the performance-based analyses are maintained and to assess the performance of the fire protection program in meeting the nuclear safety performance criteria.

The team noted that the licensee was in the transition period and was not required to have a monitoring program fully implemented until April 14, 2017. The team verified that the draft monitoring program ensured the assumptions in the engineering analyses remained valid with the possible exception of the condition described in the draft Frequently Asked Question 10-0059. The licensee stated that they intended to address the conclusions of this frequently asked question prior to full program implementation.

The team determined that the licensee had not yet developed established levels of availability, reliability, and performance in accordance with its license condition.

b. Findings

No findings were identified.

.14 Plant Change Evaluation

a. Inspection Scope

The team reviewed the one plant change evaluation that the licensee had performed under the NFPA 805 program to verify that, where performance-based methods were applied, the methods adequately represented plant design and conditions in the fire area were performed by qualified people, were acceptable for the application, and met the requirements of the fire protection license condition for self-approved changes to the fire protection program.

The team reviewed the following change:

  • DDP-1000025244-000-00, Incipient Detection

b. Findings

No findings were identified.

.15 Alternative Mitigation Strategy Inspection Activities

a. Inspection Scope

The team reviewed the licensees implementation of guidance and strategies intended to maintain or restore core, containment, and spent fuel pool cooling capabilities under the circumstances associated with the potential loss of large areas of the plant due to explosions or fire as required by 10 CFR 50.54(hh)(2).

The team verified that the licensee implemented and maintained adequate procedures, maintained and tested equipment necessary to properly implement the strategies, and ensured station personnel were knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure the availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verified the availability of on-site vehicles capable of towing the portable pump. The team assessed the off-site ability to obtain fuel for the portable pump and foam used for fire fighting efforts. The strategy and procedure selected for this inspection sample included:

  • Extensive Damage Mitigation Guideline EDG-12, Start Diesel Generator Without DC Power

b. Findings

No findings were identified.

OTHER ACTIVITIES (OA)

4OA2 Identification and Resolution of Problems

Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team selected a sample of condition reports associated with the licensee's fire protection program to verify that the licensee had an appropriate threshold for identifying deficiencies. The team reviewed the corrective actions proposed and implemented to verify that they were effective in correcting identified deficiencies. The team evaluated the quality of recent engineering evaluations through a review of condition reports, calculations, and other documents during the inspection.

b. Findings

No findings were identified.

4OA5 Other Activities

The team reviewed corrective actions and training associated with Notification NN 50687017 written for site fire department activities related to fire protection program equipment maintenance and testing. The team did not identify any significant issues with licensee corrective actions or training in this area.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the inspection results to Mr. J. Nimick, Senior Director, Nuclear Services, and other members of the licensee staff at an exit meeting on October 20, 2016. The licensee acknowledged the finding presented.

The team verified that no proprietary information was retained by the team or documented in this report.

4OA7 Licensee-Identified Violations

The following licensee-identified violation of NRC requirements was determined to be of very low safety significance and met the NRC Enforcement Policy criteria for being dispositioned as a non-cited violation.

  • License Conditions 2.C.(5) for Unit 1 and 2.C.(4) for Unit 2 state, in part, that the licensee shall implement and maintain all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request, dated June 26, 2013, and as approved in the safety evaluation, dated April 14, 2016. Section 3.2.3 of Attachment A of the license amendment request states, in part:

Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:

Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.

Equipment Control Guideline 18.1, Fire Suppression Systems/Fire Suppression Water Systems, provided the requirements to demonstrate the operability of the fire suppression water system. Equipment Control Guideline Surveillance Requirement 18.1.10 required the licensee to perform a flow test of the fire suppression water system in accordance with Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition. Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition, stated, in part, that tests should be conducted in such a way that the available flow and pressure at high value or hazardous areas can be determined readily.

Contrary to the above, prior to October 20, 2016, the licensee failed to implement all provisions of the approved fire protection program. Specifically, during the flow tests, the licensee failed to establish surveillance test procedures that measured pressure values for one of the three fire suppression water subsystems using the methodology in Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition.

The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened in accordance with Inspection Manual Chapter 0609, Appendix F, dated September 20, 2013. The finding was determined to be of very low safety significance (Green) in Task 1.4.7, Fire Water Supply, Question A. Although the licensee did not measure and record fire main pressure, they did measure flow and it was greater than 50 percent of the required capacity. The finding was entered into the licensees corrective action program as Notifications NN 50853684 and NN 50863322.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

A. Arsene, Engineer, Fire Protection Engineering
A. Chitwood, Shift Manager, Operations
D. Ensminger, Chief, Fire Department
L. Fusco, Manager, Engineering
J. Gregerson, Engineer, Fire Protection Engineering
D. Hampshire, Supervisor, Fire Protection Engineering
H. Hamzehee, Manager, Regulatory Services
A. Heffner, NRC Interface, Regulatory Services
D. Hromyak, Engineer, Fire Protection Engineering
K. Johnston, Director, Operations
S. Maze, Beyond Design Basis Owner, Emergency Services
M. McCoy, NRC Interface, Regulatory Services
J. Morris, Supervisor Compliance, Regulatory Services
J. Nimick, Senior Director, Nuclear Services
M. Penner, Assistant Chief, Fire Department
M. Shepard, Senior Engineer, PRA
B. Waggener, Engineer, Fire Protection Engineering
T. Wernet, Assistant Chief, Fire Department
B. Wong, Engineer, Fire Protection Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

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