IR 05000298/2016008: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:September 26, 2016
{{#Wiki_filter:ber 26, 2016


==SUBJECT:==
==SUBJECT:==
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The NRC team did not identify any findings or violations of more than minor significance.
The NRC team did not identify any findings or violations of more than minor significance.


In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronic ally for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,
Sincerely,
/RA/ Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety  
/RA/
Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-298 License No. DPR-46


Docket No. 50-298 License No. DPR-46
===Enclosure:===
Inspection Report 05000298/2016008 w/Attachment: Supplemental Information


Enclosure: Inspection Report 05000298/2016008 w/Attachment: Supplemental Information
REGION IV==
Docket: 05000298 License: DPR-46 Report Nos.: 05000298/2016008 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Ave Brownville, NE Dates: August 8 through August 26, 2016 Team Leader: J. Mateychick, Senior Reactor Inspector, Engineering Branch 2 Team: S. Alferink, Reactor Inspector, Engineering Branch 2 G. Pick, Senior Reactor Inspector, Engineering Branch 2 J. Watkins, Reactor Inspector, Engineering Branch 2 R. Deese, Senior Reactor Analyst, Plant Support Branch 2 Accompanying P. Lain, Senior Fire Protection Engineer, Office of Nuclear Reactor Personnel: Regulation, Division of Risk Assessment Approved By: Gregory E. Werner Chief, Engineering Branch 2 Division of Reactor Safety Enclosure


cc w/enclosure: Electronic Distribution September 26, 2016  
=SUMMARY=
IR 05000298/2016008; 08/08/2016 - 08/26/2016; Cooper Nuclear Station; Triennial Fire


Mr. Oscar
Protection Team Inspection.


=SUMMARY=
The report covers a two-week triennial fire protection team inspection by specialist inspectors from Region IV. No findings were 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.
IR 05000298/2016008; 08/08/2016 - 08/26/2016; Cooper Nuclear Station; Triennial Fire Protection Team Inspection.


The report covers a two-week triennial fire protection team inspection by specialist inspectors from Region IV. No findings were 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.
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===


None
None


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


None
None
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==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 Cooper Nuclear Station 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 condition.
This report presents the results of a triennial fire protection team inspection conducted at Cooper Nuclear Station 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  
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 Cooper Nuclear Station NFPA 805 fire probabilistic risk assessment to select the following four risk-significant fire areas (inspection samples) for review:
Fire Area                    Description                            Category CB-D        Control Room, Computer Room, Cable                Performance-Based /
Spreading Room, Cable Expansion Room,              Primary Control Station Auxiliary Relay Room DG-A        Diesel Generator Room 1A                          Deterministic RB-FN        Reactor Building 903 Northeast Corner            Performance-Based RB-M        Reactor Building South West Corner, RHR            Performance-Based Heat Exchanger Room B and RWCU Hear Exchanger Room 932 Since this was the first triennial inspection following NRC approval of the risk-informed, performance-based fire protection program, the team reviewed samples of the implementation items required to be completed in accordance with Operating License Condition 2.C.(4). The team also reviewed samples of the plant modifications credited to support the approved fire protection program.


section of the Cooper Nuclear Station NFPA 805 fire probabilistic risk assessment to select the following four risk-significant fire areas (inspection samples) for review:
The team evaluated the licensees fire protection program using the applicable requirements, which included the plant Technical Specifications, Operating License Condition 2.C.(4), NRC safety evaluations, 10 CFR 50.48, and NFPA 805. The team also reviewed related documents that included the final safety analysis report, the nuclear safety capability assessment, and the fire safety analysis. Specific documents reviewed by the team are listed in the attachment.
Fire Area Description Category CB-D Control Room, Computer Room, Cable Spreading Room, Cable Expansion Room, Auxiliary Relay Room Performance-Based / Primary Control Station DG-A Diesel Generator Room 1A Deterministic RB-FN Reactor Building 903' Northeast Corner Performance-Based RB-M Reactor Building South West Corner, RHR Heat Exchanger Room B and RWCU Hear Exchanger Room 932' Performance-Based Since this was the first triennial inspection following NRC approval of the risk-informed, performance-based fire protection program, the team reviewed samples of the implementation items required to be completed in accordance with Operating License Condition 2.C.(4). The team also reviewed samples of the plant modifications credited to support the approved fire protection program.
 
The team evaluated the licensee's fire protection program using the applicable requirements, which included the plant Technical Specifications, Operating License Condition 2.C.(4), NRC safety evaluations, 10 CFR 50.48, and NFPA 805. The team also reviewed related documents that included the final safety analysis report, the nuclear safety capability assessment, and the fire safety analysis. Specific documents reviewed by the team are listed in the attachment.


Four fire area inspection samples and two mitigating strategy samples were completed.
Four fire area inspection samples and two mitigating strategy samples 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 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 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.
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====
====b. Findings====
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The team walked down accessible portions of the selected fire areas to observe the material condition and configuration of the installed fire area boundaries (including walls, fire doors, and fire dampers) and verify that the fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.
The team walked down accessible portions of the selected fire areas to observe the material condition and configuration of the installed fire area boundaries (including walls, fire doors, and fire dampers) and verify that the fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.


The team reviewed installation, repair, and qualification records for a sample of penetration seals to ensure that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design. The team reviewed modifications related to the conversion to a risk-informed fire protection  
The team reviewed installation, repair, and qualification records for a sample of penetration seals to ensure that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design. The team reviewed modifications related to the conversion to a risk-informed fire protection program.
 
program.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====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 verified that the licensee had appropriately reduced the frequencies of fire protection surveillances. The licensee implemented the process described in Electric Power Research Institute Technical Report 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features."
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 verified that the licensee had appropriately reduced the frequencies of fire protection surveillances. The licensee implemented the process described in Electric Power Research Institute Technical Report 1006756, Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features.


The team walked down accessible portions of the detection and suppression systems in the selected fire areas. The team walked down major system support equipment in other areas (e.g., fire pumps and Halon supply systems) to assess the material condition  
The team walked down accessible portions of the detection and suppression systems in the selected fire areas. The team walked down major system support equipment in other areas (e.g., fire pumps and Halon supply systems) to assess the material condition of these systems and components.


of these systems and components.
The team reviewed the flow and pressure tests for electric and diesel fire pumps to verify that the pumps met their design requirements. The team also reviewed the Halon suppression functional tests to verify that the system capability met the design requirements.
 
The team reviewed the flow and pressure tests for electric and diesel fire pumps to verify  
 
that the pumps met their design requirements. The team also reviewed the Halon suppression 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 safe shutdown equipment and instrumentation and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. In addition, the team inspected fire brigade equipment to determine operational readiness for firefighting.
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 safe shutdown equipment and instrumentation and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. In addition, the team inspected fire brigade equipment to determine operational readiness for firefighting.


The team observed an unannounced fire drill and subsequent drill critique on August 26, 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 at the station startup transformer. 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 August 26, 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 at the station startup transformer. 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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====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 AC and DC power supplies.
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 AC and DC power supplies.
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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.
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 Procedure 5.4FIRE-S/D, "Fire Induced Shutdown from Outside Control Room," Revision 65, 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 Procedure 5.4FIRE-S/D, Fire Induced Shutdown from Outside Control Room, Revision 65, 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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The team reviewed the nuclear safety capability assessment to verify that the licensee identified the circuits that may impact the ability to achieve and maintain safe and stable conditions. The team verified, on a sample basis, that the licensee properly identified the cables for equipment required to achieve and maintain safe and stable conditions in the event of a fire in the selected fire areas. The team verified that these cables 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 prevent achieving safe and stable conditions. The team verified that the licensee's analysis 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 that may impact the ability to achieve and maintain safe and stable conditions. The team verified, on a sample basis, that the licensee properly identified the cables for equipment required to achieve and maintain safe and stable conditions in the event of a fire in the selected fire areas. The team verified that these cables 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 prevent achieving safe and stable conditions. The team verified that the licensee's analysis considered potential spurious operations due to fire-induced cable faults.


The team's evaluation focused on the cables of selected components from the high pressure core injection system, the residual heat removal system, the automatic depressurization system, motor-operated valves, the alternate shutdown panel, isolation and transferring control equipment and the local alternate shutdown panels. 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 and conduit 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. Specific components reviewed by the team are listed in the  
The teams evaluation focused on the cables of selected components from the high pressure core injection system, the residual heat removal system, the automatic depressurization system, motor-operated valves, the alternate shutdown panel, isolation and transferring control equipment and the local alternate shutdown panels. 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 and conduit 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. Specific components reviewed by the team are listed in the attachment.
 
attachment.


====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.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the licensee's approved fire protection program, implementing procedures, and programs for the control of ignition sources and transient combustibles. The team assessed the licensee's effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The team performed plant walk downs to independently verify that transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.
The team reviewed the licensees approved fire protection program, implementing procedures, and programs for the control of ignition sources and transient combustibles.
 
The team assessed the licensees effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The team performed plant walk downs to independently verify that transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.


====b. Findings====
====b. Findings====
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=====Introduction.=====
=====Introduction.=====
The team identified an unresolved item associated with the licensee's implementation of the monitoring program required in Section 2.6 of National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants."  Specifically, the team required additional information to determine whether the licensee's actions to set the action levels for the availability of some plant components at the components' maintenance rule monitoring values and the licensee's performance of a risk-informed sensitivity analysis to ensure that the assumptions in the engineering analysis remained valid were acceptable.
The team identified an unresolved item associated with the licensees implementation of the monitoring program required in Section 2.6 of National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants. Specifically, the team required additional information to determine whether the licensees actions to set the action levels for the availability of some plant components at the components maintenance rule monitoring values and the licensees performance of a risk-informed sensitivity analysis to ensure that the assumptions in the engineering analysis remained valid were acceptable.


=====Description.=====
=====Description.=====
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Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid.
Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid.


The team reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, "NFPA 805 Monitoring Program," Revision 0, to ensure that the licensee's program properly implemented the requirements of NFPA 805, Section 2.6. The team also reviewed Engineering Report Number ER2015-002, "NFPA 805 Fire Protection Monitoring Program," Revision 2.
The team reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, NFPA 805 Monitoring Program, Revision 0, to ensure that the licensees program properly implemented the requirements of NFPA 805, Section 2.6. The team also reviewed Engineering Report Number ER2015-002, NFPA 805 Fire Protection Monitoring Program, Revision 2.


The team observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule monitoring program. These components included the:
The team observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule monitoring program. These components included the:
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* Service water pumps The team noted that the action levels for availability in the maintenance rule monitoring program were greater than the assumptions in the fire probabilistic risk assessment.
* Service water pumps The team noted that the action levels for availability in the maintenance rule monitoring program were greater than the assumptions in the fire probabilistic risk assessment.


With this observation, the team questioned the licensee as to whether this met the requirement in NFPA 805 to maintain the assumptions in the engineering analysis. The licensee informed the team that they had performed a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule. This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability. This increase in core damage frequency was then determined to be acceptable if it did not exceed 1.0E-6/year. The team noted that for an individual component this screening criterion would not exceed more than 2 percent of the licensee's baseline fire core damage frequency.
With this observation, the team questioned the licensee as to whether this met the requirement in NFPA 805 to maintain the assumptions in the engineering analysis.
 
The licensee informed the team that they had performed a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule. This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability. This increase in core damage frequency was then determined to be acceptable if it did not exceed 1.0E-6/year. The team noted that for an individual component this screening criterion would not exceed more than 2 percent of the licensees baseline fire core damage frequency.


The team was aware that some particular aspects of the monitoring program were being discussed between the industry and the NRC's Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question 10-0059, "NFPA 805 Monitoring."  The monitoring program and the sensitivity analysis approach used by the licensee are enveloped in these discussions.
The team was aware that some particular aspects of the monitoring program were being discussed between the industry and the NRCs Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question 10-0059, NFPA 805 Monitoring. The monitoring program and the sensitivity analysis approach used by the licensee are enveloped in these discussions.


The team determined that additional information is required to determine if a performance deficiency exists. Specifically, the team needed to determine if the licensee's action to set the action levels for the availability of some plant components at the components' maintenance rule monitoring values and the performance of a risk-informed sensitivity analysis in an attempt to ensure that the assumptions in the engineering analysis remained valid would be an acceptable approach. Judgment on the suitability of this approach is pending further resolution of the monitoring program during discussions of Frequently Asked Question 10-0059, "NFPA 805 Monitoring."
The team determined that additional information is required to determine if a performance deficiency exists. Specifically, the team needed to determine if the licensees action to set the action levels for the availability of some plant components at the components maintenance rule monitoring values and the performance of a risk-informed sensitivity analysis in an attempt to ensure that the assumptions in the engineering analysis remained valid would be an acceptable approach. Judgment on the suitability of this approach is pending further resolution of the monitoring program during discussions of Frequently Asked Question 10-0059, NFPA 805 Monitoring.


The licensee entered this issue of concern into the corrective action program as Condition Report CR-CNS-2016-05109. This issue of concern is being treated as Unresolved Item 05000298/2016008-01, "Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid."
The licensee entered this issue of concern into the corrective action program as Condition Report CR-CNS-2016-05109. This issue of concern is being treated as Unresolved Item 05000298/2016008-01, Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid.


===.15 Plant Change Evaluation===
===.15 Plant Change Evaluation===
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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 maintained and implemented 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 firefighting efforts. The strategies and procedures selected for this inspection sample included:
The team verified that the licensee maintained and implemented 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 firefighting efforts. The strategies and procedures selected for this inspection sample included:
Line 296: Line 289:


====a. Inspection Scope====
====a. Inspection Scope====
The team verified that the licensee had appropriately implemented risk-related items in the establishment and early operation of their NFPA 805 program. The team reviewed changes to the configuration risk management program, the risk assessment program, and a performance-based fire protection surveillance frequency program. The team reviewed the licensee's qualification standard used by plant personnel performing fire probabilistic risk assessment work. The team also reviewed the quality assurance program auditing requirements for completeness. Finally, the team reviewed the licensee's probabilistic risk assessment to ensure the basic event data in the fire probabilistic risk assessment matched the internal events probabilistic risk assessment basic events, which included a verification of multiple spurious operation and human reliability analysis treatment.
The team verified that the licensee had appropriately implemented risk-related items in the establishment and early operation of their NFPA 805 program. The team reviewed changes to the configuration risk management program, the risk assessment program, and a performance-based fire protection surveillance frequency program. The team reviewed the licensees qualification standard used by plant personnel performing fire probabilistic risk assessment work. The team also reviewed the quality assurance program auditing requirements for completeness. Finally, the team reviewed the licensees probabilistic risk assessment to ensure the basic event data in the fire probabilistic risk assessment matched the internal events probabilistic risk assessment basic events, which included a verification of multiple spurious operation and human reliability analysis treatment.
 
The team reviewed samples from the NFPA 805 Transition Report, Tables S-2, "Plant Modifications Committed," and S-3, "Implementation Items," to verify the implementation of the licensee's risk-related implementation items. The items reviewed are listed in the


attachment.
The team reviewed samples from the NFPA 805 Transition Report, Tables S-2, Plant Modifications Committed, and S-3, Implementation Items, to verify the implementation of the licensees risk-related implementation items. The items reviewed are listed in the attachment.


====b. Findings====
====b. Findings====
Line 306: Line 297:


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
[OA]
[OA] {{a|4OA2}}
 
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
==4OA2 Identification and Resolution of Problems==


Line 318: Line 307:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
 
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==


Line 333: Line 321:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::T. Barker]], Manager, Engineering Programs and Components  
: [[contact::T. Barker]], Manager, Engineering Programs and Components
: [[contact::J. Bebb]], Manager, Security  
: [[contact::J. Bebb]], Manager, Security
: [[contact::M. Bergmeier]], Supervisor, Operations Support Group  
: [[contact::M. Bergmeier]], Supervisor, Operations Support Group
: [[contact::D. Buman]], Director, Engineering  
: [[contact::D. Buman]], Director, Engineering
: [[contact::W. Chapin]], Manager, Maintenance  
: [[contact::W. Chapin]], Manager, Maintenance
: [[contact::L. Connor]], Specialist, Operations Support Group  
: [[contact::L. Connor]], Specialist, Operations Support Group
: [[contact::L. Dewhirst]], Manager, Corrective Action and Assessment  
: [[contact::L. Dewhirst]], Manager, Corrective Action and Assessment
: [[contact::K. Dia]], Manager, System Engineering Department  
: [[contact::K. Dia]], Manager, System Engineering Department
: [[contact::M. Dickerson]], Engineer, Electrical  
: [[contact::M. Dickerson]], Engineer, Electrical
: [[contact::J. Ehlers]], Supervisor, Electrical Instrument and Control  
: [[contact::J. Ehlers]], Supervisor, Electrical Instrument and Control
: [[contact::T. Forland]], Engineer, Licensing  
: [[contact::T. Forland]], Engineer, Licensing
: [[contact::D. Goodman]], Manager, Operations/Acti
: [[contact::D. Goodman]], Manager, Operations/Acting General Manager, Plant Operations
ng General Manager, Plant Operations  
: [[contact::J. Houston]], Manager, Production
: [[contact::J. Houston]], Manager, Production  
: [[contact::B. Howard]], Technician, Radiation Protection
: [[contact::B. Howard]], Technician, Radiation Protection  
: [[contact::R. Jensen]], Electrical Engineer
: [[contact::R. Jensen]], Electrical Engineer  
: [[contact::J. Keithley]], Electrician
: [[contact::J. Keithley]], Electrician  
: [[contact::B. Kirkpatrick]], Specialist, Licensing Specialist
: [[contact::B. Kirkpatrick]], Specialist, Licensing Specialist  
: [[contact::O. Limpias]], Vice President-Nuclear and Chief Nuclear Officer
: [[contact::O. Limpias]], Vice President-Nuclear and Chief Nuclear Officer  
: [[contact::T. Mertes]], Electrician
: [[contact::T. Mertes]], Electrician  
: [[contact::M. Neddenreip]], Engineer, Fire Protection
: [[contact::M. Neddenreip]], Engineer, Fire Protection  
: [[contact::S. Nelson]], Supervisor, Risk and Fire Programs Supervisor
: [[contact::S. Nelson]], Supervisor, Risk and Fire Programs Supervisor  
: [[contact::K. Newcomb]], Fire Marshall
: [[contact::K. Newcomb]], Fire Marshall  
: [[contact::O. Olson]], Engineer, Probabilistic Risk Assessment Engineer
: [[contact::O. Olson]], Engineer, Probabilistic Risk Assessment Engineer  
: [[contact::B. Parker]], Electrician
: [[contact::B. Parker]], Electrician  
: [[contact::R. Penfield]], Director, Nuclear Safety Assurance
: [[contact::R. Penfield]], Director, Nuclear Safety Assurance  
: [[contact::R. Schultz]], Engineer, Quality Assurance Engineer
: [[contact::R. Schultz]], Engineer, Quality Assurance Engineer  
: [[contact::A. Seeba]], Electrician
: [[contact::A. Seeba]], Electrician  
: [[contact::J. Shaw]], Manager, Licensing Manager
: [[contact::J. Shaw]], Manager, Licensing Manager  
: [[contact::J. Shrader]], Corporate Fire and Safety Lead
: [[contact::J. Shrader]], Corporate Fire and Safety Lead  
: [[contact::T. Shudak]], Engineer, Fire Protection Program
: [[contact::T. Shudak]], Engineer, Fire Protection Program  
: [[contact::K. Tom]], Assistant to Director of Engineering
: [[contact::K. Tom]], Assistant to Director of Engineering  
 
===NRC Personnel===
===NRC Personnel===
: [[contact::P. Voss]], Senior Resident Inspector  
: [[contact::P. Voss]], Senior Resident Inspector
: [[contact::C. Henderson]], Resident Inspector  
: [[contact::C. Henderson]], Resident Inspector


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


===Opened===
===Opened===
: 05000298/2016008-01 URI Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid (Section 1R05.05.14)
 
Possible Failure to Ensure that the Assumptions in the
: 05000298/2016008-01            URI Engineering Analysis Remain Valid (Section 1R05.05.14)


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==


}}
}}

Latest revision as of 19:03, 19 December 2019

NRC Triennial Fire Protection Inspection Report 05000298/2016008
ML16270A561
Person / Time
Site: Cooper Entergy icon.png
Issue date: 09/26/2016
From: Greg Werner
NRC/RGN-IV/DRS/EB-2
To: Limpias O
Nebraska Public Power District (NPPD)
References
IR 2016008
Download: ML16270A561 (36)
v • d • e


Text

ber 26, 2016

SUBJECT:

COOPER NUCLEAR STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000298/2016008

Dear Mr. Limpias:

On August 26, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Cooper Nuclear Station and discussed the results of this inspection with you and other members of your staff. The NRC team documented the results of this inspection in the enclosed inspection report.

The NRC team did not identify any findings or violations of more than minor significance.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gregory E. Werner, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-298 License No. DPR-46

Enclosure:

Inspection Report 05000298/2016008 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000298 License: DPR-46 Report Nos.: 05000298/2016008 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: 72676 648A Ave Brownville, NE Dates: August 8 through August 26, 2016 Team Leader: J. Mateychick, Senior Reactor Inspector, Engineering Branch 2 Team: S. Alferink, Reactor Inspector, Engineering Branch 2 G. Pick, Senior Reactor Inspector, Engineering Branch 2 J. Watkins, Reactor Inspector, Engineering Branch 2 R. Deese, Senior Reactor Analyst, Plant Support Branch 2 Accompanying P. Lain, Senior Fire Protection Engineer, Office of Nuclear Reactor Personnel: Regulation, Division of Risk Assessment Approved By: Gregory E. Werner Chief, Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000298/2016008; 08/08/2016 - 08/26/2016; Cooper Nuclear Station; Triennial Fire

Protection Team Inspection.

The report covers a two-week triennial fire protection team inspection by specialist inspectors from Region IV. No findings were 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

None

Licensee-Identified Violations

None

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 Cooper Nuclear Station 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 Cooper Nuclear Station NFPA 805 fire probabilistic risk assessment to select the following four risk-significant fire areas (inspection samples) for review:

Fire Area Description Category CB-D Control Room, Computer Room, Cable Performance-Based /

Spreading Room, Cable Expansion Room, Primary Control Station Auxiliary Relay Room DG-A Diesel Generator Room 1A Deterministic RB-FN Reactor Building 903 Northeast Corner Performance-Based RB-M Reactor Building South West Corner, RHR Performance-Based Heat Exchanger Room B and RWCU Hear Exchanger Room 932 Since this was the first triennial inspection following NRC approval of the risk-informed, performance-based fire protection program, the team reviewed samples of the implementation items required to be completed in accordance with Operating License Condition 2.C.(4). The team also reviewed samples of the plant modifications credited to support the approved fire protection program.

The team evaluated the licensees fire protection program using the applicable requirements, which included the plant Technical Specifications, Operating License Condition 2.C.(4), NRC safety evaluations, 10 CFR 50.48, and NFPA 805. The team also reviewed related documents that included the final safety analysis report, the nuclear safety capability assessment, and the fire safety analysis. Specific documents reviewed by the team are listed in the attachment.

Four fire area inspection samples and two mitigating strategy samples 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 fire barriers were appropriate for the fire hazards in the area. The team compared the installed configurations to the approved construction details, supporting fire tests, and applicable license commitments.

The team reviewed installation, repair, and qualification records for a sample of penetration seals to ensure that the installation met the engineering design. The team also reviewed similar records for the rated fire wraps to ensure the material possessed an appropriate fire rating and that the installation met the engineering design. The team reviewed modifications related to the conversion to a risk-informed fire protection program.

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 verified that the licensee had appropriately reduced the frequencies of fire protection surveillances. The licensee implemented the process described in Electric Power Research Institute Technical Report 1006756, Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features.

The team walked down accessible portions of the detection and suppression systems in the selected fire areas. The team walked down major system support equipment in other areas (e.g., fire pumps and Halon supply systems) to assess the material condition of these systems and components.

The team reviewed the flow and pressure tests for electric and diesel fire pumps to verify that the pumps met their design requirements. The team also reviewed the Halon suppression 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 safe shutdown equipment and instrumentation and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. In addition, the team inspected fire brigade equipment to determine operational readiness for firefighting.

The team observed an unannounced fire drill and subsequent drill critique on August 26, 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 at the station startup transformer. 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

No findings were identified.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team performed plant walk downs and document reviews to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified:

  • A fire in one of the selected fire areas would not directly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains.
  • A fire in one of the selected fire areas or the inadvertent actuation or rupture of a fire suppression system would not directly cause damage to all redundant trains (e.g., sprinkler-caused flooding of other than the locally affected train).
  • Adequate drainage 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 AC and 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 Procedure 5.4FIRE-S/D, Fire Induced Shutdown from Outside Control Room, Revision 65, 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 that may impact the ability to achieve and maintain safe and stable conditions. The team verified, on a sample basis, that the licensee properly identified the cables for equipment required to achieve and maintain safe and stable conditions in the event of a fire in the selected fire areas. The team verified that these cables 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 prevent achieving safe and stable conditions. The team verified that the licensee's analysis considered potential spurious operations due to fire-induced cable faults.

The teams evaluation focused on the cables of selected components from the high pressure core injection system, the residual heat removal system, the automatic depressurization system, motor-operated valves, the alternate shutdown panel, isolation and transferring control equipment and the local alternate shutdown panels. 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 and conduit 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. Specific components reviewed by the team are listed in the attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team inspected the contents of designated emergency storage lockers 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 routes 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 distribution system contained protective devices so that a fire in the area will not cause a loss of emergency lighting in any unaffected area needed to achieve and maintain safe and stable plant conditions.
  • 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.

b. Findings

No findings were identified.

.11 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the licensees approved fire protection program, implementing procedures, and programs for the control of ignition sources and transient combustibles.

The team assessed the licensees effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The team performed plant walk downs to independently verify that transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.

b. Findings

No findings were identified.

.12 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 evaluated that any radiation release to any unrestricted area resulting from fire suppression activities (but not involving fuel damage) were 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.

.13 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.

.14 Monitoring Program

a. Inspection Scope

The team verified that the licensee established a 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 monitoring program ensured the assumptions in the engineering analysis remain valid. The team also verified that the licensee was maintaining acceptable levels of availability, reliability, and performance per its license condition. When the established levels of availability, reliability, and performance were not met, the team verified that the licensee took appropriate corrective actions to return fire protection systems and features to the established acceptable levels.

b. Findings

Introduction.

The team identified an unresolved item associated with the licensees implementation of the monitoring program required in Section 2.6 of National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants. Specifically, the team required additional information to determine whether the licensees actions to set the action levels for the availability of some plant components at the components maintenance rule monitoring values and the licensees performance of a risk-informed sensitivity analysis to ensure that the assumptions in the engineering analysis remained valid were acceptable.

Description.

As part of the transition to a performance-based, risk-informed fire protection program, the licensee adopted the requirements of NFPA 805. NFPA 805 requires the following in Section 2.6:

Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid.

The team reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, NFPA 805 Monitoring Program, Revision 0, to ensure that the licensees program properly implemented the requirements of NFPA 805, Section 2.6. The team also reviewed Engineering Report Number ER2015-002, NFPA 805 Fire Protection Monitoring Program, Revision 2.

The team observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule monitoring program. These components included the:

  • Emergency station service transformer
  • Startup station service transformer
  • Instrument air compressors

With this observation, the team questioned the licensee as to whether this met the requirement in NFPA 805 to maintain the assumptions in the engineering analysis.

The licensee informed the team that they had performed a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule. This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability. This increase in core damage frequency was then determined to be acceptable if it did not exceed 1.0E-6/year. The team noted that for an individual component this screening criterion would not exceed more than 2 percent of the licensees baseline fire core damage frequency.

The team was aware that some particular aspects of the monitoring program were being discussed between the industry and the NRCs Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question 10-0059, NFPA 805 Monitoring. The monitoring program and the sensitivity analysis approach used by the licensee are enveloped in these discussions.

The team determined that additional information is required to determine if a performance deficiency exists. Specifically, the team needed to determine if the licensees action to set the action levels for the availability of some plant components at the components maintenance rule monitoring values and the performance of a risk-informed sensitivity analysis in an attempt to ensure that the assumptions in the engineering analysis remained valid would be an acceptable approach. Judgment on the suitability of this approach is pending further resolution of the monitoring program during discussions of Frequently Asked Question 10-0059, NFPA 805 Monitoring.

The licensee entered this issue of concern into the corrective action program as Condition Report CR-CNS-2016-05109. This issue of concern is being treated as Unresolved Item 05000298/2016008-01, Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid.

.15 Plant Change Evaluation

The team reviewed plant change evaluations 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.

b. Findings

No findings were identified.

.16 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 maintained and implemented 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 firefighting efforts. The strategies and procedures selected for this inspection sample included:

  • Fire protection water supply to the residual heat removal subsystem using either the existing fire protection system or using the onsite portable pump

The team completed two samples.

b. Findings

No findings were identified.

.17 Implementation of Risk-Related Implementation Items

a. Inspection Scope

The team verified that the licensee had appropriately implemented risk-related items in the establishment and early operation of their NFPA 805 program. The team reviewed changes to the configuration risk management program, the risk assessment program, and a performance-based fire protection surveillance frequency program. The team reviewed the licensees qualification standard used by plant personnel performing fire probabilistic risk assessment work. The team also reviewed the quality assurance program auditing requirements for completeness. Finally, the team reviewed the licensees probabilistic risk assessment to ensure the basic event data in the fire probabilistic risk assessment matched the internal events probabilistic risk assessment basic events, which included a verification of multiple spurious operation and human reliability analysis treatment.

The team reviewed samples from the NFPA 805 Transition Report, Tables S-2, Plant Modifications Committed, and S-3, Implementation Items, to verify the implementation of the licensees risk-related implementation items. The items reviewed are listed in the attachment.

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.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the inspection results to Mr. O. Limpias, Vice President-Nuclear and Chief Nuclear Officer, and other members of the licensee staff at an exit meeting on August 26, 2016. The licensee acknowledged the findings presented.

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

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Barker, Manager, Engineering Programs and Components
J. Bebb, Manager, Security
M. Bergmeier, Supervisor, Operations Support Group
D. Buman, Director, Engineering
W. Chapin, Manager, Maintenance
L. Connor, Specialist, Operations Support Group
L. Dewhirst, Manager, Corrective Action and Assessment
K. Dia, Manager, System Engineering Department
M. Dickerson, Engineer, Electrical
J. Ehlers, Supervisor, Electrical Instrument and Control
T. Forland, Engineer, Licensing
D. Goodman, Manager, Operations/Acting General Manager, Plant Operations
J. Houston, Manager, Production
B. Howard, Technician, Radiation Protection
R. Jensen, Electrical Engineer
J. Keithley, Electrician
B. Kirkpatrick, Specialist, Licensing Specialist
O. Limpias, Vice President-Nuclear and Chief Nuclear Officer
T. Mertes, Electrician
M. Neddenreip, Engineer, Fire Protection
S. Nelson, Supervisor, Risk and Fire Programs Supervisor
K. Newcomb, Fire Marshall
O. Olson, Engineer, Probabilistic Risk Assessment Engineer
B. Parker, Electrician
R. Penfield, Director, Nuclear Safety Assurance
R. Schultz, Engineer, Quality Assurance Engineer
A. Seeba, Electrician
J. Shaw, Manager, Licensing Manager
J. Shrader, Corporate Fire and Safety Lead
T. Shudak, Engineer, Fire Protection Program
K. Tom, Assistant to Director of Engineering

NRC Personnel

P. Voss, Senior Resident Inspector
C. Henderson, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

Possible Failure to Ensure that the Assumptions in the

05000298/2016008-01 URI Engineering Analysis Remain Valid (Section 1R05.05.14)

LIST OF DOCUMENTS REVIEWED

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