IR 05000324/2014008: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
(3 intermediate revisions by the same user not shown)
Line 52: Line 52:
=REPORT DETAILS=
=REPORT DETAILS=


===1. ===
==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
 
{{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==


Line 65: Line 63:


====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the licensees FPP referenced in the Updated Final Safety Analysis Report (UFSAR) Chapter 9; the licensees safe shutdown analysis (SSA); fire hazards analysis (FHA);
The team reviewed the licensees FPP referenced in the Updated Final Safety Analysis Report (UFSAR) Chapter 9; the licensees safe shutdown analysis (SSA); fire hazards analysis (FHA);plant procedures; piping and instrumentation drawings (P&IDs); electrical drawings; and other supporting documents. The team selected a sample of SSD systems to evaluate the licensees ability to safely shut down the plant in the event of a fire. The team performed in-plant inspections to verify that the plant configuration was consistent with that described in the SSA.
plant procedures; piping and instrumentation drawings (P&IDs); electrical drawings; and other supporting documents. The team selected a sample of SSD systems to evaluate the licensees ability to safely shut down the plant in the event of a fire. The team performed in-plant inspections to verify that the plant configuration was consistent with that described in the SSA.


The team reviewed the licensees shutdown methodology to verify that it properly identified the components and systems necessary to achieve and maintain SSD conditions for postulated fires resulting in shutdown from the main control room (MCR). The team focused their inspection activities on systems specified in the SSA for reactivity control, reactor coolant makeup, and decay heat removal; as well as process monitoring instrumentation and necessary support systems, such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.
The team reviewed the licensees shutdown methodology to verify that it properly identified the components and systems necessary to achieve and maintain SSD conditions for postulated fires resulting in shutdown from the main control room (MCR). The team focused their inspection activities on systems specified in the SSA for reactivity control, reactor coolant makeup, and decay heat removal; as well as process monitoring instrumentation and necessary support systems, such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.
Line 93: Line 90:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
04. Protection From Damage From Fire Suppression Activities
04. Protection From Damage From Fire Suppression Activities


Line 187: Line 183:
No findings were identified.
No findings were identified.


===4. ===
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA2}}
{{a|4OA2}}
Line 197: Line 192:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
 
{{a|4OA3}}
{{a|4OA3}}
==4OA3 Follow-up of Events and Notices of Enforcement Discretion==
==4OA3 Follow-up of Events and Notices of Enforcement Discretion==


Line 253: Line 247:


===Discussed===
===Discussed===
: 05000324/2013-002-00              LER                  Fire Related Unanalyzed Condition
: 05000324/2013-002-00              LER                  Fire Related Unanalyzed Condition that Could Impact Equipment Credited in Safe Shutdown Analysis (Section 4OA3.1)
that Could Impact Equipment Credited
: 05000324/2014-004-00              LER                  Fire Related Unanalyzed Condition that Could Impact Equipment Credited in Safe Shutdown Analysis (Section 4OA3.2)
in Safe Shutdown Analysis (Section
4OA3.1)
: 05000324/2014-004-00              LER                  Fire Related Unanalyzed Condition
that Could Impact Equipment Credited
in Safe Shutdown Analysis (Section
4OA3.2)


LIST OF FIRE BARRIER FEATURES INSPECTED
LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section 1RO5.02- Passive Fire Barriers)
                    (Refer Report Section 1RO5.02- Passive Fire Barriers)
Fire Barriers Floors/Walls/Ceiling Identification        Description 3-Hour Wall                                              RB2-1D to RB2-02 3-Hour Wall                                              RB2-1D to RB2-03 3-Hour Ceiling                                          RB2-1D to RB2-01F 3-Hour Ceiling                                          RB2-1D to RB2-05 3-Hour Ceiling                                          RB2-1D to RB2-01G (SE)
Fire Barriers Floors/Walls/Ceiling Identification        Description
3-Hour Wall                                              RB2-1D to RB2-02
3-Hour Wall                                              RB2-1D to RB2-03
3-Hour Ceiling                                          RB2-1D to RB2-01F
3-Hour Ceiling                                          RB2-1D to RB2-05
3-Hour Ceiling                                          RB2-1D to RB2-01G (SE)
3-Hour Ceiling                                          RB2-1D to RB2-01G (SC)
3-Hour Ceiling                                          RB2-1D to RB2-01G (SC)
3-Hour Wall                                              CB-23E to CB-4
3-Hour Wall                                              CB-23E to CB-4 3-Hour Wall                                              CB-23E to CB-13A 3-Hour Wall                                              CB-23E to CB-13B 3-Hour Wall                                              DG-07 to DG-05 3-Hour Wall                                              DG-07 to DG-06 3-Hour Floor                                            DG-07 to DG-01 Fire Door Identification                                Description 3-Hour Door (FD-106/107, Double Door)                    DG-07 to DG 05 3-Hour Door (FD-114/115, Double Door)                    DG-07 to DG-06 3-Hour Door (FD-128, Single Door)                        DG-07 to DG-01 LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1R05.01 / 1R05.03 / 1R05.05 / 1R05.06)
3-Hour Wall                                              CB-23E to CB-13A
1-B21-LI-5977 - Remote Reactor Water Level Indicator for ASSD 2-B21-LI-5977 - Remote Reactor Water Level Indicator for ASSD 1-CAC-TR-778 - Suppression Pool Water Temperature Recorder 2-CAC-TR-778 - Suppression Pool Water Temperature Recorder 1-CAC-LI-3342 - Torus Water Level Indicator 2-CAC-LI-3342 - Torus Water Level Indicator 1-C32-PI-3332 - Reactor Vessel Pressure Indicator 2-C32-PI-3332 - Reactor Vessel Pressure Indicator 1-B21-LI-R604-BX - Remote Reactor Water Level Indicator 2-B21-LI-R604-BX - Remote Reactor Water Level Indicator 1(2) - E51-F045 - RCIC Turbine Steam Supply Valves 1(2) - E51-F012 - RCIC Pump Discharge Valves 1-E1 - 4KV Emergency Switchgear E1 1-E5-AU9 - Unit Substation E5 Main Feed Breaker Compt.
3-Hour Wall                                              CB-23E to CB-13B
3-Hour Wall                                              DG-07 to DG-05
3-Hour Wall                                              DG-07 to DG-06
3-Hour Floor                                            DG-07 to DG-01
Fire Door Identification                                Description
3-Hour Door (FD-106/107, Double Door)                    DG-07 to DG 05
3-Hour Door (FD-114/115, Double Door)                    DG-07 to DG-06
3-Hour Door (FD-128, Single Door)                        DG-07 to DG-01
LIST OF COMPONENTS REVIEWED
              (Refer to Report Sections 1R05.01 / 1R05.03 / 1R05.05 / 1R05.06)
1-B21-LI-5977 - Remote Reactor Water Level Indicator for ASSD
2-B21-LI-5977 - Remote Reactor Water Level Indicator for ASSD
1-CAC-TR-778 - Suppression Pool Water Temperature Recorder
2-CAC-TR-778 - Suppression Pool Water Temperature Recorder
1-CAC-LI-3342 - Torus Water Level Indicator
2-CAC-LI-3342 - Torus Water Level Indicator
1-C32-PI-3332 - Reactor Vessel Pressure Indicator
2-C32-PI-3332 - Reactor Vessel Pressure Indicator
1-B21-LI-R604-BX - Remote Reactor Water Level Indicator
2-B21-LI-R604-BX - Remote Reactor Water Level Indicator
1(2) - E51-F045 - RCIC Turbine Steam Supply Valves
1(2) - E51-F012 - RCIC Pump Discharge Valves
1-E1 - 4KV Emergency Switchgear E1
1-E5-AU9 - Unit Substation E5 Main Feed Breaker Compt.
2-DG1-GEN - Diesel Generator No. 1
2-DG1-GEN - Diesel Generator No. 1



Latest revision as of 07:35, 20 December 2019

IR 05000325/2014008 and 05000324/2014008, September 8-12, 2014 and September 22-26, 2014, Brunswick, NRC Triennial Fire Protection
ML14310A776
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/06/2014
From: Scott Shaeffer
NRC/RGN-II/DRS/EB2
To: William Gideon
Duke Energy Progress
entered for Joyce Calloway, LXG2
References
IR-2014008
Download: ML14310A776 (24)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 6, 2014

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000325/2014008 AND 05000324/2014008

Dear Mr. Gideon:

This refers to the inspection completed on September 26, 2014 at the Brunswick Steam Electric Plant, Units 1 and 2 (Inspection Report Nos. 05000325/2014008 and 05000324/2014008, enclosed). The purpose of the inspection was to evaluate the design, operational status, and material condition of the facilitys fire protection program. The purpose was to also verify that B.5.b mitigating strategies were feasible in light of operator training, maintenance of necessary equipment, and any plant modifications. The enclosed report presents the results of this inspection.

During this inspection, the NRC examined activities conducted under your license as they relate to public health and safety, and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of this inspection, no findings of significance were identified. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov./reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by Omar R. Lopez-Santiago Acting For/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-324 and 50-325 License Nos. DPR-62 and DPR-71

Enclosure:

Inspection Report 05000324/2014008, 05000325/2014008 w/Attachment: Supplementary Information

REGION II==

Docket Nos: 50-325 and 50-324 License Nos: DPR-62 and DPR-71 Report Nos: 05000324/2014008 and 05000325/2014008 Licensee: Duke Energy Progress, Inc.

Facility: Brunswick Steam Electric Plant Location: 8470 River Rd. SE Southport, NC 28461 Dates: September 8 - 12, 2014 (Week 1)

September 22 - 26, 2014 (Week 2)

Inspectors: J. Dymek, Reactor Inspector D. Jones, Senior Reactor Inspector T. Lighty, Reactor Inspector W. Monk, Reactor Inspector J. Montgomery, Reactor Inspector (Lead Inspector)

M. Singletary, Reactor Inspector Approved by: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report (IR) 05000324/2014008, 05000325/2014008; 9/8/2014 - 9/12/2014 and 9/22/2014 - 9/26/2014; Brunswick Steam Electric Plant, Units 1 and 2; Fire Protection (Triennial) and Other Activities This report covers an announced 2-week triennial fire protection inspection by a team of six Regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

No findings were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R05 Fire Protection

This report documents the results of a triennial fire protection inspection of the Brunswick Steam Electric Plant (BNP) Units 1 and 2. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure 71111.05T, Fire Protection (Triennial), dated January 31, 2013. The objective of the inspection was to review a minimum sample of three risk-significant fire areas (FAs) to evaluate implementation of the Brunswick Fire Protection Program (FPP). An additional objective was to review site specific implementation of one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walk-downs of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the team reviewed licensee submittal letters, safety evaluation reports (SERs), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-05 of the IP specifies a minimum sample size of three FAs and one B.5.b mitigating strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of five FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:

1. Fire Zone (FZ) CB-21 - Southwest Control Room Area El. 49 2. FZ CB-23 - Control Room El. 49 3. FA DG-07 - E6 Switchgear Room, Diesel Building El. 20 4. FA TB1 - Turbine Building El. 20 5. FZ RB2-2 - HPCI Room, Reactor Building El. -17 For each of the selected FAs, the team evaluated the licensees FPP against applicable NRC requirements and licensee design basis documents. Applicable licensing and design basis documents reviewed by the team are listed in the Attachment to this report.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the licensees FPP referenced in the Updated Final Safety Analysis Report (UFSAR) Chapter 9; the licensees safe shutdown analysis (SSA); fire hazards analysis (FHA);plant procedures; piping and instrumentation drawings (P&IDs); electrical drawings; and other supporting documents. The team selected a sample of SSD systems to evaluate the licensees ability to safely shut down the plant in the event of a fire. The team performed in-plant inspections to verify that the plant configuration was consistent with that described in the SSA.

The team reviewed the licensees shutdown methodology to verify that it properly identified the components and systems necessary to achieve and maintain SSD conditions for postulated fires resulting in shutdown from the main control room (MCR). The team focused their inspection activities on systems specified in the SSA for reactivity control, reactor coolant makeup, and decay heat removal; as well as process monitoring instrumentation and necessary support systems, such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.

The team reviewed and performed a walkthrough of procedure steps used for post-fire SSD to ensure the technical and human factors adequacy of the procedures. The team verified the licensee personnel credited for performance of procedures were available in the event a fire occurred. The team also verified that the credited licensee personnel had procedures available, and were trained on implementation. The team reviewed and walked down applicable sections of procedures 1ASSD-32, Unit 2 Reactor Building North 2ASSD-05, Reactor Building North, 0ASSD-01, Control Building,1OP-43, Service Water System Operating Procedure, and 1OP-17, Residual Heat Removal System Operating Procedure. The team reviewed operator actions to ensure these actions could be implemented in accordance with plant procedures in a manner necessary to support the SSD method for the applicable fire zone.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

For the selected FAs, the team evaluated the adequacy of fire barriers, including: walls, ceilings, floors, mechanical and electrical penetrations, fire doors, fire dampers and electrical raceway fire barrier systems (ERFBS). The team walked down accessible portions of the selected FAs to observe material condition of the fire barriers and reviewed work orders associated with their repair. The team reviewed the design of selected ERFBS to confirm that appropriate materials and construction methods were used to assure that the respective fire barriers met their intended design function. The team reviewed licensee calculation 0-89-0001, Combustible Loading Calculation to verify that the plant fire loading used by the licensee was appropriate for the stated fire resistance rating of the enclosures. The team reviewed recently completed surveillance procedures for fire doors, penetration seals and ERFBS.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

For the selected FAs, the team performed in-plant observations of the material condition and operational line-up of fire detection systems, fire protection water supply, automatic wet pipe sprinkler systems and manual fire hose and standpipe systems. The team reviewed the adequacy of the design and installation of fire suppression systems in the selected FAs. This was accomplished by review of system vendor drawings, calculations, and code compliance reviews. The team evaluated if the fire detection and suppression methods were appropriate for the hazards in the selected FAs. The team compared the fire detection and fire suppression systems to the applicable code of record for National Fire Protection Association (NFPA)

Standard(s) for the selected FAs by reviewing the system design documents and observing their as-installed configurations as part of performing the in-plant walk-downs. The team reviewed recently completed surveillance procedures for fire detection, gaseous suppression, and fire sprinkler systems in the selected FAs and compared them to the BNP FPP.

For the selected FAs, the team compared the pre-fire plan strategy of each FA to existing plant layout and equipment configurations, and the fire response procedures. The team assessed the condition of firefighting and smoke removal equipment by inspecting the equipment located in the fire brigade equipment staging and storage areas. The team reviewed fire brigade drill planning and evaluation report records for announced, unannounced and off-site fire department drills performed in 2013 and 2014.

b. Findings

No findings were identified.

04. Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team evaluated whether the installed automatic wet pipe sprinkler systems or manual fire fighting activities could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect operator manual actions (OMAs) required for SSD for the selected FAs. The team considered the consequences of a rupture, inadvertent operation, or actual operation of a fire suppression system concurrent with manual fire fighting activities that would result from a fully involved fire in one of the selected FAs. The team reviewed pre-fire plans which addressed the opening of doors to drain water so that OMAs could be performed.

The team observed the material condition of floor penetration seals and concrete floor slabs to assess the potential for damage to equipment below. In addition, the team measured curb heights above the floor for installed equipment and visually checked floor slope to determine if water could inadvertently pool in such a manner as to adversely affect SSD equipment or OMAs.

A specific review of postulated fusing of fire sprinklers in the Reactor Building due to steam from a High Energy Line Break (HELB) was performed to address potential flooding issues in lower elevations and to assess effects on equipment credited for mitigation of a HELB.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

The team reviewed the licensees FPP referenced in UFSAR Chapter 9, the FHA, SSA, plant procedures, P&IDs, electrical drawings, and other supporting documents for postulated fires in FZs CB-21, CB-23, and RB2-2. The team performed the review to ensure that the required functions for post-fire SSD, and the corresponding equipment necessary to perform those functions, were included in the fire SSD procedures. The team assessed whether transfer of control from the MCR to the remote shutdown panel, to achieve hot and cold shutdown from outside the MCR could be successfully accomplished. The team reviewed periodic test procedures and test records of alternate shutdown transfer capability and instrumentation and control functions, to ensure that the tests were adequate to verify the functionality of alternative shutdown capability. The review included verification that shutdown from outside the MCR could be performed both with and without the availability of offsite power.

The team performed in-plant inspections to verify that the plant configuration was consistent with that described in the SSA. The team focused their inspection activities on systems specified in the SSA for reactivity control, reactor coolant makeup, and decay heat removal, as well as process monitoring instrumentation and necessary support systems. The team reviewed shift attendance records to verify that personnel required to accomplish SSD, exclusive of those assigned as fire brigade members, were available. The team reviewed training lesson plans and job performance measures, to verify that the training included the shutdown methodology of the SSA and the SSD. The team reviewed and walked down selected applicable steps of 0ASSD-01, Alternative Safe Shutdown Procedure Index, 2ASSD-05, Reactor Building North, and 0ASSD-01, Control Building, in order to assess technical and human factors adequacy of the procedures. The team also verified that operators could reasonably be expected to perform the procedure actions in order to maintain plant parameters within specified limits.

b. Findings

No findings were identified.

.06 Circuit Analyses

a. Inspection Scope

The team reviewed Brunswicks FHA, SSA, Fire Safe Shutdown Program Manager Database (FSSDMD) and system flow diagram drawings to verify that the licensee had identified required and associated circuits that may impact post-fire SSD for the selected FAs. The team reviewed the credited components specified in the SSD Compliance Assessment Report for meeting the SSD function. The team also reviewed cable routing information for a sample of these credited components to determine if their cables had either been adequately protected from the potentially adverse effects of fire damage or analyzed to show that fire induced faults would not prevent post fire SSD. The team conducted walk-downs of the chosen FAs to help determine if the credited components relied upon for SSD would still be available given a fire in the chosen FAs.

Additionally, a review was conducted of routing information for credited fire protection and SSD components to determine if a fire in the selected FAs would impact the credited defense-in-depth systems. The team reviewed the licensees evaluations for spurious circuit failure scenarios (single and/or multiple) specified in the circuit analysis to determine if potential circuit failure scenarios, for a sample list of components, challenged the assumptions made in the SSA. The team reviewed the licensees electrical coordination study calculations to determine if credited power supplies were susceptible to fire damage. The specific components and references reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team reviewed plant communication capabilities to evaluate the availability of the sound powered phone (SSP) system to support plant personnel in the performance of OMAs to achieve and maintain SSD, as credited in the BNP UFSAR, Section 9.5.2, Communications Systems. The team performed plant walk-downs with the licensees operations staff to assess the credited method of communications used to complete SSD actions as specified in post-fire SSD procedures for the selected FAs. The team also reviewed the communication systems available at different locations within the plant that would be relied upon to support fire event notification and fire brigade firefighting activities to verify their availability. Additionally, the team assessed the operators ability to communicate based upon observation of a licensee-conducted communications test with the SSP systems and fire brigade portable radios.

The team reviewed the cable routing for the plant phone system to ensure that the required communication systems remained functional following a fire in the selected FAs. Additionally, a walk-down of the fire brigade storage building was conducted to verify the material condition status of the fire brigades communication systems. The team reviewed preventive maintenance and surveillance test records to verify that the communication equipment was being properly maintained and tested. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team verified the adequacy of the plants emergency lighting systems through review of design and maintenance aspects and inspection walk-downs of the fixed 8-hour battery pack emergency lighting units (ELUs), as required by 10 CFR 50 Appendix R, Section III.J and the BNP approved FPP. The team performed plant walk-downs of the post-fire SSD procedures for the selected FAs to observe the placement and coverage area of the ELUs required to illuminate operator access and egress pathways, and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. This review also included examination of whether backup ELUs were provided for the primary and secondary fire emergency equipment storage locations and dress-out areas in support of fire brigade operations should power fail during an emergency. In the selected FAs, the team observed operations personnel perform onsite functional tests of the ELUs to verify operation.

The team also reviewed completed test records of ELU battery 8-hour post-service capacity tests, completed surveillances, system health reports, and maintenance tests to ensure that they were sized, tested, rated for at least an 8-hour capacity and maintained consistent with vendor guidance, license requirements, and licensee commitments. Additionally, the team reviewed the licensees 10 CFR 50.65, Maintenance Rule performance criteria for the ELU system. The team also reviewed the vendor manual to ensure that the ELUs were being maintained consistent with the manufacturers recommendations and verified the battery storage conditions and maintenance practices were also being followed in accordance with the vendor guidance. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team reviewed the licensees FHA and SSA to verify that the licensee had evaluated the need for cold shutdown repairs. The team determined from the review that the licensee did not take credit for repairs in order to achieve cold shutdown.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

(1) Compensatory Measures for Degraded Fire Protection Components For the selected FAs, the team reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features such as detection and suppression systems, and passive fire barriers. The team reviewed current fire protection impairments and compared them to the FAs selected for the inspection. Fire detection and suppression system impairments were reviewed against operability requirements and compensatory measures outlined in the BNP FPP. The team reviewed this information to determine if the risk associated with removing the fire protection feature from service was adequately addressed with appropriate compensatory measures. The team reviewed unplanned fire protection action statement entries for such items as system malfunction, failure, inadvertent actuation, out of specification operating parameters and surveillance test failures. Entry and closure dates of impaired fire protection items tracked were assessed to determine if restoration to normal operating mode was being done in a timely manner and met the overall objectives of administrative control and compensatory measures outlined in the BNP FPP. The team reviewed the fire protection and fire watch training program documents, as well as training records for personnel tasked with performing fire watch responsibilities, to ensure that individuals were properly instructed and qualified to perform the task.
(2) Operator Manual Actions as Compensatory Measures for Safe Shutdown The team reviewed the SSA, FHA, and applicable abnormal operating procedures, to determine if the licensees SSD methodology credited OMAs outside the MCR as compensatory measures for SSD, for postulated fires in FZs CB-21, CB-23, and RB2-2. For a sample of credited OMAs, the team verified the adequacy of procedural guidance and the accessibility and feasibility of the actions to be performed within the required time limit.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The team reviewed a sample of FPP changes made between November 2011 and August 2014 to assess the licensees effectiveness to determine if the changes to the FPP were in accordance with the fire protection license condition and that these changes had no adverse effect on the ability to achieve SSD.

b. Findings

No findings were identified.

.12 Control of Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the controls for combustibles and ignition sources throughout the plant to verify that they were in compliance with the BNP FPP. The team verified that the transient combustible materials were being controlled in accordance with the licensees administrative control procedures and the licensees fire probabilistic risk assessment.

b. Findings

No findings were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The team reviewed, on a sample basis, the licensees mitigation measures for reactor pressure vessel depressurization and injection for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the measures, and equipment was properly staged and maintained. The team reviewed surveillance testing records to verify that required equipment was adequately maintained. Through discussions with plant staff, review of documentation, and plant walk-downs, the team verified the sites engineering assessment that the makeup capability could be provided using the specified equipment and water sources. The team reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply. The team reviewed inventory records and performed a walk-down of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the procedures was available and maintained. The team conducted an independent audit and inventory of required equipment and a visual inspection of the dedicated credited power and water sources. The team reviewed training records to verify that operations and security personnel training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

a. Inspection Scope

The team reviewed recent licensee independent audits, self-assessments, and system/program health reports for thoroughness, completeness and conformance to FPP requirements described in the BNP UFSAR and FPP Manual. The team also reviewed corrective action program (CAP) documents, including completed corrective actions documented in selected condition reports (CRs), to verify that fire protection deficiencies were adequately identified, evaluated, and that appropriate corrective actions were implemented. Operating experience program documents were also reviewed to verify that industry identified fire protection problems, potentially or actually affecting BNP, were appropriately entered into and assessed by the CAP process. Specific documents reviewed by the team are listed in the Attachment.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 (Discussed) Licensee Event Report (LER) 05000324/2013-002-00, Fire Related Unanalyzed

Condition that Could Impact Equipment Credited in Safe Shutdown Analysis

.a Inspection Scope The licensee reported in LER 2013-002-00 that a postulated fire in specified areas of the plant could disable components credited for achieving safe shutdown conditions. The team conducted interviews, performed plant walk-downs, and reviewed corrective action documentation to determine if the issue involved a more than minor performance deficiency.

The LER review is open pending the completion of the review in the Region II offices and, if deemed necessary, a subsequent site visit. This issue was entered into the licensees CAP as CR 619341.

.2 (Discussed) Licensee Event Report (LER) 05000324/2014-004-00, Fire Related Unanalyzed

Condition that Could Impact Equipment Credited in Safe Shutdown Analysis

.a Inspection Scope The licensee reported in LER 2014-004-00 that a postulated fire in specified areas of the plant could disable components credited for achieving safe shutdown conditions. The team conducted interviews, performed plant walk-downs, and reviewed corrective action documentation to determine if the issue involved a more than minor performance deficiency.

The LER review is open pending the completion of the review in the Region II offices and, if deemed necessary, a subsequent site visit. This issue was entered into the licensees CAP as CR 676576.

4OA6 Meetings, Including Exit

On September 26, 2014, the lead inspector presented the preliminary inspection results to Mr.

William Gideon and other members of the licensees staff, who acknowledged the results.

Following completion of additional reviews in the Region II office, a conference call was held with Mr. Lee Grzeck on October 14, 2014, to provide an update on changes to the preliminary inspection findings. The licensee acknowledged the results. Proprietary information was not included in this inspection report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Boyce, Nuclear Ops Specialist
J. Brady, Nuclear Licensing Consultant
C. Browne, Contract Safe Shutdown Engineer
L. Davidson, Safe Shutdown Engineer
M. Fiorino, Control Room Supervisor
J. Gaver, Nuclear Fire Protection Coordinator
L. Grzeck, Manager Nuclear Regulatory Affairs
M. Goddard, Fire Protection Programs
G. Hamrick, Vice President, BNP
A. Holder, Corporate Fire Protection
M. Humphrey, PRA
B. Kelly, Fire Protection Systems
R. Tart, NFPA 805 Project Manager
R. Zambo, Licensing Engineer

NRC Personnel

M. Catts, Senior Resident Inspector
M. Schwieg, Resident Inspector
S. Shaeffer, Chief, Engineering Branch 2, DRS, Region II

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Discussed

05000324/2013-002-00 LER Fire Related Unanalyzed Condition that Could Impact Equipment Credited in Safe Shutdown Analysis (Section 4OA3.1)
05000324/2014-004-00 LER Fire Related Unanalyzed Condition that Could Impact Equipment Credited in Safe Shutdown Analysis (Section 4OA3.2)

LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section 1RO5.02- Passive Fire Barriers)

Fire Barriers Floors/Walls/Ceiling Identification Description 3-Hour Wall RB2-1D to RB2-02 3-Hour Wall RB2-1D to RB2-03 3-Hour Ceiling RB2-1D to RB2-01F 3-Hour Ceiling RB2-1D to RB2-05 3-Hour Ceiling RB2-1D to RB2-01G (SE)

3-Hour Ceiling RB2-1D to RB2-01G (SC)

3-Hour Wall CB-23E to CB-4 3-Hour Wall CB-23E to CB-13A 3-Hour Wall CB-23E to CB-13B 3-Hour Wall DG-07 to DG-05 3-Hour Wall DG-07 to DG-06 3-Hour Floor DG-07 to DG-01 Fire Door Identification Description 3-Hour Door (FD-106/107, Double Door) DG-07 to DG 05 3-Hour Door (FD-114/115, Double Door) DG-07 to DG-06 3-Hour Door (FD-128, Single Door) DG-07 to DG-01 LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1R05.01 / 1R05.03 / 1R05.05 / 1R05.06)

1-B21-LI-5977 - Remote Reactor Water Level Indicator for ASSD 2-B21-LI-5977 - Remote Reactor Water Level Indicator for ASSD 1-CAC-TR-778 - Suppression Pool Water Temperature Recorder 2-CAC-TR-778 - Suppression Pool Water Temperature Recorder 1-CAC-LI-3342 - Torus Water Level Indicator 2-CAC-LI-3342 - Torus Water Level Indicator 1-C32-PI-3332 - Reactor Vessel Pressure Indicator 2-C32-PI-3332 - Reactor Vessel Pressure Indicator 1-B21-LI-R604-BX - Remote Reactor Water Level Indicator 2-B21-LI-R604-BX - Remote Reactor Water Level Indicator 1(2) - E51-F045 - RCIC Turbine Steam Supply Valves 1(2) - E51-F012 - RCIC Pump Discharge Valves 1-E1 - 4KV Emergency Switchgear E1 1-E5-AU9 - Unit Substation E5 Main Feed Breaker Compt.

2-DG1-GEN - Diesel Generator No. 1

LIST OF DOCUMENTS REVIEWED