IR 05000266/2013010: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 December 6, 2013
[[Issue date::December 6, 2013]]


Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241
Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241


SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000266/2013010; 05000301/2013010
SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2
, TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000266/2013010; 05000301/2013010


==Dear Mr. Meyer:==
==Dear Mr. Meyer:==
On November 25, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 8, 2013, with Mr. E. McCartney, and on November 25, 2013, with Mr. B. Woyak and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No NRC-identified or self-revealing findings were identified during this inspection. However, inspectors documented a licensee-identified violation which was determined to be of very low safety significance (Green) in Section 4OA7 of this report. The NRC is treating this violation as a Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the subject or severity of any Non-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector office at the Point Beach Nuclear Plant, Units 1 and 2. In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
On November 25, 2013, the U.S. Nuclear Regulato ry Commission (NRC) completed a Triennial Fire Protection Inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 8, 2013, with Mr. E. McCartney, and on November 25, 2013, with Mr. B. Woyak and other members of your staff.


Sincerely,/RA/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27  
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
 
No NRC-identified or self-revealing findings were identified during this inspection.
 
However, inspectors documented a licensee
-identified violation which was determined to be of very low safety significance (Green) in Section 4OA7 of this report.
 
The NRC is treating this violation as a Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the subject or severity of any Non-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555
-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission
- Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532
-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washing ton, DC 20555
-0001; and the NRC Resident Inspector office at the Point Beach Nuclear Plant, Units 1 and 2
. In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,/RA/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos.
 
50-266; 50-301 License Nos. DPR-24; DPR-27  


===Enclosure:===
===Enclosure:===
Inspection Report 05000266/2013010; 05000301/2013010  
Inspection Report 05000 266/2013010; 05000301/2013010  


===w/Attachment:===
===w/Attachment:===
Supplemental Information cc w/encl: Distribution via ListServŽ Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27 Report No: 05000266/2013010; 05000301/2013010 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: Two Rivers, WI Dates: October 21 through November 25, 2013 Inspectors: D. Szwarc, Senior Reactor Inspector, Lead M. Munir, Reactor Inspector D. Oliver, Reactor Inspector R. Winter, Reactor Inspector Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure  
Supplemental Information cc w/encl:
Distribution via ListServ
Ž Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No s: 50-266; 50-301 License No s: DPR-24; DPR-27 Report No:
05000266/2013010; 05000301/2013010 Licensee:
NextEra Energy Point Beach, LLC Facility:
Point Beach Nuclear Plant, Units 1 and 2 Location:
Two Rivers, WI Dates: October 21 through November 25, 2013 Inspectors:
D. Szwarc, Senior Reactor Inspector, Lead M. Munir, Reactor Inspector D. Oliver, Reactor Inspector R. Winter, Reactor Inspector Approved by:
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure


=SUMMARY=
=SUMMARY=
IR 05000266/2013010, 05000301/2013010; 10/21/2013 - 11/25/2013; Point Beach Nuclear Plant, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection. This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III inspectors. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated June 7, 2012. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
IR 05000266/2013010, 05000301/2013010; 10/21/2013 - 11/25/2013
 
; Point Beach Nuclear Plant, Units 1 and 2
; Routine Triennial Fire Protection Baseline Inspection.
 
This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III inspectors.
 
The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated June 7, 2012.
 
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process," Revision 4, dated December 2006.


===A. NRC-Identified===
===A. NRC-Identified===
Line 43: Line 78:


===B. Licensee-Identified Violations===
===B. Licensee-Identified Violations===
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's Corrective Action Program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's Corrective Action Program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.


Line 48: Line 84:


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones:  Initiating Events and Mitigating Systems
Cornerstone s:  Initiating Events and Mitigating Systems
 
{{a|1R05}}
{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
{{IP sample|IP=IP 71111.05T}}
The licensee was in transition to National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," as incorporated by 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 deterministic aspects of the standard are comparable to traditional requirements. However, the transition to a risk-informed, performance-based Fire Protection Program requires an in-depth nuclear safety circuit analysis for equipment identified for nuclear safety functions such as safe shutdown. Because the conversion and licensing process to NFPA 805 was expected to identify and address a variety of issues that were normally the subject of the Triennial Fire Protection Baseline Inspection, the Nuclear Regulatory Commission (NRC) modified the Enforcement Policy for licensees in transition to NFPA 805. As part of the transition to NFPA 805, certain findings not associated with findings of high-safety significance that meet the four criteria established by Section A of the NRC's Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) receive enforcement discretion in accordance with the NRC's Enforcement Policy. The purpose of the fire protection triennial baseline inspection was to conduct a design-based, plant specific, risk-informed, onsite inspection of the licensee's Fire Protection Program's defense-in-depth elements used to mitigate the consequences of a fire. The Fire Protection Program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:  preventing fires from starting;  rapidly detecting, controlling and extinguishing fires that do occur;  providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and  taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires. The inspectors' evaluation focused on the design, operational status, and material condition of the reactor plant's Fire Protection Program, post-fire safe shutdown systems, and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a Fire Protection Program that:  (1) provided adequate controls for combustibles and ignition sources inside the plant; (2) provided adequate fire detection and suppression capability; (3) maintained passive fire protection features in good material condition; (4) established adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features; (5) ensured that procedures, equipment, fire barriers 2 Enclosure and systems exist so that the post-fire capability to safely shut down the plant was ensured; (6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and (7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensee's problem identification and resolution program. In addition, the inspectors' review and assessment focused on the licensee's post-fire safe shutdown systems for selected risk significant fire areas. Inspector emphasis was placed on determining that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspectors' review and assessment also focused on the licensee's B.5.b related license conditions and the requirements of Title 10, Code of Federal Regulations (10 CFR) Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.


The fire areas and fire zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas and fire zones selected constituted four inspection samples and the B.5.b mitigating strategies selected constituted two inspection samples, respectively, as defined in Inspection Procedure 71111.05T. Fire Area Fire Zone Description A23N 304N Auxiliary Feedwater Pump Room North A30 318 Cable Spreading Room A33 337 Control Building Heating, Ventilation, and Air Conditioning (HVAC) Room A71 308 Diesel Generator Room
(71111.05T)
The licensee was in transition to National Fire Protection Association (NFPA) 805
, "Performance
-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," as incorporated by 10 CFR 50.48(c). The NFPA 805 standard establishes a comprehensive set of requirements for Fire Protection Program s at nuclear power plants. The standard incorporates both deterministic and risk
-informed, performance
-based concepts. The deterministic aspects of the standard are comparable to traditional requirements. However, the transition to a risk
-informed, performance
-based Fire Protection Program requires an in
-depth nuclear safety circuit analysis for equipment identified for nuclear safety functions such as safe shutdown. Because the conversion and licensing process to NFPA 805 was expected to identify and address a variety of issues that were normally the subject of the Triennial Fire Protection Baseline Inspection, the Nuclear Regulatory Commission (
NRC) modified the Enforcement Policy for licensees in transition to NFPA 805. As part of the transition to NFPA 805, certain findings not associated with findings of high-safety significance that meet the four criteria established by Section A of the NRC's Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)receive enforcement discretion in accordance with the NRC's Enforcement Policy.
 
The purpose of the fire protection triennial baseline inspection was to conduct a design-based, plant specific, risk
-informed, onsite inspection of the licensee's Fire Protection Program's defense-in-depth elements used to mitigate the consequences of a fire
. The Fire Protection Program shall extend the concept of defense
-in-depth to fire protection in plant areas important to safety by
:  preventing fires from starting; rapidly detecting, controlling and extinguishing fires that do occur; providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.
 
The inspectors' evaluation focused on the design, operational status, and material condition of the reactor plant
's Fire Protection Program
, post-fire safe shutdown systems, and B.5.b mitigating strategies
. The objectives of the inspecti on were to assess whether the licensee ha d implemented a Fire Protection Program that:  (1) provided adequate controls for combustibles and ignition sources inside the plant; (2) provided adequate fire detection and suppression capability; (3)maintained passive fire protection features in good material condition; (4)established adequate compensatory measures for out
-of-service, degraded or inoperable fire protection equipment, systems or features; (5)ensured that procedures, equipment, fire barriers and systems exist so that the post
-fire capability to safely shut down the plant was ensured; (6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and (7) identifie d fire protection issues at an appropriate threshold and ensure d these issues were entered into the licensee's problem identification and resolution program.
 
In addition, the inspectors' review and assessment focused on the licensee's post
-fire safe shutdown systems for selected risk significant fire areas. Inspector emphasis was placed on determining that the post
-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post
-fire safe shutdown success path was available. The inspectors' review and assessment also focused on the licensee's B.5.b related license conditions and the requirements of Title 10, Code of Federal Regulations (10 CFR) Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.
 
The fire areas and fire zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas and fire zones selected constitute d four inspection samples and the B.5.b mitigating strategies selected constitute d two inspection samples, respectively, as defined in Inspection Procedure 71111.05T. Fire Area Fire Zone Description A23N 304N Auxiliary Feedwater Pump Room North A30 318 Cable Spreading Room A33 337 Control Building Heating, Ventilation, and Air Conditioning (HVAC) Room A71 308 Diesel Generator Room


===.2 Protection of Safe Shutdown Capabilities===
===.2 Protection of Safe Shutdown Capabilities===


====a. Inspection Scope====
====a. Inspection Scope====
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire safe shutdown analysis and procedures.
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected.
 
The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post
-fire safe shutdown analysis and procedures.


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
3 Enclosure


===.3 Passive Fire Protection===
===.3 Passive Fire Protection===


====a. Inspection Scope====
====a. Inspection Scope====
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments. The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area. The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments.
 
The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area. The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.


====b. Findings====
====b. Findings====
Line 86: Line 153:
====a. Inspection Scope====
====a. Inspection Scope====
For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.
For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.
4 Enclosure


====b. Findings====
====b. Findings====
Line 95: Line 160:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions. The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.
The inspectors reviewed the licensee's systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.
 
The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls
.


====b. Findings====
====b. Findings====
Line 111: Line 179:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order. The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.
The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.
 
The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.
 
The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
5 Enclosure


===.9 Emergency Lighting===
===.9 Emergency Lighting===
Line 126: Line 196:
No findings of significance were identified.
No findings of significance were identified.


===.10 Cold Shutdown Repairs===
===.10 Cold Shutdown Repair===
 
s


====a. Inspection Scope====
====a. Inspection Scope====
Line 137: Line 209:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions or capabilities). The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.
The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post
-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions or capabilities). The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.


6 Enclosure
===.12 Review and Documentation of Fire Protection Program===


===.12 Review and Documentation of Fire Protection Program Changes===
Changes


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post-fire safe shutdown analysis and procedures.
The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post
-fire safe shutdown analysis and procedures.


====b. Findings====
====b. Findings====
Line 155: Line 229:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed. The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
The inspectors reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed.
 
The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.


====b. Findings====
====b. Findings====
Line 163: Line 239:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that: Procedures were being maintained and adequate;  Equipment was properly staged, maintained, and tested;  Station personnel were knowledgeable and could implement the procedures; and  Additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b related equipment. The inspectors reviewed the licensee's B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the 7 Enclosure licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections. The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of Nuclear Energy Institute (NEI) 06-12, "B.5.b Phase II and III Submittal Guidance," Revision 2 are evaluated each time due to the mitigation strategies' scenario selected. NEI 06-12, Revision 2, Section Licensee Strategy (Table) Selected for Review 3.2.2 Off-site and On-site Communications (Table A.3-1) Evaluated 3.2.3 Notification/Emergency Response Organization Activation (Table A.3-1) Evaluated 3.2.4 Initial Operation Response Actions (Table A.3-1) Evaluated 3.2.5 Initial Damage Assessment (Table A.3-1) Evaluated 3.3.3 Manual Operation of Turbine-Driven Auxiliary Feedwater Pump (Table A.4-3) Selected 3.3.6 Containment Flooding with Portable Pump (Table A.4-6) Selected
The inspectors reviewed the licensee's preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that:
Procedures were being maintained and adequate
;  Equipment was properly staged
, maintained, and tested
;  Station personnel were knowledgeable and could implement the procedures; and  Additionally, inspectors review ed the storage, maintenance, and testing of B.5.b related equipment.
 
The inspectors reviewed the licensee's B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections.
 
The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of Nuclear Energy Institute (NEI) 06
-12, "B.5.b Phase II and III Submittal Guidance," Revision 2 are evaluated each time due to the mitigation strategies' scenario selected.
 
NEI 06-12, Revision 2, Section Licensee Strategy (Table)
Selected for Review 3.2.2 Off-site and On
-site Communications (Table A.3
-1) Evaluated 3.2.3 Notification/Emergency Response Organization Activation (Table A.3
-1) Evaluated 3.2.4 Initial Operation Response Actions (Table A.3-1) Evaluated 3.2.5 Initial Damage Assessment (Table A.3
-1) Evaluated 3.3.3 Manual Operation of Turbine
-Driven Auxiliary Feedwater Pump (Table A.4
-3) Selected 3.3.6 Containment Flooding with Portable Pump (Table A.4
-6) Selected


====b. Findings====
====b. Findings====
Line 170: Line 265:
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
==4OA2 Identification and Resolution==
{{IP sample|IP=IP 71152}}
 
of Problems (71152)


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the Fire Protection Program at an appropriate threshold and entering them in the Corrective Action Program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.
The inspectors reviewed the licensee's corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the Fire Protection Program at an appropriate threshold and entering them in the Corrective Action Program.
 
The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non
-conformance documents.


====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==


===.1 Exit Meeting Summary On November 25, 2013, the inspectors presented the inspection results to Mr. R. Seizer, and other members of the licensee staff.===
===.1 Exit Meeting Summary===
The licensee acknowledged the issues 8 Enclosure presented. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
 
On November 25, 2013, the inspectors presented the inspection results to Mr. R. Seizer
, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
 
===.2 Interim Exit Meetings===
 
On November 8, 2013, the inspectors presented the preliminary inspection results to Mr. E. McCartney, and other members of the licensee staff.


===.2 Interim Exit Meetings On November 8, 2013, the inspectors presented the preliminary inspection results to Mr. E. McCartney, and other members of the licensee staff.
{{a|4OA7}}
{{a|4OA7}}
==4OA7 Licensee-Identified Violations==
==4OA7 Licensee-Identified Violations==
===
 
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. The licensee identified a finding of very low safety significance (Green) and associated NCV of Technical Specification 5.4.1.h for the failure to control transient combustible material in accordance with the Fire Protection Program requirements. Technical Specification Section 5.4.1.h for Units 1 and 2 required that written procedures be established, implemented, and maintained, covering activities related to Fire Protection Program implementation. Nuclear Procedure (NP) 1.9.9, "Transient Combustible Control," Revision 23, Section 2.10 stated, in part, that no transient combustible material be allowed in combustible exclusion zones without specific evaluation and the approval of the fire protection engineer. Contrary to the above, on September 17, 2013, the licensee failed to implement the guidelines specified in Procedure NP 1.9.9 and identified two instances where transient combustibles were located in combustion exclusion zones. The licensee entered this issue into their Corrective Action Program as Action Request (AR) AR01904510 and removed the transient combustible materials. The finding was associated with the Initiating Events cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations. The inspectors evaluated the finding using the Significance Determination Process (SDP) in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012, and Appendix F, "Fire Protection Significance Determination Worksheet," dated September 20, 2013. This finding screened to a Phase II analysis in accordance with SDP Phase I based on review of the "Fire Prevention and Administrative Controls" Section of IMC 0609. Using IMC 0609 Appendix F, Attachment 2, "Degradation Rating Guidance Specific to Various Fire Protection Program Elements," dated February 28, 2005, the inspectors determined that the finding resulted in a low degradation from the combustible controls program and screened the finding as having very low safety significance (Green). ATTACHMENT:   
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
 
The licensee identified a finding of very low safety significance (Green) and associated NCV of Technical Specification 5.4.1.h for the failure to control transient combustible material in accordance with the Fire Protection Program requirements. Technical Specification Section 5.4.1.h for Units 1 and 2 required that written procedures be established, implemented, and maintained, covering activities related to Fire Protection Program implementation. Nuclear Procedure (NP) 1.9.9, "Transient Combustible Control," Revision 23, Section 2.10 stated, in part, that no transient combustible material be allowed in combustible exclusion zones without specific evaluation and the approval of the fire protection engineer. Contrary to the above, on September 17, 2013, the licensee failed to implement the guidelines specified in Procedure NP 1.9.9 and identified two instances where transient combustibles were located in combustion exclusion zones. The licensee entered this issue into their Corrective Action Program as Action Request (AR)
AR01904510 and removed the transient combustible materials
. The finding was associated with the Initiating Events cornerstone attribute of Protection Against External Factors (Fire)and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations
. The inspectors evaluated the finding using the Significance Determination Process (SDP) in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012, and Appendix F, "Fire Protection Significance Determination Worksheet," dated September 20, 2013. This finding screened to a Phase II analysis in accordance with SDP Phase I based on review of the "Fire Prevention and Administrative Controls" Section of IMC 0609. Using IMC 0609 Appendix F, Attachment 2, "Degradation Rating Guidance Specific to Various Fire Protection Program Elements," dated February 28, 2005, the inspectors determined that the finding resulted in a low degradation from the combustible controls program and screened the finding as having very low safety significance (Green).
 
ATTACHMENT:   


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
Attachment
Licensee  
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC
: [[contact::E. McCartney]], Site Director  
T Licensee  
: [[contact::R. Wright]], Plant General Manager  
: [[contact::E. McCartney]], Site Director
: [[contact::J. Fischer]], Fire Protection Engineer  
: [[contact::R. Wright]], Plant General Manager
: [[contact::K. Locke]], Licensing Engineering Analyst
: [[contact::J. Fischer]], Fire Protection Engineer
: [[contact::R. Mrozinsky]], Appendix R Engineer  
: [[contact::K. Locke]], Licensing Engineering Analyst  
: [[contact::V. Rubano]], Fleet NFPA 805 Project Manager  
: [[contact::R. Mrozinsky]], Appendix R Engineer
: [[contact::E. Schmidt]], Engineering Supervisor  
: [[contact::V. Rubano]], Fleet NFPA 805 Project Manager
: [[contact::T. Schneider]], License Engineering  
: [[contact::E. Schmidt]], Engineering Supervisor
: [[contact::R. Seizert]], Licensing Supervisor  
: [[contact::T. Schneider]], License Engineering
: [[contact::B. Woyak]], Engineering Manager Nuclear Regulatory Commission  
: [[contact::R. Seizert]], Licensing Supervisor
: [[contact::D. Betancourt]], Acting Senior Resident Inspector  
: [[contact::B. Woyak]], Engineering Manager
: [[contact::B. Bartlett]], Acting Senior Resident Inspector  
Nuclear Regulatory Commission
: [[contact::K. Barclay]], Resident Inspector  
: [[contact::D. Betancourt]], Acting Senior Resident Inspector
==LIST OF ITEMS==
: [[contact::B. Bartlett]], Acting Senior Resident Inspector
OPENED, CLOSED AND DISCUSSED
: [[contact::K. Barclay]], Resident Inspector
===Opened, Closed, and Discussed===
LIST OF ITEMS OPENED, CLOSED AND DISCUSS
ED Opened, Closed,
and Discussed
None.
None.
Attachment  
Attachment
==LIST OF DOCUMENTS REVIEWED==
LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
The following is a list of documents reviewed during the inspection.
CALCULATIONS
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
Number Description or Title
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
Date or Revision
: CALCULATIONS Number Description or Title Date or Revision 2004-004 MAAP4 Analysis for Appendix R Timing of Restoration of AFW and Charging Flow January 20, 2005 2005-0054 Control Building Gothic Temperature Calculation 4 95-0094 Acceptance Criteria for
2004-004 MAAP4 Analysis for Appendix R Timing of Restoration of AFW
: TS-74, Annual Underground Fire Main Flow Test June 26, 1995 FPTE 015 Technical Evaluation of Acceptance Testing For The Cable Spreading Room, Vital Switchgear Room And Auxiliary Feedwater Pump Room Halon System 1
and Charging Flow
: COMPLETED SURVEILLANCES Number Description or Title Date or Revision
January 20, 2005
: RMP 9384-1 Appendix R Emergency Lighting Testing and Maintenance August 15, 2013
2005-0054 Control Building Gothic Temperature Calculation
: 352007 Discharge Test Concentration Log - Cable Spreading, Vital Electric Switchgear, and Auxiliary Feedwater Rooms
95-0094 Acceptance Criteria for TS
: September 20, 1984 0-PT-FP-004 Annual Fire Pump Capacity Test July 26, 2013
-74, Annual Underground Fire Main Flow Test
: TS-78 Semiannual Halon 1301 Fire Suppression Surveillance Test March 15, 2013
June 26, 1995
: TS-78 Semiannual Halon 1301 Fire Suppression Surveillance Test September 24, 2013
FPTE 015 Technical Evaluation of Acceptance Testing For The Cable Spreading Room, Vital Switchgear Room And Auxiliary Feedwater Pump Room Halon System
: RMP 9057
COMPLETED SURVEILLANCES
: Fire Barrier Penetration Fire Seal Surveillance August 11, 2011
Number Description or Title
: RMP 9057
Date or Revision
: Fire Barrier Penetration Fire Seal Surveillance February 27, 2013
RMP 9384-1 Appendix R Emergency Lighting Testing and Maintenance
: CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION Number Description or Title Date or Revision
August 15, 2013
: 1914362 FEP 4.16 - Control Room/Cable Spreading Room/Computer Room October 22, 2013
2007 Discharge Test Concentration Log  
: 1914696 Drawing
- Cable Spreading, Vital Electric Switchgear, and Auxiliary Feedwater Rooms
: PBC-219 Sheet 27 Shows Inaccurate W12 Switch Location October 23, 2013
September 20, 1984
: Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION Number Description or Title Date or Revision
0-PT-FP-004 Annual Fire Pump Capacity Test
: 1914764 NRC Triennial - B.5.b Flowchart Concerns October 23, 2013
July 26, 2013
: 1914872
TS-78 Semiannual Halon 1301 Fire Suppression Surveillance Test
: EDMG-2 - Loss of Large Areas of the Plant Due to Fire or Explosions October 24, 2013
March 15, 2013
: 1915145 NRC Triennial-Unsecured Items in Non Vital Switchgear Room October 24, 2013
TS-78 Semiannual Halon 1301 Fire Suppression Surveillance Test
: 1915268 NRC Triennial - Timeliness of Corrective Actions October 25, 2013
September 24, 2013
: 1917802
RMP 9057 Fire Barrier Penetration Fire Seal Surveillance
: EDMG-2 Att. F TD AFW Pump Local Operation Procedure Flowpath November 5, 2013
August 11, 2011
: 1917813 NRC Triennial -
RMP 9057 Fire Barrier Penetration Fire Seal Surveillance
: AOP 10A Operation of TDAFP November 5, 2013
February 27, 2013
: 1918130 NRC Triennial - Transient Combustibles Identified Near ADVs November 5, 2013
CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION
: 1918133 Triennial Fire Protection - Missing Appendix R Label November 5, 2013
Number Description or Title
: 1918141 NRC Triennial - Cable Identification for Appendix R Equipment November 5, 2013
Date or Revision
: 1918487 NRC Triennial - Discussion of NFPA 805 Comp Measures November 6, 2013
1914362 FEP 4.16 - Control Room/Cable Spreading Room/Computer Room
: 1918804 NRC Triennial -
October 22, 2013
: AOP 10A Guidance Improvement November 7, 2013
1914696 Drawing PBC
: 1919120
-219 Sheet 27 Shows Inaccurate W12 Switch Location
: RMP 9057 - Fire Barrier Penetration Seal Surveillance November 8, 2013
October 23, 2013
: 1919180 Triennial Fire Protection - Unresolved Item November 8, 2013
 
: 1921659 NRC Triennial - Error Identified in NFPA 805 Report November 19, 2013
Attachment
: CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION
: 1232138 Comments on 125 V DC Vendor Calc.'s After Owner's Review August 12, 2003
Number Description or Title
: 1263584 Radios May Not Function Properly for Appendix R Fire November 5, 2004
Date or Revision
: 1290079 Treatment of Safe Shutdown Manual Actions During NFPA 805 Transition March 14, 2006
1914764 NRC Triennial  
: 1323111 NFPA 13 Issues with G-01 and G-02 Room Sprinklers July 12, 2007
- B.5.b Flowchart Concerns
: 1339552 Calculation 2001-0049 Identified Issues with Fire Pump Power Supply March 21, 2008
October 23, 2013
: 1345411 Appendix R Common Enclosure Concern June 16, 2013
1914872 EDMG-2 - Loss of Large Areas of the Plant Due to Fire or Explosions
: 1356884 B.5.b Fire Drills December 17, 2008
October 24, 2013
: 1400837 Changes to OM 3.27 Rev 40 for
1915145 NRC Triennial
: EC 13407 November 30, 2010
-Unsecured Items in Non Vital Switchgear Room
: 1621315 OM 3.27 -
October 24, 2013
: EC 259831 &
1915268 NRC Triennial  
: 259835 EPU Procedure Revisions per
- Timeliness of Corrective Actions October 25, 2013
: EC 259831 and February 18, 2011
1917802 EDMG-2 Att. F TD AFW Pump Local Operation Procedure Flowpath
: Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
November 5, 2013
: EC 259835.
1917813 NRC Triennial
: 1623991 Degraded Fire Seal Between PAB and AFP Room February 25, 2011
- AOP 10A Operation of TDAFP November 5, 2013
: 1636540 IER1 11-1 Vulnerability: Inadequate B.5.b Pump April 1, 2011
1918130 NRC Triennial  
: 1638260
- Transient Combustibles Identified Near ADVs
: OI-40 - Fire Detection System Reset Instruction for Alarms April 6, 2011
November 5, 2013
: 1669330 Japan Earthquake
1918133 Triennial Fire Protection  
: EDMG-2 B.5.b Pump Prolonged Use with No AC July 14, 2011
- Missing Appendix R Label
: 1669678 NRC URI - Loss of Diesel-Driven Fire Pump Suction During Test July 15, 2011
November 5, 2013
: 1672387 Less Than Timely Training Review Committee Actions July 26, 2011
1918141 NRC Triennial  
: 1678233 Appendix R Concern Identified During Review of CDBI Question August 16, 2011
- Cable Identification for Appendix R Equipment
: 1713472 Computer RM Smoke Detectors Not Installed Per NFPA Standards December 7, 2011
November 5, 2013
: 1713509 Fire Detection Procedures Do Not Meet NFPA Standards December 7, 2011
1918487 NRC Triennial  
: 1713517 Control Room Smoke Detector Coverage May Not Meet NFPA December 7, 2011
- Discussion of NFPA 805 Comp Measures
: 1725575 Fire Detection Modification is Still Not Fully Implemented January 18, 2012
November 6, 2013
: 1787922 AFW Modification Has Not Finished Fire Protection Program Document Revisions July 26, 2012
1918804 NRC Triennial  
: 1805552 There Seems To Be a Lack of Respect for Fire Detection at PB September 21, 2012
- AOP 10A Guidance Improvement
: 1844088 WO to Repair Fire Detection Panel Pushed Out Another Year January 31, 2013
November 7, 2013
: 1848619 WO to Repair D-405 Pushed Out 6 Months February 15, 2013
1919120 RMP 9057  
: 1854599 D-416 Delay In Alarm Function March 7, 2013
- Fire Barrier Penetration Seal
: 1858707 NRC
Surveillance
: IN 2013-02 Issues Potentially Affecting Fire Safety March 21, 2013
November 8, 2013
: 1875052
1919180 Triennial Fire Protection  
: NFPA-805 Electrical Review "Short Time Pick-up" Concerns May 16, 2013
- Unresolved Item
: 1879465 Cable Running Through Combustible Exclusion Zone June 5, 2013
November 8, 2013
: 1904510 Inadequate Control of Transient Combustibles September 17, 2013
21659 NRC Triennial  
: DRAWINGS Number Description or Title Date or Revision 6118 E-1 Single Line Diagram Station Connections 28 6118 E-6 Sh. 1 Single Line Diagram 125V DC Distribution 60 
- Error Identified in NFPA 805 Report
: Attachment DRAWINGS Number Description or Title Date or Revision System 6118 E-6 Sh. 2 Single Line Diagram 125V DC Distribution System 19
November 19, 2013
: 6118 E-6 Sh. 3 Single Line Diagram 125V DC Distribution System 4 6118 E-98 Sh. 50D Panel Schedule 125V DC Panel D-28 (D-40) 12
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
: PBC-218, Sh. 2 Fire Protection for Turbine Building Aux Building and Containment Elev. 8'-0" 23 MFPL
Number Description or Title
: 00001010 Fire emergency Procedure 4.12 Turbine & Aux Building Elev 8'0" 10 MFPL
Date or Revision
: 000015111 Fire Barrier Locations Turbine Building, Aux Building and Containment Elev 8'0"
232138 Comments on 125 V DC Vendor Calc.'s After Owner's Review
: 11 MFPL
August 12, 200
: 000015225 Fire Protection Turbine Building, Aux Building and Containment Elev 8'0 23 MFPL
1263584 Radios May Not Function Properly for Appendix R Fire
: 000015312 Fire Protection Turbine Building, Aux Building and Containment Elev 26'0"
November 5, 2004
: 11 MFPL
290079 Treatment of Safe Shutdown Manual Actions During NFPA 805 Transition
: 000015410 Fire Protection Turbine Building, Aux Building and Containment Elev 44'0"
March 14, 2006
: 10 MFPL
23111 NFPA 13 Issues with G
: 000015606 Fire Protection Turbine Building and Containment Elev 66'0"
-01 and G-02 Room Sprinklers
: 6 MFPK
July 12, 2007
: 00000123 P&ID Fire Protection Water Unit 2 23 MFPK
1339552 Calculation 2001
: 00000502 P&ID Halon Fire Protection System 2 MFPK
-0049 Identified Issues with Fire Pump Power Supply
: 00000736 P&ID Fire Protec./Sprinkler Sys Unit 1 36 EFPL
March 21, 2008
: 00001103 Electrical Layout Fire Detection Control Bldg
1345411 Appendix R Common Enclosure Concern
: EL 60'0" 3 EFPL
June 16, 2013
: 00001405 Electrical Layout Fire Detection Control Bldg
1356884 B.5.b Fire Drills
: EL 26'0" 5 E147
December 17, 2008
: 01800103 Electrical Layout Fire Detection Control Bldg EL 8'0" 3
1400837 Changes to OM 3.27 Rev
: MISCELLANEOUS DOCUMENTS Number Description or Title Date or Revision
for EC 13407
: MR 00-063 Install New 900 MHZ Radio System May 22, 2002
November 30, 2010
: IWP 00-63 Work Order Plan Point to Point Testing for Appendix R Safe Shutdown Analysis June 26, 2001 PC 6 Part 1 Monthly Operations Inventory Report October 24, 2013
21315 OM 3.27 - EC 259831 & 259835 EPU Procedure Revisions per EC 259831 and February 18, 2011
: PROCEDURES Number Description or Title Date or Revision 0-PT-FP-013 Quarterly Operations B.5.b Fire Equipment Inventory Report 7
 
: AOP-10A Safe Shutdown - Local Control 63 
Attachment
: Attachment PROCEDURES Number Description or Title Date or Revision
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
: AOP-30 Temporary Ventilation for Vital Areas 8
Number Description or Title
: CS-13 ERO Notification 4
Date or Revision
: EDMG-2 Loss of Large Areas of the Plant Due to Fire or Explosion 7 EPIP 2.1 Notifications - ERO, State and Counties, and
EC 259835.
: NRC 47
23991 Degraded Fire Seal Between PAB and AFP Room February 25, 2011
: FEP-4.0 Fire Emergency Plan 5
1636540 IER1 11-1 Vulnerability: Inadequate B.5.b Pump April 1, 2011
: FEP-4.12 Auxiliary Feedwater Pump And Vital Switchgear Area 9
1638260 OI-40 - Fire Detection System Reset Instruction for Alarms
: FEP-4.13 Emergency Diesel Generator (G01/G02) And Compressor Rooms 10
April 6, 2011
: FEP-4.16 Control Room/Cable Spreading Room/Computer Room 9 FOP 1.2 Potential Fire Affected Safe Shutdown Components 21 FPTE 007 Technical Evaluation of PBNP Point-to- Point Portable Radio Communications for an Appendix R Fire 2
1669330 Japan Earthquake EDMG
: MA-AA-100-1008 Station Housekeeping And Material Control 5 NP 1.9.13 Ignition Control Procedure 19 NP 1.9.9 Transient Combustible Control 23
-2 B.5.b Pump Prolonged Use with No AC
: OI-40 Fire Detection System Reset Instructions for Alarms and Detectors 10
July 14,
: OI-62B Turbine-Driven Auxiliary Feedwater System (P-29) 27 OM 3.27 Control of Fire Protection & Appendix R Safe Shutdown Equipment 50
2011 1669678 NRC URI - Loss of Diesel
: RMP 262 Emergency Replacement of Power Supply Cables to RHR and CCW Pump Motors 2
-Driven Fire Pump Suction During Test
: RMP 9006-4 Component Cooling Water Pump Motor Emergency Replacement 11
July 15, 2011
: RMP 9376-12 Emergency Power for Containment MOVs 2
1672387 Less Than Timely Training Review Committee Actions
: WORK ORDERS Number Description or Title Date or Revision
July 26, 2011
: 40100443 01
1678233 Appendix R Concern Identified During Review of CDBI Question
: EL-LTG11, 2 Year Test of Emergency Light Batteries Group II February 10, 2012
August 16, 2011
: 40141461 01
1713472 Computer RM Smoke Detectors Not Installed Per NFPA Standards
: EL-LTGIV, 2 Year Test of Emergency Light Batteries May 12, 2013
December 7, 2011
: 40160612 01
1713509 Fire Detection Procedures Do Not Meet NFPA Standards
: EL-LTG III, 2 Year Test of Emergency Light Batteries February 6, 2013
December 7, 2011
: 40067174 01 P-011A/B-M SPR, Inspect Spare CCW Motor (Warehouse No. 3) February 8, 2011  
1713517 Control Room Smoke Detector Coverage May Not Meet NFPA
: Attachment
December 7, 2011
==LIST OF ACRONYMS==
25575 Fire Detection Modification is Still Not Fully Implemented
: [[USED]] [[]]
January 18, 2012
: [[AC]] [[Alternating Current]]
1787922 AFW Modification Has Not Finished Fire Protection Program
: [[ADAMS]] [[Agencywide Document Access Management System]]
Document Revisions
: [[ADV]] [[Atmospheric Dump Valve]]
July 26, 2012
: [[AFP]] [[Auxiliary Feedwater Pump]]
1805552 There Seems To Be a Lack of Respect for Fire Detection at PB
: [[AFW]] [[Auxiliary Feedwater]]
September 21, 2012 1844088 WO to Repair Fire Detection Panel Pushed Out Another Year
: [[AOP]] [[Abnormal Operating Procedure]]
January 31, 2013
: [[AR]] [[Action Request]]
1848619 WO to Repair D
: [[CCW]] [[Component Cooling Water]]
-405 Pushed Out 6 Months
: [[CDBI]] [[Component Design Basis Inspection]]
February 15, 2013
: [[CFR]] [[Code of Federal Regulations]]
1854599 D-416 Delay In Alarm Function
: [[DC]] [[Direct Current]]
March 7, 2013
: [[EC]] [[Engineering Change]]
1858707 NRC IN 2013
: [[EDMG]] [[Extensive Damage Mitigation Guideline]]
-02 Issues Potentially Affecting Fire Safety
: [[EPIP]] [[Emergency Plan Implementing Procedures]]
March 21, 2013
: [[EPU]] [[Extended Power Uprate]]
1875052 NFPA-805 Electrical Review "Short Time Pick-up" Concerns
: [[ERO]] [[Emergency Response Organization]]
May 16, 2013
: [[IMC]] [[Inspection Manual Chapter]]
1879465 Cable Running Through Combustible Exclusion Zone
: [[IN]] [[Information Notice]]
June 5, 2013
: [[IR]] [[Inspection Report MHz Megahertz]]
1904510 Inadequate Control of Transient Combustibles
: [[MOV]] [[Motor-Operated Valve]]
September 17,
: [[NCV]] [[Non-Cited Violation]]
2013 DRAWINGS Number Description or Title
: [[NFPA]] [[National Fire Protection Association]]
Date or Revision
: [[NRC]] [[]]
6118 E-1 Single Line Diagram Station Connections
: [[U.S.]] [[Nuclear Regulatory Commission]]
6118 E-6 Sh. 1 Single Line Diagram 125V DC Distribution
: [[OM]] [[Operations Manual]]
Attachment
: [[P&ID]] [[Piping and Instrumentation Drawing]]
DRAWINGS Number Description or Title
: [[PAB]] [[Primary Auxiliary Building]]
Date or Revision
: [[PARS]] [[Publicly Available Records]]
System 6118 E-6 Sh. 2 Single Line Diagram 125V DC Distribution System 19 6118 E-6 Sh. 3 Single Line Diagram 125V DC Distribution System 4 6118 E-98 Sh. 50D
: [[PBNP]] [[Point Beach Nuclear Plant]]
Panel Schedule 125V DC Panel D
: [[RHR]] [[Residual Heat Removal]]
-28 (D-40) 12 PBC-218, Sh. 2
: [[SSD]] [[Safe Shutdown]]
Fire Protection for Turbine Building Aux Building and Containment Elev. 8'
: [[TCCF]] [[Transient Combustible Control Form]]
-0" 23 MFPL 00001010 Fire emergency Procedure 4.12 Turbine & Aux Building Elev 8'0"
: [[TDAFW]] [[Turbine Driven Auxiliary Feedwater Pump WO Work Orde]]
MFPL 000015111
: [[L.]] [[Meyer    -2- In accordance with Title 10, Code of Federal Regulations (]]
Fire Barrier Locations Turbine Building, Aux Building
: [[CFR]] [[), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response (if any), will be available electronically for public inspection in the]]
and Containment Elev 8'0"
: [[NRC]] [[Public Document Room or from the Publicly Available Records System (]]
MFPL 000015225
: [[PARS]] [[) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the]]
Fire Protection Turbine Building, Aux Building
: [[NRC]] [[Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /]]
and Containment Elev 8'0 23 MFPL 000015312
RA/
Fire Protection Turbine Building, Aux Building
Robert
and Containment Elev 26'0"
: [[C.]] [[Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-266; 50-301 License Nos.]]
MFPL 000015410
: [[DPR]] [[-24; DPR-27 Enclosure: Inspection Report 05000266/2013010; and 05000301/2013010   w/Attachment:  Supplemental Information cc w/encl: Distribution via ListServŽ]]
Fire Protection Turbine Building, Aux Building
and Containment Elev 44'0"
MFPL 000015606
Fire Protection Turbine Building
and Containment Elev 66'0"
MFPK 00000123
P&ID Fire Protection Water Unit 2
MFPK 00000502
P&ID Halon Fire Protection System
MFPK 00000736
P&ID Fire Protec./Sprinkler Sys Unit 1
EFPL 00001103
Electrical Layout Fire Detection Control Bldg EL 60'0"
EFPL 00001405
Electrical Layout Fire Detection Control Bldg EL 26'0"
E147 01800103
Electrical Layout Fire Detection Control Bldg EL 8'0"
MISCELLANEOUS DOCUMENTS
Number Description or Title
Date or Revision
MR 00-063 Install New 900 MHZ Radio System May 22, 2002
IWP 00-63 Work Order Plan Point to Point Testing for Appendix R Safe Shutdown Analysis
June 26, 2001
PC 6 Part 1
Monthly Operations Inventory Report
October 24, 2013
PROCEDURES
Number Description or Title
Date or Revision
0-PT-FP-013 Quarterly Operations B.5.b Fire Equipment Inventory Report
AOP-10A Safe Shutdown  
- Local Control
Attachment
PROCEDURES
Number Description or Title
Date or Revision
AOP-30 Temporary Ventilation for Vital Areas
CS-13 ERO Notification
EDMG-2 Loss of Large Areas of the Plant Due to Fire or Explosion
EPIP 2.1 Notifications  
- ERO, State and Counties, and NRC 47 FEP-4.0 Fire Emergency Plan
FEP-4.12 Auxiliary Feedwater Pump And Vital Switchgear Area
FEP-4.13 Emergency Diesel Generator (G01/G02) And Compressor Rooms
FEP-4.16 Control Room/Cable
Spreading Room/Computer Room
FOP 1.2 Potential Fire Affected Safe Shutdown Components
FPTE 007 Technical Evaluation of PBNP Point
-to- Point Portable Radio Communications for an Appendix R Fire
MA-AA-100-1008 Station Housekeeping And Material Control 5 NP 1.9.13
Ignition Control Procedure
NP 1.9.9 Transient Combustible Control
OI-40 Fire Detection System Reset Instructions for Alarms and Detectors
OI-62B Turbine-Driven Auxiliary Feedwater System (P
-29) 27 OM 3.27 Control of Fire Protection & Appendix R Safe Shutdown Equipment
RMP 262 Emergency Replacement of Power Supply Cables to RHR and CCW Pump Motors
RMP 9006-4 Component Cooling Water Pump Motor Emergency Replacement
RMP 9376-12 Emergency Power for Containment MOVs
WORK ORDERS
Number Description or Title
Date or Revision
40100443 01
EL-LTG11, 2 Year Test of Emergency Light Batteries Group
II February 10, 2012
40141461 01
EL-LTGIV, 2 Year Test of Emergency Light Batteries
May 12, 2013
40160612 01
EL-LTG III, 2
Year Test of Emergency Light Batteries
February 6, 2013
40067174 01
P-011A/B-M SPR, Inspect Spare CCW Motor (Warehouse No. 3) February 8, 2011
 
Attachment
LIST OF ACRONYMS USE
D  AC Alternating Current
ADAMS Agencywide Document Access Management System
ADV Atmospheric Dump Valve
AFP Auxiliary Feedwater Pump
AFW Auxiliary Feedwater
AOP Abnormal Operating Procedure
AR Action Request
CCW Component Cooling Water
CDBI Component Design Basis Inspection
CFR Code of Federal Regulations
DC Direct Current
EC Engineering Change
EDMG Extensive Damage Mitigation Guideline
EPIP Emergency Plan Implementing Procedures
EPU Extended Power Uprate
ERO Emergency Response Organization
IMC Inspection Manual Chapter
IN Information Notice
IR Inspection Report
MHz Megahertz
MOV Motor-Operated Valve
NCV Non-Cited Violation
NFPA National Fire Protection Association
NRC U.S. Nuclear Regulatory Commission
OM Operations Manual
P&ID Piping and Instrumentation Drawing
PAB Primary Auxiliary Building
PARS Publicly Available Records
PBNP Point Beach Nuclear Plant
RHR Residual Heat Removal
SSD Safe Shutdown
TCCF Transient Combustible Control Form
TDAFW Turbine Driven Auxiliary Feedwater Pump
WO Work Orde  
: [[contact::L. Meyer    -2- In accordance with Title 10]], Code of Federal Regulations
(CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading
-rm/adams.html
(the Public Electronic Reading Room).
Sincerely,
  /RA/
Robert  
: [[contact::C. Daley]], Chief
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50
-266; 50-301 License Nos. DPR
-24; DPR-27 Enclosure:
Inspection Report 05000266/2013010; and 05000301/2013010
w/Attachment:  Supplemental Information
cc w/encl:
Distribution via ListServŽ
}}
}}

Revision as of 12:31, 3 July 2018

IR 05000266-13-010, 05000301-13-010; on 10/21/2013 - 11/25/2013; Point Beach Nuclear Plant, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection
ML13340A790
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 12/06/2013
From: Daley R C
Engineering Branch 3
To: Meyer L
Point Beach
Dariusz Szwarc
References
IR-13-010
Download: ML13340A790 (20)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 December 6, 2013

Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241

SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

, TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000266/2013010; 05000301/2013010

Dear Mr. Meyer:

On November 25, 2013, the U.S. Nuclear Regulato ry Commission (NRC) completed a Triennial Fire Protection Inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 8, 2013, with Mr. E. McCartney, and on November 25, 2013, with Mr. B. Woyak and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

No NRC-identified or self-revealing findings were identified during this inspection.

However, inspectors documented a licensee

-identified violation which was determined to be of very low safety significance (Green) in Section 4OA7 of this report.

The NRC is treating this violation as a Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the subject or severity of any Non-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555

-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission

- Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532

-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washing ton, DC 20555

-0001; and the NRC Resident Inspector office at the Point Beach Nuclear Plant, Units 1 and 2

. In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos.

50-266; 50-301 License Nos. DPR-24; DPR-27

Enclosure:

Inspection Report 05000 266/2013010; 05000301/2013010

w/Attachment:

Supplemental Information cc w/encl:

Distribution via ListServ

Ž Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No s: 50-266; 50-301 License No s: DPR-24; DPR-27 Report No:

05000266/2013010; 05000301/2013010 Licensee:

NextEra Energy Point Beach, LLC Facility:

Point Beach Nuclear Plant, Units 1 and 2 Location:

Two Rivers, WI Dates: October 21 through November 25, 2013 Inspectors:

D. Szwarc, Senior Reactor Inspector, Lead M. Munir, Reactor Inspector D. Oliver, Reactor Inspector R. Winter, Reactor Inspector Approved by:

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure

SUMMARY

IR 05000266/2013010, 05000301/2013010; 10/21/2013 - 11/25/2013

Point Beach Nuclear Plant, Units 1 and 2
Routine Triennial Fire Protection Baseline Inspection.

This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III inspectors.

The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated June 7, 2012.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified

and Self-Revealed Findings No findings were identified.

B. Licensee-Identified Violations

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

REPORT DETAILS

REACTOR SAFETY

Cornerstone s: Initiating Events and Mitigating Systems

1R05 Fire Protection

(71111.05T)

The licensee was in transition to National Fire Protection Association (NFPA) 805

, "Performance

-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," as incorporated by 10 CFR 50.48(c). The NFPA 805 standard establishes a comprehensive set of requirements for Fire Protection Program s at nuclear power plants. The standard incorporates both deterministic and risk

-informed, performance

-based concepts. The deterministic aspects of the standard are comparable to traditional requirements. However, the transition to a risk

-informed, performance

-based Fire Protection Program requires an in

-depth nuclear safety circuit analysis for equipment identified for nuclear safety functions such as safe shutdown. Because the conversion and licensing process to NFPA 805 was expected to identify and address a variety of issues that were normally the subject of the Triennial Fire Protection Baseline Inspection, the Nuclear Regulatory Commission (

NRC) modified the Enforcement Policy for licensees in transition to NFPA 805. As part of the transition to NFPA 805, certain findings not associated with findings of high-safety significance that meet the four criteria established by Section A of the NRC's Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)receive enforcement discretion in accordance with the NRC's Enforcement Policy.

The purpose of the fire protection triennial baseline inspection was to conduct a design-based, plant specific, risk

-informed, onsite inspection of the licensee's Fire Protection Program's defense-in-depth elements used to mitigate the consequences of a fire

. The Fire Protection Program shall extend the concept of defense

-in-depth to fire protection in plant areas important to safety by

preventing fires from starting; rapidly detecting, controlling and extinguishing fires that do occur; providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.

The inspectors' evaluation focused on the design, operational status, and material condition of the reactor plant

's Fire Protection Program

, post-fire safe shutdown systems, and B.5.b mitigating strategies

. The objectives of the inspecti on were to assess whether the licensee ha d implemented a Fire Protection Program that: (1) provided adequate controls for combustibles and ignition sources inside the plant; (2) provided adequate fire detection and suppression capability; (3)maintained passive fire protection features in good material condition; (4)established adequate compensatory measures for out

-of-service, degraded or inoperable fire protection equipment, systems or features; (5)ensured that procedures, equipment, fire barriers and systems exist so that the post

-fire capability to safely shut down the plant was ensured; (6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and (7) identifie d fire protection issues at an appropriate threshold and ensure d these issues were entered into the licensee's problem identification and resolution program.

In addition, the inspectors' review and assessment focused on the licensee's post

-fire safe shutdown systems for selected risk significant fire areas. Inspector emphasis was placed on determining that the post

-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post

-fire safe shutdown success path was available. The inspectors' review and assessment also focused on the licensee's B.5.b related license conditions and the requirements of Title 10, Code of Federal Regulations (10 CFR) Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.

The fire areas and fire zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas and fire zones selected constitute d four inspection samples and the B.5.b mitigating strategies selected constitute d two inspection samples, respectively, as defined in Inspection Procedure 71111.05T. Fire Area Fire Zone Description A23N 304N Auxiliary Feedwater Pump Room North A30 318 Cable Spreading Room A33 337 Control Building Heating, Ventilation, and Air Conditioning (HVAC) Room A71 308 Diesel Generator Room

.2 Protection of Safe Shutdown Capabilities

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected.

The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post

-fire safe shutdown analysis and procedures.

b. Findings

No findings of significance were identified.

.3 Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments.

The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area. The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings of significance were identified.

.4 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.

b. Findings

No findings of significance were identified.

.5 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.

b. Findings

No findings of significance were identified.

.6 Alternative Shutdown Capability

a. Inspection Scope

The inspectors reviewed the licensee's systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.

The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls

.

b. Findings

No findings of significance were identified

.7 Circuit Analyses

a. Inspection Scope

The inspectors did not review the licensee's post-fire safe shutdown (SSD) analysis because the licensee was in transition to NFPA 805.

b. Findings

No findings of significance were identified.

.8 Communications

a. Inspection Scope

The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.

The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.

The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.

b. Findings

No findings of significance were identified.

.9 Emergency Lighting

a. Inspection Scope

The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repair

s

a. Inspection Scope

The inspectors reviewed the licensee's procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available onsite. The inspectors also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available onsite and properly staged.

b. Findings

No findings of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post

-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions or capabilities). The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.

b. Findings

No findings of significance were identified.

.12 Review and Documentation of Fire Protection Program

Changes

a. Inspection Scope

The inspectors reviewed changes to the approved Fire Protection Program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the Fire Protection Program and/or post

-fire safe shutdown analysis and procedures.

b. Findings

No findings of significance were identified.

.13 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The inspectors reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed.

The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.

b. Findings

No findings of significance were identified.

.14 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensee's preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that:

Procedures were being maintained and adequate

Equipment was properly staged

, maintained, and tested

Station personnel were knowledgeable and could implement the procedures; and Additionally, inspectors review ed the storage, maintenance, and testing of B.5.b related equipment.

The inspectors reviewed the licensee's B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections.

The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of Nuclear Energy Institute (NEI) 06

-12, "B.5.b Phase II and III Submittal Guidance," Revision 2 are evaluated each time due to the mitigation strategies' scenario selected.

NEI 06-12, Revision 2, Section Licensee Strategy (Table)

Selected for Review 3.2.2 Off-site and On

-site Communications (Table A.3

-1) Evaluated 3.2.3 Notification/Emergency Response Organization Activation (Table A.3

-1) Evaluated 3.2.4 Initial Operation Response Actions (Table A.3-1) Evaluated 3.2.5 Initial Damage Assessment (Table A.3

-1) Evaluated 3.3.3 Manual Operation of Turbine

-Driven Auxiliary Feedwater Pump (Table A.4

-3) Selected 3.3.6 Containment Flooding with Portable Pump (Table A.4

-6) Selected

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution

of Problems (71152)

a. Inspection Scope

The inspectors reviewed the licensee's corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the Fire Protection Program at an appropriate threshold and entering them in the Corrective Action Program.

The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non

-conformance documents.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On November 25, 2013, the inspectors presented the inspection results to Mr. R. Seizer

, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

.2 Interim Exit Meetings

On November 8, 2013, the inspectors presented the preliminary inspection results to Mr. E. McCartney, and other members of the licensee staff.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

The licensee identified a finding of very low safety significance (Green) and associated NCV of Technical Specification 5.4.1.h for the failure to control transient combustible material in accordance with the Fire Protection Program requirements. Technical Specification Section 5.4.1.h for Units 1 and 2 required that written procedures be established, implemented, and maintained, covering activities related to Fire Protection Program implementation. Nuclear Procedure (NP) 1.9.9, "Transient Combustible Control," Revision 23, Section 2.10 stated, in part, that no transient combustible material be allowed in combustible exclusion zones without specific evaluation and the approval of the fire protection engineer. Contrary to the above, on September 17, 2013, the licensee failed to implement the guidelines specified in Procedure NP 1.9.9 and identified two instances where transient combustibles were located in combustion exclusion zones. The licensee entered this issue into their Corrective Action Program as Action Request (AR)

AR01904510 and removed the transient combustible materials

. The finding was associated with the Initiating Events cornerstone attribute of Protection Against External Factors (Fire)and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations

. The inspectors evaluated the finding using the Significance Determination Process (SDP) in accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012, and Appendix F, "Fire Protection Significance Determination Worksheet," dated September 20, 2013. This finding screened to a Phase II analysis in accordance with SDP Phase I based on review of the "Fire Prevention and Administrative Controls" Section of IMC 0609. Using IMC 0609 Appendix F, Attachment 2, "Degradation Rating Guidance Specific to Various Fire Protection Program Elements," dated February 28, 2005, the inspectors determined that the finding resulted in a low degradation from the combustible controls program and screened the finding as having very low safety significance (Green).

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Attachment

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC

T Licensee

E. McCartney, Site Director
R. Wright, Plant General Manager
J. Fischer, Fire Protection Engineer
K. Locke, Licensing Engineering Analyst
R. Mrozinsky, Appendix R Engineer
V. Rubano, Fleet NFPA 805 Project Manager
E. Schmidt, Engineering Supervisor
T. Schneider, License Engineering
R. Seizert, Licensing Supervisor
B. Woyak, Engineering Manager

Nuclear Regulatory Commission

D. Betancourt, Acting Senior Resident Inspector
B. Bartlett, Acting Senior Resident Inspector
K. Barclay, Resident Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSS

ED Opened, Closed,

and Discussed

None.

Attachment

LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

CALCULATIONS

Number Description or Title

Date or Revision

2004-004 MAAP4 Analysis for Appendix R Timing of Restoration of AFW

and Charging Flow

January 20, 2005

2005-0054 Control Building Gothic Temperature Calculation

95-0094 Acceptance Criteria for TS

-74, Annual Underground Fire Main Flow Test

June 26, 1995

FPTE 015 Technical Evaluation of Acceptance Testing For The Cable Spreading Room, Vital Switchgear Room And Auxiliary Feedwater Pump Room Halon System

COMPLETED SURVEILLANCES

Number Description or Title

Date or Revision

RMP 9384-1 Appendix R Emergency Lighting Testing and Maintenance

August 15, 2013

2007 Discharge Test Concentration Log

- Cable Spreading, Vital Electric Switchgear, and Auxiliary Feedwater Rooms

September 20, 1984

0-PT-FP-004 Annual Fire Pump Capacity Test

July 26, 2013

TS-78 Semiannual Halon 1301 Fire Suppression Surveillance Test

March 15, 2013

TS-78 Semiannual Halon 1301 Fire Suppression Surveillance Test

September 24, 2013

RMP 9057 Fire Barrier Penetration Fire Seal Surveillance

August 11, 2011

RMP 9057 Fire Barrier Penetration Fire Seal Surveillance

February 27, 2013

CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION

Number Description or Title

Date or Revision

1914362 FEP 4.16 - Control Room/Cable Spreading Room/Computer Room

October 22, 2013

1914696 Drawing PBC

-219 Sheet 27 Shows Inaccurate W12 Switch Location

October 23, 2013

Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION

Number Description or Title

Date or Revision

1914764 NRC Triennial

- B.5.b Flowchart Concerns

October 23, 2013

1914872 EDMG-2 - Loss of Large Areas of the Plant Due to Fire or Explosions

October 24, 2013

1915145 NRC Triennial

-Unsecured Items in Non Vital Switchgear Room

October 24, 2013

1915268 NRC Triennial

- Timeliness of Corrective Actions October 25, 2013

1917802 EDMG-2 Att. F TD AFW Pump Local Operation Procedure Flowpath

November 5, 2013

1917813 NRC Triennial

- AOP 10A Operation of TDAFP November 5, 2013

1918130 NRC Triennial

- Transient Combustibles Identified Near ADVs

November 5, 2013

1918133 Triennial Fire Protection

- Missing Appendix R Label

November 5, 2013

1918141 NRC Triennial

- Cable Identification for Appendix R Equipment

November 5, 2013

1918487 NRC Triennial

- Discussion of NFPA 805 Comp Measures

November 6, 2013

1918804 NRC Triennial

- AOP 10A Guidance Improvement

November 7, 2013

1919120 RMP 9057

- Fire Barrier Penetration Seal

Surveillance

November 8, 2013

1919180 Triennial Fire Protection

- Unresolved Item

November 8, 2013

21659 NRC Triennial

- Error Identified in NFPA 805 Report

November 19, 2013

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

Date or Revision

232138 Comments on 125 V DC Vendor Calc.'s After Owner's Review

August 12, 200

1263584 Radios May Not Function Properly for Appendix R Fire

November 5, 2004

290079 Treatment of Safe Shutdown Manual Actions During NFPA 805 Transition

March 14, 2006

23111 NFPA 13 Issues with G

-01 and G-02 Room Sprinklers

July 12, 2007

1339552 Calculation 2001

-0049 Identified Issues with Fire Pump Power Supply

March 21, 2008

1345411 Appendix R Common Enclosure Concern

June 16, 2013

1356884 B.5.b Fire Drills

December 17, 2008

1400837 Changes to OM 3.27 Rev

for EC 13407

November 30, 2010

21315 OM 3.27 - EC 259831 & 259835 EPU Procedure Revisions per EC 259831 and February 18, 2011

Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

Number Description or Title

Date or Revision

EC 259835.

23991 Degraded Fire Seal Between PAB and AFP Room February 25, 2011

1636540 IER1 11-1 Vulnerability: Inadequate B.5.b Pump April 1, 2011

1638260 OI-40 - Fire Detection System Reset Instruction for Alarms

April 6, 2011

1669330 Japan Earthquake EDMG

-2 B.5.b Pump Prolonged Use with No AC

July 14,

2011 1669678 NRC URI - Loss of Diesel

-Driven Fire Pump Suction During Test

July 15, 2011

1672387 Less Than Timely Training Review Committee Actions

July 26, 2011

1678233 Appendix R Concern Identified During Review of CDBI Question

August 16, 2011

1713472 Computer RM Smoke Detectors Not Installed Per NFPA Standards

December 7, 2011

1713509 Fire Detection Procedures Do Not Meet NFPA Standards

December 7, 2011

1713517 Control Room Smoke Detector Coverage May Not Meet NFPA

December 7, 2011

25575 Fire Detection Modification is Still Not Fully Implemented

January 18, 2012

1787922 AFW Modification Has Not Finished Fire Protection Program

Document Revisions

July 26, 2012

1805552 There Seems To Be a Lack of Respect for Fire Detection at PB

September 21, 2012 1844088 WO to Repair Fire Detection Panel Pushed Out Another Year

January 31, 2013

1848619 WO to Repair D

-405 Pushed Out 6 Months

February 15, 2013

1854599 D-416 Delay In Alarm Function

March 7, 2013

1858707 NRC IN 2013

-02 Issues Potentially Affecting Fire Safety

March 21, 2013

1875052 NFPA-805 Electrical Review "Short Time Pick-up" Concerns

May 16, 2013

1879465 Cable Running Through Combustible Exclusion Zone

June 5, 2013

1904510 Inadequate Control of Transient Combustibles

September 17,

2013 DRAWINGS Number Description or Title

Date or Revision

6118 E-1 Single Line Diagram Station Connections

6118 E-6 Sh. 1 Single Line Diagram 125V DC Distribution

Attachment

DRAWINGS Number Description or Title

Date or Revision

System 6118 E-6 Sh. 2 Single Line Diagram 125V DC Distribution System 19 6118 E-6 Sh. 3 Single Line Diagram 125V DC Distribution System 4 6118 E-98 Sh. 50D

Panel Schedule 125V DC Panel D

-28 (D-40) 12 PBC-218, Sh. 2

Fire Protection for Turbine Building Aux Building and Containment Elev. 8'

-0" 23 MFPL 00001010 Fire emergency Procedure 4.12 Turbine & Aux Building Elev 8'0"

MFPL 000015111

Fire Barrier Locations Turbine Building, Aux Building

and Containment Elev 8'0"

MFPL 000015225

Fire Protection Turbine Building, Aux Building

and Containment Elev 8'0 23 MFPL 000015312

Fire Protection Turbine Building, Aux Building

and Containment Elev 26'0"

MFPL 000015410

Fire Protection Turbine Building, Aux Building

and Containment Elev 44'0"

MFPL 000015606

Fire Protection Turbine Building

and Containment Elev 66'0"

MFPK 00000123

P&ID Fire Protection Water Unit 2

MFPK 00000502

P&ID Halon Fire Protection System

MFPK 00000736

P&ID Fire Protec./Sprinkler Sys Unit 1

EFPL 00001103

Electrical Layout Fire Detection Control Bldg EL 60'0"

EFPL 00001405

Electrical Layout Fire Detection Control Bldg EL 26'0"

E147 01800103

Electrical Layout Fire Detection Control Bldg EL 8'0"

MISCELLANEOUS DOCUMENTS

Number Description or Title

Date or Revision

MR 00-063 Install New 900 MHZ Radio System May 22, 2002

IWP 00-63 Work Order Plan Point to Point Testing for Appendix R Safe Shutdown Analysis

June 26, 2001

PC 6 Part 1

Monthly Operations Inventory Report

October 24, 2013

PROCEDURES

Number Description or Title

Date or Revision

0-PT-FP-013 Quarterly Operations B.5.b Fire Equipment Inventory Report

AOP-10A Safe Shutdown

- Local Control

Attachment

PROCEDURES

Number Description or Title

Date or Revision

AOP-30 Temporary Ventilation for Vital Areas

CS-13 ERO Notification

EDMG-2 Loss of Large Areas of the Plant Due to Fire or Explosion

EPIP 2.1 Notifications

- ERO, State and Counties, and NRC 47 FEP-4.0 Fire Emergency Plan

FEP-4.12 Auxiliary Feedwater Pump And Vital Switchgear Area

FEP-4.13 Emergency Diesel Generator (G01/G02) And Compressor Rooms

FEP-4.16 Control Room/Cable

Spreading Room/Computer Room

FOP 1.2 Potential Fire Affected Safe Shutdown Components

FPTE 007 Technical Evaluation of PBNP Point

-to- Point Portable Radio Communications for an Appendix R Fire

MA-AA-100-1008 Station Housekeeping And Material Control 5 NP 1.9.13

Ignition Control Procedure

NP 1.9.9 Transient Combustible Control

OI-40 Fire Detection System Reset Instructions for Alarms and Detectors

OI-62B Turbine-Driven Auxiliary Feedwater System (P

-29) 27 OM 3.27 Control of Fire Protection & Appendix R Safe Shutdown Equipment

RMP 262 Emergency Replacement of Power Supply Cables to RHR and CCW Pump Motors

RMP 9006-4 Component Cooling Water Pump Motor Emergency Replacement

RMP 9376-12 Emergency Power for Containment MOVs

WORK ORDERS

Number Description or Title

Date or Revision

40100443 01

EL-LTG11, 2 Year Test of Emergency Light Batteries Group

II February 10, 2012

40141461 01

EL-LTGIV, 2 Year Test of Emergency Light Batteries

May 12, 2013

40160612 01

EL-LTG III, 2

Year Test of Emergency Light Batteries

February 6, 2013

40067174 01

P-011A/B-M SPR, Inspect Spare CCW Motor (Warehouse No. 3) February 8, 2011

Attachment

LIST OF ACRONYMS USE

D AC Alternating Current

ADAMS Agencywide Document Access Management System

ADV Atmospheric Dump Valve

AFP Auxiliary Feedwater Pump

AFW Auxiliary Feedwater

AOP Abnormal Operating Procedure

AR Action Request

CCW Component Cooling Water

CDBI Component Design Basis Inspection

CFR Code of Federal Regulations

DC Direct Current

EC Engineering Change

EDMG Extensive Damage Mitigation Guideline

EPIP Emergency Plan Implementing Procedures

EPU Extended Power Uprate

ERO Emergency Response Organization

IMC Inspection Manual Chapter

IN Information Notice

IR Inspection Report

MHz Megahertz

MOV Motor-Operated Valve

NCV Non-Cited Violation

NFPA National Fire Protection Association

NRC U.S. Nuclear Regulatory Commission

OM Operations Manual

P&ID Piping and Instrumentation Drawing

PAB Primary Auxiliary Building

PARS Publicly Available Records

PBNP Point Beach Nuclear Plant

RHR Residual Heat Removal

SSD Safe Shutdown

TCCF Transient Combustible Control Form

TDAFW Turbine Driven Auxiliary Feedwater Pump

WO Work Orde

L. Meyer -2- In accordance with Title 10, Code of Federal Regulations

(CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

/RA/

Robert

C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50

-266; 50-301 License Nos. DPR

-24; DPR-27 Enclosure:

Inspection Report 05000266/2013010; and 05000301/2013010

w/Attachment: Supplemental Information

cc w/encl:

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