Revision as of 14:00, 31 July 2018

Text

IR 05000305-11-008 (Drs), on 09/07/2011 - 09/09/2011, 09/19/2011 - 09/23/2011, and 10/03/2011 10/07/2011, Kewaunee Power Station, Triennial Fire Protection Baseline Inspection
	ML11319A244
Person / Time
Site:	Kewaunee
Issue date:	11/14/2011
From:	Daley R C; Engineering Branch 3
To:	Heacock D A; Dominion Energy Kewaunee
References
	IR-11-008
	Download: ML11319A244 (26)
	v • d • e

November 14, 2011

Mr. David President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT: KEWAUNEE POWER STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000305/2011008(DRS)

Dear Mr. Heacock:

On October 7, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Kewaunee Power Station. The enclosed inspection report documents the inspection results, which were discussed on October 7, 2011, with Mr. Stephen Scace, 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. Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified. The finding involved a violation of NRC requirements. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating this issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy. If you contest the subject or severity of the NCV, 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, Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Kewaunee Power Station. In accordance with Title 10, Code of Federal Regulations (CFR), Part 50, Section 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records 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 No. 50-305 License No. DPR-43

Enclosures:

Inspection Report 05000305/2011008(DRS)

w/Attachment:

Supplemental Information cc w/encl: Distribution via ListServŽ Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 050000305 License No: DPR-43 Report No: 05000305/2011008(DRS)

Licensee: Dominion Energy Kewaunee, Inc. Facility: Kewaunee Power Station Location: Kewaunee, WI Dates: September 7 - 9, 19 - 23, 2011, and October 3 - 7, 2011 Inspectors: George M. Hausman, Senior Reactor Inspector, Lead Larry J. Jones, Reactor Inspector Benny Jose, Senior Reactor Inspector Nicholas A. Valos, Senior Reactor Analyst Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety 1 Enclosure

SUMMARY OF FINDINGS

IR 05000305/2011008 (DRS); 09/07/2011 - 09/09/2011, 09/19/2011 - 09/23/2011, and 10/03/2011 - 10/07/2011; Kewaunee Power Station; Triennial Fire Protection Baseline Inspection. This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. One (Green) finding was identified by the inspectors. The finding was considered a Non-Cited Violation (NCV) of U.S. Nuclear Regulatory Commission (NRC) regulations. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, "Significance

Determination Process (SDP)." Findings for which the SDP does not apply may be (Green) or be assigned a severity level after NRC management review. The cross-cutting aspects, if any, were determined using IMC 0310, "Components Within the Cross-Cutting Areas." 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

Cornerstone: Initiating Events

Green.

The inspectors identified a finding of very low safety significance and associated NCV of Title 10, Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, "Design Control," for the failure to check the adequacy of design for flammable gas bottles installed and/or stored in fire areas and fire zones located within the auxiliary building and their impact on safe shutdown cables, safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and a resulting fire or explosion at the installed and/or stored locations could impact nearby safety-related structures, systems, or components. The licensee entered this issue into their corrective action program to review the placement of the flammable gas bottles. The inspectors determined that the finding was more than minor because the finding was associated with the Initiating Events cornerstone attribute of Protection against External Factors (Fire) and affected the cornerstone's objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was of very low safety significance due to the low fire initiating frequency and the availability of remaining mitigating systems. This finding did not have a cross-cutting aspect because the finding was not representative of current performance. (Section 1R05.11b)

B. Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection

Main article: IP 71111.05T

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, 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 (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.

3 Enclosure The fire areas/zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas/zones selected constitute three samples and the B.5.b mitigating strategies selected constitute four samples as defined by Inspection Procedure (IP) 71111.05T. Fire Area Fire Zone Description A (Alternate) TU-92 1-B Emergency Diesel Generator (EDG) D (Dedicated) TU-95A Dedicated Shutdown Panel Room A (Alternate) TU-95B Safeguards Alley

.1 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 ensured that applicable separation requirements of Section lll.G of 10 CFR 50, Appendix R and the licensee's design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.

b. Findings

No findings of significance were identified.

.2 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. In addition, the inspectors reviewed license documentation, such as U.S. Nuclear Regulatory Commission (NRC) safety evaluation reports (SERs), 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.

b. Findings

No findings of significance were identified.

4 Enclosure

.3 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 SERs, 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.

.4 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.

.5 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.

5 Enclosure

.6 Circuit Analyses

a. Inspection Scope

The inspectors verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the inspectors verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown. The inspectors' review considered fire and cable attributes, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events. The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices. The inspectors reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. Additionally, the inspectors reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.

b. Findings

No findings of significance were identified.

.7 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 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.

6 Enclosure

.8 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 walkdown, 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.

.9 Cold Shutdown Repairs

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.

.10 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 on 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.

7 Enclosure

.11 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

Flammable Gas Bottles Installed and/or Stored in the Auxiliary Building

Introduction:

The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to check the adequacy of design for flammable gas bottles installed and/or stored in fire areas and fire zones located within the auxiliary building and their impact on safe shutdown cables, safety-related cables and safety-related equipment.

Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and a resulting fire or explosion at the installed and/or stored locations could impact nearby safety-related structures, systems, or components.

Description:

In response to NUREG-0578, "TMI-2 [Three Mile Island Unit 2] Lessons Learned Task Force Report and Short Term Recommendations," Section 2.1.8.a and Appendix A, "Improved Post-Accident Sampling Capability," dated July 1979, and NUREG-0737, "Clarification of TMI Action Plan Requirements,"Section II.B.3, "Post-Accident Sampling Capability," dated October 31, 1980, the licensee initiated a modification for post accident containment air monitoring. On March 4, 1980, the licensee approved Design Change Request (DCR) 844, "Addition of High Radiation Sample Room" and subsequently installed the DCR per the TMI Action Item II.B.3. As a result, the licensee installed three compressed hydrogen bottles, two compressed oxygen bottles, and associated equipment near the high radiation sampling room (HRSR) on the 586 foot elevation of the auxiliary building. The flammable gas bottles were located in the "Reactor Auxiliaries North Center" area of the Dedicated Fire Area's Fire Zone 23B. A fire hazards evaluation or safety evaluation for the flammable gas bottles was not found in the DCR. The flammable gas bottles' combustible quantities were added to the Kewaunee Power Station's Fire Protection Program Analysis (FPPA), Revision 2 in October 1986. On September 7, 2011, during the inspectors' walkdown to identify the fire areas and fire zones to be inspected, additional flammable gas bottles were observed physically installed and/or stored in the auxiliary building. The licensee had installed three compressed methane bottles, two compressed acetylene bottles (one bottle in-use and one bottle stored), and associated equipment on the fan floor's 657 foot-6 inch elevation of the auxiliary building. The flammable gas bottles were located in the "Refueling Water Storage Tank Area" of the Alternate Fire Area's Fire Zone AX-23A. A fire hazards evaluation or safety evaluation for the flammable gas bottles was not found in the DCR.

8 Enclosure During the inspectors' walkdowns, the inspectors noticed that the flammable gas bottles, at the different elevations, were within close proximity of safe shutdown cables and safety-related equipment (e.g., Technical Specification specified equipment) at each location. The inspectors raised concerns about the locations of the flammable gas bottles with respect to the safe shutdown cables, safety-related cables and safety-related equipment located within the fire areas and fire zones. The flammable gas bottles present a fire and an explosion hazard. According to Table 2-7.1 of the Society of Fire Protection Engineers (SFPE) Handbook of Fire Protection Engineering (Fourth Edition) acetylene, hydrogen and methane have a lower flammability limit of 2.5, 4, and 5 percent, and an upper flammability limit of 100, 75, and 15 percent, respectively. This means that an acetylene mixture of between 2.5 and 100 percent, a hydrogen mixture of between 4 and 75 percent, and a methane mixture of between 5 and 15 percent will burn. One hydrogen bottle had a mixture of 50 percent hydrogen and 50 percent nitrogen, the second had a mixture of 9 percent hydrogen and 91 percent nitrogen, and the third bottle, although empty at the time of the inspectors' observation, had contained 2 percent hydrogen and 98 percent nitrogen, both of the acetylene bottles were 100 percent, and the three methane bottles had a mixture of 10 percent methane and 90 percent argon. Each of the hydrogen and methane bottles and one of the acetylene bottles had a regulator attached to the discharge. However, if a piece of equipment or some object were to hit the regulator it could fail, cause a spark, and ignite the flammable gas. A fire from one or more of the flammable gas bottles could damage safe shutdown cables and/or safety-related cables and an explosion could additionally damage other nearby safety-related equipment. The approved fire protection program has three primary tiers that constitute defense-in-depth. These include preventing and minimizing the effects of fires, detecting and suppressing fires, and safe shutdown. Each of the three tiers has regulatory requirements needed for compliance with General Design Criterion 3. In addition, the impact to safe shutdown capability is not the only consideration when evaluating a plant change. The change must still satisfy the regulatory requirement of 10 CFR 50.48(a) by having a program satisfying Criterion 3 of 10 CFR Part 50, Appendix A. Criterion 3 specifies a program such that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. A fire hazards evaluation or safety evaluation for the flammable gas bottles was not found in either of the DCRs. As a result, the inspectors concluded that the licensee failed to check the adequacy of the design for the flammable gas bottles installed and stored locations and their impact on safe shutdown cables, safety-related cables, and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and a resulting fire or explosion at the installed and/or stored locations could impact the defense-in-depth strategies for the licensee's fire protection program. The licensee entered this issue into their corrective action program as Condition Report (CR) 446453, "NRC Identifies Potential Issue for Flammable Gas Bottles Located in Aux Bldg," dated October 6, 2011, to review the placement of the flammable gas bottles.

Analysis:

The inspectors determined that the failure to evaluate the impact of the flammable gas bottles' installed and/or stored locations near safe shutdown cables, safety-related cables and safety-related equipment was contrary to 10 CFR Part 50, 9 Enclosure Appendix B, Criterion III, "Design Control," and was a performance deficiency. The inspectors determined that the finding was more than minor because the finding was associated with the Initiating Events cornerstone attribute of Protection against External Factors (Fire) and affected the cornerstone's objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the installed and/or stored locations of the flammable gas bottles could have resulted in damage to safe shutdown cables, safety-related cables, and safety-related equipment if the gas bottles were to ignite or explode. As a result, the licensee's fire protection program's defense-in-depth strategies for the affected fire areas and fire zones were degraded. In accordance with Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," Attachment 0609.04, "Phase I - Initial Screening and Characterization of Findings," Table 3b the inspectors determined the finding degraded the fire protection defense-in-depth strategies. Therefore, screening under IMC 0609, Appendix F, "Fire Protection Significance Determination Process," was required. The inspectors determined that the finding impacted the Fire Prevention and Administrative Controls category. Based on review of IMC 0609, Appendix F, Attachment 2, "Degradation Rating Guidance Specific to Various Fire Protection Program Elements," the inspectors determined the degradation rating to be high because of the flammable gases being more flammable than low flashpoint combustibles and there being a significant fire hazard associated with release of the gas. The Duration Factor was 1.0 based on the duration of the degradation being greater than 30 days per Table 1.4.1, "Duration Factors." An overall fire frequency of 7E-3 per year was calculated for the flammable gas bottles based on information from IMC 0609, Appendix F, Attachment 4, "Fire Ignition Source Mapping Information: Fire Frequency, Counting Instructions, Applicable Fire Severity Characteristics, and Applicable Manual Fire Suppression Curves." The conditional core damage probability (CCDP) from Table 2.1.1, "Total Unavailability Values for SSD [Safe Shutdown] Path Based Screening CCDP," included a screening value of 1E-2, which was conservative. The Region III Senior Reactor Analyst used the Kewaunee Standard Plant Analysis Risk (SPAR) Model, Version 8.16, and Systems Analysis Programs for Hands-on Integrated Reliability Evaluations (SAPHIRE), Version 8.0.7.17 to calculate a CCDP of 1.1E-7. The Senior Reactor Analyst assumed that a fire due to failure of the flammable gas bottles would result in a reactor trip. Based on the above CCDP and frequency values, the risk associated with this finding is very low (Green). The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Contrary to the above, from March 4, 1980, through October 7, 2011, the licensee failed to check the adequacy of design for flammable gas bottles installed and/or stored in fire areas and fire zones located within the auxiliary building and their impact on safe 10 Enclosure shutdown cables, safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and a resulting fire or explosion at the installed and/or stored locations could impact nearby safety-related structures, systems, or components. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as CR 446453, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000305/2011008-01(DRS), Flammable Gas Bottles Installed and/or Stored in the Auxiliary Building).

.12 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.

.13 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 Part 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 the 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.

11 Enclosure The B.5.b mitigating strategies selected for review 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 the 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 2.2 Spent Fuel Pool (SFP) Makeup - Internal Strategy (Table A.2 1) 2.3.1 SFP Makeup - External Strategy (Table A.2-2)2.3.2 SFP Spray - External Strategy (Table A.2-3)3.4.4 Manually Depressurize SGs [Steam Generators] and Use Portable Pump (Table A.4-4)

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

Main article: IP 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

Exit Meeting Summary

The inspectors presented the inspection results to Mr. Stephen Scace and to other members of the licensee staff on October 7, 2011. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Allen, Senior Instructor Operations Training

E. Alsteen, Fire Marshall

S. Baldwin, Fire Training

B. Behrendt, Operations Supervisor

S. Boeing, Fire Protection (App. R Supplemental Support)

E. Brand, Fire Protection (App. R Supplemental Support)

T. Breene, Licensing Manager

E. Coen, PRA Engineer

C. Drescher, Design Engineer

C. Edwards, Maintenance Supervisor

J. Egdorf, Emergency Preparedness (B.5.b) Supervisor

M. Failey, Chemistry Supervisor

J. Gadzala, Licensing

R. Giese, Operations Senior Reactor Operator

J. Giesler, Primary Systems Supervisor

K. Gille, Procedures Supervisor

E. Gilson, Safety Supervisor

M. Haese, Licensing

D. Heling, Administrative Support

B. Herris, EP Manager

T. Hoy, Information Technology

B. Koehler, Engineering Program Supervisor

L. Leanna, Records Supervisor

J. Langan, Nuclear Oversight Manager

J. Martin, Liaison Engineer

B. O'Connell, Ventilation

T. Olson, Program Manager

R. Repshas, Regulatory Affairs

M. Rosseau, Electrical Design Supervisor

S. Salzsieder, Administrative Support

S. Scace, Site Vice-President

B. Schramm, Security Officer

M. Sievert, Engineer

C. Sly, Liaison Engineer

J. Stafford, Safety and Licensing Director

E. Streich, Electrical /Instrumentation and Control Supervisor

D. Tolete, Fire Protection Engineer

M. Townsend, Fire Protection Program Owner

D. Vorpahl, Balance of Plant Supervisor

S. Yuen, Director of Engineering

Nuclear Regulatory Commission

R. Krsek, Senior Resident Inspector

K. Barclay, Resident Inspector

2

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

05000305/2011008-01(DRS) NCV Flammable Gas Bottles Installed and/or Stored in the Auxiliary Building (Section 1R05.11b)

Closed

05000305/2011008-01(DRS) NCV Flammable Gas Bottles Installed and/or Stored in the Auxiliary Building (Section 1R05.11b)

Discussed

None.

3

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

C10016, Pages 1 - 2, 25 - 27, 34, 78, & Figure G.3 Electrical Penetration Coordination Study 4 C10016, Attachment H, Pages 2 - 15 of 59 Kewaunee Power Station (KPS) Design and License Basis Summary for Containment Electrical Penetration Protection

C11714, Attachment A, Page A65 of A212 Medium and Low Voltage Protection and Coordination Plots MCC 1-43 February 23, 2007 C11714, Attachment A, Page A159 of A212 Medium and Low Voltage Protection and Coordination Plots MCC 1-43B February 19, 2007 Calc. No. 180 Attachment 1, Sheet 13 of 65 Combustible Inventory Worksheet, Fire Zone / Area AX23A

Calc. No. 180 Attachment 1, Sheet 14 of 65 Combustible Inventory Worksheet, Fire Zone / Area AX23B

CHC1698 CO

System for the EDG Rooms May 4, 1999

CORRECTIVE ACTION PROGRAM DOCUMENTS (CRs) ISSUED DURING INSPECTION Number Description or Title Date or Revision

441840 NRC Triennial Inspection Team Questions/Comments on B.5.b September 7,

2011441921 Acceptability of Glass Cleaning Solution Questioned September 7,

2011441922 B.5.b Truck Not Starting September 7, 2011

443051 B.5.b Observations During NRC Triennial Fire Inspection September 15,

2011443986 Fire Protection Program Analysis for Zone

AX-23A Acetylene Quantity Incorrect September 21,

2011444954

Are the Appendix R Response Time Critical Operator Actions Validated On a Periodic Basis? September 27,

2011446161 Appendix R FPPA EDG CO

System Concentration Documentation Error October 5, 2011

446453 NRC Identifies Potential Issue for Flammable Gas Bottles Located in Aux Bldg October 6, 2011

CORRECTIVE ACTION PROGRAM DOCUMENTS (CRs) REVIEWED

Number Description or Title Date or Revision

119110

PRP-01 at the SCR Lobby Had an Outdated Revision November 17,

2008119304 Revise Fire Brigade Training Program Description to Include B.5.b Training November 18,

2008119459

PRP-01 Recommended Changes and Enhancements November 19,

2008119463

PRP-02 Recommended Changes and Enhancements November 19, 2008

119468 B.5.b Inventory Checklist November 19, 2008

119490 Ref. Godwin Pump Speed in

PRP-01 for RWST and

CST November 19,

2008119649 Vital Area Keys May Be Needed to Access Areas for

PRP-01, 2, 3 Actions November 20,

2008119787 Emergency Key Ring for SAS November 21,

2008339133 Emergency Light

RAB-9 Needs New Battery June 23, 2009

362354 B.5.b Response Truck Readiness December 17, 2009

384130 Replacement Batteries For Emergency Battery Lighting Fail PMT

June 10, 2010

407825 Simulator Emergency Light By EVA Panel Is Not Working December 16,

2010429328 B.5.b Pump PM Not Required to Flow Water June 1,2011

432783 Breaker 14305 Failed to Open for PZR Heater Group D June 30,2011

433367 Emergency Light RA01 Failed Its Retest July 6, 2011

DRAWINGS Number Description or Title Date or Revision

36373 Damper February 28, 1987 A-209 General Arrangement Reactor and Auxiliary Building Miscellaneous Floor Plan

AA A-211 General Arrangement Auxiliary and Turbine Building Cross Section

M A-511 Fire Zones Basement Floor Elev. 586'-0" A

E-228 Circuit Diagram 480V SWGR - Normal Buses AW

E-235 Circuit Diagram 480V SWGR.-Safeguard Buses AL

E-240 Circuit Diagram 4160V & 480V Power Sources AZ

E-262 Circuit Diagram 480V MCC 1-33A, 1-33B, 1-43A, 1-43B & 1-62G

W E-297 Cable Tray System - Aux Bldg Bsmt Plan El. 586' - 0" Sheet 1 Y E-301 Cable Tray System and Elec. Equip. Location - Aux Bldg El 626' - 0" & El 633' - 6" BW E-303 Cable Tray System - Aux Bldg - Plan - El. 642' - 3" G E-304 Cable Tray System - Aux Bldg - Plan - El. 657' - 6" D

5DRAWINGS Number Description or Title Date or Revision

E-334 Elec. Equip. Location Aux. Bldg. Mezz. Plan El. 606' - 0", Sheet 1 CG E-416 Front View - Motor Control Center 1-35F, 1-45F,

1-5262, 1-33A, 1-33B, 1-43A, 1-62G, & 1-45G AM E-520 W/D-Penetrations A1, A2, A4, A5 Junct. Boxes JB1086, JB1087, JB1137, JB1138

F E-536 Wiring Diagram - 480V SWGR. Bus 1-43 - Unit No. 2 J E-600 Wiring Diagram - Motor Control Center - 1--33A, 1-33B, 1-43A, 1-43B, & 1-62G

K E-621 External Connections - PRZR HTRS MCC 1--33A, 1-33B, 1-43A, 1-43B, & 1-62G

L E-1043 Control Schematic 4160V Breaker 1-509 V E-1872 Schematic Diagram Bus 5 Voltage Restoring Z

E-1874 Schematic Diagram Bus 5 Voltage Control X

E-2890 Front View - Motor Control Center 1-52B, 1-52F, 1-62B, Ext's

1-3852 & 1-62H

P

KW-3205-5 319 CLH Round Horiz. 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Fire Damper; UL Classified March 20, 1983

OPERM-205 Flow Diagram Feedwater System BL

PEROM-208-2 Flow Diagram Fire Protection System B

S-501 Turbine Building Foundation Plan Q

S-508 Administration Building Foundation Plan & Floor Drains R

EVALUATIONS Number Description or Title Date or Revision

- - - - - - - B.5.b Strategy Evaluations 1

ACE 018730 Circuit Breaker 14305BKR for Pressurizer Heater Group 1D Failed to Open on Demand September 6, 2011ECP 4.11 DCR No. 2522 pg. 7 of 7 July 21, 1993 FPEE No. 003 Fire Protection Engineering Evaluation For Manual Action Feasibility

FPEE No. 009 Exterior Wall Fire Ratings 0 FPEE No. 010 Turbine Building Structural Steel

0

FPEE No. 034 Allowable Cable Types 0

FPEE No. 037 Pressure Relief Blow Out Panel for

DGR 252 0

FPEE No. 040 Diesel Generator Rooms Carbon Dioxide Suppression Systems 01 FPEE No. 052 Evaluation of Periodic Testing Requirements 0 FPEE No. 064 Evaluation of Door 8 Replacement with Non-Fire Rated water tight door

N80982 CBS Nuclear Services, Inc. Root Cause Report for Circuit Breaker Serial Number H-61981F-9 August 8, 2011

6EVALUATIONS Number Description or Title Date or Revision

OEA No.92-112 Inadequate Fire Suppression System Testing January 31, 1994

MODIFICATIONS

Number Description or Title Date or Revision

DCR 844 Addition of High Radiation Sample Room (Selected Pages) March 4, 1980

DCR 2400 Relocation of Hot Chem Lab Bottles (Selected Pages) May 20, 1991

PRE-FIRE PLANS

Number Description or Title Date or Revision

PFP-17 Pre-Fire Plan for Charging Pump, Boric Acid Concentrate Pump and RHR Pump Pit Areas (AX-23B,

AX-23D,

AX-25 / Elevation 586') April 25, 2007

PFP-19 Pre-Fire Plan for Condensate Storage and Rx Make-up Water Storage Room and Adjacent Areas (AX-22,

AX-33,

AX-39 / Elevation 606') November 17, 2004PFP-27 Pre-Fire Plan for Hot Chem Lab and Shield Building Filter Assembly Areas (AX-23A,

AX-34,

AX-36 / Elevation 642') August 23, 2006

PFP-29 Pre-Fire Plan for Auxiliary Building and Turbine Building Fan Rooms (AX-23A,

AX-36 / Elevation 657') November 17, 2004

PROCEDURES

Number Description or Title Date or Revision

EPIP-AD-20 Response to a Security Threat 14

EPMPF-09.02-14 Site Relocation Facility (SRF) Communications Checklist

EPMPF-10.01-06 Emergency Equipment Quarterly Inventory 6

EPMPF-AD-07-10 ERO Event Notification 5

FPP-08-07 Control of Ignition Sources 12

FPP-08-11 Fire Brigade/Team Equipment Inspection 16

KW-PROC-000-GMP-

240 ELV - 480V Air Circuit Breaker and MCC Electrical Maintenance 29 & 30 MA-KW-ECM-RHR-

2

RHR-1B MOV RCS Pressure Interlock Bypass 1 MA-KW-ECM-RHR-

003

RHR-2B MOV RCS Pressure Interlock Bypass 1 MA-KW-ECM-RHR-

004 RHR Power Cable Restoration RHR Pump 1B Motor 1

7PROCEDURES

Number Description or Title Date or Revision

MA-KW-ECM-RHR-

005 RHR Power Cable Restoration RHR Pump 1B Fan Coil Unit 1

MA-KW-GIP-009 B.5.b Designated Equipment Storage and Maintenance 0 MA-KW-MPM-FP-

001 Safeguards Alley Preaction Sprinkler System Testing 2 MA-KW-MPM-FP-

007 Fire Hose Pressure Test 2 MA-KW-MPM-FP-

21B Inspection of Train B Fire Protection (FP) Dampers During Normal Plant Operation

MA-KW-MPM-FP-

21C Inspection of Fire Protection (FP) Dampers During Plant Shutdown

MA-KW-MPM-FP-

030A Inspection and Dry Test of CO2 System for Diesel Generator Room 1A

MA-KW-MPM-FP-

040 Annual Preventive Maintenance of Godwin Dri-Prime Portable Pump and John Deere Diesel Engine

MA-KW-MPM-FP-

041 2-Year Preventive Maintenance of Godwin Dri-Prime Portable Pump and John Deere Diesel Engine

MA-KW-MPM-FP-

25 Operability Test of Group 5 Fire Protection Dampers during Plant Shutdown

OP-KW-AOP-FP-001 Abnormal Operating Procedure - Fire 5

OP-KW-AOP-FP-002 Abnormal Operating Procedure; Fire in Alternate Fire Zone 10

OP-KW-AOP-FP-003 Abnormal Operating Procedure; Fire in dedicated Fire Zone 8 OP-KW-NCL-MISC-

001 Dedicated Shutdown System Periodic Checklist 7 OP-KW-ORT-SAE-

001 Control Room/Dedicated Shutdown System Emergency Equipment Inventory

PMP-08-09 FP - Automatic Sprinkler Dry Test 18

PMP-08-22

FP-Operability Test of Fire Dampers (Fusible link style) F

PMP-08-22

FP-Operability Test of Fire Dampers (Fusible link style) G

PMP-41-06

LT-Big Beam Emergency Light Common Train Electrical Maintenance- Appendix R and Non Appendix

R 23

PMP-41-06A

LT-Big Beam Emergency Light Train A Electrical Maintenance Appendix R and Non Appendix R

PMP-41-06B

LT-Big Beam Emergency Light Train B Electrical Maintenance, Appendix R and Non Appendix R

PRP-01 Recovery Plan for Catastrophic Event 12

PRP-02 Initial Response to Catastrophic Event 3

8PROCEDURES

Number Description or Title Date or Revision

PRP-03 Initial Response to Catastrophic Event for Loss of Control Room and Control Room Personnel

REFERENCES Number Description or TitleDate or Revision

ARDD Appendix R Design Description 7 EPM Report No. P1919-086-001 Identification and Evaluation of Communications Design Basis July 2008

FBI-01-LP001 Lesson Plan: Fire Brigade Initial Training

FBC-01 A FPPA Fire Protection Program Analysis 8

FPPP Fire Protection Program Plan 9

LRC-10-LP304 Lesson Plan: Fire in a Dedicated/Alternate Fire Zone Cycle 10-03

B

LRC-11-SE406 Lesson Plan: B.5.b. Review LOR Cycle 11-04 A NRC

Memorandum Summary of Public Meeting Held on March 15, 2011, to Discuss NRC Inspection Procedure 71111.05XT, "Fire Protection - NFPA 805 (Triennial) March 22, 2011 Standard Handbook for Elect. Engineers, Figure 4-15 Fusing Current Time for Copper Conductors 12 Edition

TR-AA-210, Attachment 3 Kewaunee Fire Brigade

FB-TP Training Program Description

VENDOR DOCUMENTS Number Description or TitleDate or Revision

23-7127A Cardox Pipe or Tank Break December 21,

197254126 Purchase Order: Air Balance Inc. July 8, 1983

AIRBA-0004 Fire/Seal Damper Model 319CL1T Horizontal only 0

AIRBA-0007 Air Balance Inc. Bendor Technical Manual

ALLIS-0023 (42990-2) Allis Chalmers Air Circuit Breaker Type

LA-600 &

LA-600F (Fused)

FL-16663 Cardox System Test December 4, 1973

GENER-0032 (216-1) 7700 Line Motor Control Center 11

OKONI-0001 (XK-54154) 3/C No. 6 CU Okoguard, Okolow w/3 314CC Grd. Wires - Okolon G.S. Lox

SQUAR-0027 (34248-2) 480V Motor Control Centers 4

WORK ORDERS (WOs) Number Description or TitleDate or Revision

KW100272182 Fire Damper Visual Inspection April 9, 2009

9WORK ORDERS (WOs) Number Description or TitleDate or Revision

KW100274024 PM08; Fire Hose Pressure Test November 24, 2009KW100307617 PM08-825; Test Sprinkler System - Safeguards Alley

February 24, 2009 KW100489368 PM08-825; Test Sprinkler System - Safeguards Alley March 11, 2010 KW100509694 Fire Damper Visual Inspection November 23, 2010KW100654037 PM08-825; Test Sprinkler System - Safeguards Alley February 10, 2011 KW100729242 PM87-894; 6 Month Maintenance and Inventory March 28. 2011 KW100730953 PM08-845; Perform Annual

PMS-B.5.b Pump June 10, 2011 KW100731904 PM08-846; Test Run-Pump Water from Lake Michigan-B.5.b Pump June 10, 2011

EPMPF-10.01-06 Emergency Equipment Quarterly Inventory June 6, 2011

FPP-08-11, Attachment A Fire Brigade Equipment Checklist June 23, 2011

WO-7-5288 Fire Damper Visual Inspection Sheet July 5, 2007

10

LIST OF ACRONYMS

USEDAD AMS Agencywide Documents Access and Management System

ATTN Attention

CFR Code of Federal Regulations

CCDP Conditional Core Damage Probability

CR Condition Report

DCR Design Change Request

DPR Demonstration Power Reactor

DRP Division of Reactor Project

DRS Division of Reactor Safety

EDG Emergency Diesel Generator

FPPA Fire Protection Program Analysis

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

KPS Kewaunee Power Station

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NFPA National Fire Protection Association

NRC [[]]

U.S. Nuclear Regulatory Commission

NUREG [[]]

NRC Technical Report Designation

OA Other Activities

PARS Public Available Records System

RHR Residual Heat Removal

SDP Significance Determination Process

SER Safety Evaluation Report

SFP Spent Fuel Pool

SFPE Society of Fire Protection Engineers

SG Steam Generator

TMI Three Mile Island WO Work Order

D. Heacock -2- 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 Resident Inspector Office at the Kewaunee Power Station. In accordance with Title 10, Code of Federal Regulations (CFR), Part 50, Section 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the]]

NRC Public Document Room or from the Publicly Available Records 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 No. 50-305 License No. DPR-43 Enclosures: Inspection Report 05000305/2011008(DRS) w/Attachment: Supplemental Information cc w/encl: Distribution via ListServŽ

DISTRI BUTION

See next page

DOCUME NT NAME: G:\DRSIII\DRS\Work in Progress\-KEWA

2011008 FPI [[]]

GMH.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE [[]]

RIII E

RIII [[]]

NAME GHausman: ls RDaley

DATE 11/09/11 11/14/11