IR 05000331/2006014: Difference between revisions

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{{Adams|number = ML063460555}}
{{Adams
| number = ML063460555
| issue date = 12/11/2006
| title = IR 05000331-06-014; Florida Power and Light Energy Duane Arnold, LLC; 09/11/06 - 11/15/06; Duane Arnold Energy Center; Routine Triennial Fire Protection Baseline Inspection
| author name = Lara J F
| author affiliation = NRC/RGN-III/DRS/EB3
| addressee name = VanMiddlesworth G D
| addressee affiliation = FPL Energy Duane Arnold, LLC
| docket = 05000331
| license number = DPR-049
| contact person =
| document report number = IR-06-014
| document type = Inspection Report, Letter
| page count = 23
}}


{{IR-Nav| site = 05000331 | year = 2006 | report number = 014 }}
{{IR-Nav| site = 05000331 | year = 2006 | report number = 014 }}
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===w/Attachment:===
===w/Attachment:===
Supplemental Informationcc w/encl:J. Stall, Senior Vice President, Nuclear and Chief Nuclear Officer R. Helfrich, Senior Attorney M. Ross, Managing Attorney W. Webster, Vice President, Nuclear Operations M. Warner, Vice President, Nuclear Operations Support R. Kundalkar, Vice President, Nuclear Engineering J. Bjorseth, Site Director D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs Chairman, Linn County Board of Supervisors D. McGhee, State Liaison Officer
Supplemental Informationcc w/encl:J. Stall, Senior Vice President, Nuclear and Chief Nuclear Officer R. Helfrich, Senior Attorney M. Ross, Managing Attorney W. Webster, Vice President, Nuclear Operations M. Warner, Vice President, Nuclear Operations Support R. Kundalkar, Vice President, Nuclear Engineering J. Bjorseth, Site Director D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs Chairman, Linn County Board of Supervisors D. McGhee, State Liaison Officer G. Van Middlesworth-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (thePublic Electronic Reading Room).
 
Sincerely,Julio F. Lara, ChiefEngineering Branch 3 Division of Reactor SafetyDocket No. 50-331License No. DPR-49
 
===Enclosure:===
Inspection Report 05000331/2006014
 
===w/Attachment:===
Supplemental Informationcc w/encl:J. Stall, Senior Vice President, Nuclear and Chief Nuclear Officer R. Helfrich, Senior Attorney M. Ross, Managing Attorney W. Webster, Vice President, Nuclear Operations M. Warner, Vice President, Nuclear Operations Support R. Kundalkar, Vice President, Nuclear Engineering J. Bjorseth, Site Director D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs Chairman, Linn County Board of Supervisors D. McGhee, State Liaison OfficerDISTRIBUTION
:TEB DWS RidsNrrDirsIrib GEG KGO GLS SRI Duane Arnold
 
CAA1 LSL DRPIII DRSIII PLB1 TXN ROPreports@nrc.gov DOCUMENT NAME:
G Publicly Available G Non-Publicly Available G Sensitive G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copyOFFICERIIIRIIIRIIIRIIINAMERLangstaff:jbBBurgessJLaraDATE12/06/0612/11/0612/11/06OFFICIAL RECORD COPY EnclosureU.S. NUCLEAR REGULATORY COMMISSIONREGION IIIDocket No.:License No.:50-331DRP-49Report No:05000331/2006014(DRS)Licensee:Florida Power and Light Energy Duane Arnold, LLC Facility:Duane Arnold Energy Center Location:Palo, Iowa 52324-9785 Dates:September 11 through November 15, 2006 Inspectors:R. Langstaff, Senior Reactor Inspector, LeadC. Moore, Operations Engineer D. Schrum, Reactor Inspector D. Szwarc, Reactor InspectorApproved by:Julio F. Lara, ChiefEngineering Branch 3 Division of Reactor Safety Enclosure 2


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
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No findings of significance were identified.
No findings of significance were identified.


Enclosure3
3


=REPORT DETAILS=
=REPORT DETAILS=
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The code incorporated both deterministic and risk-informed, performance-based concepts. The deterministic aspects of the code 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 NRC modified the fire protection inspection program and Enforcement Policy for licensees in transition to NFPA 805. As a result, this inspection was conducted inaccordance with IP 71111.05TTP, "Fire Protection - NFPA 805 Transition Period (Triennial)," dated May 9, 2006. Associated with the transition to NFPA 805, when a circuit-related finding not associated with a finding of high safety significance meets 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),
The code incorporated both deterministic and risk-informed, performance-based concepts. The deterministic aspects of the code 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 NRC modified the fire protection inspection program and Enforcement Policy for licensees in transition to NFPA 805. As a result, this inspection was conducted inaccordance with IP 71111.05TTP, "Fire Protection - NFPA 805 Transition Period (Triennial)," dated May 9, 2006. Associated with the transition to NFPA 805, when a circuit-related finding not associated with a finding of high safety significance meets 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),
the violation would receive enforcement discretion in accordance with the NRC's Enforcement Policy.The purpose of this inspection was to review the Duane Arnold Energy Center (DAEC)Fire Protection Program for selected risk-significant fire areas. 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 inspection was performed in accordance with the NRC's regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The team used the DAEC Individual Plant Examination for External Events to choose several risk-significant areas for detailed inspection and review. The fire zones chosen for review during this inspection constituted six-inspection samples which were:Fire Area/ZonesDescription07ATurbine Building - Reactor Feed Pump Area07BTurbine Building - 1A2, Lower Switchgear Room Fire Area/ZonesDescriptionEnclosure407CTurbine Building - Turbine Lube Oil Tank Area07ETurbine Building - Condensate Pump Area08FTurbine Building - 1G-21, "B" EDG Room (West)08GTurbine Building - "B" EDG Day Tank RoomFor each of these fire zones, the inspection focused on the fire protection features, thesystems and equipment necessary to achieve and maintain safe shutdown conditions, determination of license commitments, and changes to the Fire Protection Program..1Shutdown from Outside Main Control RoomTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that structures, systems, andcomponents that were necessary to achieve and maintain post-fire safe shutdown from outside the main control room be protected by fire protection features, such that, one train of systems necessary to achieve and maintain hot shutdown conditions was free of fire damage; and systems necessary to achieve and maintain cold shutdown could be repaired within 72-hours.
the violation would receive enforcement discretion in accordance with the NRC's Enforcement Policy.The purpose of this inspection was to review the Duane Arnold Energy Center (DAEC)Fire Protection Program for selected risk-significant fire areas. 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 inspection was performed in accordance with the NRC's regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The team used the DAEC Individual Plant Examination for External Events to choose several risk-significant areas for detailed inspection and review. The fire zones chosen for review during this inspection constituted six-inspection samples which were:Fire Area/ZonesDescription07ATurbine Building - Reactor Feed Pump Area07BTurbine Building - 1A2, Lower Switchgear Room Fire Area/ZonesDescriptionEnclosure 407CTurbine Building - Turbine Lube Oil Tank Area07ETurbine Building - Condensate Pump Area08FTurbine Building - 1G-21, "B" EDG Room (West)08GTurbine Building - "B" EDG Day Tank RoomFor each of these fire zones, the inspection focused on the fire protection features, thesystems and equipment necessary to achieve and maintain safe shutdown conditions, determination of license commitments, and changes to the Fire Protection Program..1Shutdown from Outside Main Control RoomTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that structures, systems, andcomponents that were necessary to achieve and maintain post-fire safe shutdown from outside the main control room be protected by fire protection features, such that, one train of systems necessary to achieve and maintain hot shutdown conditions was free of fire damage; and systems necessary to achieve and maintain cold shutdown could be repaired within 72-hours.


====a. Inspection Scope====
====a. Inspection Scope====
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====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the fire hazards analysis, safe shutdown analysis and supportingdrawings and documentation to verify that safe shutdown capabilities were properly protected. Under the NFPA 805 transition period inspection period, the team were to validate 1 to 3 nonconformances identified in the licensee's transitional assessment of their fire areas. At the time of this inspection, no fire areas had been assessed by the licensee.The team reviewed the licensee procedures and programs for the control of ignitionsources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis.
The team reviewed the fire hazards analysis, safe shutdown analysis and supportingdrawings and documentation to verify that safe shutdown capabilities were properly protected. Under the NFPA 805 transition period inspection period, the team were to validate 1 to 3 nonconformances identified in the licensee's transitional assessment of their fire areas. At the time of this inspection, no fire areas had been assessed by the
 
licensee.The team reviewed the licensee procedures and programs for the control of ignitionsources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis.


The team performed plant walk-downs to verify that protective features were being properly maintained and administrative controls were being implemented.The team also reviewed the licensee's design control procedures to ensure that theprocess 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 team performed plant walk-downs to verify that protective features were being properly maintained and administrative controls were being implemented.The team also reviewed the licensee's design control procedures to ensure that theprocess 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.
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Consequently, the team concluded that the 10 CFR Part 50, Appendix R, requirements supplemented, rather than superseded, many of the Branch Technical Position 9.5-1, Appendix 'A' commitments.For example, with respect to the fire barriers for the diesel generator rooms, Position F.9of Appendix A to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," stated "Diesel generators should be separated from each other and other areas of the plant by fire barriers having a minimum fire resistance rating of three hours."  By letter dated January 18, 1977, the licensee committed to the NRC that DAEC complied with this NRC position and specifically noted that the diesel generators were separated from each other and other plant areas by three hour fire barriers and Class A fire doors. The team noted that the NRC adopted a similar position for review of post-1979 plants in NUREG-0800. In addition, Section 5.15.4 of the June 1, 1978 Safety Evaluation Report referenced by the facility fire protection license condition noted that both the diesel generator and diesel day tank rooms were enclosed in 3-hour rated construction and that the fire doors into these areas were Class A 3-hour rated doors.Revision 1 of FHA-800, "Branch Technical Position APCSB 9.5-1 Appendix ACommitment Cross-Reference Index," which existed prior to the changes of DDC 3151 reflected the above commitment by stating that the diesel generator rooms were separated from each other and other plant areas by 3-hour rated fire barriers with Class A fire doors. Revision 2 of FHA-800, which implemented DDC 3151, limited the commitment by stating "Barrier commitments in this document superseded by Appendix R requirements. Reference Safety Evaluation 95-03."With respect to surveillance and inspection of fire barriers, Section 4.9 of the June 1,1978 Safety Evaluation Report stated that appropriate controls will be provided to assure the effectiveness of fire doors protecting safety-related areas. The Safety Evaluation Report specifically stated that fire doors would be inspected semiannually to verify that self-closing mechanisms and latches were in good working order. In addition, Safety Evaluation Report Supplement dated February 10, 1981 stated that based on licensee's committment to meet the "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" guidelines, the licensee's administrative controls were found to be acceptable. The Quality Assurance section of the "Nuclear Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" guidelines transmitted to the licensee by letter dated August 8, 1977, the quality assurance program should assure that the requirements for design, procurement, installation, testing, and administrative controls for the fire protection program for safety related areas approved by NRC are satisfied. Paragraph 4.0.h of the "Nuclear Plant Fire Protection Functional Responsibilities, Administrative 10Controls, and Quality Assurance" guidelines Quality Assurance section specifiedperiodic inspection of materials subject to degradation such as fire stops, seals, and fire retardant coatings to assure these items have not deteriorated or been damaged.The team noted that revision 6, effective September 16, 1996, of surveillance procedureNS13F002, "Fire Door and Frame Inspection," included doors numbered 130 and 131, which were the doors to the diesel generator rooms in the turbine building. Revision 17 of surveillance procedure NS13F002, which was in effect at the time of the inspection, did not include doors 130 and 131. The team noted that there had been a significant reduction in the number of doors surveilled. Revision 6 of surveillance procedure NS13F002 required surveillance of over 140 doors. By comparison, revision 7 of surveillance procedure NS13F002, effective September 24, 1997, which implemented DDC 3151 only required surveillance of 52 doors and did not include surveillance of doors numbered 130 and 131. The team further noted that revision 17 of surveillance procedure NS13F002 in effect during this inspection required surveillance of less than 40 doors. Doors 130 and 131 had been last inspected in August 1996. With respect to fire barriers, the team noted that revision 10 of surveillance procedure NS13F001, "Fire Barrier Penetration Seal Inspection," the revision in effect during this inspection, did not include the walls for the diesel generator rooms. The fire seals in the walls for the diesel generator rooms were last inspected in September 1992.The team noted that the changes made by DDC 3151 with respect to which fire barrierswere in the fire protection program were made without a thorough evaluation.
Consequently, the team concluded that the 10 CFR Part 50, Appendix R, requirements supplemented, rather than superseded, many of the Branch Technical Position 9.5-1, Appendix 'A' commitments.For example, with respect to the fire barriers for the diesel generator rooms, Position F.9of Appendix A to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," stated "Diesel generators should be separated from each other and other areas of the plant by fire barriers having a minimum fire resistance rating of three hours."  By letter dated January 18, 1977, the licensee committed to the NRC that DAEC complied with this NRC position and specifically noted that the diesel generators were separated from each other and other plant areas by three hour fire barriers and Class A fire doors. The team noted that the NRC adopted a similar position for review of post-1979 plants in NUREG-0800. In addition, Section 5.15.4 of the June 1, 1978 Safety Evaluation Report referenced by the facility fire protection license condition noted that both the diesel generator and diesel day tank rooms were enclosed in 3-hour rated construction and that the fire doors into these areas were Class A 3-hour rated doors.Revision 1 of FHA-800, "Branch Technical Position APCSB 9.5-1 Appendix ACommitment Cross-Reference Index," which existed prior to the changes of DDC 3151 reflected the above commitment by stating that the diesel generator rooms were separated from each other and other plant areas by 3-hour rated fire barriers with Class A fire doors. Revision 2 of FHA-800, which implemented DDC 3151, limited the commitment by stating "Barrier commitments in this document superseded by Appendix R requirements. Reference Safety Evaluation 95-03."With respect to surveillance and inspection of fire barriers, Section 4.9 of the June 1,1978 Safety Evaluation Report stated that appropriate controls will be provided to assure the effectiveness of fire doors protecting safety-related areas. The Safety Evaluation Report specifically stated that fire doors would be inspected semiannually to verify that self-closing mechanisms and latches were in good working order. In addition, Safety Evaluation Report Supplement dated February 10, 1981 stated that based on licensee's committment to meet the "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" guidelines, the licensee's administrative controls were found to be acceptable. The Quality Assurance section of the "Nuclear Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" guidelines transmitted to the licensee by letter dated August 8, 1977, the quality assurance program should assure that the requirements for design, procurement, installation, testing, and administrative controls for the fire protection program for safety related areas approved by NRC are satisfied. Paragraph 4.0.h of the "Nuclear Plant Fire Protection Functional Responsibilities, Administrative 10Controls, and Quality Assurance" guidelines Quality Assurance section specifiedperiodic inspection of materials subject to degradation such as fire stops, seals, and fire retardant coatings to assure these items have not deteriorated or been damaged.The team noted that revision 6, effective September 16, 1996, of surveillance procedureNS13F002, "Fire Door and Frame Inspection," included doors numbered 130 and 131, which were the doors to the diesel generator rooms in the turbine building. Revision 17 of surveillance procedure NS13F002, which was in effect at the time of the inspection, did not include doors 130 and 131. The team noted that there had been a significant reduction in the number of doors surveilled. Revision 6 of surveillance procedure NS13F002 required surveillance of over 140 doors. By comparison, revision 7 of surveillance procedure NS13F002, effective September 24, 1997, which implemented DDC 3151 only required surveillance of 52 doors and did not include surveillance of doors numbered 130 and 131. The team further noted that revision 17 of surveillance procedure NS13F002 in effect during this inspection required surveillance of less than 40 doors. Doors 130 and 131 had been last inspected in August 1996. With respect to fire barriers, the team noted that revision 10 of surveillance procedure NS13F001, "Fire Barrier Penetration Seal Inspection," the revision in effect during this inspection, did not include the walls for the diesel generator rooms. The fire seals in the walls for the diesel generator rooms were last inspected in September 1992.The team noted that the changes made by DDC 3151 with respect to which fire barrierswere in the fire protection program were made without a thorough evaluation.


Specifically, safety evaluation 95-03 did not address the licensing basis for individual features affected and did not show how an equivalent level of fire protection would be provided for individual features affected. For example, for the diesel generator room fire doors and fire barriers, safety evaluation 95-03 provided no discussion nor evaluation ofhow  Position F.9 of Appendix A to Branch Technical Position APCSB 9.5-1 would be satisfied nor how the diesel generators would continue to be protected against fire hazards from outside their respective diesel generator rooms.By license amendment 190, dated November 23, 1992, the NRC added the standardfire protection program license condition endorsed by Generic Letter 86-10,
Specifically, safety evaluation 95-03 did not address the licensing basis for individual features affected and did not show how an equivalent level of fire protection would be provided for individual features affected. For example, for the diesel generator room fire doors and fire barriers, safety evaluation 95-03 provided no discussion nor evaluation ofhow  Position F.9 of Appendix A to Branch Technical Position APCSB 9.5-1 would be satisfied nor how the diesel generators would continue to be protected against fire hazards from outside their respective diesel generator rooms.By license amendment 190, dated November 23, 1992, the NRC added the standardfire protection program license condition endorsed by Generic Letter 86-10, "Implementation of Fire Protection Requirements," to the DAEC license. The standard fire protection program license condition permitted the licensee to make changes to approved fire protection program without prior approval of the NRC only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. In discussions with the licensee, the licensee believed that the changes made to remove Appendix A barriers from the fire protection program during the 1990's were acceptable under their licensee condition. The team noted that while the standard fire protection license condition permitted the licensee to make changes to their fire protection program, the license condition did not relieve the licensee of the requirement to meet 10 CFR 50.48, "Fire Protection."  10 CFR 50.48(a) required each operating nuclear power plant to have a fire protection plan which satisfied General Design Criteria 3, "Fire Protection," of 10 CFR Part 50, Appendix A. General Design Criteria 3 specified that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. The NRC position with respect to changes 11which could be made under the licensee condtion was discussed in Generic Letter 86-10. Generic Letter 86-10 specifically stated that "The licensee may alter specific features of the approved program provided:
"Implementation of Fire Protection Requirements," to the DAEC license. The standard fire protection program license condition permitted the licensee to make changes to approved fire protection program without prior approval of the NRC only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. In discussions with the licensee, the licensee believed that the changes made to remove Appendix A barriers from the fire protection program during the 1990's were acceptable under their licensee condition. The team noted that while the standard fire protection license condition permitted the licensee to make changes to their fire protection program, the license condition did not relieve the licensee of the requirement to meet 10 CFR 50.48, "Fire Protection."  10 CFR 50.48(a) required each operating nuclear power plant to have a fire protection plan which satisfied General Design Criteria 3, "Fire Protection," of 10 CFR Part 50, Appendix A. General Design Criteria 3 specified that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. The NRC position with respect to changes 11which could be made under the licensee condtion was discussed in Generic Letter 86-10. Generic Letter 86-10 specifically stated that "The licensee may alter specific features of the approved program provided: (a) such changes do not otherwise involve a change in a license condition or technical specification...; and (b) such changes do notresult in failure to complete the fire protection program as approved by the Commission."  In addition, Generic Letter 86-10 also specified that "...the licensee shallmaintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program."  The team noted that the changes made by DDC-3151 may have been beyond the scope of those permitted by the license condition in that the changes could be considered a failure to complete the fire protection program as approved by the NRC. In addition, the team noted that the licensee had not provided an analysis of the effects of the changes on the fire protection program.In October 2005, the licensee recognized that many fire barriers had beeninappropriately removed from the fire protection program. The licensee initiated CAP038444, "Maintenance of Fire Protection SER Credited Barriers," dated October 19, 2005 to effect corrective actions. In CAP038444, the licensee specifically referred to Letter NG-94-2443 and noted that the affected walls were specifically required by the approved fire protection program and were required to be maintained by the station operating license condition for fire protection. CAP038444 further noted that the change could be considered to have adversely affected post fire safe shutdown capability as the failure to maintain the penetration seals and other material condition issues could have allowed the fire to propagate beyond that evaluated in the original Safety Evaluation Report. However, the corrective actions outlined in the corrective action for CAP038444 (i.e., CA041423, "Revise Fire Plan to Require Maintenance of Appendix A Barriers," dated November 16, 2005, were limited. Specifically, CA041423 specified revision of the fire plan administrative controls to add requirements to maintain Appendix A barriers. However, CA041423 specifically stated that no surveillance or compensatory measures were required. The team noted that no justification was provided as to why the licensee believed no surveillance or compensatory measures were required.The team considered the issue of not including Appendix A barriers in the fire protectionsurveillance program and operability requirements to be an unresolved item pending further NRC review of the applicability of the license condition to the changes which had been made.  (Unresolved Item 05000331/2006014-01).4Active Fire ProtectionBranch Technical Position APCSB 9.5-1, Section IV.C.1, "Fire Detection,"Section IV.C.3, "Water Sprinkler and Hose Standpipe Systems," Section IV.C.5,
: (a) such changes do not otherwise involve a change in a license condition or technical specification...; and
"Carbon Dioxide Suppression Systems," and Section IV.D.2, "Control Room," identified the requirements for the licensee's fire protection active features.
: (b) such changes do notresult in failure to complete the fire protection program as approved by the Commission."  In addition, Generic Letter 86-10 also specified that "...the licensee shallmaintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program."  The team noted that the changes made by DDC-3151 may have been beyond the scope of those permitted by the license condition in that the changes could be considered a failure to complete the fire protection program as approved by the NRC. In addition, the team noted that the licensee had not provided an analysis of the effects of the changes on the fire protection program.In October 2005, the licensee recognized that many fire barriers had beeninappropriately removed from the fire protection program. The licensee initiated CAP038444, "Maintenance of Fire Protection SER Credited Barriers," dated October 19, 2005 to effect corrective actions. In CAP038444, the licensee specifically referred to Letter NG-94-2443 and noted that the affected walls were specifically required by the approved fire protection program and were required to be maintained by the station operating license condition for fire protection. CAP038444 further noted that the change could be considered to have adversely affected post fire safe shutdown capability as the failure to maintain the penetration seals and other material condition issues could have allowed the fire to propagate beyond that evaluated in the original Safety Evaluation Report. However, the corrective actions outlined in the corrective action for CAP038444 (i.e., CA041423, "Revise Fire Plan to Require Maintenance of Appendix A Barriers," dated November 16, 2005, were limited. Specifically, CA041423 specified revision of the fire plan administrative controls to add requirements to maintain Appendix A barriers. However, CA041423 specifically stated that no surveillance or compensatory measures were required. The team noted that no justification was provided as to why the licensee believed no surveillance or compensatory measures were required.The team considered the issue of not including Appendix A barriers in the fire protectionsurveillance program and operability requirements to be an unresolved item pending further NRC review of the applicability of the license condition to the changes which had been made.  (Unresolved Item 05000331/2006014-01).4Active Fire ProtectionBranch Technical Position APCSB 9.5-1, Section IV.C.1, "Fire Detection,"Section IV.C.3, "Water Sprinkler and Hose Standpipe Systems," Section IV.C.5, "Carbon Dioxide Suppression Systems," and Section IV.D.2, "Control Room," identified the requirements for the licensee's fire protection active features.
 
12


====a. Inspection Scope====
====a. Inspection Scope====
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====b. Findings====
====b. Findings====
No findings of significance were identified..6Alternative Shutdown CapabilityTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that systems, structures, andcomponents important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions was free of fire damage. Options for providing this level of fire protection were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2, an alternative ordedicated shutdown capability independent of the area under consideration was required to be provided. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72-hours and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those 13predicted for a loss of normal ac power, and the fission product boundary integrity mustnot be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).
No findings of significance were identified..6Alternative Shutdown CapabilityTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that system s, structures, andcomponents important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions was free of fire damage. Options for providing this level of fire protection were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2, an alternative ordedicated shutdown capability independent of the area under consideration was required to be provided. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72-hours and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those 13predicted for a loss of normal ac power, and the fission product boundary integrity mustnot be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).


====a. Inspection Scope====
====a. Inspection Scope====
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====a. Inspection Scope====
====a. Inspection Scope====
The team conducted a review to verify that compensatory measures were in place forout-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 team 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.
The team conducted a review to verify that compensatory measures were in place forout-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 team 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.
15


====b. Findings====
====b. Findings====
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==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
Licensee
Licensee
: [[contact::J. Bjorseth]], Site Director
: [[contact::J. Bjorseth]], Site Director
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: [[contact::J. Kuehl]], Supervisor, Programs Engineering
: [[contact::J. Kuehl]], Supervisor, Programs Engineering
: [[contact::J. Lang]], Staff Engineer, Corporate Engineering
: [[contact::J. Lang]], Staff Engineer, Corporate Engineering
: [[contact::G. Rushworth]], Manager, OperationsNRC
: [[contact::G. Rushworth]], Manager, Operations
NRC
: [[contact::R. Orlikowski]], Senior Resident Inspector
: [[contact::R. Orlikowski]], Senior Resident Inspector
: [[contact::R. Baker]], Resident Inspector
: [[contact::R. Baker]], Resident Inspector
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
Open05000331/2006014-01URISurveillances and Compensatory Measures for Appendix'A' Fire BarriersClosed and DiscussedNone
Open05000331/2006014-01URISurveillances and Compensatory Measures for Appendix'A' Fire Barriers
Closed and  
===Discussed===
 
None
AttachmentA-2
AttachmentA-2
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
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: STP NS13F002; Fire Door and Frame Inspection; Revision 17Updated Final Safety Analysis Report Change Requests94-20; dated August 12, 1994
: STP NS13F002; Fire Door and Frame Inspection; Revision 17Updated Final Safety Analysis Report Change Requests94-20; dated August 12, 1994
==LIST OF ACRONYMS==
==LIST OF ACRONYMS==
: [[USEDAD]] [[]]
USEDADAMSAgency-Wide Document Access and Management SystemDAECDuane Arnold Energy Center
: [[AMSA]] [[gency-Wide Document Access and Management SystemDAECDuane Arnold Energy Center]]
DDCDesign Document Change
: [[DD]] [[]]
DPRDemonstration Power Reactor
: [[CD]] [[esign Document Change]]
CFRCode of Federal Regulations
: [[DP]] [[]]
DRSDivision of Reactor Safety
: [[RD]] [[emonstration Power Reactor]]
LLCLimited Liability Company
: [[CF]] [[]]
NFPANational Fire Protection Association
: [[RC]] [[ode of Federal Regulations]]
NRCU.S. Nuclear Regulatory Commission
: [[DR]] [[]]
PARSPublicly Available Records
: [[SD]] [[ivision of Reactor Safety]]
: [[UFSARU]] [[pdated Final Safety Analysis Report]]
: [[LL]] [[]]
: [[CL]] [[imited Liability Company]]
: [[NFP]] [[]]
: [[AN]] [[ational Fire Protection Association]]
: [[NR]] [[]]
: [[CU.S.]] [[Nuclear Regulatory Commission]]
: [[PAR]] [[]]
: [[SP]] [[ublicly Available Records]]
: [[UFSA]] [[]]
: [[RU]] [[pdated Final Safety Analysis Report]]
}}
}}

Revision as of 10:53, 25 October 2018

IR 05000331-06-014; Florida Power and Light Energy Duane Arnold, LLC; 09/11/06 - 11/15/06; Duane Arnold Energy Center; Routine Triennial Fire Protection Baseline Inspection
ML063460555
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 12/11/2006
From: Lara J F
Engineering Branch 3
To: VanMiddlesworth G D
Duane Arnold
References
IR-06-014
Download: ML063460555 (23)
v • d • e


Text

December 11, 2006

Mr. Gary Van MiddlesworthVice-President Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785

SUBJECT: DUANE ARNOLD ENERGY CENTERNRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION INSPECTION REPORT 05000331/2006014(DRS)

Dear Mr. Van Middlesworth:

On November 15, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Duane Arnold Energy Center facility. The enclosed inspection report documents the inspection results, which were discussed at the end of the on-site activities on September 29, 2006, with Mr. J. Bjorseth and other members of your staff. A re-exit meeting was held by telephone at the conclusion of the inspection on November 15, 2006, with S. Catron.The inspection examined activities conducted under your license as they relate to safety and tocompliance 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.As a result of your intent to adopt the National Fire Protection Association Standard (NFPA)805 code, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," as defined by Title 10, Code of Federal Regulations (CFR),

Part 50, Section 48(c), the inspection was conducted in accordance with Inspection Procedure 71111.05TTP, "Fire Protection - NFPA 805 Transition Period (Triennial)," dated May 9, 2006.

The inspection examined activities conducted under your license, as they relate to safety and to 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, no findings of significance were identified.

G. Van Middlesworth-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (thePublic Electronic Reading Room).

Sincerely,/RA/Julio F. Lara, ChiefEngineering Branch 3 Division of Reactor SafetyDocket No. 50-331License No. DPR-49

Enclosure:

Inspection Report 05000331/2006014

w/Attachment:

Supplemental Informationcc w/encl:J. Stall, Senior Vice President, Nuclear and Chief Nuclear Officer R. Helfrich, Senior Attorney M. Ross, Managing Attorney W. Webster, Vice President, Nuclear Operations M. Warner, Vice President, Nuclear Operations Support R. Kundalkar, Vice President, Nuclear Engineering J. Bjorseth, Site Director D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs Chairman, Linn County Board of Supervisors D. McGhee, State Liaison Officer G. Van Middlesworth-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (thePublic Electronic Reading Room).

Sincerely,Julio F. Lara, ChiefEngineering Branch 3 Division of Reactor SafetyDocket No. 50-331License No. DPR-49

Enclosure:

Inspection Report 05000331/2006014

w/Attachment:

Supplemental Informationcc w/encl:J. Stall, Senior Vice President, Nuclear and Chief Nuclear Officer R. Helfrich, Senior Attorney M. Ross, Managing Attorney W. Webster, Vice President, Nuclear Operations M. Warner, Vice President, Nuclear Operations Support R. Kundalkar, Vice President, Nuclear Engineering J. Bjorseth, Site Director D. Curtland, Plant Manager S. Catron, Manager, Regulatory Affairs Chairman, Linn County Board of Supervisors D. McGhee, State Liaison OfficerDISTRIBUTION

TEB DWS RidsNrrDirsIrib GEG KGO GLS SRI Duane Arnold

CAA1 LSL DRPIII DRSIII PLB1 TXN ROPreports@nrc.gov DOCUMENT NAME:

G Publicly Available G Non-Publicly Available G Sensitive G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copyOFFICERIIIRIIIRIIIRIIINAMERLangstaff:jbBBurgessJLaraDATE12/06/0612/11/0612/11/06OFFICIAL RECORD COPY EnclosureU.S. NUCLEAR REGULATORY COMMISSIONREGION IIIDocket No.:License No.:50-331DRP-49Report No:05000331/2006014(DRS)Licensee:Florida Power and Light Energy Duane Arnold, LLC Facility:Duane Arnold Energy Center Location:Palo, Iowa 52324-9785 Dates:September 11 through November 15, 2006 Inspectors:R. Langstaff, Senior Reactor Inspector, LeadC. Moore, Operations Engineer D. Schrum, Reactor Inspector D. Szwarc, Reactor InspectorApproved by:Julio F. Lara, ChiefEngineering Branch 3 Division of Reactor Safety Enclosure 2

SUMMARY OF FINDINGS

IR 05000331/2006014(DRS); 09/11/06 - 11/15/06; Duane Arnold Energy Center; RoutineTriennial Fire Protection Baseline Inspection.This report covers an announced triennial fire protection baseline inspection. The inspectionwas conducted by Region III inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.Inspector-Identified and Self-Revealed Findings

Cornerstone: Initiating EventsNo findings of significance were identified.Cornerstone:

Mitigating SystemsNo findings of significance were identified.

B.Licensee-Identified Violations

No findings of significance were identified.

3

REPORT DETAILS

1.REACTOR SAFETYCornerstones: Initiating Events and Mitigating Systems1R05Fire Protection (71111.05TTP)Florida Power and Light Energy Duane Arnold, LLC, the licensee, in letters to theU. S. Nuclear Regulatory Commission (NRC) dated November 30, 2005, and July 11, 2006 (ADAMS Accession Numbers ML053460342 and ML062060317, respectively) , committed to adopt the National Fire Protection Association Standard (NFPA) 805 code, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition," as defined by 10 CFR 50.48(c) for the Duane Arnold Energy Center (DAEC). The NFPA 805 code establishes a comprehensive set of requirements for fire protection programs at nuclear power plants.

The code incorporated both deterministic and risk-informed, performance-based concepts. The deterministic aspects of the code 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 NRC modified the fire protection inspection program and Enforcement Policy for licensees in transition to NFPA 805. As a result, this inspection was conducted inaccordance with IP 71111.05TTP, "Fire Protection - NFPA 805 Transition Period (Triennial)," dated May 9, 2006. Associated with the transition to NFPA 805, when a circuit-related finding not associated with a finding of high safety significance meets 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),

the violation would receive enforcement discretion in accordance with the NRC's Enforcement Policy.The purpose of this inspection was to review the Duane Arnold Energy Center (DAEC)Fire Protection Program for selected risk-significant fire areas. 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 inspection was performed in accordance with the NRC's regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The team used the DAEC Individual Plant Examination for External Events to choose several risk-significant areas for detailed inspection and review. The fire zones chosen for review during this inspection constituted six-inspection samples which were:Fire Area/ZonesDescription07ATurbine Building - Reactor Feed Pump Area07BTurbine Building - 1A2, Lower Switchgear Room Fire Area/ZonesDescriptionEnclosure 407CTurbine Building - Turbine Lube Oil Tank Area07ETurbine Building - Condensate Pump Area08FTurbine Building - 1G-21, "B" EDG Room (West)08GTurbine Building - "B" EDG Day Tank RoomFor each of these fire zones, the inspection focused on the fire protection features, thesystems and equipment necessary to achieve and maintain safe shutdown conditions, determination of license commitments, and changes to the Fire Protection Program..1Shutdown from Outside Main Control RoomTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that structures, systems, andcomponents that were necessary to achieve and maintain post-fire safe shutdown from outside the main control room be protected by fire protection features, such that, one train of systems necessary to achieve and maintain hot shutdown conditions was free of fire damage; and systems necessary to achieve and maintain cold shutdown could be repaired within 72-hours.

a. Inspection Scope

The team reviewed the functional requirements identified by the licensee as necessaryfor achieving and maintaining hot shutdown conditions to ensure that at least one post-fire safe shutdown success path was available in the event of fire in each of the selected fire areas and for alternative shutdown in the case of control room evacuation.

The team reviewed the plant systems required to achieve and maintain post-fire safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for each fire area selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant inventory makeup, reactor heat removal, process monitoring, and support system functions. The review also included the fire Safe Shutdown Analysis to ensure that all required components in the selected systems were included in the licensee's Safe Shutdown

Analysis.

The team reviewed the Safe Shutdown Analysis, licensee operating procedures, pipingand instrumentation drawings, electrical drawings, the DAEC Updated Final Safety Analysis Report (UFSAR) and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power.The team also reviewed the operators' ability to perform the necessary manual actionsfor achieving safe shutdown by reviewing procedures, the accessibility of safe shutdown equipment, and the available time for performing the actions.The team reviewed the DAEC UFSAR and the licensee's engineering and/or licensingjustifications (e.g., NRC guidance documents, license amendments, Technical 5Specifications, Safety Evaluation Reports, exemptions, and deviations) to determine thelicensing basis.

b. Findings

No findings of significance were identified..2Protection of Safe Shutdown CapabilitiesTitle 10 CFR Part 50, Appendix R, Section III.G.1, required the licensee to provide fireprotection features that were capable of limiting fire damage to systems, structures, and components important to safe shutdown. The systems, structures, and components that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features that were capable of limiting fire damage to the systems, structures, and components so that:*one train of systems necessary to achieve and maintain hot shutdown conditionsfrom either the control room or emergency control station(s) was free of fire damage; and*systems necessary to achieve and maintain cold shutdown from either thecontrol room or emergency control station(s) could be repaired within 72-hours.Specific design features for ensuring this capability were specified by 10 CFR Part 50,Appendix R,Section III.G.2.

a. Inspection Scope

The team reviewed the fire hazards analysis, safe shutdown analysis and supportingdrawings and documentation to verify that safe shutdown capabilities were properly protected. Under the NFPA 805 transition period inspection period, the team were to validate 1 to 3 nonconformances identified in the licensee's transitional assessment of their fire areas. At the time of this inspection, no fire areas had been assessed by the

licensee.The team reviewed the licensee procedures and programs for the control of ignitionsources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis.

The team performed plant walk-downs to verify that protective features were being properly maintained and administrative controls were being implemented.The team also reviewed the licensee's design control procedures to ensure that theprocess 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.

6.3Passive Fire ProtectionBranch Technical Position APCSB 9.5-1,Section IV.B.1, "General Guidelines for PlantProtection Building Design,"Section IV.B.3, "Cable Construction, Cable Trays and Penetrations," and Section IV.D.2, "Control Room," identified the requirements for the licensee's FP passive features.

a. Inspection Scope

For the selected fire areas, the team evaluated the adequacy of fire area barriers,penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The team observed the material condition and configuration of the installed barriers, seals, doors, and cables. The team compared the as-installed configurations to the approved construction details and supporting fire tests. In addition, the team reviewed license documentation, such as NRC Safety Evaluation Reports, and deviations from NRC regulations and the NFPA codes to verify that fire protection features met license commitments.The team walked down accessible portions of the selected fire areas to observe materialcondition 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 team reviewed the installation, repair, and qualification records for a sample ofpenetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.

b. Findings

b.1Surveillances and Compensatory Measures For Appendix 'A' Fire BarriersIntroduction: The team identified an unresolved item relating to surveillances of andcompensatory measures for fire barriers. Specifically, the licensee was not conducting surveillances of nor requiring compensatory measures for impairment of fire barriers for the diesel generator rooms. The fire barriers for the diesel generator rooms were explicitly credited in the DAEC fire protection Safety Evaluation Report.Description: The team identified that many fire protection barriers, including fire doors,were not included in the licensee's fire protection surveillance program and operational requirements (i.e., compensatory measure requirements) for fire protection. Upon further review and discussion with licensee personnel, the team determined that the licensee had removed a number fire barriers from the fire protection surveillance program during the 1990's.On June 30, 1994, the licensee initiated UFSAR Change 94-20 to change the fireprotection description in the UFSAR. The UFSAR, at that time, contained the fire protection equipment operability requirements (which had previously been relocated from Technical Specifications). The UFSAR change modified the equipment operability requirements for fire rated assemblies from:

7"1.All fire barrier penetration seals protecting safety-relatedareas shall be intact.2.All fire doors protecting safety related areas shall be functional.

3.Fire protection raceway wrap and structural steel fireproofing shall beintact."to:"1.All fire barrier penetration seals protecting areas containingsafety related equipment required for safe plant shutdown shall be intact.2.All fire doors protecting areas containing safety relatedequipment required for safe plant shutdown shall be functional.3.Fire protection raceway wrap and structural protecting safetyrelated systems required for safe shutdown steel fireproofing shall be intact."This change effectively excluded fire barriers which did not separate redundant divisionsof safe shutdown equipment from fire protection operability requirements. Although the change had the effect of significantly reducing the scope of which fire barriers had operability requirements with associated compensatory and surveillance requirements, the licensee had, at the time, considered the change "editorial" and no 10 CFR 50.59 safety evaluation, screening, or commensurate evaluation was performed for the change. An internal memorandum, Memorandum NG-94-0841, "Clarification of Penetration Seal Inspection Basis," dated February 25, 1994, appeared to have been used as a basis for the change. During this inspection, the licensee initiatedCAP044512, "UFSAR Change Request 94-20 does not contain adequate 50.59 basis,"

concerning this issue.The changes made by UFSAR Change 94-20 continued to be reflected in fire protectionoperability requirements which were in place during this inspection. Volume 1 of the Fire Plan, revision 53, specified Limiting Condition for Operation 12.1.F.1 for "All fire barriers required for Appendix R safe shutdown shall be operable," which limited applicability to those fire barriers which separated redundant divisions of equipment for safe shutdown purposes. For example, the implementing procedure, procedure ACP 1412.4, "Impairments to Fire Protection Systems," revision 43 (in effect at the time of the inspection) specified that no fire watch was required if the fire doors to the diesel generator rooms were impaired.By letter NG-94-2243, dated July 19, 1994, the licensee informed the NRC that theyintended to retract their commitment to Branch Technical Position APCSB 9.5-1, Appendix 'A,' dated August 23, 1976. The letter stated, in part:

8"We determined that several commitments for fire barriers andemergency lighting made in response to Appendix A are obviated by those elements of the fire protection program related to Appendix R.

We therefore are retracting our previous commitments to Appendix A for the following elements:*Three-hour rated fire barriers surrounding the Control Room,Cable Spreading Room, Switchgear Rooms, Battery Rooms, Main Turbine Oil Storage Area, Emergency Diesel Generator Rooms, Diesel Fuel Day Tank Rooms, Safety-Related Pump Areas, Heater Boiler Rooms, Stairwells, Radwaste Building and building exterior walls.*Emergency Lighting for safety-related areas.

Instead of those Appendix A commitments, the determination of areasrequiring three-hour rated fire barriers and emergency lighting is based on the safe shutdown analysis performed to comply with Appendix R."The letter did not request a review by the NRC of the licensee's intent to retract theirprevious commitment. The team was not able to identify any records indicating that the NRC had performed a review of and responded to the July 19, 1994 letter.The licensee used Safety Evaluation 95-03, "Safety Evaluation to Support [DesignDocument Change] DDC-3151, Revision of FHA-800 to Supersede Appendix 'A' Requirements with Appendix 'R' Requirements," dated December 18, 1996, as a basis for revising Section FHA-800 of the Fire Hazards Analysis with respect to the requirement of Branch Technical Position 9.5-1, Appendix 'A'. The DAEC was committed to meet many of the requirements Branch Technical Position 9.5-1, Appendix

'A,' dated August 23, 1976. The evaluation stated that the Branch Technical Position 9.5-1, Appendix 'A,' commitments were superseded by 10 CFR Part 50, Appendix R.

The evaluation specifically identified, in part, the following commitments for fire barriers as having been superseded:3-hour barriers surrounding the control room3-hour barriers surrounding the cable spreading room 3-hour barriers surrounding the switchgear rooms 3-hour barriers surrounding the station battery rooms 3-hour barriers surrounding the emergency diesel generator areas 3-hour barriers surrounding safety related pump areasThe team disagreed with the evaluation conclusion that many of the Branch TechnicalPosition 9.5-1, Appendix 'A' commitments had been superseded. The team noted that many of the Branch Technical Position 9.5-1, Appendix "A" commitments provided general protection against fires consistent with designing and locating structures, systems, and components important to safety to minimize the probability and effect of fires and explosions. As such, the team determined that the Branch Technical Position 99.5-1, Appendix 'A' commitments were for meeting 10 CFR Part 50, Appendix A,General Design Criteria 3, rather than for specifically meeting 10 CFR Part 50, Appendix R. In addition, the team noted Section 9.5.1, "Fire Protection Program," revision 4, of NUREG-0800, "Standard Review Plan," which the NRC used as a basis for review of post-1979 plants (for which 10 CFR Part 50, Appendix R, does not apply) contained many regulatory positions comparable to those of outlined in Appendix A of Branch Technical Position 9.5-1 for which the licensee was committed to for DAEC.

Consequently, the team concluded that the 10 CFR Part 50, Appendix R, requirements supplemented, rather than superseded, many of the Branch Technical Position 9.5-1, Appendix 'A' commitments.For example, with respect to the fire barriers for the diesel generator rooms, Position F.9of Appendix A to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976," stated "Diesel generators should be separated from each other and other areas of the plant by fire barriers having a minimum fire resistance rating of three hours." By letter dated January 18, 1977, the licensee committed to the NRC that DAEC complied with this NRC position and specifically noted that the diesel generators were separated from each other and other plant areas by three hour fire barriers and Class A fire doors. The team noted that the NRC adopted a similar position for review of post-1979 plants in NUREG-0800. In addition, Section 5.15.4 of the June 1, 1978 Safety Evaluation Report referenced by the facility fire protection license condition noted that both the diesel generator and diesel day tank rooms were enclosed in 3-hour rated construction and that the fire doors into these areas were Class A 3-hour rated doors.Revision 1 of FHA-800, "Branch Technical Position APCSB 9.5-1 Appendix ACommitment Cross-Reference Index," which existed prior to the changes of DDC 3151 reflected the above commitment by stating that the diesel generator rooms were separated from each other and other plant areas by 3-hour rated fire barriers with Class A fire doors. Revision 2 of FHA-800, which implemented DDC 3151, limited the commitment by stating "Barrier commitments in this document superseded by Appendix R requirements. Reference Safety Evaluation 95-03."With respect to surveillance and inspection of fire barriers, Section 4.9 of the June 1,1978 Safety Evaluation Report stated that appropriate controls will be provided to assure the effectiveness of fire doors protecting safety-related areas. The Safety Evaluation Report specifically stated that fire doors would be inspected semiannually to verify that self-closing mechanisms and latches were in good working order. In addition, Safety Evaluation Report Supplement dated February 10, 1981 stated that based on licensee's committment to meet the "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" guidelines, the licensee's administrative controls were found to be acceptable. The Quality Assurance section of the "Nuclear Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" guidelines transmitted to the licensee by letter dated August 8, 1977, the quality assurance program should assure that the requirements for design, procurement, installation, testing, and administrative controls for the fire protection program for safety related areas approved by NRC are satisfied. Paragraph 4.0.h of the "Nuclear Plant Fire Protection Functional Responsibilities, Administrative 10Controls, and Quality Assurance" guidelines Quality Assurance section specifiedperiodic inspection of materials subject to degradation such as fire stops, seals, and fire retardant coatings to assure these items have not deteriorated or been damaged.The team noted that revision 6, effective September 16, 1996, of surveillance procedureNS13F002, "Fire Door and Frame Inspection," included doors numbered 130 and 131, which were the doors to the diesel generator rooms in the turbine building. Revision 17 of surveillance procedure NS13F002, which was in effect at the time of the inspection, did not include doors 130 and 131. The team noted that there had been a significant reduction in the number of doors surveilled. Revision 6 of surveillance procedure NS13F002 required surveillance of over 140 doors. By comparison, revision 7 of surveillance procedure NS13F002, effective September 24, 1997, which implemented DDC 3151 only required surveillance of 52 doors and did not include surveillance of doors numbered 130 and 131. The team further noted that revision 17 of surveillance procedure NS13F002 in effect during this inspection required surveillance of less than 40 doors. Doors 130 and 131 had been last inspected in August 1996. With respect to fire barriers, the team noted that revision 10 of surveillance procedure NS13F001, "Fire Barrier Penetration Seal Inspection," the revision in effect during this inspection, did not include the walls for the diesel generator rooms. The fire seals in the walls for the diesel generator rooms were last inspected in September 1992.The team noted that the changes made by DDC 3151 with respect to which fire barrierswere in the fire protection program were made without a thorough evaluation.

Specifically, safety evaluation 95-03 did not address the licensing basis for individual features affected and did not show how an equivalent level of fire protection would be provided for individual features affected. For example, for the diesel generator room fire doors and fire barriers, safety evaluation 95-03 provided no discussion nor evaluation ofhow Position F.9 of Appendix A to Branch Technical Position APCSB 9.5-1 would be satisfied nor how the diesel generators would continue to be protected against fire hazards from outside their respective diesel generator rooms.By license amendment 190, dated November 23, 1992, the NRC added the standardfire protection program license condition endorsed by Generic Letter 86-10, "Implementation of Fire Protection Requirements," to the DAEC license. The standard fire protection program license condition permitted the licensee to make changes to approved fire protection program without prior approval of the NRC only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. In discussions with the licensee, the licensee believed that the changes made to remove Appendix A barriers from the fire protection program during the 1990's were acceptable under their licensee condition. The team noted that while the standard fire protection license condition permitted the licensee to make changes to their fire protection program, the license condition did not relieve the licensee of the requirement to meet 10 CFR 50.48, "Fire Protection." 10 CFR 50.48(a) required each operating nuclear power plant to have a fire protection plan which satisfied General Design Criteria 3, "Fire Protection," of 10 CFR Part 50, Appendix A. General Design Criteria 3 specified that structures, systems, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. The NRC position with respect to changes 11which could be made under the licensee condtion was discussed in Generic Letter 86-10. Generic Letter 86-10 specifically stated that "The licensee may alter specific features of the approved program provided:

(a) such changes do not otherwise involve a change in a license condition or technical specification...; and
(b) such changes do notresult in failure to complete the fire protection program as approved by the Commission." In addition, Generic Letter 86-10 also specified that "...the licensee shallmaintain, in auditable form, a current record of all such changes, including an analysis of the effects of the change on the fire protection program." The team noted that the changes made by DDC-3151 may have been beyond the scope of those permitted by the license condition in that the changes could be considered a failure to complete the fire protection program as approved by the NRC. In addition, the team noted that the licensee had not provided an analysis of the effects of the changes on the fire protection program.In October 2005, the licensee recognized that many fire barriers had beeninappropriately removed from the fire protection program. The licensee initiated CAP038444, "Maintenance of Fire Protection SER Credited Barriers," dated October 19, 2005 to effect corrective actions. In CAP038444, the licensee specifically referred to Letter NG-94-2443 and noted that the affected walls were specifically required by the approved fire protection program and were required to be maintained by the station operating license condition for fire protection. CAP038444 further noted that the change could be considered to have adversely affected post fire safe shutdown capability as the failure to maintain the penetration seals and other material condition issues could have allowed the fire to propagate beyond that evaluated in the original Safety Evaluation Report. However, the corrective actions outlined in the corrective action for CAP038444 (i.e., CA041423, "Revise Fire Plan to Require Maintenance of Appendix A Barriers," dated November 16, 2005, were limited. Specifically, CA041423 specified revision of the fire plan administrative controls to add requirements to maintain Appendix A barriers. However, CA041423 specifically stated that no surveillance or compensatory measures were required. The team noted that no justification was provided as to why the licensee believed no surveillance or compensatory measures were required.The team considered the issue of not including Appendix A barriers in the fire protectionsurveillance program and operability requirements to be an unresolved item pending further NRC review of the applicability of the license condition to the changes which had been made. (Unresolved Item 05000331/2006014-01).4Active Fire ProtectionBranch Technical Position APCSB 9.5-1,Section IV.C.1, "Fire Detection,"Section IV.C.3, "Water Sprinkler and Hose Standpipe Systems,"Section IV.C.5, "Carbon Dioxide Suppression Systems," and Section IV.D.2, "Control Room," identified the requirements for the licensee's fire protection active features.

a. Inspection Scope

For the selected fire areas, the team evaluated the adequacy of fire suppression anddetection systems. The team observed the material condition and configuration of the installed fire detection and suppression systems. The team reviewed design documents and supporting calculations. In addition, the team reviewed license basis documentation, such as NRC Safety Evaluation Reports, and deviations from NRC regulations and the NFPA codes to verify that fire suppression and detection systems met license commitments.

b. Findings

No findings of significance were identified..5Protection from Damage from Fire Suppression ActivitiesTitle 10 CFR Part 50, Appendix A, Criterion 3, "Fire Protection," required that firefightingsystems shall be designed to minimize the adverse effects of fires on systems, structures, and components important to safety and to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these systems, structures, and components.

a. Inspection Scope

For the selected fire areas, the team verified that redundant trains of systems requiredfor 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 team 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..6Alternative Shutdown CapabilityTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that system s, structures, andcomponents important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions was free of fire damage. Options for providing this level of fire protection were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2, an alternative ordedicated shutdown capability independent of the area under consideration was required to be provided. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72-hours and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those 13predicted for a loss of normal ac power, and the fission product boundary integrity mustnot be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).

a. Inspection Scope

No inspection was performed in this area because none of the fire areas selected forthis inspection required alternative safe shutdown capability. Alternative safe shutdown capability was verified during the previous triennial fire protection inspection documented in NRC Inspection Report 05000331/2003002 (DRS) (ADAMS accession number ML031430217).

b. Findings

No findings of significance were identified..7Circuit Analyses

a. Inspection Scope

In accordance with Inspection Procedure 71111.05TTP, "Fire Protection - NFPA 805Transition Period (Triennial)," dated May 9, 2006, this section of the IP was suspended for facilities in NFPA 805 transition.

b. Findings

No findings of significance were identified..8CommunicationsBranch Technical Position APCSB 9.5-1, required that emergency communicationequipment be provided. For a fire in an alternative shutdown fire area, control room evacuation may be required and a shutdown is performed from outside the control room.

Radio communications are relied upon to coordinate the shutdown of both units and for fire fighting.

a. Inspection Scope

The team reviewed, on a sample bases, the adequacy of the communication system tosupport plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.

b. Findings

No findings of significance were identified.

14.9Emergency LightingTitle 10 CFR Part 50, Appendix R, Section III.J., required that emergency lighting unitswith at least an eight-hour battery power supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

a. Inspection Scope

The team performed a plant walkdown of areas in which a sample of the actions wouldbe performed as described in procedure AOP 913, "Fire." As part of the walkdowns, the team focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations.

b. Findings

No findings of significance were identified..10Cold Shutdown RepairsTitle 10 CFR Part 50, Appendix R, Section III.G.1.b, required that equipment andsystems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72-hours. Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.

a. Inspection Scope

The team reviewed the licensee's procedures to determine whether repairs wererequired to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available on-site. The team also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods.

b. Findings

No findings of significance were identified..11Compensatory Measures

a. Inspection Scope

The team conducted a review to verify that compensatory measures were in place forout-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 team 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

An unresolved item pertaining to compensatory measures was identified and isdiscussed in Section 1R05.3.b.1.4.OTHER ACTIVITIES4OA2Identification and Resolution of Problems

a. Inspection Scope

The team reviewed the corrective action program procedures and samples of correctiveaction 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 team reviewed selected samples of condition reports, work orders, design packages, and fire protection system non-conformance documents.

b. Findings

No findings of significance were identified.4OA6Meetings.1Exit MeetingOn September 29, 2006, at the conclusion of the on-site inspection activities, the teampresented preliminary inspection results to Mr. J. Bjorseth and other members of licensee management. On November 15, 2006, at the conclusion of the inspection, the lead inspector presented the inspection results to Mr. S. Catron. The team asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Bjorseth, Site Director
D. Curtland, Plant Manager
D. Blair, Assistant Manager, Operations
S. Catron, Manager, Licensing
G. Ellis, Program Owner, Fire Protection
K. Kleinheinz, Manager, Programs Engineering
J. Kuehl, Supervisor, Programs Engineering
J. Lang, Staff Engineer, Corporate Engineering
G. Rushworth, Manager, Operations

NRC

R. Orlikowski, Senior Resident Inspector
R. Baker, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Open05000331/2006014-01URISurveillances and Compensatory Measures for Appendix'A' Fire Barriers

Closed and

Discussed

None

AttachmentA-2

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list doesnot imply that the NRC team 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.Fire Protection Program DocumentsFire Plan - Volume 1; Program; Revision 53
Fire Plan - Volume 2; Fire Brigade Organization; Revision 38
FHA-200; Fire Protection Program Licensing Basis; Revision 15
FHA-300; Fire Protection System Requirements; Revision 14
FHA-500; Post Fire Safe Shutdown Analysis; Revision 5
FHA-600; Fire Hazards Analysis; Revision 7
FHA-800; Branch Technical Position APCSB 9.5-1 Appendix A Commitment Cross-ReferenceIndex; Revision 1FHA-800; Branch Technical Position APCSB 9.5-1 Appendix A Commitment Cross-ReferenceIndex; Revision 2Corrective Action DocumentsCA041423; Revise the Fire Plan to Require Maintenance of Appendix A Barriers; datedNovember 11, 2005.CA041819; Ability to complete AOP301.1 (SBO) Attachment 1 in 30 minutes not verified; datedJanuary 5, 2006CA041819; Ability to complete AOP301.1 (SBO) Attachment 1 in 30 minutes not verified; datedJanuary 5, 2006CA043042; Create a Timed Operator Action Program; dated May 10, 2006
CA043046; Failure to Meet Ventilation Time Requirements of AOP301.0; dated May 10, 2006
CA043052; Failure to Meet Ventilation Time Requirements of AOP301.1; dated May 10, 2006
CA043054; Validate AOP's Containing Time Critical Operator Actions; dated May 10, 2006
CA044089;Validate UFSAR Time Critical Actions; dated September 26, 2006
AttachmentA-3CAP037408; Design/Licensing basis concerns with Sprinkler 1 (turbine lube oil tank area);dated August 5, 2005CAP038444; Maintenance of Fire Protection SER Credited Barriers; dated October 19, 2005.
CAP039362; Time Critical Operator Actions Credited in Licensing Basis; datedDecember 15, 2005CAP041379; Failure to Meet Ventilation Time Requirements of
AOP 301.0; dated April 5, 2006Corrective Action Documents Initiated as a Result of InspectionCA044089; Validate UFSAR Time Critical Actions; dated September 26, 2006CA044116; Failure to Meet Ventilation Time Requirements of AOP301.0; datedSeptember 28, 2006CAP044170; Fire Extinguisher over pressurized; dated September 12, 2006
CAP044191; Documentation discrepancy in
FHA-800; dated September 13, 2006
CAP044195; NRC Letter to DAEC RE:
Offsite Fire Department Training; datedSeptember 13, 2006CAP044201; Inaccurate Description in
FHA-400 of Turbine Lube Oil Piping in "B" EDG Room;dated September 13, 2006CAP044204; Surveillance of 1VFD037 and 1VFD311 not completed in 2003; datedSeptember 13, 2006CAP044225;
PWR 14334 Fire Plan Revision 39 Inadequately Evaluated; dated September 14, 2006CAP044226; Fire Hose Testing; dated September 14, 2006
CAP044244; EDG Room Sprinkler Head Setpoint Selection not Well Documented; datedSeptember 15, 2006CAP044249; Sprinkler System #16 Calculation Needs Revision; dated September 15, 2006
CAP044300; Lube oil potential not identified in combustible loading; September 18, 2006
CAP044470; East EDG Day Tank Room Thermal Detector Sprinkler Temperature RatingDiscrepancy; dated September 26; 2006CAP044473; UFSAR Section 15.3.3.1 Appendix R Safe Shutdown-Time Critical OperatorAction; dated September 26, 2006
AttachmentA-4CAP044475; Diesel Maximum Room Temperature Calculation Requires Revision; datedSeptember 26, 2006CAP044512; UFSAR Change Request 94-20 does not contain adequate 50.59 basis; datedSeptember 28, 2006CorrespondenceNG-94-0841; Clarification of Penetratino Seal Inspection Basis; dated February 25, 1994NG-94-2443; Revision to DAEC Commitments on Fire Protection; dated July 19, 1994DrawingsM107-001<1>: Fire & Smoke Detection System Sh.1; Revision 11
Engineering EvaluationsFPE-B06-006: Evaluation of Fire Barrier Between Fire Zones 08F and 08H; Revision 1FPE-S02-001; Fire Detection Code Compliance Evaluation for Fire Plan Required and Fire PRAHigher Risk Areas; Revision 3SE 95-03; Safety Evaluation to Support
DDC-3151, Revision of
FHA-800 to SupersedeAppendix 'A' Requirements with Appendix 'R' Requirements; dated December 18, 1996VC-2-15: Ventilation of the Stand By Diesel Generators; dated November 26, 1972Licensee AssessmentsPDA-06-012; Fire Protection Assessment; dated August 2, 2006SA041814; Perform FSA of the Fire Protection Program; dated January 5, 2006ModificationsECP-1787; Abandon In Place Fire Damper 1V-FD-034; Revision 0
ProceduresACP 103.10; Control of Time Critical Tasks; Revision 0ACP 1203.70; Time Critical Operator Responses; Revision 0
AttachmentA-5ACP 1412.4;
Impairments to Fire Protection Systems; Revision 43AOP 913; Fire; Revision 47
AOP 915; Shutdown Outside Control Room; Revision 31
FPDI 21; NEIL Fire Barrier Inspection; Revision 0
STP NS13F001; Fire Barrier Penetration Seal Inspection, Revision 10
STP NS13F002; Fire Door and Frame Inspection; Revision 6
STP NS13F002; Fire Door and Frame Inspection; Revision 7
STP NS13F002; Fire Door and Frame Inspection; Revision 17Updated Final Safety Analysis Report Change Requests94-20; dated August 12, 1994

LIST OF ACRONYMS

USEDADAMSAgency-Wide Document Access and Management SystemDAECDuane Arnold Energy Center

DDCDesign Document Change

DPRDemonstration Power Reactor

CFRCode of Federal Regulations

DRSDivision of Reactor Safety

LLCLimited Liability Company

NFPANational Fire Protection Association

NRCU.S. Nuclear Regulatory Commission

PARSPublicly Available Records

UFSARU pdated Final Safety Analysis Report
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