Text

IR 05000382/2015007; on 01/26/2015 - 04/15/2015; Waterford Steam Electric Station, Unit 3; Triennial Fire Protection Team Inspection
	ML15147A192
Person / Time
Site:	Waterford
Issue date:	05/27/2015
From:	Greg Werner; NRC/RGN-IV/DRS/EB-2
To:	Chisum M; Entergy Operations
References
	EA-15-077 IR 2015007
	Download: ML15147A192 (50)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

May 27, 2015

EA-15-077

Mr. Michael R. Chisum

Site Vice President

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC TRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000382/2015007 AND EXERCISE OF

ENFORCEMENT DISCRETION

Dear Mr. Chisum:

On April 15, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

the Waterford Steam Electric Station, Unit 3, and discussed the results of this inspection with

Mr. B. Lanka, Director, Engineering, and other members of your staff. Inspectors documented

the results of this inspection in the enclosed inspection report.

NRC inspectors documented four findings of very low safety significance (Green) in this report.

All of these findings involved violations of NRC requirements. The NRC is treating these

violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.

Additionally, one finding involving 10 CFR 50.48(b) was identified and was a violation of NRC

requirements. The inspectors have screened this finding and determined that it warrants

enforcement discretion per the NRC Enforcement Policy Section 9.1, Enforcement Discretion

for Certain Fire Protection Issues (10 CFR 50.48) and Section 11.05(b) of Inspection Manual

Chapter 0305 (EA-15-077).

If you contest the violations or significance of the violations in this report, you should provide a

written 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 copies to the Regional Administrator, Region IV; the

Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the

Waterford Steam Electric Station, Unit 3.

M. Chisum -2-

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections,

Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response

(if any) will be available electronically for public inspection in the NRCs Public Document Room

or from the Publicly Available Records (PARS) component of the NRC's Agencywide

Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC

Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gregory E. Werner, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-382

License No. NPF-38

Enclosure:

Inspection Report No. 05000382/2015007

w/Attachment: Supplemental Information

cc w/encl: Waterford Steam Electric Station

ML15147A192

SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: Yes No Non-Publicly Available Sensitive NRC-002

OFFICE DRS/EB2 DRS/EB2 DRS/EB1 DRS/SRA DRS/EB2 C:ACES BC:DRP/D

NAME JMateychick JWatkins RKopriva GReplogle SAlferink MHay GMiller

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/11/2015 4/21/2015 4/29/2015 4/29/2015 5/5/2015 4/30/2015 5/5/2015

OFFICE OE BC:DRS/EB2

NAME KHanley GWerner

SIGNATURE /RA/ email /RA/

DATE 5/5/2015 5/27/2015

Letter to Michael R. Chisum from Gregory E. Werner, dated May 27, 2015

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC TRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000382/2015007 AND EXERCISE OF

ENFORCEMENT DISCRETION

Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Frances.Ramirez@nrc.gov)

Resident Inspector (Chris.Speer@nrc.gov)

WAT Administrative Assistant (Linda.Dufrene@nrc.gov)

Branch Chief, DRP/D (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP/D (Bob.Hagar@nrc.gov)

Project Engineer, DRP/D (Brian.Parks@nrc.gov

Project Engineer, DRP/D (Jan.Tice@nrc.gov)

Branch Chief, RES/DRA/FRB (MarkHenry.Salley@nrc.gov

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Michael.Orenak@nrc.gov)

Branch Chief, DRS/TSS (Don.Allen@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Branch Chief, OE (Nick.Hilton@nrc.gov)

Enforcement Specialist, OE (Kyle.Hanley@nrc.gov)

NRR Enforcement (Lauren.Casey@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Michael.Waters@nrc.gov)

RidsOEMailCenter.Resource

NRREnforcement.Resource

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000382

License: NPF-38

Report: 05000382/2015007

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: Hwy. 18

Killona, Louisiana

Dates: January 26 through April 15, 2015

Team Leader: J. Mateychick, Senior Reactor Inspector, Engineering Branch 2

Inspectors: S. Alferink, Reactor Inspector, Engineering Branch 2

J. Watkins, Reactor Inspector, Engineering Branch 2

R. Kopriva, Senior Reactor Inspector, Engineering Branch 1

Approved By: Gregory E. Werner

Chief, Engineering Branch 2

Division of Reactor Safety

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000382/2015007; 01/26/2015 - 04/15/2015; Waterford Steam Electric Station, Unit 3;

Triennial Fire Protection Team Inspection.

The report covered a two-week triennial fire protection team inspection by specialist inspectors

from Region IV. Four findings of very low safety significance (Green) are documented in this

report. Four of these findings involved violations of NRC requirements. The significance of

inspection findings is indicated by their color (i.e., Green, White, Yellow, or Red) which is

determined using Inspection Manual Chapter 0609, Significance Determination Process,

dated June 2, 2011. Cross-cutting aspects are determined using Inspection Manual

Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. Violations

of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The

NRCs program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 4.

Cornerstone: Mitigating Systems

Green. The team identified a non-cited violation of License Condition 2.C.(9), Fire

Protection, for the failure to ensure the required separation between fire areas.

Specifically, the licensee installed fire barriers on two ventilation ducts which were not in

a configuration demonstrated to provide the required three-hour fire-rated separation

between fire areas. The licensee entered this issue into their corrective action program

as Condition Report CR-WF3-2015-00540 and established an hourly fire watch as a

compensatory measure until corrective actions can be taken (Fire Impairments 15-30

and 15-31).

The failure to ensure the required separation between fire areas was a performance

deficiency. The performance deficiency was more than minor because it was associated

with the protection against external events (fire) attribute of the Mitigating Systems

cornerstone and it adversely affected the cornerstone objective of ensuring the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. The team evaluated this finding using Inspection

Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process,

dated September 20, 2013. Both emergency diesel generator rooms were equipped

with pre-action sprinkler systems which would limit temperatures near the ceiling around

the room exhaust ducts; therefore, the finding screened to Green at Section 1.4.3.C.

This finding did not have a cross-cutting aspect since it was not indicative of current

licensee performance since this fire barrier configuration was installed in the 1980s.

(Section 1R05.02.b)

Green. The team identified a non-cited violation of License Condition 2.C.9, "Fire

Protection," for the failure to adequately correct a previous violation. Specifically, the

licensee failed to provide a bounding calculation for the amount of time available for

operators to establish component cooling water during an alternative shutdown. The

licensee developed this calculation in response to Non-cited Violation 2012007-02.

The licensee entered this issue into their corrective action program as

-2-

Condition Report CR-WF3-2015-0859 and implemented a fire impairment as a

compensatory measure.

The failure to provide a bounding calculation for the amount of time available for

operators to establish component cooling water during an alternative shutdown was a

performance deficiency. The performance deficiency was more than minor because it

was associated with the protection against external events (fire) attribute of the

Mitigating Systems cornerstone and it adversely affected the cornerstone objective of

ensuring the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. A senior reactor analyst performed a

Phase 3 evaluation to determine the risk significance of this finding since it involved a

postulated control room fire that led to control room evacuation and determined this

violation was of very low safety significance.

This finding had a cross-cutting aspect associated with resolution within the problem

identification and resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensees corrective actions

were not effective since the licensee failed to provide a bounding calculation for the

amount of time available for operators to establish component cooling water during an

alternative shutdown (P.3). (Section 1R05.05.b.1)

Green. The team identified a non-cited violation of License Condition 2.C.9, Fire

Protection, for the failure to periodically test and demonstrate the 8-hour capacity of the

Appendix R emergency lighting units. The licensee entered this issue into their

corrective action program as Condition Report CR-WF3-2015-00856 and operators had

flashlights available as a compensatory measure.

The failure to periodically test and demonstrate the 8-hour capacity of the Appendix R

emergency lighting units was a performance deficiency. The performance deficiency

was more than minor because it was associated with the protection against external

events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the

cornerstone objective of ensuring the availability, reliability, and capability of systems

that respond to initiating events to prevent undesirable consequences. The team

evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire

Protection Significance Determination Process, dated September 20, 2013. The team

assigned the finding a low degradation rating because it would not prevent reaching and

maintaining safe shutdown conditions in the event of a control room fire. Specifically,

the team had reasonable assurance that the emergency lighting units would provide

adequate illumination for a sufficient amount of time for operators to perform the most

time critical actions. In addition, the team determined that operators performing an

alternative shutdown had flashlights available in the Appendix R equipment lockers.

Because the team assigned a low degradation rating, this finding screened as having

very low safety significance.

This finding did not have a cross-cutting aspect since it was not indicative of present

performance in that the performance deficiency occurred more than three years ago.

(Section 1R05.08.b.1)

-3-

Green. The team identified a non-cited violation of License Condition 2.C.9, Fire

Protection, for the failure to correct adverse conditions associated with fire protection.

Specifically, the licensee failed to correct longstanding deficiencies with the Appendix R

emergency lighting units. The licensee entered this issue into their corrective action

program as Condition Report CR-WF3-2015-00593 and operators had flashlights

available as a compensatory measure.

The failure to correct longstanding deficiencies with the Appendix R emergency lighting

units was a performance deficiency. The performance deficiency was more than minor

because it was associated with the protection against external events (fire) attribute of

the Mitigating Systems cornerstone and it adversely affected the cornerstone objective

of ensuring the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. The team evaluated this finding using

Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance

Determination Process, dated September 20, 2013. The team assigned the finding a

low degradation rating because the failure to provide adequate 8-hour emergency lights

at all locations would not prevent reaching and maintaining safe shutdown conditions in

the event of a control room fire. Specifically, the team determined that operators

performing an alternative shutdown had flashlights available in the Appendix R

equipment lockers. Because the team assigned a low degradation rating, this finding

screened as having very low safety significance.

This finding had a cross-cutting aspect associated with resolution within the problem

identification and resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensee failed to take corrective

actions to address the nonfunctional emergency lighting units in a timely manner (P.3).

(Section 1R05.08.b.2)

-4-

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (71111.05T)

This report presents the results of a triennial fire protection inspection conducted in

accordance with NRC Inspection Procedure 71111.05T, Fire Protection (Triennial),

at the Waterford Steam Electric Station, Unit 3. The licensee committed to adopt a

risk-informed fire protection program in accordance with National Fire Protection

Association 805 (NFPA-805), but has not yet completed the program transition. The

team evaluated the implementation of the approved fire protection program in selected

risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and

systems that ensure the post-fire capability to safely shutdown the plant.

Inspection Procedure 71111.05T requires the selection of three to five fire areas and one

or more mitigating strategies for review. The team used the Waterford Steam Electric

Station, Unit 3, Fire PRA Summary Report to select the following three risk-significant

fire areas (inspection samples) for review:

Fire Area Description

RAB 6 Electrical Penetration Room A

RAB 7 Relay Rooms (+35' Elevation)

RAB 8 Switchgear Rooms

The team evaluated the licensees fire protection program using the applicable

requirements, which included plant Technical Specifications, Operating License

Condition 2.C.(9), NRC safety evaluations, 10 CFR 50.48, and Branch Technical

Position 9.5-1. The team also reviewed related documents that included the Final Safety

Analysis Report, Section 9.5; the fire hazards analysis; and the post-fire safe shutdown

analysis. Specific documents reviewed by the team are listed in the attachment.

Three fire area inspection samples and one mitigating strategy sample were completed.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the piping and instrumentation diagrams, safe shutdown equipment

list, safe shutdown design basis documents, and the post-fire safe shutdown analysis to

verify that the licensee properly identified the components and systems necessary to

achieve and maintain safe shutdown conditions for fires in the selected fire areas. The

team observed walkdowns of the procedures used for achieving and maintaining safe

shutdown in the event of a fire to verify that the procedures properly implemented the

safe shutdown analysis provisions.

-5-

For each of the selected fire areas, the team reviewed the separation of redundant safe

shutdown cables, equipment, and components located within the same fire area. The

team also reviewed the licensees method for meeting the requirements of

10 CFR 50.48; Branch Technical Position 9.5-1, Appendix A; and 10 CFR Part 50,

Appendix R,Section III.G. Specifically, the team evaluated whether at least one

post-fire safe shutdown success path remained free of fire damage in the event of a fire.

In addition, the team verified that the licensee met applicable license commitments.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe the

material condition and configuration of the installed fire area boundaries (including walls,

fire doors, and fire dampers) and verify that the electrical raceway fire barriers were

appropriate for the fire hazards in the area. The team compared the installed

configurations to the approved construction details, supporting fire tests, and applicable

license commitments.

The team reviewed installation, repair, and qualification records for a sample of

penetration seals to ensure the fill material possessed an appropriate fire rating and that

the installation met the engineering design. The team also reviewed similar records for

the rated fire wraps to ensure the material possessed an appropriate fire rating and that

the installation met the engineering design.

b. Findings

Introduction. The team identified a Green non-cited violation of License

Condition 2.C.(9), Fire Protection, for the failure to ensure the required separation

between fire areas. Specifically, the licensee installed fire barriers on two ventilation

ducts which were not in a configuration demonstrated to provide the required three-hour

fire-rated separation between fire areas.

Description. The approved fire protection program required fire areas to be separated

by floors, walls, and ceilings having a three-hour fire resistance rating except as noted in

the fire area analysis. The team reviewed surveillance Procedure ME-0003-009, Fire-

Rated Walls, Floors, and Ceilings, Revision 302. The procedure identified two fire

barriers which did not require inspection because they were encapsulated in metal

flashing.

-6-

The emergency diesel generator (EDG) rooms were fire areas reactor auxiliary

building (RAB) 15 (EDG B) and RAB 16 (EDG A). These rooms were below the

ventilation mechanical room which is fire area RAB 2. The inlets to the EDG room

exhaust fans were 72x72 ducts which extended down from the ceilings and flared out

to larger openings. Fire Dampers FD-76 and FD-77 were located on the ends of the

ducts in fire area RAB 15 and RAB 16, respectively. Since the fire dampers were not in

the plane of the ceiling, the ductwork between the fire damper and the ceiling required

protection from the effects of a fire. Thermo-Lag material was installed on the ducts

between the fire damper and the ceiling. Records show that three-hour rated materials

were used; however, metal flashing was also installed encapsulating the fire barriers on

the ducts.

Thermo-Lag fire barriers are not passive insulating materials. Thermo-Lag sublimates

when exposed to high temperatures. The gases generated during the process absorb

heat which would otherwise be transferred to the item being protected. Encapsulating

the fire barriers with metal flashing restricts the release of gases. This is not a tested

configuration for Thermo-Lag fire barriers. While three-hour rated materials were used,

the effective fire resistance of the as-installed configuration is unknown.

Analysis. The failure to ensure the required separation between fire areas was a

performance deficiency. The performance deficiency was more than minor because it

was associated with the protection against external events (fire) attribute of the

Mitigating Systems cornerstone and it adversely affected the cornerstone objective of

ensuring the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. The team evaluated this finding using

Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance

Determination Process, dated September 20, 2013. The finding involved fire barrier

elements that separate one fire area from another; therefore, it was determined to be in

the fire confinement category in Inspection Manual Chapter 0609, Appendix F,

Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet. Both EDG rooms are

equipped with pre-action sprinkler systems (fully automated suppression system) which

would limit temperatures near the ceiling around the room exhaust ducts; therefore, the

finding screened to Green in accordance with Section 1.4.3.C.

This finding did not have a cross-cutting aspect since it was not indicative of current

licensee performance since this fire barrier configuration was installed in the 1980s.

Enforcement. License Condition 2.C(9), Fire Protection, states, in part, EOI [Entergy

Operations, Inc.] shall implement and maintain in effect all provisions of the approved

fire protection program as described in the Final Safety Analysis Report for the facility

through Amendment 36 and as approved in the safety evaluation report (SER) through

Supplement 9. The Final Safety Analysis Report, Section 9.5.1.2.1, Fire Containment,

states, in part, Ductwork penetrations through fire area/zone boundary walls, floors, and

ceilings are externally sealed to provide fire resistance rating of three hours. The Final

Safety Analysis Report, Section 9.5.1.3.1, Detailed Comparison to Appendix "A" to the

Branch Technical Position APCSB 9.5-1, Revision 0, Item D.1.(j), states, in part,

Appendix R fire areas are isolated from each other by floors, walls, and ceilings having

a fire resistance rating of three hours unless noted otherwise in the Fire Area-By-Area

-7-

Analysis. The Final Safety Analysis Report, Section 9.5.1.3.2, Fire Area-By-Fire Area

Analysis, identifies the fire area design rating of three hours for the boundaries between

fire areas RAB 2, RAB 15, and RAB 16. Contrary to the above, prior to February 13,

2015, the licensee failed to establish fire area boundaries having a fire resistance rating

of three hours. Specifically, two fire barriers protecting ventilation ducts between fire

dampers and the rooms ceilings are configured in a manner in which the fire resistance

rating is indeterminate.

Because this violation was of very low safety significance, has been entered into the

corrective action program as Condition Report CR-WF3-2015-00540, and the licensee

has established an hourly fire watch as a compensatory measure until corrective actions

can be taken, Fire Impairments 15-30 and 15-31, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000382/2015007-01, Inadequate Fire Area Boundary.

.03 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection

and suppression systems in the selected fire areas. The team verified the automatic

detection systems and the manual and automatic suppression systems were installed,

tested, and maintained in accordance with the National Fire Protection Association code

of record or approved deviations and that each suppression system was appropriate for

the hazards in the selected fire areas.

The team performed a walkdown of accessible portions of the detection and suppression

systems in the selected fire areas. The team also performed a walkdown of major

system support equipment in other areas (e.g., fire pumps) to assess the material

condition of these systems and components.

The team reviewed the electric and diesel fire pumps flow and pressure tests to verify

that the pumps met their design requirements. The team also reviewed the fire water

supply system flow and pressure tests to verify that the system capability met the design

requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and

drill critique records. The team also reviewed pre-fire plans and smoke removal plans

for the selected fire areas to determine if appropriate information was provided to fire

brigade members and plant operators to identify safe shutdown equipment and

instrumentation and to facilitate suppression of a fire that could impact post-fire safe

shutdown capability. In addition, the team inspected fire brigade equipment to determine

operational readiness for fire-fighting.

The team observed an unannounced fire drill and subsequent drill critique on

February 12, 2015, using the guidance contained in Inspection Procedure 71111.05AQ,

Fire Protection Annual/Quarterly. The team observed fire brigade members fight a

simulated fire in fire area RAB 15, EDG room B. The team verified that the licensee

-8-

identified problems, openly discussed them in a self-critical manner at the drill debrief,

and identified appropriate corrective actions. Specific attributes evaluated were (1)

proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use

and layout of fire hoses; (3) employment of appropriate fire-fighting techniques; (4)

sufficient fire-fighting equipment was brought to the scene; (5) effectiveness of fire

brigade leader communications, command, and control; (6) search for victims and

propagation of the fire into other areas; (7) smoke removal operations; (8) utilization of

pre-planned strategies; (9) adherence to the pre-planned drill scenario; and (10) drill

objectives.

b. Findings

No findings were identified.

.04 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed plant walkdowns and document reviews to verify that redundant

trains of systems required for hot shutdown, which are located in the same fire area,

would not be subject to damage from fire suppression activities or from the rupture or

inadvertent operation of fire suppression systems. Specifically, the team verified:

A fire in one of the selected fire areas would not directly, through production of

smoke, heat, or hot gases, cause activation of suppression systems that could

potentially damage all redundant safe shutdown trains.

A fire in one of the selected fire areas or the inadvertent actuation or rupture of a

fire suppression system would not directly cause damage to all redundant trains

(e.g., sprinkler-caused flooding of other than the locally affected train).

Adequate drainage is provided in areas protected by water suppression systems.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

Review of Methodology

The team reviewed the safe shutdown analysis, operating procedures, piping and

instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and

other supporting documents to verify that hot and cold shutdown could be achieved and

maintained from outside the control room for fires that require evacuation of the control

room, with or without offsite power available.

-9-

The team conducted plant walkdowns to verify that the plant configuration was

consistent with the description contained in the safe shutdown and fire hazards

analyses. The team focused on ensuring the adequacy of systems selected for

reactivity control, reactor coolant makeup, reactor decay heat removal, process

monitoring instrumentation, and support systems functions.

The team also verified that the systems and components credited for shutdown would

remain free from fire damage. Finally, the team verified that the transfer of control from

the control room to the alternative shutdown location would not be affected by

fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for

alternative shutdown control circuits).

Review of Operational Implementation

The team verified that licensed and non-licensed operators received training on

alternative shutdown procedures. The team also verified that sufficient personnel to

perform a safe shutdown were trained and available on-site at all times, exclusive of

those assigned as fire brigade members.

The team performed a timed walkdown of the alternative shutdown procedure with

licensed and non-licensed operators to determine the adequacy of the procedure. The

team verified that the operators could reasonably be expected to perform specific

actions within the time required to maintain plant parameters within specified limits.

Time critical actions that were verified included restoring electrical power, establishing

control at the remote shutdown panels, establishing reactor coolant makeup, and

establishing decay heat removal.

The team also reviewed the periodic testing of the alternative shutdown transfer

capability and instrumentation and control functions to verify that the tests were

adequate to demonstrate the functionality of the alternative shutdown capability.

b. Findings

.1 Introduction. The team identified a Green non-cited violation of License Condition 2.C.9,

Fire Protection, for the failure to adequately correct a previous violation. Specifically,

the licensee failed to provide a bounding calculation for the amount of time available for

operators to establish component cooling water during an alternative shutdown. The

licensee developed this calculation in response to Non-cited Violation 2012007-02.

Description. During the 2012 triennial fire protection inspection, the team identified a

violation for the failure to perform a safe shutdown design calculation. Specifically, the

team determined that the licensee failed to calculate the amount of time available for

operators to establish component cooling water to a running emergency diesel generator

that was providing power to safe shutdown components during an alternative shutdown.

The team documented this issue as Non-cited Violation 2012007-02, Failure to

Calculate Adequate Cooling Provided to Diesel Generator B within Required Time.

- 10 -

The licensee entered this issue into their corrective action program as Condition

Report 2012-00818.

In response to this violation, the licensee developed Engineering Change EC-36621,

Evaluate Impacts of Operating the Emergency Diesel Generators (EDGs) Without

Component Cooling Water. This engineering change revised Calculation EC-M12-001,

Emergency Diesel Generator with no CCW Flow, which determined the amount of time

that an emergency diesel generator could run without component cooling water during

an alternative shutdown prior to being damaged.

In Calculation EC-M12-001, the licensee first determined a worst case emergency diesel

generator load of 3.23 megawatt (MW) for an alternative shutdown without component

cooling water. The licensee then estimated the heat load for a running emergency

diesel generator by fitting a second order polynomial to empirical data. The licensee

estimated a heat load of approximately 5.65 MBTU/hr. when an emergency diesel

generator carried a load of 3.23 MW. Using this heat load of 5.65 MBTU/hr., the

licensee calculated an emergency diesel generator could run for 10 minutes without

component cooling water and not be damaged. The licensee used this result to support

the 10-minute time-critical action for operators to establish component cooling water

during an alternative shutdown.

The team reviewed Calculation EC-M12-001 and noted the empirical data demonstrated

the heat load near 3.23 MW was greater than the estimated heat load from the best fit

polynomial regression. The team concluded that the licensees calculation was not

bounding and operators had less than 10 minutes available to establish component

cooling water during an alternative shutdown. During the timed walkdown of the

alternative shutdown procedure, the team determined that it would take operators

approximately 11 minutes to establish component cooling water.

Analysis. The failure to provide an appropriate bounding calculation for the amount of

time available for operators to establish component cooling water during an alternative

shutdown was a performance deficiency. The performance deficiency was more than

minor because it was associated with the protection against external events (fire)

attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone

objective of ensuring the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. The team evaluated this finding

using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance

Determination Process, dated September 20, 2013, because it affected the ability to

reach and maintain safe shutdown conditions in case of a fire. A senior reactor analyst

performed a Phase 3 evaluation to determine the risk significance of this finding since it

involved a postulated control room fire that led to control room evacuation.

For the control room, the senior reactor analyst assigned a generic fire ignition frequency

for the main control board (FIFMCB) from NUREG/CR-6850, Table 6-1, Fire Frequency

Bins and Generic Frequencies. The analyst multiplied the fire ignition frequency by a

severity factor (SF) and a non-suppression probability indicating that operators failed to

extinguish the fire within 20 minutes, assuming a 2-minute detection that required a

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control room evacuation (NPCRE). The resulting control room evacuation frequency (FCR)

was:

FCR = FIFMCB * SF * NPCRE

= 2.5E-3/year * 0.1 * 1.3E-2

= 3.25E-6/year

The main control board had a total of 12 panels. The analyst determined that only a fire

in one of these panels (CP-8) could lead to the loss of component cooling water to the

emergency diesel generator. Therefore, a bounding change in core damage frequency

for a control room fire that leads to evacuation and the loss of the emergency diesel

generator (FCRE+EDG) was determined to be:

FCR+EDG = FCR * (1 / 12)

= 3.25E-6/year * (1 / 12)

= 2.7E-7/year

For the cable vault, the senior reactor analyst limited the risk determination to transient

and hot work fires since there were no fixed ignition sources in the cable vault. The

senior reactor analyst assigned a low likelihood rating for transients and hot work

activities in the cable vault. The senior reactor analyst then assigned a fire ignition

frequency for transients (FIFCV-TR) and hot work activities (FIFCV-HW) from Inspection

Manual Chapter 0609, Appendix F, Attachment 4.

The senior reactor analyst determined that the floor area of the cable vault was

5778.5 square feet. The senior reactor analyst assigned a screening weighting

factor (W) of 0.1 for transient and hot work fires. The senior reactor analyst noted that

the cable vault had smoke detectors and a pre-action automatic sprinkler system. The

senior reactor analyst assigned a nominal failure probability of the sprinkler system

(PSPR) from Inspection Manual Chapter 0609, Appendix F, Task 2.7.4.

The senior reactor analyst calculated a bounding change in core damage frequency for a

cable vault fire that leads to evacuation and the loss of the emergency diesel generator

(FCV+EDG) was determined to be:

FCV+EDG = (FIFTR + FIFHW) * W * NPSPR

= (5.5E-5/year + 2.3E-5/year) * 0.1 * 0.05

= 3.9E-7/year

Since fires in the control room are independent of fires in the cable vault, the senior

reactor analyst calculated a bounding total change in core damage frequency (CDFTOT)

for the performance deficiency by adding the change in core damage frequencies for the

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control room and cable vault calculated above. The senior reactor analyst calculated a

bounding total change in core damage frequency of:

CDFTOT = FCR+EDG + FCV+EDG

= 2.7E-7/year + 3.9E-7/year

= 6.6E-7/year

This change in core damage frequency was considered to be bounding since it

assumed:

A fire in any of the applicable main control board panels or the cable vault areas

would cause a loss of offsite power and a loss of component cooling water,

resulting in a loss of the emergency diesel generator;

The conditional core damage probability given a control room fire with evacuation

and the loss of the emergency diesel generator was equal to one, and

The performance deficiency accounted for the entire change in core damage

frequency (i.e., the baseline core damage frequency for this event was zero).

In accordance with the guidance in Inspection Manual Chapter 0609, Appendix H,

Containment Integrity Significance Determination Process, dated May 6, 2004, the

senior reactor analyst screened the performance deficiency for its potential risk

contribution to large early release frequency since the bounding change in core damage

frequency provided a risk significance estimate greater than 1E-7/yr. Given that

Waterford has a large dry containment and that control room evacuation sequences do

not include steam generator tube ruptures or intersystem loss of coolant accidents, the

analyst determined that this example was not significant with respect to large early

release frequency. The analyst determined this example was of very low risk

significance (Green).

This finding had a cross-cutting aspect associated with Resolution within the Problem

Identification and Resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensees corrective actions

were not effective since the licensee failed to provide a bounding calculation for the

amount of time available for operators to establish component cooling water during an

alternative shutdown (P.3).

Enforcement. License Condition 2.C.9, Fire Protection, states, in part, that the licensee

shall implement and maintain in effect all provisions of the approved fire protection

program as described in the Final Safety Analysis Report for the facility through

Amendment 36 and as approved in the Safety Evaluation Report through Supplement 9.

Final Safety Analysis Report, Section 9.5.1.3.1.C, states that the fire protection program

quality assurance program is documented in Procedure UNT-005-013, Fire Protection

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Program. Procedure UNT-005-013, Section 5.8.8, states, in part, that conditions

adverse to quality relating to the fire protection program will be identified and corrected.

Contrary to the above, from September 5, 2012, to April 15, 2015, the licensee failed to

implement and maintain in effect all provisions of the approved fire protection program.

Specifically, the licensee failed to correct a condition adverse to fire protection since the

licensee failed to perform an appropriate bounding calculation for the amount of time

available for operators to establish component cooling water during an alternative

shutdown. The licensee developed this calculation as a corrective action for Non-cited

Violation 2012007-02, Failure to Calculate Adequate Cooling Provided to Diesel

Generator B within Required Time.

The licensee entered this issue into their corrective action program as Condition

Report CR-WF3-2015-00859 and implemented Fire Impairment 15-045 as a

compensatory measure. Because this violation was of very low safety significance and

has been entered into the corrective action program, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000382/2015007-02, Failure to Provide a Bounding Calculation for Time Critical

Actions.

.2 Introduction. The team identified a violation of Technical Specification 6.8.1.f for the

failure to implement and maintain adequate written procedures covering fire protection

program implementation. Specifically, the team identified four examples where the

licensee failed to maintain an alternative shutdown procedure that successfully mitigated

all postulated alternative shutdown scenarios. This finding affects 10 CFR 50.48 and

has been screened and determined to warrant enforcement discretion per the Interim

Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues

(10 CFR 50.48).

Description. The licensee used Procedure OP-901-502, Evacuation of Control Room

and Subsequent Plant Shutdown, Revision 28, to shut down the reactor from the

remote shutdown panel in the event a control room or cable vault fire required

evacuation of the control room. This alternative shutdown procedure provided steps for

operators to transfer control of the credited safe shutdown equipment away from the

control room to the remote shutdown panel and to achieve and maintain safe shutdown

conditions from the remote shutdown panel.

The team performed a timed walkdown of the alternative shutdown procedure. Based

on the walkdown results, the team determined that the alternative shutdown procedure

was not adequate to ensure that operators could successfully mitigate all postulated

alternative shutdown scenarios. In particular, the team identified the following four

scenarios where operators may not be able to achieve and maintain a safe shutdown:

Example 1: Potential Loss of Credited Safe Shutdown Pumps

The first scenario involved fire damage resulting in blown fuses for either the component

cooling water or emergency feedwater pumps. In this scenario, the team determined the

operators would be unable to control the affected pump from the remote shutdown

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panel, but the operators would be able to control the affected pump by manually

operating the breakers that supplied power to the motors. The team noted that the

alternative shutdown procedure did not provide any steps for operators to manually

operate the breakers to control these pumps, which were required for safe shutdown.

Example 2: Potential Spurious Opening of the Atmospheric Dump Valves

The second scenario involved the spurious actuation of two atmospheric dump valves.

The team noted that the licensee previously had a 10-minute requirement for operators

to mitigate the spurious actuation of two atmospheric dump valves by taking manual

control of an open atmospheric dump valve locally and then manually closing the valve.

The team determined that the alternative shutdown procedure provided steps for

operators to manually close an open atmospheric dump valve; however, the licensee

removed the 10-minute requirement for operators to be able to perform this action.

The licensee removed the 10-minute requirement based on its understanding that the

spurious actuation of only one atmospheric dump valve was required to be analyzed and

mitigated. The team referred to guidance in Regulatory Guide 1.189, Revision 2, which

stated, in part, after control of the plant is achieved by the alternative or dedicated

shutdown system, single or multiple spurious actuations that could occur in the fire-

affected area should be considered...

The team reviewed the licensees method for isolating the atmospheric dump valves

from the effects of a control room or cable vault fire. The team determined that the

circuits responsible for isolating the atmospheric dump valves were located within the

control room complex and, therefore, could not be relied upon to isolate the atmospheric

dump valves in the event of a control room fire. The team concluded that the licensee

should have maintained the 10-minute requirement in the alternative shutdown

procedure for operators to manually close a spuriously open atmospheric dump valve.

During the timed walkdown of the alternative shutdown procedure, the team determined

that it would take operators approximately 13 minutes to close a spuriously open

atmospheric dump valve.

Example 3: Potential Spurious Opening of a Pressurizer Spray Valve

The third scenario involved the spurious opening of a pressurizer spray valve. In this

scenario, the open pressurizer spray valve results in a rapid depressurization of the

reactor coolant system, which could negatively impact the ability to achieve and maintain

natural circulation.

The licensee considered this scenario in the safe shutdown analysis. The licensee did

not perform an analysis or calculation to determine the amount of time operators had

available to mitigate this scenario. Instead, the licensee used engineering judgment to

specify that operators had 10 minutes available to secure the spurious spray flow.

The team was concerned that the 10-minute limit may not be sufficient to ensure that

operators could achieve and maintain natural circulation. In response to the teams

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concern, the licensee modeled this scenario on the simulator. The team noted that the

use of the simulator was not a preferred method; however, it provided a reasonable

estimate for the amount of time available.

The results of the simulator run indicated that the reactor coolant system would reach

saturation pressure in less than 8 minutes. Once the reactor coolant system reaches

saturation pressure, voiding begins in the reactor coolant system. This voiding could

then negatively impact the ability to achieve and maintain natural circulation.

The team determined that the alternative shutdown procedure provided steps for

operators to trip the reactor coolant pumps, which would mitigate this scenario by

eliminating flow through the pressurizer spray valves. During the timed walkdown of

the alternative shutdown procedure, the team determined that it would take operators

approximately 9 minutes and 15 seconds to trip all of the reactor coolant pumps.

Scenario 4: Potential Overfilling of the Steam Generators

The fourth scenario involved the potential overfilling of the steam generators. In this

scenario, the open main steam isolation valves continue to provide steam to the turbine-

driven main feedwater pumps, which continue to inject feedwater into the steam

generators until they overfill.

The team noted that the action to close the main steam isolation valves prior to

evacuating the control room was an operator action within the fire area. The team

determined that this action was not credited in the plants approved fire protection

program; therefore, the operators must take action outside of the control room to ensure

that the main steam isolation valves were closed.

Because the licensee did not have an analysis establishing a time limit, the team was

concerned the operators may not perform this action prior to main feedwater overfilling

the steam generators. In response to the teams concern, the licensee modeled this

scenario on the simulator. The team noted that the use of the simulator was not a

preferred method; however, it provided a reasonable estimate for the amount of time

available.

The results of the simulator run indicated that the continued injection of main feedwater

at full flow could overfill the steam generators in approximately 2 minutes and

30 seconds. The team noted that overfilling the steam generators would negatively

impact the ability to remove decay heat.

The team determined that the alternative shutdown procedure provided steps for

operators to close the main steam isolation valves from outside the control room, which

would mitigate this scenario by eliminating steam flow to the turbine-driven main

feedwater pumps. During the timed walkdown of the alternative shutdown procedure,

the team determined that it would take operators approximately 4 minutes and

30 seconds to close all of the main steam isolation valves.

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Analysis. The failure to implement and maintain adequate written procedures covering

fire protection program implementation was a performance deficiency. The performance

deficiency was more than minor because it was associated with the procedure quality

attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone

objective of ensuring the availability, reliability, and capability of systems that respond to

initiating events to prevent undesirable consequences. A senior reactor analyst

performed a calculation to bound the risk significance of this finding. The senior reactor

analyst determined that the finding was not of high safety significance. As discussed

below, the team consulted the NRC Enforcement Policy, Section 9.1, Enforcement

Discretion for Certain Fire Protection Issues (10 CFR 50.48), to determine if the

noncompliance was eligible for enforcement discretion.

This finding did not have a cross-cutting aspect because it qualified for enforcement

discretion.

Enforcement. Technical Specification 6.8.1.f states that written procedures shall be

established, implemented, and maintained covering fire protection program

implementation. Licensee Procedure OP-901-502, Evacuation of Control Room and

Subsequent Plant Shutdown, Revision 28, implemented alternative shutdown outside of

the control room. Contrary to the above, prior to April 15, 2015, the licensee failed to

implement and maintain written procedures covering fire protection program

implementation. Specifically, the team identified four scenarios where the licensee failed

to ensure that the alternative shutdown procedure was adequate to ensure that

operators could mitigate all postulated alternative shutdown scenarios.

Because the licensee committed to adopting National Fire Protection Association

Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor

Electric Generating Plants, and has committed to changing their fire protection program

license basis to comply with 10 CFR 50.48(c) by submitting a license amendment

request to the NRC, this violation was eligible for enforcement discretion as described in

Section 9.1 of the Enforcement Policy, Enforcement Discretion for Certain Fire

Protection Issues (10 CFR 50.48).

Specifically, the team determined that the licensee: (1) would have identified the

violation in light of the defined scope, thoroughness, and schedule of its transition to

10 CFR 50.48(c) because the licensee was performing new analyses and revising the

alternative shutdown procedure for the transition to NFPA-805; (2) the licensee will

correct the violation after completing its transition to 10 CFR 50.48(c) and took

immediate corrective action and compensatory measures within a reasonable time

commensurate with the risk significance of the issue following identification; (3) routine

licensee efforts were not likely to have previously identified the violation; (4) the violation

was not willful; and (5) the team determined that this violation was not of high safety

significance. The finding also met additional discretion criteria established in

Section 11.05.b of Inspection Manual Chapter 0305, Operating Reactor Assessment

Program.

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The licensee entered these issues into its corrective action program as Condition

Reports CR-WF3-2015-00833, CR-WF3-2015-00857, CR-WF3-2015-00858,

CR-WF3-2015-01871, CR-WF3-2015-01872, and CR-WF3-2015-01873, and

implemented Fire Impairments 15-041 through 15-045 as compensatory measures.

Since all the criteria for the use of enforcement discretion were met, the NRC is

exercising enforcement discretion to not cite this violation in accordance with the

Interim Enforcement Policy regarding Enforcement Discretion For Certain Fire

Protection Issues (10 CFR 50.48). This use of enforcement discretion is documented

in the Enforcement Tracking System as EA-2015-077.

.06 Circuit Analysis

a. Inspection Scope

The team reviewed the post-fire safe shutdown analysis to verify that the licensee

identified the circuits that may impact the ability to achieve and maintain safe shutdown.

The team verified, on a sample basis, that the licensee properly identified the cables for

equipment required to achieve and maintain hot shutdown conditions in the event of a

fire in the selected fire areas. The team verified that these cables were either

adequately protected from the potentially adverse effects of fire damage or were

analyzed to show that fire-induced circuit faults (e.g., hot shorts, open circuits, and

shorts to ground) would not prevent safe shutdown.

The teams evaluation focused on the cables of selected components from the reactor

coolant system, refueling water storage tank, component cooling water, auxiliary

component cooling water, main steam isolation, atmospheric steam dumps, emergency

feed water, emergency diesel, low pressure safety injection, and chemical volume and

control system. For the sample of components selected, the team reviewed electrical

elementary and block diagrams and identified power, control, and instrument cables

necessary to support their operation. In addition, the team reviewed cable routing

information to verify that fire protection features were in place as needed to satisfy the

separation requirements specified in the fire protection license basis. Specific

components reviewed by the team are listed in the attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team inspected the contents of designated emergency storage lockers and

reviewed the alternative shutdown procedure to verify that portable radio

communications and fixed emergency communications systems were available,

operable, and adequate for the performance of designated activities. The team verified

the capability of the communication systems to support the operators in the conduct and

coordination of their required actions. The team also verified that the design and

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location of communications equipment such as repeaters and transmitters would not

cause a loss of communications during a fire. The team discussed system design,

testing, and maintenance with the system engineer.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team reviewed the portion of the emergency lighting system required for alternative

shutdown to verify that it was adequate to support the performance of manual actions

required to achieve and maintain hot shutdown conditions and to illuminate access and

egress routes to the areas where manual actions would be required. The team

evaluated the locations and positioning of the emergency lights during a walkdown of the

alternative shutdown procedure.

The team verified that the licensee installed emergency lights with an 8-hour capacity,

maintained the emergency light batteries in accordance with manufacturer

recommendations, and tested and performed maintenance in accordance with plant

procedures and industry practices.

b. Findings

.1 Introduction. The team identified a Green non-cited violation of License Condition 2.C.9,

Fire Protection, for the failure to periodically test and demonstrate the 8-hour capacity

of the Appendix R emergency lighting units.

Description. In 2004, the licensee discontinued the performance of 8-hour discharge

tests for the Appendix R emergency lighting units. Specifically, the licensee removed

the requirement to perform the discharge tests from Procedure ME-004-445, Self

Contained Battery Powered Emergency Lighting Unit. In lieu of performing discharge

tests, the licensee implemented a preventive maintenance program that replaced the

emergency lighting unit batteries every three years.

The licensee documented their justification in Engineering Request ER-W3-2004-0222,

Alternative Methodology for Appendix R 8-Hour Battery Powered Emergency Light

Testing, Revision 0. This engineering request referenced guidance contained in

EPRI TR-106826, Battery Performance Monitoring by Internal Ohmic Measurements.

The team reviewed the engineering request and the EPRI report and determined that the

licensee incorrectly applied the results of the EPRI report. Specifically, the team noted

that the objective of the EPRI report was to determine the extent to which internal ohmic

measurements could replace or reduce the frequency of discharge tests for emergency

lighting units. Based on the favorable test results, EPRI recommended using internal

ohmic measurements in lieu of discharge tests for two types of emergency lighting units.

- 19 -

The team noted that the licensee did not use either of these two types of emergency

lighting units, nor did the EPRI report recommend discontinuing discharge tests for any

other types of emergency lighting units.

In addition to referencing the EPRI report, the licensee made the following statements

regarding the discharge tests:

No specific regulatory or OEM requirement was found that requires the 8-hour

discharge test.

The 8-hour capacity of the unit is a design function which is applicable to

component selection and does not require periodic re-verification.

The units self-diagnostic circuit monitors the battery capacity which is the

equivalent to the current discharge test.

The team reviewed the fire protection program described in Procedure UNT-005-013,

Fire Protection Program, Revision 12, and determined that it required the licensee to

periodically test the emergency lighting units to ensure that the equipment will function

properly and continue to meet their design criteria (i.e., have an 8-hour battery capacity).

The team noted that the licensee failed to consider this requirement when changing

Procedure ME-004-445. Finally, the team reviewed the licensees justification and the

vendors information and did not find evidence to support the statement that the units

self-diagnostic circuit monitoring was sufficient to demonstrate the required 8-hour

battery capacity.

Analysis. The failure to periodically test and demonstrate the 8-hour capacity of the

Appendix R emergency lighting units was a performance deficiency. The performance

deficiency was more than minor because it was associated with the protection against

external events (fire) attribute of the Mitigating Systems cornerstone and it adversely

affected the cornerstone objective of ensuring the availability, reliability, and capability

of systems that respond to initiating events to prevent undesirable consequences.

The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F,

Fire Protection Significance Determination Process, dated September 20, 2013,

because it affected the ability to reach and maintain safe shutdown conditions in case of

a fire. The team assigned the finding to the post-fire safe shutdown category since it

impacted the alternate shutdown element. The team assigned the finding a low

degradation rating because the failure to periodically test and demonstrate the 8-hour

capacity of the Appendix R emergency lighting units would not prevent reaching and

maintaining safe shutdown conditions in the event of a control room fire. Specifically,

the team had reasonable assurance that the emergency lighting units would provide

adequate illumination for a sufficient amount of time for operators to perform the most

time critical actions. In addition, the team determined that operators performing an

alternative shutdown had flashlights available in the Appendix R equipment lockers.

Because the team assigned a low degradation rating, in accordance with Inspection

Manual Chapter 0609, Appendix F, Step 1.3.1.B, this finding screened as having very

low safety significance (Green).

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