IR 05000498/2014008

IR 05000498/2014008, 05000499/2014008; on 09/08 - 09/25/2014; South Texas Project Electric Generating Station, Units 1 and 2; Triennial Fire Protection Team Inspection

ML14295A263
Person / Time
Site:	South Texas
Issue date:	10/21/2014
From:	Werner G E NRC/RGN-IV/DRS/EB-2
To:	Koehl D L South Texas
Werner G E
References
IR 2014008
Download: ML14295A263 (30)

Text

October 21, 2014

Mr. Dennis L. Koehl, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000498/2014008 AND 05000499/2014008

Dear Mr. Koehl:

On September 25, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The team documented the results of this inspection in the enclosed inspection report.

An NRC team of inspectors documented one finding of very low safety significance (Green) in this report. Further, a licensee-identified violation that was determined to be of very low safety significance is documented in this report. Both 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. 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 South Texas Project Electric Generating Station, Units 1 and 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 NRC's 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 Dockets: 50-498; 50-499 Licenses: NPF-76; NPF-80

Enclosure:

Inspection Report No 05000498/2014008 AND 05000499/2014008

w/Attachment:

Supplemental Information cc w/

Enclosure:

DISTRIBUTION: See next page

SUMMARY OF FINDINGS

IR 05000498/2014008, 05000499/2014008; 09/08 - 09/25/2014; South Texas Project Electric Generating Station, Units 1 and 2; Triennial Fire Protection Team Inspection. The report covered a two-week triennial fire protection team inspection by specialist inspectors from Region IV. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one licensee-identified violation of very low safety significance. The significance of inspection findings is indicated by their color (i.e., Green, White, Yellow, or Red) and 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." Violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy dated July 9, 2013. The NRC's 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 Technical Specification 6.8.1.d for the failure to implement and maintain written procedures for fire protection program implementation. Specifically, the licensee failed to have procedures for and to flow test the portions of the underground piping that supplied water to the diesel generator buildings since the initial startup test. The licensee initiated actions to perform the flow testing within two months and entered the deficiency into their corrective action program as Condition Report 14-17098. The failure to conduct flow testing of the entire underground fire protection piping loop was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors attribute (fire) and adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to performance test the underground fire protection piping loops supplying the emergency diesel generator buildings for both units did not demonstrate the continued capability to deliver adequate flow and pressure to the fire suppression systems supplying those buildings. The team evaluated the finding using Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," because it affected fire protection defense-in-depth strategies involving fire water supply. Using Appendix F, the team determined that the finding screened to very low safety significance. Specifically, the finding did not prevent the reactor from achieving safe shutdown since only one safe shutdown train would be affected at a time. Since these underground fire protection piping loops had not been flow tested since initial installation and nothing caused the licensee to reevaluate the test, the team determined that this failure did not reflect current performance. (Section 1R05)

B. Licensee-Identified Violations

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

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection

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 South Texas Project Electric Generating Station, Units 1 and 2. The inspection 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 inspection team used the fire hazards analysis section of the South Texas Project Electric Generating Station, Units 1 and 2 Individual Plant Examination of External Events to select the following four risk-significant fire areas (inspection samples) for review: Fire Area Fire Zone Description 1 Z032 Z034 Relay cabinet room Control room 3 Z147 Locker rooms and clothing issue 4 Z046 Z050 Z052 Train C electrical penetration area Corridor, offices, CAS battery room and electrical equipment Train C ESF switchgear room 31 Z047 Cable Spreading Room The inspection team evaluated the licensee's fire protection program using the applicable requirements, which included plant Technical Specifications, Operating License Condition 2.E, NRC safety evaluations, 10 CFR 50.48, and Branch Technical Position 9.5-1. The team also reviewed related documents that included the Updated 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. Four 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 walk downs 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. 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 licensee's 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

No findings were identified.

.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 and Halon supply systems) 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 halon suppression functional 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 September 23, 2014, using the guidance contained in Inspection Procedure 71111.05AQ, "Fire Protection Annual/Quarterly." The team observed fire brigade members fight a simulated fire in the electrical auxiliary building. The team verified that the licensee 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

Introduction.

The team identified a Green non-cited violation of Technical Specification 6.8.1.d for the failure to implement and maintain written procedures for fire protection program implementation. Specifically, the licensee failed to have procedures for and to flow test the portions of the underground piping that supplied water to the diesel generator buildings since the initial startup test. The licensee initiated actions to perform the flow testing within two months and entered the deficiency into their corrective action program as Condition Report 14-17098.

Description.

The team reviewed the underground fire protection piping loop flow testing conducted in accordance with their fire protection program. Procedure 0PGP03-ZF-0018, "Fire Protection System Functionality Requirements," Revision 17, specified that the licensee shall perform flow testing at least once every 3 years in accordance with Chapter 8, Section 17 of the Fire Protection Handbook, 17th Edition, published by the National Fire Protection Association. As specified in the Fire Protection Handbook, Chapter 8, Section 17, the hydrant flow tests (i.e., underground fire protection piping) are used to determine the adequacy and reliability of the water system. Specifically, the flow tests determine, in part, the rate at which water is available at specific locations within the distribution system and verify the accuracy of distribution models. The licensee flow tested the underground fire protection piping loops both inside and outside the protected area using Procedure 0PTP03-FP-0105, "Fire Protection System Flow Test," Revision 8.

Calculation MC 6285, "Fire Protection Underground Loop," Revision 0, provided the distribution model for the underground fire protection piping and other flow arteries at the plant. Calculation MC 6285 determined the available pressure at specific nodes given the design flow rate in the underground fire protection piping. The team noted that the flow calculation determined the flow and pressures distributed through all of the underground legs and not just the outer loop. During discussions with licensee personnel, the team questioned why they did not test the underground fire protection piping routed to the diesel generator buildings and the deluge valve houses in each unit and questioned the purpose of the testing.

Based on review of Calculation MC 6285, review of Procedure 0PTP03-FP-0105, and discussions with licensee personnel, the team determined that the licensee had not conducted full flow testing of the underground portions of the main fire protection piping loop that supplied the diesel generator buildings in each unit since the original startup tests in 1986. Consequently, the failure to demonstrate the adequacy and reliability of the water flow supplied to the diesel generator buildings was a performance deficiency. The licensee documented the failure to properly perform flow testing in Condition Report 14-17098.

Analysis.

The failure to conduct flow testing of the entire underground fire protection piping loop was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors attribute (fire) and adversely affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to performance test the underground fire protection piping loops supplying the emergency diesel generator buildings for both units did not demonstrate the continued capability to deliver adequate flow and pressure to the fire suppression systems supplying those buildings.

The team evaluated the finding using Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," because it affected fire protection defense-in-depth strategies involving fire water supply. Using Appendix F, the team determined that the finding screened to very low safety significance. Specifically, the finding did not prevent the reactor from achieving safe shutdown since only one safe shutdown train would be affected at a time. Since these underground fire protection piping loops had not been flow tested since initial installation and nothing caused the licensee to reevaluate the test, the team determined that this failure did not reflect current performance.

Enforcement.

Technical Specification 6.8.1.d specifies that written procedures shall be established, implemented, and maintained for Fire Protection Program implementation. Procedure 0PGP03-ZF-0018, "Fire Protection System Functionality Requirements," Revision 17, Step 4.2.3.7 specified the licensee will perform system flow testing at least every 3 years in accordance with Chapter 8, Section 17 of the Fire Protection Handbook, 17th Edition, which specifies testing of the system to ensure water is available and within limits of the firemain distribution model. Contrary to the above, since original testing in 1986, the licensee failed to implement and maintain the Procedure 0PTP03-FP-0105, "Fire Protection Flow Test," for the flow test for the underground fire protection piping loop by testing all portions of the piping. Specifically, the licensee failed to flow test portions of the underground fire protection piping that serviced the diesel generator buildings. The licensee initiated actions to perform flow testing on that portion of the system. Because this violation was of very low safety significance and has been entered into the corrective action program as Condition Report 14-17098, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000498;05000499/2014008-01, "Inadequate Loop Flow Test."

.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 updated 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. The team conducted plant walk downs 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 onsite at all times, exclusive of those assigned as fire brigade members.

The team performed a timed walk down of the alternative shutdown procedure for Unit 1 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 and local 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

No findings were identified.

.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 team's evaluation focused on the cables of selected components from the auxiliary feedwater, chemical volume and control, essential service water, main steam atmospheric vent, and main steam isolation systems. 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 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 walk down 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

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team verified that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs. Using these procedures, the team evaluated whether these components could be repaired in time to bring the plant to cold shutdown within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools, and materials needed for the repairs were available and accessible on site.

b. Findings

This licensee does not implement any cold shutdown repairs.

.10 Compensatory Measures

a. Inspection Scope

The team verified that compensatory measures were implemented for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment; passive fire barriers; or pumps, valves, or electrical devices providing safe shutdown functions). The team also verified that the short-term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.

The team reviewed operator manual actions credited for achieving hot shutdown for fires that do not require an alternative shutdown. The team verified that operators could reasonably be expected to perform the actions within the applicable shutdown time requirements. The team reviewed these operator manual actions using the guidance contained in NUREG-1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," dated October 2007.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The team reviewed changes to the approved fire protection program. The team verified that the changes did not constitute an adverse effect on the ability to safely shutdown.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the licensee's approved fire protection program, implementing procedures, and programs for the control of ignition sources and transient combustibles. The team assessed the licensee's effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The team performed plant walk downs to independently verify that transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.

b. Findings

No findings were identified.

.13 Alternative Mitigation Strategy Inspection Activities

a. Inspection Scope

The team reviewed the licensee's implementation of guidance and strategies intended to maintain or restore core, containment, and spent fuel pool cooling capabilities under the circumstances associated with the potential loss of large areas of the plant due to explosions or fire as required by 10 CFR 50.54(hh)(2). The team verified that the licensee maintained and implemented adequate procedures, maintained and tested equipment necessary to properly implement the strategies, and ensured station personnel were knowledgeable and capable of implementing the procedures. The team performed a visual inspection of portable equipment used to implement the strategy to ensure the availability and material readiness of the equipment, including the adequacy of portable pump trailer hitch attachments, and verify the availability of on-site vehicles capable of towing the portable pump. The team assessed the off-site ability to obtain fuel for the portable pump and foam used for firefighting efforts. The strategy and procedure selected for this inspection sample included Procedure 0POP10-ZO-EDMG, "Extensive Damage Mitigation Guideline," Revision 4.

One mitigating strategy sample was completed.

b. Findings

No findings were identified.

OTHER ACTIVITIES

[OA]

4OA2 Identification and Resolution of Problems

Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team selected a sample of condition reports associated with the licensee's fire protection program to verify that the licensee had an appropriate threshold for identifying deficiencies. The team reviewed the corrective actions proposed and implemented to verify that they were effective in correcting identified deficiencies. The team evaluated the quality of recent engineering evaluations through a review of condition reports, calculations, and other documents during the inspection. The team also reviewed a sample of condition reports that were generated as a result of the last triennial fire protection inspection.

b. Findings

No findings were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Discussed) Violation 05000498; 05000499/2012007-01:

Failure to Timely Correct Conditions Adverse to Fire Protection During the 2005 triennial fire protection inspection, the team identified a concern with the assumptions used in the thermal hydraulic analysis that determined the time available for operators to perform time critical actions during an alternative shutdown. This issue was closed as a non-cited violation in 2006. In response to this violation, the licensee submitted a license amendment request in 2008 to request approval to credit the actions performed in the control room prior to evacuation during an alternative shutdown. The licensee subsequently withdrew this request in 2008.

The licensee resubmitted the license amendment request in 2011. During the 2011 triennial fire protection inspection, the team documented a non-cited violation (NCV 05000498;05000499/2011006-01) of License Condition 2.E for the failure to implement timely corrective actions for this issue. The licensee subsequently withdrew this request in 2011. During the 2012 problem identification and resolution inspection, the team issued a cited violation (05000498;05000499/2012007-01) of License Condition 2.E for this issue. As corrective action for this violation, the licensee submitted a third license amendment request in 2013. During the current inspection, the team identified one additional example of a control room fire scenario where the backup actions performed in the plant may not be performed within the allowable time. This scenario involved a single spurious actuation that disabled thermal barrier cooling to the running reactor coolant pumps followed by operator actions to secure the centrifugal charging pumps and terminate seal injection. The team was concerned that the operator action to trip the reactor coolant pumps may occur too late after the charging pumps were secured. The team noted that the license amendment request, if approved, would resolve this scenario because the licensee would be able to credit the action to trip the reactor coolant pumps in the control room prior to evacuation. The team determined that this issue was a violation of License Condition 2.E. This violation constitutes an additional example of non-cited Violation 05000498;05000499/2011006-01, and is not being cited individually. Corrective actions for this additional example are expected to be taken in conjunction with corrective actions for Violations 05000498;05000499/2011006-01 and 05000498;05000499/2012007-01. During the current inspection, the team reviewed the license amendment request and the compensatory measures the licensee implemented during the review process for the license amendment request. The team performed a timed walk down of the alternative shutdown procedure and verified that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits, assuming the license amendment request was approved. Since the third license amendment request was in the review process, the team could not close the 2012 violation.

.2 (Closed) Licensee Event Report (LER) 05000498; 499/2013-003-00:

Unanalyzed Condition - Direct Current Ammeter Circuits without Overcurrent Protection This licensee event report documented that the licensee had installed non-safety-related ammeters on the main control board without circuit protection. Because of the lack of circuit protection, a fire affecting a non-safety-related circuit could create a secondary fire in another area of the plant. The licensee had confirmed safety-related circuits were properly protected and required no modifications.

The team performed a detailed review of the information related to this deficiency. The team reviewed drawings, design documents, and discussed the event with plant personnel to gain an understanding of the actions taken to address the deficiency. The team verified that the licensee established appropriate compensatory measures and corrective actions. The licensee documented this deficiency in their corrective action program as Condition Report 13-11633 and initiated actions to review the applicable circuits. The licensee determined that seven non-safety-related circuits had insufficient electrical circuit protection. As compensatory measures, the licensee established roving fire watches in the fire areas where they had routed the circuits.

The team reviewed the circuit modifications completed in Unit 1 and verified that they corrected the deficiency.

The licensee continued to implement roving fire watches in Unit 2 until they complete the modifications, which were scheduled for April 2015. The team discussed the enforcement related to this deficiency in Section 4OA7.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the inspection results to Dennis L. Koehl, President and Chief Executive Officer, and other members of the licensee staff at an exit meeting on September 25, 2014. The licensee acknowledged the findings presented.

The team verified that they retained no proprietary information or documented in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements that meets the criteria of Section 2.3.2.a of the NRC Enforcement Policy for being dispositioned as a non-cited violation.

Unanalyzed Condition - Direct Current Ammeter Circuits without Overcurrent Protection On October 31, 2013, Licensee Event Report 05000498; 05000499/2013-003 described an unanalyzed condition wherein a fire in non-safety-related control room instruments could cause a secondary fire because of a lack of circuit protection. License Condition 2.E specifies, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment No. 55 and the Fire Hazards Analysis Report through Amendment No. 7. Section 1.5.2 of the Fire Hazards Analysis Report states that "only one fire originating from a single source is assumed to occur at a time." Contrary to the above, since initial construction, the licensee failed to implement the fire protection program that ensured that only one fire originating from a single source will occur at one time. Specifically, the licensee failed to ensure that direct current ammeter circuits were properly protected to prevent secondary fires from initiating in other areas of the plant during a control room fire event. The performance deficiency was more than minor because, if left uncorrected, it could have become a more risk significant fire concern. Since this involved a control room fire, a senior reactor analyst performed a detailed risk evaluation that concluded the fire had very low risk significance. The licensee documented this issue in their corrective action program as Condition Report 13-11633. This violation is also discussed in Section 4OA3.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Berg, Manager, Design Engineering - Test and Programs

R. Butler, Operations Support

F. Cox, Safe Shutdown Design Engineer

D. Dayton, Systems Engineer, Emergency Lighting

T. Frahm, Manager, Unit 1 Operations

C. Georgeson, Supervisor, Electrical Design Engineering

R. Gonzales, Senior Licensing Engineer

R. Lacey, Electrical Design Engineer

M. Murray, Manager, Regulatory Affairs

S. Rosales, Electrical Design Engineer

R. Savage, Engineering Specialist

G. Schinzel, Design Engineer

D. Shook, Fire Marshall

D. Wiegand, Fire Protection Systems Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000498;

05000499/2014008-01 NCV Inadequate Loop Flow Test

Closed

05000498;

05000499/LER-2013-003-00 LER Unanalyzed Condition - Direct Current Ammeter Circuits without Overcurrent Protection

Discussed

05000498;

05000499/2011006-01 NCV Failure to Timely Correct Conditions Adverse to Fire Protection

LIST OF DOCUMENTS REVIEWED

Cable Routing Data Components

A1CVMOV0218 A1RCMOV0001A A1RCPCV0655A B1RCPCV0656A B1RCMOV0001B 3R171NPA103A 3R171NPA103B

Calculations

Number Title Revision

EC-5025, Sheet 105A Protection of Elect Penetration Conductors 9

EC-5033 Protection Non 1E 48 VDC, 125 VDC & 250 VDC and Class 1E 125 VDC Systems 6

EC-5053 Protective Device Study for Appendix R 6

MC 6023 Appendix R Evaluation 13

MC 6285 Single Fire Pump Operation and Available Pressure 0

NC-7079 Fire Hazards Analysis 5

STI 117211 Fire Hazards Analysis Report 0

Condition Reports

(CR-)

9-5872 9-11392 10-9935 10-9943 10-9950 10-9955 10-10033-2 10-23260 11-2003 11-10791 12-19430 12-19431 12-19637 12-19651 12-19695 12-20312 12-26399 12-28283 12-30292 12-31692 13-557 13-985 13-1672 13-2239 13-3279 13-3283 13-3767 13-4494 13-5006 13-8261 13-11633 14-716 14-3245 14-3298 14-4791 14-5330 14-8139 14-9132 14-15511* 14-16092* 14-16120* 14-16137* 14-16202* 14-16220* 14-16243* 14-16603* 14-16998* 14-17091* 14-17098* 14-17100* 14-17147* 14-17185* 14-17198* 14-17202* 14-17206* 14-17219* 14-17270* 14-17322* 14-17331* 14-17332*

• Issued as a result of inspection activities.

Drawings

Number Title Revision 00009E0CV11 #1

CVCS-Boric Acid Make Up Isol.

MOV-0218 12

Drawings

Number Title Revision 00009E0CV27 #1 Boric Acid Transfer Pumps 1A & 1B PA103A & PA103B 10 00009E0DCAA #1 250V DC Power Dist. Switchboard 1A 13 00009E0DEAA #1 48V DC Power Distribution Swbd PL048A (EAB) 13 00009E0DG01 #1 Standby Diesel Generator DG11 4.16KV Feeder Breaker 20 00009E0DG04 #1 Standby DG No. 11 Emergency Control and Instrumentation 18 00009E0DJAA #1 125VDC Class 1E Distribution Swbd E1A11 (Channel I) (E.A.B.) 19 00009E0DJAB #1 125VDC Class 1E Distribution Swbd E1D11 (Channel II)

(E.A.B.) 22 00009E0DJAC #1 125VDC Class 1E Distribution Swbd E1B11 (Channel III) (E.A.B.) 20 00009E0DJAD #1 125VDC Class 1E Distribution Swbd E1C11 (Channel IV) (E.A.B.) 17 00009E0HC21 #1 CRDM Vent Fans FN017, 018, & 019 15 00009E0HE13 #1 E.A.B. HVAC Return Air Fans FN001, FN002, & FN003 13 00009E0LT07 #1 Turbine Lube Oil DC Emergency Oil Pump PA004 14 00009E0LT07 #1 Turbine Lube Oil DC Emergency Oil Pump PA004 14 00009E0PLAA #1 480V Class-1E Load Center E1A (EAB) 17 00009E0PM02 #1 MCC 1A5, 1B5, 1C5 Feeder Breaker Shunt Trip Control 7 00009E0RC05 #1 Reactor Coolant Pressurizer Relief Block Valve MOV0001A & MOV0001B 17 5R179F05007 #1 Chemical and Volume Control System 51

Drawings

Number Title Revision 5R179F05009 #1 Chemical and Volume Control System 28 7D149M24531 #1 Diesel Generator Building Plan at El. 25'0" & 55'0" 6 7D149M24532 #1 Electrical Auxiliary Building Section A-A 5 7M149M24515 Mechanical & Electrical Auxiliary Building Plan at El. 35'0", 41'0" & 51'6" 19 7M149M24516 #1 Mechanical & Electrical Auxiliary Building Plan at El. 60'0" 11 7M149M24520 #1 Electrical Auxiliary Building Section A-A

4 7Q270F00006 Piping and Instrumentation Diagram (P&ID) Fire Protection - Storage and Pumps 21 7Q270P0104 Fire Protection Loop Yard Plan - Area 57 12 7Q270P0105 Fire Protection Loop Yard Plan - Area 58 13 7Q270P0106 Fire Protection Loop Yard Plan - Area 59 10 7Q270P0107 Fire Protection Loop Yard Plan - Area 60 9 7Q270P0108 Fire Protection Loop Yard Plan - Area 61 8 7Q270P0109 Fire Protection Loop Yard Plan - Area 62 13 7Q271F00046 P&ID Fire Protection Loop - Unit 1 39 7Q272F00046 P&ID Fire Protection Loop - Unit 2 41 7Q271F05064 Fire Protection - Deluge and Flow Alarm Trim Valves 5 7Q279F05049#1 Fire Protection - Deluge Valve House No. 11 16 7Q279F05053#1 Fire Protection - Mechanical Electrical Auxiliary Building 26 7Q279F05056#1 Fire Protection - Mechanical Electrical Auxiliary Building and Admin Building (Halon) 13 9EDC10-01 #1 Master Cable Block Diagram 250V DC Power Distr Switchboard and Battery Charges 6 9EDE10-01 #1 Master Cable Block Diagram 48V DC Distr Swgr & Battery Chargers 8 9EHC23-01 #1 Reactor Cavity Vent Fans FN023 & FN024 9 9EPKAA-01 #1 4.16KV Class-1E Switchgear 12 9E220E2050 Station Cathodic Protection General Arrangement 10

Drawings

Number Title Revision 9E220E2051 Station Composite Yard Piping Cathodic Protection Plan 5 9E220E2052 Station Composite Yard Piping Cathodic Protection Plan 7 9E220E2053 Station Composite Yard Piping Cathodic Protection Plan 12 9E220E2054 Station Composite Yard Piping Cathodic Protection Plan 7 9E220E2055 Station Composite Yard Piping Cathodic Protection Plan 9 9E220E2056 Station Composite Yard Piping Cathodic Protection Plan 12 9-E-56-9-E-03608 Electrical - Mechanical Auxiliary Building, Lighting and Communication Plan, Elevation 29'-0" 12 9-E-56-9-E-03617 Electrical - Mechanical Auxiliary Building, Lighting and Communication Plan, Elevation 41'-0" 30 9-E-56-9-E-50003 Electrical - Electrical Auxiliary Building, Communications Plan, Elevation 35'-0" 11 9-E-56-9-E-50005 Electrical - Electrical Auxiliary Building, Communications Plan, Elevation 35'-0" 10 9W-01-9-E-59762 Lossy Loop Radio System, Mechanical Electrical Auxiliary Building Plan, Elevation 35'-0" Area J 1 9Y280Y36087 Civil - Protected Area Vehicle Barrier System 3 14296-0295(1)-00007-GSP Diesel Generator Building Standpipe - Plan View Elevations 25'-0" & 55'0" 6 14296-0295(1)-00008-HSP South Texas Project - Diesel Generator Building, Pre-action Systems 1, 2, & 3; Foam-water Systems 1, 2 & 3 7 14296-0295(1)-00052-JSP South Texas Project - Deluge Valve House No. 11 11 14296-0295(1)-00064-HSP South Texas Project - Fuel Handling Building & Mechanical Electrical Auxiliary Building Carbon Filters (Deluge) Unit 1 0 14296-0295(1)-00080-ESP South Texas Project Mechanical Auxiliary Building Fire Area 3:

Zones #130 & #147 6 14296-0295(1)-00090-ESP South Texas Project Electrical Auxiliary Building Fire Area 31:

Zone #47 5 14296-0295(1)-00137-CSP South Texas Project, Unit 1, Carbon Filters (Deluge) 2 14296-0295(1)-00170-Alarm Valve Trim, Variable Pressure, Models 253 & 353 5

Drawings

Number Title Revision

ASP 14296-0295(1)-00172-ASP South Texas Project, Units 1 & 2, Grinnell Model A-4 Multimatic Valve Trimming Details 0 14296-0295(1)-00173-BSP South Texas Project, Unit 1, Grinnell Valve Trim Detail 0 14926-4148-01002-B 48VDC Switchboard 0

PW-N10071-721 Wiring Details Transfer Switch Panel

ZLP-653 0

PW-N10071-723 Terminal Block Arrangement Transfer Switch Panel

ZLP-653 5 R107D-1109651-G Filter House Assembly Control Room HVAC Clean-up Unit 0

Penetration Seal Repairs

7M1-E-F05006 7M1-E-F05018 7M1-E-W08461 7M1-E-W10138 7M1-N-W13073

Licensing Documents

Number Title Revision/Date

Fire Hazards Analysis Report

Proof and Review of Standard Technical Specifications (STS) for Westinghouse Pressurized Water Reactors,

NUREG-0452, Revision 5 July 8, 1989

Updated Final Safety Analysis Report, Sections 7.4, 7.5.6, 9.5.1, 13.2 and 13.7

Letter

NOC-AE-07002114 Response Providing Information Regarding Implementation Details for the Phase 2 and 3 Mitigation Strategies February 22, 2007 Letter

ST-HL-AE-1867 South Texas Project, Unit 1, Draft Revision 1 Technical Specifications (Tech Specs) January 7, 1987 Letter

ST-HL-AE-2007 Revised FSAR Sections Related to Fire Protection March 26, 1987

NUREG-0781 Safety Evaluation Report Related to the Operation of South Texas Project, Units 1 and 2

NUREG-0781, Supplement 3 Safety Evaluation Report Related To The Operation of South Texas Project, Units 1 and 2, Supplement 3

Miscellaneous Documents

Number Title Revision/Date

Final Report - Fire Protections Systems Completed Test Procedure Review January 2000

Fire brigade leader, fire brigade member, and fire brigade systems qualified fire brigade members

Fire Protection Handbook, Seventeenth Edition, Chapter 8, "Test of Water Supplies"

List of fire brigade qualified operators on each shift

MAPPRO site fire protection piping layouts for South Texas Project that included cathodic protection cell measurements and rectifier placements

Preventive Maintenance Task

96000929

Selected fire impairments

Selected transient fire permits

Underground Piping Program Health Report

340301628 STP Plant Piping, River Pipeline, Water Intake Cathodic Protection System Survey Report 0

420819 FO Technical Services Department Laboratory Report January 15, 2013

602356 FO Technical Services Department Laboratory Report December 4, 2013

DCP 12-24061-3 Unit 1 and 2 Cathodic Protection System Upgrade 0

DCP 12-28283-14 Revise Drawing for Penetration Seal Detail E1 0

DCP 13-12309-8 Installation of Cable Protection Fuses on Non-1E 48V and 250 VDC Systems 0 51-9094209-002 Timeline and Manual Action Feasibility Report for South Texas Project 2 Form 6 of 0PAP01-ZA-0102, Rev 9 Training Identification for Rev 0 to 0POP10-ZO-EDMG, Rev 3 December 12, 2007 Form 6 of

0PAP01-ZA-0102, Rev 10 Training Identification for Rev 1 to 0POP10-ZO-EDMG, Rev 3 October 23, 2008 Form 6 of

0PAP01-ZA-0102, Rev 10 Training Identification for Rev 2 to 0POP10-ZO-EDMG, Rev 3 October 5, 2010

Licensing Documents

Number Title Revision/Date Form 6 of 0PAP01-ZA-0102, Rev 11 Training Identification for Rev 3 to 0POP10-ZO-EDMG, Rev 3 January 18, 2011 Form 1 of

0PAP01-ZA-0103, Rev 11 License Compliance Review Form for 0POP10-FC-0001, Rev 5 September 2, 2011 Form 6 of 0PAP01-ZA-0102, Rev 12 Training Identification for Rev 4 to 0POP10-ZO-EDMG, Rev 4 September 15, 2011 Form 1 of 0PGP05-ZN-0002, Rev 5 Commitment Evaluation Form for CR Action Number 07-457-75 September 14, 2011 Form 1 of 0PAP01-ZA-0102, Rev 12 Procedure Approval for 0POP10-FC-0001, Spent Fuel Pool Damage Mitigation Strategies, Rev 5 October 18, 2011 Form 6 of

0PAP01-ZA-0102, Rev 12 Training Identification for Rev 5 to 0POP10-FC-0001 October 18, 2011

LTR-RAM-I-10-053 White Paper Westinghouse Reactor Coolant Pump Seal Behavior for Fire Scenarios 2 Setpoint Index Record Pressure Relief Isol

MOV-0001A September 10, 2014 Setpoint Index Record Pressure Relief Isol

MOV-0001B September 10, 2014 Setpoint Index Record Boric Acid Transfer Pump 1A September 2, 2014 Setpoint Index Record Boric Acid Transfer Pump 1B September 2, 2014 USQE 00-1187-1 Changes to 0PGP03-ZF-0018, Revision 10 0

Penetration Seal Configuration Drawings

Number Title Revision

NP 59-01 Detail "E-2" Self Supporting High Density Gel - Typical Electrical Pen Seals (Walls & Floors) 5

NP 59-03 Detail "E-17" Hydrosil

TS-102C - Typical Electrical Pen Seals (Walls & Floors) 5

NP 59-08 Detail "M-3A" Self Supporting High Density Gel - Typical Mechanical Pen Seals (Wall or Floor) 6

NP 59-17 Detail "M-1B" Silicone Elastomer - Typical Mechanical Pen Seals (Walls & Floors) 0

NP 59-19 Detail "E-1" Silicone Elastomer - Typical Electrical Pen Seals (Walls & Floors) G

NP 59-23 Detail "M-1A" Silicone Elastomer - Typical Mechanical Pen Seals (Walls & Floors) E

NP 59-29 Detail "M-22A" Promoflex - Typical Mechanical Pen Seals (Walls & Floors) 3

NP 59-30 Detail "M-22B" Promoflex - Typical Mechanical Pen Seals (Walls & Floors) 1

NP 59-31 Detail "E-26" Conduit End Caps (Wall or Floor) 2

Procedures

Number Title Revision

FBT-G001 Fire Brigade Training Guideline 3

MEG-0101 Penetration Seals Attachment

MEG-0101-02, Seal Types and Criteria 1 0EAB03-FP-0039 Fire Preplan Electrical Auxiliary Building Control Room HVAC Equipment Room, Train B 4 0ERP01-ZV-IN01, Addendum 1 Emergency Classification, Fire/Explosion 9 0PAP01-ZA-0101 Plant Procedure Writer's Guide 6 0PAP01-ZA-0102 Plant Procedures 12 0PGP03-ZA-0514 Controlled System or Barrier Impairment 12 0PGP03-ZF-0001 Fire Protection Program 27 0PGP03-ZF-0011 STPEGS Fire Brigade 12

- 10 - Attachment Procedures

Number Title Revision 0PGP03-ZF-0001 Fire Protection Program 27 0PGP03-ZF-0014 Fire Prevention Surveys 13 0PGP03-ZF-0018 Fire Protection System Functionality Requirements 17 0PGP03-ZF-0019

Control of Transient Fire Loads and Use of Combustible and Flammable Liquids and Gases 11 0PGP03-ZO-0043 Fuel Oil Monitoring Program 9 0PGP03-ZT-0131 Fire Protection Training and Qualification Program 9 0PMP04-FP-0006 Fire Damper Visual Inspection 5 0POP01-ZA-0001 Plant Operations Department Administrative Guidelines 43 0POP04-ZO-0001 Control Room Evacuation 35 & 36 0POP04-ZO-0008 Fire/Explosion 23 0POP04-ZO-0009 Safe Shutdown Fire Response 12 0POP05-EO-ES12 Post LOCA Cooldown and Depressurization, Addendum 3, SG PORV 17 0POP10-FC-0001 Spent Fuel Pool Damage Mitigation Strategies 3 0POP10-FP-0001 Alternate Fire Protection System Operation 4 0POP10-ZO-EDMG Extensive Damage Mitigation Guideline 4 0PTP03-FP-0014 Hose House Rerack and Inspection 5 0PTP03-FP-0018 Fire Pump Controller Functional Test 8 0PTP03-FP-0020 Portable Fire Extinguishers 8 0PTP03-FP-0028 Hose House Visual Inspection 4 0PTP03-FP-0101 Fire Protection Systems Valve Position Verification 11 0PTP03-FP-0103 Fire Protection System Flush 8 0PTP03-FP-0105 Fire Protection System Flow Test 8 0PTP03-FP-0106 Fire Protection Water System Functional Test 13 0PTP03-FP-0107 Halon Cylinder Weight Verification 15 0PTP03-FP-0108 Halon System Automatic Actuation Verification 8 0PTP03-FP-0109 Sprinkler/Spray System Visual Inspection 3

- 11 - Attachment Procedures

Number Title Revision 0PTP03-FP-0110 Deluge Water Spray System Air Flow Test 13 0PTP03-FP-0111 Deluge Water Spray/Automatic Sprinkler Valve Actuation Verification and Valve Reset 9 0PTP03-FP-0117 Hose Station Visual Inspection 6 0PTP03-FP-0118 Hose Station Hose Visual Inspection 1 0PTP03-FP-0119 Fire Hose Station Valves Functional Test 6 0PTP03-FP-0120 Fire Hose Hydrostatic Test 9 0PTP03-FP-0123 Fire Barrier Penetration Seal Visual Examination 10 0PTP03-FP-0125 Fire Rated Assembly Visual Examination 9 0PTP03-FP-0126 Fire Door Visual Examination 18 0PTP03-FP-0127 Fire Door Hold Open and Release Mechanisms Functionality Check 20 0PTP03-FP-0129 Fire Door Supervision System Functional Check 4 0PSP03-ZG-0005 Remote Shutdown System Operability Test (Cold Shutdown) 15

ZFG-0001 Fire Watch Program Guideline 10

Standards

Number Title Date

NFPA-11 Foam Extinguishing Systems 1978

NFPA-25 Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems 2014

NFPA-291 Recommended Practice for Fire Flow Testing and Marking of Hydrants 2013

Suppression System Calculations

Number Title Revision H578.A01 South Texas Project Diesel Generator Building Pre-Action System (Unit 1) 0 H578.B01 South Texas Project Diesel Generator Building Foam-Water System (Unit 1) 0

- 12 - Attachment Suppression System Calculations

Number Title Revision H578.F01 South Texas Project Electrical Auxiliary - System #2 (Carbon Filters) 0 H578.W01 South Texas Project Mechanical Auxiliary Building

0

Surveillance Test Work Authorization Numbers (WAN)

343875

344483

344484

360144

374940

374944

386879

392823

396613

396967

398558

401055

403262

403666

404131

404133

406291

406299

409179

409181

413289

413290

414217

415142

415409

419059

419640

421172

421955

422352

422368

422750

423077

423098

423609

424083

424757

425108

425119

425452

426231

426589

428835

430747

431102

433673

433683

434289

436953

437052

438487

441144

441494

441497

441576

441998

442350

442496

443031

443359

443717

443728

448343

448627

448628

448629

450051

450060

453423

456822

457026

458155

458172

458797

459398

459799

460030

460032

461745

462346

464330

464339

464341

479880

479885

479886

480060

480065

480643

481292

481301

481302

481673

481974

481977

VENDOR DOCUMENTS

Number Title Revision

VTD-W120-0202 AB

DE-ION Circuit Breakers 0

VTD-W120-0220 K-Frame Molded Case Circuit Breakers 0

Work Authorization Numbers (WAN)

394343

410521

410524

471736

471737

472481

473835

474293

541146 541147