IR 05000424/2021012

Triennial Fire Protection Inspection Report 05000424/2021012 and 05000425/2021012

ML21253A142
Person / Time
Site:	Vogtle
Issue date:	09/10/2021
From:	Scott Shaeffer NRC/RGN-II
To:	Gayheart C Southern Nuclear Operating Co
References
IR 2021012
Download: ML21253A142 (9)

Text

September 10, 2021

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000424/2021012 AND 05000425/2021012

Dear Ms. Gayheart :

On July 29, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Vogtle Electric Generating Plant. On July 29, 2021, the NRC inspectors discussed the results of this inspection with Mr. Jesse Thomas, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Vogtle Electric Generating Plant.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholdin

Sincerely,

/RA/

Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety

C. Gayheart 2 Docket Nos. 05000424 and 05000425 License Nos. NPF-68 and NPF-81

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000424 and 05000425 License Numbers: NPF-68 and NPF-81 Report Numbers: 05000424/2021012 and 05000425/2021012 Enterprise Identifier: I-2021-012-0031 Licensee: Southern Nuclear Operating Co.

Facility: Vogtle Electric Generating Plant Location: Waynesboro, GA Inspection Dates: July 12, 2021 to July 29, 2021 Inspectors: P. Braaten, Senior Reactor Inspector L. Jones, Senior Reactor Inspector W. Monk, Senior Reactor Inspector M. Singletary, Reactor Inspector, Team Lead Approved By: Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Vogtle Electric Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71111.21N.0

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)

The inspectors verified that the following systems credited in the approved fire protection program could perform their licensing basis function:

(1) Unit 1 Chemical Volume Control System

(2) Unit 2 Nuclear Service Cooling Water

(3) 1-CB-LA-K, Fire Zone 95 water fire suppression pre-action sprinkler system

(4) 1-CB-LA-L, Fire Zone 98 gaseous fire suppression system halon system

Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)

The inspectors verified that the following fire protection program administrative controls were implemented in accordance with the current licensing basis:

(1) Combustible Control Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors reviewed the following changes to ensure that they did not constitute an adverse effect on the ability to safely shutdown post-fire and to verify that fire protection program documents and procedures affected by the changes were updated.

(1) Surveillance Frequency Extensions

(2) Penetration Seal Inspection Frequency

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.21N.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: A green Licensee Identified Violation of Vogtle Unit 1&2 Operating License Condition 2.G was identified for the licensee's failure to implement corrective actions adequately as required by the approved fire protection program. Specifically, Procedure NMP-ES-035, Fire Protection Program, Version 6.1 Section 3.20, states:

Ensure that fire-protection-related problems (for example, condition reports) are sufficiently evaluated and that appropriate, timely corrective actions are implemented.

Contrary to above during a self-assessment review of the fire protection review the licensee identified two instances where appropriate corrective actions were not taken. In both instances the condition reports (CRs) were assigned to the Long-Term Asset Management process and subsequently dropped without the corrective actions being completed. CR 562463 was identified as a failure to address 16 unfused Class 1E battery ammeter cables and CR 699204 was written to address a non-compliance with NFPA 14- 1983s hose station requirements. The licensee wrote two new CRs to reevaluate and address the missed actions, CR 10790361 and CR 10790449.

Significance/Severity: Green. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 screening check was required. The issue was determined to be of very low significance, GREEN, based on answering Yes to Step 1.3, Does the fire finding have a low degradation rating?

Corrective Action References: CR 10790361, CR

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 29, 2021, the inspectors presented the triennial fire protection inspection results to Mr. Jesse Thomas and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Calculations 1380-0005-MD- Evaluation of MOV Pressure Boundaries and Operator Rev. 0

Manual Actuation Capabilities for IN92-18 Hot-Short

Events

X4C2301S310 VEGP SSEL and Safe Shutdown Fault Tree Ver. 5.0

X4C2301S311 VEGP Multiple Spurious Operations Analysis Ver. 4.0

X4C2301S311 - 92-18 MOV Evaluation Ver. 2

F

X4C2301S316 Post Fire Safe Shutdown Compliance Strategy Ver. 4.0

X4G2301S317 Post Fire Safe Shutdown Manual Action Feasibility Study Rev. 5

Calibration CR 10705004 Fire Protection Screening 4/24/2020

Records

Corrective Action CR 10705024 FP NRC FASA PMCR 4/24/2021

Documents CR 10705341 Procedure change to 29101-C 4/27/2020

CR 10705350 Target NET Pressures Don't Match Pump Curve 4/27/2020

CR 10705358 PMCR was not complete before closure 4/27/2020

CR 10705360 Table 9.5.1-10 contains duplicated information 04/27/2020

CR 10705545 2020 FP NRC FASA - Objective 1 - Non-compliances 04/28/2020

with NFPA72E-1978 Code of Record

CR 10706347 2020 FP NRC FASA - Objective 4 -NMP-ES-035-014 05/01/2020

does not align with Fire Hazards Analysis

CR 10706693 2020 FP NRC FASA - Objective 1 & 2 - FSAR 05/04/2020

Requirements for Door Checks Deficiency

CR 10707319 2020 FP NRC FASA - Objective 3 - VEGP 1-2 SSD 05/06/2020

Calculations Enhancements

CR 10755274 Wood found Ceiling Level Unit 1 CB Level A Room 45 11/20/2020

CR 10790361 FP NRC CISA 2021 - Untimely Corrective Actions 04/14/2021

Related to Unfused Battery Ammeter Cables

CR 10790362 FP NRC CISA 2021 - Missed Secondary Fire Zone in Fire 04/14/2021

Pre-Plan 92805-1

Corrective Action CR 10812501 2021 NRC Fire Protection Inspection - Treated Wood in 7/13/2021

Documents A44

Resulting from CR 10816136 RSDP Label Discrepancy 7/28/21

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection

Drawings 1X4DB111 Chemical and Volume Control System No. 1204 Version 30.0

2X4DB133-2 P&ID Nuclear Service Cooling Water System No. 1202 Version 57.0

2X4DB174-1 P&ID Fire Protection Halon Systems No. 2302 & 2304 Version 4.0

Engineering TE 1066463 Fire Protection FSAR Administration Changes Version 1.0

Evaluations TE 614917 Fire Protection Action Plan 03/29/2013

Miscellaneous Remote Shutdown Equipment Rev. 1.1

219-RPT-01 JH NFPA 72 CODE COMPLIANCE EVALUATIONS Plant 12/21/2020

Vogtle Units 1 & 2

LTAM V-14-0104 Wet Pipe Sprinkler System Overpressure Protection 11/13/2014

LTAM V-17-0098 Battery Ammeter Cable Fuses for Secondary Fires 8/17/2017

VEGP-FSAR-9A 9A-2-1 FHA Unit 2 Rev. 20

VEGP-FSAR-9A 9A-1-1 FHA Unit 1 Rev. 19

Procedures 17103A-C Annunciator Response Procedure for Fire Alarm Ver. 44

Computer

18038-1 Operation from Remote Shutdown Panels Ver. 35.1

18038-2 Operation from Remote Shutdown Panels Ver. 28.2

1X6AZ02-00115 INSTRUCTION MANUAL FOR ALTERNATE Ver. 7.0

SHUTDOWN INDICATION SYSTEM

2025-C FIRE PROTECTION SURVEILLANCE PROGRAM Ver. 19.5

NMP-ES-035 Fire Protection Program Ver. 7.0

NMP-ES-035-006 Fire Protection Program Impact Screen and Detailed Ver. 13

Reviews

NMP-ES-035-014 Fleet Transient Combustible Controls Version 5.0

NMP-ES-035-015 Performance Based Evaluations for Fire Protection Ver. 4.0

Surveillances

NMP-ES-035-016 Fleet Fire Barrier and Penetration Seal Program Ver. 3

Work Orders 29143-C Fire Dampers - 18 Month Visual Inspection 03/25/2010

SNC974290 12 Month Fire Suppression System - Annual System Ver. 0

Pump Test

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