ML18330A172
| ML18330A172 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/26/2018 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Hamilton D FirstEnergy Nuclear Operating Co |
| References | |
| IR 2018011 | |
| Download: ML18330A172 (16) | |
See also: IR 05000440/2018011
Text
November 26, 2018
Mr. David B. Hamilton
Site Vice President
FirstEnergy Nuclear Operating Company
Perry Nuclear Power Plant
Reg Affairs-A210
10 Center Road, P.O. Box 97
Perry, OH 44081-0097
SUBJECT: PERRY NUCLEAR POWER PLANTNRC TRIENNIAL FIRE PROTECTION
INSPECTION REPORT 05000440/2018011
Dear Mr. Hamilton:
On October 18, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial
Fire Protection Inspection at your Perry Nuclear Power Plant. The NRC inspectors discussed
the results of this inspection with Mr. D. Reeves and other members of your staff. The results
of this inspection are documented in the enclosed report.
Based on the results of this inspection, the NRC has identified three issues that were
evaluated under the risk significance determination process as having very-low safety
significance (green). The NRC has also determined that three violations were associated with
these issues. Because the licensee initiated condition reports to address these issues, these
violations are being treated as Non-Cited Violations (NCVs), consistent with Section 2.3.2 of the
Enforcement Policy. These NCVs are described in the subject inspection report.
If you contest the violations or significance of these NCVs, 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 III; the Director, Office of Enforcement; and the
NRC Resident Inspector at the Perry Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement 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 U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region III; and the NRC Resident Inspector at Perry Nuclear Power
Plant.
D. Hamilton -2-
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, Part 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure:
Inspection Report 05000440/2018011
cc: Distribution via LISTSERV
D. Hamilton -3-
Letter to David B. Hamilton from Robert C. Daley dated November 26, 2018.
SUBJECT: PERRY NUCLEAR POWER PLANTNRC TRIENNIAL FIRE PROTECTION
INSPECTION REPORT 05000440/2018011
DISTRIBUTION:
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ADAMS Accession Number ML18330A172
OFFICE RIII RIII
NAME ADahbur:jw RDaley
DATE 11/26/18 11/26/18
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-440
License No: NPF-58
Report No: 05000440/2018011
Enterprise Identifier: I-2018-011-0047
Licensee: First Energy Nuclear Operating Company (FENOC)
Facility: Perry Nuclear Power Plant
Location: North Perry, Ohio
Dates: September 17, 2018, through October 18, 2018
Inspectors: A. Dahbur, Senior Reactor Inspector (Lead)
I. Hafeez, Reactor Inspector
A. Shaikh, Senior Reactor Inspector
Approved by: Robert C. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance
by conducting a Triennial Fire Protection at Perry Nuclear Power 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. The NRC and
self-revealed findings, violations, and additional items are summarized in the table below.
There were no Licensee-identified violations.
List of Findings and Violations
Failure to have Adequate Pre-Fire Plans
Cornerstone Significance Cross-Cutting Aspect Report Section
Initiating Events Green None 71111.05T
Opened and Closed
The inspectors identified a finding of very-low safety significance (Green), and associated
Non-Cited Violation (NCV) of License Condition 2.C(6), Fire Protection, for the licensees
failure to implement and maintain all provision of the approved Fire Protection Program to
ensure that a fire in any zone would not have the potential to cause a secondary fire/damage
to safe shutdown components in different zone. Specifically, the inspectors identified a
potential existed for a fire induced fault to cause a secondary fire in a different fire zones/areas
due to unfused circuit associated with the Diesel Generator Building Ventilation Fan
1M43C0001A. This condition was outside the boundaries of the safe shutdown analysis.
Failure to Include Operator Action in the Plant Operating Procedure
Cornerstone Significance Cross-Cutting Aspect Report Section
Mitigating Systems Green [H.2] - CCA 71111.05T
NCV 05000331/2018011-02 Field Presence
Opened and Closed
The inspectors identified a finding of very-low safety significance and associated violation
of License Condition 2.C.6, Fire Protection, for failure to meet the requirements of its Fire
Protection Program. Specifically, the licensee failed to implement a fire watch in accordance
with the Fire Protection Program when transient combustibles were located in the Emergency
Service Water pump house room that is classified as a combustible control zone.
2
Failure to have Adequate Pre-Fire Plans
Cornerstone Significance Cross-Cutting Aspect Report Section
Mitigating Systems Green None 71111.05T
Opened and Closed
The inspectors identified a finding of very-low safety significance (Green), and an associated
NCV of License Condition 2.C.6, Fire Protection, for the licensees failure to install smoke
detection system in accordance with National Fire Protection Association 72E Automatic Fire
Detectors. Specifically, the licensee installed the smoke detectors in the Emergency Service
Water pump-house with one-half at ceiling level and one-half at 18 inches from the ceiling
instead of 36 inches as required per National Fire Protection Association 72E-1974.
Additional Tracking Items
None
3
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.
REACTOR SAFETY
71111.05TFire Protection (Triennial)
The inspectors evaluated the following from September 17, 2018, to October 18, 2018:
Fire Protection Inspection Requirements (4 Samples)
The inspectors evaluated the Fire Protection Program implementation in the following
selected areas:
(1) Fire Zone 1CC-3c, Division 1 Switchgear Room;
(2) Fire Zone 1CC-5a, Control Room;
(3) Fire Zone CC1, Control Complex Elevation 574; and
(4) Fire Zone ESW1, Essential Service Water (ESW) Pump House.
B.5.b Inspection Activities (2 Samples)
The inspectors evaluated feasibility of the following B.5.b Mitigating Strategies:
(1) NEI 06-12, Section 3.4.5, Make up to Condensate Storage Tank; and
(2) NEI 06-12, Section 3.4.9, Inject Water Into Drywell.
INSPECTION RESULTS
71111.05TFire Protection (Triennial)
Failure to have Adequate Pre-Fire Plans
Cornerstone Significance Cross-cutting Aspect Report Section
Initiating Events Green None 71111.05T
Opened and Closed
Introduction: The inspectors identified a finding of very-low safety significance (Green), and
associated NCV of License Condition 2.C(6), Fire Protection, for the licensees failure to
implement and maintain all provision of the approved Fire Protection Program to ensure that
a fire in any zone would not have the potential to cause a secondary fire/damage to safe
shutdown components in a different zone. Specifically, the inspectors identified a potential for
4
a fire induced fault to cause a secondary fire in different fire zones/areas due to an unfused
circuit associated with the Diesel Generator Building Ventilation fan 1M43C0001A.
This condition was outside the boundaries of the safe shutdown analysis.
Description: While reviewing the Schematic Drawing 208-0135-00003, Revision AA, for Diesel
Generator Building Ventilation Fan 1M43C0001A, the inspectors identified an unfused circuit
fed directly from 250 VA control power transformer associated with the control circuit for the
fan. This circuit was contained in Cable 1M43C88A and was routed from Motor Control Center
EF1A08-PP located in Division 1 Switchgear Room (Fire Zone 1CC-3C), through the Elevator
vestibule (1CC-3e), through the Diesel Generator Hallway (DG-1d), and finally terminated in
the Division 1 Diesel Generator Room (1DG-1c).
Further review revealed that the change to the originally installed fan circuit that added this
cable was performed under Engineering Change Notice 27102-86-1502/G in June of 1985
specifically for Appendix R compliance. It was determined that in order to be able to run the
fan locally from the EDG Room, in the event of a fire in the control room area that could result
in fire damage to a portion of the fan circuit and the control power fuse blown, the 1985
modification would still allow the capability to locally start the fan by bypassing the blown
control fuse.
In response to the inspectors question related to this unfused circuit, the licensee determined
that without overcurrent protection for this circuit, the potential existed for a fire event that
affects this circuit to cause a short circuit without protection. This event would cause excessive
current through the circuit beyond the capacity rating of the conductors or the control power
transformer. This could lead to a secondary fire in another plant area where this circuit was
routed, thereby challenging the ability to achieve and maintain safe shutdown.
This condition was not bounded by existing design and licensing documents. The stations fire
protection safe shutdown analysis, documented in Calculation SSC-001, was dependent on a
fire being limited to a single area. Once a secondary fire was possible, it represented an
unanalyzed condition. The licensee reported this condition to the U.S. Nuclear Regulatory
Commission (NRC) in accordance with Title 10 of the Code of Federal Regulations, Part 50.72,
per non-emergency Event Notification EN-53644 on October 4, 2018.
Corrective Action(s): As immediate corrective actions, the licensee established interim
compensatory measures (i.e., fire watches) and recommended an action to fuse this circuit.
Corrective Action References: Condition Report (CR) 2018-08718 and EN-53644
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to ensure that a
single fire in any zone would not result in the potential to cause a secondary fire/damage to
safe shutdown component in a different zone was contrary to License Condition 2.C(6) and
was a performance deficiency. Specifically, the licensee failed to ensure that a fire induced
fault on the unfused circuit associated with EDG Building Ventilation Fan 1M43C0001A would
not result in a secondary fire in other zones, which was not bounded by the existed design and
licensing documents.
Screening: The inspectors determined the performance deficiency was more-than-minor
because it adversely affected the Initiating Events cornerstone attribute of Protection Against
5
External Factors (Fire) and affected the cornerstone objective of limiting the likelihood of events
that upset plant stability and challenge critical safety functions during shutdown as well as
power operations. Specifically, the unfused circuit associated with 1M43C0001A increased the
potential of a secondary fire in other zones. This condition was outside the boundaries of the
safe shutdown analysis. Additionally, a secondary fire event could complicate firefighting
activities by the fire brigade and could either increase the likelihood of a larger fire event or the
severity of the fire.
Significance: In accordance with IMC 0609, Significance Determination Process (SDP),
Attachment 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined
the finding affected the Initiating Events cornerstone. The finding degraded fire protection
defense-in-depth strategies and the inspectors determined, using Table 3, that it could be
evaluated using Appendix F, Fire Protection SDP. The inspectors assigned this finding to
the Fire Prevention, category in Step 1.4 of IMC 0609, Appendix F. The inspectors then
answered NO to Question 1.4.6-A because the finding did not result in a more significant fire
than previously analyzed such that the credited safe shutdown strategy could be adversely
impacted, and determined that the issue screened as having very-low safety significance
(Green). Although, a secondary fire could complicate firefighting activities and could either
increase the likelihood of a larger fire event or the severity of the fire, the probability of a fire
that could impact both safe shutdown methods was very-low. The inspectors walk down the
affected Fire Zones (1CC-3e, 1CC-3c, DG-1d and 1DG-1c) and reasonably concluded that
the potential of a fire that could impact both safe shutdown methods was low.
Cross-Cutting Aspect: The finding did not have a cross-cutting aspect because it was
considered not to be indicative of current licensee performance (i.e., deficiency existed
for more than 3 years).
Enforcement:
Violation: License Condition 2.C(6) requires the licensee to implement and maintain
in effect all provisions of the approved Fire Protection Program as described in the Final
Safety Analysis Report (FSAR), as amended, and as approved through Safety Evaluation
Report (NUREG-0887) dated May 1982, and Supplements Numbers 1 through 10. The FSAR
Section 9A.2.3.6, Review of Redundant Shutdown Systems, stated, in part, that a Safe
Shutdown Analysis/Evaluation was performed to ensure that redundant shutdown systems
and all circuits, equipment and instrumentation that are associated with shutdown system
are separated from each other, so that both are not subject to damage from a single fire.
In addition, Section 3.4.03.04 of SSC-001, Safe Shutdown Capability Report, Revision 5,
stated in part, that Fire Zone 1CC-3e, contains components and circuits for Method A and
Method B systems. For this area, safe shutdown could be achieved utilizing Method A
systems and equipment.
Contrary to the above, as of October 18, 2018, the licensee failed to ensure that redundant
shutdown systems including circuits were separated from each other, so that both were not
subject to damage from a single fire. Specifically, the licensee failed to ensure a fire induced
fault to unfused circuit associated with DG Building Ventilation Fan 1M43C0001A would not
result in a secondary fire in a different zones. This condition was not bounded by existed
design and licensing documents. A fire in any of these fire zones 1CC-3c, DG-1d and
1DG-1c could cause a secondary fire in zone 1CC-3e that impact the credited safe
shutdown components for a fire in area 1CC-3e.
6
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the
Failure to Include Operator Action in the Plant Operating Procedure
Cornerstone Significance Cross-cutting Aspect Report Section
Mitigating Systems Green [H.2] - CCA 71111.05T
NCV 05000440/2018011-02 Field Presence
Opened and Closed
Introduction: The inspectors identified a finding of very-low safety significance and associated
violation of License Condition 2.C(6), Fire Protection, for failure to meet the requirements of
its Fire Protection Program. Specifically, the licensee failed to implement a fire watch in
accordance with the fire protection program when transient combustibles were located in the
ESW pump house room that is classified as a combustible control zone.
Description: During a field walk down of the ESW pump house room, the inspectors identified
a significant quantity of temporary 480V power cables in the combustible control zone of the
pump house (ESW-1a). In addition, a portable diving pump with oil was also found by the
licensee in the combustible control zone. The inspectors questioned the impact to safe
shutdown equipment in this area by staging a portable oil filled pump and routing these
temporary power cables through a combustible control zone and requested a transient
combustible control permit for these combustibles. The licensee determined that no transient
combustible control permit was issued for these power cables and portable pump and
therefore, no evaluation was performed on the impact of these combustibles in this combustible
control zone. Subsequent to the NRC inspectors questions, the licensee performed an
evaluation on the impact of these combustibles in the combustible control zone.
The temporary power cables were routed immediately adjacent to cable tray 1305, which
contains safe shutdown Method B circuits. The circuits in cable tray 1305 include those circuits
that support the ESW screen wash pump (B train), ESW pump house ventilation supply fan
and related dampers (B train) and the ESW pump discharge isolation valve and related limit
switch (B train). Although, these circuits are spatially separated from redundant equipment by
at least 20 feet. A postulated fire involving the temporary power cables and a portable oil filled
pump could damage the circuits in cable tray 1305, but could also potentially damage the
corresponding redundant circuits (Method A).
Procedure PAP-1910, Fire Protection Program, establishes the fire protection policy at
Perry Nuclear Power Plant. The PAP-1910, Section 4.6.4, Fire Watches, states, in part,
that the specifics that control this process are described in sub-tier instruction FPI-A-C01,
Fire Protection Program Control Processes (Hot Work Permits, Transient Combustibles,
Impairments, and Fire Watches). The FPI-A-C01, Section 6.5, Fire Watches, states, in part,
that continuous fire watches are established when there is increased combustible loading in
areas listed in Attachment 1 beyond the exempted limits specified in PAP-1910. Attachment 1
of FPI-A-C01 lists the ESW pump house room, area ESW-1a as a combustible control zone
and PAP-1910 specifies the exempted limit of combustible material in a combustible control
zone is 10 pounds. The licensee determined that approximately 60 pounds of temporary
power cables were located in the ESW-1a combustible control zone and the portable diving
pump was in excess of 10 pounds as well.
Corrective Action(s): The licensee entered the NRC inspectors concern into its Corrective
Action Program. As part of immediate corrective actions, the licensee removed and relocated
7
the temporary power cables and pump outside the combustible control zone of the ESW pump
house room.
Corrective Action Reference: CR 2018-08305
Performance Assessment:
Performance Deficiency: Failure to implement a fire watch due to exceeding combustible
loading limit in a combustible control zone.
Screening: The licensees Failure to implement fire watches due to exceeding the combustible
loading limit in a combustible control zone was a performance deficiency. The inspectors
determined the performance deficiency was more-than-minor, and therefore, a finding,
because it adversely affected the Protection Against External Factors attribute of the Mitigating
Systems Cornerstone objective to ensure the availability, reliability, and capability of systems
that respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, the failure to implement a fire watch in the ESW pump house room, fire area
ESW-1a, reduced the defense in depth in fire protection of the ESW pump house and could
have resulted in a potential fire damaging equipment required for both safe shutdown methods.
Significance: The inspectors assessed the significance of the finding in accordance with
IMC 0609, SDP, Attachment 0609.04, Initial Characterization of Findings, Table 2. The
inspectors determined the finding affected the Mitigating Systems cornerstone. The finding
degraded fire protection defense-in-depth strategies, and the inspectors determined, using
Table 3, that it could be evaluated using Appendix F, Fire Protection SDP. The inspectors
screened the finding using IMC 0609, Appendix F, Attachment 1, Part 1: Fire Protection SDP
Phase 1 Worksheet, dated May 2, 2018. The inspectors determined that the finding
degradation rating was low in accordance with the guidance in IMC 0609, Appendix F,
Attachment 2. The inspectors answered YES to question 1.3.1 of IMC 0609, Appendix F,
Attachment 1, Based on the criteria in Attachment 2, does the finding have a low
degradation? Therefore, the inspectors determined that the finding screened as having
very-low safety significance (Green).
Cross-Cutting: The finding had a cross-cutting aspect of Field Presence in the Area of Human
Performance for the licensees failure to provide supervisory oversight of work activities
including contractors and supplemental personnel. Specifically, the licensee management and
supervisors failed to appropriately recognize the requirements in Procedure FPI-A-C01, which
establishes fire watches in combustible control zones when exempted combustible limits were
exceeded. [H.2]
Enforcement:
Violation: License Condition 2.C(6) requires the licensee to implement and maintain all
provisions of the approved Fire Protection Program as described in the FSAR, as amended,
and as approved through Safety Evaluation Report (NUREG-0887) dated May 1982, and
Supplements Numbers 1 through 10. The FSAR, Appendix 9A, Fire Protection Evaluation
Report, Position B.1, states, in part, that First Energy Nuclear Operating Company has
implemented Plant Administrative Procedure PAP-1910, Fire Protection Program as the
controlling document.
Procedure PAP-1910, Section 4.6.4, Fire Watches states, in part, that the specifics that
control this process are described in sub-tier instructions FPI-A-C01, Fire Protection Program
8
Control Processes (Hot Work Permits, Transient Combustibles, Impairments, and Fire
Watches). The FPI-A-C01, Section 6.5, Fire Watches, states, in part, that continuous fire
watches are established when there is increased combustible loading in areas listed in
Attachment 1 beyond the exempted limits specified in PAP-1910. Attachment 1 of FPI-A-C01
lists the ESW pump house room, area ESW-1a as a combustible control zone and PAP-1910
specifies the exempted limit of combustible material in a combustible control zone is
10 pounds.
Contrary to the above, since September 2018, the licensee failed to maintain its Fire Protection
Program because it failed to implement fire watches in the ESW pump house room area
ESW-1a when greater than 10 pounds (approximately 60 pounds) of combustible material was
temporary located in this area.
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the
Failure to Include Operator Action in the Plant Operating Procedure
Cornerstone Significance Cross-cutting Aspect Report Section
Mitigating Systems Green None 71111.05T
Opened and Closed
Introduction: The inspectors identified a finding of very-low safety significance (Green),
and an associated NCV of License Condition 2.C.6, Fire Protection, for the licensees
failure to install smoke detection system in accordance with National Fire Protection
Association (NFPA) 72E-1974. Specifically, the licensee installed the smoke detectors in
the ESW pump-house with one-half at ceiling level and one-half at 18 inches from the ceiling
instead of 36 inches as required per NFPA 72E-1974.
Description: During a walkdown of the ESW pump house area, the inspectors observed smoke
detectors installed on the high ceiling (approximately 62 feet) of the pump house. The ESW
pump house contains fire area ESW-1a which contains safe shutdown Method A and B
equipment. The inspectors questioned the position of the detectors relative to the ceiling
height. Specifically, the inspectors noted that the detectors were installed in an alternating
pattern where half the ESW pump house room detectors were mounted on the I-beams running
across the ceiling of the pump house and the other half of the detectors were mounted flush to
the ceiling. The depth of the I-beam was 18 inches and the I-beam was flush with the ceiling
such that the detectors were mounted 18 inches from the ceiling surface.
A review of the licensees code of record of NFPA 72E-1974, Automatic Fire Detectors,
Section 4-4, High Ceilings Location and Spacing, revealed that for proper protection for
building with high ceilings, detectors shall be installed alternately at two levels; one-half at
ceiling level, and the other half at least 3 feet below the ceiling. This is required to
accommodate for stratification of smoke due to the smoke losing its thermal lift from the fire
and the generally higher temperature of the air near the ceiling.
In addition, Calculation P54-010, Revision 0, evaluated the smoke detection to be used in
the ESW Pump house. This calculation states that ionization detectors were installed at
ceiling level and 3 feet below the ceiling. Specifically, the calculation referenced the applicable
portion of the NFPA 72E standard. Also, Drawing 221-0071-00000 showed half the detectors
were mounted at elevation 643-1 inch where the ceiling level is at 646-1 inch per
9
Drawing 526-0301-00000 Revision D. Additionally, in Supplemental Safety Evaluation
Report 3, the NRC staff granted the licensee a requested deviation from meeting the Branch
Technical Position 9.5-1 requiring automatic suppression system in fire area ESW-1a. One of
the basis for the NRC granted deviation was that the license stated that fire area ESW-1a had
early warning detection.
Corrective Action(s): The inspectors were concerned that failure to install detectors in
accordance with the applicable NFPA 72E code could result in an adverse impact in the ability
of the detectors to provide an early warning in the event of a fire. Subsequent to the NRC
inspectors questions, the licensee acknowledge the inspectors concerns and entered it into its
Corrective Action Program and as immediate corrective actions, the licensee declared a fire
detection impairment for the ESW pump house room and implemented an hourly fire watch in
accordance with the site fire protection program.
Corrective Action Reference: Condition Report (CR) 2018-08725
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to install
smoke detectors in the ESW pump-house area 36 inches from the ceiling was contrary
to NFPA 72E-1974, Section 4-4 and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more-than-minor
because it affected the Mitigating Systems cornerstone attribute of Protection Against External
Factors (Fire), and affected the cornerstone objective of ensuring the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable consequences
(i.e., core damage). Specifically, the failure to install the detection system in accordance with
the code of record degraded the defense-in-depth element of the Fire Protection Program for
this area. This could affect the timeliness of response to a fire in the area due to delayed
detection of smoke, allowing the fire to grow and delaying the firefighting activities of the
fire-brigade. In addition, this condition did not ensure early-warning fire detection, which
was one of the bases for approval of a deviation for the lack of a suppression system.
Significance: In accordance with IMC 0609, SDP, Attachment 0609.04, Initial
Characterization of Findings, Table 2 the inspectors determined that the finding affected
the Mitigating Systems cornerstone. The finding degraded fire protection defense-in-depth
strategies, and the inspectors determined, using Table 3, that it could be evaluated using
Appendix F, Fire Protection SDP. The inspectors screened the finding using IMC 0609,
Appendix F, Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet, dated
May 2, 2018. The inspectors assigned a Low degradation rating in accordance with
Attachment 2 of Appendix F, because although the smoke detection system installed in ESW
did not fully conform to NFPA 72E-1974, all installed detectors in the area were functional. The
inspectors determined that the finding screened as having very-low safety significance (Green)
per answering YES to Question 1.3.1 A, based on the finding had a low degradation rating.
Cross-Cutting Aspect: The finding did not have a cross-cutting aspects because it was
considered not to be indicative of current licensee performance (i.e., deficiency existed
for more than 3 years).
10
Enforcement:
Violation: License Condition 2.C(6) requires the licensee to implement and maintain all
provisions of the approved Fire Protection Program as described in the FSAR, as amended,
and as approved through Safety Evaluation Report (NUREG-0887) dated May 1982, and
Supplements Numbers 1 through 10. The FSAR Section 9A.7, states, in part, that fire
detectors are located and spaced in accordance with NFPA 72E. The NFPA 72E, Section 4-4,
High Ceilings Location and Spacing, states that for proper protection for building with high
ceilings, detectors shall be installed alternately at two levels; one-half at ceiling level, and the
other half at least 3 feet below the ceiling.
Contrary to the above, since original construction, the licensee failed to install smoke detection
system in ESW pump house accordance with the requirements of NFPA 72E-1974.
Specifically, the detectors in the ESW pump house were installed with one-half at ceiling level
and one-half at 18 inches from the ceiling instead of at least 3 feet from the ceiling as required
per NFPA 72E-1974, Section 4-4.
Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure. No proprietary information was documented in this report.
- On October 18, 2018, the inspectors presented the Triennial Fire Protection inspection
results to Mr. D. Reeves, and other members of the licensee staff.
DOCUMENTS REVIEWED
Condition Reports - Issued During Inspection
- CR 2018-08191; Combustibles Found in ESW Pumphouse Combustible Control Zone;
09/17/2018
- CR 2018-08305; Unevaluated Transient Combustibles in Combustible Control Zone (Fire Zone
ESW-1a); 09/20/2018
- CR 2018-08310; B.5.b Building Exhaust Fan Inappropriate Status Labeling; 09/20/2018
- CR 2018-08648; 2018 Discrepancy Between Calculation P54-024, Rev.6 and As-Found Field
Conditions; 10/02/2018
- CR 2018-08649; CC-574 Scaffolding Obstructing Overhead Sprinklers with No Active Fire
Impairment; 10/02/2018
- CR 2018-08258; Issues Identified During B.5.b Walkdown of Emergency Management
Overview, OAI-1901; 09/19/2018
- CR 2018-08725; Smoke Detection in the Emergency Service Water Pumphouse Not Installed
in Accordance with Design Documents and NFPA Code; 10/04/2018
- CR 2018-08718; Vulnerability to Cause Secondary Fire due to Unfused M43 Circuit Caused by
Fire Induced Short; 10/04/2018
- CR 2018-09112; Potential Shortfall in IOI-0011; Shutdown from Outside Control Room;
10/17/2018
- CR 2018-09093; Reportability of 20101-76215; 10/17/2018
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Condition Reports - Reviewed During Inspection
CR 2012-04734; Potential Spray Nozzle Coverage Issue in 638 Penetration Room; 03/28/2012
CR 2012-04714; Detection Coverage in Unit 1, Division 2 Cable Spreading Area; 03/28/2012
CR 2017-12488; NRC Question-Effects of internal flooding in the Control Complex 620
elevation; 12/28/2017
CR 2010-76215; Control Room Fire Induced MSO Potential Vulnerability; 04/30/2010
CR 2012-14336; Calculation P54-010 references the incorrect year of NFPA 72E, 09/18/2012
CR G202-2010-76215; Control Room Fire Induced MSO potential Vulnerability; 04/30/2010
Procedures
- PTI-P54-P0003; Fire Main Flow Test; Revision 7
- ONI-SPI-A-8; LPCS Fire Water; Revision 4
- ONI-SPI-D-9; Makeup Water Sources; Revision 1
- FPI-A-A02; Periodic Fire Inspections; Revision 6
- PYBP-POS-0029; Time Critical Operator Action Validation; Revision 3
- IOI-0011; Shutdown from Outside Control Room; Revision 37
- ONI-P54; Fire; Revision 23
Drawings
- 023-0034-00000; Fire Protection Evaluation - Emergency Service Water Pumphouse Plans
and Sections; Revision H
- 015-0002-00000; Final Plant Layout, Revision F
- 549-D-526-301; Emergency Service Water Pump House Steel Framing- Roofing Plan- EL.
648-0; Revision D
- 302-0602-00000; Reactor Water Recirculation System; Revision U
- 302-0621-00000; Emergency Closed Cooling System; Revision TT
- 302-0791-00000; Emergency Service Water System; Revision AAA
- 206-0044-00000; One Line Diagram Non-Class 1E 480V Bus XF-1-A; Revision WW
- 220-0834-00000; Lighting Panel R71P136; Revision N
- 023-0034-00000; Fire Protection Evaluation - Emergency Service Water Pump house Plans
and Sections; Revision H
Calculations and Evaluations
- P54-213; Fire Protection Evaluation to Abandon the Drywell Supplemental Heat Detection
(Zone 8 and 9) in the Unit 1 Drywell (Fire Zone 1RB-1c); 03/14/2018
- P54-145; Unit 1, Division 1 Cable Spreading Areas, Vertical Cable Chase and Tunnel Fire
Suppression Hydraulic Calculation; 08/28/2012
- P54-123; Piping Configuration Input for the Hydraulic Model of the Water Supply Distribution
System for Fire Suppression Systems; 04/29/1997
- SSC-001; Appendix R Evaluation: Safe Shutdown Capabilities Report, Revision 5
Work Orders
- 200677254; 24 Month M21 System Fire Damper Visual Inspection; 04/10/2018
- 200667900; 24 Month M23 System Fire Damper Visual Inspection; 12/31/2017
- 200689434; 24 Month M24 System Fire Damper Visual Inspection; 07/06/2018
- 200680396; 24 Month M25 and M26 System Fire Damper Visual Inspection; 06/12/2018
- 200710691; 6 Month Magnetically Held Open Fire Door Operability Test; 05/07/2018
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- 200477581; 3 Year Fire Main Flow Test; 09/22/2012
- 200532067; 3 Year Fire Main Flow Test; 05/06/2016
- 200655272; 18 Month Diesel Fire Pump Flow Data and Control Panel Functional Test;
06/22/2017
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