ML040890083
| ML040890083 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/26/2004 |
| From: | Ogle C NRC/RGN-II/DRS/EB |
| To: | Stall J Florida Power & Light Co |
| References | |
| FOIA/PA-2004-0277 IR-04-007 | |
| Download: ML040890083 (38) | |
See also: IR 05000250/2004007
Text
March 26, 2004
Florida Power and Light Company
ATTN: Mr. J. A. Stall, Senior Vice President
Nuclear and Chief Nuclear Officer
P.O. Box 14000
Juno Beach, FL 33408-0420
SUBJECT:
TURKEY POINT NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION
INSPECTION REPORT 05000250/2004007 AND 05000251/2004007
Dear Mr. Stall:
On February 13, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Turkey Point Nuclear Plant Units 3 and 4. The enclosed inspection report
documents the inspection findings, which were discussed on that date with Mr. T. Jones and
other members of your staff. Following completion of additional review in the Region II office, a
final exit was held by telephone with Mr. W. Prevatt and other members of your staff on
March 26, 2004, to provide an update on changes to the preliminary inspection findings.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one NRC-identified finding of very low safety significance (Green)
involving a violation of NRC requirements. However, because of the very low safety
significance and because it is entered into your corrective action program, the NRC is treating
the finding as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement
Policy. If you contest any NCV in this report, you should provide a response within 30 days of
the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator Region 2; the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at
Turkey Point Nuclear Plant.
2
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publically Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos.: 50-250, 50-251
Enclosure:
NRC Triennial Fire Protection Inspection Report 05000250/2004007 and
05000251/2004007 w/Attachment: Supplemental Information
cc w/encl:
T. O. Jones
Site Vice President
Turkey Point Nuclear Plant
Florida Power and Light Company
Electronic Mail Distribution
Walter Parker
Licensing Manager
Turkey Point Nuclear Plant
Florida Power and Light Company
Electronic Mail Distribution
Michael O. Pearce
Plant General Manager
Turkey Point Nuclear Plant
Florida Power and Light Company
Electronic Mail Distribution
David Moore, Vice President
Nuclear Operations Support
Florida Power & Light Company
Electronic Mail Distribution
(cc w/encl contd - See page 3)
3
(cc w/encl contd)
Rajiv S. Kundalkar
Vice President - Nuclear Engineering
Florida Power & Light Company
Electronic Mail Distribution
M. S. Ross, Managing Attorney
Florida Power & Light Company
Electronic Mail Distribution
Marjan Mashhadi, Senior Attorney
Florida Power & Light Company
Electronic Mail Distribution
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee, FL 32304
William A. Passetti
Bureau of Radiation Control
Department of Health
Electronic Mail Distribution
County Manager
Metropolitan Dade County
Electronic Mail Distribution
Craig Fugate, Director
Division of Emergency Preparedness
Department of Community Affairs
Electronic Mail Distribution
Curtis Ivy
City Manager of Homestead
Electronic Mail Distribution
Distribution w/encl:
E. Brown, NRR
C. Evans (Part 72 Only)
L. Slack, RII EICS
RIDSNRRDIPMLIPB
PUBLIC
OFFICE
RII:DRS
RII:DRS
RII:DRS
RII:DRS
RII:DRP
SIGNATURE
RA
RA
NAME
PFILLION
GWISEMAN
CPAYNE
KODONOHUE
JMUNDAY
DATE
3/26/2004
3/26/2004
3/26/2004
3/26/2004
3/26/2003
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
PUBLIC DOCUMENT
YES
NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML040890083.wpd
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.:
50-250, 50-251
License Nos.:
Report No.:
05000250/2004007 and 05000251/2004007
Licensee:
Florida Power and Light Company
Facility:
Turkey Point Nuclear Plant
Location:
9760 S. W. 344th Street
Florida City, FL 33035
Dates:
January 26 - 30, 2004 (Week 1)
February 9 - 13, 2004 (Week 2)
Inspectors:
C. Payne, Senior Reactor Inspector (Lead Inspector)
P. Fillion, Reactor Inspector
G. Wiseman, Fire Protection Inspector
Accompanying
N. Staples, Nuclear Safety Intern
Personnel:
K. ODonohue, Fire Protection Team Leader
Approved by:
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000250/2004-007, 05000251/2004-007; 01/26 - 30/2004 and 02/09 - 13/2004; Turkey
Point Nuclear Plant, Units 3 and 4; Triennial Fire Protection.
The report covered an announced two-week period of inspection by three regional inspectors.
One Green non-cited violation, six unresolved items pending a significance determination, and
two unresolved items pending additional inspection were identified. The significance of most
findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply
may be Green or be assigned a severity level after NRC management review. The NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. A non-cited violation (NCV) of 10 CFR 50, Appendix R, Section III.G.3
and License Condition 3.D was identified for failure to provide full area fire
detection and a fixed suppression system in the Unit 3 and 4 mechanical
equipment room for fires in Fire Area (FA) MM [Fire Zone (FZ) 97]. Upon
discovery, the licensee declared the detection and suppression inoperable,
established an hourly fire watch for FZ 97, and entered this issue into its
corrective action program.
The finding adversely affected the fire detection and suppression capability
defense-in-depth elements. The finding is greater than minor because it is
associated with the protection against external factors attribute and degraded the
reactor safety mitigating systems cornerstone objective. Because the fire
ignition frequency was low, the fire detection in the emergency recirculating filter
was not degraded, and alternative shutdown systems and procedures were
available to mitigate a fire in this area, the finding was determined to have very
low safety significance. (Section R05.10.b.2)
TBD. A finding was identified for failure to protect the control circuit of motor
operated valve (MOV) MOV-4-626, RCP thermal barrier component cooling
water return isolation valve, to prevent spurious operation during a fire in Fire
Area (FA) U [Fire Zone (FZ) 67] as required by 10 CFR 50, Appendix R, Section
III.G.3. An error in the Safe Shutdown Analysis Essential Equipment List
resulted in failure to properly classify MOV-4-626 as being required to assure
SSD. As a result, 0-ONOP-016.10 failed to include MOV-4-626 as part of the
mitigation strategy against spurious valve operation in FZ 67. The licensee
entered this issue into its corrective action program.
The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating
systems cornerstone objective. The finding degraded the defense-in-depth for
fire protection. The finding is applicable to FZ 67 and is unresolved pending
completion of a significance determination. (Section 1R05.01.b.1)
2
TBD. A finding was identified for failure to protect the control circuits and cables
that could cause maloperation of necessary valves in the reactor coolant pump
(RCP) thermal barrier cooling system as required by 10 CFR 50, Appendix R,
Section III.G.2 for fires in either Fire Area (FA) T [Fire Zone (FZ) 63] or FA U (FZ
67). The inspectors found that the licensee instead relied upon local manual
operator actions to verify correct alignment of RCP seal package thermal barrier
cooling valves. When evaluating the feasibility of the manual actions using the
guidance in the inspection procedure, the inspectors identified that 0-ONOP-
016.10 allowed 20 minutes to complete the operator actions for verification of
thermal barrier cooling valve alignment. However, industry analyses have
determined that seal package damage could occur within 13 minutes of loss of
all seal package cooling. The licensee entered this finding into its corrective
action program and resolved this concern by revising 0-ONOP-016.10.
The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating
systems cornerstone objective. The finding degraded the defense-in-depth for
fire protection. The finding is applicable to FZ 63 and FZ 67 and is unresolved
pending completion of a significance determination. (Section 1R05.01.b.2)
TBD. A finding was identified for failure to protect the control circuits and cables
that could cause maloperation of safe shutdown components for fires in either
Fire Area U [Fire Zone (FZ) 67] as required by 10 CFR 50, Appendix R, Section
III.G.2. The inspectors found that the licensee instead relied upon local manual
operator actions. However, the licensee failed to evaluate and mitigate the
effects of loss of security card key access to rooms where local manual operator
actions are performed for a fire in these areas. The inspectors identified that
security card key readers for FZ 68 (4A 4160 V switchgear room) and for FZ
93/94 (Unit 4, 480 V Load Centers A and B Room and Unit 4, 480 V Load
Centers C and D Room, respectively) could potentially lose card key function as
a result of a fire in FZ 67; thus impeding operator access to these rooms. The
licensee entered this finding into its corrective action program.
The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating
systems cornerstone objective. The finding degraded the defense-in-depth for
fire protection. The finding is applicable to FZ 67 and is unresolved pending
completion of a significance determination. (Section 1R05.01.b.3)
TBD. A finding was identified for failure to protect the control circuits for level
control valves (LCV) LCV-3-115B and LCV-4-115B, refueling water storage tank
(RWST) to charging pump valve, to prevent spurious operation during a fire in
Fire Area (FA) T [Fire Zone (FZ) 63] or FA U (FZ 67) as required by 10 CFR 50,
Appendix R,Section III.G.2. If valve LCV-3/4-115B spuriously closes due to a
fire-induced thermal insult, loss of the RWST as a suction source could lead to
charging pump damage. The licensee entered this finding into its corrective
action program and resolved this concern by revising 0-ONOP-016.10.
3
The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating
systems cornerstone objective. The finding degraded the defense-in-depth for
fire protection. This finding is applicable to FZ 63 and FZ 67 and is unresolved
pending completion of a significance determination. (Section 1R05.03)
TBD. A finding was identified for failure to ensure local manual operator actions
to verify correct alignment of MOV-3-716A and MOV-4-716A, Unit 3 and Unit 4
reactor coolant pump (RCP) thermal barrier component cooling water supply
isolation valves, were completed in a timely manner for a fire in Fire Area (FA)
MM (Fire Zones 106, 106R, or 97) as required by 10 CFR 50, Appendix R,
Section III.G.3. The inspectors identified that 0-ONOP-105, Attachment 7 (Unit
3) and Attachment 8 (Unit 4) allowed 20 minutes to complete the operator
actions for verifying that MOV-3-716A and MOV-4-716A were open. However,
industry analyses have determined that seal package damage could occur within
13 minutes of loss of all seal package cooling. Thus, the operator guidance
provided in 0-ONOP-105 does not provide timely action and could possibly result
in an RCP seal LOCA. The licensee entered this finding into its corrective action
program and resolved this concern by adding a security key to the operator key
rings.
The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating
systems cornerstone objective. The finding degraded the defense-in-depth for
fire protection. This finding is applicable to FA MM and is unresolved pending
completion of a significance determination. (Section 1R05.05.b.1)
TBD. A finding was identified for local manual operator actions that may not be
timely due to reliance on security support to bring a vital area security key to
access normally locked rooms which do not have a security card key readers for
fires in Fire Area (FA) MM [Fire Zones 106, 106R, and 97] as required by 10 CFR 50, Appendix R, Section III.G.3. Operators do not carry vital access
security keys with them and 0-ONOP-105 does not require vital access security
keys be brought when the control room is evacuated. Instead, security support
is required to bring access keys to the operator. However, operator access to
key-locked rooms is not ensured because security support could be diverted to
higher priority activities. Consequently, local manual operator actions may be
delayed and may not be completed in a timely manner to ensure that safe
shutdown is achieved. The licensee entered this finding into its corrective action
program and resolved this concern by revising 0-ONOP-105.
4
The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating
systems cornerstone objective. The finding degraded the defense-in-depth for
fire protection. This finding is applicable to FA MM and is unresolved pending
completion of a significance determination.
B.
Licensee-Identified Violations
None
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity
1R05
Fire Protection
The purpose of this inspection was to review the Turkey Point Nuclear Plant fire
protection program (FPP) for selected risk-significant fire areas. Emphasis was placed
on verification that the post-fire safe shutdown (SSD) capability [from both the Main
Control Room (MCR) and the Alternate Shutdown Panel (ASP)] and the fire protection
features provided for ensuring that at least one redundant train of SSD systems is
maintained free of fire damage. The inspection was performed in accordance with the
U.S. Nuclear Regulatory Commissions (NRC) Reactor Oversight Process using a risk-
informed approach for selecting the fire areas and attributes to be inspected. The
inspectors used the licensees Individual Plant Examination for External Events and in-
plant tours to choose three risk-significant fire areas for detailed inspection and review.
The fire areas (zones) chosen for review during this inspection were:
Fire Area (FA) T - Unit 3 Reactor Control Rod Equipment Room on the +18 foot (ft)
level. It is a single zone area comprised of Fire Zone (FZ) 63.
FA U - Unit 4 Train B 4160 Volt (V) Switchgear Room on the +18 ft level. It is a
single zone area comprised of FZ 67.
FA MM - Unit 3 and Unit 4 Control Room on the +42 ft level. It is a multiple zone
area comprised of FZ 106, 106R, and 97.
The inspectors evaluated the licensees FPP against applicable requirements, including
Operating License Condition 3.D; Title 10 of the Code of Federal Regulations, Part 50
(10 CFR 50), Appendix R; 10 CFR 50.48; commitments to Appendix A of Branch
Technical Position Auxiliary and Power Conversion Systems Branch 9.5-1; Turkey Point
Nuclear Plant Updated Final Safety Analysis Report (UFSAR); related NRC safety
evaluation reports (SER); and plant Technical Specifications. The inspectors evaluated
all areas of this inspection, as documented below, against these requirements.
Specific documents reviewed by the inspectors are listed in the attachment.
.01
Systems Required to Achieve and Maintain Post-fire Safe Shutdown
a.
Inspection Scope
The licensees Safe Shutdown Analysis Report (SSAR) was reviewed to determine the
components and systems necessary to achieve and maintain SSD conditions from the
MCR in the event of fire in FZ 63 and 67. The objectives of this evaluation were to:
2
Verify that the licensee's shutdown methodology had correctly identified the
components and systems necessary to achieve and maintain an SSD condition.
Confirm the adequacy of the systems selected for reactivity control, reactor coolant
makeup, reactor heat removal, process monitoring and support system functions.
Verify that an SSD can be achieved and maintained without off-site power when it
can be confirmed that a postulated fire in any of the selected fire areas could cause
the loss of off-site power.
Verify that local manual operator actions are consistent with the plants fire
protection licensing basis.
Focusing on the chemical and volume control system, the team evaluated whether the
SSAR properly identified and categorized components in terms of safe shutdown
function. In addition, instrumentation known to be necessary for safe shutdown, e.g.,
pressurizer pressure and level indication, was checked. The following safe shutdown
components were reviewed for operability during and after a severe fire in either FZ 63
or 67.
Volume control tank outlet valve, LCV-3(4)-115C
Refueling Water Storage Tank (RWST) to charging pump valve, LCV-3(4)-115B
Reactor Coolant Pump (RCP) thermal barrier component cooling water supply
isolation valve, MOV-3(4)-716A
RCP thermal barrier component cooling water supply isolation valve, MOV-
3(4)-716B
RCP thermal barrier component cooling water return isolation valve, MOV-3(4)-626
Coolant charging pumps 4A, 4B and 4C
The team reviewed the capability to safely shutdown given a fire in FZ 67 causes a loss
of the normal power source to the Unit 4 safety-related buses. Specifically, the control
circuit for emergency diesel generator 4A was reviewed in terms of the potential for
permissives and interlocks to be affected by a fire in the 4B 4160 V switchgear room.
The MCR (remote) and in-plant manual operator actions (local) for controlling plant
operation, fire response, and achieving an SSD condition in response to a severe fire in
FZ 63 or 67, were reviewed and walked down by the inspectors. To accomplish this
task, the inspectors evaluated the following Off-Normal Operating Procedures (ONOP):
0-ONOP-016.8, Response to a Fire/Smoke Detection System Alarm
0-ONOP-016.10, Pre-Fire Plant Guidelines and Safe Shutdown Manual Actions
- Pre-fire Plan, Fire Zone No. 63, Unit 3 Reactor Control Rod Equipment Room
- Pre-fire Plan, Fire Zone No. 67, 4160 V Switchgear 4B Room
The procedure reviews focused on ensuring that all required functions for post-fire safe
shutdown, and the corresponding equipment necessary to perform those functions,
were included in the procedures. The team walked down each pre-fire plan listed above
to verify that local manual operator actions were feasible and could be performed in a
timely manner.
3
b.
Findings
1. Failure to Prevent Spurious Operation of Valve MOV-4-626 For a Severe Fire in 4B
4160 V Switchgear Room
Introduction: A finding was identified for failure to protect the control circuit of motor
operated valve (MOV) MOV-4-626, RCP thermal barrier component cooling water return
isolation valve, to prevent spurious operation during a fire in FA U (FZ 67). The finding
is an unresolved item (URI) pending completion of the significance determination
process (SDP).
Description: Per the SSAR, thermal barrier cooling is the assured method for protecting
the RCP seals during a severe fire in FZ 67 because charging pump seal injection flow
may be terminated by operator action or lost due to the fire. Valve MOV-4-626 is a
motor operated valve in the thermal barrier component cooling water (CCW) header
returning from all three Unit 4 RCPs. The valve can be controlled from either the MCR
(FZ 106) or the ASP [which is located in the 4B 4160V switchgear room (FZ 67)].
Because the control cable for this valve terminates at the ASP and the cable is
unprotected, thermal insult to the control circuit for the valve could cause it to spuriously
close. Closure of the valve would stop thermal barrier cooling return flow from all three
Unit 4 RCPs. Guidance in 0-ONOP-016.10, Pre-fire Plan Fire Zone 67, directs local
manual operator actions to prevent, or recover from, spurious closure of MOVs that
could interrupt thermal barrier cooling. For FZ 67, thermal barrier cooling valves MOV-
4-716B and MOV-4-626 could be subject to spurious operation but the inspectors found
that MOV-4-626 was not included in the procedure.
The inspectors found that on September 9, 2003, the licensee had identified an error in
the SSA Essential Equipment List, in that, MOV-4-626 was not properly classified as
being required to assure SSD. As a result, the fire response procedure failed to include
MOV-4-626 as part of the mitigation strategy against spurious valve operation. The
issue was entered into the licensees corrective action program (CAP) as condition
report (CR) 03-1330-1. The need to review and update 0-ONOP-016.10 was entered
into the CAP as CR 04-0292; but, this deficiency was not resolved prior to the
inspection. During the inspection, the licensee resolved this concern by issuing an on-
the-spot-change to 0-ONOP-016.10 which specified manual actions to de-energize and
verify open MOV-4-626. The licensee documented this action in its CAP as CR 04-
0610.
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following a severe fire. The
finding is greater than minor because it is associated with the protection against external
factors attribute and degraded the reactor safety mitigating systems cornerstone
objective. The finding degraded the defense-in-depth for fire protection. This finding is
applicable to FZ 67 and is unresolved pending completion of a significance
determination.
Enforcement: 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants
licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of
Appendix R,Section III.G. Section III.G.2 states, in part, that where cables or
4
equipment, including associated non-safety circuits that could prevent operation or
cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant
trains of systems necessary to achieve and maintain hot shutdown conditions are
located within the same fire area outside of primary containment, one of three means of
ensuring that one of the redundant trains is free of fire damage shall be provided.
Contrary to the above, on February 13, 2004, the inspectors identified that the licensee
failed to protect control circuits and cables that could cause maloperation of MOV-4-626
in the RCP thermal barrier cooling system. This condition existed since at least
September 9, 2003, when it was first identified by the licensee. The finding and related
violation are unresolved pending completion of a significance determination. This
finding is identified as URI 05000251/2004007-001, Failure to Prevent Spurious
Operation of Valve MOV-4-626 For a Severe Fire in 4B 4160 V Switchgear Room.
2. Local Manual Operator Actions to Protect RCP Seal Package Cooling Not Timely
Introduction: A finding was identified for failure to ensure that local manual operator
actions used to verify correct alignment of RCP seal package thermal barrier cooling
valves were completed in a timely manner for fires in either FA T (FZ 63) or FA U (FZ
67). The finding is a URI pending completion of the SDP.
Description: Per the SSAR, thermal barrier cooling is the assured method for protecting
the RCP seals during a severe fire in FZ 63 or FZ 67 because charging pump seal
injection flow may be terminated by operator action or lost due to the fire. In lieu of
protecting the control circuits and cables for the RCP thermal barrier cooling valves
[MOV-3-716B and MOV-3-626 in FZ 63; and MOV-4-716B in FZ 67], guidance in 0-
ONOP-016.10 directs local manual operator actions to prevent, or recover from,
spurious closure of the MOVs. When evaluating the feasibility of the manual actions
using the guidance in the inspection procedure, the inspectors identified that 0-ONOP-
016.10 allowed 20 minutes to complete the operator actions for verification of thermal
barrier cooling valve alignment. However, industry analyses [Westinghouse Direct Work
No. DW-94-011; Westinghouse WCAP-10541, Revision 2; and Westinghouse WCAP-
15603, Revision 1-A] have determined that seal package damage could occur within 13
minutes of loss of all seal package cooling. Thus, the operator guidance provided in 0-
ONOP-016.10 does not provide timely action and could possibly result in an RCP seal
LOCA. Loss of reactor coolant system (RCS) inventory due to an RCP seal LOCA could
be beyond the capacity of equipment dedicated to achieve and maintain post-fire safe
shutdown. The licensee entered the finding into its CAP as CR 04-0688 and resolved
this concern by revising 0-ONOP-016.10.
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following a severe fire. The
finding is greater than minor because it is associated with the protection against external
factors attribute and degraded the reactor safety mitigating systems cornerstone
objective. The finding degraded the defense-in-depth for fire protection. The finding is
applicable to FZ 63 and FZ 67 and is unresolved pending completion of a significance
determination.
5
Enforcement: 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants
licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of
Appendix R,Section III.G. Section III.G.2 states, in part, that where cables or
equipment, including associated non-safety circuits that could prevent operation or
cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant
trains of systems necessary to achieve and maintain hot shutdown conditions are
located within the same fire area outside of primary containment, one of three means of
ensuring that one of the redundant trains is free of fire damage shall be provided.
Contrary to the above, on February 13, 2004, the inspectors identified that the licensee
failed to protect control circuits and cables that could cause maloperation of necessary
valves in the RCP thermal barrier cooling system. This condition has since at least
February 9, 2001, when the applicable procedure page was last revised. This finding
and related violation are unresolved pending completion of a significance determination.
This finding is identified as URI 05000250,251/ 2004007-002, Local Manual Operator
Actions to Protect RCP Seal Package Cooling Not Timely.
3. Local Manual Operator Actions Not Evaluated for Loss of Security Card Key Access for
a Severe Fire in 4B 4160 V Switchgear Room
Introduction: A finding was identified for failure to evaluate and mitigate the effects of
loss of security card key access to rooms where local manual operator actions are
performed for a fire in FA U (FZ 67). The finding is a URI pending completion of the
SDP.
Description: Access to the 4B 4160 V switchgear room (FZ 67) is controlled by a
security card key reader system. A fire in FZ 67 could potentially cause thermal insult to
the readers control circuit located within the room and in some scenarios cause the
door mechanism to fail in the locked position. The inspectors questioned whether failure
of the security card key reader in FZ 67 would impede operator access to other rooms
during performance of SSD local manual operator actions. The licensee had not
analyzed the routing of security system cables. To address potential access issues for
the fire brigade at the site of a fire, a security officer responds to all fires with a vital area
key. However, investigation revealed that security card key readers for FZ 68 (4A 4160
V switchgear room) and for FZ 93/94 (Unit 4, 480 V Load Centers A and B Room and
Unit 4, 480 V Load Centers C and D Room, respectively) could potentially lose card key
function as a result of a fire in FZ 67; thus impeding operator access to these rooms.
The inspectors identified six steps in Pre-fire Plan 67 of 0-ONOP-016.10 that must be
performed in FZ 68 or FZ 93/94 within 15 minutes of a fire in FZ 67. However,
procedural guidance to ensure access to these rooms (e.g., keys or security support) to
perform these time critical local manual operator actions was not included in 0-ONOP-
016.10. As a result, the inspectors determined that local manual operator actions in
these fire zones may be delayed and could adversely affect achieving SSD conditions.
The licensee entered the finding into its CAP as CR 04-0700.
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following a severe fire. The
finding is greater than minor because it is associated with the protection against external
factors attribute and degraded the reactor safety mitigating systems cornerstone
6
objective. The finding degraded the defense-in-depth for fire protection. The finding is
applicable to FZ 67 and is unresolved pending completion of a significance
determination.
Enforcement: 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants
licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of
Appendix R,Section III.G. Section III.G.2 states, in part, that where cables or
equipment, including associated non-safety circuits that could prevent operation or
cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant
trains of systems necessary to achieve and maintain hot shutdown conditions are
located within the same fire area outside of primary containment, one of three means of
ensuring that one of the redundant trains is free of fire damage shall be provided.
Contrary to the above, on February 13, 2004, the licensee failed to protect control
circuits and cables that could cause maloperation of equipment necessary to achieve
and maintain safe shutdown for fires in FZ 67. This condition has existed since at least
February 9, 2001, when the applicable procedure pages were last revised. This finding
and related violation are unresolved pending completion of a significance determination.
The finding is identified as URI 05000251/2004007-003, Local Manual Operator Actions
Not Evaluated for Loss of Security Card Key Access For a Severe Fire in 4B 4160 V
Switchgear Room.
.02
Fire Protection of Safe Shutdown Capability
a.
Inspection Scope
For the selected fire areas, the inspectors evaluated the frequency of or potential for
fires, the combustible fire load characteristics and potential exposure fire severity, the
separation of systems necessary to achieve SSD, and the separation of electrical
components and circuits to ensure that at least one SSD path was free of fire damage.
The inspectors reviewed selected portions of the Fire Protection Program Report
(FPPR), which includes the fire hazards analysis (FHA), to determine if the licensees
commitments, as established in the fire protection licensing basis documents, were
satisfied.
The inspectors reviewed the following documents, which establish and implement
controls and practices to prevent fires and to control the storage of permanent and
transient combustible materials and ignition sources, to verify that the objectives
established by the NRC-approved FPP were satisfied.
Fire Protection Procedure 0-ADM-016, Fire Protection Program
Turkey Point Information Bulletin Number 03-26, Smoking Policy
Turkey Point Combustible Storage Locker List
Turkey Point Transient Combustible Permits issued from January 2001, for FZs 63,
67, and 106
Fire Protection Procedure 0-ADM-016.1, Transient Combustible and Flammable
Substances Program
Fire Protection Procedure 0-ADM-016.5, Hot Work Program
Quality Instruction QI 2-PTN-4, Housekeeping
7
The inspectors toured the selected plant fire areas to observe: (1) the material condition
of fire protection systems and equipment, (2) the storage of permanent and transient
combustible materials, and (3) the licensees implementation of the procedures for
limiting fire hazards, combustible waste collection, housekeeping practices, and
cleanliness conditions. These reviews were accomplished to ensure that the licensee
was maintaining the fire protection systems, had properly evaluated in-situ combustible
fire loads, controlled hot-work activities, and limited transient fire hazards in a manner
consistent with the UFSAR, administrative procedures and other fire protection program
procedures.
The inspectors examined the fire protection barriers and selected combustible oil-
retention basins to confirm installation was in accordance with the applicable separation
and design requirements stated above. To address the issue of separation of
redundant electric circuits located in the same fire area, the team determined which
unprotected cables penetrated the wall between the 4A and 4B 4160 V switchgear
rooms. The function of each of these cables was reviewed by the team to ascertain
whether a fire in one switchgear room could affect the capability of equipment in the
other room to achieve safe shutdown.
Fire brigade response and emergency/incident reports for 2002 and 2003, selected fire
safety inspection reports, as well as CRs resulting from fire, smoke, sparks, arcing, and
equipment overheating incidents were reviewed. This review was conducted to assess
the effectiveness of the fire prevention program and any maintenance-related or
material condition problems related to fire incidents. Additionally, design control
procedures were reviewed to determine if plant changes were adequately reviewed for
the potential impact on the fire protection program, SSD equipment, and procedures as
required by the FPP.
The inspectors reviewed operator and fire brigade staffing, fire brigade response, fire
brigade qualification training and drill program procedures, and fire brigade drill critiques
for brigade shifts from January 2001 - May 2003. The reviews were performed to
determine whether fire brigade drills had been conducted in high fire risk plant areas
and whether fire brigade personnel qualifications, drill response, and performance met
the requirements of the FPP.
The inspectors walked down the fire brigade staging and dress-out areas in the turbine
building to assess the operational readiness of fire fighting and smoke control
equipment. Fire brigade personal protective equipment located at both of the fire
brigade dress-out areas and fire brigade house were reviewed to evaluate equipment
accessibility and functionality. The fire brigade self-contained breathing apparatuses
were reviewed for adequacy as well as the availability of supplemental breathing air
tanks and the capability to refill these tanks.
The inspectors reviewed fire fighting pre-fire plans for the selected fire areas to
determine if appropriate information was provided to fire brigade members to identify
SSD equipment and instrumentation, and to facilitate suppression of a fire that could
impact safe shutdown capability. The inspectors walked down the selected fire areas to
compare the associated pre-fire plans and drawings with as-built plant conditions. This
was done to verify that fire fighting pre-fire plans and drawings were consistent with the
8
fire protection features and potential fire conditions described in the FPPR. In addition,
the team reviewed drawings and engineering calculations associated with fire
suppression-caused flooding for a fire in FZ 67. The review focused on the floor and
equipment drain systems to confirm that actions required for SSD would not be inhibited
by fire suppression activities or leakage from manual fire suppression systems within the
fire area or from an adjacent area.
The inspectors reviewed licensee engineering department standards and design control
procedures to verify that plant changes were adequately reviewed for the potential
impact on the FPPR, SSD equipment, and procedures as required by Turkey Point
Operating License Condition 3.D. The inspectors reviewed criteria in licensee
engineering standard STD-M0006, Engineering Guidelines for Fire Protection, and QI-
PTN-1, Design Control, to verify that risk significant plant modifications were developed,
reviewed, and approved per the procedure requirements.
b.
Findings
Failure to Provide Adequate Concrete Curb Height and Volume for the Unit 4 Generator
Hydrogen and Seal Oil Unit Oil-Retention Basin
A finding was identified in that the curbing height and volume of the oil-retention basin
for the Unit 4 Generator Hydrogen and Seal Oil Unit would not fully contain an
inadvertent oil spill from the unit, thereby preventing an oil-based fire from spreading to
surrounding areas or into the turbine building floor drain system. A failure of the Unit 4
generator hydrogen and seal oil unit tank, piping or joints could overflow the existing 6-
inch curb, spread oil onto the turbine building floor and into two nearby floor drains on
the east and west sides of the curbed oil-retention basin. Hot energized equipment
located in the vicinity could ignite this combustible oil resulting in a wide-area fluid fire.
The inspectors were concerned that the oil-retention basin curbing height and volume
would not prevent inadvertent oil flow or oil-based fire from spreading to surrounding
areas and to the drainage system as described in the Turkey Point UFSAR. The
licensee entered this issue into its CAP as CR 04-0477.
Pending additional NRC inspection, this finding is identified as URI 05000251/2004007-
004, Inadequate Concrete Curb Height and Volume for the Unit 4 Generator Hydrogen
and Seal Oil Unit Oil-Retention Basin.
.03
Post-fire Safe Shutdown Circuit Analysis
a.
Inspection Scope
Using the SSAR, the inspectors reviewed how systems would be used to achieve and
maintain reactivity control, over-pressure protection, inventory control with high or low
pressure injection systems, and residual heat removal during and following a fire in the
areas selected for inspection. The inspection specifically focused on the minimum
required systems and equipment necessary to achieve and maintain hot shutdown
conditions because damage to these systems could pose a significantly greater risk
than damage to systems required to achieve cold shutdown conditions.
9
The team made a detailed review of a number of valves, instruments and other
equipment relative to a postulated fire in each of the selected three fire areas. This
review included examination of the licensees essential equipment list, power supply,
essential cable list with routing information, resolution of potential problem cables,
elementary control diagrams and special fire response procedures. The inspectors
walked down these fire areas to compare the actual plant configuration to the layout
indicated on the drawings.
The potential for spurious valve operation or malfunction was considered in the period
immediately following a fire and in the period after operator realignment to hot standby
mode but before fire extinguishment. The inspectors also utilized this information to
determine if the requirements of 10 CFR 50, Appendix R, Section III.G.2 (for protection
of control and power cables) were met. In the case of a severe control room fire,
alternative safe shutdown capability was considered. The applicable criterion was that a
fire would not degrade the ability to safely shutdown from the ASP. The components
and equipment included in the review are listed in the attachment. Unit 3 components
were reviewed in relation to the MCR and the Unit 3 Reactor Control Rod Equipment
Room, and Unit 4 components were reviewed in relation to the 4B 4160 V switchgear
room.
Coordination of alternating current power and direct current (DC) control protective
devices was considered in terms of fire-induced short circuits resulting in loss of SSD
capability. Specific control circuits reviewed were LCV-3/4-115B and the 4B component
cooling water pump breaker.
b.
Findings
Failure to Prevent Spurious Operation of Charging Pump Suction From RWST Valves
LCV-3-115B and LCV-4-115B
Introduction: A finding was identified for failure to protect the control circuits for level
control valves (LCV) LCV-3-115B and LCV-4-115B, RWST to charging pump valves, to
prevent spurious operation during a fire. This finding is applicable to FA T (FZ 63) on
Unit 3 and FA U (FZ 67) on Unit 4. The finding is a URI pending completion of the SDP.
Description: Per the SSAR, charging pump flow from the RWST is the assured method
for providing makeup water to the RCS. Valve LCV-3/4-115B is an air powered,
solenoid-controlled valve in a flow path between the RWST and the charging pumps
suction header. Electric power for the valve is 125 VDC, and the logic is energize to
open. The valve can be controlled from the MCR or the ASP. Because the control
cable for this valve is unprotected in FZ 63 and FZ 67, thermal insult to the control circuit
for the valve could cause the valve to spuriously close.
The team noted procedure 0-ONOP-016.10 directs the operators to stop the 3A
charging pump, if it is running, immediately after the start of a fire in FZ 63 (4A charging
pump for FZ 67). Valve LCV-3/4-115B is opened within one hour from the control room
to establish the RWST as a suction source for the charging pumps. Procedure 0-
ONOP-016.10 then directs starting the 3A charging pump (4A charging pump for FZ
67). If valve LCV-3/4-115B spuriously closes due to a fire-induced thermal insult, loss of
10
the RWST as a suction source could lead to charging pump damage. Two other
charging pumps are installed. For FZ 63, the 3B charging pump would not be available
if 3A charging pump is damaged. However, the 3C charging pump would be available
to provide RCS makeup flow. For FZ 67, the 4B pump may not have power because it
is powered from the 4B 4160 V bus which is in FZ 67. The 4C pump, a Train A/B swing
pump, would not be available because its power supply is procedurally tripped due to
diesel generator loading considerations. The licensee entered this finding into its CAP
as CR 04-0683 and resolved this concern by revising 0-ONOP-016.10.
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following a severe fire. The
finding is greater than minor because it is associated with the protection against external
factors attribute and degraded the reactor safety mitigating systems cornerstone
objective. The finding degraded the defense-in-depth for fire protection. This finding is
applicable to FZ 63 and FZ 67 and is unresolved pending completion of a significance
determination.
Enforcement: 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants
licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of
Appendix R,Section III.G. Section III.G.2 states, in part, that where cables or
equipment, including associated non-safety circuits that could prevent operation or
cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant
trains of systems necessary to achieve and maintain hot shutdown conditions are
located within the same fire area outside of primary containment, one of three means of
ensuring that one of the redundant trains is free of fire damage shall be provided.
Contrary to the above, on February 13, 2004, the inspectors identified that the licensee
failed to protect control circuits and cables that could cause maloperation of valves
LCV-3-115B and LCV-4-115B. This condition has existed since at least February 9,
2001, on Unit 3 and since at least May 9, 2001, on Unit 4, when the applicable
procedure pages were last revised. The finding and related violation are unresolved
pending completion of a significance determination. This finding is identified as URI
05000250,251/2004007-005, Failure to Prevent Spurious Operation of Charging Pump
Suction From RWST Valves LCV-3-115B and LCV-4-115B.
.04
Alternative Shutdown Capability
a.
Inspection Scope
The licensees SSAR and plant configuration were reviewed to determine the
components and systems necessary to achieve and maintain SSD conditions from the
ASP in the event of fire in the MCR. The objectives of this evaluation were to:
Verify that the licensee's alternative shutdown methodology had correctly identified
the components and systems necessary to achieve and maintain an SSD condition.
Confirm the adequacy of the systems selected for reactivity control, reactor coolant
makeup, reactor heat removal, process monitoring and support system functions.
Verify that hot and cold shutdown from outside the MCR can be achieved and
maintained with offsite power available or not available.
11
Because Train B is relied upon to achieve SSD during a severe fire in the MCR and
offsite power may be lost, the team evaluated Unit 4s Train B 4160 V normal power
supply circuit breaker to determine if it could be disabled due to the fire and possibly
prevent the Train B emergency diesel generator output breaker from closing.
Additionally, the team reviewed a sample of control circuits and fuse coordination
applications to confirm that transfer of controls from the MCR to the ASP would not be
affected by fire in the control room.
b.
Findings
No findings of significance were identified.
.05
Operational Implementation of Alternative Shutdown Capability
a.
Inspection Scope
The team reviewed the operational implementation of the alternative SSD capability that
would be used during a severe fire in the MCR (FZ 97, 106 and 106R). This review
functioned to determine if: (1) the training program for licensed personnel included
alternative SSD capability; (2) personnel required to achieve and maintain the plant in
hot standby following a fire using the ASP could be provided from normal onsite staff,
exclusive of the fire brigade; (3) the licensee had incorporated the operability of
alternative shutdown transfer and control functions into plant administrative procedures;
and (4) the licensee periodically performed operability testing of the alternative
shutdown instrumentation, and transfer and control functions.
The team reviewed and walked down the following procedures that implemented the
licensees alternative SSD strategy:
0-ONOP-105, Control Room Evacuation
- Attachment 5, Third Licensed Reactor Control Operator
- Attachment 7, Non-fire Brigade Number 1 Senior Nuclear Plant Operator
- Attachment 8, Non-fire Brigade Number 2 Senior Nuclear Plant Operator
The procedure reviews focused on ensuring that all required functions for post-fire safe
shutdown, and the corresponding equipment necessary to perform those functions,
were included in the procedures. The team walked down each attachment listed above
to verify that local manual operator actions were feasible and could be performed in a
timely manner.
b.
Findings
1. Local Manual Operator Actions to Protect RCP Thermal Barrier Cooling Valves
MOV-3-716A and MOV-4-716A Not Timely
Introduction: A finding was identified for failure to ensure local manual operator actions
to verify correct alignment of MOV-3-716A and MOV-4-716A, Unit 3 and Unit 4 RCP
12
thermal barrier component cooling water supply isolation valves, were completed in a
timely manner for a fire in FA MM (FZ 106, 106R, or 97). The finding is a URI pending
completion of the SDP.
Description: Fire Area MM includes the MCR, the MCR roof, and the Unit 3 and 4
mechanical equipment room. Per the SSAR, thermal barrier cooling is the assured
method for protecting the RCP seals during a severe fire in FA MM because charging
pump seal injection flow may be terminated by operator action or lost due to the fire.
Guidance in 0-ONOP-105 directs local manual operator actions to prevent, or recover
from, spurious closure of MOVs that could interrupt thermal barrier cooling. The
inspectors identified that 0-ONOP-105, Attachment 7 (Unit 3) and Attachment 8 (Unit 4)
allowed 20 minutes to complete the operator actions for verifying that MOV-3-716A and
MOV-4-716A were open. However, industry analyses [Westinghouse Direct Work No.
DW-94-011; Westinghouse WCAP-10541, Revision 2; and Westinghouse WCAP-
15603, Revision 1-A] have determined that seal package damage could occur within 13
minutes of loss of all seal package cooling. Thus, the operator guidance provided in 0-
ONOP-105 does not provide timely action and could possibly result in an RCP seal
LOCA. Loss of RCS inventory due to an RCP seal LOCA could be beyond the capacity
of equipment dedicated to achieve and maintain post-fire safe shutdown. The licensee
entered the finding into its CAP as CR 04-0688 and resolved this concern by revising
0-ONOP-105.
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following a severe fire. The
finding is greater than minor because it is associated with the protection against external
factors attribute and degraded the reactor safety mitigating systems cornerstone
objective. The finding degraded the defense-in-depth for fire protection. This finding is
applicable to FA MM and is unresolved pending completion of a significance
determination.
Enforcement: 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants
licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of
Appendix R,Section III.G. Section III.G.3 states that alternative shutdown capability
should be provided where the protection of systems whose function is required for hot
shutdown, does not satisfy the requirements of III.G.2. Section III.L of Appendix R
provides requirements to be met by alternative shutdown methods. Section III.L.2.b
states, in part, that The reactor coolant makeup function shall be capable of
maintaining the reactor coolant level...within the level indication in the pressurizer in
PWRs.
Contrary to the above, on February 13, 2004, the inspectors identified that the
alternative shutdown capability specified for a fire in the Fire Area MM did not meet this
requirement. Specifically, the licensees procedure may not mitigate a spurious closure
of valves MOV-3-716A and MOV-4-716A in a timely manner, possibly resulting in an
RCP seal LOCA, and pressurizer level dropping below the indicating range. This
condition has existed since at least April 24, 2002, when the applicable procedure pages
were last revised. This finding and related violation are unresolved pending completion
of a significance determination. This finding is identified as URI
05000250,251/2004007-006, Local Manual Operator Actions to Protect RCP Thermal
13
Barrier Cooling Valves MOV-3-716A and MOV-4-716A For Control Room Evacuation
Not Timely.
2. Local Manual Operator Actions Not Evaluated for Availability of Security Support
Introduction: A finding was identified for local manual operator actions that may not be
timely due to reliance on security support to bring a vital area security key to access
normally locked rooms which do not have a security card key readers. The finding is a
URI pending completion of the SDP.
Description: The inspectors identified that certain local manual operator actions for a fire
in FA MM (FZ 106, 106R, or 97) require access to rooms through doors that are only
accessible with a vital access security key (i.e., no security card key readers are
installed at these doors). Operators do not carry vital access security keys with them
and 0-ONOP-105 does not require vital access security keys be brought when the MCR
is evacuated. Instead, security support is required to bring access keys to the operator.
However, operator access to key-locked rooms is not ensured because security support
could be diverted to higher priority activities. Consequently, local manual operator
actions may be delayed and may not be completed in a timely manner to ensure that
safe shutdown is achieved. The licensee entered the finding into its CAP as CR
04-0700 and resolved this concern by adding a security key to the operator key rings.
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following a severe fire. The
finding is greater than minor because it is associated with the protection against external
factors attribute and degraded the reactor safety mitigating systems cornerstone
objective. The finding degraded the defense-in-depth for fire protection. This finding is
applicable to FA MM and is unresolved pending completion of a significance
determination.
Enforcement: 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants
licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of
Appendix R,Section III.G. Section III.G.3 states that alternative shutdown capability
should be provided where the protection of systems whose function is required for hot
shutdown, does not satisfy the requirements of III.G.2. Section III.L of Appendix R
provides requirements to be met by alternative shutdown methods. Section III.L.2.b
states, in part, that The reactor coolant makeup function shall be capable of
maintaining the reactor coolant level...within the level indication in the pressurizer in
PWRs.
Contrary to the above, on February 13, 2004, the alternative shutdown capability
specified for a fire in Fire Area MM did not meet this requirement. Specifically, operator
access to key-locked rooms is not ensured because security support could be diverted
to higher priority activities. Consequently, local manual operator actions may be
delayed and may not be completed in a timely manner to ensure that RCP thermal
barrier cooling is protected/restored, thereby ensuring an RCP seal LOCA does not
occur and ensuring that pressurizer level remains in the indicating range. This condition
has existed since at least April 24, 2002, when the applicable procedure pages were last
revised. This finding and related violation are unresolved pending completion of a
14
significance determination. This finding is identified as URI 05000250,251/2004007-
007, Local Manual Operator Actions For Control Room Evacuation Not Evaluated for
Availability of Security Support.
.06
Communications
a.
Inspection Scope
The inspectors reviewed plant communication capabilities to evaluate the availability of
the communication systems to support plant personnel in the performance of SSD local
manual operator actions, fire event notification, and fire brigade fire fighting duties. The
inspectors walked down sections of the fire protection equipment surveillance
procedures and observed operational checks of the fire brigade portable radios. The
inspectors also assessed the radio system repeater tower and power equipment for
proper operation and vulnerability to a fire in the selected fire areas. In addition, the
inspectors reviewed the fire brigade drill critiques to identify any history of operational or
performance problems with the fire brigade command post radio communications during
fire drills. In addition, the team reviewed the fire brigade radio communications systems
to assess whether the licensees radio channel features would continue to operate
should the radio repeaters for the primary communications system be unavailable.
b.
Findings
No findings of significance were identified.
.07
a.
Inspection Scope
The inspectors reviewed the design, placement, operation, and periodic testing
procedures for DC self-contained battery powered emergency lighting units (ELU) and
dedicated, battery powered portable ELUs. The inspectors evaluated the capability of
the ELUs to support plant personnel in the performance of SSD functions, including
local manual operator actions, and for illuminating access and egress routes to the
areas where those manual actions would be performed. The inspectors checked that
these battery power supplies were rated with at least an 8-hour capacity, as required by
Section III.J of 10 CFR 50, Appendix R. During inspector walk downs of the plant areas
where operators performed local manual actions, the inspectors inspected area ELUs
for proper operation and checked the aiming of lamp heads to determine if sufficient
illumination would be available to adequately illuminate the SSD equipment, the
equipment identification tags, and the access and egress routes thereto, so that
operators would be able to perform the actions without needing to use flashlights. The
inspectors also reviewed completed surveillance and maintenance procedures and test
records to ensure that the licensee properly maintained the lighting equipment.
The inspectors observed whether emergency exit lighting was provided for personnel
evacuation pathways to the outside exits as identified in the National Fire Protection
Association (NFPA) 101, Life Safety Code, and the Occupational Safety and Health
Administration (OSHA) Part 1910, Occupational Safety and Health Standards. This
15
review also included examination of whether backup emergency lighting was provided
for access pathways to the fire brigade staging and dress-out areas in support of fire
brigade operations should power fail during a fire emergency.
b.
Findings
No findings of significance were identified.
.08
Cold Shutdown Repairs
a.
Inspection Scope
The licensees SSAR did not identify a need for post-fire repairs to achieve a cold
shutdown condition. Thus, cold shutdown repairs were not reviewed during this
inspection. However, the inspectors reviewed the Unit 3 General Operating Procedure
(GOP) 3-GOP-305, Hot Standby to Cold Shutdown, to evaluate those components and
instruments used to achieve cold shutdown and assessed the availability of this
equipment (without repair) following a severe fire in the Unit 3 Reactor Control Rod
Equipment Room (FZ 63).
b.
Findings
No findings of significance were identified.
.09
Fire Barriers and Fire Area/Zone/Room Penetration Seals
a.
Inspection Scope
The inspectors reviewed the selected fire areas to evaluate the adequacy of the fire
resistance of fire area barrier enclosure walls, ceilings, floors, fire barrier mechanical
and electrical penetration seals, fire doors, and fire dampers to ensure that at least one
train of SSD equipment would be maintained free of fire damage. The inspectors
selected several fire barrier features for detailed evaluation and inspection to verify
proper installation and qualification. The inspectors walked down the selected fire areas
to observe the material condition and configuration of the installed fire barrier features.
The inspectors also reviewed construction details and supporting fire endurance tests
for the installed fire barrier features to verify the as-built configurations were qualified by
appropriate fire endurance tests. In addition, the inspectors reviewed the FHA to verify
the fire loading used by the licensee to determine the fire resistance rating of the fire
barrier enclosures.
The inspectors conducted a detailed inspection of the two fire rated concrete block fire
walls in FZ 67 to confirm proper qualification and installation. Additionally, the
inspectors reviewed the design and qualification testing of four fire doors from FZ 63
and 67 as well as the surveillance procedures for these fire doors. These reviews were
performed to ensure that the passive fire barriers were properly maintained and met the
licensing and design bases as described in the licensing submittals, NRC SERs, and the
FPPR.
16
The inspectors selected seven penetration fire seals (063S-E003, 063E-E005, 063F-
E006, 067N-E002, 067N-E003, 067S-E006, and 067W-E001) in FZ 63 and 67. A
detailed inspection of these seals was conducted to confirm proper qualification and
installation. The inspectors reviewed the installation instructions for the mechanical and
electrical penetrations, the penetration seal database, Generic Letter 86-10 evaluations,
and the fire protection penetration seal deviation analysis to verify that the fire barrier
installations met design requirements and license commitments. The inspectors also
compared the penetration seal ratings with the ratings of the barrier enclosures in which
they were installed. In addition, the inspectors reviewed a summary of completed
surveillance and maintenance procedures for the selected fire barrier walls to verify the
fire seals were being adequately inspected and maintained.
The team reviewed abnormal operating fire procedures, selected fire fighting pre-plans,
fire damper location and detail drawings, and heating, ventilation and air conditioning
system drawings to verify that access to shutdown equipment and selected operator
manual actions would not be inhibited by smoke migration from one area to adjacent
plant areas used to accomplish SSD. The inspectors reviewed the design, installation
details, and qualification testing for two mechanical fire dampers in the MCR to verify
that the damper installations met design requirements and license commitments.
b.
Findings
No findings of significance were identified.
.10
Fire Protection Systems, Features and Equipment
a.
Inspection Scope
The inspectors reviewed SSAR calculations, vendor documentation, flow diagrams,
cable routing information, operational valve lineup procedures, and system availability
studies associated with the fire pumps and fire protection water supply system. The
review evaluated whether the common fire protection water delivery and supply
components could be damaged or inhibited by fire-induced failures of electrical power
supplies or control circuits. The inspectors examined the electric motor-driven fire pump
and diesel-driven fire pump to observe system material condition, evaluate the
consistency of as-built configurations with engineering drawings, and determine proper
system controls and valve lineups. Additionally, the inspectors reviewed periodic
surveillance and functional operability test procedures for the fire pumps to assess
whether the test program was sufficient to verify proper operation of the fire protection
water supply system.
For the selected fire areas, the inspectors reviewed the adequacy of the design,
installation, and operation of the automatic detection and alarm system to actuate in the
early stages of a fire. This included walk downs of the system and an examination of
the types of detectors, detector spacing, and the licensees technical evaluation of the
detector locations, and the ceiling reinforcing plans, as shown on location drawings.
The inspectors also reviewed the licensees submittals and associated NRC SERs for
the selected fire areas. These reviews were performed to ensure that the fire detection
systems for the selected fire areas were installed in accordance with the design and
17
licensing bases of the plant. Additionally, the team reviewed fire detection surveillance
procedures and the detection system operating requirements specified in 0-ADM-016 to
determine the adequacy of fire detection component testing and to ensure that the
detection systems could function when needed.
The inspectors reviewed the manual suppression standpipe and fire hose system to
verify adequate design, installation, and operation in the selected fire areas. The
inspectors examined flow measurement/pressure test data to verify that sufficient
pressure and flow volume were available to produce effective fire hose nozzle patterns.
During plant walkdowns, the inspectors observed placement of the fire hoses and
extinguishers to confirm consistency with the fire fighting pre-plan drawings.
Additionally, the inspectors checked a sample of fire hose lengths to confirm they could
reach the affected fire zones in support of manual fire fighting efforts.
b.
Findings
1. Potentially Inadequate Ionization Smoke Detector Placement and Spacing in the 4B
4160 V Switchgear Room
A finding was identified in that the placement of the ionization product of combustion
(POC) detectors installed in the 4B 4160 V switchgear room, which deviated from the
Underwriters Laboratory (UL) tested configuration, was not adequately evaluated. The
licensee installed ten ionization POC detectors in the room. Six detectors were installed
over cable trays that were routed along the north and south sides of the room. Four
were installed at the ceiling height of 23 feet. Ionization POC detectors are listed by UL
to be installed on a smooth ceiling that does not exceed 15 feet 9 inches in height with a
maximum distance between detectors of 30 feet. The inspectors were concerned that
the detectors, in the current configuration, will not quickly detect early stage flaming or
smoldering fires in the 4B 4160 V Switchgear Room as described in the Turkey Point
UFSAR. The licensee entered this issue into the CAP as CR 04-0686.
Pending additional NRC inspection, this is identified as URI 05000251/2004007-008,
Potentially Inadequate Ionization Smoke Detector Installation in the 4B 4160 V
Switchgear Room.
2. Failure to Install Detection and Fixed Suppression in Fire Zone 97
Introduction: A non-cited violation (NCV) of 10 CFR 50, Appendix R, Section III.G.3 and
License Condition 3.D was identified for failure to provide full area fire detection and a
fixed suppression system in the Unit 3 and 4 mechanical equipment room for fires in
Fire Area (FA) MM [Fire Zone (FZ) 97].
Description: On January 28, 2004, the inspectors walked down the fire protection
features of FZ 97. This room contained the safety-related emergency recirculating filter
unit and air handling supply fans for the MCR. Unprotected ventilation control cables
and safety-related process monitoring cables were also routed within the room. As part
of FA MM, the FPPR identified the room as an alternative SSD area [along with the
MCR (FZ 106) and the control room roof (FZ 106R)]. The inspectors observed that no
full area detection system existed on the ceiling areas or within beam pockets above the
18
emergency filter unit or air handling supply fans. Additionally, the room did not have a
full area fixed suppression system. The inspectors noted that one duct-mounted smoke
detector was installed within the emergency recirculating filter unit exhaust duct.
However, the function of this detector was to detect a fire within the charcoal filter unit
and not to provide area detection.
The licensee determined that the emergency filter unit and air handling supply fans were
cross-train safety-related equipment used for the emergency recirculating mode of MCR
heating ventilation and air conditioning (HVAC) operation. As such, they were neither
protected nor credited for Appendix R safe shutdown. However, the emergency
recirculating air handling motors are credible fire ignition sources such that a single fire
could damage cross-train safety-related systems or components. The licensee declared
the detection and suppression inoperable on the day of discovery and established an
hourly roving fire watch for FZ 97 (and 106R).
Analysis: The finding adversely affected the fire detection and suppression capability
defense-in-depth elements. The finding is greater than minor because it is associated
with the protection against external factors attribute and degraded the reactor safety
mitigating systems cornerstone objective. The inspectors analyzed the finding using
Manual Chapter 0609, Appendix F. Because neither fire detection nor fixed suppression
were available in FZ 97, Phase 1 directed that a Phase 2 analysis be performed.
Because the fire ignition frequency was low (the emergency recirculating air handling
motors are not continuously used), the fire detection in the emergency recirculating filter
was not degraded, and alternative shutdown systems and procedures were available to
mitigate a fire in this area, the finding was determined to have very low safety
significance (Green).
Enforcement: Turkey Point Operating License Condition 3.D specifies, in part, that the
licensee implement and maintain in effect all provisions of the approved fire protection
program as described in the UFSAR and as approved in the SER dated September 19,
1979, and subsequent supplements. Turkey Point UFSAR, Section 3.5.1, Fire
Detection Systems, states that fire detection instrumentation ensures that adequate
warning capability is installed in areas of the plant that contain or present a possible fire
hazard to safety related components. In addition, 10 CFR 50, Appendix R, Section
III.G.3 states that fire detection and a fixed fire suppression system shall be installed in
the area, room, or zone where alternative or dedicated shutdown capability is being
provided.
Contrary to the above, on January 28, 2004, Fire Zone 97 did not have the required full
area wide detection and fixed suppression systems installed. This condition has existed
since 1984 when the licensee incorporated this room as an extension of the MCR
pressure boundary. Because the finding is of very low safety significance and because
it has been entered into the CAP (CR 04-0688), this violation is being treated as an
NCV, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000250,251/
2004007-009, Failure to Install Full Area Wide Detection and Fixed Suppression
Systems in the Unit 3 and 4 Mechanical Equipment Room.
19
.11
Compensatory Measures
a.
Inspection Scope
The inspectors reviewed the administrative controls for out-of-service, degraded, and/or
inoperable fire protection features. The review was performed to verify that the risk
associated with removing fire protection and/or post-fire systems or components from
service was properly assessed and adequate compensatory measures were
implemented in accordance with the approved FPP. The inspectors also reviewed the
adequacy of short-term compensatory measures to compensate for a degraded function
or feature until appropriate corrective actions were taken.
b.
Findings
No findings of significance were identified.
.12
Fire Protection Licensing Basis
a.
Inspection Scope
The inspectors reviewed licensing basis documents, including but not limited to SERs
and Appendix R exemptions, to ascertain if the Turkey Point FPP was consistent, and in
compliance, with 10 CFR 50.48 and 10 CFR 50, Appendix R. The inspectors evaluated
and compared the licensees SSD procedures, the FPPR, and various calculations of
record against the licensing basis to measure the adequacy and consistency of the
program documentation.
b.
Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
a.
Inspection Scope
The inspectors reviewed a sample of licensee audits, self-assessments and CRs to
verify that items related to the Turkey Point FPP, and the capability to successfully
achieve and maintain the plant in a SSD condition following a plant fire, were
appropriately entered into the licensees corrective action program in accordance with
the Turkey Point quality assurance program and procedural requirements. Included in
this review were CRs resulting from fire, smoke, sparks, arcing, and equipment
overheating incidents for the last 18 months to assess the frequency of fire incidents
and to identify any maintenance or material condition problems related to fire incidents.
In addition, the team reviewed the licensees evaluations and corrective actions for
selected industry experience issues related to the fire protection area. Operating
experience issues, also reviewed by the inspectors, included NRC Information Notices,
20
industry or vendor-generated reports of defects and noncompliance under 10 CFR Part 21, and vendor information letters. All items selected were reviewed for classification
and appropriateness of the corrective actions taken, or initiated, to resolve the issues.
The items reviewed are listed in the attachment.
b.
Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On February 13, 2004, the lead inspector presented the inspection results to
Mr. T. Jones and other members of his staff who acknowledged the findings. The
licensee confirmed that proprietary information was not provided or examined during the
inspection. Following completion of additional review in the Region II office, a final exit
was held by telephone with Mr. W. Prevatt and other members of your staff on
March 26, 2004, to provide an update on changes to the preliminary inspection findings.
The licensee acknowledged the findings.
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel:
V. Barry, Assistant Nuclear Plant Supervisor
F. Busch, Fire Protection Supervisor
S. Chaviano, Plant Engineering Manager
A. Dunstan, Fire Protection Engineer
M. Eades, Quality Assurance
O. Hanek, Licensing
T. Jones, Site Vice-President
M. Lacal, Operations Manager
J. Laduca, Engineering Mechanical Design Supervisor
T. Miller, Maintenance Manager
W. Parker, Licensing Manager
M. Pierce, Plant General Manager
W. Prevatt, Work Control Manager
B. Stamp, Operations, Supervisor
T. Sweeney, Engineering Electrical Supervisor
B. Thaker, Electrical Engineer
G. Warriner, Site Quality Manager
A. Zielonka, Manager Engineering
NRC personnel:
K. Weaver, Senior Resident Inspector
K. Green-Bates, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Failure to Prevent Spurious Operation of Valve
MOV-4-626 For a Severe Fire in 4B 4160 V
Switchgear Room (Section 1R05.01.b.1)
05000250,251/2004007-002
Local Manual Operator Actions to Protect RCP
Seal Package Cooling Not Timely (Section
1R05.01.b.2)05000251/2004007-003
Local Manual Operator Actions Not Evaluated for
Loss of Security Card Key Access For a Severe
Fire in 4B 4160 V Switchgear Room (Section
1R05.01.b.3)05000251/2004007-004
Inadequate Concrete Curb Height and Volume for
the Unit 4 Generator Hydrogen and Seal Oil Unit
Oil-Retention Basin (Section 1R05.02)
2
ATTACHMENT
05000250,251/2004007-005
Failure to Prevent Spurious Operation of Charging
Pump Suction From RWST Valves LCV-3-115B
and LCV-4-115B (Section 1R05.03)
05000250,251/2004007-006
Local Manual Operator Actions to Protect RCP
Thermal Barrier Cooling Valves MOV-3-716A and
MOV-4-716A For Control Room Evacuation Not
Timely (Section 1R05.05.b.1)
05000250,251/2004007-007
Local Manual Operator Actions For Control Room
Evacuation Not Evaluated for Availability of
Security Support (Section 1R05.05.b.2)05000251/2004007-008
Potentially Inadequate Ionization Smoke Detector
Installation in the 4B 4160 V Switchgear Room
(Section 1R05.10.b.1)
Opened and Closed
05000250,251/2004007-009
Failure to Install Full Area Wide Detection and
Fixed Suppression Systems in the Unit 3 and 4
Mechanical Equipment Room (Section
1R05.10.b.2)
Discussed
None
3
ATTACHMENT
LIST OF COMPONENTS INSPECTED
Section 1R05.03: Post-Fire Safe Shutdown Capability
Component Identification
Description
LCV-3(4)-115C
Volume control tank outlet valve (MOV)
LCV-3(4)-115B
RWST to charging pump valve (AOV)
CV-3(4)-303B
RCP 3B #1 seal leakoff control valve (AOV)
MOV-3(4)-350
Boric acid injection stop valve
HCV-3(4)-121
Charging flow control valve (AOV)
MOV-3(4)-716B
RCP thermal barrier component cooling water supply
isolation valve
MOV-3(4)-626
RCP thermal barrier component cooling water return
isolation valve
PI-3-406-1
RCS pressure indicator (at auxiliary shutdown panel)
LI-3-462-1
RCS pressurizer level (at auxiliary shutdown panel)
NI-4-6649B-3
Excore neutron flux detector (at auxiliary shutdown panel)
AHU 4E243B
Air handling unit
AHU 4E244A
Air handling unit
EDG 4B
Voltmeter and wattmeter (at auxiliary shutdown panel)
LIST OF DOCUMENTS REVIEWED
Procedures
0-ADM-016, Fire Protection Program, Rev. 01/10/02
0-ADM-016.1, Transient Combustible and Flammable Substances Program, Rev. 11/30/00
0-ADM-016.2, Fire Brigade Program, Rev. 11/01/01
0-ADM-016.2, Fire Brigade Program, Rev. 10/09/01
0-ADM-016.3, Fire Protection Impairments (FPI), Rev. 04/16/02
0-ADM-016.4, Fire Watch Program, Rev. 02/06/02
0-ADM-016.5, Hot Work Program, Rev. 11/30/00
0-ADM-101, Procedure Writers Guide, Enclosure 8, Action Verb/Terms, Rev. 03/30/01
0-ONOP-016.10, Pre-plan Guidelines and Safe Shutdown Manual Actions, Rev. 10/04/03
0-ONOP-016.10, Pre-Fire Plan, Fire Zone 63, Rev. 02/09/01
0-ONOP-016.10, Pre-Fire Plan, Fire Zone 67, Rev. 02/09/01
0-ONOP-105, Control Room Evacuation, Attachments 5, 7 and 8, Rev. 10/19/03
0-OSP-016.23, Diesel Driven Fire Pump Operability Test, Rev. 05/23/03
0-OSP-016.26, Electric Driven Fire Pump Operability Test, Rev. 08/06/03
0-SFP-016.5, Fire Protection Equipment Surveillance, Rev. 04/12/02
0-SME-091.1, Fire and Smoke Detection System Annual Test, Rev. 12/10/01
3-OSP-300.1, Alternate Shutdown Panel 3C264 Operability Test, Rev. 09/29/03
3-OSP-300.2, Pre-Staging Equipment and Alternate Shutdown Panel 3C64 Switch and
Instrumentation Alignment Check, Rev. 11/02/01
4
ATTACHMENT
3-SOP-300.2, Pre-Staging Equipment and Alternate Shutdown Panel 3C264 Switch and
Instrumentation Alignment Check, Rev. 01/10/01
3/4-EOP-E-0, Reactor Trip or Safety Injection, Rev. 05/28/03
PM-016017, 60 Month Diesel Fire Pump Outlet Valve 10-757 Operability Inspection, Rev.
3102353001
QI 2-PTN-4, Housekeeping, Rev. 03/09/99
Drawings
5610-A-63, Fire Walls, Doors, Dampers & Fireproofing, Rev. 12
5610-A-178 Series, Fire Barriers and Penetrations, Rev. 100
5610-C-13, Utility Piping, Main Plant Area, Rev. 20
5610-C-302, Control Building Ground Floor Slab, Plan and Details, Rev. 8
5610-C-375, Yard Tanks & Equipment Foundation Details, Rev. 7
5610-C-377, Transformer Foundations Concrete & Reinforcing Details, Rev. 9
5610-C-1354, Turbine Building Masonry Wall Modifications Sections and Details, Rev. 7
5610-C-1371, Turbine Building Masonry Wall Modifications Plans and Sections, Rev. 6
5610-E-1, Sheet 1, Main Single Line Unit 3, Rev. 33
5610-E-1, Sheet 2, Main Single Line Unit 4, Rev. 8
5610-E-27, Sheet 3Y, Elementary Diagram, Mechanical Auxiliaries Fire Pump Control Breaker
30305, Rev. 4
5610-E-27, Sheet 3Y1, Elementary Diagram, Mechanical Auxiliaries Fire Pump Motor P39,
Rev. 1
5610-E-144, Tray, Conduit & Grounding Miscellaneous Details, Rev. 31
5610-E-761, Technical Support Center 480V Distribution Panel DP85, Rev. 8
5610-E-855, Breaker List for Diesel Fire Pump Area (DP-85), Rev. 325
5610-E-938, Fire Detection 4.16 KV Swgr. & 480V Load Center Rooms, Rev. 3
5610-J-539P, Instrument Loop Diagram RCS Pressure Indication Alternate Shutdown, Rev. 4
5610-M-430-204, Instrument Loop Diagram, Charging Pump Pressure Discharge Flow & CVCS
Hand Controls, Rev. 3
5610-M-3016, Fire Protection System Fire Pumps, Rev. 14
5610-T-E-1592, Sheet 1, 125V D.C. & 120V A.C. Electrical Distribution, Rev. 39
5613-E-25, Sheet 5B, Elementary Diagram, Reactor Auxiliaries Charging Pump 3P201B
Breaker 30203, Rev. 4
5613-E-25, Sheet 27C, Unit 3, Elementary Diagram, Reactor Auxiliaries Boric Acid Injection
Stop Valve MOV-3-350, Rev. 2
5613-E-25, Sheet 32H, Unit 3, Elementary Diagram, Reactor Auxiliaries RCP Thermal Barrier
CCW Supply Isolation Valve MOV-3-716B, Rev. 5
5613-E-25, Sheet 33A, Unit 3, Elementary Diagram, Reactor Auxiliaries RCP Thermal Barrier
C.C.W. Isolation MOV, MOV-3-626, Rev. 2
5613-E-25, Sheet 34A, Unit 3, Elementary Diagram, Reactor Auxiliaries Volume Control Tank
Low Level Isolation LCV-3-115C, Rev. 6
5613-E-25, Sheet 65B, Unit 3, Elementary Diagram, Reactor Auxiliaries Refueling Water Inlet
Stop Valve into Charging Header - 115B, Rev. 2
5613-E-25, Sheet 67B, Unit 3, Elementary Diagram, Reactor Auxiliaries RCP B Seal Water
Disch. Isolation Valve CV-3-303B, Rev. 2
5
ATTACHMENT
5613-E-25, Sheet 98A, Unit 3, Elementary Diagram, Reactor Auxiliaries Charging System
Control Valve HCV-3-121, Rev. 0
5613-E-28, Sheet 36B, Elementary Diagram, Electrical Auxiliaries Diesel Generator 3A
Relaying & Metering, Rev. 2
5613-M-3030, Sheet 5, Unit 3, Piping and Instrumentation Diagram, Component Cooling Water
System, Rev. 16
5613-M-3047, Sheet 1, Unit 3, Piping and Instrumentation Diagram, Chemical and Volume
Control System Charging and Letdown, Rev. 17
5613-M-3047, Sheet 2, Unit 3 Piping and Instrumentation Diagram, Chemical and Volume
Control System Charging and Letdown, Rev. 38
5613-M-3047, Sheet 3, Unit 3, Piping and Instrumentation Diagram, Chemical and Volume
Control System Charging and Letdown, Rev. 20
5614-E-25, Sheet 2B, Elementary Diagram, Reactor Auxiliaries Component Cooling Water PP
4B Breaker 4AB13, Rev.5
5614-E-28, Sheet 8A, Elementary Diagram, Electrical Auxiliaries Diesel Generator Breaker
4AA20, Rev. 5
5614-E-25, Sheet 8B, Unit 4, Elementary Diagram, Reactor Auxiliaries Pressurizer Heater
Backup Group 4B Breaker 40408, Rev. 3
5614-E-28, Sheet 14A, Elementary Diagram, Electrical Auxiliaries 4160V Switchgear Bus 4A
Lock Out Relay, Rev. 2
5614-E-25, Sheet 32G, Unit 4, Elementary Diagram, Reactor Auxiliaries RCP Thermal Barrier
CCW Supply Isolation Valve MOV-4-716A, Rev. 5
5614-E-25, Sheet 32H, Unit 4, Elementary Diagram, Reactor Auxiliaries RCP Thermal Barrier
CCW Supply Isolation Valve MOV-4-716B, Rev. 4
5614-E-25, Sheet 33A, Unit 4, Elementary Diagram, Reactor Auxiliaries RCP Thermal Barrier
CCW Isolation MOV, MOV-4-626, Rev. 4
5614-E-28, Sheet 1B, Elementary Diagram, Electrical Auxiliaries Auxiliary Transformer Breaker
4AB02. Rev. 8
5614-J-806, Sheet 2B, Instrument Loop Diagram Pressurizer Pressure and Level, Rev. 0
Calculations, Analyses, and Evaluations
5610-M-722, Appendix R Safe Shutdown Analysis (pages relevant to the selected fire areas)
5610-M-723, Appendix R Essential Equipment List (pages relevant to the systems reviewed)
5610-E-2000, Appendix R Essential Cable List (pages relevant to the components reviewed)
5177-265-EG-22, Breaker Fuse Coordination (pages relevant to inspection scope)
JPN-PTN-SEEP-93-011, Safety Evaluation for Potential for Loss of Remote Shutdown
Capability During a Control Room Fire, Rev. 0
JPN-PTN-SECS-93-042, Turkey Point Units 3 & 4 Evaluation for the Installation of Rain Gutters
in the Units 3B & 4B Switchgear Rooms, Rev. 2
PTN-BFSC-00-2002, Adequacy of Start-up Transformer Foundation and Basin for Transformer
Replacement, Rev. 0
PTN-C-SJ204-04, Required Thickness of Fire Walls, Rev. 0
PTN-FPE-89-003, Evaluation of Conduit Penetrations on the Door Frame for Door D063-2,
Rev. 09/29/89
PTN-FPER-96-024, Technical Evaluation to Compare a Sample Population of Penetration Fire
Seals Against Tested Configurations, Rev. 0
6
ATTACHMENT
PTN-FPER-99-005, Penetration Fire Seal Evaluations, Rev. 7
PTN-M12-202-02, Manual Actions Required to Mitigate the Consequences of Fire Damper
Closure Due to Appendix R Postulated Fire, Rev. 2
Audits and Self-Assessments
Turkey Point Nuclear Plant Appendix R and Fire Protection Program 2003 Self-Assessment,
dated 12/31/2003
Assessment-03-12, Fire Protection Self-Assessment, dated 11/21/03
Completed Surveillance Procedures and Test Records
0-SMM-016.6, Fire Door Inspection for Door No. D063-2, completed 03-13-02
0-SMM-016.6, Fire Door Inspection for Door Nos. D067-2 and D067-3, completed 04-23-03
0-SME-104.1, Self Contained, Battery Powered, Emergency Lighting Quarterly Performance
Test, dated 09/16/03
Technical Manuals/Vendor Information
Brooks Equipment Co., Inc., E15NST 1-1/2" Adjustable Fog/Shutoff Only Poly-Carbonate
Nozzle, dated 01/29/04
MRN Metron, Manual for Engine Driven Fire Pump Controllers, Model FD2-AFHJKPSV, dated
02/02/87
PTN Technical Specification for Fire Rated Hollow Metal Doors, Frames and Hardware, Rev. 1
PTN 5177-230-M-616, Technical Specification for Fire Dampers, Rev. 1
Pyrotronics Catalog Number 6119, Technical Specification for Model DI-3 Series Ionization
Smoke Detector, dated 04/87
Applicable Codes and Standards
NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1974 Edition
NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1982 Edition
NFPA 80, Standard on Fire Doors and Windows, 1975 Edition
NUREG-1552, Supplement 1, Fire Barrier Penetration Seals in Nuclear Power Plants, dated
01/99
OSHA Standard 29 CFR 1910, Occupational Safety and Health Standards
Underwriters Laboratory, Fire Resistance Directory, dated 01/98
Underwriters Laboratory Standard 555, Standard for Fire Dampers and Ceiling Dampers, dated
05/14/79
Other Documents
Exercise Guide Number 760210500 SPS-105, IC-1 Control Room Evacuation Simulator
Scenario, Rev. 2/11/02
Exercise Guide Number 760207701 SPS-07701, IC-7 S/G Tube Leak / NIS Malfunction / 3B
4KV Bus Fire Simulator Scenario, Rev. 02/23/99
7
ATTACHMENT
Exercise Guise Number 760007502 SPS-75.2, IC #20 Plant Startup / 3A EDG Failure / Loss of
All AC Simulator Scenario, Rev. 10/1/97
Fire Protection Inspection Reports for 2003
Job Performance Measure 1200012300, Respond To Control Room Evacuation Condition -
Unit 4 RCO, Rev. 07/24/03
Job Performance Measure 1200013300, Respond To Control Room Evacuation Condition -
Third Licensed RCO, Rev. 03/05/03
Job Performance Measure 1200013301, Respond To Control Room Evacuation Condition -
Third Licensed RCO, Rev. 12/01/03
Job Performance Measure 14200014300, Respond To Control Room Evacuation As Non-Fire
Brigade NPO, Rev. 12/12/01
Job Performance Measure 14200014301, Respond To Control Room Evacuation As Non-Fire
Brigade NPO, Rev. 03/17/03
Job Performance Measure 14200014302, Respond To Control Room Evacuation As Non-Fire
Brigade NPO, Rev. 03/17/03
Job Performance Measure 2200004300, Respond To Control Room Evacuation Condition -
NPS, Rev. 03/16/03
Job Performance Measure 2200019300, Respond To Control Room Evacuation Condition -
ANPS, Rev. 3/17/03
Job Performance Measure 24200016301, Respond To Control Room Evacuation As Inside
SNPO, Rev. 12/19/02
Job Performance Measure 24200017300, Respond To Control Room Evacuation As Outside
SNPO, Rev. 12/19/02
RAR ADD #0201006-O-23, Associate Nuclear Plant Operator Continuing Training
Tasks/Training Materials Matrix
RAR ADD #0201006-O-25, Nuclear Plant Operator Continuing Training Tasks/Training
Materials Matrix
RAR ADD #0201006-O-28, Senior Nuclear Plant Operator Continuing Training Tasks/Training
Materials Matrix
RAR ADD #0207053-O-02, Lesson Plan No. 6902261, 0-ONOP-016.10, Respond To A Plant
Fire, Rev. 5/23/03
RAR ADD #0207053-O-02, Lesson Package No. 6900261, 0-ONOP-016.10, Response To
Plant Fire, Rev. 05/23/03
RAR ADD #0207098-O-02, Lesson Package No. 6900252, 0-ONOP-0105, Control Room
Evacuation, Rev. 05/06/03
RAR ADD #0301008-O-11, Lesson Package No. 6900320, 0-ADM-22, EOP Introduction And
EOP/ONOP Users Guide, Rev. 12/17/03
RAR ADD #9405136-O-02, Lesson Package No. 6900019, 0-ADM-016.3, Fire Protection
Impairments (FPI), Rev. 01/18/95
RAR ADD #9801001-O-48, Lesson Package No. 760007702, Main Transformer Oil Leak/Plant
Shutdown Zion), Rev. 03/03/99
RAR ADD #9806008-O-03, System Description SD-153 (Sys. 016, 017, 091), Fire Protection,
Alternate Shutdown and Safe Shutdown Systems (App. R), Rev. 05/24/99
RAR ADD #9812152-O-01, Lesson Package No. 760007700, Main Transformer Oil/NIS
Malfunction, Rev. 02/19/99
SAP-200, Attachment 1, FEP Manning Sheet, Rev. 7
Turkey Point Combustible Storage Locker List, dated 01/27/04
8
ATTACHMENT
Turkey Point Transient Combustible Permits issued from January 2001, for Fire Zones 63, 67,
and 106
License Basis Documents
UFSAR 9.6A, Fire Protection Program Report, Rev. 17
CRs Reviewed
Corrective action program plant issues (PIs) resulting from fire, smoke, sparks, arcing, and
equipment overheating incidents for the period 2001-2003
Turkey Point Information Bulletin #03-26, Smoking Policy, dated 07/21/03
Fire Brigade Assignment Sheet for Currently Qualified Brigade Members, dated 02/11/04
Fire Brigade Qualifications List, dated 02/10/04
U. S. Consumer Product Safety Commission, Invensys Building Systems Announce Recall of
Siebe Actuators in Building Fire/Smoke Dampers, dated 10/02/02
NRC Information Notice 2003-08, Potential Flooding through Unsealed Concrete Floor Cracks,
dated 06/25/03
Southwest Research Institute, Three-hour Fire Test of Four Penetrations Sealed With Silicone
Elastomer, Hydrosil, Boots and Fiber, and Adhesive and Caps, dated 09/87
Tech-Sil Inc., Fire and Hose Stream Test # TS-TP-0018, of a Silicone Elastomer Seal in an
Electrical Penetration, dated 08/21/79
Tech-Sil Inc., Test Report #TS-TP-0084, Fire and Hose Stream Test for 6" of TS-MS-0045-B
Silicone Elastomer, dated 04/14/82
Summary of TPN Penetration Seal Inspections, dated 01/08/04
Fire Protection Impairment No. 9459, dated 02/02/04
CR 01-0011, Fire in Dryer
CR 01-0230, Fire Area CC Not Bounded by Three Hour Fire Barrier
CR 01-0293, Fire Barriers Discrepancy
CR 01-0300, Discrepancies Between Safe Shutdown Analysis and Off-Normal Operating
Procedures
CR 01-0310, Foam Installation on Chilled Water Lines Not Evaluated as Combustible
CR 01-0318, Compensatory Measures For Safe Shutdown Analysis Components
CR 01-0319, Charging Pump Room Doors Are Not Three Hour Fire Barriers
CR 01-0320, Smoke Detectors in 3B Switchgear Room Not Installed Per NFPA 72E-1982
CR 01-0326, Lack Of Halon System Testing or Calculations
CR 01-0333, Underground Cable Penetration Seals Between Fire Areas Were Not Inspected
CR 01-1168, Overheated Wires
CR 02-2452, Fire Alarm During EDG Run
CR 02-1268-1&2, Feasibility of performing manual actions with respect to normalized criteria
CR 03-1260, Overheated Compressor Oil
CR 03-1330, 03-1330-1, Review Safe Shutdown Assumptions to Determine If Station Blackout
Assumptions for RCP Seal Cooling Apply
CR 03-2310, Evaluate the Type of Lighting and Power Sources Needed to Provide Emergency
Lighting for Fire Fighter Dress Out Areas
CR 03-3497, Weld Slag Ignited Rags
9
ATTACHMENT
CR 03-4126, Procedure enhancement recommended to assign groups of fire zone manual
actions to designated operators
CR 04-0033, Credited valves MOV-3/4-860A&B and 861A&B in path from containment sump to
RHR suction could be affected by fire
CR 04-0124, Manual action required to trip RCP breakers when trip from main control room not
available
CR 04-0292, Operations practices not fully reflected in Pre-fire Plans procedural format
CR 04-0580, Evaluate an alternate method to define time-lines that could enhance manual
action sequences and interactions
CRs and Work Orders Generated During this Inspection
CR 04-0369, Not All NFPA Standard Codes in the PTN Licensing Basis Are Listed In UFSAR
Table 9.6A-12.
CR 04-0385, No Provisions for DDFP Start Testing on Loss of Power in Either the Surveillance
or Operability Procedures.
CR 04-0476, Area Fire Detection Is Not Installed in the Areas of the Control Room HVAC (Fire
Zones 97 and 106R).
CR 04-0477, Curbing for the Hydrogen Seal Oil Units Appears Insufficient to Contain the Full
846 Gallon Inventory Described in UFSAR Appendix 9.6A
CR 04-0610, Review of 0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual
Actions, Discovered That Steps to Prevent Spurious Actuation of MOV-626 (CCW From
Seal Cooling) Were Missing From Fire Zone 67 and 70. OTSC 04-0036 Generated.
CR 04-0683, Inconsistency Identified in Manual Actions Prescribed in the Safe Shutdown
Analysis and the Operations Safe Shutdown Manual Actions for Fire Zone 63 in 0-ONOP-
16.10
CR 04-0686, Ceiling Level Fire Detectors in the 4B Switchgear Room (Fire Zone 67) Do Not
Meet the Spacing Guidelines per NRC MC 0609F, Attachment 2 and Is Not Consistent
With UFSAR Section 3.5.1.
CR 04-0687, Equipment Procedurally Required to Achieve Cold Shutdown (GOP-305 and EOP-
ES-0.2) Was Discovered to be Affected By the Fire and Would Require Manual Operator
Action to Re-position When Aligning RHR.
CR 04-0688, OTSCs 04-0038 [0-ONOP-016.10] and 04-0039 [0-ONOP-105] Have Been Issued
to Advance the Current Manual Actions to Establish RCP Seal Injection Within 13 Minutes
Instead of Current 20 Minutes.
CR 04-0700, Control Room Evacuation procedure 0-ONOP-105 Does Not Direct Plant
Operators to Take Security Vital Access Keys Prior to Evacuating.
CR 04-0705, 0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions,
Attachment 1, Does Not Have the Timed Actions Broken Down Into Designated Manual
Actions.
10
ATTACHMENT
LIST OF ACRONYMS
Agency-Wide Documents Access and Management System
alternate shutdown panel
corrective action program
component cooling water
CFR
Code of Federal Regulations
CR
condition report
direct current
emergency lighting unit
fire area
Fire Hazards Analysis
ft
foot
FPPR
Fire Protection Program Report
FZ
fire zone
General Operating Procedure
heating, ventilation, and air conditioning
level control valve
main control room
motor operated valve
non-cited violation
National Fire Protection Association
NRC
U.S. Nuclear Regulatory Commission
ONOP
Off-Normal Operating Procedure
Occupational Safety and Health Administration
Publicly Available Records Systems
point of combustion
reactor coolant pump
refueling water storage tank
Significance Determination Process
safety evaluation report
Safe Shutdown Analysis Report
SSD
Updated Final Safety Analysis Report
UL
Underwriters Laboratory
unresolved item
V
volt