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| issue date = 12/30/2011
| issue date = 12/30/2011
| title = IR 05000325-11-011, 05000324-11-011; on 10/31 - 11/04/2011, and 11/14 - 18/2011; Brunswick Steam Electric Plant; Fire Protection and Other Activities
| title = IR 05000325-11-011, 05000324-11-011; on 10/31 - 11/04/2011, and 11/14 - 18/2011; Brunswick Steam Electric Plant; Fire Protection and Other Activities
| author name = Rodriguez R E
| author name = Rodriguez R
| author affiliation = NRC/RGN-II/DRS/EB2
| author affiliation = NRC/RGN-II/DRS/EB2
| addressee name = Annacone M, Annacone M J
| addressee name = Annacone M, Annacone M
| addressee affiliation = Carolina Power & Light Co
| addressee affiliation = Carolina Power & Light Co
| docket = 05000324, 05000325
| docket = 05000324, 05000325
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:December 30, 2011
[[Issue date::December 30, 2011]]


Mr. Michael Annacone Vice President Brunswick Steam Electric Plant P.O. Box 10429 Southport, NC 28461
==SUBJECT:==
BRUNSWICK STEAM ELECTRIC PLANT - NRC TRIENNIAL FIRE


SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000325/2011011 AND 05000324/2011011
PROTECTION INSPECTION REPORT 05000325/2011011 AND  
 
05000324/2011011


==Dear Mr. Annacone:==
==Dear Mr. Annacone:==
On November 18, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed inspection report documents the inspection results, which were discussed on November 17, 2011, with you and other members of your staff.
On November 18, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed inspection report documents the inspection results, which were discussed on November 17, 2011, with you and other members of your staff.


The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspection examined activities conducted under your licenses 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.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Line 36: Line 38:
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of  
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of  


2 Progress Energy NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Progress Energy NRC's 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/
 
Reinaldo Rodriguez, Acting Chief Engineering Branch 2 Division of Reactor Safety


Sincerely,/RA/ Reinaldo Rodriguez, Acting Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62  
Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62  


===Enclosure:===
===Enclosure:===
Triennial Fire Protection Inspection Report 05000325/2011011 and 05000324/2011011  
Triennial Fire Protection Inspection Report 05000325/2011011 and 05000324/2011011 w/Attachment: Supplemental Information
 
REGION II==
Docket Nos.:
50-325, 50-324
 
License Nos.:
DPR-71, DPR-62
 
Report Nos.:
05000325/2011011 and 05000324/2011011
 
Licensee:
Carolina Power and Light (CP&L)
 
Facility:
Brunswick Steam Electric Plant, Units 1 and 2
 
Location:
8470 River Rd SE
 
Southport, NC 28461


===w/Attachment:===
Dates:
Supplemental Information cc w/encl: (See page 3)  
October 31 - November 4, 2011 (Week 1)  


__ML# 113640026____________
November 14 - 18, 2011 (Week 2)
X SUNSI REVIEW COMPLETE 3 Progress Energy cc w/encl: Edward L. Wills, Jr. Director Site Operations Brunswick Steam Electric Plant Electronic Mail Distribution


Joseph M. Frisco, Jr Plant General Manager Brunswick Steam Electric Plant Progress Energy Electronic Mail Distribution
Inspectors:
M. Thomas, Senior Reactor Inspector (Lead Inspector)


Phyllis N. Mentel Manager, Support Services Brunswick Steam Electric Plant Progress Energy Carolinas, Inc. Electronic Mail Distribution
J. Dymek, Reactor Inspector


Annette H. Pope Supervisor, Licensing/Regulatory Programs Brunswick Steam Electric Plant Progress Energy Carolinas, Inc. Electronic Mail Distribution
R. Fanner, Reactor Inspector


Randy C. Ivey Manager, Nuclear Oversight Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.
L. Suggs, Reactor Inspector


Electronic Mail Distribution Paul E. Dubrouillet Manager, Training Brunswick Steam Electric Plant Electronic Mail Distribution Kelvin Henderson General Manager Nuclear Fleet Operations Progress Energy Electronic Mail Distribution Joseph W. Donahue Vice President Nuclear Oversight Progress Energy Electronic Mail Distribution David T. Conley Senior Counsel, Legal Dept Progress Energy Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission Brunswick Steam Electric Plant U.S. NRC 8470 River Road, SE Southport, NC 28461 John H. O'Neill, Jr. Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128 Peggy Force Assistant Attorney General State of North Carolina P.O. Box 629 Raleigh, NC 27602
Accompanying


Chairman North Carolina Utilities Commission Electronic Mail Distribution
N. Merriweather, Senior Reactor Inspector (Weeks 1 and 2)
Personnel:


Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326
E. Patterson, Construction Inspector (Weeks 1 and 2)


Brunswick County Board of Commissioners P.O. Box 249 Bolivia, NC 28422
M. Riches, Operations Engineer (Week 1 only)


Public Service Commission State of South Carolina P.O. Box 11649 Columbia, SC 29211
G. Wiseman, Senior Reactor Inspector (Week 1 only)


W. Lee Cox, III, Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Warren Lee Emergency Management Director New Hanover County Department of Emergency Management 230 Government Center Drive Suite 115 Wilmington, NC 28403 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 Report Nos.: 05000325/2011011 and 05000324/2011011
Approved by:
Reinaldo Rodriguez, Acting Chief  


Licensee: Carolina Power and Light (CP&L)
Engineering Branch 2  
Facility: Brunswick Steam Electric Plant, Units 1 and 2 Location: 8470 River Rd SE Southport, NC 28461 Dates: October 31 - November 4, 2011 (Week 1) November 14 - 18, 2011 (Week 2)
 
Inspectors: M. Thomas, Senior Reactor Inspector (Lead Inspector)
Division of Reactor Safety  
J. Dymek, Reactor Inspector R. Fanner, Reactor Inspector L. Suggs, Reactor Inspector Accompanying N. Merriweather, Senior Reactor Inspector (Weeks 1 and 2)
Personnel: E. Patterson, Construction Inspector (Weeks 1 and 2) M. Riches, Operations Engineer (Week 1 only) G. Wiseman, Senior Reactor Inspector (Week 1 only)
Approved by: Reinaldo Rodriguez, Acting Chief Engineering Branch 2 Division of Reactor Safety


Enclosure  
Enclosure  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000325, 324/2011-011; 10/31 - 11/04/2011, and 11/14 - 18/2011; Brunswick Steam Electric Plant; Fire Protection and Other Activities  
IR 05000325, 324/2011-011; 10/31 - 11/04/2011, and 11/14 - 18/2011; Brunswick Steam  
 
Electric Plant; Fire Protection and Other Activities  


This report covers an announced two-week period of inspection by a triennial fire protection team composed of four regional inspectors. No findings were identified during this inspection period.
This report covers an announced two-week period of inspection by a triennial fire protection team composed of four regional inspectors. No findings were identified during this inspection period.


===A. NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===
 
None  
None  
 
===B. Licensee Identified Violations===


===Licensee Identified Violations===
None
None


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==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity  
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity  
{{a|1R05}}


{{a|1R05}}
==1R05 Fire Protection==
==1R05 Fire Protection==
This report documents the results of a triennial fire protection inspection of the Brunswick Steam Electric Plant (also referred to as Brunswick Nuclear Plant (BNP)),
This report documents the results of a triennial fire protection inspection of the Brunswick Steam Electric Plant (also referred to as Brunswick Nuclear Plant (BNP)),
Units 1 and 2. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure (IP) 71111.05T, "Fire Protection (Triennial)," dated August 1, 2011. The objective of the inspection was to review a minimum sample of three risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP), and to review site specific implementation of at least one B.5.b mitigating strategy as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs, and associated fire zones (FZs) were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walkdowns of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports (SER), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-02 of the IP specifies a minimum sample size of three FAs and one B.5.b implementing strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of three FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:
Units 1 and 2. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), dated August 1, 2011. The objective of the inspection was to review a minimum sample of three risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP), and to review site specific implementation of at least one B.5.b mitigating strategy as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs, and associated fire zones (FZs) were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walkdowns of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports (SER), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-02 of the IP specifies a minimum sample size of three FAs and one B.5.b implementing strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of three FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:  
1. Control Building 49-foot elevation, FA CB-23 (Unit 1 Main Control Room).
 
2. Reactor Building 20-foot elevation, FA RB1-1g (North East, East Central, and South East).


3. Diesel Generator Building 50 foot elevation, FA DG-12 (4160 Volt AC switchgear Division II, E2).
===1. Control Building 49-foot elevation, FA CB-23 (Unit 1 Main Control Room).===
===2. Reactor Building 20-foot elevation, FA RB1-1g (North East, East Central, and===
South East).


The inspectors evaluated the licensee's FPP against applicable requirements, including BNP Unit 1 Operating License Condition 2.B(6) and Unit 2 Operating License Condition 2.B(6), "Fire Protection;" Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criteria 3, "Fire Protection;" 10 CFR Part 50, Appendix R Subsections III.G, III.J, and III.L; 10 CFR 50.48, "Fire Protection;"
===3. Diesel Generator Building 50 foot elevation, FA DG-12 (4160 Volt AC===
Appendix A to NRC Auxiliary Power Conversion System Branch (APCSB) Branch Technical Position (BTP) 9.5-1, "Guidelines For Fire Protection For Nuclear Power Plants," August 1976; NRC Safety Evaluation Reports dated November 22, 1977, as supplemented April 1979, June 11, 1980, December 30, 1986, December 6, 1989, July 28, 1993, and February 10, 1994; BNP Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, "Fire Protection System"; and plant Technical Specifications.
switchgear Division II, E2).


The review of the B.5.b mitigating strategies was based on the BNP Operating License Conditions 2.P for Unit 1, and 2.M for Unit 2, "Mitigation Strategy License Condition;" licensee B.5.b submittals; 4 Enclosure 10 CFR 50.54(hh)(2); and related NRC SERs. The inspectors evaluated all areas of this inspection, as documented below, against these requirements. Specific licensing basis documents reviewed are listed in the Attachment.
The inspectors evaluated the licensees FPP against applicable requirements, including BNP Unit 1 Operating License Condition 2.B(6) and Unit 2 Operating License Condition 2.B(6), Fire Protection; Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criteria 3, Fire Protection; 10 CFR Part 50, Appendix R Subsections III.G, III.J, and III.L; 10 CFR 50.48, Fire Protection; Appendix A to NRC Auxiliary Power Conversion System Branch (APCSB) Branch Technical Position (BTP)9.5-1, Guidelines For Fire Protection For Nuclear Power Plants, August 1976; NRC Safety Evaluation Reports dated November 22, 1977, as supplemented April 1979, June 11, 1980, December 30, 1986, December 6, 1989, July 28, 1993, and February 10, 1994; BNP Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire Protection System; and plant Technical Specifications. The review of the B.5.b mitigating strategies was based on the BNP Operating License Conditions 2.P for Unit 1, and 2.M for Unit 2, Mitigation Strategy License Condition; licensee B.5.b submittals; 10 CFR 50.54(hh)(2); and related NRC SERs. The inspectors evaluated all areas of this inspection, as documented below, against these requirements. Specific licensing basis documents reviewed are listed in the Attachment.


===.01 Protection of Safe Shutdown Capabilities===
===.01 Protection of Safe Shutdown Capabilities===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors evaluated the licensee's ability to achieve hot and cold shutdown assuming a postulated fire in selected FAs. The inspectors examined those fire protection features provided to limit fire damage to structures, systems and components (SSCs) important to post-fire SSD as required by the approved FPP. The inspectors selected a sample of SSD systems to evaluate the licensee's ability to safely shutdown the plant. The components and systems examined included reactor coolant makeup, reactor heat removal, and associated support systems such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.
The inspectors evaluated the licensees ability to achieve hot and cold shutdown assuming a postulated fire in selected FAs. The inspectors examined those fire protection features provided to limit fire damage to structures, systems and components (SSCs) important to post-fire SSD as required by the approved FPP. The inspectors selected a sample of SSD systems to evaluate the licensees ability to safely shutdown the plant. The components and systems examined included reactor coolant makeup, reactor heat removal, and associated support systems such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.


The inspectors performed in-plant walkdowns of selected FAs to observe: (1) the material condition of fire protection systems and equipment; (2) the storage of permanent and transient combustibles; (3) the proximity of fire hazards to cables relied upon for SSD; and (4) the licensee's implementation of procedures and processes for limiting fire hazards, housekeeping practices, and compensatory measures for inoperable or degraded fire protection systems and credited fire barriers. Reviews were accomplished to ensure that the licensee was maintaining the fire protection systems, had properly evaluated the in-situ combustible fire loads, controlled hot-work activities, and limited transient fire hazards in a manner consistent with operating license conditions, regulatory requirements, and plant administrative and FPP procedures.
The inspectors performed in-plant walkdowns of selected FAs to observe:
: (1) the material condition of fire protection systems and equipment;
: (2) the storage of permanent and transient combustibles;
: (3) the proximity of fire hazards to cables relied upon for SSD; and
: (4) the licensees implementation of procedures and processes for limiting fire hazards, housekeeping practices, and compensatory measures for inoperable or degraded fire protection systems and credited fire barriers. Reviews were accomplished to ensure that the licensee was maintaining the fire protection systems, had properly evaluated the in-situ combustible fire loads, controlled hot-work activities, and limited transient fire hazards in a manner consistent with operating license conditions, regulatory requirements, and plant administrative and FPP procedures.


The inspectors reviewed calculation 7453-101-8-B-21-57F, "Appendix R Spurious Operations Analysis," which identified components that could be susceptible to spurious operations, which could, in turn, affect redundant trains of equipment or other credited SSD systems. Components identified in this calculation were compared to components identified in the licensee's separation analysis and fire hazards analysis (FHA). The licensee indicated that calculation 7453-101-8-B-21-57F was no longer being updated and was neither used in the development of nor referenced in the safe shutdown analysis (SSA) or FHA. The inspectors reviewed the documents to verify that the licensee had reconciled the differences for each component indentified in the calculation.
The inspectors reviewed calculation 7453-101-8-B-21-57F, Appendix R Spurious Operations Analysis, which identified components that could be susceptible to spurious operations, which could, in turn, affect redundant trains of equipment or other credited SSD systems. Components identified in this calculation were compared to components identified in the licensees separation analysis and fire hazards analysis (FHA). The licensee indicated that calculation 7453-101-8-B-21-57F was no longer being updated and was neither used in the development of nor referenced in the safe shutdown analysis (SSA) or FHA. The inspectors reviewed the documents to verify that the licensee had reconciled the differences for each component indentified in the calculation.


The inspectors reviewed the pre-fire plans for selected FAs to determine if information provided to the fire brigade was adequate to 1) identify equipment important to SSD; 2) facilitate fire suppression activities; and 3) remove smoke and/or water runoff so that operator manual actions (OMAs) required for SSD could be accomplished. The location and proper storage of compressed gas cylinders within the reactor building (RB) was also reviewed to determine if they represented a fire or missile hazard to equipment or cables required for SSD.
The inspectors reviewed the pre-fire plans for selected FAs to determine if information provided to the fire brigade was adequate to 1) identify equipment important to SSD; 2)facilitate fire suppression activities; and 3) remove smoke and/or water runoff so that operator manual actions (OMAs) required for SSD could be accomplished. The location and proper storage of compressed gas cylinders within the reactor building (RB) was also reviewed to determine if they represented a fire or missile hazard to equipment or cables required for SSD.


====b. Findings====
====b. Findings====
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===.02 Passive Fire Protection===
===.02 Passive Fire Protection===
====a. Inspection Scope====
For the selected FAs, the inspectors evaluated the adequacy of fire barrier walls, ceilings, floors, mechanical and electrical penetrations, fire doors, fire dampers and electrical raceway fire barrier systems (ERFBS). The inspectors walked down accessible portions of the selected FAs to observe material condition of the fire barriers including the use of portable cameras for inspection of penetrations in the overhead.


====a. Inspection Scope====
The inspectors reviewed the design of selected ERFBS to confirm that appropriate materials and construction methods were used to assure that the respective fire barriers met their intended design function. The inspectors reviewed the fire protection data system for selected and adjoining FAs to verify that the plant fire loading used by the licensee was appropriate for the stated fire resistance rating of the enclosures. The inspectors reviewed recently completed surveillance procedures for fire doors, penetration seals and ERFBS.
For the selected FAs, the inspectors evaluated the adequacy of fire barrier walls, ceilings, floors, mechanical and electrical penetrations, fire doors, fire dampers and electrical raceway fire barrier systems (ERFBS). The inspectors walked down accessible portions of the selected FAs to observe material condition of the fire barriers including the use of portable cameras for inspection of penetrations in the overhead. The inspectors reviewed the design of selected ERFBS to confirm that appropriate materials and construction methods were used to assure that the respective fire barriers met their intended design function. The inspectors reviewed the fire protection data system for selected and adjoining FAs to verify that the plant fire loading used by the licensee was appropriate for the stated fire resistance rating of the enclosures. The inspectors reviewed recently completed surveillance procedures for fire doors, penetration seals and ERFBS.


====b. Findings====
====b. Findings====
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===.03 Active Fire Protection===
===.03 Active Fire Protection===
====a. Inspection Scope====
====a. Inspection Scope====
For the selected FAs, the inspectors performed in-plant observations of the material condition and operational line-up of fire detection, fire protection water supply, automatic wet pipe sprinkler systems and manual fire hose and standpipe systems. The inspectors reviewed the adequacy of the design and installation of fire suppression systems in the selected FAs. This was accomplished by review of system vendor drawings, calculations, and code compliance reviews. The inspectors evaluated if the fire detection and suppression methods were appropriate for the hazards in the selected FAs. The inspectors compared the fire detection and fire suppression systems to the applicable code of record for National Fire Protection Association (NFPA) Standard(s) for the selected FAs by reviewing the system design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The inspectors reviewed recently completed surveillance procedures for fire detection and fire sprinkler systems in the selected FAs and compared them to the BNP FPP.
For the selected FAs, the inspectors performed in-plant observations of the material condition and operational line-up of fire detection, fire protection water supply, automatic wet pipe sprinkler systems and manual fire hose and standpipe systems. The inspectors reviewed the adequacy of the design and installation of fire suppression systems in the selected FAs. This was accomplished by review of system vendor drawings, calculations, and code compliance reviews. The inspectors evaluated if the fire detection and suppression methods were appropriate for the hazards in the selected FAs. The inspectors compared the fire detection and fire suppression systems to the applicable code of record for National Fire Protection Association (NFPA) Standard(s) for the selected FAs by reviewing the system design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The inspectors reviewed recently completed surveillance procedures for fire detection and fire sprinkler systems in the selected FAs and compared them to the BNP FPP.


For the selected FAs, the inspectors compared the pre-fire plan strategy of each FA to existing plant layout and equipment configurations and the fire response procedures. The inspectors assessed the condition of firefighting and smoke removal equipment by inspecting the equipment located in the fire brigade equipment staging and storage areas. The inspectors reviewed fire brigade drill planning and evaluation report records for drills performed in the control building, RB 20 foot elevation, and the diesel generator building 50 foot elevation performed in 2010 and 2011. The inspectors assessed the fire brigade fire fighting activities by observing an announced drill in the RB 20 foot elevation.
For the selected FAs, the inspectors compared the pre-fire plan strategy of each FA to existing plant layout and equipment configurations and the fire response procedures.
 
The inspectors assessed the condition of firefighting and smoke removal equipment by inspecting the equipment located in the fire brigade equipment staging and storage areas. The inspectors reviewed fire brigade drill planning and evaluation report records for drills performed in the control building, RB 20 foot elevation, and the diesel generator building 50 foot elevation performed in 2010 and 2011. The inspectors assessed the fire brigade fire fighting activities by observing an announced drill in the RB 20 foot elevation.
 
The inspectors review of specific attributes of fire brigade conduct for these drills included strategy and tactics, command and control, use of fire brigade equipment, radio communications, and time-lines for alarm, assembly and first mitigating events (i.e.


The inspectors' review of specific attributes of fire brigade conduct for these drills included strategy and tactics, command and control, use of fire brigade equipment, radio communications, and time-lines for alarm, assembly and first mitigating events (i.e. suppression).
suppression).


====b. Findings====
====b. Findings====
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===.04 Protection From Damage From Fire Suppression Activities===
===.04 Protection From Damage From Fire Suppression Activities===
====a. Inspection Scope====
The inspectors evaluated whether the installed automatic wet pipe sprinkler systems or manual fire fighting activities could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment or adversely affect OMAs required for SSD for the selected FAs. The inspectors considered the consequences of a rupture, inadvertent operation or actual operation of a fire suppression system concurrent with manual fire fighting activities as could result from a fully involved fire in one of the selected FAs. The inspectors reviewed BNP operating experience reviews for NRC Information Notice 98-31, Fire Protection System Design Deficiencies and Common Mode Flooding of Emergency Core Cooling Rooms at Washington Nuclear Project Unit


====a. Inspection Scope====
===2. The inspectors reviewed pre-fire plans which addressed the opening of doors to===
The inspectors evaluated whether the installed automatic wet pipe sprinkler systems or manual fire fighting activities could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment or adversely affect OMAs required for SSD for the selected FAs. The inspectors considered the consequences of a rupture, inadvertent operation or actual operation of a fire suppression system concurrent with manual fire fighting activities as could result from a fully involved fire in one of the selected FAs. The inspectors reviewed BNP operating experience reviews for NRC Information Notice 98-31, "Fire Protection System Design Deficiencies and Common Mode Flooding of Emergency Core Cooling Rooms at Washington Nuclear Project Unit 2.The inspectors reviewed pre-fire plans which addressed the opening of doors to drain water or ventilate smoke so that OMAs could be performed. The inspectors observed inspection activities of penetration seals and condition monitoring of structures to address potential damage from water leaking through floor slabs to equipment below. The inspectors measured curb heights above the floor for installed equipment and visually checked floor slope to determine if water could inadvertently pool in such a manner as to adversely affect SSD equipment or OMAs.
drain water or ventilate smoke so that OMAs could be performed. The inspectors observed inspection activities of penetration seals and condition monitoring of structures to address potential damage from water leaking through floor slabs to equipment below.
 
The inspectors measured curb heights above the floor for installed equipment and visually checked floor slope to determine if water could inadvertently pool in such a manner as to adversely affect SSD equipment or OMAs.


====b. Findings====
====b. Findings====
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===.05 Alternative Shutdown Capability===
===.05 Alternative Shutdown Capability===
====a. Inspection Scope====
Methodology


====a. Inspection Scope====
For a postulated fire in any of the selected FAs, the licensee credited alternative shutdown capability to achieve hot and cold shutdown. The licensee defined alternative shutdown as SSD activities requiring utilization of abnormal operational practices:  
Methodology For a postulated fire in any of the selected FAs, the licensee credited alternative shutdown capability to achieve hot and cold shutdown. The licensee defined alternative shutdown as SSD activities requiring utilization of abnormal operational practices:
 
- Operations other than normal SSD activities from the main control room - Operations from designated alternative control system locations and/or - Manual operation at equipment locations The inspectors examined the following BNP fire response procedures and emergency operating procedures (EOP):
-
- 1ASSD-04, "Unit 1 Train A Shutdown- 1ASSD-05, "Unit 1 Reactor Building North- 1ASSD-06, "Unit 1 Reactor Building South
Operations other than normal SSD activities from the main control room  
- 0ASSD-02, "Control Building"  - 0-ASSD-00, "Users Guide"  - 0-ASSD-01, "Alternative Safe Shutdown Procedure Index- 2ASSD-03, "Unit 2 Train B Shutdown- 2ASSD-04, "Unit 2 Train A Shutdown
-
- 0PFP-013, "General Fire Plan
Operations from designated alternative control system locations and/or  
- 1EOP-01-RSP, "Unit 1 Reactor Scram Procedure
-
- 0EOP-02- PCCP, "Primary Containment Control Procedure
Manual operation at equipment locations The inspectors examined the following BNP fire response procedures and emergency operating procedures (EOP):  
- 1EOP-01-RVCP, "Reactor Vessel Control Procedure" The inspectors compared the procedures to the FHA, SSA, flow diagrams, and other design basis documents to determine if equipment required for post-fire SSD was properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G and the approved FPP. The inspectors reviewed cable routing information by FA for a selected sample of SSD components to verify that cables would not be damaged by a fire in the selected FAs or the licensee's analysis determined that the fire damage would not prohibit safe shutdown. In cases where OMAs were credited in-lieu of cable protection of SSD equipment, the inspectors reviewed selected OMAs to verify that the OMAs were feasible utilizing the guidance of the NRC IP. A list of SSD components examined for cable routing is included in the Attachment.
 
-
1ASSD-04, Unit 1 Train A Shutdown  
-
1ASSD-05, Unit 1 Reactor Building North  
-
1ASSD-06, Unit 1 Reactor Building South  
-
0ASSD-02, Control Building ASSD-00, Users Guide ASSD-01, Alternative Safe Shutdown Procedure Index  
-
2ASSD-03, Unit 2 Train B Shutdown  
-
2ASSD-04, Unit 2 Train A Shutdown  
-
0PFP-013, General Fire Plan  
-
1EOP-01-RSP, Unit 1 Reactor Scram Procedure  
-
0EOP-02-PCCP, Primary Containment Control Procedure  
-
1EOP-01-RVCP, Reactor Vessel Control Procedure  
 
The inspectors compared the procedures to the FHA, SSA, flow diagrams, and other design basis documents to determine if equipment required for post-fire SSD was properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G and the approved FPP. The inspectors reviewed cable routing information by FA for a selected sample of SSD components to verify that cables would not be damaged by a fire in the selected FAs or the licensees analysis determined that the fire damage would not prohibit safe shutdown. In cases where OMAs were credited in-lieu of cable protection of SSD equipment, the inspectors reviewed selected OMAs to verify that the OMAs were feasible utilizing the guidance of the NRC IP. A list of SSD components examined for cable routing is included in the Attachment.
 
Operational Implementation
 
The inspectors reviewed applicable sections of procedures 0PFP-13, 0ASSD-01, 0ASSD-02, 1ASSD-04, 1ASSD-05, 1ASSD-06 for FAs CB-23, RB1-1g, and DG-12 to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain SSD conditions. The inspectors assessed the timeliness of the operators in identifying and assessing the initial plant conditions, response to suspected fire, and subsequent actions credited afterwards. The inspectors performed a walk-through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The inspectors reviewed the licensee shift staffing of personnel credited for procedure implementation to verify personnel had procedures available, were trained on implementation, and were available in the event a fire occurred. The inspectors also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.
 
Procedure 0PLP-01.5, Alternative Shutdown Capability Controls, established controls to provide reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. The inspectors reviewed records of the most recently completed functional tests for a sample of the Appendix R transfer switches, relays and remote shutdown panel. The testing was performed by the following test procedures:
-
Maintenance Surveillance Test procedure 1MST-RSDP21R, RSDP and RTGB Panel Reactor Water Level Indication Channel Calibration, completed on January 13, 2011.


Operational Implementation The inspectors reviewed applicable sections of procedures 0PFP-13, 0ASSD-01, 0ASSD-02, 1ASSD-04, 1ASSD-05, 1ASSD-06 for FAs CB-23, RB1-1g, and DG-12 to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain SSD conditions. The inspectors assessed the timeliness of the operators in identifying and assessing the initial plant conditions, response to suspected fire, and subsequent actions credited afterwards. The inspectors performed a walk-through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The inspectors reviewed the licensee shift staffing of personnel credited for procedure implementation to verify personnel had procedures available, were trained on implementation, and were available in the event a fire occurred. The inspectors also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.
-
Operability Test, 0PT-19.11.L, Safety Relief Valve Local Control Operability Test, completed April 12, 2010
-
Operability Test, 0PT-10.16.L, Remote Shutdown Panel RCIC Flow Controller, RCIC Manual Turbine Trip, and RCIC Turbine Trip Reset Local Control Operability Test, completed July 1, 2011


Procedure 0PLP-01.5, "Alternative Shutdown Capability Controls," established controls to provide reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. The inspectors reviewed records of the most recently completed functional tests for a sample of the Appendix R transfer switches, relays and remote shutdown panel. The testing was performed by the following test procedures:
The tests objectives were to demonstrate the capability to transfer plant controls from the main control room to the remote shutdown panel or local control station. The inspectors reviewed the records to verify that testing was performed satisfactorily and that test deficiencies were properly entered and corrected by the corrective action program.
- Maintenance Surveillance Test procedure 1MST-RSDP21R, "RSDP and RTGB    Panel Reactor Water Level Indication Channel Calibration," completed on January 13, 2011. - Operability Test, 0PT-19.11.L, "Safety Relief Valve Local Control Operability Test," completed April 12, 2010- Operability Test, 0PT-10.16.L, "Remote Shutdown Panel RCIC Flow Controller, RCIC Manual Turbine Trip, and RCIC Turbine Trip Reset Local Control Operability Test, completed July 1, 2011 The tests objectives were to demonstrate the capability to transfer plant controls from the main control room to the remote shutdown panel or local control station. The inspectors reviewed the records to verify that testing was performed satisfactorily and that test deficiencies were properly entered and corrected by the corrective action program.


====b. Findings====
====b. Findings====
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===.06 Circuit Analyses===
===.06 Circuit Analyses===
====a. Inspection Scope====
The inspectors assessed whether the licensee identified the SSCs important to meeting the 10 CFR Part 50.48 requirements consistent with the established licensing basis.


====a. Inspection Scope====
The inspectors reviewed training material, UFSAR, and system flow drawings to assess the likelihood of flow diversion paths, loss of function, or other scenarios that would adversely impact the plants ability to achieve and maintain SSD conditions. The inspectors reviewed licensee SSD procedures and compared them with the post-fire SSA and separation analysis for the selected FAs. For areas where there were questions, the inspectors performed more detailed circuit analysis to verify fire induced damage would not adversely impact the credited SSD methodology.
The inspectors assessed whether the licensee identified the SSCs important to meeting the 10 CFR Part 50.48 requirements consistent with the established licensing basis. The inspectors reviewed training material, UFSAR, and system flow drawings to assess the likelihood of flow diversion paths, loss of function, or other scenarios that would adversely impact the plant's ability to achieve and maintain SSD conditions. The inspectors reviewed licensee SSD procedures and compared them with the post-fire SSA and separation analysis for the selected FAs. For areas where there were questions, the inspectors performed more detailed circuit analysis to verify fire induced damage would not adversely impact the credited SSD methodology.


During a walkdown of Fire Area DG-12, E2 Switchgear Room, the inspectors identified conduits associated with the credited SSD train traversing the FA. These conduits contained the following cables, which were served from the 120/208VAC distribution panel 1-1A-DG:  
During a walkdown of Fire Area DG-12, E2 Switchgear Room, the inspectors identified conduits associated with the credited SSD train traversing the FA. These conduits contained the following cables, which were served from the 120/208VAC distribution panel 1-1A-DG:  
- H32-R43, circuit 9, Load Power Cable for E1-E3 Bus Duct Heater  - H32-H82, circuit 18, RHRSW Pump 1A Control Panel H82 Bus E-3 - AF3-H32, circuit 23, 4160 Switchgear E1 Heater and Control Bus The inspectors verified that none of these components were required for SSD.


However, since they were associated with the credited shutdown train, inspectors reviewed the licensee's breaker coordination analysis to ensure that fire damage to these cables would not interrupt the SSD capability.
-
H32-R43, circuit 9, Load Power Cable for E1-E3 Bus Duct Heater
-
H32-H82, circuit 18, RHRSW Pump 1A Control Panel H82 Bus E-3
-
AF3-H32, circuit 23, 4160 Switchgear E1 Heater and Control Bus
 
The inspectors verified that none of these components were required for SSD.
 
However, since they were associated with the credited shutdown train, inspectors reviewed the licensees breaker coordination analysis to ensure that fire damage to these cables would not interrupt the SSD capability.


The inspectors also reviewed a sample of SSD components to verify that the components specified in the post-fire SSD procedures were available for a postulated fire in any of the selected FAs. The cables examined were based upon a list of SSD components selected by the inspectors after a review of the licensee's separation analysis, FHA, and the system flow drawings. The results of this review were compared with the licensee's circuit analysis, electrical design drawings, Appendix R SSA, and the operations post-fire SSD procedures. The specific components reviewed are listed in the Attachment.
The inspectors also reviewed a sample of SSD components to verify that the components specified in the post-fire SSD procedures were available for a postulated fire in any of the selected FAs. The cables examined were based upon a list of SSD components selected by the inspectors after a review of the licensees separation analysis, FHA, and the system flow drawings. The results of this review were compared with the licensees circuit analysis, electrical design drawings, Appendix R SSA, and the operations post-fire SSD procedures. The specific components reviewed are listed in the Attachment.


====b. Findings====
====b. Findings====
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===.07 Communications===
===.07 Communications===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the communications systems (sound powered phones and radios) to evaluate the availability and capability of systems used to support plant personnel in the performance of OMAs to achieve and maintain SSD conditions. During observation of an announced fire brigade drill the inspectors verified that the radio communication system functioned reliably at different locations within the plant. The inspectors walked down the SSD procedures at various locations with operators to verify designated sound powered phone jacks were available to licensee personnel. The inspectors reviewed the inventory records to ensure credited sound powered phones were available at the designated locations specified by procedures. The inspectors reviewed routing information for the sound powered phone system to determine if fire induced faults would damage credited circuits. During this review, the inspectors considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns. On a sampling basis, the inspectors had the operators perform sound powered phone and radio checks to ensure communications were available and reliable.
The inspectors reviewed the communications systems (sound powered phones and radios) to evaluate the availability and capability of systems used to support plant personnel in the performance of OMAs to achieve and maintain SSD conditions. During observation of an announced fire brigade drill the inspectors verified that the radio communication system functioned reliably at different locations within the plant. The inspectors walked down the SSD procedures at various locations with operators to verify designated sound powered phone jacks were available to licensee personnel. The inspectors reviewed the inventory records to ensure credited sound powered phones were available at the designated locations specified by procedures. The inspectors reviewed routing information for the sound powered phone system to determine if fire induced faults would damage credited circuits. During this review, the inspectors considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns. On a sampling basis, the inspectors had the operators perform sound powered phone and radio checks to ensure communications were available and reliable.
Line 198: Line 276:


===.08 Emergency Lighting===
===.08 Emergency Lighting===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors performed plant walkdowns with operations staff on various post-fire SSD procedures for the selected FAs to observe the placement and coverage area of credited fixed 8-hour battery pack emergency lights. The inspectors evaluated the lights to ensure they provided adequate illumination of access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post fire SSD.
The inspectors performed plant walkdowns with operations staff on various post-fire SSD procedures for the selected FAs to observe the placement and coverage area of credited fixed 8-hour battery pack emergency lights. The inspectors evaluated the lights to ensure they provided adequate illumination of access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post fire SSD.
Line 204: Line 281:
In instances where 8-hour battery pack emergency lights were not credited inspectors verified the credited lighting systems would be available for operators under post-fire SSD conditions.
In instances where 8-hour battery pack emergency lights were not credited inspectors verified the credited lighting systems would be available for operators under post-fire SSD conditions.


The inspectors reviewed the licensee's maintenance and test records to ensure the design aspects of the fixed emergency lighting met the 8-hour capacity requirements specified in commitments. The inspectors reviewed the applicable vendor documentation to ensure the lighting units were maintained consistent with vendor recommendations. The inspectors reviewed completed preventive maintenance and surveillance testing records to ensure adequate surveillance testing was conducted. For lights not meeting the acceptance criteria the inspectors verified work-orders were written to address the issues. A list of documents reviewed is included in the Attachment.
The inspectors reviewed the licensees maintenance and test records to ensure the design aspects of the fixed emergency lighting met the 8-hour capacity requirements specified in commitments. The inspectors reviewed the applicable vendor documentation to ensure the lighting units were maintained consistent with vendor recommendations. The inspectors reviewed completed preventive maintenance and surveillance testing records to ensure adequate surveillance testing was conducted. For lights not meeting the acceptance criteria the inspectors verified work-orders were written to address the issues. A list of documents reviewed is included in the Attachment.


====b. Findings====
====b. Findings====
Line 210: Line 287:


===.09 Cold Shutdown Repairs===
===.09 Cold Shutdown Repairs===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the licensee's alternative safe shutdown procedures and verified that cold shutdown repairs were not required to achieve cold shutdown conditions within 72 hours after a fire event assuming no offsite power was available.
The inspectors reviewed the licensees alternative safe shutdown procedures and verified that cold shutdown repairs were not required to achieve cold shutdown conditions within 72 hours after a fire event assuming no offsite power was available.


====b. Findings====
====b. Findings====
Line 218: Line 294:


===.10 Compensatory Measures===
===.10 Compensatory Measures===
====a. Inspection Scope====
====a. Inspection Scope====
For the selected FAs, the inspectors reviewed the administrative controls for out-of service, degraded and/or inoperable fire protection features such as detection and suppression systems, and passive fire barriers. The inspectors reviewed databases containing current fire protection impairments and compared them to the FAs selected for the inspection. Fire detection and suppression system impairments were reviewed against operability requirements and compensatory measures outlined in the BNP FPP.
For the selected FAs, the inspectors reviewed the administrative controls for out-of service, degraded and/or inoperable fire protection features such as detection and suppression systems, and passive fire barriers. The inspectors reviewed databases containing current fire protection impairments and compared them to the FAs selected for the inspection. Fire detection and suppression system impairments were reviewed against operability requirements and compensatory measures outlined in the BNP FPP.
Line 230: Line 305:


===.11 Review and Documentation of Fire Protection Program Changes===
===.11 Review and Documentation of Fire Protection Program Changes===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed a sample of FPP changes made between November 2008 and November 2011 to assess the licensee's effectiveness to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse effect on the ability to achieve SSD.
The inspectors reviewed a sample of FPP changes made between November 2008 and November 2011 to assess the licensees effectiveness to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse effect on the ability to achieve SSD.


====b. Findings====
====b. Findings====
Line 238: Line 312:


===.12 Control of Transient Combustibles and Ignition Sources===
===.12 Control of Transient Combustibles and Ignition Sources===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the controls for combustibles and ignition sources throughout the plant to verify that they were in compliance with the BNP FPP.
The inspectors reviewed the controls for combustibles and ignition sources throughout the plant to verify that they were in compliance with the BNP FPP. The inspectors verified that the transient combustible materials and locations of transient combustible materials were being controlled in accordance with the licensees administrative control procedures and the licensees fire probabilistic risk assessment. The inspectors also reviewed and observed hot work that was being performed at the time of the inspection to verify that it was accomplished in accordance with the licensees administrative control procedures.
 
The inspectors verified that the transient combustible materials and locations of transient combustible materials were being controlled in accordance with the licensee's administrative control procedures and the licensee's fire probabilistic risk assessment. The inspectors also reviewed and observed hot work that was being performed at the time of the inspection to verify that it was accomplished in accordance with the licensee's administrative control procedures.


====b. Findings====
====b. Findings====
Line 248: Line 319:


===.13 B.5.b Inspection Activities===
===.13 B.5.b Inspection Activities===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed, on a sampling basis, the licensee's condensate storage tank and hot-well makeup mitigation strategies to verify that the measures were feasible, personnel were trained to implement the strategies, and equipment was properly staged and maintained. The inspectors requested and reviewed inventory and maintenance records of required equipment. The inspectors had discussions with plant staff, reviewed relevant documentation, and performed plant walkdowns with licensee staff.
The inspectors reviewed, on a sampling basis, the licensees condensate storage tank and hot-well makeup mitigation strategies to verify that the measures were feasible, personnel were trained to implement the strategies, and equipment was properly staged and maintained. The inspectors requested and reviewed inventory and maintenance records of required equipment. The inspectors had discussions with plant staff, reviewed relevant documentation, and performed plant walkdowns with licensee staff.


The inspectors reviewed applicable calculations for the selected strategies to verify the calculations provided an adequate engineering basis to support the appropriateness for the strategies. The inspectors assessed if the strategies could be met with the procedures, equipment, staff training, and water sources provided. The inspectors reviewed the design requirements of the credited equipment to verify the licensee's capability to provide a reliable and available water source, and the ability to provide the minimum fuel supply. The inspectors reviewed completed test records and performed a physical inspection to verify that B.5.b equipment was being properly stored, maintained, and tested in accordance with the licensee's B.5.b program procedures. The inspectors performed a walkdown of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures were available, calibrated, and maintained.
The inspectors reviewed applicable calculations for the selected strategies to verify the calculations provided an adequate engineering basis to support the appropriateness for the strategies. The inspectors assessed if the strategies could be met with the procedures, equipment, staff training, and water sources provided. The inspectors reviewed the design requirements of the credited equipment to verify the licensees capability to provide a reliable and available water source, and the ability to provide the minimum fuel supply. The inspectors reviewed completed test records and performed a physical inspection to verify that B.5.b equipment was being properly stored, maintained, and tested in accordance with the licensees B.5.b program procedures. The inspectors performed a walkdown of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures were available, calibrated, and maintained.


The inspectors reviewed training and qualification requirements for operators, fire brigade, emergency response organization, and new employees for the implementation of actions needed to mitigate a B.5.b related event. The inspectors reviewed training records of the licensee's staff to verify that operator training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures.
The inspectors reviewed training and qualification requirements for operators, fire brigade, emergency response organization, and new employees for the implementation of actions needed to mitigate a B.5.b related event. The inspectors reviewed training records of the licensees staff to verify that operator training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures.


====b. Findings====
====b. Findings====
Line 261: Line 331:
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
==4OA2 Identification and Resolution of Problems==
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed recent independent licensee audits for thoroughness, completeness and conformance to requirements. The inspectors reviewed other corrective action program (CAP) documents, including completed corrective actions documented in selected NCRs to verify that industry-identified fire protection problems potentially or actually affecting the plant were appropriately entered into, and resolved by, the CAP process. The NCRs were reviewed with regard to the attributes of timeliness and apparent cause determination to ensure that proposed corrective actions addressed the apparent cause, reportability and operability determination.
The inspectors reviewed recent independent licensee audits for thoroughness, completeness and conformance to requirements. The inspectors reviewed other corrective action program (CAP) documents, including completed corrective actions documented in selected NCRs to verify that industry-identified fire protection problems potentially or actually affecting the plant were appropriately entered into, and resolved by, the CAP process. The NCRs were reviewed with regard to the attributes of timeliness and apparent cause determination to ensure that proposed corrective actions addressed the apparent cause, reportability and operability determination.
Line 269: Line 339:
No findings were identified.
No findings were identified.


{{a|4OA6}}
{{a|4OA6}}
 
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==
On November 17, 2011, the lead inspector presented the inspection results to Mr. M.


On November 17, 2011, the lead inspector presented the inspection results to Mr. M. Annacone, BNP Site Vice President, and other members of his staff. The licensee acknowledged the results. The lead inspector informed the licensee that proprietary information reviewed would not be included in this inspection report.
Annacone, BNP Site Vice President, and other members of his staff. The licensee acknowledged the results. The lead inspector informed the licensee that proprietary information reviewed would not be included in this inspection report.


ATTACHMENT:
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee personnel===
===Licensee personnel===
: [[contact::S. Allen]], Fire Protection System Engineer  
: [[contact::S. Allen]], Fire Protection System Engineer  
Line 304: Line 375:
: [[contact::R. Tart]], NFPA 805 Transition Engineer  
: [[contact::R. Tart]], NFPA 805 Transition Engineer  
: [[contact::M. White]], Fire Protection Coordinator  
: [[contact::M. White]], Fire Protection Coordinator  
===NRC personnel===
===NRC personnel===
: [[contact::H. Christensen]], Deputy Division Director, Division of Reactor Safety, NRC Region II
: [[contact::H. Christensen]], Deputy Division Director, Division of Reactor Safety, NRC Region II  
: [[contact::P. O'Bryan]], Senior Resident Inspector, BNP, NRC Region II  
: [[contact::P. OBryan]], Senior Resident Inspector, BNP, NRC Region II  
: [[contact::M. Schwieg]], Resident Inspector, BNP, NRC Region II  
: [[contact::M. Schwieg]], Resident Inspector, BNP, NRC Region II  


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
===Opened===
===Opened===
None  
None  


===Opened and Closed===
===Opened and Closed===
None


None 
LIST OF COMPONENTS REVIEWED (Refer to Report Section 1R05.01 / 1R05.05 / 1R05.06 - Circuit Analyses)


LIST OF COMPONENTS REVIEWED (Refer to Report Section 1R05.01 / 1R05.05 / 1R05.06 - Circuit Analyses)
Component Identification  
Component Identification   Description
Valves  1-SW-V19    MN STM to FWP & TURB BP, SG A  1-E41-F002    HPCI Steam Supply Line Isolation MO 1-E41-F007    HPCI Pump Discharge MO
1-E41-F012    HPCI Bypass to Suppression Pool MO 1-E11-F020A    RHR 1A & 1C Suppression Pool Suction Valve MO  1-SW-V17-MO  Conventional SW PMP C Discharge Valve
1-SW-V18-MO  Conventional SW PMP C Discharge Valve
Pump Motors
1-SW-1A-NUC-PMP-M  1A Nuclear Service Water Pump Motor  2-SW-2A-NUC-PMP-M  2A Nuclear Service Water Pump Motor
2-SW-2B-NUC-PMP-M  2B Nuclear Service Water Pump Motor  1-SW-1B-NUC-PMP-M  1B Nuclear Service Water Pump Motor
Ventilation Fan
2-VA-B-EF-DG  4160 VAC E2 Exhaust Fan
Switchgear


1-E1    Unit 1 4KV Emergency SWGR E1  2-E3    Unit 2 4KV Emergency SWGR E3 2-E4    Unit 2 4KV Emergency SWGR E4
Description
Breakers  4 KV E3 Compartment  "AJ5"  Tie Breaker To SWGR E1  4 KV E1 Compartment  "AG0" Tie Breaker To SWGR E3
Communications
1-SPP-JAC-AH0 Sound Powered Phone Jack @ E2 4KV SWGR
AH0  Emergency Diesel Generators
2-DG4-GEN    Diesel Generator No. 4


Instruments
Valves
1-CAC-TR-4426-1A   Suppression Pool Temperature (MCR)
 
1-CAC-LR-2602   Suppression Pool Level (MCR)
1-SW-V19
Attachment 1-B21-PI-R605A   Reactor Pressure (MCR) 1-C32-LI-R606A   Reactor Water Level (MCR) 1-B21-LI-R604A   Reactor Water Level (MCR) 1-CO-LIT-1160   CST Level (local at CST) 1-B21-LI-5977   Reactor Water Level (RSDP) 1-E51-FIC-3325   RCIC Flow Controller (RSDP)
 
1-CAC-TR-778   Suppression Pool Water Temperature (RSDP)  
MN STM to FWP & TURB BP, SG A
 
1-E41-F002
 
HPCI Steam Supply Line Isolation MO 1-E41-F007
 
HPCI Pump Discharge MO 1-E41-F012
 
HPCI Bypass to Suppression Pool MO 1-E11-F020A
 
RHR 1A & 1C Suppression Pool Suction Valve MO
 
1-SW-V17-MO
 
Conventional SW PMP C Discharge Valve
 
1-SW-V18-MO
 
Conventional SW PMP C Discharge Valve
 
Pump Motors
 
1-SW-1A-NUC-PMP-M
 
1A Nuclear Service Water Pump Motor
 
2-SW-2A-NUC-PMP-M
 
2A Nuclear Service Water Pump Motor
 
2-SW-2B-NUC-PMP-M
 
2B Nuclear Service Water Pump Motor
 
1-SW-1B-NUC-PMP-M
 
1B Nuclear Service Water Pump Motor
 
Ventilation Fan
 
2-VA-B-EF-DG
 
4160 VAC E2 Exhaust Fan
 
Switchgear
 
1-E1
 
Unit 1 4KV Emergency SWGR E1
 
2-E3
 
Unit 2 4KV Emergency SWGR E3 2-E4
 
Unit 2 4KV Emergency SWGR E4
 
Breakers
 
KV E3 Compartment AJ5 Tie Breaker To SWGR E1
 
KV E1 Compartment AG0 Tie Breaker To SWGR E3
 
Communications
 
1-SPP-JAC-AH0 Sound Powered Phone Jack @ E2 4KV SWGR AH0
 
Emergency Diesel Generators
 
2-DG4-GEN
 
Diesel Generator No. 4
 
Instruments  
 
1-CAC-TR-4426-1A  
 
Suppression Pool Temperature (MCR)
1-CAC-LR-2602  
 
Suppression Pool Level (MCR)  
 
1-B21-PI-R605A  
 
Reactor Pressure (MCR)  
 
1-C32-LI-R606A  
 
Reactor Water Level (MCR)  
 
1-B21-LI-R604A  
 
Reactor Water Level (MCR)  
 
1-CO-LIT-1160  
 
CST Level (local at CST)  
 
1-B21-LI-5977  
 
Reactor Water Level (RSDP)  
 
1-E51-FIC-3325  
 
RCIC Flow Controller (RSDP)  
 
1-CAC-TR-778  
 
Suppression Pool Water Temperature (RSDP)  


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
===Procedures===
 
: 0ASSD-00, "Users Guide," Rev. 38 0ASSD-01, "Alternative Safe Shutdown Procedure Index," Rev. 35 0ASSD-02, "Control Building," Rev. 50 1ASSD-04, "Unit 1 Train A Shutdown," Rev. 24 1ASSD-05, "Unit 1 Reactor Building North," Rev. 25 1ASSD-06, "Unit 1 Reactor Building South," Rev. 19
: 2ASSD-03, "Unit 2 Train B Shutdown," Rev. 22 2ASSD-04, "Unit 2 Train A Shutdown," Rev. 22 0AOP-38.0, "Loss of Fuel Pool Cooling," Rev. 23 0AP-033, "Fire Protection Program Manual," Rev. 13 0AP-050, "Site Command, Control, and Communications Procedure," Rev. 19
: 0EDMG-000, "Extreme Damage Mitigation Users Guide and Basis Document," Rev. 6 0EDMG-001, "Extreme Damage Mitigation Initial Response," Rev. 3 0E&RC-0040, "Administrative Controls for High Radiation Areas, Locked High Radiation Areas,  and Very High Radiation Areas, Rev. 32 0EOP-02- PCCP, "Primary Containment Control Procedure," 
: 1EOP-01-RSP, "Unit 1 Reactor Scram Procedure,"
: 1EOP-01-RVCP, "Reactor Vessel Control Procedure,"
: 0MST-ELU11SA, "Battery-Powered Emergency Lighting Units Functional Test," Rev. 2 0MST-ELU11FY, "Emergency Lighting Unit Battery Discharge Test," Rev. 0 0OP-41, Attachment 3, Fire Protection System Valve Line-up, Rev. 0 
: 0PFP-013, "General Fire Plan,'' Rev. 36 0PLP-01.1, Fire Protection Commitment Document, Rev. 34 0PLP-01.5, "Alternative Shutdown Capability Controls," Revision 11 0PT-48.4, "ASSD Sound - Powered Phone System Functional Test," Rev. 14 0PS-NGGC-1000, "Fleet Conduct of Operations," Rev. 5
: 0FPP-005, "Fire Watch Program," Rev. 29 0FPP-13, Transient Fire Load Evaluation, Rev. 500FPP-014, "Control of Combustible, Transient Fire Loads, and Ignition Sources," Rev. 34 0FPP-31, "Fire Brigade Staffing Roster and Equipment Requirements," Rev. 29 1EOP-01-RSP, "Unit 1 Reactor Scram Procedure," Rev. 8
: 0EOP-02- PCCP, "Primary Containment Control Procedure," Rev. 10 1EOP-01-RVCP, "Reactor Vessel Control Procedure," Rev. 8
: EGR-NGGC-0028, "Engineering Evaluation", Rev.0
: EGR-NGGC-0005, "Engineering Change," Rev. 31
: ENG-NGGC-0507, "Cable Aging Management Program," Rev. 3 0PT-34.7.2.1, "Hose Station Flow," Rev. 13 0PT-34.15.9.7, "Cable and Conduit Fire Barriers," Rev. 20
: Attachment 0PT-34.24.6.1, "Control Building Cable Spread Rooms Sprinkler System Operability Test,"
: Rev. 16 0OI-01.01, "BNP Conduct of Operations Supplement," Rev. 38 0OI-01.02, "BNP Operations Unit Organization and Operating Practices," Rev. 71
: Calculations, Analyses and Evaluations
: 7453-101-8-B21-57F, Appendix R - Spurious Operation Review, Rev. 1
: BNP-E-7.002, Momentary Duty Summary Report, Rev. 5
: BNP-E-7.010, Emergency Diesel Generator Static & Dynamic Load Study, Rev. 7
: BNP-E-8.010, AC Coordination Study, Rev. 11
: BNP-E-9.004, Safe Shutdown Analysis Report, Rev. 8
: BNP-E-9.006, Appendix R Separation Analysis, Rev. 6 704U-M-03/S2, Units 1 and 2 Evaluation Of Adequacy Of Diesel Generator Building HVAC Fire
: Dampers for Compliance with 10CFR50, Appendix R And CP&L Commitments Relevant To
: BTP APCSB 9.5-1, Rev. 000
: 1FP-0084, Hydraulic Calculations Unit 1 Reactor Building, 20 Foot Elevation East Water Curtain
: And Railroad Bay, Rev. 0 0FP-1042, Code Compliance Evaluation NFPA 13 Diesel Generator Building, Rev. 1
: 1-FP-0075, Hydraulic Calculation Unit 1 Cable Spreading Room, Rev. 0 2-FP-0074, Hydraulic Calculation Unit 2 Cable Spreading Room, Rev. 0 85-125-0-27-F, BSEP Fire Seal Evaluation, Rev. 1
: EER 84-0477, Barrier Evaluation Wall Common To 4160 Volt Switchgear Rooms E-1 and E-2,
: Rev. 0
: EER 89-0052, NFPA Standard 13 Sprinkler Location Deviation, Rev.0
: EC 0000046900, Evaluation of DG Fire Damper Requirements, Rev. 0
: EC 0000078830, Fire Suppression Sprinkler and Guard Replacement Unit 1, Rev. 0
: EC 51419, Cable Spreading Room Sprinkler Modifications, Rev. 0
: EC 0000051419, Convert CSR Sprinkler System from Manual to Auto, Rev. 2
: EC 50724, Control Building Fire Detection System Replacement, Rev. 0
: EC 68968, Install two diesel generators to charge safety related station batteries      during a station blackout event, Rev. 0
: EC 63168, Installation of a video camera on the refueling mast, Rev. 2
: EC 50932, DG Fire Detection System Replacement, Rev. 0
: EC 50933, Fire Detection System Change, Rev. 0
: EC 63168, Installation of a video camera on the refueling mast, Rev. 4
: EC 68968, Install two diesel generators to charge safety related station batteries      during a station blackout event, Rev. 6
: EC 47050, Circuit Breaker Change-out, Rev. 0
: EC 76455, Strategy Change for Surveillance Testing on DC Emergency Lighting Units, Rev. 0
: EC 77370, DG1 fire detection system, Rev. 2EC 74355, Lube oil piping fire barrier, Rev. 3
: EC 50934, Fire Detection System, Rev. 0
: EC 50934, Fire Detection System, Rev. 5
: NG-3514 (B), Fire Protection Program Evaluation, dated June 23, 1977 0FP-1017, Code Compliance Evaluation NFPA 24, Rev. 1
: 0FP-1018, Code Compliance Evaluation NFPA 20, Rev. 1 0FP-1030, Code Compliance Evaluation NFPA 14 - Diesel Generator Building, Rev. 1 0FP-1036, Code Compliance Evaluation NFPA 72E Units 1 and 2 RB, Rev. 1 0FP-1038, Code Compliance Evaluation NFPA 13 - Reactor Building, Rev. 1 0FP-1039, Code Compliance Evaluation NFPA 13 - Control Building Cable Spread Room 23
: Foot Elevation, Rev. 2 
: Attachment 0FP-1042, Code Compliance Evaluation NFPA 13 Diesel Generator Building, Rev. 1 0FPP-013, Transient Fire Load Evaluation(s) performed 8/02/2011, 8/16/2011, 8/30/2011,
: 9/13/2011, and 9/27/2011 Sheets 1.1, 1.2, 2.19 of Calculation 83-315-02, Pipe Support Analysis & Design for Fire
: Protection Appendix R Line No. Cable Spread Room Sprinkler System Unit 1, Rev. P Calculation
: BNP-E-8.010, Attachment F, Page F1, 4160 Volt Switchgear - Bus Common A, Rev. 7
: Calculation
: BNP-E-8.010, Attachment F, Page F2, 4160 Volt Switchgear - Bus Common A,
: Rev. 1 Calculation
: BNP-E-8.010, Attachment F, Page F2A, 4160 Volt Switchgear - Bus Common A,
: Rev. 6
: Calculation
: BNP-E-8.010, Attachment F, Page F2B, 4160 Volt Switchgear - Bus Common A,
: Rev. 6 Calculation
: BNP-E-8.010, Attachment F, Page F3, 4160 Volt Switchgear - Bus Common A,
: Rev. 1 Calculation
: BNP-E-8.010, Attachment F, Page F3A, 4160 Volt Switchgear - Bus Common A,
: Rev. 6 Calculation
: BNP-E-8.010, Attachment F, Page F3B, 4160 Volt Switchgear - Bus Common A, Rev. 6 Calculation
: BNP-E-8.010, Attachment F, Page F4, 4160 Volt Switchgear - Bus Common A,
: Rev. 0 Calculation
: BNP-E-5.036, Attachment A, Page A1, Ampacities of 3/C 5KV Interlocked Armor
: Power Cables in Tray (Single Layer/Maintained Spacing), Rev. 1
: Calculation
: BNP-E-5.036, Attachment E, Pages 17 & 18, Bus Interconnection Cables, Rev. 16 Calculation
: BNP-LR-664, License Renewal Aging Management Program Description of the
: Electrical Cables and Connections Not Subject To 10
: CFR 50.49 Environmental
: Qualification Requirements Program, Rev. 1 Calculation
: RNP-E-5.004, Intumastic 285 Fire Retardant Coating for Electrical Power and Control Cables from Carboline Company, dated May 16, 1979
: GE-NE-0000-0004-6894-01, Brunswick Nuclear Plant Unit 1 and 2 EPU
: WIN-41: Appendix R
: Fire Protection, Revision 0
: GE-NE-A22-00113-38-01, Brunswick Nuclear Plant Unit 1 and 2 Extended Power Uprate Task T0611: Appendix R Fire Protection, Revision 0 
===Drawings===
: LL-9113, Sheet 41, 4160 V SWGR "E3" Compt "AJ5" Tie Breaker to SWGR E1, Control Wiring Diagram, Rev. 4
: LL-9113, Sheet 41A, 4160 V SWGR "E3" Compt "AJ5" Tie Breaker to SWGR E1 Control Wiring Diagram, Rev. 10
: LL-9111, Sheet 45, 4160 VAC SWGR "E1" Compt "AG0" Tie Breaker to SWGR E3 Cable
: Diagram, Rev. 8
: LL-9113, Sheet 42, 4160 V SWGR "E3" Compt "AJ5" Tie Breaker to SWGR E1 Cable
: Diagram, Rev. 11
: LL-09113, Sheet 7C, Unit No. 2 4160V Switchgear "E3" Switch Development, Rev. 0
: LL-9111, Sheet 44, 4160 VAC SWGR "E1" Compt "AG0" Tie Breaker to SWGR E3 Control Wiring Diagram, Rev. 3
: LL-9111, Sheet 44A, 4160 VAC SWGR "E1" Compt "AG0" Tie Breaker to SWGR E3 Control
: Wiring Diagram, Rev. 9
: LL-30024, Sheet 5, Unit 1 125 - 250 Volt DC System Diesel Generator Building Distribution
: Panel 1B - HA8, Rev. 14
: Attachment
: LL-09114, Sheet 50, Unit 2 4160 Volt Switchgear "E4" 125V DC Control Power & 120V AC
: Heater Circuit Cable Diagram, Rev. 7
: LL-09114, Sheet 51, Unit 2 4160 Volt Switchgear "E4" 208/120V AC & 125V DC Control Bus
: Control Wiring Diagram, Rev. 2 F-09348, Sheet 6, Diesel Generator No.4 Circuits Control Wiring Diagram, Rev. 11
: LL-09234, Sheet 8, 480V Unit Substation "E8" Compartments "FB1" and "FN2" Power and Control Diagrams, Rev. 10
: LL-09234, Sheet 27, 480V Unit Substation "E8" Miscellaneous Cable Diagrams, Rev. 10 9527-LL-92055, Sheet 23, Unit No.1 - MCC "1PB" - Compt "1-BX8" Service Water Conv.
: Header Pump 1C Discharge Valve 1-SW-V17 Cable Diagram, Rev. 4
: 9527-LL-92055, Sheet 25, Unit No.1 - MCC "1PB" - Compt "1-BX9" Service Water Conv.
: Header Pump 1C Discharge Nuclear Header Valve 1-SW-V18 Cable Diagram, Rev. 4
: LL-92055, Sheet 24, Unit No. 1 - MCC "1PB" - Compt "1-BX9" Service Water Conv. Header
: Pump 1C Discharge Nuclear Header Valve 1-SW-V18 Control Wiring Diagram, Rev. 7
: LL-92055, Sheet 22, Unit No.1 - MCC "1PB" - Compt "1-BX8" Service Water Conv. Header
: Pump 1C Discharge Valve 1-SW-V17 Control Wiring Diagram, Rev. 7
: LL-03024, Sheet 4, 125 - 250 Volt DC System Diesel Generator Building Distribution Panel 2A-        "HC1," Rev. 13
: LL-09111, 4160 Volt Switchgear "E1" 125 Volt DC Control Power & 120 Volt AC Heater Circuit
: Cable Diagram, Rev. 8
: LL-09111, Sheet 7D, Unit 1 4160V Switchgear "E1" Switch Development, Rev. 0
: LL-09111, Sheet 44, 4160V SWGR "E1" Compartment "AG0" Tie Breaker to Switchgear "E3"
: Control Wiring Diagram, Rev. 3
: LL-09111, Sheet 44A, 4160 SWGR "E1" Compartment AG0 Tie Breaker to Switchgear "E3"
: Control Wiring Diagram, Rev. 9
: LL-09111, Sheet 45, 4160V SWGR "E1" Compartment "AG0" Tie Breaker to Switchgear "E3"
: Cable Diagram, Rev. 8
: LL-09111, Sheet 49, 4160V SWGR "E1" 208/120V AC & 125V DC Control Bus Control Wiring Diagram, Rev. 2
: LL-30024, Sheet 4, 125 - 250 Volt DC System Diesel Generator Building Distribution Panel 1A-  "HA7," Rev. 11
: LL-09113, Sheet 45, 4160 Volt Switchgear "E3" 125V DC Control Power & 120V AC Heater Circuit Cable Diagram, Rev. 9
: LL-09113, Sheet 46, 4160V SWGR "E3" 208/120V AC & 125V DC Control Bus Control Wiring Diagram, Rev. 4
: LL-09113, Sheet 41, 4160V SWGR "E3" Compartment "AJ5" Tie Breaker to SWGR E1 Control Wiring Diagram, Rev. 4
: LL-93041, Sheet 15, Unit No. 1 Emergency Power System 120/208 Volts AC 3Q 4W
: Distribution Panel 1A - DG "H32", Rev. 10
: LL-4105, Fire Protection Tank, Rev. 0 D-01398, Control Building Cable Spreading Rooms Structural Steel Framing Plan, Rev. 0 D-42013, Appendix R Safe Shutdown Analysis Residual Heat Removal System Shutdown Cooling Train-A, Rev. 11 D-42014, Appendix R Safe Shutdown Analysis Residual Heat Removal System Shutdown
: Cooling Train-B Unit 1, Rev. 16 D-42015, Appendix R Safe Shutdown Analysis Residual Heat Removal System, Torus Cooling Train A Unit 1, Rev. 10 D-42016, Appendix R Safe Shutdown Analysis Residual Heat Removal System, Torus Cooling Train B Unit 1, Rev. 14D-42017, Appendix R Safe Shutdown Analysis Reactor Core Isolation Cooling (RCIC) System
: Unit 1, Rev. 21 
: Attachment D-42019, Appendix R Safe Shutdown Analysis Plant Monitoring Instrumentation Unit 1, Rev. 21 D-42021, Appendix R Safe Shutdown Analysis Hi-Low Pressure unit 1, Rev. 6 F-03690, Sheet 5, Sound Powered Telephone System Cable and Interconnection Wiring
: Diagram Unit 1 and 2, Rev. 2 1-FP-81283, Unit 1 Cable Spreader Room Sprinkler System, Rev. C 2-FP-81281, Unit 2 Cable Spreader Room Sprinkler System, Rev. A
: D-02057, Plant Fire Protection System Piping Diagram, Rev. 6 D-03412, Sheet Nos. 2,3,4,6, and 9, Fire Protection Emergency DC Lighting, Rev. 0
: LL-83006, Unit 1, Sheets 1 - 3, Reactor Building Draft Curtain Details, Rev. 0 F-42025, Unit 1, Reactor Building Fire Protection System Plan at Elevation 20 Foot East, Rev. 0 F-04027, Control Building Drainage Floor El. 23'-0", Rev. 7
: F-04093, Sheet 1, Diesel Generator Building Ventilation System Plans, Rev. 22 F-04170, Sheets 1 - 2, Units 1 and 2 Fire Protection Fire Damper Schedule, Rev. 3
: PF-1161-FD-1, Sheet 1 - 2, Zero Clearance Fire Damper Model #'s
: FD-100-H &
: FD-200-H, Rev. 1
: LL-FB-07302, Sheet 1 & 2, Diesel Generator Building Fire Barrier Penetrations NW Switchgear Room North Wall Division II Elevation 50 Foot - 0 Inches, Rev. 4
: FSP-04020, Sheet 1 - 4, Water Treatment Building Fire Protection System Tanks and Pumps, Rev. 1 D-04106, Plant Fire Protection System Piping Diagram, Rev. 23 F-04020, Fire Protection Units 1 and 2 Tank and Fire Pumps Piping & Details, Rev. 16 0-FP-03097, 4160V, 3 Phase, 3W, 60 Hz 4KV Switchgear Bus Section E1 General Arrangement, Rev. A
: 0-FP-04115, Sump Pumps for Control Building
: SHW-D-10490, SHW P2230 Backdraft Damper W/Extra Deep Frame, Rev. C F-03896, Sheet 39, Fire Detection System Plan Diesel Generator Building EL. 50' - 0", Rev. 0 F-03896, Sheet 21, Fire Detection System Plan Reactor Building EL. 20' - 0", Rev. 0 F-03896, Sheet 5, Diesel Generator Building Fire Detection System Plans & Details, Rev. 26
: D-02043, Plant Fire Protection System Piping Diagram, Rev. 8 F-42025, Sheet 1, Unit No. 1 Reactor Building Fire Protection System Plan at Elevation 20' - 0" East, Rev. 0 F-025002, Reactor Building Grade Elevation 20'-0" General Arrangement, Rev. 21
: LL-83006, Sheets 1, 2, 3, Unit No. 1 Reactor Building Draft Curtain Details, Rev. 0
: 27-F-4027, Control Building Drainage Piping Floor El. 23' - 0", Rev. 7
: Completed Surveillance Procedures, Test Records, & Work Orders
: WO 1969050, Task 01, 2-SPP-JAC-JF9, ASSD Sound Powered Phone Jack is Inoperable, Completed August 29, 2011
: WO 0108397104, Diesel Building Fire Barrier Inspection, Completed 1/19/09WO
: 0108397112, Appendix A and Appendix R Fire Damper Inspection, Completed 2/2/2009
: WO 0187221601, Weekly Fire System Pressure Check, Completed 11/15/11
: WO 0182790901, Weekly Fire System Pressure Check, Completed 8/2/11
: WO 0183093701, Weekly Fire System Pressure Check, Completed 8/9/11
: WO 077591101, License Renewal Cable Aging Management (Open) 0PT-19.11.L, Safety Relief Valve Local Control Operability Test, Completed April 12, 2010
: 0PT-10.16.L, Remote Shutdown Panel RCIC Flow Controller, RCIC Manual Turbine Trip, and RCIC Turbine Trip Reset Local Control Operability Test, Completed July 1, 2011 0PT-34.6.7.10, Fire Barrier Penetration Seals Diesel Generator Building, Rev. 13, Completed 12/18/09 0PT-34.6.7.10, Fire Barrier Penetration Seals Diesel Generator Building, Rev. 15, Completed 6/23/11 
: Attachment 0PT-34.2.2.1, Fire Door, Pressure Boundary Door, ASSD Access/Egress Door, and Severe Weather Door Inspections, Rev. 39, Completed 1/17/11 0PT-34.2.2.1, Fire Door, Pressure Boundary Door, ASSD Access/Egress Door, and Severe Weather/Flood Control Door Inspections, Rev. 40, Completed 4/11/11 0PT-34.2.2.1, Fire Door, Pressure Boundary Door, ASSD Access/Egress Door, and Severe Weather/Flood Control Door Inspections, Rev. 41, Completed 7/09/11 0PT-34.2.2.1, Fire Door, Pressure Boundary Door, ASSD Access/Egress Door, and Severe Weather/Flood Control Door Inspections, Rev. 42, Completed 10/09/11 0PT-34.4.1.1, Unit 1 Reactor Building Fire Detection Instrument Operability Test, Completed
: 3/30/2011 0PT-34.7.2.1, Hose Station Flow, Rev. 13, Completed 9/7/11
: 0PT-34.24.6.1, Control Building Cable Spreading Rooms Sprinkler System Operability Test,
: Completed 9/22/2011
: Applicable Codes, Specifications, & Standards
: NFPA 13-1971, 1976, and 1983 Installation of Sprinkler Systems
: NFPA 14-1976, Fire Standpipe Systems NFPA 20-1971, Standard for the Installation of Centrifugal Fire Pumps
: NFPA 24-1973, Standard for the Installation of Private Service Mains ad their Appurtenances
: NFPA 72E-1974 and 2002, Standard on Automatic Fire Detectors
: Modifications
: 85-124, Rev. 30, DG2 Cell Vent Air Intake Fire Damper
: PM 85-124
: Technical Manuals & Vendor Information
: FP-81335, Lighting Emergency (Exide)
: EGR-NGGC-0006, Rev. 8
: Specification for Angus Fire Hose data Data Sheet #AHDS040, Angus Red Chief Heavy-Duty Rubber Attack Hose Data Sheet Dixon Industrial Fog Nozzles BRN150
: FP-8849, American Warming and Ventilating Dampers Installation, Operating and Maintenance
: Manual M80851, Rev. B
: Air Balance, Inc. Submittal Data 3-Hour Static Rated Damper, Model 319-A FP - P4277, Fairbanks Morse Pump Operation Maintenance Service and Repair Instructions, Rev. A
: FP-30118, Brown Boveri Electric ITE Medium Voltage Metal Enclosed Non-Segregated Phase Bus Duct Installation/Maintenance Instructions, Rev. C Edwards Systems Technology Photoelectric Smoke Detector Model #
: SIGA-PS
: Audits & Self-Assessments
: AR 00440002, BNP Fire Protection/Safe Shutdown Program Effectiveness Formal
: Self-Assessment Report, August 2011 B-FP-08-01, Nuclear Assessment, August 13, 2008 B-FP-10-1, Nuclear Assessment, August 2010 
: License Basis Documents
: CFR 50.48, Fire Protection 10
: CFR 50, Appendix A, Criterion 3, Fire Protection10
: CFR 50, Appendix R, Section
: III.G, Fire Protection of Safe Shutdown Capability 10
: CFR 50, Appendix R, Section
: III.J, Emergency Lighting 10
: CFR 50, Appendix R, Section
: III.L, Alternative and Dedicated Shutdown Capability
: Attachment BNP Unit 1 and Unit 2 Operating License Conditions 2.B (6), Fire Protection
: Appendix A, to USNRC Auxiliary Power Conversion System Branch (APCSB) Branch
: Technical Position (BTP) 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants,
: August 1976
: NRC Fire Protection Program Evaluation, dated June 23, 1977 NRC Safety Evaluation Reports dated November 22, 1977; as supplemented April 1979;
: June 11, 1980; December 30, 1986; December 6, 1989; July 28, 1993; and February 10, 1994 BNP UFSAR Section 9.5.1, Fire Protection System; and Plant Technical Specifications BNP Operating License Conditions 2.P, Unit 1; and 2.M Unit 2; Mitigation Strategy License Condition; 10
: CFR 50.54(hh)(2) 
===Other Documents===
: Pre-Fire Plan Attachment 3 Unit 1 Cable Spreading Room 23' Elevation, Rev.6
: Pre-Fire Plan Attachment 8 Unit 1 Reactor Building North 20' Elevation, Rev. 10 Pre-Fire Plan Attachment 13 E2 Switchgear Room Elevation 50, Rev. 15 Drill No. 03-F-RB-02, Fire in
: MCC-1XK, Rev. 2, Performed on 11/15/2011 (Observed) Drill No. 03-F-RB-02, Fire in
: MCC-1XK, Rev. 2, Performed on 9/17/2010 
: Drill No. 03-F-RB-02, Fire in
: MCC-1XK, Rev. 2, Performed on 11/2//2010
: Drill No. 03-F-RB-02, Fire in
: MCC-1XK, Rev. 2, Performed on 11/9/2010 Drill No. 03-F-RB-02, Fire in
: MCC-1XK, Rev. 2, Performed on 11/16/2010 Drill No. 03-F-RB-02, Fire in
: MCC-1XK, Rev. 2, Performed on 11/23/2010 Drill No. 10-F-DG-01, Fire in E-3 Switchgear, Rev. 0, Performed on 1/12/2010
: BPN Unit 2 Turnover Log, July 3, 2011 BPN Unit 2 Turnover Log, September 4, 2011 BPN Unit 2 Turnover Log, October 31, 2011
: ASSD-02-002-DRILL, 0ASSD-02 Control Building Fire with LOOP Requiring Unit 2 LPCI, Rev.0
: ASSD-02-001-DRILL, 0ASSD-02 Control Building Fire Requiring Unit 2 LPCI, Rev. 1
: CLS-LP-304, ASSD Procedure Training: Alternate Safe Shutdown, Rev. 5
: LOI-CLS-LP-304A, Licensed Operator Training: Alternative Safe Shutdown, ASSD Procedure Training: Alternate Safe Shutdown, Rev. 0
: AOI-CLS-LP-304A, Non-licensed Operator Training Alternative Safe Shutdown, ASSD Procedure Training, Rev. 0
: LOI-CLS-LP-016-A, Licensed Operator Training: Reactor Core Isolation Cooling (RCIC), Rev. 6 BPN Unit 0, 1, 2 and SW/Intake Open Hot Work Permits, 11/01/2011 BPN Self Identified Violations of the Transient Combustible Program, 11/01/2011 BNP Fire Incident Investigation Reports, 10/15/1985 to 11/01/2011 BNP Fire Protection Limiting Condition for Operability (LCO) Summary 11/01/2011
===Action Requests===
(ARs) / Nuclear Condition Reports (NCRs) Reviewed During Inspection
: ACR B-92-651, High Voltage Cables in DG Building Discoloration on Fire Coating
: AR 00440002, Conduct Self- Assessment of Fire Protection
: AR 00486464, Configuration Control NFPA Code Compliance Calculation
: AR 00493784, Safe Shutdown Analysis Discrepancies
: AR 00073402, NRC Non-Cited Violation - Cable Spread Room Sprinkler Design
: AR 00486588, SA #440002, D5, Fire Brigade Training
: AR 00486586, SA #440002, D3, Insufficient Site Priorities on Fire Protection Program Maintenance
: AR 00481752, Inadequate Time Line Margin for Startup of RCIC at the RSDP
: Attachment ARs/NCRs/Procedure Revision Requests (PRRs) Generated as a Result of this Inspection
: AR 00499144, NCR, Maintaining Control Room Minimum Staffing During ASSD Procedures
: AR 00497681, NCR, Determination of Credited Communication Method for EDMGS
: AR 00496983, NCR, Labels Reading "Hot" on 120 VAC & 125 VDC Panels in 4 KV E-Bus
: AR 00496998, NCR, Drawing 1-FP-81283 Erroneous Information
: AR 00497159, NCR, MWT Building Roof Leak Above Diesel Fire Pump Batteries
: AR 00497468, NCR, Procedure 1ASSD-05 Incorrectly Lists MCC 1XB
: AR 00497514, NCR, Availability of Locked High Rad Area Keys for ERO
: AR 00497529, NCR, Drawing
: LL-09234 Sheet 27 Should Be Labeled Units 1 and 2
: AR 00497553, NCR, Revise the BCAMS Data Base to Capture Exposed Cabling
: AR 00497450, PRR, 1ASSD-05
: AR 00499962, NCR, Ampacity Calculation
: BNP-E-5.036 Contains an Error
: AR 00499975, NCR, Coordination Calculation
: BNP-E-8.010 Contains an Error
: AR 00499600, NCR, Additional Clarification Needed For Evaluation 85-125-0-27-F
: AR 00499666, NCR, Cable
: DW1-L6G/1 Not Identified As Appendix R Related
: AR 00499773, NCR, Letter of Agreement with Off-Site Support Agencies (Southport FD)
: AR 00499995, NCR,
: PLP-01.1 Commitment
: EL-004 Notes Need to be Revised
: AR 00500079, NCR, Hot Short or Fault May Potentially Impact E2 Fire Damper
: AR 00497563, PRR, 0PT-34.5.1.5, Lubricate Valves
==LIST OF ACRONYMS==
: [[AND]] [[]]
: [[ABBREV]] [[IATIONS]]
: [[AR]] [[Action Request]]
: [[BNP]] [[Brunswick Nuclear Plant]]
: [[BTP]] [[Branch Technical Position]]
: [[CAP]] [[Corrective Action Program]]
: [[CFR]] [[Code of Federal Regulations]]
: [[EC]] [[Engineering Change]]
: [[EOP]] [[Emergency Operating Procedure]]
: [[ERFBS]] [[Electrical Raceway Fire Barrier System]]
: [[FA]] [[Fire Area]]
: [[FHA]] [[Fire Hazards Analysis]]
: [[FPP]] [[Fire Protection Program]]
: [[FZ]] [[Fire Zone]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[MCC]] [[Motor Control Center]]
: [[IP]] [[Inspection Procedure]]
: [[NCR]] [[Nuclear Condition Report]]
: [[NFPA]] [[National Fire Protection Association]]
: [[NRC]] [[United States Nuclear Regulatory Commission]]
: [[OMA]] [[Operator Manual Action]]
: [[PRR]] [[Procedure Revision Request]]
: [[RB]] [[Reactor Building]]
: [[RCIC]] [[Reactor Core Isolation Cooling Rev  Revision]]
: [[ROP]] [[Reactor Oversight Process]]
: [[RSDP]] [[Remote Shutdown Panel]]
: [[SDP]] [[Significance Determination Process]]
: [[SER]] [[Safety Evaluation Report]]
: [[SSA]] [[Safe Shutdown Analysis]]
: [[SSC]] [[Structures, Systems and Components]]
: [[SSD]] [[Safe Shutdown]]
: [[UFSAR]] [[Updated Final Safety Analysis Report]]
}}
}}

Latest revision as of 21:16, 12 January 2025

IR 05000325-11-011, 05000324-11-011; on 10/31 - 11/04/2011, and 11/14 - 18/2011; Brunswick Steam Electric Plant; Fire Protection and Other Activities
ML113640026
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 12/30/2011
From: Reinaldo Rodriguez
NRC/RGN-II/DRS/EB2
To: Annacone M, Annacone M
Carolina Power & Light Co
References
IR-11-011
Download: ML113640026 (29)


Text

December 30, 2011

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT - NRC TRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000325/2011011 AND

05000324/2011011

Dear Mr. Annacone:

On November 18, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed inspection report documents the inspection results, which were discussed on November 17, 2011, with you and other members of your staff.

The inspection examined activities conducted under your licenses 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.

Based on the results of this inspection, no findings were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of

Progress Energy NRC's 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/

Reinaldo Rodriguez, Acting Chief Engineering Branch 2 Division of Reactor Safety

Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62

Enclosure:

Triennial Fire Protection Inspection Report 05000325/2011011 and 05000324/2011011 w/Attachment: Supplemental Information

REGION II==

Docket Nos.:

50-325, 50-324

License Nos.:

DPR-71, DPR-62

Report Nos.:

05000325/2011011 and 05000324/2011011

Licensee:

Carolina Power and Light (CP&L)

Facility:

Brunswick Steam Electric Plant, Units 1 and 2

Location:

8470 River Rd SE

Southport, NC 28461

Dates:

October 31 - November 4, 2011 (Week 1)

November 14 - 18, 2011 (Week 2)

Inspectors:

M. Thomas, Senior Reactor Inspector (Lead Inspector)

J. Dymek, Reactor Inspector

R. Fanner, Reactor Inspector

L. Suggs, Reactor Inspector

Accompanying

N. Merriweather, Senior Reactor Inspector (Weeks 1 and 2)

Personnel:

E. Patterson, Construction Inspector (Weeks 1 and 2)

M. Riches, Operations Engineer (Week 1 only)

G. Wiseman, Senior Reactor Inspector (Week 1 only)

Approved by:

Reinaldo Rodriguez, Acting Chief

Engineering Branch 2

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000325, 324/2011-011; 10/31 - 11/04/2011, and 11/14 - 18/2011; Brunswick Steam

Electric Plant; Fire Protection and Other Activities

This report covers an announced two-week period of inspection by a triennial fire protection team composed of four regional inspectors. No findings were identified during this inspection period.

NRC-Identified and Self-Revealing Findings

None

Licensee Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R05 Fire Protection

This report documents the results of a triennial fire protection inspection of the Brunswick Steam Electric Plant (also referred to as Brunswick Nuclear Plant (BNP)),

Units 1 and 2. The inspection was conducted in accordance with the guidance provided in NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), dated August 1, 2011. The objective of the inspection was to review a minimum sample of three risk-significant fire areas (FAs) to evaluate implementation of the fire protection program (FPP), and to review site specific implementation of at least one B.5.b mitigating strategy as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs, and associated fire zones (FZs) were chosen based on a review of available risk information as analyzed by a senior reactor analyst from Region II, a review of previous inspection results, plant walkdowns of FAs, consideration of relational characteristics of combustible material to targets, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. In selecting a B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports (SER), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-02 of the IP specifies a minimum sample size of three FAs and one B.5.b implementing strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the procedure by selecting a sample of three FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:

1. Control Building 49-foot elevation, FA CB-23 (Unit 1 Main Control Room).

2. Reactor Building 20-foot elevation, FA RB1-1g (North East, East Central, and

South East).

3. Diesel Generator Building 50 foot elevation, FA DG-12 (4160 Volt AC

switchgear Division II, E2).

The inspectors evaluated the licensees FPP against applicable requirements, including BNP Unit 1 Operating License Condition 2.B(6) and Unit 2 Operating License Condition 2.B(6), Fire Protection; Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criteria 3, Fire Protection; 10 CFR Part 50, Appendix R Subsections III.G, III.J, and III.L; 10 CFR 50.48, Fire Protection; Appendix A to NRC Auxiliary Power Conversion System Branch (APCSB) Branch Technical Position (BTP)9.5-1, Guidelines For Fire Protection For Nuclear Power Plants, August 1976; NRC Safety Evaluation Reports dated November 22, 1977, as supplemented April 1979, June 11, 1980, December 30, 1986, December 6, 1989, July 28, 1993, and February 10, 1994; BNP Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, Fire Protection System; and plant Technical Specifications. The review of the B.5.b mitigating strategies was based on the BNP Operating License Conditions 2.P for Unit 1, and 2.M for Unit 2, Mitigation Strategy License Condition; licensee B.5.b submittals; 10 CFR 50.54(hh)(2); and related NRC SERs. The inspectors evaluated all areas of this inspection, as documented below, against these requirements. Specific licensing basis documents reviewed are listed in the Attachment.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The inspectors evaluated the licensees ability to achieve hot and cold shutdown assuming a postulated fire in selected FAs. The inspectors examined those fire protection features provided to limit fire damage to structures, systems and components (SSCs) important to post-fire SSD as required by the approved FPP. The inspectors selected a sample of SSD systems to evaluate the licensees ability to safely shutdown the plant. The components and systems examined included reactor coolant makeup, reactor heat removal, and associated support systems such as the electrical power distribution system, service water and heating ventilation and air conditioning systems.

The inspectors performed in-plant walkdowns of selected FAs to observe:

(1) the material condition of fire protection systems and equipment;
(2) the storage of permanent and transient combustibles;
(3) the proximity of fire hazards to cables relied upon for SSD; and
(4) the licensees implementation of procedures and processes for limiting fire hazards, housekeeping practices, and compensatory measures for inoperable or degraded fire protection systems and credited fire barriers. Reviews were accomplished to ensure that the licensee was maintaining the fire protection systems, had properly evaluated the in-situ combustible fire loads, controlled hot-work activities, and limited transient fire hazards in a manner consistent with operating license conditions, regulatory requirements, and plant administrative and FPP procedures.

The inspectors reviewed calculation 7453-101-8-B-21-57F, Appendix R Spurious Operations Analysis, which identified components that could be susceptible to spurious operations, which could, in turn, affect redundant trains of equipment or other credited SSD systems. Components identified in this calculation were compared to components identified in the licensees separation analysis and fire hazards analysis (FHA). The licensee indicated that calculation 7453-101-8-B-21-57F was no longer being updated and was neither used in the development of nor referenced in the safe shutdown analysis (SSA) or FHA. The inspectors reviewed the documents to verify that the licensee had reconciled the differences for each component indentified in the calculation.

The inspectors reviewed the pre-fire plans for selected FAs to determine if information provided to the fire brigade was adequate to 1) identify equipment important to SSD; 2)facilitate fire suppression activities; and 3) remove smoke and/or water runoff so that operator manual actions (OMAs) required for SSD could be accomplished. The location and proper storage of compressed gas cylinders within the reactor building (RB) was also reviewed to determine if they represented a fire or missile hazard to equipment or cables required for SSD.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

For the selected FAs, the inspectors evaluated the adequacy of fire barrier walls, ceilings, floors, mechanical and electrical penetrations, fire doors, fire dampers and electrical raceway fire barrier systems (ERFBS). The inspectors walked down accessible portions of the selected FAs to observe material condition of the fire barriers including the use of portable cameras for inspection of penetrations in the overhead.

The inspectors reviewed the design of selected ERFBS to confirm that appropriate materials and construction methods were used to assure that the respective fire barriers met their intended design function. The inspectors reviewed the fire protection data system for selected and adjoining FAs to verify that the plant fire loading used by the licensee was appropriate for the stated fire resistance rating of the enclosures. The inspectors reviewed recently completed surveillance procedures for fire doors, penetration seals and ERFBS.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

For the selected FAs, the inspectors performed in-plant observations of the material condition and operational line-up of fire detection, fire protection water supply, automatic wet pipe sprinkler systems and manual fire hose and standpipe systems. The inspectors reviewed the adequacy of the design and installation of fire suppression systems in the selected FAs. This was accomplished by review of system vendor drawings, calculations, and code compliance reviews. The inspectors evaluated if the fire detection and suppression methods were appropriate for the hazards in the selected FAs. The inspectors compared the fire detection and fire suppression systems to the applicable code of record for National Fire Protection Association (NFPA) Standard(s) for the selected FAs by reviewing the system design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The inspectors reviewed recently completed surveillance procedures for fire detection and fire sprinkler systems in the selected FAs and compared them to the BNP FPP.

For the selected FAs, the inspectors compared the pre-fire plan strategy of each FA to existing plant layout and equipment configurations and the fire response procedures.

The inspectors assessed the condition of firefighting and smoke removal equipment by inspecting the equipment located in the fire brigade equipment staging and storage areas. The inspectors reviewed fire brigade drill planning and evaluation report records for drills performed in the control building, RB 20 foot elevation, and the diesel generator building 50 foot elevation performed in 2010 and 2011. The inspectors assessed the fire brigade fire fighting activities by observing an announced drill in the RB 20 foot elevation.

The inspectors review of specific attributes of fire brigade conduct for these drills included strategy and tactics, command and control, use of fire brigade equipment, radio communications, and time-lines for alarm, assembly and first mitigating events (i.e.

suppression).

b. Findings

No findings were identified.

.04 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The inspectors evaluated whether the installed automatic wet pipe sprinkler systems or manual fire fighting activities could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment or adversely affect OMAs required for SSD for the selected FAs. The inspectors considered the consequences of a rupture, inadvertent operation or actual operation of a fire suppression system concurrent with manual fire fighting activities as could result from a fully involved fire in one of the selected FAs. The inspectors reviewed BNP operating experience reviews for NRC Information Notice 98-31, Fire Protection System Design Deficiencies and Common Mode Flooding of Emergency Core Cooling Rooms at Washington Nuclear Project Unit

2. The inspectors reviewed pre-fire plans which addressed the opening of doors to

drain water or ventilate smoke so that OMAs could be performed. The inspectors observed inspection activities of penetration seals and condition monitoring of structures to address potential damage from water leaking through floor slabs to equipment below.

The inspectors measured curb heights above the floor for installed equipment and visually checked floor slope to determine if water could inadvertently pool in such a manner as to adversely affect SSD equipment or OMAs.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

Methodology

For a postulated fire in any of the selected FAs, the licensee credited alternative shutdown capability to achieve hot and cold shutdown. The licensee defined alternative shutdown as SSD activities requiring utilization of abnormal operational practices:

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Operations other than normal SSD activities from the main control room

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Operations from designated alternative control system locations and/or

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Manual operation at equipment locations The inspectors examined the following BNP fire response procedures and emergency operating procedures (EOP):

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1ASSD-04, Unit 1 Train A Shutdown

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1ASSD-05, Unit 1 Reactor Building North

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1ASSD-06, Unit 1 Reactor Building South

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0ASSD-02, Control Building ASSD-00, Users Guide ASSD-01, Alternative Safe Shutdown Procedure Index

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2ASSD-03, Unit 2 Train B Shutdown

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2ASSD-04, Unit 2 Train A Shutdown

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0PFP-013, General Fire Plan

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1EOP-01-RSP, Unit 1 Reactor Scram Procedure

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0EOP-02-PCCP, Primary Containment Control Procedure

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1EOP-01-RVCP, Reactor Vessel Control Procedure

The inspectors compared the procedures to the FHA, SSA, flow diagrams, and other design basis documents to determine if equipment required for post-fire SSD was properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G and the approved FPP. The inspectors reviewed cable routing information by FA for a selected sample of SSD components to verify that cables would not be damaged by a fire in the selected FAs or the licensees analysis determined that the fire damage would not prohibit safe shutdown. In cases where OMAs were credited in-lieu of cable protection of SSD equipment, the inspectors reviewed selected OMAs to verify that the OMAs were feasible utilizing the guidance of the NRC IP. A list of SSD components examined for cable routing is included in the Attachment.

Operational Implementation

The inspectors reviewed applicable sections of procedures 0PFP-13, 0ASSD-01, 0ASSD-02, 1ASSD-04, 1ASSD-05, 1ASSD-06 for FAs CB-23, RB1-1g, and DG-12 to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain SSD conditions. The inspectors assessed the timeliness of the operators in identifying and assessing the initial plant conditions, response to suspected fire, and subsequent actions credited afterwards. The inspectors performed a walk-through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The inspectors reviewed the licensee shift staffing of personnel credited for procedure implementation to verify personnel had procedures available, were trained on implementation, and were available in the event a fire occurred. The inspectors also reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.

Procedure 0PLP-01.5, Alternative Shutdown Capability Controls, established controls to provide reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. The inspectors reviewed records of the most recently completed functional tests for a sample of the Appendix R transfer switches, relays and remote shutdown panel. The testing was performed by the following test procedures:

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Maintenance Surveillance Test procedure 1MST-RSDP21R, RSDP and RTGB Panel Reactor Water Level Indication Channel Calibration, completed on January 13, 2011.

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Operability Test, 0PT-19.11.L, Safety Relief Valve Local Control Operability Test, completed April 12, 2010

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Operability Test, 0PT-10.16.L, Remote Shutdown Panel RCIC Flow Controller, RCIC Manual Turbine Trip, and RCIC Turbine Trip Reset Local Control Operability Test, completed July 1, 2011

The tests objectives were to demonstrate the capability to transfer plant controls from the main control room to the remote shutdown panel or local control station. The inspectors reviewed the records to verify that testing was performed satisfactorily and that test deficiencies were properly entered and corrected by the corrective action program.

b. Findings

No findings were identified.

.06 Circuit Analyses

a. Inspection Scope

The inspectors assessed whether the licensee identified the SSCs important to meeting the 10 CFR Part 50.48 requirements consistent with the established licensing basis.

The inspectors reviewed training material, UFSAR, and system flow drawings to assess the likelihood of flow diversion paths, loss of function, or other scenarios that would adversely impact the plants ability to achieve and maintain SSD conditions. The inspectors reviewed licensee SSD procedures and compared them with the post-fire SSA and separation analysis for the selected FAs. For areas where there were questions, the inspectors performed more detailed circuit analysis to verify fire induced damage would not adversely impact the credited SSD methodology.

During a walkdown of Fire Area DG-12, E2 Switchgear Room, the inspectors identified conduits associated with the credited SSD train traversing the FA. These conduits contained the following cables, which were served from the 120/208VAC distribution panel 1-1A-DG:

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H32-R43, circuit 9, Load Power Cable for E1-E3 Bus Duct Heater

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H32-H82, circuit 18, RHRSW Pump 1A Control Panel H82 Bus E-3

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AF3-H32, circuit 23, 4160 Switchgear E1 Heater and Control Bus

The inspectors verified that none of these components were required for SSD.

However, since they were associated with the credited shutdown train, inspectors reviewed the licensees breaker coordination analysis to ensure that fire damage to these cables would not interrupt the SSD capability.

The inspectors also reviewed a sample of SSD components to verify that the components specified in the post-fire SSD procedures were available for a postulated fire in any of the selected FAs. The cables examined were based upon a list of SSD components selected by the inspectors after a review of the licensees separation analysis, FHA, and the system flow drawings. The results of this review were compared with the licensees circuit analysis, electrical design drawings, Appendix R SSA, and the operations post-fire SSD procedures. The specific components reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The inspectors reviewed the communications systems (sound powered phones and radios) to evaluate the availability and capability of systems used to support plant personnel in the performance of OMAs to achieve and maintain SSD conditions. During observation of an announced fire brigade drill the inspectors verified that the radio communication system functioned reliably at different locations within the plant. The inspectors walked down the SSD procedures at various locations with operators to verify designated sound powered phone jacks were available to licensee personnel. The inspectors reviewed the inventory records to ensure credited sound powered phones were available at the designated locations specified by procedures. The inspectors reviewed routing information for the sound powered phone system to determine if fire induced faults would damage credited circuits. During this review, the inspectors considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns. On a sampling basis, the inspectors had the operators perform sound powered phone and radio checks to ensure communications were available and reliable.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The inspectors performed plant walkdowns with operations staff on various post-fire SSD procedures for the selected FAs to observe the placement and coverage area of credited fixed 8-hour battery pack emergency lights. The inspectors evaluated the lights to ensure they provided adequate illumination of access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post fire SSD.

In instances where 8-hour battery pack emergency lights were not credited inspectors verified the credited lighting systems would be available for operators under post-fire SSD conditions.

The inspectors reviewed the licensees maintenance and test records to ensure the design aspects of the fixed emergency lighting met the 8-hour capacity requirements specified in commitments. The inspectors reviewed the applicable vendor documentation to ensure the lighting units were maintained consistent with vendor recommendations. The inspectors reviewed completed preventive maintenance and surveillance testing records to ensure adequate surveillance testing was conducted. For lights not meeting the acceptance criteria the inspectors verified work-orders were written to address the issues. A list of documents reviewed is included in the Attachment.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the licensees alternative safe shutdown procedures and verified that cold shutdown repairs were not required to achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after a fire event assuming no offsite power was available.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

For the selected FAs, the inspectors reviewed the administrative controls for out-of service, degraded and/or inoperable fire protection features such as detection and suppression systems, and passive fire barriers. The inspectors reviewed databases containing current fire protection impairments and compared them to the FAs selected for the inspection. Fire detection and suppression system impairments were reviewed against operability requirements and compensatory measures outlined in the BNP FPP.

The inspectors reviewed this information to determine if the risk associated with removing the fire protection feature from service was adequately addressed with appropriate compensatory measures. The inspectors reviewed unplanned fire protection action statement entries for such items as system malfunction, failure, inadvertent actuation, out of specification operating parameters and surveillance test failures. Entry and closure dates of impaired fire protection items tracked were assessed to determine if restoration to normal operating mode was being done in a timely manner and met the overall objectives of control and compensatory measures outlined in the BNP FPP.

The inspectors reviewed actions for nuclear condition report (NCR) 493784 to verify that the licensee implemented compensatory measures (in the form of a roving fire watch) as a result of deficiencies identified during their NFPA 805 SSD revalidation project. The inspectors reviewed the fire protection and fire watch training program documents as well as training records for personnel tasked with performing fire watch responsibilities to ensure that individuals were properly instructed and qualified to perform the task.

b. Findings

No findings were identified.

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The inspectors reviewed a sample of FPP changes made between November 2008 and November 2011 to assess the licensees effectiveness to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse effect on the ability to achieve SSD.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The inspectors reviewed the controls for combustibles and ignition sources throughout the plant to verify that they were in compliance with the BNP FPP. The inspectors verified that the transient combustible materials and locations of transient combustible materials were being controlled in accordance with the licensees administrative control procedures and the licensees fire probabilistic risk assessment. The inspectors also reviewed and observed hot work that was being performed at the time of the inspection to verify that it was accomplished in accordance with the licensees administrative control procedures.

b. Findings

No findings were identified.

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed, on a sampling basis, the licensees condensate storage tank and hot-well makeup mitigation strategies to verify that the measures were feasible, personnel were trained to implement the strategies, and equipment was properly staged and maintained. The inspectors requested and reviewed inventory and maintenance records of required equipment. The inspectors had discussions with plant staff, reviewed relevant documentation, and performed plant walkdowns with licensee staff.

The inspectors reviewed applicable calculations for the selected strategies to verify the calculations provided an adequate engineering basis to support the appropriateness for the strategies. The inspectors assessed if the strategies could be met with the procedures, equipment, staff training, and water sources provided. The inspectors reviewed the design requirements of the credited equipment to verify the licensees capability to provide a reliable and available water source, and the ability to provide the minimum fuel supply. The inspectors reviewed completed test records and performed a physical inspection to verify that B.5.b equipment was being properly stored, maintained, and tested in accordance with the licensees B.5.b program procedures. The inspectors performed a walkdown of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures were available, calibrated, and maintained.

The inspectors reviewed training and qualification requirements for operators, fire brigade, emergency response organization, and new employees for the implementation of actions needed to mitigate a B.5.b related event. The inspectors reviewed training records of the licensees staff to verify that operator training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed recent independent licensee audits for thoroughness, completeness and conformance to requirements. The inspectors reviewed other corrective action program (CAP) documents, including completed corrective actions documented in selected NCRs to verify that industry-identified fire protection problems potentially or actually affecting the plant were appropriately entered into, and resolved by, the CAP process. The NCRs were reviewed with regard to the attributes of timeliness and apparent cause determination to ensure that proposed corrective actions addressed the apparent cause, reportability and operability determination.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On November 17, 2011, the lead inspector presented the inspection results to Mr. M.

Annacone, BNP Site Vice President, and other members of his staff. The licensee acknowledged the results. The lead inspector informed the licensee that proprietary information reviewed would not be included in this inspection report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Allen, Fire Protection System Engineer
M. Annacone, Vice President, BNP
J. Becker, Engineering Programs Supervisor
C. Browne, NFPA 805 Project
R. Brusselman, Fire Protection
D. Bryant, Operations Fire Protection
J. Burke, Engineering Director
C. Chan, Safe Shutdown Engineer
D. Dearie, Operations Senior Reactor Operator
P. Dubrouillet, Training Manager
J. Frisco, Plant General Manager
S. Hardy, Appendix R Safe Shutdown Engineer
A. Holder, Corporate Fire Protection
P. Mentel, Support Services Manager
R. Mosier, Corporate Communications
A. Pope, Supervisor Licensing
T. Rouns, Fire Protection Program Manager
K. Sawyer, Operations Training
T. Sherrill, Licensing Engineer
M. Souther, Support Systems Supervisor
R. Stewart, NFPA 805 Project Manager
R. Tart, NFPA 805 Transition Engineer
M. White, Fire Protection Coordinator

NRC personnel

H. Christensen, Deputy Division Director, Division of Reactor Safety, NRC Region II
P. OBryan, Senior Resident Inspector, BNP, NRC Region II
M. Schwieg, Resident Inspector, BNP, NRC Region II

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

LIST OF COMPONENTS REVIEWED (Refer to Report Section 1R05.01 / 1R05.05 / 1R05.06 - Circuit Analyses)

Component Identification

Description

Valves

1-SW-V19

MN STM to FWP & TURB BP, SG A

1-E41-F002

HPCI Steam Supply Line Isolation MO 1-E41-F007

HPCI Pump Discharge MO 1-E41-F012

HPCI Bypass to Suppression Pool MO 1-E11-F020A

RHR 1A & 1C Suppression Pool Suction Valve MO

1-SW-V17-MO

Conventional SW PMP C Discharge Valve

1-SW-V18-MO

Conventional SW PMP C Discharge Valve

Pump Motors

1-SW-1A-NUC-PMP-M

1A Nuclear Service Water Pump Motor

2-SW-2A-NUC-PMP-M

2A Nuclear Service Water Pump Motor

2-SW-2B-NUC-PMP-M

2B Nuclear Service Water Pump Motor

1-SW-1B-NUC-PMP-M

1B Nuclear Service Water Pump Motor

Ventilation Fan

2-VA-B-EF-DG

4160 VAC E2 Exhaust Fan

Switchgear

1-E1

Unit 1 4KV Emergency SWGR E1

2-E3

Unit 2 4KV Emergency SWGR E3 2-E4

Unit 2 4KV Emergency SWGR E4

Breakers

KV E3 Compartment AJ5 Tie Breaker To SWGR E1

KV E1 Compartment AG0 Tie Breaker To SWGR E3

Communications

1-SPP-JAC-AH0 Sound Powered Phone Jack @ E2 4KV SWGR AH0

Emergency Diesel Generators

2-DG4-GEN

Diesel Generator No. 4

Instruments

1-CAC-TR-4426-1A

Suppression Pool Temperature (MCR)

1-CAC-LR-2602

Suppression Pool Level (MCR)

1-B21-PI-R605A

Reactor Pressure (MCR)

1-C32-LI-R606A

Reactor Water Level (MCR)

1-B21-LI-R604A

Reactor Water Level (MCR)

1-CO-LIT-1160

CST Level (local at CST)

1-B21-LI-5977

Reactor Water Level (RSDP)

1-E51-FIC-3325

RCIC Flow Controller (RSDP)

1-CAC-TR-778

Suppression Pool Water Temperature (RSDP)

LIST OF DOCUMENTS REVIEWED