IR 05000280/2012011: Difference between revisions

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{{Adams
{{Adams
| number = ML121450437
| number = ML12279A308
| issue date = 05/23/2012
| issue date = 10/04/2012
| title = Notification of Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000280-12-011 and 05000281-12-011)
| title = IR 05000280-12-011 & 05000281-12-011; Virginia Electric and Power Company; 07/30/2012 - 08/03/2012; Surry Power Station, NRC Triennial Fire Protection Inspection Report
| author name = King M
| author name = King M
| author affiliation = NRC/RGN-II/DNMS, NRC/RGN-II/DRS/EB2
| author affiliation = NRC/RGN-II/DRS/EB2
| addressee name = Heacock D
| addressee name = Heacock D
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
Line 10: Line 10:
| license number = DPR-032, DPR-037
| license number = DPR-032, DPR-037
| contact person =  
| contact person =  
| case reference number = FOIA/PA-2013-0030, FOIA/PA-2013-0139
| document report number = IR-12-011
| document report number = IR-12-011
| document type = Letter
| document type = Inspection Report, Letter
| page count = 9
| page count = 31
}}
}}


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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION May 23, 2012
{{#Wiki_filter:UNITED STATES tober 4, 2012


==SUBJECT:==
==SUBJECT:==
SURRY POWER STATION, UNITS 1 AND 2 - NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION REPORT 05000280/2012011 AND 05000281/2012011)
SURRY POWER STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT NOS. 05000280/2012011 AND 05000281/2012011


==Dear Heacock:==
==Dear Mr. Heacock:==
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
On August 24, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed with Mr. R. Johnson, Surry Power Station Manager of Operations, and other members of your staff on August 24, 2012. Subsequently, additional in-office reviews were conducted and the final inspection results were discussed by telephone with Mr. F. Mladen, Director Station Safety and Licensing, and other members of your staff on September 12, 2012.
Region II staff will conduct a triennial fire protection baseline inspection at the Surry Power Station, Units 1 and 2, in July and August 2012. McKenzie Thomas, Senior Reactor Inspector, will lead the team which will be composed of inspectors from the NRC Region II Office. The inspection will be conducted in accordance with Inspection Procedure 71111.05T, the NRC=s triennial fire protection baseline inspection procedure dated October 28, 2011.


The inspection objective will be to evaluate your fire protection program implementation with emphasis on post-fire safe shutdown capability and the fire protection features provided to ensure at least one post-fire safe shutdown success path is maintained free of fire damage.
The inspection examined activities conducted under your license as they related to safety and compliance with the Commissions rules and regulations and with the conditions of your license.


The inspection team will focus their review on the systems and equipment necessary to achieve and maintain safe shutdown and the fire protection features of selected fire areas.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.


On May 16, 2012, during a telephone conversation between Mr. Barry Garber, Surry Licensing Supervisor, and Mrs. LaDonna Suggs, our respective staffs confirmed arrangements for a three-day information gathering onsite visit and a two-week onsite inspection. The schedule for the inspection is:
No NRC-identified or self-revealing findings were identified during this inspection. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Surry Power Station.
* Information gathering visit: July 10 - 12, 2012
* Week 1 of onsite inspection: July 30 - August 3, 2012
* Week 2 of onsite inspection: August 13 - 17, 2012


VEPCO  2 The purposes of the information gathering visit are to obtain information and documentation needed to support the inspection, and to become familiar with the Surry Power Station fire protection program, fire protection features, post-fire shutdown capabilities and plant layout mitigating strategies to address Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures, dated February 25, 2002, and Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2); and, as necessary, obtain plant-specific site access training and badging for unescorted site access. A list of the types of documents the team may be interested in reviewing, and possibly obtaining, are listed in Enclosures 1 and 2.
In accordance with 10 CFR 2.390 of the NRCs 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 NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Please contact McKenzie Thomas or Rodney Fanner prior to preparing copies of the materials listed in the Enclosure. The inspection team will try to minimize your administrative burden by specifically identifying those documents required for inspection preparation.
Sincerely,
/RA/
Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37
 
===Enclosure:===
Inspection Report 05000280/2012011, 05000281/2012011 w/Attachment: Supplemental Information
 
REGION II==
Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report Nos.: 05000280/2012011 and 05000281/2012011 Licensee: Virginia Electric and Power Company Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Road Surry, VA 23883 Dates: July 30 - August 3, 2012 (Week 1)
August 20-24, 2012 (Week 2)
Inspectors: G. Wiseman, Senior Reactor Inspector (Lead Inspector)
M. Thomas, Senior Reactor Inspector R. Fanner, Reactor Inspector J. Dymek, Reactor Inspector Approved by: Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
 
=SUMMARY OF FINDINGS=
IR 05000280/2012011, 05000281/2012011; 07/30 - 08/03/2012 and 08/20 - 24/2012; Surry
 
Power Station, Units 1 and 2; Triennial Fire Protection Inspection This report covers an announced two-week triennial fire protection inspection by a team of four regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.
 
===NRC-Identified and Self-Revealing Findings===
 
No findings were identified.
 
===Licensee Identified Violations===
 
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program (CAP). The violation is described in Section 4OA7 of this report.
 
=REPORT DETAILS=
 
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
{{a|1R05}}
==1R05 Fire Protection==
 
This report documents the results of a triennial fire protection inspection of the Surry Power Station (SPS), 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 October 28, 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) as described in the SPS Updated Final Safety Analysis Report (UFSAR) and Appendix R Fire Protection Report (FPR), Units 1 and 2; and to review site specific implementation of at least one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs 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 walk-downs 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 (SERs), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports (IRs). 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 four FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:
 
Fire Area FA-3, Unit 1 emergency switchgear room (ESGR) and relay room
 
Fire Area FA-13, Unit 1 normal switchgear room


During the information gathering visit, the team will also discuss the following administrative details - office space; specific documents to be made available to the team in its office space; arrangements for reactor site access (including radiation protection training, security, safety and fitness for duty requirements); and the availability of knowledgeable plant engineering and licensing organization personnel to serve as points of contact during the inspection.
Fire Area FA-31, Turbine building, northeast sector


We request that during the inspection weeks you ensure that copies of analyses, evaluations or documentation regarding the implementation and maintenance of the Surry Power Station fire protection program, including post-fire safe shutdown capability, be readily accessible to the team for its review. Of specific interest are those documents which establish that your fire protection program satisfies NRC regulatory requirements and conforms to applicable NRC and industry fire protection guidance. For the B.5.b portion of the inspection, the documents implementing your mitigating strategies and demonstrating the management of your commitments for the strategies are of specific interest. Also, personnel should be available at the site during the inspection who are knowledgeable regarding those plant systems required to achieve and maintain safe shutdown conditions from inside and outside the control room (including the electrical aspects of the relevant post-fire safe shutdown analyses), reactor plant fire protection systems and features, and the Surry Power Station fire protection program and its implementation.
Fire Area FA-46, Unit 1 cable spreading room For each of the selected fire areas, the inspectors evaluated the licensee=s FPP against the applicable NRC requirements and design basis documents. Applicable design basis documents reviewed by the team are listed in the Attachment to this report.


This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, under control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.
===.01 Protection of Safe Shutdown Capabilities===


Your cooperation and support during this inspection will be appreciated. If you have questions concerning this inspection, or the inspection teams information or logistical needs, please contact McKenzie Thomas at (404) 997-4673, Rodney Fanner at (404) 997-4638 or me at (404) 997-4511.
====a. Inspection Scope====
For the selected FAs, the inspectors performed physical walk-downs 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.


VEPCO  3 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Methodology Cable routing information by FA was reviewed for a selected sample of SSD components to verify that the associated cables would not be damaged by a fire in the selected fire areas or the licensees analysis determined that the fire damage would not prohibit safe plant shutdown. The inspectors reviewed the SPS FPR for the selected FAs and compared it to the fire contingency action (FCA) procedures, emergency procedures, and abnormal procedures to verify that cables and equipment credited for post-fire SSD in the FPR and applicable procedures were adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability. In cases where local operator manual actions (OMAs) were credited in-lieu of cable protection of SSD equipment, the inspectors reviewed the OMAs to verify that the OMAs were feasible utilizing the guidance of NRC IP 71111.05T, paragraph 02.02.j.2. A list of SSD components examined for cable routing is included in the Attachment.


Sincerely,
Operational Implementation The inspectors reviewed applicable sections of FCA procedures, emergency procedures, and abnormal procedures to verify that the shutdown methodology properly identified the systems and components necessary to achieve and maintain SSD conditions. The inspectors performed a walk-through of the FCA procedure steps to ensure the implementation and human factors adequacy of the procedures. The inspectors verified that licensee personnel credited for procedure implementation 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.
/RA/
 
Michael F. King Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Enclosures:
====b. Findings====
1. Triennial Fire Protection Program Supporting Documentation 2. Mitigating Strategies Supporting Documentation cc w/encls: (See page 4)
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 penetration seals, fire doors, and fire dampers.
 
The inspectors walked down accessible portions of the selected FAs to observe material condition of the passive barriers and to identify any potential degradation or non-conformance. The inspectors compared the installed configurations to the approved construction details and supporting fire endurance test data to assure the respective fire barriers met the requirements of 10CFR50, Appendix R, Section III.G and Appendix A to BTP APCSB 9.5-1. In addition, the inspectors reviewed licensing basis documentation to verify that passive fire protection features met license commitments. Also, a sample of completed surveillance and maintenance procedures for selected fire doors, fire dampers, and penetration seals were reviewed to ensure that these passive fire barriers were being properly inspected and maintained. The fire protection features included in the review are listed in the Attachment.
 
====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 lineup of fire water storage tanks, diesel and electric motor-driven fire pumps and fire protection water supply distribution piping, including manual fire hose and standpipe systems and sprinklers. Using operating and valve alignment procedures as well as engineering drawings, the inspectors examined selected fire pumps and accessible portions of the fire main piping system to evaluate operational status, consistency of as-built configurations with engineering drawings, and to verify correct system valve lineups.
 
Automatic carbon dioxide (CO2) gaseous fire extinguishing systems were inspected in conjunction with the associated heat and smoke detection systems for the Unit 1 normal switchgear room (FA-13) and Unit 1 cable spreading room, (FA-46) respectively. The inspectors reviewed the CO2 systems vendor equipment specifications and drawings and engineering calculations to determine whether the fire detection and suppression methods were appropriate for the types of fire hazards that exist in the selected FAs.
 
The inspectors compared the fire detection and fire suppression systems to the applicable National Fire Protection Association (NFPA) Standard(s) by reviewing design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The manually actuated Halon system installed in the Unit 1 ESGR and relay room (FA-3) was also reviewed. The inspectors reviewed completed periodic surveillance, testing and maintenance program procedures for the fire detection and suppression systems and compared them to the testing and maintenance requirements of the SPS FPP and Technical Requirements Manual (TRM). This review was to assess whether the test program was sufficient to validate proper operation of the fire detection and suppression systems in accordance with their design requirements.
 
For the selected FAs, the inspectors compared fire fighting pre-plan strategies to existing plant layout and equipment configuration and to fire response procedures. The inspectors also assessed the condition of fire fighting and smoke control equipment by inspecting equipment located at fire brigade staging and dress out areas. In addition, the inspectors evaluated fire brigade staffing, qualification and training, and conducted a review of applicable drill records for the past five years. Letters of Agreement and Invitations to Participate with off-site emergency responders were also reviewed.
 
====b. Findings====
No findings were identified.
 
===.04 Protection From Damage From Fire Suppression Activities===
 
====a. Inspection Scope====
The inspectors evaluated whether manual water-based fire fighting activities or installed manual Halon 1301 or automatic CO2 gaseous fire extinguishing systems for the selected FAs could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local operator actions required for SSD. The inspectors reviewed documentation related to flooding analysis from fire protection activities as well as potential flooding through unsealed concrete floor cracks.
 
The inspectors reviewed SPS evaluations addressing concerns identified in Information Notice (IN) 1988-060, Inadequate Design and Installation of Watertight Penetration Seals and IN 2003-030 Unanalyzed Internal Flooding Events and Inadequate Design.
 
Fire Strategies (Pre-Fire Plans); Fire Brigade Training Procedures; heating, ventilating and air conditioning (HVAC) drawings; and, Fire Abnormal Operating Procedures were also reviewed to verify that inter-area migration of water or ventilation of gaseous fire extinguishing agents or heat and smoke was addressed and would not adversely affect SSD equipment or the performance of operator manual actions.
 
====b. Findings====
No findings were identified.
 
===.05 Alternative Shutdown Capabilities===
 
====a. Inspection Scope====
Methodology For a postulated fire in FA-3, Unit 1 ESGR and relay room (ESGR-1), the licensee credited alternative shutdown capability (the capability to achieve SSD outside the main control room (MCR), a requirement for areas where redundant trains of equipment required for hot shutdown were located in the same FA and may be subject to damage from a single fire, from fire suppression activities, or from the rupture or inadvertent operation of fire suppression systems). The inspectors reviewed UFSAR Section 9.10, the SPS FPR, and corresponding FCA procedures to ensure that appropriate controls provided reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. In cases where local OMAs were credited in lieu of cable protection of SSD components, the inspectors performed a walk-through of the procedures to verify that the OMAs were feasible. Reviews also included verification that alternative shutdown could be accomplished with or without offsite power. The inspectors reviewed the licensees credited SSD capability for transferring control to an alternate control station, if needed for a fire in the chosen area. The inspectors reviewed the licensees safe shutdown analysis (SSA) specified in the SPS FPR and the corresponding procedures. The inspectors reviewed a sample list of credited components specified in 1-FCA-4.00, Limiting Emergency Switchgear Room (ESGR)
Number 1 Fire, to ensure the sample list was consistent with those stated in the analysis. In instances where components were specified by the procedure yet not in the analysis the inspectors performed a further review to determine if there was an impact to the SSD strategy.
 
The inspectors reviewed a sample of completed surveillance testing records to ensure the circuits credited for the alternate control stations were isolated based on transfer from the MCR.
 
Operational Implementation The inspectors reviewed selected training materials for licensed and non-licensed operators to verify the training reinforced the shutdown methodology in the SPS FPR and FCAs for FA-3. The inspectors also reviewed shift turnover logs and shift manning to verify that personnel required for SSD using alternative shutdown systems and procedures were available onsite, exclusive of those assigned as fire brigade members.
 
The inspectors performed a walk-through of procedure steps with operations personnel to assess the implementation and human factors adequacy of the procedures and shutdown strategy, evaluate the expected ambient conditions, relative difficulty and operator familiarization associated with each OMA. The inspectors reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The inspectors 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.
 
====b. Findings====
No findings were identified.
 
===.06 Circuit Analyses===
 
====a. Inspection Scope====
The inspectors reviewed the licensees UFSAR, SPS FPR, system flow diagrams, post-fire procedures, operator training material, and applicable information to gain an understanding of the licensees SSD strategy. The inspectors reviewed credited components specified in the FPR for meeting the SSD function. The inspectors reviewed cable routing information for credited components to determine if these components would be impacted by a fire within the chosen FAs. In instances where questions arose regarding potential fire induced circuit failures to cables, the inspectors performed a more detailed review by evaluating the credited resolution. The inspectors reviewed the licensees single spurious evaluations specified in the circuit analysis to determine if the sample list of components challenged the assumptions made in the current analysis. The inspectors reviewed the licensees electrical coordination study to determine if power supplies were susceptible to fire damage, which would potentially affect the credited components for the FAs chosen for review. The specific components reviewed are listed in the Attachment.
 
====b. Findings====
No findings were identified.
 
===.07. Communications===


_ML121450437_______________ xG SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRS RII:DRS SIGNATURE RA RA NAME DJONES MKING DATE  5/23/2012 5/23/2012 5/ /2012 5/ /2012 5/ /2012 5/ /2012 5/ /2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
====a. Inspection Scope====
The inspectors reviewed the licensees UFSAR, SPS FPR, plant drawings, and applicable licensing submittals to ascertain the communications commitments for a fire event. The inspectors reviewed cable block diagrams associated with plant communication system to evaluate the availability of the communications systems credited to support plant personnel in fire event notification, fire brigade fire fighting activities, and in the performance of post-fire SSD procedures. The inspectors reviewed the routing information associated with these communications systems to verify that no fire affected damage occurred in the chosen FAs that would prohibit the ability to communicate between operators performing actions in response to the fire event.


VEPCO  4 cc w/encls:  Michael M. Cline Larry Lane  Director Site Vice President  Virginia Department of Emergency Services Surry Power Station  Management Virginia Electric and Power Company Electronic Mail Distribution Electronic Mail Distribution B. L. (Sonny) Stanley Director, Nuclear Safety and Licensing Virginia Electric and Power Company Electronic Mail Distribution Kenny B. Sloane Plant Manager Surry Power Station Virginia Electric & Power Company Electronic Mail Distribution Lillian M. Cuoco, Esq.
Additionally, the inspectors observed in-plant operational checks of radio equipment during FCA procedure walk downs to verify radio operation in selected locations.


Senior Counsel Dominion Resources Services, Inc.
====b. Findings====
No findings were identified.


Electronic Mail Distribution Tom Huber Director, Nuclear Licensing & Operations Support Innsbrook Technical Center Electronic Mail Distribution Ginger L. Rutherford Virginia Electric and Power Company Electronic Mail Distribution Virginia State Corporation Commission Division of Energy Regulation P.O. Box 1197 Richmond, VA 23209 Attorney General Supreme Court Building 900 East Main Street Richmond, VA 23219 Senior Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission 5850 Hog Island Rd Surry, VA 23883
===.08 Emergency Lighting===


VEPCO  5 Letter to David A. Heacock from Michael F. King dated May 23, 2012.
====a. Inspection Scope====
The inspectors reviewed the UFSAR, SPS FPR, and FCA procedures to gain an understanding of the applicable components for which fixed emergency lighting units (ELUs) were needed in the event of a fire within the selected FAs. The inspectors performed plant walk down inspections with licensee staff of the corresponding FCA procedures to observe if the placement and coverage area of fixed 8-hour battery pack ELUs provided reasonable assurance of illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post fire SSD.


SUBJECT: SURRY POWER STATION , UNITS 1 AND 2 - NOTIFICATION OF TRIENNIAL FIRE PROTECTION BASELINE INSPECTION (NRC INSPECTION REPORT 05000280/2012011 AND 05000281/2012011)
The inspectors reviewed applicable surveillance and maintenance procedures for ELUs.
Distribution w/encls:
RIDSNRRDIRS PUBLIC RidsNrrPMSurry Resource


Triennial Fire Protection Program Supporting Documentation Note: This is a broad list of the documents the NRC inspection team may be interested in reviewing, and possibly obtaining, during the information gathering site visit. Electronic media is preferred, if readily available. (The preferred file format on CD-ROM or DVDROM is .pdf).
The inspectors also reviewed completed maintenance records to ensure the equipment was being maintained consistent with licensee commitments. In this review, the inspectors verified that the battery power supplies were rated with at least an 8-hour capacity as required SPS FPP. The inspectors reviewed completed surveillance testing records to ensure adequate surveillance testing was being conducted to ensure continued reliable operation of the fixed emergency lights. Where failures were identified, the inspectors reviewed completed work orders (WOs) to verify that battery replacements or other repairs were completed. In addition, the inspectors reviewed the completed 8-hour discharge test records for a random sample of fixed emergency lights to verify they met the minimum rating of at least an eight-hour capacity.


The CD/DVD-ROM should be indexed, hyperlinked, readable, and searchable to facilitate ease of use. Please provide 5 copies of each CD/DVD-ROM submitted. Information in lists should contain enough information to be easily understood by someone who has knowledge of the technology. The lead inspector will discuss specific information needs with the licensee staff and may request additional documents or electronic information.
====b. Findings====
No findings were identified.


1. The current version of the fire protection program and fire hazards analysis.
===.09 Cold Shutdown Repairs===


2. Corrective action closeouts as part of operator manual actions corrective actions.
====a. Inspection Scope====
The inspectors reviewed the SPS FPR and FCA procedures to verify that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs after a fire event assuming no offsite power was available.


3. List of identified fire induced circuit failure configurations for the selected fire areas/zones (to be determined during information gathering visit).
The inspectors verified that the fire damage repair procedures were current and adequate and repair parts and equipment were being stored and maintained onsite. The inspectors toured the SPS Warehouse Appendix R Storage Aisle, where cold shutdown fire damage repair equipment, tools, cables, and Appendix R gang-boxes were stored and examined the material condition of the tools and equipment stored in the designated storage area.


4. Corrective actions for fire-induced circuit failures, both single and multiple spurious actuations for the selected fire areas/zones (to be determined during information gathering visit).
The licensee conducted annual inventories of the repair parts and equipment in accordance with the applicable attachments in electrical preventive maintenance procedure 0-EMP-2303-01, RHR/CC Appendix R Equipment Inspection (Warehouse).


5. Cable routing for components and equipment credited for safe shutdown for the selected fire areas/zones (to be determined during information gathering visit).
The inspectors reviewed the inventory inspection work order records for 2011-2012 and compared them to the equipment and tool list in 0-EMP-2303-01 to verify that all required replacement parts and equipment were being accounted for and were available for use. In addition, the inspectors reviewed instrument calibration records for 2012, and verified that instrumentation test equipment stored in the Appendix R gang-boxes had also been inventoried and checked for proper calibration.


6. List of protected safe shutdown train equipment for the selected fire areas/zones (to be determined during information gathering visit).
====b. Findings====
No findings were identified.


7. Current versions of the fire protection program implementing procedures (e.g.,
===.10 Compensatory Measures===
administrative controls, surveillance testing, fire brigade).


8. Fire brigade training program and pre-fire plans.
====a. Inspection Scope====
The team reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features (e.g. detection and suppression systems and passive fire barriers). The team reviewed selected items from the impairment list and compared them to the FAs selected for the inspection. The team also observed performance of a fire protection surveillance activity, including implementation of compensatory measures.


9. Post-fire safe shutdown systems and separation analysis.
The team observed continuous and roving fire watch personnel stationed in Turbine and Service Building(s) posted for a licensee identified Appendix R Section III.G. SSD fire protection barrier protection or spatial separation issue. The team reviewed the SPS Fire Protection LCO and Transient Combustible Permit Log for applicable activities performed on August 21, 2012, to determine programmatic requirements were being complied with.


10. Post-fire alternative shutdown analysis.
====b. Findings====
No findings were identified.


11. Piping and instrumentation diagrams showing the components used to achieve and maintain hot standby and cold shutdown for fires outside the control room and those components used for those areas requiring alternative shutdown capability.
===.11 Review and Documentation of Fire Protection Program Changes===


12. Plant layout and equipment drawings which identify the physical plant locations of hot standby and cold shutdown equipment.
====a. Inspection scope====
The inspectors reviewed a sample of FPP changes made between July 2009 and August 2012 to assess the licensees effectiveness and to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse affect on the ability to achieve SSD.


13. Plant layout drawings which identify plant fire area delineation, areas protected by automatic fire suppression and detection, and the locations of fire protection equipment.
====b. Findings====
No findings were identified


14. Plant layout drawings which identify the general location of the post-fire emergency lighting.
===.12 Control of Transient Combustibles and Ignition Sources===


Enclosure 1
====a. Inspection Scope====
The inspectors conducted tours of numerous plant areas that were important to reactor safety, including the selected FAs, to verify the licensees implementation of fire protection requirements as described in fleet procedures CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, and CM-AA-FPA-101, Control of Combustible and Flammable Materials. The inspectors verified that the licensee had properly evaluated in-situ combustible fire loads, limited transient fire hazards, controlled hot-work activities, and maintained general housekeeping consistent with administrative control procedures and the fire hazards analysis (FHA). For the selected FAs, the inspectors evaluated the fire event history, the potential for fires and explosions, and potential fire severity. The inspectors also discussed the assigned duties of roving, continuous, and hot work type fire watch personnel to determine that such duties would be accomplished in accordance with the licensees administrative control procedures.


15. Plant operating procedures which would be used and describe shutdown from inside the control room with a postulated fire occurring in any plant area outside the control room, procedures which would be used to implement alternative shutdown capability in the event of a fire in the control or cable spreading room.
There were no hot work activities ongoing during the inspection so direct observations of hot work related activities could not be performed.


16. Maintenance and surveillance testing procedures for alternative shutdown capability and fire barriers, detectors, pumps and suppression systems.
====b. Findings====
No findings were identified


17. Maintenance procedures that routinely verify fuse breaker coordination in accordance with the post-fire safe shutdown coordination analysis.
===.13 B.5.b Inspection Activities===


18. A list of significant fire protection and post-fire safe shutdown related design change packages and evaluations according to Generic Letter 86-10, Implementation of Fire Protection Requirements.
====a. Inspection Scope====
The inspectors reviewed, on a sample basis, the licensees spent fuel pool external makeup mitigation measures for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the strategy, and equipment was properly staged and maintained. The inspectors requested and reviewed inventory and maintenance records of required equipment. Through discussions with plant staff, review of documentation, and plant walk-downs, the inspectors verified the engineering basis to establish reasonable assurance that the makeup capacity could be provided using the specified equipment and water sources. The inspectors reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply to the portable pumping equipment. The inspectors performed a walk-down 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. In the presence of licensee staff, the inspectors conducted an independent audit and inventory of required equipment and a visual inspection of the dedicated credited power and water sources. 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. The inspectors verified, by review of records and physical inspection, that B.5.b equipment was currently being properly stored, maintained, and tested in accordance with the licensees B.5.b program procedures.


19. The reactor plant's Individual Plant Examination for External Events (IPEEE), results of any post-IPEEE reviews, and listings of actions taken/plant modifications conducted in response to IPEEE information.
====b. Findings====
No findings were identified.


21. Organization charts of site personnel (including fire protection staff personnel).
==OTHER ACTIVITIES==
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==


22. If applicable, drawings of potential reactor coolant/recirculation pump lube oil system leakage points and associated lube oil collection systems.
====a. Inspection Scope====
The inspectors reviewed recent independent licensee audits for thoroughness, completeness and conformance to FPP requirements. Specifically, fire protection system health reports and Dominion Nuclear Oversight Fire Protection Quality Assurance Program audit reports for 2009 and 2012 were reviewed. In addition, other corrective action program (CAP) documents, including completed corrective actions documented in selected condition reports (CRs) were reviewed 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 CRs 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.


23. Licensing basis documents for fire protection (safety evaluation reports, pertinent sections of the final safety analysis report, exemptions, deviations, letters to/from the NRC regarding fire protection/fire safe shutdown, etc.).
{{a|4OA6}}
24. Procedures/instructions that control the configuration of the plant's fire protection program, features, and post-fire safe shutdown methodology, and system design.
==4OA6 Meetings, Including Exit==


25. A list of applicable codes and standards related to the design of plant fire protection features and evaluations of code deviations.
On August 24, 2012, the lead inspector presented the preliminary inspection results to Mr. R. Johnson, SPS Manager of Operations and other members of the licensees staff.


26. Procedures/instructions that govern the implementation of plant modifications, maintenance, special operations, and their impact on fire protection.
The licensee acknowledged the results. The lead inspector informed the licensee that proprietary information would not be included in this IR, although none was identified.


27. Internal and external self-assessments, audits, peer-assessments or similar reviews related to post-fire safe shutdown capability or the fire protection program completed since the previous NRC fire protection triennial inspection.
Following completion of additional reviews in the Region II office, another exit meeting was held by telephone with Mr. F. Mladen, Director Station Safety and Licensing, and other members of the licensees staff on September 12, 2012, to provide an update on changes to the preliminary inspection findings. The licensee acknowledged the findings.


28. Recent quality assurance surveillances of fire protection activities.
{{a|4OA7}}
==4OA7 Licensee-Identified Violation==


29. A listing of open and closed fire protection condition reports (problem reports/nuclear condition reports/event analysis reports/problem identification, and resolution reports)
The following violation of very low safety significance was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation (NCV).
since the last triennial inspection.


Enclosure 1
10 CFR Part 50.48(b)(1) requires that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of 10 CFR Part 50, Appendix R, Section III.G. Appendix R, Section III.G.2, requires that where redundant trains of equipment necessary to achieve and maintain hot shutdown are located in the same fire area outside of primary containment, one of three means of protecting cables to ensure that one of the redundant trains is maintained free of fire damage shall be provided. The three acceptable methods described in Appendix R, Section III.G.2 for maintaining one of the redundant trains in the same fire area free of fire damage are based on the use of physical barriers, spatial separation, and fire detection and an automatic fire suppression system. Appendix R, Section III.G.2, does not allow the use of operator manual actions in lieu of protection.


Mitigating Strategies Supporting Documentation Note: This is a broad list of the documents the NRC inspection team may be interested in reviewing, and possibly obtaining, during the information gathering site visit. The current version of these documents is expected unless specified otherwise. Electronic media is preferred, if readily available. (The preferred file format on CD-ROM or DVDROM is .pdf).
Contrary to the above requirements, during walk downs on March 22, 2012, the licensee identified that power and control cables for 1-SW-P-10A and 1-SW-P-10B, redundant trains of charging pump service water pumps, were routed through the turbine building (FA-31) in close proximity to each other and they did not meet the fire protection requirements of 10 CFR Part 50, Appendix R, Section III.G.2. This violation was determined to be of very low safety significance based on the results of the Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2 quantitative screening evaluation performed by a regional fire protection engineer and a senior reactor analyst. The significance determination process screening evaluation resulted in a delta core damage frequency (CDF) of <
1E-6. Therefore, this finding was determined to be of very low safety significance (Green). This issue was identified in the licensees corrective action program as Condition Report CR 467396.


The CD/DVD-ROM should be indexed, hyperlinked, readable, and searchable to facilitate ease of use. Please provide 5 copies of each CD/DVD-ROM submitted. The lead inspector will discuss specific information needs with the licensee staff and may request additional documents or electronic information.
ATTACHMENT: SUPPPLEMENTAL INFORMATION


1. A list of all modifications to regulatory commitments made to meet the requirements of Section B.5.b of NRC Order, EA-02-026, Order for NRC Interim Safeguards and Security Compensatory Measures, dated February 25, 2002, the subsequently imposed license conditions, and Title 10 of the Code of Federal Regulations (10 CFR)
=SUPPLEMENTAL INFORMATION=
50.54(hh)(2).


2. Lists of procedures/guidelines that were revised or generated to implement the mitigation strategies. These could be extensive damage mitigation guidelines (EDMGs), severe accident management guidelines (SAMGs), emergency operating procedures (EOPs), abnormal operating procedures (AOPs), etc.
==KEY POINTS OF CONTACT==


3. A matrix that shows the correlation between the mitigation strategies identified in Nuclear Energy Institute 06-12, Revision 2, B.5.b Phase 2 & 3 Submittal Guideline, issued December 2006, and the site-specific procedures or guidelines used to implement each strategy.
===Licensee Personnel===
: [[contact::J. Ashley]], Licensing Engineer
: [[contact::L. Black]], Supervisor, Outage Support
: [[contact::D. Criswell]], Security Supervisor
: [[contact::R. Dillard]], Appendix R Coordinator
: [[contact::J. Eggart]], Manager, Radiation Protection & Chemistry
: [[contact::B. Garber]], Supervisor, Station Licensing
: [[contact::G. Hayes]], Manager, Protection Services
: [[contact::J. Henderson]], Manager, Engineering
: [[contact::R. Johnson]], Manager, Operations
: [[contact::F. Mladen]], Director Station Safety and Licensing
: [[contact::C. Olsen]], Manager, Site Engineering
: [[contact::T. Rawls]], Supervisor, Security Training
: [[contact::J. Rosenberger]], Manager, Engineering Programs
: [[contact::M. Smith]], Manager, Nuclear Oversight
: [[contact::J. Warren]], Supervisor Engineering Programs
===NRC Personnel===
: [[contact::J. Nadel]], Resident Inspector, Surry Power Station Units 1 & 2


4. Engineering evaluations/calculations that were used to verify engineering bases for the mitigation strategies.
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


5. Piping and instrumentation diagram for systems relied upon in the mitigation strategies.
===Opened===


These could be of the type used for training.
None


6. A list of modification packages or simplified drawings or descriptions of modifications that were made to plant systems to implement the mitigation strategies.
===Opened and Closed===


7. Copies of procedures used to inventory equipment (hoses, fittings, pumps, etc.)
None


required to implement the mitigation strategies.
===Discussed===


8. A list of B.5.b strategies, if any, that have implementing details that differ from those documented in the submittals and the safety evaluation report.
None


9. A copy of site general arrangement drawing(s) that show the majority of buildings/areas referenced in B.5.b documents.
List of Fire Barrier Features Inspected (Refer to Report Section 1RO5.02-Passive Fire Barriers)
Barrier Identification                              Description Fire Door 1BS-DR40                                            Separating FA13 and FA31 1BS-DR41                                            Separating FA13 and FA31 1BS-DR42                                            Separating FA13 and FA14 1BS-DR46                                            Separating FA46 and FA31 1STR-RSD1                                            Separating FA36B and FA36B Fire Damper 1VS-FDMP33                                          Separating FA36B and FA36B 1VS-FDMP34                                          Separating FA36B and FA36B Fire Barrier Penetration Seal 01FP-FBAR-009ESGR06                                  Separating FA3 and FA31 01FP-FBAR-009BTR01                                  Separating FA9 and FA3 01FP-FBAR-009BTR01                                  Separating FA10 and FA3 Flood Protection Dike (Fire Suppression Effects)
1BS-DR-25                                            FA3, ESGR 1BS-DR-26                                            FA3, ESGR 1BS-DR-27                                            FA3, ESGR Wall, Ceiling, Floor Identification Floor, wall and ceiling construction                FA 3, ESGR Floor and wall construction                          FA13, Normal Switchgear Room Floor, wall and ceiling construction                FA 46 Cable Spread Room


10. Training records, training matrix, and lesson plans related to B.5.b.
LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1RO5.05-Alternative Shutdown Capability and 1RO5-.06-Circuit Analysis)
Valves 1-CH-HCV-1137, Excess Letdown Flow 1-CH-MOV-1115B, D Charging Pump Suction from RWST 1-CH-MOV-1287A, Charging Pump Discharge to Alternate Charging Header 1-CH-LCV-1460A, Letdown Isolation 1-FW-MOV-160A & B, AFW Cross-connect valves 1-MS-PCV-102B, Steam Supply to AFW Pump Turbine 1-RC-PCV-1455C, Pressurizer PORV 1-RC-MOV-1536, Pressurizer Block Valve Pump Motors 1-CH-P-1A, Charging Pump 1-CH-P-1B, Charging Pump 1-FW-P-3A, Motor Driven AFW Pump A Train 1-FW-P-3B, Motor Driven AFW Pump B Train Process Instruments 1-FW-LI-487A, Steam Generator B Wide Range Level 1-RC-LI-459A, Wide Range Pressurizer Level Indication 1-LT-1459A, Wide Range Pressurizer Level Transmitter 1-LT-1461, Pressurizer Level Transmitter


11. Copies of Memoranda of Understanding (MOUs) (e.g., with local fire departments)
==LIST OF DOCUMENTS REVIEWED==
required to implement any mitigating strategies.


Enclosure 2
}}
}}

Revision as of 12:03, 20 March 2020

IR 05000280-12-011 & 05000281-12-011; Virginia Electric and Power Company; 07/30/2012 - 08/03/2012; Surry Power Station, NRC Triennial Fire Protection Inspection Report
ML12279A308
Person / Time
Site: Surry  Dominion icon.png
Issue date: 10/04/2012
From: Mark King
NRC/RGN-II/DRS/EB2
To: Heacock D
Virginia Electric & Power Co (VEPCO)
References
FOIA/PA-2013-0030, FOIA/PA-2013-0139 IR-12-011
Download: ML12279A308 (31)
v • d • e


Text

UNITED STATES tober 4, 2012

SUBJECT:

SURRY POWER STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT NOS. 05000280/2012011 AND 05000281/2012011

Dear Mr. Heacock:

On August 24, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Surry Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed with Mr. R. Johnson, Surry Power Station Manager of Operations, and other members of your staff on August 24, 2012. Subsequently, additional in-office reviews were conducted and the final inspection results were discussed by telephone with Mr. F. Mladen, Director Station Safety and Licensing, and other members of your staff on September 12, 2012.

The inspection examined activities conducted under your license as they related 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.

No NRC-identified or self-revealing findings were identified during this inspection. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Surry Power Station.

In accordance with 10 CFR 2.390 of the NRCs 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 NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37

Enclosure:

Inspection Report 05000280/2012011, 05000281/2012011 w/Attachment: Supplemental Information

REGION II==

Docket Nos.: 50-280, 50-281 License Nos.: DPR-32, DPR-37 Report Nos.: 05000280/2012011 and 05000281/2012011 Licensee: Virginia Electric and Power Company Facility: Surry Power Station, Units 1 and 2 Location: 5850 Hog Island Road Surry, VA 23883 Dates: July 30 - August 3, 2012 (Week 1)

August 20-24, 2012 (Week 2)

Inspectors: G. Wiseman, Senior Reactor Inspector (Lead Inspector)

M. Thomas, Senior Reactor Inspector R. Fanner, Reactor Inspector J. Dymek, Reactor Inspector Approved by: Michael F. King, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000280/2012011, 05000281/2012011; 07/30 - 08/03/2012 and 08/20 - 24/2012; Surry

Power Station, Units 1 and 2; Triennial Fire Protection Inspection This report covers an announced two-week triennial fire protection inspection by a team of four regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

No findings were identified.

Licensee Identified Violations

A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program (CAP). The violation is described in Section 4OA7 of this report.

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 Surry Power Station (SPS), 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 October 28, 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) as described in the SPS Updated Final Safety Analysis Report (UFSAR) and Appendix R Fire Protection Report (FPR), Units 1 and 2; and to review site specific implementation of at least one mitigating strategy from Section B.5.b of NRC Order EA-02-026, Order for Interim Safeguards and Security Compensatory Measures (commonly referred to as B.5.b), as well as the storage, maintenance, and testing of B.5.b mitigating equipment. The sample FAs 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 walk-downs 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 (SERs), licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports (IRs). 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 four FAs and one B.5.b mitigating strategy. The FAs chosen were identified as follows:

Fire Area FA-3, Unit 1 emergency switchgear room (ESGR) and relay room

Fire Area FA-13, Unit 1 normal switchgear room

Fire Area FA-31, Turbine building, northeast sector

Fire Area FA-46, Unit 1 cable spreading room For each of the selected fire areas, the inspectors evaluated the licensee=s FPP against the applicable NRC requirements and design basis documents. Applicable design basis documents reviewed by the team are listed in the Attachment to this report.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

For the selected FAs, the inspectors performed physical walk-downs 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.

Methodology Cable routing information by FA was reviewed for a selected sample of SSD components to verify that the associated cables would not be damaged by a fire in the selected fire areas or the licensees analysis determined that the fire damage would not prohibit safe plant shutdown. The inspectors reviewed the SPS FPR for the selected FAs and compared it to the fire contingency action (FCA) procedures, emergency procedures, and abnormal procedures to verify that cables and equipment credited for post-fire SSD in the FPR and applicable procedures were adequately protected from fire damage in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability. In cases where local operator manual actions (OMAs) were credited in-lieu of cable protection of SSD equipment, the inspectors reviewed the OMAs to verify that the OMAs were feasible utilizing the guidance of NRC IP 71111.05T, paragraph 02.02.j.2. A list of SSD components examined for cable routing is included in the Attachment.

Operational Implementation The inspectors reviewed applicable sections of FCA procedures, emergency procedures, and abnormal procedures to verify that the shutdown methodology properly identified the systems and components necessary to achieve and maintain SSD conditions. The inspectors performed a walk-through of the FCA procedure steps to ensure the implementation and human factors adequacy of the procedures. The inspectors verified that licensee personnel credited for procedure implementation 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.

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 penetration seals, fire doors, and fire dampers.

The inspectors walked down accessible portions of the selected FAs to observe material condition of the passive barriers and to identify any potential degradation or non-conformance. The inspectors compared the installed configurations to the approved construction details and supporting fire endurance test data to assure the respective fire barriers met the requirements of 10CFR50, Appendix R, Section III.G and Appendix A to BTP APCSB 9.5-1. In addition, the inspectors reviewed licensing basis documentation to verify that passive fire protection features met license commitments. Also, a sample of completed surveillance and maintenance procedures for selected fire doors, fire dampers, and penetration seals were reviewed to ensure that these passive fire barriers were being properly inspected and maintained. The fire protection features included in the review are listed in the Attachment.

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 lineup of fire water storage tanks, diesel and electric motor-driven fire pumps and fire protection water supply distribution piping, including manual fire hose and standpipe systems and sprinklers. Using operating and valve alignment procedures as well as engineering drawings, the inspectors examined selected fire pumps and accessible portions of the fire main piping system to evaluate operational status, consistency of as-built configurations with engineering drawings, and to verify correct system valve lineups.

Automatic carbon dioxide (CO2) gaseous fire extinguishing systems were inspected in conjunction with the associated heat and smoke detection systems for the Unit 1 normal switchgear room (FA-13) and Unit 1 cable spreading room, (FA-46) respectively. The inspectors reviewed the CO2 systems vendor equipment specifications and drawings and engineering calculations to determine whether the fire detection and suppression methods were appropriate for the types of fire hazards that exist in the selected FAs.

The inspectors compared the fire detection and fire suppression systems to the applicable National Fire Protection Association (NFPA) Standard(s) by reviewing design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The manually actuated Halon system installed in the Unit 1 ESGR and relay room (FA-3) was also reviewed. The inspectors reviewed completed periodic surveillance, testing and maintenance program procedures for the fire detection and suppression systems and compared them to the testing and maintenance requirements of the SPS FPP and Technical Requirements Manual (TRM). This review was to assess whether the test program was sufficient to validate proper operation of the fire detection and suppression systems in accordance with their design requirements.

For the selected FAs, the inspectors compared fire fighting pre-plan strategies to existing plant layout and equipment configuration and to fire response procedures. The inspectors also assessed the condition of fire fighting and smoke control equipment by inspecting equipment located at fire brigade staging and dress out areas. In addition, the inspectors evaluated fire brigade staffing, qualification and training, and conducted a review of applicable drill records for the past five years. Letters of Agreement and Invitations to Participate with off-site emergency responders were also reviewed.

b. Findings

No findings were identified.

.04 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The inspectors evaluated whether manual water-based fire fighting activities or installed manual Halon 1301 or automatic CO2 gaseous fire extinguishing systems for the selected FAs could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local operator actions required for SSD. The inspectors reviewed documentation related to flooding analysis from fire protection activities as well as potential flooding through unsealed concrete floor cracks.

The inspectors reviewed SPS evaluations addressing concerns identified in Information Notice (IN) 1988-060, Inadequate Design and Installation of Watertight Penetration Seals and IN 2003-030 Unanalyzed Internal Flooding Events and Inadequate Design.

Fire Strategies (Pre-Fire Plans); Fire Brigade Training Procedures; heating, ventilating and air conditioning (HVAC) drawings; and, Fire Abnormal Operating Procedures were also reviewed to verify that inter-area migration of water or ventilation of gaseous fire extinguishing agents or heat and smoke was addressed and would not adversely affect SSD equipment or the performance of operator manual actions.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capabilities

a. Inspection Scope

Methodology For a postulated fire in FA-3, Unit 1 ESGR and relay room (ESGR-1), the licensee credited alternative shutdown capability (the capability to achieve SSD outside the main control room (MCR), a requirement for areas where redundant trains of equipment required for hot shutdown were located in the same FA and may be subject to damage from a single fire, from fire suppression activities, or from the rupture or inadvertent operation of fire suppression systems). The inspectors reviewed UFSAR Section 9.10, the SPS FPR, and corresponding FCA procedures to ensure that appropriate controls provided reasonable assurance that alternative shutdown equipment remained operable, available, and accessible when required. In cases where local OMAs were credited in lieu of cable protection of SSD components, the inspectors performed a walk-through of the procedures to verify that the OMAs were feasible. Reviews also included verification that alternative shutdown could be accomplished with or without offsite power. The inspectors reviewed the licensees credited SSD capability for transferring control to an alternate control station, if needed for a fire in the chosen area. The inspectors reviewed the licensees safe shutdown analysis (SSA) specified in the SPS FPR and the corresponding procedures. The inspectors reviewed a sample list of credited components specified in 1-FCA-4.00, Limiting Emergency Switchgear Room (ESGR)

Number 1 Fire, to ensure the sample list was consistent with those stated in the analysis. In instances where components were specified by the procedure yet not in the analysis the inspectors performed a further review to determine if there was an impact to the SSD strategy.

The inspectors reviewed a sample of completed surveillance testing records to ensure the circuits credited for the alternate control stations were isolated based on transfer from the MCR.

Operational Implementation The inspectors reviewed selected training materials for licensed and non-licensed operators to verify the training reinforced the shutdown methodology in the SPS FPR and FCAs for FA-3. The inspectors also reviewed shift turnover logs and shift manning to verify that personnel required for SSD using alternative shutdown systems and procedures were available onsite, exclusive of those assigned as fire brigade members.

The inspectors performed a walk-through of procedure steps with operations personnel to assess the implementation and human factors adequacy of the procedures and shutdown strategy, evaluate the expected ambient conditions, relative difficulty and operator familiarization associated with each OMA. The inspectors reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The inspectors 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.

b. Findings

No findings were identified.

.06 Circuit Analyses

a. Inspection Scope

The inspectors reviewed the licensees UFSAR, SPS FPR, system flow diagrams, post-fire procedures, operator training material, and applicable information to gain an understanding of the licensees SSD strategy. The inspectors reviewed credited components specified in the FPR for meeting the SSD function. The inspectors reviewed cable routing information for credited components to determine if these components would be impacted by a fire within the chosen FAs. In instances where questions arose regarding potential fire induced circuit failures to cables, the inspectors performed a more detailed review by evaluating the credited resolution. The inspectors reviewed the licensees single spurious evaluations specified in the circuit analysis to determine if the sample list of components challenged the assumptions made in the current analysis. The inspectors reviewed the licensees electrical coordination study to determine if power supplies were susceptible to fire damage, which would potentially affect the credited components for the FAs chosen for review. The specific components reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.07. Communications

a. Inspection Scope

The inspectors reviewed the licensees UFSAR, SPS FPR, plant drawings, and applicable licensing submittals to ascertain the communications commitments for a fire event. The inspectors reviewed cable block diagrams associated with plant communication system to evaluate the availability of the communications systems credited to support plant personnel in fire event notification, fire brigade fire fighting activities, and in the performance of post-fire SSD procedures. The inspectors reviewed the routing information associated with these communications systems to verify that no fire affected damage occurred in the chosen FAs that would prohibit the ability to communicate between operators performing actions in response to the fire event.

Additionally, the inspectors observed in-plant operational checks of radio equipment during FCA procedure walk downs to verify radio operation in selected locations.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The inspectors reviewed the UFSAR, SPS FPR, and FCA procedures to gain an understanding of the applicable components for which fixed emergency lighting units (ELUs) were needed in the event of a fire within the selected FAs. The inspectors performed plant walk down inspections with licensee staff of the corresponding FCA procedures to observe if the placement and coverage area of fixed 8-hour battery pack ELUs provided reasonable assurance of illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post fire SSD.

The inspectors reviewed applicable surveillance and maintenance procedures for ELUs.

The inspectors also reviewed completed maintenance records to ensure the equipment was being maintained consistent with licensee commitments. In this review, the inspectors verified that the battery power supplies were rated with at least an 8-hour capacity as required SPS FPP. The inspectors reviewed completed surveillance testing records to ensure adequate surveillance testing was being conducted to ensure continued reliable operation of the fixed emergency lights. Where failures were identified, the inspectors reviewed completed work orders (WOs) to verify that battery replacements or other repairs were completed. In addition, the inspectors reviewed the completed 8-hour discharge test records for a random sample of fixed emergency lights to verify they met the minimum rating of at least an eight-hour capacity.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the SPS FPR and FCA procedures to verify that the licensee identified repairs needed to reach and maintain cold shutdown and had dedicated repair procedures, equipment, and materials to accomplish these repairs after a fire event assuming no offsite power was available.

The inspectors verified that the fire damage repair procedures were current and adequate and repair parts and equipment were being stored and maintained onsite. The inspectors toured the SPS Warehouse Appendix R Storage Aisle, where cold shutdown fire damage repair equipment, tools, cables, and Appendix R gang-boxes were stored and examined the material condition of the tools and equipment stored in the designated storage area.

The licensee conducted annual inventories of the repair parts and equipment in accordance with the applicable attachments in electrical preventive maintenance procedure 0-EMP-2303-01, RHR/CC Appendix R Equipment Inspection (Warehouse).

The inspectors reviewed the inventory inspection work order records for 2011-2012 and compared them to the equipment and tool list in 0-EMP-2303-01 to verify that all required replacement parts and equipment were being accounted for and were available for use. In addition, the inspectors reviewed instrument calibration records for 2012, and verified that instrumentation test equipment stored in the Appendix R gang-boxes had also been inventoried and checked for proper calibration.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The team reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features (e.g. detection and suppression systems and passive fire barriers). The team reviewed selected items from the impairment list and compared them to the FAs selected for the inspection. The team also observed performance of a fire protection surveillance activity, including implementation of compensatory measures.

The team observed continuous and roving fire watch personnel stationed in Turbine and Service Building(s) posted for a licensee identified Appendix R Section III.G. SSD fire protection barrier protection or spatial separation issue. The team reviewed the SPS Fire Protection LCO and Transient Combustible Permit Log for applicable activities performed on August 21, 2012, to determine programmatic requirements were being complied with.

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 July 2009 and August 2012 to assess the licensees effectiveness and to determine if the changes to the FPP were in accordance with the fire protection license condition and had no adverse affect 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 conducted tours of numerous plant areas that were important to reactor safety, including the selected FAs, to verify the licensees implementation of fire protection requirements as described in fleet procedures CM-AA-FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, and CM-AA-FPA-101, Control of Combustible and Flammable Materials. The inspectors verified that the licensee had properly evaluated in-situ combustible fire loads, limited transient fire hazards, controlled hot-work activities, and maintained general housekeeping consistent with administrative control procedures and the fire hazards analysis (FHA). For the selected FAs, the inspectors evaluated the fire event history, the potential for fires and explosions, and potential fire severity. The inspectors also discussed the assigned duties of roving, continuous, and hot work type fire watch personnel to determine that such duties would be accomplished in accordance with the licensees administrative control procedures.

There were no hot work activities ongoing during the inspection so direct observations of hot work related activities could not be performed.

b. Findings

No findings were identified

.13 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed, on a sample basis, the licensees spent fuel pool external makeup mitigation measures for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the strategy, and equipment was properly staged and maintained. The inspectors requested and reviewed inventory and maintenance records of required equipment. Through discussions with plant staff, review of documentation, and plant walk-downs, the inspectors verified the engineering basis to establish reasonable assurance that the makeup capacity could be provided using the specified equipment and water sources. The inspectors reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply to the portable pumping equipment. The inspectors performed a walk-down 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. In the presence of licensee staff, the inspectors conducted an independent audit and inventory of required equipment and a visual inspection of the dedicated credited power and water sources. 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. The inspectors verified, by review of records and physical inspection, that B.5.b equipment was currently being properly stored, maintained, and tested in accordance with the licensees B.5.b program 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 FPP requirements. Specifically, fire protection system health reports and Dominion Nuclear Oversight Fire Protection Quality Assurance Program audit reports for 2009 and 2012 were reviewed. In addition, other corrective action program (CAP) documents, including completed corrective actions documented in selected condition reports (CRs) were reviewed 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 CRs 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.

4OA6 Meetings, Including Exit

On August 24, 2012, the lead inspector presented the preliminary inspection results to Mr. R. Johnson, SPS Manager of Operations and other members of the licensees staff.

The licensee acknowledged the results. The lead inspector informed the licensee that proprietary information would not be included in this IR, although none was identified.

Following completion of additional reviews in the Region II office, another exit meeting was held by telephone with Mr. F. Mladen, Director Station Safety and Licensing, and other members of the licensees staff on September 12, 2012, to provide an update on changes to the preliminary inspection findings. The licensee acknowledged the findings.

4OA7 Licensee-Identified Violation

The following violation of very low safety significance was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation (NCV).

10 CFR Part 50.48(b)(1) requires that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of 10 CFR Part 50, Appendix R, Section III.G. Appendix R,Section III.G.2, requires that where redundant trains of equipment necessary to achieve and maintain hot shutdown are located in the same fire area outside of primary containment, one of three means of protecting cables to ensure that one of the redundant trains is maintained free of fire damage shall be provided. The three acceptable methods described in Appendix R,Section III.G.2 for maintaining one of the redundant trains in the same fire area free of fire damage are based on the use of physical barriers, spatial separation, and fire detection and an automatic fire suppression system. Appendix R,Section III.G.2, does not allow the use of operator manual actions in lieu of protection.

Contrary to the above requirements, during walk downs on March 22, 2012, the licensee identified that power and control cables for 1-SW-P-10A and 1-SW-P-10B, redundant trains of charging pump service water pumps, were routed through the turbine building (FA-31) in close proximity to each other and they did not meet the fire protection requirements of 10 CFR Part 50, Appendix R, Section III.G.2. This violation was determined to be of very low safety significance based on the results of the Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2 quantitative screening evaluation performed by a regional fire protection engineer and a senior reactor analyst. The significance determination process screening evaluation resulted in a delta core damage frequency (CDF) of <

1E-6. Therefore, this finding was determined to be of very low safety significance (Green). This issue was identified in the licensees corrective action program as Condition Report CR 467396.

ATTACHMENT: SUPPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Ashley, Licensing Engineer
L. Black, Supervisor, Outage Support
D. Criswell, Security Supervisor
R. Dillard, Appendix R Coordinator
J. Eggart, Manager, Radiation Protection & Chemistry
B. Garber, Supervisor, Station Licensing
G. Hayes, Manager, Protection Services
J. Henderson, Manager, Engineering
R. Johnson, Manager, Operations
F. Mladen, Director Station Safety and Licensing
C. Olsen, Manager, Site Engineering
T. Rawls, Supervisor, Security Training
J. Rosenberger, Manager, Engineering Programs
M. Smith, Manager, Nuclear Oversight
J. Warren, Supervisor Engineering Programs

NRC Personnel

J. Nadel, Resident Inspector, Surry Power Station Units 1 & 2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Discussed

None

List of Fire Barrier Features Inspected (Refer to Report Section 1RO5.02-Passive Fire Barriers)

Barrier Identification Description Fire Door 1BS-DR40 Separating FA13 and FA31 1BS-DR41 Separating FA13 and FA31 1BS-DR42 Separating FA13 and FA14 1BS-DR46 Separating FA46 and FA31 1STR-RSD1 Separating FA36B and FA36B Fire Damper 1VS-FDMP33 Separating FA36B and FA36B 1VS-FDMP34 Separating FA36B and FA36B Fire Barrier Penetration Seal 01FP-FBAR-009ESGR06 Separating FA3 and FA31 01FP-FBAR-009BTR01 Separating FA9 and FA3 01FP-FBAR-009BTR01 Separating FA10 and FA3 Flood Protection Dike (Fire Suppression Effects)

1BS-DR-25 FA3, ESGR 1BS-DR-26 FA3, ESGR 1BS-DR-27 FA3, ESGR Wall, Ceiling, Floor Identification Floor, wall and ceiling construction FA 3, ESGR Floor and wall construction FA13, Normal Switchgear Room Floor, wall and ceiling construction FA 46 Cable Spread Room

LIST OF COMPONENTS REVIEWED (Refer to Report Sections 1RO5.05-Alternative Shutdown Capability and 1RO5-.06-Circuit Analysis)

Valves 1-CH-HCV-1137, Excess Letdown Flow 1-CH-MOV-1115B, D Charging Pump Suction from RWST 1-CH-MOV-1287A, Charging Pump Discharge to Alternate Charging Header 1-CH-LCV-1460A, Letdown Isolation 1-FW-MOV-160A & B, AFW Cross-connect valves 1-MS-PCV-102B, Steam Supply to AFW Pump Turbine 1-RC-PCV-1455C, Pressurizer PORV 1-RC-MOV-1536, Pressurizer Block Valve Pump Motors 1-CH-P-1A, Charging Pump 1-CH-P-1B, Charging Pump 1-FW-P-3A, Motor Driven AFW Pump A Train 1-FW-P-3B, Motor Driven AFW Pump B Train Process Instruments 1-FW-LI-487A, Steam Generator B Wide Range Level 1-RC-LI-459A, Wide Range Pressurizer Level Indication 1-LT-1459A, Wide Range Pressurizer Level Transmitter 1-LT-1461, Pressurizer Level Transmitter

LIST OF DOCUMENTS REVIEWED

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