IR 05000400/2014008
| ML14175B542 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/23/2014 |
| From: | Scott Shaeffer NRC/RGN-II/DRS/EB2 |
| To: | Kapopoulos E Progress Energy Carolinas |
| References | |
| IR-14-008 | |
| Download: ML14175B542 (26) | |
Text
June 23, 2014
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000400/2014008
Dear Mr. Kapopoulos:
On May 9, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Shearon Harris Nuclear Power Plant, Unit 1. The enclosed inspection report documents the inspection results, which were discussed with Mr. J. Dufner and other members of your staff on May 9, 2014. Following completion of additional post-inspection analysis of the inspection findings and review of additional information by the NRC in the Region II office, a final exit was held by telephone with you and other members of your staff on June 23, 2014, to provide an update on changes to the preliminary inspection findings.
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.
One NRC-identified finding of very low safety significance (Green) was identified during this inspection. This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance of this violation and because it was entered into your corrective action program, 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 20555-0001; 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 Shearon Harris Nuclear Power Plant. 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 the NRCs Agencywide Documents Access and Management 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/
Scott M. Shaeffer, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No.:
50-400 License No.: NPF-63
Enclosure:
NRC Inspection Report 05000400/2014008
w/Attachment: Supplementary Information
REGION II==
Docket No.:
50-400
License No.:
Report No.:
Licensee:
Duke Energy Progress, Inc.
Facility:
Shearon Harris Nuclear Power Plant, Unit 1
Location:
New Hill, NC 27562
Dates:
April 21-25, 2014
May 5-9, 2014
Inspectors:
P. Braxton, Reactor Inspector
D. Jones, Senior Reactor Inspector
J. Montgomery, Reactor Inspector
M. Thomas, Senior Reactor Inspector (Lead Inspector)
G. Wiseman, Senior Reactor Inspector
Accompanying
G. MacDonald, Senior Reactor Analyst Personnel:
W. Monk, Reactor Inspector
J. Patel, Reactor Inspector
Approved by:
Scott M. Shaeffer, Chief Engineering Branch 2 Division of Reactor Safety
SUMMARY
IR 05000400/2014008; 04/21/2014 - 05/09/2014; Shearon Harris Nuclear Power Plant, Unit 1;
Fire Protection - NFPA 805 (Triennial)
The report covers an announced two-week triennial fire protection inspection by a team of five regional inspectors. One Green non-cited violation was identified. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow,
Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.
Cornerstone: Mitigating Systems
- Green.
An NRC-identified non-cited violation of 10 CFR 50.48 (c) and National Fire Protection Association Standard (NFPA) 805 Section 2.4.3.2 was identified for the licensees failure to address in the Fire Probabilistic Risk Assessment (Fire PRA) the risk contribution associated with all potentially risk significant fire scenarios for a given fire compartment/fire area. The licensee did not identify and evaluate all targets that were within the zone of influence (ZOI) of ignition sources for selected fire scenarios which could potentially contribute to the risk for the fire scenarios. The licensee entered the issue in the corrective action program as Nuclear Condition Reports 682633 and 685355 and established an hourly roving fire watch as compensatory measures.
The licensees failure to comply with the requirements of 10 CFR 50.48(c) and NFPA 805 was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the reactor safety mitigating systems cornerstone attribute of protection against external factors (i.e., fire) and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The missed targets in the ZOI for the selected fire scenarios had the potential to impact the ability to achieve safe and stable conditions. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review was required as the finding affected post-fire SSD. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the finding was screened as Green in step 1.6.1 Screen by Licensee PRA-Based Safety Evaluation. An SDP Phase 3 analysis was performed to document the review of the risk determination of the missed ignition source-target interactions using the licensees Fire PRA model. A senior reactor analyst performed the Phase 3 SDP analysis in accordance with the guidance in IMC 0609 Appendix F and NUREG/CR-6850 Revisions 0 and 1. The evaluation determined that the missed ignition source-target interactions resulted in a CDF increase of 5.91E-8/year, a Green finding of very low safety significance. There was no cross cutting aspect assigned to this finding because it was not indicative of current licensee performance since the original ignition source and target walkdowns were performed in 2006 and 2007. (Section 1R05.06).
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 (TFPI) at the Shearon Harris Nuclear Power Plant (HNP), Unit 1. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05XT, Fire Protection - NFPA 805 (Triennial), issued January 31, 2013. The objective of the inspection was to review a minimum sample of two risk-significant fire areas (FAs) [also referred to as fire compartments (FCs)] to verify implementation of the HNP Fire Protection Program (FPP). An additional objective was to review site specific implementation of 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. Section 71111.05-05 of the IP specifies a minimum sample size of two FAs and one B.5.b mitigation strategy for addressing large fires and explosions. The inspectors selected four FAs based on available risk information as analyzed onsite by a senior reactor analyst from Region II, data obtained from in-plant walkdowns regarding potential ignition sources, location and characteristics of combustibles, and location of equipment needed to achieve and maintain the reactor in a safe and stable condition. Other considerations for selecting the FCs/FAs were the relative complexity of the post-fire safe shutdown (SSD) procedures, information contained in FPP documents, and results of prior NRC TFPIs. In selecting the B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports, licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. This inspection fulfilled the requirements of the procedure by selecting a sample of four FAs and one B.5.b mitigating strategy. The following FCs/FAs/fire scenarios were selected for review.
- FC35/FA 1-A-SWGRB, Switchgear Room B, was a performance based FA. Focus was on fire scenario FC35_S0716 involving the 1B DC Distribution Panel DP-1B-SB.
- FC03/FA 12-A-CRC1, Control Room Complex (PIC Room), was a performance based FA which involved shutdown from a primary control station. Focus was on fire scenario FC03_S1527 involving Train A Output Cabinets 1 & 2.
- FC18/FA 1-A-BAL-B, Reactor Auxiliary Building, was a performance based FA.
Focus was on fire scenario FC18_S0460 involving motor control center MCC 1B35-SB. Other fire scenarios reviewed for FA 1-A-BAL-B included FC18_S0495 BOS, Chiller 2A small oil fire; FC18_S0495 B98, Chiller 2A 40hp motor 98th percentile small thermal fire; and FC18_S3007 BHEAF, Bus Duct HEAF scenario 36.
- FC28/FA 1-A-BAT-B, Battery Room B, was a deterministic based FA. Focus was on classical fire protection features such as detection and suppression for fire scenario FC28_S0584 for 1EE-E115 - 125V Emergency Battery Bank 1B-SB fire and fire scenario FC28_S3391 for TRANS-28-A - 1-A-BATB transient combustible fire.
For each FC/FA/fire scenario selected, the inspectors evaluated the licensees FPP against applicable NRC requirements and licensee design and licensing basis documents. The B.5.b mitigation strategy selected for review was spent fuel pool external makeup using the portable pump. Specific licensing and design basis documents reviewed by the inspectors are listed in the Attachment.
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The inspectors examined HNP fire response abnormal operating procedures (AOPs)and compared them to the NFPA 805 Nuclear Safety Capability Assessment (NSCA)and Fire Safety Analysis (FSA), system flow diagrams, and other design basis documents to determine if equipment required to achieve post-fire safe and stable plant conditions was properly identified and adequately protected from fire damage in accordance with the requirements of 10 CFR 50.48(c) and the HNP approved FPP.
The inspectors reviewed applicable sections of the AOPs for the selected FCs/FAs and fire scenarios to verify that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe and stable plant conditions. The inspectors performed walk-throughs of 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 verified 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
The inspectors conducted in-plant inspections and examined the material condition and as-built configuration of accessible passive barrier features both surrounding and within the FCs/FAs selected for review to evaluate the adequacy of their fire confinement in accordance with the associated design basis documents (DBD) and NFPA 805 FSA calculations. Fire barrier features in use included poured concrete walls, ceilings, floors, fire doors, dampers, electrical raceway fire barrier systems (ERFBS), safety system fire resistive cable and NFPA 805 monitoring program floor drains and curbs.
The inspectors reviewed licensing bases documentation, such as 10 CFR 50.48(a), 10 CFR 50.48(c), the NRC NFPA 805 Safety Evaluation Report (SER), Underwriters Laboratories (UL) listing data, construction details; supporting fire endurance test data, applicable NFPA Code of Record requirements and a sample Existing Engineering Equivalence Evaluations (EEEEs) for selected fire barrier configurations to verify that passive barrier as-built configurations met the FPP fire resistance requirements, engineering design basis, standard industry practices, and were properly evaluated or qualified by appropriate fire endurance tests. In addition, a sample of completed NFPA 805 Monitoring Program credited surveillances and maintenance procedures for selected fire doors, fire dampers, ERFBS and floor drains were reviewed to ensure that these passive barrier features were being properly inspected and maintained. The passive barriers reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The inspectors reviewed the licensees active fire suppression which included the fire pumps and water distribution system, conventional fire detection systems, very early warning fire detection systems and manual fire-fighting fire hose and standpipe systems protecting the FAs selected for review.
The inspectors reviewed the adequacy of the design, installation, and operation of the conventional automatic fire detection and alarm system to actuate in the early stage of a fire. The review included walk downs of the of the as-built configurations and an examination of detector equipment specifications, detector spacing, the licensees technical evaluation of the detector locations, and the ceiling, steel beam reinforcing plans to assess whether the areas were protected by fire detectors appropriate for the types of fire hazards that existed in the selected FAs and were in accordance with the Code of Record requirements (NFPA 72E, 1978 Edition). The inspectors also reviewed the licensees alarm response procedures, NFPA 805 FSA calculations, NFPA 805 license amendment request (LAR) submittals; associated NRC NFPA 805 safety evaluation report (SER). The inspectors used the NRC approved Fire Dynamics Tools (FDT) fire modeling to independently evaluate the fire detection system response to selected NFPA 805 fire scenarios and to verify that the conventional fire detection and alarm systems for the selected FAs would perform in accordance with the established design and licensing bases of the plant.
The inspectors reviewed fire pre-plans and fire response procedures for the selected FAs to determine if appropriate information was provided to fire brigade members to facilitate suppression of an exposure fire that could impact NSCA strategies. The inspectors walked down the selected FAs to compare the associated pre-fire plans and drawings with as-built plant conditions and fire response procedures. This was done to verify that fire pre-fire plan instructions and drawings were consistent with the fire protection features and potential fire conditions described in the NFPA 805 FSA calculations. The inspectors also evaluated whether the fire response procedures and pre-plans for the selected FAs could be implemented as intended. Additionally, fire brigade response time-to-drill scenarios that transpired since 2011 were reviewed to verify that fire brigade response time performance basis monitoring criteria were met.
The inspectors also performed in-plant observations of the material condition and operational lineup of the fire water pumps and fire protection water supply distribution piping including, manual fire hose and standpipe systems for the selected FCs/FAs.
Using operating and valve cycle/alignment procedures as well as engineering drawings, the inspectors examined the electric motor-driven and the diesel-driven 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 (i.e. position of valves). During plant tours, the inspectors observed placement of the fire hoses, fire extinguishers, fire hose nozzle types, and fire hose lengths to verify they were not blocked and that adequate reach and coverage was provided consistent with the fire pre-plans and FPP documents. In addition, a sample of completed NFPA 805 Monitoring Program credited surveillances and maintenance procedures for the conventional fire detection systems, very early warning fire detection systems and fire hose and standpipe systems were reviewed to ensure that these active fire protection systems were being properly inspected and maintained. Specific documents reviewed by the inspectors are listed in the Attachment.
b. Findings
No findings were identified.
.04 Protection from Damage from Fire Suppression Activities
a. Inspection Scope
The inspectors evaluated whether the ability to achieve the nuclear safety performance criteria could be adversely affected due to damage from fire suppression activities or from the rupture or inadvertent operation of manual fire suppression systems. The inspectors walked down the selected FCs/FAs to compare the associated fire pre-plan fire attack tactics and guidelines and checked that fire fighting water would either be contained in the fire affected area or be safely drained off through floor drains or stairwells. The inspectors also reviewed available documentation related to flooding analysis from fire protection activities as well as potential flooding through unsealed concrete floor cracks. The inspectors addressed the possibility that a fire in one FC/FA could lead to the migration of manual smoke or hot gases to other plant areas. Air flow paths out of the selected FCs/FAs identified on heating ventilation and air conditioning (HVAC) drawings were reviewed to verify that inter-area migration of smoke or hot gases would not inhibit necessary post-fire recovery actions for the selected FCs/FAs.
Additionally, the inspectors reviewed flow diagrams and engineering calculations associated with the B train battery room HVAC systems. This review was done to verify that systems used to accomplish post-fire SSD would not be inhibited by a potential hydrogen gas fire in the B battery room due to inoperable ventilation supply and exhaust fans. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.05 Shutdown from a Primary Control Station
a. Inspection Scope
For postulated fire scenarios in FCs/FAs 12-A-CR, 12-A-CRC1, and 12-A-HVIR, which may impair main control room (MCR) functions, the licensee credited shutdown from primary control stations to achieve safe and stable plant conditions. This would involve transferring plant controls from the MCR to the auxiliary control panel (ACP). The process monitoring instruments which were relied on to support safe shutdown were examined to verify that they were either electrically or physically independent of the FAs.
The inspectors reviewed the ACP transfer switch testing methodology to assess the functionality of the isolation feature of the transfer switches. The inspectors also reviewed the licensees FPP as described in the Updated Final Safety Analysis Report (UFSAR) Section 9.5.1, the NSCA, piping and instrumentation drawings, electrical drawings, and other supporting documents. The reviews focused on ensuring that the required functions for post-fire SSD and the corresponding equipment necessary to perform those functions were included in the fire response AOPs. The review included assessing whether safe and stable plant conditions from the primary control stations outside the MCR could be implemented and that transfer of control from the MCR to the ACP could be accomplished in accordance with procedure AOP-004, Remote Shutdown. This review also included verification that safe and stable conditions could be achieved and maintained from the primary control station with and without the availability of offsite power.
b. Findings
No findings were identified.
.06 Circuit Analysis
a. Inspection Scope
The inspectors verified that the licensee performed a NSCA for the selected FCs/FAs and that the assessment identified the structures, systems and components important for achieving safe and stable conditions. For each FC/FA, the inspectors reviewed the electrical schematics, flow diagrams, and the NSCA to identify any potential fire-induced cable damage that could directly affect post-fire recovery actions. The review also focused on ensuring that the required functions for post-fire safe shutdown and the corresponding equipment specified as necessary to perform those functions were included in the procedures. The inspectors reviewed a sample of circuit diagrams to verify that transfer/isolation switches needed for shutdown from a primary control station were provided with circuit isolation at appropriate points in the circuits. The inspectors reviewed the licensees breaker/fuse coordination analysis for distribution panel 1B-SB and MCC 1B35-SB to verify that SSD components had proper breaker and fuse selective coordination.
b. Findings
Introduction:
An NRC-identified Green non-cited violation (NCV) of 10 CFR 50.48 (c)and National Fire Protection Association Standard (NFPA) 805 Section 2.4.3.2 was identified for the licensees failure to address in their Fire Probabilistic Risk Assessment (Fire PRA) the risk contribution associated with all potentially risk significant fire scenarios for selected FCs/FAs. The licensee did not identify and evaluate all targets within the zone of influence (ZOI) of ignition sources for selected fire scenarios which could potentially contribute to the risk for the fire scenarios.
Description:
Walkdowns of the selected FCs/FAs during this TFPI inspection resulted in the identification of numerous missed targets within the ZOI of ignition sources that were not evaluated for their risk contribution to the selected risk significant fire scenarios. The targets were missed when the original ignition source walkdowns were performed in 2006 and 2007 during the licensees initial fire scenario development to support the HNP Fire PRA. Specifically, the licensee did not identify and evaluate several conduits and cable trays that were within the ZOI of ignition sources which could potentially contribute to a risk increase for the selected fire scenarios. The licensee evaluated the risk contribution of the missed targets which resulted in a delta core damage frequency (CDF) of 5.34E-8/year for the selected fire scenarios. The licensee completed extent of condition reviews of fire scenarios in additional risk significant FCs/FAs (FC35/FA 1-A-SWGRB, FC34/FA 1-A-SWGRA, and FC41/FA 1-G Turbine Building) by identifying targets of interest associated with important equipment and evaluation of the ignition sources ZOI around the targets to determine if the ignition sources impacted the targets.
This extent of condition review identified an additional 21 previously unanalyzed ignition source-target ZOI interactions. The risk contribution for the 21 unanalyzed targets resulted in a delta CDF of 4.99E-9/year. Similarly another extent of condition review was performed in other risk significant FCs/FAs (FC16/FA 1-A-ACP, FC19/FA 1-A-BAL-C, and FC32/FA 1-A-EPB) which resulted in the identification of 9 unanalyzed ignition source-target interactions and a delta CDF of 7.21E-10/year. The missed targets identified during the three walkdowns resulted in a total delta CDF of 5.91E-8/year. The licensee documented this issue in the corrective action program (CAP) in nuclear condition reports (NCRs) 682633 and 685355 and established an hourly roving fire watch as compensatory measures.
Analysis:
The licensees failure to comply with the requirements of 10 CFR 50.48(c) and NFPA 805 is a performance deficiency. The performance deficiency was determined to be more than minor because it is associated with the reactor safety mitigating systems cornerstone attribute of protection against external factors (i.e., fire) and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The missed targets in the ZOI for the selected fire scenarios had the potential to impact the ability to achieve safe and stable conditions. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011; Attachment 4, Initial Characterization of Findings, dated June 19, 2012; which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, review was required as the finding affected post-fire SSD. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013, the finding was screened as Green in step 1.6.1 Screen by Licensee PRA-Based Safety Evaluation. An SDP Phase 3 analysis was performed to document the review of the risk determination of the missed ignition source-target interactions using the licensees Fire PRA model. A senior reactor analyst performed the Phase 3 SDP analysis in accordance with the guidance in IMC 0609 Appendix F and NUREG/CR-6850 Revisions 0 and 1. The dominant sequence was a 75th percentile thermal fire in the WC2 chiller motor which remained unsuppressed long enough to result in damage to targets in the ZOI. The fire damage would cause a transient and loss of offsite power to the 6.9kV safety buses and impact operator alignment of offsite breakers. The fire damage combined with random emergency diesel generator common cause failure to run and a random failure to run of the turbine driven auxiliary feedwater pump would result in failure of secondary side heat removal and lead to core damage due to lack of core cooling. The risk was mitigated by the small impact the missed ignition source-target interactions had on the required SSD equipment for the specific scenarios. The evaluation determined that the missed ignition source-target interactions resulted in a CDF increase of 5.91E-8/year, a Green finding of very low safety significance. There was no cross cutting aspect assigned to this finding because it was not indicative of current licensee performance since the original ignition source and target walkdowns were performed in 2006 and 2007.
Enforcement:
Harris Nuclear Power Plant, Unit 1 Renewed Facility Operating License Condition 2.F requires the licensee to implement and maintain in effect all provisions of the approved FPP that comply with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805, as specified in the NRC safety evaluation report dated June 28, 2010. NFPA 805 Section 2.4.3.2 states that the probabilistic safety assessment (HNP Fire PRA) evaluation shall address the risk contribution associated with all the potentially risk-significant fire scenarios.
Contrary to the above, since 2007 the licensee failed to address the risk contribution of all targets within the ZOI of ignition sources associated with all potentially risk significant fire scenarios for selected fire compartments resulting in potentially underestimating the post-fire SSD risk. Because the finding was of very low safety significance (Green) and was entered into the licensees CAP as NCRs 682633 and 685355, this finding is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement policy. This finding is identified as NCV 05000400/2014008-01, Failure to Identify and Evaluate All Targets Within the Zone of Influence of Ignition Sources.
.07 Communications
a. Inspection Scope
The inspectors reviewed the communications capabilities required to support plant personnel in the conduct and coordination of their required actions to achieve safe and stable conditions. The inspectors also verified that portable radio communications and fixed emergency communications systems were available, operable, and adequate for the performance of designated activities to support fire event notification and fire brigade firefighting activities. The inspectors observed the licensee conducting a communication test with the sound powered phone systems and the fire brigade radios to verify the equipment was operational. The inspectors verified, through inspection, the contents of designated emergency storage lockers. Additionally, the inspectors verified that the design and location of communications equipment, such as repeaters and transmitters, would not cause a loss of communications during a fire. The inspectors reviewed preventive maintenance and surveillance test records and vendor manuals to verify that the communications equipment was being properly maintained and tested.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The inspectors reviewed the adequacy of the emergency lighting units (ELUs) used to support plant personnel during post-fire safe shutdown for the selected fire compartments. The inspectors performed plant walkdowns and observed the placement and coverage area of fixed 8-hour battery pack emergency lights credited for SSD, to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. The inspectors reviewed maintenance and test procedures and completed test records of ELU battery 8-hour capacity tests to ensure that they were sized, tested, and maintained consistent with vendor guidance, license requirements, and licensee commitments. The specific documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The inspectors interviewed licensee personnel and the Nuclear Safety Capability Assessment to verify that the licensee had evaluated the need for cold shutdown repairs.
The inspectors determined that the licensee does not require transitioning to cold shutdown to achieve the safe and stable condition, and therefore does not credit repairs to cold shutdown components.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection Scope
The inspectors reviewed the administrative controls for out-of-service, degraded, and/or inoperable fire protection features (e.g., detection and suppression systems, passive fire barriers, SSD). The compensatory measures that had been established were compared to those specified in the FPP for the applicable fire protection feature.
b. Findings
No findings were identified.
.11 Radiological Release
a. Inspection Scope
The inspectors verified that the licensee analysis of radioactive release had been examined on a fire area basis and was addressed in applicable NFPA 805 FSA calculations and fire pre-plans in accordance with NFPA 805, Section 2.2.4. The inspectors reviewed the licensees transient radioactive material fire pre-plan and walked down the selected FCs/FAs to verify that the associated pre-fire plan tactics and instructions were consistent with the potential radiological conditions identified in the NFPA 805 FSA calculations.
b. Findings
No findings were identified.
.12 Non-Power Operations
a. Inspection Scope
One of the requirements in NFPA 805 is for licensees to implement FPP controls during non-power operational modes. Although HNP did not enter an outage during the inspection period, the inspectors reviewed plant calculations, procedures, and analyses that defined the key safety functions required to maintain the plant in a safe and stable condition during non-power operational modes. The inspectors also verified that where the licensee had identified specific areas or pinch points where one or more key safety functions could be lost, additional actions had been established which would be taken during high-risk evolutions in the locations of the pinch points where key safety functions could be lost.
b. Findings
No findings were identified.
.13 Monitoring Program
a. Inspection Scope
The inspectors reviewed procedure AD-EG-ALL-1503, National Fire Protection Association (NFPA) 805 Monitoring, and calculation HNP-M/BMRK-0019, HNP NFPA 805 Monitoring, to verify that a monitoring program was established to ensure that the availability and reliability of the fire protection systems and features credited in the performance-based analyses are maintained and to assess the performance of the FPP in meeting the performance criteria in accordance with NFPA 805. The licensee established performance monitoring groups that provide a link between components and functions that are monitored together. The items in scope were being monitored for performance based on the established criteria as part of the system health reports process. The inspectors reviewed a sample of completed NFPA 805 Monitoring Program credited surveillances and maintenance procedures for the conventional fire detection systems, very early warning fire detection systems and fire hose and standpipe systems to ensure that these active fire protection systems were being properly inspected and maintained. The inspectors also verified that the monitoring program instituted appropriate corrective actions to return availability, reliability, and performance of systems that fall outside of established levels.
b. Findings
No findings were identified.
.14 Plant Change Evaluation
a. Inspection Scope
The inspectors reviewed plant change evaluation forms and engineering change evaluations to verify that the modifications met the requirements of the fire protection license condition for self-approved changes to the fire protection program. The documents reviewed are listed in the attachment.
b. Findings
No findings were identified.
.15 Control of Combustibles and Ignition Sources
a. Inspection Scope
The inspectors reviewed the administrative controls of combustible materials and ignition sources to verify that the FPP performance requirements of NFPA 805 Chapter 3 were satisfied. Plant administrative procedures were reviewed to determine if adequate controls were in place to control the potential ignition sources of welding and grinding and the handling of transient combustibles in the plant. The inspectors walked down numerous areas in the plant, including the selected FCs/FAs, for control of combustible materials, storage of in-plant materials, transient combustibles, and general housekeeping. The inspectors verified that safety can containers with combustibles or flammable liquids were UL or Factory Mutual listed. The inspectors reviewed CAP documents to verify that the licensee was addressing marginal performance in the area of transient combustible controls noted in the 4th quarter 2013 FPP Health Report.
b. Findings
No findings were identified.
.16 B.5.b Mitigating Strategy
a. Inspection Scope
The inspectors reviewed on a sample basis, the licensees preparedness to handle large fires or explosions by reviewing the spent fuel pool external makeup mitigating strategy.
To verify that the licensee continued to meet the requirements of their B.5.b license condition and 10 CFR 50.54 (hh)(2), the inspectors reviewed procedures to ensure that they were being maintained and were adequate; and performed walkdowns with licensee personnel to ensure that the actions were feasible, the required equipment was properly staged, and that personnel were properly trained to implement the strategy.
The inspectors also reviewed maintenance and testing records of equipment to ensure that the equipment was being maintained consistent with vendor recommendations and licensee requirements.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed recent independent licensee assessments for thoroughness, completeness and conformance to FPP requirements. The inspectors also reviewed other CAP documents, including completed corrective actions documented in selected NCRs and operating experience program documents, to verify that industry identified fire protection issues (actual or potential) affecting HNP were appropriately entered into the CAP for resolution. Items included in the operating experience program effectiveness review were NRC information notices, regulatory guides, regulatory issues summaries, industry or vendor generated reports of defects and non-compliances submitted pursuant to 10 CFR Part 21, and vendor information letters. The inspectors evaluated the effectiveness of the corrective actions for the identified issues. The inspectors reviewed CAP documents to verify that the licensee was addressing the marginal performance in the control of transient combustible noted in the 4th quarter 2013 FPP Health Report. The documents reviewed are listed in the Attachment.
4OA6 Meetings, Including Exit
On May 9, 2014, the lead inspector presented the preliminary inspection results to Mr. J.
Dufner, HNP Plant Manager, and other members of the licensees staff, who acknowledged the results. Following completion of additional reviews in the Region II office, another exit meeting was held by telephone with Mr. E. Kapopoulos and other members of the licensees staff on June 23, 2014, to provide an update on changes to the preliminary inspection findings. The licensee acknowledged the findings.
Proprietary information was not included in this inspection report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Brewer, Director, Organization Effectiveness
- J. Caves, Engineer, Regulatory Affairs
- D. Corlett, Manager, Regulatory Affairs
- J. Dufner, Plant General Manager
- R. Dukes, Safe Shutdown Engineer, Harris Engineering Support Section (HESS)
- J. Ertman, Manager, Fleet Fire Protection
- M. Grantham, Director, Design Engineering
- D. Griffin, Manager, Nuclear Training
- D. Hayes, Operations Manager
- E. Kapopoulos, Site Vice President, Harris Plant
- T. Kazukynas, Fire Protection Engineer, HESS
- C. Kidd, Harris Engineering Director
- D. Lewis, Fire Protection Program Manager, HESS
- J. MacIntyre, Fleet Fire Protection Engineer
- K. Miller, Manager, Engineering Programs, HESS
- T. Mitchell, Manager, Maintenance
- J. Nobles, Site Fire Marshall, Operations
- S. OConnor, General Manager, Engineering
- R. Rhodes, Principal Engineer - Safe Shutdown Program Manager, HESS
- B. Scharff, Fire Protection System Engineer, HESS
- G. Simmons, Manager, Emergency Preparedness
- J. Warner, Manager, Work Management
NRC Personnel
- J. Austin, Senior Resident Inspector
- P. Lessard, Resident Inspector
- T. Reis, Director, Division of Reactor Safety, Region II
- S. Shaeffer, Chief, Engineering Branch 2, Division of Reactor Safety, Region II
LIST OF REPORT ITEMS
Opened and Closed
Failure to Identify and Evaluate All Targets
Within the Zone of Influence of Ignition
Sources (Section 1R05.06)