IR 05000219/2017007
Download: ML17122A008
Text
May 1, 2017
Mr. Bryan Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd. Warrenville, IL 60555 SUBJECT: OYSTER CREEK NUCLEAR GENERATING STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000219/2017007
Dear Mr. Hanson:
On April 7, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Oyster Creek Nuclear Generating Station. The enclosed inspection report documents the inspection results, which were discussed on April 7, 2017, with Mr. Garey Stathes, Site Vice President, and other members of your staff. The inspection examined activities conducted under your license as they related to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed station personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions. The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC's Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Sincerely,/RA/ Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-219 License No. DPR-16
Enclosure:
Inspection Report 05000219/2017007
w/Attachment:
Supplemental Information
SUMMARY
IR 05000219/2017007; 03/20/2017 - 04/07/2017; Oyster Creek Nuclear Generating Station; Triennial Fire Protection Inspection. The report covered a two-week onsite triennial fire protection team inspection by specialist inspectors. The U.S. Nuclear Regulatory Commission's (NRC's) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.
No findings were identified.
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REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, "Fire Protection." The objective of the inspection was to assess whether Exelon Generation Company, LLC (Exelon) had implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Oyster Creek Nuclear Generating Station (Oyster Creek). The following fire areas (FAs) and/or fire zones (FZs) were selected for detailed review based on risk insights from the Oyster Creek Individual Plant Examination of External Events (IPEEE) and the Oyster Creek Fire Probabilistic Risk Assessment: OB-FZ-8A/B Motor-Generator Set Room and Mechanical Equipment Room OB-FZ-4 Cable Spreading Room RB-FZ-1D Reactor Building 51' Elevation TB-FA-3A 4160V Emergency Switchgear 1C Vault Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples. The inspection team evaluated Exelon's fire protection program (FPP) against applicable requirements which included Operating License Condition, NRC Safety Evaluation Reports (SERs), 10 CFR 50.48, and 10 CFR 50, Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.5.1, fire protection plan, fire hazards analysis (FHA), and post-fire safe shutdown analyses. The team evaluated aspects of two mitigating strategies for responding to large fires and explosions, as required by Operating License Condition 2.C.(8) and 10 Code of Federal Regulations (CFR) 50.54(hh)(2). Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample. Specific documents reviewed by the team are listed in the attachment to this report.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R05 Fire Protection (IP 71111.05T)
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, safe shutdown analyses, and supporting drawings and documentation to verify that post-fire safe shutdown capabilities were properly protected. The team ensured that applicable separation requirements of Section III.G of 10 CFR Part 50, Appendix R, and the licensee's design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring and associated support system functions.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to evaluate whether the material conditions of the fire area boundaries were adequate for the fire hazards in the area. The team compared the fire area boundaries, including walls, ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway and conduit fire barriers, and redundant equipment fire barriers and radiant energy heat barriers to design and licensing basis requirements, industry standards, and the Oyster Creek FPP, as approved by the NRC, to identify any potential degradation or non-conformances. The team reviewed selected engineering evaluations, installation and repair work orders, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating. The team also reviewed similar records for selected fire protection wraps to verify whether the material and configuration was appropriate for the required fire rating and conformed to the engineering design.
The team also reviewed recent inspection and functional test records for fire dampers, and the inspection records for penetration seals and fire barriers, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The team evaluated manual and automatic fire suppression and detection systems in the selected fire areas to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements, National Fire Protection Association (NFPA) codes of record, and the Oyster Creek FPP, as approved by the NRC. The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas. The team reviewed the as-built capability of the fire water supply system to verify the design and licensing basis and NFPA code of record requirements were satisfied, and to assess whether those capabilities were adequate for the hazards involved. The team reviewed the fire water system hydraulic analyses to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus concurrent fire hose usage.
The team evaluated the fire pump performance tests to assess the adequacy of the test acceptance criteria for pump minimum discharge pressure at the required flow rate, to verify the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied. The team also evaluated the underground fire loop flow tests to verify the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed recent pump and loop flow test results to verify the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified. The team reviewed initial discharge testing, design specifications, vendor requirements, and routine functional testing for the carbon dioxide (CO2) suppression systems for the 4160V Emergency Switchgear 1C Vault. The team walked down accessible portions of the CO2 system, including storage tanks and supply systems, to independently assess the material condition, operational lineup, and availability of the systems. The team also reviewed and walked down the associated fire fighting strategies and CO2 system operating procedures.
The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including diesel driven fire pumps, interviewed system and program engineers, and reviewed selected issue reports (IRs) to independently assess the material condition of the systems and components. In addition, the team reviewed recent test results for the fire detection and suppression systems for the selected fire areas to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified. The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed Exelon's fire fighting strategies (i.e., pre-fire plans) and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. The team independently inspected the fire brigade equipment, including personnel protective gear (e.g., turnout gear) and smoke removal equipment, to determine operational readiness for firefighting. In addition, the team reviewed Exelon's fire brigade equipment inventory and inspection procedure and recent inspection and inventory results to verify adequate equipment was available, and any potential material deficiencies were identified.
b. Findings
No findings were identified.
.04 Protection from Damage from Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
Specifically, the team verified that: A fire in one of the selected fire areas would not indirectly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains; A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not indirectly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and, Adequate drainage is provided in areas protected by water suppression systems
b. Findings
No findings were identified.
.05 Post-Fire Safe Shutdown Capability - Normal and Alternative
a. Inspection Scope
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents for the selected fire areas to verify that the licensee had properly identified the systems and components necessary to achieve and maintain safe shutdown conditions. The team assessed the adequacy of the selected systems and components for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included verification that alternative post-fire shutdown could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the safe shutdown and fire hazards analyses. The team verified that the systems and components credited for use during shutdown would remain free from fire damage.
The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members. The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits.
Specific procedures reviewed for normal and alternative post-fire shutdown included the following: ABN-30, Control Room Evacuation, Revision 29; FSP-OB8A, Fire Support Procedure for Recirculation Motor-Generator Set Room, Revision 6; FSP-OB8B, Fire Support Procedure for Mechanical Equipment Room, Revision 4; FSP-RB1D, Fire Protection Procedure for Reactor Building 51' Elevation, Revision 7; and, FSP-TB3A, Fire Support Procedure for Turbine Building, 4160 Switchgear Room 1C, Revision 4 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
b. Findings
No findings were identified.
.06 Circuit Analysis
a. Inspection Scope
The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown. The team's review considered fire and cable attributes, cable routing, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events. The team also reviewed cable raceway drawings and/or cable routing databases for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the safe-shutdown analysis. The team also reviewed equipment important to safe shutdown, but not part of the success path, to verify that the licensee had taken appropriate actions in accordance with the design and licensing basis and NRC Regulatory Guide 1.189, Revision 2.
Circuit analysis was performed for the following components: LI-211-994, Isolation Condenser 'B' Shell Water Level V-17-2, Shutdown Cooling Pump 'B' Inlet Suction Valve V-17-56, Shutdown Cooling Loop 'B' Discharge Isolation Valve V-20-21, Core Spray Parallel Isolation Valve V-20-33, Core Spray Pump Suction Valve 1B2M, Main Breaker, 460V Unit Substation (USS) 1B2 Unit 041B 1B2P, Breaker, 460V Feeder to USS 1B2 1-1, Reactor Building Closed Cooling Water Pump The team reviewed a sample of circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination that could result in a common power supply or common bus concern.
The team verified that the transfer of control from the control room to the alternative shutdown location(s) would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns. The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The team walked down the emergency lights in the selected fire areas to independently evaluate the placement and coverage areas of the lights. The team assessed whether the lights provided adequate illumination on local equipment and instrumentation required for post-fire safe shutdown, to ensure local operations could be reliably performed under expected post-fire conditions. In addition, emergency light placement was also evaluated to determine adequate illumination of local area access and egress pathways.
The team interviewed system engineers and technical staff to evaluate the adequacy and the performance of the Emergency Lighting Units (ELUs). The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained consistent with the manufacturer's recommendations and in a manner that would ensure reliable operation.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The team reviewed Exelon's dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. In addition, the team verified that the repair equipment, components, tools, and materials (e.g. pre-cut cables with prepared attachment lugs) were available and accessible on site.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time. The team reviewed selected compensatory measures in the form of operator manual actions for 10 CFR 50 Appendix R, Section III.G.2 designated areas to evaluate whether those actions could be reasonably accomplished. Specific attributes reviewed included availability of diagnostic instrumentation, expected environmental conditions, minimum staffing, communications, equipment availability, training, procedures, and verification and validation.
b. Findings
No findings were identified.
.11 Fire Protection Program Changes
a. Inspection Scope
The team reviewed recent changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown.
b. Findings
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The team reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
b. Findings
No findings were identified.
.13 Large Fires and Explosions Mitigation Strategies
a. Inspection Scope
The team reviewed selected mitigation strategies intended to maintain or restore core decay heat removal and spent fuel pool cooling capabilities under the circumstances associated with the loss of large areas of the plant due to explosions or large fires. The team assessed whether Exelon continued to meet the requirements of License Condition 2.C.(8), and 10 CFR 50.54(hh)(2). The team reviewed the following mitigation strategies: EDMG-SPX6, Reactor Pressure Vessel Injection via Feedwater system using the portable pump EDMG-SPX10, Containment Injection using the portable pump The team's review included: a detailed assessment of the procedural guidance; a discussion with operations staff to discuss initial response actions; walk-down of selected mitigation strategies with plant staff to assess the feasibility of the strategies and familiarity of the staff with plant equipment and implementing procedures; maintenance and surveillance testing of selected strategy equipment; and an inventory check of selected mitigation equipment to verify whether equipment storage and availability was appropriate.
b. Findings
No findings were identified.
OTHER ACTIVITIES
[OA]
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that the licensee was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program. The team also reviewed a sample of selected issues to verify that the licensee had taken or planned appropriate corrective actions.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary The team presented their preliminary inspection results to Garey Stathes, Site Vice President, and other members of the site staff at an exit meeting on April 7, 2017. No proprietary information was included in this inspection report.
ATTACHMENT: