IR 05000244/2009006
| ML093620010 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 12/28/2009 |
| From: | Darrell Roberts Division of Reactor Safety I |
| To: | John Carlin Ginna |
| References | |
| EA-09-308, EA-09-310 IR-09-006 | |
| Download: ML093620010 (22) | |
Text
UNITED STATES ber 28, 2009
SUBJECT:
R. E. GINNA NUCLEAR POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000244/2009006 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Carlin:
On November 20. 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your R. E. Ginna Nuclear Power Plant. The enclosed inspection report documents the inspection results, which were discussed on November 20, 2009, with Mr. E. Larson and other members of your staff.
The inspection examined activities conducted under your license as they relate 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 personnel. The scope of the inspection was reduced, in accordance with Inspection Procedure 71111.05TTP, "Fire Protection-NFPA 805 Transition Period (Triennial)," issued on May 9, 2006, as a result of your ongoing project to convert your fire protection program to the performance-based methodology as described in National Fire Protection Association Standard 805.
The report documents one NRC identified and one licensee identified violations for which the NRC is exercising enforcement discretion. The NRC is not taking enforcement action for these violations because they meet the criteria of the NRC Enforcement Policy, "Interim Enforcement Policy regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48),"
and NRC Inspection Manual Chapter 0305, Section 12.01.b, "Violations in Specified Areas of Interest Qualifying for Enforcement Discretion." In accordance with Title 10 of the Code of Federal Regul~tions Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure. and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS):
Darrell J. Roberts, Irector Division of Reactor Safety Docket No. 50-244 License No. DPR-18 Enclosure: Inspection Report No. 05000244/2009006
. w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ State of New York
SUMMARY OF FINDINGS
IR 05000244/2009006; 11/02/2009 -11/20/2009; R.E. Ginna Nuclear Power Plant; Triennial
Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors. .
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Additionally, Constellation Energy Nuclear Group (CENG) has committed to converting the R.
E. Ginna Nuclear Power Plant fire protection program to one which meets 10 CFR 50.48(c),
National Fire Protection Association (NFPA) Standard 805. As a result of NRC enforcement policy changes applicable to plants in the process of transitioning to NFPA 805, two issues were identified and documented in this inspection report but are subject to enforcement discretion (Section 1R05.01 and 40A7).
No findings of significance were identified.
ii
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05TTP. "Fire Protection-NFPA 805 Transition Period (Triennial)." The objective of the inspection was to assess whether CENG has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and were being properly maintained at the R. E. Ginna Nuclear Power Plant facility (Ginna). The following fire areas were selected for detailed review based on risk insights from the Individual Plant Examination (lPE)/lndividual Plant Examination of External Events (IPEEE):
- FZABM
- FZ IBN-1
- FZRR
- FZ SH-2 Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated CENG's fire protection program against applicable requirements which included plant Technical Specifications, Operating License Conditions 2.C.3. NRC Safety Evaluations. 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). the Fire Hazards Analysis (FHA). and the post-fire safe shutdown analyses.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (IP 71111.05T)
.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and
Normal Shutdown
a. Inspection Scope
Methodology The team reviewed the safe shutdown analYSiS, operating procedures. piping and instrumentation drawings (P&IDs), electrical drawings. the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained for fires that rely on shutdown from outside the control room. This review included verification that shutdown from outside the control room 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. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. 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).
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
Operational Implementation 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. Time critical actions, which were verified, included restoration of alternating current (AC) electrical power, establishing the remote shutdown and local shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.
Specific procedures reviewed for alternatiive shutdown, including shutdown from outside the control room included the following:
- ER-Fire.O, Control Room Response to Fire Alarms and Reports;
- ER-Fire.1, Alternate Shutdown for Control Complex Fire; and
- ER-Fire.3, Alternate Shutdown for Aux Building Basement/Mezzanine Fire.
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
Introduction.
The team identified a violation of very low safety significance regarding the adequacy of post-fire safe shutdown analysis and associated operating procedures.
Specifically, the safe shutdown analysis did not evaluate the potential for a steam generator overfill event ,causing the introduction of water into the turbine driven auxiliary feedwater (TDAFW) pump steam supply line. Water in this piping could result in the trip or failure of the turbine. The failure to evaluate and resolve the potential for a steam generator overfill event caused by a plant fire is a violation of License Condition 2.C.3 that requires that the licensee implement the fire protection program features. This issue was determined to satisfy the criteria specified for the exercise of enforcement discretion for plants in transition to a fire protection program that meets the requirements of 10 CFR 50.48(c}, National Fire Protection Association Standard (NFPA)805.
Description.
The Ginna Station Fire Protection Program, Part IV, Safe Shutdown Analysis, states that for a control complex fire, decay heat removal will be provided by local operation of the TDAFW pump and associated valves. Plant procedure ER-Fire.1, Alternate Shutdown for Control Complex Fire, provides the instructions for plant operators to achieve cold shutdown conditions following a control room fire.
The team found that the potential for overfilling the steam generator(s), and the potential impact on post-fire safe shutdown, had not been evaluated in the safe shutdown analysis. The team also noted that procedure ER-Fire.1 did not include operator actions to secure the main feedwater pumps or to isolate feedwater flow to the steam generator(s) prior to evacuation of the control room. As a result, spurious component actuations (such as feedwater control valve opening caused by fire damage to cabling)could result in a rapid fill, and subsequent overfill, of the steam generator(s). One adverse impact on the plant safe shutdown capability resulting from steam generator overfill is that the steam line to the TDAFW pump could be flooded and cause damage to the steam turbine or require additional operator actions ter restore operation of the TDAFW pump following mitigation of the overfill event.
In response to this issue, CENG entered the deficiency in the corrective action program by initiating condition report (CR) 2009-8557 and promptly implemented compensatory actions, including taking actions to revise the affected procedures.
Analysis.
CENG's failure to properly evaluate and resolve the potential for a steam generator overfill event is a performance deficiency. This performance deficiency is more than minor because it was associated with the external factors attribute of the Mitigating Systems Cornerstone and adversely affected the objective to ensure the availability, reliability. and capability of systems that respond to initiating events to prevent undesirable consequences. CENG entered this performance deficiency into their Corrective Action Program (CAP) (CR 2009-8557) and implemented compensatory measures to provide additional guidance to the control room operators. The team viewed these interim actions as appropriate until this issue is fully resolved as part of the licensee's NFPA 805 implementation program. In addition, CENG performed a bounding risk analysis of the potential steam generator overfill event. This bounding analysis represented the cumulative risk for all potentially affected fire areas. No postulated individual fire area scenario was estimated to exceed the GreenIWhite significance threshold. Review by the NRC Region I Senior Reactor Analyst (SRA)determ ined that the CENG risk estimate was appropriately conservative. The SRA concluded that a more detailed risk assessment using more accurate fire modeling and realistic risk values would confirm that this issue is of very low safety significance (Green). Cross~cutting aspects are not applicable as this issue is not indicative of current performance and also because the finding involves enforcement discretion.
Enforcement.
License condition 2.C.3 requires that CENG implement and maintain in effect all fire protection features as approved by the NRC's Fire Protection Safety Evaluation (SE) and SE supplements, including NRC SE dated February 27, 1985.
NRC SE dated February 27, 1985, states that the licensee identified associated circuits that could prevent operation or cause maloperatlon of shutdown systems and equipment, and protection was provided for the safe shutdown systems accordingly.
Contrary to the above, CENG failed to evaluate and resolve the potential impact of a steam generator overfill event caused by spurious actuations resulting from control complex (an alternate shutdown area) fire damage. Although the performance deficiency involves a violation of License Condition 2.C.3; no enforcement action will be taken for this issue because the criteria of NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)," were satisfied. Specifically: 1) although the NRC identified the concern, it is likely that CENG would have identified and corrected this issue as part of the transition to NFPA 805; 2) CENG entered the issue into their CAP and implemented compensatory measures in a reasonable time commensurate with the risk significance; 3) this issue was not likely to have been previously identified by routine CENG activities; and, 4) the violation was not willful. Because all the criteria were met, the NRC is exercising enforcement discretion for this issue.
.02 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separatiQn requirements of Section III.G of 10 CFR50, Appendix R 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.
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 protective features were being properly maintained and administrative controls were being implemented.
.
b. Findings
No findings of significance were identified .
.03 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors and fire dampers). and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.
The team reviewed installation/repair and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design. The team also reviewed similar records for the fire protection wraps to ensure the material was of an appropriate fire rating and that the installation met the engineering design.
b. Findings
No findings of significance were identified .
.04 Active Fire Protection
a. Inspection Scope
The team revieWed the design, maintenance, testing. and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed. tested, and maintained in accordance with the NFPA code of record, or as NRC approved exemptions. and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems were verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, Halon and/or carbon dioxide (C02) storage tanks and supply system) to assess the material co,ndition of the systems and components.
The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine jf ,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. In addition, the Jeam inspected the fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.
b. Findings
No findings of significance were identified .
.05 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 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 directly. 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 directly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train).
- Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings of Significance were identified .
.06 Alternative Shutdown Capability
a. ' Inspection Scope Alternative shutdown capability is discussed in section 1R05.01 of this report .
.07 *
Circuit Analysis NRC Inspection Procedure 71111.05TTP, "Fire Protection-NFPA 805 Transition Period (Triennial)," reduces the scope of this inspection by specifically eXcluding review of circuit configurations for plants transltloning their lire protection program. to the requirements of NFPA 805.
.08 Communications
a. Inspection ~cope 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 of significance were identified .
.09 Emergency Lighting
a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and _ _ __
egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire safe shutdown. 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
.in a manner that would ensure reliable operation.
b. Findings
No findings of Significance were identified . . 10 Cold Shutdown Repairs
a. Inspection Scope
The team verified that the licensee had 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. 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 of significance were identified.
.11 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.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
lOA] 40A2 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 of significance were identified.
40A6 Meetings, Including Exit .
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. E. Larson, Plant Manager, and other members of the site staff at an exit meeting on November 20, 2009. No proprietary information was included in this inspection report.
40A7 Licensee-Identified Violations The following violation was identified by CENG and is a violation of NRC requirements which met the criteria of the NRC Enforcement Policy for disposition as a Non-Cited Violation (NCV).
License Condition 2.C.3 requires that CENG implement and maintain in effect all fire protection features as approved by the NRC's Fire Protection Safety Evaluation (SE)and SE supplements, including NRC SE dated February 27,1985. NRC SE dated February 27. 1985. states that the licensee identified associated circuits that could prevent operation or cause maloperation of shutdown systems, and that the licensee provided protection for the affected safe shutdown systems. Contrary to the above, as part of the transition to NFPA 805, CENG identified potential fire induced spurious operations which could negatively affect the fire safe shutdown systems which were not previously protected against. Specifically:
- Spurious motor operated valve failure, preventing the isolation of letdown which could result in excessive inventory loss
- Spurious isolation of the credited charging pump's suction source which could result in damaging the credited makeup source
- Spurious emergency diesel generator (EDG) "A" output breaker closing which could result in damaging the EDG "A"
- Spurious emergency diesel generator (EDG) "8" output breaker closing which could result in damaging the EDG "8"
- Spurious closure of TDAFW pump discharge valve which could result in loss of decay heat removal
- Spurious closure of standby auxiliary feedwater (SAFW) pump discharge and suction valves which could prevent transitioning into cold shutdown Although the performance deficiency involves a violation of License Condition 2.C.3; no enforcement action will be taken for this issue because the criteria of NRC Enforcement Policy, "Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48)," were satisfied. Specifically: 1) CENG identified and will correct this issue as part of the transition to NFPA 805; 2) CENG entered the issue into their CAP (CR Nos. 2009-5923, 6284, 6291, 6295, 7542, 7584) and implemented compensatory measures in a reasonable time commensurate with the risk significance; 3) this issue was not likely to have been previously identified by routine CENG activities; and, 4) the violation was not willful. CENG performed a bounding risk assessment of .
each potential spurious actuation event. Individual postulated fire area scenarios were estimated to be near or below the GreenlWhite significance threshold. Review by the NRC Region I SRA concluded that CENG's bounding analysis assumptions were conservative and that a more accurate fire model and realistic risk values would likely confirm that this issue is of very low safety Significance (Green). Because all the criteria were met, the NRC is exercising enforcement discretion for this issue.
ATIACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
E. Larson Plant Manager
L. Brennan Fire Safety Instructor
B. Cooper Fire Protection Engineering Consultant
D. Crowley HVAC Systems Engineer
M. Edelstein Fire Marshal
B.Hunn Design Engineering
J. Jackson Design Engineering
M. McGraw Fire Protection Engineer
K. McLaughlin Operations
N. Meaker Operations Training
M. Ruby Licensing Engineer
J. Sharlow Fire Protection Specialist
- S. Wihlen Maintenance, Supervisor
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- W. Cook, Senior Reactor Analyst, Division of Reactor Safety
- K. Kolaczyk. Senior Resident Inspector, Ginna Nuclear Power Plant
- L. Casey, Resident Inspector, Ginna Nuclear Power Plant
LIST OF ITEMS
O~ENED, CLOSED, AND DISCUSSED None