IR 05000247/2017007
| ML17341A080 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/05/2017 |
| From: | Glenn Dentel Engineering Region 1 Branch 2 |
| To: | Vitale A Entergy Nuclear Operations |
| Dentel G | |
| References | |
| IR 2017007 | |
| Download: ML17341A080 (32) | |
Text
A.
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., Suite 100 KING OF PRUSSIA, PA 19406-2713 December 5, 2017 Mr. Anthony Site Vice President Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 SUBJECT: INDIAN POINT NUCLEAR GENERATING - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000247/2017007 and 05000286/2017007
Dear Mr. Vitale:
On November 3, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Indian Point Nuclear Generating (Indian Point), Units 2 and 3 and the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
These findings involved violations of NRC requirements. The NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a written response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Indian Point. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Indian Point. 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 NRCs 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 Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Enclosure:
Inspection Report 05000247/2017007 and 05000286/2017007 w/Attachment:
Supplementary Information
ML17341A080 SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available OFFICE RI/DRS RI/DRS RI/DRP RI/DRS ARosebrook via NAME EDiPaolo DSchroeder GDentel email DATE 12/5/17 12/4/17 12/5/17 12/5/17
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Report Nos. 05000247/2017007 and 05000286/2017007 Licensee: Entergy Nuclear Northeast (Entergy)
Facility: Indian Point Nuclear Generating, Units 2 and 3 Location: 450 Broadway, General Services Building Buchanan, NY 10511-0249 Dates: October 16, 2017, through November 3, 2017 Inspectors: E. DiPaolo, Senior Reactor Inspector (Team Leader)
D. Kern, Senior Reactor Inspector K. Young, Senior Reactor Inspector L. Dumont, Reactor Inspector S. Elkhiamy, Reactor Inspector J. Patel, Reactor Inspector J. Rady, Reactor Inspector Approved by: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY
IR 05000247/2017007 and 05000286/2017007; 10/16/2017 - 11/03/2017; Indian Point Nuclear
Generating (Indian Point; Triennial Fire Protection Inspection.
This report covers a two-week onsite triennial fire protection team inspection by specialist inspectors. Two findings of very low safety significance (Green) were identified. These findings were determined to be non-cited violations (NCVs). The significance of most 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 April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of U.S. Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, Reactor Oversight Process, Revision 6.
Cornerstone: Mitigating Systems
- Green.
An NRC-identified finding of very low safety significance (Green), involving an NCV of Indian Point Unit 3 Facility Operating License (FOL) Condition 2.H, was identified because Entergy did not implement and maintain in effect all provisions of the Fire Protection Program (FPP), as approved by the NRC. Specifically, Entergy did not have an adequate post-fire operating procedure for its alternative shutdown capability to ensure that safe shutdown (SSD) equipment analyzed to be available during the postulated fire in fire area ETN-4{2}, Upper Electrical Tunnel, were credited in the procedure. Entergy entered this issue into its corrective action program (CAP) and promptly implemented compensatory measures by establishing a fire watch.
This finding was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The team performed a Phase 2 Significance Determination Process screening for this issue, in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected the post-fire SSD category because the implementing procedures were adversely affected. The team determined that this finding screened to very low safety significance (Green) based upon task 2.3.5, because no credible fire ignition source scenarios were identified in fire area ETN-4{2}
that could affect both electrical channels I and II cables. This finding did not have a cross-cutting aspects because it was a legacy issue and was considered to not be indicative of current licensee performance. (Section 1R05.05)
- Green.
An NRC-identified finding of very low safety significance (Green) and NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh)(2), Conditions of Licenses, the Unit 2 FOL Condition 2.N, and the Unit 3 FOL Condition 2.AC was identified for failure to maintain strategies for addressing large fires and explosions.
Specifically, Entergy failed to maintain the B.5.b strategies when the sites diesel contingency pump (B.5.b pump), B5B-101-PMP, was declared non-functional and unavailable on March 20, 2017, due to a deficiency associated with the pumps engine and failed to promptly restore the pump to a functional status or establish any compensatory measures. Entergy entered this issue into its CAP and promptly completed repairs to the B.5.b pump.
This finding was more than minor because it is associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent core damage. The team evaluated the significance of the finding in accordance with IMC 0609, Appendix L, B.5.b Significance Determination Process. The finding was determined to be of very low safety significance (Green) because although the B.5.b pump was considered unavailable, the team concluded that the pump was recoverable. This finding had a cross-cutting aspect of Resources, in the area of Human Performance, because leaders did not ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety. Specifically, procedural guidance and equipment were not available to operators to implement adequate compensatory measures when the B.5.b pump became non-functional and unavailable. [H.1] (Section 1R05.13)
Other Findings
A violation of very low safety significance that was identified by Entergy was reviewed by the inspectors. Corrective actions taken or planned by Entergy have been entered into the CAP.
This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure 71111.05T, Fire Protection. The objective of the inspection was to assess whether Entergy had implemented an adequate FPP and that post-fire SSD capabilities have been established and are being properly maintained at Indian Point, Units 2 and 3. The following fire areas and/or fire zones were selected for detailed review based on risk insights from the Indian Point Individual Plant Examination of External Events:
Unit 2 Fire Areas / Fire Zones Fire Area A, FZ-11-Cable Spreading Room Fire Area A, FZ-32A-Electrical Tunnel Fire Area C, FZ-23-Auxiliary Boiler Feed Pump Room Unit 3 Fire Areas / Fire Zones Fire Area CNT-1-Containment Fire Area ETN-4, FZ-60A-Upper Electrical Tunnel Fire Area CTL-3, FZ-10-Diesel Generator 31 Fire Area CTL-3, FZ-14-480V Switchgear Room Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated Entergys FPP against applicable requirements which included Unit 2 FOL Condition 2.K, Unit 3 FOL Condition 2.H, NRC Safety Evaluation Reports, 10 CFR 50.48, and 10 CFR Part 50, Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report, the fire protection plan, fire hazards analysis (FHA), and post-fire SSD analyses.
The team evaluated aspects of five mitigating strategies for responding to large fires and explosions, as required by Unit 2 FOL Condition 2.N, Unit 3 FOL Condition 2.AC, and 10 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
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, SSD analyses, and supporting drawings and documentation to verify that SSD capabilities were properly protected. The team ensured that applicable separation requirements of Section III.G of 10 CFR Part 50, Appendix R and the licensees design and licensing bases were maintained for the credited SSD 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 Indian Point 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. In addition, the team reviewed recent test results for the carbon dioxide (CO2) and Halon fire damper functionality tests for the areas protected to verify the testing was adequately conducted, the acceptance criteria were met, and any 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 Indian Point 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, modifications and engineering evaluations, and routine functional testing for the CO2 and Halon suppression systems for the areas protected. The team walked down accessible portions of the CO2 and Halon systems, 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 and Halon 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 motor and diesel driven fire pumps and fire water storage tanks, interviewed system and program engineers, and reviewed selected condition reports (CRs) 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 Indian Point'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 SSD equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire SSD 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 Indian Point'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 SSD 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 SSD analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the Updated Final Safety Analysis Report, 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 SSD 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 SSD 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 SSD 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.
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.
Specific procedures reviewed for normal and alternative post-fire shutdown included the following:
Unit 2 2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control 2-ONOP-FP-001, Plant Fires 2-SOP-ESP-001, Local Equipment Operation and Contingency Actions Unit 3 3-ONOP-FP-1, Plant Fires 3-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control 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 SSD 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
Unit 3 - Inadequate Alternative Post-Fire Safe Shutdown Procedure
Introduction:
An NRC-identified finding of very low safety significance (Green), involving an NCV of Indian Point Unit 3 FOL Condition 2.H, was identified because Entergy did not implement and maintain in effect all provisions of the FPP, as approved by the NRC.
Specifically, Entergy did not have an adequate post-fire operating procedure for its alternative shutdown capability to ensure that SSD equipment analyzed to be available during the postulated fire in fire area ETN-4{2}, Upper Electrical Tunnel, were credited in the procedure.
Description:
IP3-ANAL-FP-01503, Unit 3 Safe Shutdown Analysis, analyzed fire area ETN-4{2}, Upper Electrical Tunnel, for SSD equipment and cables within the area and determined that the requirements for component and cable separation specified in Appendix R,Section III.G.2, could not be satisfied. As such, Entergy designated fire area ETN-4{2} as an alternative SSD area, in accordance with Appendix R,Section III.G.3 and III.L. The SSD analysis also identified fire area CTL-3, Control Building Area, as a III.G.3 area. Fire area CTL-3 consisted of the control room, switchgear room, cable spreading room, and the diesel generator rooms. The SSD analysis determined that a postulated worst case fire in any of III.G.3 fire areas would result in a control room evacuation, with alternative shutdown performed at remote shutdown locations throughout the plant.
Operators would implement Indian Point Unit 3 procedure 3-ONOP-FP-1, Plant Fires, for response to any fire in the plant. Procedure 3-ONOP-FP-1 provided criteria for evacuation of the control room, and when those criteria were met, the procedure directed operators to implement Indian Point Unit 3 procedure 3-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control. The team identified that for a fire in fire area ETN-4{2}, procedure 3-ONOP-FP-1 did not direct operators to implement alternative SSD procedure 3-AOP-SSD-1. Additionally, the team identified that 2 of 3-ONOP-FP-1, which provided tables by each fire area that contained equipment credited for each fire areas, was missing a table for fire area ETN-4{2}. The team noted that alternative SSD procedure 3-AOP-SSD-1 credited equipment for achieving SSD based on the SSD equipment and cables analyzed for control building fire area CTL-3. The team reviewed Indian Point Unit 3 SSD analysis IP3-ANAL-FP-01503 and determined that the analysis credited different sets of alternative SSD equipment for fire areas CTL-3 and ETN-4{2}. Based on these, the team identified the following deficiencies within 3-AOP-SSD-1 procedure:
ETN-4{2} credited the use of 32 charging pump while CTL-3 credited the use of 31 charging pump; ETN-4{2} credited Appendix R diesel generator for supplying power to the vital 480V buses, however, no instructions were provided in the procedure to energize vital 480V buses from Appendix R diesel generator; Appendix R diesel generator had capability to power 38 service water pump from MCC 312A, however, 38 service water pump was not analyzed in the analysis for ETN-4{2}; and, ETN-4{2} credited process instruments for steam generator level, steam generator pressure, reactor coolant system temperature, reactor coolant system pressure, and pressurizer level, which were not consistent with equipment credited for alternative shutdown areas in 3-AOP-SSD-1.
The team determined that the SSD analysis correctly analyzed and identified equipment to achieve SSD conditions for a postulated fire in fire area ETN-4{2}. However, the results of the SSD analysis were not correctly translated into post-fire SSD operating procedures. Entergy entered this issue into its CAP as CR-IP3-2017-05108 and CR-IP3-2017-05109, and promptly implemented compensatory measures in accordance with the FPP. Interim compensatory measures included establishing fire watches in the affected fire area. The team concluded that Entergys compensatory measures were reasonable and appropriate.
Analysis:
Failure to ensure that the alternative post-fire SSD operating procedures for some postulated fire-induced equipment failures provided adequate instruction for achieving SSD of the plant was a performance deficiency. This performance deficiency was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
The team performed a Phase 2 Significance Determination Process screening for this issue, in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected the post-fire SSD category because the implementing procedures were adversely affected. The team determined that this finding screened to Green based upon task number 2.3.5, because the affected cables were routed in the area that was protected by four separate pre-action sprinkler systems that protected the cable trays along each wall of the tunnel with head at 10-ft intervals in the cable trays; heat detectors (one for each pre-action systems) that are located in the trays with individual detectors at approximately 20-ft intervals; and area wide ionization detectors and CO2 fire extinguishers. Based on the teams walkdown, no credible fire ignition source scenarios were identified in the fire area ETN-4{2} that could affect both electrical channels I and II cables. Therefore, this finding screened to very low safety significance (Green).
The finding did not have a cross-cutting aspect because it was a legacy issue (i.e.,
deficiency existed for more than three years) and was considered to not be indicative of current licensee performance.
Enforcement:
Indian Point Unit 3 FOL Condition 2.H, in part, required Entergy to implement and maintain in effect all provisions of the FPP, as approved by the NRC.
IP3-ANAL-FP-01503, Safe Shutdown Analysis, stated that Section III.L of 10 CFR Part 50, Appendix R was applicable for areas of the plant where postulated fire scenarios were mitigated through use of alternative shutdown methods. Appendix R,Section III.G.3, states, in part, where protection of SSD systems does not satisfy the requirements of III.G.2, alternative dedicated shutdown capability shall be provided.
Appendix R,Section III.L.3, states, in part, that alternative shutdown capability shall be independent of the specific fire areas and procedures shall be in effect to implement this capability.
Contrary to the above, as of November 2, 2017, Entergys alternative shutdown procedures did not provide adequate written instructions to ensure SSD was achieved for a postulated fire in fire area ETN-4{2}. Specifically, 3-AOP-SSD-1 procedure did not contain any steps to direct the use of alternative shutdown equipment credited in ETN-4{2} fire area. The procedure was not consistent with respect to SSD equipment analyzed for the alternate shutdown areas. As a result, operators would have relied on equipment that was susceptible to fire damage. Entergy implemented compensatory measures for this procedure deficiency. Because this violation was of very low safety significance (Green) and was entered into Entergys CAP (CR-IP3-2017-05108 and CR-IP3-2017-05109), this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000286/2017007-01, Inadequate Alternative Post-Fire Safe Shutdown Procedure)
.06 Circuit Analysis
a. Inspection Scope
The team verified that the licensee performed a post-fire SSD analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining SSD. Additionally, the team verified that the licensees analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact SSD due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent SSD.
The teams 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 SSD to verify that cables were routed as described in the SSD analysis. The team also reviewed equipment important to SSD, 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:
Unit 2 HCV3100 & HCV3101, Indian Point Unit 2 (IP2) Reactor Head Vent Motor-Operated Valves 730 & 731, IP2 Residual Heat Removal (RHR) Pump Suction Isolation Shutdown Cooling Motor-Operated Valves 22, IP2 RHR Pump PT-3105, IP2 Pressurizer Pressure Indication for Alternate Safe Shutdown LCV-112B, IP2 Refuel Water to Charging Pump Suction Unit 3 MOV-882, RHR Pump Suction Stop Valve MOV-744, RHR Pump Discharge Header Isolation Valve LCV-112B, Level Control Valve Isolation for the Refueling Water Storage Tank to Charging Pump MOV-822B, Shut-Off Valve for Component Cooling Water from RHR System Heat Exchanger 32 ACS2 Pump-31, Component Cooling Water Pump 31 TE-413A, RCS Delta T Temperature Element Hot Leg Loop 1 The team reviewed a sample of circuit breaker coordination studies to ensure equipment needed to conduct post-fire SSD 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 SSD procedures, the SSD 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 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 or instrumentation monitoring for post-fire SSD. 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 manufacturers 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 verified that Entergy 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 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 SSD equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing SSD 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 on Unit 2 in the form of operator manual actions for 10 CFR Part 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. The team noted that for the selected fire areas on Unit 3 which were designated as 10 CFR Part 50 Appendix R, Section III.G.2 areas, there were no compensatory measures in the form of operator manual actions.
b. Findings
No findings were identified.
.11 Fire Protection Program Changes
a. Inspection Scope
The team reviewed recent changes to the approved FPP 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 licensees 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 Entergy continued to meet the requirements of FOL Condition 2.N for Unit 2, FOL Condition 2.AC for Unit 3, and 10 CFR 50.54(hh)(2). The team reviewed the following mitigation strategies:
Unit 2 Spent Fuel Pool External Fill or Spray using Portable Pump Unit 2 and 3 Refueling Water Storage Tank Makeup with Diesel Contingency Pump Unit 3 Steam Generator Depressurization and Fill with 32 Auxiliary Boiler Feed Pump Unit 3 Manual Depressurization of Steam Generators using Local Operation of Atmospheric Steam Dump Valves The team's review included: a detailed assessment of the procedural guidance; a tabletop discussion with a non-licensed operator (i.e., postulated highest ranking Operations Department staff member to survive an event or hostile action) 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
Introduction:
An NRC-identified finding of very low safety significance (Green) and NCV of 10 CFR 50.54(hh)(2), Conditions of Licenses, the Unit 2 FOL Condition 2.N, and the Unit 3 FOL Condition 2.AC was identified for failure to maintain strategies for addressing large fires and explosions. Specifically, Entergy failed to maintain the B.5.b strategies when the sites B.5.b pump, B5B-101-PMP, was declared non-functional and unavailable on March 20, 2017, due to a deficiency associated with the pumps engine and failed to promptly restore the pump to a functional status or establish any compensatory measures.
Description:
The team reviewed the operational status of the sites B.5.b pump. The team discovered that the pump was declared non-functional and unavailable on March 20, 2017, due to a deficient throttle on the pumps diesel engine. In addition, the pumps diesel engine failed to crank on a start demand during testing on September 11, 2017. Entergy did not establish any compensatory measures for the non-functional B.5.b pump and planned to complete repairs through the normal work scheduling process with a targeted completion date in February 2018. The team noted that there was no mechanism in place by control room operators to track the operational status of the pump. The team concluded that unnecessary delays would be encountered in the event that mitigating strategies associated with a loss of large areas of the plant due to explosions or fire needed to be implemented due to the unavailable pump. The team determined that the failure to promptly restore the B.5.b pump to a functional status or establish any compensatory measures was a performance deficiency.
Analysis:
The failure to promptly restore the sites B.5.b pump to a functional and available status or establish any compensatory measures in order to satisfy the Units 2 and 3 FOL conditions associated with maintaining strategies for addressing large fires and explosions was a performance deficiency. Specifically, Entergy failed to maintain B.5.b strategies when the sites B.5.b pump was declared non-functional and unavailable on March 20, 2017, due to a deficient throttle valve on the pumps diesel engine. In addition, the B.5.b pumps diesel engine failed to crank on a start demand on September 11, 2017. Entergy failed to promptly restore the B.5.b pump to a functional status or establish any compensatory measures. This finding was more than minor because it is associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent core damage.
The team evaluated the significance of the finding in accordance with IMC 0609, Appendix L, B.5.b Significance Determination Process. The finding was determined to be of very low safety significance (Green) because although the B.5.b pump was considered unavailable, the team concluded that the pump was recoverable. This was because: 1) operators, with minor assistance of onsite maintenance personnel, were able to troubleshoot, repair, and place the B.5.b pump into operation within the time needed to support the most time limiting mitigating strategy (1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> versus a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> commitment) on November 3, 2017; and 2) an alternate B.5.b pump (B5B-102-PMP),although not officially credited, maintained, or periodically tested, was demonstrated to be functional in the as-found condition on November 4, 2017.
This finding had a cross-cutting aspect of Resources, in the area of Human Performance, because leaders did not ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety.
Specifically, procedural guidance and equipment were not available to operators to implement adequate compensatory measures when the B.5.b pump became non-functional and unavailable. Entergy entered this issue into the CAP as CR-IP2-2017-04349. [H.1]
Enforcement:
10 CFR 50.54(hh)(2) requires, in part, that each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire. Unit 2 FOL Condition 2.N and Unit 3 FOL Condition 2.AC require that the licensee shall develop and maintain strategies for addressing large fires and explosions. Procedure 0-SOP-ESP-002, Emergency Contingency Plan, Revision 12, implements mitigating strategies addressing large fires and explosion utilizing the diesel-driven B.5.b pump.
Contrary to the above, between March 20, 2017, and November 3, 2017, Entergy failed to maintain strategies for addressing large fires and explosions. Specifically, the B.5.b Pump was declared non-functional and unavailable due to a deficient throttle on the pumps diesel engine. Entergy did not promptly restore the pump to a functional status or establish any compensatory measures until November 3, 2017, when repairs and testing were completed. Because this finding is of very low safety significance (Green)and has been entered into Entergys CAP as CR-IP2-2017-04349, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy.
(NCV 05000247, 286/2017007-02, Failure to Maintain B.5.b Mitigating Strategies)
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that Entergy was identifying fire protection and post-fire SSD issues at an appropriate threshold and entering them into the CAP. The team also reviewed a sample of selected issues to verify that Entergy 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 Mr. Anthony J. Vitale, Site Vice President, and other members of the site staff at an exit meeting on November 3, 2017. No proprietary information was included in this inspection report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
Indian Point Unit 2 Technical Specification 5.4.1.k and Indian Point Unit 3 Technical Specification 5.4.1.d require written procedures shall be established, implemented, and maintained covering FPP implementation. Procedure 0-PT-M004, Fire Extinguisher Inspection, Revision 9 implements monthly inspections of portable fire extinguishers to verify hydrostatic testing and periodic maintenance was performed within the periodicity specified by NFPA 10-1990, Standard for Portable Fire Extinguishers. Procedure 0-PT-M004 requires portable fire extinguishers to be removed from service and replaced if their periodic maintenance or hydrostatic testing are not current within the specified periodicity.
Contrary to the above, from July 1, 2015, to August 25, 2017, approximately 200 portable fire extinguishers were not removed from service and replaced when they exceeded their specified periodicity for maintenance and/or hydrostatic testing.
Specifically, plant staff did not properly implement procedure 0-PT-M004 to verify portable fire extinguishers were periodically maintained and hydrostatically tested at intervals specified by NFPA 10-1990. The application software used in conjunction with 0-PT-M004 to perform monthly fire extinguisher inspections was revised in June 2015 and plant staff did not set up the software to require verification that fire extinguisher maintenance and hydro tests were current. Fire protection engineers identified the issue in August 2017, evaluated the subject fire extinguishers, and determined they were acceptable for continued use until December 31, 2017, based on the relatively short period of untimely maintenance/testing, satisfactory monthly verifications of physical condition, and the availability of additional portable fire extinguishers in the affected fire areas. Additional corrective actions included initiation of an accelerated maintenance and hydro test program to ensure all portable fire extinguishers met NFPA-10 maintenance and test requirements by December 21, 2017, and revision of 0-PT-M004 and the associated application software. Entergy entered the issue into the CAP (CRs IP3-2017-04084 and IP3-2017-02945). The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because the finding did not impact the frequency of a fire and did not involve a loss or degradation of equipment or function specifically designed to mitigate an external event.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- A. Vitale, Site Vice President
- M. Troy, Engineering Programs Supervisor
- S. Bianco, Fire Marshal
- R. Caffo, Fire Brigade Member and Nuclear Plant Operator
- G. Dahl, Senior Regulatory Affairs Engineer
- S. Hurbanek, Senior Reactor Operator
- K. Elliot, Safe Shutdown Engineer
- J. Geraci, Telecommunication Engineer
- K. McKenna, Unit 2 Operations Manager
- M. Mirzai, Licensing
- P. Robert, Telecommunication Engineer
- E. Schimpf, Reactor Operator
- C. Wilson, Fire Protection Program Engineer
NRC
- B. Haagensen, Senior Resident Inspector, Indian Point Nuclear Generating Units 2 and 3
- A. Siwy, Resident Inspector, Indian Point Nuclear Generating Units 2 and 3
- M. Rossi, Resident Inspector, Indian Point Nuclear Generating Units 2 and 3
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Opened and Closed
- 05000286/2017007-01 NCV Inadequate Alternative Post-Fire Safe Shutdown Procedure (Section 1R05.05)
- 05000247, 286/2017007-02 NCV Failure to Maintain B.5.b Mitigating Strategies (Section 1R05.13)
Closed
None.