IR 05000254/2003012
| ML033390045 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/04/2003 |
| From: | Julio Lara NRC/RGN-III |
| To: | Skolds J Exelon Generation Co |
| References | |
| IR-03-012 | |
| Download: ML033390045 (37) | |
Text
ber 4, 2003
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 NRC INSPECTION REPORT 05000254/2003012; 05000265/2003012(DRS)
Dear Mr. Skolds:
On October 24, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Quad Cities Nuclear Power Station, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on October 24, 2003, with Mr. Tulon and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Julio F. Lara, Chief Electrical Engineering Branch Division of Reactor Safety Docket Nos. 50-254; 50-265 License Nos. DPR-29; DPR-30 Enclosure: Inspection Report 05000254/2003012; 05000265/2003012(DRS)
See Attached Distribution
December 4, 2003 Mr.
SUMMARY OF FINDINGS
IR 05000254/2003012; 05000265/2003012; 10/06/2003-10/24/2003; Quad Cities Nuclear
Power Station, Units 1 and 2; Routine Triennial Fire Protection.
This report covers an announced baseline triennial fire protection inspection. The inspection was conducted by Region III inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after U.S. Nuclear Regulatory Commision (NRC) management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings Cornerstones: Initiating Events and Mitigating Systems No findings of significance were identified.
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of this inspection was to review the Quad Cities Nuclear Power Plant fire protection program for a selected risk-significant fire area. Emphasis was placed on verifying that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspection was performed in accordance with the U.S.
Nuclear Regulatory Commission (NRC) regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The lead inspector used the Quad Cities Nuclear Power Plant Individual Plant Examination for External Events to choose several risk-significant areas for detailed inspection and review. Fire Area TB-III, Unit 1 Turbine Building, Southern Zone Group was reviewed for this inspection. The inspectors focused their review on the following fire zones:
Fire Zone Description of Fire Zone Reviewed 8.2.6.A Unit 1 Turbine Building Ground Floor 8.2.7.A Unit 1 Turbine Building Mezzanine Floor 9.1 Unit 1 Emergency Diesel Generator Room The primary focus for this inspection was on the safe shutdown procedures and safe shutdown methodology for the selected fire area and zones. The determination of license commitments and changes to the fire protection program were reviewed for the selected fire area and zones.
.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
Title 10 CFR Part 50, Appendix R, Section III.G.1, required the licensee to provide fire protection features that were capable of limiting fire damage to structures, systems, and components important to safe shutdown. The structures, systems, and components that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features that were capable of limiting fire damage to the structures, systems, and components so that:
- One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) was free of fire damage; and
- Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) could be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Specific design features for ensuring this capability were specified by 10 CFR Part 50, Appendix R, Section III.G.2.
a. Inspection Scope
The inspectors reviewed the plant systems required to achieve and maintain post-fire safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for each fire zone selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included the fire protection safe shutdown analysis.
The inspectors also reviewed the operators ability to perform the necessary manual actions for achieving safe shutdown including a review of procedures, accessibility of safe shutdown equipment, and the available time for performing the actions.
The inspectors reviewed the updated final safety analysis report and the licensees engineering and/or licensing justifications (e.g., NRC guidance documents, license amendments, technical specifications, safety evaluation reports, exemptions, and deviations) to determine the licensing basis.
b. Findings
No findings of significance were identified.
.2 Fire Protection of Safe Shutdown Capability
Title 10 CFR Part 50, Appendix R, Section III.G.2, required separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. If the requirements cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided (Section III. G.3).
a. Inspection Scope
For the selected fire area, the inspectors reviewed the licensees safe shutdown analysis to ensure that at least one post-fire safe shutdown success path was available in the event of a fire. This included a review of manual actions required to achieve and maintain hot shutdown conditions and make the necessary repairs to reach cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The inspectors also reviewed procedures to verify that adequate direction was provided to operators to perform these manual actions. Factors, such as timing, access to the equipment, and the availability of procedures, were considered in the review.
The inspectors also evaluated the adequacy of fire suppression and detection systems, fire area barriers, penetration seals, and fire doors to ensure that at least one train of safe shutdown equipment was free of fire damage. To accomplish this, the inspectors observed the material condition and configuration of the installed fire detection and suppression systems, fire barriers, and construction details and supporting fire tests for the installed fire barriers. In addition, the inspectors reviewed license documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, fire hazard analysis reports, safe shutdown analyses, and National Fire Protection Association codes to verify that the fire barrier installations met license commitments.
b. Findings
No findings of significance were identified.
.3 Post-Fire Safe Shutdown Circuit Analysis
Title 10 CFR Part 50, Appendix R, Section III.G.1, required that structures, systems, and components important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Options for providing this level of fire protection were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2, an alternative or dedicated shutdown capability and its associated circuits, was required to be provided that was independent of the cables, systems, and components in the area. For such areas, 10 CFR Part 50, Appendix R, Section III.L.3, specifically required the alternative or dedicated shutdown capability to be physically and electrically independent of the specific fire areas and capable of accommodating post-fire conditions where offsite power was available and where offsite power was not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
a. Inspection Scope
On a sample basis, the inspectors evaluated the adequacy of separation provided for the power and control cabling of redundant trains of shutdown equipment. This investigation focused on the cabling of selected components in systems important for safe shutdown. The inspectors review also included a sampling of components whose inadvertent operation due to fire may adversely affect post-fire safe shutdown capability.
The purpose of this review was to determine if a single exposure fire, in one of the fire areas selected for this inspection, could prevent the proper operation of both safe shutdown trains.
b. Findings
No findings of significance were identified.
.4 Alternative Safe Shutdown Capability
Title 10 CFR Part 50, Appendix R, Section III.G.1, required that structures, systems, and components important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Options for providing this level of fire protection were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2, an alternative or dedicated shutdown capability independent of the area under consideration was required to be provided. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those predicted for a loss of normal alternating current power, and the fission product boundary integrity must not be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).
a. Inspection Scope
The inspectors reviewed the licensees systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.
b. Findings
No findings of significance were identified.
.5 Operational Implementation of Alternative Shutdown Capability
Title 10 CFR Part 50, Appendix R, Section III.L.2.d, required that the process monitoring function should be capable of providing direct readings of the process variables necessary to perform and control the functions necessary to achieve reactivity control, reactor coolant makeup, and decay heat removal.
a. Inspection Scope
The inspectors interviewed operators with respect to actions described in procedures QCOA 4100-11, Fire Alarm System Alarm/Trouble; QCOA 0010-12, Fire/Explosion; and QCARP 0030-01, TB-III, Injection with SSMP (Safe Shutdown Makeup Pump) and Bring the Unit to Cold Shutdown. The inspectors reviewed the ability of operators to perform procedure actions within applicable plant shutdown time requirements.
The inspectors reviews of the adequacy of communications and emergency lighting associated with these procedures are documented in Sections 1R05.6 and 1R05.7 of this report.
b. Findings
No findings of significance were identified.
.6 Communications
For a fire in an alternative shutdown fire area such as the cable spreading room, control room evacuation is required and a shutdown is performed from outside the control room.
Radio communications are relied upon to coordinate the shutdown of both units and for fire fighting and security operations. Title 10 CFR Part 50, Appendix R, Section III.H.,
required that equipment provided for the fire brigade include emergency communications equipment.
a. Inspection Scope
The inspectors verified that communications equipment was available to operations personnel.
b. Findings
No findings of significance were identified.
.7 Emergency Lighting
Title 10 CFR Part 50, Appendix R, Section III.J., required that emergency lighting units with at least an eight hour battery power supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
a. Inspection Scope
The inspectors performed a walkdown of a sample of the safe shutdown pathways used for procedure QCARP 0030-01. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations.
b. Findings
No findings of significance were identified.
.8 Cold Shutdown Repairs
Title 10 CFR Part 50, Appendix R, Section III.L.5, required that equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.
a. Inspection Scope
The inspectors reviewed the licensees procedures to determine if any repairs were required to achieve cold shutdown. The inspectors determined that the licensee did require repair of some equipment to reach cold shutdown based on the safe shutdown methods used. The inspectors reviewed the procedures for adequacy.
b. Findings
No findings of significance were identified.
.9 Fire Barriers and Fire Zone/Room Penetration Seals
Title 10 CFR Part 50, Appendix R, Section III.M., required that penetration seal designs be qualified by tests that are comparable to tests used to rate fire barriers.
a. Inspection Scope
The inspectors reviewed the test reports for three-hour rated barriers installed in the plant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with the tested configuration. In addition, the inspectors reviewed the fire loading for selected areas to ensure that existing barriers would not be challenged by a potential fire.
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems, Features, and Equipment
a. Inspection Scope
The inspectors reviewed the material condition, operations lineup, operational effectiveness, and design of fire detection systems, fire suppression systems, manual fire fighting equipment, fire brigade capability, and passive fire protection features. The inspectors reviewed deviations, detector placement drawings, fire hose station drawings, carbon dioxide system pre-operational test reports, and fire hazard analysis reports to ensure that selected fire detection systems, sprinkler systems, portable fire extinguishers, and hose stations were installed in accordance with their design, and that their design was adequate given the current equipment layout and plant configuration.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The inspectors conducted a review to verify that adequate compensatory measures were put in place by the licensee for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features. The inspectors also reviewed the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.
b. Findings
No findings of significance were identified.
.12 Cable Trays
a. Inspection Scope
The inspectors performed a walkdown of the selected fire areas to assess the electrical separation of power, control, and instrumentation cables.
b. Findings
- Cable Ampacity Calculations
Introduction:
The inspectors identified one issue with respect to cable ampacity calculation methodology. The issue will be treated as an unresolved item pending further review of the licensees methodology.
Description:
During the inspectors walkdown of Fire Area TB-III, the inspectors observed that the cable fill for several cable trays, located in the Unit 1 Turbine Building mezzanine area, exceeded the cable trays sidewall height by several inches. The inspectors questioned the licensee about potential overheating of the cables at cable tray points 261T, 261M1, 261M2, and 261B. In addition, the licensee was questioned as to what method was used to account for cable derating/cable tray loading and potential ampacity concerns.
The licensee compared the cable tray points in question to a cable tray thermal analysis report in the Sargent and Lundy Interactive Cable Engineering (SLICE) database. The comparison indicated that cable tray points 261T, 261M2, and 261B did not contain any power cables with ampacity concerns. However, cable tray point 261M1 contained 23 power cables with identified SLICE database ampacity concerns. Licensee engineering personnel stated that the SLICE Users Manual commented that, many apparent overloads can be attributed to the inherent conservatism of the analysis.
Based on the use of ampacity multiplying factors, generated by the calculations identified below, to the cables at cable tray point 261M1, the licensee stated that there were only three cables with ampacity concerns. The three cables identified (i.e., 11636, 11638, and 14007) required a SLICE database revision for two of the cables, as documented in Condition Report (CR) 00180384, Cable Ampacity Input Discrepancies in SLICE Database, dated October 10, 2003, and the remaining cable (cable 14007)supplied a non-continuous load that did not have an adverse effect of cable tray ampacity loading. However, the inspectors were concerned that the calculations used to generate the ampacity multiplying factors, which modified the SLICE database, had not been reviewed and approved by the NRC staff.
The SLICE database program was developed using the Stolpe methodology.1 The experimental work and theory developed by J. Stolpe and others was an accepted methodology utilized in the Insulated Cable Engineers Association (ICEA) and National Electrical Manufacturers Association (NEMA) Standards Publication Number ICEA P-54-440/NEMA WC 51, for calculating Ampacities of Cables in Open-top Cable Trays to provide a more accurate means of calculating cable tray ampacities.
The licensee generated Calculation 9198-13-19-1, Calculation for SLICE Cable Ampacity Multiplying Factors for the Dresden and Quad Cities Stations, Revision 0, dated August 24, 1994, to address inherent conservatism in the SLICE database program. Specifically, the scope of this calculation was to perform analysis and establish a mathematical relationship for refinement of the SLICE calculated ampacities based on cable tray temperature and cable current measurement data for the purpose of investigating whether ampacities higher than the SLICE calculated values could be justified. Initially, cable tray temperature measurements were made at Dresden and Quad Cities Stations for a representative sample of low, medium, and high thermally and physically loaded cable tray points (10 routing points per station). However, the licensee stated that the selected routing points did not bound all possible cases and the number of sample points were low, which resulted in extremely conservative multiplying factors being selected. As a result, the licensee generated Calculation QDC-0000-E-0853, SLICE Cable Ampacity Multiplying Factors for Quad Cities, Revision 0, dated December 2, 1999, where an additional 25 cable tray routing points were selected for temperature measurements at Quad Cities Station. The purpose of this calculation was to determine the load and geometric diversity factors based on the additional cable tray temperature measurements and to select more reasonable ampacity multiplying factors, if possible, which could be applied to the SLICE program to adjust the SLICE ampacity values to reflect the cable tray temperature measurement test results.
Analysis:
Based on a cursory review of Calculation QDC-0000-E-0853, the inspectors concluded that the calculation did not follow the requirements of CC-AA-309-1001, Guidelines for Preparation and Processing Design Analyses, Revision 0. To address this issue, the licensee initiated condition report (CR) 00182702, Deficiency Identified in Calculation QDC-0000-E-0853, Revision 0, dated October 24, 2003. In addition, the inspectors noted that no bounding assumptions were identified in the calculation and, as such, the inspectors were concerned that potential undocumented assumptions may exist. The inspectors also noted that the testing used to support the calculations development (identified in Attachment F, Technical Paper - Braidwood Ampacity Testing) used different cable types and cable tray sizes from those used at the Quad Cities Nuclear Power Station. The effect of these differences on the ampacity multiplying factors were not discussed in the calculation.
IEEE [Institute of Electrical and Electronics Engineers] Transactions on Power Apparatus and Systems, Paper 70 TP 557 PWR, Ampacities for Cables in Randomly Filled Trays, by J. Stolpe, 1970
Enforcement:
Based on the review of the previous items, the inspectors were not able to confirm that the methodology used in the most recent calculation had been reviewed by the NRC. As a result, this issue will be treated as an Unresolved Item (URI) pending further evaluation of the adequacy of the licensee cable ampacity calculation methodology by the NRC staff. (URI 05000254/2003012-01; 05000265/2003012-01)
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed the corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to fire protection at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, work orders, design packages, and fire protection system non-conformance documents.
b. Findings
No findings of significance were identified.
4OA5 Other
(Open) Unresolved Item 05000254/2000016-04; 05000265/2000016-04: Single spurious operation, including effects of automatic depressurization system failures on the time line for achieving safe shutdown. This item was originally discussed in Section E1.4 of Inspection Report 50-254/98-11; 50-265/98-11. Most of the original item was closed in Inspection Report 50-254/00-16; 50-265/00-16. However, the portion involved associated circuits remained open and was tracked under this item. Pending completion of the NRC and industry review and resolution of associated circuit issues affecting safe shutdown, this item will remain open as an Unresolved Item (URI).
4OA6 Meeting(s)
Exit Meeting An exit meeting was conducted for:
Routine Triennial Fire Protection, with Mr. Tulon and other members of licensee management at the Quad Cities Nuclear Power Station on October 24, 2003. The licensee identified proprietary material reviewed during the inspection. The licensee acknowledged that this material had been returned.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- T. Tulon, Site Vice-President
- W. Beck, Regulatory Assurance Manager
- T. Bell, Deputy Engineering Director
- D. Boyles, Operations Support Manager
- A. Scott, Shift Operations Superintendent
NRC
- K. Stoedter, Senior Resident Inspector
Illinois Emergency Management Agency
- R. Ganser, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000254/2003012-01 URI Cable Ampacity Calculation Methodology
- 05000265/2003012-01 (Section 1R05.12)
Closed
None.
Discussed
- 05000254/2000016-04 URI Associated Circuits Issue. Single Spurious Operation,
- 05000265/2000016-04 Including Effect of Automatic Depressurization System Failures on the Time Line (Section 4OA5)
Attachment