IR 05000255/2005003
| ML050730278 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/14/2005 |
| From: | Julio Lara Division of Reactor Safety III |
| To: | Domonique Malone Nuclear Management Co |
| References | |
| IR-05-003 | |
| Download: ML050730278 (28) | |
Text
rch 14, 2005
SUBJECT:
PALISADES NUCLEAR PLANT FIRE PROTECTION TRIENNIAL BASELINE INSPECTION NRC INSPECTION REPORT 05000255/2005003(DRS)
Dear Mr. Malone:
On January 28, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection findings which were discussed on January 28, 2005, with you 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. Additionally, a licensee identified violation is listed in Section 4OA7 of this report.
In accordance with 10 CFR 2.390 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 (PARS) component of NRCs document 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 No. 50-255 License No. DPR-20 Enclosure: Inspection Report 05000255/2005003(DRS)
w/Attachment: Supplemental Information See Attached Distribution
March 14, 2005 Mr. Daniel
SUMMARY OF FINDINGS
IR 05000255/2005003(DRS); 01/10/2005 - 01/28/2005; Palisades Nuclear Plant; Fire Protection
Triennial Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. Based on the results of this inspection, no findings of significance were identified. 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 NRC management review. The NRC's 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
Cornerstone: Initiating Events
No findings of significance were identified.
Cornerstone: Mitigating Systems
No findings of significance were identified.
Licensee-Identified Violations
A violation of very low safety significance, was identified by the licensee and has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. The violation and the licensees corrective action tracking number is listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
At the start of the inspection the plant was shutdown. On January 14, 2005, the reactor was taken critical and the main generator was synchronized to the electrical grid on January 19, 2005. The plant was returned to full power on January 21,
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of this inspection was to review the Palisades Nuclear Plants (PNPs) Fire Protection Program (FPP) for selected risk-significant fire areas. Emphasis was placed on determining 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 Nuclear Regulatory Commissions (NRCs) regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The inspectors used the PNPs Individual Plant Examination of External Events (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire zones chosen for review during this inspection were:
Selected Fire Areas and Zones Fire Area Fire Zones Description A thru G Auxiliary Building (590' - 0" Elevation)
For each of these fire zones, the inspection focused on the fire protection features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of licensee commitments, and changes to the FPP.
.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
Title 10 of the Code of Federal Regulations (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 (SSCs) important to safe shutdown.
The SSCs 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 SSCs 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) can be repaired within 72-hours.
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 area selected for review in accordance with the criteria discussed above. 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 by reviewing procedures, the accessibility of safe shutdown equipment, and the available time for performing the actions.
The inspectors reviewed the PNPs Updated 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. Title 10 CFR Part 50, Appendix R, Section III.G.3, required that, if the guidelines 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.
a. Inspection Scope
For each of the selected fire zones, the inspectors reviewed the licensees Safe Shutdown Analysis (SSA) to ensure that at least one post-fire safe shutdown success path was available in the event of a fire in accordance with the criteria discussed above.
This included a review of manual actions required to achieve and maintain hot shutdown conditions and to make the necessary repairs to reach cold shutdown within 72-hours.
The inspectors also reviewed procedures to determine whether or not 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, construction details, and supporting fire tests for the installed fire barriers. In addition, the inspectors reviewed licensee documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, Fire Hazard Analysis (FHA) reports, SSA, and National Fire Protection Association (NFPA) 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 SSCs 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, were 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-hours.
a. Inspection Scope
The inspectors performed a review of the licensees SSA and Safe Shutdown Equipment List (SSEL) to determine whether the licensee had appropriately identified and analyzed the safety related and non-safety related cables associated with safe shutdown equipment located in the selected plant fire zones in accordance with the criteria discussed above. The inspectors review included the assessment of the licensee's electrical systems and electrical circuit analyses.
The inspectors evaluated a sample of safety and non-safety related cables for equipment in the selected fire zones to determine if the design requirements of Section III.G of Appendix R to 10 CFR Part 50 were being met. This included determining that hot shorts, open circuits, or shorts to ground would not prevent implementation of safe shutdown.
b. Findings
No findings of significance were identified.
.4 Alternative Shutdown Capability
Title 10, Part 50, Appendix R,Section III.G.1, required the licensee to provide fire protection features that were capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Specific design features for ensuring this capability were provided in 10 CFR Part 50, Appendix R, Section III.G.2. Where compliance with the separation criteria of 10 CFR Part 50, Appendix R, Section III.G.2, could not be met, an alternative or dedicated shutdown capability be provided that was independent of the specific fire area under consideration. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72-hours 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 safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions in accordance with the criteria discussed above. 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 Alternate Shutdown Capability
The PNPs FPP described the means by which safe shutdown could be achieved to meet the requirements of 10 CFR Part 50, Appendix R, Sections III.G.3 and III.L. The PNPs safe shutdown analysis identified the minimum number of components and plant systems necessary for achieving Appendix R safe shutdown performance goals.
a. Inspection Scope
The inspectors performed a review of the licensees operating procedures, which augmented the post-fire safe shutdown procedures to determine if the licensee complied with the criteria discussed above. The review focused on ensuring that all required functions for post-fire safe shutdown and the corresponding equipment necessary to perform those functions were included in the procedures. The review also looked at operator training, as well as consistency between the operations shutdown procedures and any associated administrative controls.
b. Findings
Introduction:
The inspectors identified an unresolved item associated with licensee procedures ONP-25.1, Fire Which Threatens Safety-Related Equipment, Revision 15 and ONP-25.2, Alternate Safe Shutdown Procedure, Revision 20. The inspectors were concerned that not all operators utilizing these procedures could perform the necessary operator actions required to meet the time requirements of 10 CFR Part 50, Appendix R, Section III.G.3, for a potential Appendix R fire in any fire area and/or fire zone. The inspectors could not conclude that the licensees operator training adequately accounted for meeting the requirements of a potential Appendix R fire in all fire areas and/or fire zones.
Description:
The inspectors reviewed the licensees procedures ONP-25.1, and ONP-25.2. The inspectors evaluated the two procedures for consistency, adequacy and whether the operators could perform the procedures within the applicable shutdown requirements. Although the procedures were prescriptive for each individual fire area, the procedures were extremely complex (i.e., procedures daisy chained to many other procedures). Based upon this review, the inspectors could not conclude that all operators utilizing these procedures could perform the necessary operator actions (i.e., access the availability of and select the appropriate free of fire damaged equipment within the shutdown time requirements) required to meet the requirements of 10 CFR Part 50, Appendix R, Section III.G.3, for a potential fire in any fire area and/or fire zone.
As a result, the inspectors concluded that additional review was necessary to evaluate the operator training with respect to Appendix R fire scenarios. Therefore, pending a review of the licensees operator training program this issue is an Unresolved Item (URI 05000255/2005003-01(DRS)).
.6 Communications
Title 10, Part 50, Appendix R,Section III.H, required that a portable communications system be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of other plant personnel. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage.
a. Inspection Scope
The inspectors reviewed the adequacy of the communication systems to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties to determine compliance. The inspectors conducted a review to determine that adequate communications were available to support safe shutdown implementation.
b. Findings
No findings of significance were identified.
.7 Emergency Lighting
Title 10, Part 50, Appendix R,Section III.J., required that fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual eight-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire zones.
a. Inspection Scope
The inspectors performed a walkdown of the fire zones and the access/egress routes to determine that adequate emergency lighting existed in accordance with the criteria discussed above.
b. Findings
No findings of significance were identified.
.8 Cold Shutdown Repairs
Title 10, 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-hours.
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, 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 tested configuration in accordance with the criteria discussed above. 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, 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 determine 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.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed the corrective action program procedures and samples of corrective action documents to assess whether or not 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.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Malone and other members of licensee management at the conclusion of the inspection on January 28, 2005. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
No interim exits were conducted.
4OA7 Licensee-Identified Violations
The following violation of very low significance was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Manual, NUREG-1600, for being dispositioned as an NCV.
Cornerstone: Mitigating System
Palisades Operating License (i.e., Amendment 171, Section 2.C.(3)) stated that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR and as approved in the facilitys safety evaluation reports (SERs). In the SER dated September 1, 1978, the NRC provided guidance on the implementation of General Design Criterion 3, Fire Protection, as identified in Appendix A of the Auxiliary Power Conversion and System Branch (APCSB)issuance of Branch Technical Position (BTP) APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants.
In response to the NRCs regulatory position identified in Appendix A, Section D.5, Lighting and Communication, paragraph (d), the licensee stated, in part, that portable radio transmitter receivers are provided and that the radios provide communication throughout the plant. However, as stated in Operator Work Around 03-03OWA, Auxiliary Building Radio Coverage During Transient Response, dated July 2, 2003, radio coverage in the auxiliary building is inadequate and provides an obstacle to safe operation by requiring operators to take compensatory actions during a auxiliary building fire. The licensee initiated CAP034533 and Modification MOD-2005-2, Auxiliary Building Radio Upgrade Existing Operations and Security Radio Systems, to resolve this finding.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- M. Acker, Reliability & Analysis Programs
- G. Arent, Performance Improvement Manager
- G. Baustian, Training Manager
- J. Broschak, Design Engineering Manager
- T. Brown, Nuclear Oversight Manager
- M. Carlson, Engineering Director
- E. Dorbeck, Consumers Energy/Fire Protection Engineer
- B. Dotson, Regulatory Compliance
- T. Fouty, Palisades Program Engineering Manager
- P. Harden, Site Director
- R. Harvill, PSA Support
- B. Heimsath, Operations Procedures Supervisor
- G. Hettel, Plant General Manager
- G. Higgs, Maintenance Manager
- K. Housh, Fire Protection Engineer
- M. Hutting, Acting Vice President Engineering
- D. Malone, Site Vice President
- D. Malone, Regulatory Compliance Supervisor
- B. Rarrick, Nuclear Oversight
- G. Shaffer, Operations
- G. Sleeper, Senior Reactor Operator
- K. Smith, Operations Manager
- T. Swiecicki, Appendix R Engineer
- D. VandeWalle, Operations Support Manager
- B. VanWagner, Reliability & Analysis Programs Supervisor
- R. Womack, Prairie Island Programs Engineering Manager
- K. Yeager, Operations Supervisor
- S. Wawro, Consumers Energy/Asset Manager
- P. Zwissler, Maintenance Technical Support
Nuclear Regulatory Commission
- C. Pederson, DRS Director
- J. Lennartz, Senior Resident Inspector
A1 Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000255/2005003-01 URI Evaluate Adequacy of Operator Training for Meeting Appendix R Requirements for a Potential Fire in All Fire Areas And/Or Fire Zones (Section 1R05.5b )
Closed
None.
Discussed
None.
A2 Attachment