IR 05000286/2005006

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IR 05000286-05-006, on 01/10/2005 - 01/28/2005, Entergy Nuclear Northeast, Indian Point 3 Nuclear Power Plant. Fire Protection Team Inspection
ML050660356
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 03/03/2005
From: Rogge J
NRC/RGN-I/DRS/EFPB
To: Dacimo F
Entergy Nuclear Operations
References
IR-05-006
Download: ML050660356 (25)


Text

rch 3, 2005

SUBJECT:

INDIAN POINT 3 NUCLEAR POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000286/2005006

Dear Mr. Dacimo:

On January 28, 2005, the NRC completed a triennial fire protection team inspection at the Indian Point 3 nuclear power plant. The enclosed report documents the inspection findings which were discussed at an exit meeting on January 28, 2005, with Mr. C. Schwarz and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions regulations and with the conditions of your license. The purpose of the inspection was to evaluate your post-fire safe shutdown capability and fire protection program. 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 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be 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/

John F. Rogge, Chief Electrical and Fire Protection Branch Division of Reactor Safety Docket No. 50-286 License No. DPR-64 Enclosure: Inspection Report No. 05000286/2005006

Mr. Fred

SUMMARY OF FINDINGS

IR 05000286/2005006 on 01/10/2005 - 01/28/2005, Entergy Nuclear Northeast, Indian Point 3

Nuclear Power Plant. Fire Protection Team Inspection.

The report covered a two-week triennial fire protection team inspection by specialist inspectors.

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.

NRC-Identified Findings

No findings of significance were identified.

Licensee-Identified Violations

None ii

REPORT DETAILS

Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Entergy Nuclear Northeast has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Indian Point Nuclear Generating Unit 3 (IP3) facility. The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the IP3 Individual Plant Examination (IPE)/ Individual Plant Examination of External Events (IPEEE):

C FA CTL-3, Fire Zone 14 C FA CTL-3, Fire Zone 10 C FA TBL-5, Fire Zone 37A

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems

1R05 Fire Protection

1. Fire Area Boundaries and Barriers

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries, fire doors, and fire dampers. The team reviewed engineering evaluations, as well as surveillance and functional test procedures for selected items. The team also reviewed the licensee submittals and NRC safety evaluation reports (SERs) associated with fire protection features at IP3. Additionally, the team reviewed the design and qualification testing of selected barriers and reviewed surveillance procedures for structural fire barriers and penetration seals. These reviews were performed to ensure that the passive fire barriers were properly maintained and met the licensing and design bases as described in the licensee submittals, NRC SERs, the fire hazards analysis (FHA) and the IP3 Final Safety Analysis Report (FSAR).

b. Findings

No findings of significance were identified.

2. Post-Fire Safe Shutdown Lighting and Communications

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 for post-fire safe shutdown. The team also reviewed preventive maintenance procedures and various documents, including the vendor manuals and completed surveillance tests, to determine if adequate surveillance testing and periodic battery replacements were in place to ensure reliable operation of the eight-hour emergency lights.

The team reviewed radio repeater location, power sources and preventive maintenance procedures to ensure fire department and operator communications could be maintained for fire fighting and post-fire safe shutdown conditions.

b. Findings

No findings of significance were identified.

3. Programmatic Controls

a. Inspection Scope

During tours of the facility, the team observed the material condition of fire protection systems and equipment, the storage of permanent and transient combustible materials, and control of ignition sources. The team also reviewed the procedures that controlled hot-work activities and combustibles at the site. Additionally, the team reviewed a sample of hot work permits and transient combustible evaluations. These reviews were accomplished to ensure that Entergy Nuclear Northeast was maintaining the fire protection systems, controlling hot-work activities, and controlling combustible materials in accordance with the FSAR, administrative procedures and other fire protection program procedures.

b. Findings

No findings of significance were identified.

4. Fire Detection Systems and Equipment

a. Inspection Scope

The team reviewed the adequacy of the fire detection systems in the selected plant fire areas. This included a walkdown of the systems and review of the type of installed detectors as shown on location drawings. The team also reviewed licensee submittals and the NRC SERs associated with the selected fire areas. These reviews were performed to ensure that the fire detection systems for the selected fire areas were installed in accordance with the design and licensing bases of the plant. Additionally, the team reviewed fire detection surveillance procedures to determine the adequacy of the fire detection component testing and to ensure that the detection system would function as required.

b. Findings

No findings of significance were identified.

5. Fixed Fire Suppression Systems

a. Inspection Scope

Carbon Dioxide and Sprinkler Systems The team reviewed the adequacy of the FA CTL-3, Fire Zone 14 and the FA CTL-3, FZ 10 automatic low pressure total flooding carbon dioxide (CO2) systems by performing walkdowns of the systems and the fire area envelopes. The team also reviewed the design and installation to ensure it was in accordance with NFPA 12, Standard on Carbon Dioxide Extinguishing Systems. Initial discharge tests that verified the adequacy of CO2 concentration and hold times were reviewed. Completed surveillance procedures were also reviewed to ensure periodic testing of the systems was being accomplished. These reviews were performed to ensure that the low pressure total flooding CO2 systems met the design and licensing bases as described in the licensee submittals, NRC SERs, the FHA and the FSAR and that the system could perform its intended function in the event of a fire in these areas.

The team reviewed the adequacy of the 31 EDG room automatic wet pipe sprinkler system by performing walkdowns of the system. The team also reviewed the design and installation to ensure it was in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems. Completed surveillance procedures were also reviewed to ensure appropriate periodic testing of the system was being accomplished.

These reviews were performed to ensure that the sprinkler system met the design and licensing bases as described in the licensee submittals, NRC SERs and the FSAR and that the systems could perform their intended function in the event of a fire in these areas.

b. Findings

No findings of significance were identified.

6. Manual Fire Suppression Capability

a. Inspection Scope

The team walked down selected standpipe systems and observed portable extinguishers to determine the material condition of the manual fire fighting equipment and verify locations as specified in the pre-fire plans and fire protection program documents. The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements. The team inspected the fire brigades protective ensembles, self-contained breathing apparatus (SCBA), and various fire brigade equipment to determine operational readiness for fire fighting.

The team reviewed pre-fire plans and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown.

The team performed in-plant walk downs to evaluate the physical configuration of electrical raceway and safe shutdown components in the selected fire areas to determine whether water from an inadvertent fire suppression system pipe rupture or from manual fire suppression activities in the selected areas could cause damage that could inhibit the ability to safely shutdown the plant.

The team reviewed fire brigade initial training and continuing training course materials to verify appropriate training was being conducted for the station fire fighting personnel.

Additionally, the team reviewed selected fire drills and critiques to ensure that drills were being conducted in risk significant areas.

The team reviewed the qualifications of several fire brigade leaders and members to ensure that they had met and maintained the requirements to be fire brigade leaders and members.

b. Findings

No findings of significance were identified.

7. Safe Shutdown Capability

a. Inspection Scope

The team reviewed IP3's Fire Hazards Analysis (FHA), Safe Shutdown Analysis, and FSAR to determine the methods and equipment that Entergy Nuclear Northeast used to achieve safe shutdown following postulated fires. The team assessed the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions. In addition, the team evaluated IP3's fire response procedures, alarm response procedures and operating procedures for the selected fire areas to assess the adequacy of methods and equipment used to achieve safe shutdown following a fire. The team's review included piping and instrumentation drawings (P&IDs) for post-fire safe shutdown systems to identify required components for establishing flow paths, to identify equipment required to isolate flow diversion paths, and to verify whether appropriate components were included in the alternate safe shutdown equipment list. The team performed field walkdowns to evaluate whether alternate safe shutdown equipment was adequately protected from the effects of fires.

The team evaluated selected safe shutdown components and their power and control circuits to verify that proper isolation and alternate power sources were provided for those components necessary for alternate shutdown in the event of a fire affecting the 480 Volt switchgear room. In addition, the team reviewed selected alternate shutdown equipment surveillance tests to verify periodic testing was adequate to demonstrate component operability and that the tests satisfied the applicable surveillance requirements.

Post-fire safe shutdown procedures were evaluated to determine if appropriate information was provided to plant operators to identify protected equipment and instrumentation and whether recovery actions specified in post-fire shutdown procedures considered manpower needs for performing required actions. The team also reviewed training lesson plans and job performance measures for shutdown actions, discussed training with licensed operators, reviewed the adequacy of shift manning, and evaluated the accessibility of the safe shutdown operating stations and required manual action locations.

Specific procedures reviewed for safe shutdown included:

C 3-AOP-SSD-1, Rev. 3, "Control Room Inaccessibility Safe Shutdown Control" C 3-SOP-ESP-001, Rev. 12, Local Operation of Safe Shutdown Equipment C SOP-EL-012, Rev. 17, Operation of the Alternate Safe Shutdown Equipment C SOP-EL-013, Rev. 20, "Appendix R Diesel Generator Operation" The team performed a walkdown of procedures for an evacuation and plant shutdown from outside the main control room. The walkdown was performed by an operations crew and focused primarily on the portion of the procedure associated with achieving stable hot shutdown conditions. Plant operators were accompanied by NRC team members during the walkdown and the approximate time for completing critical steps, such as establishing makeup flow to the reactor vessel, aligning the appendix R diesel generator to supply electrical power to safe shutdown loads and establishing seal injection for reactor coolant pump (RCP) seal cooling were noted and evaluated to assess the ability of the operators to maintain plant parameters within procedural limits.

b. Findings

No findings of significance were identified.

8. Safe Shutdown Circuits

a. Inspection Scope

The team reviewed cable routing for post-fire safe shutdown components to confirm that cables subject to fire damage in the selected fire areas were identified and adequately addressed. The team also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.

Cable failure modes were reviewed for the following components:

(1) valves PCV-455C and PCV-456 (PORVs),
(2) head vent valves RCS-SOV-653, 653, 654 and 655, and
(3) RHR isolation valves MOV-730 and 731.

The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted by improper coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance procedures and testing records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.

The team reviewed the electrical isolation capability of selected equipment needed for post-fire safe shutdown to ensure that such equipment could be operated locally or from the alternate shutdown panels, if needed. The team also reviewed surveillance test procedures and test records for the alternate shutdown control transfer switches and alternate power supplies, to ensure that functionality of the transfer switches and alternate power sources were adequately demonstrated.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

1. Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team reviewed the open corrective maintenance work orders for fire protection and safe shutdown equipment, selected condition reports (CRs) for fire protection and safe shutdown issues and recent fire protection system health reports to evaluate the prioritization of deficiencies and the effectiveness of corrective actions. The team also reviewed recent Quality Assurance (QA) Audits of the fire protection program to determine if Entergy Nuclear Northeast was identifying program deficiencies and implementing appropriate corrective actions.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented their preliminary inspection results to Mr. C. Schwarz, Plant Manager, and other members of the IP3 staff at an exit meeting on January 28, 2005.

No proprietary information was included in this inspection report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Bencivegna, Mechanical Design Manager
F. Dacimo, Site Vice President
P. Coleman, Consultant (EPM)
P. Conroy, Licensing Manager
J. Comiotes, Director Nuclear Safety Assurance
G. Dahl, Licensing
K. Elliot, Fire Protection Engineer
C. Embry, Operations
T. Jones, Licensing
D. Leach, Director Engineering
T. Orlando, PCE Manager
S. Petrosi, Design System Manager
J. Pineda, Supervisor, Control Supervisor
R. Schimp, Engineer, Communications
C. Schwarz, General Manager - Plant Operations
S. VanBuren, Fire Chief
G. Vranjesevic, Electrical Engineer
S. Wilkie, Supervisor, Fire Protection

NRC

J. Rogge, Chief, Electrical and Fire Protection Branch, Division of Reactor Safety
T. Hipschman, Senior Resident Inspector, Indian Point Generating Unit 3
R. Berryman, Resident Inspector, Indian Point Generating Unit 3

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE Open and

Closed

NONE

Closed

NONE

Discussed

NONE

LIST OF DOCUMENTS REVIEWED