IR 05000293/2012008
| ML12349A069 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/14/2012 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Rich Smith Entergy Nuclear Operations |
| References | |
| IR-12-008 | |
| Download: ML12349A069 (23) | |
Text
November 8, 2012
SUBJECT:
PILGRIM NUCLEAR POWER STATION - NRC TRIENNIAL FIRE PROTECTION I NSPECTION REPORT 05000293/201 2008
Dear Mr. Smith:
On November 8, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Pilgrim Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on November 8,2012, with yourself and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
Based on the results of this inspection, no findings were identified.
ln accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RN John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-293 License No, DPR-35 DOCUMENT NAME: G:\\DRS\\Engineering Branch 3\\Fuhrmeister\\Pilgrim 12-08.docx ADAMS ACCESSION NUMBER: M112349A069 V
suNstReview V
Non-Sensitive n
Sensitive V!
Publicly Available Non-Publicly Available OFFICE RI/DRS RI/DRS RI/DRS NAME RFuhrmesiter CCahill JRogge DATE 12112112 12112112 12t14t12 RECORD OFFICIAL
R. Smith
Enclosure:
lnspection Report No. 0500029312012008 w/Attachment: Supplemental Information
REGION I==
DPR-35 05000293/2012008 Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Rocky Hill Road, Plymouth, Massachusetts October 22 - November 8,2012 R. Fuhrmeister, Sr. Reactor Inspector, Division of Reactor Safety (DRS)
(Team Leader)
L. Scholl, Sr. Reactor Inspector, DRS J. Rady, Reactor lnspector, DRS C. Cahill, Sr. Risk Analyst, DRS John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
lR 05000293t2012008i 1012212012 - 1110812012; Entergy Nuclear Operations; Pilgrim Nuclear
Power Station; Triennial Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Mitigating Systems No findings were identified.
Other Findings
None
REPORT DETAILS
Backqround This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (lP) 711 11.05T, "Fire Protection." The objective of the inspection was to assess whether Entergy Nuclear Operations (Entergy) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Pilgrim Nuclear Power Station (Pilgrim).
The following fire areas (FAs) and fire zones (FZs)were selected for detailed review based on risk insights from the Pilgrim lndividual Plant Examination of External Events (IPEEE):
. FA 1.1Q,F22.6;
. FA 1.9, F22.2; and,
.
FA 4.3, FZ 4.3.
Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated Entergy's fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Conditions 3.F and 3.K, NRC Safety Evaluations, 1O CFR 50.48, and 10 CFR 50, Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR),
Section 10.8, the fire hazards analysis (FHA), and the post-fire safe shutdown analysis.
The team also evaluated 8 licensee mitigating strategies for addressing large fires and explosions as required by Operating License Condition 3.K. Inspection of these strategies fulfils the inspection procedure requirement to inspect a minimum of one sample.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
==1R05 Fire Protection (lP 7111 1.05T)
==
.01 Protection of Safe Shutdown Capabilities
a.
lnspection Scope The team reviewed the FHA, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that applicable separation requirements of Section lll.G of 10 CFR 50, Appendix R and the licensee's design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control and b.
.02 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.
Findinqs No findings were identified.
Passive Fire Protection Inspection Scope The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, ceilings, floors, fire doors and fire dampers), and electrical raeeway fire barriers to ensure they were appropriate for the fire hazards in the area.
The team reviewed installation lrepair and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design. The team also reviewed completed surveillance and maintenance procedures for selected passive fire protection features to verify that maintenance and inspection activities are adequate.
Findinqq No findings were identified.
Active Fire Protection lnsoection Scope The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA) code of record, or as NRC approved exemptions, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems were verified to be adequate for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.9. fire pumps, carbon dioxide storage tanks and supply system) to assess the material condition and the operational lineup and availability of the systems and components.
The team reviewed electric and dieselfire 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' Encrosure a.
b.
a.
.03 b.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also compared pre-fire plans for the selected fire areas with as-built plant conditions and fire response procedures to verify fire-fighting pre-fire plans are consistent with the fire protection features and potentialfire conditions described in the FPP. In addition, the team inspected the fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.
Findinqs No findings were identified.
Protection From Damaqe From Fire Suppression Activities Inspection Scope The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
. A fire in one of the selected fire areas would not indirectly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains; r 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, e Adequate drainage is provided in areas protected by water suppression systems.
Findinqs No findings were identified.
Shutdown Capabilitv - Normal and Alternative Inspection Scope The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&lDs), electrical drawings, the UFSAR 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 safe shutdown 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 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
,04
.05 b.
a.
b.
a.
.06 that described in the safe shutdown and fire hazards analyses. The team verified that
the systems and components credited for use during this shutdown method would remain free from fire damage.
The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits.
Specific procedures reviewed for normal and alternative post-fire shutdown included the following:
. 2.4.143, Shutdown From Outside the Control Room, Rev' 49
. 2.4.143.1, Shutdown With A Fire in Reactor Building East (Fire Area 1.9), Rev. 21
. 2.4.143.2, Shutdown With A Fire in Reactor Building West (Fire Area 1.10), Rev. 21 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area, The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
Findinqs No findings were identified.
Circuit Analvsis Inspection Scooe The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The team's 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 cable routing databases for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the safe-shutdown analysis. The team also reviewed equipment important to safe shutdown, 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, Rev. 2.
Cable failure modes were reviewed for the following components:
o MO-1001-438 r MO-4010A
. P-203B o Ll-263-59A
. Pl-263-604 RHR Pump P-203B Suction Valve; RBCCW lsolation Valve to RHR Heat Exchanger E-207B; RHR Pump; Reactor Water Level Indicator; and, Reactor Pressure Indicator.
b.
.07 The team reviewed a sample of circuit breaker coordination studies to ensure equipment
needed to conduct pos!fire safe shutdown 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 locations would not be affected by fire-induced circuit faults (e.9., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Findinqs No findings were identified.
Communications Inspection Scope The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.
.08.09
b.
a.
b.
a.
b.
.10 a.
Findinqs No findings were identified.
Emerqencv Liqhtino Inspection Scope The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained consistent with the manufacturer's recommendations and in a manner that would ensure reliable operation.
Findinos No findings were identified.
Cold Shutdown Reoairs lnspection Scope The team verified that the licensee had dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools, and materials (e.9., pre-cut cables with prepared attachment lugs) were available and accessible on site.
Findinqs No findings were identified.
Compensatorv Measures lnspection Scope The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action
.12 could be taken and that the licensee was effective in returning the equipment to service
in a reasonable period of time.
The team reviewed compensatory measures in the form of manual actions for 10 CFR Part 50, Appendix R, Section lll.G.2 areas to verify that there is reasonable assurance that manual actions can be accomplished. Specific attributes reviewed include diagnostic instrumentation, environmental consideration, staffing, communications, equipment availability, training, procedures, and verification and validation.
Findinqs No findings were identified.
Fire Protection Prooram Chanqes lnspection Scope The team reviewed recent changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown.
Findinqs No findings were identified.
Control of Transient Combustibles and lonition Sources Inspection Scope The team reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
Findinqs No findings were identified.
Larqe Fires and Explosions Mitiqation Strateqies Inspection Scope The team reviewed the licensee's preparedness to handle large fires or explosions by reviewing eight licensee mitigating strategies to verify they continue to meet 10 CFR 50.54(hhX2) by determining that:
.13 4.
4c42
.01 a.
.02. Procedures are being maintained and adequate;
. Equipment is properly staged and is being maintained and tested; and,
. Station personnel are knowledgeable and can implement the procedures.
Findinqs No findings were identified.
oTHER ACTTVTTIES IOAI ldentification and Resolution of Problems Corrective Actions for Fire Protection Deficiencies Inspection Scope The team verified that the licensee was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program. The team also reviewed a sample of selected issues to verify that the licensee had taken or planned appropriate corrective actions.
Findinqs No findings were identified.
Multiple Spurious Operations Evaluations Inspection Scope The team reviewed condition reports, a General Electric report of safety-relief valve testing, Entergy engineering evaluations, and a contractor report related to multiple spurious actuations to determine whether the current NRC guidance for resolving circuit analysis issues had been met.
Observations and Findinos The Office of Nuclear Reactor Regulation (NRR) issued new guidance for power reactor licensees in Revision 2 to Regulatory Guide 1
.189, "Fire Protection For Nuclear Power
Plants," regarding the disposition of circuit analysis issues. The new guidance was based on the results of cable fire tests performed during 2001. Those fire tests significantly increased the knowledge available to the industry and the NRC with respect to fire-induced circuit failures and their potential to cause multiple spurious actuations that could affect shutdown after a fire. The enforcement discretion for circuit related findings provided in Enforcement Guidance Memorandum (EGM) 09-002, "Enforcement Guidance Memorandum - Enforcement Discretion for Fire Induced Circuit Faults,"
ended six months after issuance of the revised regulatory guide. Licensees were to a.
b.
I complete corrective actions within three years after issuance of the revised regulatory guide (November 2, 2012).
On April 30, 2010, Entergy issued CR-PNP-2010-01557 to document that an expert panel determined that Pilgrim could be susceptible to some of the generic multiple spurious operation (MSO) scenarios identified in NEI 00-01, "Guidance for Post-Fire Safe-Shutdown Circuit Analysis," Rev. 2. The condition report identified the specific scenarios which required resolution. Entergy undertook detailed analyses of control and power circuits for the identified scenarios, and initiated compensatory measures, including fire watch tours for the associated fire zones. Entergy received a report from their contractor on October 16,2012, which identified several MSO scenarios which required additional engineering evaluations to resolve potential MSO scenarios.
Entergy issued CR-PNP-2012-04915 to document that the corrective actions for potential MSO scenarios had not been completed by the November 2,2012 deadline.
Entergy verified that a train of equipment necessary to achieve and maintain safe shutdown had been protected for each of the fire areas involved, and continued work to achieve resolution of the potential MSO scenarios.
The team independently confirmed that a protected train of post-fire safe shutdown equipment existed for each fire area, and that no violation of the requirements of Appendix R to Title 10 of the Code of Federal Regulations, Part 50 had occurred.
4OAO Meetinqs, includinq Exit Exit Meetinq Summarv The team presented their preliminary inspection results to Mr. Robert G. Smith, Site Vice President, and other members of the site staff at an exit meeting on November 8,2012' No proprietary information was included in this inspection report' ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Smith, Site Vice President
- J. Dent, Plant Manager
- V. Fallacara, Director of Engineering
- D. Noyes, Operations Manager
- T. White, Design Engineering Manager
- B. Chenard, Engineering Systems Manager
- K. Kee, Engineering Programs and Components Manager
- J. Lynch, Licensing Manager
- J. Edelhauser, Electrical Design Supervisor
- F. Clifford, Senior Reactor Operator
- M. Landry, Fire Protection System Engineer
- D. Berkland, Electrical Design Engineer
- F. McGinnis, Senior Licensing Engineer
- R. Byrne, Senior Licensing Engineer
- S. Burke, Fire Protection Engineer
- C. McMurrow, Senior Operations lnstructor
- R. German, Reactor Operator
NRg
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- M. Schneider, Senior Resident Inspector, Pilgrim Nuclear Power Station
- B. Smith, Resident Inspector, Pilgrim Nuclear Power Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE
Opened and Closed
NONE
Closed
NONE
Discussed
NONE