IR 05000315/2006002
| ML060830130 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/22/2006 |
| From: | Julio Lara Engineering Branch 3 |
| To: | Nazar M Indiana Michigan Power Co |
| References | |
| IR-06-002 | |
| Download: ML060830130 (21) | |
Text
rch 22, 2006
SUBJECT:
DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION INSPECTION REPORT 05000315/2006002(DRS); 05000316/2006002(DRS)
Dear Mr. Nazar:
On February 10, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on February 10, 2006, with Mr. D. Fadel 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 2.390 of the NRCs 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 NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Julio F. Lara, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74 Enclosure: Inspection Report 05000315/2006002(DRS); 05000316/2006002(DRS)
w/Attachment: Supplemental Information cc w/encl: J. Jensen, Site Vice President L. Weber, Plant Manager G. White, Michigan Public Service Commission L. Brandon, Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division Emergency Management Division MI Department of State Police D. Lochbaum, Union of Concerned Scientists
SUMMARY OF FINDINGS
IR 05000315/2006002(DRS), 05000316/2006002(DRS); 01/23/06 - 02/10/06; Donald C. Cook
Nuclear Power Plant, Units 1 and 2; Routine Triennial Fire Protection 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 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
Cornerstone: Initiating Events
No findings of significance were identified.
Cornerstone: 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 Donald C. Cook Nuclear Power (CNP)
Plants 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 (FP) 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 CNP Plants Individual Plant Examination for External Events (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire zones chosen for review during this inspection were:
Fire Zones Description
- 18 CD Diesel Generator Room
- 19 AB Diesel Generator Room
- 45 ESS & MCC Room
- 46A EPS Transformer Room
- 46B EPS Control Rod Drive Room
- 46C EPS Motor Control Room (CR)
- 47B 4kV CD Switchgear Room
- 58 CR Cable Vault For each of these fire zones, the inspection focused on the FP features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of license 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 FP 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 FP 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 CR or emergency control station(s) was free of fire damage; and
- systems necessary to achieve and maintain cold shutdown from either the CR or emergency control station(s) could 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 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 FP Safe Shutdown Analysis (SSA).
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 CNP Plants Updated Final Safety Analysis Report (UFSAR)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 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 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 in accordance with 10 CFR Part 50, Appendix R, Section III.G.3.
a. Inspection Scope
For each of the selected fire areas, the inspectors reviewed the licensees Safe Shutdown Capability Analysis (SSCA) and Safe Shutdown Systems Analysis (SSSA) 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-hours. 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 (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 FP 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 FP 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-hours.
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.
The inspectors evaluated selected portions of licensees fuse/breaker coordination analysis for ground faults on the 4160 Volt alternating current (Vac) and 480Vac systems and the vital low-voltage ac and direct current
- (dc) power sources to determine whether fire-induced faults on distribution system cables or buses could degrade post-fire safe shutdown capability. Specifically, the inspectors determined if selective coordination existed between branch circuit protective devices and the upstream distribution panel fuse/breaker feeders to ensure that in the event of a fire-induced short circuit, the fault would be isolated before the upstream feeder fuse/breaker tripped.
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 SSCs important to safe shutdown be provided with FP 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 FP 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-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 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 reviewed a sample of the actions defined in procedure 02-OHP-4025-001-001, Emergency Remote Shutdown, and other procedures which were referenced by procedure 02-OHP-4025-001-001. Procedure 02-OHP-4025-001-001 was the procedure for performing a plant alternative shutdown from outside the CR. The inspectors reviewed the ability of operators to perform procedure actions within applicable plant shutdown time requirements. The inspectors also focused on the feasability of the actions described in the procedure.
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, CR evacuation may be required and a shutdown is performed from outside the CR. Radio communications are relied upon to coordinate the shutdown of both units and for fire fighting and security operations.
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 reviewed the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.
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 8-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 plant walkdown of areas in which a sample of the actions would be performed as described in procedure 02-OHP-4025-001-001, Emergency Remote Shutdown, and other procedures which were referenced by procedure 02-OHP-4025-001-001. 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-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. The inspectors also reviewed completed surveillances of the tools and equipment needed to reach cold shutdown.
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 FP 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 FP 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
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 FP 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 FP system non-conformance documents.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
(Closed) Unresolved Item (URI)05000315/2003005-04; 05000316/2003005-04:
Fire Spread Rating and Thickness Requirements for Epoxy Floor Coating A URI was opened during the 2003 triennial FP inspection regarding the fire spread rating and thickness requirements for the epoxy floor coating used at the plant. The URI was opened pending NRC receipt and review of the licensees evaluation and testing of the epoxy floorings flame spread characteristics. Specifically, the inspectors were concerned that the epoxy floor coating that was applied over the cement flooring in various plant areas may have been a combustible that was not accounted for in the licensees FPP.
During this inspection, the inspectors reviewed the licensees activities associated with the testing and evaluation of the epoxy floor coating. The results of the test reports indicated that the epoxy floor coating was a combustible material. As a result, the licensee conducted additional testing to identify the caloric heat content of the epoxy floor coating. The tests were conducted for several epoxy floor coating thicknesses (i.e., 0.035, 0.115 and 0.250-inches), which represented an application of a primer, second coat and topcoat. Of the three thicknesses, the licensee stated that the 0.115-inch was the most likely thickness used at the plant. The licensee stated that as a conservative measure the 0.250-inch thickness, which represented a caloric heat content value of 7,665 British thermal units per square foot (Btu/sq ft), was selected to assess the fire loading in their fire hazard evaluation. The results of the licensees fire hazard evaluation indicated that the additional combustible loading due to the epoxy floor coating produced no impact on the fire load classifications in the FHA. Therefore, the licensee concluded that there was a negligible increase in hazard due to the epoxy floor coating and that sufficient margin existed for maintaining combustible loading/fire severity within the established allowable limits.
The inspectors reviewed the fire zone classification for those fire zones that contained the epoxy floor coating to verify that the areas did not rely on a 20-foot horizontal separation distance in order to meet Appendix R,Section III.G.2 requirements. All fire zones were classified as meeting the requirements of Appendix R,Section III.G.1 (Fire Zones 15, 16, 17D-G, 18 & 19) or Appendix R,Section III.G.3 (Fire Zones 4, 17A-C, 41, 42A, 42D, 45, 46A, 46D, 55, 60, 83, 88, 95, 100, 110, 111 & 127), except Fire Zone 29G, which was classified as Appendix R,Section III.G.2. Fire Zone 29G had cables wrapped in accordance with Appendix R,Section III.G.2(c), which does not include the requirement for "no intervening combustible or fire hazards" as required for Appendix R,Section III.G.2(b). Therefore, the combustible load represented by the epoxy floor coating did not impact Appendix R,Section III.G.2(c) compliance. The inspectors concluded that the fire zones that contained the epoxy floor coating did not rely on a 20-foot horizontal separation distance in order to meet Appendix R,Section III.G.2 requirements nor could cause a fire to spread from one fire area to another.
The inspectors did not identify any concerns with the licensees corrective actions, or with the licensees resolution of the inspectors issue. Therefore, no performance deficiency or violation was identified and this URI is closed.
4OA6 Meetings
.1 Exit Meeting
On February 10, 2006, at the conclusion of the on-site inspection activities, the inspectors presented the inspection results to Mr. D. Fadel and other members of licensee management. 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.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Fadel, Vice President Engineering
- R. Jervey, Regulatory Affairs
- D. MacDougall, FP Design Engineer
- A. Robertson, Operations Assistant Manager
- R. Crane, Regulatory Affairs
- P. Schoepf, Design Modification Engineer
NRC
- B. Kemker, Senior Resident Inspector
Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Closed
- 05000315/2003005-004; URI Fire Spread Rating and Thickness Requirements for Epoxy
- 05000316/2003005-004 Floor Covering (Section 4OA5)
Discussed
None.
Attachment