IR 05000324/2008009
| ML083540643 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/18/2008 |
| From: | Nease R NRC/RGN-II/DRS/EB2 |
| To: | Waldrep B Carolina Power & Light Co |
| References | |
| IR-08-009 | |
| Download: ML083540643 (26) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 18, 2008
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000325/2008009 AND 05000324/2008009
Dear Mr. Waldrep:
On November 21, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Brunswick Unit 1 and 2 facilities. The enclosed inspection report documents the inspection results, which were discussed on that date, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and 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 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 NRC's 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/
Rebecca L. Nease, Chief Engineering Branch 2 Division of Reactor Safety Docket No.: 50-325, 50-324 License No.: DPR-71, DPR-62
Enclosure:
(See page 2)
CP&L 2 Enclosure: Triennial Fire Protection Inspection Report 05000325/2008009 and 05000324/2008009 w/Attachment: Supplemental Information
REGION II==
Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62 Report Nos.: 05000325/2008009 and 05000324/2008009 Licensee: Carolina Power and Light (CP&L)
Facility: Brunswick Steam Electric Plant, Units 1 & 2 Location: 8470 River Road SE Southport, NC 28461 Dates: November 3 - 7, 2008 (Week 1)
November 17 - 21, 2008 (Week 2)
Inspectors: P. Fillion, Senior Reactor Inspector (Lead Inspector)
C. Even, Reactor Inspector R. Fanner, Reactor Inspector N. Staples, Reactor Inspector G. Wiseman, Senior Reactor Inspector Accompanying J. Dymek, General Engineer Personnel: K. Miller, Reactor Inspector Approved by: Rebecca Nease, Chief Engineering Branch 2 Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000325/2008009, 05000324/2008009; 11/03 - 07/2008 and 11/17 - 21/2008; Brunswick
Steam Electric Plant, Units 1 & 2; Triennial Fire Protection Inspection.
This report covers an announced two-week triennial fire protection inspection by a team of five regional inspectors. No findings of significance were identified. 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.
NRC-Identified and Self-Revealing Findings
None
Licensee Identified Violations
None
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R05 Fire Protection
This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial), dated May 9, 2006. The objective of the inspection was to review the Brunswick Steam Electric Plant Units 1 and 2 fire protection program (FPP). The team selected three fire areas (FAs) for detailed review to examine the licensees implementation of the FPP. The three FAs chosen for review were selected based on available risk information as analyzed onsite by a Senior Reactor Analyst from Region II, data obtained in plant walkdowns regarding potential ignition sources, location and characteristics of combustibles and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. Other considerations for selecting the FAs were the relative complexity of the post-fire SSD procedure, information contained in FPP documents, and results of prior NRC triennial fire protection inspections. Section 71111.05-05 of the IP specifies a minimum sample size of three FAs. Detailed inspection of these three FAs fulfills the procedure completion criteria. The three areas chosen were:
Unit 1 cable spreading/switchgear room, identified as Fire Zone CB-05.
Alternate shutdown type compliance (III.G.3) applies to this fire zone.
Battery room 2B, identified as Fire Area CB-10. This room contains a 250 V battery, a 48 V battery, motor control centers, battery chargers, inverters, a small motor generator set and a number of cable trays.
Shutdown would be controlled from the main control room.
Service water pump house, identified as Fire Area SW-1. Shutdown would be controlled from the main control room.
The team evaluated the licensee=s FPP against applicable requirements, including Brunswick Steam Electric Plant (BSEP) Units 1 and 2 Updated Facility Operating License Condition 2.B.(6) and documents referenced therein; Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix R; 10 CFR 50.48; commitments to Appendix A of Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1, AGuidelines for Fire Protection for Nuclear Power Plants@; related NRC safety evaluation reports (SERs); and plant Technical Specifications. The team reviewed related FPP requirements, as described in the Updated Final Safety Analysis Report (UFSAR), Section 9.5.1, Fire Protection System, Section 9.5.2, Communication System, and 9.5.3, Lighting Systems. The team reviewed the Safe Shutdown Analysis (SSA) Report, the licensee=s Fire Protection Program Manual and their Fire Protection Commitment Document. The team evaluated all areas of this inspection, as documented below, against these requirements. Specific licensing basis documents reviewed are listed in the Attachment.
.01 SSA and Protection of SSD Capabilities
a. Inspection Scope
The team reviewed that portion of the SSA which listed the credited and fire-affected equipment for the three FAs selected. This review included an evaluation of the completeness and depth of the SSA in terms of the capacity and capability to achieve and maintain hot shutdown and transition to cold shutdown. The list of credited equipment in the SSA was compared to the SSD procedures. The team reviewed the circuit analysis portion of the SSA to ascertain the special post-fire operator actions specified by the analysis as resolution to potential fire-induced cable damage. It was then checked whether the SSD procedures included these actions. Conversely, a comparison of the SSA and the SSD procedure was made to check that equipment specified in the procedure had been addressed in the analysis. In addition, the accuracy of the SSA with regard to pinpointing the location of cables throughout the plant was inspected. This was done through in-plant inspection of the location of a random sample of about 80 raceways which in turn was compared to the location given in the analysis.
Through a combination of licensing basis information review and in-plant inspection, the team ascertained whether the plant layout and the fire prevention and protection features in place to protect the SSD capability satisfy the requirements of 10 CFR 50, Appendix R, Section III.G.
b. Findings
No findings of significance were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team inspected the material condition and as-built configuration of accessible passive fire barriers surrounding and within the FAs selected for review to evaluate the adequacy of the fire resistance in accordance with the requirements of 10 CFR 50, Appendix R, Section III.G, and Appendix A of BTP APCSB 9.5-1. Fire barriers in use included block walls, poured walls, ceilings, floors, mechanical and electrical penetration seals, doors, dampers and electrical raceway fire barrier systems (ERFBS). The as-built configuration of these fire barriers was compared to their tested or approved configuration. For example fire doors were examined for attributes such as material condition, tightness, proper operation, Underwriters Laboratories (UL) label on door, frame, and latch, method of attachment to the wall, etc. Construction detail drawings were reviewed as necessary. Other types of fire barriers were inspected in a similar detail. Fire endurance test data were reviewed as necessary to verify the qualified fire resistance ratings of the selected fire barriers and ERFBS. In cases where the qualification of a fire barrier depended on engineering evaluations by the licensee in lieu of testing, the team requested the licensee to provide those evaluations for review. The teams review of fire barriers included evaluation of fire proofing applied to structural steel. Fire model calculations were generated by the team as appropriate using NRC recommended computer codes to evaluate the selected barriers effectiveness to contain potential fires. The overall criterion applied to this element of the inspection procedure was that the passive fire barriers had the capability to contain fires for one hour or three hours as applicable. The passive fire protection features included in the review are listed in the Attachment.
b. Findings
No findings of significance were identified.
.03 Active Fire Suppression
a. Inspection Scope
The teams review of active fire suppression included the fire detection systems, fire protection water supply system, automatic fire suppression systems and manual fire fighting fire hose and standpipe systems. The inspection of fire detection systems included a review and walk-down of the as-built configuration of the systems as compared to the applicable National Fire Protection Association (NFPA) standard. The testing and maintenance program and its implementation for the fire detection system were reviewed. The team reviewed and walked-down operational aspects of the fire detection system such as location of panels and alarms to determine the capability to rapidly pinpoint the location of any detected fires. At the time of the inspection the licensee was in the process of implementing a plant modification to replace the existing fire detection system(s) with a new addressable fire alarm network. An air sampling type incipient fire detection system is to be provided in both cable spreading rooms and cable access ways. This modification had already been partially completed for the three focus fire areas. The team reviewed Engineering Change EC-50724, Fire Detection System, and Engineering Change EC-51305, Progress Energy Specification for Fire Detection System.
The team inspected the material condition, operational lineup (i.e. position of valves),design and testing of the sprinkler systems in the cable spreading/switchgear room (Fire Zone CB-05) and service water pump house (Fire Area SW-1). Battery room 2B (Fire Area CB-10) did not have a fixed fire suppression system. Hydraulic calculations which demonstrated the fire pumps and piping had the capacity and capability to deliver proper flow and pressure were reviewed. The most recent flow and pressure test data were also reviewed. The locations of sprinkler heads were observed to check for obstructions.
The redundancy of fire protection water sources and fire pumps to fulfill their fire protection function to provide adequate flow and pressure to hose stations and automatic suppression systems were reviewed as compared to licensing basis requirements.
All aspects of fire brigade readiness were reviewed, including but not limited to, personal protective and smoke control equipment availability and condition, training, fire drills, daily staffing levels of fire brigade personnel, hose station locations, hose lengths, nozzle types, pre-fire planning, emergency lighting, fitness for fire fighting duty of brigade members. In general, the acceptance criteria applied to active fire suppression systems were contained in applicable codes and standards listed in the Attachment as modified by the design basis documents.
b. Findings
No findings of significance were identified.
.04 Protection from Damage from Fire Suppression Activities
a. Inspection Scope
The team evaluated whether the automatic fixed sprinkler systems or manual fire fighting activities could adversely affect the credited SSD equipment, inhibit access to alternate shutdown equipment, and/or adversely affect the local operator actions required for SSD in the selected fire areas. With regard to the fixed automatic sprinkler system in the cable spreading/switchgear room (Fire Zone CB-05), the team considered consequences of a pipe break and inadvertent system actuation. In the service water pump house (Fire Area SW-1), which contained all the service water cooling pumps and their ancillary equipment, the impact of sprinkler system actuation on equipment was evaluated. The team also checked that sprinkler system water would either be contained in the fire affected area or be safely drained off. In cases where the licensees analysis of these concerns took credit for drains, the team evaluated the adequacy and condition of floor drains and sumps and ascertained whether the drains were maintained open through periodic cleaning and inspections.
The team also addressed the possibility that a fire in one FA could lead to activation of an automatic suppression system in another FA through the migration of smoke or hot gases, and thereby adversely affect SDD. The team reviewed air flow paths out of the selected FAs to verify that inter-area migration of smoke or hot gases would not inhibit necessary operator actions. This portion of the inspection was carried out through a combination of walk-downs, drawing review, and records review.
b. Findings
No findings of significance were identified.
.05 Operational Implementation for Shutdown from the Main Control Room and Alternate
Shutdown
a. Inspection Scope
The team inspected the operational implementation of post-fire SSD for each of the three selected FAs. Walkthroughs of the shutdown procedures were performed (refer to the for a list of the procedures). Acceptance criteria applied to local operator actions specified in the shutdown procedures were contained in IP 71111.05TTP,
2.
b. Findings
No findings of significance were identified.
.06 Circuit Analysis
a. Inspection Scope
For each of the three selected FAs, the team reviewed selected SSD components (refer to the Attachment for a list), which the licensee credited for post-fire SSD. The team reviewed routing information for credited components to determine if a fire in the chosen areas would impact them. If there was a potential for components to be impacted by fire, the team performed additional analysis and reviewed licensee credited resolutions.
The individual circuit analysis review consisted of identifying the impacted cable, determining the purpose of the impacted cable, and verifying the licensee action to resolve the condition.
The control circuits for the service water pumps were reviewed to ascertain the permissives and interlocks needed for proper pump operation, how they could be affected by fire-induced cable damage, and whether the post-fire shutdown procedure for manual starting of the service water pumps ensured the equivalent start sequence. Also, a review was made of the overcurrent protection relays at the circuit breakers controlling the service water pump motors and at the bus incoming breaker to check that fire induced short-circuits would not lead to de-energization of the credited service water pump. The circuitry associated with the electric motor-driven fire pump and the diesel engine-driven fire pump remote control and automatic functions was reviewed to check that it implemented the desired start logic and would not be vulnerable to fire damage.
The team reviewed a sample of circuit diagrams to check that transfer/isolation switches needed for alternate shutdown were provided with contacts at appropriate points in the circuits.
This portion of the inspection was carried out through document review supplemented by in-plant inspection as deemed appropriate.
b. Findings
No findings of significance were identified.
.07 Communications
a. Inspection Scope
The team inspected the plant communications systems that would be relied upon to support safe shutdown, fire event notification, and fire brigade fire fighting activities.
Attributes of the plant communications systems important to post-fire safe shutdown were addressed by the team, such as availability at designated locations, reliability ensured through periodic testing, batteries maintained sufficiently charged, good reception in all required areas of the plant, vulnerability to fire damage etc. Statements made by operations personnel during the inspection as to which communication system they would use were compared to statements in the UFSAR concerning communications for post-fire SSD. The team also reviewed selected fire brigade drill evaluation/critique reports to assess proper operation and effectiveness of the fire brigade command post portable radio communications during fire drills and identify any history of operational or performance problems with radio communications during fire drills. Communications were inspected through a combination of in-plant observations, drawing and records review, and interviews.
b. Findings
No findings of significance were identified.
.08 Emergency Lighting
a. Inspection Scope
The team inspected the placement and aiming of emergency lighting units (ELUs)installed to provide illumination for operators carrying out the SSD procedures for the three selected FAs. The team reviewed the design, maintenance and testing of ELUs throughout the plant to confirm they would illuminate for an 8-hour period following interruption of normal power to the battery chargers. Copies of data sheets from recent past surveillance tests on the ELUs were reviewed. Refer to the Attachment to this report for procedure titles and dates of completion. In cases where an ELU failed the surveillance test, the team followed up to confirm the corrective action and programmatic treatment.
The team observed whether emergency exit lighting was provided for personnel evacuation pathways to the outside as identified in NFPA 101, Life Safety Code, and the Occupational Safety and Health Administration (OSHA) 29 CFR 1910, Occupational Safety and Health Standards. This review also included examination of whether backup ELUs were provided for the primary and secondary fire emergency equipment storage locker locations and dress-out areas in support of fire brigade operations should power fail during a fire emergency.
b. Findings
No findings of significance were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The SSA did not identify any needed repairs necessary to achieve cold shutdown following postulated fires, and this aspect of the analysis was reviewed by the team.
b. Findings
No findings of significance were identified.
10. Compensatory Measures
a. Inspection Scope
The team reviewed the administrative controls for out-of-service, degraded, and/or inoperable, fire protection features (e.g., detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing post-fire safe shutdown functions or capabilities). A sample of completed fire watch logs and records of recent and active fire protection features impairments were compared to the programmatic requirements, including the licensees evaluation for having Unit 1 1A uninterruptible power supply in the bypass mode.
b. Findings
No findings of significance were identified.
11.
Control of Combustibles and Ignition Sources
a. Inspection Scope
For the selected FAs, the team evaluated the fire event history, the potential for fires or explosions, the combustible fire load characteristics, and the potential exposure fire severity. The team reviewed the licensee=s transient fire load calculations; selected fire emergency reports; generic plant access fire protection training; and selected portions of the FPP administrative procedures to determine if adequate controls were in place to control the handling of in-situ and transient combustibles in the plant. The team walked down numerous areas in the plant, including the selected plant FAs, to ensure that the licensee had properly evaluated in-situ combustible fire loads, limited transient fire hazards, and maintained general housekeeping consistent with the UFSAR, administrative procedures, and other FPP procedures. Hot work conforming to programmatic requirements in one of the selected areas was observed and discussed with the workers and the fire watch assigned to the activity.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The team reviewed recent independent licensee audits for thoroughness, completeness and conformance to requirements. Requirements for the independent audits are contained in Regulatory Guide 1.189, Fire Protection for Operating Nuclear Power Plants, Generic Letter 82-21, Technical Specifications for Fire Protection Audits, and the licensees Nuclear Quality Assurance Plan. Audits of the fire protection program reviewed were: B-FP-04-01, dated September 28, 2004, B-FP-06-01, dated September 11, 2006, and B-FP-08-01, dated August 13, 2008. In addition, a self assessment of the fire protection program was reviewed (Self-Assessment Report No. 178623-08, conducted August 2008).
The team also reviewed corrective action program documents, including completed corrective actions documented in selected Action Requests (ARs) and operating experience program documents, to ascertain whether industry-identified fire protection problems actually or potentially affecting Brunswick were appropriately entered into, and resolved by, the corrective action program process. Items included in the operating experience program effectiveness review were NRC Information Notices, industry or vendor-generated reports of defects and non-compliances submitted pursuant to 10 CFR 21, and vendor information letters. The team evaluated the effectiveness of the corrective actions for the identified issues. The documents reviewed are listed in the
.
b. Findings
The scope and frequency of the audits was consistent with the requirements and at least one member of each audit team was qualified to member grade status in the Society of Fire Protection Engineers. The self assessment appeared to be an effective review as it identified problems and initiated corrective action.
4OA6 Meetings, Including Exit
On November 21, 2008, the lead inspector presented the inspection results to Mr. B.
Waldrep, Vice President, Brunswick Steam Electric Plant, and other members of the licensees staff. The licensee acknowledged the results. Proprietary information is not included in this report.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- G. Atkinson, Supervisor Licensing/Regulatory Programs
- S. Allen, Fire Protection Engineer
- K. Began, Design Engineer, Corporate Office
- B. Davis, Engineering Manager
- J. Ertman, Supervisor, Fire Protection Engineering, Corporate Office
- M. Grantham, Superintendent Design Engineering
- K. Hill, Reactor Operator
- S. Howard, Operations Manager
- P. Mental, Manager (Acting) Support Section
- T. Rouns, Fire Protection Engineer
- K. Sawyer, Fire Protection Instructor
- T. Sherrill, Licensing Engineeer
- B. Stackhouse, Supervisor, Fire Protection Engineering
- J. Titrington, Manager Nuclear Assessment Services
- B. Waldrep, Vice President, Brunswick Steam Electric Plant
- K. Welch, Superintendent System Engineering
- M. Williams, Training Manager
- E. Wills, Plant General Manager
NRC Personnel
- H. Christensen, Deputy Division Director, Division of Reactor Safety, RII
- J. Austin, Senior Resident Inspector, Brunswick Steam Electric Plant
- G. Kolcum, Resident Inspector, Brunswick Steam Electric Plant
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
There were no items to record.
LIST OF FIRE BARRIER FEATURES INSPECTED (Refer Report Section 1RO5.02- Passive Fire Barriers)
Interior Structural Components Description Oil Containment Curbs Fire Area SW-1, (1A Nuclear SW Pump to 1C Conventional SW Pump)
Fire Wall Identification Description Masonry Block Wall, 2-CTB-MAS-EL-023-9D Fire Area CB-10 to Fire Area CB-9 Fireproofing, Column in 2-CTB-MAS-EL-023-9D Fire Area CB-10 to Fire Area CB-9 Fire Door Identification Description Door 110 Fire Area CB-5 to Stair-Well Unit 1 Door 115 Fire Area CB-10 to Fire Area CB-9 Door 117 Fire Area CB-5 to Fire Area CB-8 Fire Damper Identification Description 2-CB-FDMP-68 Fire Area CB-10 to HVAC Duct Chase 2-CB-FDMP-70 Fire Area CB-10 to Fire Area CB-4 2-CB-FDMP-75 Fire Area CB-5 to HVAC Duct Chase 2-CB-FDMP-76 Fire Area CB-5 to HVAC Duct Chase Fire Barrier Penetration Seal Identification Description CB-1-148 Fire Area CB-10 to Fire Area CB-9 CB-1-149 Fire Area CB-10 to Fire Area CB-9 CB-1-150 Fire Area CB-10 to Fire Area CB-9 CB-1-153 Fire Area CB-10 to Fire Area CB-9 CB-1-464 Fire Area CB-5 to Stair-Well Unit 1 CB-1-371 Fire Area CB-5 to Stair-Well Unit 1 CB-1-483 Fire Area CB-5 to Stair-Well Unit 1 ERFBS Identification Description Raceway Fire Barrier Enclosure Fire Area SW-1, 1-Hour Rated 3-M Interam E-50A ERFBS
THE FOLLOWING SSD PROCEDURES WERE REVIEWED AND WALKED THROUGH (Refer Report Section 1R05.05 - Operational Implementation etc.)
0ASSD-01, Alternative Safe Shutdown Procedure Index 0ASSD-02, Safe Shutdown Control Building, Rev. 42
- Section C, Service Water Building Operator Actions
- Section F, Unit 1 SCO Actions
- Section G, Diesel Generator Operator Actions
- Section H, Alternate Shutdown Cooling 0ASSD-09, Safe Shutdown Service Water Building, Rev. 19 2ASSD-04, Safe Shutdown Train A Shutdown, Rev. 21 LIST OF COMPONENTS REVIEWED (Refer to Report Section 1R05.06 - Circuit Analysis)
2-E41-C002, HPCI Turbine Auxiliary Oil Pump 2-E11-F009, RHR Shutdown Cooling Inboard Isolation Valve 2-E11-F008, RHR Shutdown Cooling Outboard Isolation Valve 2-E11-F015A, RHR Inboard Injection Valve 2-E41-F042, HPCI Pump Suction Valve 2-E51-C002, RCIC Turbine Barometric Condenser Vacuum Pump 2-SW-V102, RHR Conventional Nuclear Header valve 2-SW-V105, RHR Nuclear Service Water Supply 2-SW-V117, Nuclear Service Water to Header valve 1-E11-F009, RHR Shutdown Cooling Inboard Isolation Valve 1-E41-F002, HPCI Inboard Steam Line Isolation valve 1-E41-F003, HPCI Outboard Steam Line Isolation valve 1-E41-F042, HPCI Inboard Torus Suction valve 1-E41-F041, HPCI Outboard Torus Suction valve 1-E51-C002, RCIC Turbine Barometric Condenser Vacuum Pump 1-E51-FIC-3325, RCIC System Flow NSW-1A, Nuclear Service Water Pump 1A