IR 05000333/2011007
| ML112910204 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/17/2011 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Bronson K Entergy Nuclear Northeast |
| References | |
| IR-11-007 | |
| Download: ML112910204 (25) | |
Text
September 30, 2011
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT O5OOO333/2011007
Dear Mr. Bronson:
On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed inspection report documents the inspection results, which were discussed with Mr. Brian Sullivan, General Manager, Plant Operations, and other members of your staff on September 30,2011.
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 station personnel.
Based on the results of this inspection, no findings 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 the NRC's document system, Agencyruide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RN John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No.: 50-333 License No.: DPR-59 DISTRIBUTION: See next page SUNSlReview Gomplete: JFR (Reviewer's Initials)
ADAMS ACC #M1112910204 DOCUMENT NAME: G:\\DRS\\Engineering Branch 3\\Richmond\\Fitz 2011-07 Fire\\Fitz2011-07 Fire.doc After declaring this document "An Official Agency Record" it will be released to the Public.
To receive a copv ol this indicate in the box: 'C'= Copy without attachmenUenclosure 'E'= Copy with attachmenVenclosure DATE 10117111 OFFICIAL RECORD COPY
Enclosure:
I nspection Report 05000333/201 1 007 MAttachment: Supplemental Information
REGION I==
Docket No.:
50-333 License No.:
DPR-59 Report No.:
05000333/2011007 Licensee:
Entergy Nuclear Northeast (Entergy)
Facility:
James A. FitzPatrick Nuclear Power Plant Location:
Scriba, New York Dates:
September 12,2011 through September 30,2011 lnspectors:
J. Richmond, Senior Reactor Inspector (Team Leader)
W. Cook, Senior Reactor Analyst L. Scholl, Senior Reactor Inspector K. Young, Senior Reactor Inspector A. Rao, Reactor Inspector Approved by:
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
lR 0500033 312011007;0911212011 - Ogl3Ol2O11; James A. FitzPatrick Nuclear Power plant;
Triennial Fire Protection Inspection.
This report covered a two week on-site 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.
No findings were identified.
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 Northeast (Entergy) had implemented an adequate fire protection program and that post-fire safe shutdown capabilities had been established and were properly maintained at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The following fire areas (FA) and associated fire zones (FZ)were selected for detailed review based on prior inspection results and risk insights from the FitzPatrick Individual Plant Examination of External Events:
Fire Areas (Fire Zones)
.
1D (CT-4), North Cable Tunnel (Elevation 286)
. 06 (EG-3, EG-4, and EG-6), "B" and'D'EDG Rooms, and "B/D" EDG Switchgear Room
. 09 (RB-1A), Reactor Building East Side (Elevation 272), Southeast Quadrant (Elevation 300), entire floor at Elevations 326, 344, and 369 Inspection of these FAs/FZs fulfilled 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 Condition 2.C.(3), NRC Safety Evaluation Reports (SERs), 10 CFR 50.48, 10 CFR Part 50, Appendix R, and Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1 and Appendix A. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.8-1, FPP, Fire Hazards Analyses (FHA), and 10 CFR Part 50, Appendix R, Safe Shutdown Analysis (SSD) Report.
The team also evaluated aspects of three mitigating strategies for addressing large fires and explosions as required by Operating License Condition 2.R. Inspection of the strategies fulfills the inspection procedure requirement to inspect a minimum of one sample' Specific documents reviewed by the team are listed in the attachment to this report.
REACTOR SAFETY
Cornerstones: lnitiating Events, Mitigating Systems, Barrier Integrity
==1R05 Fire Protection (lP 7111 1.05T)
==
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, SSD, and supporting drawings and documentation to verify whether the safe shutdown capabilities were properly protected. The team evaluated equipment and cable separation to determine whether applicable separation b.
a.
requirements of Section lll.G of 10 CFR Part 50, Appendix R, and FitzPatrick's design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and 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 lnspection Scope The team walked down accessible portions of the selected FAs to evaluate whether the observed material conditions of the FA boundaries were adequate for the fire hazards in the area. The team compared the FA boundaries, including walls, fire doors, fire dampers, penetration seals, electrical raceway fire barriers, and redundant equipment fire barriers to design basis requirements, industry standards, and the FitzPatrick FPP, as approved by the NRC, to identify any potential degradation or non-conformances.
The team reviewed selected engineering evaluations, installation work orders, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating. The team also reviewed the most recent inspection records for fire dampers, penetration fire barrier seals, and fire separation barriers for the selected fire areas, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
ln addition, the team reviewed the most recent test results of the carbon dioxide (COz)fire damper functionality tests for the north cable tunnel and the B/D emergency diesel generator (EDG) switchgear room to verify whether the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
Findinqs No findings were identified.
Active Fire Protection Inspection Scope The team evaluated the flre detection and suppression systems in the selected fire areas to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements and approved exemptions, National Fire Protection
.02.03
b.
Association (NFPA) codes of record, and the FitzPatrick FPP, as approved by the NRC.
The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas.
The team reviewed the design capability of the fire water supply system to verify whether the design basis and NFPA code requirements for the hazards involved were adequately satisfied. The team reviewed the fire water system hydraulic analyses to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus concurrent fire hose usage. The team evaluated the motor-driven and diesel-driven fire pump capacity tests to assess the adequacy of the test acceptance criteria, for pump minimum discharge pressure at the required flow rate, to satisfy design basis and hydraulic analysis requirements. The team also evaluated the underground fire loop flow tests to verify whether the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed the most recent pump and loop flow test results to verify whether the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
The team reviewed initial discharge testing, design specifications, modifications, and engineering evaluations for the COz suppression systems for the north cable tunnel and the B/D EDG switchgear room. The team also reviewed and walked down the associated fire fighting strategies and COz system operating procedures.
The team walked down accessible portions of the detection and suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire pumps, interviewed system and program engineers, and reviewed selected open condition reports to assess the material condition of the systems and components. In addition, the team reviewed the most recent test results for the fire detection and suppression systems for the selected fire areas to verify whether the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed Entergy's fire fighting strategies (i.e., pre-fire plans) and smoke removal plans for the selected FAs to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and facilitate suppression of a fire that could impact post-fire safe shutdown capability. The team independently inspected the fire brigade equipment, including personnel protective gear (e.9., turnout gear) and smoke removal equipment, to determine operational readiness for fire fighting.
Ln addition, the team reviewed Entergy's fire brigade equipment inventory and inspection procedures and the most recent inspection and inventory results to verify whether adequate equipment was available, and whether any potential material deficiencies were identified.
Findinqs No findings were identified.
.04 Protection from Damaqe from Fire Suppression Activities
a. Inspection Scope
The team walked down the selected FAs and adjacent areas, and reviewed selected documents to determine whether redundant safe shutdown trains could be potentially damaged from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, to determine whether a potential existed to damage redundant safe shutdown trains, the team evaluated whether:
. A fire in one of the selected FAs would not release smoke, heat, or hot gases that could cause unintended activation of suppression systems in adjacent fire areas which could potentially damage all redundant safe shutdown trains; o A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected FAs, could not indirectly damage all redundant trains (e.g., sprinkler caused flooding of other than the locally affected train); and o Adequate drainage was provided in areas protected by water suppression systems.
b.
Findinqs No findings were identified.
.05 AlternativeShutdownCapabilitv
a.
lnspection Scope The team reviewed the SSA, operating procedures, piping and instrumentation drawings (P&lD), electrical drawings, the UFSAR, and other supporting documents for the selected FAs to verify whether Entergy had properly identified the systems and components necessary to achieve and maintain safe shutdown conditions.
The team evaluated selected systems and components for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions to assess the adequacy Entergy's alternative shutdown methodology. In addition, the team assessed whether alternative post-fire shutdown could be performed both with and without the availability of offsite power. The team walked down selected plant configurations to verify whether they were consistent with that described in the safe shutdown and FHA. The team also evaluated whether the systems and components credited for use during shutdown would remain free from fire damage.
The team reviewed the training program for licensed and non-licensed operators to verify whether it included alternative shutdown capability. The team also verified whether personnel required for safe shutdown using either the normal or alternative shutdown systems and procedures were trained and available onsite at all times, exclusive of those assigned as fire brigade members.
b.
a.
.06 The team reviewed the adequacy of procedures utilized for post-fire shutdown and
performed an independent walk through of procedure steps to assess the adequacy of implementation and human factors within the procedures. The team also evaluated the time required to perform specific actions to verify whether operators could reasonably be expected to perform those actions within sufficient time to maintain plant parameters within specified limits.
Specific procedures reviewed for normal and alternative post-fire shutdown included:
o AOP-28, Operation during Plant Fires, Rev. 19
. AOP-43, Plant Shutdown From Outside the Control Room, Rev. 34 The team reviewed selected manual actions to verify whether they had been properly reviewed and approved and whether the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each FA. The team also reviewed the periodic testing of the alternative shutdown transfer and isolation capability, and instrumentation and controlfunctions to evaluate whether the tests were adequate to ensure the functionality of the alternative shutdown capability.
The team also reviewed the periodic testing of the alternative shutdown transfer and isolation capability, and instrumentation and control functions to evaluate whether the tests were adequate to ensure the functionality of the alternative shutdown capability.
Findinqs No findings were identified.
Circuit Analvsis Inspection Scope The team reviewed Entergy's post-fire SSD for the selected FAs and determined whether the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team assessed Entergy's analysis to verify whether the necessary electrical circuits were properly proteCted and whether 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 the cable routing database for a sample of components required for post-fire safe shutdown to determine whether those cables were routed as described in the SSD. The team also reviewed equipment b.
important to safe shutdown, but not part of the success path, to assess whether Entergy's actions were appropriate and conformed to design and licensing basis requirements and NRC Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," Revision 2.
Cable failure modes were reviewed for the following components:
. 10MOV-1668, "8" Residual Heat Removal (RHR) Heat Exchanger Inboard Vent Valve; o 23MOV-16, High Pressure Coolant Injection (HPCI) Outboard Steam Supply Valve; o 46MOV-101B, "8" Emergency Service Water (ESW) System Injection Valve; and
. 46MOV-1028, 'B'ESW System Test (Minimum Flow) Valve.
The team reviewed a sample of circuit breaker coordination studies to determine whether equipment needed for post-fire safe shutdown activities could be adversely affected due to a lack of coordination that could result in a common power supply or common bus concern.
The team assessed the transfer of controlfrom the control room to the alternative shutdown location(s) to determine whether it would 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 SSD, and associated documents to verify whether 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 inspected the designated emergency storage lockers to independently verify whether portable radios for the fire brigade and for plant operators would be available. In addition, the team evaluated whether communications equipment such as repeaters and transmitters would be unaffected by a fire.
Findinqs No findings were identified.
.07.08
.09 Emerqencv Liqhtinq
lnspection Scope The team walked down the emergency lights in the selected FAs to independently evaluate the placement and coverage areas of the lights. The team assessed whether the lights provided adequate illumination on local equipment and instrumentation required for post-fire safe shutdown, to ensure local operations could be reliably performed under expected post-fire conditions. Emergency light placement was also evaluated to determine adequate illumination of local area access and egress pathways.
The team verified whether the emergency light batteries 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 evaluate whether the emergency lighting was being maintained in a manner that would ensure reliable operation.
Findinqs No findings were identified.
Cold Shutdown Repairs lnspection Scope Entergy did not identify any systems or components that would require repairs to achieve post-fire cold shutdown. The team assessed Entergy's determination that no dedicated repair procedures, equipment, or materials were needed to accomplish repairs of components required for cold shutdown which might be damaged by a fire, to verify whether cold shutdown could be achieved within the time frames specified in the design and licensing bases without performing any cold shutdown repairs.
Findinos No findings were identified.
Compensatory Measures Inspection Scope The team verified whether compensatory measures were in place for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.9., detection and suppression systems and equipment, passive fire barriers, pumps, valves, or electrical devices providing safe shutdown functions or capabilities). The team evaluated whether the short term compensatory measures adequately compensated for the degraded function or feature until appropriate corrective action could be taken and whether Entergy was effective in returning the equipment to service in a reasonable period of time.
b.
a.
b.
.10 b.
Findinos No findings were identified.
.11 Review and Documentation of Fire Protection Prooram Chanqes
a. Inspection Scope
The team reviewed recent changes to the approved FFP to assess whether those changes had an adverse effect on the ability to safely shutdown.
b.
Findinos No findings were identified.
.12 Control of Transient Combustibles and lqnition Sources
a. Inspection Scope
The team reviewed Entergy'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 reviewed to assess the adequacy of Entergy's FFP administrative controls. The team performed plant walkdowns to independently verify whether transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.
b.
Findinqs No findings were identified.
.13 Laroe Fires and Explosions Mitiqation Strateqies
a. Inspection Scope
The team conducted a review of selected mitigation strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire.
The team assessed whether Entergy continued to meet the requirements of Operating License condition 2.R. The team reviewed three mitigation strategies:
. Manual operation of the reactor core isolation cooling system; e Reactor coolant system depressurization and injection using the fire pumper truck; and r Containment venting.
The team's review included: a detailed assessment of the procedural guidance; a walkdown of the strategy with a trained operator to assess the feasibility of the strategy and operator familiarity; maintenance and surveillance testing of all designated strategy equipment; and an inventory check of all strategy equipment to ensure the appropriateness of equipment storage and availability. The team also evaluated the adequacy of corrective actions associated with issues identified during the Temporary lnstruction 251 51 1 83 Inspection, documented in NRC Inspection Report No. 0500033312011008.
b.
Findinqs No findings were identified.
OTHER ACTIVITIES
4OA2 ldentification and Resolution of Problems (lP 71152)
a. Inspection Scope
The team reviewed a sample of condition reports associated with the FitzPatrick FPP and post-fire safe shutdown issues to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated with these areas, and to assess whether the planned or completed corrective actions were appropriate. The condition reports reviewed are listed in the attachment.
b.
Findinqs No findings were identified.
4OAO Meetinqs. includinq Exit The team presented the inspection results to Mr. Brian Sullivan, General Manager, Plant Operations, and other members of Entergy's staff on September 30, 2011. The team verified that this report does not contain proprietary information.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Enterov Personnel
- T. Andersen, Electrical Design Engineer
- H. Borick, Operations Procedure Coordinator
- G. Dorman, Senior Licensing Specialist
- M. Hawes, Licensing Specialist
- R. Jennings, Fire Protection Instructor
- D. Koelbel, Fire Protection System Engineer
- R. Lathrop, Licensed Operator lnstructor
- J. Pachacek, Manager, Licensing
- K. Smith, Licensed Reactor Operator
- D. Stokes, Fire Protection Program Engineer
- J. Walkowiak, Assistant Operations Manager, Shift
NRC Personnel
- E. Knutson, Senior Resident Inspector - FitzPatrick
- S. Rutenkroger, Resident lnspector - FitzPatrick
- K. Cronk, Resident lnspector - FitzPatrick
- D. Frumkin, Fire Protection Branch, Division of Risk Assessment, Office of the
Nuclear Reactor Regulation (NRR)
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None.