IR 05000333/2017007

Triennial Fire Protection Inspection Report 05000333/2017007

ML17170A009
Person / Time
Site:	FitzPatrick
Issue date:	06/16/2017
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Dentel G
References
IR 2017007
Download: ML17170A009 (22)

Text

une 16, 2017

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000333/2017007

Dear Mr. Hanson:

On May 18, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The enclosed inspection report documents the inspection results, which were discussed on May 18, 2017, with Mr. Joseph Pacher, Site Vice President, and other members of your staff.

The inspection examined activities conducted under your license as they related 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 station personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.

The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-333 License No. DPR-59

Enclosure:

Inspection Report 05000333/2017007 w/Attachment: Supplementary Information

REGION I==

Docket No. 50-333 License No. DPR-59 Report No. 05000333/2017007 Licensee: Exelon Generation Company, LLC Facility: James A. FitzPatrick Nuclear Power Plant Location: Scriba, New York Dates: May 1, 2017 through May 18, 2017 Inspectors: J. Rady, Acting Senior Reactor Inspector (Team Leader)

C. Cahill, Senior Reactor Analyst G. DiPaolo, Senior Reactor Inspector J. Ayala, Reactor Inspector L. Dumont, Reactor Inspector D. Kern, Senior Reactor Inspector (Training)

Observers: H. Roth, New York State Fire Protection Engineer Approved by: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000333/2017007; 05/01/2017 - 05/18/2017; 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 2016.

No findings were identified.

REPORT DETAILS

Background This report presents the results of a triennial fire protection inspection conducted in accordance with U.S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T, "Fire Protection (Triennial)." The objective of the inspection was to assess whether Exelon Generation Company, LLC (Exelon) had implemented an adequate fire protection program (FPP) and whether post-fire safe shutdown capabilities had been established and were properly maintained at James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The following fire areas and/or 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 Area / Fire Zone FZ BR-3, Train B Battery Room 3, 272 Elevation; FZ BR-4, Train B Battery Charger Room 4, 272 Elevation; FZ CR-1, Main Control Room, 300 Elevation; and, FZ RB-1E, Reactor Building E. Crescent Area, 227 and 242 Elevation Inspection of these fire areas/FZs fulfilled the IP requirement to inspect a minimum of three samples.

The inspection team evaluated Exelon's FPP against applicable requirements which included plant technical specifications; Operating License Condition 2.C.(3); NRC Safety Evaluation Reports; Title 10 of the Code of Federal Regulations (10 CFR) 50.48; 10 CFR Part 50, Appendix R; and Branch Technical Position Auxiliary and Power Conversion Systems Branch 9.5-1 and Appendix A. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.8; FPP; Fire Hazards Analyses; and 10 CFR Part 50, Appendix R, Safe Shutdown Analysis Report.

The team evaluated aspects of four mitigating strategies for responding to large fires and explosions, which are required by Operating License Condition 2.R and 10 CFR 50.54(hh)(2).

Inspection of these strategies fulfills the IP 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: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (IP 71111.05T)

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the Fire Hazards Analysis Report (FHAR), post-fire safe shutdown analyses, and supporting drawings and documents to determine whether the safe shutdown capabilities were properly protected from fire damage. The team evaluated equipment and cable separation to determine whether the applicable separation requirements of the FitzPatrick design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and instrumentation cables. The team's review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant inventory control, reactor pressure control, decay heat removal, process monitoring, and associated support system functions.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to evaluate whether the material conditions of the fire area boundaries were adequate for the fire hazards in the area. The team compared the fire area boundaries, including walls, ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway and conduit fire barriers, water spray curtains, and redundant equipment fire barriers to design and licensing 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 and repair 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 recent inspection records for fire dampers, penetration seals, and fire barriers to verify whether the inspection was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

The team evaluated manual and automatic fire suppression and detection systems in the selected fire areas to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements, National Fire Protection Association (NFPA) codes of record, and FitzPatricks 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 as-built capability of the fire water supply system to verify whether the design and licensing basis and NFPA code of record requirements were satisfied, and to assess whether those capabilities were adequate for the hazards involved. 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 fire pump performance tests to assess the adequacy of the test acceptance criteria for pump minimum discharge pressure at the required flow rate, and to verify whether the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied. The team also evaluated the underground fire loop flow tests to determine whether the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed 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 walked down accessible portions of the detection and water 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 issue reports (IRs) to independently assess the material condition of the systems and components. In addition, the team reviewed 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 Exelon's fire-fighting strategies (i.e., pre-fire plans) and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. The team independently inspected the fire brigade equipment, including personnel protective gear (e.g., turnout gear) and smoke removal equipment, to determine operational readiness for fire-fighting.

In addition, the team reviewed Exelon's fire brigade equipment inventory and inspection procedures and recent inspection and inventory results to verify whether adequate equipment was available, and whether any potential material deficiencies were identified.

b. Findings

No findings were identified.

.04 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

The team performed document reviews and plant walk downs to determine whether redundant trains of systems required for hot shutdown, located in the same or adjacent fire areas, would be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team evaluated whether:

A fire in one of the selected fire areas would indirectly, through production of smoke, heat, or hot gases, cause unintended activation of suppression systems in adjacent fire areas that could potentially damage redundant safe shutdown trains; A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, would directly damage all redundant trains (e.g.,

sprinkler caused flooding of other than the locally affected train); and Adequate drainage was provided in areas protected by water suppression systems.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings, electrical drawings, the UFSAR, and other supporting documents for the selected fire areas to determine whether Exelon had properly identified the systems and components necessary to achieve and maintain post-fire safe shutdown conditions. The team evaluated selected systems and components credited by the safe shutdown analysis for reactivity control, reactor coolant inventory control, reactor pressure control, decay heat removal, process monitoring, and support system functions to assess the adequacy of Exelon's alternative shutdown methodology. The team also assessed whether alternative post-fire shutdown could be performed both with and without the availability of off-site power. The team walked down selected plant configurations to verify whether they were consistent with the assumptions and descriptions in the safe shutdown and the FHAR. In addition, the team evaluated whether the systems and components credited for use during post-fire safe 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 post-fire safe shutdown, using either the normal or alternative shutdown methods, were trained and available on-site 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 (i.e., a procedure tabletop)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:

AOP-28, Operation during Plant Fires, Revision 22; and, AOP-43, Plant Shutdown From Outside the Control Room, Revision 39.

The team reviewed selected operator 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 fire area. 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.

b. Findings

No findings were identified.

.06 Circuit Analysis

a. Inspection Scope

The team reviewed Exelon's post-fire safe shutdown analysis for the selected fire areas to determine whether the analysis identified both required and associated electrical circuits and cables for the systems and components necessary to achieve and maintain safe shutdown. The team reviewed electrical schematics and cable routing data for power, control, and instrumentation associated with selected components. Specifically, the team evaluated the selected circuits and cables to determine whether they were

(a) adequately protected from potential fire damage, or

(b) analyzed to show that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown, or

(c) analyzed to show that potential damage could be mitigated with approved operator manual actions, in order to determine whether fire-induced faults could adversely impact safe shutdown capabilities. The team's evaluations considered credible fire scenarios, cable insulation attributes, cable failure modes, cable routing, and common power supply or electrical bus configurations.

In addition, the team reviewed cable raceway drawings and cable routing databases for a sample of components required for post-fire safe shutdown to determine whether those 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 assess whether Exelon's safe shutdown methodologies were appropriate, conformed to design and licensing basis requirements, and appropriately considered the guidance in NRC Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," Revision 2.

Cable failure modes were reviewed for the following components:

14P-1A, Core Spray Pump A; 13MOV-21, Reactor Core Isolation Cooling (RCIC) Pump Discharge Isolation Valve to Reactor; 13MOV-41, RCIC Pump Suction Isolation Valve From Torus; 10AOV- 71A, Residual Heat Removal (RHR) A Discharge Isolation Valve to Torus; 10MOV-16B, RHR B Minimum Flow Isolation Valve; and, 02-3LI58A, Reactor Level Indicator.

The team reviewed a sample of circuit breaker and fuse over-current protection 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 electrical bus concern. The team also evaluated whether coordination studies appropriately considered multiple faults due to fire. In addition, the team reviewed a sample of circuit breaker maintenance records, for components required for safe shutdown, to determine whether the breakers were properly maintained.

The team assessed the transfer of control from the main control room to the alternative shutdown location to determine whether it would be adversely affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team reviewed safe shutdown procedures, the safe shutdown analysis, 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 selected emergency storage lockers to independently verify whether portable communication equipment was available for the fire brigade and plant operators. In addition, the team evaluated whether radio or phone repeaters, transmitters, and power supplies would be reasonably unaffected by a fire.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown. The team also verified whether 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 evaluate whether the emergency lighting had been maintained consistent with the manufacturers recommendations and in a manner that would ensure reliable operation.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

Exelon did not identify any systems or components that would require repairs to achieve post-fire cold shutdown. The team assessed Exelons 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.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. 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.g., detection and suppression systems and equipment, passive fire barriers, or 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 Exelon was effective in returning the equipment to service in a reasonable period of time.

b. Findings

No findings were identified.

.11 Review and Documentation of FPP Changes

a. Inspection Scope

The team reviewed recent changes to the approved FPP to assess whether those changes had an adverse effect on the ability to safely shutdown.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed Exelon'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 FHAR. A sample of hot work and transient combustible control permits were reviewed to assess the adequacy of Exelon's FPP administrative controls. The team performed plant walk downs to independently verify whether transient combustibles and ignition sources were being properly controlled in accordance with the administrative controls.

b. Findings

No findings were identified.

.13 Large Fires and Explosions Mitigation Strategies

a. Inspection Scope

The team conducted a review of selected mitigation strategies intended to maintain or restore core decay heat removal and spent fuel pool cooling capabilities under the circumstances associated with the loss of large areas of the plant due to explosions and/or fires. The team assessed whether Exelon continued to meet the requirements of License Condition 2.R and 10 CFR 50.54(hh)(2).

The team reviewed the following mitigation strategies:

Makeup to the Spent Fuel Pool with Permanently Installed and Portable Equipment; External Spray; Operation of Safety Relief Valves; and, Makeup to the Reactor with the Portable Pump.

The team's review included: a detailed assessment of the procedural guidance; a tabletop discussion with licensed operators; a walk down of four mitigation strategies with operators to assess the feasibility of the strategies and operator familiarity; maintenance and surveillance testing of selected strategy equipment; and an inventory check of the B.5.b pump and equipment trailers to ensure the appropriateness of equipment storage and availability.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (IP 71152)

a. Inspection Scope

The team reviewed a sample of IRs associated with the FPP, post-fire safe shutdown issues, and mitigation strategy issues to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with these areas and whether the planned or completed corrective actions were appropriate. The IRs reviewed are listed in the Attachment.

b. Findings

No findings were identified.

4OA6 Meetings, including Exit

The team presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of Exelon's staff on May 18, 2017. The team verified that this report does not contain proprietary information.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Cooney, Fire Protection Engineer

M. Hawes, Licensing Specialist

R. Jennings, Fire Marshall

J. Pechaceke, Senior Reactor Operator

C. Pragman, Exelon Corporate Fire Protection

C. Smolinski, Operations Support Manager

D. Starczewski, Engineering Supervisor

M. Taylor, Exelon Corporate Fire Protection

C. Wallace, System Engineer

E. Weimer, Fire Protection System Engineer

NRC Personnel

B. Sienel, Senior Resident Inspector, FitzPatrick

G. Stock, Acting Resident Inspector, FitzPatrick

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Opened and Closed

None.

Closed

None.