IR 05000336/2005011
| ML051950314 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/14/2005 |
| From: | Rogge J Division of Reactor Safety I |
| To: | Christian D Dominion Resources Services |
| References | |
| IR-05-011 | |
| Download: ML051950314 (21) | |
Text
uly 14, 2005
SUBJECT:
MILLSTONE POWER STATION UNIT 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000336/2005011
Dear Mr. Christian:
On June 24, 2005, the NRC completed a triennial fire protection team inspection at the Millstone Power Station Unit 2 Power Plant. The enclosed report documents the inspection findings which were discussed at an exit meeting on June 24, 2005, with Mr. J. Alan Price and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions regulations and with the conditions of your license. The purpose of the inspection was to evaluate your post-fire safe shutdown capability and fire protection program. 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 and its enclosure 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 Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-336 License No. DPR-65 Enclosure: Inspection Report No. 05000336/2005011
Mr. David
SUMMARY OF FINDINGS
IR 05000336/2005011 on 06/06-10/2005 and 06/20-24/2005, Dominion Nuclear Connecticut,
LLC, Millstone Power Station Unit 2. Fire Protection Team Inspection.
The report covered a two-week 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 3, dated July 2000.
NRC-Identified Findings
No findings of significance were identified.
Licensee-Identified Violations
None ii
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Dominion Nuclear Connecticut has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Millstone Power Station Unit 2 facility. The following fire areas were selected for detailed review based on risk insights from the Millstone Power Station Unit 2 (MP2) Individual Plant Examination (IPE) and Individual Plant Examination of External Events (IPEEE):
C Fire Area A-25 C Fire Area A-20 C Fire Area I-1
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems
1R05 Fire Protection
.01 Shutdown From Outside Main Control Room
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries, fire doors, and fire dampers. The team reviewed engineering evaluations, as well as surveillance and functional test procedures for selected items. The team also reviewed the licensee submittals and NRC safety evaluation reports (SERs) associated with fire protection features at MP2. Additionally, the team reviewed the design and qualification testing of selected barriers and reviewed surveillance procedures for structural fire barriers and penetration seals. These reviews were performed to ensure that the passive fire barriers were properly maintained and met the licensing and design bases as described in the licensee submittals, NRC SERs, the fire hazards analysis (FHA) and the MP2 Final Safety Analysis Report (FSAR).
b. Findings
No findings of significance were identified.
.02 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the fire hazards analysis, safe shutdown analysis and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team verified that separation requirements of Section III.G of Appendix R 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. The team also performed plant walkdowns to verify that protective features were being properly maintained.
b. Findings
No findings of significance were identified.
.03 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including fire doors and fire dampers), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.
The team reviewed installation/repair and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.
The team reviewed engineering evaluations, as well as surveillance and functional test procedures for selected passive fire protection items. The team also reviewed the licensee submittals and NRC safety evaluation reports (SERs) associated with passive fire protection features. These reviews were performed to ensure that the passive fire barriers were properly maintained and met the licensing and design bases as described in the licensee submittals, NRC SERs, the fire hazards analysis (FHA) and the MP2 FSAR.
b. Findings
No findings of significance were identified.
.04 Active Fire Protection
Fire Detection Systems and Equipment
a. Inspection Scope
The team reviewed the adequacy of the fire detection systems in the selected plant fire areas. This included a walkdown of the systems and review of the type of installed detectors as shown per location drawings. Additionally, the team reviewed fire detection surveillance procedures to determine the adequacy of the fire detection component testing and to ensure that the detection system would function as required.
b. Findings
No findings of significance were identified.
Fixed Fire Suppression Systems
a. Inspection Scope
Halon Systems The team reviewed the adequacy of the East DC Switchgear room Halon systems by performing walkdowns of the systems and the fire area envelopes. The team also reviewed the design and installation initial discharge testing that verified concentration and hold times and the adequacy of surveillance procedures. Completed surveillance procedures were also reviewed to ensure periodic testing of the systems was being accomplished. These reviews were performed to ensure that the low pressure total flooding Halon systems met the design and licensing bases as described in the licensee submittals, NRC SERs, the FHA and the FSAR and that the system could perform its intended function in the event of a fire in these areas.
b. Findings
No findings of significance were identified.
Manual Fire Suppression Capability
a. Inspection Scope
The team walked down selected standpipe systems and observed portable extinguishers to determine the material condition of the manual fire fighting equipment and verify locations as specified in the pre-fire plans and fire protection program documents. The team reviewed fire hose hydrostatic pressure tests to ensure that the equipment was meeting the design requirements.
The team reviewed pre-fire 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.
The team performed in-plant walk downs to evaluate the physical configuration of electrical raceway and safe shutdown components in the selected fire areas to determine whether water from an inadvertent fire suppression system pipe rupture or from manual fire suppression activities in the selected areas could cause damage that could inhibit the ability to safely shutdown the plant.
The team reviewed fire brigade initial training and continuing training course materials to verify appropriate training was being conducted for the station fire fighting personnel.
Additionally, the team observed fire brigade training at the on-site fire-fighting simulator.
The team reviewed the qualifications of several fire brigade leaders and members to ensure that they had met and maintained the requirements to be fire brigade leaders and members.
The team performed a walkdown of the fire brigade facilities and response vehicles for adequacy and material conditions.
b. Findings
No findings of significance were identified.
.05 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
C A fire in one of the selected fire areas would not indirectly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant trains.
C A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not indirectly cause damage to all redundant trains (e.g., sprinkler caused flooding of other than the locally affected train).
C Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings of significance were identified.
.06 Alternative Shutdown Capability
a. Inspection Scope
Methodology The team verified that the alternative shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for each of the fire areas selected for review. The team specifically assessed the adequacy of systems for reactivity control, reactor coolant makeup, decay heat removal, process monitoring and support system functions. The team also verified that hot and cold shutdown from outside the control room could be achieved and maintained with or without off-site power available.
The team verified that the transfer of control from the control to the alternative shutdown location(s) will not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Operational Implementation The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for alternative shutdown and performed independent walk throughs of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions which were verified included restoration of AC electrical power, restoration of reactor coolant pump seal cooling, establishing reactor coolant makeup using the charging systems and establishing decay heat removal.
The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
b. Findings
No findings of significance were identified.
.07 Circuit Analyses
a. Inspection Scope
The team verified that the Dominion Nuclear had performed a post-fire safe shutdown analysis for the selected fire areas and that the analysis appropriately identified the structures, systems and components important to achieving and maintaining safe shutdown. Additionally, the team verified that Dominion Nuclears analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground or other failures were identified, evaluated and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The teams reviewed considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, multiple spurious actuations, actuations resulting in flow diversion or loss of coolant events.
The team also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices. This included a walkdown of selected cable trays to verify their location.
Cable failure modes were reviewed for the following components:
C Power Operated Relief Valves (PORVs), 2-RC-402 and 2-RC-404 C Reactor Head Vents, 2-RC-414, 415, 416, and 417 C Auxiliary Flow Control Valve, 2-FW-43B C Turbine Driven AFW Pump Discharge Valve, 2-FW-44 The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance and records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.
Additionally, the team reviewed self-assessment MP-SA-05-13, Fire Safe Shutdown Multiple Circuit Failure Exposure, June 9, 2005, to determine if Dominion Nuclear had identified any circuit non-compliance issues. The team also reviewed Dominion Nuclears response to Information Notice (IN) 2005-04, Single Failure Vulnerability of Redundant Buses, to determine if Millstone Nuclear Power Station, Unit 2 was vulnerable to the IN identified condition.
b. Findings
No findings of significance were identified.
.08 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The inspectors also verified that communications equipment such as repeaters, transmitters, etc. would not be affected by a fire.
b. Findings
No findings of significance were identified.
.09 Emergency Lighting
a. Inspection Scope
During walkthrough of a post-fire shutdown procedure, the team observed the placement and coverage areas of emergency lighting units to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an 8-hour capacity.
Preventive maintenance procedures and various documents, including the vendors manual and completed surveillance tests were reviewed to ensure adequate surveillance testing and periodic battery replacements were in place to ensure reliable operation of the eight-hour emergency lights and that the emergency lighting units were being maintained consistent with the manufacturers recommendations and accepted industry practices.
b. Findings
No findings of significance were identified.
.10 Cold Shutdown Repairs
a. Inspection Scope
During walkthroughs of the selected fire areas, the team verified that the temporary instruments called out in AOP 2579AA, Fire procedure for Cooldown and Cold Shutdown, Appendix R Fire Area, R-1" were stored and available in the locker adjacent to Fire Shutdown Panel C-10 in the Upper 4169V Switchgear Room.
b. Findings
No findings of significance were identified
.11 Compensatory Measures
b. Inspection Scope
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, pumps, valves and electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures were adequate for the degraded function or feature until appropriate corrective action could be taken and that Dominion was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings of significance were identified.
.12 Programmatic Controls
During tours of the facility, the team observed the material condition of fire protection systems and equipment, the storage of permanent and transient combustible materials, and control of ignition sources. The team also reviewed the procedures that controlled hot-work activities and combustibles at the site. Additionally, the team reviewed a sample of hot work permits and transient combustible evaluations. These reviews were accomplished to ensure that Dominion was maintaining the fire protection systems, controlling hot-work activities, and controlling combustible materials in accordance with the FSAR, administrative procedures and other fire protection program procedures.
c. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that Dominion was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program. The team also reviewed a sample of selected issues to verify that Dominion had taken or planned appropriate corrective actions.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. J. Alan price, Site Vice president, and other members of the site staff at an exit meeting on June 24, 2005.
No proprietary information was included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Dominion Personnel
- J. Price, Site Vice President
- S. Sarver, Director, operations and Maintenance
- A. Jordan, Director, Engineering
- P. Grossman, Manager, Nuclear Engineering
- S. Wainio, Supervisor, Nuclear Technical Programs
- W. Bartron, Licensing Engineer
- M. Jalbert, Inspector Liaison
- N. Kuzel, Technical Programs Engineer
- S. Garvin, Supervisor, Operations Support
- R. Wells, Engineer, Mechanical Systems and Standards
- J. Armstrong, Engineer, Nuclear Technical Programs
- P. Raimondi, Technical Programs Engineer, Appendix R
- D. Scott, Technical Programs Engineer, Appendix R
- B. Smith, Engineer, Nuclear Technical Programs
- W. Weseman, Engineer, Materials Engineering Programs
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- S. Schneider, Senior Resident Inspector, Millstone
- S. Kennedy, Resident Inspector, Millstone
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE Open and
Closed
NONE
Closed
NONE
Discussed
NONE