IR 05000352/2010006
| ML101650139 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/14/2010 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-10-006 | |
| Download: ML101650139 (22) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
SUBJECT:
LIMERICK GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000352/2010006 AND 05000353/2010006
Dear Mr. Pacilio:
On May 28,2010, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Limerick Generating Station. The inspectors also reviewed mitigation strategies for addressing large fires and explosions. The enclosed inspection report documents the inspection results, which were discussed on May 28, 2010, with Mr. William Maguire and other members of your staff.
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 personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with Title 10 of the Code of Federal Regulations Part 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 (ADAMS).
ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
~~~
Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-352, 50-353 License Nos. NPF-39, NPF-85 Enclosure: Inspection Report No. 05000352/2010006 and 05000353/2010006 w/Attachment: Supplemental Information cc: Distribution via ListServ
June 10, 2010 Mr. Michael Pacilio Senior Vice President, Exelon Generating Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd.
Warrenville, IL 60555 SUBJECT: LIMERICK GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000352/2010006 AND 05000353/2010006 Dear M
SUMMARY OF FINDINGS
IR 05000352/2010006, 05000353/2010006; 05/10/2010 - 05/28/2010; Exelon Generation
Company, LLC; Limerick Generating Station: Triennial Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by Region I 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.
Cornerstone: Mitigating Systems
No findings of significance were identified.
Other Findings
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 Exelon Generation Company, LLC has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Limerick Generating Station (LGS). The following fire areas (FAs) were selected for detailed review based on risk insights from the LGS Individual Plant Examination (IPE)lIndividual Plant Examination of External Events (IPEEE):
- FA 2;
- FA 7;
- FA 22; and
- FA 67.
Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated the licensee's fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Condition 2.C.(3), NRC Safety Evaluations Reports (SERs), 10 CFR 50.48, and Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.5, the fire hazards analysis (FHA), and the post-fire safe shutdown analysis.
The team also evaluated licensee mitigating strategies for addressing large fires and explosions as required by Operating License Conditions 2.C.(21) for Unit 1 and 2.C.(9) for Unit 2.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (IP 71111.05T)
.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and
Normal Shutdown
a. Inspection Scope
Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained for fires that rely on shutdown from outside the control room. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the safe shutdown and fire hazards analyses. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown location(s) would not be affected by fire-induced circuit faults (e.g. by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
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 normal or 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 post-fire safe shutdown and performed an independent walk through 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 operator actions, which were verified, included restoration of alternating current (AC) electrical power, establishing the remote shutdown and local shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
- SE-1, Remote Shutdown, Revision 63;
- 1FSSG-3002, 13 kV Switchgear Area (U-1), Revision 6;
- 1FSSG-3002, 13 kV Switchgear Area (U-2), Revision 5;
- 2FSSG-2007, Corridor (4 kV), Revision 6;
- 2FSSG-3022, Fire Area 22 Fire Guide, Revision 7;
- 2FSSG-3067E, Safeguard System Access Area East, Revision 4; and
- 2FSSG-3067W, Safeguard System Access Area East, Revision 4.
The team reviewed manual actions to ensure that they had been properly reviewed and approved and that 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 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 .
.02 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, safe shutdown analyses, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of the UFSAR 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 reviewed the licensee'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 also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
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 walls, 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 also reviewed similar records for the fire protection wraps to ensure the material was of an appropriate fire rating and that the installation met the engineering design.
b. Findings
No findings of significance were identified .
.04 Active Fire Protection
a. Inspection Scope
The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA)code of record, or NRC approved deviations, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems were verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, Halon, and/or carbon dioxide (C0 2 ) storage tanks and supply system)to assess the material condition of the systems and components.
The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed 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. In addition, the team inspected the fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.
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:
- A fire in one of the selected fire areas would not directly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains;
- A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not directly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and,
- 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
Alternative shutdown capability is discussed in section 1R05.01 of this report .
.07 Circuit Analysis
a. Inspection Scope
The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team verified that the licensee's 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 team's review 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, and 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.
Cable failure modes were reviewed for the following components:
- HV-11-071, Loop 'A' Equipment Header Return Valve;
- HV-49-2F008, Steam Supply Line Outboard Containment Isolation Valve;
- HV-51-1 F014A, RHR Heat Exchanger Tube Inlet Valve;
- HV-51-1 F047A, Heat Exchanger Inlet Valve (from Pump Discharge);
- HV-51-003A, Heat Exchanger Shell Side Discharge Valve;
- HV-51-2F021A, Drywell Spray Line Inboard Containment Isolation Valve;
- U-42-2R010, Reactor Vessel Water Level Indicator; and,
- OAP506, Loop 'A' RHRSW Pump.
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 records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.
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 team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.
b. Findings
No findings of significance were identified .
.09 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 and/or instrumentation monitoring for post-fire safe shutdown. The team also verified that 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 verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.
Findings No findings of significance were identified .
.10 Cold Shutdown Repairs
a. Inspection Scope
. The team verified that the licensee had dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools, and materials (e.g. pre-cut cables with prepared attachment lugs) were available and accessible on site.
b. Findings
No findings of significance were identified . . 11 Compensatory Measures
a. 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, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings of significance were identified .
.12 Large Fires and Explosions* Mitigation Strategies
a. Inspection Scope
The team reviewed the licensee's preparedness to handle large fires or explosions by reviewing four mitigating strategies to verify they continue to meet operating license conditions 2.C.(21) for Unit 1 and 2.C.(9) for Unit 2 by determining that:
- Procedures are being maintained and adequate;
- Equipment is properly staged and is being maintained and tested; and,
- Station personnel are knowledgeable and can implement the procedures.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
lOA] 40A2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that the licensee 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 the licensee had taken or planned appropriate corrective actions.
Additionally, the team reviewed several Issue Reports (IRs) associated with the licensee's review of circuits for multiple spurious operations (MSO) scenarios that uses the guidance provided in NEI 00-01, Revision 2, "Guidance for Post-Fire Safe Shutdown Circuit Analysis" and Regulatory Guide 1.189, Revision 2, "Fire Protection for Nuclear Power Plants."
Specific IRs reviewed by the team are listed in the attachment.
b. Findings
No findings of significance were identified.
The team determined that the licensee had identified several MSO scenarios for further
.review. The licensee placed the identified scenarios into their corrective action program and implemented alternate compensatory measures prior to the May 2, 2010.
40A6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. William Maguire, Site Vice President - Limerick Generating Station, and other members of the site staff at an exit meeting on May 28, 2010. No proprietary information was included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Ajmara, Nuclear Oversight
- S. Bobyock, Engineering Programs Manager
- J. Brittain, Fire Protection Engineer
- F. Burzynski, Fire Marshal
- E. Callan, Plant Manager
- F. Coffey, Operations Support Manager
- G. Curtain, Fire Protection Engineer
- P. Gardner, Director Operations
- R. Harding, Regulatory Assurance
- J. Hunter, Manager Reg. Assurance
- S. Johnson, Assistant Plant Manager
- C. Markle, Assessment Specialist
- W. Maguire, Site Vice President - LGS
- T. Moore, Director of Engineering
- C. Pragman, Exelon Corporate Fire Protection
- R. Rhode, Operator Instructor
- C. Rich, Director Work Management
- S. Soerun,Safe Shutdown Engineer
- M. Taylor, Exelon Corporate Fire Protection
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- W. Cook, Senior Reactor Analyst, Division of Reactor Safety
- E. DiPaolo, Senior Resident Inspector, Limerick Generating Station
- P. McKenna, Resident Inspector (Acting), Limerick Generating Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE
Opened and Closed
NONE
Closed
NONE
Discussed
NONE