IR 05000352/2016007
| ML16356A000 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/20/2016 |
| From: | Glenn Dentel, Richmond J Engineering Region 1 Branch 2 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Dentel G | |
| References | |
| IR 2016007 | |
| Download: ML16356A000 (24) | |
Text
ber 20, 2016
SUBJECT:
LIMERICK GENERATING STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000352/2016007 AND 05000353/2016007
Dear Mr. Hanson:
On November 18, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Limerick Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 18, 2016, with Mr. David Lewis, Plant Manager, 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 station personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
Based on the results of this inspection, no findings were identified.
In accordance with Title 10 of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's document system, Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Docket No: 50-352 and 50-353 License No: NPF-39 and NPF-85
Enclosures:
Inspection Report Nos. 05000352/2016007 and 05000353/2016007 w/Attachment:
Supplemental Information
REGION I==
Docket No: 50-352 and 50-353 License No: NPF-39 and NPF-85 Report No: 05000352/2016007 and 05000353/2016007 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 and 2 Location: Sanatoga, PA Dates: October 31 to November 18, 2016 Inspectors: J. Richmond, Senior Reactor Inspector (Team Leader)
W. Cook, Senior Reactor Analyst K. Young, Senior Reactor Inspector S. Anderson, Reactor Inspector J. Ayala, Reactor Inspector Observers: L. Cole, Audit Manager, NRC Office of the Inspector General J. Cheung, Auditor, NRC Office of the Inspector General Approved by: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY
IR 05000352/2016007 and 05000353/2016007; 10/31/2016 - 11/18/2016; Limerick Generating
Station, Units 1 and 2 (LGS); Triennial Fire Protection Team 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 6, dated July 2016.
No Findings were identified.
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 Limerick Generating Station (LGS). The following fire areas (FA) and associated fire zones (FZ) were selected for detailed review based on prior inspection results, risk insights from the LGS Individual Plant Examination of External Events (IPEEE), and the LGS Fire Probabilistic Risk Assessment:
Fire Area / Fire Zone
- FA 20 Unit 1 Inverter Room, Elevation (Elev.) 254 foot
- FA 26 Remote Shutdown Panel Room Elev. 289 foot
- FZ 44E Unit 1 Reactor Building East, Safeguard System Access Area, Elev. 217 foot Inspection of these fire areas/zones fulfilled the inspection procedure 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 (SER), Title 10 of the Code of Federal Regulations (10 CFR) 50.48, and Branch Technical Position Chemical Engineering Branch (CMEB) 9.5-1. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR),
Section 9.5.1, "Fire Protection Program," UFSAR, Appendix 9A, "Fire Protection Evaluation Report," which included the fire hazards analysis (FHA), and LGS post-fire safe shutdown analyses.
The team evaluated aspects of three mitigating strategies for responding to large fires and explosions, which are required by Operating License Condition 2.C.(21) for Unit 1,
Operating License Condition 2.C.(9) for Unit 2, and 10 CFR 50.54(hh)(2). The team also reviewed related documents that included Nuclear Energy Institute 06-12, "B.5.b Phases 2 and 3 Submittal Guidance," Revision 2 (ML070090060). Inspection of these 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.
REPORT DETAILS
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 FHA, 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 LGS 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 reactor pressure control, reactivity control, reactor coolant makeup, 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, and redundant equipment fire barriers to design and licensing basis requirements, industry standards, and Exelon's 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 similar records for selected fire protection wraps (including the encapsulation system for 125 Volts Direct Current (VDC) Distribution Panel 1BD102, located in FA 20) to determine whether the material and configuration was appropriate for the required fire rating and conformed to the engineering design requirements.
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 Exelon's 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, 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 reviewed design specifications, vendor requirements, and routine functional testing for the Halon suppression system for the remote shutdown panel room (FA 26).
The team walked down accessible portions of the Halon system, including storage tanks and supply systems, to independently assess the material condition, operational lineup, and availability of the systems. The team also reviewed and walked down the associated firefighting strategies and Halon system operating procedures.
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 condition reports 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 not 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; and
- A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, would not 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 reactor pressure control, reactivity control, reactor coolant makeup, 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 FHA. 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:
- SE-1, Remote Shutdown, Revision 73
- 1FSSG-3020, Unit 1 FA 20 Fire Guide, Revision 16
- 1FSSG-3024, Unit 1 FA 24 Fire Guide, Revision 8
- 2FSSG-3024, Unit 2 FA 24 Fire Guide, Revision 7
- 1FSSG-3026, Unit 1 FA 26 Fire Guide, Revision 7
- 2FSSG-3026, Unit 2 FA 26 Fire Guide, Revision 6
- 1FSSG-3044E, Unit 1 FZ 44E Fire Guide, Revision 1
- 2FSSG-3044E, Unit 2 FZ 44E Fire Guide, Revision 1 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:
- 0AP506, "A" Residual Heat Removal Service Water (RHRSW) Pump
- F151-1R005, Residual Heat Removal (RHR) Flow Indicator
- HV49-1F029, Reactor Core Isolation Cooling (RCIC) Pump Suction Valve from Suppression Chamber
- HV49-1F012, RCIC Pump Discharge Valve
- P142-2R011, Reactor Pressure 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
The team reviewed Exelon's dedicated repair procedures, for components which might be damaged by fire and were required to achieve post-fire cold shutdown. The team evaluated selected cold shutdown repairs to determine whether they could be achieved within the time frames assumed in the design and licensing bases. In addition, the team verified whether the necessary repair equipment, tools, and materials (e.g., pre-cut cables with prepared attachment lugs) were available and accessible on site.
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 fire protection program 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 FHA. A sample of hot work and transient combustible control permits were reviewed to assess the adequacy of Exelon's fire protection program 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 reviewed 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 or large fires.
The team assessed whether Exelon continued to meet the requirements of License Condition 2.C.(21) for Unit 1, License Condition 2.C.(9) for Unit 2, and 10 CFR 50.54(hh)(2). The team reviewed the following mitigation strategies:
- T-312, Unit 1, Safety Relief Valve Operation using Alternate Source of DC Power from Portable Cart
- T-342, Unit 2, Portable Pump Injection into Containment
- T-304, Unit 1, Portable Pump Injection into the Reactor Vessel The team's review included: a detailed assessment of the procedural guidance; a tabletop discussion with a non-licensed operator (i.e., postulated highest ranking Operations Department staff member to survive an event or hostile action) to discuss initial response actions; walk down of selected mitigation strategies with plant staff to assess the feasibility of the strategies and familiarity of the staff with plant equipment and implementing procedures; maintenance and surveillance testing of selected strategy equipment; and an inventory check of selected mitigation equipment to verify whether equipment storage and availability was appropriate.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems (IP 71152)
a. Inspection Scope
The team reviewed a sample of condition reports (CR) associated with the fire protection program, 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 CRs reviewed are listed in the attachment.
b. Findings
No findings were identified.
4OA6 Meetings, including Exit
The team presented the inspection results to Mr. David Lewis, Plant Manager, and other members of Exelon's staff on November 18, 2016. The team verified that this report does not contain proprietary information.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Brittian, Fire Protection Program Engineer
- G. Budock, Regulatory Assurance
- F. Burzynski, Site Fire Marshall
- N. Kanoss, Radio System Engineer
- A. McDonald, Fire Brigade Member
- J. Mittura, Safe Shutdown Electrical Engineer
- C. Pragman, Corporate Fire Protection Engineer
- T. Ryan, Manager Engineering Programs
- J. Thoryk, Fire Protection System Engineer
NRC Personnel
- S. Rutenkroger, Senior Resident Inspector, Limerick
- M. Fannon, Resident Inspector, Limerick
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Opened and Closed
None.
Closed
None.