IR 05000373/2011009
| ML11342A077 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/07/2011 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Alan Dahbur | |
| References | |
| IR-11-009 | |
| Download: ML11342A077 (18) | |
Text
UNITED STATES ber 7, 2011
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2011009; 05000374/2011009(DRS)
Dear Mr. Pacilio:
On November 18, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your LaSalle County Station Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 18, 2011, with Mr. P. Karaba and other members of your staff.
The inspection examined activities conducted under your license as they relate 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 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 enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18
Enclosure:
Inspection Report 05000373/2011009; 05000374/2011009(DRS)
w/Attachment: Supplemental Information
REGION III==
Docket No: 50-373; 50-374 License No: NPF-11; NPF-18 Report No: 05000373/2011009; 05000374/2011009(DRS)
Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: October 19, 2011 - November 18, 2011 Inspectors: A. Dahbur, Senior Reactor Inspector, Lead M. Munir, Reactor Inspector R. Winter, Reactor Inspector Approved by: R. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000373/2011009, 05000374/2011009(DRS); 10/19/2011 - 11/18/2011; LaSalle County
Station; Triennial Fire Protection Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. Based on the results of this inspection, no findings of significance were identified by the inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity
No violations of significance were identified.
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of the fire protection triennial baseline inspection was to conduct a design-based, plant specific, risk-informed, on-site inspection of the licensees fire protection programs defense-in-depth elements used to mitigate the consequences of a fire. The fire protection program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:
- preventing fires from starting;
- rapidly detecting, controlling and extinguishing fires that do occur;
- providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and
- taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.
The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants fire protection program, post-fire safe shutdown systems, and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a fire protection program that:
- (1) provided adequate controls for combustibles and ignition sources inside the plant;
- (2) provided adequate fire detection and suppression capability;
- (3) maintained passive fire protection features in good material condition;
- (4) established adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features;
- (5) ensured that procedures, equipment, fire barriers and systems exist so that the post-fire capability to safely shut down the plant was ensured;
- (6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and
- (7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees problem identification and resolution program.
In addition, the inspectors review and assessment focused on the licensees post-fire safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspectors review and assessment also focused on the licensees B.5.b related license conditions and the requirements of 10 CFR 50.54(hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.
The fire zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.11. The fire zones selected constituted four inspection samples and the B.5.b mitigating strategies selected constituted two inspection samples, respectively, as defined in Inspection Procedure 71111.05T.
Fire Area Fire Zone Description 4E2 Unit 2 Auxiliary Equipment Room 5C11 Turbine Building Ground Floor- Diesel Generator Corridors 7B3 Division 1 Standby Diesel-Generator Room 4D2 Unit 2 - Cable Spreading Room
.1 Protection of Safe Shutdown Capabilities
a. Inspection Scope
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected.
The inspectors reviewed the licensees 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 fire hazards analysis. The inspectors performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post-fire safe shutdown analysis and procedures.
b. Findings
No findings of significance were identified.
.2 Passive Fire Protection
a. Inspection Scope
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments.
The inspectors 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) to ensure they were appropriate for the fire hazards in the area.
The inspectors reviewed the 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.
b. Findings
No findings of significance were identified.
.3 Active Fire Protection
a. Inspection Scope
For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.
b. Findings
No findings of significance were identified.
.4 Protection from Damage from Fire Suppression Activities
a. Inspection Scope
For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.
b. Findings
No findings of significance were identified.
.5 Alternative Shutdown Capability
a. Inspection Scope
The inspectors reviewed the licensees systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.
The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.
b. Findings
No findings of significance were identified.
.6 Circuit Analyses
a. Inspection Scope
The inspectors reviewed the licensees post-fire safe shutdown analysis to verify that the licensee had identified both required and associated circuits that may impact safe shutdown. On a sample basis, the inspectors verified that the cables of equipment required achieving and maintaining hot shutdown conditions, in the event of fire in the selected fire zones, had been properly identified. In addition, the inspectors verified whether these cables had either been adequately protected from the potentially adverse effects of fire damage, mitigated with approved manual operator actions, or analyzed to show that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown. In order to accomplish this, the inspectors reviewed electrical schematics and cable routing data for power and control cables associated with each of the selected components.
In addition, the inspectors reviewed licensees evaluation of potential circuit protective coordination issues for the safe shutdown systems electrical power and instrumentation busses.
- (1) Review of Licensees Multiple Spurious Operations Circuit Analyses In Accordance with Guidance in Regulatory Guide 1.189, Revision 2 Background In October 2009, the NRC issued guidance in Regulatory Guide (RG) 1.189, Fire Protection for Nuclear Power Plants, Revision 2, to identify acceptable methods for resolving issues related to circuits required for post-fire safe shutdown and circuits important to post-fire safe shutdown. Equipment required for post-fire safe shutdown (credited train) must use one of the three methods identified in 10 CFR Part 50, Appendix R, Section III.G.2 to protect the circuits located within the same fire area from damage, including single and multiple spurious operations (MSOs). For important to post-fire safe shutdown circuits, the licensee may use operator manual actions if the licensee demonstrates they can be shown to be feasible and reliable or resolve issues using other analysis methods including fire modeling.
In May 2009 the NRC issued Enforcement Guidance Memorandum (EGM) 09-002, Enforcement Discretion for Fire-Induced Circuit Faults, which described the conditions limiting enforcement discretion during the resolution of the fire protection concerns involving MSOs. The EGM limited the enforcement discretion to three years from the date of issuance of RG 1.189, Revision 2:
- (1) six months following the issuance of RG 1.189, Revision 2, for licensees to identify non-compliances related to multiple fire-induced circuit faults, place the non-compliances into their corrective action program and implement compensatory measures for the non-compliances and
- (2) three years following the issuance of RG 1.189, Revision 2, for licensees to complete the corrective actions associated with non-compliant multiple fire-induced circuit faults. The enforcement discretion would not be granted to identified non-compliances that are found to be willful or findings that the Reactor Oversight Process Significant Determination Process would evaluate as (Red) or categorized at Severity Level I.
Inspection Effort During this inspection, the inspectors reviewed representative sampling of single and multiple spurious issues throughout the plant to verify:
- The licensee successfully addressed single and multiple spurious issues in a way that met regulations;
- The licensee properly classified equipment required for safe shutdown and equipment important for safe shutdown;
- The adequacy of the licensees evaluation of multiple spurious actuations, in accordance with RG 1.189 and Nuclear Energy Institute (NEI) 00-01, Guidance for Post-Fire Safe Shutdown Analysis, Revision 2; and
- The adequacy of the licensees compensatory actions taken for identified non-compliances.
The inspectors reviewed a selected sample of the licensees post-fire safe shutdown analysis to verify that the licensee had identified both required and important circuits that could impact safe shutdown, entered the findings into the corrective action program, and initiated appropriate compensatory measures. The inspectors reviewed the LaSalles expert panel results for the potential fire-induced operations of component supported safe shutdown at LaSalle County Station. The expert panel performed this review in accordance with RG 1.189 and guidance provided in NEI 00-01. The purpose of the expert panel was to review the applicable industry developed generic boiling water reactor (BWR) owners group list of MSOs for applicability to LaSalle County Station.
The expert panel was also tasked with considering plant specific MSOs similar to those in the generic list, but not specifically listed. The expert panel identified MSOs as applicable to LaSalle County Station and provided recommendations to resolve these issues. The inspectors reviewed a sample of MSO scenarios identified by the expert panel as potential non-compliances requiring further evaluations to determine corrective action needed.
The licensee initiated several ARs to document the identified non-conforming MSO scenarios. In addition, the licensee implemented alternate compensatory measures as a form of enhanced documented operator rounds as justified by the fire protection engineering evaluation EC-379592, GL 86-10 Evaluation: Use of Alternate Compensatory Measures Related to Multiple Spurious Operations (MSOs), Revision 1.
The inspectors reviewed a sample of the non-conforming MSO scenarios identified by the licensee. The inspectors noted that the licensee has not completed the analyses and evaluations of the identified non-conforming MSOs. The licensee was in the process of determining the appropriate long term corrective actions needed to address these findings. The documents and ARs reviewed by the inspectors are listed in the to this report. The licensees plans to complete corrective actions to address the identified MSOs prior to November 2, 2012, (the end of the enforcement discretion period per EGM 09-002). The licensee evaluated the sample MSO scenarios for potential significance and determined that none of the sample MSOs were considered to be risk-significant.
b. Findings
No findings of significance were identified.
.7 Communications
a. Inspection Scope
The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.
The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.
b. Findings
No findings of significance were identified.
.8 Emergency Lighting
a. Inspection Scope
The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.
b. Findings
No findings of significance were identified.
.9 Cold Shutdown Repairs
a. Inspection Scope
The inspectors reviewed the licensees procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available on-site. The inspectors also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available on-site and properly staged.
b. Findings
No findings of significance were identified.
.10 Compensatory Measures
a. Inspection Scope
The inspectors conducted a review to verify 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 or electrical devices providing safe shutdown functions or capabilities). The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.
b. Findings
No findings of significance were identified.
.11 B.5.b Inspection Activities
a. Inspection Scope
The inspectors reviewed the licensees preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that:
- Procedures were being maintained and adequate;
- Equipment was properly staged, maintained, and tested;
- Station personnel were knowledgeable and could implement the procedures; and
- Additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b related equipment.
The inspectors reviewed the licensees B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction 2515/171 or subsequent performances of these inspections.
The B.5.b mitigating strategies selected for review during this inspection are listed below. The off-site and on-site communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of NEI 06-12, B.5.b Phase II and III Submittal Guidance, Revision 2, are evaluated each time due to the mitigation strategies scenario selected.
NEI 06-12, Revision 2, Licensee Strategy Section 2.3.1 SFP Makeup - External Strategy 3.4.2 DC Power Supplies to Allow Depressurization of RPVandInjection With Portable Pump
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The inspectors reviewed the licensees corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the fire protection program at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.
b. Findings
No findings of significance were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On November 18, 2011, the inspectors presented the inspection results, to Mr. Karaba, and other members of the licensees staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- P. Karaba, Plant Manager
- E. Ballou, Engineering
- J. Bauer, Site Training Director
- W. Hilton, Engineering Manager
- J. Houston, Regulatory Assurance
- B. Houston, Maintenance Manager
- W. Keller, Engineering
- K. Lyons, Chemistry Manager
- T. Riddle, Engineering
- J. Vergara, Regulatory Assurance
- H. Vinyaed, Engineering Director
- K. Ihnen, Nuclear Oversight Manager
- J. Washko, Operations Director
- E. Zacharias, Engineering
Nuclear Regulatory Commission
- R. Daley, Chief, Engineering Branch 3
- R. Ruiz, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened, Closed, and Discussed
None Attachment