IR 05000387/2005009
| ML060120445 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/12/2006 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Mckinney B Susquehanna |
| References | |
| IR-05-009 | |
| Download: ML060120445 (23) | |
Text
ary 12, 2006
SUBJECT:
SUSQUEHANNA GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT NO. 05000387/2005009 AND 05000388/2005009
Dear Mr. McKinney:
On December 2, 2005, the NRC completed a triennial fire protection team inspection at the Susquehanna Steam Electric Station. The enclosed report documents the inspection findings which were discussed at an exit meeting on December 2, 2005, with you 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 inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, there was one NRC-identified finding of very low safety significance (Green), which did not involve violations of NRC requirements.
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 Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22 Enclosure: Inspection Report No. 05000387/2005009 and 05000388/2005009
Mr. Britt
SUMMARY OF FINDINGS
IR 05000387/2005009, 05000388/2005009; 11/14/2005 - 12/02/2005, Susquehanna Steam
Electric Station; Triennial Fire Protection Team Inspection, Fire Protection.
This report covered a two-week triennial fire protection team inspection by three Region I inspectors. One Green finding was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. 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
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green finding regarding the implementation of the fire brigade drill program. The finding involves practices that are not consistent with regulatory guidance (Branch Technical Position (BTP) SPLB 9.5.1and Regulatory Guide (RG) 1.189) and industry standards for the performance and crediting of fire brigade drills. Specifically, the program does not result in the five member, on-shift, fire brigade practicing as a team during drills and consequently does not allow for an effective assessment of the brigades performance during drills. In addition, two examples were identified where the licensee failed to implement specific drill program requirements. The licensee has entered these issues into their corrective action program for review and resolution.
The finding is more than minor because it affected the Protection Against External Factors attribute of the Mitigating Systems Cornerstone, in that it impacted manual fire suppression (fire brigade) capability; and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events. This finding has been reviewed by NRC management and is determined to be a finding of very low safety significance (Green).
(Section 1R05.04)
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 PPL Susquehanna, 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 Susquehanna Steam Electric Station facility. The following fire areas (FAs) were selected for detailed review based on risk insights from the SSES Individual Plant Examination (IPE)/Individual Plant Examination of External Events (IPEEE):
C FA CS-9 C FA CS-11 C FA CS-31 C FA D-1 C FA R-2H Section 71111.05-05 of the inspection procedure specifies a minimum sample size of three.
Inspection of these five areas fulfills the procedure completion criteria. The inspection team evaluated the licensees fire protection program (FPP) against applicable requirements which include plant Technical Specifications, Operating License Condition 2.C.(6), NRC Safety Evaluations, 10 CFR 50.48 and 10 CFR 50 Appendix R. The team also reviewed related documents that include the Fire Protection Review Report (FPRR) and the Post-Fire Safe Shutdown
Analysis.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems
1R05 Fire Protection
.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 FPRR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room 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 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 actions which were verified included restoration of AC electrical power, establishing reactor coolant makeup using the reactor core isolation cooling system and establishing decay heat removal.
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
C ON-013-001, Response to Fire, Rev. 16 C ON-100-009, Control Room Evacuation, Rev. 10 C ON-200-009, Control Room Evacuation, Rev. 11 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 fire hazards analysis, 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 FPRR 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 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 FPRR. 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.
The team 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.
.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 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
b. 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 NFPA code of record and that they would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of suppression agent delivery systems were verified to meet the code requirements for the fire hazards involved. The team also performed a walkdown of accessible portions of the detection and suppressions systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g., fire protection pumps, Halon and CO2 storage tanks and supply system) as 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 also assessed the fire brigade capabilities by reviewing training and qualification records 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. In addition, the team inspected the fire brigades protective ensembles, self-contained breathing apparatus (SCBA), and various fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.
b. Findings
Introduction.
The inspectors identified a Green finding regarding the implementation of the fire brigade drill program. The finding involves practices that are not consistent with regulatory guidance and industry standards for the performance and crediting of fire brigade drills. Specifically, the program does not result in the five member, on-shift, fire brigade practicing as a team during drills and consequently does not allow for an effective assessment of the brigades performance during drills. In addition, two examples were identified where the licensee failed to implement specific drill program requirements.
Description.
The five member fire brigade consists of four members from the operations department (including the brigade leader) and one member from the security department. The fire brigade leader is normally the field unit supervisor, an on-shift senior reactor operator outside of the control room. The licensees program requires that the operations department personnel qualified as fire brigade members participate in at least two drills per year. The program also specifies that the individuals from the security organization assigned to fire brigade duty at the time of a drill shall participate.
The inspectors reviewed the fire brigade training and qualification records, including Drill Critique and Training Roster Sheets, for the period of 2003 to 2005. The inspectors noted that, in addition to the assigned five on-shift fire brigade members, numerous other qualified fire brigade members report to the drill scene. The five responders that arrive at the dress out area first don protective equipment. The critique sheets typical list eight to ten, and at times, as many as 15, participants. The practice at SSES is that everyone that responds and participates receives credit for performing one of their required drills. The licensees program does not specify the level of participation necessary to receive credit for a drill. The team also found that the Fire Brigade Training Program, NTP-QA-53.1, allows a qualified fire brigade leader in the control room at the time of a drill to get credit of one fire drill per year. This credit is given even though the field supervisor actually directs the fire brigade during the drill and the control room operator is not a direct participant in the drill.
Two deviations from specific program requirements were identified:
- One of the fire brigade leaders participated in only one drill in 2004 and continued to perform fire brigade leader duties in 2005 without having participated in minimum two drills per year as required by the program to maintain his qualification.
- A review of 2005 drill critique forms showed that the security force brigade members generally arrived at the dress-out area after the operations personnel and that the security force member donned protective equipment in only four of nineteen drills. In two instances, May 10 and September 27, 2005, the drill sheets did not document any security members reporting to the dress-out location for participation in the drill as specified by the program.
Analysis.
Section 6.5 of Branch Technical Position (BTP) SPLB 9.5.1, Guidelines for Fire Protection For Nuclear Power Plants, states that personnel assigned to the fire brigade should be qualified, trained and equipped for firefighting in accordance with the guidelines in Regulatory Guide (RG) 1.189, Fire Protection For Operating Nuclear Power Plants. Section 3.5.1.4 of RG 1.189 states, in part, that fire brigade drills should be performed in the plant so that the fire brigade can practice as a team and that each member should participate in at least two drills per year. In addition the RG provides performance assessment attributes that should be evaluated during drills. The performance deficiency is that the program does not result in the on-shift brigade practicing as a team and does not allow an effective assessment of the performance of the shift brigade and fire brigade leader. The finding is more than minor because it affected the Protection Against External Factors attribute of the Mitigating Systems cornerstone, in that it impacted manual fire suppression (i.e., fire brigade) capability; and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events. The Significance Determination Process (SDP), Appendix F does not specifically address fire brigade issues and allows for management discretion to determine issue significance. This issue has been reviewed by NRC management and is determined to be a finding of very low safety significance (Green). This issue was acknowledged by SSES management and entered into the corrective action program (CRs 728295, 728936, 730852, 730944, and 730947). (FIN 05000387/2005-009-01; 05000388/2005-009-01) Fire Brigade Drill Program Not Consistent With Regulatory Guidance and Industry Standards
Enforcement.
The performance deficiency is the improper application of regulatory guidance and industry practices and therefore is documented as a finding. The specific examples of the licensee failing to implement the fire brigade drill program requirements were considered to be minor violations of the licensees program but were documented because they are relevant to the overall issue of drill program adequacy.
.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 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).
- 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 for the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.
.07 Circuit Analyses
a. Inspection Scope
The inspectors verified that the licensee 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 the licensees 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 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, multiple spurious actuations, actuations resulting in flow diversion or loss of coolant events. This review included the results of a recent self-assessment performed by the licensee and documented in calculation EC-013-1871, Circuit Analysis Assessment for NRC RIS 2004-03 Revision 1.
The team also reviewed information in the cable and raceway information management system (CRIMPS) for a sample of components, including a sample of instrumentation circuits, required for post-fire safe shutdown to verify that licensees program appropriately evaluated documented and the adequacy of cable routing as described in the cable routing matrices.
Cable failure modes were reviewed for the following components:
C HV-E11-2F009 RHR Shutdown Cooling Inboard Isolation Valve C HV-E11-2F008 RHR Outboard Shutdown Isolation Valve C HV-B21-1F001 Reactor Head Vent Valve C HV-B21-1F002 Reactor Head Vent Valve 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 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
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 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
The team verified that the licensee had evaluated the need for any 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 specific in their design and licensing bases. The team confirmed that the safe shutdown analysis for SSES did not identify any systems or components that would require repairs to achieve cold shutdown.
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.
OTHER ACTIVITIES
4OA2 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.
b. Findings
No findings of significance were identified. However, the inspectors reviewed the most recent Quality Assurance audit and Self-Assessment of the fire protection program.
They were generally thorough and critical with one exception; neither organization identified the fire brigade drill practice issues prior to this NRC inspection.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. B. McKinney, Chief Nuclear Officer, and other members of the site staff at an exit meeting on December 2, 2005. No proprietary information was included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Brophy, Licensing
- L. Casella, Station Engineering
- F. Czysz, Probablistic Risk Assessment
- S. Davis, Station Engineering
- T. Gorman, Fire Protection Project Manager
- F. Gruscavage, Station Engineering
- J. Krais, Design Engineering Manager
- Y. Lee, Quality Assurance Engineer
- M. Lichtner, Unit Supervisor
- B. McKinney, Chief Nuclear Officer
- F. Negvesky, Station Engineering
- D. Ritter, Station Engineering
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- B. Bickett, Senior Resident Inspector, Susquehanna Steam Electric Station
- F. Jaxheimer, Resident Inspector, Susquehanna Steam Electric Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Open and
Closed
- 05000387/2005009-01 FIN Fire Brigade Drill Program Not Consistent With Regulatory
- 05000388/2005009-01 Guidance and Industry Standards