IR 05000440/2003008
| ML040160041 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/15/2004 |
| From: | Julio Lara NRC/RGN-III/DRS/EEB |
| To: | Kanda W FirstEnergy Nuclear Operating Co |
| References | |
| IR-03-008 | |
| Download: ML040160041 (37) | |
Text
ary 15, 2004
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT 1 FIRE PROTECTION TRIENNIAL BASELINE INSPECTION NRC INSPECTION REPORT 05000440/2003008(DRS)
Dear Mr. Kanda:
On December 5, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Perry Nuclear Power Plant, Unit 1. The enclosed report documents the inspection findings which were discussed on December 5, 2003, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to 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 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Document Access and Management 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/
Julio F. Lara, Chief Electrical Engineering Branch Division of Reactor Safety Docket No. 50-440 License No. NPF-58 Enclosure: Inspection Report 05000440/2003008(DRS)
w/Attachment: Supplemental Information See Attached Distribution
January 15, 2004 Mr. William
SUMMARY OF FINDINGS
IR 05000440/2003008(DRS); 11/17/03 - 12/05/03; Perry Nuclear Power Plant, Unit 1; Fire
Protection Triennial Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. No findings of significance were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
No findings of significance were identified.
Cornerstone: Mitigating Systems
No findings of significance were identified.
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
Summary of Plant Status
Unit 1 operated at or near full power throughout the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of this inspection was to review the Perry Nuclear Power Plants (PNPPs)
Fire Protection Program (FPP) for selected risk-significant fire areas. Emphasis was placed on verifying 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 inspection was performed in accordance with the Nuclear Regulatory Commissions (NRCs) new regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The inspectors used the Perry Nuclear Power Plants Individual Plant Examination of External Events (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire areas chosen for review during this inspection were:
Fire Area Description of Fire Area Reviewed DG-1d Diesel Generator Building Hallway (Elevation 620' - 6" and 646' - 6")
1CC-3c Division 1 Switchgear Room (Elevation 620' - 6")
1CC-3d Remote Shutdown Panel (Control Complex, Elevation 620' - 6") and 1DG-1c Division 1 Diesel Generator Building (Elevation 620' - 6" and 646' - 6")
For each of these fire areas, the inspection focused on the fire protection features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of licensee commitments, and changes to the FPP.
.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
The guidelines established by Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1, Section C.5.b, Safe Shutdown Capability, paragraph (1),required the licensee to provide fire protection features that were capable of limiting fire damage to structures, systems, and components (SSCs) important to safe shutdown.
The SSCs that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features that were capable of limiting fire damage to the SSCs so that:
- One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) was free of fire damage; and
- Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
a. Inspection Scope
The inspectors reviewed the plant systems required to achieve and maintain post-fire safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for each fire area selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included the fire protection safe shutdown analysis.
The inspectors also reviewed the operators ability to perform the necessary manual actions for achieving safe shutdown by reviewing procedures, the accessibility of safe shutdown equipment, and the available time for performing the actions.
The inspectors reviewed the PNPPs Updated Safety Analysis Report (USAR) and the licensees engineering and/or licensing justifications (e.g., NRC guidance documents, license amendments, technical specifications, safety evaluation reports, exemptions, and deviations) to determine the licensing basis.
A comparison of the safe shutdown component assets found in the Safe Shutdown Capability Report (SSCR) to plant Piping and Instrumentation Drawings (P&IDs) was made by the inspection team. On a sample basis, the inspection team verified that components having the potential to impact operation were properly analyzed in the SSCR.
b. Findings
No findings of significance were identified.
.2 Fire Protection of Safe Shutdown Capability
The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraphs (2)(a) and (3), required separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. If the guidelines cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.
a. Inspection Scope
For each of the selected fire areas, the inspectors reviewed the licensees Safe Shutdown Analysis (SSA) to ensure that at least one post-fire safe shutdown success path was available in the event of a fire. This included a review of manual actions required to achieve and maintain hot shutdown conditions and to make the necessary repairs to reach cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The inspectors also reviewed procedures to verify that adequate direction was provided to operators to perform these manual actions. Factors such as timing, access to the equipment, and the availability of procedures, were considered in the review.
The inspectors also evaluated the adequacy of fire suppression and detection systems, fire area barriers, penetration seals, and fire doors to ensure that at least one train of safe shutdown equipment was free of fire damage. To accomplish this, the inspectors observed the material condition and configuration of the installed fire detection and suppression systems, fire barriers, construction details, and supporting fire tests for the installed fire barriers. In addition, the inspectors reviewed licensee documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, Fire Hazard Analysis (FHA) reports, SSA, and National Fire Protection Association (NFPA) codes to verify that the fire barrier installations met license commitments.
b. Findings
No findings of significance were identified.
.3 Post-Fire Safe Shutdown Circuit Analysis
The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1), required that SSCs important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Options for providing this level of fire protection were delineated in BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (2). Where the protection of systems whose function was required for hot shutdown did not satisfy BTP CMEB 9.5-1, Section C.5.b, Paragraph (2), an alternative or dedicated shutdown capability and its associated circuits, were required to be provided that was independent of the cables, systems, and components in the area. For such areas, BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (3),specifically required the alternative or dedicated shutdown capability to be physically and electrically independent of the specific fire areas and capable of accommodating post-fire conditions where offsite power was available and where offsite power was not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
a. Inspection Scope
The inspectors performed a review of the licensees SSA and Safe Shutdown Equipment List (SSEL) to determine whether the licensee had appropriately identified and analyzed the safety related and non-safety related cables associated with safe shutdown equipment located in the selected plant fire zones. The inspectors review included the assessment of the licensee's electrical systems and electrical circuit analyses.
A sample of safety and non-safety related cables for equipment in the selected fire areas were evaluated to determine if the design requirements of Section III.G of Appendix R to 10 CFR Part 50 are being met. This included verifying that the licensee ensured that hot shorts, open circuits, or shorts to ground would not prevent implementation of safe shutdown.
b. Findings
No findings of significance were identified.
.4 Alternative Shutdown Capability
The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1), required the licensee to provide fire protection features that were capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Specific design features for ensuring this capability were provided in BTP CMEB 9.5-1, Section C.5.b, Paragraph (2). Where compliance with the separation criteria of BTP CMEB 9.5-1, Section C.5.b, Paragraphs
- (1) and
- (2) could not be met, BTP CMEB 9.5-1, Section C.5.b, Paragraph
- (3) and Section C.5.c, required an alternative or dedicated shutdown capability be provided that was independent of the specific fire area under consideration. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those predicted for a loss of normal AC power, and the fission product boundary integrity must not be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).
a. Inspection Scope
The inspectors reviewed the licensees systems required to achieve 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.
b. Findings
No findings of significance were identified.
.5 Operational Implementation of Alternate Shutdown Capability
a. Inspection Scope
The inspectors performed a review of the licensees operating procedures, which augment the post safe shutdown procedures. The review focused on ensuring that all required functions for post-fire safe shutdown and the corresponding equipment necessary to perform those functions were included in the procedures. The review also looked at operator procedural training, as well as consistency between the operations shutdown procedures and any associated administrative controls.
b. Findings
No findings of significance were identified.
.6 Communications
The guidelines established by BTP CMEB 9.5-1, Section C.5.g, Lighting and Communication, Paragraph (4), required that a portable communications system be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of the plant security force. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage.
a. Inspection Scope
The inspectors reviewed the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors also conducted a review to verify that sufficient channels were available to support safe shutdown implementation and that repeaters were powered by an emergency power source.
b. Findings
No findings of significance were identified.
.7 Emergency Lighting
The guidelines established by BTP CMEB 9.5-1, Section C.5.g, Lighting and Communication, Paragraph (1), required that fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual eight-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas.
a. Inspection Scope
The inspectors performed a walkdown of the fire areas and the access/egress routes to verify that adequate emergency lighting existed.
b. Findings
No findings of significance were identified.
.8 Cold Shutdown Repairs
The guidelines established by BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (5), required that equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available onsite, and procedures shall be in effect to implement such repairs.
a. Inspection Scope
The team reviewed licensees procedures to determine if any repairs were required to achieve cold shutdown. The team determined that the licensee did require repair of some equipment to reach cold shutdown based on the safe shutdown methods used.
b. Findings
No findings of significance were identified.
.9 Fire Barriers and Fire Zone/Room Penetration Seals
The guidelines established by BTP CMEB 9.5-1, Section C.5.a, Building Design, Paragraph (3), required that penetration seal designs be qualified by tests that are comparable to tests used to rate fire barriers.
a. Inspection Scope
The inspectors reviewed the test reports for 3-hour rated barriers installed in the plant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with tested configuration. In addition, the inspectors reviewed the fire loading for selected areas to ensure that existing barriers would not be challenged by a potential fire.
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems, Features and Equipment
The guidelines established by BTP CMEB 9.5-1 required that fire protection systems, features and equipment, specifically the passive fire protection features and fire detection system, were designed in accordance with Sections C.5.a and C.6.a.
a. Inspection Scope
The inspectors reviewed the material condition, operations lineup, operational effectiveness, and design of fire detection systems, fire suppression systems, manual fire fighting equipment, fire brigade capability, and passive fire protection features. The inspectors reviewed deviations, detector placement drawings, fire hose station drawings, carbon dioxide system pre-operational test reports, and fire hazard analysis reports to ensure that selected fire detection systems, sprinkler systems, portable fire extinguishers, and hose stations were installed in accordance with their design, and that their design was adequate given the current equipment layout and plant configuration.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The inspectors conducted a review to verify that adequate compensatory measures were put in place by the licensee for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features. The inspectors also reviewed 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.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed the corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to fire protection at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, work orders, design packages, and fire protection system non-conformance documents.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Kanda and other members of licensee management at the conclusion of the inspection on December 5, 2003. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
No interim exits were conducted.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- P. Chatterjee, Design Engineering
- J. Eck, Plant Operations
- J. Ford, Design Engineering
- H. Hegrat, Quality Assessment Manager
- W. Kanda, Site Vice President
- R. Kearney, Operations Manager
- T. Lentz, Engineering Director
- M. Makar, Design Engineering
- L. McGuire, Design Engineering
- J. McHugh, Fire Protection
- T. Rausch, Plant Manager
- K. Russell, Regulatory Affairs
- M. Saric, System Engineering
- S. Solhdoost, Design Engineering
- B. Swartz, Plant Systems Engineering
- J. Zarea, Design Engineering
Nuclear Regulatory Commission
- R. Powell, Senior Resident Inspector
- J. Ellegood, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Closed
None.
Discussed
None.
A1 Attachment