IR 05000443/2005008
| ML052420525 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/30/2005 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Peschel J, St.Pierre G Florida Power & Light Energy Seabrook |
| References | |
| IR-05-008 | |
| Download: ML052420525 (21) | |
Text
ust 30, 2005
SUBJECT:
SEABROOK NUCLEAR POWER STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000443/2005008
Dear Mr. St. Pierre:
On July 29, 2005, the NRC completed a triennial fire protection team inspection at the Seabrook Nuclear Power Plant. The enclosed report documents the inspection findings which were discussed at an exit meeting on July 29, 2005, with Mr. J. Dent 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 purpose of the inspection was to evaluate your post-fire safe shutdown capability and fire protection program. 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 a violation 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 No. 50-443 License No. NPF-86 Enclosure: Inspection Report 05000443/2005008
Mr. Gene S
SUMMARY OF FINDINGS
IR 05000443/2005008; 07/11/2005 - 07/29/2005, Seabrook Nuclear Power Station; Triennial
Fire Protection Team Inspection.
The report covered a two-week triennial fire protection team inspection by three Region I specialist 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 team identified a finding regarding the adequacy of the licensees post-fire safe shutdown analysis. Specifically, the analysis was found to be incomplete in that it did not specify the time available for the implementation of safe shutdown procedure actions necessary to restore mitigating systems to operation following their loss due to a fire. These actions include timely restoration of reactor coolant system makeup, reactor coolant pump seal cooling and feedwater flow to the steam generators to ensure safe shutdown performance goals would be met during a post-fire safe shutdown. Additionally, time lines or validations had not been performed to establish the time necessary to perform time critical portions of the safe shutdown procedures.
The finding is more than minor because it is associated with the Mitigating Systems Cornerstone attribute of design control and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events. Specifically, the safe shutdown analysis did not ensure the availability and capability of credited safe shutdown systems was sufficient to ensure post-fire performance goals would be met. The finding was found to represent a low degradation, and as such was of very low safety significance in accordance with the Fire Protection Significance Determination Process (NRC Inspection Manual Chapter 609, Appendix F). Specifically, timed walkdowns of procedures performed during the inspection indicated that, while plant parameters may not always be maintained within the safe shutdown goals, they would not deviate by an amount that would place the plant in an unrecoverable condition. The walkdown results were evaluated against estimated times available from related accident analyses, probabilistic risk assessment (PRA) studies and information from plants of similar designs.
(Section 1R05.01)
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 Florida Power and Light has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Seabrook nuclear power plant. Four plant areas that included the following fire areas (FAs), were selected for detailed review based on risk insights from the Seabrook Individual Plant Examination (IPE)/Individual Plant Examination of External Events (IPEEE):
C FA CB-F-1B-A C FA CB-F-2A-A C FAs ET-F-1C-A & ET-F-1D-A C FAs DG-F-1B-A , DG-F-2B-A, DG-F-3F-A, DG-F-3B-Z The inspection team evaluated the licensees fire protection program (FPP) against applicable requirements which include plant Technical Specifications, Operating License Condition 2.F, NRC Safety Evaluations, 10 CFR 50.48 and 10 CFR 50 Appendix R. The team also reviewed related documents that include the Updated Final Safety Analysis Report Section 9.5.1, the Fire Hazards Analysis 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 UFSAR 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, restoration of reactor coolant pump seal cooling, establishing reactor coolant makeup using the charging systems and establishing decay heat removal.
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
C OS1200.00, Response to Fire or Fire Alarm Actuation, Rev. 11, Chg. 02 C OS1200.00A, Fire Hazards Analysis For Affected Area/Zone - Appendix A.
Rev. 09 C OS1200.01, Safe Shutdown and Cooldown From The Main Control Room, Rev. 09, Chg. 01 C OS1200.02, Safe Shutdown and Cooldown From The Remote Safe Shutdown Facilities, Rev. 09, Chg. 01 C OS1200.02A, Safe Shutdown and Cooldown From The Remote Safe Shutdown Facilities - Train A, Rev. 09 C OS1200.02B, Safe Shutdown and Cooldown From The Remote Safe Shutdown Facilities - Train B, Rev. 09 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
Introduction.
The inspectors identified a Green finding regarding the adequacy of the licensees post-fire safe shutdown analysis.
Description.
The post-fire safe shutdown analysis was found to be inadequate in that it did not document the time available for the implementation of safe shutdown procedure actions necessary to restore mitigating systems to operation following their loss due to a fire. These actions include timely restoration of reactor coolant system makeup, reactor coolant pump seal cooling and feedwater flow to the steam generators to ensure safe shutdown performance goals would be met during a post-fire safe shutdown.
Additionally, SSD procedure time lines had not been developed nor had procedure time validations been performed to establish the time necessary to perform time critical portions of the safe shutdown procedures.
Analysis.
Section 2.4 of Branch Technical Position (BTP) SPLB 9.5.1, Guidelines for Fire Protection For Nuclear Power Plants, states that alternate or dedicated shutdown may require manual actions required to be taken from remote operating stations, local panels, and/or individual equipment locations. The BTP also specifies that the analysis must demonstrate that the manual actions are sufficient to achieve the safe shutdown functions and can be performed within the time constraints necessary to ensure the safe shutdown performance objectives are met. The performance deficiency was that analysis did not establish plant specific times that would be available to complete time critical actions nor were any timed walkthroughs documented or time lines developed to establish the time necessary to perform time critical portions of the safe shutdown operating procedures.
The finding is more than minor because it is associated with the Mitigating Systems Cornerstone attribute of design control and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events. Preliminary time lines were developed through the performance of procedure walkdowns during the inspection and the results were compared to estimated times that would be available (estimated times based on related accident analyses, PRA studies and generic information available for similar plant designs). The results of these comparisons indicated that, when using the most limiting fire scenario assumptions, it could be challenging for the operators to maintain plant parameters within the safe shutdown performance goals. However, potential deviations from the goals would not be expected to be significant enough to result in the plant being in an unrecoverable condition. As a result, this finding was determined to be a safe shutdown issue that would be assigned a low degradation rating in accordance with NRC Manual Chapter 609, Significance Determination Process, Appendix F, Fire Protection, and screened to Green in step 1.3.1. (FIN 05000443/2005-08-01) Time Critical Operator Actions Not Included in the Safe Shutdown Analysis
Enforcement.
No violation of regulatory requirements occurred.
.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 Section III.G of 10 CFR 50 Appendix R (or the UFSAR for SRP plants) 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 FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
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)to ensure they were appropriate for the fire hazards in the area. (No electrical raceway fire barriers were utilized in the areas inspected.)
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.
b. Findings
No findings of significance were identified.
.04 Active Fire Protection
a. Inspection Scope
The team reviewed the design, maintenance, testing and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested and maintained in accordance with the NFPA code of record, or as NRC approved deviations, 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 was 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/or CO2 storage tanks and supply system) and 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, 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
No findings of significance were identified.
.05 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
C 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; C 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).
C 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 reviewed 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.
The team also reviewed cable raceway drawings and routing lists for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.
Cable failure modes were reviewed for the following components:
C RC-PCV-456A, -B Power Operated Relief Valves (PORVs)
C RC-V-122, -124 PORV Isolation Valves C CS-V-168 RCP Seal Water Isolation Valve C CS-V-175 Excess Letdown Isolation Valve C RC-V-87, -88 RHR Inlet Isolation Valves C RC-FV-2881 Head Vent Valve C RC-V-323 Head Vent Isolation 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 and 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. 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, and in specified locations permanent essential lighting, 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 vendor manuals 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 dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The inspectors verified that the repair equipment, components, tools and materials (e.g., precut cables with prepared attachment lugs) were available and accessible onsite. Repair procedures reviewed included LS0565.06, Temporary Power Modification for RHR Loop Isolation Valves, Rev. 01, Chg. 01.
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 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.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. J. Dent, Assistant Plant Manager, and other members of the site staff at an exit meeting on July 29, 2005. No proprietary information was included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Conti, Operations
- J. Dent, Jr., Assistant Plant Manager
- R. N. Douceur, Regulatory Compliance
- R. Faix, Engineering
- R. Jamison, Engineering
- D. Kelly, Operations
- M. OKeefe, Regulatory Compliance
- E. Trump, Engineering
- P. Tutinas, Engineering
NRC
- J. Rogge, Chief, Electrical and Fire Protection Branch, Division of Reactor Safety
- G. Dentel, Senior Resident Inspector, Seabrook Nuclear Power Station
- S. Shaffer, Resident Inspector, Seabrook Nuclear Power Station
LIST OF ITEMS
OPENED & CLOSED Open and
Closed
- 05000443/2005008-01 FIN Time Critical Operator Actions Not Included in the Safe Shutdown Analysis