IR 05000454/2013008
| ML14009A367 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/09/2014 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Ronald Langstaff | |
| References | |
| IR-13-008 | |
| Download: ML14009A367 (19) | |
Text
ary 9, 2014
SUBJECT:
BYRON STATION, UNITS 1 AND 2, TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000454/2013008; 05000455/2013008
Dear Mr. Pacilio:
On December 13, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Fire Protection Inspection at your Byron Station. The enclosed inspection report documents the inspection results, which were discussed on December 13, 2013, with Mr. R. Kearney, Site Vice-President 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.
No findings were identified during this inspection.
In accordance with Title 10, Code of Federal Regulations (CFR), Section 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 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. 50-454; 50-455 License Nos. NPF-37; NPF-67
Enclosure:
Inspection Report 05000454/2013008; 05000455/2013008 w/Attachment: Supplemental Information
REGION III==
Docket No: 50-454; 50-455 License No: NPF-37; NPF-66 Report No: 05000454/2013008; 05000455/2013008 Licensee: Exelon Generation Company, LLC Facility: Byron Station Location: Byron, IL Dates: November 18, 2013 thru December 13, 2018 Inspectors: R. Langstaff, Senior Reactor Inspector (Lead)
M. Munir, Reactor Inspector R. Winter, Reactor Engineer Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY
IR 05000454/2013008, 05000455/2013008; 11/18/2013 - 12/13/2013; Byron Station, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection.
This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III 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 No findings 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, onsite 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 Title 10, Code of Federal Regulations (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 areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire areas 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 Description 2.1-0 Control Room 3.1-1 Unit 1 Cable Tunnel 3.2 A-1 Unit 1 Non-segregated Bus Duct Area 11.4-0 Auxiliary Building General Area 383 Feet - 0 Inches
.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 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 verified that the licensee performed a post-fire safe shutdown (SSD)analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the inspectors verified that the licensee's 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 inspectors' 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, and actuations resulting in flow diversion or loss of coolant events.
The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.
The inspectors 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. Additionally, the inspectors 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.
The inspectors verified for cables that are important to SSD, but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either: (1)determined that there is not a credible fire scenario (through fire modeling), (2)implemented feasible and reliable manual actions to assure SSD capability, or (3)performed a circuit fault analysis demonstrating no potential impact on SSD capability exists.
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 onsite. 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 onsite 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 Review and Documentation of Fire Protection Program Changes
a. Inspection Scope
The inspectors reviewed changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. 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.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The inspectors reviewed the licensee's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed. The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
b. Findings
No findings of significance were identified.
.13 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 (TI) 2515/171 or subsequent performances of these inspections.
The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of Nuclear Energy Institute (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 (Table)
Section 2.3.1 Spent Fuel Pool Makeup (A.2-2)2.3.2 Spent Fuel Pool Spray (A.2-3)
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
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 December 13, 2013, the inspectors presented the inspection results to Mr. R. Kearney, and other members of the licensee 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
- R. Kearney, Site Vice-President
- F. Beutler, Design Engineering
- T. Edwards, Fire Marshal
- J. Fiesel, Director, Maintenance
- E. Hernandez, Director, Engineering
- R. Lawlor, Superintendent, Shift Operations
- B. Ledger, Manager, Design Electrical Branch
- J. Martinez, Fire Protection System Manager
- K. McGuire, Manager, Balance of Plant Branch
- C. Pragman, Corporate Engineering
- M. Taylor, Corporate Engineering
- L. Wehner, Manager, Nuclear Oversight
Nuclear Regulatory Commission
- J. Robbins, Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None Attachment