IR 05000454/2007008
| ML080180426 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/18/2008 |
| From: | Julio Lara Engineering Branch 3 |
| To: | Pardee C Exelon Generation Co |
| References | |
| IR-07-008 | |
| Download: ML080180426 (23) | |
Text
January 18, 2008
SUBJECT:
BYRON STATION, UNITS 1 AND 2 FIRE PROTECTION TRIENNIAL BASELINE INSPECTION NRC INSPECTION REPORT 05000454/2007008(DRS);
Dear Mr. Pardee:
On December 7, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Byron Station, Units 1 and 2. The enclosed report documents the inspection results, which were discussed on December 7, 2007, with Mr. Mike Prospero and other members of your staff.
The fire protection triennial baseline inspection was conducted in accordance with NRC Inspection Procedure 71111.05T, Fire Protection (Triennial), dated April 21, 2006. The fire protection inspection team examined activities conducted under your license related to safety and to compliance with the Commissions rules and regulations, and the conditions of your license related to fire protection and post-fire safe shutdown. The inspection consisted of a selected examination of procedures and records, observations of activities and installed plant systems, and interviews with 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 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/
Julio F. Lara, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 Enclosure:
Inspection Report 05000454/2007008(DRS); 05000455/2007008(DRS)
w/Attachment: Supplemental Information
cc w/encl:
Site Vice President - Byron Station
Plant Manager - Byron Station
Regulatory Assurance Manager - Byron Station
Chief Operating Officer and Senior Vice President
Senior Vice President - Midwest Operations
Senior Vice President - Operations Support
Vice President - Licensing and Regulatory Affairs
Director - Licensing and Regulatory Affairs
Manager Licensing - Braidwood, Byron, and LaSalle
Associate General Counsel
Document Control Desk - Licensing
Assistant Attorney General
Illinois Emergency Management Agency
State Liaison Officer, State of Illinois
State Liaison Officer, State of Wisconsin
Chairman, Illinois Commerce Commission
B. Quigley, Byron Station
SUMMARY OF FINDINGS
IR 05000454/2007008(DRS); 05000455/2007008(DRS); 11/13/2007 - 11/30/2007; Byron
Station, Units 1 and 2; Fire Protection Triennial Baseline Inspection.
This report covers an announced fire protection triennial baseline inspection. The inspection was conducted by Region III inspectors in accordance with the U. S. Nuclear Regulatory Commissions (NRCs) Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), dated April 21, 2006. Based on the results of this inspection, 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.
Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC describes its program for overseeing the safe operation of commercial nuclear power reactors in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events
No findings of significance were identified.
Cornerstone: Mitigating Systems
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; and
- 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.
The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants fire protection program and post-fire safe shutdown systems. 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 inspection was performed in accordance with U. S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial), dated April 21, 2006. The NRC regulatory oversight process IP used a risk-informed approach for selecting the fire areas and/or fire zones and attributes to be inspected. The inspectors with assistance from a senior reactor analyst used the licensees Individual Plant Examination for External Events (IPEEE) to select several risk-significant areas for detailed inspection and review. The fire areas and/or fire zones selected for review during this inspection are listed below and constitute four inspection samples.
Fire Fire Zone Description 3.3 B-2 Unit 2 Upper Cable Spreading Room 5.2-2 Unit 2 Division 21 ESF Switchgear Room 11.2-0 Unit 1 Auxiliary Building General Area Elevationation 346 ft-0 in.
11.6-0 Unit 2 Auxiliary Building General Area Elevationation 426 ft-0 in.
.1 Shutdown from Outside Main Control Room
a. Inspection Scope
The inspectors reviewed the functional requirements identified by the licensee as necessary for achieving and maintaining hot shutdown conditions to ensure that at least one post-fire safe shutdown success path was available in the event of fire in each of the selected fire areas and for alternative shutdown in the case of control room evacuation.
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 inventory makeup, reactor heat removal, process monitoring, and support system functions. The review also included the fire safe shutdown analysis to ensure that all required components in the selected systems were included in the licensees safe shutdown analysis.
The inspectors reviewed the licensees post-fire safe shutdown analysis, normal and abnormal operating procedures, piping and instrumentation drawings, electrical drawings, their updated final safety analysis report, 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.
The inspectors also examined the operators ability to perform the necessary manual actions for achieving safe shutdown by reviewing post-fire shutdown procedures, the accessibility of safe shutdown equipment, and the available time for performing the actions.
The inspectors reviewed the updated final safety analysis report 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
.
b. Findings
No findings of significance were identified.
.2 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 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 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.
.3 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 codes 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.
.4 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 the National Fire Protection Association codes to verify that fire suppression and detection systems met license commitments.
b. Findings
No findings of significance were identified.
.5 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 Elevationations, and spray protection.
b. Findings
No findings of significance were identified.
.6 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 team 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
.7 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 that 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, on a sample basis, the adequacy of circuit protective coordination for the safe shutdown systems electrical power and instrumentation busses were evaluated.
Also, on a sample basis, a cable tray that contain both safe shutdown and non-safe shutdown cables was evaluated for proper circuit protection to ensure that cables are protected by a proper protective device in order to preclude common enclosure concerns.
b. Findings
No findings of significance were identified.
.8 Communications
a. Inspection Scope
The inspectors reviewed, on a sample bases, 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.
.9 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.
.10 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.
.11 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 on 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 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, work orders, design packages, and fire protection system non-conformance documents.
Findings
No findings of significance were identified.
4OA6 Management Meetings
.1
Exit Meeting Summary
On December 7, 2007, at the conclusion of the inspection, the inspectors presented the inspection results to Mr. Mike Prospero and other members of licensee management.
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
- F. Beutler, Design Engineering
- S. Chingo, Contractor
- J. Connelly, Design Engineering
- M. Denniston, Fire Marshall
- H. Goi, Design Engineering
- B. Grundmann, Regulatory Assurance Manager
- T. Hulbert, Regulatory Assurance
- H. Kats, System Engineering
- H. Madronero, Senior Manager Plant Engineering
- V. Naschansky, Electrical/IandC Design Manager
- G. ODonnell, System Engineering
- B. Perchiazzi, Design Engineering
- C. Pragman, Corporate Fire Protection Engineer
- M. Prospero, Operations Manager
- N. Rhoe, System Engineering
- S. Rhoe, Design Engineering
- D. Robinson, Contractor
- M. Shah, Design Engineering
- P. Shier, Design Engineering
- M. Taylor, Corporate Fire Protection Engineer
Nuclear Regulatory Commission
- B. Bartlett, Senior Resident Inspector
- R. Ng, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed and
Discussed
None