IR 05000461/2005006
| ML051820113 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/30/2005 |
| From: | Julio Lara Division of Reactor Safety III |
| To: | Crane C Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-05-006 | |
| Download: ML051820113 (28) | |
Text
une 30, 2005
SUBJECT:
CLINTON POWER STATION FIRE PROTECTION TRIENNIAL BASELINE INSPECTION NRC INSPECTION REPORT 05000461/2005006(DRS)
Dear Mr. Crane:
On May 20, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Clinton Power Station. The enclosed report documents the inspection findings which were discussed on May 20, 2005, with Mr. R. Bement 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 team 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 2.390 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 (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/
Julio F. Lara, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-461 License No. NPF-62 Enclosure: Inspection Report 05000461/2005006(DRS)
w/Attachment: Supplemental Information cc w/encl: Site Vice President - Clinton Power Station Plant Manager - Clinton Power Station Regulatory Assurance Manager - Clinton Power Station Chief Operating Officer Senior Vice President - Nuclear Services Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Manager Licensing - Clinton Power Station Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing
SUMMARY OF FINDINGS
IR 05000461/2005006(DRS); 05/02/2005 - 05/20/2005; Clinton Power Station; Triennial Fire
Protection Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. 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
The unit 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 Clinton Power Stations (CPSs) Fire Protection Program (FPP) for selected risk-significant fire areas. 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 the Nuclear Regulatory Commissions (NRCs) regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The team used the CPSs Individual Plant Examination of External Events (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire zones chosen for review during this inspection were:
Fire Areas Fire Zones Description F-1 F-1m Fuel Building - General Access Area at Elevation 737'-0" CB-5 CB-5a Div. 3 Switchgear Room at Elev. 781'0" CB-6 CB-6a Main Control Room Complex at Elev. 800'0" For each of these fire zones, 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 />.
General Description of Clintons Safe Shutdown Paths and Capability The licensees safe shutdown methodology relied upon the identification of those components necessary and available to achieve and maintain hot shutdown conditions following a fire condition. Once identified for all plant areas, the licensee selected the components necessary to achieve and maintain the reactor in a hot shutdown condition which could be operated from the main control room or which could be operated locally and were not within the fire affected area. The methodology further identified those components necessary to achieve and maintain cold shutdown.
The licensee also identified an alternate or dedicated shutdown capability for fire conditions that affected the main control room and several other areas, including the auxiliary electric equipment room. For each of these areas, the licensee relied upon the operators use of the remote shutdown panel to ensure that the reactor could be brought to and maintained in a hot shutdown status.
To direct the plant staffs response to fire conditions throughout the plant, the licensee relied upon the operators use of a single fire response operating procedure in conjunction with other non-fire specific plant procedures. The fire response operating procedure provided the main control room staff with information as to the possible impacts of a fire condition in each of the identified plant areas and those actions necessary to minimize the impacts of potential spurious equipment operations.
Expected local equipment operations were also identified in the fire response operating procedure.
a. Inspection Scope
The team 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 zone 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 CPS fire protection Safe Shutdown Analysis (SSA, USAR Appendix F) and the Fire Protection Evaluation Report (FPER, USAR Appendix E).
The team 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 team reviewed the 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.
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 zones, the team reviewed the licensees SSA to ensure that at least one post-fire safe shutdown success path was available in the event of a fire in accordance with the criteria discussed above. 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-hours. The team also reviewed procedures to determine whether or not 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 team 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 team examined 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 team reviewed license documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, the FHA report, the SSA report, 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-hours.
a. Inspection Scope
On a sample bases, the team reviewed the adequacy of separation provided for the power, control, and instrumentation cabling of redundant trains of shutdown equipment.
This inspection focused on the cabling of selected components in systems important for safe shutdown. The teams review also included a sampling of components whose inadvertent operation due to fire may adversely affect post-fire safe shutdown capability.
The purpose of this review was to determine if a single exposure fire, in one of the fire areas selected for this inspection, could prevent the proper operation of both safe shutdown trains.
The team reviewed electrical coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted by improper coordination. The team reviewed fuse/breaker coordination analysis for selected 4.16 kV, 480 Vac, vital 120 Vac, and 125 Vdc components required for post-fire safe shutdown. The purpose of this review was to verify that selective coordination exists between branch circuit protective devices (i.e., fuses, breakers) and the bus feeder protective devices to ensure that in the event of a fire-induced short circuit, the fault is isolated before the feeder device trips. In addition, a review of the licensees fuse replacement procedure and an inspection of a sample of field installed fuses was conducted to determine if adequate administrative controls exist to prevent the inadvertent substitution of incorrectly sized fuses in critical circuits. Additionally, the team reviewed a sample of circuit breaker maintenance procedures and testing records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.
The team performed a review of the licensees SSA, Safe Shutdown Equipment List (SSEL), post fire safe shutdown criteria and compliance assessment calculations, safe shutdown flow diagrams and Piping and Instrumentation (P&I) diagrams 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 in accordance with the criteria discussed above. The team also reviewed cable routing for post-fire safe shutdown components to confirm that cables subject to fire damage in the selected fire areas were identified and adequately addressed. The team 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 teams review included the assessment of the licensee's electrical systems and electrical circuit analyses. The team evaluated a sample of safety and non-safety related cables for equipment in the selected fire zones to determine if the design requirements of Section III.G of 10 CFR Part 50, Appendix R were being met. This included evaluation of potential hot shorts, open circuits, or shorts to ground to ensure that they would not prevent implementation of safe shutdown. The team 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
Postulated Fire-Induced Circuit Failures Resulting in Potential Spurious Actuation of Division III High Pressure Core Spray (HPCS) Pump 1E22-C001 and Discharge Valve 1E22-F004:
Introduction:
The team identified an Unresolved Item (URI) associated with potential fire-induced electrical circuit failures in the HPCS system. The team postulated a fire in the Division III switchgear room, located in Fire Zone CB-5a, which could result in fire-induced electrical circuit faults in the control cables and control logic of the HPCS pump and discharge valve. Such faults could potentially impair the capability to shut off the pump and stop it from continually injecting into the core.
Description:
The team reviewed the methodology used by the licensee during the performance of Clintons post-fire safe shutdown circuit analysis to determine if it was consistent with NRC Regulatory Issue Summary (RIS) 2004-003, Revision 1, Risk-Informed Approach for Post-Fire Safe-Shutdown Circuit Inspections, issued on December 29, 2004. The team attempted to determine, based on available safe shutdown circuit analysis documentation (calculations, design drawings) used to perform the circuit analyses, if the licensee considered in their analysis circuit configuration failure scenarios such as multiple concurrent spurious component actuations due to fire induced cable shorts. The licensee stated that the fire induced cable failure mechanism was considered within the CPS Appendix R analysis, and therefore exceeded the RIS cable failure considerations. The team performed a sample review of post-fire safe shutdown circuit analysis, using the guidance and criteria provided in the RIS.
The licensee documented in calculation IP-0532, 10 CFR Part 50, Appendix R, Compliance Assessment, that any and all spurious operations or failures shall be evaluated and that the spurious actuations or failures are not required at the time to be evaluated simultaneously except for high/low pressure interface components. However, the licensee stated that they did consider the potential for concurrent/simultaneous spurious actuations or failures in the Appendix R analysis for the ECCS system automatic initiation instrumentation logic network as well as the high/low pressure interface components.
The team noted that no documentation was available for review to demonstrate that the licensee had evaluated the potential fire induced electrical circuit failures scenarios, postulated by the team, in the HPCS logic control system. The team evaluated fire induced circuit failures in the HPCS system that could potentially impact safe shutdown.
The team selected HPCS pump 1E22-C001 and pump discharge valve 1E22-F004 logic circuitry and associated control cables for evaluation. The team reviewed licensing and design basis documents and related operating, emergency and shutdown procedures.
The team performed a circuit analysis and evaluation using the following design drawings to determine CPSs compliance with their licensing basis and the approved fire protection program:
- E02-1HP99, Sheet 110, Schematic Diagram, High Pressure Core Spray (HP)
HPCS Power Supply System (1E22-1070), Revision H;
- E02-1HP99, Sheet 501, Schematic Diagram, High Pressure Core Spray (HP)
HPCS Suction Valve (1E22-F001) and HPCS Suct. Disc. Valve 1E22-F004, Revision J;
- E02-1AP03, Electrical Loading Diagram, Revision AA;
- M05-1074, P&ID High Pressure Core Spray (HP), Revision AG;
- CPS-SSD-LOG-217, Sheet 1, Division 3 Diesel Generator & Electrical Distribution Safe Shutdown Logic Diagram, Revision 2; and
- CPS-SSD-LOG-101, Sheet 1, High Pressure Core Spray Safe Shutdown Logic Diagram, Revision 2.
The team conducted an evaluation of the impact of fire induced faults on HPCS system operation. The team postulated the following fire induced electrical faults, using guidance provided in the RIS, which could result in the HPCS discharge valve opening and the HPCS pump continually running and injecting water into the Reactor:
HPCS Discharge Valve 1E22-F004 (Control Cable 1HP11C (12/c)): One hot short in the opening control logic circuitry of the valve, and one short to ground in the closing control logic circuitry of the valve.
HPCS Pump 1E22-C001 (Control Cable 1HP08C (15/c)): One hot short in the breaker closing control logic circuitry of the HPCS pump which will close the pump breaker and start the pump, and two shorts to ground in the tripping circuitry of the pump control logic which will result in a blown fuse, and prevent tripping of the pump breaker.
(Note that if the hot short stays in for 20 minutes then there is no need to postulate the faults in the tripping circuitry).
The team determined that no documented evidence was available to indicate that the licensee considered the potential hot shorts, shorts to ground and open circuits, postulated by the team, in the multiconductor control cables used in the control system of HPCS pump 1E22-C001 (15/c) and pump discharge valve 1E22-F004 (12/c).
On June 8, 2005, the licensee, RIII, and NRR fire protection staff members conducted a conference call to further discuss the concerns raised by the team. The NRC requested that the licensee evaluate the postulated scenarios provided by the team and determine if CPS can achieve and maintain safe shutdown in Fire-Zone CB-5a if HPCS injection can not be stopped and if CPS is within their licensing basis considering the electrical faults and fire induced actuations of HPCS components. The licensee provided their response to the NRC on June 20, 2005. The licensee entered this issue in their corrective action program under CR 00343489, dated June 13, 2005. This issue is considered an unresolved item (URI) pending NRC review of the licensees response to the issues raised by the team (URI 05000461/2005006-01).
.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-hours 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 alternating current 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 team 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 in accordance with the criteria discussed above. The team 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 reviewed the electrical isolation capability of selected equipment needed for post-fire safe shutdown to ensure that such equipment could be operated from the alternate shutdown panel or locally, if needed. The team also reviewed surveillance test procedures and test records for the alternate shutdown panel control transfer switches and alternate power supplies, to ensure that functionality of the transfer switches and alternate power sources were adequately demonstrated. This was done to ensure that an alternate or dedicated shutdown capability was provided that was independent of the specific fire area under consideration and that was capable of limiting fire damage so that one train remained free of fire damage and must be able to achieve and maintain safe shutdown conditions.
b. Findings
No findings of significance were identified.
.5 Operational Implementation of Alternate Shutdown Capability
The guidelines established by BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (2)(d), required that the process monitoring function should be capable of providing direct readings of the process variables necessary to perform and control the functions necessary to achieve reactivity control, reactor coolant makeup, and decay heat removal.
a. Inspection Scope
The team performed a walkdown of a sample of the actions defined in Procedure CPS 4003-01, Remote Shutdown, which was the procedure for performing a plant alternative shutdown from outside the control room. The team verified that operators could reasonably be expected to perform the procedure actions within the identified applicable plant shutdown time requirements and that equipment labeling was consistent with the procedure.
The team performed a review of the licensees operating procedures, which augmented the post-fire safe shutdown procedures to determine if the licensee complied with the criteria discussed above. 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 training, as well as consistency between the operations shutdown procedures and any associated administrative controls.
The team reviews of the adequacy of communications and emergency lighting associated with these procedures are documented in Sections 1R05.6 and 1R05.7 of this report.
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 other plant personnel. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage.
a. Inspection Scope
The team reviewed the adequacy of the communication systems to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties to determine compliance.
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 8-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 zones.
a. Inspection Scope
The team performed a walkdown of selected fire zones and the access/egress routes to determine that adequate emergency lighting existed for performing necessary equipment operations in accordance with the criteria discussed above.
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-hours.
Materials for such repairs shall be readily available onsite, and procedures shall be in effect to implement such repairs.
a. Inspection Scope
The team determined that the licensee did not require repair of any 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 team 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 accordance with the criteria discussed above. In addition, the team reviewed the fire loading for selected areas to ensure that existing barriers would not be challenged by a potential fire.
The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries, fire doors, and fire dampers. The team reviewed engineering evaluations, as well as surveillance and functional test procedures for selected items. The team also reviewed the licensee submittals and NRC safety evaluation reports (SERs) associated with fire protection features at Clinton. Additionally, the team reviewed the design and qualification testing of selected barriers and reviewed surveillance procedures for structural fire barriers and penetration seals. The team also selectively verified through review of installation records that material of an approved fire resistance rating has been used to fill the penetration opening. These reviews were performed to ensure that the passive fire barriers were properly maintained and met the licensing and design bases as described in the licensee submittals, NRC SERs, the fire hazards analysis (FHA), and the Clinton Updated Safety Analysis Report (USAR).
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems, Features and Equipment
a. Inspection Scope
The guidelines established by BTP CMEB 9.5-1, required that fire protection systems, features, and equipment were designed in accordance with the following:
Fire Protection Systems, BTP CMEB 9.5-1 BTP CMEB 9.5-1 Features and Equipment Section Title Fire Brigade Capabilities C.3 Fire Brigade Passive Fire Protection C.5.a Building Design Features Fire Detection System C.6.a Fire Detection Fire Suppression System C.6.b Fire Protection Water Supply Systems C.6.c Water Sprinkler and Hose Standpipe Systems Manual Fire Fighting C.6.f and C.3 Portable Extinguishers and Equipment Fire Brigade
a. Inspection Scope
The team 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 team reviewed deviations, detector placement drawings, fire hose station drawings, 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 team conducted a review to determine 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 team 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
The guidelines established by BTP CMEB 9.5-1, Section C.4, Quality Assurance [QA]
Program, Paragraph H, required that measures should be established to ensure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformance, are promptly identified, reported, and corrected.
a. Inspection Scope
The team reviewed a selected sample of corrective action documents to assess whether or not the licensee was identifying issues related to fire protection at an appropriate threshold and entering them in the corrective action program for resolution. The team reviewed condition reports, work orders, design packages, and fire protection system non-conformance documents. The team also evaluated the effectiveness of the corrective actions for the identified issues.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The team presented the inspection results to Mr. R. S. Bement and other members of licensee management at the conclusion of the inspection on May 20, 2005, and during a subsequent telephone call with licensee representatives on June 29, 2005. The team asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Bement, Site Vice President
- M. McDowell, Plant Manager
- J. Cunningham, Work Management Director
- R. Frantz, Regulatory Assurance Representative
- M. Hiter, Access Control Supervisor
- W. Iliff, Regulatory Assurance Director
- J. Domitrovich, Maintenance Director
- D. Schavey, Operations Director
- T. Marini, Nuclear Oversight Manager (Acting)
- R. Weber, Sr. Manager Design Engineering
- K. Scott, Sr. Manager Plant Engineering
- C. Pragman, Corporate Fire Protection Engineer,
Nuclear Regulatory Commission
- R. Caniano, Deputy Division Director, Division of Reactor Safety
- D. Tharp, Resident Inspector
- B. Dixon, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000461/2005006-01 URI Evaluation of Fire Induced Circuit Failures in HPCS System Control Logic (Section 1R05.3)
Closed
None
Discussed
None A1 Attachment