ML11116A141
| ML11116A141 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/25/2011 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co |
| Loretta Sellers | |
| References | |
| IR-11-009 | |
| Download: ML11116A141 (24) | |
See also: IR 05000461/2011009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
April 25, 2011
Mr. Michael J. Pacilio
Site Vice-President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville IL 60555
SUBJECT: CLINTON POWER STATION FIRE PROTECTION TRIENNIAL BASELINE
INSPECTION NRC INSPECTION REPORT 05000461/2011009(DRS)
Dear Mr. Pacilio:
On March 18, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial
fire protection inspection at your Clinton Power Station (CPS). The enclosed inspection
report documents the inspection results, which were discussed on March 18, 2011, with
Mr. F. Kearney 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.
Based on the results of this inspection, one NRC-identified finding of very low safety
significance was identified. The finding involved a violation of NRC requirements. However,
because of the very low safety significance, and because the issue was entered into your
corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in
accordance with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the subject or severity of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with
a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III,
2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector
Office at Clinton Power Station. In addition, if you disagree with the cross-cutting aspect
assigned to any finding in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the Regional Administrator,
Region III, and the NRC Resident Inspector at Clinton Power Station.
M. Pacilio -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any), 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 No. 50-461
License No. NPF-62
Enclosure: Inspection Report 05000461/2011009
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-461
License No: NPF-62
Report No: 05000461/2011-009(DRS)
Licensee: Exelon Generation Company, LLC
Facility: Clinton Power Station
Location: Clinton, IL
Dates: February 16 through March 18, 2011
Inspectors: Z. Falevits, Senior Reactor Inspector, Lead
A. Dahbur, Senior Reactor Inspector
R. Winter, Senior Reactor Inspector
L. Kozak, Senior Reactor Analyst
Observers: J. Hafeez, Reactor Engineer in Training
Approved by: R. Daley, Chief
Engineering Branch 3
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000461/2011009(DRS); 02/16/2011 - 03/18/2011 Clinton Power Station, Routine Triennial
Fire Protection Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection
was conducted by Region III inspectors. One Green finding was identified by the inspectors.
The finding was considered a Non-Cited Violation (NCV) of NRC regulations. The significance
of most findings is indicated by their color (Green, White, Yellow, or 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 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.
A. NRC-Identified and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green. A finding of very low safety significance and associated NCV of Clinton Power
Station Unit 1 Operating License NPF-62, Section 2.F was identified by the inspectors
for the licensee's failure to ensure fire doors were closed and latched. Specifically,
during a walkdown of fire area CB-1e 737 General Access Area, fire door 1DR1-432
located between fire area CB-1e and D-6 Emergency Diesel 2 Room, was found
unlatched/not fully closed. The door was a 3-hour fire rated door credited for fire barrier
between the two fire areas. Site personnel closed the door when it was found open and
the door remained fully closed when challenged. The issue was entered into the
licensee corrective action program as AR 01187906.
The inspectors determined that this finding was more than minor because the finding
affected the Mitigating Systems cornerstone attributes of protection against external
factors (Fire) and affected the cornerstone objective of ensuring the capability of the
system to respond to events to prevent undesirable consequences. This finding
was of very low safety significance (Green) based on answering Yes to Question 7 of
Task 1.3.2. of Appendix F of IMC 0609. The inspectors did not identify a cross-cutting
aspect associated with this finding because the underlining cause of unlatched door was
indeterminate during the inspection. (Section 1R05.b(1))
B. Licensee-Identified Violation
No violations of significance were identified.
1 Enclosure
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection (71111.05T)
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) identify 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
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.
2 Enclosure
The fire areas/fire zones and B.5.b mitigating strategies selected for review during this
inspection are listed below and in Section 1R05.6. The fire areas/fire zones and B.5.b
mitigating strategies selected, constitute four inspection samples and four inspection
samples, respectively, as defined in Inspection Procedure 71111.05T.
Fire Zone Description
A-3f Division 2 Switchgear Room
CB-1e General Access Area
CB-2 Division 2 Cable Spreading Room
CB-3a Auxiliary Electrical Equipment Room
.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, updated final safety analysis report (UFSAR), and supporting
drawings and documentation to verify that safe shutdown capabilities were properly
protected.
The inspectors reviewed the licensees 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 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
3
Enclosure
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
1) Failure to Ensure Fire Door was Closed and Latched
Introduction: A finding of very low safety significance (Green) and associated NCV of
License Condition 2.F, Fire Protection, was identified by the inspectors for the licensee's
failure to ensure that fire door 1DR1-432, located between the Division 2 emergency
diesel generator (EDG) room (D 3-9) and control building corridor (D 3-13), was closed
and latched. The door provided a 3-hour fire barrier between these two separate fire
areas.
Description: On March 14, 2011, during a plant walkdown of the 737 Control Building,
General Access Area, fire door 1DR1-432 was observed not to be fully latched. When
noted, site personnel closed the door and the door remained closed/latched when it was
challenged. The door was a 3-hour fire rated door credited for fire barrier between the
two fire areas as discussed below.
Section 3.4.1.5 Fire Zone CB-1e; Elevation 737 and 751 General Access Area, of the
Appendix E of the fire protection report indicated that the portion of the south wall
adjacent to the diesel generators rooms were 3-hour fire rated. The zone included
Division 1 and 2 electrical cables and diesel generator associated motor control centers.
In the event of a fire in this fire zone, safe shutdown can be achieved using Method 2
and 3 as described in the safe shutdown analysis. An ionization fire detection system
and an automatic wet pipe sprinkler system were provided in this zone where cables for
both divisions were located.
Section 3.5.6.1 Fire Zone D-6a; Elevation 737 Division 2 Diesel Generator Room,
indicated that this zone housed the Division 2 diesel generator and its associated
support cables and equipment. Therefore, a fire in this zone may affect equipment relied
upon for method 2 safe shutdown due to fire damage. This fire zone was protected by
an automatic carbon dioxide (CO2) fire suppression system actuated by thermal
detectors.
The inspectors were concerned that with the door left unlatched, a fire could spread
between the two fire areas. The inspectors noticed that the licensee currently has an
open item in their corporate corrective action program to develop and implement a plan
to reinforce with site workers the need to challenge fire doors and write condition reports
if doors do not self close and latch.
4
Enclosure
On March 15, 2011, the inspectors questioned the licensee if a condition report was
written to document the issue related to the door being found open during the plant
walkdown on March 14, 2011. Subsequently, the licensee issued AR 01187906. The
inspectors were concerned that the licensee was not timely in entering this issue into
their corrective action program.
Procedure 9601.05 Visual Inspection of Closed Fire Doors, was last completed on
March 13, 2011, at which time door 1DR1-432 was verified closed and latched.
Analysis: The inspectors determined that the licensees failure to ensure a 3-hour fire
door was closed and latched was contrary to Licensee Condition 2.F. and was a
performance deficiency. The finding was determined to be more than minor because it
was associated with the Mitigating System cornerstone attribute of Protection Against
External Factors (Fire) and affected the cornerstone objective of ensuring the availability
of systems that respond to initiating events to prevent undesirable consequences (i.e.,
core damage). Specifically, the failure to ensure that a 3-hour rated fire door was closed
and latched between Fire Areas D-6 and CB-1e degraded the defense and depth
element of the fire protection program. In the event of a fire in the EDG room (Fire Area
D-6), the fire could spread to the control building corridor (CB-1e) and could have
complicated safe shutdown of the plant.
In accordance with IMC 0609, Significance Determination Process, Attachment
0609.04, Phase I - Initial Screening and Characterization of Findings, Tables 3b the
inspectors determined the finding degraded the fire protection defense-in-depth
strategies. Therefore, screening under IMC 0609, Appendix F, Fire Protection
Significance Determination Process, was required. Based on Table 1.1-1 of Appendix F
and Table A2.2 of Attachment 2 of Appendix F, the inspectors determined that the
finding affected the fire confinement category and the barrier was moderately degraded
because the door was not latched. Since the EDG room has a curb included in the wall
between the two fire areas that could contain the fuel oil available in the EDG, the
inspectors determined that in the event of a fire in the EDG room, the affect of a hot gas
layer was the only concern for the adjacent fire area CB-1e. The inspectors determined
that the finding was of very low safety significance (Green) because the inspectors
answered Yes to Question 7 of Task 1.3.2 Supplemental Screening for Fire
Confinement Findings. In addition, Table 2.3.2 of IMC 0609, Appendix F, showed that
for a 2MW fire in the EDG room, the zone of influence in the adjacent room (CB-1e) for
damage to thermoset cables was 13.3 feet in height and 6.7 feet in radial distance. The
Division 1 cables were located in cable trays and conduits installed near a wide ceiling
area in CB-1e; therefore, the cables of concern were outside the zone of influence and
would not be directly affected by a fire in the EDG room (Fire Area D-6). The inspectors
also determined that the finding only affected one of the defense-in-depth elements of
the fire protection program; because both fire areas had fully functional automatic fire
detection and suppression systems.
The licensee entered this issue into their corrective action program on March 15, 2011,
a day after the door was found unlatched and after the inspectors prompted the licensee
to issue a corrective action document. The inspectors did not identify a cross-cutting
aspect associated with this finding because the underlining cause of unlatched door was
indeterminate during the inspection.
5
Enclosure
Enforcement: Clinton Power Station Unit 1 Operating Licensee Condition 2.F.
required the licensee to implement and maintain in effect all provisions of the
approved fire protection program as described in the Final Safety Analysis Report
(UFSAR), as amended, and as approved in the Safety Evaluation Report (NUREG-
0853), dated February 1982 and Supplemented Numbers 1 through 8. The Clinton
Power Station UFSAR, Appendix E, Fire Protection Evaluation Report, Section 3.4.1.5,
Fire Zone CB-1e, stated, in part, that the portion of the south wall adjacent to the EDG
rooms is 3-hour fire rated. Section 3.1.2.2.9, Fire Doors, of Appendix E, stated, in part,
that access opening in the fire barrier walls is closed with fire rated doors or equivalent.
Contrary to the above, on March 14, 2011, the licensee failed to ensure that the 3-hour
fire rated door 1DR1-432, located in the portion of the south wall between the EDG room
(Fire Area D-6) and the control building corridor (Fire Area CB-1e) was closed and
latched. Because this violation was of a very-low-safety significance and because it was
entered into the licensees Corrective Action Program as AR 01187906, this violation is
being treated as an NCV, consistent with Section 2.3.2 of the NRC enforcement policy.
(NCV 05000461/2011009-01, Failure to ensure fire door was closed and latched)
.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 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 were identified.
6
Enclosure
.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 were identified.
.6 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
whether 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, the adequacy of circuit protective coordination for the safe shutdown
systems electrical power and instrumentation busses was evaluated. The inspectors
also evaluated cable trays that contained both safe shutdown and non-safe shutdown
cables for proper circuit protection to ensure that cables were protected by a proper
protective device in order to preclude common enclosure concerns.
1) Review of Licensees Multiple Spurious Operations (MSOs) Circuit Analyses In
Accordance with Guidance in Regulatory Guide 1.189, Revision 2
Background
In October 2009 the NRC issued guidance in Regulatory Guide 1.189, Fire Protection
for Nuclear Power Plant, Revision 2, to identify acceptable methods for resolving issues
7
Enclosure
related to circuits required for post-fire safe shutdown and circuits important to post-fire
safe shutdown. Equipment required for post-fire safe shutdown (credited train) must use
one of the three methods identified in 10 CFR Part 50, Appendix R, Section III.G.2 to
protect the circuits located within the same fire area from damage, including single and
multiple spurious operations (MSOs). For important to post-fire safe shutdown circuits,
the licensee may use operator manual actions if the licensee demonstrates they can be
shown to be feasible and reliable or resolve issues using other analysis methods
including fire modeling.
In May 2009, the NRC issued Enforcement Guidance Memorandum 09-002,
Enforcement Discretion for Fire-Induced Circuit Faults, which described the conditions
limiting enforcement discretion during the resolution of the fire protection concerns
involving MSOs. The EGM limited the enforcement discretion to three years from the
date of issuance of RG 1.189, Revision 2: (1) six months following the issuance of
RG 1.189, Revision 2, for licensees to identify non-compliances related to multiple fire-
induced circuit faults, place the non-compliances into their corrective action program and
implement compensatory measures for the non-compliances and (2) three years
following the issuance of RG 1.189, Revision 2, for licensees to complete the corrective
actions associated with non-compliant multiple fire-induced circuit faults. The
enforcement discretion would not be granted to identified non-compliances that are
found to be willful or findings that the Reactor Oversight Process Significant
Determination Process would evaluate as (Red) or categorized at Severity Level I.
Inspection Effort
During this inspection, the inspectors reviewed representative sampling of single and
multiple spurious issues throughout the plant to verify:
- The licensee successfully addressed single and multiple spurious issues in a way
that met regulations;
- The licensee properly classified equipment required for safe shutdown and
equipment important for safe shutdown;
- The adequacy of the licensees evaluation of multiple spurious actuations, in
accordance with Regulatory Guide 1.189 and NEI 00-01, Revision 2; and
- The adequacy of the licensees compensatory actions taken for identified non-
compliances.
The inspectors reviewed the licensees post-fire safe shutdown analysis to verify that
the licensee had identified both required and important circuits that could impact safe
shutdown. The inspectors reviewed the Clintons expert panel results for the potential
fire-induced operations of component supported safe shutdown at CPS. The expert
panel performed this review in accordance with RG 1.189 and Guidance provided in
NEI 00-01 Revision 2. The purpose of the expert panel was to review the applicable
industry developed Generic BWR Owners Group List of MSOs for applicability to CPS.
The expert panel was also tasked with considering plant specific MSOs similar to those
in the Generic List, but not specifically listed. The expert panel identified MSOs as
applicable to CPS and provided recommendations to resolve these issues. The
8
Enclosure
inspectors reviewed a sample of MSO scenarios identified by the expert panel as
potential non-compliances requiring further evaluations to determine corrective action
needed.
The inspectors verified that the safe shutdown cables had either been adequately
protected from the potentially adverse effects of fire damage, mitigated with approved
compensatory measures, 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 piping and instrumentation diagrams (P&IDs),
electrical schematics and logic diagrams, Safe Shutdown flow diagrams and cable
routing data sheets associated with each of the selected safe shutdown components. In
addition, the adequacy of electrical circuit protective coordination for the reviewed safe
shutdown systems components was evaluated by sampling.
The licensee initiated 27 ARs to document the identified non-conforming MSO
scenarios. In addition, the licensee implemented alternate compensatory measures as a
form of documented operator rounds as justified by the fire protection engineering
evaluation EC-EVAL 379435, GL 86-10 Evaluation: Use of Alternate Compensatory
Measures Related to Multiple Spurious Operations (MSOs), Revision 1. The inspectors
reviewed a sample of the nonconforming MSO scenarios identified by the licensee. The
inspectors noted that the licensee has not completed the analyses and evaluations of
the identified non-conforming MSOs. The licensee was in the process of determining
the appropriate long term corrective actions needed to address these findings. The
documents and ARs reviewed by the inspectors are listed in the Attachment to this
report. The licensee plans to identify and complete corrective actions to address the
identified MSOs prior to November 2, 2010, (the end of the enforcement discretion
period per EGM 09-002). The licensee evaluated the identified MSO scenarios for
potential significance and determined that none of the 27 identified MSOs were
considered to be risk significant.
b. Findings
No findings were identified.
2) Review of Licensee Actions to Address a Post-Fire Safe Shutdown MSO Scenario
Documented in NRC URI 461/2005-006-01(DRS)
(Open URI 461/2005-006-01(DRS): During the 2005 FP inspection, the NRC inspectors
performed an independent review of post-fire safe shutdown circuit analysis, using the
guidance and criteria provided in NRC Regulatory Issue Summary (RIS) 2004-003,
Revision 1, Risk-Informed Approach for Post-Fire Safe Shutdown Circuit Inspections,
dated December 29, 2004. The inspectors postulated a fire in the Division III
switchgear room, located in Fire Zone CB-5a, and determined that it could result in
multiple fire-induced electrical circuit faults in the control logic cables used in the
Division III High Pressure Core Spray (HPCS) Pump 1E22-C001 and discharge
Valve 1E22-F004 control logic. The inspectors determined that postulating such
multiple spurious faults could impair the capability to shut off the HPCS pump and stop
it from continually injecting and overfilling the reactor pressure vessel (RPV).
9
Enclosure
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 to be
evaluated simultaneously except for high/low pressure interface components.
However, the licensee also documented 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.
At the time of the inspection, the inspectors determined that documented evidence
was not available to show that the licensee considered the potential hot shorts, shorts
to ground and open circuits, postulated by the team, in the multi-conductor control
cables used in the control logic of HPCS pump 1E22-C001 and pump discharge valve
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
cannot be stopped, and if CPS is within their licensing basis considering the electrical
faults and fire-induced actuations of HPCS components. The licensee entered this issue
in their Corrective Action Program under CR 00343489, dated June 13, 2005.
During this current inspection, the team reviewed the licensees response to address the
NRC finding documented in the URI. The team noted that the licensee had identified a
similar finding during their MSO analysis and evaluation of automatic initiation logic
instrumentation logic cables related to the high drywell pressure or low RPV level
instrument loop logic. On April 7, 2010, the licensee initiated AR 01053529, MSOPS
Scenario 2U - Spurious HPCS/HPCI Operation, to document this similar finding to the
one documented in the NRCs URI. The AR stated that further work was needed to
resolve the Safe Shutdown Analysis (SSA) that evaluated the potential for spurious
HPCS initiation due to fire damage to the initiation logic, instrumentation wiring, pump
breaker wiring, and injection valve wiring and ensure the new regulatory requirements
(i.e., RG 1.189, R2) are addressed.
Subsequently, on February 8, 2011, the licensee issued AR 01172335, RVW Identifies
Design Basis Issue for Spurious HP Operation, and Event Notification (EN) No. 46603,
to document an unanalyzed condition identified by the licensee. The EN reported that
an SSA assumed operator action to locally depress the HPCS internal trip plunger to trip
the pump breaker in response to a fire in the MCR and continuous operation of the
pump, could not be performed as stated in the written procedure. The unanalyzed
condition involved a postulated scenario where, in the event of a MCR fire, the HPCS
will continuously inject into the RPV due to fire-induced faults and instrument logic cable
damage, and place the Main Steam Safety Relief Valves (MSSRVs) and their associated
tailpipes in an unanalyzed condition for the stresses expected during the two-phase flow
event. The licensee promptly initiated a confirmatory analysis to evaluate this issue and
implemented compensatory measures for potential non-conforming MSOs until the
analysis is complete.
10
Enclosure
Unresolved item (URI) 461/2005-006-01(DRS) remains open pending review of results
of the licensees confirmatory analysis of the stresses expected on the MSSRVs and
their associated tailpipes. These stresses could potentially occur during the HPCS
injection and a two-phase flow event as a result of multiple fire-induced faults in the
instrument logic cables (refer to licensee MSO Scenario No. 2U) or in the HPCS pump
and valve control logic cables (refer to NRC URI).
.2 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 were identified.
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 walkdown, 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 were identified.
.4 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.
11
Enclosure
b. Findings
No findings were identified.
.5 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 were identified.
.6 B.5.b Inspection Activities
a. Inspection Scope
The inspectors reviewed the licensees preparedness to handle large fires or explosions
by reviewing one or more mitigating strategies as identified below. 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. Note: The off-site and onsite communications, notifications/ERO activation,
initial operational response actions, and damage assessment activities identified in
Table A.3-1 were evaluated during the review of the Command and Control
Enhancements Strategy.
12
Enclosure
NEI 06-12, Selected for
Revision 2 Licensee Strategy (Table) Review
Section
2.2 SFP Makeup - Internal Strategy (Table A.2-1) Selected
3.2.2 to 3.2.5 Command and Control Enhancements (Table A.3-1) Selected
BWR Enhancement Strategy No. 3 Utilize Feedwater
3.4.3 and Condensate (Table A.5-3) Selected
BWR Enhancement Strategy No. 8 Manually Open
3.4.8 Containment Vent Lines (Table A.5-8) Selected
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (71152)
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 were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
The inspectors presented the inspection results to Mr. F. Kearney and to other members
of the licensee staff on March 18, 2011, and during subsequent telephone calls with
licensee representatives on March 24, 2011, and on April 13, 2011. The licensee
acknowledged the issues presented.
The inspectors confirmed that none of the potential report input discussed was
considered proprietary.
4OA7 Licensee-Identified Violations
No violations were identified.
ATTACHMENT: SUPPLEMENTAL INFORMATION
13
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
F. Kearney, Site Vice-President
M. Kanavos, Plant Manager
R. Zadislski, Manager, Nuclear Oversight Manager
T. Chalmers, Director, Operations
R. Frantz, Regulatory Assurance
K. Baker, Sr. Manager, Design Engineering
G. Mosley, Engineering Programs Manager
S. Fatora, Maintenance Director
C. Dunn, Shift Operations Superintendent
J. Ruth, Operations Training Manager
J. Ufert, Fire Marshall
Nuclear Regulatory Commission
B. Kemker, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
OPENED
05000461/2011009-01; Failure to Ensure Fire Door was Closed and
Latched.(Section 1R05.2.b(1))
Closed
05000461/2011009-01; Failure to Ensure Fire Door was Closed and Latched.
(Section 1R05.2.b(1))
Discussed
05000461/2005006-01; Review of Licensee Action to Address a Post-Fire Safe
Shutdown MSO Scenario. (Section 1R05.2b(2))
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
ANALYSES, CALCULATIONS AND STANDARDS
Number Description or Title Date or Revision
480 ESF SWGR Breakers and Associated Upstream 12
19-AN-04
eRelay Setting
IP-M-0471 Safe Shutdown Equipment Selection 2
EE-01.00 Safe Shutdown Cable Selection 1
H600.Y35 Automatic Sprinkler, FP Hydraulics, Auxiliary Bldg 0
H706.B01 Automatic Sprinkler, FP Hydraulics, Control Bldg 1
Automatic Sprinkler, FP Hydraulics, Auxiliary Electric 1A
H727.B02
Equipment Room
CONDITION REPORTS (ARs) ISSUED DURING INSPECTION
Number Description or Title Date or Revision
RVW Identifies Design Basis Issue for Spurious Hp
01172335 02/08/2011
Operation
01175632 NRC FP Insp. -- Paint Chips in Floor Drain 781 Control Bldg 02/15/2011
01176329 B.5.B Pump Implementation Strategy Enhancement 01/13/2011
NRC FP Triennial IDD - TSC Copy of 4303.01F001 not
01176370 02/16/2011
Readily Available
NRC FP Triennial IDD - B.5.B Pump Operating Procedure
01176393 02/16/2011
not Staged at Pump Location
NRC FP Triennial IDD - Enhance B.5.B Strategies per
01176407 02/16/2011
Procedure
4303.01 for RCIC Verification
01177009 1FP02E NRC FP Triennial IDD - Enhance 4303.01P009 02/17/2011
01177205 Status of Cable Cannot be Determined 02/18/2011
01177206 Construction ERA Wood in Cable Tray 02/18/2011
01180184 NRC FP TRI - FECN Not Posted 02/25/2011
01180220 Suppression Effects Calc Weaknesses 02/25/2011
2011 FP Triennial Issue Regarding BOP UPS 1IP06E and
01181956 03/01/2011
1IP07E
01181876 NRC FP TRI - Cable Pull Box Number is Incorrect 03/01/2011
NRC FP TRI ID - USAR App E 3.4.3.1 Fire Detection
01183043 03/03/2011
Incorrect
01183546 NRC FP TRI ID - Enhancement to 4003.01C002 03/03/2011
01186553 FP Licensing Basis Documents not Readily Available 03/03/2011
01187430 NRC FP TRI ID - Lanyard on Cable Tray Hanger 03/14/2011
1 Attachment
Number Description or Title Date or Revision
01187435 NRC FP TRI - Thermo-Leg Cable Tray Discrepancies 03/14/2011
01187906 NRC FP TRI - Div. 2 DG Fire Door Found Unlatched 03/15/2011
01188547 NRC FP TRI - Housekeeping Above AB Battery Rooms 03/16/2011
01188935 NRC FP TRI - Drawings Identified Again as Having
03/17/2011
Incorrect
01188952 NRC FP TRI - Margin Discussion is Missing from Sprinkler
03/17/2011
Calc
Elevation Description
CONDITION REPORTS (ARs) REVIEWED DURING INSPECTION
Number Description or Title Date or Revision
01053529 Evaluate HPCS MSO April 7, 2010
01053473 MSOPS 2L - Spurious RH Min. Flow Close With Spurious April 7, 2010
Pump Start
01053407 MSOPSUse of Alternate Compensatory Measures for MSO April 7, 2010
00985851 Coordinate Fleet Actions for RG 1.189/NEI 00-01 October 29, 2009
01053473 MSOPS 2L - Spurious RH Min Flow Close with Spurious Pump October 07, 2010
Start
01053538 MSOPS 2Y - RCIC Test Flow to CST Stop/Throttle Vlvs Flow April 07, 2010
Diversion
01029032 NOS ID Unauthorized BISCO Seal Penetration February 11, 2010
01135002 FP FASA Walkdown Identified Improperly Breached Nov. 3, 2010
01149954 ILL61BP06E Safe S/D Pathway Light Trickle Chg Lamp not lit Dec. 8, 2010
01153758 Fire Doors not Kept Closed Dec 17, 2010
01172335 RVW Identifies Design Basis Issue for Spurious HP Operation February 8, 2011
DRAWINGS
Number Description or Title Date or Revision
E26-1003-03A-E1 Electrical Installation Aux Bldg El 781 3 AG
Fire Detection System, Aux Bldg Switchgear Floor A
E26-1003-03A-FP
Plan El 781 0
Fire Detection System, Aux Bldg Switchgear Floor A
E26-1003-03A-FP
Plan El 790 0
Pre-Fire Plan, Auxiliary Building, Containment Pipe 1
Fire Zone A-3F
Penetration, El. 364- 0
Fire Zone CB-1e Pre-Fire Plan, 737 Control Building, General Access 6a
Fire Zone CB-1e Pre-Fire Plan, 751 Control Building, HVAC Mezzanine 6
Pre-Fire Plan, 781 Control Building Div 2 Cable 5a
Fire Zone CB-2
Spreading Room
Pre-Fire Plan, 781 Control Building Auxiliary Electrical 7a
Fire Zone CB-3a
Equipment , Inverter and Battery Rooms
M05-1039; sh, 008 P&ID Fire Protection (FP) Turbine Bldg AL
M05-1056 sh. 002 P&ID Plant Service Water AL
2 Attachment
Number Description or Title Date or Revision
Key Diagram, Control Building MCC G and H W
E02-0AP24
(0AP56E and 0AP57E)
M05-1075 P&ID - Residual Heat Removal (RH) AW
Residual Heat Removal Shutdown Cooling Upper K
E02-1RH99
Pool Valves 1E12-F037A and 1E12-F037B
E30-1003-04A- Electrical InstallationControl Bldg Cable Spreading AF
E1 Room
E03-0AP56E External Wiring Diagram - Control Building MCC G M
(0AP56E)
E02-0AP24 Key Diagram - MCC G and H (0AP56E and 0AP57E) 1
CPS-SSD-LOG- Containment and Reactor Vessel Monitoring System 2
301 Safe Shutdown Logic Diagram
CPS-SSD-LOG- Reactor Core Isolation Cooling Safe Shutdown Logic 2
102 Diagram
M05-1079 P&ID Reactor Core Isolation Cooling (RCIC) AJ
MODIFICATIONS/ENGINEERING CHANGES
Number Description or Title Date or Revision
EC 383184 Design Bases Issues for Spurious HP Operations 0
Fire Protection With Alternate Comp Measures for 0
Spurious HPCS Ops.
GL 86-10 Evaluation: Use of Alternate Compensatory 001
EC 379435 Measures Related to Multiple Spurious Operations
(MSO)
3822.04C003 Quarterly B.5.b Equipment Checklist 1d
3822.04C006 Quarterly OCA/NTD Fire Cage Checklist 2e
9277.11C001 Hose Replacement Checklist 24b
9601.05C001 Closed Fire Door Inspection Checklist 31a
9601.06C001 Semi-Annual Fire Door Operability Checklist
CC-AA-201 Plant Barrier Control Program 8
OP-AA-201-009 Control of Transient Combustible Materials 11
OP-MW-201-007 Fire Protection System Impairment Control 7
PROCEDURES
Number Description or Title Date or Revision
3822.04C003 Quarterly B.5.b Equipment Checklist 1d
3822.04C006 Quarterly OCA/NTD Fire Cage Checklist 2e
9277.11C001 Hose Replacement Checklist 24b
9601.05C001 Closed Fire Door Inspection Checklist 31a
9601.06C001 Semi-Annual Fire Door Operability Checklist 30c
CC-AA-201 Plant Barrier Control Program 8
OP-AA-201-009 Control of Transient Combustible Materials 11
3 Attachment
Number Description or Title Date or Revision
OPOP-MW-201- 7
Fire Protection System Impairment Control
007
9601.05 Visual Inspection of Closed Fire Doors March 13, 2011
4303.01P020 Emergency Confirmation of Reactor Scram 0a
WORK ORDERS
Number Description or Title Date or Revision
01162683 01 9601.01C003 Accessible Group 1 Penetration Fire August 17, 2009
Seal Inspections
01170437 01 9601.01C009 Inaccessible Group 1 Penetration Fire January 07, 2010
Seal Inspections
01170408 01 9601.01C003 Accessible Group 1 Penetration Fire April 13, 2010
Seal Inspections
01354876 04 Install BISCO Seal CB-781-09-1063 TS-EC 380713 September 17, 2010
Number Description or Title Date or Revision
AR 01056005-02 2010 Focused Area Self-Assessment November 18, 2010
Fire Protection Safe Shutdown Analysis Clinton
USAR Apx. F Power Station Unit 1 14
NEI 00-01 Apx.
G Generic List of MSOs 2
ATI 1165189 Perform CCA on TCFZ Issues February 15, 2011
Report an Unanalyzed Condition Concerning HPCS
EN No. 46603 Injection Scenario February 15, 2011
Slice Version 7.6 Cable Tabulation-Main File (S101-1) Pg. HP 14 September 29, 2010
CPS-SSD-LOG- HPCS SRV and Containment Spray and Initiation
302 Safe Shutdown Logic Diagram 2
E02-1HP99 High Pressure Core Spray (HP) (NSPS) (1E22-
Sh.5 1050) G
E02-1HP99 High Pressure Core Spray (HP) (NSPS) (1E22-
Sh.6 1050) D
E02-1HP99 High Pressure Core Spray (HP) (NSPS) (1E22-
Sh.7 1050) L
E02-1HP99 High Pressure Core Spray (HP) (NSPS) (1E22-
Sh.110 1070) H
High Pressure Core Spray (HP) HPCS Suction
E02-1HP99
Valve (1E22-F001) and HPCS Pump Disch Valve
Sh.501 J
4 Attachment
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
AR Action Request
CFR Code of Federal Regulations
CPS Clinton Power Station
DRS Division of Reactor Safety
EDG Emergency Diesel Generator
EN Event Notification
ESF Engineered Safety Features
IMC Inspection Manual Chapter
IR Inspection Report
kV KiloVolt
MCC Motor Control Center
MCR Main Control Room
MSO Multiple Spurious Operations
MSSRV Main Steam Safety Relief Valves
NCV Non-Cited Violation
NEI Nuclear Energy Institute
NFPA National Fire Protection Association
NRC U.S. Nuclear Regulatory Commission
NUREG NRC Technical Report
PARS Publicly Available Records
P&ID Piping and Instrumentation Diagram
RIS NRC Regulatory Issue Summary
SDP Significance Determination Process
SER Safety Evaluation Report
SPAR Standardized Plant Analysis Risk
SRA Senior Reactor Analyst
SRP Standard Review Plan
SSA Safe Shutdown Analysis
UFSAR Updated Final Safety Analysis Report
URI Unresolved Item
5 Attachment
M. Pacilio -2-
of this inspection report, with the basis for your disagreement, to the Regional Administrator,
Region III, and the NRC Resident Inspector at Clinton Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any), 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 No. 50-461
License No. NPF-62
Enclosures: Inspection Report 05000461/2011009(DRS)
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
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NAME ZFalevits:ls RDaley
DATE 04/25/11 04/25/11
OFFICIAL RECORD COPY
Letter to Mr. Michael J. Pacilio from Mr. Robert C. Daley dated April 25, 2011.
SUBJECT: CLINTON POWER STATION FIRE PROTECTION TRIENNIAL BASELINE
INSPECTION NRC INSPECTION REPORT 05000461/2011009(DRS)
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