IR 05000277/2015007
| ML15124A514 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/04/2015 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2015007 | |
| Download: ML15124A514 (24) | |
Text
UNITED STATES May 4, 2015
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000277/2015007 AND 05000278/2015007
Dear Mr. Hanson:
On April 2, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Peach Bottom Atomic Power Station, Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on April 2, 2015, with Mr. M. Massaro 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. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
Based on the results of this inspection, no findings were identified.
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs 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 (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-277; 50-278 License Nos. DPR-44; DPR-56
ML15124A514 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRS RI/DRS RI/DRP NAME RFuhrmeister FBower JRogge DATE 4/27/15 4/30/15 5/4/15
Enclosure:
Inspection Report Nos. 05000277/2015007 and 05000278/2015007 w/Attachment: Supplemental Information
REGION I==
Docket Nos.: 50-277; 50-278 License Nos.: DPR-44; DPR-56 Report Nos.: 05000277/2015007 and 05000278/2015007 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: 1848 Lay Road, Delta, PA 17314 Dates: March 16 - 20 and March 30 - April 2, 2015 Inspectors: R. Fuhrmeister, Senior Reactor Inspector (Team Leader)
W. Schmidt, Senior Reactor Analyst K. Young, Senior Reactor Inspector J. Richmond, Senior Reactor Inspector L. Dumont, Reactor Inspector Approved by: John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety i Enclosure
SUMMARY OF FINDINGS
IR 05000277/2015007 and 05000278/2015007; 03/16/2015 - 03/20/2015 and 03/30/2015 -
04/02/2015; Exelon Generation Company, LLC; Peach Bottom Atomic Power Station, Units 2 and 3; Triennial Fire Protection Baseline Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
No findings were identified.
ii
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Exelon has implemented an adequate fire protection program (FPP) and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom).
The following fire areas (FA) and fire zones (FZ) were selected for detailed review based on risk insights from the Peach Bottom Individual Plant Examination of External Events (IPEEE).
- FA 41 - FZ 134, E2 Diesel Generator Room
- FA 58, Unit 3 Recirculation Motor Generator Set Room Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated Exelons FPP against applicable requirements which included Renewed Facility Operating License Condition 2.C(4) (both units), NRC Safety Evaluations, 10 CFR 50.48, 10 CFR Part 50, Appendix R and Branch Technical Position (BTP) Auxiliaries and Power Conversion Systems Branch (APCSB) 9.5-1, Appendix A. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 10.12, the fire hazards analysis (FHA), and the post-fire safe shutdown analyses.
The team also evaluated three Exelon mitigating strategies for addressing large fires and explosions as required by Operating License Condition 2.C(11) (both units) and 10 CFR 50.54 (hh)(2). Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (IP 71111.05T)
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, safe shutdown analyses, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that applicable separation requirements of Section III.G of 10 CFR Part 50, Appendix R and Exelons design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected FAs to evaluate whether the material conditions of the FA boundaries were adequate for the fire hazards in the area.
The team compared the FA boundaries, including walls, ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway and conduit fire barriers, and redundant equipment fire barriers and radiant energy heat barriers to design and licensing basis requirements, industry standards, and the FPP, as approved by the NRC, to identify any potential degradation or non-conformances.
The team reviewed selected engineering evaluations, repair work orders, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating.
The team also reviewed recent inspection and functional test records for fire dampers, and the inspection records for penetration seals and fire barriers, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified. In addition, the team reviewed recent test results for the carbon dioxide (CO2) fire damper functionality tests for the areas protected to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The team evaluated manual and automatic fire suppression and detection systems in the selected FAs to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements, National Fire Protection Association (NFPA)codes of record, and the Peach Bottom FPP, as approved by the NRC. The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas.
The team reviewed the as-built capability of the fire water supply system to verify the design and licensing basis and NFPA code of record requirements were satisfied, and to assess whether those capabilities were adequate for the hazards involved. The team reviewed the fire water system hydraulic analyses to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus concurrent fire hose usage. The team evaluated the fire pump performance tests to assess the adequacy of the test acceptance criteria for pump minimum discharge pressure at the required flow rate, to verify the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied. The team also evaluated the underground fire loop flow tests to verify the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed recent pump and loop flow test results to verify the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
The team reviewed initial discharge testing, design specifications, vendor requirements, and routine functional testing for the CO2 suppression systems for the diesel generator and HPCI pump rooms. The team walked down accessible portions of the CO2 systems, including storage tanks and supply systems, to independently assess the material condition, operational lineup, and availability of the systems. The team also reviewed and walked down the associated fire fighting strategies and CO2 system operating procedures.
The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire pumps, interviewed system and program engineers, and reviewed selected condition reports (AR) to independently assess the material condition of the systems and components. In addition, the team reviewed recent test results for the fire detection and suppression systems for the selected FAs to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed Exelon's fire fighting strategies (i.e.,
pre-fire plans) and smoke removal plans for the selected FAs to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. The team independently inspected the fire brigade equipment, including personnel protective gear (e.g., turnout gear) and smoke removal equipment, to determine operational readiness for fire fighting. In addition, the team reviewed Exelon's fire brigade equipment inventory and inspection procedure and recent inspection and inventory results to verify adequate equipment was available, and any potential material deficiencies were identified.
b. Findings
No findings were identified.
.04 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
- A fire in one of the selected fire areas would not indirectly, through production of smoke, heat, or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains;
- A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not indirectly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and,
- Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings were identified.
.05 Post-Fire Safe Shutdown Capability - Normal and Alternative
a. Inspection Scope
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&lD), electrical drawings, the UFSAR, and other supporting documents for the selected FAs to verify whether Exelon had properly identified the systems and components necessary to achieve and maintain post-fire safe shutdown conditions. The team evaluated selected systems and components credited by the safe shutdown analysis for reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions to assess the adequacy of Exelon's alternative shutdown methodology. The team also assessed whether alternative post-fire shutdown could be performed both with and without the availability of off-site power. The team walked down selected plant configurations to verify whether they were consistent with the assumptions and descriptions in the safe shutdown and fire hazards analyses. In addition, the team evaluated whether the systems and components credited for use during post-fire safe shutdown would remain free from fire damage.
The team reviewed the training program for licensed and non-licensed operators to verify whether it included alternative shutdown capability. The team also verified whether personnel required for post-fire safe shutdown, using either the normal or alternative shutdown methods, were trained and available on-site at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps (i.e., a procedure tabletop)to assess the adequacy of implementation and human factors within the procedures.
The team also evaluated the time required to perform specific actions to verify whether operators could reasonably be expected to perform those actions within sufficient time to maintain plant parameters within specified limits.
Specific procedures reviewed for normal and alternative post-fire shutdown included:
- ON-114, Fire in the Power Block
- SE-10, Alternative Shutdown
- T-302-3, Unit 3 High Pressure Coolant Injection Room Fire Guide
- T-345-2(3), E2 Emergency Diesel Generator Room Fire Guide
- T-358-3, Unit 3 Recirculation Motor Generator Set Room Fire Guide The team reviewed selected operator manual actions to verify whether they had been properly reviewed and approved and whether the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer and isolation capability, and instrumentation and control functions, to evaluate whether the tests were adequate to ensure the functionality of the alternative shutdown capability.
b. Findings
No findings were identified.
.06 Circuit Analysis
a. Inspection Scope
The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team verified that the licensees analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The teams review considered fire and cable attributes, cable routing, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
The team also reviewed cable raceway drawings and/or cable routing databases for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the safe-shutdown analysis. The team also reviewed equipment important to safe shutdown, but not part of the success path, to verify that the licensee had taken appropriate actions in accordance with the design and licensing basis and NRC Regulatory Guide 1.189, Revision 2.
Circuit analysis was performed for the following components:
- M02-23-014, Unit 2 HPCI Steam Supply Isolation Valve
- M02-23-020, Unit 2 Outboard HPCI Pump Discharge Valve
- M03-10-018, Unit 3 RHR Shutdown Cooling Isolation Valve
- M03-23-019, Unit 3 Inboard HPCI Pump Discharge Valve
- LI-9456, Unit 3 Suppression Pool Water Level Indicator
- PI3-2-3-60B, Unit 3 Reactor Vessel Pressure Indicator
- RV2-02-071B, Unit 2 Main Steam Line A Safety/Relief Valve The team reviewed a sample of circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination that could result in a common power supply or common bus concern.
The team verified that the transfer of control from the control room to the alternative shutdown location(s) would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained consistent with the manufacturers recommendations and in a manner that would ensure reliable operation.
a. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The team reviewed Exelon's dedicated repair procedures for components which might be damaged by fire and were required to achieve post-fire cold shutdown. The team evaluated selected cold shutdown repairs to determine whether they could be achieved within the time frames assumed in the design and licensing bases. In addition, the team verified whether the necessary repair equipment, tools, and materials (e.g., pre-cut cables with prepared attachment lugs) were available and accessible on site.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings were identified.
.11 Fire Protection Program Changes
a. Inspection Scope
The team reviewed recent changes to the approved FPP to verify that the changes did not constitute an adverse effect on the ability to safely shutdown.
b. Findings
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The team 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 FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
b. Findings
No findings were identified.
.13 Large Fires and Explosions Mitigation Strategies
a. Inspection Scope
The team reviewed Exelons preparedness to handle large fires or explosions by reviewing two mitigating strategies to verify they continue to meet operating license condition 2.C(11) by determining that:
- Procedures are being maintained and adequate;
- Equipment is properly staged and is being maintained and tested; and,
- Station personnel are knowledgeable and can implement the procedures.
b. Findings
No findings were identified.
OTHER ACTIVITIES
[OA]
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that Exelon was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program.
The team also reviewed a sample of selected issues to verify that Exelon had taken or planned appropriate corrective actions.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. M. Massaro, Site Vice President, and other members of the site staff at an exit meeting on April 2, 2015. No proprietary information was included in this inspection report.
- Supplemental Information
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Massaro, Site Vice President
- P. Navin, Plant Manager
- W. Reynolds, Engineering Programs Manager
- M. Herr, Operations Director
- D. Henry, Engineering Director
- S. Quick, Nuclear Oversight Manager
- C. Pragman, Corporate Fire Protection Program Manager
- D. Dullum, Regulatory Assurance Engineer
- B. Miller, Fire Protection System Manager
- B. Nguyen, Fire protection System Engineer
- V. Rhodes, Fire Safe Shutdown Engineer
- J. Koester, Fire Marshall
- J. Moore, Senior Licensed Operator
- W. Zuppe, Operations Support Supervisor
- D. Turek, Supervisor - Operations Shift
- K. Kinard, Supervisor Records Management
- J. Smith, Nuclear Plant Operator
- D. Smith, Nuclear Plant Operator
- J. MacKale, Nuclear Plant Operator
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- S. Hansell, Senior Resident Inspector, Peach Bottom Atomic Power Station
- B. Smith, Resident Inspector, Peach Bottom Atomic Power Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE
Opened and Closed
NONE
Closed
NONE
Discussed
NONE