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{{Adams|number = ML082820110}}
{{Adams
| number = ML082820110
| issue date = 10/07/2008
| title = IR 05000289-08-009, on 08/25/2008 - 09/12/2008, Amergen Energy Company, LLC, Three Mile Island Station, Unit 1,Triennial Fire Protection Team Inspection, Fire Protection
| author name = Rogge J
| author affiliation = NRC/RGN-I/DRS/EB3
| addressee name = Pardee C
| addressee affiliation = AmerGen Energy Co, LLC, Exelon Generation Co, LLC
| docket = 05000289
| license number = DPR-050
| contact person =
| document report number = IR-08-009
| document type = Inspection Report, Letter
| page count = 27
}}


{{IR-Nav| site = 05000289 | year = 2008 | report number = 009 }}
{{IR-Nav| site = 05000289 | year = 2008 | report number = 009 }}


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:ber 7, 2008
[[Issue date::October 7, 2008]]


Mr. CharlesChief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC Chief Nuclear Officer AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA  19348
==SUBJECT:==
 
THREE MILE ISLAND NUCLER STATION, UNIT 1 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000289/2008009
SUBJECT: THREE MILE ISLAND NUCLER STATION, UNIT 1 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000289/2008009


==Dear Mr. Pardee:==
==Dear Mr. Pardee:==
On September 12, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Three Mile Island Station, Unit 1. The enclosed inspection report documents the inspection results, which were discussed on September 12, 2008, with Mr. W. Noll and other members of your staff.
On September 12, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Three Mile Island Station, Unit 1. The enclosed inspection report documents the inspection results, which were discussed on September 12, 2008, with Mr. W. Noll and other members of your staff.


The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
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, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Three Mile Island Station.
Based on the results of this inspection, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Three Mile Island Station.


In accordance with Title 10 of the Code of Federal Regulations Part 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 (PARS) component of the NRC's document system (ADAMS).
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 document system (ADAMS).


Mr. CharlesADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Mr. Charles 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 No. 50-289 License No. DPR-50  
Sincerely,
 
/RA/
===Enclosure:===
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-289 License No. DPR-50 Enclosure: Inspection Report No. 05000289/2008009 w/Attachment: Supplemental Information
Inspection Report No. 05000289/2008009  
 
===w/Attachment:===
Supplemental Information  


Mr. Charles
Mr. Charles


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000289/2008009; 08/25/2008 - 09/12/2008; AmerGen Energy Company, LLC; Three Mile  
IR 05000289/2008009; 08/25/2008 - 09/12/2008; AmerGen Energy Company, LLC; Three Mile


Island Station, Unit 1; Triennial Fire Protection Team Inspection, Fire Protection.
Island Station, Unit 1; Triennial Fire Protection Team Inspection, Fire Protection.
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This report covered a two-week triennial fire protection team inspection by specialist inspectors.
This report covered a two-week triennial fire protection team inspection by specialist inspectors.


One Green NCV was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance
One Green NCV was identified. 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,
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, Rev. 4, dated December 2006.
"Reactor Oversight Process," Rev. 4, dated December 2006.


===A. NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===


===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===
: '''Green.'''
: '''Green.'''
The team identified that AmerGen allowed fire brigade members to use elevators during response to a fire, when the power or control to the elevator could be lost as a result of a fire. This finding was determined to be of very low safety significance (Green) and a NCV of the Three Mile Island Nuclear Station, Unit 1
The team identified that AmerGen allowed fire brigade members to use elevators during response to a fire, when the power or control to the elevator could be lost as a result of a fire. This finding was determined to be of very low safety significance (Green) and a NCV of the Three Mile Island Nuclear Station, Unit 1 Operating License condition 2.c.(4), Fire Protection.
Operating License condition 2.c.(4), "Fire Protection."


The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator, potentially trapping fire brigade members and delaying their efforts to extinguish fires in safe shutdown areas. The team assessed this finding in accordance with NRC IMC 0609, Appendix M, Significance Determination Process Using Qualitative
The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator, potentially trapping fire brigade members and delaying their efforts to extinguish fires in safe shutdown areas. The team assessed this finding in accordance with NRC IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria because IMC 0609, Appendix F, Fire Protection Significance Determination Process specifically excludes findings associated with the performance of the fire brigade. Therefore this finding required regional branch chief review in accordance with IMC 0612, Power Reactor Inspection Reports. This finding was screened to very low safety significance (Green) based on IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria and the following considerations: the limited exposure time when brigade members would be in the elevator and AmerGens practice that the entire brigade did not enter the elevator all at once. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because when the issue of elevator usage by fire brigade members was raised by the NRC residents on November 29, 2007, the issue was not fully evaluated (P.1(c)).
Criteria because IMC 0609, Appendix F, Fire Protection Significance Determination
      (Section 1R05.04)
Process specifically excludes findings associated with the performance of the fire brigade. Therefore this finding required regional branch chief review in accordance with
 
IMC 0612, Power Reactor Inspection Reports. This finding was screened to very low safety significance (Green) based on IMC 0609 Appendix M, Significance Determination
===Licensee-Identified Violations===
Process Using Qualitative Criteria and the following considerations: the limited exposure time when brigade members would be in the elevator and AmerGen's practice that the entire brigade did not enter the elevator all at once. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because when the issue of elevator usage by fire brigade members was raised by the
NRC residents on November 29, 2007, the issue was not fully evaluated (P.1(c)).
(Section 1R05.04)


===B. Licensee-Identified Violations===
None.
None.


=REPORT DETAILS=
=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 AmerGen Energy Company, LLC, (AmerGen) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Three Mile Island (TMI)
 
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 AmerGen Energy Company, LLC, (AmerGen) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Three Mile Island (TMI)
Station, Unit 1. The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the TMI Individual Plant Examination of External Events (IPEEE):
Station, Unit 1. The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the TMI Individual Plant Examination of External Events (IPEEE):
* CB-FA-2A
* CB-FA-2A
* CB-FA-3A
* CB-FA-3A
* CB-FA-3D
* CB-FA-3D
* AB-FZ-6 The inspection team evaluated AmerGen's fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Condition 2.C.4, NRC Safety Evaluations, 10 CFR 50.48, and 10 CFR 50 Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.9 and the Fire Hazards Analysis Report (FHAR).
* AB-FZ-6 The inspection team evaluated AmerGens fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Condition 2.C.4, NRC Safety Evaluations, 10 CFR 50.48, and 10 CFR 50 Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.9 and the Fire Hazards Analysis Report (FHAR).


Specific documents reviewed by the team are listed in the attachment.
Specific documents reviewed by the team are listed in the attachment.


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R05 Fire Protection (IP 71111.05T)
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
{{a|1R05}}
==1R05 Fire Protection (IP 71111.05T)==


===.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and Normal Shutdown===
===.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and===
 
Normal Shutdown


====a. Inspection Scope====
====a. Inspection Scope====
Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with
Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the FHAR. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown locations 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).
 
that described in the FHAR. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown locations 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).


Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
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Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
* OP-TM-AOP-001, Fire, Rev. 4
* OP-TM-AOP-001, Fire, Rev. 4
* OP-TM-AOP-001-A06, Fire in AB 305' Demineralizer and 1A ESV MCC Area, Rev. 1
* OP-TM-AOP-001-A06, Fire in AB 305 Demineralizer and 1A ESV MCC Area, Rev. 1
* OP-TM-AOP-001-C2A, Fire in 1P 480V Switchgear Room, Rev. 2
* OP-TM-AOP-001-C2A, Fire in 1P 480V Switchgear Room, Rev. 2
* OP-TM-AOP-001-C3A, Fire in 1D ES 4160V Switchgear Room, Rev. 2
* OP-TM-AOP-001-C3A, Fire in 1D ES 4160V Switchgear Room, Rev. 2
* OP-TM-EOP-020, Cooldown from Outside of Control Room, Rev. 9 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that 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 capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
* OP-TM-EOP-020, Cooldown from Outside of Control Room, Rev. 9 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that 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 capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.


====b. Findings====
====b. Findings====
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The team reviewed the FHAR, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of Section III.G of 10 CFR 50, Appendix R 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.
The team reviewed the FHAR, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of Section III.G of 10 CFR 50, Appendix R 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.


The team reviewed AmerGen's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHAR. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
The team reviewed AmerGens 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 FHAR. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.


====b. Findings====
====b. Findings====
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=====Introduction.=====
=====Introduction.=====
The team identified that AmerGen allowed fire brigade members to use elevators during response to a fire, when the power or control to the elevator could be lost as a result of a fire. This finding was determined to be of very low safety significance (Green) and a NCV of the Three Mile Island Nuclear Station, Unit 1 Operating License condition 2.c.(4), "Fire Protection."
The team identified that AmerGen allowed fire brigade members to use elevators during response to a fire, when the power or control to the elevator could be lost as a result of a fire. This finding was determined to be of very low safety significance (Green) and a NCV of the Three Mile Island Nuclear Station, Unit 1 Operating License condition 2.c.(4), Fire Protection.


=====Description.=====
=====Description.=====
Based on FBP 11, Emergency Response Training Fire Brigade Program, FBP 11, "The use of the plant elevators during a fire is a determination made by the fire brigade leader as a part of his initial size up."  At TMI, fire brigade members were trained that elevator use is acceptable after establishing that the fire is not in the vicinity of the elevator. The fire brigade utilized the elevator to transport a fire cart and other fire fighting equipment.
Based on FBP 11, Emergency Response Training Fire Brigade Program, FBP 11, The use of the plant elevators during a fire is a determination made by the fire brigade leader as a part of his initial size up. At TMI, fire brigade members were trained that elevator use is acceptable after establishing that the fire is not in the vicinity of the elevator. The fire brigade utilized the elevator to transport a fire cart and other fire fighting equipment.
 
The team questioned the use of elevators by the fire brigade, specifically considering the routing of power and control cables for the elevators. The team focused their review 


on the turbine building elevator due to its convenient location near the fire brigade storage room. AmerGen determined that control and power cables for the turbine building elevator run through the control building. The inspectors concluded that fires in certain areas of the control building, while not in the vicinity of the turbine building elevator, could damage the elevator power or control cables, which would disable the elevator. Also, if a fire occurred in any switchgear through which the elevator power was routed, then operators, by procedure, would deenergize the affected switchgear which would also disable the elevator. Fire brigade members utilizing the elevator during such circumstance risk being trapped and delayed or unable to respond.
The team questioned the use of elevators by the fire brigade, specifically considering the routing of power and control cables for the elevators. The team focused their review on the turbine building elevator due to its convenient location near the fire brigade storage room. AmerGen determined that control and power cables for the turbine building elevator run through the control building. The inspectors concluded that fires in certain areas of the control building, while not in the vicinity of the turbine building elevator, could damage the elevator power or control cables, which would disable the elevator. Also, if a fire occurred in any switchgear through which the elevator power was routed, then operators, by procedure, would deenergize the affected switchgear which would also disable the elevator. Fire brigade members utilizing the elevator during such circumstance risk being trapped and delayed or unable to respond.


AmerGen had committed to not using elevators in Section 5 of the Three Mile Island Fire Hazard Analysis Report in a comparison to the NRC Branch Technical Position APCSB 9.5-1, Appendix A. Part D.4(f) of this comparison states, "Elevators are not used during fire emergencies."
AmerGen had committed to not using elevators in Section 5 of the Three Mile Island Fire Hazard Analysis Report in a comparison to the NRC Branch Technical Position APCSB 9.5-1, Appendix A. Part D.4(f) of this comparison states, Elevators are not used during fire emergencies.


AmerGen documented this issue in corrective action program condition report IR 816765. AmerGen's immediate corrective actions included issuing a policy to all fire brigade members that elevators are not to be used during any fire scenario. AmerGen planned to formally evaluate the potential for prescribing future use of elevators in certain pre-fire plans, which may include a change to the BTP 9.5-1 comparison in the Fire Hazards Analysis Report. The team determined that allowing fire brigade members to use an elevator during a fire could disable the elevator is a performance deficiency.
AmerGen documented this issue in corrective action program condition report IR 816765. AmerGens immediate corrective actions included issuing a policy to all fire brigade members that elevators are not to be used during any fire scenario. AmerGen planned to formally evaluate the potential for prescribing future use of elevators in certain pre-fire plans, which may include a change to the BTP 9.5-1 comparison in the Fire Hazards Analysis Report. The team determined that allowing fire brigade members to use an elevator during a fire could disable the elevator is a performance deficiency.


The team also noted that fire brigade use of elevators was previously questioned by the NRC resident inspectors during their annual observation of a fire brigade drill on November 29, 2007. AmerGen initiated a condition report (IR 704915) to address the inspectors' question. AmerGen closed the IR and documented that quarterly training was performed to reiterate the requirements to ensure that the elevator was not in the area of the fire or visibly affected by the fire. The associated condition report did not fully evaluate the issue in that the routing of power and control cables was not considered.
The team also noted that fire brigade use of elevators was previously questioned by the NRC resident inspectors during their annual observation of a fire brigade drill on November 29, 2007. AmerGen initiated a condition report (IR 704915) to address the inspectors question. AmerGen closed the IR and documented that quarterly training was performed to reiterate the requirements to ensure that the elevator was not in the area of the fire or visibly affected by the fire. The associated condition report did not fully evaluate the issue in that the routing of power and control cables was not considered.


=====Analysis.=====
=====Analysis.=====
The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator, potentially trapping fire brigade members and delaying their efforts to extinguish fires in safe shutdown areas.
The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator, potentially trapping fire brigade members and delaying their efforts to extinguish fires in safe shutdown areas.


The team assessed this finding in accordance with NRC IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria because IMC 0609, Appendix F, Fire Protection Significance Determination Process specifically excludes findings associated with the performance of the fire brigade. Therefore this finding required regional branch chief review in accordance with IMC 0612, Power Reactor Inspection Reports. This finding was screened to very low safety significance (Green)  
The team assessed this finding in accordance with NRC IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria because IMC 0609, Appendix F, Fire Protection Significance Determination Process specifically excludes findings associated with the performance of the fire brigade. Therefore this finding required regional branch chief review in accordance with IMC 0612, Power Reactor Inspection Reports. This finding was screened to very low safety significance (Green)based on IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria and the following considerations: the limited exposure time when brigade members would be in the elevator and AmerGens practice that the entire brigade did not enter the elevator all at once.


based on IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria and the following considerations: the limited exposure time when brigade members would be in the elevator and AmerGen's practice that the entire brigade did not enter the elevator all at once. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because when the issue of elevator usage by fire brigade members was raised by the NRC residents on November 29, 2007, the issue was not fully evaluated. (P.1(c))  
The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because when the issue of elevator usage by fire brigade members was raised by the NRC residents on November 29, 2007, the issue was not fully evaluated. (P.1(c))


=====Enforcement.=====
=====Enforcement.=====
Three Mile Island Nuclear Station Operating License condition 2.c.(4) requires that AmerGen Energy Company, LLC shall implement and maintain in effect all provisions of the Fire Protection Program as described in the Updated FSAR for TMI-1.
Three Mile Island Nuclear Station Operating License condition 2.c.(4)requires that AmerGen Energy Company, LLC shall implement and maintain in effect all provisions of the Fire Protection Program as described in the Updated FSAR for TMI-1.


The UFSAR section 9.9.2 states that the Fire Hazards Analysis Report is considered to be part of the Fire Protection Program. Section 5.0.D.4(f) of the Fire Hazards Analysis Report states, "Elevators are not used during fire emergencies."  Contrary to the above, for some period of time (and observed during a fire brigade drill on November 29, 2007)until September 12, 2008, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator. Because this finding was of very low safety significance (Green) and has been entered into AmerGen's corrective action program (IR 00816765), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000289/2008009-01, Inappropriate Use of Elevators by Fire Brigade Members.
The UFSAR section 9.9.2 states that the Fire Hazards Analysis Report is considered to be part of the Fire Protection Program. Section 5.0.D.4(f) of the Fire Hazards Analysis Report states, Elevators are not used during fire emergencies. Contrary to the above, for some period of time (and observed during a fire brigade drill on November 29, 2007)until September 12, 2008, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator. Because this finding was of very low safety significance (Green) and has been entered into AmerGens corrective action program (IR 00816765), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000289/2008009-01, Inappropriate Use of Elevators by Fire Brigade Members.


===.05 Protection From Damage From Fire Suppression Activities===
===.05 Protection From Damage From Fire Suppression Activities===
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====b. Findings====
====b. Findings====
The team identified a potential concern regarding operation of the carbon dioxide (CO2)extinguishing system for the relay room. Specifically, the potential may exist for CO2 to
The team identified a potential concern regarding operation of the carbon dioxide (CO2)extinguishing system for the relay room. Specifically, the potential may exist for CO2 to migrate outside the relay room and affect the ability of operators to perform alternative shutdown activities. Likewise, with CO2 migration potential outside the relay room, the potential existed for less than adequate CO2 concentration in the relay room for fire suppression. This issue will remain unresolved pending further NRC review of AmerGens analysis of the issue.
 
migrate outside the relay room and affect the ability of operators to perform alternative shutdown activities. Likewise, with CO2 migration potential outside the relay room, the potential existed for less than adequate CO2 concentration in the relay room for fire suppression. This issue will remain unresolved pending further NRC review of AmerGen's analysis of the issue.


The team reviewed the design and testing of the CO2 system for the relay room. The original CO2 discharge test in 1976 had some complications which required followup evaluations, further testing, and design change modifications. After the team reviewed the subsequent testing and design change documentation, the team had two remaining concerns: potential migration of CO2 into rooms outside the relay room and the concentration of CO2 in the relay room.
The team reviewed the design and testing of the CO2 system for the relay room. The original CO2 discharge test in 1976 had some complications which required followup evaluations, further testing, and design change modifications. After the team reviewed the subsequent testing and design change documentation, the team had two remaining concerns: potential migration of CO2 into rooms outside the relay room and the concentration of CO2 in the relay room.
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* The gaps under the two doors from the relay room to the 1D 4160VAC switchgear room and the ESAS room were approximately one inch high. This represented a potential CO2 migration path to areas required for alternative shutdown operations.
* The gaps under the two doors from the relay room to the 1D 4160VAC switchgear room and the ESAS room were approximately one inch high. This represented a potential CO2 migration path to areas required for alternative shutdown operations.
* The relay room ventilation ducts were automatically isolated upon a CO2 discharge with two series dampers on both the exhaust plenum and the supply plenum. On the exhaust plenum, one isolation damper (fire damper) was between the relay room and the relief dampers and the other isolation damper (ventilation damper) was downstream of the relief dampers. The relief dampers appeared to be set at a very low differential pressure (0.007 psid), and would relieve pressure into the Engineered Safeguards and Actuation System (ESAS) room, a room that required entry for alternative shutdown. This represented a potential CO2 migration path if the fire damper did not seal tightly, and this also represented a potential for over pressurization of the relay room if the fire damper did seal tightly.
* The relay room ventilation ducts were automatically isolated upon a CO2 discharge with two series dampers on both the exhaust plenum and the supply plenum. On the exhaust plenum, one isolation damper (fire damper) was between the relay room and the relief dampers and the other isolation damper (ventilation damper) was downstream of the relief dampers. The relief dampers appeared to be set at a very low differential pressure (0.007 psid), and would relieve pressure into the Engineered Safeguards and Actuation System (ESAS) room, a room that required entry for alternative shutdown. This represented a potential CO2 migration path if the fire damper did not seal tightly, and this also represented a potential for over pressurization of the relay room if the fire damper did seal tightly.
* The ESAS room contained the remote shutdown 'A' transfer panel, which was required for the alternative shutdown lineup in the event of a control room evacuation. There were also remote shutdown transfer switches in the IE 4160VAC switchgear room, which were only accessible by transiting through the ESAS room.
* The ESAS room contained the remote shutdown A transfer panel, which was required for the alternative shutdown lineup in the event of a control room evacuation. There were also remote shutdown transfer switches in the IE 4160VAC switchgear room, which were only accessible by transiting through the ESAS room.


Therefore, if CO2 was present in the ESAS room, it may impact alternative shutdown actions.
Therefore, if CO2 was present in the ESAS room, it may impact alternative shutdown actions.
Line 185: Line 186:
The team questioned AmerGen about the potential for CO2 to migrate from the relay room to areas required for alternative shutdown and about the potential for CO2 over pressurization in the relay room. AmerGen was unable to locate design documentation for the modifications to the relay room after the initial testing. AmerGen entered this issue in their corrective action program (AR 815641), isolated the CO2 system, placed a continuous fire watch in the relay room, and began a formal calculation to determine the pressure buildup in the relay room and the CO2 migration, if any.
The team questioned AmerGen about the potential for CO2 to migrate from the relay room to areas required for alternative shutdown and about the potential for CO2 over pressurization in the relay room. AmerGen was unable to locate design documentation for the modifications to the relay room after the initial testing. AmerGen entered this issue in their corrective action program (AR 815641), isolated the CO2 system, placed a continuous fire watch in the relay room, and began a formal calculation to determine the pressure buildup in the relay room and the CO2 migration, if any.


The team concluded that the identified issue concerning the migration and concentration of CO2 for the relay room CO2 system is an unresolved item pending further NRC review AmerGen's evaluation. URI 05000289/2008009-02, Potential CO2 Migration Outside the Relay Room Fire Area
The team concluded that the identified issue concerning the migration and concentration of CO2 for the relay room CO2 system is an unresolved item pending further NRC review AmerGens evaluation. URI 05000289/2008009-02, Potential CO2 Migration Outside the Relay Room Fire Area


===.06 Alternative Shutdown Capability===
===.06 Alternative Shutdown Capability===


====a. Inspection Scope====
====a. Inspection Scope====
Alternative shutdown capability for the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.
Alternative shutdown capability for the areas selected for inspection utilizes shutdown     from outside the control room and is discussed in section 1R05.01 of this report.


====b. Findings====
====b. Findings====
Line 198: Line 199:


====a. Inspection Scope====
====a. Inspection Scope====
The team verified that AmerGen 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 AmerGen's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The team verified that AmerGen 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 AmerGens analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.


The team's review considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
The teams review considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.


The team also reviewed cable routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.
The team also reviewed cable routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.
Line 210: Line 211:
* IC-P-1B, Intermediate Closed Cooling Water Pump B
* IC-P-1B, Intermediate Closed Cooling Water Pump B
* NS-P-1A, Nuclear Service Closed Cooling Water Pump A
* NS-P-1A, Nuclear Service Closed Cooling Water Pump A
* MU42-DPT, Reactor Coolant Pump Total Seal Injection Flow Transmitter The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.
* MU42-DPT, Reactor Coolant Pump Total Seal Injection Flow Transmitter The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.


====b. Findings====
====b. Findings====
Line 226: Line 227:


====a. Inspection Scope====
====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 and/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
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 and/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 in a manner that would ensure reliable operation.
 
practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.


====b. Findings====
====b. Findings====
Line 250: Line 249:


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
[OA]
[OA] {{a|4OA2}}
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems==
==4OA2 Identification and Resolution of Problems==


Line 260: Line 258:


====b. Findings====
====b. Findings====
No findings of significance were identified.  
No findings of significance were identified.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==


===Exit Meeting Summary===
===Exit Meeting Summary===
The team presented their preliminary inspection results to Mr. W. Noll and other members of the site staff at an exit meeting on September 12, 2008. No proprietary information was included in this inspection report. ATTACHMENT:
 
The team presented their preliminary inspection results to Mr. W. Noll and other members of the site staff at an exit meeting on September 12, 2008. No proprietary information was included in this inspection report.
 
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 272: Line 273:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::D. Barry]], System Engineer  
: [[contact::D. Barry]], System Engineer
: [[contact::T. Dougherty]], Plant Manager
: [[contact::T. Dougherty]], Plant Manager
T. Geyer. Engineering Programs Manager  
T. Geyer. Engineering Programs Manager
: [[contact::R. Harris]], Fire Systems Engineer  
: [[contact::R. Harris]], Fire Systems Engineer
: [[contact::A. Miller]], Senior Regulatory Specialist  
: [[contact::A. Miller]], Senior Regulatory Specialist
: [[contact::R. Myers]], Fire Marshal  
: [[contact::R. Myers]], Fire Marshal
: [[contact::W. Noll]], Site Vice President  
: [[contact::W. Noll]], Site Vice President
: [[contact::S. Queen]], Engineering Director  
: [[contact::S. Queen]], Engineering Director
: [[contact::S. Sallade]], Operations Engineer  
: [[contact::S. Sallade]], Operations Engineer
: [[contact::R. Sieglitz]], Fire Program Engineer  
: [[contact::R. Sieglitz]], Fire Program Engineer
: [[contact::B. Smith]], Safe Shutdown Engineer  
: [[contact::B. Smith]], Safe Shutdown Engineer
: [[contact::M. Taylor]], Corporate Fire Protection Engineer
: [[contact::M. Taylor]], Corporate Fire Protection Engineer
NRC
NRC
: [[contact::J. Rogge]], Chief, Engineering Branch 3, Division of Reactor Safety  
: [[contact::J. Rogge]], Chief, Engineering Branch 3, Division of Reactor Safety
: [[contact::W. Schmidt]], Senior Reactor Analyst, Division of Reactor Safety  
: [[contact::W. Schmidt]], Senior Reactor Analyst, Division of Reactor Safety
: [[contact::D. Kern]], Senior Resident Inspector, Three Mile Island Station  
: [[contact::D. Kern]], Senior Resident Inspector, Three Mile Island Station
: [[contact::J. Brand]], Resident Inspector, Three Mile Island Station  
: [[contact::J. Brand]], Resident Inspector, Three Mile Island Station


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


===Opened===
===Opened===
: 05000289/2008009-02  
: 05000289/2008009-02           URI           Potential CO2 Migration Outside the Relay Room Fire Area
===URI===
Potential CO2 Migration Outside the Relay Room Fire Area


===Opened and Closed===
===Opened and Closed===
: 05000289/2008009-01 NCV Inappropriate Use of Elevators by Fire Brigade Members  
: 05000289/2008009-01           NCV           Inappropriate Use of Elevators by Fire Brigade Members


===Closed===
===Closed===
: None  
 
None


===Discussed===
===Discussed===


None
None
Attachment
 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
Fire Protection Licensing Documents 
 
: TMI 1 Facility Operating License, License No.
: DPR-50
: TMI 1 Updated Final Safety Analysis Report, Rev. 19
: TMI 1 Fire Hazards Analysis Report, Rev. 23
: NRC Letter, TMI Unit 1, 10CFR Part 50 Appendix R Exemption Request, Dated 7/11/97
: NRC Safety Evaluation Report, Fire Protection, Supplement 5, Dated 11/19/80
: NRC Letter and Enclosures, Fire Protection for
: TMI-1, Dated 12/30/86
: NRC Letter and Enclosures, Fire Protection Exemptions for
: TMI-1, Dated 3/19/87
: AP 1038, Administrative Controls - Fire Protection Program, Rev. 70
: Calculations/Engineering Evaluation Reports/Design Bases Documents Report 0003, Tests to Determine Effect of Discharge of CO2 and Halon 1301 on Electronic Instrumentation, Rev. 0
: C-1101-911-E610-001, Appendix R 72 Hour Cold Shutdown Analysis, Rev. 0
: G/C 2734, Review of Associated Circuits for 10
: CFR 50, Appendix R, Electrical System Studies, Short Circuit and Coordination Review, Technical Report, Rev. 0
: C-1101-700-E420-015,
: TMI-1 Analysis of Multiple High Impedance Faults (MHIF) on Engineered Safeguards (ES) Buses, Rev. 0
: 329440-19, Multiple High Impedance Fault (MHIF) Evaluation for Non-vital 120V Buses ATA & ATB, Dated 1/8/07 GPUN Memo 5520-85-0520, Evaluation of Delayed EFW for Appendix R Requirements, Dated 10/1/85
===Procedures===
: 1038, Administrative Controls - Fire Protection Program, Rev. 70
: CC-AA-211, Fire Protection Program, Rev. 2
: ER-AA-610-1001, Performance Based Evaluations for Fire Protection, Rev. 3
: ER-AA-610-1002, Fire Protection Program Performance Indicators, Rev. 1
: OP-AA-201-003, Fire Drill Performance, Rev. 9
: OP-AA-201-004, Fire Prevention for Hot Work, Rev. 7
: OP-AA-201-005, Fire Brigade Qualification, Rev. 6
: OP-AA-201-006, Control of Temporary Heat Sources, Rev. 4
: OP-AA-201-008, Pre-Fire Plans, Rev. 1
: OP-AA-201-009, Control of Transient Combustible Material, Rev. 7
: OP-MA-201-007, Fire Protection System Impairment Control, Rev. 5
: OP-TM-201-009-1001, Transient Combustible Control, Rev. 5
: OP-TM-424-901, Emergency Feedwater, Rev. 1
: TQ-AA-127, Fire Brigade Training Program, Rev. 4
: OP-TM-AOP-001, Fire, Rev. 4
: OP-TM-AOP-001-A06, Fire In
: AB 305' Demineralizer and 1A ESV MCC Area, Rev. 1
: OP-TM-AOP-0011-A06, Fire In
: AB 305' Demineralizer and 1A ESV MCC
: Area Basis Document, Rev. 3
: OP-TM-AOP-001-C2A, Fire In 1P 480V Switchgear Room, Rev. 2 
: Attachment
: OP-TM-AOP-0011-C2A, Fire In 1P 480V Switchgear Room Basis Document, Rev. 3
: OP-TM-AOP-001-C3A, Fire In 1D
: ES 4160V Switchgear Room, Rev. 2
: OP-TM-AOP-0011-C3A, Fire In 1D
: ES 4160V Switchgear Room Basis Document, Rev. 3
: OP-TM-424-901, Emergency Feedwater, Rev. 1
: OP-TM-AOP-028, Loss of Instrument Air, Rev. 3
: OP-TM-AOP-0281, Loss of Instrument Air Basis Document, Rev. 2
: OP-TM-AOP-041, Loss of Seal Injection, Rev. 3
: OP-TM-AOP-0411, Loss of Seal Injection Basis Document, Rev. 2
: OP-TM-EOP-001, Reactor Trip, Rev. 9
: OP-TM-EOP-010, Emergency Procedure Rules, Guides and Graphs, Rev. 9
: OP-TM-EOP-020, Cooldown From Outside of Control Room, Rev. 9
: OP-TM-EOP-0201, Cooldown From Outside of Control Room Basis Document, Rev. 4
: OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5
: OP-TM-EOP-009, HPI Cooling, Rev. 5
: OP-TM-EOP-0091, HPI Cooling Basis Document, Rev. 0
: 20-Y-30, Repair of Appendix "R" Cold Shutdown and Remote Shutdown System Circuits, Rev. 13 1301-15.1, Appendix "R" Cold Shutdown Repair Material Inventory, Rev. 13
: 20-Y-30, Repair of Appendix "R" Cold Shutdown and Remote Shutdown System Circuits, Rev. 13 1301-15.1, Appendix "R" Cold Shutdown Repair Material Inventory, Rev. 13
: Completed Tests/Surveillances 
: 1302-13.2A, Inspect Emergency Lights Aux Building, Completed 8/19/08
: 1303-12.13, Fire System Testing Flush, Completed 8/31/07, 11/15/07
: 1303-12.17, Fire System Deluge Functional Test, Completed 10/3/05, 7/2/06, 4/3/07
: 1303-12.5, CO2 Fire Protection System Test, Completed 11/3/05, 11/4/07
: 1303-12.8B, Fire Protection Instrumentation Functional Test (CB 338'), Completed 5/23/06, 6/30/07, 6/2/08 1303-12.8C, Fire Protection Instrumentation Functional Test (CB 322'), Completed 1/25/06, 1/16/07, 1/18/08 1303-12.8F, Fire Protection Instrumentation Aux Building and Fuel Handling Building Functional Test, Completed 5/23/06, 4/8/07, 11/29/07, 4/15/08, 5/1/08 1303-12.8J, Incipient Fire Detector Instrumentation Functional Test, Completed 7/8/06, 7/12/07, 1/8/08, 4/6/08, 7/7/08 1303-13.2B, Inspect Emergency Lights Aux Building 305' Elevation, Completed 8/4/08
: 1303-13.2E, Inspect Emergency Lights Control Building 322' Elevation, Completed 7/2/08
: 1303-13.2F, Inspect Emergency Lights Control Building, Completed 7/4/08
: 3301-M1, Fire Pump Monthly Run, Completed 8/24/07, 10/11/07, 11/10/07
: 3303-A2, Fire Service Lube Flush, Completed 6/26/08
: 3303-A3, Fire Pump Capacity Test, Completed 7/2/07, 7/25/08
: Fire Service Main Header Flush Trend Data, Dated 2000-2008
: Quality Assurance (QA) Audits and Self Assessments
: NOSA-TMI-08-09, Fire Protection Program Audit Report, Dated 6/11/08
: 705155-03, TMI Triennial Fire Protection Preparatory Self Assessment, Dated 6/19/08 
: Attachment System Health Reports Fire Protection/Fire Safe Shutdown, 3rd Quarter 2007, 4th Quarter 2007, 1st Quarter 2008 
===Drawings===
and Wiring Diagrams 
: 1E-151-02-004, General Arrangement, Turbine Building, Rev. 7
: 1E-154-02-003, General Arrangement, Auxiliary and Fuel Handling Buildings, Rev. 10
: 1E-155-02-002, General Arrangement, Control Room Tower, Rev. 11
: 1E-155-02-003, General Arrangement, Control Room Tower, Rev. 12
: 1-FHA-027, Fire Area Layout - Auxiliary and Fuel Handling Buildings, Rev. 8
: 1-FHA-035, Fire Area Layout - Control Room Tower, Rev. 13
: E-214-036, Electrical Cable Trays Control Tower Below 322'-0" & 338'-6", Rev. 20
: E-214-037, Electrical Cable Trays Control Tower Below Elev. 355'-0", Rev. 20
: 2-231, Fire Service Water, Sheet 1, Rev. 102
: 2-231, Fire Service Water, Sheet 2, Rev. 12
: 2-231, Fire Service Water, Sheet 3, Rev. 13
: 2-231, Fire Service Water, Sheet 4, Rev. 6
: 2-231, Fire Service Water, Sheet 5, Rev. 1
: E-206-011, Electrical Main One Line & Relay Diagram, Rev. 51
: E-206-022, Electrical One Line & Relay Diagram 4160V. Engd. Safeguards Switchgear, Rev. 21
: 208-261, Electrical Elementary Diagram, 480V Switchgear (E.S.)
: DB-25 E.S. Motor Breaker for
: NS-P-1A &
: NR-P-1A, Rev. 1 208-351, Electrical Elementary Diagram, 480V Switchgear (E.S.) (1P-3C) Nuclear Service Closed Cooling Water Pump
: NS-P-1A, Rev. 8 208-426, Electrical Elementary Diagram, 480V Cont. Ctr. 1C-ESV-Unit 5C, Pressurizer Relief Block Valve
: RC-V-2, Rev. 7 208-527, Elementary Wiring Diag., 480V Cont. Ctr. 1A-ES-Unit 11A, Intermediate Cooling Closed Loop Pump 1C-P-1A, Rev. 8 208-528, Elementary Wiring Diag., 480V Cont. Ctr. 1B-ES-Unit 10A, Intermediate Cooling Closed Loop Pump 1C-P-1B, Rev. 7 208-756, Electrical Elementary Diagram, Remote Shutdown Transfer Switch Panel "A" "A" System, Rev. 4 209-077, Electrical Elementary Diagram, DC and Miscellaneous Intermediate Cooling Isolation Valve,
: IC-V-3, Rev. 10 209-078, Electrical Elementary Diagram, DC and Miscellaneous Intermediate Cooling Isolation Valve,
: IC-V-4, Rev. 8 210-469, Electrical Wiring Diagram, Remote Shutdown Transfer Switch Panel "B" Mounting Panel "X" and "X/B", Rev. 2 210-475, Electrical Wiring Diagram, Remote Shutdown Transfer Switch Panel "A" Mounting Panel "A" and "X", Rev. 3 AmerGen Engineering Data Base
: EDB-TMI-ECIS Cable Pull sheets for Cables:
: CG83, CG681, CG683, CG685, CG686, CH61, CH61A, CH601, CH601A, CH602, CH603, CH603A,
: CH604, CH605, CH606, CS33, CS33B, CS261, CS261B, CS261C, CS262, CS262A,
: CS263, CS264, CS265, CS266, ED117, LP6, LP6A, LP26, LP27, LP28, LP29, RE330,
: RE348, RE354, RV178, RV179, RV179A, RV180, RV181, RV185A 
: Attachment Piping and Instrumentation Diagrams 
: 2-011, Main Steam, Rev. 68
: 2-082, Emergency Feedwater, Rev. 24
: 2-279, Instrument Air, Sheets 7, 8 & 9, Revs. 11, 12 & 19
: 2-620, Intermediate Cooling, Rev. 50
: 2-640, Decay Heat Removal, Rev. 82
: 2-645, Decay Heat, Rev. 39
: 2-650, Reactor Coolant System, Rev. 55
: 2-661, Make-Up & Purification, Rev. 59
: Vendor Manuals
: VM-TM-2913, Seismic Industrial Emergency Lights, Rev. 2
: Pre-Fire Plans
: AB-FZ-6, Auxiliary Building Elevation 305' - Demineralizers and MCC 'A', Rev. 6
: AB-FZ-6A, Auxiliary Building Elevation 305' - MCC 'B', Rev. 8
: AB-FZ-7, Auxiliary Building Elevation 305' - Decay Heat Removal and Nuclear Services Closed Cycle Cooling Pump Area, Rev. 7
: CB-FA-2A, Control Building Elevation 322' - 480V ES
: CC-1A and 1P Swgr Rm, Rev. 7
: CB-FA-3A, Control Building Elevation 338'6" - 4160V Swgr 1D Room, Rev. 6 
: Fire Drills and Critique
: Fire Drill Records, Performed 1st Quarter 2007, 2nd Quarter 2007, 3rd Quarter 2007, 1st Quarter 2008 
: Hot Work and Ignition Source Permits 
: 2007-032 2008-002 2008-013 2008-015 2008-016 
===Miscellaneous Documents===
: Fire Brigade Training Record, Dated 1/1/07 to 8/26/08
: Fire System Impairment Log, Dated 8/26/08
: Letter from R. Wysocki to R. Prabhakar, Recommendation to Remove CO2 Nozzle Shells, Dated 10/5/76 Letter from E. Smith to D. McGettrick, Relief Damper Price Quote, Dated 12/22/77
: Letter from D. Goodman to R. Ritthamel, Test of CO2 Fire Suppression System in TMI Unit 1 Cable Spreading Room, Dated 4/14/76 Letter from J. Grier to T. Wysocki, Pressure Buildup and Vent Area Calculation for the Relay Room Dated, 5/17/76
: Memorandum from R. Prabhakar to D. Shovlin, Improving the Penetration Sealing of the Relay Room, Dated 3/8/1976
: Memorandum from F. Grice to J. Colitz, Test of CO2 System for Cable Spreading Room, Dated 4/15/76 
: Attachment
: Memorandum from V. Orlandi to J. Colitz, Test Results for the CO2 Discharge System for the Relay Room on March 19, 1977
: PRF-3-5, Alarm Response Procedure for CO2 Sys Actuated, Rev. 17
: SP-5701, Specification for Furnishing and Installing of Fire Protection and Detection Systems, Dated 7/1/69 Verbal Communication Form Dated 10/31/77 from R. Lefin to W. Brannen, CO2 in Cable Spreading Room RCP Seal Cooling and FHAR Plant Health Committee presentation slides Dated 7/23/08 
: Issue Reports, Action Requests, and Condition Reports 
: 2410
: 363944
: 365794
: 369355
: 371835
: 381120
: 458671
: 26384
: 568060
: 618555
: 645674
: 657399
: 658463
: 2705
: 736124
: 751354
: 761038
: 761085
: 761107
: 761206
: 761482
: 764265
: 783106
: 783176
: 788375
: 790537
: 2886
: 793979
: 796738
: 798200
: 801808
: 803770
: 811467
: 2129
: 813701
: 815641
: 815877
: 815894
: 815902
: 816236
: 816353
: 816765
===Work Orders===
: A2060055 A2060056
: C2016225
: C2016324
: R2009987
: R2010381
: R2039072
: R2058782 R2076275 R2076317
: R2076374
: R2076620
: R2076621
: R2076676
: R2076785
: R2076786 R2076787 R2076788
: R2076860
: R2076861
: R2076865
: R2076867
: R2076868
: R2076935 R2076952 R2076993
: R2077091
: R2077095
: R2077138
: R2077190
: R2077195 
: R2077363 R2077529 R2077551
: R2078723
: R2079282
: R2081891
: R2111884
: R2112355
==LIST OF ACRONYMS==
: [[AC]] [[Alternating Current]]
: [[ADA]] [[]]
MS Agency Documents Access and Management System
BTP  Branch Technical Position
: [[CFR]] [[Code of Federal Regulations]]
: [[CM]] [[]]
EB  Chemical Engineering Branch
CO2  Carbon Dioxide
DC  Direct Current
DRS  Division of Reactor Safety
: [[DRP]] [[Division of Reactor Projects]]
: [[ES]] [[]]
AS  Engineered Safeguards Actuation System
FA  Fire Area
: [[FZ]] [[Fire Zone]]
: [[FH]] [[]]
AR  Fire Hazards Analysis Report
Attachment
: [[FPP]] [[Fire Protection Program]]
IMC  Inspection Manual Chapter
: [[IP]] [[Inspection Procedure]]
: [[IPE]] [[]]
EE  Individual Plant Examination of External Events
IR  Inspection Report
: [[NCV]] [[Non-cited Violation]]
: [[NF]] [[]]
PA  National Fire Protection Association
NRC  Nuclear Regulatory commission
: [[PAR]] [[Publicly Available Records]]
: [[P&]] [[]]
ID  Piping and Instrumentation Drawing
: [[QA]] [[Quality Assurance]]
: [[SC]] [[]]
BA  Self-Contained Breathing Apparatus
SDP  Significance Determination Process
SER  Safety Evaluation Report
: [[TMI]] [[Three Mile Island]]
: [[UFS]] [[]]
AR Updated Final Safety Analysis Report
V  Volt
}}
}}

Latest revision as of 03:18, 22 December 2019

IR 05000289-08-009, on 08/25/2008 - 09/12/2008, Amergen Energy Company, LLC, Three Mile Island Station, Unit 1,Triennial Fire Protection Team Inspection, Fire Protection
ML082820110
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/07/2008
From: Rogge J
Engineering Region 1 Branch 3
To: Pardee C
AmerGen Energy Co, Exelon Generation Co
References
IR-08-009
Download: ML082820110 (27)
v • d • e


Text

ber 7, 2008

SUBJECT:

THREE MILE ISLAND NUCLER STATION, UNIT 1 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000289/2008009

Dear Mr. Pardee:

On September 12, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Three Mile Island Station, Unit 1. The enclosed inspection report documents the inspection results, which were discussed on September 12, 2008, with Mr. W. Noll 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, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Three Mile Island Station.

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 document system (ADAMS).

Mr. Charles 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 No. 50-289 License No. DPR-50 Enclosure: Inspection Report No. 05000289/2008009 w/Attachment: Supplemental Information

Mr. Charles

SUMMARY OF FINDINGS

IR 05000289/2008009; 08/25/2008 - 09/12/2008; AmerGen Energy Company, LLC; Three Mile

Island Station, Unit 1; Triennial Fire Protection Team Inspection, Fire Protection.

This report covered a two-week triennial fire protection team inspection by specialist inspectors.

One Green NCV was identified. 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

Reactor Oversight Process, Rev. 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The team identified that AmerGen allowed fire brigade members to use elevators during response to a fire, when the power or control to the elevator could be lost as a result of a fire. This finding was determined to be of very low safety significance (Green) and a NCV of the Three Mile Island Nuclear Station, Unit 1 Operating License condition 2.c.(4), Fire Protection.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator, potentially trapping fire brigade members and delaying their efforts to extinguish fires in safe shutdown areas. The team assessed this finding in accordance with NRC IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria because IMC 0609, Appendix F, Fire Protection Significance Determination Process specifically excludes findings associated with the performance of the fire brigade. Therefore this finding required regional branch chief review in accordance with IMC 0612, Power Reactor Inspection Reports. This finding was screened to very low safety significance (Green) based on IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria and the following considerations: the limited exposure time when brigade members would be in the elevator and AmerGens practice that the entire brigade did not enter the elevator all at once. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because when the issue of elevator usage by fire brigade members was raised by the NRC residents on November 29, 2007, the issue was not fully evaluated (P.1(c)).

(Section 1R05.04)

Licensee-Identified Violations

None.

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 AmerGen Energy Company, LLC, (AmerGen) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Three Mile Island (TMI)

Station, Unit 1. The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the TMI Individual Plant Examination of External Events (IPEEE):

  • CB-FA-2A
  • CB-FA-3A
  • CB-FA-3D

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 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and

Normal Shutdown

a. Inspection Scope

Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the FHAR. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown locations 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).

Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.

Operational Implementation The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite 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 to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions, which were verified included restoration of alternating current (AC) electrical power, establishing the remote shutdown panels, establishing reactor coolant makeup, and establishing decay heat removal.

Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:

  • OP-TM-AOP-001, Fire, Rev. 4
  • OP-TM-AOP-001-A06, Fire in AB 305 Demineralizer and 1A ESV MCC Area, Rev. 1
  • OP-TM-AOP-001-C2A, Fire in 1P 480V Switchgear Room, Rev. 2
  • OP-TM-AOP-001-C3A, Fire in 1D ES 4160V Switchgear Room, Rev. 2
  • OP-TM-EOP-020, Cooldown from Outside of Control Room, Rev. 9 The team reviewed manual actions to ensure that they had been properly reviewed and approved and that 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 capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.

b. Findings

No findings of significance were identified.

.02 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the FHAR, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of Section III.G of 10 CFR 50, Appendix R 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.

The team reviewed AmerGens 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 FHAR. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.

b. Findings

No findings of significance were identified.

.03 Passive Fire Protection

a. Inspection Scope

The team 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), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.

The team reviewed 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. The team also reviewed similar records for the fire protection wraps to ensure the material was of an appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings of significance were identified.

.04 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA)code of record or as NRC approved exemptions, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas.

A review of the design capability of the suppression agent delivery systems was verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, storage tanks and supply system) to assess the material condition of the systems and components.

The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed pre-fire plans and smoke removal plans for the selected fire areas 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. In addition, the team inspected the fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.

b. Findings

Introduction.

The team identified that AmerGen allowed fire brigade members to use elevators during response to a fire, when the power or control to the elevator could be lost as a result of a fire. This finding was determined to be of very low safety significance (Green) and a NCV of the Three Mile Island Nuclear Station, Unit 1 Operating License condition 2.c.(4), Fire Protection.

Description.

Based on FBP 11, Emergency Response Training Fire Brigade Program, FBP 11, The use of the plant elevators during a fire is a determination made by the fire brigade leader as a part of his initial size up. At TMI, fire brigade members were trained that elevator use is acceptable after establishing that the fire is not in the vicinity of the elevator. The fire brigade utilized the elevator to transport a fire cart and other fire fighting equipment.

The team questioned the use of elevators by the fire brigade, specifically considering the routing of power and control cables for the elevators. The team focused their review on the turbine building elevator due to its convenient location near the fire brigade storage room. AmerGen determined that control and power cables for the turbine building elevator run through the control building. The inspectors concluded that fires in certain areas of the control building, while not in the vicinity of the turbine building elevator, could damage the elevator power or control cables, which would disable the elevator. Also, if a fire occurred in any switchgear through which the elevator power was routed, then operators, by procedure, would deenergize the affected switchgear which would also disable the elevator. Fire brigade members utilizing the elevator during such circumstance risk being trapped and delayed or unable to respond.

AmerGen had committed to not using elevators in Section 5 of the Three Mile Island Fire Hazard Analysis Report in a comparison to the NRC Branch Technical Position APCSB 9.5-1, Appendix A. Part D.4(f) of this comparison states, Elevators are not used during fire emergencies.

AmerGen documented this issue in corrective action program condition report IR 816765. AmerGens immediate corrective actions included issuing a policy to all fire brigade members that elevators are not to be used during any fire scenario. AmerGen planned to formally evaluate the potential for prescribing future use of elevators in certain pre-fire plans, which may include a change to the BTP 9.5-1 comparison in the Fire Hazards Analysis Report. The team determined that allowing fire brigade members to use an elevator during a fire could disable the elevator is a performance deficiency.

The team also noted that fire brigade use of elevators was previously questioned by the NRC resident inspectors during their annual observation of a fire brigade drill on November 29, 2007. AmerGen initiated a condition report (IR 704915) to address the inspectors question. AmerGen closed the IR and documented that quarterly training was performed to reiterate the requirements to ensure that the elevator was not in the area of the fire or visibly affected by the fire. The associated condition report did not fully evaluate the issue in that the routing of power and control cables was not considered.

Analysis.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator, potentially trapping fire brigade members and delaying their efforts to extinguish fires in safe shutdown areas.

The team assessed this finding in accordance with NRC IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria because IMC 0609, Appendix F, Fire Protection Significance Determination Process specifically excludes findings associated with the performance of the fire brigade. Therefore this finding required regional branch chief review in accordance with IMC 0612, Power Reactor Inspection Reports. This finding was screened to very low safety significance (Green)based on IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria and the following considerations: the limited exposure time when brigade members would be in the elevator and AmerGens practice that the entire brigade did not enter the elevator all at once.

The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because when the issue of elevator usage by fire brigade members was raised by the NRC residents on November 29, 2007, the issue was not fully evaluated. (P.1(c))

Enforcement.

Three Mile Island Nuclear Station Operating License condition 2.c.(4)requires that AmerGen Energy Company, LLC shall implement and maintain in effect all provisions of the Fire Protection Program as described in the Updated FSAR for TMI-1.

The UFSAR section 9.9.2 states that the Fire Hazards Analysis Report is considered to be part of the Fire Protection Program. Section 5.0.D.4(f) of the Fire Hazards Analysis Report states, Elevators are not used during fire emergencies. Contrary to the above, for some period of time (and observed during a fire brigade drill on November 29, 2007)until September 12, 2008, AmerGen allowed fire brigade members to use elevators during fires which could disable the elevator. Because this finding was of very low safety significance (Green) and has been entered into AmerGens corrective action program (IR 00816765), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000289/2008009-01, Inappropriate Use of Elevators by Fire Brigade Members.

.05 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 are not subject to damage from fire suppression activities or from the rupture of inadvertent operation of fire suppression systems. Specifically, the team verified that:

  • A fire in one of the selected fire areas would not directly, 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 directly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train).
  • Adequate drainage is provided in areas protected by water suppression systems.

b. Findings

The team identified a potential concern regarding operation of the carbon dioxide (CO2)extinguishing system for the relay room. Specifically, the potential may exist for CO2 to migrate outside the relay room and affect the ability of operators to perform alternative shutdown activities. Likewise, with CO2 migration potential outside the relay room, the potential existed for less than adequate CO2 concentration in the relay room for fire suppression. This issue will remain unresolved pending further NRC review of AmerGens analysis of the issue.

The team reviewed the design and testing of the CO2 system for the relay room. The original CO2 discharge test in 1976 had some complications which required followup evaluations, further testing, and design change modifications. After the team reviewed the subsequent testing and design change documentation, the team had two remaining concerns: potential migration of CO2 into rooms outside the relay room and the concentration of CO2 in the relay room.

The original test report identified significant CO2 migration. CO2 levels were found as high as 6% in lower elevations of the adjacent fuel handling building patio area. The CO2 migration was addressed by several corrective actions including greater sealing of the room by installing tighter penetration seals and maintaining the doors closed instead of automatic door closing mechanisms. Because the room would then be sealed tighter, pressure relief dampers were added to prevent over pressurization of the relay room.

The team also made the following observations:

  • The gaps under the two doors from the relay room to the 1D 4160VAC switchgear room and the ESAS room were approximately one inch high. This represented a potential CO2 migration path to areas required for alternative shutdown operations.
  • The relay room ventilation ducts were automatically isolated upon a CO2 discharge with two series dampers on both the exhaust plenum and the supply plenum. On the exhaust plenum, one isolation damper (fire damper) was between the relay room and the relief dampers and the other isolation damper (ventilation damper) was downstream of the relief dampers. The relief dampers appeared to be set at a very low differential pressure (0.007 psid), and would relieve pressure into the Engineered Safeguards and Actuation System (ESAS) room, a room that required entry for alternative shutdown. This represented a potential CO2 migration path if the fire damper did not seal tightly, and this also represented a potential for over pressurization of the relay room if the fire damper did seal tightly.
  • The ESAS room contained the remote shutdown A transfer panel, which was required for the alternative shutdown lineup in the event of a control room evacuation. There were also remote shutdown transfer switches in the IE 4160VAC switchgear room, which were only accessible by transiting through the ESAS room.

Therefore, if CO2 was present in the ESAS room, it may impact alternative shutdown actions.

  • There was a louvered control rod drive mechanism power supply bus duct between the relay room and the fuel handling building patio area. This represented an additional potential CO2 migration path.

The team questioned AmerGen about the potential for CO2 to migrate from the relay room to areas required for alternative shutdown and about the potential for CO2 over pressurization in the relay room. AmerGen was unable to locate design documentation for the modifications to the relay room after the initial testing. AmerGen entered this issue in their corrective action program (AR 815641), isolated the CO2 system, placed a continuous fire watch in the relay room, and began a formal calculation to determine the pressure buildup in the relay room and the CO2 migration, if any.

The team concluded that the identified issue concerning the migration and concentration of CO2 for the relay room CO2 system is an unresolved item pending further NRC review AmerGens evaluation. URI 05000289/2008009-02, Potential CO2 Migration Outside the Relay Room Fire Area

.06 Alternative Shutdown Capability

a. Inspection Scope

Alternative shutdown capability for the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.

b. Findings

No findings of significance were identified.

.07 Circuit Analysis

a. Inspection Scope

The team verified that AmerGen 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 AmerGens analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.

The teams review considered fire and cable attributes, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.

The team also reviewed cable routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.

Cable failure modes were reviewed for the following components:

  • IC-V-3, Intermediate Closed Cooling Isolation Valve
  • RC-V-2, Pressurizer Relief Block Valve
  • IC-P-1A, Intermediate Closed Cooling Water Pump A
  • IC-P-1B, Intermediate Closed Cooling Water Pump B
  • NS-P-1A, Nuclear Service Closed Cooling Water Pump A
  • MU42-DPT, Reactor Coolant Pump Total Seal Injection Flow Transmitter The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.

b. Findings

No findings of significance were identified.

.08 Communications

a. Inspection Scope

The team reviewed safe shutdown procedures, the FHAR, 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 sound powered phone system cables, repeaters, and transmitters would not be affected by a fire.

b. Findings

No findings of significance were identified.

.09 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 and/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 in a manner that would ensure reliable operation.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team verified that AmerGen had dedicated repair procedures, equipment, and materials to accomplish repairs of components required for cold shutdown which might be damaged by the fire to ensure cold shutdown could be achieved within the time frames specified in their design and licensing bases. The team verified that the repair equipment, components, tools, and materials (e.g. pre-cut cables with prepared attachment lugs) were available and accessible on site.

b. Findings

No findings of significance were identified.

.11 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 AmerGen was effective in returning the equipment to service in a reasonable period of time.

b. Findings

No findings of significance 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 AmerGen 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 AmerGen had taken or planned appropriate corrective actions.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented their preliminary inspection results to Mr. W. Noll and other members of the site staff at an exit meeting on September 12, 2008. No proprietary information was included in this inspection report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Barry, System Engineer
T. Dougherty, Plant Manager

T. Geyer. Engineering Programs Manager

R. Harris, Fire Systems Engineer
A. Miller, Senior Regulatory Specialist
R. Myers, Fire Marshal
W. Noll, Site Vice President
S. Queen, Engineering Director
S. Sallade, Operations Engineer
R. Sieglitz, Fire Program Engineer
B. Smith, Safe Shutdown Engineer
M. Taylor, Corporate Fire Protection Engineer

NRC

J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
W. Schmidt, Senior Reactor Analyst, Division of Reactor Safety
D. Kern, Senior Resident Inspector, Three Mile Island Station
J. Brand, Resident Inspector, Three Mile Island Station

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000289/2008009-02 URI Potential CO2 Migration Outside the Relay Room Fire Area

Opened and Closed

05000289/2008009-01 NCV Inappropriate Use of Elevators by Fire Brigade Members

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

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