IR 05000247/2007006

IR 05000247-07-006; on 04/23 - 05/18/2007; Indian Point Nuclear Generating, Unit 2; Triennial Fire Protection Team Inspection

ML071730036
Person / Time
Site:	Indian Point
Issue date:	06/20/2007
From:	Rogge J Engineering Region 1 Branch 3
To:	Dacimo F Entergy Nuclear Operations
References
IR-07-006
Download: ML071730036 (21)

Text

une 20, 2007

SUBJECT:

INDIAN POINT UNIT 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000247/2007006

Dear Mr. Dacimo:

On May 17, 2007, the NRC completed a triennial fire protection team inspection at your Indian Point Nuclear Generating Unit 2. The enclosed report documents the inspection results, which were discussed at an exit meeting on May 17, 2007, with you 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, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety

June 20, 2007 Mr. Fred Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 SUBJECT: INDIAN POINT UNIT 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000247/2007006

Dear Mr. Dacimo:

On May 17, 2007, the NRC completed a triennial fire protection team inspection at your Indian Point Nuclear Generating Unit 2. The enclosed report documents the inspection results, which were discussed at an exit meeting on May 17, 2007, with you 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, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety SUNSI Review Complete: JFR (Reviewers Initials)

DOCUMENT NAME: C:\FileNet\ML071730036.wpd After declaring this document An Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRS N RI/DRP RI/DRS NAME RFuhrmeister/RF ECobey/JDO for JRogge/JFR DATE 06/7/07 06/14/07 06/20/07 OFFICIAL RECORD COPY

• See Previous Concurrence Page ADAMS ACC # ML071730036 Docket No. 50-247 License No. DPR-26

Enclosure:

NRC Inspection Report 05000247/2007006

REGION I==

Docket No. 50-247 License No. DPR-26 Report No. 05000247/2007006 Licensee: Entergy Nuclear Northeast (Entergy)

Facility: Indian Point Nuclear Generating Unit 2 Location: 450 Broadway, GSB Buchanan, NY 10511-0249 Dates: April 23, 2007 through April 27, 2007 and May 14, 2007 through May 18, 2007 Inspectors: R. Fuhrmeister, Senior Project Engineer, DRP L. Cheung, Senior Reactor Inspector, DRS M. Patel, Reactor Inspector, DRS K. Diederich, Reactor Inspector, DRS Approved by: John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000247/2007006; 04/23 - 05/18/2007; Indian Point Nuclear Generating Unit 2; Triennial

Fire Protection Team Inspection.

The report covered a two-week triennial fire protection team inspection by a Region I senior project inspector and three Region I specialist inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

Reactor Oversight Process, Revision 3, dated July 2000.

NRC-Identified Findings

No findings of significance were identified.

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 Entergy Nuclear Northeast has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Indian Point Energy Nuclear Generating Unit 2 (IP2). The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the IP2 Individual Plant Examination (IPE) and Individual Plant Examination of External Events (IPEEE):

C Fire Area P, FZ-1 C Fire Area A, FZ-1A C Fire Area A, FZ-11 C Fire Area I, FZ-22/63A The inspection team evaluated Entergys fire protection program (FPP) against applicable requirements which included facility operating license condition 2.K, NRC safety evaluation reports, 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), the fire hazards analysis (FHA) and the post-fire safe shutdown analysis (SSA).

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

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems

1R05 Fire Protection

.01 Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown)

and Normal Shutdown

a. Inspection Scope

Methodology The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation 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 safe shutdown and fire hazards analyses. 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 post-fire safe shutdown 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 failures.

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 were trained, available onsite at all times, and exclusive of those assigned as fire brigade members.

The team reviewed the adequacy of procedures utilized for post-fire safe 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 operators could reasonably be expected to perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions which were verified included restoring alternating current (AC) electrical power, establishing alternate shutdown system operation, 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:

C 2-AOP-SSD-1, Rev. 9, Control Room Inaccessibility Safe Shutdown Control C 2-ONOP-FP-001, Rev. 2, Plant Fires 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 selected fire area. The team also reviewed periodic testing records of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests demonstrated 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 fire hazards analysis, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that separation requirements of 10 CFR 50, Appendix R, Section III.G, were maintained for the credited safe shutdown equipment including 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 Entergys procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and controlling combustible loading within limits established in the Combustible Loading Calculation. 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 also reviewed Entergys design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program, post-fire safe shutdown analysis, and procedures.

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) to ensure they were appropriate for the fire hazards in the area.

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 NFPA code of record and that they would control or extinguish fires associated with the hazards in the selected areas. A review of the design capability of suppression agent delivery systems were verified to meet the code requirements for the fire hazards involved. The team also performed a walkdown of accessible portions of the detection and suppressions systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire protection pumps, Halon 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 also assessed the fire brigade capabilities by reviewing training and qualification records, drill critique records, and observing live fire training. 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.

b. Findings

No findings of significance were identified.

.05 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team reviewed documents and walked down the selected fire areas to verify that redundant trains of systems required for hot shutdown were not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:

C 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, C 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 safe shutdown trains (e.g., sprinkler caused flooding of other than the locally affected train), and C Adequate drainage was provided in areas protected by water suppression systems.

b. Findings

No findings of significance were identified.

.06 Alternative Shutdown Capability

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

.07 Circuit Analyses

a. Inspection Scope

The team verified that Entergy performed a post-fire safe shutdown analysis for the selected fire areas and that the analysis appropriately identified the structures, systems and components important to achieving and maintaining post-fire safe shutdown.

Additionally, the team verified that Entergys 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 construction details, cable failure modes, spurious actuations, actuations resulting in flow diversion or loss of coolant events.

The team also reviewed wiring diagrams and routing lists for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing reports.

Cable failure modes were reviewed for the following components:

C Charging Pumps 21 and 23, C Service Water Pump 24, C Auxiliary Feedwater Pump 21, C Component Cooling Pump 23, and C Circuit breakers associated with the 13.8 kV Alternate Safe Shutdown Power System.

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 and 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 SSA 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 plant operators. The team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.

b. Findings

No findings 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 and evaluated their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests and battery replacement practices were 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

The team verified that Entergy 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 specific in their design and licensing bases. The inspectors verified that the repair equipment, components, tools and materials (e.g. pre-cut cables with prepared attachment lugs) were available and accessible on site.

.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, 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 Entergy was effective in returning the equipment to service in a reasonable period of time.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.01 Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team verified that Entergy 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 Entergy had completed or planned appropriate corrective actions.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On May 18, 2007, the team presented the inspection results to Mr. F. Dacimo, Site Vice President, and other members of the site staff. No proprietary information was included in this inspection report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy Nuclear Operations, Inc.

R. Burroni, Manager, Programs and Components

S. Wilkie, Senior Fire Protection Engineer

J. Cottam, Fire Protection Engineer

K. Elliott, Fire Protection Engineer

J. Etzweiler, Operations Supervisor

A. Singer, Training Supervisor

M. Yee, Electrical Engineer

G. Dahl, Licensing Technical Specialist

NRC

J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety

W. Cook, Senior Reactor Analyst, Division of Reactor Safety

M. Cox, Senior Resident Inspector, IP2

D. Jackson, Acting Senior Resident, IP3

G. Bowman, Resident Inspector, IP2

B. Wittick, Resident Inspector, IP3

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None Open and

Closed

None

Closed

None

Discussed

None