IR 05000354/2006014

IR 05000354-06-014; 08/28/2006 - 09/14/ 2006; Hope Creek Nuclear Generating Station; Triennial Fire Protection Team Inspection

ML062750431
Person / Time
Site:	Hope Creek
Issue date:	10/02/2006
From:	Rogge J Engineering Region 1 Branch 3
To:	Levis W Public Service Electric & Gas Co
References
IR-06-014
Download: ML062750431 (23)

Text

ber 2, 2006

SUBJECT:

HOPE CREEK NUCLEAR GENERATING STATION - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000354/2006014

Dear Mr. Levis:

On September 14, 2006, the NRC completed a triennial fire protection team inspection at your Hope Creek Nuclear Generating Station. The enclosed report documents the inspection results which were discussed at an exit meeting on September 14, 2006, with Mr. P. Davison 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 Docket No. 50-354 License No. NPF-57

Enclosure:

NRC Inspection Report 05000354/2006014

Mr. William Levis 2

REGION I==

Docket No. 50-354 License No. NPF-57 Report No. 05000354/2006014 Licensee: Public Service Enterprise Group Nuclear LLC Facility: Hope Creek Nuclear Generating Station Location: P. O. Box 236 Hancocks Bridge, NJ 08038 Dates: August 28 - September 14, 2006 Inspectors: D. Orr, Senior Reactor Inspector, DRS L. Cheung, Senior Reactor Inspector, DRS J. Bobiak, Reactor Inspector, DRS T. Sicola, Reactor Inspector, DRS Approved by: John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000354/2006014; 08/28/2006 - 09/14/ 2006; Hope Creek Nuclear Generating Station;

Triennial Fire Protection Team Inspection.

The report covered a two week triennial fire protection team inspection by four 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 PSEG Nuclear, LLC, has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Hope Creek Nuclear Generating Station. The following four fire areas (FAs) were selected for detailed review based on risk insights from the Hope Creek Individual Plant Examination of External Events (IPEEE):

C Fire Area CD 46 C Fire Area CD 31 C Fire Area CD 61 C Fire Area CD 84 The inspection team evaluated PSEGs fire protection program (FPP) against applicable requirements which included plant technical specifications, Hope Creek operating license condition 2.C.7, NRC safety evaluation reports, 10 CFR 50.48 and 10 CFR 50 Appendix R. The team also reviewed related documents that included the Hope Creek Updated Final Safety Analysis Report (UFSAR) Section 9.5.1 and Appendix 9A, and the Hope Creek fire hazards analysis (FHA) and the post-fire safe shutdown analysis.

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 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 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 safe shutdown would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown location 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 all safe shutdown methods were trained, available onsite at all times, and exclusive of 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 verify adequate procedure implementation and human factors considerations. The team also verified that operators could reasonably perform specific actions within the time required to maintain plant parameters within specified limits. Time critical actions which were verified included restoring AC electrical power, establishing remote shutdown panel operation, and removing decay heat.

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

C HC.OP-IO.ZZ-0008(Q), Shutdown From Outside Control Room, Revision 23 C HC.OP-AB.HVAC-0002(Q), Control Room Environment, Revision 2 C HC.FP-EO.ZZ-0001(Q), Nuclear Fire Protection Fire and Medical Emergency Response Manual Hope Creek Control Room Fire Response, Revision 6 C HC.OP-IO.ZZ-0004(Q), Shutdown From Rated Power to Cold Shutdown, Revision 67 The team reviewed manual actions and ensured that each action was properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support safe shutdown for each fire area. The team also reviewed periodic testing records of the alternate shutdown transfer capability and instrumentation and control functions to ensure the tests demonstrated functionality of the alternate shutdown method.

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 CRF 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 reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support systems for adequacy.

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

The team also reviewed PSEGs 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 safe shutdown 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 the material condition and design adequacy of fire area boundaries such as walls, fire doors and fire dampers, and electrical raceway fire barriers and ensured each feature was appropriate for the fire hazards within the area.

The team reviewed several penetration seal installation, repair, or qualification records and ensured the fill material was of the appropriate fire rating and that the installation satisfied design requirements.

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 deviations, and that each suppression system would control or extinguish fires associated for the hazards in the selected areas. A review of the design capability of suppression agent delivery systems was 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 support equipment (e.g., fire protection pumps, carbon dioxide (CO2) storage tanks and supply system) and assessed 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 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. For the selected fire areas, the team reviewed pre-fire plans, which included smoke removal plans, to determine if appropriate information was available to fire brigade members and plant operators such as potentially affected safe shutdown equipment, fire hazards, available fire suppression systems, and firefighting and operational considerations. Additionally, the team inspected the fire brigades protective ensembles, self-contained breathing apparatus (SCBA), and various fire brigade equipment, including smoke removal equipment, to verify fire fighting readiness.

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 would not directly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage the redundant safe shutdown train, C A fire (or the inadvertent actuation or rupture of a fire suppression system)would not directly cause damage to the redundant safe shutdown train (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 PSEG 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 PSEGs 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 concerns. Specific items included the credibility of fire, cable insulation attributes, cable failure modes, spurious actuations, and 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 matrices.

Cable failure modes were reviewed for the following components:

C Reactor core isolation cooling (RCIC) turbine steam supply valves FC-HV-F007 and FC-HV-F008, C RCIC pump discharge valves BD-HV-F012 and BD-HV-F013, C RCIC lube oil cooler isolation valve BD-HV-F046, C Main steam safety relief valve solenoids SOV- 3852A and B, C B residual heat removal (RHR) motor, and C Reactor water level transmitter BB-LT-7854-1 to remote shutdown panel.

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 the coordination studies 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 post-fire safe shutdown analysis and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review, the team considered the effects of ambient noise levels, clarity of reception, reliability and coverage patterns.

The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade. The team 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 emergency lights throughout the selected fire areas and evaluated adequacy for illuminating access and egress pathways, equipment requiring local operation, or instrumentation monitoring. 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

As stated in the Hope Creek fire hazards analysis, PSEG does not rely on cold shutdown repairs since one redundant safe shutdown train will always remain free of fire damage. This section of the report is not applicable.

.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 PSEG 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 PSEG 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 PSEG completed or planned appropriate corrective actions.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On September 14, 2006, the team presented the inspection results to Mr. P. Davison, Director of Engineering - Hope Creek, and other members of the site staff. No proprietary information was included in this inspection report.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

PSEG Personnel

J. Baker, Senior Reactor Operator

J. Barstow, Regulatory Assurance Compliance Engineer

B. Booth, Operations Manager

J. Carlin, Fire Protection Supervisor

P. Davison, Director of Engineering - Hope Creek

P. Finch, Safe Shutdown Engineer

M. Jesse, Regulatory Assurance Manager

K. Knaide, Engineering Programs Manager

B. Kopchick, Senior Reactor Operator

T. MacEwen, Senior Reactor Operator

A. Ponessa, Fire Protection Superintendent

M. Reeser, Fire Protection Engineer

M. Tadjalli, Design Engineering Manager

Exelon Personnel

C. Pragman, Corporate Fire Protection Program Manager

M. Taylor, Corporate Fire Protection

NRC

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

C. Cahill, Senior Reactor Analyst

G. Malone, Senior Resident Inspector

State of New Jersey

E. Rosenfeld, Department of Environmental Protection, Bureau of Nuclear Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None Open and

Closed

None

Closed

None

Discussed

None