IR 05000333/2014008
| ML15033A238 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/02/2015 |
| From: | Rogge J F Engineering Region 1 Branch 3 |
| To: | Brian Sullivan Entergy Nuclear Northeast |
| Rogge J F | |
| References | |
| IR 2014008 | |
| Download: ML15033A238 (28) | |
Text
SUBJECT:
(James A. FitzPatrick Nuclear Power Plant) - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000333/2014008
Dear Mr. Sullivan:
On December 19, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at James A. FitzPatrick Nuclear Power Plant. The enclosed inspection report documents the inspection results, which were discussed with you and members of your staff on December 18, 2014, and by telephone on January 28, 2015. The inspection examined activities conducted under your license as they relate to safety and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions. Based on the results of this inspection, no NRC-identified or self-revealing findings were identified during this inspection. However, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy. If you contest the violation or significance of the NCV, 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 James A. FitzPatrick Nuclear Power Plant. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the Resident Inspector at James A. FitzPatrick Nuclear Power Plant. February 2, 2015 In accordance with Title 10 of the Code of Federal Regulations electronically for public inspection in the NRC Public Document Room or from the Publicly 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. 50-333 License No. DPR-59 Enclosure: Inspection Report No. 05000333/2014008 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ
ADAMS ML: 15033A238 SUNSI Review Non-Sensitive Publicly Available OFFICE RI/DRS RI/DRS NAME RFuhrmeister JRogge DATE 01/16/2015 02/02//2015 Distribution w/encl: (via E-mail) D. Dorman, RA (R1ORAMAIL RESOURCE) D. Lew, DRA (R1ORAMAIL RESOURCE) H. Nieh, DRP (R1DRPMAIL RESOURCE) M. Scott, DRP (R1DRPMAIL RESOURCE) R. Lorson, DRS (R1DRSMAIL RESOURCE) J. Trapp, DRS (R1DRSMAIL RESOURCE) A. Burritt, DRP T. Setzer, DRP J. Petch, DRP E. Knutson, DRP, SRI B. Sienel, DRP, RI M. Paulus, DRP, AA R. Fuhrmeister, DRS J. Rogge, DRS W. Schmidt, DRS M. McLaughlin, ORA K. Morgan-Butler, RI OEDO RidsNrrPMFitzPatrick Resource RidsNrrDorlLpl1-1 Resource ROPreports Resource i Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No.: 50-333 License No.: DPR-59 Report No.: 05000333/2014008 Licensee: Entergy Nuclear Northeast Facility: James A. FitzPatrick Nuclear Power Plant Location: 277 Lake Road Oswego, NY 13126 Dates: December 1-5 and December 15-19, 2014 Inspectors: R. Fuhrmeister, Senior Reactor Inspector, DRS (Team Leader) W. Schmidt, Senior Reactor Analyst, DRS D. Orr, Senior Reactor Inspector, DRS J. Rady, Reactor Inspector, DRS L. Dumont, Reactor Inspector, DRS Approved by: John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety ii Enclosure
SUMMARY OF FINDINGS
IR 05000333/2014008; 12/01/2014 12/19/2014; Entergy Nuclear Northeast; James A. FitzPatrick Nuclear Power Plant; Triennial Fire Protection Baseline Inspection. The report covered a two-week triennial fire protection team inspection by specialist inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) cance Determination Process. Cross-cutting aspects associated with findings are determined using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the significance determination process (SDP) does not apply may be Green or be assigned a severity level after NRC management review. The reactors is described in NUREG-
Cornerstone: Initiating Events, Mitigating Systems
No findings were identified.
Other Findings
- A violation of very low safety significance was identified by Entergy staff and has been reviewed by the inspectors. Corrective actions taken or planned by Entergy staff have been entered into is violation and the CAP tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 711was to assess whether Entergy Nuclear Northeast (Entergy) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick) facility. The following fire zones (FZs) were selected for detailed review based on risk insights from the FitzPatrick Individual Plant Examination (IPE)/Individual Plant Examination of External Events (IPEEE).
FZ RR-1, Relay Room FZ RB- FZ RB-1W, Reactor Building, West Crescent Area Inspection of these fire zones fulfills the inspection procedure requirement to inspect a minimum of three samples. The inspection team evaluated Entergyagainst applicable requirements which included plant Technical Specifications, Operating License Condition 2.C(3), 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 9.8, the fire hazards analysis (FHA), and the post-fire safe shutdown analyses. The team also evaluated one Entergy mitigating strategy for addressing large fires and explosions as required by Operating License Condition 2.R and 10 CFR 50.54(hh)(2). Inspection of this strategy fulfills the inspection procedure requirement to inspect a minimum of one sample. Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R05 Fire Protection (IP 71111.05T)
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The team reviewed the FHA, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that applicable separation requirements of Section III.G of 10 CFR 50, Appendix R, and Entergy were maintained for the credited safe shutdown equipment and their supporting power, control and instrumentation cables.
This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to evaluate whether the material conditions of the fire area boundaries were adequate for the fire hazards in the area. The team compared the fire area boundaries, including walls, ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway and conduit fire barriers, and redundant equipment fire barriers and radiant energy heat barriers to design and licensing basis requirements, industry standards, and the FitzPatrick FPP, as approved by the NRC, to identify any potential degradation or non-conformances. The team reviewed selected engineering evaluations, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating. The team also reviewed recent inspection records for penetration seals and fire barriers, to verify whether the inspection was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified. In addition, the team reviewed recent test results for the carbon dioxide (CO2) fire damper functionality tests for the Relay Room to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The team evaluated manual and automatic fire suppression and detection systems in the selected fire areas to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements, National Fire Protection Association (NFPA) codes of record, and the FitzPatrick FPP, as approved by the NRC. The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas.
The team reviewed the as-built capability of the fire water supply system to verify the design and licensing basis and NFPA code of record requirements were satisfied, and to assess whether those capabilities were adequate for the hazards involved. The team reviewed the fire water system to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus concurrent fire hose usage. The team evaluated the fire pump performance tests to assess the adequacy of the test acceptance criteria for pump minimum discharge pressure at the required flow rate, to verify the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied. The team also evaluated the underground fire loop flow tests to verify the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed recent pump and loop flow test results to verify the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified. The team reviewed routine functional testing for the carbon dioxide (CO2) suppression systems for the Relay Room. The team walked down accessible portions of the CO2 system, including storage tanks and supply systems, to independently assess the material condition, operational lineup, and availability of the systems. The team also reviewed and walked down the associated firefighting strategies and CO2 system operating procedures. The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire pumps, interviewed system and program engineers, and reviewed selected condition reports (CRs) to independently assess the material condition of the systems and components. In addition, the team reviewed recent test results for the fire detection and suppression systems for the selected fire areas to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified. The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed Entergy's firefighting strategies (i.e., 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.
The team independently inspected the fire brigade equipment, including personnel protective gear (e.g., turnout gear) and smoke removal equipment, to determine operational readiness for firefighting. In addition, the team reviewed Entergy's fire brigade equipment inventory and inspection procedure and recent inspection and inventory results to verify adequate equipment was available, and any potential material deficiencies were identified.
b. Findings
No findings were identified.
.04 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that: A fire in one of the selected fire areas would not indirectly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains; A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not indirectly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and, Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings were identified.
.05 Post-Fire Safe Shutdown Capability
Normal and Alternative
a. Inspection Scope
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents for the selected fire areas to verify that Entergy had properly identified the systems and components necessary to achieve and maintain safe shutdown conditions. The team assessed the adequacy of the selected systems and components for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included verification that alternative post-fire shutdown 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. The team verified that the systems and components credited for use during shutdown would remain free from fire damage. 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.
Specific procedures reviewed for normal and alternative post-fire shutdown included the following: AOP-28, Operations During Plant Fires, Rev. 21; and, AOP-43, Plant Shutdown from Outside the Control Room, Rev. 37. 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 were identified.
.06 Circuit Analysis
a. Inspection Scope
The team verified that Entergy 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 Entergys analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown. cable routing, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events. The team also reviewed cable raceway drawings and/or cable routing databases for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the safe-shutdown analysis. The team also reviewed equipment important to safe shutdown, but not part of the success path, to verify that Entergy had taken appropriate actions in accordance with the design and licensing basis and NRC Regulatory Guide 1.189, Revision 2.
Circuit analysis was performed for the following components: 10MOV-12B 10MOV-89B 10P-3D RHR 14MOV-12B 02-3LI-95 Reactor Vessel Level Indicator 02-3PI-60B Reactor Vessel Pressure Indicator The team reviewed a sample of circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination that could result in a common power supply or common bus concern.
The team verified that the transfer of control from the control room to the alternative shutdown location(s) would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and sound-powered headsets for plant operators. The team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.
a. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
This objective of the inspection procedure was not applicable to JAFNPP as its safe shutdown methodology does not require any cold shutdown repairs.
b. Findings
N/A
.10 Compensatory Measures
a. Inspection Scope
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that Entergy was effective in returning the equipment to service in a reasonable period of time. The team noted that for the selected fire areas which were designated as 10 CFR 50 Appendix R, Section III.G.2 areas, there were no compensatory measures in the form of operator manual actions.
b. Findings
No findings were identified.
.11 Fire Protection Program Changes
a. Inspection Scope
The team reviewed recent changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown.
b. Findings
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The team reviewed Entergyand transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. The team performed plant walkdowns to verify that transient combustible and ignition source controls were being implemented in accordance with the administrative procedures.
b. Findings
No findings were identified.
.13 Large Fires and Explosions Mitigation Strategies
a. Inspection Scope
The reviewing one mitigating strategies, the ability to refill the condensate storage tanks, to verify continued compliance to License condition 2.R and 10 CFR 50.54 (hh)(2) by determining that: Procedures are being maintained and adequate; Equipment is properly staged and is being maintained and tested; and, Station personnel are knowledgeable and can implement the procedures.
b. Findings
No findings were identified.
OTHER ACTIVITIES
[OA]
4OA2 Identification and Resolution of Problems
.01 Corrective Actions for Fire Protection Deficiencies
a. Inspection Scope
The team verified that 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 taken or planned appropriate corrective actions.
b. Findings
No findings were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion
.01 (Closed) Licensee Event Report (LER) 05000333/2013-003-00
On October 31, 2013, while reviewing industry operating experience, JAFNPP personnel determined that the plant was also susceptible to unfused DC ammeter wires creating an unanalyzed condition. The ammeter wires are connected to shunts on the positive side of the batteries and chargers. The ammeter wiring connected to the shunts does not contain overcurrent protection devices. It is postulated that a fire could cause one of these ammeter wires too short to ground at the same time the fire causes another wire, connected to the negative terminal of the same battery, to also short to ground. This could cause a ground loop through the unfused ammeter cable. With enough current going through the cable, the potential exists that the cable could self-heat to the point of causing a secondary fire in the electrical trays at some point along the length of the cable or possibly heat up to the point of causing damage to adjacent cables that may be needed for safe shutdown. The issue results from design and construction practices and standards in the 1960s and 1970s when the facility was designed and built. Entergy will be installing fuses in the circuit under modification EC 48868. The condition was reported to the NRC and documented in condition report CR-JAF-2013-05546. This LER is closed. The enforcement aspects of this issue are discussed in Section 4OA7.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. B. Sullivan, Site Vice President and other members of the site staff at an exit meeting on December 18, 2014, and by telephone on January 28, 2015. No proprietary information was included in this inspection report.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by Entergy and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.
.01 Unfused DC Ammeter Circuits Result in Unanalyzed Condition
Introduction:
The team determined that the condition identified in LER 50-333/2013-003 constituted a Green violation of Condition 2.C(3) of Renewed Facility Operating License DPR-59, in that Entergy did not ensure that equipment required for post-fire safe shutdown was protected from the effects of a postulated fire. Specifically, Entergy did not provide overcurrent protection for wiring associated with DC ammeter indication in the control room to prevent the wires from overheating due to fire-induced faults. The issue was identified by Entergy during review of industry operating experience.
Description:
the Davis-Besse and Cooper stations, plant staff determined that the condition pertains to JAFNPP. ammeter circuits contains a shunt in the current flow from each DC battery, with leads to an ammeter in the main control room. The ammeter wiring attached to the shunts does not have overcurrent protection devices, and if one of the ammeter wires shorts to ground during a fire at the same time another DC wire from the opposite polarity on the same battery also shorts to ground (as a result of the fire), a ground loop through the unprotected ammeter cable could occur. With enough current flowing through the cable, the potential exists that the overloaded ammeter wiring could damage safe shutdown wiring in physical contact with the cable resulting in a loss of the associated safe shutdown component or a secondary fire in another fire area. The cause of the condition is that the original design criteria did not specify overcurrent protection for shunt fed ammeter circuits.
Renewed Facility Operating License DPR-59, condition 2.C(3) requires Entergy to implement and maintain the fire protection program as documented in the Updated Final Safety Analysis Report and approved in various safety evaluation reports (SERs) including the SER dated August 1, 1979. Section 5.11 of the SER dated August 1, 1979 evaluates the Battery Charger Rooms, and concluded that with the proposed modifications (installation of fire detection and signaling systems), the areas will meet the objectives set out in Section 2.2 of the SER, and are therefore acceptable. The objectives set out in Entergy did not meet this requirement, and did not protect other safe shutdown equipment from the effects of postulated fires. Entergy initiated condition report CR-JAF-2013-05546 for evaluation and resolution of the condition. Entergy reported the issue to NRC on October 31, 2013 via event notification 49491 in accordance with 10 CFR 50.72, and initiated LER 50-333/2013-003 to report the issue to NRC in accordance with 10 CFR 50.73. Entergy implemented compensatory measures in accordance with their technical requirements manual for degraded barriers to prevent the spread of a fire to other areas. Entergy subsequently initiated design change EC 48868 to install fuses in the DC ammeter circuits. The team concluded that Entemeasures were commensurate with the risk significance of the issue.
Analysis:
fires was a performance deficiency. This issue is more than minor because it is associated with the External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems to prevent undesirable consequences. Specifically, the availability of safe shutdown cables was not ensured for fires in the Battery Charger Rooms, Battery Room Corridor, Cable Spreading Room, Relay Room, and Control Room. As stated previously, Entergy entered this issue into the corrective action program and promptly initiated compensatory measures in accordance with their fire protection program. Inspection Manual Chapter (IMC) other areas if the cable ignited, the condition was considered a high degradation of the fire confinement category. As a result, the issue did not screen in Phase 1. Phase 2 requires the development of credible fire scenarios. An NRC inspector reviewed cable routing information for the ammeter cabling and walked down the cable routing in the plant. The inspector determined that there were no in-situ or transient combustible materials which could result in a credible exposure fire to cause damage to the ammeter cables.
This meets the screening criteria of IMC 0609, Appendix F, Step 2.3.5. Therefore, the inspector determined that this licensee-identified violation would be of very low safety significance (Green). In addition, tmeasures for degraded fire barriers until final resolution of the issue is completed was commensurate with the risk significance. Cross-cutting aspects are not applicable to old design issues which do not represent current performance.
Enforcement:
Condition 2.C(3) of Renewed Facility Operating License DPR-59 requires that Entergy implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in various SERS, including the SER dated August 1, 1979. The August 1, 1979, SER indicates that with the proposed modifications to the battery charger rooms, the ability to safely shut down the plant will be maintained. Contrary to the above, on October 31, 2013, Entergy identified that they did not meet this requirement for the Battery Charger Rooms, Battery Room Corridor, Cable Spreading Room, Relay Room and Main Control Room fire zones and failed to maintain post-fire shutdown cables free of the effects of fire-induced cable faults during postulated fires. This issue existed since the plant was constructed in the early 1970s.
In addition to the above licensee identified violation the inspector noted that Entergy identified the issue as a result of its operating experience review program. Interim compensatory measures were implemented immediately on discovery, and long-term actions are in progress to correct the deficiency. Entergy is performing an extent of condition review to determine if other DC circuits are susceptible to similar overcurrent conditions as a result of fire-induced circuit faults. The condition was not likely to be identified by other efforts such as normal testing or routinely scheduled reviews such as Quality Assurance or fire protection program reviews. This issue is not linked to current Entergy performance, but rather, is tied to design standards and construction activities in the 1960s and 1970s and there was no prior notice so that Entergy would not have reasonably identified the condition earlier.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- B. Sullivan Site Vice President R. Jennings Fire Marshal D. Koelbel Fire Protection System engineer D. Stokes Fire Protection Engineer B. Marks Electrical Design Engineer B. Benoit Senior Reactor Operator R. Yurkon Reactor Operator State Of New York, Office Of Fire Prevention And Control
- H. Roth Fire Protection Engineer NRC J. Rogge Chief, Engineering Branch 3, Division of Reactor Safety
- E. Knutson Senior Resident Inspector James A. FitzPatrick Nuclear Generating Station B. Sienel Resident Inspector, James A. FitzPatrick Nuclear Generating Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE
Opened and Closed
NONE
Closed
- LER
- 05000333/2013-003-00
Discussed
NONE
Attachment
LIST OF DOCUMENTS REVIEWED
Fire Protection Licensing Documents
- Exemption from Appendix R to 10
- CFR 50 Concerning Core Uncovery During Alternate Safe
- Shutdown, dtd 9/15/1986 Issuance of Exemption from Requirements of 10 CFR Part 50, Appendix R, for
- James A. FitzPatrick Nuclear Power Plant (TAC No. M83969), dtd 9/10/92
- JAF-RPT-FPS-01975, 10CFR50 Appendix R Safe Shutdown Analysis Report, Rev. 2 JAFNPP, Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section
- III.G.2 (TAC No. ME0727), dtd. 3/11/10
- JPN-92-071, NYPA letter to the NRC, Safe Shutdown Scenario and Timetable, dtd. 12/22/92
- JPN-99-019, Withdrawal of Exemption Request Regarding Appendix R to 10
- CFR 50
- Use of Core Spray to Achieve Safe Shutdown Safety Evaluation of Safe Shutdown Capability Reassessment for
- James A. FitzPatrick Nuclear Power Plant (TAC No. M84780), dtd. 9/5/95
- JAF-RPT-FPS-02367, Fire Protection Plan, Rev.14 USFSAR 8.9, Fire Protection System, Rev.10
- Design Basis Documents
- DBD-076 Tab I, Design Basis Document for Fire Protection 076 System Water Supply and Distribution System, Rev. 4
- DBD-076 Tab IV, Design Basis Document for Fire Protection 076 System, Fire Detection and Alarm System, Rev. 4
- DBD-076 Tab X, Emergency Lighting System, Rev. 5
- DBD-076 Tab XI, Shutdown Communication System, Rev.3
- Calculations/Engineering Evaluation Reports
- Independent Plant Evaluation of External Events
- JAF-RPT-04-00478, JAF Fire Hazards Analysis, Rev. 2
- JAF-RPT-FPS-01975, 10CFR50 Appendix R Safe Shutdown Analysis, Rev. 2 Penetration 1FX006B06 Data Sheet Penetration 1FX006B06 Historical Package Penetration 1FX006R07 Data Sheet Penetration 1FX006R07 Historical Package Penetration 1FX049R19 Data Sheet Penetration 1FX049R19 Historical Package Penetration 1FX050B13 Data Sheet Penetration 1FX050B13 Historical Package Attachment
- JAF-ANAL-FPS-01183, GE 3.0, Qualification of Internal Conduit Seals Outside the
- Plane of the Barrier, Rev. 3
- GE-20.0, Fire Penetration Seal Baseline Inspection, Rev. 1
- GE 20-1, Fire Penetration Seal Baseline Inspection, Rev. 1
- JAF-RPT-MISC-02598, JAFNPP Peak Clad Temperature for an Appendix R Fire Event, dtd.
- 11/27/96
- JAF-RPT-MISC-02599, JAFNPP Peak Clad Temperature for an Appendix R Fire Event, dtd.
- 11/20/96
- JAF-RPT-11-00010, Manual Operator Actions, Rev. 0
- AOP-28, Rev. 3 Nuclear Safety Evaluation, dtd. 11/30/92
- MDE-137-0585, Analysis to Extend Operator Action Time for Alternate Shutdown Panels in Support of FitzPatrick Compliance to Appendix R, Rev. 2
- JAF-CALC-ELEC-00640, 125Vdc Electrical Distribution System Coordination Analysis, Rev. 1
- JAF-RPT-ELEC-00864, Appendix R 4160V and 600V Breaker Coordination Evaluation, Rev. 0
Procedures
- AP-14.07, Fire protection Breach Permit, Rev. 7
- EN-PC-127, Control of Hot Work and Ignition Sources, Rev. 15
- EN-DC-128, Fire Protection Impact Reviews, Rev. 8
- EN-DC-161, Control Of Combustibles, Rev. 11
- FPP-1.13, Fire Brigade Equipment Inventory, Rev. 2
- JAF-RPT-FPS-02367, Fire Protection Plan, Rev. 14
- AP-12.14, Control of Time Critical Operator Actions, Rev. 2
- AP-14.01, Fire Protection Program, Rev.13
- FP-13.4.2, Emergency Communication and Lighting, Rev.7
- FPP-1.13, Fire Brigade Equipment Inventory, Rev.2
- AP-05.12, Replacement of Electrical Fuses, Rev. 11
- ISP-5-7, Remote Shutdown Reactor Vessel Pressure Indicator Calibration, Rev. 9
- ST-43A, Remote Shutdown Panel 25RSP Component Operation and Isolation Verification,
- Rev. 10
- ST-43B, Remote Shutdown Panel 25ASP-1 Component Operation and Isolation Verification,
- Rev. 8
- ST-43B, Remote Shutdown Panel 25ASP-1 Component Operation and Isolation Verification,
- Rev. 8, Performed 5/14/14
- ST-43C, Remote Shutdown Panel 25ASP-2 Component Operation and Isolation Verification,
- Rev. 10
- ST-43D, Remote Shutdown Panel 25ASP-3 Component Operation and Isolation Verification,
- Rev. 18
- ST-43G, Remote Shutdown Panel 25ASP-5 Component Operation and Isolation Verification,
- Rev. 6
- Attachment
- Operations Procedures
- AOP-28, Operations During Plant Fires, Rev. 21
- AOP-43, Plant Shutdown from Outside the Control Room, Rev. 37
- OP-37, Containment Atmosphere Dilution System, Rev. 81
- Large Fires and Explosions Mitigation Strategies Documents
- TSG-4, Action Timing & Prioritization, Revision 1
- FPP-3.50, Fire Engine Inspection, Revision 02 Fire Pumper Periodic Maintenance, dated June 29, 2011 Fire Pumper Performance Evaluation, dated June 6, 2009
- Completed Tests/Surveillances
- ST-76U, Fire System Flow Test, completed June 24, 2014
- ST-76U, Fire System Flow Test, completed November 1, 2008
- MST-076.12, HPCI Foam System Sample and Test, completed January 27, 2014
- MST-076.12, HPCI Foam System Sample and Test, completed August 13, 2014
- ST-76J10, Heat Detector Functional Tests
- HPCI Pump Area completed August 15, 2014
- ST-76J10, Heat Detector Functional Tests
- HPCI Pump Area, completed August 11, 2012
- ST-76J11, Heat Detector Functional Tests
- RCIC Pump Area, completed July 26, 2012
- ST-76J11, Heat Detector Functional Tests
- RCIC Pump Area, completed July 20, 2010
- ST-76J21, Smoke and Heat Detector Functional Tests
- Relay Room, completed February 23,
- 2012
- ST-76J21, Smoke and Heat Detector Functional Tests
- Relay Room, completed May 28, 2014
- ST-76J28, Smoke Detector Functional Test
- South, completed August 8, 2012
- ST-76J28, Smoke Detector Functional Test
- South, completed November 11,
- 2014
- ST-76J29, Smoke Detector Functional Test
- South, completed August 24,
- 2011
- ST-76J29, Smoke Detector Functional Test
- South, completed August 1, 2013 (partial performance)
- Attachment
- ST-76J29, Smoke Detector Functional Test
- South, completed August 19,
- 2013
- ST-76J31, Smoke Detector Functional Test
- West, completed August 2, 2012
- ST-76J31, Smoke Detector Functional Test
- West, completed August 5, 2014 ST076J33, Smoke Detector Functional Test
- West Crescent, completed December 15, 2013
- ST-76J33, Smoke Detector Functional Test
- West Crescent, completed October 24, 2014
- ST-76J45, Heat Detector Functional Test
- West Spray Curtain Boundary Number 1, completed
- August 8, 2012
- ST-76J45, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 1, completed
- August 8, 2013
- ST-76J46, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 2, completed
- March 21, 2012
- ST-76J46, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 2, completed
- March 21, 2014
- ST-76J47, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 3, completed
- March 29, 2012
- ST-76J47, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 3, completed
- April 1, 2014
- ST-76J48, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 4, completed
- January 6, 2012
- ST-76J48, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 4, completed
- January 29, 2013 (partial performance)
- ST-76J48, Heat Detector Functional Test
- Water Spray Curtain Boundary Number 4, completed
- January 6, 2014
- FP-1.13, Fire Brigade Equipment Inventory, completed August 7, 2014
- ST-28, Portable Diesel Generator Operability Test, Completed 4/13/14
- ST-99C, Safe Shutdown Equipment Inventory and Panel Operability Verification, completed
- 10/25/14
- MST-76.05, Exide F-100 Emergency Light Surveillance Test, 2/24/10
- ST-16J5, Reactor Building Emergency Lighting Test, Rev.16
- ST-99C, Safe Shutdown Equipment Inventory and Panel Operability verification, Rev.34
- ISP-5-7, Remote Shutdown Reactor Vessel Pressure Indicator Calibration, Rev. 9, Performed
- 9/20/12
- ST-43A, Remote Shutdown Panel 25RSP Component Operation and Isolation Verification,
- Rev. 10, Performed 3/4/13
- ST-43C, Remote Shutdown Panel 25ASP-2 Component Operation and Isolation Verification,
- Rev. 10, Performed 12/1/12
- ST-43D, Remote Shutdown Panel 25ASP-3 Component Operation and Isolation Verification,
- Rev. 18, Performed 3/2/13
- ST-43G, Remote Shutdown Panel 25ASP-5 Component Operation and Isolation Verification,
- Rev. 6, Performed 9/14/14
- Attachment
- Quality Assurance Audits and Self Assessments
- QA-9-2013-JAF-1, JAF Fire Protection Audit Final Report, 3/28/13
- EN-DC-128, Fire Protection Impact Reviews, Rev.8
- System Health Reports
- 125Vdc Systems, 2nd and 3rd qtrs. 2014 600Vac Systems, 2nd and 3rd qtrs. 2014 4kV Systems, 2nd and 3rd qtrs. 2014
Drawings
and Wiring Diagrams
- NP-12-TE-02, Typical Silicone Elastomer Installation Upgrading Existing Penetration Seals,
- Rev. 1 FE67E, Lighting Plan - Reactor Building, Rev.10
- FE-67F, Lighting Plan
- Reactor Building,
- SH.6, Rev.9
- FE-67D, Lighting Plan
- Reactor Building, Sh.4, Rev.12
- FE-67C, Lighting Plan
- Reactor Building, Rev.21
- FE-67B, Lighting Plan
- Reactor Building, Sh.2, Rev.22
- FE-67A, Lighting Plan
- Reactor Building, Sh1, Rev.17
- FE-65B, Lighting Plan Cable Tray and RMS, Rev.16J 791E450, Elementary Diagram Jet Pump Instrumentation Systems, Rev. 24
- ESK-6MAJ, Elementary Diagram 600V Circuit Motor Operated Valve Core Spray Pumps
- Inboard Discharge Valves 10MOV-12A(B), Rev. 9
- Outlet Valves, Rev. 12
- Exchanger Discharge Valves 10MOV-89A(B), Rev. 16
- FE-1AD, 120Vac One Line Diagram Emergency Buses A3, B3, and A4, Rev. 27
- FE-1AS, 120Vac One Line Diagram Emergency Buses A2 and B2, Rev. 24
- FE-1B, Sht. 2, Main One Line Diagram Station Service Transformers, Rev. 14
- FE-1H, Sht. 4, 4160V One Line Diagram Emergency Bus 10500, Rev. 14
- FE-1J, Sht. 5, 4160V One Line Diagram Emergency Bus 10600, Rev. 15
- FE-3FG, External Connections Auxiliary Relay Cabinet
- AR-5B, Rev. 12
- FE-3GK, External Connection Diagram Main Control Board, Rev. 15
- Attachment
- FE-3UT, Wiring Diagram Remote Shutdown Panel 25RSP, Rev. 4
- FE-3UV, Internal and External Connection Diagram Remote Shutdown Panel 25RSP, Rev. 3
- FE-3K, Wiring Diagram, Main Control Board-Sect 09-8, Sheet 10, Rev. 12
- FE-34AC, Cable tray Designations, Control Bay-SH 1, X Trays, Rev. 6
- Piping and Instrumentation Diagrams
- FM-18A, Flow Diagram Drywell Inerting C.A.D. and Purge, Rev. 57
- FM-18B, Flow Diagram Drywell Inerting C.A.D. Purge and Containment Differential Pressurization
- System 27, Rev. 40
- FM-20A, Flow Diagram Residual Heat Removal System 10, Rev. 72
- FM-20B, Flow Diagram Residual Heat Removal System 10, Rev. 72
- FM-39C, Flow Diagram Instrument Air Reactor Bldg. & Drywell System 39, Rev. 31
- FM-47A, Flow Diagram Nuclear Boiler Vessel Instruments System 02-3, Rev. 52
- FM-18A, Flow Diagram Drywell Inerting and Purge System 27, Rev. 57
- FM-20B, Flow Diagram Residual Heat Removal System 10, Rev. 72
- FM-22A, Flow Diagram Reactor Core Isolation Cooling System 13, Rev. 56
- FM-20A, Flow Diagram Residual Heat Removal System 10, Rev. 72
- FM-46B, Flow Diagram Emergency Service Water System 46 and 15, Rev. 56
- FM-29A, Flow Diagram Main Steam System 29, Rev. 58
- FM-23A, Flow Diagram Core Spray System 14, Rev. 49
- FM-47A, Flow Diagram Nuclear Boiler Vessel Instruments, System 02-23, Rev. 52
- FB-49A, Flow Diagram Fire protection Water Piping, System 76, Rev. 40
- FB-49B, Flow Diagram Fire Protection Water Piping, System 76, Rev. 12
- FB-48A, Flow Diagram, Fire protection water Piping, System 76, Rev. 34
- FB-48B, Site Utilities Fire protection Water Supply Flow Diagram Mechanical, Rev. 11
- Vendor Manuals
- E353-0051, Exide Electronics Vendor Manual, Rev. 4 H249-0095, Holophane 12 Volts Vendor Manual, Rev.1 H249-0088, Holophane 6 Volts Vendor Manual, 3/24/93
- Fire Drills and Critiques
- September 7, 2014, Outage Fire Brigade August 19, 2014, Dayshift August 19, 2014, Nightshift September 25, 2014, Dayshift September 30, 2014, Dayshift Attachment
- Fire Brigade Training
- FP-13-4.1, Self-Contained Breathing Apparatus, Rev. 6 Task Qualification Matrix
- Operator Safe Shutdown Training
- JGATT-OPS-AOP43TSG-1206,
- AOP-43 and
- TSG-8 through 12, Rev. 0
- JWKT-OPS-AOP43TSG-1206-AOP-43, TSG In-Plant Walkdown, Rev. 0
- SEG-JSIM-LOR-SIMTRNA-1404, LOR Cycle 1404 Sim Training A, Rev. 0
Miscellaneous Documents
- PM Basis Template EN - I&C - DC Power Supply, Rev 3 Electrical Cable and Conduit Routing Information
- EES-8, Guidelines for the Selection and Replacement of Fuses, Rev. 2 ANSI/IEEE Std 420-1973, IEEE Trial-Use Guide for Class 1E Control Switchboards for
- Nuclear Power Generating Stations ANSI/IEEE Std 484-1975, IEEE Recommended Practice for Installation Design and Installation of Large Lead Storage Batteries for Generating Stations and Substations IEEE Std 566-1977, IEEE Recommended Practice for the Design of Display and Control Facilities for Central Control Rooms of Nuclear Power Generating Stations
Condition Reports
- CR-JAF-2014-07234*
- CR-JAF-2014-07237*
- CR-JAF-2014-07238*
- CR-JAF-2014-07240*
- CR-JAF-2013-05546 *NRC identified during this inspection.
Work Orders
- 52482517
- 52507138
- 52539910
- 51799557
- 52452412
- 52275772
- 52273101
- 51799556
- 52587854
- 52224822
- 52404551
- 52276958
- 52587860
- 52437605
- 52206426
- 358279
- 52480877
- 52366426
- 52275773
- 52436740
- 338992
- 52388675
- 393792
- 52276956
- Attachment
- 52575573
- 52362757
- 52248648
- 52410531
- 52549788
- 52250876
- 52411857
- 52230498
- 52565936
- 221031
- 52393745
- 326530
- 52212545
- 371451
- 52551178
- 52256780
- 52257593
- 52285867
- 52378941
- 52396292
- 52420891
- 52467744
- Attachment