IR 05000220/2012007
| ML12213A411 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/30/2012 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Langdon K Nine Mile Point |
| References | |
| IR-12-007 | |
| Download: ML12213A411 (27) | |
Text
July 30, 2012
SUBJECT:
NINE MILE POINT NUCLEAR STATION - NRC TRIENNIAL FIRE PROTECTION I N S P ECTl O N RE PORT 05000220 t20 1 2007 AN D 0500 041 0 l 20 1 2007
Dear Mr. Langdon:
June 22, 2012
SUBJECT:
NINE MILE POINT NUCLEAR STATION - NRC TRIENNIAL FIRE PROTECTION I N S pECTt O N RE pO RT 05000220 l 20 1 2007 AN D 0500 041 0 l 201 2007
Dear Mr. Langdon:
On June 22,2012, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Nine Mile Point Nuclear Station Units 1 and2. The enclosed inspection report documents the inspection results, which were discussed on June 22,2012, with Mr. Mike Philippon, and other members of your statf.
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 inspectors also reviewed mitigation strategies for addressing large fires and explosions.
Based on the results of this inspection, no findings were identified'
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the 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). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rmiadams.html (the Public Electronic Reading Room).
Sincerely,
/RN John F. Rogge, Chief Engineering Branch 3 Division of Reactor SafetY Docket Nos. 50-220, 50-410 License Nos. DPR-63, NPF-69 G:\\DRS\\Engineering Branch 3\\TriennialFire Protection lRs\\Nine Mile Point\\NMP1 & NMP2 FP 2012-07.doc DOCUMENT NAME:
ADAMS ACCESSION NUMBER: ML12213P.411 g
suNslReview V
Non-Sensitive n
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n Publicly Available Non-Publicly Available OFFICE RI/DRS RI/DRP RI/DRS NAME DOrr GDentel JRogge DATE 7t30t12 7t30t12 7t30t12 FTCIAL RECORD COPY
Enclosure:
Inspection Report Nos. 0500022012012007 and 05000410/2012007 dAttachment: Supplemental Information
REGION I==
50-220;50-410 DPR-63; NPF-69 05000220/201 2007 and 05000 41 0 l 2012007 Nine Mile Point Nuclear Station, LLC (NMPNS)
Nine Mile Point, Units 1 and 2 Oswego, NY June 4 -22,2412 D. Orr, Senior Reactor lnspector (Team Leader)
W. Schmidt, Senior Reactor Analyst R. Fuhrmeister, Senior Reactor Inspector L. Scholl, Senior Reactor Inspector K. Young, Senior Reactor InsPector T. O'Hara, Reactor Inspector J. Rady, Reactor lnspector John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
lR 0500022012012007,0500041012012007;61412012-612212012;
Nine Mile Point Nuclear Station, Units 1 and 2; Triennial Fire Protection Baseline Inspection'
The report covered a two-week triennialfire protection team inspection by specialist inspectors.
The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
No findings were identified.
REPORT DETAILS
Backqround This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (lP) 71111.05T, "Fire Protection." The objective of the inspection was to assess whether Nine Mile Point Nuclear Station, LLC (NMPNS) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Nine Mile Point Nuclear Station, Units 1 and 2. The following fire areas (FAs) and fire zones (FZs) were selected for detailed review based on risk insights from the Nine Mile Point Nuclear Station, Units 1 and 2 Individual Plant Examinations of External Events (IPEEE).
Unit 1 o R3A r T3B oC1 Unit2 o 19/336 XLA o 341212 SWB
.
261372.1 NZ Inspection of these zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated the licensee's fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Conditions 2.D.(7) for Unit 1 and 2.F for Unit 2, NRC Safety Evaluations, 10 CFR 50.48, and 10 CFR 50, Appendix R and Branch Technical Position (BTP) Chemical Engineering Branch 9.5-1. The team also reviewed related documents that included the Updated Final Safety Analysis Reports (UFSAR)Section X.K for Unit 1 and Section 9.5.1 for Unit 2, the fire hazards analyses (FHA),and the post-fire safe shutdown analyses.
The team also evaluated six licensee mitigating strategies (two mitigating strategies that were specific for each unit as well as two that were applicable for both units) for addressing large fires and explosions as required by 10 CFR 50.54 (hh)(2) specifically for Unit 1 and Unit 2 and.
Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample.
Specific documents reviewed by the team are listed in the attachment.
1. REACTOR SAFEW
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
==1R05 Fire Protection (lP 71 1 1 1.05T)
==
.01 Protection of Safe Shutdown Capabilities
a.
Inspection Scgpe The team reviewed the FHA, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The b.
a.
b.
a.
.02,03
team ensured that applicable separation requirements of Section lll.G of 10 CFR 50, Appendix R, BTP 9.5-1 and the licensee's design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
Findinqs No findings were identified.
Passive Fire Protection 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 NMPNS FPP, as approved by the NRC, to identify any potential degradation or non-conformances.
The team reviewed selected engineering evaluations, installation and repair work orders, and qualification records for a sample of penetration seals to determine whether the fill mateiial was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating.
ln addition. the team reviewed recent test results for the carbon dioxide (COz) and Halon fire damper functionality tests for the areas protected to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified.
Findinqs No findings were identified.
Active Fire Protection lnspection 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 NMPNS 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.
b.
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 design specifications, vendor requirements, modifications and engineering evaluations, and routine functional testing for the carbon dioxide (COz) and suppression systems for the areas protected. The team walked down accessible portions of the COz systems, including storage tanks and supply systems, to independently assess the material condition, operational lineup, and availability of the systems. The team also reviewed and walked down the associated fire fighting strategies and CO2 system operating procedures.
The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire pumps, interviewed system and program engineers, and reviewed selected condition reports (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 NMPNS's fire fighting 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.9., turnout gear) and smoke removal equipment, to determine operational readiness for fire fighting.
ln addition, the team reviewed NMPNS'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.
Findinos No findings were identified.
.04 Protection From Damaoe Erom Fire Suppression Activities
Inspection Scooe 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.
Findinqs No findings were identified.
Post-Fire Safe thutdown Capabilitv - Normal and Alternative Inspection Scope The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&lDs), electrical drawings, the UFSAR and other supporting documents for the selected fire areas to verify that the licensee 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.
b.
.05 a.
b.
a.
.06 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:
. EPIP-EPP-28, Firefighting, Rev. 01602;
. N1-SOP-21.1, Fire in Plant, Rev.00600;
. N1-SOP-21.2, Control Room Evacuation, Rev. 00600; r N2-ARP-FPM, Fire Computer System Alarm Response Procedures, Rev. 00500
. N2-ARP-849100, @CEC-PNL849 Series 100 Alarm Response Procedure, Rev.
00200; and,
. N2-SOP-78, Control Room Evacuation, Rev.00700.
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 controlfunctions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
Findinos No findings were identified.
Circuit Analvsis lnspection Scope The team verified that the licensee performed a post-fire safe shutdown analysis for the selected fire areas and the analysis appropriately identified the structures, systems, and components important to achieving and maintaining safe shutdown. Additionally, the team verified that the licensee's analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The team's review considered fire and cable attributes, cable routing, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
b.
.07 a.
The team also reviewed cable raceway drawings and/or cable routing databases for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the safe-shutdown analysis. The team also reviewed equipment important to safe shutdown, but not part of the success path, to verify that the licensee had taken appropriate actions in accordance with the design and licensing basis and NRC Regulatory Guide 1.189, Revision 2.
Circuit analysis was performed for the following components:
o PMP 81-23, Core Spray Pump;
. lV 81-21, Core Spray Pump Suction Valve;
.
lV 38-02, Shutdown Cooling Pump lsolation Valve;
. Ll 36-09, Reactor Vessel Level Indicator; o 2RHS*P1A, Residual Heat Removal (RHR) Pump A; o 2RHS*MOV9B, RHR Heat Exchanger Shell Side Inlet Valve;
. 2RHS*MOV1A, RHR Pump P1A Suction Valve; and,
. 2RSS*Ll101, ReactorVessel Level 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.9., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
Findinqs No findings were identified.
Communications Inspection Scope The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review, the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The team also verified that communications equipment, such as repeaters and transmitters, would not be affected by a fire.
Findinqs No findings were identified.
b.
.08 a.
b.
.09 a.
b.
.10 Emerqencv Liqhtino
Inspection Scope The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained consistent with the manufacturer's recommendations and in a manner that would ensure reliable operation.
FindinE No findings were identified.
Cold Shutdown Repairs Inspection Scope For Unit 1: The team verified that the licensee 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.9., pre-cut cables with prepared attachment lugs) were available and accessible on site, For Unit 2: The team reviewed the safe shutdown analysis and verified that there were no repairs necessary to achieve cold shutdown following a fire in the plant. The team verified there were sufficient separation, isolation, and redundancy of systems necessary for post-fire safe shutdown, that repair procedures and equipment to achieve cold shutdown were not necessary. Additionally, the team verified that sufficient systems were available from either the control room or the remote shutdown panels to achieve and maintain hot and cold shutdown conditions without repairs.
FindinS No findings were identified.
Compensatorv Measures 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 a.
b.
.11 a.
barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that the licensee was effective in returning the equipment to service in a reasonable period of time.
The team reviewed compensatory measures in the form of manual actions for 10 CFR Part 50, Appendix R, Section lll.G.2 areas to verify that there is reasonable assurance that manual actions can be accomplished. Specific attributes reviewed include diagnostic instrumentation, environmental consideration, staffing, communications, equipment availability, training, procedures, and verification and validation.
Findinqs No findings were identified.
Fire Protection Proqram Chanqes 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.
Findinqs No findings were identified.
Control of Transient Combustibles and lqnition Sources Inspection Scooe The team reviewed the licensee'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 FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
Findinqs No findings were identified.
b.
.12 a.
b.
.13 a.
Larqe Fires and Explosions MitiqatioL-Strateqies Inspection Scope The team reviewed the licensee's preparedness to handle large fires or explosions by reviewing six licensee mitigating strategies (two mitigating strategies that were specific to each unit as well as two that were applicable for both units) to verify they continue to meet 10 CFR 50,54 (hhx2) by determining that:
o Procedures are being maintained and adequate;
. Equipment is properly staged and is being maintained and tested; and, r Station personnel are knowledgeable and can implement the procedures.
Findinqs No findings were identified.
oTHER ACTIVIilES [OAl ldentification and Resolution of Problems Corrective Actions for Fire Protection Deficiencies Inspection Scope The team verified that the licensee was identifying fire protection and postfire 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 the licensee had taken or planned appropriate corrective actions.
Findinqs No findings were identified.
Meetinqs. includins Exit Exit N4eetinq Summarv The team presented their preliminary inspection results to Mr. Mike Philippon, Plant General fr4anager, and other members of the site staff at an exit meeting on June 22, 2012. No proprietary information was included in this inspection report.
4. 4cp.2
,01 a.
40A6 b.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Philippon, Plant General Manager
- J. Blasiak, Fire Protection System Engineer
- P. Carroll, Plant Equipment Operator
- K. Cherchio, Reactor Operator
- B. Geiss, Senior Reactor OPerator
- B. Law, Maintenance Electrician
- R. Mason, Plant Equipment OPerator
R, Pellegrino, Operations Instructor
- R. Saunderson, Engineering Programs
- S. Savar, Safe Shutdown Engineer
- W. Schultz, Plant Equipment Operator
- R. Schulz, Safe Shutdown Engineer
- W. Sullivan, Fire Protection Engineer
- T. Syrell, Electrical Maintenance Supervisor
- D. Vanamee, Fire Marshall
- C. Willett, Safe Shutdown Engineer
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- K. Kolaczyk, Senior Resident Inspector, Nine Mile Point Nuclear Station
- D. Dempsey, Resident Inspector, Nine Mile Point Nuclear Station
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
NONE