IR 05000254/2012011
| ML12250A879 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/06/2012 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Alan Dahbur | |
| References | |
| IR-12-011 | |
| Download: ML12250A879 (24) | |
Text
September 6, 2012
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000254/2012011; 05000265/2012011(DRS)
Dear Mr. Pacilio:
On August 2, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Quad Cities Nuclear Power Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on August 2, 2012, with Mr. S. Darin 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.
Two NRC-identified findings of very low safety significance (Green) were identified during this inspection. These findings were determined to involve violations of NRC requirements.
However, because of their very low safety significance and because the issues were entered into your corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the subject or severity of any Non-Cited Violation you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector office at the Resident Inspector at Quad Cities Nuclear Power Station. In accordance with 10 CFR 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 System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-254 and 50-265 License Nos. DPR-29 and DPR-30
Enclosure:
Inspection Report 05000254/2012011; 05000265/2012011(DRS)
w/Attachment: Supplemental Information
REGION III==
Docket Nos:
50-254; 50-265 License Nos:
05000254/2012011; 05000265/2012011 Licensee:
Exelon Generation Company, LLC Facility:
Quad Cities Nuclear Power Station, Units 1 and 2 Location:
Cordova, IL Dates:
July 11 through August 2, 2012 Inspectors:
A. Dahbur, Team Lead, Senior Reactor Inspector
N. Valos, Senior Risk Analyst
R. Winter, Reactor Inspector Approved by:
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety
Enclosure
SUMMARY
IR 05000254/2012011, 05000265/2012011; 07/11/12 - 08/02/12; Quad Cities Nuclear Power
Station, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection.
This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection was conducted by Region III inspectors. Two (Green) findings were identified by the inspectors.
The findings were considered Non-Cited Violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be (Green) or be assigned a severity level after NRC management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
A.
Cornerstone: Mitigating Systems
NRC-Identified
and Self-Revealed Findings
- Green The inspectors determined that the finding was more than minor because the procedure deficiency did not ensure the successful energization of Bus 23-1 from the Unit 2 SBO DG in the event of a fire in fire area TB-III, which was required to provide Torus cooling for Unit 1. The finding was screened as having very low safety significance in Task 1.3.1 of IMC 0609, Appendix F. This finding did not have a cross-cutting aspect because the finding was not representative of current performance. (Section 1R05.5.b)
. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix R, Section III.L.3 for the licensees failure to have an adequate procedure used to implement an alternative shutdown capability in the event of a fire in fire area TB-III. Specifically, the licensee failed to provide adequate steps to ensure the successful energization of Bus 23-1 from the Unit 2 Station Blackout (SBO) Diesel Generator (DG) in the event of a fire in fire area TB-III (Turbine Building Southern Zone Group). The licensee entered the issue into their corrective action program and added a step to close the Bus 23-1 and Bus 71 Tie Breaker.
- Green The inspectors determined that the finding was more than minor because the procedure deficiency could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB-III. The finding was screened as having very low safety significance in Task 1.3.1 of IMC 0609, Appendix F. This finding did not have a cross-cutting aspect because the finding was not representative of current performance. (Section 1R05.9.b)
. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix R, Section III.L.5 for the licensees failure to have a procedure in effect that would provide adequate cold shutdown repairs for the 1A Recirculation Pump Discharge Valve MO 1-202-5A. Specifically, a procedure deficiency in Quad Cities Annunciator Response Procedure (ARP) 0030-01, Attachment D, provided an incorrect terminal point and cubicle location on MCC 18/19-5 for the cable wire to be lifted for cold shutdown repair in the event of a fire in fire area TB-III. The licensee entered the issue into their corrective action program revised the procedure and corrected the deficiency.
B.
No violations of significance were identified.
Licensee-Identified Violations
1.
REACTOR SAFETY
REPORT DETAILS
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of the fire protection triennial baseline inspection was to conduct a design based, plant specific, risk-informed, onsite inspection of the licensees fire protection programs defense-in-depth elements used to mitigate the consequences of a fire. The fire protection program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:
- preventing fires from starting;
- rapidly detecting, controlling and extinguishing fires that do occur;
- providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and
- taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.
The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants fire protection program, post-fire safe shutdown systems, and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a fire protection program that:
- (1) provided adequate controls for combustibles and ignition sources inside the plant;
- (2) provided adequate fire detection and suppression capability;
- (3) maintained passive fire protection features in good material condition;
- (4) established adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features;
- (5) ensured that procedures, equipment, fire barriers, and systems exist so that the post-fire capability to safely shut down the plant was ensured;
- (6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and
- (7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees problem identification and resolution program.
In addition, the inspectors review and assessment focused on the licensees post-fire safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspectors review and assessment also focused on the licensees B.5.b related license conditions and the requirements of Title 10, Code of Federal Regulations (10 CFR) Part 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could maintain or restore core cooling, containment, and spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of power reactor facilities due to explosions or fires. Documents reviewed are listed in the Attachment to this report.
The fire zones/areas and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.13. The fire zones/areas selected constituted four inspection samples and the B.5.b mitigating strategies selected constituted four inspection samples, respectively, as defined in Inspection Procedure 71111.05T.
Fire Area Fire Zone Description CT-1 8.2.4 Unit 1 Cable Tunnel TB-I 8.2.6.E Unit 2 TB Ground Floor TB-III 6.1.B Unit 1 DC Panel Room TB-I 8.2.7.E Unit 2 TB Mezzanine Floor
.1 a.
Protection of Safe Shutdown Capabilities For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected.
Inspection Scope The inspectors also reviewed the licensees 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 and/or post-fire safe shutdown analysis and procedures.
b.
No findings of significance were identified.
Findings
.2 a.
Passive Fire Protection For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association (NFPA) standards to verify that fire protection features met license commitments.
Inspection Scope The inspectors 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.
The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.
b.
No findings of significance were identified.
Findings
.3 a.
Active Fire Protection For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.
Inspection Scope b.
No findings of significance were identified.
Findings
.4 a.
Protection from Damage from Fire Suppression Activities For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.
Inspection Scope b.
No findings of significance were identified.
Findings
.5 a.
Alternative Shutdown Capability The inspectors reviewed the licensees systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.
Inspection Scope The inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training, as well as consistency between the operations shutdown procedures and any associated administrative controls.
b.
Inadequate Procedure to Energize Bus 23-1 to Provide Torus Cooling for Unit 1 Findings
Introduction:
The inspectors identified a finding of very low safety significance (Green)and associated Non-Cited Violation of 10 CFR Part 50, Appendix R, Section III.L.3 for the licensees failure to have an adequate procedure used to implement an alternative shutdown capability in the event of a fire. Specifically, the licensee failed to implement a procedure which would ensure the successful energization of Bus 23-1 from the Unit 2 Station Blackout (SBO) Diesel Generator (DG) in the event of a fire in fire area TB-III (Turbine Building Southern Zone Group). Bus 23-1 was required to be energized to provide Torus cooling for Unit 1 in the event of a fire in fire area TB-III.
Description:
The licensee used the Quad Cities ARP 0030-01, TB-III Injection with a safety system performance monitor (SSMP) and Bringing the Unit to Cold Shutdown, to safely shutdown the plant in the event of a fire in fire area TB-III. If power was lost to Bus 23, then Attachment K, ANSO2 SBO DG 2 Local Emergency Operation, was used to energize Bus 23-1 from the Unit 2 SBO DG to allow restart of the 2A and 2B Residual Heat Removal Service Water (RHRSW) Pumps to support Unit 1 Torus cooling. The actions listed in Attachment K were to be performed by an operator from outside the control room.
The use of the Unit 2 SBO DG to provide power for Torus cooling was a contingency action in case of loss of offsite power. Safe shutdown circuit analysis has determined that offsite power would not be damaged for a fire in fire area TB-III. However, the overall reliability and availability of electrical power (i.e., onsite and offsite power) to Bus 23-1 would be decreased in the event of a fire in area TB-III. Also, since fire area TB-III is an alternative shutdown area, in accordance with the technical requirements of Sections III.L.3 of 10 CFR Part 50, Appendix R, the shutdown capability is required to accommodate post-fire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Figure 8.3-1 Emergency Power System of the updated final safety analysis report (UFSAR) showed three breakers required to be closed to provide a power source to Bus 23-1 from the Unit 2 SBO DG. These breakers were the SBO DG 2 feed to Bus 71 (Breaker 7101), Bus 23-1 Tie Breaker to Bus 71 located at Bus 71 (Breaker 7103) and Bus 23-1 Tie Breaker to Bus 71 located at Bus 23-1 (Breaker 2328).
During review of Attachment K by the inspectors, it was determined that the procedure lacked a step to close the Bus 23-1 Tie Breaker to Bus 71 (Breaker 2328) to provide the final electrical flow path to energize Bus 23-1 after Bus 71 was energized by the Unit 2 SBO DG. Bus 23-1 was required to be energized to provide Torus cooling for Unit 1 in the event of a fire in fire area TB-III.
In response to the inspectors concern, the licensee initiated IR 01387237, FPI - QCARP Procedure Deficiency, No Step to Energize Bus, and revised Attachment K of the Quad Cities ARP 0030-01 on July 11, 2012, to provide a step to close the Bus 23-1 Tie Breaker to Bus 71 to provide an electrical flow path to energize Bus 23-1.
Analysis:
The inspectors determined that the failure to implement a procedure which would provide alternative shutdown capability in the event of a fire in fire area TB-III was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.L.3, and was a performance deficiency. Specifically, the licensee failed to implement a procedure to ensure the successful energization of Bus 23-1 from the Unit 2 SBO DG in the event of a fire in fire area TB-III. Bus 23-1 was required to be energized to provide Torus cooling for Unit 1 in the event of a fire in fire area TB-III.
The finding was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Events (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the procedure deficiency did not ensure the successful energization of Bus 23-1 from the Unit 2 SBO DG in the event of a fire in fire area TB-III in case of loss of offsite power. In the event of a fire in fire area TB-III, Bus 23-1 was required to be energized to provide Torus cooling for Unit 1. Although the safe shutdown analysis determined that the fire would not damage cables associated with the offsite power sources, the overall reliability and availability of electrical power (i.e., onsite and offsite power) to Bus 23-1 would be decreased in the event of a fire in area TB-III.
In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase I - Initial Characterization of Findings, Table 3, the inspectors determined that the finding affected the ability to reach or maintain safe shutdown conditions in case of a fire. Therefore, screening under IMC 0609, Appendix F, Fire Protection Significance Determination Process, was required.
The inspectors determined that the finding affected the post-fire safe shutdown finding category. The inspectors determined that the finding represented a low degradation because of two factors that limited the overall impact on the performance of the Quad Cities ARP 0030-01. First, the use of the Unit 2 SBO DG to provide power for Torus cooling was a contingency action in case of loss of offsite power in order to meet the requirement of Appendix R,Section III.L. Second, the affected action was to establish Torus cooling within three hours of a reactor scram. The failure to energize Bus 23-1 should be readily apparent to the operators. With a time period of three hours to establish Torus cooling, it would be expected that the operators would have diagnosed and corrected the issue associated with the failure of Bus 23-1 to be energized.
Therefore, the inspectors determined that the finding screened as having very low safety-significance (Green) in Task 1.3.1 of IMC 0609, Appendix F.
The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance.
Enforcement:
Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G,Section III.J, and Section III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix R, Section III.G,Section III.L of 10 CFR Part 50, Appendix R, specifies implementation of alternative to dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.3 of 10 CFR Part 50, Appendix R, states, in part, that alternative shutdown capability shall be independent of the specific fire area and that procedures shall be in effect to implement this capability and shall accommodate post-fire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Section 4.10.1 Unit 1 Shutdown Analysis, of the Fire Protection Report stated, in part, that an alternative shutdown capability was utilized in the event of a fire in TB-III.
Contrary to the above, from March 4, 2009 until July 11, 2012, for an area where alternative shutdown capability was established, the licensees procedure failed to implement this alternative shutdown capability where offsite power was not available.
Specifically, Attachment K of procedure Quad Cities ARP 0030-01 did not ensure the successful energization of Bus 23-1 from the Unit 2 SBO DG in the event of a fire in fire area TB-III. Bus 23-1 was required to be energized to provide Torus cooling for Unit 1.
Following the identification of the procedure deficiency, the licensee revised the procedure and added a step to ensure the energization of Bus 23-1 in the event of a fire in TB-III. Because this violation was of very low safety significance and it was entered into the licensees corrective action program as IR 01387237, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000254/2012011-01; 05000265/2012011-01, Inadequate Procedure to Energize Bus 23-1 to Provide Torus Cooling for Unit 1).
.6 a.
Circuit Analyses The inspectors 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 inspectors 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, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
Inspection Scope The inspectors' review considered fire and cable attributes, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
The inspectors also reviewed cable raceway drawings for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the cable routing matrices.
The inspectors 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. Additionally, the inspectors 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.
The inspectors verified for cables that are important to safe shutdown (SSD) but not part of the success path, and that do not meet the separation/protection requirements of Section III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable failure modes. In addition, the inspectors have verified that the licensee has either:
- (1) determined that there is not a credible fire scenario (through fire modeling);
- (2) implemented feasible and reliable manual actions to assure SSD capability; or
- (3) performed a circuit fault analysis demonstrating no potential impact on SSD capability exists.
b.
No findings of significance were identified.
Findings
.7 a.
Communications The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.
Inspection Scope The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.
b.
No findings of significance were identified.
Findings
.8 a.
Emergency Lighting The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.
Inspection Scope b.
No findings of significance were identified.
Findings
.9 a.
Cold Shutdown Repairs The inspectors reviewed the licensees procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available onsite. The inspectors also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available onsite and properly staged.
Inspection Scope b.
Inadequate Procedure for Cold Shutdown Repair of 1A Recirculation Pump Discharge Valve MO 1-202-5A Findings
Introduction:
The inspectors identified a finding of very low safety significance (Green)and associated Non-Cited Violation of 10 CFR Part 50, Appendix R, Section III.L.5 for the licensees failure to have a procedure in effect that would provide adequate cold shutdown repair for the 1A Recirculation Pump Discharge Valve MO 1-202-5A.
Specifically, Attachment D, Repair of MO-1-202-5A Valve, of the Quad Cities ARP 0030-01, provided an incorrect Terminal Point
- (19) and cubicle location (Cubicle A4) on motor control center (MCC) 18/19-5 for the cable wire to be lifted for Cable 12654.
These inadequate repair instructions could have resulted in operational complications and could have caused a delay in reaching cold shutdown in the event of a fire in fire area TB-III (Turbine Building Southern Zone Group).
Description:
The licensee used the Quad Cities ARP 0030-01 to safely shutdown the plant in the event of a fire in fire area TB-III. To ensure that there is no backflow through the 1A Recirculation Pump and injection bypassing the reactor, motor operated valve MO 1-202-5A, 1A Recirculation Pump Discharge Valve, must be closed when reconfiguring the Unit 1 Division 1 RHR system for shutdown cooling. The MCC, 480V MCC 18/19-5, which supplied power to motor operated valve MO 1-202-5A was located inside primary containment and was not readily accessible. The safe shutdown analysis indicated that a fire in fire area TB-III may damage the control cables associated with the 480V MCC 18/19-5. Because of the location of the valve and the potential cable damage, a repair was required to remotely close valve MO 1-202-5A from Unit 1 480V MCC 18/19-5. Attachment D, Repair of 1-202-5A Valve, was used to provide the repair to allow remote closure of the 1A Recirculation Pump Discharge Valve MO 1-202-5A.
D provided repair instructions to lift cable wires at certain terminal points to isolate the control circuit to allow the cold shutdown repair of valve MO 1-202-5A.
During the inspectors review of Attachment D and schematic/wiring drawings associated with the motor operated valve, it was determined that the procedure listed an incorrect Terminal Point
- (19) and cubicle location (Cubicle A4) on MCC 18/19-5 for the cable wire to be lifted for Cable 12654. The correct terminal point was for a GRN-BLK conductor for Cable 12654 to be lifted at MCC 18/19-5, Cubicle B2, Terminal Point 17.
During 2009, the licensee implemented a modification per Engineering Change (EC)344616 (that electrically disconnected the Reactor Recirculation Loop Crosstie and Crosstie Bypass Valves MO 1-202-6A, 6B and MO 1-202-9A, 9B) that changed the wiring configuration associated with MO 1-202-5A. The EC 344616 did not identify the Quad Cities ARP 0030-01 as a procedure that was required to be changed as a result of the modification. The Quad Cities ARP 0030-01, Attachment D, was required to be revised to reflect the new correct terminal point and cubicle location for the cable wire to be lifted for Cable 12654.
In response to the inspectors concern, the licensee conducted a preliminary review of the electrical diagrams associated with the motor operated valve MO 1-202-5A and determined that the GRN-BLK conductor for Cable 12654 at MCC 18/19-5, Cubicle B2, Terminal Point 17, was not required to be lifted to allow remote closure of valve MO 1-202-5A. Because of the lifting of other wires as specified in the repair procedure, safe shutdown could be accomplished without lifting this wire, fire induced failures of cables associated with the valve would not result in spurious opening of the valve in the event of a fire in TB-III. However, the inspectors determined that the procedure deficiency could have caused a delay in reaching cold shutdown in the event of a fire in fire area TB-III, while the cause of the procedure deficiency was investigated. Specifically, the inspectors were concerned that the procedure deficiency could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB-III.
The licensee entered this issue into their corrective action program as IR 01393856, FPI - QCARP 0030-01 and 0030-02 Identified Discrepancies, and revised the procedure and corrected the deficiency.
Analysis The finding was determined to be more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Events (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the procedure deficiency could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB-III. The procedure deficiency delayed the capability of systems to achieve cold shutdown and would have added burden as well as uncertainty for operations personnel during an already challenging fire event.
- The inspectors determined that the failure to provide an adequate procedure for the cold shutdown repair of 1A Recirculation Pump Discharge Valve MO 1-202-5A in the event of a fire in fire area TB-III was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.L.5 and was a performance deficiency. Specifically, procedure Quad Cities ARP 0030-01, Attachment D, provided an incorrect Terminal Point
- (19) and cubicle location (Cubicle A4) on MCC 18/19-5 for the cable wire to be lifted for Cable 12654 associated with MO 1-202-5A.
In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase I - Initial Characterization of Findings, Table 3, the inspectors determined that the finding affected the ability to reach or maintain safe shutdown conditions in case of a fire. Therefore, screening under IMC0609, Appendix F, Fire Protection Significance Determination Process, was required.
The inspectors determined that the finding affected the post-fire safe shutdown finding category and only affected the ability to reach and maintain cold shutdown conditions. Therefore, the inspectors determined that the finding screened as having very low safety significance (Green) in Task 1.3.1 of IMC 0609, Appendix F.
The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of current performance.
Enforcement:
Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix R, Section III.G.Section III.L of 10 CFR Part 50, Appendix R, specifies implementation of alternative of dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.5 of 10 CFR Part 50, Appendix R, states, in part, that the fire damage to equipment and systems shall be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and that procedures shall be in effect to implement such repairs.
Section 4.10.1 Unit 1 Shutdown Analysis, of the Fire Protection Report stated, in part, that an alternative shutdown capability was utilized in the event of a fire in TB-III.
Contrary to the above, from April 28, 2009, until July 31, 2012, the licensee did not have a procedure in effect that would provide adequate cold shutdown repairs for the 1A Recirculation Pump Discharge Valve MO 1-202-5A. Specifically, a procedure deficiency in the Quad Cities ARP 0030-01, Attachment D, provided an incorrect Terminal Point
- (19) and cubicle location (Cubicle A4) on MCC 18/19-5 for the cable wire to be lifted for Cable 12654, which could have resulted in operational complications and could have delayed reaching cold shutdown in the event of a fire in fire area TB-III. Following the identification of the procedure deficiency, the licensee revised the procedure and corrected the deficiency. Because this violation was of very low safety significance and it was entered into the licensees corrective action program as IR 01393856, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000254/2012011-02; 05000265/2012011-02, Inadequate Procedure for Cold Shutdown Repair of 1A Recirculation Pump Discharge Valve MO 1-202-5A).
.10 a.
Compensatory Measures The inspectors conducted a review to verify 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 inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.
Inspection Scope b.
No findings of significance were identified.
Findings
.11 a.
Review and Documentation of Fire Protection Program Changes The inspectors reviewed changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown. The inspectors also reviewed the licensees 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 and/or post-fire safe shutdown analysis and procedures.
Inspection Scope b.
No findings of significance were identified.
Findings
.12 a.
Control of Transient Combustibles and Ignition Sources The inspectors 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 fire hazards analysis. A sample of hot work and transient combustible control permits were also reviewed. The inspectors performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
Inspection Scope b.
No findings of significance were identified.
Findings
.13 a.
B.5.b Inspection Activities The inspectors reviewed the licensees preparedness to handle large fires or explosions by reviewing selected mitigating strategies. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that:
Inspection Scope
- Procedures were being maintained and adequate;
- Equipment was properly staged, maintained, and tested;
- Station personnel were knowledgeable and could implement the procedures; and
- Additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b related equipment.
The inspectors reviewed the licensees B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections.
The B.5.b mitigating strategies selected for review during this inspection are listed below. The offsite and onsite communications, notifications/emergency response organization activation, initial operational response actions and damage assessment activities identified in Table A.3 1 of Nuclear Energy Institute (NEI) 06-12, B.5.b Phase II and III Submittal Guidance, Revision 2 are evaluated each time due to the mitigation strategies scenario selected.
NEI 06-12, Revis ion 2, Section Licens ee Strategy (Table)2.2 SFP Internal Makeup (Table A.2-1)2.3.1 SFP External Makeup (Table A.2-2)2.3.2 SFP External Spray (Table A.2-3)3.4.6 Maximize Control Rod Drive Flow (Table A.5-6)b.
No findings of significance were identified.
Findings
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
a.
(71152)
The inspectors reviewed the licensees corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the fire protection program at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.
Inspection Scope b.
No findings of significance were identified.
Findings 4OA6
.1 Management Meetings
On August 2, 2012, the inspectors presented the inspection results to Mr. Darin, and other members of the licensee staff. The licensee acknowledged the issues presented.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
Exit Meeting Summary
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
- S. Darin, Plant Manager
Licensee
- C. Alguire, System Engineering Manager
- W. Beck, Regulatory Assurance Manager
- K. Ohr, Engineering Director
- J. Garrity, Maintenance Director
- A. Misak, Nuclear Oversight Manager
- K. OShea, Operations Director
- B. Steadman, Design Engineering Director
- M. Wagner, Regulatory Assurance
- C. Pragman, Fire Protection Program Manager, Corporate Office
- M. Dunlay, Design Engineering
- M. Humphrey, Engineering Program
- L. Geerts, Fire Marshal
- V. Ezugha, Fire Protection System Manager
- M. Bridges, Operations/SRO
- J. Rathman, Design Engineering (Electrical)
- M. Taylor, Fire Protection Engineer, Corporate Office
- T. Wojcik, Work Control
- M. Rice, Program Engineering Manager
- G. Harris, Human Performance Manager
- T. Peterson, Regulatory Assurance Lead
- T. Scott, Work Management Director
- J. McGee, Senior Resident Inspector
Nuclear Regulatory Commission
- B. Cushman, Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened and Closed
NCV Inadequate Procedure to Energize Bus 23-1 to Provide Torus Cooling for Unit 1 (Section 1RO5.5.b)
- 05000265/2012011-02 NCV Inadequate Procedure for Cold Shutdown Repair of 1A Recirculation Pump Discharge Valve MO 1-202-5A (Section 1RO5.9.b)