IR 05000247/2013007: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION rch 28, 2013
{{#Wiki_filter:March 28, 2013


==SUBJECT:==
==SUBJECT:==
INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000247/2013007 AND 05000286/2013007
INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000247/2013007 AND 05000286/2013007  


Dear Mr. Ventosa On February 15, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Indian Point Energy Center. The enclosed inspection report documents the inspection results, which were discussed on February 15, 2013, with yourself and other members of your staff.
Dear Mr. Ventosa  
 
On February 15, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Indian Point Energy Center. The enclosed inspection report documents the inspection results, which were discussed on February 15, 2013, with yourself 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. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
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. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
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In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs 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 NRCs document system (ADAMS).
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs 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 NRCs document system (ADAMS).


J. Ventosa   2 ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
J. Ventosa  
 
ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,
Sincerely,
/RA/
/RA/  
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-247; 50-286 License Nos. DPR-26; DPR-64
 
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety  
 
Docket Nos.
 
50-247; 50-286 License Nos. DPR-26; DPR-64  


===Enclosure:===
===Enclosure:===
Inspection Report Nos. 05000247/2013007 and 05000286/2013007 w/Attachment: Supplemental Information
Inspection Report Nos. 05000247/2013007 and 05000286/2013007 w/Attachment: Supplemental Information  


REGION I==
REGION I==
Docket Nos.: 50-247; 50-286 License Nos.: DPR-26; DPR-64 Report Nos.: 05000247/2013007 and 05000286/2013007 Licensee: Entergy Nuclear Northeast Facility: Indian Point Energy Center Location: 450 Broadway, Buchanan, New York Dates: January 28-February 1 and February 11-15, 2013 Inspectors: R. Fuhrmeister, Senior Reactor Inspector (Team Leader)
Docket Nos.:
W. Schmidt, Senior Reactor Analyst K. Young, Senior Reactor Inspector J. Rady, Reactor Inspector S. Galbreath, Reactor Inspector Approved by: John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
50-247; 50-286  
 
License Nos.:
DPR-26; DPR-64  
 
Report Nos.:
05000247/2013007 and 05000286/2013007  
 
Licensee:  
 
Entergy Nuclear Northeast  
 
Facility:  
 
Indian Point Energy Center  
 
Location:  
 
450 Broadway, Buchanan, New York  
 
Dates:  
 
January 28-February 1 and February 11-15, 2013  
 
Inspectors:  
 
R. Fuhrmeister, Senior Reactor Inspector (Team Leader)  
 
W. Schmidt, Senior Reactor Analyst  
 
K. Young, Senior Reactor Inspector J. Rady, Reactor Inspector S. Galbreath, Reactor Inspector  
 
Approved by:
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety  
 
iii Enclosure  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000247/2013007 and 05000286/2013007; 01/28/2013 - 02/15/2013; Entergy Nuclear
IR 05000247/2013007 and 05000286/2013007; 01/28/2013 - 02/15/2013; Entergy Nuclear  


Northeast; Indian Point Energy Center; Triennial Fire Protection Baseline Inspection.
Northeast; Indian Point Energy Center; Triennial Fire Protection Baseline Inspection.
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Two findings of very low significance were identified. These findings were determined to be non-cited violations. The significance of most findings is indicated by their color (Green, White,
Two findings of very low significance were identified. These findings were determined to be non-cited violations. The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process. Cross-cutting aspects associated with findings are determined using IMC 0310,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
"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 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.
Revision 4, dated December 2006.


===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===
Green: The team identified a non-cited violation (NCV) of Unit 2 Operating License Condition 2.N, Unit 3 Operating License Condition 2.AC, and 10 CFR 50.54(hh)(2) for Entergys failure to implement guidance for one of the two strategies intended to maintain or restore core cooling by supplying water to the steam generators.
Green: The team identified a non-cited violation (NCV) of Unit 2 Operating License Condition 2.N, Unit 3 Operating License Condition 2.AC, and 10 CFR 50.54(hh)(2) for Entergys failure to implement guidance for one of the two strategies intended to maintain or restore core cooling by supplying water to the steam generators.


Entergys failure to provide adequate procedural guidance to maintain or restore core cooling is considered a performance deficiency. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent core damage. In accordance Inspection Manual Chapter 0609, Appendix L, B.5.b Significance Determination Process, the team concluded that this finding is of very low safety significance (Green). The team judged that as-found, one of the steam generator fill strategies was unavailable, because on initial implementation, given the assumed severity of plant damage and the procedural inadequacies, the required flow rate to the steam generators would not have been provided. The team determined that this strategy was recoverable, because the equipment would not have been damaged, and the operator likely would request and receive additional direction from emergency management personnel when they became available, such that the required flow rate could be achieved. The team determined that no cross-cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. (Section 1R05.13)
Entergys failure to provide adequate procedural guidance to maintain or restore core cooling is considered a performance deficiency. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent core damage. In accordance Inspection Manual Chapter 0609, Appendix L, B.5.b Significance Determination Process, the team concluded that this finding is of very low safety significance (Green). The team judged that as-found, one of the steam generator fill strategies was unavailable, because on initial implementation, given the assumed severity of plant damage and the procedural inadequacies, the required flow rate to the steam generators would not have been provided. The team determined that this strategy was recoverable, because the equipment would not have been damaged, and the operator likely would request and receive additional direction from emergency management personnel when they became available, such that the required flow rate could be achieved. The team determined that no cross-cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. (Section 1R05.13)  


===Other Findings===
===Other Findings===
None iii
None


=REPORT DETAILS=
=REPORT DETAILS=


Background This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Entergy Nuclear Northeast (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 Indian Point Energy Center (IPEC) facility.
Background  
 
This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Entergy Nuclear Northeast (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 Indian Point Energy Center (IPEC) facility.


The following fire areas (FA) and/or fire zones (FZ) were selected for detailed review based on risk insights from the Indian Point Nuclear Generating Unit 2 (IP2) Individual Plant Examination of External Events (IPEEE).
The following fire areas (FA) and/or fire zones (FZ) were selected for detailed review based on risk insights from the Indian Point Nuclear Generating Unit 2 (IP2) Individual Plant Examination of External Events (IPEEE).


Fire Zone 1 Fire Zone 1A Fire Zone 2A Fire Zone 6A Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
Fire Zone 1  
 
Fire Zone 1A  
 
Fire Zone 2A  
 
Fire Zone 6A  
 
Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.


The inspection team evaluated Entergys fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Condition 2.K, NRC Safety Evaluations, Title 10 of the Code of Federal Regulations (10 CFR) 50.48, and 10 CFR Part 50, Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.6.2, the fire hazards analysis (FHA),and the post-fire safe shutdown analyses.
The inspection team evaluated Entergys fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Condition 2.K, NRC Safety Evaluations, Title 10 of the Code of Federal Regulations (10 CFR) 50.48, and 10 CFR Part 50, Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.6.2, the fire hazards analysis (FHA),and the post-fire safe shutdown analyses.
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==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity  
  {{a|1R05}}
  {{a|1R05}}
==1R05 Fire Protection (IP 71111.05T)==


==1R05 Fire Protection (IP 71111.05T)
==
===.01 Protection of Safe Shutdown Capabilities===
===.01 Protection of Safe Shutdown Capabilities===
====a. Inspection Scope====
====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 Part 50, Appendix R, and the licensees 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.
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 Part 50, Appendix R, and the licensees 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.
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===.02 Passive Fire Protection===
===.02 Passive Fire Protection===
====a. Inspection Scope====
====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 Indian Point Generating Unit 2 Fire Protection Program (FPP), as approved by the NRC, to identify any potential degradation or non-conformances.
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 Indian Point Generating Unit 2 Fire Protection Program (FPP), as approved by the NRC, to identify any potential degradation or non-conformances.
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===.03 Active Fire Protection===
===.03 Active Fire Protection===
====a. Inspection Scope====
====a. Inspection Scope====
The team evaluated manual 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 Indian Point Generating Unit 2 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 hydraulic analyses 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 evaluated manual 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 Indian Point Generating Unit 2 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 hydraulic analyses 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.
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===.04 Protection from Damage from Fire Suppression Activities===
===.04 Protection from Damage from Fire Suppression Activities===
====a. Inspection Scope====
====a. Inspection Scope====
The team walked down the selected fire areas and adjacent areas, and reviewed selected documents to determine whether redundant safe shutdown trains could be potentially damaged from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. During the walkdowns, the team evaluated the adequacy and condition of floor drains, equipment elevations, and spray protection.
The team walked down the selected fire areas and adjacent areas, and reviewed selected documents to determine whether redundant safe shutdown trains could be potentially damaged from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. During the walkdowns, the team evaluated the adequacy and condition of floor drains, equipment elevations, and spray protection.


Specifically, to determine whether a potential existed to damage redundant safe shutdown trains, the team evaluated whether:
Specifically, to determine whether a potential existed to damage redundant safe shutdown trains, the team evaluated whether:  
A fire in one of the selected fire areas would not release smoke, heat, or hot gases that could cause unintended activation of suppression systems in adjacent fire areas which could potentially damage all redundant safe shutdown trains; or A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, could not directly damage all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and Adequate drainage was provided in areas protected by water suppression systems.
 
A fire in one of the selected fire areas would not release smoke, heat, or hot gases that could cause unintended activation of suppression systems in adjacent fire areas which could potentially damage all redundant safe shutdown trains; or  
 
A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, could not directly damage all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and  
 
Adequate drainage was provided in areas protected by water suppression systems.


====b. Findings====
====b. Findings====
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===.05 Post-Fire Safe Shutdown Capability - Normal and Alternative===
===.05 Post-Fire Safe Shutdown Capability - Normal and Alternative===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&ID), 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.
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&ID), 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.
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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.
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:
Specific procedures reviewed for normal and alternative post-fire shutdown included the following:  
2-SOP-ESP-001, Local Equipment Operation and Contingency Actions, Rev. 8 2-ONOP-FP-001, Plant Fires, Rev. 11 and 2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 21.
 
2-SOP-ESP-001, Local Equipment Operation and Contingency Actions, Rev. 8  
 
2-ONOP-FP-001, Plant Fires, Rev. 11 and  
 
2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 21.


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.
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.
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===.06 Circuit Analysis===
===.06 Circuit Analysis===
====a. Inspection Scope====
====a. Inspection 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 licensees 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 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 licensees 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.
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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.
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:
Circuit analysis was performed for the following components:  
21RHRP                   RHR Pump 21; 744                     RHR Pump Discharge Valve; LCV-112C                 VCT Outlet Isolation Valve; 23CHP                   Charging Pump 23; and 23AFP                   AFW Pump 23 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.
 
21RHRP  
 
RHR Pump 21;  
 
744  
 
RHR Pump Discharge Valve;  
 
LCV-112C  
 
VCT Outlet Isolation Valve;  
 
23CHP  
 
Charging Pump 23; and  
 
23AFP  
 
AFW Pump 23  
 
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).
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).
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===.07 Communications===
===.07 Communications===
====a. Inspection Scope====
====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 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.
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===.08 Emergency Lighting===
===.08 Emergency Lighting===
====a. Inspection Scope====
====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 consistent with the manufacturers recommendations and in a manner that would ensure reliable operation.
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 manufacturers recommendations and in a manner that would ensure reliable operation.
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===.09 Cold Shutdown Repairs===
===.09 Cold Shutdown Repairs===
====a. Inspection Scope====
====a. Inspection Scope====
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.g., pre-cut cables with prepared attachment lugs) were available and accessible on site.
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.g., pre-cut cables with prepared attachment lugs) were available and accessible on site.
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===.10 Compensatory Measures===
===.10 Compensatory Measures===
====a. Inspection Scope====
====a. Inspection Scope====
The team verified compensatory measures were in place for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, pumps, valves, or electrical devices providing safe shutdown functions or capabilities). The team evaluated whether the short term compensatory measures adequately compensated for the degraded function or feature until appropriate corrective action could be taken and whether the licensee was effective in returning the equipment to service in a reasonable period of time.
The team verified compensatory measures were in place for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, pumps, valves, or electrical devices providing safe shutdown functions or capabilities). The team evaluated whether the short term compensatory measures adequately compensated for the degraded function or feature until appropriate corrective action could be taken and whether the licensee was effective in returning the equipment to service in a reasonable period of time.
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===.11 Fire Protection Program Changes===
===.11 Fire Protection Program Changes===
====a. Inspection Scope====
====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.
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====
====b. Findings====
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===.12 Control of Transient Combustibles and Ignition Sources===
===.12 Control of Transient Combustibles and Ignition Sources===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the licensees 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.
The team reviewed the licensees 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.
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===.13 Large Fires and Explosions Mitigation Strategies===
===.13 Large Fires and Explosions Mitigation Strategies===
====a. Inspection Scope====
The team assessed the licensees preparedness, at both IP2 and IP3, to respond to large fires or explosions, as required by 10 CFR 50.54(hh)(2). The team specifically reviewed two mitigating strategies to verify:
The adequacy and continued maintenance of procedures;
Maintenance, periodic testing, and storage of equipment; and


====a. Inspection Scope====
The knowledge and ability of station personnel to implement the procedures.
The team assessed the licensees preparedness, at both IP2 and IP3, to respond to large fires or explosions, as required by 10 CFR 50.54(hh)(2). The team specifically reviewed two mitigating strategies to verify:
The adequacy and continued maintenance of procedures; Maintenance, periodic testing, and storage of equipment; and The knowledge and ability of station personnel to implement the procedures.


====b. Findings====
====b. Findings====
=====Introduction:=====
=====Introduction:=====
The team identified a non-cited violation (NCV) of 10 CFR 50.54(hh)(2)for Entergys failure to implement guidance for one of the two strategies intended to maintain or restore core cooling by supply water to the steam generators.
The team identified a non-cited violation (NCV) of 10 CFR 50.54(hh)(2)for Entergys failure to implement guidance for one of the two strategies intended to maintain or restore core cooling by supply water to the steam generators.
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==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
[OA] {{a|4OA2}}
[OA]  
{{a|4OA2}}
 
==4OA2 Identification and Resolution of Problems==
==4OA2 Identification and Resolution of Problems==
===.01 Corrective Actions for Fire Protection Deficiencies===
===.01 Corrective Actions for Fire Protection Deficiencies===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed a sample of CRs associated with FPP and post-fire safe shutdown issues to determine whether Entergy was appropriately identifying, characterizing, and correcting problems in these areas, and to assess whether the planned or completed corrective actions were appropriate. The CRs reviewed are listed in the attachment.
The team reviewed a sample of CRs associated with FPP and post-fire safe shutdown issues to determine whether Entergy was appropriately identifying, characterizing, and correcting problems in these areas, and to assess whether the planned or completed corrective actions were appropriate. The CRs reviewed are listed in the attachment.
Line 252: Line 329:


  {{a|4OA3}}
  {{a|4OA3}}
==4OA3 Followup of Events==
==4OA3 Followup of Events==
{{IP sample|IP=IP 92702|count=1}}
{{IP sample|IP=IP 92702|count=1}}


===.01 Followup of Notice of Violations 05000247/2012009-01 and 05000286/2012008-01===
===.01 Followup of Notice of Violations 05000247/2012009-01 and 05000286/2012008-01===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed Entergys responses to the Notices of Violation dated September 17 and December 7, 2012, to determine the actions which had been planned to be completed to date. The team verified the progress to date and discussed the remaining schedule with the fire protection engineer and safe shutdown engineer.
The team reviewed Entergys responses to the Notices of Violation dated September 17 and December 7, 2012, to determine the actions which had been planned to be completed to date. The team verified the progress to date and discussed the remaining schedule with the fire protection engineer and safe shutdown engineer.
Line 266: Line 343:
b.
b.


Observations The team determined that the items noted as complete in Entergys letters of September 17 and December 7, 2012 had in fact been completed. The team further confirmed that the items identified for implementation during the Unit 3 Spring 2013 refueling outage were on track for completion. The activities identified for implementation during the Unit 2 Spring 2014 refueling outage will be reviewed in future, after approval of the design change documentation.
Observations  
 
The team determined that the items noted as complete in Entergys letters of September 17 and December 7, 2012 had in fact been completed. The team further confirmed that the items identified for implementation during the Unit 3 Spring 2013 refueling outage were on track for completion. The activities identified for implementation during the Unit 2 Spring 2014 refueling outage will be reviewed in future, after approval of the design change documentation.


{{a|4OA6}}
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
==4OA6 Meetings, Including Exit==
===Exit Meeting Summary===
===Exit Meeting Summary===
The team presented their preliminary inspection results to Mr. John Ventosa, Site Vice President, and other members of the site staff at an exit meeting on February 15, 2013.
The team presented their preliminary inspection results to Mr. John Ventosa, Site Vice President, and other members of the site staff at an exit meeting on February 15, 2013.


No proprietary information was included in this inspection report.
No proprietary information was included in this inspection report.
: Supplemental Information
: Supplemental Information  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee Personnel===
: [[contact::G. Dahl]], Licensing Specialist
: [[contact::J. Cottam]], Fire Protection Engineer
: [[contact::K. Elliot]], Safe Shutdown Engineer
: [[contact::R. Carpino]], Operations Support, Fire Brigade Equipment
: [[contact::S. Bianco]], Fire Protection Training
: [[contact::G. Dahl]], Licensing
: [[contact::D. Orce]], Maintenance Mechanic (ELUs)
: [[contact::J. Peters]], Chemistry Supervisor


===Licensee Personnel===
New York State Personnel  
: [[contact::G. Dahl]], Licensing Specialist
: [[contact::J. Cottam]], Fire Protection Engineer
: [[contact::K. Elliot]], Safe Shutdown Engineer
: [[contact::R. Carpino]], Operations Support, Fire Brigade Equipment
: [[contact::S. Bianco]], Fire Protection Training
: [[contact::G. Dahl]], Licensing
: [[contact::D. Orce]], Maintenance Mechanic (ELUs)
: [[contact::J. Peters]], Chemistry Supervisor
New York State Personnel
: [[contact::G. Tarbell]], Fire Protection Specialist
: [[contact::G. Tarbell]], Fire Protection Specialist
NRC
NRC  
: [[contact::J. Rogge]], Chief, Engineering Branch 3, Division of Reactor Safety
: [[contact::J. Rogge]], Chief, Engineering Branch 3, Division of Reactor Safety  
: [[contact::J. S. Stewart]], Senior Resident Inspector, Indian Point Nuclear Generating Unit 2
: [[contact::J. S. Stewart]], Senior Resident Inspector, Indian Point Nuclear Generating Unit 2  
: [[contact::P. Cataldo]], Senior Resident Inspector, Indian Point Nuclear Generating Unit 3
: [[contact::P. Cataldo]], Senior Resident Inspector, Indian Point Nuclear Generating Unit 3  
: [[contact::K. Dunham]], Resident Inspector, Indian Point Nuclear Generating Unit 2
: [[contact::K. Dunham]], Resident Inspector, Indian Point Nuclear Generating Unit 2  
: [[contact::A. Patel]], Resident Inspection, Indian Point Nuclear Generating Unit 3
: [[contact::A. Patel]], Resident Inspection, Indian Point Nuclear Generating Unit 3  


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
===Opened===
===Opened===
 
NONE  
NONE


===Opened and Closed===
===Opened and Closed===
NCV
: 05000247/2012007-01 Failure to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).


NCV  
NCV  
: 05000247/2012007-01 Failure to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).
: 05000286/2012007-01 Failure to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).  
NCV
: 05000286/2012007-01 Failure to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).


===Closed===
===Closed===
 
NONE  
NONE


===Discussed===
===Discussed===
VIO
: 05000247/2012009-01 Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Section 4OA3)


VIO  
VIO  
: 05000247/2012009-01      Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Section 4OA3)
: 05000286/2012008-01 Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Section 4OA3)  
VIO
: 05000286/2012008-01       Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Section 4OA3)


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==


}}
}}

Latest revision as of 10:04, 11 January 2025

IR 05000247-13-007 & 05000286-13-007, on 01/28/2013 02/11-15/2013; Entergy Nuclear Northeast; Indian Point Nuclear Generating Units 2 and 3 - NRC Triennial Fire Protection Inspection Report
ML13087A415
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/28/2013
From: Rogge J
Engineering Region 1 Branch 3
To: Ventosa J
Indian Point, Entergy Nuclear Operations
References
IR-13-007
Download: ML13087A415 (26)


Text

March 28, 2013

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000247/2013007 AND 05000286/2013007

Dear Mr. Ventosa

On February 15, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Indian Point Energy Center. The enclosed inspection report documents the inspection results, which were discussed on February 15, 2013, with yourself 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. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.

Based on the results of this inspection, two findings of very low safety significance (Green) were identified. These findings were also determined to be violations of NRC requirements.

However, because of their very low safety significance, and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCV)

consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a written 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 D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Senior Resident Inspector at Indian Point Energy Center. 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 Indian Point Energy Center.

In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs 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 NRCs document system (ADAMS).

J. Ventosa

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 Nos.

50-247; 50-286 License Nos. DPR-26; DPR-64

Enclosure:

Inspection Report Nos. 05000247/2013007 and 05000286/2013007 w/Attachment: Supplemental Information

REGION I==

Docket Nos.:

50-247; 50-286

License Nos.:

DPR-26; DPR-64

Report Nos.:

05000247/2013007 and 05000286/2013007

Licensee:

Entergy Nuclear Northeast

Facility:

Indian Point Energy Center

Location:

450 Broadway, Buchanan, New York

Dates:

January 28-February 1 and February 11-15, 2013

Inspectors:

R. Fuhrmeister, Senior Reactor Inspector (Team Leader)

W. Schmidt, Senior Reactor Analyst

K. Young, Senior Reactor Inspector J. Rady, Reactor Inspector S. Galbreath, Reactor Inspector

Approved by:

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

iii Enclosure

SUMMARY OF FINDINGS

IR 05000247/2013007 and 05000286/2013007; 01/28/2013 - 02/15/2013; Entergy Nuclear

Northeast; Indian Point Energy Center; Triennial Fire Protection Baseline Inspection.

The report covered a two-week triennial fire protection team inspection by specialist inspectors.

Two findings of very low significance were identified. These findings were determined to be non-cited violations. The significance of most findings is indicated by their color (Green, White,

Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance 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 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.

Cornerstone: Mitigating Systems

Green: The team identified a non-cited violation (NCV) of Unit 2 Operating License Condition 2.N, Unit 3 Operating License Condition 2.AC, and 10 CFR 50.54(hh)(2) for Entergys failure to implement guidance for one of the two strategies intended to maintain or restore core cooling by supplying water to the steam generators.

Entergys failure to provide adequate procedural guidance to maintain or restore core cooling is considered a performance deficiency. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent core damage. In accordance Inspection Manual Chapter 0609, Appendix L, B.5.b Significance Determination Process, the team concluded that this finding is of very low safety significance (Green). The team judged that as-found, one of the steam generator fill strategies was unavailable, because on initial implementation, given the assumed severity of plant damage and the procedural inadequacies, the required flow rate to the steam generators would not have been provided. The team determined that this strategy was recoverable, because the equipment would not have been damaged, and the operator likely would request and receive additional direction from emergency management personnel when they became available, such that the required flow rate could be achieved. The team determined that no cross-cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. (Section 1R05.13)

Other Findings

None

REPORT DETAILS

Background

This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether Entergy Nuclear Northeast (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 Indian Point Energy Center (IPEC) facility.

The following fire areas (FA) and/or fire zones (FZ) were selected for detailed review based on risk insights from the Indian Point Nuclear Generating Unit 2 (IP2) Individual Plant Examination of External Events (IPEEE).

Fire Zone 1

Fire Zone 1A

Fire Zone 2A

Fire Zone 6A

Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.

The inspection team evaluated Entergys fire protection program (FPP) against applicable requirements which included plant Technical Specifications, Operating License Condition 2.K, NRC Safety Evaluations, Title 10 of the Code of Federal Regulations (10 CFR) 50.48, and 10 CFR Part 50, Appendix R. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.6.2, the fire hazards analysis (FHA),and the post-fire safe shutdown analyses.

The team also evaluated two licensee mitigating strategies at each unit for addressing large fires and explosions as required by Unit 2 Operating License Condition 2.N, Unit 3 Operating License Condition 2.AC, and 10 CFR 50.54 (hh)(2). Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample per unit.

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 Part 50, Appendix R, and the licensees 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.

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 Indian Point Generating Unit 2 Fire Protection Program (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 material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating. The team also reviewed similar records for selected fire protection wraps to verify whether the material and configuration was appropriate for the required fire rating and conformed to the engineering design.

The team also reviewed recent inspection and functional test records for fire dampers, and the inspection records for penetration seals and fire barriers, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.

b. Findings

No findings were identified.

.03 Active Fire Protection

a. Inspection Scope

The team evaluated manual 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 Indian Point Generating Unit 2 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 hydraulic analyses 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 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 corrective action program documents (condition reports (CR)) 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 Indian Point Generating Unit 2'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.g., turnout gear) and smoke removal equipment, to determine operational readiness for fire fighting. In addition, the team reviewed Indian Point Generating Unit 2'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 walked down the selected fire areas and adjacent areas, and reviewed selected documents to determine whether redundant safe shutdown trains could be potentially damaged from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. During the walkdowns, the team evaluated the adequacy and condition of floor drains, equipment elevations, and spray protection.

Specifically, to determine whether a potential existed to damage redundant safe shutdown trains, the team evaluated whether:

A fire in one of the selected fire areas would not release smoke, heat, or hot gases that could cause unintended activation of suppression systems in adjacent fire areas which could potentially damage all redundant safe shutdown trains; or

A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, could not directly damage all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and

Adequate drainage was 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&ID), 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.

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:

2-SOP-ESP-001, Local Equipment Operation and Contingency Actions, Rev. 8

2-ONOP-FP-001, Plant Fires, Rev. 11 and

2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 21.

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 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 licensees 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 teams 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.

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:

21RHRP

RHR Pump 21;

744

RHR Pump Discharge Valve;

LCV-112C

VCT Outlet Isolation Valve;

23CHP

Charging Pump 23; and

23AFP

AFW Pump 23

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 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 consistent with the manufacturers recommendations and in a manner that would ensure reliable operation.

b. Findings

No findings were identified.

.09 Cold Shutdown Repairs

a. Inspection Scope

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.g., pre-cut cables with prepared attachment lugs) were available and accessible on site.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The team verified compensatory measures were in place for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems and equipment, passive fire barriers, pumps, valves, or electrical devices providing safe shutdown functions or capabilities). The team evaluated whether the short term compensatory measures adequately compensated for the degraded function or feature until appropriate corrective action could be taken and whether the licensee was effective in returning the equipment to service in a reasonable period of time.

The team reviewed selected compensatory measures in the form of operator manual actions for 10 CFR Part 50 Appendix R, Section III.G.2 designated areas to evaluate whether those actions could be reasonably accomplished. Specific attributes reviewed included availability of diagnostic instrumentation, expected environmental conditions, minimum staffing, communications, equipment availability, training, procedures, and verification and validation.

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 the licensees 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.

b. Findings

No findings were identified.

.13 Large Fires and Explosions Mitigation Strategies

a. Inspection Scope

The team assessed the licensees preparedness, at both IP2 and IP3, to respond to large fires or explosions, as required by 10 CFR 50.54(hh)(2). The team specifically reviewed two mitigating strategies to verify:

The adequacy and continued maintenance of procedures;

Maintenance, periodic testing, and storage of equipment; and

The knowledge and ability of station personnel to implement the procedures.

b. Findings

Introduction:

The team identified a non-cited violation (NCV) of 10 CFR 50.54(hh)(2)for Entergys failure to implement guidance for one of the two strategies intended to maintain or restore core cooling by supply water to the steam generators.

Description:

The team identified inadequacies in procedure 0-SOP-ESP-002, Emergency Contingency Plan, Rev. 8, concerning the filling of steam generators not using the auxiliary boiler feedwater system. The operation of the portable pump according to procedural steps and associated precautions, limitations, cautions and notes on pump suction pressure and speed, reasonably would not have produced the required discharge pressure and as such the required flowrate to the SGs. Upon initial implementation, given the assumed severity of plant damage and these procedural inadequacies the operator reasonably could not have successfully accomplished the strategy. The team did note that the operator would likely identify the insufficient discharge pressure and that the procedure inadequacies would not have caused equipment damage. At some point following unsuccessful initial implementation the operator would likely request and receive additional direction from emergency management personnel, when they became available, such that the required flow could be achieved.

Analysis:

This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent core damage. In accordance Inspection Manual Chapter 0609, Appendix L, B.5.b Significance Determination Process, the team concluded that this finding is of very low safety significance (Green). The team judged that as-found, one of the steam generator fill strategies was unavailable, because on initial implementation, given the assumed severity of plant damage and the procedural inadequacies, the required flow rate to the steam generators would not have been provided. The team determined that this strategy was recoverable, because the equipment would not have been damaged, and the operator likely would request and receive additional direction from emergency management personnel when they became available, such that the required flow rate could be achieved. This issue was not more significant because the team concluded that Entergy could adequately provide makeup to the SGs with the other available strategy. Entergy entered this issue into their corrective action program Condition Report CR-IP2-2013-00474. The team determined that no cross-cutting aspect was applicable to this performance deficiency because the finding was not indicative of current licensee performance.

Enforcement:

10 CFR 50.54(hh)(2), in part, required that Entergy shall develop and implement guidance and strategies intended to maintain or restore core cooling to mitigate fuel damage under the circumstances associated with loss of large areas of the plant due to explosions or fire. Specifically the portion of 0-SOP-ESP-002, Emergency Contingency Plan, Rev. 8, to fill steam generators not using the auxiliary boiler feedwater system was inadequate, in that without additional direction from emergency management personnel, the as-found procedural steps and associated precautions, limitations, cautions and notes on pump suction pressure and speed, reasonably would not have produced the required discharge pressure and as such the required flowrate to the steam generators. Because this finding is of very low safety significance (Green)and has been entered into Entergys corrective action program (CR-IP2-2013-00474),this violation is being treated as a non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000247/2012007-01 and 05000286/2012007-01:

Entergy failed to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).

OTHER ACTIVITIES

[OA]

4OA2 Identification and Resolution of Problems

.01 Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team reviewed a sample of CRs associated with FPP and post-fire safe shutdown issues to determine whether Entergy was appropriately identifying, characterizing, and correcting problems in these areas, and to assess whether the planned or completed corrective actions were appropriate. The CRs reviewed are listed in the attachment.

b. Findings

No findings were identified.

4OA3 Followup of Events

.01 Followup of Notice of Violations05000247/2012009-01 and 05000286/2012008-01

a. Inspection Scope

The team reviewed Entergys responses to the Notices of Violation dated September 17 and December 7, 2012, to determine the actions which had been planned to be completed to date. The team verified the progress to date and discussed the remaining schedule with the fire protection engineer and safe shutdown engineer.

The team walked down electrical raceway fire barriers being installed in both units for the purpose of eliminating operator manual actions. The team evaluated the condition of the barriers and conformance to design and tested configurations.

The team reviewed the design change package for work to be performed during the Unit 3 Spring 2013 refueling outage to eliminate operator manual action 10, and discussed its status with engineering personnel.

b.

Observations

The team determined that the items noted as complete in Entergys letters of September 17 and December 7, 2012 had in fact been completed. The team further confirmed that the items identified for implementation during the Unit 3 Spring 2013 refueling outage were on track for completion. The activities identified for implementation during the Unit 2 Spring 2014 refueling outage will be reviewed in future, after approval of the design change documentation.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented their preliminary inspection results to Mr. John Ventosa, Site Vice President, and other members of the site staff at an exit meeting on February 15, 2013.

No proprietary information was included in this inspection report.

Supplemental Information

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Dahl, Licensing Specialist
J. Cottam, Fire Protection Engineer
K. Elliot, Safe Shutdown Engineer
R. Carpino, Operations Support, Fire Brigade Equipment
S. Bianco, Fire Protection Training
G. Dahl, Licensing
D. Orce, Maintenance Mechanic (ELUs)
J. Peters, Chemistry Supervisor

New York State Personnel

G. Tarbell, Fire Protection Specialist

NRC

J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
J. S. Stewart, Senior Resident Inspector, Indian Point Nuclear Generating Unit 2
P. Cataldo, Senior Resident Inspector, Indian Point Nuclear Generating Unit 3
K. Dunham, Resident Inspector, Indian Point Nuclear Generating Unit 2
A. Patel, Resident Inspection, Indian Point Nuclear Generating Unit 3

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE

Opened and Closed

NCV

05000247/2012007-01 Failure to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).

NCV

05000286/2012007-01 Failure to implement an appropriate procedure to ensure that one of two strategies provided adequate cooling water flow to the SGs per 50.54(hh)(2).

Closed

NONE

Discussed

VIO

05000247/2012009-01 Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Section 4OA3)

VIO

05000286/2012008-01 Failure to Protect Safe Shutdown Equipment from the Effects of Fire (Section 4OA3)

LIST OF DOCUMENTS REVIEWED