IR 05000272/2009006: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(3 intermediate revisions by the same user not shown)
Line 3: Line 3:
| issue date = 03/24/2009
| issue date = 03/24/2009
| title = IR 05000272-09-006; 05000311-09-006; on 01/26/2009 - 02/13/2009; PSEG Nuclear LLC; Salem Nuclear Generating Station, Unit Nos. 1 and 2; Triennial Fire Protection Team Inspection; Fire Protection
| title = IR 05000272-09-006; 05000311-09-006; on 01/26/2009 - 02/13/2009; PSEG Nuclear LLC; Salem Nuclear Generating Station, Unit Nos. 1 and 2; Triennial Fire Protection Team Inspection; Fire Protection
| author name = Rogge J F
| author name = Rogge J
| author affiliation = NRC/RGN-I/DRS/EB3
| author affiliation = NRC/RGN-I/DRS/EB3
| addressee name = Joyce T P
| addressee name = Joyce T
| addressee affiliation = PSEG Nuclear, LLC
| addressee affiliation = PSEG Nuclear, LLC
| docket = 05000272, 05000311
| docket = 05000272, 05000311
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:March 24, 2009
[[Issue date::March 24, 2009]]


Mr. Thomas President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038
==SUBJECT:==
 
SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000272/2009006 and 05000311/2009006
SUBJECT: SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000272/2009006 and 05000311/2009006


==Dear Mr. Joyce:==
==Dear Mr. Joyce:==
On February 13, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Salem Nuclear Generating Station, Unit Nos. 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on February 13, 2009, with Mr. Braun and other members of your staff.
On February 13, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Salem Nuclear Generating Station, Unit Nos. 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on February 13, 2009, with Mr. Braun and other members of your staff.


The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.


Based on the results of this inspection, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Salem Nuclear Generating Station.
Based on the results of this inspection, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Salem Nuclear Generating Station.


In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
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 component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely,
/RA/


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


Docket Nos. 50-272; 50-311 License Nos. DPR-70; DPR-75  
Docket Nos. 50-272; 50-311 License Nos. DPR-70; DPR-75  


===Enclosure:===
Enclosure: Inspection Report No. 05000272/2009006 and 05000311/2009006  
Inspection Report No. 05000272/2009006 and 05000311/2009006  


===w/Attachment:===
w/Attachment: Supplemental Information
Supplemental Information


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
Line 51: Line 50:
This report covered a two-week triennial fire protection team inspection by specialist inspectors.
This report covered a two-week triennial fire protection team inspection by specialist inspectors.


One Green NCV was identified. 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Rev. 4, dated December 2006.
One Green NCV was identified. 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, Rev. 4, dated December 2006.
 
===A. NRC-Identified and Self-Revealing Findings===


===NRC-Identified and Self-Revealing Findings===
===Cornerstone: Mitigating Systems===
===Cornerstone: Mitigating Systems===
: '''Green.'''
: '''Green.'''
Line 61: Line 59:
The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, PSEG did not ensure that post-fire operator manual actions subsequent to a single spurious operation of the safety injection signal during a main control room fire could be performed within sufficient time to achieve and maintain hot standby conditions. The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP). This finding affected the completeness of the post-fire safe shutdown analysis. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because a technical evaluation of pressurizer level response to a spurious safety injection signal from a main control room fire concluded that pressurizer level would remain in the indicating range. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because PSEG identified the issue on February 15, 2006 but never thoroughly evaluated the issue and its potential impact on the ability to achieve and maintain post-fire hot standby conditions.
The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, PSEG did not ensure that post-fire operator manual actions subsequent to a single spurious operation of the safety injection signal during a main control room fire could be performed within sufficient time to achieve and maintain hot standby conditions. The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP). This finding affected the completeness of the post-fire safe shutdown analysis. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because a technical evaluation of pressurizer level response to a spurious safety injection signal from a main control room fire concluded that pressurizer level would remain in the indicating range. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because PSEG identified the issue on February 15, 2006 but never thoroughly evaluated the issue and its potential impact on the ability to achieve and maintain post-fire hot standby conditions.


(P.1(c)) (Section 4OA2.01)  
(P.1(c)) (Section 4OA2.01)  
 
===B. Licensee-Identified Violations===


===Licensee-Identified Violations===
None.
None.


=REPORT DETAILS=
=REPORT DETAILS=


Background
Background  


This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, "Fire Protection."  The objective of the inspection was to assess whether PSEG Nuclear LLC (PSEG) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem). The following fire areas and fire zones were selected for detailed review based on risk insights from the Salem Individual Plant Examination of External Events:
This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether PSEG Nuclear LLC (PSEG) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem). The following fire areas and fire zones were selected for detailed review based on risk insights from the Salem Individual Plant Examination of External Events:
* 1(2)FA-AB-100A
* 1(2)FA-AB-100A
* 1(2)FA-AB-64A
* 1(2)FA-AB-64A
Line 77: Line 74:
* 1(2)FA-EP-78C  
* 1(2)FA-EP-78C  


The inspection team evaluated PSEG's fire protection program (FPP) against applicable requirements which included plant technical specifications, OP-SA-108-115-1001, Operability Assessment and Equipment Control Program, Rev. 2, Operating License condition 2.C.5 and 2.C.10 for Unit Nos. 1 and 2 respectively, 10 CFR 50.48, and 10 CFR 50 Appendix R. The team also reviewed related documents that included NRC safety evaluation reports, Section 9.5.1 of the Updated Final Safety Analysis Report (UFSAR), the fire hazards analysis (FHA), and the post-fire safe shutdown analysis.
The inspection team evaluated PSEGs fire protection program (FPP) against applicable requirements which included plant technical specifications, OP-SA-108-115-1001, Operability Assessment and Equipment Control Program, Rev. 2, Operating License condition 2.C.5 and 2.C.10 for Unit Nos. 1 and 2 respectively, 10 CFR 50.48, and 10 CFR 50 Appendix R. The team also reviewed related documents that included NRC safety evaluation reports, Section 9.5.1 of the Updated Final Safety Analysis Report (UFSAR), the fire hazards analysis (FHA), and the post-fire safe shutdown analysis.


Specific documents reviewed by the team are listed in the attachment.
Specific documents reviewed by the team are listed in the attachment.


==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 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and Normal Shutdown===
==
===.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and===
Normal Shutdown


====a. Inspection Scope====
====a. Inspection Scope====
Methodology
Methodology  


The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings, electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room.
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings, electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room.
Line 98: Line 97:
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.
Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.


Operational Implementation
Operational Implementation  


The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for 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 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.
Line 106: Line 105:
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
Specific procedures reviewed for alternative shutdown, including shutdown from outside the control room included the following:
* S1(2).OP-AB.Fire-0001, Control Room Fire Response, Rev. 3(6)
* S1(2).OP-AB.Fire-0001, Control Room Fire Response, Rev. 3(6)
* S1(2). OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 23(26)
* S1(2). OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 23(26)  
 
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 were 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 were adequate to ensure the functionality of the alternative shutdown capability.


Line 113: Line 113:


===.02 Protection of Safe Shutdown Capabilities===
===.02 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  
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 separation requirements of Section III.G of 10 CFR 50, Appendix R 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.
 
team ensured that separation requirements of Section III.G of 10 CFR 50, Appendix R 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 PSEG's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.
The team reviewed PSEGs 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 protective features were being properly maintained and administrative controls were being implemented.


====b. Findings====
====b. Findings====
Line 125: Line 122:


===.03 Passive Fire Protection===
===.03 Passive Fire Protection===
====a. Inspection Scope====
====a. Inspection Scope====
The team 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), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.
The team 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), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.
Line 135: Line 131:


===.04 Active Fire Protection===
===.04 Active Fire Protection===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA) code of record or as NRC approved exemptions, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems was verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, storage tanks and supply system) to assess the material condition of the systems and components.
The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA) code of record or as NRC approved exemptions, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems was verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, storage tanks and supply system) to assess the material condition of the systems and components.
Line 149: Line 144:


===.05 Protection From Damage From Fire Suppression Activities===
===.05 Protection From Damage From Fire Suppression Activities===
====a. Inspection Scope====
====a. Inspection Scope====
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
Line 160: Line 154:


===.06 Alternative Shutdown Capability===
===.06 Alternative Shutdown Capability===
====a. Inspection Scope====
====a. Inspection Scope====
Alternative shutdown capability for some of the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.
Alternative shutdown capability for some of the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.
Line 168: Line 161:


===.07 Circuit Analysis===
===.07 Circuit Analysis===
====a. Inspection Scope====
====a. Inspection Scope====
The team verified that PSEG 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 PSEG'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.
The team verified that PSEG 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 PSEGs analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.


The team's 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 teams 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 team also reviewed cable routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.
The team also reviewed cable routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.
Line 189: Line 181:


===.08 Communications===
===.08 Communications===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed safe shutdown procedures, the FHA, 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 sound powered phone system cables, repeaters, and transmitters would not be affected by a fire.
The team reviewed safe shutdown procedures, the FHA, 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 sound powered phone system cables, repeaters, and transmitters would not be affected by a fire.
Line 197: Line 188:


===.09 Emergency Lighting===
===.09 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 and/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, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.
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 and/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, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.
Line 205: Line 195:


===.10 Cold Shutdown Repairs===
===.10 Cold Shutdown Repairs===
====a. Inspection Scope====
====a. Inspection Scope====
The team verified that PSEG 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 PSEG 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.
Line 213: Line 202:


===.11 Compensatory Measures===
===.11 Compensatory Measures===
====a. Inspection Scope====
====a. Inspection Scope====
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that PSEG was effective in returning the equipment to service in a reasonable period of time.
The team verified that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g. detection and suppression systems and equipment, passive fire barriers, or pumps, valves or electrical devices providing safe shutdown functions or capabilities). The team also verified that the short term compensatory measures compensated for the degraded function or feature until appropriate corrective action could be taken and that PSEG was effective in returning the equipment to service in a reasonable period of time.
Line 221: Line 209:


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
[OA]
[OA] {{a|4OA2}}


{{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 verified that PSEG was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program.
The team verified that PSEG was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program.
Line 234: Line 219:


====b. Findings====
====b. Findings====
=====Introduction.=====
=====Introduction.=====
The team identified that PSEG failed to evaluate a single spurious operation of a safety injection signal during a main control room fire and its impact on the ability to achieve and maintain hot standby conditions. This finding was determined to be of very low safety significance (Green) and a NCV of the Salem Nuclear Generating Station, Unit Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C.(10) respectively, Fire Protection.
The team identified that PSEG failed to evaluate a single spurious operation of a safety injection signal during a main control room fire and its impact on the ability to achieve and maintain hot standby conditions. This finding was determined to be of very low safety significance (Green) and a NCV of the Salem Nuclear Generating Station, Unit Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C.(10) respectively, Fire Protection.


=====Description.=====
=====Description.=====
During a post-fire circuit failure self assessment of Salem Appendix R safe shutdown program, PSEG documented on February 15, 2006 in notification 2027112 that several spurious operation questions involved additional research and reviews. The notification documented that DE-PS.ZZ-0001-A4, Salem Fire Protection Report -
During a post-fire circuit failure self assessment of Salem Appendix R safe shutdown program, PSEG documented on February 15, 2006 in notification 2027112 that several spurious operation questions involved additional research and reviews. The notification documented that DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1, section 7.10 states that circuit analysis will conservatively assume that a safety injection signal output to components is possible to cause spurious operation. Notification 2027112 specifically documented How has the analysis addressed the potential for spurious SI in general? as well as other potential single spurious operations of individual safety injection components.
Shutdown Cables, Rev. 1, section 7.10 states that circuit analysis will conservatively assume that a safety injection signal output to components is possible to cause spurious operation. Notification 2027112 specifically documented "How has the analysis addressed the potential for spurious SI in general?" as well as other potential single spurious operations of individual safety injection components.


PSEG initiated condition report 70054167 to evaluate the post-fire safety injection signal spurious operation as well as the other issues in notification 2027112. The potential for a single spurious operation causing a complete safety injection signal and the subsequent impact on the ability to achieve and maintain hot standby conditions was not evaluated by PSEG. PSEG extended the evaluation due date several times: July 19, 2007, January 25, 2008, and finally September 25, 2008. The inspectors also noted that each new deadline was established after the due date had already past.
PSEG initiated condition report 70054167 to evaluate the post-fire safety injection signal spurious operation as well as the other issues in notification 2027112. The potential for a single spurious operation causing a complete safety injection signal and the subsequent impact on the ability to achieve and maintain hot standby conditions was not evaluated by PSEG. PSEG extended the evaluation due date several times: July 19, 2007, January 25, 2008, and finally September 25, 2008. The inspectors also noted that each new deadline was established after the due date had already past.


On January 9, 2009 PSEG performed a timeline study of S2.OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 26 and walked down with operators all operator manual actions for a control room fire scenario. The team reviewed the collected timeline data and noted that the operator manual actions to completely terminate high-head injection, such as would be necessary during a spurious safety injection signal, would not occur until about 28 minutes after the reactor trip. The team questioned whether pressurizer level would remain in the indicating range during such a scenario. PSEG subsequently performed a technical evaluation that addressed the teams' question. The technical evaluation was documented in condition report 70094126. The evaluation included conservative assumptions and concluded that pressurizer level would remain in the indicating range. When compared to the operator manual action timeline study of January 9, 2009, about one minute of margin existed before pressurizer level would exceed the reliable indication range. PSEG also documented this issue in corrective action notification 20402904. The team concluded that failing to ensure that a single spurious operation of a safety injection signal would not adversely impact post-fire safe shutdown operations consistent with DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1 is a performance deficiency.
On January 9, 2009 PSEG performed a timeline study of S2.OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 26 and walked down with operators all operator manual actions for a control room fire scenario. The team reviewed the collected timeline data and noted that the operator manual actions to completely terminate high-head injection, such as would be necessary during a spurious safety injection signal, would not occur until about 28 minutes after the reactor trip. The team questioned whether pressurizer level would remain in the indicating range during such a scenario. PSEG subsequently performed a technical evaluation that addressed the teams question. The technical evaluation was documented in condition report 70094126. The evaluation included conservative assumptions and concluded that pressurizer level would remain in the indicating range. When compared to the operator manual action timeline study of January 9, 2009, about one minute of margin existed before pressurizer level would exceed the reliable indication range. PSEG also documented this issue in corrective action notification 20402904. The team concluded that failing to ensure that a single spurious operation of a safety injection signal would not adversely impact post-fire safe shutdown operations consistent with DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1 is a performance deficiency.


=====Analysis.=====
=====Analysis.=====
Line 251: Line 234:
The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP). This finding affected the completeness of the post-fire safe shutdown analysis. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because a technical evaluation of pressurizer level response to a spurious safety injection signal from a main control room fire concluded that pressurizer level would remain in the indicating range.
The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP). This finding affected the completeness of the post-fire safe shutdown analysis. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because a technical evaluation of pressurizer level response to a spurious safety injection signal from a main control room fire concluded that pressurizer level would remain in the indicating range.


The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because PSEG identified the issue on February 15, 2006 but never thoroughly evaluated the issue and its potential impact on the ability to achieve and maintain post-fire hot standby conditions. (P.1(c))  
The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because PSEG identified the issue on February 15, 2006 but never thoroughly evaluated the issue and its potential impact on the ability to achieve and maintain post-fire hot standby conditions. (P.1(c))  


=====Enforcement.=====
=====Enforcement.=====
Salem Nuclear Generating Station, Units Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C(10) respectively, requires that PSEG Nuclear LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). UFSAR section 9.5.1.1.5 assures that corrective action measures are established to ensure that conditions adverse to fire protection such as non-conformances are promptly identified, reported, and corrected. Contrary to the above, from February 15, 2006, to February 13, 2009, PSEG did not promptly correct a non-conformance in its safe shutdown analysis in that a spurious operation of the safety injection signal was not conservatively assumed to occur consistent with fire protection program document, DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1. Because this finding was of very low safety significance (Green) and has been entered into PSEG's corrective action program (Notification 20402904), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000272&311/2009006-01, Failure to Evaluate Spurious Operation of SI Signal.
Salem Nuclear Generating Station, Units Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C(10) respectively, requires that PSEG Nuclear LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). UFSAR section 9.5.1.1.5 assures that corrective action measures are established to ensure that conditions adverse to fire protection such as non-conformances are promptly identified, reported, and corrected. Contrary to the above, from February 15, 2006, to February 13, 2009, PSEG did not promptly correct a non-conformance in its safe shutdown analysis in that a spurious operation of the safety injection signal was not conservatively assumed to occur consistent with fire protection program document, DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1. Because this finding was of very low safety significance (Green) and has been entered into PSEGs corrective action program (Notification 20402904), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000272&311/2009006-01, Failure to Evaluate Spurious Operation of SI Signal.


{{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. R. Braun, Site Vice President, and other members of the site staff at an exit meeting on February 13, 2009.
The team presented their preliminary inspection results to Mr. R. Braun, Site Vice President, and other members of the site staff at an exit meeting on February 13, 2009.


Line 270: Line 252:


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
===Licensee Personnel===
===Licensee Personnel===
M. Adair
Fire Protection Program Manager
R. Braun
Site Vice President
J. Carlin
Fire Department Superintendent
R. Chambers
Fire Marshall
K. Colville
Inspection Support Manager
E. Eilola
Engineering Director
J. Konovalchick
Senior Reactor Operator
K. Mathur
Design Engineer
L. Rajkowski
Design Engineering Manager
S. Savar
Safe Shutdown Engineer
B. Thomas
Senior Licensing Engineer
K. Wolf
System Engineer
NRC
J. Rogge


M. Adair  Fire Protection Program Manager
Chief, Engineering Branch 3, Division of Reactor Safety
R. Braun  Site Vice President
C. Cahill
J. Carlin  Fire Department Superintendent
R. Chambers  Fire Marshall
K. Colville  Inspection Support Manager
E. Eilola  Engineering Director
J. Konovalchick Senior Reactor Operator
K. Mathur  Design Engineer
L. Rajkowski  Design Engineering Manager
S. Savar  Safe Shutdown Engineer
B. Thomas  Senior Licensing Engineer
K. Wolf  System Engineer


NRC 
Senior Reactor Analyst, Division of Reactor Safety
: [[contact::J. Rogge  Chief]], Engineering Branch 3, Division of Reactor Safety
D. Schroeder
: [[contact::C. Cahill  Senior Reactor Analyst]], Division of Reactor Safety  
Senior Resident Inspector, Salem Nuclear Generating Station
: [[contact::D. Schroeder   Senior Resident Inspector]], Salem Nuclear Generating Station  
H. Balian
: [[contact::H. Balian Resident Inspector]], Salem Nuclear Generating Station  
Resident Inspector, Salem Nuclear Generating Station  


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


===Opened and Closed===
===Opened and Closed===
: 05000272&311/2009006-01 NCV Failure to Evaluate Spurious Operation of SI Signal
: 05000272&311/2009006-01 NCV  
 
Failure to Evaluate Spurious Operation of SI Signal  


===Closed===
===Closed===
: None  
None  


===Discussed===
===Discussed===
None


None
Attachment
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
Fire Protection Licensing Documents
 
: Salem Units 1 and 2 Updated Final Safety Analysis Report, Rev. 24
: Letter to NRC, Revised Exemption Requests Fire Protection - 10 CFR Appendix R, Salem Generating Station Unit Nos. 1 and 2, 7/15/88 Letter to PSE&G, Exemption from the Requirements of 10
: CFR 50, Appendix R (Fire Protection),
: 7/20/89 Letter to PSE&G, Correction to Salem Exemption - Exemption from the Requirements of 10
: CFR 50, Appendix R,
: 8/15/89 Letter to NRC, Schedule for Completion of Fire Protection Features Modifications Salem Generating Station Unit Nos. 1 and 2, 12/28/90 Letter to NRC, Request for Reconsideration of Exemption Fire Protection - 10
: CFR 50, Appendix R Salem Generating Stations Unit Nos. 1 and 2, 1/4/91 Letter to PSE&G, Request for Additional Information, Reconsideration of Exemption from Fire Protection Requirements, Salem Nuclear Generating Station, Units 1 and 2, 1/21/92 Letter to NRC, Additional Information - Reconsideration of Exemption from Fire Protection Requirements Salem Generating Station, Unit Nos. 1 and 2, 4/28/92 Letter to PSE&G, Emergency Control Air Compressors, Salem Nuclear Generating Station, Unit Nos. 1 and 2, 6/29/92 Letter to PSE&G, Exemption Correction, Exemption from the Requirements of 10
: CFR 50, Appendix R, Salem Nuclear Generating Station, Units 1 and 2, 6/17/94 Letter to NRC, Update to Exemption Request Fire Protection - Appendix R Salem Generating Station Unit Nos. 1 and 2, 6/4/97 Letter to NRC, Control of Minimum Staffing Requirements for Dual Unit Shutdown Outside of the Control Room Commitment Change Salem Generating Station Unit Nos. 1 and 2, 1/2/02 Letter to NRC, Withdrawal of Exemptions form the Requirements of 10 CFR Part 50, Appendix R, Salem Nuclear Generating Station, Unit Nos. 1 and 2, 3/28/07
: Calculations/Engineering Evaluation Reports/Design Bases Documents
: CC-AA-211, Fire Protection Program, Rev. 4
: DE-PS.ZZ-0001, Programmatic Standard for Fire Protection, Rev. 3
: DE-PS.ZZ-0001-A2-FHA, Salem Fire Protection Report - Fire Hazards Analysis, Rev. 6
: DE-PS.ZZ-0001-A3-SSA, Salem Fire Protection Report - Safe Shutdown Analysis, Rev. 5
: DE-PS.ZZ-0001-A3-SSAR (003), Salem Fire Protection Report - Safe Shutdown Analysis, Safe Shutdown Manual Action Feasibility Assessment, Rev. 1
: DE-PS.ZZ-0001-A3-SSAR-(005), Salem Fire Protection Report - Safe Shutdown Analysis, 1FA-AB-64A, Rev. 1
: DE-PS.ZZ-0001-A3-SSAR-(005), Salem Fire Protection Report - Safe Shutdown Analysis, 2FA-AB-64A, Rev. 1
: DE-PS.ZZ-0001-A3-SSAR-(007), Salem Fire Protection Report - Safe Shutdown Analysis, 1FA-AB-84A, Rev. 1
: DE-PS.ZZ-0001-A3-SSAR-(007), Salem Fire Protection Report - Safe Shutdown Analysis, 2FA-AB-84A, Rev. 1 
: Attachment
: DE-PS.ZZ-0001-A3-SSAR-(015), Salem Fire Protection Report - Safe Shutdown Analysis, 1FA-EP-78C, Rev. 3
: DE-PS.ZZ-0001-A3-SSAR-(015), Salem Fire Protection Report - Safe Shutdown Analysis, 2FA-EP-78C, Rev. 3
: DE-PS.ZZ-0001-A3-SSAR-(059), Salem Fire Protection Report -Safe Shutdown Analysis, 12FA-AB-122A & 1FA-AB-100A, Rev. 0
: DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1
: DE-PS.ZZ-0001-A6-GEN, Salem Fire Protection Report, Rev. 2
: ES-44.018, Salem Units 1 & 2 Electrical Coordination for Appendix R Applications, Rev. 1
: S-C-CAV-MDC-1878, Salem Units 1 and 2 SPAVS Gothic Appendix R Scenarios, Rev. 1
: S-C-CVC-MEE-1475, Appendix R Fire in 1(2)FA-EP-78C Impact on CVCS, Rev. 0
: S-C-FP-FEE-1746, Acceptable Operator Response Times to Appendix R Failures, Rev. 1 
: S-C-WD-MDC-2116, Electrical Equipment Room Water Drain Calculation, Rev. 1
: S-C-ZZ-EEE-1430, Loss of Offsite Power Evaluation for a Postulated Appendix R Fire at Salem Generating Station Unit 1 & 2, Rev. 2 S-C-ZZ-NEE-0839, Time Analysis for Alternative Shutdown Capability for Appendix R Scenario, Rev. 2 S-1-FP-FDC-2115, Hydraulic Analysis for Unit 1 FP Sprinkler Piping for El. 78 Elec. Pen Area, Rev. 0 
: Design Change Packages
: 80089441
: 80089591 
===Procedures===
: FP-AA-008, Fire Prevention for Hot Work, Rev. 1
: FP-AA-008-F1, Hot Work Permit, Rev 0
: FP-AA-009-F2, Hot Work Authorization Log, Rev. 0
: FP-AA-011, Control of Combustible Material, Rev. 1
: MA-AA-723-300-, Diagnostic Testing and Inspection of Motor Operated Valves, Rev. 4
: NC.FP-AP.ZZ-0001, Fire Protection Organization, Duties, and Staffing, Rev. 4
: NC.FP-AP.ZZ-0005, Fire Protection Surveillance and Periodic Test Program, Rev.14
: NC.FP-AP.ZZ-0009, Fire Protection Training Program, Rev. 5
: NC.FP-AP.ZZ-0010, Fire Protection Impairment Program, Rev. 7
: ND.FP-ST.FS-0037, Fire Hose Service Test and EP Equipment Inspection, Rev. 1
: OP-SA-108-115-1001, Operability Assessment and Equipment Control Program, Rev. 2
: OP-AA-101-111-1004, Operations Standards, Rev. 2
: SC.FP-AP.ZZ-0003, Actions for Inoperable Fire Protection - Salem Station, Rev. 13
: SC.FP-SO.FP-0001, Fire Protection Water Suppression Systems Operation, Rev. 7
: SC.FP-ST.FS-0004, Fire Suppression Water System Flush, Rev. 2
: SC.FP-ST.FS-0006, Fire Pump Capacity Test, Rev. 9
: SC.FP-ST.FS-0007, Class 1 Fire Water Systems Valve Cycling, Rev. 4
: SC.FP-ST.FS-0008, Fire Main Flow Test, Rev. 1
: SC.FP-SV.FBR-0026, Flood and Fire Barrier Penetration Seal Inspection, Rev. 3 
: Attachment
: SC.MD-AB.ZZ-0001, Installation of Temporary 4kV Power Cables to CCW and RHR Motors,
: Rev. 4
: SC.MD-PM.ZZ-0010, Model 7700 and 8000 Line Motor Control Center Maintenance, Rev. 18
: SH.FP-EO.ZZ-0002, Fire Department Fire Response, Rev. 2
: SH.MD-GP.ZZ-0007, General Guideline for Fuse Inspection/Replacement, Rev. 2
: SH.MD-SP.FBR-0001, Installation and Repair of Penetration Seals, Rev. 1
: SH.MD-SP.FBR-0002, Damming and Ceramic Fiber Seal Installation, Rev. 0
: SH.MD-SP.FBR-0004, Installation and Repair of Silicone Nonfoaming Materials, Rev. 0
: S1.FP-PM.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Inspection & Preventive Maintenance, Rev. 11 S1.FP-PM.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Test, Rev. 14 S1.FP-ST.FS-0009, #1 Diesel Fire Pump Operability Test, Rev. 17
: S1.FP-ST.FS-0025, Triennial Fire Hose Service Test, Rev. 2 
: S1.FP-ST.FS-0116, Switchgear Rooms and Electrical Penetration Area Dry Sprinkler System Functional Test and Inspection, Rev. 0 S1.FP-ST.FBR-0028, Class 1 Fire Damper Operability Test, Rev 4 
: S1.FP-SV.FBR-0005, Fire Wrapped Cable, Conduit, and Cable Tray Inspection, Rev. 1
: S1.FP-SV.FBR-0027, Class 1 Fire Door Inspection and Operability Test, Rev. 4
: S1.FP-SV.FBR-0031, Class 1 Fire Damper Visual Inspection, Rev. 3
: S1.FP-SV.FS-0066, Relay Room Halon Cylinders Volume and Pressure Check, Rev. 7
: S1.OP-AB.CAV-0001, Loss of Unit 1 Control Area HVAC, Rev. 2 
: S1.OP-SO.HSD-0001, Fire Related Alternate Shutdown Equipment, Rev. 4
: S1.OP-ST.CVC-0006, Inservice Testing Chemical and Volume Control Valves Modes 1-6,
: Rev. 18
: S1.OP-ST.CVC-0007, Inservice Testing Chemical and Volume Control Valves Modes 5-6,
: Rev. 13 S1.
: OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 23 S1.OP-AB.Fire-0001, Control Room Fire Response, Rev. 3
: S1.OP-AB.Fire-0002, Fire Damage Mitigation, Rev. 4
: S1.OP-PT.HSD-0003, Alternate Shutdown and Appendix "R" Equipment Storage Cabinet Inventory, Rev 5 S2.FP-PM.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Inspection & Preventive Maintenance, Rev. 11 S2.FP-ST.FBR-0028, Class 1 Fire Damper Operability Test, Rev. 4 
: S2.FP-ST.FS-0025, Triennial Fire Hose Service Test, Rev. 2
: S2.FP-ST.FS-0048, Halon 1301 System Functional Test and Inspection, Rev. 3
: S2.FP-ST.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Test, Rev. 12 S2.FP-SV.FBR-0005, Fire Wrapped Cable, Conduit, and Cable Tray Inspection, Rev. 1
: S2.FP-SV.FS-0068, Relay Room Halon Cylinders Volume and Pressure Check, Rev. 6 
: S2.OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 26 S2.OP-AB.Fire-0001, Control Room Fire Response, Rev. 6
: S2.OP-AB.Fire-0002, Fire Damage Mitigation, Rev. 4 
: Attachment S2.OP-PT.HSD-0003, Alternate Shutdown and Appendix R Equipment Storage Cabinet Inventory, Rev. 9
: Completed Tests/Surveillances
: ND.FP-ST.FS-0037, Fire Hose Service Test and EP Equipment Inspection, Rev. 1, 7/19/08
: SC.FP-ST.FS-0004, Fire Suppression Water System Flush, Rev. 2, 11/15/07
: SC.FP-ST.FS-0006, Fire Pump Capacity Test, Rev. 9, 8/11/07
: SC.FP-ST.FS-0007, Class 1 Fire Water Systems Valve Cycling, Rev. 4, 5/29/08
: SH.MD-SP.FBR-0001, Installation and Repair of Penetration Seals, Rev. 1, 4/7/02
: SH.MD-SP.FBR-0002, Damming and Ceramic Fiber Seal Installation, Rev. 0, 4/7/02
: SH.MD-SP.FBR-0004, Installation and Repair of Silicone Nonfoaming Materials, Rev. 0, 4/7/02
: S1.FP-ST.FBR-0028, Class 1 Fire Damper Operability Test, Rev 4, 7/18/08
: S1.FP-ST.FS-0009, #1 Diesel Fire Pump Operability Test, Rev. 17, 12/18/08
: S1.FP-ST.FS-0025, Triennial Fire Hose Service Test, Rev. 2, 1/31/08
: S1.FP-SV.FBR-0005, Fire Wrapped Cable, Conduit, and Cable Tray Inspection, Rev. 1, 11/12/07
: S1.FP-SV.FBR-0031, Class 1 Fire Damper Visual Inspection, Rev. 3, 6/11/06
: S1.FP-SV.FBR-0031, Class 1 Fire Damper Visual Inspection, Rev. 3, 3/6/08
: S1.FP-PM.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Inspection & Preventive Maintenance, Rev. 11, 11/18/08 S1.FP-ST.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Test, Rev. 14, 12/14/08 S1.FP-SV.FS-0066, Relay Room Halon Cylinders Volume and Pressure Check, Rev. 7, 9/20/08
: S1.OP-PT.HSD-0001, Instrumentation - Remote Shutdown Panel, Rev. 7, 8/31/08
: S1.OP-PT.HSD-0002, Hot Shutdown Panel Functional Test, Rev. 8, 3/26/07 & 10/16/08
: S1.OP-PT.HSD-0003, Alternate Shutdown and Appendix "R" Equipment Storage Cabinet Inventory, Rev 5, 10/11/08 S1.OP-ST.HSD-0001, Instrumentation - Remote Shutdown Panel, Rev. 2, 12/20/08
: S2.FP-PM.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Inspection & Preventive Maintenance, Rev. 11, 8/8/08
: S2.FP-ST.FBR-0028, Class 1 Fire Damper Operability Test, Rev. 4, 12/24/08
: S2.FP-ST.FS-0025, Triennial Fire Hose Service Test, Rev. 1, 10/23/07 
: S2.FP-ST.FS-0048, Halon 1301 System Functional Test and Inspection, Rev. 3, 8/15/07
: S2.FP-ST.LTS-0039, Appendix R Self-Contained, Battery Powered Emergency Light Unit Test, Rev. 12, 12/12/08
: S2.FP-SV.FBR-0005, Fire Wrapped Cable, Conduit, and Cable Tray Inspection, Rev. 1, 1/17/08
: S2.FP-SV.FS-0068, Relay Room Halon Cylinders Volume and Pressure Check, Rev. 6, 12/18/08
: S2.OP-PT.HSD-0001, Instrumentation - Remote Shutdown Panel, Rev. 7, 7/6/08
: S2.OP-PT.HSD-0002, Hot Shutdown Panel Functional Test, Rev. 8, 3/11/08
: S2.OP-PT.HSD-0003, Alternate Shutdown and Appendix R Equipment Storage Cabinet Inventory, Rev. 9, 11/15/08
: S2.OP-ST.HSD-0001, Instrumentation - Remote Shutdown Panel, Rev. 3, 12/14/08 
: Attachment Quality Assurance (QA) Audits and Self Assessments
: NOS Audit
: NOSA-SLM-05-10 (2005-0082), Fire Protection Program Audit, September 2005
: NOSA-SLM-06-09, Order
: 80090020, Salem Fire Protection Program Audit Report, September
: 2006
: NOSA-SLM-08-07 Order
: 80096156, Salem Generating Station Fire Protection, September 2008 
===Drawings===
and Wiring Diagrams
: 203001 A 8789, Number 1 Unit - 4160V Group Buses One Line, Rev. 31
: 203002 A 8789, Number 1 Unit - 4160V Vital Buses One Line, Rev. 34
: 203003 A 8789, Number 1 Unit - 460V & 230V Vital & Non Vital Bus One Line Control, Rev. 45
: 203007 A 8789, Number 1 Unit - 125V DC One Line, Rev. 29
: 203061 A 8789, Number 2 Unit - 4160V Vital Buses One Line, Rev. 33
: 203063 A 8789, Number 2 Unit - 460V & 230V Vital & Non Vital Bus One Line Control, Rev. 36
: 205489 A 8768, Number 1 Unit - Penetration Area Trays Below EL. 100', Rev.41
: 205824 A 8774-20, Control & Electrical Penetration Area Fire Protection, Rev. 20
: 205839 A 8775, Number 1 Unit - Auxiliary Building Trays Below EL. 84', Rev.30
: 205840 A 8775, Number 1 Unit - Auxiliary Building Trays Below EL. 100', Rev.44
: 211365 B 9511, Number 1 Unit - Control Area 1B 115V AC Vital Instrument Bus, Rev. 29
: 211564 A 9772, Number 1 Unit - CVCS 1CV69 Charging Isolation Valves, Rev. 19
: 211566 B 583, Number 1 Unit - CVCS 1CV68 Charging Isolation Valves, Rev. 16
: 211586 B 9773, Number 1 & 2 Units - CVCS 1CV2 & 2CV2 RCS Letdown Line Isolation Valves, Rev.11
: 211587 B 9773, Number 1 & 2 Units - CVCS 1CV277 & 2CV277 RCS Letdown Line Isolation Valves, Rev. 7
: 211676 A 8863, Number 1 Unit - Auxiliary Building Instrument Panel Locations EL. 78' & 84', Rev.24
: 217149 A 8943, Number 1& 2 Units - Auxiliary Building Hot Shutdown Station - Panel 213, Rev.
: 217150 B 9557, Number 1 & 2 Units - Auxiliary Building Hot Shutdown Station - Panel 213, Rev.
: 219456 A 8933, Number 1 & 2 Units - Auxiliary Building EL. 84' Hot-Shutdown Station, Rev. 30
: 231428 B 9645-5, Sh. 1, No. 1 Unit Auxiliary Building Ventilation Switchgear Room & Penetration Area Dampers, Rev. 5
: 247756 B 9753, Number 1 Unit - Containment & Penetration Area EL. 100', Rev.1
: 248118 A 1751, Number 1 & 2 Units - Reactor Head Ventilation Valves, Rev.3
: 248116 B 9676, Number 1 & 2 Units - Reactor Head Ventilation Valves, Rev.6
: 601526 B 9451, Number 1 Unit - Auxiliary Building EL. 84', Rev.4
: 605502 A-00, No. 2 Unit Electrical Penetration Area El. 78, Rev. 0
: 605502 A-00, S2FBW-2EP78C-02, Sh. 1, No.2 Unit - Electrical Penetration Area El.78 Isometric, Rev. 0
: 605502 A-00, Sh. 3-8, No. 2 Unit Electrical Penetration Area El 78, Rev. 0
: 605819 A-0, No. 1 & 2 Unit Auxiliary Bldg. Boundary Locations Floor Plan El 64-0", Rev. 0
: 605820 A-0, No. 1 & 2 Unit Auxiliary Bldg. Boundary Locations Floor Plan El 78-0" & El. 84-0", Rev 0 
: Attachment
: 605821 A-0, No. 1 & 2 Unit Auxiliary Bldg. Boundary Locations Floor Plan El. 1000" & El. 110-10", Rev.0
: 606093 A-0, No. 1 Unit Fire Protection Miscellaneous Wiring, Rev. 0
: Firearea-78C, Unit 2 Fire Area 78 C Fire Barrier System Pictogram, Rev. 0
: M-03, Halon 1301 Cylinder Foundation & Weighing Rack Unit 1, Rev. D
: M-04, Halon 1301 Piping Unit 1, Rev. D
: M-05, Halon 1301 Piping Unit 2, Rev. D
: Piping and Instrumentation Diagrams
: 205201-SIMP-01, Sh.1-2, No. 1 Unit Reactor Coolant - Simplified PI&D, Rev. 1
: 205222 A 8760, Sh. 1, No. 1 & 2 Units Fire Protection, Rev. 60
: 205222 A 8760, Sh. 2-3, No. 1 & 2 Units Fire Protection, Rev. 59
: 205222 A 8760, Sh. 4, No. 1 & 2 Units Fire Protection, Rev. 57
: 205222 A 8760, Sh.7, No 1 & 2 Units Fire Protection, Rev. 5
: 205248 A 8761, Sh. 1, No. 1 Aux Bldg Control Area Air Conditioning & Ventilation, Rev. 35
: Vendor Manuals
: 3040608,
: NC.CC-AP.ZZ-0043, Viking Corporation Fire Protection, 10/31/06
: Pre-Fire Plans
: FRS-II-421, 4160 V Switchgear Rooms & Battery Rooms
: FRS-II-431, 460V Switchgear Rooms and Corridor
: FRS-II-441, Relay and Battery Rooms, and Corridor
: FRS-II-511, Electrical Penetration Area, Elevation Fire Drills and Critique
: Dated:
: 01/31/07
: 03/06/07 07/26/07 02/11/08 08/04/08 09/07/08 11/11/08 12/18/08 
: Operator Training Documents
: NTMCSAEOPSA, Assist with Implementating Salem EOP's and Salem AMG's Training,
: 12/16/2008 NOS05ABFIRE-02, Control Room Fire Response and Fire Damage Mitigation, 8/20/06
: NOS05ABCR02-03, Control Room Evacuation Due to Fire, Rev. 2 
===Miscellaneous Documents===
: Fire Protection Drain System El. 84 & 78 Master Diagram
: NFPA Chapter 6, Test Methods for Manufacturers Hose Certification
: NFPA Chapter 7, Sampling, Inspection, and Tests
: PSEG Supplier Requirements, Material Master:
: 1016451 
: Attachment S-1-FP-FEE-1984, Rev. 0, Fire Suppression System Performance Capability Evaluation - 1FA-AB-64A, 3/4/2008 S-1-FP-FEE-1985, Rev. 0, Fire Suppression System Performance Capability Evaluation - 1FA-EP-78C, 3/4/2008 S-1-FP-FEE-1986, Rev. 0 Fire Suppression System Performance Capability Evaluation - 1FA-AB-84A, 3/4/2008 
===Notifications===
: 268709
: 268765
: 268811
: 270836
: 272048
: 272112
: 20315017
: 20316541
: 20335166
: 20336711
: 20345196
: 20353219
: 20354809
: 20362271
: 20378334
: 20378382
: 20378391
: 20378410
: 20378772
: 20378979
: 20386278
: 20386345
: 20388963
: 20388964
: 20388966
: 20388967
: 20388968
: 20388970
: 20394639
: 20394926
: 20394927
: 20394973
: 20395387
: 20396127
: 20397530
: 20397531
: 20397915
: 20398762
: 20398845
: 20398981
: 20398982
: 20398983
: 20398984
: 20398985
: 20398986
: 20399052
: 20399179
: 20399325
: 20399409
: 20399475
: 20399479
: 20399500
: 20399780
: 20399794
: 20399891
: 20400373
: 20400808
: 20401253
: 20401330
: 20401333
: 20401469
: 20401474
: 20401484
: 20402904
===Condition Reports===
: 70053366
: 70053794
: 70054167
: 70060947
: 70061473
: 70062041
: 70068117
: 70073828
: 70077852
: 70079337
: 70083120
: 70089875
: 70089930
: 70092905
: 70093992
: 70094126
===Work Orders===
: 30043626
: 30070896
: 30075164
: 30080843
: 30090761
: 30108656
: 30111884
: 30118164
: 30130043
: 30134048
: 30134095
: 30134839
: 30136041
: 30136961
: 30137928
: 30137990
: 30137991
: 30138333
: 30138499
: 30139330
: 30139331
: 30140303
: 30140691
: 30141821
: 30143759
: 30144189
: 30145194
: 30145244
: 30145888
: 30146552
: 30147366
: 30147780
: 30148388
: 30150605
: 30150761
: 30152268
: 30154288
: 30156086
: 30160579
: 30162329
: 30162972
: 30163526
: 30164226
: 30165998
: 30167782
: 30167865
: 30172746
: 30172862 
: Attachment
: 30173280
: 30173781
: 60023148
: 60040631
: 60066104
: 60067092
: 60067560
: 60068388
: 60068403
: 60071610
: 60073510
: 60073511
: 60074122
: 60074922
: 60078942
==LIST OF ACRONYMS==
: [[AC]] [[Alternating Current]]
: [[ADAMS]] [[Agency Documents Access and Management System]]
: [[CFR]] [[Code of Federal Regulation]]
: [[DRS]] [[Division of Reactor Safety]]
: [[DRP]] [[Division of Reactor Projects]]
: [[FHA]] [[Fire Hazards Analysis]]
: [[FPP]] [[Fire Protection Program]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[IP]] [[Inspection Procedure]]
: [[IR]] [[Inspection Report]]
: [[NCV]] [[Non-cited Violation]]
: [[NFPA]] [[National Fire Protection Association]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[PSEG]] [[]]
: [[PSEG]] [[Nuclear]]
: [[LLC]] [[]]
: [[SDP]] [[Significance Determination Process]]
SER  Safety Evaluation Report
: [[UFSAR]] [[Updated Final Safety Analysis Report]]
}}
}}

Latest revision as of 12:40, 14 January 2025

IR 05000272-09-006; 05000311-09-006; on 01/26/2009 - 02/13/2009; PSEG Nuclear LLC; Salem Nuclear Generating Station, Unit Nos. 1 and 2; Triennial Fire Protection Team Inspection; Fire Protection
ML090850464
Person / Time
Site: Salem  PSEG icon.png
Issue date: 03/24/2009
From: Rogge J
Engineering Region 1 Branch 3
To: Joyce T
Public Service Enterprise Group
References
IR-09-006
Download: ML090850464 (25)
v • d • e


Text

March 24, 2009

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000272/2009006 and 05000311/2009006

Dear Mr. Joyce:

On February 13, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Salem Nuclear Generating Station, Unit Nos. 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on February 13, 2009, with Mr. Braun and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the NRC identified one finding of very low safety significance (Green) that was a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with copies to the Regional Administrator Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and the NRC Resident Inspector at the Salem Nuclear Generating Station.

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 component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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

Docket Nos. 50-272; 50-311 License Nos. DPR-70; DPR-75

Enclosure: Inspection Report No. 05000272/2009006 and 05000311/2009006

w/Attachment: Supplemental Information

SUMMARY OF FINDINGS

IR 05000272/2009006; 05000311/2009006; 01/26/2009 - 02/13/2009; Salem Nuclear Generating

Station, Unit Nos. 1 and 2; Triennial Fire Protection Team Inspection; Fire Protection.

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

One Green NCV was identified. 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, Rev. 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The team identified that PSEG failed to evaluate a single spurious operation of a safety injection signal during a main control room fire and its impact on the ability to achieve and maintain hot standby conditions. This finding was determined to be of very low safety significance (Green) and a NCV of the Salem Nuclear Generating Station, Unit Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C.(10) respectively, Fire Protection.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, PSEG did not ensure that post-fire operator manual actions subsequent to a single spurious operation of the safety injection signal during a main control room fire could be performed within sufficient time to achieve and maintain hot standby conditions. The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP). This finding affected the completeness of the post-fire safe shutdown analysis. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because a technical evaluation of pressurizer level response to a spurious safety injection signal from a main control room fire concluded that pressurizer level would remain in the indicating range. The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because PSEG identified the issue on February 15, 2006 but never thoroughly evaluated the issue and its potential impact on the ability to achieve and maintain post-fire hot standby conditions.

(P.1(c)) (Section 4OA2.01)

Licensee-Identified Violations

None.

REPORT DETAILS

Background

This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection. The objective of the inspection was to assess whether PSEG Nuclear LLC (PSEG) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem). The following fire areas and fire zones were selected for detailed review based on risk insights from the Salem Individual Plant Examination of External Events:

  • 1(2)FA-AB-100A
  • 1(2)FA-AB-64A
  • 1(2)FA-AB-84A
  • 1(2)FA-EP-78C

The inspection team evaluated PSEGs fire protection program (FPP) against applicable requirements which included plant technical specifications, OP-SA-108-115-1001, Operability Assessment and Equipment Control Program, Rev. 2, Operating License condition 2.C.5 and 2.C.10 for Unit Nos. 1 and 2 respectively, 10 CFR 50.48, and 10 CFR 50 Appendix R. The team also reviewed related documents that included NRC safety evaluation reports, Section 9.5.1 of the Updated Final Safety Analysis Report (UFSAR), the fire hazards analysis (FHA), and the post-fire safe shutdown analysis.

Specific documents reviewed by the team are listed in the attachment.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

==1R05 Fire Protection (IP 71111.05T)

==

.01 Post-Fire Safe Shutdown From Outside Main Control Room (Alternative Shutdown) and

Normal Shutdown

a. Inspection Scope

Methodology

The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentations drawings, electrical drawings, the UFSAR and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the control room for fires that rely on shutdown from outside the control room.

This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the FHA. These inspection activities focused on ensuring the adequacy of systems selected for reactivity control, reactor coolant makeup, reactor decay heat removal, process monitoring instrumentation, and support systems functions. The team verified that the systems and components credited for use during this shutdown method would remain free from fire damage. The team verified that the transfer of control from the control room to the alternative shutdown locations would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).

Similarly, for fire areas that utilize shutdown from the control room, the team also verified that the shutdown methodology properly identified the components and systems necessary to achieve and maintain safe shutdown conditions.

Operational Implementation

The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for 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. Time critical actions, which were verified included restoration of alternating current (AC) electrical power, establishing the remote shutdown panel, establishing reactor coolant makeup, and establishing decay heat removal.

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

  • S1(2).OP-AB.Fire-0001, Control Room Fire Response, Rev. 3(6)
  • S1(2). OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 23(26)

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 were adequate to ensure the functionality of the alternative shutdown capability.

b. Findings

No findings of significance were identified.

.02 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 separation requirements of Section III.G of 10 CFR 50, Appendix R 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 PSEGs 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 protective features were being properly maintained and administrative controls were being implemented.

b. Findings

No findings of significance were identified.

.03 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire doors and fire dampers), and electrical raceway fire barriers to ensure they were appropriate for the fire hazards in the area.

The team reviewed 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. The team also reviewed similar records for the fire protection wraps to ensure the material was of an appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings of significance were identified.

.04 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection and suppression systems in the selected plant fire areas. This included verification that the manual and automatic detection and suppression systems were installed, tested, and maintained in accordance with the National Fire Protection Association (NFPA) code of record or as NRC approved exemptions, and that each suppression system would control and/or extinguish fires associated with the hazards in the selected areas. A review of the design capability of the suppression agent delivery systems was verified to meet the code requirements for the hazards involved. The team also performed a walkdown of accessible portions of the detection and suppression systems in the selected areas as well as a walkdown of major system support equipment in other areas (e.g. fire pumps, storage tanks and supply system) to assess the material condition of the systems and components.

The team reviewed electric and diesel fire pump flow and pressure tests to ensure that the pumps were meeting their design requirements. The team also reviewed the fire main loop flow tests to ensure that the flow distribution circuits were able to meet the design requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed 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.

In addition, the team inspected the fire brigade equipment (including smoke removal equipment) to determine operational readiness for fire fighting.

b. Findings

No findings of significance were identified.

.05 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:

  • A fire in one of the selected fire areas would not directly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains;
  • A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not directly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and,
  • Adequate drainage is provided in areas protected by water suppression systems.

b. Findings

No findings of significance were identified.

.06 Alternative Shutdown Capability

a. Inspection Scope

Alternative shutdown capability for some of the areas selected for inspection utilizes shutdown from outside the control room and is discussed in section 1R05.01 of this report.

b. Findings

No findings of significance were identified.

.07 Circuit Analysis

a. Inspection Scope

The team verified that PSEG 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 PSEGs analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.

The teams review considered fire and cable attributes, potential undesirable consequences and common power supply/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 routing for a sample of components required for post-fire safe shutdown to verify that cable routing was consistent with the assumptions and conclusions of the safe shutdown analyses.

Cable failure modes were reviewed for the following components:

  • 1CV68 & 1CV69, Charging Isolation Valves;
  • 1CV2 & 1CV277, Normal Letdown Inboard and Outboard Isolation Valves;
  • 1RC41 & 1RC42, Reactor Head Vent Valves;
  • 2PT1648, Pressurizer Pressure Instrument.

The team reviewed circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination. The team confirmed that coordination studies had addressed multiple faults due to fire. Additionally, the team reviewed a sample of circuit breaker maintenance records to verify that circuit breakers for components required for post-fire safe shutdown were properly maintained in accordance with procedural requirements.

b. Findings

No findings of significance were identified.

.08 Communications

a. Inspection Scope

The team reviewed safe shutdown procedures, the FHA, 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 sound powered phone system cables, repeaters, and transmitters would not be affected by a fire.

b. Findings

No findings of significance were identified.

.09 Emergency Lighting

a. Inspection Scope

The team observed the placement and coverage area of 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 and/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, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained in a manner that would ensure reliable operation.

b. Findings

No findings of significance were identified.

.10 Cold Shutdown Repairs

a. Inspection Scope

The team verified that PSEG 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 of significance were identified.

.11 Compensatory Measures

a. Inspection Scope

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

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

[OA]

4OA2 Identification and Resolution of Problems

.01 Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team verified that PSEG was identifying fire protection and post-fire safe shutdown issues at an appropriate threshold and entering them into the corrective action program.

The team also reviewed a sample of selected issues to verify that PSEG had taken or planned appropriate corrective actions.

b. Findings

Introduction.

The team identified that PSEG failed to evaluate a single spurious operation of a safety injection signal during a main control room fire and its impact on the ability to achieve and maintain hot standby conditions. This finding was determined to be of very low safety significance (Green) and a NCV of the Salem Nuclear Generating Station, Unit Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C.(10) respectively, Fire Protection.

Description.

During a post-fire circuit failure self assessment of Salem Appendix R safe shutdown program, PSEG documented on February 15, 2006 in notification 2027112 that several spurious operation questions involved additional research and reviews. The notification documented that DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1, section 7.10 states that circuit analysis will conservatively assume that a safety injection signal output to components is possible to cause spurious operation. Notification 2027112 specifically documented How has the analysis addressed the potential for spurious SI in general? as well as other potential single spurious operations of individual safety injection components.

PSEG initiated condition report 70054167 to evaluate the post-fire safety injection signal spurious operation as well as the other issues in notification 2027112. The potential for a single spurious operation causing a complete safety injection signal and the subsequent impact on the ability to achieve and maintain hot standby conditions was not evaluated by PSEG. PSEG extended the evaluation due date several times: July 19, 2007, January 25, 2008, and finally September 25, 2008. The inspectors also noted that each new deadline was established after the due date had already past.

On January 9, 2009 PSEG performed a timeline study of S2.OP-AB.CR-0002, Control Room Evacuation Due to Fire in the Control Room, Relay Room, 460/230V Switchgear Room, or 4kV Switchgear Room, Rev. 26 and walked down with operators all operator manual actions for a control room fire scenario. The team reviewed the collected timeline data and noted that the operator manual actions to completely terminate high-head injection, such as would be necessary during a spurious safety injection signal, would not occur until about 28 minutes after the reactor trip. The team questioned whether pressurizer level would remain in the indicating range during such a scenario. PSEG subsequently performed a technical evaluation that addressed the teams question. The technical evaluation was documented in condition report 70094126. The evaluation included conservative assumptions and concluded that pressurizer level would remain in the indicating range. When compared to the operator manual action timeline study of January 9, 2009, about one minute of margin existed before pressurizer level would exceed the reliable indication range. PSEG also documented this issue in corrective action notification 20402904. The team concluded that failing to ensure that a single spurious operation of a safety injection signal would not adversely impact post-fire safe shutdown operations consistent with DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1 is a performance deficiency.

Analysis.

The team determined that this finding was more than minor because it was associated with the external factors attribute (fire) of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, PSEG did not ensure that post-fire operator manual actions subsequent to a single spurious operation of the safety injection signal during a main control room fire could be performed within sufficient time to achieve and maintain hot standby conditions.

The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP). This finding affected the completeness of the post-fire safe shutdown analysis. This finding screened to very low safety significance (Green) in phase 1 of the SDP because it was assigned a low degradation rating. A low degradation rating was assigned because a technical evaluation of pressurizer level response to a spurious safety injection signal from a main control room fire concluded that pressurizer level would remain in the indicating range.

The team determined that this finding had a cross cutting aspect in the area of problem identification and resolution because PSEG identified the issue on February 15, 2006 but never thoroughly evaluated the issue and its potential impact on the ability to achieve and maintain post-fire hot standby conditions. (P.1(c))

Enforcement.

Salem Nuclear Generating Station, Units Nos. 1 and 2 Operating License conditions 2.C.(5) and 2.C(10) respectively, requires that PSEG Nuclear LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). UFSAR section 9.5.1.1.5 assures that corrective action measures are established to ensure that conditions adverse to fire protection such as non-conformances are promptly identified, reported, and corrected. Contrary to the above, from February 15, 2006, to February 13, 2009, PSEG did not promptly correct a non-conformance in its safe shutdown analysis in that a spurious operation of the safety injection signal was not conservatively assumed to occur consistent with fire protection program document, DE-PS.ZZ-0001-A4, Salem Fire Protection Report - Shutdown Cables, Rev. 1. Because this finding was of very low safety significance (Green) and has been entered into PSEGs corrective action program (Notification 20402904), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. NCV 05000272&311/2009006-01, Failure to Evaluate Spurious Operation of SI Signal.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented their preliminary inspection results to Mr. R. Braun, Site Vice President, and other members of the site staff at an exit meeting on February 13, 2009.

No proprietary information was included in this inspection report.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Adair

Fire Protection Program Manager

R. Braun

Site Vice President

J. Carlin

Fire Department Superintendent

R. Chambers

Fire Marshall

K. Colville

Inspection Support Manager

E. Eilola

Engineering Director

J. Konovalchick

Senior Reactor Operator

K. Mathur

Design Engineer

L. Rajkowski

Design Engineering Manager

S. Savar

Safe Shutdown Engineer

B. Thomas

Senior Licensing Engineer

K. Wolf

System Engineer

NRC

J. Rogge

Chief, Engineering Branch 3, Division of Reactor Safety

C. Cahill

Senior Reactor Analyst, Division of Reactor Safety

D. Schroeder

Senior Resident Inspector, Salem Nuclear Generating Station

H. Balian

Resident Inspector, Salem Nuclear Generating Station

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000272&311/2009006-01 NCV

Failure to Evaluate Spurious Operation of SI Signal

Closed

None

Discussed

None

LIST OF DOCUMENTS REVIEWED

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000272/2009006&oldid=5318372"