IR 05000255/2010008

IR 05000255-10-008(DRS), on 08/5/2010 – 09/3/2010, Palisades Nuclear Power Plant, Routine Triennial Fire Protection Baseline Inspection

ML102650530
Person / Time
Site:	Palisades
Issue date:	09/20/2010
From:	Robert Daley Engineering Branch 3
To:	Schwarz C Entergy Nuclear Operations
References
IR-10-008
Download: ML102650530 (19)

Text

September 20, 2010

SUBJECT:

PALISADES NUCLEAR PLANT NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REPORT 05000255/2010-008(DRS)

Dear Mr. Schwarz:

On September 3, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Palisades Nuclear Plant. The enclosed inspection report documents the inspection results, which were discussed on September 3, 2010, with members of your staff.

As a result of your intent to adopt the National Fire Protection Association Standard (NFPA) 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as defined by Title 10, Code of Federal Regulations (CFR),

Part 50, Section 48(c), the inspection was conducted in accordance with Inspection Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial), issued December 24, 2009, and effective January 1, 2010. 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, no findings were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No.:

50-255 License No.: DPR-20

Enclosure:

Inspection Report 05000255/2010008(DRS)

w/Attachment: Supplemental Information

REGION III==

Docket No:

50-255 License No:

DPR-20 Report No:

05000255/2010-008(DRS)

Licensee:

Entergy Nuclear Operations, Inc.

Facility:

Palisades Nuclear Plant Location:

Covert, MI Dates:

August 5 through September 3, 2010 Inspectors:

B. Jose, Senior Reactor Inspector, Lead

Z. Falevits, Senior Reactor Inspector

L. Kozak, Senior Reactor Analyst

R. Winter, Reactor Inspector Approved by:

R. C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000255/2010008(DRS); 08/5/2010 - 09/3/2010; Palisades Nuclear Power

Plant; Routine Triennial Fire Protection Baseline Inspection.

This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. Based on the results of this inspection, no NRC-identified findings were discovered that involved violations of NRC requirements. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings No violations of significance were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events and Mitigating Systems

1R05 Fire Protection (71111.05TTP)

The purpose of the fire protection triennial baseline inspection was to conduct a design-based, plant specific, risk-informed, onsite inspection of the licensees fire protection programs defense-in-depth elements used to mitigate the consequences of a fire. The fire protection program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:

• preventing fires from starting;

• rapidly detecting, controlling and extinguishing fires that do occur;

• providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant; and

• taking reasonable actions to mitigate postulated events that could potentially cause loss of large areas of power reactor facilities due to explosions or fires.

The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants fire protection program, post-fire safe shutdown systems and B.5.b mitigating strategies. The objectives of the inspection were to assess whether the licensee had implemented a fire protection program that:

(1) provided adequate controls for combustibles and ignition sources inside the plant;

(2) provided adequate fire detection and suppression capability;

(3) maintained passive fire protection features in good material condition;

(4) established adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features; (5)ensured that procedures, equipment, fire barriers and systems exist so that the post-fire capability to safely shut down the plant was ensured;

(6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and

(7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensees problem identification and resolution program.

In addition, the inspectors review and assessment focused on the licensees post-fire safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was placed on determining that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspectors review and assessment also focused on the licensees B.5.b related license conditions and the requirements of 10 CFR 50.54 (hh)(2). Inspector emphasis was to ensure that the licensee could establish command and control, maintain, or restore core cooling capabilities utilizing the B.5.b mitigating strategies following a loss of large areas of the power reactor facility due to explosions or fires. Documents reviewed are listed in the Attachment to this report.

The fire areas and/or fire zones and B.5.b mitigating strategies selected for review during this inspection are listed below and in Section 1R05.11. The fire areas and/or fire zones and B.5.b mitigating strategies selected constitute 5 inspection samples and 1 inspection sample, respectively, as defined in IP 71111.05TTP.

Fire Area Description 1-C Switchgear Room 1-2 Diesel Generator Room Engineered Safeguards Panel Room Electrical Equipment Room

.1 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The inspectors reviewed the functional requirements identified by the licensee as necessary for achieving and maintaining hot shutdown conditions to ensure that at least one post-fire safe shutdown success path was available in the event of fire in each of the selected fire areas and for alternative shutdown in the case of control room evacuation.

In addition, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The updated final safety analysis report and the licensees engineering and/or licensing justifications (e.g., NRC guidance documents, License Amendments, Technical Specifications, Safety Evaluation Reports, Exemptions, and Deviations) were also reviewed to determine the licensing basis.

The inspectors reviewed the licensee procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis.

The inspectors performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented.

The inspectors examined the operators ability to perform the necessary manual actions for achieving safe shutdown by reviewing post-fire shutdown procedures, the accessibility of safe shutdown equipment, the available time for performing the manual actions and whether manual actions had been verified and validated by plant walkdowns. In addition, the inspectors evaluated manual actions not supported by an NRC approved exemption or deviation using the guidance provided in Attachment 2 of IP 71111.05TTP.

The inspectors also reviewed the licensees design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post-fire safe shutdown analysis and procedures.

b. Findings

No findings of significance were identified.

.2 Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details. In addition, the inspectors reviewed license documentation, such as NRC Safety Evaluation Reports, and deviations from NRC regulations and NFPA standards to verify that fire protection features met license commitments.

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

The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design.

b. Findings

No findings of significance were identified.

.3 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed licensing basis documentation, such as, NRC Safety Evaluation Reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.

b. Findings

No findings of significance were identified.

.4 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions such as the adequacy and condition of floor drains, equipment elevations, and spray protection.

b. Findings

No findings of significance were identified.

.5 Alternative Shutdown Capability

a. Inspection Scope

The inspectors reviewed the licensees systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.

The team conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.

b. Findings

No findings of significance were identified.

.6 Circuit Analyses

a. Inspection Scope

In accordance with IP 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial), issued December 24, 2009, and effective January 1, 2010, this segment of the IP was suspended for facilities in NFPA 805 transition.

b. Findings

No findings of significance were identified.

.7 Communications

a. Inspection Scope

The inspectors reviewed, on a sample basis, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order.

b. Findings

No findings of significance were identified.

.8 Emergency Lighting

a. Inspection Scope

The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas.

b. Findings

No findings of significance were identified.

.9 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the licensees procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available onsite. The inspectors also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available onsite and properly staged.

b. Findings

No findings of significance were identified.

.10 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions or capabilities). The inspectors also conducted a review of the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions could be taken.

b. Findings

No findings of significance were identified.

.11 B.5.b Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees preparedness to handle large fires or explosions by reviewing one or more mitigating strategies as identified below. This review ensured that the licensee continued to meet the requirements of their B.5.b related license conditions and 10 CFR 50.54(hh)(2) by determining that:

• Procedures were being maintained and adequate.

• Equipment was properly staged, maintained, and tested.

• Station personnel were knowledgeable and could implement the procedures.

• Additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b related equipment.

The inspectors reviewed the licensees B.5.b related license conditions and evaluated selected mitigating strategies to ensure they remain feasible in light of operator training, maintenance/testing of necessary equipment and any plant modifications. In addition, the inspectors reviewed previous inspection reports for commitments made by the licensee to correct deficiencies identified during performance of Temporary Instruction (TI) 2515/171 or subsequent performances of these inspections.

The B.5.b mitigating strategies selected for review during this inspection are listed below. The off-site and on-site communications, notifications Emergency Response Organization (ERO) activation, initial operational response actions, and damage assessment activities identified in Table A.3-1 are evaluated each time due to the mitigation strategies scenario selected.

NEI 06-12, Revision 2, Section Licensee Strategy (Table)

Selected for Review 3.2.2 On-Site and Off-Site Communications (Table A.3-1)

Evaluated 3.2.3 Notifications/ERO Activation (Table A.3-1)

Evaluated 3.2.4 Initial Operational Response Actions (Table A.3-1)

Evaluated 3.2.5 Initial Damage Assessment (Table A.3-1)

Evaluated 3.3.7 PWR Enhancement Strategy No.7 - Portable Sprays (Table A.4-7) Evaluated

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

The inspectors reviewed the licensees corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the fire protection program at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, and fire protection system non-conformance documents.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On September 3, 2010, the inspectors presented the inspection results to Mr. M. Sicard and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D.Hamilton, Nuclear Safety Assurance Director

G. Sleeper, Assistant Operations Manager

M. Sicard, Operations Manager

J. Miksa, Programs Engineering Manager

P. Anderson, Licensing Manager

D. Campbell, Fire Marshall

A. Verzwyvelt, System Engineer

G. Schrader, Programs Supervisor

S. Mongeau, PRA Engineer

M. Knapp, System Engineer

T. Swiecicki, Appendix R Engineer

J. Kneeland, Fire Protection Engineer

B. Dotson, Licensing Technical Specialist III

Nuclear Regulatory Commission

R. Daley, Division of Reactor Safety, Engineering Branch 3

J. Ellegood, Senior Resident Inspector

T. Taylor, Resident Inspector

LIST OF ITEMS

Opened, Closed, and Discussed

None