IR 05000220/2015007
| ML15211A313 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/29/2015 |
| From: | Rogge J Engineering Region 1 Branch 3 |
| To: | Orphanos P Exelon Generation Co |
| Rogge J | |
| References | |
| IR 2015007 | |
| Download: ML15211A313 (31) | |
Text
SUBJECT:
NINE MILE POINT NUCLEAR STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000220/2015007 AND 05000410/2015007
Dear Mr. Orphanos:
On July 9, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at Nine Mile Point Nuclear Station (NMPNS). The enclosed inspection report documents the inspection results, which were discussed on July 9, 2015, with yourself and other members of your staff.
The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
No NRC identified or self-revealing findings were identified.
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS).
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.
50-220 and 50-410 License Nos. DPR-63 and NPF-69
July 29, 2015
Enclosure:
Inspection Report 05000220/2015007 and 05000410/2015007 w/Attachment:
Supplemental Information
REGION I==
Docket Nos.
50-220 and 50-410
License Nos.
Report Nos.
05000220/2015007 and 05000410/2015007
Licensee:
Exelon Generation Company, LLC
Facility:
Nine Mile Point Nuclear Station
Location:
348 Lake Road, Oswego, NY 13126
Dates:
June 22 - 26 and July 6 - 9, 2015
Inspectors:
R. Fuhrmeister, Senior Reactor Inspector (Team Leader)
W. Schmidt, Senior Reactor Analyst
F. Arner, Senior Reactor Inspector
J. Rady, Reactor Inspector
T. OHara, Reactor Inspector J. Patel, Reactor Inspector S. Galbreath, Reactor Inspector L. Dumont, Reactor Inspector H. Barrett, Sr., Fire Protection Engineer, Office of Nuclear Reactor Regulation
Approved by:
John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety
ii
SUMMARY
IR 05000220/2015007 and 05000410/2015007; 06/22/2015 - 06/26/2015 and 07/06/2015 -
07/09/2015; Exelon Generation Company, LLC; Nine Mile Point Nuclear Station; Triennial Fire Protection Baseline Inspection.
The report covered a two-week triennial fire protection team inspection by specialist inspectors.
No NRC or self-revealing findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process. Cross-cutting aspects associated with findings are determined using IMC 0310, "Components Within The Cross-Cutting Areas." Findings for which the significance determination process (SDP) does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,
Reactor Oversight Process, Revision 5.
Cornerstone: Initiating Events and Mitigating Systems
No findings were identified.
Other Findings
Two violations of very low safety significance that were identified by Exelon were reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
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, and 71111.05XT, Fire Protection - NFPA 805. The objective of the inspection was to assess whether Exelon Generation Company, LLC (Exelon) has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained at the NMPNS facility. The following fire zones (FZs) were selected for detailed review based on risk insights from the NMPNS Unit 2 Individual Plant Examination of External Events (IPEEE) and the NMPNS Unit 1 Fire Probabilistic Risk Assessment (PRA).
Unit 1
Unit 2 R1D CS Pump Room 198
333XL Div I Standby Switchgear Room R4C EC Isolation Valve Room 281
357XL PGCC Computer Room T2D Turbine Bldg Gen Area E 250
213SW S Reactor Bldg 175 S1 Screenhouse 225 - 256
602XL E Normal Switchgear Room
Inspection of these areas/zones fulfills the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated Exelons fire protection program (FPP) against applicable requirements which included Operating License Condition 2.D
- (7) for Unit 1, Operating License Condition 2.F for Unit 2, NRC Safety Evaluations, 10 CFR 50.48, Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1, and NFPA 805. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR),Section X.K for Unit 1 and Section 9.5.1 for Unit 2, the fire hazards analysis (FHA) for Unit 2, the post-fire safe shutdown analysis for Unit 2, and the Nuclear Safety Capability Assessment for Unit 1.
The team also evaluated two mitigating strategies (one each for Unit 1 and Unit 2) for addressing large fires and explosions as required by Operating License Condition 2.D
- (13) for Unit 1, Operating License Condition 2.C(17) for Unit 2, and 10 CFR 50.54 (hh)(2). Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample.
Specific documents reviewed by the team are listed in the attachment.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
==1R05 Fire Protection (IP 71111.05T)
==
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
Unit 1
The team reviewed NMP Unit 1 Nuclear Safety Capability Assessment (NSCA)documents to verify that the shutdown methodology properly identified the components and systems necessary to achieve safe and stable plant conditions for a fire under any plant operational mode or configuration. For each of the selected fire areas, the team reviewed NSCA fault tree logic model for the development of the safe shutdown (SSD)success path, equipment selection, and the Fire Risk Evaluation (FRE) report. This review included an assessment of the adequacy of the selected systems for reactivity control, inventory and pressure control, decay heat removal, process monitoring, and associated vital auxiliary support system functions.
Unit 2
The team reviewed the FHA, safe shutdown analyses and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The team ensured that applicable separation requirements of BTP 9.5-1 and Nine Miles design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control and instrumentation cables. This review included an assessment of the adequacy of the selected systems for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and associated support system functions.
b. Findings
No findings were identified.
.02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to evaluate whether the material conditions of the fire area boundaries were adequate for the fire hazards in the area. The team compared the fire area boundaries, including walls, ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway and conduit fire barriers, and redundant equipment fire barriers and radiant energy heat barriers to design and licensing basis requirements, industry standards, and the NMPNS FPP, as approved by the NRC, to identify any potential degradation or non-conformances.
The team reviewed selected engineering evaluations, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating.
The team also reviewed recent inspection and functional test records for fire dampers, and the inspection records for penetration seals and fire barriers, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified. In addition, the team reviewed recent test results for the carbon dioxide (CO2) and Halon fire damper functionality tests for the areas protected to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified.
b. Findings
No findings were identified.
.03 Active Fire Protection
a. Inspection Scope
The team evaluated manual and automatic fire suppression and detection systems in the selected fire areas to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements, National Fire Protection Association (NFPA) codes of record, and the NMPNS FPP, as approved by the NRC. The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas.
The team reviewed the as-built capability of the fire water supply system to verify the design and licensing basis and NFPA code of record requirements were satisfied, and to assess whether those capabilities were adequate for the hazards involved. The team reviewed the fire water system to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus concurrent fire hose usage. The team evaluated the fire pump performance tests to assess the adequacy of the test acceptance criteria for pump minimum discharge pressure at the required flow rate, to verify the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied. The team also evaluated the underground fire loop flow tests to verify the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed recent pump and loop flow test results to verify the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
The team reviewed initial discharge testing, design specifications, engineering evaluations, and routine functional testing for the carbon dioxide (CO2) and Halon suppression systems for the areas so protected. The team walked down accessible portions of the CO2 and Halon systems, including storage tanks and supply systems, to independently assess the material condition, operational lineup, and availability of the systems. The team also reviewed and walked down the associated fire fighting strategies and CO2 and Halon system operating procedures.
The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire pumps, interviewed system and program engineers, and reviewed selected condition reports (CRs) to independently assess the material condition of the systems and components. In addition, the team reviewed recent test results for the fire detection and suppression systems for the selected fire areas to verify the testing was adequately conducted, the acceptance criteria were met, and any performance degradation was identified.
The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed Exelon's fire fighting strategies (i.e., pre-fire plans) and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. The team independently inspected the fire brigade equipment, including personnel protective gear (e.g., turnout gear) and smoke removal equipment, to determine operational readiness for firefighting.
In addition, the team reviewed Exelon's fire brigade equipment inventory and inspection procedure and recent inspection and inventory results to verify adequate equipment was available, and any potential material deficiencies were identified.
b. Findings
No findings were identified.
.04 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The team performed document reviews and plant walkdowns to verify that redundant trains of systems required for hot shutdown, which are located in the same fire area, are not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team verified that:
A fire in one of the selected fire areas would not indirectly, through production of smoke, heat or hot gases, cause activation of suppression systems that could potentially damage all redundant safe shutdown trains;
A fire in one of the selected fire areas (or the inadvertent actuation or rupture of a fire suppression system) would not indirectly cause damage to all redundant trains (e.g. sprinkler caused flooding of other than the locally affected train); and,
Adequate drainage is provided in areas protected by water suppression systems.
b. Findings
No findings were identified.
.05 Post-Fire Safe Shutdown Capability - Normal and Alternative
a. Inspection Scope
Unit 1
The team verified that Exelon performed a NSCA for the selected fire areas, and the assessment appropriately identified the structures, systems, and components necessary to achieve safe and stable plant conditions. For each of the selected fire areas, the team reviewed the electrical schematics, flow diagrams, and the NSCA to identify any potential fire-induced cable damage that could directly affect the nuclear safety performance criteria. The team selected a sample of SSD components to verify that all appropriate cables had been selected and incorporated into the NSCA. The team then evaluated selected components to ensure all fire scenarios had been identified, and dispositioned for all mode of operations.
The team verified that Exelons analysis ensured that necessary electrical circuits were properly protected; and that circuits that could adversely impact nuclear safety performance criteria due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe and stable plant conditions. The review considered fire and cable attributes, cable routing, potential undesirable consequences, and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
Review of circuit analysis was performed for the following components:
- PSV-01-102A, Pressure Safety Valve - ADS Electromatic Relief Valve 111;
- PMP-81-21, Core Spray Pump 112;
- BKR-(102/2-1) R1022/571, Diesel Generator 102 Output Breaker to PB102; and,
- LI-36-28, Level Indicator - High/Low Reactor Vessel Level The team verified that the transfer of control from the control room to the primary control station 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).
Unit 2
The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&IDs), electrical drawings, the UFSAR and other supporting documents for the selected fire areas to verify that NMPNS had properly identified the systems and components necessary to achieve and maintain safe shutdown conditions.
The team assessed the adequacy of the selected systems and components for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included verification that alternative post-fire shutdown could be performed both with and without the availability of offsite power. Plant walkdowns were also performed to verify that the plant configuration was consistent with that described in the safe shutdown and fire hazards analyses. The team verified that the systems and components credited for use during shutdown would remain free from fire damage.
The team verified that the training program for licensed and non-licensed operators included alternative shutdown capability. The team also verified that personnel required for safe shutdown using the normal or alternative shutdown systems and procedures are trained and available onsite at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps to ensure the implementation and human factors adequacy of the procedures. The team also verified that the operators could be reasonably expected to perform specific actions within the time required to maintain plant parameters within specified limits.
Specific procedures reviewed for normal and alternative post-fire shutdown included the following:
N2-SOP-78, Control Room Evacuation, Revision 00704 N2-EOP-RPV, RPV Control, Revision 01400 N2-ARP-FPM, Fire Computer System Alarm Response Procedures, Revision 00900
The team reviewed manual actions to ensure that they had been properly reviewed and approved and that the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer capability and instrumentation and control functions to ensure the tests are adequate to ensure the functionality of the alternative shutdown capability.
b. Findings
No findings were identified.
.06 Circuit Analysis
a. Inspection Scope
Unit 1
The inspectors verified that Exelon performed a Nuclear Capability Safety Assessment (NCSA) for the selected fire areas, and that the assessment identified the structures, systems and components important for achieving safe and stable conditions. For each fire area, the inspectors reviewed electrical schematics, flow diagrams, and the NSCA to identify any potential fire-induced cable damage that could directly affect post-fire safe shutdown. The inspectors reviewed a sample of circuit diagrams to verify that all appropriate cables had been selected and incorporated into the NSCA. The inspectors then evaluated selected circuits to ensure all fire scenarios had been identified, and dispositioned for all modes of operation including shut down operations, and abnormal plant configurations.
The inspectors verified that the NSCA demonstrated that hot shorts, shorts to ground, or other failures that could result in a spurious actuation will not affect the capability to meet the performance criteria. The inspectors verified that Exelons assessment identified circuits that may impact the Nuclear Safety Performance Criteria. The assessment demonstrated that that hot shorts, shorts to ground or other failures that would not result in a spurious actuation will not affect the capability to meet the performance criteria. The inspectors reviewed the fire scenarios and cable attributes, potential undesirable consequences, and common power supply/bus concerns.
The inspectors also reviewed Exelons response to multiple spurious operations as identified by Nuclear Energy Institute document NEI 00-01, and the sites Expert Panel.
The review ensured that Exelon followed the approved guidance provided in NEI 00-01, evaluated all appropriate MSO scenarios, and properly addressed any discrepancies.
Unit 2
The team verified that Exelon 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 Exelons analysis ensured that necessary electrical circuits were properly protected and that circuits that could adversely impact safe shutdown due to hot shorts or shorts to ground were identified, evaluated, and dispositioned to ensure spurious actuations would not prevent safe shutdown.
The teams review considered fire and cable attributes, cable routing, potential undesirable consequences and common power supply/bus concerns. Specific items included the credibility of the fire threat, cable insulation attributes, cable failure modes, and actuations resulting in flow diversion or loss of coolant events.
The team also reviewed cable raceway drawings and/or cable routing databases for a sample of components required for post-fire safe shutdown to verify that cables were routed as described in the safe-shutdown analysis. The team also reviewed equipment important to safe shutdown, but not part of the success path, to verify that Exelon had taken appropriate actions in accordance with the design and licensing basis and NRC Regulatory Guide 1.189, Revision 2.
Circuit analysis was performed for the following components:
2CSH*MOV107 HPCS Discharge Valve 2CSH*MOV118 HPCS Suction Valve from Suppression Pool 2RHS* MOV40A(B)
RHR A & B Shutdown Cooling Return Valves 2RSS* LI101(112)
Reactor Vessel Wide Range Water Level Indicators
The team reviewed a sample of circuit breaker coordination studies to ensure equipment needed to conduct post-fire safe shutdown activities would not be impacted due to a lack of coordination that could result in a common power supply or common bus concern.
The team verified that the transfer of control from the control room to the alternative shutdown location(s) would not be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify an adequate method of communications would be available to plant operators following a fire. During this review the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns.
The team also inspected the designated emergency storage lockers to verify the availability of portable radios for the fire brigade and for plant operators. The team also verified that communications equipment such as repeaters and transmitters would not be affected by a fire.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The team observed the placement and coverage area of eight-hour emergency lights throughout the selected fire areas to evaluate their adequacy for illuminating access and egress pathways and any equipment requiring local operation or instrumentation monitoring for post-fire safe shutdown. The team also verified that the battery power supplies were rated for at least an eight-hour capacity. Preventive maintenance procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to verify that the emergency lighting was being maintained consistent with the manufacturers recommendations and in a manner that would ensure reliable operation.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
Unit 1
The inspectors determined that NMPNS Unit 1 does not credit cold shutdown repairs to meet the Nuclear Safety Performance Criteria. The inspectors reviewed the NSCA and determined that Nine Mile Unit 1 does not require transitioning to cold shutdown to achieve a safe and stable condition.
Unit 2
The inspectors determined that NMPNS Unit 2 does not credit cold shutdown repairs to achieve safe and stable shutdown conditions. The separation built into the plant during construction ensures the survival of one train of equipment necessary to achieve cold shutdown.
b. Findings
No findings were identified.
.10 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 NMPNS was effective in returning the equipment to service in a reasonable period of time.
b. Findings
No findings were identified.
.11 Fire Protection Program Changes
a. Inspection Scope
The team reviewed recent changes to the approved fire protection program to verify that the changes did not constitute an adverse effect on the ability to safely shutdown.
b. Findings
No findings were identified.
.12 Control of Transient Combustibles and Ignition Sources
a. Inspection Scope
The team reviewed Exelons procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were also reviewed. The team performed plant walkdowns to verify that transient combustibles and ignition sources were being implemented in accordance with the administrative controls.
b. Findings
No findings were identified.
.13 Large Fires and Explosions Mitigation Strategies
a. Inspection Scope
The team reviewed Exelons preparedness to handle large fires or explosions by reviewing a mitigating strategy for each Unit to verify that they continue to meet 10 CFR 50.54 (hh)(2) by determining that:
- Procedures are being maintained and adequate;
- Equipment is properly staged and is being maintained and tested; and,
- Station personnel are knowledgeable and can implement the procedures
b. Findings
No findings were identified.
.14 Radiological Release (Unit 1)
a. Inspection Scope
The inspectors verified that Exelon had provided reasonable assurance that a fire would not result in a radiological release that adversely affects the public, plant personnel, or the environment in accordance with NFPA 805, Section 1.3.2. The inspectors verified that Exelon had evaluated the potential for radioactive releases to any unrestricted areas resulting from fire suppression activities were as-low-as-reasonably-achievable. The inspectors verified that Exelon had analyzed radioactive release on a fire area basis in accordance with NFPA 805, Section 2.2.4. The inspectors walked down the selected fire zones, and verified that the pre-fire plan tactics and instructions were consistent with the potential radiological conditions identified in the fire hazards analysis.
b. Findings
No findings were identified.
.15 Monitoring Program (Unit 1)
a. Inspection Scope
The inspectors reviewed procedure ER-AA-610-1003, NFPA 805 Monitoring Program, and engineering evaluation FPEE1-14-001, NFPA 805 Monitoring Process - Scoping and Screening, to verify that a monitoring program was established to ensure that the availability and reliability of the fire protection systems and features credited in the performance based analyses are maintained and to assess the performance of the fire protection program in meeting the performance criteria in accordance with NFPA 805.
Exelon established performance monitoring groups that provide a link between components and functions that are monitored together. The items in scope were being monitored for performance based on the established criteria as part of the system health reports process. The inspectors also verified that the monitoring program initiated appropriate corrective actions to return availability, reliability and performance of systems that fall outside of established levels.
b. Findings
No findings 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 Exelon or NMPNS 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 NMPNS had taken or planned appropriate corrective actions.
b. Findings
No findings were identified.
4OA3 Followup of Events and Notices Of Enforcement Discretion
.01 (Closed) Licensee Event Report 50-220/2013-002:
Unanalyzed Condition Caused by Unfused Control Room DC Ammeters
On October 22, 2013, Exelon determined that unfused ammeter indication circuits associated with safety-related Direct Current busses could short circuit due to a fire in the circuit cable routing. This ground fault equivalent hot short could cause the cable to self-heat and lead to secondary fires. The unanalyzed secondary fires could adversely affect safe shutdown equipment and potentially cause the loss of the ability to safely shutdown the unit as required by Condition 2.D(7) of the Renewed Facility Operating License. The enforcement aspects of this issue are discussed in Section 4OA7. The inspectors did not identify any new issues during the review of this LER. This LER is closed.
.02 (Closed) Licensee Event Report 50-410/2013-003:
Unanalyzed Condition Caused by Unfused Control Room DC Ammeters
On October 22, 2013, Exelon determined that unfused ammeter indication associated with safety-related Direct Current busses could short circuit due to a fire in the circuit cable routing. This ground fault equivalent hot short could cause the cable to self-heat and lead to secondary fires. The unanalyzed fires could adversely affect safe shutdown equipment and potentially cause the loss of the ability to safely shutdown as required by Condition 2.F of the Renewed Facility Operating License. The enforcement aspects of this issue are discussed in Section 4OA7. The inspectors did not identify any new issues during the review of this LER. This LER is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The team presented their preliminary inspection results to Mr. P. Orphanos, Site Vice President, and other members of the site staff at an exit meeting on July 9, 2015. No proprietary information was included in this inspection report.
4OA7 Licensee Identified Violations
The following violations of very low safety significance (Green) were identified by Exelon and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violations.
In October 2013, Unit 1 License Condition 2.D7 required NMPNS to implement and maintain in effect all the provisions of the approved fire protection program. That program included the requirement to maintain one train of equipment necessary to achieve and maintain safe shutdown free of fire damage. Contrary to the requirements of License Condition 2.D7, Unit 1 was determined to have unfused safety-related DC ammeter circuits which could be faulted by a fire, and cause secondary fires. These secondary fires could potentially cause the loss of equipment necessary to achieve and maintain safe shutdown. Exelon entered this issue into the corrective action program as CR-2013-008747. The inspectors evaluated this issue using IMC 0609, Appendix F, Fire Protection Significance Determination Process. The inspectors determined the issue to be of very low safety significance (Green) because a walkdown of the circuit routing in the plant determined that there were no credible fire scenarios to cause the postulated damage.
Unit 2 License Condition 2.F requires NMPNS to implement and maintain in effect all the provisions of the approved fire protection program. That program includes the requirement to maintain one train of equipment necessary to achieve and maintain safe shutdown free of fire damage. Contrary to the requirements of License Condition 2.F, Unit 2 was determined to have unfused safety-related DC ammeter circuits which could be faulted by a fire, and cause secondary fires. These secondary fires could potentially cause the loss of equipment necessary to achieve and maintain safe shutdown.
Exelon entered this issue into the corrective action program as CR-2013-008749. The inspectors evaluated this issue using IMC 0609, Appendix F, Fire Protection Significance Determination Process.
The inspectors determined the issue to be of very low safety significance (Green)because a walkdown of the circuit routing in the plant determined that there were no credible fire scenarios to cause the postulated damage.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Saunderson, System Engineering Supervisor
- W. Sullivan, Fire Protection Engineer
- W. Jameson, PRA Engineer
- J. Rolince, NMP Fire Marshall
- D. Morley, Safe Shutdown Engineer
- M. Checola, Fire Protection System Manager
- C. Moorhead, Operations Shift Supervisor Unit 2
- G. Carter, Operations Shift Supervisor
- M. Restani, Plant Operator
- M. Dougherty, Operations Instructor
- D. VanNamee, Fire Marshal
- S. Savar, Safe-Shutdown Engineer
NRC
- J. Rogge, Chief, Engineering Branch 3, Division of Reactor Safety
- W. Schmidt, Senior Reactor Analyst, Division of Reactor Safety
- K. Kolaczyk, Senior Resident Inspector Nine Mile Point
- E. Miller, Resident Inspector, Nine Mile Point
- G. Stock, Resident Inspector, Nine Mile Point
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE
Opened and Closed
NONE
Closed
- 05000220/2013-002 LER Unanalyzed Condition Caused By Unfused Control Room DC Ammeters
- 05000410/2013-003 LER Unanalyzed Condition Caused by Unfused Control Room DC Ammeters
Discussed
NONE