IR 05000315/2009006
| ML093500625 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/15/2009 |
| From: | Robert Daley Engineering Branch 3 |
| To: | Jensen J Indiana Michigan Power Co, Nuclear Generation Group |
| References | |
| EA-09-313 IR-09-006 | |
| Download: ML093500625 (21) | |
Text
December 15, 2009
SUBJECT:
DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTION REPORT 05000315/2009006(DRS); 05000316/2009006(DRS)
AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Jensen:
On November 20, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your Donald C. Cook Nuclear Power Plant, Units 1 and 2.
The enclosed inspection report documents the inspection results, which were discussed on November 20, 2009, with Mr. Larry Webber and other 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), dated May 9, 2006. 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 NRC-identified and no self-revealed findings were discovered that involved violations of NRC requirements. However, a licensee-identified violation which was determined to be of very low safety-significance is listed in this report. The licensee-identified finding was not associated with a finding of high safety-significance (Red)
and met the four criteria established by Section A of the NRC's Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR Part 50.48) for a licensee in NFPA 805 transition, including being entered into your corrective action program.
The finding also met additional criteria established in Section 12.01.b of Inspection Manual Chapter (IMC) 0305. Therefore, we are exercising enforcement discretion to not cite this violation in accordance with the NRC's Enforcement Policy. If you disagree with the characterization of this finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Donald C.
Cook Nuclear Power Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74
Enclosure:
Inspection Report 05000315/2009006(DRS); 05000316/2009006(DRS)
w/Attachment: Supplemental Information
REGION III==
Docket Nos.
50-315; 50-316 License Nos.
05000315/2009006(DRS); 05000316/2009006(DRS)
Licensee:
Indiana Michigan Power Company Facility:
Donald C. Cook Nuclear Power Plant, Units 1 and 2 Location:
Bridgman, MI Dates:
November 2 through November 20, 2009 Inspectors:
G. Hausman, Senior Reactor Inspector, Lead
M. Munir, Reactor Inspector
B. Winter, Reactor Inspector Approved by:
R. Daley, Chief Engineering Branch 3 Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000315/2009006(DRS); 05000316/2009006(DRS); 11/02/2009 - 11/20/2009; Donald C.
Cook Nuclear Power Plant, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors. Based on the results of this inspection, no NRC-identified and no self-revealed findings of safety-significance 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 (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 Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity No findings and/or violations of safety-significance were identified.
Licensee-Identified Violations
A violation of very low safety-significance that was identified by the licensee has been reviewed by inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R05 Fire Protection (71111.05TTP)
Indiana Michigan Power Company, the licensee, in a letter (ML060090370) to the U. S.
Nuclear Regulatory Commission (NRC) dated December 28, 2005, committed 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 10 CFR 50.48(c) for the Donald C. Cook Nuclear Power Plant.
The NFPA 805 standard established a comprehensive set of requirements for fire protection programs at nuclear power plants. The standard incorporated both deterministic and risk-informed, performance-based concepts. The deterministic aspects of the standard are comparable to traditional requirements. However, the transition to a risk-informed, performance-based fire protection program requires an in-depth nuclear safety circuit analysis for equipment identified for nuclear safety functions such as safe-shutdown. Because the conversion and licensing process to NFPA 805 was expected to identify and address a variety of issues that were normally the subject of the triennial fire protection baseline inspection, the NRC modified the fire protection inspection program and Enforcement Policy for licensees in transition to NFPA 805. As a result, this inspection was conducted in accordance with Inspection Procedure (IP) 71111.05TTP, Fire Protection - NFPA 805 transition Period (Triennial),dated May 9, 2006. Associated with the transition to NFPA 805, when a certain finding not associated with a finding of high safety-significance meets the four criteria established by Section A of the NRC's Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), the violation would receive enforcement discretion in accordance with the NRC's Enforcement Policy.
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; and
- 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.
The inspectors evaluation focused on the design, operational status, and material condition of the reactor plants fire protection program and post-fire safe-shutdown systems. 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 inspection was performed in accordance with the NRCs regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The inspectors, with assistance from a Senior Reactor Analyst (SRA), used the licensees Individual Plant Examination for External Events (IPEEE) to select several risk-significant areas for detailed inspection and review. Documents reviewed are listed in the Attachment to this report.
The fire areas and/or fire zones selected for review during this inspection are listed below and constituted five inspection samples as defined in IP 71111.05TTP.
Fire Area Fire Zone Description M
Unit 1, 1CD Diesel Generator Room (EL. 587 0)
EE 29B Unit 1, Essential Service Water Pump PP-1W (EL. 591-0)
KK 40A Unit 1, 4-kV AB Switchgear Room (EL. 609-6)
MM 42D Unit 1, EPS (AB) Battery Room (EL. 609-6)
RR Unit 2, Control Room (EL. 633-0)
.1 Shutdown from Outside Main Control Room
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. The inspectors reviewed the plant systems required to achieve and maintain post-fire safe-shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe-shutdown conditions for each fire area selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant inventory makeup, reactor heat removal, process monitoring, and support system functions. The review also included the fire safe-shutdown analysis to ensure that all required components in the selected systems were included in the licensees safe-shutdown analysis.
The inspectors reviewed the licensees post-fire safe-shutdown analysis, normal and abnormal operating procedures, piping and instrumentation drawings, electrical drawings, their updated final safety analysis report, 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.
The inspectors also 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, and the available time for performing the actions.
The inspectors reviewed 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) to determine the licensing basis.
b. Findings
No findings of safety-significance were identified.
.2 Protection of Safe-shutdown Capabilities
a. Inspection Scope
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe-shutdown analysis, and supporting drawings and documentation to verify that safe-shutdown capabilities were properly protected.
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 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 safety-significance were identified.
.3 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 and supporting fire tests. 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 safety-significance were identified.
.4 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 license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and NFPA standards to verify that fire suppression and detection systems met license commitments.
b. Findings
No findings of safety-significance were identified.
.5 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 safety-significance were identified.
.6 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 inspectors conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe-shutdown procedure actions and that equipment labeling was consistent with the alternate safe-shutdown procedure.
The review also looked at operator training as well as consistency between the operations shutdown procedures and any associated administrative controls.
b. Findings
No findings of safety-significance were identified.
.7 Circuit Analyses
a. Inspection Scope
In accordance with IP 71111.05TTP, Fire Protection - NFPA 805 Transition Period (Triennial), dated May 9, 2006, this section of the IP was suspended for facilities in NFPA 805 transition.
b. Findings
No findings of safety-significance were identified.
.8 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. The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire.
b. Findings
No findings of safety-significance were identified.
.9 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 safety-significance were identified.
.10 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 safety-significance were identified.
.11 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 on the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.
b. Findings
No findings of safety-significance were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The inspector reviewed the licensees corrective action program procedures and samples of corrective action documents to verify that the licensee was identifying issues related to the fire protection program at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, design packages, and fire protection system non-conformance documents.
b. Findings
No findings of safety-significance were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
(Closed)Licensee Event Report (LER) 05000315/2008-002-00: 250Vdc Cable Separation Criteria for 10 CFR Part 50, Appendix R Not Met This event, which occurred on February 6, 2008, during the licensees transition to NFPA 805, a finding of nonconformance and a violation of NRC requirements (see Section 4OA7), was discovered by the licensee in their Appendix R fire protection analyses for both units. The finding involved the failure to identify a short section of Train A 250Vdc conduit enclosed cable passing through the Train B 4kV switchgear room. The routing of the unprotected conduit enclosed cable presented a potential fire hazard which, if left unprotected, could disable both the Train B switchgear as-well-as the remote control to the Train A 4kV switchgear due to fire damaged should a fire occur in the Train B 4kV switchgear room. As a result, the licensee issued AR00825805, Appendix R Compliance for Train B 4kV Room Fire. In addition, compensatory fire watch tours of the affected fire zones were established and remained in effect until permanent corrective actions were implemented. Permanent corrective action included wrapping the conduit with a fire retardant material and converting the CO2 suppression system from manual to automatic in accordance with the requirements of Appendix R,Section III.G.2.(c). In addition, the applicable design documents were updated to reflect the installed fire protective material.
The inspectors reviewed the licensees corrective actions for the above described Appendix R nonconformance finding. The inspectors review of applicable licensee documents showed that the licensee had established compensatory fire watch tours for the affected fire zones and that the fire watch tours remained in effect until permanent corrective actions were implemented. Based on the inspectors review of applicable modification documents (e.g., EC-48720 and EC-48721) and by independent walkdown observations, the inspectors concluded that the previously unprotected conduit enclosed cable was now wrapped with an appropriate fire retardant material (i.e., 3M' Interam)and that the CO2 suppression system was converted from a manual suppression system to an automatic suppression system to restore conformance with the requirements of 10 CFR Part 50, Appendix R, Paragraph III.G.2(c) requirements and the licensees original Appendix R Program assumptions. The inspectors concluded that the licensees corrective actions, both taken and planned, were appropriate and reasonable.
The enforcement aspects of this finding are discussed in Section 4OA7. Documents reviewed as part of this inspection are listed in the Attachment. This LER is closed.
This event follow-up review constituted one sample as defined in IP 71153-05.
4OA6 Management Meetings
.1
Exit Meeting Summary
On November 20, 2009, the inspectors presented the inspection results to Mr. Larry Webber 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.
4OA7 Licensee-Identified Violations
The following violation of very low safety-significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned as a NCV.
Title 10 CFR Part 50, Appendix R, requires, in part, that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station is free of fire damage. On February 6, 2008, the licensee identified an Appendix R non-compliance (see Section 4OA3), where the Train A 4kV switchgear would not be free of fire damage to support safe-shutdown in the unlikely event of a postulated fire in the Train B 4kV switchgear room. The licensee performed a safety-significance evaluation (i.e., PRA Study 054) and determined that the issue was not of high safety-significance (i.e., the event had a CDF of 1.93E-7). The inspectors concurred with the overall results of the licensees evaluation for safety-significance. This finding met the criteria for enforcement discretion under Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) published in Federal Register Notices dated June 16, 2004; January 14, 2005; and April 18, 2006.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- D. Baker, Mechanical Production Supervisor
- L. Bush, Performance Assurance Manager
- D. Cobb, Operations Fire Protection Manager
- J. Gebbie, Plant Manager
- R. Gray, Design Engineering Mechanical (DEM) Fire Protection Program Manager
- K. Housh, Fire Protection System Manager
- R. Hruby, Site Support Vice President
- D. MacDougall, DEM-Fire Protection
- B. Mammoser, Design Engineering-Mechanical Supervisor
- R. Niedzielski, Regulatory Affairs-Sr. Licensing Coordinator
- K. OConnor, Design Engineering Manager
- S. Partin, Maintenance Manager
- T. Robinson, Learning Organization Department Corrective Action Program Supervisor
- M. Scarpello, Regulatory Affairs Manager
- L. Webber, Site Vice President
- R. Werdann, Design Engineering Director
Nuclear Regulatory Commission
- R. Daley, Chief, Engineering Branch 3, Division of Reactor Safety
- P. LaFlamme, Resident Inspector
- J. Lennartz, Senior Reactor Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None
Closed
- 05000315/2008-002-00 LER 250Vdc Cable Separation Criteria for 10 CFR Part 50 Appendix R Not Met
Discussed
None