05000282/LER-2016-004, Regarding Missing Fire Barrier Between Fire Area (FA) 59 and 85 / Fire Hazard Analysis Drawings Do Not Match Boundary Description
| ML16173A434 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/21/2016 |
| From: | Northard S Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-PI-16-052 LER 16-004-00 | |
| Download: ML16173A434 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 2822016004R00 - NRC Website | |
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(l Xcel Energy 06/21/2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License Nos. DPR-42 and DPR-60 Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch. MN 55089 L-PI-16-052 10 CFR 50.73 Licensee Event Report 50-282/2016-004-00. Missing Fire Barrier Between Fire Area (FA) 59 and 85 I Fire Hazard Analysis Drawings Do Not Match Boundary Description Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), encloses Licensee Event Report (LER) 50-282/2016-004-00, Missing Fire Barrier Between Fire Area (FA) 59 and 85/ Fire Hazard Analysis Drawings Do Not Match Boundary Description.
If there is any question or if any additional information is needed, please contact Frank Sienczak, at 651-267-1740.
Summary of Commitments This letter contains no new commitments and no changes to existing commitments Scott Northard Acting Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company-Minnesota
Enclosures:
cc:
Regional Administrator, Region Ill, USNRC Project Manager, Prairie Island Nuclear Generating Plant, USNRC Resident Inspector, Prairie Island Nuclear Generating Plant, USNRC Department of Commerce, State of Minnesota
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 (11-2015)
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EsUmated, the NRC may not conduct or sponsor, and a person is not required to respond to, the informaUon collection.
~-PAGE Prairie Island Nuclear Generating Plant Unit 1 05000 282 1 OF4
- 4. TITLE Missina Fire Barrier Between Fire Area (FA) 59 and 85/ Fire Hazard Analvsis Drawinas Do Not Match Boundarv Descriotion
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO.
MONTH DAY YEAR Prairie Island Unit 2 05000 306 FACILITY NAME DOCKET NUMBER 04 21 2016 2016
- - 004
- - 00 06 21 2016 05000
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
D 20.2201(b)
D 20.2203(a)(3)(i)
D 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A)
Unit 1 Mode 1 D 20.2201(d).
D 20.2203(a)(3)(ii)
~ 50.73(a)(2)(ii)(B)
D 50.73(a)(2)(viii)(B)
Unit 2 Mode 1 D 20.2203(a)(1)
D 20.2203(a)(4)
D 50.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
D 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x)
D 20.2203(a)(2)(ii)
D 50.36(c)(1)(ii)(A)
D 50.73(a)(2)(v)(A)
D 73.71 (a)(4)
- 10. POWER LEVEL D 20.2203(a)(2)(iii)
D 50.36(c)(2)
D 50.73(a)(2)(v)(B)
D 73.71 (a)(5)
Unit 1 100%
D 20.2203(a)(2)(iv)
D 50.46(a)(3)(ii)
D 50.73(a)(2)(v)(C)
D 73.77(a)(1)
Unit 2 100%
D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(D)
D 73.77(a)(2)(i)
D 20.2203(a)(2)(vi)
D 50.73(a)(2)(i)(B)
D 50.73(a)(2)(vii)
D 73.77(a)(2)(ii)
D 50.73(a)(2)(i)(C) 0 OTHER Specify in Abstract below or in NRC Form 366A
- 12. LICENSEE CONTACT FOR THIS LER LICENSEE CONTACT
~ELEPHONE NUMER (lndude Area Code)
Frank Sienczak 651-267-1740
- 13. COMPLETE ONE UNE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE
CAUSE
SYSTEM COMPONENT MANU-REPORTABLE FACTURER TOEPIX FACTURER TO EPIX
- 14. SUPPLEMENTAL REPORT EXPECTED
- 15. EXPECTED MONTH DAY YEAR 0 YES (If yes, complete 15. EXPECTED SUBMISSION DATE)
-~NO SUBMISSION DATE ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)
On April21, 2016, during a walkdown of fire barriers for the National Fire Protection Association (NFPA) 805 project, it was determined that the fire barrier between Fire Area (FA) 59 (Auxiliary Building Mezzanine Unit 1) and FA 85 (Holdup Tank/
Demineralizer Area) is not a rated barrier due to unsealed combustible pathway penetrations in the barrier.
The walkdown also identified that penetrations in the fire barriers between FA 68 (Unit 1 Annulus) and FA 60 (Auxiliary Building Operating Level Unit 1 ), FA 68 and FA 61A (Auxiliary Building Hatch Area), FA 72 (Unit 2 Annulus) and FA 75 (Auxiliary Building Operating Level Unit 2), and FA 72 and 61A are not sealed with fire rated materials.
Both conditions were reported under 10 CFR 50. 73(a)(2)(ii)(B) as an unanalyzed condition that significantly degrades plant safety due to the missing fire barrier between redundant Appendix R safe shutdown trains.
The apparent cause was determined to be that the Engineering Manual 3.4.2 does not require Appendix R program owner review of Fire Protection Engineering Evaluations that depend on Appendix R Safe Shutdown analysis.
The corrective action is to revise the Engineering Manual 3.4.2 to require Appendix R review when the program is impacted.
NRC FORM 366 (11-2015)
BACKGROUND 05000-282 YEAR I
2016 SEQUENTIAL I
NUMBER
- - 004 REV NO.
- - 00 The original Fire Hazards Analysis (FHA) was submitted to the NRC with drawings that show the walls (between Fire Area (FA) 59 & 85, 74 & 85, FA 68 & 60, FA 72 & 75, 68 & 61A, 72 & 61A) are fire area boundaries.
[Northern States Power (NSP)-NRC Fire Hazards Analysis report dated March 11, 1977]
Sections 3.1.1 (2) through (4) of the Fire Protection Safety Evaluation Report (SER) require fire barrier modifications to upgrade penetration seals in various plant areas, to install qualified seal designs in the future, and to replace or modify existing seals which contain polyurethane foam.
[NRC Safety Evaluation Report dated September 6, 1979]
In response to the requirements above from the September 6, 1979, NRC SER, NSP committed to review and upgrade seals as necessary, to use 3-hour rated seal designs for new seals and to upgrade seals in specific areas. Among the areas listed were the Elevation 735' Auxiliary Building barriers shared with Turbine Building and Hatch Area (FA 61) barriers shared with parts of the Auxiliary Building. The barriers that are the subject of this event were not included in the list of areas where seals would be upgraded. The details of the penetration seal upgrades laid out in the November 30, 1979, letter was accepted in NRC SER dated April21, 1980.
[NSP letter to the NRC dated November 30, 1979; NRC Safety Evaluation Report dated April21, 1980]
Revision 12 to the FHA updated the FHA Boundary drawings to reflect boundaries discussed in licensing correspondence and the results of the Safe Shutdown Analysis (GEN-PI-026 Rev.1 dated December 15, 1997, and F5 App E Rev. 4). The FHA drawings were updated to remove and add Appendix R barriers. The barriers between FA 59 & 85, FA 74 & 85, FA 68 & 60, FA 72 & 75, FA 68 & 61A and FA 72 & 61A were not addressed in the FHA or Safety Evaluation 502.
[Safety Evaluation (SE) 502, F5 Appendix F Rev.12-Fire Hazards Analysis dated March 12, 1999]
On August 16, 2012, Fire Protection Engineering Evaluation (FPEE)12-006 Rev. 1 was completed. The FPEE evaluated the fire area boundaries between FA 85 and FA 59. The evaluation concludes that the fire area boundary is not required for separation of safe shutdown equipment therefore the barrier is acceptable as is.
The safe shutdown analysis section of the FPEE states, "All the cabling for required equipment in FA 85, except for CV-31198, is also routed in FA 59. FA 59 does not contain cabling for the component redundant to CV-31198. As such, fire safe shutdown capability is identical between FA 59 and FA 85 for the identified components and there is no impact on fire safe shutdown capability should a fire spread between FA 59 and FA 85." The methodology used to justify the condition was inappropriate because it considered availability of safe shutdown components in the fire area instead of availability of the entire safe shutdown train.
The evaluation was prepared in accordance with Engineering Manual 3.4.2 which provides guidelines for completing FPEEs in accordance with NRC Generic Letter 86-10. The preparer and reviewer were assigned in accordance with the procedure which does not require an Appendix R program owner to review FPEEs. An Appendix R program owner review would have identified that the evaluation was not consistent with the Appendix R Safe Shutdown Analysis.
[FPEE 12-006; AR 1311038-03 Evaluate change to F5 App K barrier]
NRC FORM 366 (11-2015) 11-2015)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 1. FACILITY.NAME
- 2. DOCKET NUMBER
- 3. LERNUMBER Prairie Island Nuclear Generating Plant Unit 1
DESCRIPTION OF EVENT
05000-282 YEAR l 2016 SEQUENTIAL I
NUMBER
- - 004 At the time of discovery, both units were operating in Mode 1 at 100 percent power. There were no other structures, systems or components inoperable that contributed to the condition.
REV NO.
- - 00 On April21, 2016, walkdowns were performed to support the NFPA 805 License Amendment Request. Specifically, fire barriers that will be credited for the NFPA 805 licensing basis that were not credited for Appendix R separation were inspected to identify required upgrades. During review of the fire barrier between FA 59 (Auxiliary Building Mezzanine Unit
- 1) I FA 74 (Auxiliary Building Mezzanine Unit 2) and FA 85 (Holdup Tank/ Demineralizer Area), the vendor questioned the conclusion of FPEE 12-006, which states that the fire barrier between FA 59 and 85 is not required for separation of Appendix R safe shutdown equipment.
The walkdowns also identified that the fire barriers identified in the FHA drawing for FAs 68 and 72 do not agree with the boundary description in the FHA for each fire area. The FHA drawing shows the FA 68 Containment Annulus Unit 1) and FA 72 (Containment Annulus Unit 2) boundary as the shield building wall up to the containment airlock. The descriptions in the FHA show the boundary between FA 68 (Unit 1 Annulus) and FA 60 (Auxiliary Building Operating Level Unit 1 ), FA 68 and FA61A (Auxiliary Building Hatch Area), FA 72 (Unit 2 Annulus) and FA 75 (Auxiliary Building Operating Level Unit 2), and FA 72 and 61A at the shield building vent zone boundary since the personnel and maintenance airlock doors are listed as part of the boundary. The annulus airlock doors are 3-hour fire rated and the airlock is constructed of concrete thick enough to qualify as a 3-hour fire barrier; however, there are unnumbered penetrations 1 in the barrier that have not been sealed with fire rated materials.
The fire barriers above were evaluated and it was determined that the fire barriers between FA 59 & 85, FA 68 & 60, FA 68 & 61A, FA 72 & 75 and FA 72 and 61A separate redundant Appendix R safe shutdown trains. The fire barrier between 74 and 85 does not separate redundant Appendix R safe shutdown trains.
On April 21, 2016, at 2303 CST this condition was reported to the NRC in EN 51877.
EVENT ANALYSIS
This condition is being submitted in accordance with 10 CFR 50.73(a)(2)(ii)(B) as an "Unanalyzed Condition That Significantly Degrades Plant Safety" due to a missing fire barrier between redundant trains of Appendix R safe shutdown equipment. As a result of the non-functional fire barrier, a fire in one area could propagate to the adjacent fire area.
SAFETY SIGNIFICANCE
PINGP has procedures and controls in place to minimize the likelihood and severity of fires occurring, and a significant fire impacting the ability to safely shutdown did not occur. This is a postulated event and there were no nuclear, environmental, radiological or industrial safety consequences related to this event.
The postulated fire scenarios for FA 59 and 85, 60 and 68, 75 and 72, require that a significant fire of sufficient size and intensity to propagate between the fire areas. The in-situ combustible loading in FA 59, 60 and 75 is low and is primarily IEEE-383 qualified electrical cable insulation. The combustible loading in FA 85, 68 and 72 is very low. The combustible loading in Fire Area 61A is low except during outages when it is frequented by personnel. The walls, albeit with unrated penetrations, continue to provide some fire confinement of a postulated fire and fire detection is available on one side of each of these barriers in Fire Areas 59, 74, 60, 75, and 61A, to initiate a prompt response by the fire brigade.
1(1EEE Code-PEN) 11-2015)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018 LICENSEE EVENT REPORT (LER)
CONTINUATION SHEET
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. LERNUMBER Prairie Island Nuclear Generating Plant 05000-282 YEAR I
SEQUENTIAL I
REV NUMBER NO.
Unit 1 2016
- - 004
- - 00 The fire modeling performed to support the Fire PRA for the NFPA 805 LAR indicates that a hot gas layer would not be developed in Fire Compartment 59GRP (Fire Areas 59 and 74), Fire Compartment 85, Fire Compartment 60, Fire Compartment 75, Fire Compartment 68, Fire Compartment 72 or Fire Compartment 4GRP (which includes Fire Area 61A). Based on this information, the risk of a fire propagating between these areas is low. Therefore, the overall risk to the site is very low.
CAUSE
Apparent Cause Engineering Manual (EM) 3.4.2 does not require Appendix R program owner review of FPEEs dependent on Appendix R analysis.
Contributing Causes
The scope of fire barrier upgrades was determined based on protection of safety related equipment and fire loading adjacent to fire barriers instead of Appendix R separation.
The risk of introducing errors was not assessed during the pre-job brief and Subject Matter Expert review was not obtained.
CORRECTIVE ACTION
Immediate Actions For compensatory measures a fire watch was established for the fire barrier impairments per F5 Appendix K, Fire Protection System Functional Requirements.
Corrective Actions
Engineering Change Request (ECR) 8790 submitted to upgrade 13 penetration seals. The ECR has been reviewed in ECR Screening and approved to be a Work Order (WO) Modification.
Revise safe shutdown analysis in FPEE 12-006 Track Procedure Change Request (PCR) for F5 Appendix F-airlock penetrations Track Resolution for the Operation Status Non-Functional (OSNF) OPS Status Corrective Actions to Preclude Repetition (CAPR)
The corrective action is to revise the Engineering Manual 3.4.2 to require Appendix R review when the program is impacted.
PREVIOUS SIMILAR EVENTS
LER 50-282/2014-006-00, identified a missing fire barrier. The missing fire barrier is related to separation of redundant pressurizer heater cables credited for safe shutdown in FA 32 (Unit 1, Train 8 Aux Feedwater Pump Room).
The cause of the foam material in the seismic joint seals is consistent with the cause identified in Root Cause Evaluation for "Aux Feedwater Pump Room Penetration Left Unsealed Without Compensatory Measures," which was due to lack of rigor in the 1979 design change.
The corrective action had the combustible foam material in the seismic gap seals replaced with fire rated material by implementation of a design change with work orders.
NRC FORM 366 (11-2015)