05000341/LER-2002-002, Re Fire Protection Dedicated Shutdown Valve Accessibility Impacted by Field Modification
| ML021640041 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/30/2002 |
| From: | O'Connor W Detroit Edison |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-02-0047 LER-02-002-00 | |
| Download: ML021640041 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| 3412002002R00 - NRC Website | |
text
William T. O'Connor, Jr.
Vice President, Nuclear Generation Fermi 2 6400 North Dixie Hwy., Newport, Michigan 48166 Tel: 734.686.6201 Fax: 734.586.4172 Detroit Edison A MDTE EMnery Company 10 CFR 50.73 May 30, 2002 NRC-02-0047 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001
Reference:
Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
Subject:
Licensee Event Report 02-002, "Fire Protection Dedicated Shutdown Valve Accessibility Impacted by Field Modification" Pursuant to the requirement in Section 2.F of the Fermi 2 Operating License, Detroit Edison is submitting the enclosed Licensee Event Report (LER)02-002. This LER documents the discovery of a recent plant modification that hindered accessibility to a valve required to be closed to preclude losing Condensate Storage Tank (CST) water inventory to the Hotwell during a dedicated shutdown scenario. Although no compensatory measures were established to address valve accessibility, the absence of such compensatory measures would have only delayed the closure of the valve for a short time, therefore, this event resulted in no adverse effect on the health and safety of the public.
Should you have any questions or require additional information, please contact Mr. Norman K. Peterson of my staff at (734) 586-4258.
Sincerely, cc:
T. J. Kim M. A. Ring M. V. Yudasz, Jr.
NRC Resident Office Region III Regional Administrator, Region III Wayne County Emergency Management Division
Abstract
As a result of a fire protection program self assessment, on May 2, 2002, Detroit Edison Company determined that a field modification performed on February 19, 2002 invalidated an inherent assumption in the procedure for controlling the plant from the dedicated shutdown panel. Specifically, the motor operator for motor operated valve (MOV) N2000F636, Condenser Hotwell Emergency Makeup Bypass Valve, was rotated 180 degrees to help alleviate an oil leakage problem. Rotating the MOV relocated the motor operator handwheel away from the first floor of the Turbine Building such that operators could not reasonably close the valve without the use of a ladder. Procedure 20.000.18, "Control of the Plant from the Dedicated Shutdown Panel," directs operators to de-energize and manually close N2000F636 to prevent losing Condensate Storage Tank (CST) water inventory to the Hotwell, in case a hot short caused the valve to open. Losing CST inventory threatens the ability to achieve safe shutdown conditions in the event of a fire. Therefore, this condition is reportable under Section 2.F of the Fermi 2 Operating License as a violation of License Condition 2.C.(9).
Based on the short delay associated with obtaining a ladder and closing the valve, this condition did not result in any adverse effect on the health and safety of the public.
A dedicated ladder has been staged near the valve and accessibility of other components requiring operator action has been verified. Other corrective actions are being finalized.
NRC FORM 366 (7-2001)
(If more space is required, use additional copies of (If more space is required, use additional copies of (if more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A)
Additional Information
A. Failed Components: None B.
Previous LERs on Similar Problems LER 99-006 On October 27, 1999, it was determined that a deficiency existed in the dedicated shutdown procedure used for plant shutdown in the event of fires in certain areas of the plant. The dedicated shutdown procedure did not include a required action for fires in all fire zones for which the action would be required. The dedicated shutdown procedure requires isolation of the control air supply for the High Pressure Coolant Injection (HPCI) system test return line control valve, E41FO 11, only for some fires in some of the fire zones where the action is required. Isolation of the control air supply is required to prevent fire induced spurious opening of the HPCI test return line control valve which, in combination with fire induced spurious opening of two other valves, could result in Standby Feedwater (SBFW) flow being bypassed to the Condensate Storage Tank (CST), reducing flow to the reactor vessel. The cause of this event was not having adequate involvement of a fire protection engineer in the development and review of procedure changes.
LER 98-003 On March 18, 1998, it was determined that fire induced multiple hot shorts could cause spurious valve operations which could reopen closed valves and result in Condensate Storage Tank (CST) inventory to drain to Condenser Hotwell. This could have resulted in a loss of CST inventory necessary for safe shutdown following a fire. Procedures were revised to de-energize appropriate valves to prevent this drain path. The cause of this event was inadequate cross-discipline review of assumptions made in the fire protection program safe shutdown evaluation.
LER 96-019 On November 15, 1996, a Deviation Event Report (DER) was initiated to investigate the adequacy of the water supply for the Standby Feedwater (SBFW) system to meet Appendix R requirements. The water supply for SBFW is from a nine foot standpipe in the Condensate Storage Tank (CST). Technical Specification (TS) 3.7.11 required an operable SBFW system consisting of two operable SBFW pumps and an operable flow path from the CST to the reactor vessel. The cause of this event was an inadequate design review of the Appendix R Dedicated Shutdown Method during design development in 1984.
Appropriate operating procedures were revised to maintain the required volume of water in the CST at greater than 22 feet.