05000346/FIN-2013008-03
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Finding | |
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| Title | ) Failure to Provide Procedure for Cold Shutdown Repair |
| Description | Introduction: The following finding that affects 10 CFR 50.48 was identified by the NRC and is a violation of NRC requirements. This finding has been screened and determined to warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues. The inspectors identified a finding of very low safety significance and associated violation of 10 CFR Part 50, Appendix R, Section III.L.5 for the licensees failure to have a repair procedure in effect for closing a valve in the event of a fire in two fire areas. Specifically, there was a potential for the valve actuator to be damaged in the event of a fire. The safe shutdown procedure for a fire in the two fire areas did not provide instruction on how to close the valve if valve actuator damage had occurred. Description: Note 37 for Fire Areas DD (cable spreading room) and FF (control room) within Section 4.0 of the Fire Hazard Analysis Report identified that Decay Heat Pump 1 Borated Water Storage Tank Suction Valve DH 2733 was normally open and required closure prior to cool down using decay heat removal. The note stated that the valve actuator may be damaged due to the torque or limit switches being potentially bypassed due to a hot short. The note indicated that if valve actuator damage occurred, procedures instructed plant personnel to remove the actuator and mechanically close the valve. Procedure DB-OP-02519, Serious Control Room Fire, Revision 17, provided operators guidance for addressing a severe fire in Fire Areas DD and FF, including guidance for transitioning to cool down using decay heat removal. Step 4.i.5 of Procedure DB-OP-02519 directed operators to verify that Valve DH 2733 was closed. However, Procedure DB-OP-02519 did not provide instructions indicating that the valve actuator could be damaged and that removal of the actuator and mechanical closure of the valve may be required. Moreover, it was not clear to the inspectors how mechanical closure of the valve would be accomplished once the actuator had been removed. Valve closure would have required driving the exposed valve stem inward to close the valve. Calculation C-ME-049.02-119 MOV Thrust/Torque Calculation for DH 2733, determined that 4,218 pounds of thrust was required to overcome stem packing friction alone. Based on the calculated thrust value and the configuration of the valve with the actuator removed, the inspectors determined that mechanically closing the valve was not a simple task. The inspectors concluded that the lack of instructions for closing the valve when there is damage to the actuator could result in operational complications and delay reaching cold shutdown in the event of a fire in Fire Areas DD and FF. The licensee entered this issue into their Corrective Action Program as CR-2013-04512 Post Fire Safe-Shutdown Repair Does not have Detailed Procedure, dated March 26, 2013, to determine the proper level of detail and repair instructions needed for their safe shutdown procedures. Analysis: The inspectors determined that the failure to have a repair procedure in effect for closing a valve in the event of a fire in two fire areas was contrary to the requirements of 10 CFR Part 50, Appendix R, Section III.L.5 and was a performance deficiency. Specifically, there was a potential for the valve actuator to be damaged in the event of a fire. The safe shutdown procedure for a fire in the two fire areas did not provide instruction on how to close the valve if valve actuator damage had occurred. The finding was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the lack of instructions for closing the valve when there is damage to the actuator could result in operational complications and delay reaching cold shutdown in the event of a fire in two fire areas. In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase I - Initial Characterization of Findings, Table 3, the inspectors determined that the finding affected the ability to reach or maintain safe shutdown conditions in case of a fire. Therefore, screening under IMC 0609, Appendix F was required. The inspectors determined that the finding affected the post-fire safe shutdown finding category and only affected the ability to reach and maintain cold shutdown conditions. Therefore, the inspectors determined that the finding screened as having very low safety significance (Green) in Task 1.3.1 of IMC 0609, Appendix F. Cross-cutting aspects are not addressed for findings, which warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues. Enforcement: Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix R, Section III.G.Section III.L of 10 CFR Part 50, Appendix R, specifies implementation of alternative or dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.5 of 10 CFR Part 50, Appendix R, states, in part, that the fire damage to equipment and systems shall be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and that procedures shall be in effect to implement such repairs. Fire Areas DD and FF were fire areas which required alternative or dedicated shutdown capability. Contrary to the above, as of March 26, 2013, the licensee did not have a repair procedure in effect to close Valve DH 2733 in the event of a fire in alternative shutdown Fire Areas DD and FF. Specifically, due to the potential for the valve actuator torque and limit switches being bypassed due to a hot short during a fire in either Fire Area DD or Fire Area FF, the valve actuator could be damaged. In the event of valve actuator damage, the valve could only be closed by driving the valve stem inward with the valve actuator removed. Abnormal Procedure DB-OP-02519 did not provide instructions how to close Valve DH 2733 in the event that the valve actuator had been damaged. The licensee is in transition to NFPA 805 and; therefore, the NRC-identified violation was evaluated in accordance with the criteria established by Section A of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for a licensee in NFPA 805 transition. The inspectors determined that for this violation: (1) the licensee would have identified the violation during the scheduled transition to 10 CFR 50.48(c); (2) the licensee had established adequate compensatory measures within a reasonable time frame following identification and would correct the violation as a result of completing the NFPA 805 transition; (3) the violation was not likely to have been previously identified by routine licensee efforts; and (4) the violation was not willful. The finding also met additional criteria established in Section 12.01.b of Inspection Manual Chapter (IMC) 0305. In addition, in order for the NRC to consider granting enforcement discretion the violation must not be associated with a finding of high safety significance (i.e., Red). Therefore, the inspectors determined that this issue was associated with a finding of very low safety significance (Green) per Task 1.3.1 of IMC 0609, Appendix F. In addition, the licensee entered this issue into their Corrective Action Program as, CR-2013-04512. As a result, the inspectors concluded that the violation met all four criteria established by Section A and the NRC was exercising enforcement discretion to not cite this violation in accordance with the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues. |
| Site: | Davis Besse  |
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| Report | IR 05000346/2013008 Section 1R05 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | Violation: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | R Daley R Langstaff R Winter A Dahbur |
| Violation of: | 10 CFR 50 Appendix R 10 CFR 50 Appendix R Section III.G 10 CFR 50 Appendix R Section III.L 10 CFR 50.48 |
| INPO aspect | |
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Finding - Davis Besse - IR 05000346/2013008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Davis Besse) @ 2013Q2
Self-Identified List (Davis Besse)
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