IR 05000254/1993018
| ML20045D450 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/23/1993 |
| From: | Jablonski F, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045D438 | List: |
| References | |
| 50-254-93-18, 50-265-93-18, EA-93-162, NUDOCS 9306290035 | |
| Download: ML20045D450 (32) | |
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V. S. NUCLEAR REGULATORY COMMISS10fl REGION Ill'
Report Nos.
50-254/265-93018(DRS)
EA 93-162 Docket Nos.
50-254; 50-265 License Nos. DPR-29; DPR-30'
Licensee:
Commonwealth Edison Company
Executive Towers West 111
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1400 Opus P1 ace, Suite 300 Downers Grove, IL 60515
,a Meeting Conducted:
June 21, 1993 Meeting Location:
Region III Office 799 Roosevelt Road
Glen Ellyn, Illinois 60137 l
Type of Meeting:
Enforcement Conference Inspection Conducted:
February 24-26, April 19-23 and May 27, 1993 Inspector:
G. M. Hausman l
Reviewed by:
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~2E Frank J. Jableriski, Chief Date-
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Maintenance and Outages Section rd b h du b2 S 'f3 Approved by:
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Geoffre, if / Wright, Chief U Date l
Enginee.7, Branch i
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Meetinq_Summarv:
Enforcement Conference on June 21. 1993. (Renort Nos. 50-254/265-93018(DRS.B
Areas Discussed: Apparent violations identified during the inspection were i
discussed, along with the corrective actions taken or planned by the licensee.
The enforcement options pertaining to the apparent violations were also
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discussed with the licensee.
The apparent violations concerned: (1) Quad Cities Unit 2 operated more than 67 days with Unit 1 RHR-service water system loop A (opposite unit / shared unit safe shutdown (SSD) component)
out-of-service; (2a) procedures were not established to track opposite unit / shared unit SSD components when equipment was taken out-of-service; (2b) fire protection equipment was not-tested in accordance with establisLJ
procedures: (2c) procedures were not established to maintain the fire
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protection systems associated.with the rotor unstacking transformers; (3) a
- test program'had not bl.en established to periodically demonstrate operabilitj-of certain SSD components; and (4) the ' licensee failed to correct conditions-
't adverse to quality in a timely manner even though the conditions were specifically identified in 1986,1989 and 1990.
i 9306290035'930623 PDR ADOCK 05000254-.
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DETAILS.
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Persons Present at the Conference-
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Commonwealth Edison Company R. Pleniewicz, Site Vice President, Quad Cities J. Burkhead, Quality Verification Superintendent.
J. Leider, Technical Service Superintendent-QC i
E. Netzel, Quality Verification Support Superintendent
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'A. Misak, Regulatory Assurance Supervisor
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D. Bucknell, Assistant Technical Staff Supervisor.
l M. Dillon, Fire Protection
P. Hart, Fire Protection Engineer
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M. Jackson, Regulatory Performance Administration D. Kanakares, Regulatory Assurance, NRC Coordinator
J. Masterlark, Fire Protection System Engineer D. Saccomando, Regulatory Performance Administration
J. Schrage, Nuclear Licensing Administrator
S. Trubatch, Winston & Straw Attorney
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M. Willoughby, Safety Review
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U. S. Nuclear Reaulatory Commission
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H. Miller, Deputy Regional Administrator i
T. Martin, Acting Director, Division of Reactor Safety (DRS)
l R. Hoefling, Acting Regional Counsel R. DeFayette, Director,. Enforcement and Investigations Staff G. Wright., Chief, Engineering Branch, DRS
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F. Jablonski, Chief, Maintenance and.0utages-Section, DRS.
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G. Hausman, Reactor Inspector, DRS
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T.' Taylor,. Senior Resident inspector, Quad Cities-K. Shembarger, Reactor Engineer
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P. Pelke, Enforcement Specialist D. Liao, Reactor Engineer C. Patel, Project Manager, Office of Nuclear Reactor Regulation (NRR)
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J. Holmes, Fire Protection Engineer, NRR 2.
Enforcement Conference
An enforcement conference was held in the NRC Region 111 office on
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June 21, 1993.
This conference was conducted as a result of the
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preliminary findings of the inspection conducted from February 24-26,-
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April 19-23 and May 27, 1993, in which apparent violations of NRC regulations were identified.
Inspection findings were documented in
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Inspection Report 50-254/265-93009(DRS), transmitted to the licensee by
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letter dated June 11, 1993.
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The purpose of this conference was to (1) discuss the apparent l
violations, the cause(s), and the licensee's corrective actions;
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(2) determine if there were any escalating or mitigating circumstances;
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and (3) obtain any information which would help determine the appropriate enforcement action.
The c,onference was closed to the
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publ i c.
Following.an introduction by the acting director of the division of reactor safety, the apparent violations were presented.
The licensee's representatives provided additional information concerning the apparent
violations The licensee's representatives described the events which led to the' apparent violations, including root. causes and corrective actions taken.
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At the conclusion of the meeting, the licensee was informed that they-
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would be notified in the near future of the final enforcement action, f
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At t a chmen t s..
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NRC Presentation Slides 2.
CECO Presentation Slides
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
COMMONWEALTH EDISON COMPANY QUAD CITIES NUCLEAR STATION.
ENFORCEMENT CONFERENCE
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JUNE 21,1993
9:00 A.M. (CDT)
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REPORT NOS. 50-254/265-93009 EA 93-162
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REGION III OFFICE 799 ROOSEVELT ROAD, BUILDING 4 i
GLEN ELLYN, ILLINOIS i
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' ATTA0BDFT 1 SLIDE #2 of 11-
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COMMONWEALTH EDISON COMPANY QUAD. CITIES NUCLEAR STATION AGENDA June 21,1993 INTRODUCTION:
Tom Martin, Aeting Director Division of Reactor Safety (DRS)
DISCUSSION OF CONCERNS:
Geoffrey Wright, Chief Engineering Branch, DRS SUMMARY OF APPARENT VIOLATIONS:
George Hausman, Reactor Inspector, DRS LICENSEE PRESENTA. TION AND DISCUSSION:
CLOSING REMARKS:
Tom Martin i
(Stide # 2)
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ATTAOPE7f 1 -
SLIDE #3 of 11-
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NRC CONCERNS
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o APPARENT BREAKDOWN OF FP PROGRAM CONTROLS Attention to known fire protection problems was not proactive.
Defined program was not properly implemented.
Prioritization of known problems was inappropriate.
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O LACK OF CONTINUITY AND OVERSIGHT OF A CRITICAL SYSTEM
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ATTAQME2iT 1
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APPARENT VIOLATION NUMBER 1
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Appendix R to Part 50, requires " Alternative or dedicated shutdown capability shall be provided."
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t Quad Cities Fire Protection Report.(FPR), requires if neither the safe shutdown component or opposite unit / shared replacement equipment has not been returned to service within 67 days, the unit must be
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shutdown.
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Contrary to the above, Quad Cities Unit 2 reactor operated at power with the Unit 1, RHR Service
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Water System Loop A out-of-service for 120 days.
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This is an apparent violation which is subiect to further review, and may be subiect to chance prior to any resultine enforcement action (stice # 4)
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CHRONOLOGY OF EVENTS FOR APPARENT VIOLATION NUMBER 1 DATE-DESCRIPTION 08/29/86 B. Rybak to Station Managers Letter: controls needed for opposite unit / shared unit equipment.
12/07/89 Quad Cities Fire Protection Assessment (9/8/89),
controls not implemented. Response due January 8, 1990.
01/08/90 Station stated analysis would be prepared by June 1,1990.
06/01/90 Due date missed.
11/14/90 Unit 1 RIIR Service Water Loop A taken out-of-service.
12/90 Fire Protection Report Amendment 8 issued: ATR for opposite unit / shared unit SSD equipment 67 day limit.
01/21/91 Unit 1 RIIR Service Water Loop A exceeds SSD 67 Day LCO. Unit 2 not shutdown.
03/15/91 Unit 1 RIIR Service Water Loop A returned to service.
(stide # 5)
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APPARENT VIOLATION NUMBER 2
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Quad Cities TS requires written procedures to be established,
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implemented and maintained for Fire Protection Program
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implementation.
Quad Cities Procedure QAP 1170-19 requires:
fire detection instruments be demonstrated operable every 6 months and sprinkler systems be tested and inspected each operating cycle.
(1)
Contrary to the above, fire detection instrument functional testing was not performed for the following systems:
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345 KV Relay llouse UI & U2 Main Transformer UI & U2 Aux Transformer UI & U2 Reserve Aux Transformer UI & U2 Turbine Oil Tanks UI & U2 Turbine Bearings UI & U2 Ilydrogen Seal Oil UI & U2 Exciter llousing MG Set Water Curtain (2)
Contrary to the above, sprinkler system functional test and inspections were not performed for the following systems:
UI & U2 Rotor Unstacking Transformer MG Set Water Curtain I
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Contrary to the above, written procedures have not been established to maintain fire protection systems associated with the rotor unstacking transformers.
This is an apparent violation which is subject to further review. and may be sulite.t to change prior to any resultine enforcement action (stice a 6)
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CHRONOLOGY OF EVENTS FOR APPARENT VIOLATION NUMBER 2 DATE DESCRIPTION 05/09/89 NFPA code violations identified on Rotor Unstacking Transformer Water Spray Systems.
02/28/91 QAP 1170-19: administrative requirements for fire protection.
11/20/91 Modification Request Form MR4-0-91-024: remove transformers or correct code violations.
12/21/92 Identified other problems existed with FP and SSD programs.
01/07/93 LER 92-032, Revision 0 issued.
(Slide # 7)
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.ATflCFETT 1 SLIDE #8 of 11
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APPARENT VIOLATION NUMBER 3 10 CFR 50, Appendix B, Criterion XI, " Test Control,"
states that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.
Contrary to the above, from June 1,1990, until May 27, 1993, test procedures had not been established to periodically demonstrate operability of certain 10 CFR 50, Appendix R, SSD components.
This is an apparent violation which is suidect to further review, and may be suldect to change prior to any resultine enforcement action (Slide # 8)
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l CHRONOLOGY' OF-EVENTS FOR APPARENT VIOLATION NUMBER 3 DATE DESCRIPTION 08/29/86 B. Rybak to Station Managers Letter: local SSD components required periodic testing.
12/07/89 Quad Cities Fire Protection Assessment (9/8/89),
testing not implemented. Response due January 8, 1990.
01/08/90 Station stated procedures would be written by June 1,1990.
05/29/90 Quad Cities Fire Protection Assessment (3/23/90),
express concern meeting due date.
06/01/90 Duc date missed.
05/27/93 SSD fire protection systems / components operability still not verified.
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I APPARENT VIOLATION NUMBER 4
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10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," states " Measures shall be established to
assure that conditions adverse to quality, are promptly identified and corrected."
Quad Cities TS 6.2, " Procedures and Programs,"
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Paragraph A.-7, requires written procedures shall be
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established, implemented and maintained for Fire
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Protection Program implementation.
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.l Contrary to the above, the licensee failed to correct conditions adverse to quality, deficiencies in SSD equipment status tracking and SSD equipment testing, in a timely manner even though the conditions were specifically identitled in 1986,1989 and 1990.
This is an apparent violation which is subject to further review, and may be subject to change prior to any resulting enforcement action (Stide # 10)
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CHRONOLOGY OF, EVENTS FOR APPARENT VIOLATION NUMBER 4 DATE DESCRIPTION 08/29/86 B. Rybak to Station Managers Letter: opposite unit / shared unit equipment controls and local SSD equipment testing.
12/07/89 Quad Cities Fire Protection Assessment (9/8/89),
controls and testing not implemented. Response due January 8,1990.
01/08/90 Station stated analysis would be prepared and procedures would be written by June 1,1990.
05/29/90 Quad Cities Fire Protection Assessment (3/23/90),
express concern meeting due date.
06/01/90 Due date missed.
03/93 Licensee developed interim SSD equipment status trackmg.
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05/27/93 Procedures still not established to control opposite unit / shared unit equipment and test local SSD equipment. SSD equipment not tested.
(Stide # 11)
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ATTAOMNT 2
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ENFORCEMENT CONFERENCE QUAD CITIES STATION FIRE PROTECTION PROGRAM AND SAFE SHUTDOWN EQUIPMENT
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JUNE 21,1993 INTRODUCTION R. Pleniewicz Site Vice President
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NARRATIVES, CAUSES, CORRECTIVE ACTIONS J. Leider
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Technical Superintendent SAFETY SIGNIFICANCE J. Leider
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CONCLUSION R. Pleniewicz i
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-ATTACHMENT 2-SLTDE #2'of 18
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PRESENTATION OVERVIEW
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NARRATIVES CAUSES, CORRECTIVE ACTIONS FIRE PROTECTION PROGRAM PROCEDURES Apparent Violation 254/265-93009-02B
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FIRE PROTECTION CODE DEVIATIONS Apparent Violation 254/265-93009-02C FIRE PROTECTION PROGRAM: SAFE SHUTDOWN EQUIPMENT Apparent Violation 254/265-93009-01,02A,03, & 04
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SLIDE #3 of 18
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FIRE PROTECTION PROGRAM PROCEDURES
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NARRATIVE
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Apparent Violation (254(265)l93009-028):
Failure to establish, implement, and maintain written procedures for the fire protection program Subsequent to implementation of OAP 1170-19:
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Fire protection equipment surveillance procedures were not implemented and surveillances were not performed for non-Technical Specification systems.
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Fire protection systems were not always declared inoperable under the correct
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circumstances due to a misunderstanding of requirements.
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Failure to recognize inoperability resulted in f ailure to report inoperable non-Tech Spec-systems.
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1976 Surveillance and LCO requirements for the original Fire Protection systems were incorporated in the Technical Specifications.
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1979 Branch Technical Position 9.5-1, Appendix A SER was issued. This required the addition of a number of fire protection systems to meet the requirements of Appendix A. Additionally, it contained the requirements to submit-changes to Tech Specs no later than 90 days before fire protection facility modifications are implemented.
1980 Submitted proposed Tech Spec Amendment for fire protection modifications.
that had been completed at that time (R. Janacek to T.E. Murley letter dated July 3,1980 letter). This proposed amendment was never approved, rejected, or withdrawn. However, these systems were tested and continue to be tested in accordance with the proposed Technical Specification amendment.
The station continued to complete additional modifications from 1980 to
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1989 as part of the ongoing implementation of BTP 9.5-1 Appendix A.
Although the modifications subsequent to the proposed Technical Specification amendment were not incorporated into th Tech Specs, the station performed some testing / surveillance.
Wet Pipe and Pre-Action Systems Mechanical testing of sprinkler alarm
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Stand-alone Detection Systems: Testing was performed on detectors and detector system alarm functions.
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FIRE PROTECTION PROGRAM PROCEDURES NARRATIVE 1980(cont.)
Deluge Syst >ms: Testing of the valves was performed per surveillance procedures to ensure the capability to discharge water by manual action.
This mechanical testing was performed on the fol!owing systems:
345 kV Relay House U1 & U2 Main Transformer U1 & U2 Aux Transformer U1 & U2 Reserve Aux Transformer U1 & U2 Turbine Oil Tank U1 & U2 Turbine Bearings U1 & U2 Hydrogen Seal Oil U1 & U2 Exciter Housing However, procedures for testing the detection portion of these deluge systems were not developed, implemented, or performed.
Procedures for mechanical testing and detection system testing for the MG set water curtain were not developed, implemented, or performed.
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5/86 and Generic Letter (GL)B6-10, " Implementation Of Fire Protection 8/88 Requirements" and GL 88-12, " Removal of Fire Protection Requirements From Technical Specifications" were issued. These provided guidance on removal of fire protection requirements from Technical Specifications and incorporation into the FSAR.
b 3/91 in response to GL 88-12, CAP 1170-19, " Administrative Requirements For Fire Protection," was issued defir'ing the surveillance requirements and limiting conditions of operation for the fire protection systems. This procedure included the systems that were originally included in the Tech Specs, pending techaical specification amendments, and modifications installed since that time. This procedure was reviewed in accordance with the station on-site review process.
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10/91 Submitted proposed Tech Spec amendment to remove Fire Protection-i requirements from the Technical Specifications in accordance with GLs 86-10 and 88-12.
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10/27/92 During a turnover by fire protection system engineers, Tech Staff reviewed
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OAP 1170-19.
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ATT1CIPIENT 2-SLIDE #5.of-18
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FIRE PROTECTION PROGRAM PROCEDURES NARRATIVE
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10/27/92 This review indicated:
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All fire protection systems were tested in accordance with the procedure'
with the exception of the MG set water curtain, and the detection
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system for certain deluge systerns.
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Fire protection systems were not always declared inoperable under the correct circumstances due to misunderstanding of the operability requirements. Consequently, compensatory measures and reporting requirements were not adequately implemented.
Compensatory measures for the affected systems were implemented as specified in OAP 1170-19, and deviation report (DVR) 4-01-92-124 was written.
This DVR documented these circumstances and events, which are cited as
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the apparent violation.
11/92 The station performed a DVR investigation and, as a result, a voluntary LER was written. A detailed action plan was developed on 12/21/92 to address deficiencies identified as a result of the DVR investigation, i
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ATIACHMENT 2 ~
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FIRE PROTECTION PROGRAM PROCEDURES CAUSES
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CECO Response:
CECO agrees that the station failed to fully implement the fire protection program in that surveillance requirements for certain fire protection modifications were not established or implemented.
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CECO agrees that the station did not fully implement QAP. 1170-19.
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All testing requirements were not incorporated into surveillance procedures, subsequent to cornpletion of modification testing. The investigation has been unable to -
determine the cause of this situation. In addition, a comprehensive evaluation of existing station surveillances was not performed prior to the issuance of OAP 1170-19.
This review would have ensured. that all of the requirements specified in the administrative procedure were being performed.
The modifications were implemented prior to revision of the modification program in 1986. The current modification program would have resulted in the incorporation of the testing requirements into surveillance procedures.
Training that was provided to appropriate personnel was inadequate to identify fire protection system inoperability.
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FIRE PROTECTION PROGRAM PROCEDURES CORRECTIVE ACTIONS
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All affected systems were immediately declared inoperable upon discovery; appropriate compensatory measures were implemented in accordance with QAP 1170-19.
Functional testing of detection systems was performed on the available systems. All tested detection systems have successfully passed functional tests, with the exception of three turbine bearing deluge systems. Compensatory measures have been implemented for these systems. These will be repaired orior to restart of Units "I and 2.
OAP 1170-19 and other reference documents are currently being reviewed to ensure that:
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Surveillance requirements specified in applicable codes and standards are implemented in the fire protection program.
Appropriate operability requirements for fire protection systems are incorporated mto the procedure.
Reporting requirements for all fire protection systems are incorporated into the procedure.
The review of OAP 1170-19 will be completed; all identified discrepancies will be resolved; l
and an appropriate revision to the procedure will be implemented by July 30,1993.
To date, procedures have been written to address allidentified fire protection
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surveillances not previously incorporated into procedures. These procedures will be
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issued prior to the next required system surveillances, and implemented into the general surveillance scheduling program.
A schedule will be developed to write procedures for any additional missing surveillances identified during the review of QAP 1170-19. This schedule will be developed by August 15,1993.
Training will be provided to appropriate personnel on the revised QAP 1170-19 to ensure proper implementation of procedure requirements.
The station has implemented a Qualification program for all System Engineers. The current Fire Protection System Engineer has completed the qualification requirements for the l
position. This program will enhance continuity of oversight of the fire protection program.
i Additional corrective actions are not currently being contemplated to ensure that future
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changes to the fire protection program are incorporated into station procedures. CECO believes that the current modification program would have resulted in the incorporation of testing requirements into surveillance procedures.
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CECO will review a sample of prior modifications to ensure that testing requirements have been incorporated into applicable procedures. This will be completed by December 31, 1993.
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FIRE PROTECTION CODE DEVIATIONS NARRATIVE-
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Apparent Violation (254(265)l93009-02C):
Failure to maintain a fire protection system for the Turbine Rotor Unstacking Transformers.
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pre-1983 Transformers were installed on the main floor of.the Turbine Building to provide supplemental power during turbine overhauls. Fire protection suppression system installed for transformers.
11/88 CECO deterrnined that the transformers should be a permanent plant modification, and initiated an evaluation of the adequacy of the fire protection system for the transformers, 5/89 Evaluation of fire protection system for transformers completed. Several-
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NFPA deficiencies were identified.
11/91 CECO initiated a modification to correct the NFPA deficiencies. Priority for modification was determined to be low by modification engineer and station -
. modification review committee (SMRC).
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'During the review of the fire protection program by the system engineer, CECO identified that the fire protection system for the transformers was r
inoperable..The system was immediately declared inoperable, and compensatory measures were irnplemented. The event was documented in Deviation Report (DVR) 4-01-92-124.
12/92 CECO reported the inoperability of the fire protection system for the Turbine Rotor Unstacking Transformers (which is the issue cited in the apparent violation) in the DVR; a voluntary LER was written.
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t FIRE PROTECTION CODE DEVIATIONS
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CAUSES.
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CECO Response:
CECO agrees that the station failed to maintain a fire protection' system for two temporary transformers on the main turbine floor.
The significance of the modification to the fire protection program was not recognized by the modification engineer and the Station Modification Review Committee (SMRC).
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SLIDE #10 of 18 FIRE PROTECTION CODE DEVIATIONS CORRECTIVE ACTIONS Long standing safety significant' code deviations at Quad Cities Station are unacceptable and will not continue.
In this case, CECO _has removed the Turbine Rotor Unstacking Transformers.
CECO willinstall new dry type transformers with an appropriate fire protection system.
More generally, CECO has determined that the process for assigning priorities to resolve code deviations needs to be improved.
To ensure that appropriate priorities are assigned to the resolution of code deviations, the station Technical Superintendent will issue a statement of expectations to all station engineers. This statement will require that for deterrnination of the priority for resolution of code deviations, input from individuals with substantive knowledge of the significance of code deviations must be obtained. The basis for assigning priorities associated with code deviations will be docurnented.
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i ANN 2 SLIDE #11'of 18
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i SAFE SHUTDOWN EQUIPMENT NARRATIVE
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Apparent Violation (254(265)/93009-01):
Operation of Unit 2 with Unit 1 RHR service water system (RHRSW) loop A (opposite unit / shared Safe Shutdown (SSD) component) (technically) inoperable for rnore than 67 days.
Appartmt Violation (254(265)/93009-02A):
Failure to have procedures established to track opposite unit / shared unit SSD components when equipment is taken out-of service Apparent Violation (254(2G5)/93009-03):
Failure to take timely corrective actions in controlling opposite unit / shared safe shutdown
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components and testing certain safe shutdown components.
Apparent Violation (254(265)l93009-04):
Failure to establish a test program to assure that all testing required to demonstrate that structures, systems, and components will perforrn satisf actorily in service in that test procedures were not established to test certain safe shutdown components, switches, breakers, alternate feed breakers, local control and isolation switches.
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1978 Quad Cities implemented a large number of modifications to meet fire
to 1986 protection requirements, including Appendix R.
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08/29/86 Letter was issued by the engineering department to CECO stations suggesting a review of: Control of Safe Shutdown Systems not covered by Tech Specs and surveillance of equipment added by Safe Sh':tdown mods.
1986 Upon review of the engineering letter, the station deferred implementation of the recommended actions until completan and
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implementation of Appendix R safe shutdown procedures.
01/03/89 Following an NRC inspection at Dresden Station, Dresdea developed and i
implemented administrative controls to ensure that the required
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opposite unit equipment was available when the opposite unit equipment is out of service. These administrative controls (or DATRs) were shared with Quad Cities.
1989 The station reviewed the Dresden DATRs and determined that they were
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not applicable for the Quad Cities design.
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SLIDE'#12 of I8 SAFE SHUTDOWN EQUIPMENT l
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NARRATIVE 12/07/89 Results of the Corporato Fire Protection Assessment (conducted in September 1989) were issued. This assessment utilized lessons learned from the Dresden NRC inspection as a basis for a portion of the assessment, and the assessment report recommended the
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implementation of the actions described in tho 8/29/86 Engineering letter.
L 01/08/90 Quad Cities response to the fire protection assessment identified more than 12 action items with a completion date of 6/1/90.
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Among those items was the preparation of administrative technical requirements (ATRs) by an AE. No date was established for implementation of administrative controls.
The response assigned due dates of 6/1/90 to over 12 items, but writing of the test procedures was not scheduled for initiation until completion of the ATRs. The intention of the station, at the time, was to ensure the availability of ATR action statements prior to the performance of the surveillance.
The Quad Cities Nuclear Tracking System was used to track these items.
05/29/90 CECO received and initiated a review of draft ATRs for alternate unit SSD equipment.
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07/27/90 The ATRs for alternate unit SSD equipment were completed by the AE.
The station received the ATRs and initiated a process to determine the appropriate method for implementation of the ATRs as procedures.
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11/02/90 Refuel outage Q1R11; Outage work was assigned a higher priority than procedure development.
11/14/90 1 A RHRSW Loop taken out-of-service (OOS day 1): This neluded both pumps, RHRSW vault room coolers, and system valves.
12/26/90 1 A RHRSW Vault Room Cooler maintenance work requests Q85132 &
085133 completed.
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SLIDE #13 of 18
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SAFE SHU'iDOWN EQUIPMENT NARRATIVE
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1/11/91 Shift Engineer logs indicate operation of the 1 A RHRSW loop from 1/11/91 (OOS day 58) through 2/10/91 (OOS day.88) for shutdown cooling; RHRSW vault room coolers listed OOS until 1/25/91 (OOS day 72). The attached timeline graphically describes this sequence of events.
5/91 to Outage ends, but procedure development continued to have a low.
1/92 priority.
1/20/92 Action to write the test procedures was reassigned to Administrative Services (Procedure Writing Group) because of expertise in new procedure format. This group was responsible for conversion of all existing station procedures into the new procedure format.
08/13/92 As part of issues Management Policy implementation. Administrative
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Services prioritized the completion of test procedures and a scheduled completion date was established for March 93.
10/27/92 During a turnover by fire protection system engineers, Tech staff reviewed QAP 1170-19. The station identified certain fire protection program deficiencies and documented these in a deviation report (DVR).
One of the corrective actions in the DVR was initiation of a broad based review of the fire protection program, including Safe Shutdown i
equipment.
12/21/92 This broad based review of the fire protection program identified deficiencies in the Fire Protection / Safe Shutdown prcgram. These i
deficiencies (which included the issues cited as apparent violations 02A,
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03, and 04) were documented in voluntary LER 254-92-032.
2/93 CECO initially determined that the 1 A RHRSW subsystem had been out-of-service from 11/14/90 through 3/14/91(120 days).
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6/93 Upon further evaluation, the station clarified the operational history of the 1 A RHRSW subsystem in January and February 1991.
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. ATTAOFEFr 2 SLIDE #14 of 18
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SAFE SHUTDOWN EQUIPMENT
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CAUSES CECO Response:
CECO acknowledges and agrees with the apparent violations.
The station's assessment of the need for shared unit equipment _ led to the adoption of a low priority for completion of additional administrative controls and surveillance procedures for opposite unit / shared unit Safe Shutdown equipment.
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ATEG6T 2 SLIDE #15 of 18
SAFE SHUTDOWN EQUIPMENT
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CORRECTIVE ACTIONS
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As part of the initial DVR review in October 1992, the station recognized the narrow focus / scope of the DVR, and initiated a more broad based review of the fire protection program. This broad based review identified deficiencies with testing and control of opposite unit / shared unit Safe Shutdown equipment.
During 1992, the issues Management Policy was adopted. This policy requires the i
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assignment of a priority and an accountability date for all corrective action items in the NTS database. This has significantly reduced the number of open items.
l The station implemented Safe Shutdown Equipment ATRs during 02R12.
The station tested all opposite unit / shared unit safe shutdown systems and equipment with the exception of the local operation and isolation switches for the RCIC system
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auxiliaries. These components will be tested subsequent to restart of Units 1 and 2.
All tested equipment successfully met the required acceptance criteria with the exception of the alternate feed to the 2B RHR room cooler f an. This will be repaired orior to rgstart i
of Unit 2.
The station has functionally tested all Safe Shutdown equipment (excluding the previously described exception). Surveillance procedures for these tests will be finalized by the end of July 1993.
The station has implemented the ATRs. Administrative control procedures incorporating the ATRs will be finalized by the end of August 1993.
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. A'FIEMmT 2 SLIDE #16 of 18 FIRE PROTECTION PROGRAM AND SAFE SHUTDOWN EQUIPMENT SAFETY SIGNIFICANCE CECO believes that the safety significance of the apparent violations described in the inspection Report is minimal. This conclusion is based upon the following points:
Testing of all fire detection equipment indicated that all equipment would have functioned as required with the exception of three out of ten Turbine Bearing Deluge systems. Tho impact of this exception is minimal due to:
The capability to quickly detect a fire by routine walkdowns/ personnel presence on the main turbine floor.
The availability of the manual deluge function from a remote location.
The absence of safe shutdown cabling in the turbine deck fire zone.
The prevention of the spread of any fire to adjacent fire zones (which contain safe shutdown cabling) by the equivalent 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers.
The large size of the area, with few intervening combustibles.
Testing of all safe shutdown equipment to date showed that all equipment would have functioned as required, with the exception of the attemate feed to the 2B RHR Room-Cooler fan. The alternate feed causes the room cooler fan to run backwards, degrading the room cooler to approximately 30% of normal. The impact of this is minimal as shown by a CECO evaluation which indicated that with no other operator action, the reduction in room cooler capacity will not affect the operability of the RHR equipment.
The operators could also open the doors to the adjacent 1B RHR room to assist in cooling. A portable fan, which is required to be in the nearby RCIC room, could also be used to improve ventilation between the two RHR rooms.
The 1 A RHRSW subsystem was operated for shutdown cooling between Day 58 and Day 88 of the 120 day OOS period, and therefore available to supply RHR service water to Unit 2 prior to_ expiration of the 67 day LCO.
CECO has also evaluated the ability to achieve and maintain Unit 2 in a safe shutdown condition following a design basis fire without the 1 A RHRSW subsystem. This evaluation indicated that Unit 2 could be brought to a shutdown condition with reactor pressure at 18.5 psia and a maximum Torus temperature of 185 degrees F. This -
condition would be achieved by implementing the following actions:
Gravity feed of Closed Contaminated Storage Tank (CCST) water to the Torus.
Rejection of hot water from the Torus with an RHR pump.
Replenishment of the CCST with river water. This would be purnped to the CCST with the diesel driven fire pumps, and then gravity fed to the Torus.
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SLIDE #17 of 18
- ATLTHMENT 2 FIRE PROTECTION PROGRAM AND SAFE SHUTDOWN EQUIPMENT SAFETY SIGNIFICANCE CECO believes that cold shutdown repairs could be implemented to restore the 1 A
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RHRSW subsystem and achieve a cold shutdown condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Existing additional hourly fire watches assigned to the potentially affected areas in the normal course of outage work would have detected and minimized a design basis fire.
Administrative procedures governing transient combustibles and the use of fire ignition sources were in place to minimize the probability of fire initiation.
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