IR 05000266/2004010
| ML050030120 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/03/2005 |
| From: | Reynolds S Division Reactor Projects III |
| To: | Koehl D Nuclear Management Co |
| References | |
| IR-04-010 | |
| Download: ML050030120 (33) | |
Text
ary 3, 2005
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 FIRE PROTECTION TRIENNIAL BASELINE INSPECTION NRC INSPECTION REPORT 05000266/2004010(DRS);
Dear Mr. Koehl:
On November 19, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Point Beach Nuclear Plant, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on November 19, 2004, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to 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, one NRC-identified finding of very low safety significance (Green) was identified in the report. This finding was determined to involve a violation of NRC requirements. However, because the violation was of very low safety significance and because the issue was entered into your corrective program, the NRC is treating this finding as a Non-Cited Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Point Beach Nuclear Plant facility.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by Patrick Louden Acting for/
Steven A. Reynolds, Deputy Director Division of Reactor Projects Docket Nos. 50-266; 50-301 License Nos. DPR-24; DPR-27 Enclosure: Inspection Report 05000266/2004010(DRS);
w/Attachment: Supplemental Information cc w/encl: F. Kuester, President and Chief Executive Officer, We Generation J. Cowan, Executive Vice President Chief Nuclear Officer D. Cooper, Senior Vice President, Group Operations J. McCarthy, Site Director of Operations D. Weaver, Nuclear Asset Manager Plant Manager Regulatory Affairs Manager Training Manager Site Assessment Manager Site Engineering Director Emergency Planning Manager J. Rogoff, Vice President, Counsel & Secretary K. Duveneck, Town Chairman Town of Two Creeks Chairperson Public Service Commission of Wisconsin J. Kitsembel, Electric Division Public Service Commission of Wisconsin State Liaison Officer
SUMMARY OF FINDINGS
IR 05000266/2004010(DRS); 05000301/2004010(DRS); 11/01/2004 - 11/19/2004; Point Beach
Nuclear Plant, Units 1 and 2; Fire Protection Triennial Baseline Inspection.
This report covers an announced triennial fire protection baseline inspection. The inspection was conducted by Region III inspectors and a fire protection contractor. One Green Non-Cited Violation (NCV) of very low safety significance was 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
No findings of significance were identified.
Cornerstone: Mitigating Systems
- Green.
A finding of very low safety significance was identified by the inspectors for failure to align safe shutdown instrumentation to an electrical bus with a battery charger in procedure AOP-10A, Safe Shutdown - Local Control. Specifically, the procedure aligned Units 1 and 2 safe shutdown instrumentation to a 125Vdc bus that did not have a battery charger available to support the selected instrumentation.
This issue was more than minor because it affected the procedure quality attribute of the Reactor Safety Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events. Specifically, the safe shutdown instrumentation associated with this bus, without a battery charger, could potentially become inoperable as the voltage of the battery supplying the bus decreased. Operators could select another bus with a safe shutdown inverter, however, the procedure did not direct this action. To correct this procedural error, the licensee issued Temporary Change Notice 2004-0762. This issue was entered into the licensees corrective action program as CAP059262 and CE014635. The issue was of very low safety significance because it did not represent an actual loss of a safety function. The issue was a Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B,
Criterion V, Instruction, Procedures, and Drawings, for failure to provide a procedure of a type appropriate to the circumstances. (Section 4OA5)
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
Summary of Plant Status
Units 1 and 2 operated at or near full power throughout the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of this inspection was to review the Point Beach Nuclear Plants (PBNPs)
Fire Protection Program (FPP) for selected risk-significant fire areas. 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 Nuclear Regulatory Commissions (NRCs) regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The inspectors used the PBNPs Individual Plant Examination of External Events (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire areas chosen for review during this inspection were:
Fire Area Description of Fire Area Reviewed A01-E General Plant Area - Turbine Building (Specifically Fire Zone 224 - Alternate Shutdown Panel Zone)
A30 Cable Spreading Room A31 Control Room A33 HVAC Equipment Room For each of these fire areas, the inspection focused on the fire protection features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of licensee commitments, and changes to the FPP.
.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
The Code of Federal Regulations (CFR) Title 10, Part 50, Appendix R,Section III.G.1, required the licensee to provide fire protection features that were capable of limiting fire damage to structures, systems, and components (SSCs) important to safe shutdown.
The SSCs that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features that were capable of limiting fire damage to the SSCs so that:
- One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) was free of fire damage; and
- Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72-hours.
Specific design features for ensuring this capability were specified by 10 CFR Part 50, Appendix R, Section III.G.2.
a. Inspection Scope
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 in accordance with the criteria discussed above. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included the fire protection safe shutdown analysis.
The inspectors also reviewed the operators ability to perform the necessary manual actions for achieving safe shutdown by reviewing procedures, the accessibility of safe shutdown equipment, and the available time for performing the actions.
The inspectors reviewed the PNPPs Updated 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 significance were identified.
.2 Fire Protection of Safe Shutdown Capability
Title 10 CFR Part 50, Appendix R, Section III.G.2, required separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. Title 10 CFR Part 50, Appendix R, Section III.G.3, required that, if the guidelines cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.
a. Inspection Scope
For each of the selected fire areas, the inspectors reviewed the licensees Safe Shutdown Analysis (SSA) to ensure that at least one post-fire safe shutdown success path was available in the event of a fire in accordance with the criteria discussed above.
This included a review of manual actions required to achieve and maintain hot shutdown conditions and to make the necessary repairs to reach cold shutdown within 72-hours.
The inspectors also reviewed procedures to determine whether or not adequate direction was provided to operators to perform these manual actions. Factors such as timing, access to the equipment, and the availability of procedures, were considered in the review.
The inspectors also evaluated the adequacy of fire suppression and detection systems, fire area barriers, penetration seals, and fire doors to ensure that at least one train of safe shutdown equipment was free of fire damage. To accomplish this, the inspectors observed the material condition and configuration of the installed fire detection and suppression systems, fire barriers, construction details, and supporting fire tests for the installed fire barriers. In addition, the inspectors reviewed licensee documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, Fire Hazard Analysis (FHA) reports, SSA, and National Fire Protection Association (NFPA) codes to verify that the fire barrier installations met license commitments.
b. Findings
No findings of significance were identified.
.3 Post-Fire Safe Shutdown Circuit Analysis
Title 10 CFR Part 50, Appendix R, Section III.G.1, required that SSCs important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Options for providing this level of fire protection were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function was required for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2, an alternative or dedicated shutdown capability and its associated circuits, were required to be provided that was independent of the cables, systems, and components in the area. For such areas, 10 CFR Part 50, Appendix R, Section III.L.3, specifically required the alternative or dedicated shutdown capability to be physically and electrically independent of the specific fire areas and capable of accommodating post-fire conditions where offsite power was available and where offsite power was not available for 72-hours.
a. Inspection Scope
The inspectors performed a review of the licensees SSA and Safe Shutdown Equipment List (SSEL) to determine whether the licensee had appropriately identified and analyzed the safety related and non-safety related cables associated with safe shutdown equipment located in the selected plant fire zones in accordance with the criteria discussed above. The inspectors review included the assessment of the licensee's electrical systems and electrical circuit analyses.
The inspectors evaluated a sample of safety and non-safety related cables for equipment in the selected fire areas to determine if the design requirements of Section III.G of Appendix R to 10 CFR Part 50 were being met. This included determining that hot shorts, open circuits, or shorts to ground would not prevent implementation of safe shutdown.
b. Findings
No findings of significance were identified.
.4 Alternative Shutdown Capability
Title 10, Part 50, Appendix R,Section III.G.1, required the licensee to provide fire protection features that were capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Specific design features for ensuring this capability were provided in 10 CFR Part 50, Appendix R, Section III.G.2. Where compliance with the separation criteria of 10 CFR Part 50, Appendix R, Section III.G.2, could not be met, an alternative or dedicated shutdown capability be provided that was independent of the specific fire area under consideration. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72-hours and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those predicted for a loss of normal alternating current power, and the fission product boundary integrity must not be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).
a. Inspection Scope
The inspectors reviewed the licensees systems required to achieve safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions in accordance with the criteria discussed above. 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.
b. Findings
No findings of significance were identified.
.5 Operational Implementation of Alternate Shutdown Capability
The PBNPs FPP described the means by which safe shutdown could be achieved to meet the requirements of 10 CFR Part 50, Appendix R, Sections III.G.3 and III.L. The PBNPs safe shutdown analysis identified the minimum number of components and plant systems necessary for achieving Appendix R safe shutdown performance goals. The FPP accomplished safe shutdown by isolating power to most plant equipment and then used an emergency diesel generator or the station blackout turbine generator to power equipment necessary for plant shutdown. Numerous manual actions were required with four operations staff working together to shutdown both Unit 1 and Unit 2.
a. Inspection Scope
From November 1, 2004 through November 5, 2004, the inspectors performed a review of the licensees operating procedures, which augment the post-fire safe shutdown procedures to determine if the licensee complied with the criteria discussed above. The review focused on ensuring that all required functions for post-fire safe shutdown and the corresponding equipment necessary to perform those functions were included in the procedures. The review also looked at operator procedural training, as well as consistency between the operations shutdown procedures and any associated administrative controls.
b. Findings
Introduction:
The inspectors identified an unresolved item associated with a lack of time critical manual actions in procedure FOP 1.2 Potential Fire Affected Safe Shutdown Equipment, Revision 6 and for other potentially non-conservative Appendix R response times. The inspectors could not evaluate the risk significance of this issue until the licensee completed additional reviews and calculations to resolve this issue.
Description:
The inspectors reviewed and walked down the fire protection procedures AOP-10A, Safe Shutdown - Local Control, Revision 39 and AOP-10C, Safe Shutdown Following a Fire at PAB [Primary Auxiliary Building] 26 Foot Central, Revision 0. The inspectors evaluated the two procedures for consistency, adequacy, operator training and operator familiarity. The two fire protection procedures were common to both units and were to be implemented as fire area specific (i.e., alternate shutdown (ASD))
procedures for the Control Room, Cable Spreading Room, and the 26 foot elevation of the PAB.
The inspectors determined if:
- (1) the procedures used for ASD were consistent with the safe shutdown analysis (SSA) methodology and assumptions;
- (2) the procedures were written so that the operator actions could be correctly performed within the times assumed in the SSA;
- (3) the training program for operators included ASD capability; and
- (4) personnel required to achieve and maintain the plant in hot standby from ASP could be provided with normal on-site staff, exclusive of the fire brigade.
In 2000, the licensee issued CAP012654, Contractor Spurious Opening of the 851 Safety Injection (SI) Valves and Potential Sump Flooding, dated September 22, 2000, and associated LER 266/2000-008-00, Inadequate Procedural Guidance for Spurious Operation of Valves During Appendix R Alternate Shutdown, dated October 19, 2000.
The two documents stated that according to Appendix R calculations an unrecoverable condition could develop from drain-down of the refueling water storage tank (RWST) to the containment sump through a spuriously opened SI-851A/B valve. In addition, the LER stated that the time for this condition to develop was 15-minutes. To isolate this draining the RHR Suction Valves must be closed within this period of time. During this inspection, however, the inspectors observed that procedure AOP-10A only ensured that RHR Suction Valves (i.e., 1SI-856A, 1SI-856B, 2SI-856A and 2SI-856B) were shut at 22-minutes and for procedure AOP-10C at 25-minutes. As a result, the inspectors were concerned that there would not be adequate water inventory available for reactor makeup during the 72-hours required to reach cold shutdown. The inspectors questioned why the procedures did not ensure the affected valves were closed within the LER specified time period (i.e., 15-minutes) to isolate the potential diversion of water from the RWST.
The licensee stated that the LER had been issued in error since there was no approved calculation available to support the 15-minute time period. After the inspectors requested additional clarification, the licensee located an unapproved calculation (i.e., a spreadsheet) used to support the 15-minute time period. The licensees review of the unapproved computer spreadsheet indicated that the 15-minutes was based on RCP seal leakage which had not been accounted for in the licensees previous calculations for inventory lost from the RWST.
Specifically, the RCP seals would be potentially damaged after 13-minutes without seal cooling from the charging pumps. The procedures AOP-10A and AOP-10C remove power to most components in the plant. This included having power removed to the charging pumps. The charging pumps for seal cooling are not restored in AOP-10A and AOP-10C until after 30-minutes. The licensee stated that the calculated RCP seal leakage was 21.5 gallons per minute (gpm) for each RCP after the RCP seals are damaged.
The licensee stated that the unapproved computer spreadsheet assumptions were overly restrictive and that the current timeline for manual actions was acceptable. For example, the spreadsheet calculation assumed a number of worst case scenarios, which included simultaneous spurious operation of the two drain-down flow paths from the RWST and all failures were assumed to occur instantaneously. The licensee stated that the assumptions used in the unapproved computer spreadsheet led to the LER statement that the RWST should be isolated within 15-minutes for an Appendix R fire.
This issue regards the potential for not having adequate water inventory available for reactor makeup during the 72-hours required to reach cold shutdown due to the inventory lost due to RCP leakage and the potential drain-down of the RWST (i.e., through a spuriously operated valve to the containment sump) from an Appendix R fire. As a result, the inspectors were concerned that the licensee had the potential for a non-conservative Appendix R manual action response time in their procedures for ensuring that the RWST was isolated from draining to containment. In addition, not having RCP seal cooling for 30-minutes may be an unacceptable condition. The licensee wrote a CAP to formalize the un-approved evaluation and prepare a new calculation. The licensee entered this issue into their corrective action program as CAP060624, Potentially Non-Conservative Appendix R Response Times, dated November 18, 2004.
The inspectors also identified a similar instance where the licensee did not identified the time critical manual actions in FOP 1.2, Potential Fire Affected Safe Shutdown Equipment, Revision 6. Time critical manual actions are required to ensure that the RWST is isolated to prevent drain-down to the containment sump. As a result, the licensee issued CAP 060641, FOP 1.2 Enhancement Recommendation, November 19, 2004, to review this issue. In addition, the licensee initiated compensatory actions, hourly fire rounds were assigned for all areas where a fire could potential cause a spurious actuation and a subsequent drain-down of the RWST.
Pending a review of the licensees assumptions and calculations; and completion of the review of FOP 1.2, this issue is an Unresolved Item (URI 05000266/2004010-01; 05000301/2004010-01).
.6 Communications
Title 10, Part 50, Appendix R,Section III.H, required that a portable communications system be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of the plant security force. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage.
a. Inspection Scope
The inspectors reviewed the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties to determine compliance with the criteria discussed above. The inspectors also conducted a review to determine that sufficient channels were available to support safe shutdown implementation and that repeaters were powered by an emergency power source.
b. Findings
No findings of significance were identified.
.7 Emergency Lighting
Title 10, Part 50, Appendix R,Section III.J., required that fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual eight-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas.
a. Inspection Scope
The inspectors performed a walkdown of the fire areas and the access/egress routes to determine that adequate emergency lighting existed in accordance with the criteria discussed above.
b. Findings
No findings of significance were identified.
.8 Cold Shutdown Repairs
Title 10, Part 50, Appendix R,Section III.L.5, required that equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72-hours.
Materials for such repairs shall be readily available onsite, and procedures shall be in effect to implement such repairs.
a. Inspection Scope
The inspectors examined the licensees ability to conduct cold shutdown repairs in accordance with the 72-hour requirement discussed above. The inspection team reviewed the licensees procedure for implementation of cold shutdown repairs. The inspectors assessed whether the licensee identified all the appropriate tools and equipment needed to complete the required cold shutdown repairs. The inspectors review focused on ensuring that the tools and equipment were readily available onsite and designated solely for those repairs.
b. Findings
No findings of significance were identified.
.9 Fire Barriers and Fire Zone/Room Penetration Seals
Title 10, Part 50, Appendix R,Section III.M, required that penetration seal designs be qualified by tests that are comparable to tests used to rate fire barriers.
a. Inspection Scope
The inspectors reviewed the test reports for three-hour rated barriers installed in the plant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with tested configuration in accordance with the criteria discussed above. In addition, the inspectors reviewed the fire loading for selected areas to ensure that existing barriers would not be challenged by a potential fire.
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems, Features and Equipment
a. Inspection Scope
The inspectors reviewed the material condition, operations lineup, operational effectiveness, and design of fire detection systems, fire suppression systems, manual fire fighting equipment, fire brigade capability, and passive fire protection features. The inspectors reviewed deviations, detector placement drawings, fire hose station drawings, halon and/or carbon dioxide system pre-operational test reports, and fire hazard analysis reports to ensure that selected fire detection systems, sprinkler systems, portable fire extinguishers, and hose stations were installed in accordance with their design, and that their design was adequate given the current equipment layout and plant configuration.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The inspectors conducted a review to determine that adequate compensatory measures were put in place by the licensee for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features. The inspectors also reviewed 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 significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed the corrective action program procedures and samples of corrective action documents to assess whether or not the licensee was identifying issues related to fire protection at an appropriate threshold and entering them in the corrective action program. The inspectors reviewed selected samples of condition reports, work orders, design packages, and fire protection system non-conformance documents.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
a. Inspection Scope
(Closed) Unresolved Item URI 50-266/2004006-02; 50-301/2004006-02: In a review conducted from November 1, 2004 through November 5, 2004, the inspectors identified that the licensees procedure AOP-10A, Safe Shutdown - Local Control, Revision 38, failed to align safe shutdown instrumentation to an electrical bus with a battery charger.
Specifically, the procedure aligned Units 1 and 2 safe shutdown instrumentation to a 125Vdc bus that did not have a battery charger available to support the selected instrumentation (see Sections 4OA2.1 and 4OA2.b.(2) of Inspection Reports 05000266/2004006; 05000301/2004006 and 05000266/2004008; 05000301/2004008, respectively for details).
b. Findings
Introduction:
A Green NCV was identified for failure to provide a procedure of a type appropriate to the circumstances during alignment of safe shutdown instrumentation to an electrical bus in AOP-10A, as required by 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings.
Analysis:
The inspectors determined that the licensees AOP-10A procedure aligned Units 1 and 2 safe shutdown instrumentation to a 125Vdc safety-related battery bus without a battery charger. The safe shutdown instrumentation associated with this bus could potentially become inoperable as the voltage of the battery supplying the bus decreased. Operators could select another bus with a safe shutdown inverter, however, the procedure did not direct this action. As a result, the procedure was not of a type appropriate to the circumstances and was a performance deficiency warranting a significance evaluation in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, issued on June 20, 2003. The inspectors determined that the finding was more than minor because it affected the procedure quality attribute of the Reactor Safety Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events.
The inspectors completed a significance determination of this issue using IMC 0609, "Significance Determination Process," dated March 21, 2003, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," dated September 10, 2004. The inspectors determined that the finding did not degrade short term decay heat removal capability or reactivity control; result in a design or qualification deficiency or an actual loss of safety function; or involve internal or external initiating events. Therefore, the finding was considered to be of very low safety significance (Green).
Enforcement:
Title 10, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions and/or procedures, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions and/or procedures.
Contrary to this, prior to September 16, 2004, the licensees procedure AOP-10A, Safe Shutdown - Local Control, Revision 38, failed to align Units 1 and 2 safe shutdown instrumentation to a 125Vdc safety-related battery bus with a battery charger. As a result, the procedure was not of a type appropriate to the circumstances and the safe shutdown instrumentation associated with this bus, without a battery charger, could potentially become inoperable as the voltage of the battery supplying the bus decreased. To correct this procedural error, the licensee issued Temporary Change Notice 2004-0762. This violation is associated with a finding that is characterized by the SDP as having very low risk significance (Green) and is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. This issue was entered into the licensees corrective action program as CAP059262 and CE014635.
(NCV 05000266/2004010-02; 05000301/2004010-02)
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. Koehl and other members of licensee management at the conclusion of the inspection on November 19, 2004. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
No interim exits were conducted.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- H. Abelquader, Appendix R. Engineer
- G. Casadonte, Fire Protection Coordinator
- S. Cassidy, Communications Manager
- R. Davenport, Production Planning Manager
- B. Dungan, Operations Manager
- F. Flentje, Regulatory Affairs Principal Analyst
- R. Harper, Shift Manager
- F. Hennessy, Programs Engineering Manager
- D. Koehl, Site Vice President
- C. Krause, Regulatory Affairs Senior Engineer
- R. Ladd, Fire Protection Engineer
- C. Lambert, NMC Vice President - Engineering
- J. McCarthy, Director-Site Operations
- B. McLean, Fire Protection Engineer
- R. Milner, Business Support Manager
- L. Peterson, Design Engineering Manager
- D. Schuelke, Acting Radiation Protection Manager
- J. Schweitzer, Director-Site Engineering
- J. Shaw, Plant Manager
- G. Sherwood, Engineering Programs Manager
Nuclear Regulatory Commission
- P. Krohn, Senior Resident Inspector
- M. Morris, Resident Inspector
A1 Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000266/2004010-01; URI Potentially Non-Conservative Appendix R Response Times
- 05000301/2004010-01 (Section 1R05.5)
- 05000266/2004010-02; NCV Failure to Ensure That a Safe Shutdown Procedure Directed
- 05000301/2004010-02 Alignment of Instrumentation to a Direct Current Bus with a Battery Charger (Section 4OA5)
Closed
- 05000266/2004006-02; URI Resident Inspector Review of a Safe Shutdown Procedure
- 05000301/2004006-02 That Directed Alignment of Instrumentation to a Direct Current Bus Without a Battery Charger (Section 4OA5)
- 05000266/2004010-02; NCV Failure to Ensure That a Safe Shutdown Procedure Directed
- 05000301/2004010-02 Alignment of Instrumentation to a Direct Current Bus with a Battery Charger (Section 4OA5)
Discussed
None.
A2 Attachment