IR 05000528/1991042
| ML17306A292 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/21/1991 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A291 | List: |
| References | |
| 50-528-91-42, 50-529-91-42, 50-530-91-42, NUDOCS 9112100017 | |
| Download: ML17306A292 (16) | |
Text
Report Nos.:
Docket Nos.:
License Nos.
Licensee:
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
50-528/91-42; 50-529/91-42, 50-530/91-42 50-528, 50-529, 50-530 NPF-41, NPF-51, NPF-74 Arizona Nuclear Power Project P.
0.
Box 53999, Station 9012 Phoenix, Arizona 85072-3999 Facility Name:
Palo 'Verde Nuclear Generating Station (PVNGS) Units 1,2, and
Inspection at:
Palo Verde Site, Mintersburg, Arizona Inspection Conducted:
October 21-25, 1991 Inspectors P.
P. Narbut, Reactor Inspector, RV Approved by:
~Summar lrsc, le Reactor Safety Branch lr m/
e one Ins ection October 21-25 1991 (Re ort Nos.
50-528/91-42 50-529/91-42, Areas Ins ected:
An announced routine inspection by a regional inspector of
>re pro ec ion issues.
The inspection effort focused on reportability aspects of fire protection problems previously identified by the licensee.
Additionally, the licensee's overall emergency lighting actions were reviewed.
Results:
General Conclusions on Stren ths and Meaknesses:
Areas Stren th and Meakness:
No telling strengths or weaknesses were identified during this inspection due to the narrow scope of the inspection.
It was suggested to the licensee that when a highly complex reportability analysis was required, the licensee might consider submitting a voluntary LER or, alternately, enhancing their procedures to provide a more structured and detailed reportabi lity analysis for management review.
cyy )P)00017 9 OOp~gg p DR ADOCK 05O
Si nificant Sa fet tlatters:
None Summar of Violations or Deviations:
None 0 en Items Summar One unresolved item was close.Persons Contacted DETAILS
- L. Henson, Electrical Supervisor, Site Nuclear Engineering
"M. Hypse, Electrical Supervisor, Balance of Plant
- K. Clark, Senior Engineer, Licensing
"S. Gross, Engineer El Paso Electric Co.
- D.
L. Kanitz, Compliance Engineer
"D. Alan Johnson, Compliance Supervisor
"R. Adney, Manager, Unit 3
- G. Overbeck, Director, Site Technical Support
.~R. Fullmer, Manager, equality Assurance and Monitoring
"D.
H. Kissinger, equality Engineering Supervisor
- S. J.
Kanter, Site Representative RE P.
Guron, Electrical Engineer The inspector also interviewed other licensee employees during the course of the inspection
~Denotes those attending the exit meeting on October 25, 1991.
Fire Protection Issues (64704)
General The inspector examined two fire protection problem areas which had been identified by the licensee.
The inspector focused on the reportabi lity aspects of the problems'pecifically, the inspector examined the issues to determine if the licensee had made the proper reportability determinations as required by their technical specifications.
The inspector concluded that the issues were not reportable, and that the licensees determinations were proper and in accordance with requirements.
Details l.
Emergency Light Miring In a previous inspection report (50-528/91-30)
an inspector examined some specific problems with fire protection emergency lighting.
One of these was Condition Report/Disposition Request (CRDR) 91004.
The identified problem was that all the lights in some important spaces might be lost due to wiring problems.
The design intent of lighting at Palo Verde was that upon loss of normal lighting, about 10X if the florescent fixtures would remain on, powered by Class 1E power.
This was called "essential lighting."
Should essential lighting be lost either wholly or in part, each space involved in safe shutdown was further equipped with battery powered sealed beam lights called "emergency" lights.
The emergency lights should automatically turn on upon loss of voltage to the essential lights in the same space, thus maintaining lighting.
The
licensee found, durinq their walkdowns and testinq of lighting that in some cases the emergency lights in a space were not triggered by the essential lights in the same space.
In the inspection report 50-528/91-30, the inspector questioned whether the discovered condition should be reported to the NRC as a
Licensee Event Report (LER).
The inspector had carried the item as Unresolved Item 50-528/91-30-01.
During the inspection, the inspector examined the details developed by the licensee and reviewed the reportability requirements of the technical specification.
Re uirements Repor tabi lity requirements for fire protection in the licensees technical specification state:
"6.9.3 Violations of the requirements of the fire protection
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rogram described in the Final Safety Analysis Report which would ave adversely affected the ability to achieve and maintain safe shutdown in the event of a fire shall be reported in accordance with
CFR 50.73."
Therefore, the inspector focused on whether:
The wiring problem was a violation of the fire protection
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rogram described in the FSAR and he problem was of a magnitude that'he ability to achieve and maintain safe shutdown was adversely affected.
Licensee Evaluation The licensee's evaluation of reportabi lity for this event concluded the situation was not reportable based on an analysis of CRDR No.
91004.
The analysis was performed by compliance personnel and recorded on a CRDR Status Log memorandum dated June 5, 1991.
The memorandum states that the condition does not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
The rationale presented in the memo was that actions can be performed using hand held portable lights and that a study of the problem provided other compensatory actions for each specific case where an emergency light was not triggered by an essential light in the same area.
The licensee's written (June 5, 1991) evaluation by Compliance personnel did not specifically address whether the problem was also a violation of a fire protection program.
The inspector questioned Compliance personnel on this matter.
They stated that the decision as to whether this problem was a violation of the fire protection program was not germane to a reportabi lity decision since both conditions of the technical specification 6. 9. 3 have to be met for a positive reportabi lity determinatio The Compliance personnel introduced other studies for related essential lighting problems which concluded essential lighting problems were not reportable.
These studies included an attachment to Problem Resolution Sheet PRS 0020001, prepared by Compliance.
This problem dealt with insufficient levels of illumination provided by -the florescent essential lighting in certain areas.
The licensee concluded this parallel problem was not reportable.
The decision was based on a memorandum by Licensing (memo 161-03999 dated June
1991).
This memorandum was preceded by an earlier memorandum (memo 161-53919 dated May 2, 1991).
Both memorandums provide positions on essential lighting.
The May 2, 1991 memorandum stated that the FSAR design basis had not been violated and also stated that essential lighting was not discussed in Appendix R of 10CFR50.
The June 13, 1991 memorandum was a reevaluation.
This memorandum concluded the committments in the FSAR were inconsistant within the FSAR.
The Licensing conclusion was difficult to understand as written.
It stated:
"Licensing has determined that the placement of essential lights where Appendix R lights are required is not a regulatory requireme'nt therefore, the conditions described in PRS 002001 are not outside the regulatory design basis for the Essential Lighting System.
However, the licensing design basis for the system does include placement of the essential lights where Appendix R emergency lights are required.
Thus, the conditions described in PRS 0002001 are outside the current licensing design basis for the Essential Lighting System."
The inspector met with Licensing and Compliance personnel to determine what the licensee meant.
The personnel stated that their conclusion was that Appendix R was not violated but that the FSAR committment for essential lighting wasn't met.
They elaborated further that'the FSAR, as written, had not been clear and was contradictory within itself and would be clarified.
The document did not clearly address whether the fire protection plan had been violated (the first condition of reportabi lity) but licensee personnel considered that there was no adverse effect on the -ability to achieve safe shutdown (the second condition of reportability).
NRC Evaluation The inspector reviewed the fire protection program presented in the FSAR and concluded that essential lighting is part of the fire protection e
rogram and is a condition of the facility license.
Therefore, essential ighting contrary to that described in the FSAR would be a violation of the fire protection program, a license conditio. The inspector's review of the second condition of reportabi lity, whether the licensee's ability to achieve safe shutdown would be adversely affected, was done by reviewing the detailed effects of the miswiring problems.
These details are provided in an evaluation of CRDR No.
91004.
The inspector reviewed the evaluation and discussed it with the lighting design engineer.
In summary, the engineer determined 'that there were 125 cases in total for. all three Palo Verde units that had the potential for having the miswiring problem.
Of these, 42 cases were discounted because the fire which would affect the essential lights was a control room fire which already has an action to abandon essential lights and activate emergency lights.
The remaininq 83 cases involve a fire in an area other than the control room.
The studied fire might affect the lighting needed in a different area requiring operator action.
The engineer conservatively assumed that the lighting would be lost in the operations area because the routing of the lighting is not known (it was field run during construction).
In short, the 83 cases are a conservative maximum total for three units.
The number of potential cases in a single fire in a single unit are much less, perhaps one or two, but cannot be determined without extensive wire tracing.
Engineering judgement indicates the number of cases that would potentially come into play in any given fire are small.
Therefore, licensee's ability to achieve safe shutdown would not be adversely affected since the use of hand held lights for such cases was anticitipated by the regulations, i.e.
emergency use.
In addition, for the cases of non-control room fires, most actions can be taken from the control room. Further, the licensee has added compensatory actions to the Pre-Fire Strategies Hanual to identify actions to ensure emergency lighting is provided in each fire response area that might be affected.
The inspector, therefore, concluded that from a strict regulatory basis the problems with essential lightin~ were not reportable.
The problems reviewed included the problem with miswiring (where emergency lights are not triggered by loss of the essential light in the same area)
and the problem with insufficient essential lighting when only essential lighting was used.
Licensee Corrective Actions The licensee discussed the corrective actions taken and planned and provided documentation, such as design changes, to substantiate their statements.
In summary, the lighting at the time of inspection was as follows:
Emergency lighting (sealed beam battery powered lights) have been upgraded such that all lighting required for Appendix R is complete.
Other emergency lighting (for non-Appendix R usages is not yet done but is being worked on).
0
Essential lighting (generally florescent fixtures) have been upgraded in Unit 2 and will be completed in Units 1 and 3 in 1991 er the licensee's schedules.
he licensee plans to rewi re those emergency lights which are not triggered by essential lights in the same space.
The design change is planned to be issued by November 15, 1991 and the work,'in all three units, is planned to be done by early 1992.
Based on all the above, unresolved item 50-528/91-30-01 is considered closed.
The licensee's response, dated July 1, 1991, to the NRC letter dated May 29, 1991, regarding essential lighting concerns was reviewed and determined to be acceptable.
2.
Y~dLi hti The second problem area examined by the inspector for potential reportability had to do with the absence of'emergency lights in outdoor areas.
This problem was identified by engineering personnel during their examination of lighting.
The problem was identified on Condition Report/Disposition Request (CRDR) 91001.
The CRDR described five cases where outdoor paths used to transit from one building to another were not lighted with emergency lights.
In addition, one outdoor valve which might have to be closed on the reactor make-up water tank, was not provided with emergency lights.
Licensee Evaluation The licensee concluded in thei r reportabi lity evaluation that the condition was not reportable.
This conclusion was documented in CRDR Status Log Evaluation dated June 4, 1991.
Compliance personnel justified the condition based on the statement that security lighting was originally used to satisfy Appendix R requirements for operator actions outside the power block.
They further stated that hand held lights were available and, therefore, the ability to achieve and maintain safe shutdown was not affected.
NRC Evaluation The inspector walked down the outside transit areas with a licensed operator and observed the valve which had to be manipulated.
The inspector concluded all such actions could easily be done'ith a
f1 as hl ight.
In addition, the inspector discussed the situation with regional security inspectors and NRC headquarters fire protection personnel.
It was agreed that security lights are a very reliable source of lighting and although the security lights were not specifically described in the fire protection plan, they could be.
The licensee was preparing an FSAR change to recognize the absence of emergency lights in the yard are The inspector concluded the absence of emergency lights in the yard areas did not affect the ability to achieve and maintain safe shutdown.
The inspector further concluded that the problem was a
violation of the fire protection plan in that emergency lighting was to have been provided for access and egress paths to areas necessary for achieving and maintaining safe shutdown.
However, since both technical specification conditions for reportabi lity were not met (as explained in paragraph 1 above),
the problem is not reportable.
The inspector cons>dered this matter closed.
No violations or deviations were identified.
~Fit.
N ti The inspector met with the licensee management representatives denoted in paragraph 1 on October 25, 1991.
The scope of.the inspection and the findings as described in this report were discusse I 0