ML022530113
| ML022530113 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/09/2002 |
| From: | Ogle C Division of Reactor Safety II |
| To: | Scarola J Carolina Power & Light Co |
| References | |
| EA-00-022, EA-01-310 IR-02-008 | |
| Download: ML022530113 (17) | |
See also: IR 05000400/2002008
Text
EA-01-310
Carolina Power & Light Company
ATTN: Mr. James Scarola
Vice President - Harris Plant
Shearon Harris Nuclear Power Plant
P. O. Box 165, Mail Code: Zone 1
New Hill, NC 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - NRC SUPPLEMENTAL
INSPECTION REPORT 50-400/02-08
Dear Mr. Scarola:
On May 31, 2002, the Nuclear Regulatory Commission (NRC) completed the onsite portion of a
supplemental inspection at your Shearon Harris Nuclear Power Plant. A preliminary exit was
held with you and other members of your staff on May 31, 2002, to discuss the results of that
effort. Following completion of additional review in the Region II office, a final exit was held with
Mr. J. Caves on September 6, 2002. The enclosed report documents our findings from this
inspection.
This supplemental inspection was an examination of your problem identification, root cause
evaluation, extent of condition determination, and corrective actions associated with a White
finding identified in the mitigating systems cornerstone. The White finding involved a violation
of your fire protection program resulting from a Thermo-Lag fire barrier assembly (wall) which
had an indeterminate fire resistance rating.
Based on the results of this inspection, the NRC determined that portions of your actions to
resolve this issue were appropriate. However, the NRC noted that your planned corrective
actions included the use of local manual actions as opposed to one of the protection methods
identified in NRC Position C.5.b.(2) of Branch Technical Position (BTP) CMEB 9.5-1.
Therefore, the White finding will remain open pending further NRC review of your planned
corrective actions and the development of internal NRC inspection guidance in this area.
For administrative purposes, the White finding and a Severity Level III violation associated with
the Thermo-Lag fire barrier assembly between the B train switchgear room/auxiliary control
panel room and the A train cable spreading room which were previously identified in NRCs
letter dated April 16, 2002, are included in the enclosed report.
No findings of significance were identified during the inspection.
2
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publically 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/
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No.: 50-400
License No.: NPF-63
Enclosure: NRC Inspection Report No. 50-400/02-08
w/Attachment
cc w/encl:
Terry C. Morton, Manager
Performance Evaluation and
Regulatory Affairs CPB 9
Carolina Power & Light Company
Electronic Mail Distribution
Robert J. Duncan II
Director of Site Operations
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
Benjamin C. Waldrep
Plant General Manager--Harris Plant
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
James W. Holt, Manager
Support Services
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
(cc w/encl contd - See page 3)
3
(cc w/encl contd)
John R. Caves, Supervisor
Licensing/Regulatory Programs
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
William D. Johnson
Vice President & Corporate Secretary
Carolina Power & Light Company
Electronic Mail Distribution
John H. O'Neill, Jr.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, NW
Washington, DC 20037-1128
Beverly Hall, Acting Director
Division of Radiation Protection
N. C. Department of Environmental
Commerce & Natural Resources
Electronic Mail Distribution
Peggy Force
Assistant Attorney General
State of North Carolina
Electronic Mail Distribution
Public Service Commission
State of South Carolina
P. O. Box 11649
Columbia, SC 29211
Chairman of the North Carolina
Utilities Commission
P. O. Box 29510
Raleigh, NC 27626-0510
Robert P. Gruber
Executive Director
Public Staff NCUC
4326 Mail Service Center
Raleigh, NC 27699-4326
(cc w/encl contd - See page 4)
4
(cc w/encl contd)
Linda Coleman, Chairman
Board of County Commissioners
of Wake County
P. O. Box 550
Raleigh, NC 27602
Gary Phillips, Chairman
Board of County Commissioners
of Chatham County
Electronic Mail Distribution
Distribution w/encl:
R. Subbaratnam, NRR
RIDSNRRDIPMLIPB
PUBLIC
OFFICE
RII:DRS
RII:DRS
RII:DRS
RII:DRP
RII:EICS
SIGNATURE
LENAHAN
WISEMAN
PAYNE
BONSER
EVANS
NAME
LENAHAN
WISEMAN
PAYNE
BONSER
EVANS
DATE
9/4/2002
9/5/2002
9/5/2002
9/9/2002
9/9/2002
9/ /2002
9/ /2002
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
PUBLIC DOCUMENT
YES
NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML022530113.wpd
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
50-400
License No:
Report No:
50-400/2002-08
Licensee:
Carolina Power & Light (CP&L)
Facility:
Shearon Harris Nuclear Power Plant, Unit 1
Location:
5413 Shearon Harris Road
New Hill, NC 27562
Dates:
May 29 - September 6, 2002
Inspector:
J. Lenahan, Senior Reactor Inspector
Approved By:
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000400-02-08; Carolina Power and Light Company; on 5/29 - 9/6/02; Shearon Harris
Nuclear Plant, Unit 1; Supplemental inspection of Thermo-Lag fire barrier with indeterminate
fire resistance rating.
This inspection was conducted by a regional inspector. A White finding, which was previously
dispositioned in an NRC letter dated April 16, 2002, is identified in this report for administrative
purposes. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using IMC 0609 Significance Determination Process (SDP). Findings for which the SDP
does not apply may be Green or be assigned a severity level after management review. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 3, dated
July, 2000.
Cornerstone: Mitigating Systems
The NRC performed this supplemental inspection to assess the licensees corrective actions
associated with the Thermo-Lag fire barrier separating Train A and Train B safety related
cables in the Auxiliary Control Panel (ACP) room. The Thermo-Lag barrier provided a fire
resistance less than the minimum three-hour fire resistance rating required by the licensees
approved fire protection program. [Approved methods for achieving the required separation in
the ACP room are specified by NRC Branch Technical position (BTP) CMEB 9.5-1.] This
performance issue was previously documented in NRC Inspection Report 50-400/99-13 and
later characterized as having low to moderate risk significance (White) in an NRC letter dated
April 16, 2002.
During this supplemental inspection, performed in accordance with Inspection Procedure 95001, the inspector determined that the licensees problem identification, root cause and
extent of condition evaluation were adequate. The licensees corrective actions to resolve the
issues were ongoing. However, the inspector identified that the licensee intended to use local
manual operator actions in lieu of one of the methods identified in NRC Position C.5.b.(2) of
Branch Technical Position (BTP) CMEB 9.5-1. The licensee entered this issue into their
corrective action program and resolution is pending.
As a result, the White issue associated with the Thermo-Lag fire barrier will not be closed at this
time. The issue will remain open pending further NRC review of the licensees corrective
actions and the development of NRC inspection guidance on the use of local manual actions.
White. A violation of the fire protection program required by 10 CFR 50.48 and License
Condition 2.F was identified in an NRC letter dated April 16, 2002. The violation was for
failure to implement the NRC approved fire protection program safe shutdown system
separation requirements by maintaining a three-hour fire rated area separation barrier
between the B Train switchgear room/auxiliary control panel room and the A Train cable
spreading room. The existing Thermo-Lag barrier had an indeterminate fire resistance
rating.
Report Details
01
INSPECTION SCOPE
The NRC performed this supplemental inspection to assess the licensees corrective
actions associated with a degraded Thermo-Lag fire barrier separating Train A and Train
B safety related cables in the Auxiliary Control Panel (ACP) room. The Thermo-Lag
barrier provided a fire resistance rating less than the minimum three-hour fire resistance
rating required by the approved fire protection program. This performance issue was
previously documented in NRC Inspection Report 50-400/99-13 and later characterized as
having low to moderate risk significance (White) in an NRC letter dated April 16, 2002.
The inspector assessed problem identification, the licensees root cause and extent of
condition evaluation, and the licensees corrective actions to resolve the White finding in
their fire protection program. The inspector reviewed design change documents,
including design inputs, assumptions, and design evaluations; licensee self assessments;
and changes to operating procedures, fire protection procedures, and the safe shutdown
analysis. The inspector also examined in process plant modifications being performed on
02
EVALUATION OF INSPECTION REQUIREMENTS
02.01 Problem Identification
a.
Determination of who identified the issue and under what conditions.
During a fire protection inspection, conducted from November 1 - 5, 1999, and
documented in NRC Inspection Report 50-400/99-13, two unresolved items (URIs) were
identified by NRC inspectors. One of the URIs concerned the adequacy of a Thermo-Lag
wall which was designated as a three-hour fire barrier between the Train B switchgear
room and Train A safety related cables routed in the Auxiliary Control Panel (ACP) room.
The potential problem of using Thermo-Lag as a fire barrier material was identified to the
industry by the NRC in 1992 in Generic Letter (GL) 92-08 and NRC Bulletin 92-01. In
response to NRC Bulletin 92-01 and GL 92-08, the licensee conducted testing on a mock-
up of this Thermo-Lag wall. This testing showed the barrier failed the fire endurance test
acceptance criteria at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 48 minutes. The licensee then performed an
engineering evaluation which concluded that the as-constructed Thermo-Lag wall
provided sufficient protection for the area. The NRC did not agree with this determination.
Hence, this issue was identified by NRC. The licensee initiated Problem Evaluation
Report (PER) 99-006863 to document and disposition the URI identified during the
original fire protection inspection.
b.
Determination of how long the issue existed, and prior opportunities for identification.
The degraded fire barrier was installed during original plant construction. In response to
NRC Bulletin 92-01 and GL 92-08, the licensee identified that the Thermo-Lag barrier in
the ACP room did not have a 3-hour fire rating. However, licensee actions to address
this issue resulted in the acceptance of an inadequate Thermo-Lag fire barrier in 1997
(ESR 95-00620, Thermo-lag Fire Protection Issues Resolution, Revision 1).
2
Opportunities to identify this included a 1998 triennial fire protection Nuclear Assessment
Section audit and self-assessments of the fire protection program performed after 1997.
c.
Determination of the plant-specific risk consequences (as applicable) and compliance
concerns associated with the issue.
The degraded fire barrier was evaluated for a postulated fire in the B switchgear room that
could cause the Thermo-Lag fire barrier wall in the ACP area of the B switchgear room
fire area to fail. Failure of this wall exposed Train A cables, located within the enclosed
barrier area, to the postulated fire. The Train A cables behind the Thermo-Lag wall
affected the Train A auxiliary feedwater function and the steam generator A pressure
operated relief valve functions. The NRC assessment concluded that this event was in
the increased regulatory response (White) band. The results of the NRCs final
significance determination for the degraded fire barrier were documented in an NRC letter
to CP&L dated April 16, 2002, Subject: Final Significance Determination For a White
Finding and Notice of Violation (Shearon Harris Nuclear Power Plant - NRC Inspection
Report 50-400/00-09).
02.02 Root Cause and Extent of Condition Evaluation
a.
Evaluation of methods used to identify root causes and contributing causes.
The licensee initiated a Significant Adverse Condition Report, Action Request Number
53063, to evaluate and correct the problem associated with the Thermo-Lag wall. The
evaluation was performed using the systematic methods specified in the licensees
corrective action program as contained in CP&L procedure CAP-NGGC-0200. The
licensee concluded that the root cause of the White finding was the inappropriate use of
an analysis to accept changes to the NRC approved fire protection program.
Contributing causes were inadequate testing of installed fire barriers, too much reliance
on engineering evaluations, and failure to address design requirements.
b.
Level of detail of the root cause evaluation.
The inspector determined that the root cause evaluation was sufficiently detailed to
support the identified root and contributing causes. However, the root cause analysis did
not specifically identify why the inadequate fire testing of the installed fire barrier
occurred (root cause), or why there was too much reliance on GL 86-10 engineering
evaluations (contributing cause), or why there was a failure to adequately address design
requirements (contributing cause).
c.
Consideration of prior occurrences of the problem and knowledge of prior operating
experience.
The licensees investigation identified 218 matches from the INPO database including
GLs, NRC Bulletins and Information Notices, and LERs related to similar Thermo-Lag
issues at various nuclear power plants. The root cause evaluation found that the method
of resolution at HNP was unique from the others identified.
3
d.
Consideration of potential common causes and extent of condition of the problem.
In late 2000, the NRC identified additional Thermo-Lag fire barriers in the cable
spreading rooms which did not meet the requirements for three-hour fire barriers.
Because fire suppression systems (sprinklers) existed in most of these areas, the
licensee was able to downgrade the barriers to a one-hour fire rating and comply with the
approved fire protection program requirements. However, some areas did not have
sufficient spatial coverage by these sprinklers. The licensee also did not have sufficient
test data/documentation to adequately demonstrate that some as-built Thermo-Lag
barrier configurations in the cable spreading room provided a one-hour barrier. As a
result, the licensee has initiated a program to evaluate existing sprinkler coverage, install
new sprinklers as required, and test the existing barrier configurations to show they will
meet the one-hour requirement. These corrective actions are scheduled to be
completed by December 2002. The licensee performed a detailed self-assessment to
examine the overall fire protection program and compare it to applicable regulatory
requirements. The evaluation portion of the assessment has been completed.
Numerous findings were identified. Examples of findings include: illegible UFSAR
drawings, typographical errors in the UFSAR, unclear statements in the UFSAR and
SERs, factual errors in the UFSAR (e.g., location of hose stations), and lack of test
documentation to demonstrate the mullions, door frames, and transoms over fire doors
meet the fire protection program requirements.
02.03 Corrective Actions
a.
Appropriateness of corrective actions.
The inspector determined that portions of the licensees corrective actions were
adequate to resolve the issue. Corrective action included modifying the ACP fire area by
upgrading an existing concrete wall to a three-hour fire barrier. This reduced the
potential for fires starting in the Train B switchgear room from spreading to the ACP
room. In addition, design procedures were revised to emphasize the requirement that
adequate qualification testing be performed prior to changing the approved fire protection
program. However, the inspector identified that the licensee intended to use local
manual operator actions in lieu of protecting Train A and Train B cables in the new ACP
room fire area using a protection method specified in NRC Position C.5.b.(2) of Branch
Technical Position (BTP) CMEB 9.5-1. The licensee entered this issue into its corrective
action program as NCR 20020823, Fire Protection Manual Action Discrepancies.
As a result, the White issue associated with the Thermo-Lag fire barrier will not be closed
at this time. The issue will remain open pending further NRC review of the licensees
corrective actions and the development of internal NRC inspection guidance in this area.
b.
Prioritization of corrective actions.
The inspector concluded that the licensees corrective actions were properly prioritized to
address the risk. The changes to the ACP fire area were being worked concurrent with
completion of the engineering change. The inspector reviewed Engineering Change
(EC) 48802 to upgrade an existing concrete wall between Switchgear Room B and the
ACP room to a three-hour rated fire barrier. This work included sealing the existing
4
penetrations in the wall. The above actions transformed the ACP room into a new fire
area. The licensee has revised its fire plan (AOP-036, Safe Shutdown Following a Fire)
to address the newly created area. However, as discussed above, this plan includes the
use of local manual operator actions to achieve safe shutdown for some fire scenarios in
the new ACP room fire area as discussed above.
c.
Establishment of schedule for implementing and completing the corrective actions.
The inspector verified that the licensees corrective action program identified assigned
individuals, completion dates, and reference numbers in the licensees corrective action
tracking program to ensure that corrective actions would be completed in accordance
with their priority. Procedure changes to ensure that review criteria exist so that fire
barrier modifications do not invalidate test results in the future was complete. Although
the EC for the ACP room had not been issued, the field work had been performed at risk
and was essentially completed prior to completion of the EC. Reviews of other fire
barriers by the licensee were in progress, and initial walk downs were complete.
Resolution of other fire protection issues was in progress and was being prioritized based
on risk.
d.
Establishment of quantitative or qualitative measures of success for determining the
effectiveness of the corrective actions to prevent recurrence.
The effectiveness of these measures will be determined by the licensee through direct
observation of the completed modifications and changes to the fire protection program.
The licensee has scheduled an effectiveness review for July 2003.
The inspector performed plant walk downs and conducted document reviews in
determining that the extent of condition for the Thermo-Lag wall issue included all
Thermo-Lag usage in the plant. Thermo-Lag usage in the plant included various
transoms and mullions on the 216', 236', 261', and 305' elevations of the reactor auxiliary
building and control building; and Thermo-Lag wall and tunnel assemblies in the A and B
cable spreading rooms, the B switchgear room and the ACP area. The problem with the
Thermo-Lag issue was related to the use of engineering evaluations for determining the
applicability of fire test results to qualify plant features as rated fire barriers. In the case
of the Thermo-Lag, a failed three-hour qualification fire test was used to accept Thermo-
Lag features by engineering evaluation as adequate for the hazard. The use of failed
tests for fire rating determination appears specific to the resolution of this Thermo-Lag
issue. In other cases, hardware modifications were made to reconcile the configurations
to the test configurations that passed rating tests. Upgrading the concrete wall between
the B switchgear room and the ACP room to a three-hour barrier decreases the risk of
damaging the A train cables in the ACP room as a result of a fire in the B switchgear
room.
5
03
OTHER ACTIVITIES
03.01 Other
(Closed) AV 50-400/00-09-01: Failure to Maintain the Fire Area Separation Barrier
Between The B Train Switchgear Room/Auxiliary Control Panel Room and the A Train
Cable Spreading Room as a 3-hour Rated Barrier
This apparent violation was identified to the licensee in a letter dated December 18,
2001, Subject: NRC Inspection Report 50-400/00-09; Preliminary White Finding. The
apparent violation concerned the Thermo-Lag fire barrier assembly which separated the
B train switchgear room and the A train cable spreading room. The results of testing
performed by the licensee in 1994 and 1995 showed that the fire barrier did not have the
required three-hour fire resistance rating. After reviewing the test results, the licensee
changed the fire protection program by revising the rating of the fire barrier from three
hours to that suitable for the hazard. This issue had been initially identified by NRC as
Unresolved Item 50-400/99-13-01. In a letter dated April 16, 2002, Subject: Final
Significance Determination For a White Finding and Notice of Violation (Shearon Harris
Nuclear Power Plant - NRC Inspection Report 50-400/00-09), the licensee was informed
that NRC had determined that this issue was a violation of License Condition 2F of the
Harris Operating License. A Notice of Violation, Severity Level III, was included as an
Enclosure to the April 16, 2002 letter. For tracking purposes, this Severity Level III
violation is identified as Violation (VIO) 50-400/02-08-01: Failure to Implement and
Maintain NRC Approved Fire Protection Program Safe Shutdown System Separation
Requirements. Apparent Violation 50-400/00-09-01 is closed.
(Closed) AV 50-400/00-09-02: Failure to Obtain NRC Approval Prior to Implementing a
Change to the Approved Fire Protection Program
This apparent violation was also identified to the licensee in a letter dated December 18,
2001, Subject: NRC Inspection Report 50-400/00-09; Preliminary White Finding. This
apparent violation concerned the fact that the licensee made changes to the approved
fire protection program by accepting the degraded fire barrier, through an engineering
evaluation, without prior Commission approval. This issue had been initially identified by
NRC as Unresolved Item 50-400/99-13-02. In a letter dated April 16, 2002, Subject:
Final Significance Determination For a White Finding and Notice of Violation (Shearon
Harris Nuclear Power Plant - NRC Inspection Report 50-400/00-09), the licensee was
informed that NRC had determined that it was appropriate to cite this issue as part of
Violation (VIO) 50-400/02-08-01: Failure to Implement and Maintain NRC Approved Fire
Protection Program Safe Shutdown System Separation Requirements. Apparent
Violation 50-400/00-09-02 is closed.
6
04
MANAGEMENT MEETINGS
Exit Meeting Summary
The inspector presented interim results of the inspection to Mr. J. Scarola and other
members of his staff at the conclusion of the inspection on May 31, 2002. A final exit
meeting was held via telephone with Mr. J. Caves and other members of the licensees
staff on September 6, 2002, to present the final results of the inspection. The licensee
acknowledged the findings presented. Proprietary information is not included in the
inspection report.
7
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
D. Alexander, Manager, Nuclear Assessment Section
J. Caves, Supervisor, Licensing
M. Fletcher, Fire Protection System Engineer
C. Georgeson, Electrical Engineer
J. Holt, Site Support Services Manager
A. Khanpour, Superintendent of Design, Harris Engineering Support Services (HESS)
D. McAfee, Fire Protection Program Manager
E. McCartney, Superintendent Of Technical Services, HESS
J. Scarola, Harris Plant Vice President
M. Wallace, Senior Analyst, Licensing
NRC
J. Brady, Senior Resident Inspector
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
50-400/02-08-01
Failure to Implement and Maintain NRC
Approved Fire Protection Program Safe
Shutdown System Separation Requirements
(Section 03.01)
Closed
50-400/00-09-01
Failure to Maintain the Fire Area Separation
Barrier Between The B Train Switchgear
Room/Auxiliary Control Panel Room and the
A Train Cable Spreading Room as a 3-hour
Rated Barrier (Section 03.01)
50-400/00-09-02
Failure to Obtain NRC Approval Prior to
Implementing a Change to the Approved
Fire Protection Program(Section 03.01)
ATTACHMENT
LIST OF BASELINE INSPECTIONS PERFORMED
The following procedure was used to perform the inspection during the report period.
Documented findings are contained in the body of the report.
Supplemental Inspection For One Or Two White Inputs In A Strategic
Performance Area.
ATTACHMENT
LIST OF DOCUMENTS REVIEWED
CP&L Procedure CAP-NGGC-200, Corrective Action Program, Rev. 4
Engineering Service Request 99-0180, Evaluation of Low Density Silicone Elastomer (LDSE)
Seals, Rev. 0, 6/16/99
Engineering Change 48802, Make ACP Room Separate Fire Area, Revision 0, 7/17/02
Calculation E-5525, Safe Shutdown Analysis in Case of Fire, Rev. 5, 5/7/02, and pending
changes resulting from EC 48802
Calculation E-5524, Safe Shutdown Analysis Changes to the Cable Function Report and
Essential Cable Analysis, Rev. 5, 6/2/02
Abnormal Operating Procedure AOP-036, Safe Shutdown Following A Fire, Rev. 19, and
pending revisions resulting from EC 48802
Drawing Numbers SK-48802-C-1000, ACP Door Transom Detail, Sheets 1 and 2
Drawing Number SK-48802-C-1000, ACP Wall Penetrations, Sheet 1
Work Orders 233062 01 and 233062 02, Make ACP Room Separate Fire Area