ML033250381

E-mail from C. Payne to E. Weiss, Fire Protection Issue

ML033250381
Person / Time
Site:	Crystal River
Issue date:	07/19/2002
From:	Payne D NRC/RGN-II
To:	Weiss E Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0358
Download: ML033250381 (2)

Text

ZEic; Weiss - Fwd: Fire protection issue Page 1 From: Charlie Payne1,x4&~

To: Eric Weiss Date: 7/19/02 2:15PM

Subject:

Fwd: Fire protection issue Eric, As discussed last week, Region II has identified that Crystal River is not complying with App. R, lll.G.2, for proper cable protection of one redundant train to achieve and maintain hot shutdown. In lieu of protection, CR-3 has chosen to substitute local manual actions (i.e., actions taken by an operator outside the MCR at the valve, pump or breaker.) The licensee did not pursue with NRR an exemption from complying with llI.G.2 for any of its local manual actions.

While many issues were identified and discussed during the inspection, three specifically dealt with local manual actions as a result of cable protection problems (Thermolag) within the fire areas selected for inspection. One was a non-regulatory performance issue, but related because it would impact the fire brigade ability to put water on a fire in these areas. Another was a local manual action in lieu of complying with lll.G.2 but of very low safety significance (i.e., the action was easy to perform, lighting was provided, not in the fire area, etc.). The last issue was also a manual action in lieu of complying with lll.G.2 but may be greater than green. An SDP evaluation is being processed for SRA review.

SUMMARY

OF LAST ISSUE: The local manual action appeared easy to perform (close a 4160V breaker) but the actual breaker was located in the same locale as the postulated fire. The inspectors determined the operator's performance could be affected by smoke, hot gas layer and water resulting from the postulated fire. The licensee has not performed an analysis or timeline to verify adequate resources and capability to successfully accomplish any local manual actions and was not previously aware of this particular problem. They hav performed a fire procedure V&V. Despite not having a written analysis, the licensee claims to have appropriately considered these issues while revising their Fire Protection Plan (after determining that their Thermolag barriers were not adequate and deciding to use local manual actions to compensate for not protecting cables in lll.G.2 areas.) The licensee also claims that NRC was fully aware of their extensive use of local manual actions when the fire protection area was inspected for CR-3 restart several years ago. The inspectors identified, and the licensee acknowledged, that many other local manual actions would be performed as a result of other cable protection issues in the plant. The licensee conducted a FP self assessment in the spring this year and identified that their use of manual actions may be an issue with the NRC and opened a problem identification report. One of the actions is to perform an engineering analysis of their local manual actions. Please see the attached briefing summary of the inspection that was provided by the team to Region II DRS management on 7/18/02 for details.

Region 11does not believe that Crystal River's use of local manual actions is only a matter of not receiving an exemption from NRR. The use of local manual actions is extensive and has not been comprehensively analyzed by the licensee. During our inspection, the team found one example where the licensee failed to properly evaluate the ability of the operator to successfully accomplish a local manual action. Other examples may or may exist. Itis indeterminate pending completion of the licensee's analysis (in mid-October 2002) or additional NRC inspection. We intend to pursue appropriate enforcement action and color these findings per the ROP.

Please see the attached response Region II's legal counsel received from OGC on this issue. Apparently OGC is waiting for NRR to formally request an interpretation of lll.G.2 before proceeding.

Also, please let me know when you may be providing interim guidance to the staff for handling issues related to this. We are preparing for a TFPI at Farley next month and fully expect to encounter similar issues there (because of Kaowool.)

Thanks, Charlie...

Eric Weiss - Fwd: Fire protection issue ____ Page 2 CC: Carolyn Evans; Charles R. Ogle; John Hannon; Phil Qualls