ML033380523
| ML033380523 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/18/2003 |
| From: | Ogle C NRC/RGN-II/DRP/RPB1 |
| To: | Scarola J Carolina Power & Light Co |
| References | |
| FOIA/PA-2004-0277 IR-03-007 | |
| Download: ML033380523 (21) | |
See also: IR 05000400/2003007
Text
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
November 18, 2003
EA-01-310
Carolina Power & Light Company
ATTN: Mr. James Scarola
Vice President - Harris Plant
PROPRIETARY INFORMATION
Shearon Harris Nuclear Power Plant
REMOVED
P. O. Box 165, Mail Code: Zone 1
New Hill, North Carolina 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - NRC FIRE PROTECTION
INSPECTION REPORT NO. 05000400/2003007
Dear Mr. Scarola:
On October 21, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed an in-office
review of the significance of the triennial fire protection inspection findings of inspection report
05000400/2002011 related to your Shearon Harris Nuclear Power Plant. The enclosed report
documents the results of our significance determination, which was discussed on
October 21, 2003, by telephone with Mr. R. Duncan and other members of your staff.
This report documents two NRC-identified findings of very low significance (Green). Both of
these findings were determined to involve violations of NRC requirements. However, because
of the very low safety significance and because they are entered into your corrective action
program, the NRC is treating these two findings as non-cited violations (NCVs) consistent with
Section VI.A. of the NRC Enforcement Policy. If you contest any NCV in this report, you should
provide a response within 30 days of the date of this inspection report, with the basis for your
denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of
Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001;
and the NRC Resident Inspector at the Shearon Harris Nuclear Power Plant.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter,
portions of its enclosure and your response (if any) will be available electronically for public
inspection in the NRC Public Document Room or from the Publicly Available Records (PARS)
component of
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
2
NRCs document system (ADAMS). However, the NRC is continuing to review the appropriate
classification of the Phase 3 significance determination process analysis (Attachment 2) within
our records management program, considering changes in our practices following the events of
September 11, 2001. Using our interim guidance, the attached analysis has been marked as
Proprietary Information or Sensitive Information in accordance with Section 2.790(d) of Title 10
of the Code of Federal Regulations. Please control the document accordingly (i.e., treat the
document as if you had determined that it contained trade secrets and commercial or financial
information that you considered privileged or confidential). We will inform you if the
classification of these documents change as a result of our ongoing assessments. ADAMS is
accessible from the NRC Website 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: Inspection Report 05000400/2003007
w/Attachments: 1. Supplemental Information
2. Phase 3 SDP Analysis (Contains Proprietary Information)
cc w/encl and Attachment 1:
James W. Holt, 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
(cc w/encl and Attachment 1 contd - See page 3)
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
3
(cc w/encl and Attachment 1 contd)
Benjamin C. Waldrep
Plant General Manager--Harris Plant
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
Terry C. Morton, Manager
Support Services
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
John R. Caves, Supervisor
Licensing/Regulatory Programs
Carolina Power & Light Company
Shearon Harris Nuclear Power Plant
Electronic Mail Distribution
Steven R. Carr
Associate General Counsel - Legal Department
Progress Energy Service Company, LLC
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
(cc w/encl and Attachment 1 contd - See page 4)
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
4
(cc w/encl and Attachment 1 contd)
Public Service Commission
State of South Carolina
P. O. Box 11649
Columbia, SC 29211
Chairman of the North Carolina
Utilities Commission
c/o Sam Watson, Staff Attorney
Electronic Mail Distribution
Robert P. Gruber
Executive Director
Public Staff NCUC
4326 Mail Service Center
Raleigh, NC 27699-4326
Herb Council, Chair
Board of County Commissioners
of Wake County
P. O. Box 550
Raleigh, NC 27602
Tommy Emerson, Chair
Board of County Commissioners
of Chatham County
Electronic Mail Distribution
Distribution w/encl and Attachment 1:
PUBLIC
RIDSNRRDIPMLIPB
Distribution w/encl and Attachments 1 and 2:
L. Slack, EICS
B. Mozafari, NRR
OEMAIL
(SEE PREVIOUS PAGE FOR CONCURRENCES)
OFFICE
RII:DRS
RII:DRS
RII:DRS
RII:DRP
RII:EICS
SIGNATURE
RA
RA
NAME
RSchin
WRogers
KODonohue
PFredrickson
CEvans
DATE
10/24/2003
10/27/2003
11/18/2003
10/27/2003
11/14/2003
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
PUBLIC
YES
NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML033380523.wpd
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.:
50-400
License No.:
Report No.:
Licensee:
Carolina Power & Light (CP&L)
Facility:
Shearon Harris Nuclear Power Plant
Location:
5413 Shearon Harris Road
New Hill, NC 27562
Dates:
February 1, 2003 - October 21, 2003
Inspectors:
W. Rogers, Senior Reactor Analyst, Region II
R. Schin, Senior Reactor Inspector, Region II
Approved by:
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
SUMMARY OF FINDINGS
IR 05000400/2003-007; 02/01/2003 - 10/21/2003; Shearon Harris Nuclear Power Plant;
Significance Determination of Fire Protection Findings.
The in-office review was conducted by a regional inspector, a regional senior reactor analyst,
and NRC Headquarters risk analysts. Two Green findings, each a non-cited violation (NCV),
were identified. The significance of issues 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 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 Findings
Cornerstones: Mitigating Systems and Initiating Events
Green. The inspectors identified a non-cited violation (NCV) of Operating License
Condition 2.F, the Fire Protection Program, and Technical Specification 6.8.1,
Procedures and Programs, for inadequate implementation of the fire protection
program. Physical and procedural protection for equipment that was relied on for safe
shutdown (SSD) during a fire in fire safe shutdown analysis (SSA) areas 1-A-BAL-B-B1,
1-A-BAL-B-B2, 1-A-BAL-B-B4, 1-A-BAL-B-B5, 1-A-EPA, and 1-A-BAL-C of the reactor
auxiliary building was inadequate. Consequently, a fire in one of these SSA areas
could result in a reactor coolant pump seal loss of coolant accident event, a main steam
power-operated relief valve failed open event, a loss of high pressure safety injection,
and/or a loss of component cooling water to the reactor coolant pump seals. Licensee
corrective action included assigning an additional operator to be available to perform
post-fire SSD actions and performing a complete review of the SSA and related
operating procedures.
This finding was greater than minor because it involved a lack of required fire barriers
for equipment that was relied upon for safe hot shutdown following a fire. The finding
also had more than minor safety significance because it affected the objectives of the
Mitigating Systems and Initiating Events Cornerstones. The finding affected the
availability and reliability of systems that mitigate initiating events to prevent undesirable
consequences and also affected the likelihood of occurrence of initiating events that
challenge critical safety functions. The finding was of very low significance (Green)
because of the low fire ignition frequencies, lack of combustible materials in critical
locations, and the effectiveness of the fire protection features and the unaffected SSD
equipment to mitigate a fire in each of the affected fire zones/areas.
[Section 1R05.1.b.(1)]
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
2
Green. The inspectors identified a non-cited violation (NCV) of Operating License
Condition 2.F, the Fire Protection Program, and Technical Specification 6.8.1,
Procedures and Programs, for inadequate corrective action for previous Violation
50-400/02-08-01. Corrective action for that violation had included creating a new
auxiliary control panel fire area (1-A-ACP) in 2002. However, that corrective action was
not adequate because physical and procedural protection for equipment that was relied
on for safe shutdown (SSD) during a fire in the new fire area was inadequate.
Consequently, a fire in area 1-A-ACP could result in a loss of auxiliary feedwater and a
main steam power-operated relief valve failed open event. Licensee corrective actions
in response to this finding included assigning an additional operator to be available to
perform post-fire SSD actions and performing a complete review of the SSA and related
operating procedures.
This finding was greater than minor because it involved inadequate fire barriers for
equipment that was relied upon for safe hot shutdown following a fire. The finding also
had more than minor safety significance because it affected the objectives of the
Mitigating Systems and Initiating Events Cornerstones. The finding affected the
availability and reliability of systems that mitigate initiating events to prevent undesirable
consequences and also affected the likelihood of occurrence of initiating events that
challenge critical safety functions. The finding was of very low significance (Green)
because of the very low ignition sources in the fire area, manual suppression capability,
and the power conversion system not being affected by a fire in this fire area. [Section
1R05.1.b.(2)]
B.
Licensee-Identified Violations
None
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
REPORT DETAILS
1.
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05
FIRE PROTECTION
.1
Significance Determination for Triennial Fire Protection Inspection Findings
a.
Inspection Scope
In Inspection Report (IR) 50-400/02-11, nine findings were identified as unresolved
items (URIs) pending completion of the NRC significance determination process (SDP).
The nine URIs were as follows:
URI 50-400/02-11-01, Failure to Protect Charging System MOV 1CS-165, VCT
Outlet to CSIPs, From Maloperation Due To a Fire
URI 50-400/02-11-02, Failure to Protect Charging System MOVs 1CS-169,
1CS-214, 1CS-218, and 1CS-219 From Maloperation Due To a Fire
URI 50-400/02-11-03, Failure to Protect Charging System MOVs 1CS-166,
1CS-168, and 1CS-217 From Maloperation Due To a Fire
URI 50-400/02-11-04, Failure to Protect Component Cooling MOVs 1CC-251
and 1CC-208, CC for RCP Seals, From Maloperation Due To a Fire
URI 50-400/02-11-05, Reliance on Manual Actions in Place of Required Physical
Separation or Protection From a Fire
URI 50-400/02-11-06, Fire SSD Operator Actions With Excessive Challenges
URI 50-400/02-11-07, Too Many Fire SSD Actions for Operators to Perform
URI 50-400/02-11-08, Using the Boric Acid Tank Without Level Indication
URI 50-400/02-11-09, Failure to Provide Required Emergency Lighting for SSD
Operator Actions
This IR documents the results of the in-office completion of the NRC SDP with respect
to the nine URIs. The significance determination was accomplished as described in
NRC Inspection Manual Chapter (IMC) 0609, Signification Determination Process; IMC
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
2
0609A, Significance Determination of Reactor Inspection Findings for At-Power
Situations; and IMC 0609F, Determining Potential Risk Significance of Fire Protection
and Post-Fire Safe Shutdown Inspection Findings. This involved evaluating the
significance of a potential fire in each of seven affected fire safe shutdown analysis
(SSA) areas using the Phase 2 SDP, considering all examples of the findings that could
be involved in each fire. To better assess the overall significance of all of the
performance deficiencies, they were processed through the SDP as two overall findings:
1) Inadequate Implementation of the Fire Protection Program (FPP) for safe shutdown
(SSD); and 2) Inadequate Corrective Action for a Previous White Fire Protection
Finding.
In addition, the performance deficiencies which could result in the loss of a safety
function were evaluated by NRC Headquarters risk analysts using the Phase 3 portion
of the SDP. Included in this evaluation were extensive walkdowns of the applicable fire
SSA areas by two NRC fire protection contractors to observe ignition sources and
possible fire propagation pathways from these ignition sources that could affect the
unprotected cables of concern. Also, electrical circuit drawings and the latest
information on cable hot short failure mechanisms and probabilities were used to
develop cable failure probabilities that could cause a loss of function for the unprotected
cables of concern.
b.
Findings
(1)
Inadequate Implementation of the FPP for SSD
Introduction: An overall finding was identified in that the implementation of the FPP was
inadequate. Eight of the nine URIs described in IR 50-400/02-11 were considered to
include performance deficiencies related to this overall finding. Based on evaluating
those performance deficiencies for their effects during fires that could occur in each of
six (of the seven total) affected fire SSA areas, this overall finding was determined to
have a very low significance (Green).
Description: The licensees implementation of the FPP for ensuring the ability to safely
shut down the plant during a fire was inadequate, in that:
The fire SSA failed to identify several cables that were relied upon for SSD
during a fire. Consequently, those cables were not provided with the required
protection from fire damage. A fire could cause hot shorts in the cables which
would result in maloperation of equipment that was relied upon for SSD during
that fire.
The SSA identified many cables that were relied upon for SSD during a fire, for
which the licensee generally failed to provide the required physical protection
from fire damage. Instead, the SSA designated that operator actions would be
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
3
taken to prevent or mitigate the effects of the fire damage. However, the
licensee did not obtain NRC approval for these deviations from the approved
FPP.
Some of the operator actions that were designated by the SSA were not
incorporated into operating procedures for SSD. Also, the operator actions in
procedures differed in many respects from the operator actions that were
analyzed in the SSA. For example, the operating procedures directed operators
to use some different flowpaths than those analyzed in the SSA.
Some operator actions in the SSD procedures would not work. They were too
challenging, involved entering the area of the fire, were not adequately analyzed,
or were too numerous for the available SSD non-licensed operator to perform.
Detailed examples related to this overall finding were included in the following eight
URIs: 50-400/02-11-01, -02, -03, -04, -05, -07, -08, and -09.
Analysis: The inspectors and analysts evaluated the effects of the multiple examples of
this overall finding during a fire that could occur in each of the six affected fire SSA
areas of the reactor auxiliary building (RAB) using Phase 2 and Phase 3 of the SDP.
Based on that analysis, the inspector and analysts concluded that this finding had more
than minor safety significance because it involved a lack of required fire barriers for
equipment that was relied upon for safe hot shutdown following a fire. The finding also
had more than minor safety significance because it affected the availability and reliability
objectives and the equipment performance attribute of the Mitigating Systems
Cornerstone. In addition, it affected the Initiating Events Cornerstone in that it affected
the objective of limiting the likelihood of occurrence of initiating events that challenge
critical safety functions and also affected the design control attribute. The overall finding
did not have more than very low safety significance (Green) because of the low fire
ignition frequencies that could impact the cables of interest, the lack of combustible
materials in critical locations, and the effectiveness of the fire protection features and
the unaffected SSD equipment to mitigate a fire in each of the affected fire zones/areas.
Enforcement: As described in IR 50-400/02-11, Operating License Condition (OLC) 2.F
requires that the licensee implement and maintain in effect all provisions of the FPP as
described in the Final Safety Analysis Report (FSAR). The Updated FSAR (UFSAR),
Section 9.5.1, FPP, states that outside containment, where cables or equipment
(including associated non-essential circuits that could prevent operation or cause
maloperation due to hot shorts, open circuits, or shorts to ground) of redundant SSD
divisions of systems necessary to achieve and maintain hot shutdown conditions are
located within the same fire area outside of primary containment, one of the redundant
divisions must be ensured to be free of fire damage. Section 9.5.1 further states that if
both divisions are located in the same fire area, then one division is to be physically
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
4
protected from fire damage by one of three methods: 1) a three-hour fire barrier, 2) a
one-hour fire barrier plus automatic detection and suppression, or 3) a 20-foot
separation with no intervening combustibles and with automatic detection and
suppression. The licensee had not received NRC approval for deviating from these
requirements.
Also, OLC 2. F. and UFSAR Section 9.5.1 state that Branch Technical Position (BTP)
9.5-1 was used in the design of the FPP for safety-related systems and equipment and
for other plant areas containing fire hazards that could adversely affect safety-related
systems. BTP 9.5-1, Section C.5.g, Lighting and Communication, paragraph (1),
requires 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 SSD and for access and egress routes to and from all fire
areas.
In addition, Technical Specification 6.8.1, Procedures and Programs, requires
procedures as recommended by Regulatory Guide 1.33 and procedures for FPP
implementation. Regulatory Guide 1.33 recommends procedures for combating
emergencies, including fires. The licensees interpretation of the FPP was that they
could and would rely on proceduralized operator actions in place of physically protecting
electrical cables for SSD equipment from fire damage. The operator actions were
contained in Procedure AOP-36, Safe Shutdown Following a Fire, Rev. 21.
Contrary to the above requirements, the licensee failed to adequately implement and
maintain in effect all of the provisions of the approved FPP. The licensee failed to
ensure that one of the redundant SSD divisions of systems necessary to achieve and
maintain cold shutdown conditions was protected from fire damage; failed to have
adequate procedures for combating fire emergencies; and failed to provide the required
emergency lighting in areas that must be manned for SSD; as described above in the
eight examples of this overall finding. These conditions were identified by the NRC in
December 2002 and had been in place for years. Because the identified examples of
this failure to adequately implement and maintain in effect all of the provisions of the
approved FPP are of very low safety significance and have been entered into the
corrective action program [Action Requests (ARs) 76260, 80212, 80089, 69721, 80215,
75065, and 79047], this violation is being treated as a NCV, consistent with Section VI.A
of the NRC Enforcement Policy: NCV 50-400/03-07-01; Inadequate Implementation of
the Fire Protection Program for Safe Shutdown.
(2)
Inadequate Corrective Action for a Previous White Fire Protection Finding
Introduction: In IR 50-400/02-08, the NRC left Violation 50-400/02-08-01 open for
further NRC review of the new manual operator actions that were added for the new
1-A-ACP fire area, as part of the licensees corrective action for the violation. In IR
50-400/02-11, the NRC documented the review of those new manual operator actions
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
5
and identified that the licensees corrective actions contributed to four new findings. For
this significance determination, those findings were grouped into one overall finding of
inadequate corrective action for a previous White fire protection finding. Based on
evaluating the multiple examples of this overall finding for their effects during a fire that
could occur in the new 1-A-ACP fire area, this overall finding was determined to have a
very low significance (Green).
Description: The licensees corrective actions for a previous White fire protection finding
(Violation 50-400/02-08-01), associated with a Thermo-Lag fire barrier assembly
between the B train switchgear room / auxiliary control panel and the A train cable
spreading room, were inadequate. The corrective actions were inadequate because
they failed to rectify deficiencies in design, construction, and operation related to SSD
from a fire in the new 1-A-ACP fire area. Consequently, a fire in area 1-A-ACP could
result in a loss of auxiliary feedwater and a main steam power-operated relief valve
failed open event. The licensees corrective actions contributed to four new findings that
are now grouped into the overall finding of inadequate corrective action:
The corrective actions created a new fire area (1-A-ACP) and many new manual
operator actions for a fire in the new fire area instead of providing the required
physical protection of cables. This finding was described in URI 50-400/02-11-
05, Reliance on Manual Actions in Place of Required Physical Separation or
Protection From a Fire.
The corrective actions also created a manual operator action with excessive
challenges such that there was not reasonable assurance that all non-licensed
operators (NLOs) would be able to perform the action during a fire event. This
finding was described in URI 50-400/02-11-06, Fire SSD Operator Actions With
Excessive Challenges.
In addition, the corrective actions created too many local manual operator
actions for the new fire area for the one SSD NLO to perform. This finding was
described in URI 50-400/02-11-07, Too Many Fire SSD Actions for Operators to
Perform.
Further, the corrective actions failed to provide the required emergency lighting
for the new manual actions. This finding was described in URI 50-400/02-11-09,
Failure to Provide Required Emergency Lighting for SSD Operator Actions.
Analysis: The inspectors and analysts evaluated the effects of the multiple examples of
the overall finding of inadequate corrective action during a fire that could occur in the
1-A-ACP fire area of the RAB, using Phase 2 of the SDP. Based on that evaluation,
the inspectors and analysts concluded that the overall finding had more than minor
safety significance because it involved inadequate fire barriers for equipment that was
relied upon for safe hot shutdown following a fire. The finding also had more than minor
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
6
safety significance because it affected the availability and reliability objectives and the
equipment performance attribute of the Mitigating Systems Cornerstone. In addition, it
affected the Initiating Events Cornerstone in that it affected the objective of limiting the
likelihood of occurrence of initiating events that challenge critical safety functions and
also affected the design control attribute. The finding did not have more than very low
safety significance (Green) because of the very low ignition sources in the fire area,
manual suppression capability, and the power conversion system not being affected by
a fire in this fire area. The Green significance determination was also confirmed by a
walkdown of the fire area by two contractors.
Enforcement: Operating License Condition 2.F and the UFSAR, Section 9.5.1, FPP,
includes quality assurance requirements for fire protection. The FPP states that a
quality assurance program is being used to identify and rectify any possible deficiencies
in design, construction, and operation of the fire protection systems. Operating License
Condition 2.F requires that one of the redundant divisions be free of fire damage.
Further, if both divisions were located in the same area, OLC 2.F requires that one of
the divisions be physically protected from fire damage by one of three specified
methods. Also, OLC.2.F requires that battery-backed emergency lights be provided in
locations where operators are required to perform actions for SSD from a fire. In
addition, Technical Specification 6.8.1, Procedures and Programs, requires procedures
for implementing the FPP and for combating fires. The licensees procedure for safe
shutdown following a fire in the new ACP room fire area was AOP-36, Safe Shutdown
Following a Fire, Rev. 24.
Contrary to the above requirements, the licensees corrective actions for previous
Violation 50-400/02-08-01 were inadequate because the actions failed to rectify
deficiencies in design, construction, and operation related to SSD from a fire in the area
of the ACP room. The licensee failed to protect various equipment either physically or
procedurally from the effects of a fire where that equipment was relied on for SSD. The
new ACP room effectively became part of the licensees FPP when AOP-36 was revised
(Revision 24) in November 2002 to include new operator actions for a fire in the new
ACP room. Consequently, the conditions included in this violation were effectively in
place for more than three days but less than thirty days when they were identified by the
NRC in December 2002 during the triennial fire protection inspection. Because the
identified examples of this inadequate corrective action are of very low safety
significance and have been entered into the corrective action program (AR 80215), this
violation is being treated as an NCV, consistent with Section VI.A of the NRC
Enforcement Policy: NCV 50-400/03-07-02; Inadequate Corrective Action for a
Previous White Fire Protection Finding.
.2
(Closed) VIO 50-400/02-08-01, Failure to Implement and Maintain NRC Approved FPP
SSD System Separation Requirements
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
7
This Violation was closed with a new corrective action NCV opened as discussed in
Section 1R05.1.b.(2).
.3
(Closed) URIs 50-400/02-11-01, -02, -03, -04, -05, -06, -07, -08, and -09
These URIs were resolved in two new NVCs as discussed in Sections 1R05.1.b.(1) and
(2). Consequently, these URIs are closed.
4.
OTHER ACTIVITIES
4OA3 Event Followup
(Closed) LER 50-400/02-04-00, Unanalyzed Condition Due to Inadequate Separation of
Associated Circuits
This LER describes conditions that were previously identified by the NRC in IR
50-500/02-11 and that were evaluated and resolved in a new NCV in Section
1R05.1.b.(1) above. This LER was reviewed by the inspectors and no additional
findings were identified. This LER is closed.
4OA6 Meetings, including Exit
The team presented the inspection results to Mr. R. Duncan and other members of his
staff at the conclusion of the inspection on October 21, 2003. The licensee
acknowledged the findings presented. Proprietary information is not included in this
inspection report.
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
Attachment 1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
J. Caves, Licensing Supervisor
F. Diya, Acting Manager, Engineering
R. Duncan, Director of Site Operations
M. Fletcher, Manager, Fire Protection Program
T. Morton, Manager, Support Services
NRC personnel
G. MacDonald, Senior Project Engineer, Division of Reactor Projects, Region II
R. Musser, Senior Resident Inspector, Shearon Harris
P. OBryan, Resident Inspector, Shearon Harris
C. Ogle, Chief, Engineering Branch 1, Division of Reactor Safety, Region II
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
50-400/03-07-01
Inadequate Implementation of the FPP for SSD
[Section 1R05.1.b.(1)]
50-400/03-07-02
Inadequate Corrective Action for a Previous White Fire
Protection Finding [Section 1R05.1.b.(2)]
Closed
50-400/02-08-01
Failure to Implement and Maintain NRC Approved FPP
SSD System Separation Requirements (Section 1R05.2)
50-400/02-11-01
Failure to Protect Charging System MOV 1CS-165, VCT
Outlet to CSIPs, From Maloperation Due To a Fire
(Section 1R05.3)
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
2
Attachment 1
50-400/02-11-02
Failure to Protect Charging System MOVs 1CS-169, 1CS-
214, 1CS-218, and 1CS-219 From Maloperation Due To a
Fire (Section 1R05.3)
50-400/02-11-03
Failure to Protect Charging System MOVs 1CS-166, 1CS-
168, and 1CS-217 From Maloperation Due To a Fire
(Section 1R05.3)
50-400/02-11-04
Failure to Protect Component Cooling MOVs 1CC-251 and
1CC-208, CC for RCP Seals, From Maloperation Due To a
Fire (Section 1R05.3)
50-400/02-11-05
Reliance on Manual Actions in Place of Required Physical
Separation or Protection From a Fire (Section 1R05.3)
50-400/02-11-06
Fire SSD Operator Actions With Excessive Challenges
(Section 1R05.3)
50-400/02-11-07
Too Many Fire SSD Actions for Operators to Perform
(Section 1R05.3)
50-400/02-11-08
Using the Boric Acid Tank Without Level Indication
(Section 1R05.3)
50-400/02-11-09
Failure to Provide Required Emergency Lighting for SSD
Operator Actions (Section 1R05.3)
50-400/02-04-00
LER
Unanalyzed Condition Due to Inadequate Separation of
Associated Circuits (Section 4OA3)
DOCUMENT TRANSMITTED HEREWITH CONTAINS SENSITIVE UNCLASSIFIED INFORMATION
WHEN SEPARATED FROM ATTACHMENT 2, THIS DOCUMENT IS DECONTROLLED
ATTACHMENT 2 CONTAINS PROPRIETARY INFORMATION
3
PROPRIETARY INFORMATION
REMOVED
Attachment 2