Text

Draft IR 05000327-02-003 and IR 05000328-02-003 on 03/25-29/02, Sequoyah Nuclear Plant. Non-Cited Violations Noted
	ML040090230
Person / Time
Site:	Sequoyah
Issue date:	04/30/2002
From:	Ogle C; NRC/RGN-II/DRS/EB
To:	Scalice J; Tennessee Valley Authority
References
	FOIA/PA-2003-0358 IR-02-003
	Download: ML040090230 (24)
	v • d • e

April XX, 2002

Tennessee Valley Authority

ATTN: Mr. J. A. Scalice

Chief Nuclear Officer and

Executive Vice President

6A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC INSPECTION REPORT 50-327/02-03,

50-328/02-03

Dear Mr. Scalice:

On March 29, 2002, the Nuclear Regulatory Commission (NRC) completed a triennial fire

protection inspection at the Sequoyah Nuclear Plant. The enclosed report documents the

results of this inspection which were discussed on March 28-29, with Mr. Dennis Cole and other

members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commission's 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, the inspectors identified two issues of very low safety

significance (Green). These issues were determined to involve violations of NRC

requirements. [However, because of their very low safety significance and because they have

been entered into your corrective action program, the NRC is treating these issues as Non-cited

Aid violations, in accordance with Section VI.A.1 of the NRC's Enforcement Policy. The first

9ation involved a failure to ensure that one of the redundant trains for isolation of normal

, letdownrjsnaintained free of fire damage. The second violation involved the failure to properly

establish the plant fire procedure such that actions necessary to mitigate the consequences of a

severe fire could be effectively performed.

If you deny these Non-cited violations, you should provide a response with the basis for your

denial, within 30 days of the date of this inspection report, 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

Sequoyah Nuclear Plant.

In accordance with 10 CFR 2.790 of the NRC's "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 Publicly Available Records (PARS) component of NRC's Document 0

system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.qov/reading-

rmladams.html (the Public Electronic Reading Room).

Sincerely,

. . .

Charles R. Ogle, Chief

Engineering Branch I

Division of Reactor Safety

Enclosure: NRC Inspection Report 50-327/02-03,

50-328/02-03

SUMMARY OF FINDINGS

Sequoyah Nuclear Plant, Units land 2

IR 05000327-02-03 and IR05000328-02-03 on 03125-29/2002,Tennesee Valley Authority,

Sequoyah Nuclear Plant Units I and 2, triennial baseline inspection of the fire protection

program.

The inspection was conducted by a Brunswick resident inspector, and three regional reactor

inspectors. The inspection identified two Non-cited violations which were determined to be of

very low safety significance (Green). The significance of most findings is indicated by their

color (Green, White, Yellow, Red) using IMC 0609 'Significance Determination Process."

Findings for which the SDP does not apply are indicated by "No Color" or by the severity level

of the applicable violation. Tl

n

Ntv:La~rnrc.

Inspector Identified Findings

Cornerstone: Mitigating Systems Wa

Green. A Non-cited violation of 10 CFR Part 50RAppendi Il.G.2, was identified for

failure to ensure that one of the redundant trains of a sys em necessary to achieve and

maintain hot shutdown conditions in the event of a fire ree of fire damage.

Specifically, electrical cables for redundant charging flow isolation valves 1-FCV-62-90

ano1 were located in Fire Area FAA-029, the Auxiliary Building Corridor, without

oqt',,-adequate spatial separation or fire barriers. o

[4C1'J The finding had a credible impact on safet n tire damage to the unprotecte

cables could prevent closure of the valves fro mafn control room (MCR) and

challenge the operators' ability to establish adeq t injection flow to the reactor coolant

pump (RCP) seals. This finding was determined be of very low safety significance

because the ignition frequency was relatively low, fire detection and suppression

systems were not degraded, and there were no c mponents in this area whose failure

would rqsult in an accident initiator (i.e., loss of of site power, loss of main feedwater,

etc.) ,se e finding only affected the mitigating sy tems cornerstone. (Section 1R05.02)

Green. A Non-cited violation of Technical Specifi tion 6.8.1.a. was identified for

inadequate procedure guidance related to the tran ition from abnormal operating

procedure (AOP)-N.01, Plant Fires, to AOP-C.04, hutdown From Auxiliary Control

Room, in the event of a severe fire in the control ilding. AOP-N.01 did not clearly

delineate what conditions would require entry into OP-C.04 and evacuation of the

My. Also, AOP-N.01 did not direct operators t enter AOP-C.04 in the event of a -

sevefe fire in the control building.

This finding had a credible impact on safe in that, t e inadequate guidance in

procedure AOP-N.01 could delay entry into . 4 and could challenge the operators'

ability to perform certain critical safe shutdown functions (e.g., isolate normal charging,

establish adequate seal injection flow to the RCPs) within the times specified in the

licensee's safe shutdown calculation for Appendix R. This finding was determined to be

of very low safety significance because it did not affect fire detection, fire suppression, or

fire barriers. (Section 1R05.05)

Licensee identified Findings

Two violations of very low safety significance which were identified by the licensee were

reviewed by the inspection team. Corrective actions taken or planned by the licensee

appear reasonable. (Section 40A7)

A

Report Details

2. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems

1R05 FIRE PROTECTION

.01 Systems Required To Achieve and Maintain Post-Fire Safe Shutdown (SSD)

a. Inspection ScoDe

The team evaluated the licensee's fire protection prog aai applicable

requirements, including the Sequoyah Nuclear'(SQN) 1 Units 5and 2 fF- l -

License Conditions 2.C(16) and 2.C(13) respectively-, F ei tle 10 of the Code

14S

of Federal Regulations Part 50 (10 CFR 50) Appendix Rll GIII.J, 111.0, and lII.L;

Appendix A of Branch Technical Position (BTP) Auxiliary and Power Conversion Systems /St,

Branch (APCSB) 9.5-1; 10 CFR 50.48; related NRC Safety Evaluation Reports (SERs); /

NUREGS and the Technical Specifications (TS).

The team used the licensee's Individual Plant Examination for External Events (IPEEE)

a in-Ian alkdowns to select four risk significant fire areas (FAs) for inspection. The

tfouire area c were:

Fire Area FAA-029, Auxiliary Building, Elevation 690: Auxiliary Building Corridor

This FA includes rooms 690.0-Al, A9, Al 0*\1 3, A14, A17, Al8, A22,tX, A23a, A24,

A27, A30 and A31. This area contains both trains of safe shutdown,,equipment or cables"

and is classified as a 10 CFR Ret 50 Appendix R, III.G.2 area. A significant fire in this

area would require shutdown of either unitbfrom the main control room (MCR).

Fire Area FAA-067, Auxiliary Building, Elevation 734: 6.9 kilovolt (kV) Shutdown Board

Rooms

This des rooms 734.0-A2 and AThis includes both units train A'

auxiliary electric power switchgear. This area S-ct d as a%10 fFRPat-50Appendix

R, llI.G.2. A significant fire in this W ould require shutdown of either unit from the

MCR. Or ,

1107

Fire Area FAC-009, Control Building, Elevation 685: Unit 1 Auxiliary Instrument R

This FA includes control ro safeSS nSS equipment fro e e

-Fomn This area is cla dsas an gerCrt Appendix R, Il .G.3 a. A significant

fire in this area woul involve'evacuation of the MCR and alternative shutdown from the

remote shutdown panuin the Auxiliary Control Room ' 7 R~located inhe-Auxilry

Fire Area FAC-20, Control Building, Elevation 732: Relay Ro JrA/roc a,

This FA includes high voltage electrical relay equipment for offsite power and is located

adjacent to the MCR complex. A significant fire in this area may result in a fire induced

loss of offsite power (LOOP). This are* assified as v1* CFR it -50 Appendix R,

III.G.3 area. A fire in this area woul reqrvacuation of the MCR and alternate

shutdown from the remote shutdown panel using the ACR,*loea in tho-Auxiliary

/0/1/ N 7'

The team reviewed the IPEEE, ppe ix A to calculation SQN-26-D054/EPM-ABB-

lMPFHAMYFire Hazards Analysis (F A), the Sequoyah Fire Protection Report (FPR),

associated procedures, and drawings to identify those systems credited for SSD

of the facility in the event of a fire i the elected fire areas. The inspection included

review of the post-fire SSD capability ande fire protection features o ensure that at

least one post-fire SSD success t was m ained free of fire da ageirnthe event of

ad. L, Bt0,S -r vb

For a selected sample of SSD syste" omponents, and plant monitoring instruments, , nel 7

the team reviewed the SQN Fire PF I Fz rt, the FHA, applicable fire protection

, R

elated-SERs and NUREGS, and system flow diagrams to evaluate the completeness 9

and adequacy of the FPR and the systems relied upon to mitigate fires in the selected

fire areas.

The team inspected the capability to shutdown for the scenario where a fire in FA FAC-

20,BRelay-4emr could initiate a LOOP. The team inspected the control circuits and

associated circuit analysis for the diesel generators to determine whether any devices in

the control circuit were located in FA FAC-20. In a similar manner, the control circuits for

the 6. iV)shutdown board incomig cruit briedkF (i.e. offite poxwor-and diesels

9S_ erwere reviewed to determine whether a fire in FA FAC-20 could

with opening of the offsite breaker or closing the diesel generator breaker.

b. Findings f

No findings of significance were identified.

.02 Fire Protection of Safe Shutdown CaDability

a. InsDection Scope

The team reviewed the licensee's the FPR for FAs FAA-029 and F 7o determine

whether redundant trains of components or circuits required forae s o )re

located in the spm8 FA. From those components, the team selecr i

charging pumpsYA and 1 tri charirgfow isolation valves 1-FCV-

62-90 a n9 spatial separation or

proper fire'a'rrier protection features were l s a fI6ccordance with the design

requirements of 10-F-FR54 Appendix R. For the seleiced cdblaes1he team examined

cable routing, raceway drawings, the actual configuration of the circuits, fire barriers, fire

detection, and fire suppression equipment as applicable for conformance to applicable

NRC requirements and National Fire Protection Association (NFPA) standards. In

addition the team walked down these FAs to verify that the licensee documentation

reflected the as-built configuration.

Team members also walked down thetselected FAsihtcomparethe associated fire

fighting pre-plans and drawings with as-built plant conditions. This was don erif

tha~qwere consistent with the fire protection features and potential fire condions

/ - -descrTed in the FPR all the team reviewed engineering evaluations

associated with th reactor auxilia uilding floor and ufr o ,45O

v ose actions required for post-fire Votive S 5 ould not be inhibited by

(7 A fire suppression activities or leakage from fire su s ystems. IThe team reviewed

fire brigade response, training, Wd drill rogram procedures. Fire brigade drill critiques

for operating shifts from 1999 _Las well as fire brigade training/drill records for , 6o

the rire hat fire brigade drills had been conducted in

high fire risk plant areas and thiltircfliade personnel qualifications, brigade drill

response, and brigade performance met the requirements of the licensee's approved fire

protection program.

The team reviewed selected portions of the SO1THiA and pWa&*e ,gsr Se

prevention/combustible hagards aol procedures to Gt the

conditions established in A fire rotection licensing basis document w

The team performed walkdopwns of fhe four selected St FAs to o be e he

licensee's aetivA4e limit ire hazards A consistent wit~poeures.

The team reviewed the fre brigade response fire emergency/incident repot from 1999

through 2001, as well as the~ft Problem Evaluation Reports (PERs) resulting from fire,

smoke, sparks, arcing, and equipment overheating incidents. This review was conducted

to assess the effectiveness of the fire prevention program and to identify any

maintenance or material condition problems related to fire incidents. Additionally, design

control procedures were reviewed to verify that plant changes were adequately reviewed

for the potential impact on the fire protection program, SSD equipment, and procedures

as required by SQN license conditions 2.Cj16) and 2.C.(13).

A ?

.-The team walked down the primary fire brigade staging and dress-out areas to assess

the condition of fire fighting and smoke control equipment. Fire brigade personal

protective equipment located in the fire brigade house, dress-out area and lockers in the

fire brigade staging area were reviewed to evaluate equipment accessibility and

functionality. The team observed whether emergency exit lighting was provided for

personnel evacuation pathways to the outside exits as identified in the NFPA 101, Life

Safety Code. This review also included examination of whether backup emergency

lighting was provided for access pathways to and within the fire brigade staging and

dress-out areas in support of fire brigade operations should power fail during a fire

emergency. The adequacy of the fire brigade self-contained breathing apparatus

(SCBAs) was reviewed as well as the availability of supplemental breathing air tanks.

The team reviewed the RCPvoil collection system enclosure drawings to vefy compliance

with 16-6fR-50 Appendix RESection 111.0. Th evaluatig f operator

response procedures to determine if sufficient procedural guidance was provided toft ie f /07

plal~tueperl bee to identify a oil leak fromgtho

one-of-the C Aoo dtk prpi cin. il

b. Findings )P J

A Non-cited violation (Green) of Part 50, Appendix R,Section III.G.2,

I2/CFR

identified for failure to ensure one of the redundant trains of a system cessary to

achieve and maintain hot shutdown conditions in the -eventva fire Free of fire

damage. Electrical cables for redundantcharging flow isolation valves 1-FCV-62-90 and

1'CLJ' 6-'?1 ( -9were located in'FA FAA-029, the'A y i ror,-without spatial separation

or fire barriers. A

,iFm~ FAA-0 29 , the FHA indicated that reactor coolant system (RCS) inventory

control was achieved through isolation of normal charging and letdown while maintaining

RCP seal flow cooling. Through review of associated system prints and safeutdowr<*St

procedures AOP-N.01 and AOP-N.08, the team noted that the stepto acieve charging

flow isolation while continuing RCP eal flow cooling frem- c-' oTwas to

close either valve 1-FCV-62-90 o& These valves were in series and powered from

redundant power sources. The FHA indicated that power and control cables for both

these valves were routed closer than the 20 feet specified in Appendix R, Ill.G.2.b in a

relatively small sub-area of FA FAA-029. Conduitkowings 1,2-45N824-7 and 1,2-

45N824-16 depicted the routing for these cables. FP'a`valkdown of the cable routing, i

PI

the team verified that there was a location where the unprotected cables for valves( 7

andItwere separated by approximately 16 feetsy t they 1uI darnaged-b~.aa t

severelfe-The team noted tPat in liu of protecting the Oandgbcables in accordance 1

wit.b.Appendix R, s afi ~ d from the main cfro , the licensee

I/o6FA5 - c orated steps in the shutdown procedure AOP-N.08 to manipulate valvei)

Tb both thve pcrLng ?ow could be damaged by a

credible fire in FAA-029 Led VIeatr t m r could affect tot-

RCP seal injection flow and RWr seal integrity. The finding was found to have credible

impact on safety in that fire damage to the unprotected cables could prevent closure of

the valves from the MCR and challenge the operators' ability to establish adequate flow

to the RCP seals. The ignition frequency for the sub-area in question was taken from

-theSQNIPEEE-as-1.85E-3 per year. -The team observed that fire detection and

suppression was installed throughout FA FAA-029. Manual suppression capability and

the automatic suppression system were deemed to be in the normal operating state by

the team. The fire mitigation frequency was conservatively calculated to be once per 105

years. The missing barrier condition existed for greater than 30 days. Based on these

factors, the finding was processed using the Phase 2 transient sheet and subsequently

characterized by the Significance Determination Process as having very low risk

significance (Green). This was because the ignition frequency was relatively low, fire

detection and suppression systems were not degraded, and there were no components

in this area whose failure would esult in an accident initiator (i.e., loss of offsite power,

loss of main feedwater, etc.)*" the finding only affects the mitigating systems

cornerstone.

The failure to protect cables with an adequate fire barrier orprovide 20 foot separation

between redundant charging flow isolation valves is a violation of 10 CFR 50, Appendix

....

R, 111.%.fZJKwhich Ierules that unpratected cabdles of ieduiddanttran3bc zcp ar

-O hvoriAntal dictars uf yit~aiei ihaii 20 t. Thi7violation is being treated as a Non-

cited violation and is identified as NCV 50-327/02-003-01. The licensee documented the

violation in PER 02-03645.

.03 Post-Fire SSD Circuit Analysis

a. Inspection Scope G

The tean~~ that selected cables of e4uipment required to achieve and maintain hot , g

shutdown conditions in the event of fire in selected FAs had been properly identified and

either adequately protected from the potentially adverse effects of fire damage or

analyzed to show that fire-induced faults , ir, w ho

,xjound)would not prevent safe shutdown. The team select d powerycontrol and

instrumentation circuits indicated to be credited for safe 454d6wn in the licensee's FHA)

and walked down the routing of the circuits. The circuits selecte were:

Fire Area FAA-067: 1-L068-335, Pressurizer level indication 1r

Fire Area FAC-009: FI-3-1 63C, Auxiliary feedwater flow to steam generator 1.

Fire Area FAC-20: Diesel generator start button

Additionallythe team reviewed selected keelrical coordination studies to verify

that fire induced faults on energized non-shutdown circuits would not prevent the success

of the SSD functions. Specifically, the team reviewed overcurrent protection devices

related to the control circuit for cenrfugeherging -purnCCP1A from,5wr source at

125 volt (V)vital battery board 1 to the circuit breaker close and trip circuits. The

manufacturer's time-current characteristics were checked;and installed devices were

examined and compared to design information. The team reviewed the coordination of

overcurrent devices on the alternat, n rrent (AC) sytem. From the licensee's FHA,

the team reviewed those buse or a fire in A FAA-029. Phase fauls and

ground faults on the 6.9 kV system re consid erdand a review of the 6.9 s stenrtd

coordination was performed for a ase fault on cable emanating from 4 88hutdown

board 1AI-A, reactor MOV board kAl-A and ER MCC 1A-A. T the extent possible

installed devices were examined acompared toein docutr!

b. Findings

No findings of significance were identified.

.04 AkeffnlefiAitd ASQCaDabiltv J-0 Y -~ 5Y8 sA

a. Inspection Scope

The team reviewed the licensee's procedures for fire response anj ASD capability for the gF

,FAs selectedtoq verify conformance with applicable requirem ents(en Section

1R05.01 abov This review included the licensee's ASD methodology to determine the

ht .

adequacy of the identified cor onents anstems to achieve and maain safe

shutdown. The review also *4at the methodology a ressed achieving

and maintaining hot and cold shutdown from outside the MCR, with without off-sit

power available. The team also reviewed the licensee's procedures a t-verifyt

pr

consistency with the calculations and assumptions supporting the operator actions

identified in the ASD methodology.

The team selected several circuits wherRjch, control or instrumentation devices were

determined to be located at the auxiliet panel or other local panels. The team

reviewed relevant drawings to determine wh ther isolation devices were appropriately

designed into the following circuits: 7

Control circuit for the centrifugal charging pump

AFW flow to the steam generator FI-3-163C

Volume control tank outlet isolation valve LCV-62-132 (MOV)

CCP flow to RCS coolant loop 1 FCV-62-85 (AOV)

Source range flux monitor Xl-92-5,

The team erif hot and cold shutdown could be maintained from outside the MCR)

without o sie power through the review of emergency diesel generatEDGYand

breaker circuits. 0-

b. Findings

No findings of significance were identified.

.05 ODerational ImDlementation of Ae iv tn Capability

a. Inspection Scope f

The team reviewd the operational i mlementation of post-fire *afeshutdown capability

for a fire in thekselected FAs to t: (1)the training program for licensed and non-

licensed personnel included alternative or dedicated SSD capability; (2) personnel

required to achieve and maintain the plant in hot standby from outside the MCR could be

provided from normal onsite staff, exclusive of the fire brigade; (3) adequate procedures

existed for use during ASDand A) the licensee periodically performed operability testing ?

eninstn tationaer an contrfunctions. The team reviewed the

A contents of lockers tder`that materials needed to support

implementation of operator actions specified in the ASD procedures for hot standby were

available and properly maintained. Fire brigade staffing was reviewed to& that it met

the requirements of the licensee's fire protection program. Training requirements were

reviewed for the fire brigade members and related support personnel such as incident

commander , reactor operator (O), senior reactor operator (8RM, and auxiliary

operatorst 2vfy compliance with the licensee's fire protection program. Lesson plans

gkx..

and job performance measures (JPMs) were reviewed to determine whether ASD

,¢ f ~activities were included in the training program.

..- +~> Post-fire safe-shutdown procedures forthe selected areas were reviewed to determine if

~4;BA Yt /adequate staffing and approprate guidance was provided for the operators to identify

_ ~ pro6tected equipment and I tfumentation and those recovery actions specified in post-

fireshutdown procedu sidered manpower needs for performing restorations and

P.area accessibility. Spec procedures reviewed included Abnormal Operating

Procedure (AOP)-N.01, Plant Fires, Revision (Rev)14; AOP-N.08, Appendix R Fire Safe

j A

Shutdown, Rev 0; AOP-C.04, Shutdown Eom Auxiliary Control Room, Rev 4. Selected

procedure sections were walked down that the procedures could be performed

within the times specified in the supporting calculations, given the minimum required

staffing level of operators, concurrent with a loss of offsite power. Additionally, the team

walked down the designated pathways and reviewed the licens oke control

procedures, ventilation systems, and the availability of SCBAsdQy-Ls that

environmental conditions, such as smoke and heat, would not prevent operators from

performing the procedures.

b. Findings

One finding of very low safety significance (Green) was identified as a Non-cited violationion11Z

of Technical Specification 6.8.1.a. for inadequate procedure guidance related .,

to the transition from AOP-N.01, IP-ant-fes, to AOP-C.04, ShutdownfomnAailiary

Copyg4Rm, in the event of-a severe fire in the Control Building.

March 2 O2, the team identified that the guidance contained in AOP-N.01 was not

AA601- adequate to transition operators to AOP-C.04, in that, AOP-N.01 did not clearly delineate

what conditions would require entry Into AOP-C.04 and evacu ion of the MCP. Also,

AOP-N.01 failed to direct operators to enter AOP-C.04 in the event of a severe fire in the

-Control Building. The lack of clear guidance in AOP-N.01 was noted during a

walkthrough by the team of the procedures AOP-N.01 and AOP-C.04 with operations

-personnel. The team observed-that the lack of adequate guidance in AOP-N.01

appeared to contribute to the operators' confusion regarding the entry conditions for

-AOP-C.04 and the transition from-AOP-N.01 to AOP-C.04-.-This team determined that

the confusion could cause thvperator to delay entry into AOP-C.04 and the

performance of time critica SD a tions.

This finding had a credible impat on safety, in thatiI'I inadequate guidance in

procedure AOP-N.01 could del& nyiojtoAOP-"4 and could challenge the operators'

ability to perform certain critical sa t n functions (e.g., isolate normal charging,

establish adequate seal injection flow to the RCPs) within the times specified in licensee

calculation SQN-SQS4-0127, Equipment Required for Safe Shutdown Per 10 CFR50

Appendix R, Rev 21. This finding affected the mitigating systems cornerstone and was

determined to be of very low safety significance (Green) using Attachment F to the

Significance Determination Process (SDP), because it did not affect fire detection, fire

suppression, or fire barriers.

Sequoyah Technical Specification 6.8.1.a. and Regulatory Guide 1.33, Rev 2, Appendix

A, Item 6.v, requires, in part, that written procedures be established, implemented, and

maintained for plant operations during emergencies such as plant fires. Embodied in this

requirement is that the procedures have to be adequate. Contrary to the above, the

licensee failed to establish adequate procedural guidance in AOP-N.01, Plant Fires, to

proVide sufficient guidance to operators with regard to what conditions would require

_entry-into AOPj:.04 for-safe-shutdown from outside of the MCR.

Because of the very low safety significance of this issue and because the licensee has

entered this issue in their corrective action program as PER 02-003550, this violation is

being treated as an NCV, consistent with Section VL.A of the NRC Enforcement Policy.

This violation is identified as NCV 50-327, 328/02-03-02, Inadequate Procedure

Guidance for Implementing Abnormal Operating Procedures for Plant Fires.

The team noted other observations during the procedure reviews and walkthroughs

which could challenge operator performance of safezehitown activities. The following

are examples of the types of observations identified: 55-

The validation method for the latest revisions to AOP-N.01 and AOP-C.04 lacked

thoroughness in that, a "tabletop review" was performed instead of a field validation.

Time requirements specified in calculation SQN-SQS4-0127 for performing certain

critical safe-shutdown functions were not incorporated into AOP-C.04.

AOP-C.04, Checklist 5 required an excessive amount of time (more than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) to

complete. The checklist appeared to contain va~eus-unnecessary items and was not

developed to minimize time. The team noted that an additional field validation of AOP-

C.04, Checklists 5 and 6 was performed the week of March 11, 2002. However, this

validation verified accuracy of component identifiers and tags, but did not evaluate

timeliness.

AOP-C.04 and AOP-N.08 were inconsistent in specifying the time required to re-

establish seal injection flow to the RCPs (i.e., AOP-C.04 specified as soon as possible

and AOP-N.08 specified 15 minutes);

. Weaknesses were identified in the operators' understanding and familiarity with AOP-

N.01, AOP-N.08, and AOP-C.04.

.06 Communications for Performance of Alternative SSD Capability

a. Inspection Scope

The team reviewed the licensee's communications systems separation analysis

the availability of the comy ucation system to support plant personnel in the

performance of al wrrtions and fire brigade duties. Walkdowns

were performed of sections of D procedure AOP-C.04 to evaluate the

adequacy of the plant communication systems to support plant personnel in the

performance of alternative SSD functions. -The team reviewed the adequacy of credited

'I

redundant communications~systems aneg'etd e licensee's portable radio channel

features would operate should the radio repe-ers for the primary communications

system be unavailable. The team also examined Whether sound-powered phone jacks

were present at the locations identified in the aferAWiAmhutdown procedure as

designated by the SQN Updated Final Safety Analysis Report (UFSAR). This review

'--included examination of theisourid powered phone periodic test record and inventory

-surveillance records of post-fire SSD operator equipment to assess whether the

surveillance test program was.sufficient to verify proper operation of the system.

b. Findings

No findings of significance were identified.

.07 Emergencv Lighting for Performance of ASD Calabilitv

a. InsDection ScoDe

The team walked down select e eas where equipment would be controlled or

monitored during post-fir dn to observe whether battery pack emergency lighting QL

units (ELUs) were installed to allow operation of the equipment if normal lighting was lost

-In s6me'cases the installed ELU§-were-tes'ted to demonstrate functionality, and the

llocations and identification numbers on the ELUs were compared to design documents to

assure the as-built configuration was consistent with the design. The team also reviewed

licensee periodic test documentation to verify that the ELUs were being maintained in an

operable manner.

b. Findings

No findings of significance were identified.

.08 -Cold Shutdown ReDairs

a. LnsDection ScoDe - -

.. ..... .... .-

-

-4 O"_ II .

The team randomly selected a component, %rom the section of the FHA that listed (M

repairs that may be needed to achieve cold shutdown, and evaluated th aprb for

success of the repair. The component chosen was the RHR system ion valve1

FCV-074-001 specified for FA FAA-029. The review consideredhte level of difficulty of

the repair as compared to expected skills of the person assigned to perform the task,

adequacy of relevant procedures, and the availability of necessary materials.

b. Findings

No findings of significance were identified.

.09 Fire Barriers and Fire Area/Zone/Room Penetration Seals

a. Inspection Scope

The team walked down the selected FAs to evaluate the adequacy of the fire resistance

of FA barrier enclosure walls, ceilings, floors, structural steel support protection, fire

barrier penetration seals, fire doors, fire dampers, and electrical raceway fire barrier

systems (ERFBS) to ensure that at least one train of SSD equipment would be

maintained free of fire damage. IThe team observed the material condition and

configuration of the installed fire barrier features, as well as, reviewed construction details

._and.supporting fire endurance-tests-for the installed fire barrier features. The team

compared the observed fire barrier penetration seal configurations to the design drawings

and tested configurations. The team also compared the penetration seal ratings with the

ratings of the barriers in which they were installed.

The team reviewed ASD procedures, selected fire fighting pre-plan procedures, and

heating ventilation and air conditioning (HVAC) systems to verify that access to remote

shutdown equipment and operator manual actions would not be inhibited by smoke

migration from one area to adjacent plant areas used to accomplish SSD.

In addition, the team reviewed the licensing documentation, Generic Letter (GL) 86-10

engineering evaluations of fire barrier features, and engineering evaluations for NFPA

code deviations to verify that the fire barrier installations met design requirements and

license commitments.

b. Findings

No findings of significance were identified.

.10 Fire Protection Systems. Features. and Equipment

a. Inspection Scope

The team reviewed flow diagrams, cable routing information, periodic test procedures,

engineering evaluations for NFPA code deviations, and operational valve lineup

procedures associated with the electric driven high pressure service water fire pumps

and fire protection water supply system. The review was to determine whether the

common-fire-protection water delivery and supply components could be damaged or

inhibited by fire-induced failures of electrical power supplies or control circuits.

Additionally, team members walked down portions of the fire protection water supply

system in the selected areas to assess the material condition, operational effectiveness,

and whether the installed configurations were within the parameters of the engineering

evaluations.

The team verified that adequate fire protection features were installed in accordance with

the separation and design requirements in Appendix R to 10 CFR Part 50, Section

Ill.G.2. The team walked down accessible portions of the fire detection and alarm

systems in the selected plant areas to evaluate the engineering design and operation of

the installed configurations. The team also reviewed engineering drawings for fire

detector spacing and locations in the selected plant areas to verify effectiveness of the

systems and compliance with the licensee's FPR and associated NFPA code of record.

Team members walked down the selected areas with sprinklers to assure proper

placement and spacing of the sprinkler heads and the lack of sprinkler head obstructions.

The team reviewed design calculations to verify that the required fire hose water flow and

sprinkler system density for each protected area were available. The team reviewed a

sample of manual fire hose lengths to verify that they could reach the SSD equipment.

Additionally, the team verified whether the placement of the manual fire fighting fire hose

equipment and fire extinguishers were properly reflected in the fire brigade pre-fire plans.

The team reviewed the adequacy of the design and installation of the carbon dioxide

(CO2) fire suppression system for the FA FAC-009. This review included CO2 fire

suppression system controls to assure accessibility and functionality of the system and

associated ventilation system fire dampers. [The team also reviewed licensee design

calculations, vendor certifications, and pre-operational test data to verify that the required

quantity of CO2 for the area was available. Additionally, the team reviewed several

drawings, schematics, flow diagrams, and evaluations associated with the area floor

'drain'system to verify that systems and operator actions required for alternative SSD

would not be inhibited through potential leakage from C02 fire suppression activities.

b. Findings

No findings of significance were identified.

.11 Comnensatorv Measures

a. InsDection Scope

The team reviewed several licensee identified deficiencies, which dealt with maintaining

one redundant train of SSCs free from fire damage in accordance with 10 CFR 50

Appendix R III.G.2. The review was performed to verify that the risk associated with the

adverse conditions were properly assessed and adequate compensatory measures

adequately considered IPEEE risk insights and were implemented in accordance with the

approved fire protection program.

b. Findinas

No findings of significance were identified.

.12 Identification and Resolution of Problems

a. InsDection ScoDe

The team reviewed a sample of PERs related to fire protection and protection of SSCs

for SSD in accordance with 10 CFR 50 Appendix R III.G, III.J. and 111.0 to verify that

items were captured in the licensee's corrective action program in accordance with SPP-

3.1, Corrective Action Program, Rev 4. The items selected were reviewed for

classification and for the appropriateness of the corrective actions taken to resolve the

issues. The team reviewed self-assessments and audits related to the fire protection and

safe shutdown programs to assess whether the licensee was performing comprehensive

audits of these programs in accordance with the requirements set forth in Appendix A of

BTP APCSB 9.5-1.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

40A6 Meetings

Exit Meeting Summary

The team presented the inspection results to Dennis Cole, and other members of

licensee management and staff at the conclusion of the inspection on March 28-29, 2002

and on April 24, 2002. The licensee acknowledged the findings presented. No

proprietary information is included in this report.

40A7 Licensee Identified Violations

The following findings of very low significance were identified by the licensee and are

violations of NRC requirements which met the criteria of Section VI of the NRC

Enforcement Policy, NUREG-1600 for being dispositioned as NCVs.

NCV Tracking Number Reauirement Licensee Failed to Meet

50-327, 328/02-03-03 10 CFR 50 Appendix III.J states that emergency lighting

units with at least an 8-hour battery power supply shall be

provided in all areas needed for operation of safe

shutdown equipment and in access and egress routes

thereto. The licensee identified during a self-assessment

that the need for emergency lighting for the 1, 2FCV-63-

001 had not been provided. Manual operation of these

valves is required in the event of a severe fire in

accordance with licensee shutdown procedures. The

failure to provide adequate illumination of manual actions

required for safe shutdown is identified as a Non-cited

violation of 10 CFR 50, Appendix R Il.J. The issue is in

the licensee's corrective action program as PER 02-

000550-000 (Green).

50-327, 328/02-03-04 10 CFR 50 Appendix R III.G. 2. states that except as

provided for in paragraph G.3 of this section, where cables

or equipment, including associated non-safety circuits that

could prevent operation or cause maloperation due to hot

shorts, open circuits, or shorts to ground, of redundant

trains of systems necessary to achieve and maintain hot

shutdownconditions are located within the same FA

outside of primary containment, one of the following

means of ensuring that one of the redundant trains is free

of fire damage shall be provided: (a.) Separation of cables

and equipment and associated non-safety circuits of

-~- ~ ~~~ redundant trains'by a fire barrier having a 3-hour rating.

Structural steel forming a part of or supporting such fire

barriers shall be protected to provide fire resistance

equivalent to that required of the barrier; (b.) Separation of

cables and equipment and associated non-safety circuits

of redundant trains by a horizontal distance of more than

20 feet with no intervening combustible or fire hazards. In

addition, fire detectors and an automatic fire suppression

system shall be installed in the FA; or (c.) Enclosure of

-: . cable and equipment and associated non-safety circuits of

one redundant train in a fire barrier having a 1-hour rating,

Inaddition, fire detectors and an automatic fire

suppression system shall be installed in the FA. The

licensee identified during a self-assessment that as a

result of inadequate protection to the control/and or control

cables a spurious closure signal to the VCT level control

valves was credible. As the power cables for the RWST

suctions valves are in the same FA and not protected

there was an interaction which existed such that suction to

both the VCT and RWST could be lost. The licensee's

failure to provide adequate protection to prevent the

operation or the maloperation of cables or equipment

necessary to achieve and maintain hot shutdown is

identified as a Non-cited violation of 10 CFR 50 Appendix

R llI;G.2. [The issue is in the licensee's corrective action

program as PER 02-000576-000 (Green).

PARTIAL LIST OF PERSONS CONTACTED

Licensee

J. Bajraszewski, Licensing Engineer

J. Bible, Maintenance and Modifications Manager, SQN

J. Beasley, Site Quality Manager, SQN

P. Boulden, Engineer, SQN

D. Craven, TPS-TOM Service Manager, SQN

T. Davis, Fire Protection Supervisor, WBN

B. Dukes, Engineer, SQN

R. Egli, Fire Protection Systems Engineer, SQN

K. Frazier, Systems Engineer, SQN

E. Freeman, Operations Manager, SQN

R. Gladney, Electrical Design Manager, SQN

J. Gomez, Lead Electrical Engineer, WBN

R. Goodman, Training Manager, SQN

0. Hayes, Operations Support Superintendent, SQN

P. Johnson, Fire Operations, SQN

D. Koehl, Plant Manager, SQN

D. Lundy, Engineering Manager, SQN

J. Patrick,'Senior Specialist, SQN

J. Pierce, Engineer, SQN

D. Porter, Operations, SQN

R. Proffitt, Nuclear Engineer, SQN

J. Reynolds, Nuclear Assurance, SQN

R. Rogers, Engineering Design Manager, SQN

P. Salas, Licensing and Industrial Affairs Manager, SQN

B. Simril, Fire Protection Specialist, SQN

J. Smith, Licensing Manager, SQN

J. Thomas, Mechanical/Nuclear Erigineering Supervisor, SQN

E. Turner, Electrical Engineering Design, SQN

J. Wilkes, Operations Superintendent, SQN

NRC

C. Pay'ne7-Senior Reactor Inspector, Ril

R. Tellson, Resident Inspector

ITEMS OPENED, CLOSED, and DISCUSSED

Oened and Closed

50-327/02-03-01 NCV Failure to Provide Adequate Protection for Cables to

Redundant SSD Components (Section 1R05.03)

50-327, 328/02-03-02 NCV -Inadequate Procedure Guidance for Implementing

-- Abnormal Operating Procedures for Plant Fires (Section

1R05.05)

50-327, 328/02-03-03 NCV Inadequate Emergency Lighting for the RWST Suction

Valve (Section 40A7)

50-327, 328/02-03-04 NCV Failure to Provide Adequate Protection for Cables to the

VCT Suction Valves (Section (40A7)

Closed

None

Discussed

None

LIST OF ACRONYMS

ACR Auxiliary Control Room

AOP Abnormal Operating Procedure

APCSB Auxiliary and Power Conversion Systems Branch

ASD Alternative Shutdown

.BTP.- Branch Technical Position

CFR Code of Federal Regulations

DC Direct Current

EOP Emergency Operating Procedure

ELU Emergency Lighting Unit

FDW/FW Feedwater

FSAR Final Safety Analysis Report

HVAC Heating, Ventilation, and Air Conditioning

IPEEE Individual Plant Examination for External Events

JPM Job Performance Measure

LP/LPI Low Pressure Injection

MCR Main Control Room

NCV Non-cited Violation

NRC Nuclear Regulatory Commission

PER Problem Evaluation Report

PORV Power Operated Relief Valve

PRA Probabilistic Risk Assessment

RCP Reactor Coolant Pump

RCS/RC Reactor Coolant System

SCBA Self-Contained Breathing Apparatus

SDP Significance Determination Process

SER Safety Evaluation Report

SLC Selected Licensee Commitment

SSA Safe Shutdown Analysis

SSD Safe Shutdown--...---

TS Technical Specifications-

UFSAR Updated Final Safety Analysis Report

URI Unresolved Item

LIST OF DOCUMENTS REVIEWED

Procedures:

0-AR-M-29, Annunciator Response Fire Detection System, Rev 8

0-PI-OPS-000-708.0,1 OCFR50 Appendix R Compliance Verification, Rev 3

1-AR-M5-B, Annunciator Response CVCS Seal Water and RCP, Rev 28

1-SO-77-4, System Operating Instruction for Auxiliary Reactor Building Floor and Equipment

1-PI-OPS-000-010.A, Verification of Remote Shutdown Transfer Switches, Rev 0, Completed

11/13/2001

AOP-C.04, Shutdown From Auxiliary Control Room, Rev 4

AOP-N.01, Plant Fires, Rev 14

AOP-N.08, Appendix R Fire Safe Shutdown, Rev 0

SPP-9.3, Plant Modifications and Engineering Change Control, Rev 6

SPP-1 0.7, Housekeeping/Temporary Equipment Control, Rev 0S2

SSP-10.10, Control of Transient Combustibles, Rev 1

SSP-10.11, Control of Ignition Sources, Rev 1

SMI-0-317-18, Special Maintenance Instruction - Appendix R - Casualty Procedures, Rev 6

0-SI-FPU-031-001.R, Visual Inspection Fire Dampers, Rev 2

0-PI-FPU-317-299.W, Attachment 4, Operations Fire Protection Weekly Inspection, Rev 10

0-SI-FPU-410-703.0, Inspection of FPR Required Fire Doors, Rev 0

O-SI-234.6, Functional Test of Fire Protection Report Required Detectors, Rev 32

FPI-0102, Appendix C Active Permits (Impairments), dated March 26, 2002

Pre-Fire Plan No. AUX-0-690-00, Auxiliary Building, Elevation 690'- 0, Rev 1

Pre-Fire Plan No. AUX-0-690-01, Auxiliary Building, Elevation 690'- 0, Rev 1

Pre-Fire Plan No. AUX-0-690-02, Auxiliary Building, Elevation 690'- 0, Rev 5

Pre-Fire Plan No. AUX-0-734-00, Auxiliary Building, Elevation 734'- 0, Rev 2

Pre-Fire Plan No. AUX-0-734-01, Auxiliary Building, Elevation 734'- 0, Rev 4

Pre-Fire Plan No. AUX-0-734-02, Auxiliary Building, Elevation 734'- 0, Rev 3

Pre-Fire Plan No. AUX-0-734-03, Auxiliary Building, Elevation 734'- 0, Rev 4

Pre-Fire Plan No. CON-0-685-00, Control Building, Elevation 685'- 0, Rev 3

Pre-Fire Plan No. CON-0-732-00,- Control Building, Elevation 732'- 0, Rev 4

Job Performance Measures (JPMs) and Lesson Plans:

Lesson Plan OPL273C0202, Appendix R Fires (AOP-N.01, AOP-N.08, AOP-C.04), Rev 0

JPM CRO-005, Evacuate the Control Room, Rev 13

JPM CRO-052, Perform Required Actions in Preparation for Manning the SSF, Rev 4

PERS, Audits. and Self-Assessments:

Fire Protection and Loss Prevention Program Audit (Biennial\Triennial) No. SSA0101

Fire Protection and Loss Prevention Program Audit (Annual) No. SSA0001

Fire Protection and Loss Prevention Program Audit (Triennial) No. SSA9802

Self Assessment Report, SQN-OPS-09-001 Rev 1

Self Assessment Report ,SQN-OPS-01-007

Attachment

2

PER 00-011423, Sequoyah Does not Perform Periodic Functional Testing on Alternate

Shutdown Transfer Switches and Controls, dated 12/15/2000

PER 01-009956, Handswitches Had to be Cycled to Pass Continuity Checks During

Performance of Procedure 0-PI-OPS-000-010.A, dated 11/2/2001

PER 01-010214, Discrepancies During Performance of Procedure 1-PI-OPS-000-010.A,

dated 11/8/2001

Calculations

SQN-26-D054/EPM-ABB-IMPFHA, Sequoyah Fire Hazards Analysis Calculation, Rev 31

SQN-SQS4-0127, Equipment Required for Safe Shutdown Per 10 CFR 50 Appendix R,

Rev I

SQN-APPR-1, Analysis of AC/DC Instrument and Control (I&C) Power Systems to Identify

Associated Circuits - 10 CFR 50, Appendix R, Sheets 16A, 16B, 16C, 17, 37, 46, 54, 76 & 79C

of 131, Appendix R Common Power Supply Analysis, Rev 7 [Coordination 125 VDC Vital

Battery Board 1,11, III & IV]

SQN-APS-003, 480 V APS Class 1E Load Coordination Study, Time-Current Curve # 2, Sheet

C-6, Rev 15 [480 V shutdown boards]

SQN-APS-003, 480 V APS Class 1E Load Coordination Study, Time-Current Curve # 3, Sheet

C-7, Rev 12 [480 V reactor mov boards]

SQN-APS-003, 480 V APS Class 1E Load Coordination Study, Time-Current Curve # 8, Sheet

C-13, Rev 28 [480 V ERCW PMP STA MCCs]

Drawing Numbers

1-47W809-1, Unit 1 Chemical and Volume Control System Flow Diagram, Rev 64

1, 2-47W810-1, Units 1 and 2 Residual Heat Removal System Flow Diagram, Rev 39

1-47W811-1, Unit 1 Safety Injection System Flow Diagram, Rev 57

1, 2-47W813-1, Units 1 and 2 Reactor Coolant System Flow Diagram, Rev 49

2-47W809-1, Unit 2 Chemical and Volume Control System Flow Diagram, Rev 64

2-47W811-1, Unit 2 Safety Injection System Flow Diagram, Rev 48

1,2-45N767-1, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-1 Rev 26

1,2-45N767-2, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-2 Rev 31

1,2-45N767-3, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-3 Rev 23

1,2-45N767-4, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-4 Rev 20

1,2-45N767-5, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-5 Rev 15

1,2-45N765-1, Wiring Diagrams 6900 V Shutdown Aux Power Schematic Diagram Sht-1, Rev

14 [6900 V Shutdown board 1A-A normal feeder breaker 1718]

1,2-45N765-2, Wiring Diagrams 6900 V Shutdown Aux Power Schematic Diagram Sht-2, Rev

16 [6900 V Shutdown board 1A-A emergency feeder breaker 1912]

1-45E890-104-1, 10 CFR 50 Appendix R RCS Pressure Control Operational & Spurious CA

Keys 1,2,4,5,6&9, Rev 4 [conduit and tray plan for charging pump cables in FAA-029]

1,2-45N824-7, Conduit & Grounding Floor Elevation 690.0 Ceiling Plan, Rev 2 [conduit plan for

62-90 & 91 valve cables]

Attachment

3

1,2-45N824-16, Conduit & Grounding Floor Elevation 690.0 Details - Sht-4, Rev 0 [conduit plan

for 62-90 valve cables]

1,2-45N826-8, Conduit & Grounding Floor Elevations 706.0 & 714.0 Ceiling Plan, Rev 2,

[Routing of pressurizer level circuits]

-1 45E890-103-1,ri:10 CFR 50 Appendix R RCS Inventory Control Operational & Spurious CA

Keys 1,2,4,5,6 & 9, Rev 3 [Routing of pressurizer level circuits]

1-45E890-103-2, 10 CFR 50 Appendix R RCS Inventory Control Operational & Spurious CA

Keys 1,2,4,5,6 & 9, Rev 1, [Routing of pressurizer level circuits]

1-45E890-102-2, 10 CFR 50 Appendix k RCS Inventory Control Operational & Spurious CA

Keys 1,2,4,5,6 & 9, Rev 1, [Routing of pressurizer level circuits]

1-47W610-3-3, Mechanical Control Diagram Auxiliary Feedwater System, Rev 17

1,2-45N812-5, Conduit & Grounding Floor 685.0 Details - Sht 3, Rev 1 [Routing of cables for

diesel generator start button] -

1,2-45N765-16, Wiring Diagrams 6900 V Shutdown Aux Power Schematic Diagram Sht-16,

Rev 17 [Centrifugal charging pumps]

1,2-15E500-1, Key Diagram Station Aux Power System, Rev 22

1,2-45N779-1 1, Wiring Diagrams 480 V Shutdown Aux Power Schematic Diagram Sht-1 1, Rev

24, [MOV LCV-62-132]

1,2-45N662-1, Wiring Diagrams Chemical & Volume Cont Sys Schematic Diagram Sht-1, Rev

10, [AOV LCV-62-85]

1-47W610-92-1, Mechanical Control Diagram Neutron Monitoring System, Rev 3

1,2-47A381 -111, Mechanical Heating & Ventilation & Air Conditioning Dampers, Rev 3

1,2-47A381-113, Mechanical Heating & Ventilation & Air Conditioning Dampers, Rev 2

1,2-47W494 series, Fire Protection Fire Cells, Rev 6

1,2-47W600-250, Mechanical Instruments and Controls Fire Detectors, Rev 5

1,2-47W600-254, Mechanical Instruments and Controls Fire Detectors, Rev 2

1,2-47W61 0 series, Control Diagram High Pressure Fire Protection System, Rev 21

1,2-47W611 series, Logic Diagram Fire Detection System, Rev 12

1,2-47W849-1, Flow Diagram Hydrogen System for.Generator Cooling, Rev 31

1,2-47W850-2, Flow Diagram Fire P-rotection,-Rev 25

1,2-47W850-6A, Connectivity Diagram Fire Protection System, Rev 0

-42-47-W866-2, Fow-Diagramr-Heating-&-Ventilation Air Flow, Rev 11.

1,2-47W866-4, Flow Diagram Heating & Ventilation Air Flow, Rev 32

1,2-47W880-26, Conduit and Grounding Cable Tray Fire Stop, Rev 2

1,2-48W990-1, Miscellaneous Steel Fire Protection Reactor Coolant Pump Hood, Rev 3

1,2-48W991-1, Miscellaneous Steel Fire Protection Reactor Coolant Pump, Rev 6

1,2-47W920-8, Mechanical Heating & Ventilation & Air Conditioning, Rev 3

ML040090230

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