ML040090283
| ML040090283 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/22/2003 |
| From: | Deem R, Fillion P, Jape F, Reinaldo Rodriguez, Matt Thomas, Sandra Walker, Wiseman G NRC/RGN-II |
| To: | |
| References | |
| FOIA/PA-2003-0358 IR-03-002 | |
| Download: ML040090283 (4) | |
Text
X Charlie Pavne - STL03-02FP debrief.Wpd Paae I I Paoe
' ChrIi Pvne - STLO3-O2FP debrief .wod ENGINEERING BRANCH I FIRE PROTECTION INSPECTION DEBRIEF Inspection of: St. Lucie Nuclear Plant Report Number: 50-335,389/03-02 Inspection Dates: March 10-14 and 24-28, 2003 (onsite inspection)
Type of Inspection: TRIENNIAL FIRE PROTECTION BASELINE INSPECTION: Fire Protection Features and Post-Fire Safe Shutdown Capability Inspectors: M. Thomas, Lead/Operations Inspector; G. Wiseman, Fire Protection Inspector; S.
Walker, Electrical Inspector; P. Fillion, Electrical Inspector (Open Items Followup); F. Jape, Operations Inspector (Training); R. Deem, Contractor (Mechanical Systems/Operations);
Accompanying Personnel: R. Rodriguez, Nuclear Reactor Safety Intern, will be in training and support the open items followup/Electrical areas.
Inspection Scope: This inspection was conducted in accordance with revised Inspection Procedure 71111.05, Fire Protection, dated 03/23/01, and the NRC Reactor Oversight Process.
The inspection team focused their review on the separation of the systems and equipment necessary to achieve and maintain safe shutdown and fire protection features of these plant areas. The team used IPEEE data, with assistance from the RII Senior Risk Analyst, to identify risk significant plant areas and components among those with the highest CDFs and CCDPs.
The fire areas/fire zones chosen for review during this inspection are:
- 1. Unit 2 Fire Area B - Cable Spreading Room (Fire Zone 52). Afire in this area could result in evacuation of the Unit 2 main control room (MCR) and the plant could be brought to cold shutdown from a remote location even with the loss of all unprotected equipment and cables in Fire Zone 52. Use of Train "A" equipment is credited for a fire in this area.
- 2. Unit 2 Fire Area C - Dual elevation fire area encompassing Fire Zone 34 (Train "B" Switchgear Room) and Fire Zone 48 (Electrical Equipment Supply Fan Room).
Fire Area C and the essential equipment and cables within, have been evaluated with respect to the protection and separation criteria of Appendix R,Section III.G.2 to assure that the ability to safely shut down the plant is not adversely effected by a single fire event. Safe shut down of Unit 2 from the MCR using Train A"equipment is credited for a fire in this area.
- 3. Unit 2 Fire Area I - consists of Fire Zone 51 West (Cable Loft), Fire Zone 21 (Personnel Rooms), Fire Zone 32 (PASS and Radiation Monitoring Room), Fire Zone 331 (Instrument Repair Shop), and Fire Zone 23 (Train "B" Electrical Penetration Room). Fire Area I and the essential equipment and cables within, have been evaluated with respect to the protection and separation criteria of Appendix R Section III.G.2 to assure that the ability to safely shut down the plant is not effected by a single fire event. Safe shut down of Unit 2 from the MCR using Train A"equipment is credited for a fire in this area.
.I - -- - -- - . -
I Charlie Pavne - STL03-02FP debriet.wpci Pane 2l lha1i Pa*y*ne - STO-O2F =ere~p Pae2 INSPECTION RESULTS: Two Findings were identified.
Finding No. I Silicone oil filled transformers in Unit 2 fire areas were not evaluated in the Fire Hazards Analysis (FHA) as required by the Fire Protection Program commitments. The affected fire areas were Fire Area A (Fire Zone 37, A SWGR Rm); Fire Area C (Fire Zone 34, B SWGR Rm); and Fire Area QQ (Fire Zone 47, Turbine Bldg SWGR Rm). This inding is More Than Minor. The 380 gallons of transformer silicone dielectric cooling fluid in each transformer was not evaluated In the FHA as contributors to fire loading and effects on SSD In FZ 34, 37 or 47.
Note: This finding affects:
- 1. Existing fire protection licensing bases (deviations to Appendix R granted by the NRC)
- 2. Current engineering evaluations allowed under GL 86-10 for fire protection barriers or systems not submitted to the NRC (CR 02-0396, Derated Thermo-Lag fire barrier wall partition separating the CSR and B Switchgear Room)
- 3. IPEEE Risk Analysis for Fire Events (the transformers were likely not accounted for in ISDS and could affect total CDF for the fire areas.
- 4. The maintenance and surveillance programs for transformer related fluid sampling and condition evaluations. (Note: Will be followed up by Resident inspectors).
The licensee initiated CRs 03-0637 and 03-0978 to address this finding Missed Opportunities For Identification:
- In 1997 the licensee conducted an UFSAR Combustible Loading Update evaluation documented in PSL-ENG-SEMS-97-070 but failed to identify that the transformers in fire zone A37 contained combustible silicone fluid.
- PSL Triennal FP Audit in 2001 documented in QA audit Report QSL-FP-01-07 reviewed the FHA but did not identify any fire loading discrepancies.
Findina No. 2 Use of Manual Operator actions outside the MCR for III.G.2 areas (Fire Area C and Fire Area I) without prior NRC approval. Many manual operator actions were used in lieu of physical protection of cables and equipment relied on for SSD during a fire. This was a deviation from the approved Fire Protection Program. The licensee identified this issue in CR 03-0153 prior to this inspection. This finding is More Than Minor. This finding will be Unresolved pending completion of the SDP to determine the risk associated with using the manual operator actions in lieu physical protection. (NOTE: The NRC and the Nuclear industry are working to resolve this issue on a generic basis).
2
(
rI Charlie J**
Pavne
--- STL03-02FP r
debrief.wod E
Pace 31 In addition to the two findings, eight condition reports (CRs) were written as a result of this inspection. The CRs were evaluatedagainstand determinedto meet the NRC criteriafor minor issues and will not be discussed in the report details.
CR 03-0847 Hot shutdown repairs using tools to achieve safe shutdown in the event of a fire CR 03-0888 Update UFSAR to delineate that Deviation C6 previously approved by the NRC for fire areas A & C is no longer required CR 03-0942 Discrepancies between the safe shutdown analysis (SSA), essential equipment list (EEL), and the breaker/fuse coordination study CR 03-0964 Rubatex insulation installed on instrument lines in the U2 intake (fire area R-R) is not considered In the FHA CR 03-0965 Combustible fire load for U1 and U2 intake fire areas same in the field but different values listed each unit's FHA CR 03-0966 Temp Mod (installation of fans between cable spreading room and B SWGR room) did not sufficiently evaluate potential impact on fire protection CR 03-0986 Discrepancies between SSA and EEL. Determined that EEL was in error CR 03-1010 Cold shutdown repairs identified in licensee procedures, but UFSAR states that no credit is taken for post-fire repair of cold shutdown equipment Open Items Reviewed: Three open items assigned to EB1 were reviewed for closure.
URI 50-335,389/99-08-03, PORV Cabling May Not Be Protected From Hot Shorts Inside Containment (Closed - Green NCV)
LER 50-335,389/00-001, Outside Design Bases Appendix R Hi-Lo Pressure Interface and Separation Issues LER 50-335/00-004, Pressurizer Level Instrumentation Conduit Separation Outside Appendix R Design Bases LESSONS LEARNED:
Successes:
- Followed up on three open Items
- ' Nuclear Safety Intern (Reinaldo Rodriguez) involvement and support on open Items
- Experience/knowledge of Fire Protection Inspector
- Resident inspector followup of licensee's sampling of transformer oil Challenges:
3
\I Charlie Pavne - STL03-02FP debrief.wpd Page 4 1
'I Pv - STO-2Pdbie-cdP~4
~hr~i
- Better coordination by team leader with licensee for open item followup
- Completing SDP for the open items
- Effect of fire on instrumentation needs to be reviewed in more depth and detail 4