ML040120108

Phase 1 Screening Worksheet for IE, Ms and B Cornerstone

ML040120108
Person / Time
Site:	Saint Lucie
Issue date:	03/18/2002
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0358, IR-03-002
Download: ML040120108 (3)

Text

SDP PHASE I SCREENING WORKSHEET FOR IE, MS, and B CORNERSTONES ReferencelTitle (LER #, Inspection Report #, etc): St. Lucie TFPI IR 50-335,389/03-02 (Fire Area C)

Performance Deficiency (concise statement clearly stating the deficient licensee performance): The licensee credited the use of manual operator actions outside the MCR for 10 CFR 50, Appendix R, Section III.G.2 areas (Fire Area C/Fire Zone 34), in lieu of physical protection of cables and equipment relied on for SSD during a fire, without obtaining prior NRC approval of these deviations 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.

Factual Description of Identified Condition (statement of facts known about the finding, without hypothetical failures included): Train A 480V load center 2A5 was located in the Train B SWGR room (Fire Area C / Fire Zone 34). Train A 480V motor control center (MCC) 2A6 was located in the Train A SWGR room (Fire Area A / Fire Zone 37). The safe shutdown analysis (SSA) identified that load center 2A5 supplied power to MCC 2A6 via cable 21703A. Safe shutdown using Train A equipment is credited. A fire in the Train B SWGR room would damage cable 21703A, causing a loss of power to load center 2A5 which, in turn, causes a loss of power to MCC 2A6. Loss of MCC 2A-6 would result in the loss of power to essential Train A equipment required for SSD such as: boric acid makeup pump; valves FCV-3306,V3659, V3664, V3536, V3444, MV-07-3, (LT-2206).

System(s) and train(s) degraded by identified condition:

Licensing Basis Function of System(s) or Train(s) (as applicable): This finding involved a violation of NRC requirements. The licensee was not in compliance with their approved Fire Protection Program in that, one train of equipment required to achieve and maintain safe shutdown during a fire was not maintained free of fire damage and manual operator actions were required.

Other Safety Function of System(s) or Train(s) (as applicable):

Maintenance Rule category (check one):

risk-significant non-risk-significant Time that identified condition existed or is assumed to have'existed: More than 30 Days Functions and Cornerstones degraded as a result of this Identified condition (check V)

INITIATING EVENT CORNERSTONE Transient initiator contributor (e.g., reactor/turbine trip, loss offsite power)

Primary or Secondary system LOCA initiator contributor (e.g., RCS or main steam/feedwater pipe degradations and leaks)

MITIGATION SYSTEMS CORNERSTONE BARRIERS CORNERSTONE Core Decay Heat Removal Degraded RCS LOCA Mitigation Boundary Degraded (e.g., PORV block valve, PTS issue)

V Initial Injection Heat Removal Degraded Primary (e.g., Safety Inj)

Containment Barrier Degraded V Low Pressure Reactor Containment Degraded High Pressure Actual Breach or Bypass Secondary - PWR only (e.g., AFW)

Heat Removal, Hydrogen or Pressure Control Degraded Long Term Heat Removal Degraded (e.g.,

ECCS sump recirculation, suppression pool Control Room, Aux Bldg, or Spent cooling)

Fuel Bldg Barrier Degraded V

Reactivity Control Degraded Fuel Cladding Barrier Degraded V

Fire/Flood/Seismic/Weather Protection Degraded

- Page of 3 I

I 0609, App A,-Att 1 Issue Date: 03/18/02

SDP PHASE 1SCREENING WORKSHEET FOR IE, MS, and B CORNERSTONES Check the~apprpriate boxes v If the finding Is assumed to degrade:

1.

fire protection defense in depth (DID), detection, suppression, barriers, fire brigade. STOP. Go to IMC 0609, Appendix F.

YES - This finding degraded the DID. A fire in the B SWGR room would cause a loss of Train A MCC 2A6 in the A SWGR room (and Train A SSD equipment powered from MCC 2A6) because power cable 21703A to MCC 2A6 was not protected.

2.

the safety of a shutdown reactor. STOP. Go to MC 0609. Appendix G l

3.

the safety of an operating reactor, Identify the degraded areas:

Initiating Event Mitigation Systems RCS Barrier Fuel Barrier Containment Barriers

4.

Two or more of the above areas degraded STOP. Go to Phase 2

5.

If only one of the above areas is degraded, continue only in the appropriate column below.

Initiating Event

1. Does the finding contribute to the likelihood of a Primary or Secondary system LOCA initiator?

If YES-Stop. Go to Phase 2 If NO, continue

2. Does the finding contribute to both the likelihood of a reactor trip AND the likelihood that mitigation equipment or functions will not be available?

If YES-Stop. Go to Phase 2 If NO, continue

3. Does the finding increase the likelihood of a fire or internatlexternal flood?

If YES -* Use the IPEEE or other existing plant-specific analyses to identify core' damage scenarios of concern and factors that increase the frequency. Provide this input for Phase 3 analysis.

If NO, screen as Green Mitigation Systems

1. Is the finding a design or qualification deficiency confirmed not to result in loss of function per GL 91-18 (rev 1)?

RCS Barrier or Fuel Barrier

1. RCS Barrier I if YES-screen as Green I

If NO, continue

2. Does the finding represent an actual loss of safety function of a System?

Stop.

Go to Phase 2

2. Fuel Barrier screen as Green If YES-Stop. Go to Phase 2 If NO, continue

3. Does the finding represent an actual loss of safety function of a single Train, for > its Tech Spec Allowed Outage Time?

If YES-Stop. Go to Phase 2 If NO, continue

4. Does the finding represent an actual loss of safety function of one or more non-Tech Spec Trains of equipment designated as risk significant per 1 0CFR50.65, for >24 hrs?

If YES-Stop. Go to Phase 2 If NO, continue

5. Does the finding screen as potentially risk significant due to a seismic, fire, flooding, or severe weather initiating event, using the criteria on page 3 of this Worksheet?

If YES -

Use the IPEEE or other existing plant-specific analyses to Identify core damage scenarios of concern and provide this input for Phase 3 analysis.

If NO, screen as Green Containment Barriers

1. Does the finding only represent a degradation of the radiological barrier function provided for the control room, or auxiliary building, or spent fuel pool, or SBGT system (BWR)?

If YES -' screen as Green If NO, continue

2. Does the finding represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere?

If YES -

Stop. Go to Phase 3 If NO, continue

3. Does the finding represent an actual open pathway in the physical Integrity of reactor containment or an actual reduction of the atmospheric pressure control function of the reactor containment?

If-YES -

Stop. Go to Appendix H of IMC 0609 If NO, screen as Green Page 2 of 3

.0609, App A, Att 1 Issue Date: 03/18/02

SDP PHASE I SCREENING WORKSHEET FOR IE, MS, and B CORNERSTONES Seismic, Fire, Flooding, and Severe Weather Screening Criteria

1. Does the finding involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g., seismic snubbers, flooding barriers, tornado doors)? (Equipment and functions for the mitigation or suppression of fire initiating events, such as thermal wrap or sprinkler systems, should be evaluated using IMC 0609 Appendix F and are not evaluated here)

If YES -

continue to question 2 If NO -

skip to question 3

2. If the equipment or safety function is assumed to be completely failed or unavailable, are ANY of the following three statements TRUE? The loss of this equipment or function by itself, during the external initiating event it was intended to mitigate a) would cause a plant trip or any of the Initiating Events used by Phase 2 for the plant in question; b) would degrade two or more Trains of a multi-train safety system or function; c) would degrade one or more Trains of a system that supports a safety system or function.

If YES -

the finding is potentially risk significant due to external initiating event core damage sequences - return to page 2 of this Worksheet If NO, screen as Green

3. Does the finding involve the total loss of any safety function, identified by the licensee through a PRA, IPEEE, or similar analysis, that contributes to external event initiated core damage accident sequences (i.e., initiated by a seismic, fire, flooding, or severe weather event)?

If YES -

the finding is potentially risk significant due to external initiating event core damage sequences - return to page 2 of this Worksheet If NO, screen as Green Result of Phase I screening process:

Screen as Green Go to Phase 2 Go to Phase 3 Important Assumptions (as applicable):

Page 3 of 3 0609, App A, Att Issue Date: 03/18/02