ML040120108
| 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 Mitigation Systems RCS Containment Barriers
- 1. Does the finding contribute to 1. Is the finding a design or Barrier or 1. Does the finding only represent a the likelihood of a Primary or qualification deficiency Fuel degradation of the radiological barrier Secondary system LOCA confirmed not to result in loss of Barrier function provided for the control room, or initiator? function per GL 91-18 (rev 1)? auxiliary building, or spent fuel pool, or
If YES-Stop. Go to Phase 2 I ifYES- screen as Green Barrier If YES -' screen as Green If NO, continue I If NO, continue Stop.
Go to If NO, continue
- 2. Does the finding contribute to 2. Does the finding represent Phase 2 both the likelihood of a reactor an actual loss of safety function 2. Does the finding represent a trip AND the likelihood that of a System? degradation of the barrier function of the mitigation equipment or control room against smoke or a toxic functions will not be available? If YES-Stop. Go to Phase 2 2. Fuel atmosphere?
Barrier If YES-Stop. Go to Phase 2 If NO, continue screen as If YES - Stop. Go to Phase 3 Green If NO, continue 3. Does the finding represent If NO, continue an actual loss of safety function
- 3. Does the finding increase the of a single Train, for > its Tech 3. Does the finding represent an actual likelihood of a fire or Spec Allowed Outage Time? open pathway in the physical Integrity of internatlexternal flood? reactor containment or an actual If YES-Stop. Go to Phase 2 reduction of the atmospheric pressure If YES -* Use the IPEEE or control function of the reactor other existing plant-specific If NO, continue containment?
analyses to identify core' damage scenarios of concern 4. Does the finding represent If-YES - Stop. Go to Appendix and factors that increase the an actual loss of safety function H of IMC 0609 frequency. Provide this input for of one or more non-Tech Spec Phase 3 analysis. Trains of equipment designated If NO, screen as Green as risk significant per If NO, screen as Green 10CFR50.65, 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 Page 2 of 3 3 analysis.
If NO, screen as Green
.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