ML041100731

Per Report, Work Order No. 01-000589-000

ML041100731
Person / Time
Site:	Sequoyah
Issue date:	03/01/2002
From:	Simril B Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0358
Download: ML041100731 (10)

Text

PER Report PER100 03/01102 Workorder: 01-000589-000

,'Status: CD Entry Date: 01/29/2001 09:49 Planner/Supv: WALTER JUSTICE Requested By: BRENDA F. SIMRIL 843-8515 "SUPERVISOR PER Level Rev Level 00 Identified By LINE ORGANIZATION Self Revealing N Problem Description Fire Interaction Manual, 0-GO-8, has a generic step in Section 5.0 to isolate non-essential air to containment in the event that letdown isolation valves fail open.

The step directs operators to close one of the following valves: 1 -FCV-32-110, 2-FCV-32-111, 0-32-718, -724, -725, or -731. PER 00-000072-000 was written during Fire Ops Self-Assessment, SA-OPS-00-01, to document that the above valves were not listed as Appendix R valves in the Fire Safe Shutdown (FSSD)

Calculation, S')N-SQS4-0127, or the Fire Hazards Analysis Calculation, SQN-26-DO54IEPM-ABB-IMPFHA.

The original PER was closed based on the determination that if letdown must be isolated following a fire, closure of either FCV-62-69, FCV-62-70, or all three of the letdown orifice isolation valves (FCV-62-72, -73,

-74) would accomplish this function (Ref. Key 7 of SQN-SQS4-127). All five of the System 62 valves are air-operated and can be isolated by closing the subject System 32 valves. The primary means for operating the System 62 valves is via the electrical controls to the valves. The valves are designed to fail closed upon loss of electrical current or control air to the solenoids. Based on this design feature, it was previously determined that isolation of non-essential air to containment was provided as an alternate means for isolating the CVCS letdown line, and was not a required Appendix R strategy. However, upon further review of the FHA calculation, cases have been discovered where isolation of control air has been credited for Appendix R compliance (e.g., FAA-081 and

-84 in FHA calc credit control air isolation to justify the fire rated barrier between the two fire areas, and Key 7 of FSSD calc notes that isolation of control air

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PER Report PER100 03/01102 to containment can be utilized to fail close the letdown valves for RCS pressure boundary isolation).

Pit Process Equip Y Potential Oper Issue Y Potential Reportable N Potential DegradlNoncon(91-18)

ASME N Systems Affected N/A Systems Affected Systems Affected Systems Affected Units Affected 1 &2 Recommendation Process PER No action, Justify If Process,PER Level C If Utilize ACP, No Immed Action Taken One of the above listed System 32 valves per unit is required to be closed in order to isolate Control Air.

It appears that FCV-32-110 and -111 cannot be used for App. R compliance since the associated cabling has not been analyzed for potential interactions. The 32-718 and -731 valves are located high off of the floor and are not easily accessible. The 32-724 valves and -725 valves are located in the Unit I El. 690 pipe chase and are equipped with pull chains to allow timely operator actions. However, emergency lighting is not currently provided in the area, which is required by the Fire Protection Report (FPR) for operator actions required within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of an Appendix R event. As an compensatory action until Appendix R emergency lighting can be installed, an alternate lighting means must be provided. Hand held lighting units, which are described as an acceptable backup to 8-hr battery packs in Part II, Section 14.7 and Part V, Section 2.0 of the FPR, are available. Procedure 0-PI-OPS-000-708.0 maintains operability of portable lanterns credited as the alternate lighting compensatory measures, which will ensure their availability. This has been coordinated with Dave Porter, Operations representative on the Appendix R team. A standing order will be issued by Operations which will document the compensatory action for this condition as well as other emergency lighting deficiencies. Based on the

,eej.oan ruiea an iasage PER Report PER100 03101/02 availability of backup lighting, it is determined that this PER does not constitute a plant operability issue.

Recommended Resp Org ENGIMECH Coordinated With wmjustice Init Sup-First Last wrnjustice Init Sup Phone 8340 Init Department ENG/MECH Init Sup Review Date 0113012001

-LEVEL D INFORMATION Lvl D Causing Org LvI D Causing Crew Human Perf Proc Code Apparent Cause LvA D Process/Proced Hardware Disposition Technical Justify Init Supv-First Last Init Supv Phone Mit Sup Review Date

• --OPS **A Functional Eval (FE) N FE Due Date Affect Operability Y If Yes,Units/Actions Sequoyah is in FOR 3.7.14 Action "A". We are in compliance with action "A" by use of the hand held lighting units.

Offsite OP Review Y Op Review BFN Y Op Review BLN Op Review SON Op Review WBN Y Reportable N If Yes, List Basis Ops SROISTA-Fst Last Loyd Hodges Ops SRO/STA Rev Date 02/0212001

• -** FE --

Functional Maint Potential Degrad/Noncon(91-18)

FE/Eval Due Date Initial Evaluation 91-18 Degrad Nonconf N FunctionaltEval Basis Immed/Comp Measures

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r ot r PER Report PER100 03/01/02 List Action/Measures Engineer Date Supervisor Date OPS SRO/STA-Fst Last OPS SROISTA Rev Date MRC Process PER Level C Interim Action Req'd N If YES, Specify RCA Required N Site Qual ConcNer N Assigned Resp Org ENG/MECH CA Develop Due Date 03/05/2001 MRC Directions 91-18 Issue MRC CAP Review N MRC-First Last Shirley Smith MRC Review Date 02/02/2001

• "- Resp Org CA Develop Due Date 03/05/2001 Section ENG/MECH POC-First Last POC Phone Reactivity Mgt Issue N AtB-LER N LER No.

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Control of NonConfor N If Yes, Scope Hardware Disposition Disposition RIM/EDMS Offsite Generic Rev Y Generic Rev BFN Y Generic Rev BLN N Generic Rev Corp N Generic Rev SON Generic Rev WBN Y Process/Procedures CAUSE DATA Apparent Cause The documentation involved with the Appendix R program at SQN is voluminous and complicated. The Fire Operating Procedure (0-GO-8), Fire Hazards Analysis (SQN-26-DO54IEPM-AB-IMPFHA), Fire Safe Shutdown

PER Report PER100 03/01/02 calculation (SQN-SQS4-0127), Appendix R drawing series, and cable block diagrams all contain Appendix R analysis and compliance information that must be used collectively in order to fully interpret all issues and conditions that were used in the original development of the program. Since the program was developed in the mid-80's timeframe, none of the originally involved personnel are still involved in the program. Hence.

due to the complexity of the program, assumptions and methodologies are not clearly evident in all instances.

For the subject of this PER, the original evaluation was that either FCV-62-69 or -70, or all three of the letdown orifice isolation valves, could be closed to isolate letdown in an Appendix R event via electric controls, as opposed to isolation of control air.

However, upon in-depth review of all Appendix R documentation during self-evaluat;.n Drocesses, it was discovered that revisions of the FHA subsequent to the original development had taken credit for control air isolation in justification of a derated fire barrier, as well as a note in the FSSD calculation that allows isolation of control air to fail close the letdown valves for RCS pressure boundary isolation.

The apparent cause of this PER is that inexperience of personnel combined with the inherent complexity of the program led to notes not being detected that contradicted the basis of the original PER justification.

Root Cause Causing Org ENGIMECH Causing Crew Human Perf Proc Code HP Perf Second Code Prev/Similar Event N/A Specify Search Basis Extent of Condition PER HUMAN PERF Human Perform Issue: Y Key Processes: ENG04

PER Report PER100 03/01102 Key Processes: ENG07 Event Precursors Task Demands: COMPLEX INFORM Individua Capability LACK OF PROFICIEN Work Environment: CONFUSING PROCED Human Nature:

Barrier Evaluation: FAILED BARRIER Error Mode: KNOWLEDGE BASED Latent Org Weakness:. DESIGN/MODIFICA PER CAJRC ITEMS 1 Action Item Evaluate adequacy of existing Appendix R emergency lighting for operator actions to manually operate VLV-32-724 and -725.

1 Action Type CORRECTIVE ACTION 1 Assigned Org OPS 1 CA Due Date 03/30/2001 1 AO Concur-Fst Last JIM DVORAK 1 AO POC Fst Last DAVE PORTER 1 CA Performed Performed walkdown and determined that existing App. R lighting is NOT adequate.

1 Date Completed 03/13/2001 2 Action Item Revise calcuation SQN-SQS4-0127 (FSSD Calc) to incorporate manual actions involving VLV-32-724, -725.

2 Action Type CORRECTIVE ACTION 2 Assigned Org ENG/MECH 2 CA Due Date 07/27/2001 2 AO Concur-Fst Last BRENDA SIMRIL 2 AO POC-Fst Last BRENDASIMRIL 2 CA Performed This action is being closed to Rev. 4 of PER 00-7928 and will be resolved by Corrective Action #14. Also, CA #14 will ensure documentation is revised to address repositioning of one head of Appendix R lighting unit (0-LGT-247-R155).

2 Date Completed 07/2312001 3 Action Item Revise 0-GO-8 to incorporate new manual actions for VLV-32-724. -725.

3 Action Type CORRECTIVE ACTION 3 Assigned Org OPS 3 CA Due Date 07/27/2001 3 AO Concur-Fst Last DAVE PORTER

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r-age PER Report PER100 03101/02 t3 AO POC Fst Last DAVE PORTER 3 CA Performed Incorporated manual actions in AOP-N.01 App. C, which replaced 0-GO-8.

3 Date Completed 07123/2001 4 Action Item Revise Part V of the Fire Protection Report to include VLV-32-724 and -725 as equipment illuminated by the associated emergency lighting unit.

4 Action Type CORRECTIVE ACTION 4 Assigned Org ENGIMECH 4 CA Due Date. 07127/2001 4 AO Concur-Fst Last BRENDA SIMRIL 4 AO POC-Fst Last BRENDA SIMRIL 4 CA Performed This action is being closed to Rev. 4 of PER 00-7928 and will be resolved by Corrective Action #14. Also, CA #14 will ensure documentation is revised to address repositioning of one head of Appendix R lighting unit (0-LGT-247-R155).

4 Date Completed 07/27/2001 CLOSURE COMMENTS FR1OM CA**-

CAP CONCUR PER Completion Date 07/27/2001 Prep-First Last Brenda Simril Preparer Date 03/05/2001 Telephone No (C) Supv-First Last John Thomas (C) Supv Ext 8224 (C) Supv Date 03/0512001 (B) DptMgr-Frst Last (B) DptMgr Date MRC Reqd N MRC Concurrence Reason for N MRC-First Last MRC Date (A) SiteSr-Fst Last (A) SiteSr Date (A) PItMgr-Fst Lst (A) PltMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N

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PER Report PER100 03/01/02

-Site Qual First Last Site Qual Date VERIFICATION Final Rev Level 00 Tags Rem-First Last Tags Date RO Verify Comp BRENDA SIMRIL RO Verify Date 07/27/2001 ANI/ANII Required N ANI/ANII Concurrence Reason for N ANI/ANII-First Last ANI/ANII Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date RO Supv Clos-Fst Lst JOHN THOMAS C's"ure Date 07/27/2001 EXTENSIONS REVISIONS ***--

""'GENERIC REVIEWS BFN Resp Org ENG/MECHANICAL' BFN Due Date 03/13/2001 BFN Gen Rev Results Information only copies distributed to Engineering/Design/Mechanical and Engineering/Design/Electrical BFN Review-Fst Lst DP WALKER BFN Review Date 03/13/2001 BLN Resp Org BLN Due Date BLN Gen Rev Results BLN Review-Fst Lst BLN Review Date CORP Resp Org CORP Due Date CORP Gen Rev Result CORP Review-Fst Lst CORP Review Date SON Resp Org

PER Report PER100 03/01102

.SQN Due Date SQN Gen Rev Results SQN Review-Fst Lst SON Review Date WBN Resp Org ENG/MECH WBN Due Date 03/05/2001 WBN Gen Rev Results Copy to BG Briody 03/05/01 for information only review.

WBN Review-Fst Lst TERESA WILSON WBN Review Date 03/05/2001 OPERABILITY REVIEWS BFN Notified-Fst Lst BFN Notified Date BFN Op Rev Results BFN Review-Fst Lst BFN Review Date SON Notified-Fst Lst SON Notified Date SQN Op Rev Results SON Review-Fst Lst SON Review Date WBN Notified-Fst Lst DUNCAN BENNETT WBN Notified Date 02/08/2001 WBN Op Rev Results Isolation of control air was not credited for letdown isolation at WBN. At WBN letdown isolation is via two separate and independent methods. Each Fire Safe Shutdown section of AOI-30.2 directs letdown isolation via HSs in the control room. Also a local FSSD HS has been added (at the Train B entrance to the ACR) to provide dedicated App R circuitry for closure of 1-FCV-62-69. Manipulation of thiselocal FSSD HS is dictated by AOI-30.2 for each case that warrants its use.

Control air isolation is not credited for any Fire Safe Shutdown Function at WBN.

WBN Review-Fst Lst DUNCAN BENNETT WBN Review Date 02/08/2001

-TRENDS Program Code FP Program Code Program Code

PER Report PER100 03/01/02

.INPO Code FP1 INPO Code NRC Code NRC Code Category PROCESS Short Term Code Impact 6.0 Behavior Code Org / Prog Code GEMS Other CAUSE CODES B2D Inadequate documentation provisions Total records selected:

1

• • • END OF REPORT^..