ML041170376

Handwritten Notes, Self Assessment Report, SQN-OPS-00-001, Revision 1

ML041170376
Person / Time
Site:	Sequoyah
Issue date:	04/09/2004
From:	Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0358, SQN-OPS-00-001, Rev 1
Download: ML041170376 (85)

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SQN-OPS-00-001 (rev.1)

FINAL REPORT 1

SELF ASSESSMENT REPORT Assessment Number: SQN-OPS-00-001 Dates of Assessment: 12/6/1999 to 12/17/1999.

Topic of Assessment: Fire Protection - Fire Safe Shutdown Operator Actions.

Lead Assessor: Dan C. Johnson (SQN) Other Assessors: James Young (WBN), David Porter (SQN),

Roy Ramsey (SQN), Brenda Simril (SQN), Calvin Burrell (SQN), I. M. Heatherly (CORP).

OBJECTIVES AND SCOPE The purpose of this assessment is to evaluate the Fire Protection Program as it relates to Appendix RJFire Safe Shutdown operator actions. The evaluation will be based on the existing program documents, procedures, and licensing requirements, and will utilize the draft NEI 99-05, "NEI Guidancefor Fire Protection Self-Assessments " as a guide. The self-assessment outline is included as Attachment A.

The assessment tasks and objectives were:

1. Review the Fire Protection Report and Licensing Basis requirements to determine the overall compliance in the area(s) of procedures for manual operator actions for post fire safe shutdown.

2. Examine a sample of plant areas and the adequacy of the post fire safe shutdown manual operator actions specified for those areas.

3. Review the effectiveness and interface of the Design Control program with the Fire Protection program by reviewing a sample of DCN's to ensure impacts on the Fire Protection Program, as it relates to manual operator actions, have been appropriately identified and addressed.

The criteria for this assessment was as follows:

1. The design basis documentation, including the Fire Protection Report and the Fire Hazards Analysis, should clearly document the design basis for the manual operator actions necessary to achieve fire safe shutdown in the event a fire.

2. The plant manual action procedure should be consistent with design basis calculation(s), Fire Hazards Analysis, and the Fire Protection Report.

3. The Fire Safe Shutdown Procedure should be clear and consistent, including restrictions and limitations.

The assessment was a multi-organizational review of the manual operator action portion of the Fire Protection Program. The review was performed by personnel technically qualified for the areas being reviewed.

SUMMARY

The self assessment review concluded that the manual operator action portion of the SQN Fire Protection Program could achieve safe shutdown conditions of both units in the event of a worst-case fire (Appendix

SQN-OPS-00-001 (rev.1)

FINAL REPORT 2

R fire) in any of the plant safety related areas. Based on this, the program meets the basic regulatory and TVAN requirements. Two (2) conditions adverse to quality were identified and PER's were written to address the issues.

The assessment also concluded that the procedures and documentation describing the methodology and actions for achieving safe shutdown conditions in the event of an "Appendix R fire" do not meet current TVAN expectations and industry standards as outlined in applicable sections of the draft NEI 99-05, "NEI GuidanceforFireProtection Self-Assessments ". This conclusion is based on the results of a sample review of plant procedures, design calculations, and design output associated with several areas. Twenty (20) areas for improvement were identified.

STRENGTHS No strengths were identified.

FINDINGS

1. 0-GO-8 Sect. 5.0 Step 6 directs isolating non-essential air to containment as a contingency action for isolating normal and excess letdown to control RCS inventory. However, the valves referenced in this step (I-FCV-32-110, 2-FCV-32-111, 0-32-718, -724, -725, and -731) are not listed in calculation SQN-SQS4-0127 nor in Fire Protection Report Table 111-2, which specify equipment required for fire safe shutdown. Also, it appears that that routing of the cables for l-FCV-32-110 and 2-FCV-32-111 may need to be analyzed for potential interactions, since non-essential air to containment is required for normal and excess letdown capability. PER 00-000072-000 written.

2. Steps in 0-GO-8 Appendix F for 480V Transformer Rooms 2A and 2B appear to be swapped. PER 99-011809-000 written.

AREAS FOR IMPROVEMENT

1. It appears that, in some cases, there is a lack of correlation between the actions specified in 0-GO-8 and the mitigative strategies specified in the FHA. A comprehensive review should be performed of 0-GO-8 and the Fire Hazards Analysis to identify, evaluate, and resolve the inconsistencies between the two.

PER 99-0011809 will track completion of this AF1.

2. 0-GO-8 does not clearly direct removing power from MOVs to prevent spurious actuations. Section 3.0 precaution E addresses removing power prior to local operation and Section 5.0 (note prior to step

2) suggests that power should be removed to prevent spurious operation, but the procedure does not clearly specify which valves should have power removed and relies on the operator to determine the appropriate breaker. For example, App. M Key 4 states that FCV-62-135/136 must be prevented from spurious closure; Appendix C Step AM-l lists the valves as having potential interactions but does not clearly address removing power.

PER 99-0011809 will track completion of this AFI.

SQN-OPS-00-001 (rev.1)

FINAL REPORT 3

3. 0-GO-8 does not address all potential interactions identified in the FHA for each fire area. Except for failed components which require specific manual actions to satisfy Appendix R, the procedure relies on operators monitoring control boards to recognize all failed/unreliable indications. Additional equipment impacts identified in the engineering documents should be included in 0-GO-8 as an enhancement.

PER 99-0011809 will track completion of this AFI.

4. Revise 0-GO-8 to resolve the following identified issues: (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 4)

Responsible Organization: Operations Due Date: 05/12/2000. Coordinated with J. Dvorak.

• 0-GO-8 does not address the need for SCBAs and does not address the likelihood of reduced visibility wvhen dispatching AUOs to perform manual actions during a fire in the Auxiliary Building.

• 0-GO-8 Section 3.0 Precaution H requires closure of FCV-63-1 to prevent loss of RWST inventory if a containment sump isolation valve (FCV-63-72 or 73) spuriously opens. It appears that closure of FCV-74-3 or 21 would be more appropriate in this scenario since these valves are normally energized and only impact one ECCS train. The RHR pump on the affected train should be placed in PULL TO LOCK prior to isolating the pump suction.

• 0-GO-8 Appendices M and N contain manual actions which are not referenced in the body of the procedure nor in the individual appendices used for various fire areas. These appendices contain primarily background information which may not be referred to in a timely manner during a fire event.

• 0-GO-8 App. C step Al -4 says that cables for MDAFW pumps and TDAFW pump interact and directs referring to 1,2-SO-3-2 for local manual control. This step does not provide sufficient information on what the potential failures are and what specific actions are required.

• 0-GO-8 App. C step Al-7 directs closing 2-FCV-63-72 & 73 if they spuriously open. Manual closure of these valves will require Maintenance unbolting the valve vault cover (a time-consuming task) and entry into a confined space. A step should be added directing removal of power from the valves prior to their spurious opening. Once power is removed with the valves in the closed position, unbolting the valve vault door should be unnecessary.

• 0-GO-8 Sect. 5.0 step [6] should be a sub-step of step [5] since, logically, the operator will not know whether the letdown valves have failed to close unless letdown isolation is required. Similarly, step

[11 ] should be a sub-step of step [10].

• Once an Appendix R fire is declared and 0-GO-8 is entered, it is recommended that a direct approach be used to direct the operators immediately to specific actions for the area involved and potentially preclude greater problems which may result from delay. Potentially some actions may be prudent before fire damage forces local manual effort. Verification of some valve positions and removal of power could be an example. Containment sump valves alignment or guaranteeing CCP suction are particular areas of concern for some areas.

5. AOP-N-01 should contain more specific guidance regarding determination of Appendix R fire and/or whether or not safe operations of the units can be maintained (i.e. FSSD equipment potential involvement by plant area). Additionally, FSSD actions should be considered a priority. Once a fire grows to Appendix R proportions, the priority for Operators is FSSD. AOP-N.01 should be revised for the Unit SRO(s) or the SM to recall Operators that have responded to the fire fighting or to other

SQN-OPS-00-001 (rev.1)

FINAL REPORT 4

stations in support of the fire alarm (e.g. the AUO at the fire pump house). (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 5)

Responsible Organization: Operations Due Date: 06/30/2000. Coordinated with J. Dvorak.

6. Operator training on 0-GO-8 should be evaluated for needed improvement and presented to the Operations Curriculum Review Committee. Specifically, previous training on this procedure appears to have been limited to classroom discussions. Since simulator scenarios have not been developed for major fires in safety-related areas, operators have not been adequately evaluated on their ability to carry out this procedure, including concurrent performance with EOPs (if the fire has caused a reactor trip or safety injection). Also, the lack of simulator scenarios has contributed to the deficiencies in 0-GO-8 due to the inability to validate the procedure through usage on the simulator. Additionally, training on 0-GO-8 has not emphasized considerations associated with entering a smoke-filled environment to perform manual actions during an Auxiliary Building fire (such as planning entry/exit routes, rotation of personnel with fresh SCBA bottles). (This AFI is loaded in TROI as SQN-OPS-00-00I seq. number 6 and 8)

Responsible Organization: Operations Superintendent Due Date: 05/12/2000 Coordinated with K. Wilkes Responsible Organization: Operations Support Due Date: 05/12/2000 Coordinated with 0. D.

Hayes

7. Calculation SQN-SQS4-0127 Key I (p.A2) incorrectly states that CCS is required for Centrifugal Charging Pump cooling. This statement should say that ERCW is required for cooling. The need for ERCW cooling is identified correctly in the calculation on page A4(This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 7)

Responsible Organization: Engineering Due Date: 08/25/2000. Coordinated with W.M. Justice

8. 0-GO-8 Appendix M incorrectly states that CCS is required for Centrifugal Charging Pump cooling.

This statement should say that ERCW is required for cooling. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 9)

Responsible Organization: Operations Due Date: 12/2212000. Coordinated with J. Dvorak.

9. 0-GO-8 Appendix M and calculation SQN-SQA4-0127 Key 28 (RCS pressure control) do not address the potential for a spurious SI signal. An evaluation is needed to determine whether the impact of a spurious SI signal on the RCS pressure control strategies has been adequately considered. (This AFM is loaded in TROI as SQN-OPS-00-001 seq. Number 10)

Responsible Organization: Engineering Due Date: 08/25/2000. Coordinated with W.M. Justice

10. Operations should evaluate whether 0-GO-8 should be converted to an abnormal operating procedure.

Since this procedure is used to mitigate an abnormal plant condition which could degrade into an emergency condition, it appears to meet the definition of an abnormal operating procedure (see FSAR 13.5.1.2.2). Also, reclassification as an AOP would ensure that this procedure is subject to the verification, validation, and training requirements consistent with other procedures used to mitigate abnormal plant conditions. (This AF1 is loaded in TROI as SQN-OPS-00-001 seq. Number 11)

Responsible Organization: Operations Due Date: 05/1212000. Coordinated with J. Dvorak

SQN-OPS-00-001 (rev.1)

FINAL REPORT 5

11. 0-GO-8 contains steps to install temporary ventilation in the 2B 480 V Transformer Room to prevent over heating of the room due to cable damage to the installed ventilation system for fires in the 2A 480 V Transformer Room and the Unit 2 Reactor Building Annulus. The FHA for the 2A 480 V Transformer Room and the Unit 2 Reactor Building Annulus does not identify the potential for cable damage to the ventilation system for the 2B 480 V Transformer Room and the need to install temporary ventilation. This represents a lack of correlation between 0-GO-8 and the FHA. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 12)

Responsible Organization: Engineering Due Date: 08/25/2000. Coordinated with W.M. Justice

12. Appendix 0 of 0-GO-8 provides the instructions to install temporary ventilation in the 480 V Transformer Rooms. Installation of this temporary ventilation system is a "repair procedure" as opposed to a "manual operator action" and would more appropriately be contained in the Appendix R Casualty Procedure, SMI-0-317-18. Revise SMI-0-317-18 to include the instructions in Appendix O of 0-GO-8. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 21)

Responsible Organization: Maintenance Due Date: 09/28/2000. Coordinated with S. Glickman

13. Revise 0-GO-8 to delete Appendix 0, which provides instructions to install a temporary ventilation system in the 480 V Transformer Rooms. Installation of this temporary ventilation system is a "repairprocedure" as opposed to a "manual operator action" and would more appropriately be contained in the Appendix R Casualty Procedure, SMI-0-317-18. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 13)

Responsible Organization: Operations Due Date: 12/22/2000. Coordinated with J. Dvorak.

14. A number of fires in the Auxiliary Building (i.e., large general areas) could result in required operator actions in a smoke filled environment. Battery pack lights have been installed for operator actions and the access/egress paths for these actions, however these light units may not provide adequate visibility in a smoke environment. Portable hand held lights/lanterns designed to penetrate smoke should be provided to assist the operators in performance of manual actions in smoke environments. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 14)

Responsible Organization: Fire Operations Due Date: 05/12/2000. Coordinated with D. Johnson

15. During review of manual operator actions specified for a fire in the general area on elevation 690 of the Auxiliary Building (Room 690-Al), the necessity for manual actions specified in 0-GO-8 to switch the CCP suction from the VCT to the RWST were questioned. The bases for this question was DCN M1893A, which provided interlocks to prevent the VCT suction to the CCP from isolating prior to the supply from the RWST to the CCP from opening. The circuits for this interlock function are protected with THERMOLAG except in the VCT Rooms. A fire in the VCT Room could cause an isolation of the VCT concurrently with a failure of the interlock to open the RWST valves, which would destroy an operating charging pump. Manual actions to open the RWST valves and start the remaining charging pump are available. 0-GO-8 and the FHA identify the need to realign the CCP suction to the RWST but do not address the potential interaction (loss of suction to the CCP and potential to destroy an operating CCP) and the need to start the remaining available CCP after realigning suction. Based on a review of the SQN-SQS4-0127, Appendix B, the FHA, and 0-GO-8, there appears to be areas of clarification needed in one or more of these documents. While no conflicts were identified between the reviewed documents, for long-term programmatic health of the program, a more detailed review of this area should be performed. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 15)

Responsible Organization: Engineering Due Date: 08/25/2000. Coordinated with WV.M. Justice

SQN-OPS-00-001 (rev.1)

FINAL REPORT 6

16. Revise 0-GO-8 to incorporate improvements identified by "Area For Improvement" number 15 above.

(This AFI is loaded in TRO! as SQN-OPS-00-001 seq. Number 16)

Responsible Organization: Operations Due Date: 12/22/2000. Coordinated with J. Dvorak.

17. Calculation SQN-SQS4-0127, Page B3, Key 5 path I => The second reference to LCV-62-135, -136 does not appear to be grouped appropriately. Review of a previous version of the calculation does not group the actions the same way. The calculation should be revised to correct this item. (This AFI is loaded in TROT as SQN-OPS-00-001 seq. Number 17)

Responsible Organization: Engineering Due Date: 08/25/2000. Coordinated with W.M. Justice

18. Calculation SQN-SQS4-0127 is currently treated as design output. The FHA, which also is considered design output, contains the credited manual operator actions, included in the calculation and is more appropriate as the source of design output for the manual operator actions. In light of the fact that the Fire Hazards Analysis (FHA) contains "Compliance Strategies" for the various fire areas and is also classified as design output, calculation SQN-SQS4-0127 should be treated as an input to the FHA and removed from the listing of approved design output calculations. (This AFI is loaded in TRO] as SQN-OPS-00-001 seq. Number 18)

Responsible Organization: Engineering Due Date: 08/25/2000. Coordinated with W.M. Justice

19. 0-GO-8 should be reviewed to identify the minimum staffing level required to support the worst case Appendix R fire. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 19)

Responsible Organization: Operations Due Date: 12/22/2000. Coordinated with J. Dvorak.

20. Revise the Fire Protection Report to capture the minimum operator staffing level to support the worst case Appendix R fire. (This AFI is loaded in TROI as SQN-OPS-00-001 seq. Number 20)

Responsible Organization: Engineering Due Date: 01/26/2001. Coordinated with W.M. Justice AREAS FOUND ACCEPTABLE

1. Although battery pack emergency lighting have been installed in areas containing manual operator actions and the access/egress paths thereto, it is recognized that poor visibility may present additional challenges to operators in the performance of these actions. Battery powered hand held lanterns are available to assist operators with manual actions in the plant in addition to the battery powered emergency lights. These lanterns are maintained and inventoried by the Operations Department in procedure 0-PI-OPS-000-708.0, I0CFR50 Appendix R Compliance Verification.

2. A thorough review of manual operator actions specified in 0-GO-8 for a fire occurring in the Auxiliary Building, elevation 690 general area (room 690-Al) was performed to determine adequacy of the procedure and the specified actions. This review also determined the number of operators that would be required to successfully complete the specified actions. This review concluded that the specified actions were acceptable and that adequate staffing (4 AUO's) was available to complete the specified actions.

3. An evaluation was performed to determine if correct decisions are being made in determining if components should be incorporated or deleted from the Appendix R shutdown logic calculation SQN-SQS4-0127 as plant modifications occur. The evaluation utilized an approved random sampling

SQN-OPS-00-001 (rev.1)

FINAL REPORT 7

process described in SPP-4.2 and the sample size selected provides a 98.5% accuracy. Of the DCN's and plant components evaluated there were no identified errors in determining if components should be incorporated or deleted from the Appendix R shutdown logic calculation. It can be concluded that modifications to the plant are being appropriately reviewed for impact on the Appendix R Fire Safe Shutdown program.

KEY PERSONNEL CONTACTED See "Survey of Licensed Operators on App. R Requirements" in Attachment C to this report.

REVIEW AND APPROVAL Oricinal signed by Dan C. Johnson 01/14/2000 Lead Assessor Date Original signed by H. H. Butterworth 01/14/2000 Department Manager Date Distribution: L. D. Clift, PSB 3A - SQN Masoud Bajestani, OPS 4A - SQN

Sequoyah Nuclear Plant Page 1 PER Report PER100 03/01/02 Workorder: 01-000589-000

• Status: CD Entry Date: 01/2912001 09:49 Planner/Supv: WALTER JUSTICE Requested By: BRENDA F. SIMRIL 843-8515 A 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-O-O01, to document that the above valves were not listed as Appendix R valves In the Fire Safe Shutdown (FSSD)

Calculation, SQN-S0S4-0127, or the Fire Hazards Analysis Calculation, SQN-26-DO541EPM-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

equoyan Nuclear iiant t-age z PER Report PER100 03/01/02 to containment can be utilized to fail ciose the letdown valves for RCS pressure boundary Isolation).

Pit Process Equip Y Potential Oper Issue Y Potential Reportable N Potential Degrad/Noncon(91-18)

ASME N Systems Affected NIA 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 appea e that FCV-32-1 10 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, Operatidns 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

Sequoyah Nuclear Plant Page 3 PER Report PER100 03/01/02 availability of backup lighting, it is determined that this PER does not constitute a plant operability issue.

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

• LEVEL D INFORMATION LvI D Causing Org LvI D Causing Crew Human Perf Proc Code Apparent Cause LvI D Process/Proced Hardware Disposition Technical Justify Init Supv-First Last Init Supv Phone

[nit Sup Review Date . :Y

'* OPS Functional Eval (FE) N FE Due Date Affect Operability Y If YesUnits/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 SRO/STA-Fst Last Loyd Hodges Ops SRO/STA Rev Date 02102/2001 Ad FE Functional Maint Potential Degrad/Noncon(91-18)

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

Sequoyah Nuclear ilam Flage 4 PER Report PER100 03/01/02 List Action/Measures Engineer Date Supervisor Date OPS SRO/STA-Fst Last OPS SRO/STA Rev Date

'* MRC Process PER Level C Interim Action Req'd N If YES, Specify RCA Required N Site Qual Conc/Ver N Assigned Resp Org ENGIMECH CA Develop Due Date 03105/2001 MRC Directions 91-18 Issue MRC CAP Review N MRC-First Last Shirley Smith MRC Review Date 02/0212001 Resp Org CA Develop Due Date 03/05/2001 Section ENG/MECH POC-First Last POC Phone Reactivity Mgt Issue N A/B-LER N LER No.

Control of NonConfor N If Yes, Scope Hardware Disposition Disposition RIWEDMS Offsite Generic Rev Y Generic Rev BFN Y Generic Rev BLN N Generic Rev Corp N Generic Rev SQN 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-D054/EPM-AB-IMPFHA), Fire Safe Shutdown

oequuyaui i'duciewe r-iidt rasy o 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-evaluation processes, 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: ENGD4

PER Report PER100 03/01/02 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 CAIRC 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 03/1312001 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 07/2712001 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 Isrevised to address repositioning of one head of Appendix R lighting unit (0-LGT-247-R155).

2 Date Completed 07/23/2001 3 Action Item Revise O-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

Sequoyah Nuclear Plant Page 7 PER Report PER100 03101102

• 3 AO POC Fst Last DAVE PORTER 3 CA Performed Incorporated manual actions in AOP-N.01 App. C, which replaced O-GO-8.

3 Date Completed 07/23/2001 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 ENG/MECH 4 CA Due Date 07/27/2001 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-RI55).

4 Date Completed 07/27/2001

"'CLOSURE COMMENTS FROM 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 03/05/2001 (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) PltMgr-Fst Lst (A) PItMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N

oequoyari umciear r-a0ti rage a 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 Closure Date 07/27/2001 EXTENSIONS REVISIONS GENERIC REVIEWS BFN Resp Org ENG/MECHANICAL BFN Due Date 03/1312001 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

bequuywni nuutsIkd rjun I*

PER Report PER100 'em 03/01/02 gow SI WNorkorder: 01-009670-000 Status: RO Entry Date: 10/26/2001 14:04 Planner/Supv: JOHN THOMAS Requested By: BRENDA F. SIMRIL 843-8515 SUPERVISOR PER Level Rev Level 00 Identified By LINE ORGANIZATION Self Revealing N.

Problem Description The current SQN Appendix R program does not credit the use of control air for Appendix R compliance.

Therefore, manual actions are required for operation of the Steam Generator (SG) Atmospheric Relief Valves (ARVs). Also, one of the three associated pressure indicators is required for the SGs being used for cooldown. The ARVs are located in the West Valve Vaults (PCV-1 -5 and -30 for SGs 1 and 4, respectively) and the East Valve Vaults (PCV-1-12 and -23 for SGs 2 and 3, respectively). Remote valve actuators and associated emergency lights have been installed for SGs I and 4, but not for SGs 2 and 3. Subsequently, SGs I and 4 are the only steam generators credited in the analysis. In two plant fire areas, FAA-31 and -39 (UI and U2 El. 690 Pipe Gallery), all three pressure indicators for SGs 1 and 4 have essential cables terminating in panels located within the fire areas. Twenty foot separation between the redundant trains of indication does not exist for these areas. However, it has been verified on the Appendix R drawings (1-45E890-304-2 and 2-45E890-314-4) that these cables are in fact located in the subject rooms. This cable routing information was also verified on the conduit and grounding drawings. For additional details see attached writeup in Curator.

PIt Process Equip Y Potential Oper Issue Y Potential Reportable N Potential DegradlNoncon(91-18) Y ASME N Systems Affected 001 Systems Affected Systems Affected

PER Report PER100 03/01102 Systems Affected Units Affected 1&2 Recommendation Process PER No action, Justify If Process,PER Level C If Utilize ACP, No Immed Action Taken Established fire watches in accordance with the SQN Fire Protection Report (FPR), Part II, FOR 3.7.12.

Recommended Resp Org ENG/MECH Coordinated With John Thomas Init Sup-First Last John Thomas Init Sup Phone 8224 Init Department ENG/MECH Init Sup Review Date 10/26/2001

• • • • • LEVEL D INFORMATION Lvi D Causing Org ENG/NSS Lvl D Causing Crew Human Perf Proc Code WMK Apparent Cause Miscommunication b.1 tween Mechanical and Electrical

- Engineering during the development of the Appendix R program in late 1980's. Due to age of issue, apparent cause could not be fully established.

LvI D Process/Proced Hardware Disposition Other Technical Justify This issue is identified as an extent of condition to PER 00-7928-000 and resolution of the condition will be rolled into that PER. See Revision 6 of 00-7928-000.

Init Supv-First Last John Thomas Init Supv Phone 8224 Init Sup Review Date 10/28/2001 OPS Functional Eval (FE) Y FE Due Date 02/28/2002 Affect Operability Y If Yes,Units/Actions Roving fire watch established on both units 1 and 2.

Enter FOR 3.7.12 Offsite OP Review Y Op Review BFN Op Review BLN Op Review SQN Op Review WBN Y Reportable N If Yes, List Basis

Sequoyah Nuclear Plant* Page 9 PER Report PER100

- 03/01/02 SQN Due Date SON 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 03/05101 for information only review.

WBN Review-Fst Lst TERESA WILSON WBN Review Date 03105/2001 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 SQN 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 thislocal FSSD HS Is dictated by AO1-30.2 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 02/0812001 godTRENDS Program Code FP Program Code Program Code

bequoyan Nuclear 11ant rage 'u 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

• Sequoyah Nuclear Plant Page 4 PER Report PER100 03/01/02 Disposition RIMIEDMS Offsite Generic Rev N Generic Rev BFN Generic Rev BLN Generic Rev Corp Generic Rev SON Generic Rev WBN Process/Procedures CAUSE DATA Apparent Cause This issue identified as extent of condition from PER 00-7928-000.

Root Cause Causing Org ENG/MECH Causing Crew Human Perf Proc Code HP Perf Second Code Prev/Similar Event N/A Specify Search Basis Extent of Condition -

• PER HUMAN PERF

• PER CA/RC ITEMS 1 Action Item Develop functional evaluation and add corrective actions to PER 00-7928-000 to resolve issue.

1 Action Type CORRECTIVE ACTION 1 Assigned Org ENG/MECH I CA Due Date 02/28/2002 1 AO Concur-Fst Last JOHN THOMAS 1 AO POC Fst Last BRENDA SIMRIL 1 CA Performed Prepared functional evaluation (see attached writeup) and added corrective action # 22 to PER 00-7928-000..

1 Date Completed 02/27/2002 CLOSURE COMMENTS FROM CA CAP CONCUR PER Completion Date 02/28/2002 Prep-First Last John Thomas Preparer Date 02/28/2002 Telephone No 8224 (C) Supv-First Last John Thomas (C) Supv Ext 8224 (C) Supv Date 02/28/2002 (B) DptMgr-Frst Last (B) DptMgr Date MRC Reqd N

ocquUyall twledi rwlir rage a PER Report PER100 03101/02 Ops SRO/STA-Fst Last David Moore Ops SRO/STA Rev Date 10126/2001 FE Functional Maint Potential DegradlNoncon(91-18) Y

-FE/Eval Due Date Initial Evaluation 91-18 Degrad Nonconf Y Functional/Eval Basis See attached writeup Immed/Comp Measures List Action/Measures Engineer Brenda Simril Date 02127/2002 Supervisor John Thomas Date 0212712002 OPS SRO/STA-Fst Last WILLIAM ROSS OPS SRO/STA Rev Date 02/2712002

• • • • MRC***:. },

Process PER Level C Interim Action Req'd N If YES, Specify RCA Required N Site Qual ConcNer N Assigned Resp Org ENGIMECH CA Develop Due Date 03127/2002 MRC Directions Close to Level B PER 00-7928 under extent of condition.

NOTE: This PER was upgraded to a Level C per telecon with John Thomas-shs-0212712002.

MRC CAP Review N MRC-First Last Beverly Bishop MRC Review Date 10127/2001

• • a Resp Org CA Develop Due Date 0312712002 Section ENGIMECH POC-First Last John Thomas POC Phone 8224 Reactivity Mgt Issue N AIB-LER N LER No.

Control of NonConfor N If Yes, Scope Hardware Disposition

Sequoyah Nuclear Plant Page 5 PER Report PER100 03/01102 MRC Concurrence Reason for N MRC-First Last MRC Date (A) SiteSr-Fst Last (A) SiteSr Date (A) PItMgr-Fst Lst (A) PItMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N Site Qual First Last Site Qual Date VERIFICATION Final Rev Level Tags Rem-First Last Tags Date RO Verify Comp RO Verify Date ANIVANII 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 Closure Date K EXTENSIONS REVISIONS

.- GENERIC REVIEWS OPERABILITY REVIEWS TRENDS Program Code FP Program Code

S .o:quuyast rUuItdi rJdillL rea u PER Report PER100 03/01/02 Program Code INPO Code FP1 INPO Code NRC Code NRC Code Category PROCESS Short Term Code Impact 4.0 Behavior Code Org I Prog Code P2 GEMS Other CAUSE CODES MI E Analysis deficiency (calculations: stress, hydraulic, thermal, electri Total records selected.I

• -- END OF REPORT"**

Appendix R - Steam Generator Pressure Control Insufficient Separation in U1 and U2 El. 690 Penetration Rooms Description In order to meet Appendix R safe shutdown requirements for decay heat removal, one Auxiliary Feedwater (AFW) pump is required to supply two Steam Generators (SG) to make up for inventory discharged as steam by the safety valves or SG Atmospheric Relief Valves (ARV).

The continued removal of heat is achieved by the controlled operation of the ARVs and the continued operation of the AFW system. Also, one of the three associated pressure indicators is required for the SGs being used for cooldown. The ARVs are air-operated valves which require the availability of the Control Air system for normal operation. The current SQN Appendix R program does not credit the use of control air for Appendix R compliance (Ref. NRC Inspection Report 50-327/88-24 and 50-328/88-24, p. 9). Therefore, manual actions are required for operation of the ARVs. '

The ARVs are located in the West Valve Vaults (PCV-1-5 and -30 for SGs 1 and 4, respectively) and the East Valve Vaults (PCV- 1-12 and -23 for SGs 2 and 3, respectively). Remote valve actuators and associated emergency lights have been installed for SGs 1 and 4. In two plant fire areas, FAA-31 and -39 (U I and U2 El. 690 Pipe Gallery), all three pressure indicators for SGs 1 and 4 have essential cables terminating in panels located within the fire areas. Twenty foot separation between the'redundant trains of indication does not exist for these areas. In the original Appendix R analysis ("Steam Generator Inventory Control" Safety Function Position Statement, RIMS #S56871222985 and #S01850827954) it was evaluated that PAM II indication was available for SGs I and 4. However, it has been verified on the Appendix R drawings (1-45E890-304-2 and 2-45E890-314-4) that these cables are in fact located in the subject rooms, along with the ARV indication and the PAM I indication. This cable routing information was also verified on the conduit and grounding drawings.

Due to the unavailability of pressure indication for SGs 1 and 4 in the two El. 690' pipe galleries, the only available steam generators for cooldown are SGs 2 and 3. But, since control air is not credited in the Appendix R program, and thus cannot be assumed to be available, manual operation of PCV-1-12 and -23 is required. Since there is currently no emergency lighting in the East Valve Vault and local operation would present a significant personnel hazard, local operator actions in the East Valve Vault is not plausible.

Contrary to the requirements of SPP-9A, a technical basis document /evaluation was not provided or referenced in the SR/SE for FPR Revision 8 to justify extending the fire detection test frequency from 6 months to 18 months.

The Fire Safe Shutdown Evaluation portion of the 50.59 Evaluation provide a qualitative discussion to support the subject matter however, no referenced document was provided to support the conclusion of this position.

This is an inappropriate use to the 50.59 process as described in SQ951557PER Corrective Action # 39. See the letter from Mark Burzynski to J. Valente dated June 13, 1997; RIMS # B45 970612 001 which states the following.

It is concluded that the inclusion of calculations or other technical information in a 50.59 document for the propose of providing a technical basis for the change is an improper use of these evaluations. The technical basis supporting a change, be it a physical change to the facility or a procedure change, must be documented in appropriate input or output such that a 50.59 qualified individual can perform evaluation required by SPP 9.4. Given below are two concerns that must be addressed to resolve the above issue.

The first concern is, the SR/SE should have referenced the NFPA 72E standards on Automatic Fire Detectors or the appropriate NFPA standard to assure the industry standard test frequencies are satisfied. For example, NFPA 72E Section 8-3.3.2 states each heat detectors should be tested within five years and NFPA 72E Section 8-3.4.2 states smoke detectors shall be checked one year after installation and every alternate year thereafter. These requirements, if applicable, would bound ihe proposed increased test frequency from 6 months to 18 months. Referencing these industry standards should be a portion of the technical basis for increasing the test frequencies rather than simply increasing the fire detectors test frequencies in SI-234.2, 234.5, and 234.6 to be consistent with the host equipment test frequencies. These revisions were addressed as action items in SQN 00-006637-000 PER without further required analyses or documentation, which leads vt the next concern.

The second concern is, no retrievable analyses or documentation is available to support the technical conchusion of increasing the fire detector's test frequency from 6 months to 18 months is acceptable. In order to independently reach this conclusion, a 50.59 qualified individual or auditor would have to recollect, reevaluate, and document for the first time test data and histories summarized in the Fire Safe Shutdown Evaluation portion of the 50.59 Evaluation. The assurance of reacquiring this conclusion is subject to question since the documentation supporting this position does not exist.

Calvin W. Burrell Jr.

SQN I OCFR50.59 Coordinator

FUNCTIONAL EVALUATION Page 1 of 2 PER Number Revision_DATE_

1.0 INITIATOR INFORMATION AND DESCRIPTION Initiator (Print Name) _ Phone Number 8515 Describe the affected system, structure or component using UNIDs as appropriate:

S/Gs 1 & 4 ARV pressure indication: 1,2-P-001-2A, -2B, -5,-27A, -27B, -30 Describe the degraded condition or operability concern Loops 1 & 4 are required for cooldown in Fire Areas FAA-031 & -039, however, cables for all pressure indicators (see above) are routed through these fire areas (Unit 1 cables only in FAA-031, Unit 2 cables only in FAA-039).

This operability determination is written to evaluate (check all that apply):

0 A past operability concern for reportability purposes.

0 A present operability concern.

0 A future operability concern In anticipation of an upcoming plant evolution/condition.

Date condition was found or could potentially exist in the future: 10/26/2001 Technical Specification (T/S) Review: (check one)

C This component/system IS NOT covered by TIS.

01 This component/system IScovered by T/S Section: U1IU2 Tech Spec Ucensing Cond 16 State the initiating document(s) [that is PER, WO] that prompted the need for this FE. If none exists mark NA. PER 01-09670-000

2.0 TECHNICAL EVALUATION

Describe the component's/system's function: SG ARV Pressure Indication for Appendix R Fire Ust the specific references used: Fire Safe Shutdown (FSSD) Analysis. SON-SQS4-127; SON FPR Describe the effects of the condition on the ability of the component/system to perform Its Intended function:

(See Attached)

If the degraded condition of the component/system causes any loss of functional capability, evaluate whether system operability can be justified using compensatory actions or by taking credit for alternate functional capabilities (such as manual operation or diverse automatic actions):

(See Attached)

FUNCTIONAL EVALUATION Page 2 of 2 PER Number Revision DATE__

Describe an alternate means of meeting the designed functions, limitations or any required compensatory actions to make the component/system operable. Describe why the alternative, limitations, or compensatory actions do not create new or different concerns:

(See Attached)

Describe the actions required to Implement the alternate functional capability, limitations, and/or compensatory actions. Include required procedures, procedure changes, temporary modifications, if known. NWA for components/systems that can perform their intended designed function(s) without limitations, credit for alternate capabilities, or compensatory actions:

(See Atached: Use of Loops 2 and 3 for cooldown utilizing Control Air per AOP-N.01)

State definitively in the first sentence whether the component/system will or will not perform Its designed function or it will with limitations. Include or reference any required limits, Compensatory Actions, or credit taken for alternate functional capability (See Attached)

Ust what actions must occur for the operability question to no longer exist?

Identifier (e.g., WO, PER) DCN F-21102-A (FAA-031) Responsible NE MI/N DCN F-21103-A (FAA-039) Org.

3.0 REVIEW AND APPROVAL (Approval Signatures on Functional Evaluation Template)

Appendix R Evaluation for FAA-031 and -039 In order to meet Appendix R safe shutdown requirements for decay heat removal, one Auxiliary Feedwater (AFW) pump is required to supply two Steam Generators (SG) to make up for inventory discharged as steam by the safety valves or SG Atmospheric Relief Valves (ARV).

The continued removaj of heat is achieved by the controlled operation of the ARVs and the continued operation of the AFW system. Also, one of the three associated pressure indicators is required for the SGs being used for cooldown. The ARVs are air-operated valves which require the availability of the control air system (supplied by Auxiliary Air) for normal operation. The SQN Appendix R program does not credit the use of control air for Appendix R compliance (Ref.

NRC Inspection Report 50-327/88-24 and 50-328188-24, p. 9), but allows the use of the components if they remain available during the event. Since the control air system has not been evaluated in every fire area for end devices and/or headers which could contain non-fire resistant materials such as copper tubing, rubber gaskets, etc., control air supplied components are only credited for specific areas. As a result, for all other plant fire areas, manual actions are required for operation of the ARVs, as well as any other air supplied components required for safe shutdown.

The ARVs are located in the West Valve Vaults (PCV-1-5 and -30 for SGs 1 and 4, respectively) and the East Valve Vaults (PCV-1-12 and -23 for SGs 2 and 3, respectively). Remote valve actuators and associated emergency lights have been installed for SG #1 and #4. In both FAA-031 and -039 (Uland U2 El. 690 Pipe Gallery, respectively), all three pressure indicators for SGs 1 and 4 have essential cables terminating in panels located within this fire area, and the 20 foot separation requirement is not met.

DCN F-21102-A (Ul) and F-21103-A (U2) are currently in progress to add Thermo-Lag ERFBS to the PAM II instrumentation for Loops 1 and 4 in these fire areas, which will provide the minimum required pressure indication for these loops. Until this modification is complete, the compliance strategies include crediting the use of SGs 2 and 3. No cables for SGs 2 and 3 pressure indication (P-001-09A, -09B, -12, and 1-P-001-20A, -20B, -23) are routed in these fire areas.

Due to the inaccessibility of the PCV-1-12 and -23 valve actuators, no manual actions are available to operate the valves; Therefore, in order to credit these valves, control air must be available to operate the valves from the MCR. Plant walkdowns have been conducted and determined that end devices for control air with the potential to breach the air header are not located within the area of concern. Also, a review of the control air flow diagrams confirmed that the end devices located in the fire areas come from the Station Air headers, and that Auxiliary Air would not be impacted. Therefore, SGs 2 and 3 would be available for cooldown using the SG ARVs from the MCR.

Until field implementation of the DCNs F-21102-r and F-21 103-A is complete, Loops 2 and 3 are credited for plant cooldown by implementing the following two additional MCR operator actions:

Main Control Room Operator. Actions:

KEY CONTROL COMPONENT FUNCTION PERFORMED REQUIRED TIME (min)

FAA-031:

26 1-PCV-1-12 OPERATE 60 26 I-PCV-1-23 OPERATE 60 FAA-039:

26 2-PCV-1-12 OPERATE 60 26 2-PCV-1-23 OPERATE 60

C*equuyal imruletl rdist riyu PER Report PER100 03/01/02 Workorder. 02-000575-000 Status: RO Entry bate: 01/21/2002 12:51 Planner/Supv: JOHN THOMAS Requested By: BRENDA F. SIMRIL 843-8515 SUPERVISOR PER Level Rev Level 00 Identified By LINE ORGANIZATION Self Revealing Y Problem Description In order to meet Appendix R safe shutdown requirements for RCS Letdown, one of three available paths must be available: Normal Letdown, Excess Letdown, Alternate Letdown. The Alternate Letdown path utilizes the Pressurizer PORVs and Block Valves, and the Reactor Vessel Head Vent Valves to alternately decrease and increase RCS pressure during plant cooldown. The Fire Safe Shutdown (FSSD) Analysis, SQN-SQS4-0127, currently describes the three methods in Key 48 of the calculation. In order to guarantee availability of the components required for Normal and Excess Letdown, Control Air (Key 13) must be available. The current SON Appendix R program does not credit the use of control air for Appendix R compliance (Ref. NRC Inspection Report 50-327/88-24 and 50-328/88-24, p. 9);

Therefore' the Alternate Letdown path must be guaranteed for each FSSD fire area. Within the Alternate Letdown path, there are four combinations of valve operation which will achieve the required safety function. The EGTS room (FAA-80, 734.0-A16) contains cables for all four acceptable combinations of PORVs, Block Valves, and RVHV Valves in such a manner that safe shutdown cannot be guaranteed using the Alternate Letdown Path.

Reliance on control air for an Appendix R event Is an industry anomaly. Also, the necessity to credit control air the subject fire area would require including the Control Air System and the Normal Letdown path in the FSSD analysis for one fire area only, which would be in contrast to the compliance strategies for the remaining fire areas. This PER Is a result of extent of condition from PER 00-7928-000. For operability discussions, see 'Immediate Actions Taken".

PER Report PER100 03/01/02 Pit Process Equip Y Potential Oper Issue N Potential Reportable N Potential DegradlNoncon(91 -18) Y ASME N Systems Affected 068 Systems Affected Systems Affected Systems Affected Units Affected 2 Recommendation Process PER No action, Justify If Process,PER Level D If Utilize ACP, No Immed Action Taken For current operability, a letdown path can be achieved for this area. Per Note 2 on Dwg. 2-45E890-042, the EGTS room does not contain any cables or components

-required for the Normal Letdown pah'. Also,.field walkdowns confirmed that the only control air end

'devices in the room are located in the far northeast corner of the room. These components are greater than 200 from the cables for 2-FCV-68-332, which would make the Alternate Letdown path using 2-FCV-68-332 and 2-PCV-68-340A (cables for this valve are not located In the subject fire area) available. Therefore, the same fire could not render this path and the Normal Letdown path inoperable and therefore current operability Is guaranteed.

PER re-openned to indicate potentially 91-18 issue and to upgrade to level C.

Recommended Resp Org ENGIMECH Coordinated With John Thomas Init Sup-First Last John Thomas Init Sup Phone 8224 Init Department ENGIMECH Init Sup Review Date 01/22/2002 LEVEL D INFORMATION LvI D Causing Org ENG/MECH Lvl D Causing Crew Human Perf Proc Code OTH Apparent Cause Identified by extent of condition of PER 00-7928-000.

Sequoyah Nuclear Plant Page 3 PER Report PER100 03/01/02 See apparent cause of 00-7928-000.

Lvl D Process/Proced Hardware Disposition Rework Technical Justify A design change will be processed in accordance with corrective action 23 for PER 00-7928-000.

Init Supv-First Last John Thomas Init Supv Phone 8224 Init Sup Review Date 01/3112002

. COPSE Functional Eval (FE) Y FE Due Date 02/28/2002 Affect Operability N If Yes,Units/Actions Offsite OP Review N Op Review BFN Op Review BLN Op Review SQN Op Review WBN

'IReportable N If Yes. List Basis Ops SRO/STA-Fst Last WILLIAM ROSS Ops SRO/STA Rev Date 02127/2002 GFER Functional Maint Potential Degrad/Noncon(91-18) Y FE/Eval Due Date Initial Evaluation 91-18 Degrad Nonconf Y Functional/Eval Basis See attached writeup.

Immed/Comp Measures List Action/Measures Engineer Brenda Simril Date 0212712002 Supervisor John Thomas Date 02/27/2002 OPS SRO/STA-Fst Last WILLIAM ROSS OPS SRO/STA Rev Date 02/27/2002 MRC Process PER Level C Interim Action Req'd N If YES, Specify RCA Required N

Sequoyah Nuclear Plant Page 4 PER Report PER100 03101/02 Site Qual ConcNer N.

Assigned Resp Org ENG/MECH CA Develop Due Date 03/27/2002 MRC Directions NOTE: This PER was upgraded to a Level C per telecon with John Thomas-shs-02/27/2002.

MRC CAP Review N MRC-First Last Renee McKaig MRC Review Date 01/23/2002 A Resp Org CA Develop Due Date 03/27/2002 Section ENG/MECH POC-First Last John Thomas POC Phone 8224 Reactivity Mgt Issue N ANB-LER N LER No.

Control of NonConfor N If Yes, Scope Hardware Disposition Disposition RIM/EDMS Offsite Generic Rev N Generic Rev BFN Generic Rev BLN Generic Rev Corp Generic Rev SON Generic Rev WBN Process/Procedures

• CAUSE DATA A Apparent Cause Condition determined to from extent of condition from PER 00-7928-000 Root Cause Causing Org ENG/MECH Causing Crew Human Perf Proc Code

'HP Perf Second Code Prev/Similar Event N/A Specify Search Basis Extent of Condition PER HUMAN PERF PER CAtRC ITEMS I Action Item A design change will be processed in accordance with corrective action 23 for PER 00-7928-000.

1 Action Type CORRECTIVE ACTION

Sequoyah Nuclear Plant Page 5 PER Report PER100 03101/02 i Assigned Org ENG/MECH I CA Due Date 0212812002 I AO Concur-Fst Last JOHN THOMAS I AO POC Fst Last BRENDA SIMRIL 1 CA Performed Corrective a6tion transferred to 00-7928-000 1 Date Completed 02/2512002 CLOSURE COMMENTS FROM CA CAP CONCUR PER Completion Date 0212812002 Prep-First Last John Thomas Preparer Date 0212512002 Telephone No 8224 (C) Supv-First Last John Thomas (C) Supv Ext 8224 (C) Supv Date 021251002 (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) PltMgr-Fst Lst (A) PltMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N Site Qual First Last Site Qual Date VERIFICATION Final Rev Level Tags Rem-First Last Tags Date RO Verify Comp RO Verify Date ANIIANII Required N ANI/ANII Concurrence Reason for N ANI/ANII-First Last

tequoyan rNuciear riani rage o PER Report PER100 03/01/02 ANI/ANII Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date RO Supv Clos-Fst Lst Closure Date

• EXTENSIONS

'* REVISIONS GENERIC REVIEWS OPERABILITY REVIEWS

• • • • • TRENDS Program Code FP Program Code Program Code INPO Code FPI INPO Code NRC Code NRC Code Category PROCESS Short Term Code Impact 2.5 Behavior Code Org / Prog Code PP3 GEMS Other CAUSE CODES MIA Misapplication or interpretation of design inputs (engineering codes a Total records selected:I

• • • END OF REPORT ***

i FUNCTIONAL EVALUATION Page 1 of 2 PER Number .- R.evlslonDATE 1.0 INITIATOR INFORMATION AND DESCRIPTION Initiator: (Print Name) _ _ s__ Phone Number 8515 Describe the affected system, structure or component using UNIDs as appropriate: ROS Letdown path for Appendix R safe shutdown requirements: this includes normal letdown excess letdown and alternate letdow which utilizes the Pressurizer PORVs and Block valves and the RV Head Vent valves Describe the degraded condition or operability concern The EGTS room (FAA-80. 734.0-Al 6) contains cables for all four acceptable combinations of PORVs, Block Valves, and RVHV Valves In such a manner that safe shutdown cannot be guaranteed using the alternate letdown path.

This operability determination Is written to evaluate (check all that apply):

ID A past operability concern for reportability purposes.

CD A present operability concem.

o A future operability concern in anticipation of an upcoming plant evolution/condition.

Date condition was found or could potentially exist In the future: Jan 21 2001 Technical Specification (TIS) Review: (check one) o This component/system IS NOT covered by T/S.

0 This component/system IS covered by T/S Section: Unit 1 and 2 Tech Spec U-censing Cond 16 State the Initiating document(s) [that Is PER. WO] that prompted the need for this FE. If none exists mark NA. PER 02-00575-000

2.0 TECHNICAL EVALUATION

Describe the component's/system's function: Providing RCS letdown for Appendix R fire Ust the specific references used: Fire Protection Report, Fire Hazard Analysis Describe the effects of the condition on the ability of the component/system to perform Its Intended function:

(See Attached)

If the degraded condition of the component/system causes any loss of functional capability, evaluate whether system operability can be justified using compensatory actions or by taking credit for alternate functional capabilities (such as manual operation or diverse automatic actions):

(See Attached)

I FUNCTIONAL EVALUATION Page 2 of 2 PER Number Revision _ DATE __

Describe an alternate means of meeting the designed functions, limitations or any required compensatory actions to make the component/system operable. Describe why the alternative, limitations, or compensatory actions do not create new or different concerns:

(See Attached)

Describe the actions required to implement the alternate functional capability, limitations, and/or compensatory actions. Include required procedures, procedure changes, temporary modifications, if known. N/A for components/systems that can perform their Intended designed function(s) without limitations, credit for alternate capabilities, or compensatory actions:

(See Attached; use of alternate letdown is used if available in acccordance with AOP N.01 State definitively In the first sentence whether the component/system will or will not perform Its designed function or it will with limitations. Include or reference any required limits, Compensatory Actions, or credit taken for alternate functional capability (See Attached)

List what actions must occur for the operability question to no longer exist?

Identifier (e.g., WO, PER) DCN M-12743 Responsible Design Mech Org.

3.0 REVIEW AND APPROVAL (Approval Signatures on Functional Evaluation Template)

a In order to meet Appendix R safe shutdown requirements for RCS Letdown, one of three available paths must be available: Normal Letdown, Excess Letdown, Alternate Letdown. The alternate letdown path utilizes the Pressurizer PORVs and Block Valves, and the Reactor Vessel Head Vent Valves to alternately decrease and increase RCS pressure during plant cooldown.

The Fire Safe Shutdown (FSSD) Analysis, SQN-SQS4-0127, currently describes the three methods in Key 48 of the calculation. In order to guarantee availability of the components required for normal and excess letdown, control air (Key 13) must be available. The SQN Appendix R program does not credit the use of control air for Appendix R compliance (Ref.

NRC Inspection Report 50-327188-24 and 50-328/88-24, p. 9). Therefore, the alternate letdown path must be guaranteed for each FSSD fire area. Within the alternate letdown path, there are four combinations of valve operation which will achieve the required safety function. The EGTS room (FAA-80, 734.0-A1 6) contains cables for all four acceptable combinations of PORVs, Block Valves, and RVHV Valves in such a manner that safe shutdown cannot be guaranteed using the alternate letdown path.

For current operability, a letdown path can be achieved for this area using either normal letdown or alternate letdown components. Note 2 on Dwg. 245E890-042 states that the EGTS room does not contain any cables or components required for the normal letdown path. Cable analysis has also verified that the only component related to the normal letdown and normal charging paths affected in this fire area is 2-FCV-62-85. This valve is normally closed to isolate the alternate charging path. Spurious opening of this valve would require closure of 2-FCV-62-86, which is available from the MCR.

This fire area has a low combustible loading, and is equipped with full area automatic suppression and detection. Field walkdowns confirmed that the only control air end devices in the room are located northeast of the column near V-line and the Rx Bldg. Shield Wall. These components are greater than 20' from the cables for 2-FCV-68-332, which would make the alternate letdown path, using 2-FCV-68-332 and 2-PCV-68-340A available from the MCR (cables for PORV 2-PCV-68-340A are not located in this fire area). A fire which could render both this path and the normal letdown path inoperable is not credible. Therefore, for a fire south of Column A13, control air will be available to be utilized for normal letdown and charging. For a fire north of A13, 2-FCV-68-332 is available for letdown.

To accomplish Key 28 (RCS Pressure Boundary Isolation) requirements for either letdown path used, a manual action to pull the fuses for the Reactor Vessel Head Vents (RVHV) is required.

If normal.letdown is employed, Main Control Room operator actions to close 2-PCV-68-340A and 2-FCV-68-333 are required. Conversely, if alternate letdown via the PORVs is employed, a MCR operator action to close 2-FCV-68-333 is required.

.a.. * -t...... . usc PER Report PER100 03/01/02 eC iu. u Workorder 02-000576-000L Status: RO 4-3 h Entry Date: 01/21/2002 12:56 Planner/Supv: JOHN THOMAS Requested By: BRENDA F. SIMRIL 843-8515 SUPERVISOR PER Level Rev Level 00 Identified By LINE ORGANIZATION Self Revealing Y Problem Description In order to meet Appendix R safe shutdown requirements for RCS inventory control and RCP seal cooling, CCP suction supply from either the VCT or RWST must be ensured. Control logic for the VCT outlet isolation valves (LCV-62-132 and -133) and RWST outlet Isolation valves (LCV-62-135, -136) Is interlocked such that prior to closing either LCV-62-132 or -133 valve, LCV-62-135 or -136 will open.

In the southeast corner of FAA-29 (690- A01), cables exist for all four Unit 2 LCVs as well as CCP 2A-A and 2B-B. Thermo-Lag protects the control cables for the

-135 and -136 valves, but not the.power cables. Also, CCP 2A-A is protected by Thermo-Lag in this area.

Subsequent to an Appendix R fire, a spurious closure signal could be generated through cables controlling valves LCV-62-132 and -133. If a low level VCT tank level signal were to occur, valves LCV-62-132 and 133 would close. Since the power-cables for -135 and -136 are not protected, automatic opening can not be guaranteed. Therefore, an Interaction exists such that suction to both the VCT and RWST could be lost. If CCP 2A-A is running at the time of the valve closure, It could be destroyed due to loss of suction, and at the same time, CCP 2B-B could be unavailable due to the fire.

The current Fire Hazards Analysis credits manual actions to ensure suction for the CCPs. During the.

development of a manual action timeline analysis for the recent Appendix R re-verification effort, it was identified that this is a time-critical action (i.e.,

less than 10 minutes). However, due to the availability of normal charging and letdown

,JWC4 UUJOII NU 0 A1 8L a4 ukf PER Report PER100 03101102 (availability of Control Air has been verified),

additional time for the manual action is available.

The reliance on time-critical operator actions increases the risks associated with mitigation of an Appendix R event In the subject fire area. This PER is a result of extent of condition of PER 00-007928-000.

For operability discussions, see 'Immediate Actions Taken".

PIt Process Equip Y Potential Oper Issue N Potential Reportable N Potential Degrad/Noncon(91-18) Y ASME N Systems Affected 062 Systems Affected 063 Systems Affected Systems Affected Linfls Affected 2.

Recommendation Process PER No action, Justify If ProcessPER Level D If Utilize ACP, No Immed Action Taken See attached functional evaluation.

PER re-openned to document potential GL 91-18 issue.

PER upgraded to level C. 2/27/02 Recommended Resp Org ENG/MECH Coordinated With John Thomas Init Sup-First Last John Thomas InitSup Phone 8224 Init Department ENG/MECH Init Sup Review Date

`d LEVEL D INFORMATION LvA D Causing Org ENGIMECH LvA D Causing Crew Human Perf Proc Code WMK Apparent Cause See apparent cause for PER 00-7928-000 LvI D Process/Proced Hardware Disposition Rework Technical Justify A design change will be prepared in accordance with corrective action number 24 for PER 00-7928-000 Init Supv-First Last John Thomas

PER Report PER100 03101102 Init Supv Phone 8224 Init Sup Review Date 02/0512002

• -. OPS Functional Eval (FE) Y FE Due Date 0212812002 Affect Operability N If Yes,Units/Actions Offsite OP Review N Op Review BFN Op Review BLN Op Review SON Op Review WBN Reportable N If Yes, List Basis Ops SRO/STA-Fst Last WILLIAM ROSS Ops SRO/STA Rev Date 02/27/2002 FE Functional Maint Potential Degrad/Noncon(91-18) Y FEIEval Due Date Initial Evaluation 91-18 Degrad Nonconf Y Functional/Eva! Basis See attached functional evaluation.

Immed/Comp Measures List Action/Measures Engineer Brenda Simril Date 02127/2002 Supervisor John Thomas Date 02127/2002 OPS SRO/STA-Fst Last WILLIAM ROSS OPS SROISTA Rev Date 0212712002 MRC Process PER Level C Interim Action Req'd N If YES, Specify RCA Required N Site Qual ConciVer N.

Assigned Resp Org ENGIMECH CA Develop Due Date 03127/2002 MRC Directions NOTE: This PER was upgraded to a Level C per telecon with John Thomas-shs-02/2712002.

MRC CAP Review N

PER Report PER100 03101/02 MRC-First Last Renee McKaig MRC Review Date 01/23/2002 Resp Org CA Develop Due Date 03127/2002 Section ENG/MECH POC-First Last John Thomas POC Phone 8224 Reactivity Mgt Issue N AIB-LER N LER No.

Control of NonConfor N If Yes, Scope Hardware Disposition Other Disposition RIMIEDMS Offsite Generic Rev N Generic Rev BFN Generic Rev BLN Generic Rev Corp Generic R1v3 SQN.

Generic Rev WBN Process/Procedures CAUSE DATA Apparent Cause This issue identified as extent of condition of PER 00-7928-000.

Root Cause Causing Org ENG/MECH Causing Crew Human Perf Proc Code HP Perf Second Code Prev/Similar Event N/A Specify Search Basis Extent of Condition PER HUMAN PERF A PER CA/RC ITEMS 1 Action Item Perform functional evaluation and document corrective appropriate corrective actions in PER 00-7928-000.

1 Action Type CORRECTIVE ACTION I Assigned Org ENG/MECH I CA Due Date 0212812002 I AO Concur-Fst Last JOHN THOMAS I AO POC Fst Last BRENDA SIMRIL 1 CA Performed Functional evaluation completed. See attached writeup.

Corrective action # 24 has been entered into PER

PER Report PER100 03/01/02 00-7928-000.

1 Date Completed 02128/2002

... CLOSURE COMMENTS FROM CA

• ^CAP CONCUR PER Completion Date 02/28/2002 Prep-First Last John Thomas Preparer Date 02/27/2002 Telephone No 8224 (C) Supv-First Last John Thomas (C) Supv Ext 8224 (C) Supv Date 0212712002 (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) PltMgr-Fst Lst (A) PltMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N Site Qual First Last Site Qual Date VERIFICATION Final Rev Level Tags Rem-First Last Tags Date.

RO Verify Comp RO Verify Date 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

PER Report PER100 03/01/02 Site Qual Date RO Supv Clos-Fst Lst Closure Date

• EXTENSIONS*

REVISIONS

• • GENERIC REVIEWS OPERABILITY REVIEWS

• TRENDS*

Program Code FP Program Code Program Code INPO Code FP1 INPO Code NRC Code NRC Code Category PROCESS Short Term Code Impact 2.5 Behavior Code Org / Prog Code PP3 GEMS Other CAUSE CODES M1A Misapplication or interpretation of design inputs (engineering codes a Total records selected: 1

• ^* END OF REPORT***

FUNCTIONAL EVALUATION Page 1 of 2 PER Number RevisionDATE 1.0 INITIATOR INFORMATION AND DESCRIPTION Initiator (Print Name) Phone Number 8515 Describe the affected system, structure or component using UNIDs as appropriate:

VCT/RWST Suction Valves: 2-LCV-62-132, -133, .-135, -136; CCPs 2A-A, 2B-B Describe the degraded condition or operability concern Between Column Lines A12-A15S-U, cable Interactions exist between 2-LCV-62-132, -133, -135, -136.

Cables also exist for both U2 CCPs (CCP 2A-A is protected by Thermo-Lag), U2 SI Initiation, U2 VCT level indication, and U2 Thermal Barrier Cooling.

This operability determination Is written to evaluate (check all that apply):

0 A past operability concern for reportability purposes.

0 A present operability concern.

o A future operability concern in anticipation of an upcoming plant evolution/condition.

Date condition was found or could potentially exist In the future: 01/21/2001 Technical Specification (T/S) Review: (check one) o This component/system IS NOT covered by T/S.

0D This component/system IS covered byT/S Section: U1/U2 Tech Spec Licensing Cond 16 State the Initiating document(s) [that Is PER, WOI that prompted the need for this FE. If none exists mark NA. PER 02-00576-000

2.0 TECHNICAL EVALUATION

Describe the component'slsystem's function: Suction to CCP for Appendix R Fire List the specific references used: Fire Safe Shutdown (FSSD) Analysis, SON-SQS4-127; SON FPR Describe the effects of the condition on the ability of the component/system to perform its intended function:

(See Attached)

If the degraded condition of the component/system causes any loss of functional capability, evaluate whether system operability can be Justified using compensatory actions or by taking credit for.

alternate functional capabilities (such as manual operation or diverse automatic actions):

(See Attached)

FUNCTIONAL EVALUATION Page 2 of 2 PER Number Revision DATE_ _

Describe an alternate means of meeting the designed functions, limitations or any required compensatory actions to make the component/system operable. Describe why the alternative, limitations, or compensatory actions do not create new or different concerns:

(See Attached)

Describe the actions required to implement the alternate functional capability, limitations, and/or compensatory actions. Include required procedures, procedure changes, temporary 'modifications, If known. NIA for components/systems that can perform their intended designed function(s) without limitations, credit for alternate capabilities, or compensatory actions:

(See Atached)

State definitively in the first sentence whether the component/system will or will not perform its designed function or It will with limitations. Include or reference any required limits, Compensatory Actions, or credit taken for alternate functional capability (See Attached)

Ust what actions must occur for the operability question to no longer exist?

Identifier (e.g., WO, PER) DCN F-21 103-A Responsible NE - MWN Org.

3.0 REVIEW AND APPROVAL (Approval Signatures on Functional Evaluation Template)

Appendix R Complia-ice Strategies for FAA-029 (A12-A15 / S-U)

In FAA-029, from A12-A15 / S-U, interactions exist between control cables for VCT Outlet Valves 2-FCV-62-132 and -133 and the power cables for RWST Outlet Valves 2-FCV-62-135, -

136. This interaction causes apptential loss of suction to the operating CCP. This loss of suction could be generated by a spurious close signal for 2-FCV-62-132 or -133, while the power supply is lost for valves 2-FCV-62-135 and -136. The logic associated with the subject control cables for 2-FCV-62-132 and -133 requires that in addition to the control cable hot short, a low level signal for the VCT or SI signal must be present to complete the valve closure logic.

In this area of concern the following combination of cable damage must all occur to prevent continued suction to the operating CCP and cause damage to the non-operating CCP. Spurious closure of 2-LCV-062-132 can be mitigated by opening 2-LCV-62-135 or -136 prior to a start of the 2B CCP since neither the pump cable or the spurious SI initiation cables are within 20 feet of the 2V2767A (control) and 2PM461, 2PM466 or 2PM75 level indication cables.

VCT LO-LO Level Signal 2t2 [b & c]

SI Signal 2/3 Lo-Lo SG Pressure [d &cl 2-LCV-062-133 spuriously close Hot Short on 2V2777B [a]

a) 2V2777B (control) must Hot Short and therefore makeup l/z of the logic to close the VCT Outlet Isolation Valve 2-LCV-062-133 b) 2PM46Ior 2PM466 must open to makeup 1/2 of the Lo-Lo VCT Level Signal c) 2PM75 must open to makeup V2 of the Lo-Lo VCT Level Signal d) 2PM13601V or 2PM1729IV must open with their associated channel I cable to makeup V2 of the SI Signal e) 2PM1335I or 2PM17151 must open with their associated channel IV cable to makeup 1/22 of the SI Signal f) 2V2070A (power supply) must open or short to prevent automatic opening of the interlocked RWST Outlet Isolation Valve 2-LCV-062-135 g) 2V2100B (power supply) or 2V2101B (control) must open or short to prevent MCR opening of the RWST Outlet Isolation Valve 2-LCV-062-136 h) 2PP562B (power) must open or short or 2PP564B (control) must open or short to prevent starting CCP 2B after either RWST Outlet Isolation Valve has been manually opened If any one of items (a) - (h) above does not occur, seal injection and makeup to the RCS will not be lost. Though the above cables are within 20 feet, some separation does exist. The 2B CCP cables are approximately 17 ft 3 in from the level indicator cables and approximately 19 ft 8 in from the intersection of the SG pressure indicator cables Thermo-Lag ERFBS has been installed on the cables for CCP 2A-A in the subject area.

However, the loss of a suction source as discussed above (and subsequent loss of CCP 2A-A) would be significant since the cables for CCP 2B-B could be damaged by the same postulated fire.

With the requirement for a local manual action to open 2-LCV-062-135 or -136 within 10 minutes, the current configuration is acceptable based on the following justification:

• The combustible loading in the subject area is low and is composed primarily of cable insulation. No large ignition sources are located in the immediate area.

• _..Automatic suppression aind-dejection is prQyid~edn Ihedrea fcg ern. _

• The temperature rating of the detectors is 165 'F, which would activate the suppression system prior to significant cable damage occurring.

• Large scale fire tests, such as NUREG/CR-0381 SAND78-1456, "A Preliminary Report on Fire Protection Research Program Fire Barriers and Fire Retardant Coating Test", and various other tests conducted by Sandia Laboratories for the NRC, indicate that the type of fires that could be reasonably expected to occur will not cause damage to multiple circuits in less than ten minutes. All of these tests have been conducted without automatic suppression. In tests where response time of sprinkler heads were obtained, they showed the sprinklers would fuse before the cables short circuited. Some of the same tests also show that large rooms and high ceilings (as in the case of the subject area) increase the time it takes a fire to cause cable damage.

• The stated fire brigade response time for all Auxiliary and Control Building fires is 5 minutes. This time period includes response to the alarm and verification of the location of the fire.

• Annunciator responses are specified for VCT low and high levels, as well as charging flow irregularities. This would ensure that damage to either the VCT outlet valve cables or the CCP cables was immediately recognized. Also, operator training reinforces the importance of continuous monitoring of VCI volume.

Based on the above evaluation, it is determined that the local manual action to establish suction to the RWST within 10 minutes is acceptable due to the lack of combustibles, the existence of suppression and detection, the large room volume with high ceilings, and the high level of operator awareness to the status of CCP flow.

Therefore, the manual action to locally open 2-LCV-62-135 or -136 within 10 minutes is required until the implementation of DCN F-21103-A.

PER Report . PERI00 03/01/02 Workorder 02-000822-000

.Status: CD Entry Date: 01/2812002 17:11 PlannerlSupv: 0. D. HAYES Requested By: JAMES DVORAK 843-7691 SUPERVISOR PER Level Rev Level 00 Identified By LINE ORGANIZATION Self Revealing N Problem Description The current Appendix - R program requires the Reactor Vessel Head Vent Valve fuses to be removed as a pre-emptive manual action for any declared Appendix-R fire. For fires in the 6.9 kv Shutdown Board Rooms, the accomplishment of this action may require the use of fire fighter 'tum-out' gear. Operations shift personnel are no longer qualified to utilize 'turn-out' gear nor does Operations maintain 'turn-out' gear for Operations shift personnel.

PltProcess Equip N Potential Oper Issue N Potential Reportable N Potential DegradlNoncon(91-18) N 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 D If Utilize ACP, No Immed Action Taken The fire areas that require Operations to use turnout gear (6.9 KV Shutdown Board rooms; FAA-067 and FAA-081) have been evaluated during the recent Appendix R verification program. During this evaluation*

engineering identified that no spurious opening of the modulating head vent valves would occur. Therefore, there is no requirement to pull the fuses associated with the head vent valves for a fire in these fire areas. Subsequently, there would have been no adverse impact to mitigation of the fire for the above listed

PER Report PER100 03/01102 fire areas.

If the fire prevented access to the fuse panel, no impact to safe shutdown capability would have occurred if this action was not performed. The condition identified by this PER does not have to be performed to mitigate an Appendix Rfire in the 6.9 KV Shutdown Board rooms (FAA-067 and FAA-081)..

Ronald Gladney John Thomas Recommended Resp Org OPS Coordinated With O.D. Hayes Int Sup-First Last O.D. Hayes Init Sup Phone 7452 Init Department OPS Init Sup Review Date 01/3012002 LEVEL D INFORMATION LvI D Causing Org ENG/ELECT LvA D Causing Crew Human Perf Proc Code OTH Apparent Cause Inadequate evaluation of fire area interactions in the 6.9kv Shutd6wn Board Rooms during development of the Appendix R Fire Hazards Analysis.

LvI D Process/Proced Appendix R Fire Hazards Analysis Hardware Disposition N/A Technical Justify Init Supv-First Last O.D. Hayes Init Supv Phone 7452 Init Sup Review Date 01/30/2002 AmOPS A Functional Eval (FE)

FE Due Date Affect Operability If Yes,Units/Actions Offsite OP Review Op Review BFN Op Review BLN Op Review SQN Op Review WBN Reportable If Yes, List Basis Ops SROISTA-Fst Last

Sequoyah Nuclear Plant Page 3 PER Report PER100 03/01/02 Ops SRO/STA Rev Date

'a FE *a Functional Maint Potential Degrad/Noncon(91-18) N FE/Eval Due Date Initial Evaluation 91-18 Degrad Nonconf Functional/Eval Basis Immed/Comp Measures List Action/Measures Engineer Date Supervisor Date OPS SRO/STA-Fst Last OPS SRO/STA Rev Date

• MRC*

Process PER Level D Interim Action Req'd N If YES, Specify RCA Required N Site Qual ConcNer N Assigned Resp Org OPS CA Develop Due Date MRC Directions MRC CAP Review N MRC-First Last Shirley Smith MRC Review Date 01131/2002 Resp Org CA Develop Due Date Section POC-First Last POC Phone Reactivity Mgt Issue AIB-LER LER No.

Control of NonConfor If Yes, Scope Hardware Disposition Disposition RIMWEDMS Offsite Generic Rev Generic Rev BFN

PER Report PER100 03/01102 Generic Rev BLN Generic Rev Corp Generic Rev SQN Generic Rev WBN Process/Procedures

• • `CAUSE DATA Apparent Cause Root Cause Causing Org Causing Crew

-Human Perf Proc Code HP Perf Second Code Prev/Similar Event Specify Search Basis Extent of Condition

• '**PER HUMAN PERF

• PER CA/RC ITEMS

• -'CLOSURE COMMENTS FROM CA*

CAP CONCLIF.**

PER Completion Date Prep-First Last Preparer Date Telephone No (C) Supv-First Last (C) Supv Ext (C) Supv Date (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) PltMgr-Fst Lst (A) PltMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N Site Qual First Last

Sequoyan Nuclear mtant t-age o PER Report PER100 03/01/02 Site Qual Date VERIFICATION Final Rev Level Tags Rem-First Last Tags Date RO Verify Comp RO Verify Date ANIIANII Required N ANI/ANII Concurrence Reason for N ANI/ANII-First Last ANIJANII Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date RO Supv Clos-Fst Lst Closure Date EXTENSIONS REVISIONS GENERIC REVIEWS OPERABILITY REVIEWS TRENDS' Program Code FP Program Code Program Code INPO Code FP1 INPO Code NRC Code NRC Code Category PROCESS Short Term Code Impact 2.1 Behavior Code Org / Prog Code P1 GEMS KNOWLEDGE BASED Other CAUSE CODES B2F Information is too generic (not equipment-specific)

PER Report PER100 03/01102 Total records selected: 1

• • • END OF REPORT-***

PER Report PER10O 03/01102 Workorder: 00-007928-000 Status: H2 Entry Date: 08/31/2000 16:20 Planner/Supv: DENNIS LUNDY Requested By: Ira M Heatherly 751-4393 SUPERVISOR PER Level Rev Level 00 Identified By SELF ASSESSMENT Self Revealing N Problem Description Some inconsistencies between Appendix R safe shutdown data sources such as calculations, procedures, cable routing programs, and design output were identified and noted in the Safe Shutdown Corporate self-assessment.

The apparent cause appears to be the multi-discipline nature of the analysis, the complexity of the analysis, the multiple documents required to understand the analysis, and the multi-organization impacts of changes.

In addition 0-GO-8, Appendices L, M, and N contain.,

generic manual actions credited in the SQN Appendix R Safe Shutdown Analysis. Some of these actions appear difficult to implement. (Itis noted that the original approach in responding to an Appendix R fire was to utilize Operations 'knowledge-based' response as opposed to a prescriptive 'rule-based' approach. This approach was presented to and approved by the NRC before restart of SON from the extended 1985-1988 shutdown). It is also noted in discussions with the Appendix R program development lead that operator staffing requirements for these generic actions was not individually or collectively analyzed since staffing needs were considered bounded by the MCR abandonment sequence. Since the MCR abandonment sequence (AOP-C.04) requires a minimum of four AUOs, the current AUO staffing level (minimum of seven per ODM-4.5) Is believed to be adequate.

PIt Process Equip N Potential Oper Issue N Potential Reportable N Potential Degrad/Noncon(91-18)

ASME N Systems Affected N/A

PER Report PER100 03/01/02 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 D. Porter and F. Roddy (OPS) have conservatively estirrfated the required AUO staffing to be 7 for the most limiting App. R fire. This agrees with the minimum staffing specified in ODM-4.5; therefore, current levels are adequate.

AOP-N.01, -Plant Fires,' will be revised to incorporate the Fire Safe Shutdown procedure, 0-GO-8.

This will ensure that safe shutdown is encompassed by the general plant fire procedure, and that sufficient operator training is conducted. As a ^immediate action, operators are being briefed during shift turnover on the new procedure and the basic steps of how to enter and utilize the safe shutdown instructions.

Recommended Resp Org ENG/MECH Coordinated With Dennis Lundy Init Sup-First Last Dennis Lundy Init Sup Phone 8214 Init Department ENG/MECH Init Sup Review Date 09101/2000 A LEVEL D INFORMATION Lvl D Causing Org Lvl D Causing Crew Human Perf Proc Code Apparent Cause Lvl D Process/Proced Hardware Disposition Technical Justify Init Supv-First Last Init Supv Phone Init Sup Review Date Functional Eval (FE)

FE Due Date

• @ w b9lt-byId*

o~}l fld.*CA * ** * -

PER Report PER100 03101/02

-Affect Operability If Yes,Units/Actions Offsite OP Review Op Review BFN Op Review BLN Op Review SQN Op Review WBN Reportable If Yes, List Basis' Ops SRO/STA-Fst Last Ops SRO/STA Rev Date FE Functional Maint Potential DegradlNoncon(91-18)

FE/Eval Due Date Initial Evaluation 91-18 Degrad Nonconf Y FunctionaVEval Basis

^lmmed/Comp Measures .

List Action/Measures Engineer Date Supervisor Date OPS SRO/STA-Fst Last OPS SRO/STA Rev Date

' MRC Process PER Level B Interim Action Req'd N If YES, Specify RCA Required Y Site Qual ConcNer N Assigned Resp Org ENG/MECH CA Develop Due Date 04/27/2001 MRC Directions NOTE: This PER was brought back to MRC for upgrading to a Level B with a root cause required. COMMENTS from 03/01/2001 MRC Meeting: (1) Upgrade to a Level B with root cause required and Extent of Condition; (2) Look and understand the similarities between our Appendix R program and Security program and their systems, and see if we have other programs with similar vunerabilities; (3) Investigation should Include determining why we can't produce any engineering documents to help us

PER Report PER100 03/01/02 understand this analysis; (4) New CAP due date of 03/28/2001; (5) Bring CAP back to MRC. *'CAP due date changed due to extension request.* COMMENTS from 05/04/2001 MRC CAP presentation: (1) Change ROOT CAUSE required to wNo," Apparent cause was okay with MRC; (2)

Add action to address the current training OPS is doing with AOP-N.01; (3) Add that briefing was conducted to address the lack of management monitoring (per Dennis Koehl-this will address the P11 OP.2 cause; (4) Add that an effectiveness self-assessment review will be performed.

MRC CAP Review Y MRC-First Last Shirley Smith MRC Review Date 03/01/2001 Resp Org CA Develop Due Date 04/2712001 Section ENG/MECH POC-First Last POC Phone -

Reactivity Mgt Issue N ANB-LER N LER No.

Control of NonConfor N If Yes, Scope Hardware Disposition N/A Disposition RIMWEDMS Offsite Generic Rev N Generic Rev BFN Generic Rev BLN Generic Rev Corp Generic Rev SQN Generic Rev WBN Process/Procedures CAUSE DATA Apparent Cause The apparent cause is that the SON Appendix R procedures and design basis documentation have not been developed in accordance with changing regulatory and site expectations. A root cause could not be determined due to the historical nature of this issue.

See attached Cause Analysis.

Root Cause Causing Org ENG/MECH Causing Crew

PER Report PER10I

.03/01102 Human Perf Proc Code HP Perf Second Code Prev/Similar Event N/A Specify Search Basis Extent of Condition During performance of corrective action #9, the following condition was identified and documented on PER 01-9670.

The current SQN Appendix R program does not credit the use of control air for Appendix R compliance.

Therefore, manual actions are required for operation of the Steam Generator (SG) Atmospheric Relief Valves (ARVs). Also, one of the three associated pressure indicators is required for the SGs being used for cooldown. The ARVs are located in the West Valve Vaults (PCV-1-5 and -30 for SGs I and 4, respectively) and the East Valve Vaults (PCV-1-12 and -23 for SGs 2 and 3, respectively). Remote valve actuators and associated emergency lights have been installed for SGs 1 and 4, but not for SGs 2 and 3. Subsequently, SGs I and 4 are the only stczcr generators credited in the analysis. In two plant fire areas, FAA-31 and -39 (Ul and U2 El. 690 Pipe Gallery), all three pressure indicators for SGs I and 4 have essential cables terminating In panels located within the fire areas. Twenty foot separation between the redundant trains of indication does not exist for these areas. However, it has been verified on the Appendix R drawings (1-45E890-304-2 and 2-45E890-314-4) that these cables are in fact located in the subject rooms. This cable routing information was also verified on the conduit and grounding drawings.

Established fire watches in accordance with the SQN Fire Protection Report (FPR), Part II, FOR 3.7.12.

- PER HUMAN PERF Human Perform Issue: Y Key Processes: ENGO4 Key Processes: ENG05 Event Precursors Task Demands: COMPLEX INFORM lndividua Capability UNFAMILIARITY

PER Report PER100 03/01/02 Work Environment Human Nature: SUGAR CYCLE Barrier Evaluation: FAILED BARRIER Error Mode: KNOWLEDGE BASED Latent Org Weakness: DESIGNIMODIFICA PER CANRC ITEMS 1 Action Item Provide necessary time and resources for applicable training of personnel involved with ownership of the FSSD Program. This should include training and skill enhancing assignments which will further the knowledge for FSSD.

I Action Type ENHANCEMENT 1 Assigned Org ENGIMECH I CA Due Date 04/28/2001 1 AO Concur-Fst Last WMJUSTICE I AO POC Fst Last BFSIMRIL 1 CA Performed After upgrade of this PER to Level B,this corrective -

action is superceded by corrective actions 7-14.

1 Date Completed 04/1212001 2 Action Item Provide necessary time and resources for applicable training of personnel involved with ownership of the FSSD Program 2 Action Type ENHANCEMENT 2 Assigned Org ENG/ELECT 2 CA Due Date 0412812001 2 AO Concur-Fst Last JHRINNE 2 AO POC-Fst Last RTRAVIS 2 CA Performed After upgrade of this PER to Level B. this corrective action is superceded by corrective actions 7-14.

2 Date Completed 04/12/2001 3 Action Item Correct identified documentation discrepancies and resolve open items identified in Corporate Engineering Self-Assessments CRP-ENG-00-031 and CRP-ENG-00-014.

3 Action Type CORRECTIVE ACTION 3 Assigned Org ENG/IMECH 3 CA Due Date 04/28/2001 3 AO Concur-Fst Last WMJUSTICE 3 AO POC Fst Last BFSIMRIL 3 CA Performed After upgrade of this PER to Level B.this corrective action is superseded by corrective actions 7-14.

PER Report PER100 03/01/02 3 Date Completed 04/12/2001 4 Action Item Correct identified documentation discrepancies and resolve open items identifed in Corporate Engineering Self-Assessments CRP-ENG-00-031 and CRP-ENG-O0-14.

4 Action Type CORRECTIVE ACTION 4 Assigned Org ENG/ELECT 4 CA Due Date 04/28/2001 4 AO Concur-Fst Last JHRINNE 4 AO POC-Fst Last RTRAVIS 4 CA Performed After upgrade of this PER to Level B, this corrective action is superceded by corrective actions 7-14.

4 Date Completed 04112/2001 5 Action Item Develop program controls which ensure future Integrity of FSSD Program documentation.

5 Action Type ENHANCEMENT 5 Assigned Org ENG/MECH 5 CA Due Date 04/28/2001 5 AO Concur-Fst Last WMJUSTICE 5 AO POC-Fst Last ;BFSIMRIL 5 CA Performed Aiter upgrade of this PER to Level B, this corrective action is superceded by corrective actions 7-14.

5 Date Completed 04/12/2001 6 Action Item Interim Actions (See Supervisor Template for Immediate Actions regarding operability issues regarding staffing levels):

Revise AOP-N.01 (Plant Fires) to incorporate all fire safe shutdown actions and to eliminate need for MCR staff to use shutdown logic diagram. Also, conduct interim training on fire safe shutdown actions for all shift crews. This training will cover 0-GO-8 and the revision to AOP-N.01. A standing order will also be issued by 3/12/01.

6 Action Type ENHANCEMENT 6 Assigned Org OPS 6 CA Due Date 03/12/2001 6 AO Concur-Fst Last JIM DVORAK 6 AO POC-Fst Last DAVE PORTER 6 CA Performed AOP-N.01 and a standing order have been issued.

Training was provided to all shift crews.

6 Date Completed 03/12/2001 7 Action Item Identify all potential FSSD paths by overlaying FSSD equipment set on flow diagrams.

PER Report PER100 03/01102

• 7Action Type CORRECTIVE ACTION 7 Assigned Org ENGIMECH 7 CA Due Date 03130/2001 7 AO Concur-Fst Last JOHN THOMAS 7 AO POC-Fst Last BRENDA SIMRIL 7 CA Performed FSSD equipment from Appendix C of calculation SQN-SQS4-0127 has been identified and marked on respective flow diagrams.

7 Date Completed 03/3012001 8 Action Item Screen for potential FSSD paths by overlaying 1987 to March 1988 changes for SOI-26.2, SQN-SQS4-0127, Cable Block Diagrams (CBD). Safety Function Position Statements (SFPS), and Cable Interaction documents.

8 Action Type CORRECTIVE ACTION 8 Assigned Org ENG/MECH 8 CA Due Date 04/13/2001 8 AO Concur-FST Last JOHN THOMAS 8 AO POC-Fst Last BRENDA SIMRIL 8 CA Performed Appendix R documents from the original program development (i.e., 1988) have-been retrieved, researched, and organized to identify credited FSSD paths.

8 Date Completed 04/11/2001 9 Action Item Safety Function Review - Using SFPS documents, identify all credited Appendix R FSSD paths by safety function (e.g., Secondary side isolation, Steam Generator inventory control, etc.), key, and fire area. Review will include resolution of open items, review of DCN changes, calculation requirements, tracing of cables for FSSD components, and verification of cable interaction resolutions.

9 Action Type CORRECTIVE ACTION 9 Assigned Org ENG/MECH 9 CA Due Date 02/1512002 9 AO Concur-Fst Last JOHN THOMAS 9 AO POC-Fst Last BRENDA SIMRIL 9 CA Performed 9 Date Completed 10 Action Item Safety Function Review - Using SFPS documents, identify all credited Appendix R FSSD paths by safety function (e.g., Secondary side isolation, Steam Generator inventory control, etc.), key, and fire area. Review will include resolution of open items, review of DCN

-equoyan Iuu~itw rant raoy a PER Report PER100 03/01/02 changes, calculation requirements, tracing of cables for FSSD components, and verification of cable interaction resolutions.

1OActionType CORRECTIVEACTION 10 Assigned Org ENG/ELECT 10 CA Due Date 02/27/2002 10 AO Concur-Fst Lst RON GLADNEY 10 AO POC-Fst Last REBECCA TRAVIS 10 CA Performed 10 Date Completed 11 Action Item Develop database to identify all FSSD components, cables, and compliance strategies by fire area.

11 Aciton Type CORRECTIVE ACTION 11 Assigned Org ENGIELECT 11 CA Due Date 02127/2002 11 AO Concur-Fst Lst RON GLADNEY 11 AO POC-Fst Lst REBECCA TRAVIS 11 CA Performed 11 Date Completed .

12 Action Item Determine Manual action time requirements to identify the time-critical actions in order to verify adequacy of minimum operator staffing levels.

12 Action Type CORRECTIVE ACTION 12 Assigned Org CORPENG 12 CA Due Date 02128/2002 12 AO Concur-Fst Lst IRA M. HEATHERLY 12 AO POC-Fst Last IRA M. HEATHERLY 12 CA Performed SQN-SOS4-0127 appendix B has been prepared and checked which develops the required operator action times associated with Appendix R shutdown.

12 Date Completed 02/26/2002 13 Action Item Based on information provided by Engineering In the comprehensive database, restructure AOP-N.01 to be a prescriptive, room-by-room instruction for safe shutdown In an Appendix R event.

13 Action Type CORRECTIVE ACTION 13 Assigned Org OPS 13 CA Due Date 03/15/2002 13 AO Concur-Fst Lst JAMES DVORAK 13 AO POC-Fst Last DAVE PORTER 13 CA Performed 13 Date Completed 14 Action Item Revise FSSD and FHA calculations, and other affected

FhRReport PER100 03/01/02 Appendix R documentation (Design Criteria, Fire Protection Report, etc.).

14 Action Type CORRECTIVE ACTION 14 Assigned Org ENG/MECH 14 CA Due Date 02/28/2002 14 AO Concur-Fst Lst JOHN THOMAS 14 AO POC-Fst Lst BRENDA SIMRIL 14 CA Performed 14 Date Completed 15 Action Item Implement Operator Training on revised AOP-N.01 15 Action Type CORRECTIVE ACTION 15 Assigned Org OPS 15 CA Due Date 0212512002 15 AO Concur-Fst Lst JAMES DVORAk 15 AO POC-Fst Lst DAVE PORTER 15 CA Performed Initial Operation training completed during 1st cycle

- of requal, 2002.

15 Date Completed 02/21/2002.

16 Action Item Develop Keys 38 and 39 for FSSD Calculation 16 Action Type CORRECTIVE ACTION 16 Assigned Org ENG/ELECT 16 CA Due Date 09/2812001 16 AO Concur-Fst Lst RON GLADNEY 16 AO POC-Fst Lst REBECCA TRAVIS 16 CA Performed Keys 38 & 39 analysis was developed for FSSD Calculation, SQN-SQS4-127.

16 Date Completed 07/28/2001 17 Action Item Brief upper management on the importance of monitoring programs for changing regulatory/site expectations to preclude future OP-2 failures.

17 Action Type CORRECTIVE ACTION 17 Assigned Org ENG/MECH 17 CA Due Date 05/04/2001 17 AO Concur-Fst Lst DENNIS LUNDY 17 AO POC-Fst Lst BRENDA SIMRIL 17 CA Performed Management was briefed during MRC on 05/04/2001. All major site organizations were represented, management was advised to consider similar cases within their respective organizations.

17 Date Completed 05/04/2001 18 Action Item In addition to Initial operator briefings (see CA Item

1. 6), implement extensive training on current FSSD procedure (AOP-N.01) as part of operator

PER Report PER100 03101102 requalification training.

18 Action Type CORRECTIVE ACTION 18 Assigned Org OPS 18 CA Due Date 05/25/2001 18 AO Concur-Fst Lst KEVIN WILKES 18 AO POC-Fst Lst KEVIN WILKES 18 CA Performed Training has been completed for all groups during this D requal cycle on the new AOP-N.01.

18 Date Completed 0512312001 19 Action Item Conduct a follow-up~self-assessment on the Appendix R program prior to the NRC triennial fire protection inspection tentatively scheduled for Spring 2002, to ensure effectiveness of corrective action plan.

19 Action Type. CORRECTIVE ACTION 19 Assigned Org ENG/MECH 19 CA Due Date 0212812002 19 AO Concur-Fst Lst JOHN THOMAS 19 AO POC-Fst Lst BRENDA SIMRIL 19 CA Performed .

19 Date Completed 20 Action Item Add line item in Self Assessment Committee for self-assessments to review programs for adherence to changing regulatory guidance/expectations.

20 Action Type CORRECTIVE ACTION 20 Assigned Org PLTMGR 20 CA Due Date 08/3012001 20 AO Concur-Fst Lst DENNIS KOEHL 20 AO POC-Fst Lst DON CLIFT 20 CA Performed When self-assessment outlines are presented to the self-assessment committee for review and comment, the committee will consider the need to assess programs for adherence to changing regulatory guidance.

20 Date Completed 08/1512001 21 Action Item UPDATE CALCULATIONS SQN-CSS-023 AND SON-CSS-024 TO PROVIDE CONSISTENCY WITH SON FIRE PROTECTION REPORT.

21 Action Type CORRECTIVE ACTION 21 Assigned Org ENG/ELECT 21 CA Due Date 0212812002 21 AO Concur-Fst Lst JOHN CAMPBELL 21 AO POC-Fst Lst REBECCA TRAVIS 21 CA Performed 21 Date Completed 22 Aciton Item Revise design documentation to install thermolag

PER Report PER100 03/01/02 insulation on unit I and 2 SG pressure indication in 690 penetration room. Work orders to install thermolag to be written as part of the design change process.

22 Action Type CORRECTIVE ACTION 22 Assigned Org ENG/MECH 22 CA Due Date 02/28/2002 22 AO Concur-Fst Lst JOHN THOMAS 22 AO POC-Fst Lst BRENDA SIMRIL 22 CA-Performed 22 Date Completed 23 Action Item Provide design change to resolve cable separation issues identified in PER 02-00575-000 for the EGTS room.

23 Action Type CORRECTIVE ACTION 23 Assigned Org ENG/MECH 23 CA Due Date 05/30/2002 23 AO Concur-Fst Lst JOHN THOMAS 23 AO POC-Fst Lst BRENDA SIMRIL 23 CA Performed 23 Date Completed 24 Action Item Provide design change to install themolag insulation on power cables to resove issue identified In PER 02-00576-000 for the 690 elevation general area.

24 Action Type CORRECTIVE ACTION 24 Assigned Org. ENG/MECH 24 CA Due Date 05/30/2002 24 AO Concur-Fst Lst JOHN THOMAS 24 AO POC-Fst Lst BRENDA SIMRIL 24 CA Performed 24 Date Completed

• • CLOSURE COMMENTS FROM CA

• • a'CAP CONCUR PER Completion Date 05/3012002 Prep-First Last Brenda Simril Preparer Date 04/26/2001 Telephone No 8515 (C) Supv-First Last John Thomas (C) Supv Ext 8224 (C) Supv Date 04/26/2001 (B) DptMgr-Frst Last dennis lundy (B) DptMgr Date 04/2712001 MRC Reqd Y MRC Concurrence Y

PER Report PER100 03/01/02 Reason for N MRC-First Last SHIRLEY SMITH MRC Date 0510412001 (A) SiteSr-Fst Last (A) SiteSr Date (A) PltMgr-Fst Lst (A) PltMgr Date React Eng-Fst Lst React Eng Date Site Qual Conc Reqd N Site Qual Concur Reason for N Site Qual First Last Site Qual Date VERIFICATION Final Rev Level Tags Rem-First Last Tags Date RO Verify Comp RO Verify Date ANI/ANII Required N ANIIANII Concurrence Reason for N ANIIANII-First Last ANIIANII Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date RO Supv Clos-Fst Lst Closure Date G'EXTENSIONS Original Comp Date 03/28/2001 Current Comp Date 03128/2001 Requested Comp Date 04/27/2001 Desc. of Actions Corrective Action Plan (Including Root Cause Analysis)

Justification A detailed resolution of the documentation issue for the Appendix R program is being implemented by SON NE (MEB and EEB), with the guidance of Corp. Engineering.

This plan will re-verify the existing Appendix R compliance strategies and will establish a clear documentation trail that will be translated into a

PER Report PER100 03/01/02 comprehensive (room-by-room) procedure for FSSD.

As an interim, OPS has evaluated current operator staffing levels and has determined them to be adequate for safe shutdown during an Appendix R event. Also, a new revision of AOP-N.01 was implemented which incorporates 0-GO-8, to ensure that safe shutdown is included in the fire events procedure. Operators have been briefed on these changes.

The extension is requested due to the complexity of the corrective action plan, and the requirement to perform a root cause analysis. Based on the discussion presented above, this extension does not affect nuclear safety.

Interim Action Req'd N Interim Actions Text Sub by-First Last BRENDA SIMRIL

,Date Submitted 03/19/2001 (C) Supv-First Last JOHN THOMAS (C) Supv Date 03/1912001 (B) Dept Mgr-Fst Lst HEYWARD R ROGERS (B) Dept Mgr Date 03/26/2001 (A) Sitesr-Frst Last (A) Sitesr Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date Site VPIEng Support Site VP/Eng Date Original Comp Date Current Comp Date

-Requested Comp Date Desc. of Actions Justification Interim Action Req'd N Interim Actions Text Sub by-First Last Date Submitted (C) Supv-First Last (C) Supv Date (B) Dept Mgr-Fst Lst

PER Report PER100 03/01/02 (B) Dept Mgr Date (A) Sitesr-Frst Last (A) Sitesr Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date Site VP/Eng Support Site VP/Eng Date REVISIONS Items(s) to Revise Revise problem description to increase scope and to document additional discrepancies Identified in the App. R program (See revised work description). Also request upgrade to level B.

Justification Recent self evaluation has led to further items identified within this program Requested Revision See revised work descrption.

Potervtial Oper Issue .N Potential Reportable N Sub By-First Last B. SIMRIUJ. THOMAS Date Submitted 02126/2001 (C) Supv-First Last JOHN THOMAS (C)Supv Date 02/26/2001 (B) Dept Mgr-Fst Lst HRROGERS.

(B) Dept Mgr Date 05/14/2001 MRC-Frst Last SHIRLEY SMITH MRC Date 05/14/2001 (A) SiteSr-Frst Last (A) SiteSr Date (A) PItMgr-Fst Lst (A) PIt Mgr Date React Eng-First Last React Eng Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date Item(s) to Revise Corrective Action Plan Justification Per MRC's comments on 05/04/2001 Requested Revision Add Corrective Actions #17-20 per MRC suggestions Potential Oper Issue N Potential Reportable N

PER Report PER100 03/01/02 Sub by-First Last BRENDA SIMRIL Date Submitted 05/09/2001 (C) Supv First Last JOHN THOMAS (C) Supv Date 05/14/2001 (B) Dept Mgr Fst Lst HRROGERS (B) Dept Mgr Date 05/14/2001 MRC Frst Last SHIRLEY SMITH MRC Date 05/14/2001 (A) SiteSr-Frst Last (A) SiteSr Date (A) PitMgr-Fst Lst (A) Pit Mgr Date React Eng-Fst Lst React Eng Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date Item(s) . Revise Corrective Action #14 {;

Justification As directed by MRC for PER 01-5753-000 Requested Revision Ensure corrective action #14 addresses the following issue identified by PER 1-005753-000: During performance of the SON Fire Protection Self Assessment.

it was noted that the Fire Hazard Analysis Calcs. AND the SON Fire Protection Report did not agree with the TVA Prints and plant field installation. It is indicated in the FHA Calcs. for Fire Area FAA-070 (480V Shutdown Board Room 1B2) that the "cable tray thermal detectors provides alarm & actuates cable tray spray system". It Is Indicated in the SON FPR, Part VII, Deviation 2.10, that the water spray systems for the cable trays in the Shutdown Board Rooms are actuated by line type thermal fire detection systems. Neither of these positions are entirely accurate. In actuality, as indicated on the TVA Prints (1,2-45W626-10), each spray system is actuated by a combination of line type heat detectors and ceiling mounted smoke detectors.

Potential Oper Issue N Potential Reportable N Sub by-First Last BRENDA SIMRIL Date Submitted 07/03/2001 (C) Supv-First Last JOHN THOMAS (C) Supv Date 07/03/2001

PER Report PER100 03/01/02 (B) Dept Mgr-Fst Lst DL LUNDY (B) Dept Mgr Date 0710312001 MRC-First Last SHIRLEY SMITH MRC Date 07/03/2001 (A) SiteSr-Frst Last (A) SiteSr Date (A) PItMgr-Frst Lst (A) PIt Mgr Date React Eng-Fst Lst React Eng Pate Site Qual Concur Siteqa N Reason 3:

Site Qual First Last Site Qual Date (C) Supv-First Last JOHN THOMAS Item(s) to Revise Corrective Action #14.

Justification Issues identified by PER 01-000589-000 are bounded by the scope of the Appendix R upgrade project, which is the basis of this-PER. - . I.

Requested Revision Ensure Corrective Action #14 addresses the fuliowing issue, which was originally identified in PER' 01-000589-000: 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. The valves were not listed as Appendix R valves in the FSSD CaIc, SQN-SQS4-0127, or the FHA CaIc, SQN-26-DO541EPM-ABB-IMPFHA.

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-SOS4-127). 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. It was previously determined that Isolation of non-essential air to containment was provided as an

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

CA #14 will ensure documentation is revised to address repositioning of one head of Appendix R lighting unit (0-LGT-247-RI 55).

Potential Oper Issue N Potential Reportable Sub by-First Last BRENDA SIMRIL Date Submitted 0/23/2001 (C) Supv Date 0TU2712001 (B) Dept Mgr-Fst Lst HRROGERS (B) Dept Mgr Date 07/2712001 MRC-First Last SHIRLEY SMITH MRC Date 07127/2001 (A) SiteSr-Frst Lst (A) Site Sr Date (A) PltMgr-Fst Lst (A) PIt Mgr Date React Eng-Fst Lst React Eng Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date Item(s) to Revise Corrective Actions #10 and #14 Justification Issues identified by PER 01-000911-000 are bounded by the scope of the Appendix R upgrade project, which Is the basis of this PER.

Requested Revision Ensure Corrective Actions #10 and #14 address the following issue, which was originally identified in PER 01-000911-000:

Sequoyahos App. R Fire Safe Shutdown analysis appears

PER Report PER100 03/01/02 to conflict with current Westinghouse information/guidance regarding loss of RCP seal cooling. Specifically:

1. The SON App. R analysis credits seal injection as an available RCS makeup path following an App. R fire and prescribes manual actions to restore seal injection flow if it is lost. However, fires in some areas in the Aux Bidg appear to have the potential to cause a loss of both seal injection flow and thermal barrier cooling. The manual operator actions required to restore seal injection or thermal barrier cooling probably would not be completed in time to prevent the RCP seals from overheating. (WOG DW 94-011 predicts 13 minutes for the seal to heat up to near RCS Tcold).

Therefore, the Appendix R analysis appears to require restoration of seal injection flow to an overheated RCP seal, which is contrary to the guidance contained In WOG DW-94-01 1.. (This DW directs NOT restoring seal injection or thermal barrier cooling and requires performing an RCS cooldown to cool the seal package.

This guidance appears to be incompatible with the Appendix R analysis).

2. If all seal cooling is lost as a result of an App.

R fire, the total expected RCP seal leakage (84 gpm) may exceed the available makeup capacity credited In the App. R analysis. This problem would be aggravated if thermal contraction due to RCS cooldowrn is considered. .

Potential Oper Issue N Potential Reportable Sub by-First Last BRENDA SIMRIL Date Submitted 09/10/2001 (C) Supv-First Last JOHN THOMAS (C) Supv Date 09/12/2001 (B) Dept Mgr-Fst Lst HRROGERS (B) Dept Mgr Date 09/12/2001 MRC-First Last SHIRLEY SMITH MRC Date 09/12/2001 (A) SiteSr-Frst Last (A) SiteSr Date (A) PItMgr-Fst Lst

PER Report PER100 03/01/02 (A) Pit Mgr Date React Eng-Fst Lst React Eng Date Site Qual Concur Reason for N ,

Site Qual First Last Site Qual Date Items(s) to Revise Extent of condition template to include information contained in PER 01-9670. Add corrective actions to resolve identified problem.

Justification During the performance of corrective action #9, the following issue identified and documented in PER 01-9670:

The current SON Appendix R program does not credit the use of control air for Appendix R compliance.

Therefore, mahual actions are required for operation of the Steam Generator (SG) Atmospheric Relief Valves (ARVs). Also, cli7 of the three associated pressure indicators is required for the SGs being used for cooldown. The ARVs are located in the West Valve Vaults (PCV-1-5 and -30 for SGs I and 4, respectively) and the East Valve Vaults (PCV-1-12 and -23 for SGs 2 and 3, respectively). Remote valve actuators and associated emergency lights have been installed for SGs I and 4, but not for SGs 2 and 3. Subsequently, SGs 1.and 4 are the only steam generators credited In the analysis. In two plant fire areas, FAA-31 and -39 (Ul and U2 El. 690 Pipe Gallery), all three pressure Indicators for SGs I and 4 have essential cables terminating in panels located within the fire areas. Twenty foot separation between the redundant trains of indication does not exist for these areas. However, it has been verified on the Appendix R drawings (1-45E890-304-2 and 2-45E890-314-4) that these cables are in fact located in the subject rooms. This cable routing Information was also verified on the conduit and grounding drawings.

Requested Revision Add PER 01-9670 description to 'extent of condition' template' and add corrective action # 22 to resolve.

Potential Oper Issue N Potential Reportable Sub by-First Last JOHN THOMAS

zequoyari ryuicwai ridliL rays I PER Report PER100 03/01/02

,Date Submitted 10/2812001 (C) Supv-First Last JOHN THOMAS (C) Supv Date 10128/2001 (B) Dept Mgr-Fst Lst HRROGERS (B) Dept Mgr Date 10/2812001 MRC-First Last SHIRLEY SMITH MRC Date 10/2812001 (A) SiteSr-Frst Last (A) SiteSr Date (A) PltMgr-Frst Last (A) PIt Mgr Date React Eng-Fst Lst React Eng Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date Item(s) to Revise Change 91-18 designation Justification -Based on review of the work required for installation . . -

of thermo-lag (PER 01-9670-000) this PER will be consider 91-18 until the thermolag has been installed or the separation requirements are met.

Requested Revision Change 91-18 designation note degraded/nonconforming condition Potential Oper Issue N Potential Reportable Sub by-First Last JOHN THOMAS Date Submitted 11/16/2001 (C) Supv-First Last JOHN THOMAS (C) Supv Date 11/16/2001 (B) Dept Mgr-Fst Lst DENNIS LUNDY (B) DeptMgrDate 11/1612001 MRC-First Last SHIRLEY SMITH MRC Date 11/1612001 (A) SiteSr-Frst Last (A) SiteSr Date (A) PitMgr-Fst Lst (A) PIt Mgr Date React Eng-Fst Lst React Eng Date Site Qual Concur Reason for N Site Qual First Last

PER Report PER100 03/01/02 Site Qual Date Item(s) to Revise Add corrective actions 23 and 24 Justification Corrective actions are needed to resolve issues identified by PERs 02-575-000 and 02-576-000.

Requested Revision Revision required to address cable separation issues for the EGTS room and elevation 690 general area.

Potential Oper Issue N Potential Reportable N Sub by-First Last JOHN THOMAS Date Submitted 02/06/2002 (C) Supv-First Last JOHN THOMAS (C) Supv Date 02/06/2002 (B) Dept Mgr-Fst Lst HRROGERS (B) Dept Mgr Date 02107/2002 MRC-First Last SHIRLEY SMITH MRC Date 02/07/2002 (A) SiteSr-Frst Last (A) SiteSr Date (A) PltMgr-Fst Lst .

(A) Plt Mgr Date React Eng-Fst Lst React Eng Date Site Qual Concur Reason for N Site Qual First Last Site Qual Date GENERIC REVIEWS

• OPERABILITY REVIEWS

• • TRENDS Program Code DE Program Code Program Code INPO Code EN2 INPO Code NRC Code NRC Code Category PEOPLE Short Term Code Impact 9.0 Behavior Code Org / Prog Code

PER Report PER100 03/01/02 GEMS Other CAUSE CODES J1 l Change-related training/retraining not performed or not adequate.

MiE Analysis deficiency (calculations: stress, hydraulic, thermal, electri Total records selected: I

^^^END OF REPORT '^-

EVENT TIMELINE PER 00-007928-000 (Approx. 2 Weeks) 1II February March . December 0 March 198:7 1988 1988 1991 1992 1993 1996 2001 1999 2000 Present I I-I I II I I1 6 I I I I I . l -I-I 1I NRC Determined Ops Conducts TVA Nuclear SQN was in Non- FSSD Self- Assurance Audit Compliance with Assessment SSA-01-01 Appendix R. . SQN-OPS-00-01 Conducted I

Sequoyah Original Appendix R Extensive Improvement NRC Issued Violations Corporate Current Efforts Units I and 2 Program Developed Plans Initiated as Part of (w/ Civil Penalties) for Engineering to Resolve PER in Shutdown (Last Issue Resolved . FPIP SQN Fire Protection Conducts FSSD 00-007928-000 Prior to Restart) Program Deficiencies Self-Assessment (Including FSSD Issues) CRP-ENG-00-031 Page 6

PER 00-007928-000 Responsible Engineer:

Brenda Simril, NE - M/N DESCRIPITON An intensive self-evaluation process is currently being conducted to address the adequacy and ability to implement the Fire Safe Shutdown (FSSD) procedures in an Appendix R event. Self assessments conducted by SQN Fire Ops and Corporate Engineering (SQN-OPS-00-001 and CRP-ENG-00-031, respectively) identified weaknesses in the documentation of the Appendix R program. This PER was written after the Corporate Engineering self-assessment to address the apparent inconsistencies and/or discrepancies between the related documentation, and the lack of training and experience of the program owners in both Site Engineering and Operations. As the research effort into the design documentation and operations procedure progressed, it was determined that the scope of the original PER had increased significantly, and that the level of the PER should be increased to Level B. At this point, no operability impacts have been identified which could prevent the ability to place the plant in a safe shutdown condition.

IMMEDIATE ACTIONS The following immediate actions were conducted to ensure no operability issues exist and that safe shutdown can be achieved during an Appendix R event:

1) Incorporate the fire safe shutdown procedure, 0-GO-8 into AOP-N.01, "Plant Fires", Rev 9. This will ensure that the procedure is incorporated into the regular requalification training.

Completed on: 03/12/2001

2) Conduct briefings for operators during shift turnovers prior to issuance of AOP-N.01 R9 on general usage and strategies in using the procedure.

Completed on: 03/1212001 CURRENT DESIGN BASIS DEVELOPMENT The SQN Appendix R program was developed just prior to plant restart in the 1987-88 timeframe.

Appendix R was the last issue to be resolved prior to restart, and was accomplished in a very short duration with a team of individuals involved. Personnel from Nuclear Engineering (site and Corporate) and Operations worked concurrently to develop the Appendix R compliance strategies. The program was designed so that the procedures would be diagnostic in nature, rather than the prescriptive procedures that are required to meet current industry standards. The resulting procedure left the operators with a high level of freedom to accomplish safe shutdown via different paths for each required safety function.

The methodology intended for the operators to observe the fire event developing, then react accordingly.

This would allow operators to attempt to shut down using the most desirable paths first (e.g., normal letdown, normal makeup). Then, if the fire involved the components for the desirable paths, the guaranteed paths would be used (e.g., seal injection for letdown, etc.). This methodology relies upon operator skills and knowledge to effectively diagnose the problems, then react accordingly. This program was presented to the NRC prior to restart and was determined to be acceptable (Ref. NUREG-1232, Vol. 2, 05/1988, Section 3.1, "Fire Protection").

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APPARENT CAUSE ANALYSIS While the SQN Appendix R procedures and design basis documentation meet the existing licensing basis requirements, they have not been developed in accordance with changing regulatory and site expectations. The apparent cause is that once the philosophy shift to more prescriptive procedures occurred, the effort to bring the Appendix R program documentation to current regulatory compliance philosophy was not made.

The Fire Safe Shutdown procedure was originally issued as a System Operating Instruction, SOI-26.2, then was incorporated into a General Operating (GO) procedure, 0-GO-8. Training was conducted initially on the SOI, but once it became 0-GO-8, it was not incorporated into the normal operator requalification training. Per the SQN training records, the last training session on 0-GO-8 was conducted during the spring of 1997. The apparent cause of the lack of training was that the FSSD instructions relate to abnormallemergency operating conditions, but were placed in a normal operating procedure, which are not typically included in the operator requalification training cycle. Therefore, the FSSD procedure was not given the properLpriority in training, which lead to unfamiliarity of the operators with the required actions to safely shutdown the plant during an Appendix R event. As an immediate action, the procedure was incorporated into Abnormal Operating Procedure, AOP-N.01, which is part of the 2-year training cycle for operator requalification. The procedure will be revised again when the design; documentation upgrade effort is complete (See Corrective Action #9). Therefore, no further corrective actions for training deficiencies associated with the FSSD procedure are required.

Due to the historical nature of this issue, a complete root cause analysis could not be performed.

Therefore, the Performance Improvement International (PII) methodology to determine organizational and programmatic deficiencies was used. The failure mode was determined to be Organization-to-Program Interface Deficiency, OP-2, "Inadequate Program Monitoring or Management".

CONTRIBUTING FACTORS

• In the time since the original Appendix R program was developed, a change in the philosophy of what is adequate procedurally has occurred. The FSSD procedure was written such that operators would make diagnostic decisions and react to each situation accordingly. Since then, the NRC has shifted expectations of what acceptable operator instructions entail. Presently, the standard format for procedures are very prescriptive in nature, with specific instructions given for each scenario.

These instructions are to be carried out completely and in the specific order in which they are listed.

The SQN Appendix R procedure was not written in this manner, and had not been revised as industry standards evolved. The current regulatory expectations are outlined in detail in NRC Inspection Procedure 71111.05, "Fire Protection", which is the procedure utilized in the recently implemented NRC Triennial Fire Protection Inspections.

• The documentation associated with the Appendix R program is voluminous and complicated. The original Fire Operating Procedure (SOI-26.2), Fire Safe Shutdown calculation (SQN-SQS4-0127),

Appendix R drawing series (ARSK drawings), Safety Function Position Statements (SFPS), Cable Interaction documents, 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 program development. Because the program was based extensively on Page 2

personnel knowledge, and the personnel who were originally assigned to the project are no longer involved with the program, assumptions and methodologies are not clearly evident in all instances.

• A high turnover rate has occurred with the owners of the Appendix R program, combined with the absence of clear design basis documentation. Various Mechanical and Electrical engineers have been involved with the program, but no extensive turnover was conducted from the original to successive owners.

INAPPROPRIATE ACTIONS

• Much of the information requires re-validation and cohesive documentation in order to determine exactly which paths were the credited Appendix R paths. Through numerous interviews and discussions with personnel originally involved in the project, it was discovered that due to the extreme time constraints, not all paths were fully traced to determine the exact areas of concern for potential cable interactions. For instance, if the cables for a certain valve were determni'.ed to have an interaction in one fire area, and the operators agreed to take a manual action for that valve, the cables were not traced further, and a generic action was credited. As a result, there could be numerous other fire areas with the same interactions, but because the manual action was listed generically, it is unknown exactly which areas are affected without completely re-tracing the cables. The current procedure contains many of these "generic" manual actions that are to be taken regardless of where the fire originates. As a result, the required operator staffing levels are difficult to ascertain.

• The procedure contains abnormal operating conditions for bringing the plant to a safe shutdown condition during an Appendix R event. However, it was initially issued as SOI-26.2, then was incorporated into O-GO-8, which is not part of the requalification training cycle. The lack of regular training, in combination with the complexity and unique structure of the procedure led to limited operator knowledge of the Appendix R program.

• Resources were not provided to document all issues involved with the Appendix R program after

• NRC approval was obtained for restart. This was a management decision based on the structure of the program which relied heavily on personnel knowledge and skills. However, once the philosophy shift to more prescriptive procedures occurred, the effort to bring the Appendix R program documentation into full compliance was not made.

• Adequate training was not conducted for both Ops and Engineering personnel after the original program development. Due to the high turnover rate of employees associated with Appendix R, much time and effort has been spent trying to individually understand the methodologies and

-complexities of the documentation with little guidance.

• The current Fire Hazards Analysis (EHA) Calculation, SQN-26-DO54IEPM-ABB-IMPFHA, was created by a contracted team of engineers several years after the original program development. The FHA contains a room-by-room listing of Appendix R compliance strategies. However, the scope of the project did not include re-analyzing the Appendix R paths to address the incomplete cable routing analysis and undocumented assumptions / methodologies discussed previously, and therefore contains some discrepancies with the original documentation.

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CORRECTIVE ACTIONS Additional corrective actions to address the apparent cause are not required due to the ongoing self-assessment program, and the designation of an Engineering Appendix R program owner. These processes will ensure that future regulatory changes are identified and translated into the SQN Appendix R program.

The objective for complete resolution of the current documentation weaknesses in the Appendix R program is to produce a procedure which specifies the manual actions required for each fire area, with no generic actions existing, and a complete FHA calculation which will be the direct input into the procedure. This will create a prescriptive type procedure, similar to the WBN and BFN Fire Safe Shutdown Procedures. Specific corrective actions are as follows:

1) Revise the Engineering design output calculations (FSSD and FHA calculations) to incorporate the Appendix R design basis information ino clear, concise, and understandable format.

Assigned Org: ENG/MECH; Due Date: 01/30/2002

2) Identify all potential FSSD paths by overlaying FSSD equipment set on flow diagrams.

Assigned Org: ENG/MECH; Due Date: 03/12/2001 (Complete)

3) Screen for potential FSSD paths by overlaying 1987 to March 1988 changes for SOI-26.2, SQN-SQS4-0127, Cable Block Diagrams (CBD), Safety Function Position Statements (SFPS), and Cable Interaction documents.

Assigned Org: ENG/MECH; Due Date: 04/13/2001 (Complete)

4) Brief upper management on the importance of monitoring programs for changing regulatory/site expectations to preclude future OP-2 failures.

Assigned Org: ENG/MECH; Due Date: 05/04/2001 (Complete)

5) In addition to initial operator briefings (see CA Item #6), implement extensive training on current FSSD procedure (AOP-N.01) as part of operator requalification training.

Assigned Org: OPS; Due Date: 05/25/2001

6) Safety Function Review - Using SFPS documents, identify all credited Appendix R FSSD paths by safety function (e.g., Secondary side isolation, Steam Generator inventory control, etc.), key, and fire area. Review will include resolution of open items, review of DCN changes, calculation requirements, verifying cable routing for FSSD components, and verification of cable interaction resolutions.

Assigned Org: ENG/MECH, ELECT; Due Date: 08/03/2001

7) Develop database to identify all FSSD components, cables, and compliance strategies by fire area.

Assigned Org: ENG/ELECT; Due Date: 08/03/2001

8) Determine manual action time requirements to identify the time-criti6al actions in order to verify adequacy of minimum operator staffing levels.

Assigned Org: CORPENG; Due Date: 08/17/2001

9) Based on information provided by Engineering in the comprehensive database, restructure AOP-N.01 to be a prescriptive, room-by-room instruction for safe shutdown in an Appendix R event.

Assigned Org: OPS; Due Date: 09/30/2001

10) Add line item in Self Assessment Committee to review programs for adherence to changing regulatory guidance/expectations.

Assigned Org: PLT.MGR; Due Date: 06/15/2001

11) Implement Operator training on revised AOP-N.01.

Assigned Org: OPS; Due Date: 01/30/2002 Page 4

12) Conduct a follow-up self-assessment on the Appendix R program prior to the NRC triennial fire protection inspection tentatively scheduled for Spring 2002, to ensure effectiveness of corrective action plan.

Assigned Org: OPS; Due Date: 02128/2002 EXTENT OF CONDITION The extent of the condition for the SQN Appendix R program is that the design basis documentation was not thoroughly developed and documented when the program was originated. The program relies heavily upon the skills and knowledge of the operators to react appropriately during an Appendix R event, as opposed to having a prescribed shutdown procedure, which is not the standard compared to other operating procedures.

Per discussions with Kevin Wilkes (OPS), Jim Dvorak (OPS), and George Sanders (TRNG), no procedures for programs outside of the Appendix R program contain instructions for abnormal operating conditions in GO's, or other site procedures that are not included in the operator requalification training

'w,cycle.. With the exception of 0-GO-8, the GO's contain startup and shutdown instructions for normal

. operation, while the EOP's and AOP's contain instructions for abnormal/emergency situations and are included in the 2-yr training cycle for operator requalification.

MRC comment (3) specified that an investigation should be conducted to determine why the engineering documents cannot be produced to aid in understanding of the analysis. The engineering design basis documentation for the Appendix R program does exist, but it is in various formats and levels of detail and is not cohesively bounded. Therefore, retrieval and reproduction of input parameters is difficult.

Comment (2) from MRC requested to examine if other programs exist with similar problems. This condition extends to and may be applicable to all major programs within SQN and TVA. However, a successful self-assessment program has been implemented throughout TVA, in which reviews are performed of all primary programs. The issues identified in this PER resulted originally from a self-assessment. A review of the recently completed and in-progress self-assessments show that all primary organizations within SQN are participating in the process. Therefore, no further corrective actions are required.

PREVIOUS SIMILAR EVENTS This PER was written as a result of the Corporate Engineering Self-Assessment, CRP-ENG-00-03 1,"Fire Protection - Fire Safe Shutdown & NEI 99-05 Level I Assessment," conducted April - July 2000. Other self-assessments conducted by Ops and Engineering groups recognized similar weaknesses in the Appendix R program:

1) Corporate Engineering Self-Assessment, RIMS B45961007001, "TVA Nuclear Self-Assessment of the Sequoyah Nuclear Plant Fire Protection Program", September 1996.

2) SQN Operations Self-Assessment, SQN-OPS-00-001, "Fire Protection - Fire Safe Shutdown Operator Actions," December 1999.

The issues identified in these self-assessments were addressed on an item-by-item basis, which resolved only the specific examples cited in the self-assessment reports. The scope of the Appendix R documentation deficiencies was not appropriately expanded to examine the entire program for similar weaknesses.

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A PER search was conducted for similar programmatic deficiencies at SQN dating back to 1985. No significant issues relative to the apparent cause of this PER were identified. The self-assessment programs will continue to identify significant weaknesses and will be addressed accordingly.

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