ML043310165
| ML043310165 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 05/06/2004 |
| From: | Matt Thomas Division of Nuclear Materials Safety II |
| To: | |
| References | |
| FOIA/PA-2004-0277 IR-04-006 | |
| Download: ML043310165 (4) | |
See also: IR 05000390/2004006
Text
WATTS BAR TRIENNIAL FIRE PROTECTION INSPECTION REPORT INPUT, Rev. 0 5/6/04
Inspector: M. Thomas
Report No.:. .50-390,391/2004-006/-
Inspection Dates: 3/29 - 4/2/2004 and 4/12-16/2004 '
1. . REACTOR SAFETY't
CORNERSTONES: -Initiating Events, Mitigating Systems, and Barrier Integrity
I R05 -'Fire Protection (71111.05T)
.05 Operational Implementation of Post-Fire Safe Shutdown Capability
a.- Inspection Scope
The team reviewed the operational implementation of the SSD capability for an .
Appendix R fire in Fire Areas 14,27, '33,'or 48 to verify that: '(1) the training program for
licensed personnel'included main control room (MCR) and alterniative'safe shutdown
capability; (2) personnel required to achieve and maintain the plant in hot standby, from
`the MCR or auxiliary control room '(ACR), following a fire could be provided from normal
onsite staff, exclusive of the fire brigade; (3) the licensee had incorporated the
-operability of alternative shutdown'transfer and control functions into plant Technical
Specifications (TS); and (4)the licensee periodically performed operability testing of the
alternative shutdown instrumentation, and transfer and control functions. The team
reviewed abnormal operating instructions (AOl) AO1-30.1, Plant Fires; and AO1-30.2,
Fire Safe Shutdown." The reviews focused on ensuring that all required functions for
post-fire safe shutdown, and the corresponding equipment necessary to perform those
functions, were included in the'procedures.---
b. Findings :
Introduction: -The team identified a non-cited violation (NCV) of Operating License
Condition 2.F. for inadequate implementation of the approved fire protection program
(FPP). The licensee's process for evaluating the impact of design changes on the FPP
(i.e., local manual operator actions) was not adequate to ensure that the changes would
not adversely affect the ability to achieve and maintain safe shutdown in the event of a
fire.
The team identified a'green non-cited violati6n (NCV) of Operating License Condition 2.F for
inadequate implementation of the approved fire protection program (FPP). The licensee made
a change to the FPP, which had the potential to adversely affect the ability to achieve'and
maintain safe shutdown in'th6 event of a fire in Room 757-A5 (Fire Area 27), without obtaining
prior NRC approval. This is a violation of NRC requirements. -
Description: The' licensee's pro6ss for evaluating the impact of design changes on the
FPP was addressed in several procedures.: This included'procedures FPDP-3,
Management of the Fire Protection'Report;'SPP-9.3, Plant Modifications and
Engineering Change Control; and TI-277, Modification Compliance Review - Fire
At/
I- n
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Protection. During review of these procedures, the team noted that the process for
evaluating the impact of design changes on FPP local manual operator actions only
addressed whether emergency lighting was affected (e.g.; changes to emergency light
positions or additional emergency lights required). The team noted that evaluating the
availability of emergency lighting alone was not sufficient to determine if the local
manual operator actions were feasible and could be satisfactorily performed within the
required time. The process did not consider other conditions such as location of the
manual actions with respect to the fire; complexity; accessibility,-environmental
considerations, etc., which could affect whether the manual action was feasible. This
process could result in the licensee inappropriately implementing changes to the FPP
which could adversely affect the ability to achieve and maintain safe shutdown in the
event of a fire, without receiving prior NRC approval.
An example of this process was noted during the team's review of design change notice
(DCN) 39742-A. The licensee implemented DCN 39742-A in December 1997, which
added a new local manual operator action for a fire in Room 757-A5 (Fire Area 27). The
licensee performed a safety assessment/safety. evaluation (WBPLEE-97-154-0) to
evaluate this DCN for impact on the fire protection program. The impact of the DCN
was evaluated against the design and licensing bases and was found to be acceptable
by the licensee. The 10 CFR 50.59 safety evaluation for, this DCN stated that the DCN
was being implemented to correct an Appendix R control circuit interaction which could
have caused the loss of both MCR air handling units (AHUs) A-A and B-B (0-MTR-31-
12-A and 0-MTR-31 -11-B, respectively) because the control circuits for both of.the
AHUs were routed in the same fire zone. A fire could cause the control power fuses to
blow for both AHUs, resulting in their loss.-The DCN added manual switches to the
control circuits for each AHU and identified new local manual operator actions for
restarting the AHUs. The switches could be used to transfer the essential control circuit
to a different set of fuses. The new manual operator action was incorporated into
SectionC.23 of AOI-30.2. This procedure section provided MCR and local manual
operator actions for a fire in Room 757-A5. During in-plant walkdowns of procedure
AOI-30.2, SectionC.23, the team observed that the new switch for AHU A-A and the
associated new local manual operator action were located in Room 757-A2 of the
auxiliary building, which was adjacent to Room 757-A5 (Fire Area 27).
The team used the guidance in Enclosure 2 of NRC Inspection Procedure 71111.05 to
assess the feasibility of the new local manual operator action. The team initially:
questioned whether this new manual action was feasible based on the potential impact
of the fire brigade activities in the immediate vicinity of Room 757-A2, and possible
smoke migration from Room 757-A5 into Room 757-A2. However,.after additional
walkdowns of AOI-30.2, SectionC.23, and discussions with licensee fire operations
personnel, the team concluded that the new manual operator action could be performed
within the time required by the Fire Protection Report (FPR). The team noted that the
location of the previous manual action for restarting AHU A-A was in Room;755-C1 of
the control building. The previous manual operator action was included in the licensee's
Fire Protection Report and was reviewed by the NRC during the licensing process for
Watts Bar Unit 1 in .1995. However, the new manual action added by DCN 39742-A was
subsequent to Watts Bar Unit.1 licensing. The licensee implemented this manual
operator action without obtaining prior NRC approval.
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Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safe shutdown condition following an Appendix R
fire. The finding is greater than minor because it is associated with the protection
against external factors attribute and degraded the reactor safety mitigating systems
cornerstone objective. The team determined that this finding was of very low safety:
significance (green), because the manual operator action was considered feasible and
could be reasonably accomplished within the :1 5-minute time specified in the Fire "-
Protection Report. This determination was based on the guidance in Enclosure 2, -
Inspection Criteria for Fire Protection Manual Actions, of NRC Inspection Procedure
Enforcement: Operating License Condition 2.F requires that the licensee shall
implement and maintain in effect all provisions of the approved fire protection program,
as described in the Fire Protection Report for Watts Bar Unit 1, as approved in
Supplements 18 and 19 of the SER (NUREG-0847). License Condition 2.F further
states that the licensee may changes to the approved fire protection program without
prior NRC approval, only if those changes would not adversely affect the ability to
achieve and maintain safe shutdown in the event of a fire.
Contrary to the above, the licensee implemented DCN 39742-A in December 1997,
- which added a new local manual operator action for restarting the MCR AHU A-A in the
event of a fire in Room 757-A5 (Fire Area 27). This new local manual operator action
was incorporated into Section C.23 of Procedure AOI-32. Use of local manual operator
actions in lieu of providing physical protection of equipment required for safe shutdown
is a change to the fire protection program that could adversely affect the ability to
- achieve and maintain safe shutdown in the event of a fire. Therefore, this new local
manual operator action required NRC approval prior to implementation. This finding is a
violation of NRC requirements will be identified as NCV 50-390/2004-006-001, Adding
Local Manual Operator Actions Which Could Affect Safe Shutdown Without Obtaining
Prior NRC Approval. This finding was entered into the licensee corrective action
program as PER 34252. - -:
SUPPLEMENTARY INFORMATION
-KEY POINTS OF CONTACTS -
Licensee
T. Davis, Fire Operations Support
J. Young, Operations Procedures Group -
- ., *... N- .*...
it
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LIST OF DOCUMENTS REVIEWED
Procedures
A01-30.1, Plant Fires, Rev. 6 ;
AO1-30.2, Fire Safe Shutdown, Rev. 15
S01-236.01, 125V DC Vital Battery Board 1, Rev. 16
FPDP-3, Management of the Fire Protection Report, Rev. 4
SPP-9.3, Plant Modifications and Engineering Change Control, Rev. 9
TI-277, Modification Compliance Review - Fire Protection, Rev. 0
Completed Surveillance Procedures
1-SI-.-53-A, 18-Month Verification of Remote Shutdown Transfer Switches for Train A, Rev. 14
1-SI-0-53-B, 18-Month Verification of Remote Shutdown Transfer Switches for Train B, Rev. 18
Lesson Plans/Job Performance Measures (JPM)
TO BE ADDED BY KATHLEEN
Problem Evaluation Report (PER)
WBN-00-01 6440-000, Revise Note in AO1-30.2, Section C.69, to be consistent with the FPR
Drawings
1-47W801 -1, Main and Reheat Steam Flow Diagram, Rev. 38
1-47W803-2, Auxiliary Feedwater Flow Diagram, Rev. 49
1-47W809-1, Chemical and Volume Control System Flow Diagram, Rev.'48
1-47W813-1, Reactor Coolant System Flow Diagram, Rev. 39 i ;
1-47W845-3, Essential Raw Cooling Water Flow Diagram, Rev. 20
1-47W859-1, Component Cooling System Flow Diagram, Rev. 44
1-47W859-2, Component Cooling System Flow Diagram, Rev. 34
Calculations
WB-DC-40-51, Fire Protection of Safe Shutdown Capability; Rev. 3
WBN-OSG4-031, Equipment Required for Safe Shutdown Per 1OCFR50 Appendix R, Rev. 32
Miscellaneous Documents
Technical Specification 3.3.4, Remote Shutdown System Instrumentation
DCN 38919-A, Appendix R Manual Action Requirements
DCN 39742-A, Add Manual Switches to Resolve Appendix R Control Circuit Interaction