ML043310166
| ML043310166 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 05/07/2004 |
| From: | Matt Thomas Division of Nuclear Materials Safety II |
| To: | |
| References | |
| FOIA/PA-2004-0277 IR-04-006 | |
| Download: ML043310166 (4) | |
See also: IR 05000390/2004006
Text
WATTS BAR TRIENNIAL FIRE PROTECTION INSPECTION REPORT INPUT, Rev. 1 517/04
Inspector:
M.Thomas
'
Report No.: .-50-390,391/2004-006
Inspection Dates: '3/29 - 4/212004 and 4/12-16/2004
.
-
.
1 :
-
I,
1.
REACTOR SAFETY
CORNERSTONES:
Initiating Events, Mitigating Systems, and Barrier Integrity
- ...
.
~7 .:
.1
.
,
.-
.
.
a4 Dn%^
I MUD
riiu ri1uiLiLiUr I I
I II I .Uo I I
.05
O6erational Irnplementation of Post-Fire Safe Shutdown Capability'
a. " Insdection Sone
-
The team reviewed the operational implementation of the SSD capabilityfor an
Appendix R fire in' Fire Areas 14,-27,- 33, or 48 to verify thiat-'(1) the training program for
licensed personnel included main control room (MCR) and alternative safe shutdown
capability; (2) personnel required to achieve and maintain the plant in hot sta'ndby, from
the MCR or auxiliary control room (ACR), following a fire could be provided from normal
onsite staff, exclusive of th'e'fire~brigade; (3) the licensee had incorporated the'
'operability of alternative shutdown transfer and contrbl functions into plant Technical
Specifications (TS); and (4) the liceinsee periodically performed op6rability testing of the
alternative shutdown instrumentation, and transfer and control functions. The team
reviewed abnormal operati!g initruction'(AO) AOI-30.1,' Plant Fires; and ~selected
sections of AO1-30.2, Fire Safe Shutdown. The reviews focused on ensuring that all
required 'functions for post-fir6 safe 6hutdown,' and the6'correspondin'g"equipment
necessary to perform those functions, were included in the pro'edures for the selected
fire areas.
b.
Findings
Introduction: The team identified a non-cited violation (NCV) of Operatinig Licerise
'Condition 2.F. for inadequate implementation of the approved fire protection program
(FPP). The licensee implemented a 'design change notice (DCN) which revised a local
manual operator action (that had been previously approved by the NRC duririg Watts
Bar Unit 1 licensing in 1 995) for a fire in' Room 757-A5 (Fire Area 27). The licensee's
process for evaluating the impact of design changes on the FPP (e.g.', local manual
operator actions) was' not adequate to ehsure that the changes would not adversely
affect the ability to achiev4.and maintain safe shutd6wn'in the event of a fire.
Description: The licensee's process for evaluating the impact of design changes on the
FPP was addressed in several procedures. This included procedures FPDP-3,
Management of the Fire ProtectionReport; SPP-9.3,Plant Modification's and
Engineering Change Control;' and TI-277, Modification Compliance Review -' Fire
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
(</
I'it
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 could be performed within the required time in a satisfactory
manner. The procedures 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 the operators' capability to perform the action.
This process could result in the licensee inappropriately implementing changes to the
FPP which may, not lead to a safe plant condition and 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
revised a local manual operator action (that had been previously approved by the NRC
during Watts Bar Unit 1 licensing in 1995) for a fire in Room 757-A5 (Fire Area 27). The
DCN added manual switches to the control circuits for MCR air handling units (AHU) A-
A and B-B and identified new local manual operator actions for restarting the AHUs.
The new manual actions replaced previous manual operator actions included in the
licensee's Fire Protection Report.
During implementation of DCN 39742-A, the licensee performed safety
assessment/safety evaluation WBPLEE-97-1 54-0 to evaluate the impact of this DCN on
the FPP. The DON was evaluated against the design and licensing bases and was
found to be acceptable by the licensee. The team noted that the evaluation did not
address the impact of the DCN on FPP emergency, lighting, as required by Procedure
SPP-9.3. .The team further'noted that other conditions which could affect capability of
the operators to perform this new manual action were not addressed, such as,
accessibility, environmental considerations, etc. The new; rmanhual operator action for
AHU A-A was incorporated into Section C.23 of AO1-30.2. This procedure section
provided MCR and local manual operator actions for a fire in Room 757-A5.
During in-plant walkdowns of procedure AO1-30.2, Section C.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 teamn initially questioned'whether this new manual action was within
the capability of the operator performance, based on the potential impact of the fire
brigade activities in the immediate vicinity of Room 757-A2, and possible smoke
migration from Roorm 757-A5 into Room 757-A2. After additional walkdowns of AOI-
30.2, Section C.23, and discussionr of possible scenarios for the fire brigade activities
with licensee fire operations personnel, the team conciuded that the new manual
operator action could reasonably be accomplished within the time required by the Fire
Protection Report (FPR).,
Analysis: The finding adversely impacted the reliability and capability of equipment
required to achieve and maintain a safevshutdown condition following an Appendix R
fire. The finding is greater than minor because it is' associate'd'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 within the
3
capability of the operator and could beyreasonably accomplished within the 15-minute
time specified in the Fire Protection Report. This determination was based on field
walkdowns of the Procedure AO1-30.2, Section C.23, and review of pre-fire plans and
fire brigade activities for a fire in Room 757-A5.
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 make 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. The licensee's process for
evaluating the impact of design changes on the FPP was addressed in 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
Protection.
Contrary to the above, the licensee's process for evaluating the impact of design
changes on the FPP (e.g., 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 procedures for evaluating the impact of design
changes on FPP local manual operator actions only require that the evaluation address
whether emergency lighting was affected; The procedures 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
actions could reasonably be accomplished. This process could result in the licensee
inappropriately implementing design changes which may not lead to safe plant,
conditions and could adversely affect the ability to achieve and maintain safe shutdown
in the event of a fire, without receiving prior NRC approval: This finding is a violation of
NRC requirements and will be identified as NCV 50-390/2004-006-001 Evaluation
Process for Design Changes Which Could Affect Safe Shutdown in the Event of a Fire
Without Obtaining Prior NRC Approval.- This finding was entered into the licensee's
corrective action program as PERs 34252 and 34259.
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee
T. Davis, Fire Operations Support -
J. Young, Operations Specialist
.
Other licensee employees contacted included operations, security, and radiation protection
personnel.
II
4
LIST OF DOCUMENTS REVIEWED
Procedures
AO1-30.1, Plant Fires, Rev. 6
AO1-30.2, Fire'Safe Shutdown, Rev.15
SO1-236.01' 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 -31-0-53-A, 18-Month Verification f Remote Shutdown Transfer Switches for Train A, Rev. 14
1 -S1-0-53-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 Revort (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
1 -47W845-3, Essential Raw Cooling Water Flow Diagram, Rev. 20
1-47W859-1, Cornporient 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 10CFR50 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