ML050380432
| ML050380432 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/03/2005 |
| From: | Ogle C NRC/RGN-II/DRP/RPB1 |
| To: | Scarola J Carolina Power & Light Co |
| References | |
| EA-00-022, EA-01-310, FOIA/PA-2004-0277 IR-03-007 | |
| Download: ML050380432 (13) | |
See also: IR 05000400/2003007
Text
EA-01-310
Carolina Power & Light Company
ATTN: Mr. James Scarola
Vice President - Harris Plant
Shearon Harris Nuclear Power Plant
P. 0. Box 165, Mail Code: Zone 1
New Hill, North Carolina 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT - NRC FIRE PROTECTION
INSPECTION REPORT NO. 05000400/2003007
Dear Mr. Scarola:
On October _,
2003, the U.S. Nuclear Regulatory Commission (NRC) completed an in-office
review of the significance of the triennial fire protection inspection findings of inspection report
05000400/2002011 related to your Shearon Harris Nuclear Power Plant. The enclosed report
documents the results of our significance determination, which was discussed on October
2003, by telephone with Mr. _
_
and other members of your staff.
This report documents two NRC-identified findings of very low significance (Green). Both of
these findings were determined to involve violations of NRC requirements. However, because
of the very low safety significance and because they are entered into your corrective action
program, the NRC is treating these two findings as non-cited violations (NCVs) consistent with
Section VI.A. of the NRC enforcement Policy. If you contest any NCV in this report, you should
provide a response within 30 days of the date of this inspection report, with the basis for your
denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of
Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001;
and the NRC Resident Inspector at the Shearon Harris Nuclear Power Plant.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at
httn://www.nrc.cov/readina-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No.: 50-400
go
I4
2
License No.: NPF-63
Enclosure: Inspection Report 05000400/200307
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DOCUMENT NAME: P.Viarris IR 03-07Rl.wpd
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.:
License No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
50-400
Carolina Power & Light (CP&L)
Shearon Harris Nuclear Power Plant
5413 Shearon Harris Road
New Hill, NC 27562
February 1, 2003 - October
_, 2003
W. Rogers, Senior Reactor Analyst, Region II
R. Schin, Senior Reactor Inspector, Region II
Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000400/2003-007; 02/01/2003 - 10/U2003; Shearon Harris Nuclear Power Plant;
Significance Determination of Fire Protection Findings.
The in-office review was conducted by a regional inspector, a regional senior reactor analyst,
and NRC Headquarters senior reactor Analysts. Two Green findings, each a non-cited violation
(NCV), were identified. The significance of issues is indicated by their color (Green, White,
Yellow, Red) using IMC 0609 "Significance Determination Process" (SDP). Findings for which
the SDP does not apply may be uGreen" or be assigned a severity level after NRC management
review. The NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1 649, "Reactor Oversight Process," Revision 3, dated July
2000.
A.
Inspector Identified Findings
Cornerstones: Mitigating Systems and Initiating Events
Green. An NCV of Operating License Condition 2.F, the Fire Protection Program, and
Technical Specification (TS) 6.8.1, Procedures and Programs, was identified for
inadequate implementation of the fire protection program. Physical and procedural
protection for equipment that was relied on for safe shutdown (SSD) during a fire in fire
safe shutdown analysis (SSA) areas 1 -A-BAL-B-B1, 1 -A-BAL-B-B2, 1 -A-BAL-B-B3, 1-A-
BAL-B-B4, 1-A-EPA, and 1-A-BAL-C of the reactor auxiliary building was inadequate.
Consequently, a fire in one of these SSA areas could result in a reactor coolant pump
seal loss of coolant accident (LOCA) event, a main steam line break (MSLB) event, a
loss of high pressure safety injection, and/or a loss of component cooling water to the
reactor coolant pump seals. The licensee has initiated corrective actions including
assigning an additional operator to be available to perform post-fire safe shutdown
actions and performing a complete review of the safe shutdown analysis and related
operating procedures.
This finding was greater than minor because it involved a lack of required fire barriers
for equipment that was relied upon for safe hot shutdown following a fire. The finding
also had more than minor safety significance because it affected the objectives of the
Mitigating Systems and Initiating Events Cornerstones of Reactor Safety. The finding
affected the availability and reliability of systems that mitigate initiating events to prevent
undesirable consequences. It also affected the likelihood of occurrence of initiating
events that challenge critical safety functions. The finding was of very low significance
(Green) because of the low fire ignition frequencies, lack of combustible materials in
critical locations, and the effectiveness of the fire protection features and the unaffected
SSD equipment to mitigate a fire in each of the affected fire zones/areas. (Section
1 R05.03.b.1)
Green. An NCV of Operating License Condition 2.F, the Fire Protection Program, and
Technical Specification (TS) 6.8.1, Procedures and Programs, was identified for
inadequate corrective action for previous Violation 50-400/02-08-01. Physical and
procedural protection for equipment that was relied on for safe shutdown (SSD) during a
Enclosure
fire in the new auxiliary control panel fire area 1-A-ACP was inadequate. Consequently,
a fire in area 1 -A-ACP could result in a loss of auxiliary feedwater and a main steam line
break (MSLB) event. The licensee has initiated corrective actions including assigning
an additional operator to be available to perform post-fire safe shutdown actions and
performing a complete review of the safe shutdown analysis and related operating
procedures.
This finding was greater than minor because it involved inadequate fire barriers for
equipment that was relied upon for safe hot shutdown following a fire. The finding also
had more than minor safety significance because it affected the objectives of the
Mitigating Systems Cornerstone of Reactor Safety. The finding affected the availability
and reliability of systems that mitigate initiating events to prevent undesirable
consequences. The finding was of very low significance (Green) because of the very
low ignition sources in the fire area, manual suppression capability, and the power
conversion system not being affected by a fire in this fire area. (Section 1 R05.03.b.2)
B.
Licensee-identified Violations
None
Enclosure
REPORT DETAILS
1.
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1 R05 FIRE PROTECTION
.01
Significance Determination for Triennial Fire Protection Inspection FindinQs
a.
Inspection Scone
In inspection report (IR) 50-400/02-11, nine findings had been identified as unresolved
items (URls) pending completion of the NRC significance determination process (SDP).
The nine URIs were:
URI 50-400/02-11-01, Failure to Protect Charging System MOV 1 CS-1 65, VCT
Outlet to CSIPs, From Maloperation Due To a Fire
URI 50-400/02-11-02, Failure to Protect Charging System MOVs 1CS-169, ICS-
214, 1 CS-218, and 1 CS-219 From Maloperation Due To a Fire
URI 50-400/02-11-03, Failure to Protect Charging System MOVs 1 CS-1 66, 1 CS-
168, and 1 CS-217 From Maloperation Due To a Fire
URI 50-400/02-11-04, Failure to Protect Component Cooling MOVs 1 CC-251
and 1 CC-208, CC for RCP Seals, From Maloperation Due To a Fire
URI 50-400/02-11-05, Reliance on Manual Actions in Place of Required Physical
Separation or Protection From a Fire
URI 50-400/02-11-06, Fire SSD Operator Actions With Excessive Challenges
URI 50-400/02-11-07, Too Many Fire SSD Actions for Operators to Perform
URI 50-400/02-11-08, Using the Boric Acid Tank Without Level Indication
URI 50-400/02-11-09, Failure to Provide Required Emergency Lighting for SSD
Operator Actions
This inspection report documents the results of the in-office completion of the NRC SDP
with respect to those nine URIs. The significance determination was accomplished as
described in NRC Inspection Manual Chapter (IMC) 0609, Signification Determination
Process; IMC 0609A, Significance Determination of Reactor Inspection Findings for At-
Power Situations; and IMC 0609F, Determining Potential Risk Significance of Fire
Protection and Post-Fire Safe Shutdown Inspection Findings. This involved evaluating
the significance of a potential fire in each of the seven affected fire safe shutdown
Enclosure
2
analysis (SSA) areas using the Phase 11 SDP, considering all examples of the findings
that could be involved in each fire. To better assess the overall significance of all of the
performance deficiencies, they were recharacterized as two overall findings: 1)
Inadequate Implementation of the Fire Protection Program for Safe Shutdown; and 2)
Inadequate Corrective Action for a Previous White Fire Protection Finding.
In addition, the performance deficiencies which could result in the loss of a safety
function were evaluated by Office of Nuclear Reactor Regulation (NRR) analysts using
the Phase Ill portion of the SDP. Inclusive in this evaluation were extensive walkdowns
of the applicable fire SSA areas by two fire protection contractors to observe ignition
sources and possible fire propagation from these ignition sources that could affect the
unprotected cables of concern. Also, electrical circuit drawings and the latest
information on cable hot short failure mechanisms and probabilities were used to
develop cable failure probabilities that could cause a loss of function for the unprotected
cables of concern.
b.
Findings
(1)
Inadequate Implementation of the Fire Protection Program for Safe Shutdown
Introduction: An overall finding was identified in that the implementation of the fire
protection program was inadequate. Eight of the nine URIs described in IR 50-400/02-
11 were considered to include performance deficiencies related to this overall finding.
Based on evaluating those performance deficiencies for their effects during fires that
could occur in each of six affected fire SSA areas, this overall finding was determined to
have a very low significance (Green).
Description: The licensee's implementation of the fire protection program for ensuring
the ability to safely shut down the plant during a fire was inadequate, in that:
The fire SSA failed to identify some cables that were relied upon for safe
shutdown (SSD) during a fire. Consequently, those cables were not provided
with the required protection from fire damage. A fire could cause hot shorts in
the cables which would result in maloperation of equipment that was relied upon
for SSD during that fire.
The SSA identified many cables that were relied upon for SSD during a fire, but
the licensee generally failed to provide the required physical protection from fire
damage. Instead, the SSA designated that operator actions would be taken to
prevent or mitigate the effects of the fire damage. However, the licensee did not
obtain NRC approval for these deviations from the approved fire protection
program.
Some of the operator actions that were designated by the SSA were not
incorporated into operating procedures for SSD. Also, the operator actions in
procedures differed in many respects from the operator actions that were
Enclosure
3
analyzed in the SSA. For example, the operating procedures directed operators
to use some different flowpaths than those analyzed in the SSA.
Some operator actions in the SSD procedures would not work. They were too
challenging, involved entering the area of the fire, were not adequately analyzed,
or were too numerous for the available SSD non-licensed operator to perform.
Examples of this overall finding were included in the following eight URls: URI 50-
400/02-11-01, -02, -03, -04, -05, -07, -08, and -09. The inspectors and analysts
evaluated the effects of the multiple examples of this overall finding during a fire that
could occur in each of the six affected fire SSA areas of the reactor auxiliary building
(RAB) using Phase II and Phase IlIl of the SDP. Based on that analysis, the inspectors
and analysts concluded that the overall finding did not have more than very low safety
significance (Green) because of the low fire ignition frequencies that could impact the
cables of interest, the lack of combustible materials in critical locations, and the
effectiveness of the fire protection features and the unaffected SSD equipment to
mitigate a fire in each of the affected fire zones/areas.
Analysis: This finding had more than minor safety significance because it involved a
lack of required fire barriers for equipment that was relied upon for safe hot shutdown
following a fire. The finding also had more than minor safety significance because it
affected the objectives of the Mitigating Systems and Initiating Events Cornerstones of
Reactor Safety. The finding affected the availability and reliability of systems that
mitigate initiating events to prevent undesirable consequences. It also affected the
likelihood of occurrence of initiating events that challenge critical safety functions. The
finding did not have more than very low safety significance (Green) because of the low
fire ignition frequencies, lack of combustible materials in critical locations, and the
effectiveness of the fire protection features and the unaffected SSD equipment to
mitigate a fire in each of the affected fire zones/areas.
Enforcement: As described in IR 50-400/02-11, Operating License Condition (OLC) 2.F
required that the licensee implement and maintain in effect all provisions of the
approved Fire Protection Program (FPP) as described in the Final Safety Analysis
Report (FSAR). The Updated FSAR (UFSAR), Section 9.5.1, FPP, stated that outside
containment, where cables or equipment (including associated non-essential circuits
that could prevent operation or cause maloperation due to hot shorts, open circuits, or
shorts to ground) of redundant safe shutdown divisions of systems necessary to achieve
and maintain cold shutdown conditions are located within the same fire area outside of
primary containment, one of the redundant divisions must be ensured to be free of fire
damage. Section 9.5.1 further stated that if both divisions are located in the same fire
area, then one division is to be physically protected from fire damage by one of three
methods: 1) a three-hour fire barrier, 2) a one-hour fire barrier plus automatic detection
and suppression, or 3) a 20-foot separation with no intervening combustibles and with
automatic detection and suppression. The licensee had received no NRC approvals for
deviating from these requirements.
Enclosure
4
Also, OLC 2. F. and UFSAR Section 9.5.1 stated that Branch Technical Position (BTP)
9.5-1 was used in the design of the fire protection program for safety-related systems
and equipment and for other plant areas containing fire hazards that could adversely
affect safety-related systems. BTP 9.5-1, Section C.5.g, "Lighting and Communication,"
paragraph (1), required that fixed self-contained lighting consisting of fluorescent or
sealed-beam units with individual eight-hour-minimum battery power supplies should be
provided in areas that must be manned for safe shutdown and for access and egress
routes to and from all fire areas.
In addition, TS 6.8.1, Procedures and Programs, required procedures as recommended
by Regulatory Guide (RG) 1.33 and procedures for fire protection program
implementation. RG 1.33 recommended procedures for combating emergencies,
including fires. The licensee's interpretation of their fire protection program was that
they could and would rely on proceduralized operator actions in place of physically
protecting SSD equipment from fire damage (see Section 1 R05.04.b.1).
Contrary to the above requirements, the licensee failed to adequately implement and
maintain in effect all of the provisions of the approved FPP. The licensee failed to
ensure that one of the redundant safe shutdown divisions of systems necessary to
achieve and maintain cold shutdown conditions was protected from fire damage; failed
to have adequate procedures for combating fire emergencies; and failed to provide the
required emergency lighting in areas that must be manned for safe shutdown; as
described above in the eight examples of this overall finding. Because the identified
examples of this failure to adequately implement and maintain in effect all of the
provisions of the approved FPP are of very low safety significance and have been
entered into your corrective action program [Action Reports (ARs) 76260, 80212, 80089,
69721, 80215, 75065, and 79047], this violation is being treated as a non-cited violation
(NCV), consistent with Section VL.A of the NRC Enforcement Policy: NCV 50-400/03-
07-01; Inadequate Implementation of the Fire Protection Program for Safe Shutdown.
(2)
Inadequate Corrective Action for a Previous White Fire Protection Finding
Introduction: An overall finding was identified in that the corrective action for previous
White finding and related Violation (VIO) 50-400/02-08-01 was inadequate. Four of the
nine URIs described in IR 50-400/02-11 included examples of this overall finding.
Based on evaluating the multiple examples of this overall finding for their effects during
a fire that could occur in the one affected fire area, this overall finding was determined to
have a very low significance (Green).
Description: The licensee's corrective action for a previous White fire protection finding
(VIO 50-400/02-08-01), associated with a Thermo-Lag fire barrier assembly between the
'B' train switchgear room / auxiliary control panel and the 'A' train cable spreading room,
was inadequate.
Examples of this overall finding were included in the following four URls: URI 50-
400/02-11-05, -06, -07, and -09. The inspectors and analysts evaluated the effects of
Enclosure
5
the multiple examples of this overall finding during a fire that could occur in the 1-A-ACP
fire area of the RAB, using Phase II of the SDP. Based on that evaluation, the
inspectors and analysts concluded that the overall finding did not have more than very
low safety significance (Green) because of the very low ignition sources in the fire area,
manual suppression capability, and the power conversion system not being affected by
a fire in this fire area. The Green significance determination was also confirmed by a
walkdown of the fire area by two contractors.
Analysis: This finding had more than minor safety significance because it involved
inadequate fire barriers for equipment that was relied upon for safe hot shutdown
following a fire. The finding also had more than minor safety significance because it
affected the objectives of the Mitigating Systems Cornerstone of Reactor Safety. The
finding affected the availability and reliability of systems that mitigate initiating events to
prevent undesirable consequences. The finding did not have more than very low safety
significance (Green) because of the very low ignition sources in the fire area, manual
suppression capability, and the power conversion system not being affected by a fire in
this fire area.
Enforcement: OLC 2.F and the UFSAR, Section 9.5.1, FPP, included quality assurance
(QA) requirements for fire protection. The FPP stated that a QA program was being
used to identify and rectify any possible deficiencies in design, construction, and
operation of the fire protection systems. Also, as described in Section 1 R05.01 .b.1
above, OLC 2.F required that one of the redundant divisions would be free of fire
damage. Further, if both divisions were located in the same area, then one of the
divisions was to be physically protected from fire damage by one of three specified
methods. Further, OLC.2.F required that battery-backed emergency lights be provided
in locations where operators were required to perform actions for SSD from a fire. In
addition, TS 6.8.1, Procedures and Programs, required procedures for implementing the
fire protection program and for combating fires.
Contrary to the above requirements, the licensee's corrective actions for previous VIO
50-400/02-08-01 were inadequate because they failed to rectify deficiencies in design,
construction, and operation related to SSD from a fire in the area of the ACP room. The
licensee failed to protect various equipment either physically or procedurally from the
effects of a fire where that equipment was relied on for SSD. The licensee entered the
finding into the corrective action program as AR 80215. Because the identified
examples of this inadequate corrective action are of very low safety significance and
have been entered into the corrective action program, this violation is being treated as
an NCV, consistent with Section VL.A of the NRC Enforcement Policy: NCV 50-400/03-
07-02; Inadequate Corrective Action for a Previous White Fire Protection Finding.
The previous open items related to these two overall findings are closed; including VIO
50-400/02-08-01 and URIs 50-400/02-11-01, -02, -03, -04, -05, -06, -07, -08, and -09.
Enclosure
6
40A6 Meetings. including Exit
The team presented the inspection results to Mr. _
_
and members of his staff
at the conclusion of the inspection on
, 2003. The licensee acknowledged the
findings presented. Proprietary information is not included in this inspection report.
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
D. Baksa, Supervisor, Equipment Performance
J. Caves, Licensing Supervisor
R. Duncan, Director of Site Operations
M. Fletcher, Manager, Fire Protection Program
A. Khanpour, Manager, Engineering
NRC personnel
J. Brady, Senior Resident Inspector, Shearon Harris
C. Ogle, Chief, Engineering Branch 1 (EB1), Division of Reactor Safety (DRS), Region II (R1l)
C. Payne, Fire Protection Team Leader, EB1, DRS, RI!
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
50-400/03-07-01
50-400/03-07-02
NCV
Inadequate Implementation of the Fire Protection Program
for Safe Shutdown (Section 1 R05.01.b.1)
Inadequate Corrective Action for a Previous White Fire
Protection Finding (Section 1 R05.01.b.2)
Closed
50-400/02-08-01
V10
Failure to Implement and Maintain NRC Approved Fire
Protection Program Safe Shutdown System Separation
Requirements (Section 1 R05.01.b.2)
50-400/02-11-01
50-400/02-11-02
50-400/02-11-03
URI
Failure to Protect Charging System MOV 1 CS-1 65, VCT
Outlet to CSIPs, From Maloperation Due To a Fire
(Section 1 R05.01.b.1)
Failure to Protect Charging System MOVs 1 CS-1 69, 1 CS-
214, 1CS-218, and 1CS-219 From Maloperation Due To a
Fire (Section 1 R05.01.b.1)
Failure to Protect Charging System MOVs 1 CS-1 66, 1 CS-
168, and 1CS-217 From Maloperation Due To a Fire
(Section 1 R05.01.b.1)
Attachment
50-400/02-11-04
50-400/02-11-05
50-400/02-11-06
50-400/02-11-07
50-400/02-11-08
50-400/02-11-09
URI
URI
URI
2
Failure to Protect Component Cooling MOVs 1 CC-251 and
1 CC-208, CC for RCP Seals, From Maloperation Due To a
Fire (Section 1 R05.01.b.1)
Reliance on Manual Actions in Place of Required Physical
Separation or Protection From a Fire (Section
1 R05.01.b.2)
Fire SSD Operator Actions With Excessive Challenges
(Section 1 R05.01.b.2)
Too Many Fire SSD Actions for Operators to Perform
(Section 1R05.01.b.2)
Using the Boric Acid Tank Without Level Indication
(Section 1 R05.01.b.1)
Failure to Provide Required Emergency Lighting for SSD
Operator Actions (Section 1 R05.01.b.2)
Attachment