ML050380440
| ML050380440 | |
| 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: ML050380440 (13) | |
See also: IR 05000400/2003007
Text
i
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 uRules 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
http://www.nrc.aov/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
2
License No.: NPF-63
Enclosure: Inspection Report 05000400/200307
w/Attachment: Supplemental Information
cc w/encl: (use normal distribution list plus EICS and OE)
Distribution w/encl:
L. Slack, EICS
B. Mozafari, NRR
OEMAIL
RIDSNRRDIPMLIPB
PUBLIC
OFFICE
RII:DRS
RII:DRS
RiI:DRS
RII:DRP
RII:EICS
SIGNATURE
NAME
ISchin
WRogers
DCPayne
PFrednckson
CEvans
DATE
E-MAIL COPY?
Y
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
I PUBLIC DOCUMENT
YES
NO
_I_
I_
_I_
I_..-_
_I____..__ _____
I
OFFICIAL RECORD COPY
DOCUMENT NAME: P:\\HiarIs IR 03-07R3.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 risk 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 "Green" 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. The inspectors identified a non-cited violation 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. The inspectors identified a non-cited violation 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 fire in the new auxiliary control panel fire area 1-A-ACP
Enclosure
2
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
1R05 FIRE PROTECTION
.01
Significance Determination for Triennial Fire Protection Inspection Findings
a.
Inspection Scope
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 as follows:
URI 50-400102-11 -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 1 CS-1 69, 1 CS-
214, 1 CS-21 8, and 1 CS-21 9 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, Significanhe Deterrnination 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 2 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 3 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 URls 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 several 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, for
which 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.
Detailed examples related to this overall finding were included in the following eight
URls: 50-400/02-11-01, -02, -03, -04, -05, -07, -08, and -09.
Analysis: 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 2 and Phase 3 of the SDP.
Based on that analysis, the inspectors and analysts concluded that 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 availability and reliability
objectives and the equipment performance attribute of the Mitigating Systems
Cornerstone of Reactor Safety. In addition, it affected the Initiating Events Cornerstone
of Reactor Safety in that it affected the objective of limiting the likelihood of occurrence
of initiating events that challenge critical safety functions and also affected the design
control attribute. 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.
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.
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
Enclosure
4
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 the 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: In IR 50-400/02-08, the NRC had left VIO 50-400/02-08-01 open for
further NRC review of the new manual operator actions that had been added as part of
the licensee's corrective action for the violation. In IR 50-400/02-11, the NRC had
documented the review of those new manual operator actions and had identified that the
licensee's corrective actions had contributed to four new findings. For this significance
determination, those findings were grouped into one overall finding of inadequate
corrective action for a previous White fire protection 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 actions 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,-
were inadequate. The corrective actions were inadequate because they failed to rectify
deficiencies in design, construction, and operation related to SSD from a fire in the area
Enclosure
5
of the ACP room. The licensee's corrective actions contributed to four new findings that
are now grouped into the overall finding of inadequate corrective action:
The corrective actions created a new fire area and many new manual operator
actions for a fire in the new fire area instead of providing the required physical
protection of cables. This finding was described in URI 50-400/02-11-05,
Reliance on Manual Actions in Place of Required Physical Separation or
Protection From a Fire.
The corrective actions also created a manual operator action with excessive
challenges such that there was not reasonable assurance that all non-licensed
operators (NLOs) would be able to perform the action during a fire event. This
finding was described in URI 50-400/02-11-06, Fire SSD Operator Actions With
Excessive Challenges.
In addition, the corrective actions created too many local manual operator
actions for the new fire area for the one SSD NLO to perform. This finding was
described in URI 50-400/02-11-07, Too Many Fire SSD Actions for Operators to
Perform
Further, the corrective actions failed to provide the required emergency lighting
for the new manual actions. This finding was described in URI 50-400/02-11-09,
Failure to Provide Required Emergency Lighting for SSD Operator Actions
Analysis: The inspectors and analysts evaluated the effects of the multiple examples of
the overall finding of inadequate corrective action during a fire that could occur in the 1-
A-ACP fire area of the RAB, using Phase 2 of the SDP. Based on that evaluation, the
inspectors and analysts concluded that the overall 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 availability and reliability objectives and the
equipment performance attribute 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. The Green significance determination was also
confirmed by a walkdown of the fire area by two contractors.
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-i 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
Enclosure
6
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 VLA 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 URls 50-400/02-11-01, -02, -03, -04, -05, -06, -07, -08, and -09.
40A6 Meetinos. 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, Ril
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
VIa
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-165, VCT
Outlet to CSIPs, From Maloperation Due To a Fire
(Section 1R05.01.b.1)
Failure to Protect Charging System MOVs 1 CS-1 69,1 CS-
214,1 CS-218, and 1 CS-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 I CS-217 From Maloperation Due To a Fire
(Section 1R05.01.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 1 R05.01.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