ML050380443
| ML050380443 | |
| 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: ML050380443 (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 21, 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 21,
2003, by telephone with Mr. R. Duncan 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
htto://www.nrc.gov/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
CP&L 2
License No.: NPF-63
Enclosure: Inspection Report 05000400/200307
w/Attachments: 1. Supplemental Information
2. Phase 3 SDP Analysis
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 RSchin WRogers KO'Donohue PFredrickson CEvans
DATE
IE-MAIL COPY? YEE YES.0 YES NO YES.. YES NO.__
PUBLIC DOCUMENT YES NO _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _
OFF~ICIAL RECORDJKL COLPY DOCUMEN T NAME: PaMarris IK 03-07R4.WPCI
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50-400
License No.: NPF-63
Report No.: 05000400/2003007
Licensee: Carolina Power & Light (CP&L)
Facility: Shearon Harris Nuclear Power Plant
Location: 5413 Shearon Harris Road
New Hill, NC 27562
Dates: February 1, 2003 - October 21, 2003
Inspectors: W. Rogers, Senior Reactor Analyst, Region II
R. Schin, Senior Reactor Inspector, Region II
Approved by: Charles R. Ogle, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000400/2003-007; 02/01/2003 - 10/21/2003; 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-1649, "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 6.8.1, Procedures and
Programs, 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-B4, 1-A-BAL-B-B5, 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 event, a main steam line break event, a loss
of high pressure safety injection, and/or a loss of component cooling water to the reactor
coolant pump seals. Licensee corrective action included assigning an additional
operator to be available to perform post-fire SSD actions and performing a complete
review of the SSA 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. The finding affected the
availability and reliability of systems that mitigate initiating events to prevent undesirable
consequences and 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
1R05.1.b.(1)]
- Green. The inspectors identified a non-cited violation of Operating License Condition
2.F, the Fire Protection Program, and Technical Specification 6.8.1, Procedures and
Programs, for inadequate corrective action for previous Violation 50-400/02-08-01.
Corrective action for that violation had included creating a new auxiliary control panel
fire area (1-A-ACP) in 2002. However, that corrective action was not adequate because
physical and procedural protection for equipment that was relied on for safe shutdown
Enclosure
2
(SSD) during a fire in the new fire area was inadequate. Consequently, a fire in area 1-
A-ACP could result in a loss of auxiliary feedwater and a main steam line break event.
Licensee corrective actions in response to this finding included assigning an additional
operator to be available to perform post-fire SSD 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 and 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 1R05.1 .b.(2)]
B. Licensee-identified Violations
None
Enclosure
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 FIRE PROTECTION
.1 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:
Outlet to CSIPs, From Maloperation Due To a Fire
214, 1CS-218, and 1CS-219 From Maloperation Due To a Fire
168, and 1CS-217 From Maloperation Due To a Fire
and 1CC-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 the nine URls. 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 seven affected fire safe shutdown analysis
Enclosure
2
(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 (FPP) 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 (of the seven total) affected fire SSA areas, this
overall finding was determined to have a very low significance (Green).
Description: The licensee's implementation of the FPP 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. In addition, it affected the Initiating Events Cornerstone 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
requires that the licensee implement and maintain in effect all provisions of the FPP as
described in the Final Safety Analysis Report (FSAR). The Updated FSAR (UFSAR),
Section 9.5.1, FPP, states 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
states 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 not received NRC approval for deviating from these
requirements.
Also, OLC 2. F. and UFSAR Section 9.5.1 state that Branch Technical Position (BTP)
9.5-1 was used in the design of the FPP 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),
Enclosure
4
requires 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, requires procedures as recommended
by Regulatory Guide (RG) 1.33 and procedures for fire protection program
implementation. RG 1.33 recommends procedures for combating emergencies,
including fires. The licensee's interpretation of the FPP was that they could and would
rely on proceduralized operator actions in place of physically protecting SSD equipment
from fire damage.
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 Requests (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 for the new
1-A-ACP fire area, 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 new 1-A-ACP 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 new
Enclosure
5
1-A-ACP fire area. 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 (1-A-ACP) 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. 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, includes quality assurance
(QA) requirements for fire protection. The FPP states that a QA program is being used
to identify and rectify any possible deficiencies in design, construction, and operation of
the fire protection systems. OLC 2.F requires that one of the redundant divisions be
free of fire damage. Further, if both divisions were located in the same area, OLC 2.F
requires that one of the divisions be physically protected from fire damage by one of
three specified methods. Also, OLC.2.F requires that battery-backed emergency lights
be provided in locations where operators are required to perform actions for SSD from a
Enclosure
6
fire. In addition, TS 6.8.1, Procedures and Programs, requires procedures for
implementing the FPP 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 the actions 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. Because the
identified examples of this inadequate corrective action are of very low safety
significance and have been entered into the corrective action program (AR 80215), 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.
.2 (Closed) VIO 50-400/02-08-01, Failure to Implement and Maintain NRC Approved Fire
Protection Program Safe Shutdown System Separation Requirements
This VIO was closed with a new corrective action NCV opened as discussed in Section
1R05.1.b.(2).
.3 (Closed) URIs 50-400/02-11-01. -02. -03. -04. -05. -06. -07. -08. and -09
These URIs were resolved to two new NVCs as discussed in Sections 1R05.1.b.(1) and
(2). Consequently, these URIs are closed.
4. OTHER ACTIVITIES
40A3 Event FollowuR
(Closed) LER 50-400/02-04-00, Unanalyzed Condition Due to Inadequate Separation of
Associated Circuits
This LER describes conditions that were previously identified by the NRC in IR 50-
500/02-11 and that were evaluated and resolved to a new NCV in Section 1R05.1.b.(1)
above. This LER was reviewed by the inspectors and no additional findings were
identified. This LER is closed.
40A6 Meetings, including Exit
The team presented the inspection results to Mr. R. Duncan and other members of his
staff at the conclusion of the inspection on October 21, 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
J. Caves, Licensing Supervisor
F. Diya, Acting Manager, Engineering
R. Duncan, Director of Site Operations
M. Fletcher, Manager, Fire Protection Program
T. Morton, Manager, Support Services
NRC personnel
G. MacDonald, Senior Project Engineer
R. Musser, Senior Resident Inspector, Shearon Harris
P. O'Bryan, Resident Inspector, Shearon Harris
C. Ogle, Chief, Engineering Branch 1 (EBI1), Division of Reactor Safety (DRS), Region II (Rll)
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
50-400/03-07-01 NCV Inadequate Implementation of the Fire Protection Program
for Safe Shutdown [Section 1R05.1 .b.(1)]
50-400/03-07-02 NCV Inadequate Corrective Action for a Previous White Fire
Protection Finding [Section 1R05.1 .b.(2)]
Closed
50-400/02-08-01 VIO Failure to Implement and Maintain NRC Approved Fire
Protection Program Safe Shutdown System Separation
Requirements (Section 1R05.2)
50-400/02-11-01 URI Failure to Protect Charging System MOV 1CS-1 65, VCT
Outlet to CSIPs, From Maloperation Due To a Fire
(Section 1R05.3)
50-400/02-11-02 URI Failure to Protect Charging System MOVs 1CS-1 69, 1CS-
214, 1CS-218, and 1CS-219 From Maloperation Due To a
Fire (Section 1R05.3)
50-400/02-11-03 URI Failure to Protect Charging System MOVs 1CS-1 66, 1CS-
168, and 1CS-217 From Maloperation Due To a Fire
(Section 1R05.3)
Attachment 1
2
50-400/02-11-04 URI Failure to Protect Component Cooling MOVs 1CC-251 and
1CC-208, CC for RCP Seals, From Maloperation Due To a
Fire (Section 1R05.3)
50-400/02-11 -05 URI Reliance on Manual Actions in Place of Required Physical
Separation or Protection From a Fire (Section 1R05.3)
50-400/02-11-06 URI Fire SSD Operator Actions With Excessive Challenges
(Section 1R05.3)
50-400/02-11-07 URI Too Many Fire SSD Actions for Operators to Perform
(Section 1R05.3)
50-400/02-11-08 URI Using the Boric Acid Tank Without Level Indication
(Section 1R05.3)
50-400/02-11-09 URI Failure to Provide Required Emergency Lighting for SSD
Operator Actions (Section 1R05.3)
50-400/02-04-00 LER Unanalyzed Condition Due to Inadequate Separation of
Associated Circuits (Section 40A3)
Attachment 1