ML050670633

Self-Assessment Report

ML050670633
Person / Time
Site:	Turkey Point
Issue date:	12/31/2003
From:	Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2004-0277
Download: ML050670633 (21)

Text

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F=PL Page 2 of 21 FPL Page 2 of2l TURKEY POINT NUCLEAR PLANT SELF-ASSESSMENT REPORT REPORT DATE:

December 31, 2003 TITLE:

APPENDIX R AND FIRE PROTECTION PROGRAM

SUBJECT:

2003 SELF-ASSESSMENT DATES OF ASSESSMENT:

June 2, 2003 - December 23, 2003 CORE ASSESSMENT TEAM:

Core Team Reviewer Initials Team Lead (FPE)

Mechanical Design Supervisor Mechanical Design Engineer Mechanical Design Engineer Electrical Design Supervisor Electrical Design Engineer Electrical Design Engineer Electrical Design Engineer Civil Design Supervisor Civil Design Engineer Design Basis Group Engineer Licensing/Fire Protection Manager Fire Protection Supervisor Fire Protection Engineer Fire Protection Engineer Licensing Supervisor Operations Supervisor Operator Operator Al Dunstan*

Joe LaDuca Abe Pineda (PT)

Chuck Zyne (PT)

Tim Sweeney Bharat Thaker*

Pat Savine (P11 Maria Pusey (PT)

Jaime Delgado Mo Afzal (P1)

Mitch Guth (PI)

Walt Parker Frank Busch Tim Bushatz Malcolm George Olga Hanek Brian Stamp Joe Stonecipher Steve Allen

FPL Page 3 of 21 TABLE OF CONTENTS SCOPE/OBJECTIVES....................

4 EXECUTIVE

SUMMARY

5 Strengthss.......................................................................................................6 W eaknesses...................................................................................................

6 Enhancem ents...............................................................................................6 ASSESSMENT DETAILS................

7 CORRECTIVE ACTIONS....................................................................................18 REFERENCES................

19

FPL Page 4 of 21 SCOPE/OBJECTIVES The self-assessment was conducted to evaluate the overall health of the fire protection program, compliance with regulatory commitments, safe shutdown timelines and feasibility of manual actions to support safe shutdown capability.

The primary objectives were to identify any areas of noncompliance with respect to design or licensing bases, deficiencies in fire protection defense-in-depth or deficiencies in safe shutdown capability for risk-significant areas.

The assessment methodology was to review the 1999 baseline self-assessment report for opportunities for further investigation, to assess the overall health and readiness of fire protection defense-in-depth and to select areas for particular focus. The 1999 report encompassed the draft NRC FPFI inspection modules of Temporary Instruction 2515/xxx. For continuity, the levels of review for the 2003 assessment are based on the 1999 scope and are indicated in Table 1. The approach used guidance from NEI 99-05 (November 2002 draft). In addition to fire protection feature health addressed in Assessment 03-12, Thermo-Lag raceway protection maintainability and fire water supply readiness are specifically assessed.

The approach to Appendix R safe shutdown capability was to review Pre-Fire Plans for feasibility and timeliness for performing prescribed manual actions to achieve safe shutdown. As the 1999 self-assessment included operator walk-through for all fire zones with safe shutdown functions, 30 fire zones considered risk-significant and with relatively high numbers of manual actions were selected for developing timelines and feasibility assessments for performing manual actions. For a sampling of these, safe shutdown circuit analyses were also reviewed and assessed.

FPL Page 5 of 21 EXECUTIVE

SUMMARY

The assessment resulted in no adverse conditions, no operability concerns, no safety concerns and no reportable events. The Appendix R safe shutdown reviews were driven primarily by condition reports and were addressed accordingly in course of the dispositions.

The use of manual actions to support PTN safe shutdown capability is considered feasible and consistent with licensing bases.

Plant transient scenarios and manual action timelines were developed, reconstituted and compiled in Evaluation PTN-ENG-SEMS-03-045 to effectively consolidate and define the bases for operator response in event of fire.

The regulatory environment concerning manual actions is fluid and is expected to remain so at least until NRC rule-making is completed. Even so, it is planned to submit an exemption request in 2004 for manual actions credited in lieu of the protection methods prescribed in Appendix R Section III.G.2.

This submittal is independent of proposed changes to overhaul Pre-Fire Plans regarding manual actions consistent with the philosophy that 0-ONOP-016.10 should assist rather than dictate performance of EOPs and ONOPs, also anticipated for 2004.

The fire protection program is considered to be in overall good health. Inspection, maintenance and training processes already in place continue to be effectively used to maintain readiness of fire protection features.

Recent enhancements include facilities to detect and measure leakage in the fire main loop and application of more effective coating systems for outdoor installations of Thermo-Lag raceway protection.

The organization is also being pro-active in anticipating special consideration for fire protection during major evolutions, such as reactor head replacement during the next refueling outages, and projects, such as obstruction of access to fire detectors in the Cable Spreading Room due to DDPS upgrades.

I FPL Page 6 of 21 Strengths

• The assessment of manual actions and safe shutdown capability effectively used the condition reporting process to identify issues and track resolution milestones via supplements and PMAIs.

Dispositions sufficiently captured the scope and implications of extended conditions so as not to overlook nonconformances, operability concerns or opportunities for resolution to prevent repeat conditions.

• Subject matter expert training effectively increases awareness of how plant changes can adversely impact fire protection feature performance.

• Proactive efforts to mitigate weather damage to outdoor Thermo-Lag installations rewarded with at least moderate success.

• Fire Protection (Assessment No.03-012) has adopted system health reporting as a practice for fire protection features based on INPO and NEI guidance.

Weaknesses

• Monitoring the EOOS log for tracking out-of-service status of Appendix R safe shutdown equipment was not adequate to capture all Appendix R components.

No operability, nonconformance or reportability issue was noted. The issue is addressed and a plan of action is prescribed via CR 03-1721.

Enhancements

• Outdoor Thermo-Lag installations continue high maintenance demands.

The harshest weather exposure tends to occur in open areas where exposure fires are least challenging.

If coating does not substantially reduce maintenance, then pursuing fire hazard analysis and.the exemption process to reduce Thermo-Lag in selected outdoor areas should be considered per CAR 03-058.

• There is an opportunity for improvement by raising the level of awareness as to operational and maintenance activities that can adversely affect the readiness of fire protection features or safe shutdown capability. Seemingly minor activities (e.g., tygon drip line from an A/C unit, switch covers, rubber mats) can affect the combustible loading described in the Fire Hazard Analysis. Other activities (e.g.,

scaffolding) can affect sprinkler or detector performance.

Focused training, similar to that provided to Engineering, could be applied to Maintenance, Operations and Work Controls.

S FPL Page 7 of 21 ASSESSMENT DETAILS The fire protection self-assessment performed in 1999 was relatively comprehensive in addressing fire protection features and safe-shutdown capabilities.

This is an extension of the 1999 assessment with focus on selected areas. Table 1 indicates the levels of review performed with respect to the categories addressed in 1999.

The project plan for the assessment is included hereto as Attachment 1. The scope included two major categories: Fire protection and Appendix R safe shutdown. The respective scopes of assessment are addressed below. Selected topics are based on issues raised during inspections at other plants. These and other concerns raised during this self-assessment are captured in a log included hereto as Attachment 2.

FPL Page 8 of 21 Fire Protection In fire protection, there have been no major modifications since 1999. As such, overall program health was assessed by Fire Protection Department personnel and presented as Assessment No.03-012. In addition, separate reviews were performed for selected topics specifically addressed herein.

Thenno-LaI RaceMau Protection Thermo-Lag raceway protection upgrade was in-progress during the 1999 self-assessment so the topic was not extensively addressed. Upgrades have since been completed and, after at least two years service, there is sufficient experience to warrant a more in-depth assessment of its performance and maintainability.

Deficiencies regarding Thermo-Lag fire barriers cited in NRC IE Bulletin 92-01 led to Thermo-Lag fire barriers at Turkey Point being declared inoperable. Since then, PCMs96-014 (containment),97-052 (indoors) and 97-057 (outdoors) were issued to effect upgrades to address the deficiencies.

Granted exemption requests are reflected in UFSAR Appendix 9.6A Section 4.0 for the respective fire zones.

Leaching is a common deficiency on outdoor installations and manifests as cracks or "allegatoring" in areas exposed to rain and direct sunshine and near sun-heated concrete structures. Several outdoor areas have been inspected per procedure 0-SFP-016.2 where degraded Thermo-Lag has been identified. Apparent cause for degraded Thermo-Lag is water intrusion through degraded topcoating, particularly at joints, or via seepage and migration over conduit.

However, based on the most recent inspections, topcoat failures do not necessarily result in degraded fire barriers.

Thermo-Lag fire barriers are constructed from Thermo-Lag 770-1 and 330-1 materials.

Most of the leaching occurs on Thermo-Lag 330-1, commonly when Thermo-Lag 330-1 material is exposed to moisture. Thermo-Lag material exposed to high levels of moisture and exhibiting well-developed leaching is no longer hard and board-like, but spongy.

In an effort to curb these effects, Thermo-Lag fire barriers installed outdoors or exposed to a significant moisture threat are protected with a polyurethane coating.

Approved topcoat materials for use at PTN are listed in Subsection 4.5 and applied per Subsection 5.8 of Specification MN-3.21. Although the topcoat systems specified in MN-3.21 were selected based on vendor recommendation and industry experience, topcoat failures at PTN have occurred at a variety of outdoor locations, particularly on installations exposed to direct heat and rain.

FPL Page 9 of 21 In an effort to improve the topcoat system and reduce maintenance, the following new protective coatings were tested on Thermo-Lag 330-1 outdoor installations:

1. Belzona 3211 manufactured by Belzona was installed on approximately 10 feet of outdoor Thermo-Lag installation where previous water intrusion and cracking has been experienced.

The new coating was inspected monthly, for approximately six months, to verify performance and coating integrity. The Belzona 3211 was installed as recommended by the manufacturer.

2. A new protective coating system was installed consisting of Butylseal 572 primer and Acrylastic 490 topcoat, manufactured by Davlin Waterproof Coatings, on approximately 10 feet of outdoor Thermo-Lag installation where previous water intrusion and cracking has been experienced. The new coating was inspected monthly, for approximately six months, to verify performance and coating integrity. Coating installation was performed as recommended by manufacturer.

Results with Belzona were considered unacceptable but Butylseal 572 primer with Acrylastic 490 topcoat provided very positive results with no deleterious effects when installed on Thermo-Lag exposed to the sun and rain.

Therefore, based on the positive result of the test conducted, Engineering is revising Specification MN-3.21 to include Butylseal 572 primer and Acrylastic 490 topcoat as an approved protective coating system for use as Thermo-Lag protection in outdoors applications.

Butylseal 572 primer and Acrylastic 490 topcoat are nonflammable in accordance with the Material Safety Data Sheet.

As such, this coating system will not contribute to fire propagation along the surface of Thermo-Lag raceway fire barriers.

In the Material Safety Data Sheet, the manufacturer indicates in Chapter V, under Hazardous Decomposition or Byproducts, that under severe thermal degradation, low molecular weight hydrocarbons may be formed. Therefore, Butylseal primer and Acrylastic 490 topcoat will consume under fire and will not adversely affect the performance of the installed Thermo-Lag barrier system or invalidate the applicability of the qualification testing as it pertains to configurations at PTN.

While use of the Butylseal/Acrylastic system appears to be an improvement to Thermo-Lag raceway protection performance and longevity, service time is just beginning. If maintenance on Thermo-Lag outdoor installations is not significantly reduced, then it would be appropriate to consider efforts to reduce the quantity of outdoor Thermo-Lag.

FPL Page 10 of 21 Fire Loop Hudraulic Gradient The fire main loop is flow-tested at 3-year intervals pursuant to 0-OSP-016.29. This satisfies the surveillance requirement prescribed in O-ADM-0161, Paragraph 5.6.4.1.d.(1) (O for demonstrating fire water supply and distribution system operability.

The onus for operability is based on satisfying NEIL (Nuclear Electric Insurance Limited) and NRC criteria and must be satisfied or reconciled at each 3-year evolution. As such, there is no formal provision for trending these test results.

Flow testing determines the hydraulic gradients (pressure profile) for each of six fire main loop alignments. Test Nos. 2 and 5 demonstrate compliance with NEIL and NRC requirements, respectively, and are assigned acceptance criteria accordingly.

However, Test Nos. 1, 3, 4 and 6 provide hydraulic profile and system performance capability information for other fire main alignments for trend information only and have no associated acceptance criteria.

In addition to satisfying NRC commitments and NEIL requirements, the composite of flow test alignments provides an overall view of firewater supply adequacy and reliability.

The primary performance objective is to be able to meet the required firewater demand anywhere along the fire main. The "demand" is whatever firewater supply is needed to fight a fire and is quantified in terms of flow rate (or combination of flow rates) and pressure. Specific values are dictated by supply requirements for automatic suppression systems, hose stations and hydrants.

Unlike municipal water supplies, which serve potable as well as firewater demands, the firewater supply at Turkey Point Plant is dedicated to fire protection, beginning with the dedicated reserve in the Raw Water Tanks.

This simplifies the demand requirements; however, stagnant water in piping can have detrimental effects on system performance. Pump readiness is assured through operability and surveillance testing. System cleanliness and functionality are assured through valve stroking and system flushing. However, pipe internal roughness can significantly degrade through tuberculation, much like the drag effect of barnacles on a ships' hull, and can only be practically assessed through flow testing.

Procedure O-ADM-016 also states that flow testing Is performed In accordance with Chapter 5, Section 11 of the Fire Protection Handbook, 14" Edition. As this reference becomes Increasingly elusive with time, a copy Is Included as Attachment 2.

FPL Page 11 of 21 Results from the past five test cycles were reviewed and the flows are summarized in the following table:

Test Year Test #1 Test#2 Test #3 Test#4 Test #5 Test #6 2002 2719

>2905 1271 1975 2741 2697 1999 2663

>2905 1086 1917 2719 2697 1995 1176 1663 1123 1610 2360 N/A 1992 2276 1896 1085 1802 2440 N/A 1989 2200 1760 1175 1635 2292 N/A Only results from the last two tests (1999 and 2002) are considered meaningful and relevant to the present configuration.

Implementation of PCM 97-031 resulted in significant hydraulic improvements.

Demand was reduced by separating main transformer fixed spray supply headers from the fixed spray supplies to their respective auxiliary transformers and hydrogen seal oil units. Pressure losses were reduced by adding a 10" fire main header between Units 2 and 3 in parallel with the 6" header, completing the 10" loop of the nuclear plant.

There is clearly a substantial improvement in flow delivery capability in all alignments. Test #5, performed for NRC requirements, measured flows increased by 15%. Test #2, performed for insurance purposes, improved by more than 50% and even exceeded flow meter range.

The other tests also showed comparable improvements. In terms of trending, there is no immediate benefit for performing the tests at every 3-year cycle. Flushing is performed per 0-OSP-016.30 so there are other provisions for removal of loose sediment or tubercular products. As such, there appear to be no overriding benefits for continuing to perform Tests 1, 3, 4 and 6.

Fre Loo, Intepr4u Fire main pressure is maintained using a tie-in from the service water system. The provision is similar to the original plant configuration where a high-tower maintained static head in the fire main and make-up was provided by service water. Jockey pumps were installed via PCM 84-27 when establishing a dedicated fire protection system. However, the Jockey pumps required excessive maintenance, could only be started locally and their failure resulted in challenging fire pumps such. The present tie-in from service water was provided for via PCM 00-008.

FPL Page 12 of 21 Service water is a reliable source for maintaining fire loop pressure, since at least one pump is virtually always operating and a diesel-driven service water pump is available under LOOP conditions. Cross-tie make-up capability can accommodate inspector test flows while maintaining pressure above fire pump actuation set-points.

The cross-tie also added the capability to measure make-up flow to detect leakage in fire loop underground piping. The acceptance criterion of 2 gpm of allowed leakage is prescribed in Section 7.8 of 0-OP-016.1 to prompt Engineering review until a baseline can be established for PTN.

Initial performance of 0-OP-016.1 Section 7.8 indicated flow (FI-1006) pegged at 17.6 gpm and CR 03-1215 was issued accordingly.

Although troubleshooting via temporary procedure (P 03-016) did not identify specific leakage locations, some conclusions could be drawn. The total flow rate was estimated to be 30 to 35 gpm.

The indicated flow reflects a composite of pressure boundary leakage to some degree but most likely reflects back-leakage through check valves. There is no one leak point with greater than 17.4 gpm (35 gpm estimated less 17.6 gpm indicated). Even so, additional troubleshooting and a more direct means of measuring higher flows are prescribed via CR supplement.

Provision for direct flow measurement is an enhancement and a reasonable method for assessing integrity of the dedicated fire water supply system.

However, the present tool is insufficient to directly measure and baseline system leakage flow. The proposed corrective actions to mount a Controlotron in series with FI-1006 and checking for back-leakage through pump check valves is appropriate for establishing a baseline and, therefore, are considered reasonable in the follow-up course of action.

Risk Significance Estimates Following the 2001 triennial inspection and having gained rudimentary experience with the Significance Determination Process (SDP), Engineering prepared Evaluation PTN-ENG-SEMS-01-0043 as a tool for assessing risk-significance of fire protection feature impairments. The process has been used to support operability assessments in CR dispositions and as stand-alone input for planned work. However, applications have been relatively infrequent (fewer than 10 occasions since inception). In this regard, and considering that regulatory developments are still in process as well as FPL initiatives for applying PRA techniques, refinements and upgrades to this particular process are considered premature and of no immediate benefit.

IPL Page 13 of 21 Appendix R Safe Shutdown and Manual Actions For PTN, since the Appendix R Fire Protection Program Report submittals in 1983, manual actions have been regarded as integral and essential in effecting safe shutdown in event of fire.

Manual action time limits were developed based on analysis and judgement (e.g., Bechtel letter SFB-6692 dated June 26, 1989) and walk-throughs performed for selected cases where operators appeared to be excessively challenged (e.g., historically, the C-bus powering to start a SSGF Pump).

Requirements were incorporated in the Pre-Fire Plans (0-ONOP-016.10) and feasibility validated via walkdown, even as recently as for the 1999 self-assessment.

However, recent developments prompted a modified perspective of manual actions at PTN.

A series of correspondence led to an NRC/NEI meeting on June 20, 2002 by which time it became clear that use of manual actions (operator actions outside the Control Room) would likely be placed under greater scrutiny with stricter guidelines regarding acceptability. Following this meeting, PTN Engineering determined that a more rigorous basis for manual action times would be prudent and CR 02-1268 was issued accordingly.

The initial approach was to consolidate and edify the bases for manual action times.

A framework was set based on event scenarios defined by Engineering and analyses performed by Nuclear Fuel using RETRAN 02. The time limits were gleaned from the Bechtel letter and other supporting calculations. The approach was determined to be feasible and Engineering initiated Evaluation PTN-ENG-SEMS-03-045 as a documentation vehicle.

As the Issue evolved in the industry and regulatory environments, the scope and depth of review was augmented. The PSL 2003 inspection results provided practical insights via OEF 03-054 and PTN review action was initiated via CR 03-1306. Also, noting RCP seal cooling issues in the station blackout context and that timing differed from Appendix R assumptions, CR 03-1330 was Issued to address RCP seal cooling in particular for Appendix R safe shutdown. Even so, input from the NEI 2003 Fire Protection Information Forum, particularly in view of the pending triennial inspection, substantially heightened a desire to more firmly define the PTN basis for manual action timing and feasibility. The review categories and results are presented under the respective headings.

FPL Page 14 of 21 Timeline Bases and Event Scenarios Three transient scenarios were selected to assess plant response.

As primary system design basis accidents and events and timelines are more definitively described in the UFSAR and Accident Analysis Basis Document (AABD), the three transient scenarios were selected primarily to challenge from the secondary plant and attendant operator actions in the first hour of the event. These were:

• Loss of AFW + LOOP + one stuck-open ADV

• Loss of AFW + one stuck-open ADV

• Loss of AFW + LOOP The first two scenarios imposed a single failure, thereby going beyond Appendix R conditions. The third scenario was consistent with Appendix R assumptions. The results are preliminary, however, and should be finalized as a formal calculation.

SSA and Manual Action Reviews Procedures 0-ONOP-105 and O-ONOP-016.10 and the Safe Shutdown Analysis (SSA) were reviewed for what manual actions were prescribed, when they had to be performed and how times compared with the timeline bases and event scenarios.

The initial focus was on manual actions credited in lieu of circuit protection per Appendix R Section III.G.2. Regulatory or industry guidance as to what constitutes such actions is not readily available; therefore, criteria were selected. In short, if performing a manual action is conditional (i.e., depends on credible input to prompt action), then it is regarded as being credited in lieu of circuit protection. A listing of such actions is presented in Appendix J of Evaluation PTN-ENG-SEMS-03-045.

Based on recent regulatory developments, it is now understood that manual actions credited in lieu of circuit protection require exemption from the protection criteria prescribed in Appendix R Section III.G.2. Although indications are that an NRC ruling is pending and may be issued in Summer 2004, it Is recommended that the need for granted exemption be regarded presently as a valid requirement and that PTN should proceed with exemption request preparations.

In more immediate regard is the imminent triennial inspection in January 2004. As indicated at the 2003 NEI Fire Protection Information Forum and in the NRC draft changes to Inspection Manual 71111.05, cited violations may be avoided if manual actions are determined to be feasible. The feasibility criteria were presented in draft form on March 6, 2003 (see Appendix C of Evaluation PTN-ENG-SEMS-03-045) and another modified version published as a notice in Vol. 68, No. 228, Page 66501 of the Federal Register. These were used in the timeline development and feasibility review of selected fire zones.

FPL Page 15 of 21 As part of the 1999 Fire Protection Self-Assessment, an operator walk-through was performed for nuclear plant fire zones with manual actions. This activity confirmed that manual actions could be performed within the timeframes prescribed in Procedure O-ONOP-016.10.

In light of evolving industry issues, however, it was deemed prudent to revisit manual action performance using an alternative, more analytical perspective. With time constraints due to the pending January inspection, Engineering opted to review a sampling of nuclear fire zones (nominal 25%) but not randomly selected. Rather, the selection was made from risk-significant fire zones weighted heavily with manual actions. The selection was considered most challenging to operation resources and, since manual actions are often similarly employed among several fire zones, to represent a relatively large portion of the manual action population. This approach appears to have optimized gain from limited resources.

The timelines were developed using plant layout drawings and walkdowns, consistent allowances for travel rates, assumed number of operators originating from the Control Room and assumed manual action performance times. The assumptions appear to be reasonably conservative with possible exception of available operators. Minimum staffing level would allow three operators to perform manual actions. A fourth may be available but requires Operations confirmation.

Although most areas credit only three operators, some require four to complete actions in the prescribed timeframes.

In this regard and related issues, follow-up action is required for the following:

• Confirm the number of Control Room operators available to perform manual actions.

• Develop or refine system response analyses as required to extend manual action timeframes beyond the first hour of the event and also to avoid entry to or passage through the affected area in the first hour.

• Address feasibility issues noted for emergency lighting and communications.

In addition, performing these reviews has fueled a perspective that performing actions to assure a success path for Appendix R safe shutdown may increase economic risk to the nuclear plant. For example, opening a breaker to prevent spurious operation of a pump in the secondary system reduces the number of potential flow paths to the steam generator. Development of the Appendix R safe shutdown procedures did not l programmatically include IPEEE or PRA criteria.

In this regard, however, it is considered prudent that operators will respond to a plant transient event as trained to EOPs and ONOPs and that manual actions prescribed in the Pre-Fire Plans, a lower-tier document, would be appropriately regarded as guidance.

FPL Page 16 of 21 RCP Seal Coolini Analysis recognized differences between Appendix R and SBO assumptions. It was determined that RCP seal cooling, by thermal banier cooling, seal injection flow or both, would be available for all fire scenarios except for mis-operation of certain flow path components due to spurious actuation.

Also a plausible justification was presented crediting the high-temperature seal O-ring design, the likely finite time before spurious actuation would occur and that the EOPs and associated training would prevent the operator from re-establishing seal cooling if found not operating late in the event.

From the analysis there indeed appears to be no nonconforming or operability issue; however, -the analysis is considered incomplete.

MOV/AOV Spurious Actuation There are a number of MOVs and some AOVs where handwheel operation is credited to manipulate the valve to the desired position.

It may be possible for a valve operator, spuriously actuated by circuit fire damage, to over-torque the valve in a way to prevent subsequent opening or closing via handwheel.

This issue was addressed regarding NRC IN 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire, dated February 18, 1992.

Evaluation JPN-PTN-SEEP-93-011 was issued rnid-year 1993. Applicable MOVs for both units were analyzed to determine if mechanical damage could occur that would prevent manual operation of the valve. Possible alternate means of performing the MOV functions and physical modifications to the MOV have been investigated if it was concluded that the MOV was not capable of being manually operated In accordance with plant procedures.

The results of this safety evaluation conclude that the PTN MOVs are susceptible to the fire induced "hot shorts" that bypasses MOV control circuit protective features, as described in IN 92-18. The subject MOVs are capable of being positioned in accordance with the appropriate plant procedures following a Control Room fire with the exception of MOV-3/4-350 (emergency boration) and MOV-3/4-1400, 1401 and

FPL Page 17 of 21 1402 (MSIV bypass). For MOV-3/4-350, alternate boron flow paths are available to accommodate a postulated hot short. To prevent spurious action for MOV-3/4-1400, 1401 and 1402 as a result of a hot short, a procedure change was made to 3/4-OP-072 to remove power from these MOVs during plant power operation. It was confirmed that plant safety was not compromised and no operability issues.

As for AOVs, the following Is a list of those AOVs that contain handwheel operators:

Main Feedwater Startup valves

>FCV-3-479, FCV-3-489, and FCV-3-499 Main Feedwater Startup valves

>FCV-4-479, FCV-4-489, and FCV-4-499 Letdown (CVC)

CV-3-200C Letdown (CVC)==->CV-4-200C Letdown (CVC)==>CV-3-204 Letdown (CVC)==

CV-4-204 Charging (CVC)===============================>CV-3-310A.

CV-3-310B, CV-3-311 Charging (CVC)===============================>CV-4-310A, CV-4-310B, CV-4-311 Letdown (CVC)==

==

>HCV-3-142 Letdown (CVC)

>HCV-4-142 Steam Generator Blowdown Flow Control Valves====> FCV-3-6278A, FCV-3-6278B, FCV-3-6278C

-Steam Generator Blowdown Flow Control Valves====> FCV-4-6278A, FCV-4-6278B, FCV-4-6278C MSRs (MAIN STEAM SYSTEM)

CV-3-3710. CV-3-371 1, CV-3-3712, CV-3-3713 MSRs (MAIN STEAM SYSTEM)====->

CV-4-3710, CV-4-371 1, CV-4-3712, CV-4-3713 Air operated valves are setup to a fail-safe position upon loss of instrument air and/or loss of power.

In this scenario a spring will place the valve in its safe position at sufficiently low actuator air pressures. Based on the passive nature of the spring return and valve setup within appropriate parameters, It is not credible for the spring stroke mis-operation to prevent the valve from being stroked via handwheel.

The only postulated failure that could prevent proper handwheel operation would be failure to vent the actuator. However, review of the AOVs with handwheels indicates that each has a local valve that may be operated locally to vent the actuator, prior to handwheel operation. Therefore, it is not credible for an AOV to be spuriously actuated by solenoid circuit fire damage, to damage the valve such that operation via handwheel Is impeded. Evaluation PTN-ENG-SEMS-03-045 appropriately includes an action to assure procedures identify the respective manual valves to assure the associated AOV position can be changed or sustained, as required.

FPL Page 18 of 21 CORRECTIVE ACTIONS Corrective Actions to address identified conditions are defined in the respective reports and/or associated supplements for the following:

CR 02-1268 MANUAL ACTIONS ARE INTEGRAL AND ESSENTIAL FOR SAFE SHUTDOWN IN EVENT OF APPENDIX R FIRE.

PERFORMANCE CAPABILITY AND TIMING REQUIREMENTS ARE VALIDATED BY WALKDOWN AND SUPPORTED BY ANALYSIS. HOWEVER, BASED ON A RECENT NRC / NEI -MEETING AND TRIENNIAL INSPECTION, THE FEASIBILITY OF PERFORMING MANUAL ACTIONS ARE LIKELY TO BE EVALUATED WITH RESPECT TO MORE NORMALIZED CRITERIA AND FORMAT.

CR 03-1215 WHILE PERFORMING 0-OP-01 6.1 SECTION 7.8, FIRE MAIN LEAKAGE INSPECTION, THE MEASURED LEAKAGE WAS 17.6 GPM. THE MAXIMUM ACCEPTABLE LEAKAGE IS 2 GPM. CALIBRATION OF FI-1006 WAS VERIFIED BY BUCKET CHECK. INDICATED FLOW OF 5 GPM YIELDED SLIGHTLY LESS THAN 6 GPM IN THE BUCKET.

CR 03-1306 OEF# 03-054 PSL NRC TRIENNIAL FIRE PROTECTION INSPECTION CR.03-1330 DURING REVIEW OF PCM 03-042, IT WAS NOTED THAT SBO COPING ASSUMES RCP SEAL DEGRADE FROM COOLING VIA RCS FLUID AND RESULTS IN A 25 GPMIPUMP INVENTORY LOSS. SEAL DEGRADATION IS BASED ON THE ASSUMPTION THAT SEAL INJECTION IS NOT RESTORED WITHIN TWOF THE SBO EVENT. THIS CONCEPT ENSUED FROM REVISION IC OF THE ERGS IN 1997 WHERE WESTINGHOUSE RECOMMENDED COPING VIA SEAL CO ING WITH RCS COOLDOWN IN LIEU OF THE PREVIOUS APPROACH TO RE-ESTABLISH SEAL INJECTION WITHIN IT WAS RECOGNIZED THAT THIS REVERSAL IN SBO PHILOSOPHY COULD AFFECT ASSUMPTIONS USED IN THE SAFESRUTDOWN (SSD) ANALYSIS FOR APPENDIX R FIRE SCENARIOS. SPECIFICALLY, THE TIME FRAME FOR PERFORMING SSD MANUAL ACTIONS (SEE PROCEDURES 0-ONOP-105 AND 0-ONOP-01 6.1 0) IS BASED ON AN ASSUMPTION MADE DURING INITIAL SSD DEVELOPMENT (CIRCA 1984) THAT RCP SEAL COOUNG MUST BE RE-ESTABLISHED, EITHER BY CCW OR SEAL INJECTION, WITHIN NDER LOOP CONDITIONS. AS THERE ARE DIFFERENCES AS WELL AS SIMILARITIES, THE APPENDIX R SCENARIOS SHOULD BE REVIEWED TO DETERMINE IF THE SBO ASSUMPTIONS FOR SEAL COOLING APPLY AND, IF SO, TO PRESCRIBE CORRECTIVE ACTIONS, IF APPROPRIATE.

CR 03-1682 THE OCC REQUESTED INPUT AS TO THE OPERABILITY OF THE MECHANICAL EQUIPMENT ROOM DOOR (D097-1) DURING MAINTENANCE.

ENGINEERING INDICATED THAT THE DOOR IS INSPECTED TO FIRE DOOR REQUIREMENTS AND THAT NO SPECIAL REQUIREMENTS APPLY AS PART OF THE CONTROL ROOM PRESSURE BOUNDARY. WITH A QUESTIONING ATTITUDE AND IN ANTICIPATION OF THE PENDING FIRE PROTECTION TRIENNIAL INSPECTION, ENGINEERING CONTINUED RESEARCH AND NOTED A POTENTIAL FOR CONFUSION BETWEEN UFSAR SECTION 9.9.1.3 AND APPENDIX 9.6A SECTION 3.12. THERE IS NO OPERABILITY CONCERN OR NONCONFORMANCE BECAUSE CONTROL ROOM SURVEILLANCE CRITERIA DO NOT INCLUDE DOOR INTEGRITY, FIRE DOOR SURVEILLANCE REQUIREMENTS INCLUDE NO SPECIAL REQUIREMENTS FOR D097-1 AND ACCIDENT ANALYSES DO NOT CREDIT SPECIFIC DOOR INTEGRITY REQUIREMENTS.

THEREFORE, THE PURPOSE OF THIS CR IS TO DOCUMENT THE CONDITION AND PRESCRIBE CORRECTIVE ACTIONS, IF REQUIRED.

CR 03-1683 DURING UFSAR REVIEW AS PART OF THE INDEPENDENT VERIFICATION OF EVALUATION PTN-ENG-SEMS-03.035, AND IN UGHT OF THE PENDING FIRE PROTECTION TRIENNIAL INSPECTION, IT WAS NOTED THAT COMPLIANCE WITH THE DESIGN BASIS TO MAINTAIN ADEQUATE VENTILATION TO ENSURE HYDROGEN CONCENTRATION REMAINS BELOW FLAMMABILITY LIMITS WAS NOT DESCRIBED IN UFSAR SECTION 9.92. THE VERIFIER RECALLED HAVING REVIEWED THE CONDITION CIRCA 1984 AND THAT THE CONDITION WAS ACCEPTABLE UNDER LOOP CONDITIONS BECAUSE OF NATURAL VENTILATION THROUGH BUOYANCY OF HYDROGEN GAS AND NO IN SITU IGNITION SOURCES.

THEREFORE, THERE ARE NO NONCONFORMANCE OR OPERABILITY CONCERNS. HOWEVER, BECAUSE INITIAL RESEARCH DID NOT LOCATE SUPPORTING DOCUMENTATION, THIS CR IS PREPARED TO PROVIDE FOR RECONSTITUTING SUPPORTING DESIGN ANALYSIS AND UPDATING THE UFSAR, IF REQUIRED.

SPL Page 19 of 21 CR 03-1721 THERE IS NO POSITIVE MEANS IN PLACE TO ENSURE ALL APPENDIX R EQUIPMENT REMOVED FROM SERVICE IS EVALUATED FOR REQUIRED COMPENSATORY MEASURES. FIRE PROTECTION CURRENTLY MONITORS THE EOOS BOOK. THERE ARE ITEMS ON THE APPENDIX R ESSENTIAL EQUIPMENT LIST THATARE NOT REQUIRED TO BE PLACED IN THE EOOS BOOK.

CR 03-1722 EVALUATE THE NEED TO PROCEDURALIZE THE USE OF FIRE PROTECTION COMPENSATORY MEASURES WHEN THE SPARE BATTERY IS PLACED IN SERVICE.

PRESENTLY, THE NEED FOR COMPENSATORY MEASURES ARE EVALUATED AFTER THE SPARE BATTERY HAS BEEN IN SERVICE FOR SEVEN DAYS IN ACCORDANCE WITH PROCEDURE O-ADM-016.

CR 03-3824 PROCEDURES O-ONOP-016.10 AND O-ONOP-105 CREDIT MANIPULATION OF MANUAL VALVES TO ACHIEVE AND MAINTAIN SAFE SHUTDOWN IN EVENT OF APPENDIX R FIRE. INSPECTION CRITERIA PROVIDED BY THE NRC INDICATE THAT SPECIAL TOOLS REQUIRED TO PERFORM MANUAL ACTIONS MUST BE DEDICATED AND AVAILABLE TO ASSURE THAT THE PRESCRIBED MANUAL ACTION IS FEASIBLE. IN THIS CONTEXT, A VALVE WRENCH (AKA CHEATER BAR) IS CONSIDERED A SPECIAL TOOL IT IS NOT READILY EVIDENT IF ALL MANUAL VALVES CREDITED FOR SAFE SHUTDOWN AND NEED A VALVE WRENCH FOR OPERATOR ASSISTANCE HAVE THE VALVES WRENCHES DEDICATED AND AVAILABLE.

THE 'DEDICATION AND AVAILABILITY' NEEDED DECREASES WITH TIME INTO THE FIRE EVENT SCENARIO AND IS MOST ESSENTIAL WHERE THE ACTION IS CREDITED TO ACHIEVE AND/OR MAINTAIN HOT SHUTDOWN. AS SUCH, THE FIRST HOUR OF THE EVENT IS CONSIDERED THE MOST CRITICAL IN DEMAND ON OPERATOR ACTIONS. THEREFORE, RECOMMEND THAT OPERATIONS REVIEW THE PROCEDURES FOR LOCAL MANUAL ACTIONS TO MANIPULATE VALVES IN THE FIRST-HOUR WINDOW AND TO ASSURE THAT VALVE WRENCHES ARE NORMALLY ON THE HANDWHEEL OR STAGED NEARBY ANY VALVE THAT REQUIRES ONE. AS MOST MANUAL VALVES HAVE BEEN OPERATED AND THOSE REQUIRING IT NORMALLY HAVE VALVE WRENCHES STAGED CONVENIENTLY OR ONE CAN BE READILY OBTAINED, THERE IS NO OPERABILITY CONCERN.

REFERENCES 0-ADM-050, Self-Assessments 0-ADM-0 16, Fire Protection Program 0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions O-ONOP-105, Control Room Evacuation FPFI Self Assessment Project Report; September 1999 Database for NRC Questions/Responses during 2001 Triennial Inspection NRC Inspection Report Nos. 50-250/01-02 and 50-251/01-02, dated March 6, 2001 NEI 99-05, NEI Guidancefor Fire Protection Self-Assessments (November 2002)

Federal Register/Vol. 68, No. 228/Wednesday, November 26, 2003/Notices - 66501 Evaluation JPN-PTN-SEEP-93-01 1, Revision 0, Potential for Loss of Remote Shutdown Capability during a Control Room Fire Evaluation PTN-ENG-SEMS-01-0043, Revision 0, Guidance for Performing Risk Significance Estimates of Fire Protection Features Appendix F - Fire Risk Significance Determination Process (SDP), Working Draft Revision 2.3a dated October 14, 2003

Is F=PL Page 20 of 21 FPL Page 20 of 21 Team Leader:

Approved By:

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Date Date D/ate

FPL Page 21 of 21 FPL Page 21 of2l TABLE 1 FINAL TASK ASSESSMENT LEVEL ASSIGNED TASK ASSESSMENTAREA LEVEL OF REVIEW 101 Administration 1

102 Organization & Management Oversight 1

103 Fire Brigade and Fire Response 2

104 Fire Protection Systems and Features 2

105 Fire Detection and Alarm System 2

106 Fixed and Automatic Fire Suppression 2

107 Manual Fire Suppression Equipment 2

108 Fire Barriers (Thermo-Lag Raceway Protection) 2(3) 109 RCP Oil Collection I

110 Post Fire Safe Shutdown Capability 2

111 Fire Hazards Analysis 1

112 Safe Shutdown Analysis (*)

2(3) 113 Post Fire Safe Shutdown Area & Systems Selection(*)

2(3) 114 Hot & Cold Shutdown Procedures(*)

2(3) 115 Electrical System Protection 2

116 Post Fire Safe Shutdown Implementation 3

117 Fire Protection & Post Fire/QA QC Audits 1

118 Surveillance Testing & Maintenance Program 1

119 Operability Assessment & Comp Measures 2

120 Post Fire Safe Shutdown Configuration Control 1

121 Potential Fire Protection Vulnerabilities 1

Level 1 = based on adequacy of previous inspections, audits, and assessments, this assessment area was not revisited.

Level 2 = assessment areas of on-going fire protection program to supplement previous inspections, audits and assessments. Performed on a sample basis, with sample expansion, as necessary.

Level 3 = assessment areas where significant developments since previous reviews warrant in-depth vertical slice type reviews to assure that a particular program attribute meets design or licensing bases.

Level 3 review performed for RCP seal cooling