ML17285A997
| ML17285A997 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/01/1990 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A996 | List: |
| References | |
| EA-86-070, EA-86-70, NUDOCS 9002070452 | |
| Download: ML17285A997 (5) | |
Text
NOTICE OF VIOLATION Washington Public Power Supply System
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- Richland, Mashington Docket No.
50-397 License No.
NPF-21 EA 86-070 During NRC inspections conducted during the periods of March 3-24,
- 1986, January 12-15,
- 1987, June 6-10, 1988 and October 23-27, 1989, violations of NRC requirements were identified.
These violations involved the implementa-tion of the fire protection program.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions",
(1989), the violations are set forth below:
I.
WNP-2 operating license condition No. 2.C(14) requires that all provisions of the approved Fire Protection Program be maintained in effect.
The approved Fire Protection Program is described in Appendix F of the WNP-2 FSAR.
FSAR Appendix F, Section F.4.2 states that the WNP-2 plant complies with the safe shutdown requirements of 10 CFR Part 50, Appendix RE 10 CFR Part 50, Appendix R,Section III.G (Fire Protection of Safe Shutdown Capability) requires that:
1.
Fire protection features shall be provided for structures,
- systems, and components important to safe shutdown.
These features shall be capable of limiting fire damage so that:
a.
One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control stations is free of fire damage; and b.
Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
2.
Where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:
a.
Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier;
Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or c.
Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a
1-hour rating.
In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
10 CFR Part 50, Appendix R, Sections III.G.3 and III.L (Alternative and Dedicated Shutdown Capability) require that where the protection prescribed by Section III.G.2 of Appendix R cannot be provided:
1.
Alternative or dedicated shutdown capability provided for a specific fire area shall be able to...(a) achieve and maintain subcriticality conditions in the reactor...(b) maintain reactor coolant inventory...
During the post fire shutdown,...there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary.
2.
The performance goals for the shutdown functions shall be...(a) the reactivity 'function shall be capable of achieving and maintaining cold shutdown reactivity conditions...(b) the reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWR's...(c) the reactor heat removal function shall be capable of achieving and maintaining decay heat removal...(d) the process monitoring function shall be capable of providing direct reading of the process variables...(e) the support functions shall be capable of providing the process cooling, lubrica-tion, etc., to permit operation of the equipment used for safe shutdown functions.
Contrary to the above, the licensee failed to provide adequate protection to enable operation of one train of safe shutdown equipment, and the licensee failed to provide alternate or dedicated safe shutdown capability as follows:
A.
As of March 3, 1986, the WNP-2 plant had not provided the fire protection features required to ensure that at least one train of safe shutdown equipment would remain free of fire damage, in that:
1.
Required electrical circuit isolation and fire barrier protection had not been provided to ensure post fire availability of at least one train of either the High Pressure Core Spray/Reactor Core Isolation Coolant (HPCS/RCIC) or Atmospheric Depressuriza-tion System/Low Pressure Coolant Injection (ADS/LPCI) shutdown methods for achieving hot shutdown.
In particular, required electrical circuit isolation had not been provided for the Division I ADS valves from the Control
- Room, and fire barrier protection (Thermolag) had not been provided for the Division II
C.
D.
Emergency Diesel Generator, Residual Heat Removal (RHR) and Service Water System, and process instrumentation cabling located in the Reactor Building, the Cable Chase and the Cable Spreading Room.
2.
Required electrical circuit isolation for the Division II Emergency Diesel Generator, and the RHR and Service Water Systems from the Control Room had not been provided at remote emergency control stations.
As of March 3, 1986, inadequate fire barriers were provided in that less than the required length (9 inches rather than 18 inches) of Thermolag fire barrier protection was installed on raceway supports and intruding steel to electrical raceways containing Division II Emergency Diesel Generator, RHR and Service Water System safe shutdown electrical circuits on elevations 501 feet and 522 feet of the Reactor Buildinq.
At four different locations, the seismic supports for electrical raceways containing these safe shutdown circuits at Node No.
3454 on the 501 foot elevation of the Reactor Building, and electrical cable No.
2NS4232 for the Division II Emergency Diesel Generator, had no Thermolag fire barrier material installed.
As of June 7,
- 1988, two cable trays containing Emergency Diesel Generator safe shutdown cabling had no Thermolag fire barrier material installed at Node Nos.
7914 and 7915 in the Reactor Building.
As of March 3, 1986, seven cable trays traversing the 20 foot exclusion zone of the Cable Spreading Room did not have the required length of Thermolag fire-barrier material applied.
As of June 7,
- 1988, two cable trays containing Division II Emergency Diesel Generator safe shutdown cabling were not protected with Thermolag fire barrier material as required in the twenty foot exclusion zone of the Cable Spreading Room.
As of March 3, 1986, the licensee failed to provide adequate fire barrier protection for process monitoring instrumentation in that concrete block walls installed between instrument rack Nos.
E-IR-H22/P021 and E-IR-H22/P027 to shield the redundant instrumentation from a fire did not meet the specified height above the instrument racks.
Furthermore, the licensee's analysis No.
NES-7 identified instrument cable Nos.
MS-LT-26D and MS-PT-51B to the instrument racks as requiring fire barrier protection, but no fire barrier protection was provided for the cables.
E.
As of January 14, 1987, 'for the Division II Emergency Diesel Generator, Residual Heat Removal, Service Water and Containment Air Cooler System safe shutdown systems, eleven circuits located in the Cable Spreading Room and eight circuits located in the Reactor Building and Cable Chase were not protected by a qualified one hour or three hour'fire barrier, were not adequately separated and no alternate/dedicated shutdown system was provided.
The fire barriers installed on these'ables were not qualified in that the Thermolag
Notice of Violation fire barrier material was applied by the annulus pumping method rather than by the specified spraying and trowelling method.
Consequently, the fire barriers installed were in untested configurations that,did not meet the required fire ratings.
This is a Severity Level II problem (Supplement I) ~
II.
10 CFR Part 50, Appendix R, Section III.G requires, in part, that:
Where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, means of ensuring that one of the redundant trains is free of fire damage shall be provided.
The means to be employed shall be separation of cables and equipment and non-safety circuits of redundant trains by a fire barrier having a 3-hour rating, or horizontal distance of more than 20 feet with no intervening combustibles and an automatic fire suppression
- system, or enclosure of the cables and equipment of one redundant train in a fire barrier having a one hour rating with fire detectors and an automatic fire suppression system installed.
Contrary to the above:
A.
As of June 11,
- 1988, the licensee's analysis of RHR system motor operated isolation valves Nos.
RHR V-8 and RHR V-9 failed to consider the fire induced effects of three phase hot shorts on intersystem pressure boundary motor operated isolation valve cabling.
As a
- result, the licensee failed to provide the required protection for the primary coolant system boundary.
B.
As of June 11, 1988, the licensee had not provided required electrical circuit isolation or fire barrier protection to prevent post-fire loss of vital 125VDC power supplies to the Division I ADS valves required for plant depressurization during a Control Room fire.
This is a Severity Level IV violation (Supplement I).
III. WNP-2 Technical Specification 6.8. 1. g requires that written procedures be established, implemented and maintained covering Fire Protection Program implementation.
Contrary to the above, on October 25,
- 1989, Revision No.
12 of Abnormal Procedure No.
PPM 4. 12. l. 1, which implements the WNP-2 Control Room Remote Shutdown capability, a required element of the Fire Protection
- Program, was not appropriate to the circumstances in that:
A.
Step No.
A. 10 incorrectly required that RHR system valve No. V-123B, instead of valve No. V-123A, be closed.
Step No, A.27 incorrectly required that cooling fan No.
RRA-FN-1 be made operable prior to RHR pump room No.
2B exceeding specified temperature limits, rather than requiring fan No.
RRA-FN-3, (which provides cooling to RHR Pump Room No. 28) to be operable.
C.
Rather than specifying the appropriate cooling equipment, Step No.
A.27 incorrectly required that Equipment No. WMA-TI-9, which is only a temperature indicator, be made operable prior to the Remote Shutdown Panel Room exceeding specified temperature limits.
This is a Severity Level IV Violation (Supplement I).
No response is required for the violations in Sections I and II above.
Corrective actions for those violations have been verified by NRC inspectors.
For the violation identified in Section III, above, pursuant to the provisi'ons of 10 CFR 2.201, Washington Public Power Supply System is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results
- achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
CLEAR REGULATORY COMMISSION Dated at Walnut Creek, California this /
day of February 1990 Martin Regional Administrator