ML20133M539
| ML20133M539 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 08/08/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| References | |
| TAC-60320, TAC-60321, NUDOCS 8508130164 | |
| Download: ML20133M539 (9) | |
See also: IR 05000369/1984028
Text
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AUG 0 81985
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Duke Power Company
/ ATTN: Mr. H. B. Tucker, Vice President
Nuclear Production Department
422 South Church Street
Charlotte, NC 28242
Gentlemen:
SUBJECT: REPORT NOS. 50-369/84-28 AND 50-370/84-25
This letter refers to your April 30, 1985 response to our Notice of Violation and
Notice of Deviation issued on March 15, 1985, concerning activities authorized
under NRC Operating License NPF-9 and NPF-17 for McGuire Nuclear Station, Units 1
and 2.
We have reviewed your response, which requests the severity level of Violation I
be mitigated and your denial of Violation IV.
Based on this review, we have
concluded for the reasons presented in the enclosure to this letter that the
violations occurred as stated in the Notice of Violation. Therefore, in accord-
ance with the requirements of 10 CFR 2.201, and within 20 days of the date of
this letter, please submit an additional response for Violation IV.
No response
is required for Violation 1.
Your response also denied Violations II, III, and V.
Based on the clarification
provided in your April 30, 1985 response, and subsequent telephone conversations
with the Duke fire protection staff, we accept your denial.
These violations
have been rescinded.
NRC Region II records have been revised to reflect their
withdrawal.
Your response alleged that backfits would result from this enforcement action,
particularly with Violations II and IV.
As previously stated, Violation II has
been rescinded, and after review by the Region II staff, we conclude that correc-
tive actions to Violation IV do not meet the criteria established for determining
that a plant-specific backfit, under 10 CFR 50.109, exists.
We have reviewed your responses to the deviations identified in Enclosure 2 of
the subject report and find them acceptable. We will examine the implementation
of your corrective actions during future inspections.
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Should you have any questions concerning this letter, we would be happy to meet
with you and discuss the matter further.
Sincerely,
/s/
J. Nelson Grace
Regional Administrator
Enclosure:
Staff Evaluation of Licensee Responses
to Inspection Report Nos. 50-369/84-28
and 50-370/84-25
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ENCLOSURE
STAFF EVALUATION OF LICENSEE RESPONSES
TO INSPECTION REPORT
50-369/84-28 AND 50-370/84-25
DATED APRIL 30, 1985
1.
Request To Mitigate the Severity Level of Violation I
As of July 18, 1984, the following safe shutdown systems /canponents at
McGuire were not provided with adequate fire protection features in order to
maintain one train free from fire damage in accordance with 10 CFR 50,
Appendix R,Section III.G.2.a. III.G.2.b, or III.G.2.c:
A.
Cabling to the valve operators for the Safe Shutdown System (SSS)
Unit 1 Turbine Driven Auxiliary Feedwater Pump (TDAFP) suction valves
ICA-161c and ICA-162c, equipment necessary to achieve and maintain hot
shutdown, did not have the required fire protection features defined in
Sections III.G.2.a
III.G.2.b, or III.G.2.c.
This cabling is located
within the Unit 1 pipe chase and mechanical penetration room. No fire
suppression system was provided in these areas.
B.
Control cables for both the Unit 1 Train "A" and Train "B" pumps of the
centrifugal charging and auxiliary feedwater systems, systems necessary
to achieve and maintain hot shutdown, did not have the required fire
protection features as defined in Section III.G.2.a. III.G.2.b, or
III.G.2.c.
These cables are located within the same Unit 1 Train "B"
switchgear room.
No fire suppression system was provided in this area.
The above Unit 1 related Appendix R deficiencies as noted by the inspection
report, were discovered by Duke, reported to the NRC appropriately upon
their discovery, and corrective actions were implemented.
However, these
deficient conditions were in violation of fire protection requirements
established to protect or enable operation (i.e., lack of automatic fire
suppression and/or fire barrier) of safe shutdown equipment such that a
fire, if it were to occur in those areas identified above, could damage
equipment to the extent that safe hot standby could not have been achieved
and maintained using the equipment dedicated for this purpose. Based on the
seriousness of these deficient conditions, this violation was categorized as
a Severity Level III violation. Therefore, this violation does not meet the
tests delineated in NRC enforcement policy,10 CFR Part 2, Appendix C for
non-issuance of a Notice of Violation.
In addition, in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Action,"
10 CFR Part 2, Appendix C, the base civil penalty assessed for this type of
violation is $50,000.
In recognition of Duke Power Company's discovery of
these deficient conditions, the reporting of these conditions immediately
upon their discovery and the actions taken to preclude their recurrence, the
civil penalty was mitigated in its entirety.
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Enclosure
I
With regard to the mitigation of potential violation co
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conditions met the Severity Level IV criteria of 10 CFR
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Unit 2 related turbine driven and motor driven auxiliary feedwater pump
Thus, the conditions described in paragraphs 9.a and 9.b(3) of the
inspection report are not similar to the conditions of the corresponding
rooms.
Unit 1 areas identified by Violation I.
In summary, we conclude that the violation, as cited in the Notice of
Violation, will remain as a Severity Level III violation.
Given that there are specific requirements, this is not a plant-specific
backfit issue.
Acceptance of Licensee's Denial of Violation II
2.
the following circuits were identified as having a
common power source with shutdown equipment and the power source was no
As of July 18, 1984,
in
properly electrically protected from the circuit of concer
lacked circuit breaker and/or fuse coordination:
125 VDC control power for Centrifugal Charging Pumps CCPA or CCPB fro
A.
panels EVDA or EVDD, respectively.
600 VAC power supply for auxiliary feedwater supply Motor Operated
Valves (MOVs)CA46B,CA50B,CA54AC,andCA58A.
B.
600 VAC power supply for PORV block valves MOVINC318 and MOVINC358.
C.
600 VAC power supply for RHR isolation valve MOVINDIB.
D.
600 VAC power supply for Turbine Driven Auxiliary Feedwater Pump
E.
(TDAFP)SuctionvalveCA7A.
600 VAC power for nuclear service valve RN16B (sic. - RN-1628).
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F.
600 VAC power for Volume Control Tank (VCT) outlet valves NV141A a
G.
NV142B.
600 VAC power for Component Cooling Pump (sic. - Centrifugal Charging
Pump) (CCP) suction valves for RWST NV221A and NV222B.
H.
We have reviewed your denial of the above alleged violation and with rega
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to the normal shutdown systems, your response indicated that the lack o
In addition, your
fuse / breaker coordination existed for the examples cited.
response indicated that only one train of the two normal shutdown systems
would be affected by the lack of electrical protection and that the
unaffected shutdown train could be utilized to achieve and main
standby conditions.
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Enclosure
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conclude that these cases were analyzed in detail. The following summarizes
the results of your analysis with regard to the fuse / breaker coordination
deficiencies identified in the violation:
A.
For cases specifically cited in Items B, D, E, and G, the valve is
already in the required shutdown position auring plant operation, is
-not subject to spurious operation, and, therefore, motive power or
subsequent operator action is not required.
B.
For other cases cited in Items A, C, F, and H, adequate time is avail-
able for operator action, procedures were provided to operations
personnel, and manpower availability verified.
In addition, further discussions with your staff have clarified that the
redundant circuits cited in the violation were separated and routed through
different fire areas.
The RHR isolation valves are made inoperable during
normal operation by opening their respective power breakers. The PORV block
valves are a defense-in-depth measure to back up the PORVs which have power
removed when a reactor trip occurs.
The PORVs fail closed on a loss of
power.
Based on your response to this violation and our subsequent
discussions with your staff, the information presented appears to be
adequate with respect to satisfying the requirements of Appendix R
associated circuit common bus and spurious signal concerns.
Therefore, we
have withdrawn the subject violation.
3.
Acceptance of Licensee's Denial of Violation III
Unit 1 Operating License Section 2.c.(4) and Unit 2 Operating License
Section 2.c.(7) require the licensee to fully implement and maintain, in
effect, all provisions of the approved fire protection plan.
The approved
fire protection plan includes the McGuire Nuclear Station Fire Protection
Review, Revision September 1982.
Section F.11 of the referenced document,
Safety-Related Pumps, indicates that redundant safety-related pumps are
separated by fire barriers and that automatic fire detection with alarm and
annunciation is provided in the control room.
Contrary to the above, at the time of this inspection, the following safety-
related pumps identified in Appendix C of the McGuire Nuclear Station Fire
Protection Review were not separated by a fire barrier.
A.
Recycle Evaporator Feed Pumps, Room 620
B.
Waste Drain Tank Pumps, Room 639
D.
Boron Injection Recirculation Pumps - Unit 2, Room 788
D.
Boron Injection Recirculation Pumps - Unit 1, Room 730
E.
Fuel Pool Cooling Pumps - Unit 1, Room 816
F.
Fuel Pool Cooling Pumps - Unit 2, Room 829
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Enclosure
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In addition, the following safety-related pumps were not provided with
automatic fire detection capabilities:
A.
Recycle Evaporator Feed Pumps, Room 620
B.
Waste Drain Tank Pumps, Room 639
C.
Fuel Pool Cooling Pumps - Unit 1, Room 816
D.
Fuel Pool Cooling Pumps - Unit 2, Room 829
In your response to the above alleged violation, you state that the pumps
noted in Items A - F are only classified safety-related due to their
existence in an ASME Section 3 system maintaining pressure boundary.
With
the exception of the Fuel Pool Cooling Pumps, these pumps do not receive
blackout or 1E power. The pumps do not provide a safe shutdown function and
are not needed for mitigation of an accident, nor are they required for the
safe shutdown of the plant.
We have reviewed Section F.11 and Appendix C of the McGuire Nuclear Station
Fire Protection Review and conclude that Appendix C (Fire Hazards Analysis)
clearly defines where fire barriers and detectors are provided and that a
fire which causes damage to both redundant trains of the subject pumps would
not impact the plant's ability to achieve and maintain safe shutdown
condition. Therefore, the provisions of fire barriers and detectors for the
subject pumps would not improve the safe shutdown capabilities of the plant.
By letter dated November 30, 1984, from H. B. Tucker to J. P. O'Reilly, you
committed to update the McGuire Fire Protection Review by October 1,1985.
It is our understanding, as a part of this revision, Section F.11 will be
revised to indicate that only those pumps required for safe shutdown will be
separated by fire barriers and will have fire detectors.
In addition, it is
our understanding that the proposed October 1, 1985, revision to the McGuire
Fire Protection Review will be submitted to the NRC for review.
Therefore, on the basis of the information you have presented in your
response, we have withdrawn the subject violation.
4.
Denial of Violation IV
Duke Power's corrective actions taken for the deficiencies identified by the
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June 1, 1984 Nonconformance Report and Violation 1, as discussed above,
consisted of the installation of fire rated barrier enclosures for valves
2CA-161C, 2CA-162C, ICA-161C, ICA-162C and their associated cables.
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10 CFR Part 50, Appendix R, Section III.G.2.a specifically states that for
these fire barriers
" 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."
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Enclosure
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At the time of the inspection, the structural steel members supporting the
following fire barrier assemblies were not protected at McGuire with a fire
proofing material which had a fire resistive rating equivalent to that of
the fire barrier assembly in that:
A.
A one-hour fire barrier enclosure for valves 2CA-161C and 2CA-162C and
associated cabling was not sufficient in that the structural steel
members ' supporting the fire barrier were not protected to assure a
one-hour fire rating as required by Section III.G.2.c.
B..
Valves 1CA-161C and ICA-162C and portions of their associated cabling
are enclosed in a three-hour rated fire barrier.
However, the
structural steel members supporting the fire barrier were not protected
to assure a three-hour fire rating as required by Section III.G.2.a.
In the attachment to your April 30, 1985 letter, you provide an explanation
.for denying the.above alleged violation.
In your explanation you reference
. the May 7,
1984 Regional Workshop and Enclosure 1. Interpretations of
Appendix R, which was distributed to the Region II licensees during the
workshop.
In your response you specifically reference the fire area
boundary criteria identified in Item 5 of Enclosure 1 as the basis for your
denial of the violation.
However, the fire area boundary evaluation
criteria addressed in Item 5 is not specifically related to maintaining one
train of safe shutdown systems free from fire damage. Enclosure 1 Item 3,
Fire Damage states, "In promulgating Appendix R, the Conunission has provided
methods acceptable for assuring that necessary structures, systems and
components are free of fire damage (see e.g., Sections III.G.2.a. b and c),
that is the structure, system or component under consideration is capable of
performing its intended functions before, during and after the postulated
fire, as needed."
In addition, Enclosure 2 Questions Raised During The
Nuclear Utility Fire Protection Seminar, question Category II, Structural
Steel, ~ response to Question B states, " exposed steel, such as cable tray
,
supports, need to be protected if their failure, because of a fire, would
result-in the loss of the integrity of the fire barrier."
In your response, you also indicated that the need to protect the subject
cables was determined in June and July 1984, and based on the information
provided in the Regional Appendix R Workshop and Attachment 1 to all licen-
sees subject to Appendix R to 10 CFR 50, dated March 3,1984, Enclosure 1,
your staff determined, utilizing the fire area boundary evaluation criteria,
that fi_re proofing of the structural steel cable tray supports was not
required.
During the inspection the inspectors reviewed the fire test
documentation for the raceway fire barrier assemblies and your fire area
boundary evaluations for the subject areas.
The fire test report which
documents the test results for the one-hour raceway fire barrier designs
qualified the fire barrier enclosure materials ability to protect approxi-
mately 12 feet of electrical raceway supported by the fire resistive furnace
walls.
Therefore, this test did not qualify a protected raceway
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Enclosure
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span which exceeds 12 feet between fire resistive raceway supports.
In
. addition, the inspectors reviewed the fire area boundary evaluations for the
Unit 2 motor driven auxiliary feedwater pump room and Unit 1 mechanical pipe
chase.
These evaluations did not consider the May 7,1984 Regional Fire
Protection Workshop guidance provided to Region II licensees in Enclosure 1,
Item.3 criteria for maintaining one train of safe shutdown systems free from
fire damage, Enclosure 2, Question Category II, Question B, protection of
structural steel supports supporting cable trays and the defense-in-depth
fire protection engineering principles provided in NUREG 0800, Standard
Review Plan 9.5.1 Fire Protection Program.
Defense-in-Depth Principle C stipulates that plant safety systems should be
designed in such a manner that if a fire that gets started, in spite of the
fire prevention program, and burns for a considerable time, in spite of the
fire protection activities, the fire will not prevent essential plant safety
functions from being performed.
In your response to the subject violation,
you indicated that the potential fire severity based on all in-situ
combustible materials in the Unit 2 motor driven auxiliary feedwater pump
room to be approximately twelve minutes and about nine minutes in the Unit 1
mechanical pipe chase.
This equates to 'a temperature of approximately
1325 F and 1240 F, respectively, when compared to the ASTM-E119 standard
time temperature curve.
This appears to be consistent with your fire area
boundary evaluations for the subject areas; however, your evaluation did not
consider, in spite of the fire protection activities, the effects of a fire
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which is not effectively controlled or suppressed.
Since structural steel
begins to lose its structural integrity when exposed to temperatures of
1000 F for about five minutes, the potential exists in the Unit 2 auxiliary
feedwater pump room and Unit 1 mechanical pipe chase that a fire could cause
structural deformation to the steel supports supporting the protected
raceway in the subject areas. Therefore, the failure of the steel supports
could lead to the failure of the raceway fire barrier assembly and could
potentially cause both redundant trains of safe shutdown systems to sustain
fire damage.
We conclude that the fire protection features required by 10 CFR 50,
Appendix R,Section III.G.2 have not been fully implemented in the Unit 2
motor driven auxiliary feedwater pump room and Unit 1 mechanical pipe chase.
Furthermore, our review indicates that by letter dated January 9, 1981, Duke
committed to implement three issues,Section III.0,Section III.J., and
Section III.G., identified in Appendix R to 10 CFR 50.
This commitment is
reflected in Supplement No. 5 to the SER dated April 1981. Supplement No. 6
to the SER states that additional licer.see information concerning
Sections III.G., III.J., and III.0., was reviewed and no deviations to these
requirements were identified.
Additionally, these issues were reflected in the license conditions for the
plant.
Therefore, based on the above, we conclude that the corrective
action to Violation IV is not a plant-specific backfit issue.
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Enclosure
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5.
Acceptance of Licensee's Denial of Violation V
Contrary to the above, at the time of this inspection, the following plant
areas were identified as not having adequate emergency lighting in
accordance with the requirements of Appendix R Section III.L:
A.
Several lighting units in the Unit 1 interior doghouse were mounted
behind concrete columns, piping, and other similar structures and/or
components which eliminated their effectiveness to illuminate access
ladders to safety shutdown valves.
B.
No 8-hour, battery-powered lighting units were provided for the Unit 1
and Unit 2 corridor 908 which provides a portion of the access and
egress route between the main control room and the Standby Shutdown
Facility.
In your response to the above alleged violation, you indicated that in the
Unit 1 interior doghouse there are two battery-powered lighting units on
elevation 767 which illuminate the path from the entrance door to a ladder
which operators may need to access in order to operate safe shutdown valves.
In addition, you indicated that in order to enhance the lighting in the area
of the ladder, a plant modification will be made to reposition a bulb of
lighting Unit 20T.
In further discussions with your staff regarding the emergency lighting
discrepancy associated with corridor 908, it was detennined that the double
non-fire rated doors at the end of the subject corridor have been removed.
Your staff indicated that this was done in order to enhance the existing
emergency lighting and provide assurance that the corridor would be
adequately lighted.
Therefore, on the basis of the information you have presented in your
response and the subsequent discussions with your staff, we have withdrawn
the subject violation.
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