ML20137M302
| ML20137M302 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/03/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| References | |
| EA-96-512, NUDOCS 9704080057 | |
| Download: ML20137M302 (78) | |
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NUCLEAR REGULATORY COMMISSION R EGloN IV
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611 RY AN PLAZA oRIVE, SUITE 400 N'o....+8 AR LINGToN, TEXAS 760118064 APR - 3 SPT EA 96-512 C. Randy Hutchinson, Vice President Operations Arkansas Nuclear One Entergy Operations, Inc.
1448 S.R. 333 Russellville, Arkansas 72801-0967
Dear Mr. Hutchinson:
SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE OF MARCH 28,1997 This refers to the meeting conducted in the Region IV office on March 28,1997. This meeting related to two apparent violations involving inadequate fire protection design l
features for the reactor coolant pump lobe oil collection systems for Units 1 and 2; and inadequate corrective actions for three prior instances of observed oil leakage in Unit 1, i
discussed in NRC Inspection Report 50-313;-368/96-27. The predecisional enforcement conference agenda, the attendance list, and the licensee presentation are included as Enclosures 1,2, and 3, respectively. Enclosure 3, licensee presentation, does not include the copied documentation sections of "An Introduction to Fire Dynamics," by Dougal Drysdale; "FPA Guide to Safety with Piped Services"; and " Spontaneous Combustion of i
Oil-Soaked Thermal Insulations," an ASME Publication, in accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Should you have any questions concerning this matter, we will be pleased to discuss them with you.
Sincerely, bw h
[ Arthur T. Howell lil, Director Division of Reactor Safety Docket Nos.: 50-313;50-368 License Nos.: DPR 51; NPF-6 9704080057 970403 PDR ADOCK 05000313 G
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Arkansas Nuclear One
Enclosures:
- 1. Precedecisional Enforcement Conference Agenda
- 2. Attendance List -
- 3. Licensee Presentation cc w/ Enclosures 1 and 2:
Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President Operations Support Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286 Manager, Washington Nuclear Operations ABB Combustion Engineering Nuclear Power i
12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 i
County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Winston & Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502 Bernard Bevill, Acting Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rcck, Arkansas 72205-3867 Manager Rockville Nuclear Licensing Framatome Technologies 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852 Y
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l Arkansas Nuclear One l l
l E-Mail report to T. Boyce (THB) l E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK) bec to DCD (IE01) bec distrib. by RIV w/ Enclosures 1,2, & 3:
l Regional Administrator Resident inspector DRP Director MIS System l
Branch Chief (DRP/C)
RI V File Project Engineer (DRP/C)
DRS-PSB Branch Chief (DRP\\TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
DOCUMENT NAME: R:\\_ANO\\AN627MS.CAV To receive copy of document. Indicate in box: "C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy RIV:C:EB E
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. E-Mail report to T. Boyce (THB) l
. E-Mail report to NRR Event Tracking System (IPAS)
E Mail report to Document Control Desk (DOCDESK) bec to DCD'(M bec distrib. by RIV w/ Enclosures 1,2, & 3:
Regional Administrator Resident inspector
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DRP Director MIS System.
Branch Chief (DRP/C)
RI V File I
' Project Engineer (DRP/C)
DRS-PSB Branch Chief (DRP\\TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10) i I
l DOCUMENT NAME: R:\\_ANO\\AN627MS.CAV To receive copy of document, indicate in box: "C" = Copy weout enclosures "E" = Copy we enclosures "N" = No copy RIV:C:EB E
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OFFICIAL RECORD COPY 080010'
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ENCLOSURE 1 PREDECISIONAL ENFROCEMENT CONFERENCE AGENDA 1
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7 PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA CONFERENCE WITH ENTERGY, INC MARCH 28,1997 NRC REGION IV, ARLINGTON, TEXAS 1.
INTRODUCTIONS / OPENING REMARKS - JIM DYER, DRA 2.
ENFORCEMENT PROCESS - GARY SANBORN, RIV ENFORCEMENT OFFICER 3.
APPARENT VIOLATIONS & REGULATORY CONCERNS - ART HOWELL, DD/DRS BRANCH CHIEF 4.
LICENSEE PRESENTATION -
5.
BREAK (10-MINUTE NRC CAUCUS IF NECESSARY) 6.
RESUMPTION OF CONFERENCE 7.
CLOSING REMARKS - LICENSEE 8.
CLOSING REMARKS - ART HOWELL, DD/DRS i
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APPARENT VIOLATIONS
- PREDECISIONAL ENFORCEMENT CONFERENCE ENTERGY OPERATIONS, INC.
J ARKANSAS NUCLEAR ONE UNITS 1 AND 2 MARCH 28,1997
- NOTE: THE APPARENT VIOLATIONS OlSCUSSED AT THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND MAY BE REVISED PRIOR TO ANY RESULTING ENFORCEMENT ACTION.
APPARENT VIOLATION:
1.
10 CFR 50 Appendix R, Section ll1.0 states in part:
"The reactor coolant pump shall be equipped with an oil collection system if the containment is not inerted during normal operation."
"Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems.
" Leakage points to be protected shallinclude lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on reactor coolant pumps."
Contrary to the above:
From March 1995 to October 17,1996, the licensee failed to protect the lift oil piping on the Unit 1 B Reactor Coolant Pump; the lift oil piping on the four Unit 2 Reactor Coolant Pumps; the lower reservoir sightglass on the Unit 1 A, C, D, and all four Unit 2 Reactor Coolant Pumps; and the oil filllines on all four Unit 1 and Unit 2 Reactor Coolant Pumps.
THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED
l APPARENT VIOLATION-l l
2.
10 CFR Appendix B Criteria XVI states:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of i
significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The 1
identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to the j
appropriate levels of management."
Contrary to the above; f
A.
On October 9,1996, the licensee personnel identified a crack in a weld on the Unit 1 B Reactor Coolant Pump lift oil piping, which resulted in oil accumulation in the fibrous insulation of Steam Generator B. This condition adverse to quality was not identified and corrected, nor was the cause and corrective action taken documented and reported.
B.
On October 15,1996, the licensee identified oil in tic containment on the insulation adjacent to the reactor coolant pumps. This condition adverse to quality was not identified and corrected, nor was the cause and corrective action taken documented and reported.
C.
On October 17,1996, licensee personnel identified oil-soaked insulation which was smoking excessively. This condition adverse to quality was not identified and corrected, nor was the cause and corrective action taken documented and reported.
THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED 1
0 ENCLOSURE 2 ATTENDANCE LIST 1
3 PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDANCE LICENSEE / FACILITY Entergy Operations. Inc.
Arkansas Nuclear One. Units 1 and 2 DATE/ TIME March 28. 1997. 10:30 a.m.. CST CONFERENCE LOCATION Region IV. Training Conference Room Arlington. TX EA NUMBER EA 96-512 LICENSEE REPRESENTATIVES NAME (PLEASE PRINT)
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.,.c PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDANCE LICENSEE / FACILITY Entergy Operations. Inc.
Arkansas Nuclear One. Units 1 and 2 DATE/ TIME March 28. 1997, 10:30 a.m.. CST CONFEPsENCE LOCATION Region IV. Training Conference Room Arlington. TX EA NUMBER EA 96-512 LICENSEE REPRESENTATIVES NAME (PLEASE PRINT)
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Arkansas Nuclear One. Units 1 and 2 DATE/ TIME March 28. 1997. 10:30 a.m.. CST CONFERENCE LOCATION Region IV. Training Conference Room Arlington. TX EA NUMBER EA 96-512 NRC REPRESENTATIVES-NAME (PLEASE PRINT)
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Agenda
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l Opening Remarks............................................... Randy Hutchinson Vice-President, ANO In troductio n.......................................................... D w i gh t Mims Director, Nuclear Safety Management Overview........................................ Randy Edington l
GeneralManager, ANO Eve n t Ove rview.................................................... C h arlie Zimme rman Plant Manager, Unit 1 Event Root Cause and Corrective Actions.......... Bill Greeson Supervisor, Unit 1 System Engineering ANO RCP Lube Oil Collection System............... Don Lomax Manager, EngineeringPrograins Oil Collection System Corrective Actions........... Rick Lane Director, Design Engineering Enforcement Perspective..................................... Dwight Mims Director, Nuclear Safety Conclusion............................................................ R andy Hutchins on Vice-President, ANO.
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Introduction f
Dwight Mims l
Director, Nuclear Safety
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Z Management Overview Randy Edington GeneralManager, ANO s
Overview Fire was preventable Condition report required by procedure Lagging fire phenomenon (auto-ignition temperature reduction)
RCP oil collection systems upgraded
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Event Overview l
Charlie Zimmerman l
Plant Manager, Unit 1 i
Condition Description
- - _ =
On October 17, : 996, during RCS heat-up, a fire occurred in the Unit 1 reactor building The fire was caused by oilleaked from a cracked weld in the discharge piping of the "B" reactor coolant pump (RCP) motor high pressure lift oil l
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2 Location of Cracked Weld in the Discharge Piping of the "B" RCP Motor High Pressure Lift Oil Pump y
Event Overview l
=__
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= _ _ _
Events prior to fire
- 1R12 (Spring 1995) "B" RCP motor replaced with a French designed motor
- September 15,1996 "B" RCP secured following RCS cooldown < 280 degrees t
Lift oil pump ran for ~17 hours j
- October 9,1996 - Crack in lift oil pump piping discovered j
Discovered during post-maintenance testing l
Run time of ~15-30 seconds Minimum oil spilled - cleaned up t
- October 13, 1996 - Cracked weld repaired and leak tested J
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Event Overview l
Heat-up sequence (October 17,1996)
~0010 - Heat-up commenced
~0900-1030 RCS Temperature ~360 degrees Electrician reported oil-soaked insulation and excessive smoke 1
in reactor building
- Report to electrical maintenance supervisor
- Supervisor reported smoke to outage desk Fire Prevention Coordinator contacted by outage desk i
- Material Safety Data Sheet (MSDS) for the RCP motor oil 4
was reviewed l
Oil flashpoint was 400 degrees Auto-ignition point was believed to be well above flashpoint i
- Insulation in area was covered with flashing and believed to -
be mirror i
- Concluded oil did not represent a fire hazard A
Event Overview 9
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. Heat-up sequence (October 17,1996)
~1130 - RCS temperature 430 degrees and stabilized
~1545 - Fire Prevention Coordinator began sampling.for air quality as requested by Outage Desk
~1607 - Fire reported to Control Room by Fire Prevention ~ Coordinator
- RCS temperature ~450 degrees
- Two operators (qualified fire brigade) in the reactor building responded
~1617 - Notification of Unusual Event (NUE) declared
~1623 - Fire extinguished
- CO2 and a light fog spray (<50 gallons) used to extinguish fire i
~1635 - RCS Cooldown initiated
~1735 - NUE terminated based on
- Fire extinguished
- Reflash watch established
- RCS temperature below oil flash point d
6 Event Overview Post Fire Actions
- Issued six prior to heat-up corrective actions (day of fire)
- Brought in forensic fire protection engineer (next day)
-- Initiated a multi-disciplined root cause investigation headed by a system engineering supervisor
- Investigation produced a thorough set of corrective actions i
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=-;_==- _ _ - ---------------::-----------------------------
Unit 1 Reactor Building Fire Event Root Cause Evaluation and Corrective Actions i
Bill Greeson Supervisor, Unit 1 System Engineering I
Event Root Cause Evaluation and Corrective Actions
=
Discussion Topics
- Apparent violation involving the failure to identify and take prompt corrective action for three prior instances of observed oil leakage
- Root cause evaluation of the Unit 1 Reactor Building Fire Event l
- Corrective actions associated with the Unit 1 Reactor Building Fire Event 4
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Event Root Cause Evaluation
= _
_ _ = _
Apparent violation involves the failure to identify and take prompt corrective ~ action for three instances of observed oilleakage
- Oilleakage caused by cracked weld
- Reports of excessive smoke and oil-soaked insulation
- Oil on reactor building floor identified by radiation protection (RP) personnel 4
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Event Root Cause Evaluation l
=
=_
October 9,1996 - Oilleakage caused by cracked weld discovered
- Small amount of oil missing from reservoir
- Light oil film in vicinity of RCPs not viewed as abnormal
- Not known when crack developed Conclusion at time of occurrence
- Repair weld defect, clean up small amount of oil spilled l
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Event Root Cause Evaluation October 17,1996 - Reports of excessive smoke and oil-soaked insulation
- Communication issues
- Use of MSDS sheets led to nonconservative conclusions
- Some level of smoke during heat-up not unexpected Conclusion at time of occurrence
- Continue heat-up 6
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Event Root Cause Evaluation
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Oil on reactor building floor identified by RP personnel Characterized as infrequent-droplets of oil Xot considered as potential fire hazard Conclusion at nime of occurrence Housekeeping issue I
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i Event Root Cause Evaluation
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Root Cause Team
- System Engineering lead Supported by six engineering groups Supported by forensic fire protection engineer
- Investigation included:
Walkdowns, interviews, document reviews, and evaluations of equipment Short term effects of fire and fire suppression activities evaluated
- Major focus:
Assure plant safety Establish root cause and contributing causes Develop comprehensive immediate and long term corrective actions to prevent recurrence
l Event Root Cause Evaluation Root Cause
- Fabrication defect in the weld in the discharge piping of the "B" RCP motor high pressure lift oil pump Contributing Causes
- Unknown potential for auto-ignition temperature to be reduced (lagging fire phenomenon) i l
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- Personnel not appropriately sensitive to smoke during l
heat-up l
- Communication issues I
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Event Corrective Actions
==
Immediate
- Plant cooldown was initiated after fire
- Immediate actions in place prior to heat-up from 1R13 l
The near-term effects of fire and fire suppression activities evaluated
- Did not affect any safe shutdown equipment Oil-fouled and damaged fibrous insulation replaced Interim measures established to safely operate with high pressure lift oil pump (hold card and administrative controls)
Modification made to high pressure lift oil pump interlock Interim strategy for heat-up which included specifically monitoring for smoke and oilleakage RCP motor oil collection system on all four pumps enhanced Unit 2 RCP motor oil collection system reviewed
Corrective Actions Root Cause - Weld defect l
- High pressure lift oil pump on "B" RCP (new motor) is currently tagged out (administrative controls for usage)
- Additional shrouding added to "B" RCP high pressure lift oil pump piping
- Complete evaluation of remaining high pressure lift oil pump piping welds and develop plan for inspection to insure no additional questionable welds remain on piping system (1R14)
- Investigate Jeumont's piping design and manufacturing process (prior to 1R14)
- Investigate any potential breakdowns in specifying RCP motor (prior to 1R14)
Corrective Actions
~
= _ __-
Contributing Cause - Unknown potential for auto-i l
igniuion temperature to be reduced
- Developed and implementing training (prior to 2R12)
Causes oflagging fires l
Limit.tions of MSDS information
- Operating Experience report was issued Phenomenon of auto-ignition temperature reduction of oilin fiber insulation
- The Abnormal Operating Procedures for Fire and Explosion have been modified to provide a warning concerning potential reduction of auto-ignition i
temperatures of oil-soaked insulation
Corrective Actions ContributingUause - Personnel not appropriately sensitive to smoke during heat-up
- Developed and implementing training (prior to 2R12) l Lessons learned on response to smoke or oil spills
- The procedure for Containment Closeout was revised to l
provide specific instructions for inspections for oil leaks i
and spills
- Plant Startup and Shutdown procedures have been modified to emphasize monitoring for smoke, oil vapor and on leaks
- The Abnormal Operating Procedures for Fire and Explosion have been modified to provide guidance to operators on how to respond to reports of smoke.
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Corrective Actions 1
Contributing Cause - Communications 1
1 j.
- Developed and implementing training (prior to 2R12) i i
Lessons learned on communications t
Other l-
- Trending program developed for RCP oil usage utilizing new remote oil levelinstrumentation
- Electrical Maintenance personnel were trained on importance of Appendix R requirements for the RCP lube oil collection systems
- Enhancements of condition reporting procedure I
Fire Protection section added to Attachment A guidelines:
- Speci5cally identifies RCP oil collection capability l
- Specifically identifies equipment oil leaks or spills
- Designates specific personnel to evaluate questionable conditions
- Existing fiber insulation to be evaluated for removal or marking (prior to 2R12 & 1R14)
Event Root Cause Evaluation L
and Corrective Actions i
l
==
Conclusions:==
- Condition report required for cracked weld failed to meet Appendix R requirements
- The potential for auto-ignition temperature ofliquids to be reduced (lagging fire phenomenon) - unknown to ANO and industry
- Root Cause Evaluation thorough and broad based Independent forensic fire protection engineer l
- Immediate and long term corrective actions timely, l
comprehensive, and focused on plant safety l
l Extensive training l
Plant modifications Procedure changes
l i
---__a__-_=-_
ANO RCP Lube Oil Collection System Don Lomax Manager, Engineering Programs i
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Collection System Apparent violation of 10 CFR Part 50, Appendix R
- The lube oil collection systems for the "B" RCP in Unit 1 and all the RCPs in Unit 2 had not been designed to collect oilleakage from all pressurized and unpressurized locations
- The Unit 1 "A", "C", and "D" RCP lube oil collection systems were not maintained to collect oil from unpressurized locations l
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ANO RCP Lube Oil Collection System Apparent violation of 10 CFR Part 50, Appendix R
- Agree with violation Drip protection on some low pressure components for both Units 1& 2 RCPs Spray protection for flanged connections on Unit 1 "B" RCP (new l
motor) high pressure lift oil piping
- Disagree with violation Spray protection for high pressure lift oil piping for Unit 1 "B" and Unit 2 RCPs Oil collection for remote oil addition systems on both Units 1 & 2
_____________._______m
ANO RCP Lube Oil Collection System RCP oil collection regulatory history
- Pre-Appendix R RCP oil collection system design ANO/NRC correspondence began 1977 ANO response to lift pump discharge line break question:
i "No means...to collect oil...from line break in discharge piping...
pumps only run during startup and shutdown minimizing probability of break occurring..."
ANO committed to NRC staff position:
"...would collect oil leaks from the lift pump, oil cooler (if external to the reservoir), flanged or gasketed oil connections, oil level i
sight glasses, drain and fill connection points, and oil reservoirs."
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ANO RCP Lube Oil Collection System RCP oil collection regulatory history
- Detailed drawings, figures, photographs and descriptions of systems submitted
- Deficiencies XRC noted:
"No spray deflectors on flanged connections or collection 1
pans under externalpiping and flanged connections; 1
No oil collection pans around the upper reservoir to
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collect leakage from fill connections, upper bearing oil gauges, and piping to the oil level transmitter; and l
No oil collection pans to collect leakage from lower bearing oil gauge and filler lines."
- Design modifications submitted l
~
Collection System RCP oil collection regulatory history
- RCP oil collection systems accepted by XRC in 1980
- ANO letter March 1981 (post Appendix R) stated:
"It is our understanding...that our present oil collection systems... meet the requirements of Appendix R,Section III.O."
- NRC inspections in 1982 and 1983 with no violations or deviations from Fire Protection Program SERs or Appendix R
- Consistent with subsequent XRC correspondence such as IX 84-09 and GL 86-10 l
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ANO RCP Lube Oil Collection System RCP oil collection regutatory history i
- RCP oil collection systems accepted by NRC in 1980
- ANO letter March 1981 (post Appendix R) stated:
"It is our understanding...that our present oil collection systems... meet the requirements of Appendix R,Section III.O."
- NRC inspections in 1982 and 1983 with no violations or deviations from Fire Protection Program SERs or Appendix R
- Consistent with subsequent NRC correspondence such as IN 84-09 and GL 86-10
m ANO RCP Lube Oil Collection System High pressure piping spray protection
- Absence of spray / drip protection for high pressure piping on each unit was communicated
- Spray protection required only for flanged /gasketed mechanical joints
- Detailed design documents submitted / accepted
- Believed in compliance with Appendix R
- Subsequent inspections acceptable
- No generic correspondence (ins and GLs) caused ANO to believe design change required
~
Collection System Collection system for remote oil addition system
- Unit 1 Installed ~ 1987
- - Funnel with tygon tubing Currently tagged out Modifications plannedin 1R14
- Unit 2 Installed similar to Unit 1 (1991-1994)
System modifiedin 1994 l
Stainless steel tubing, manifold, and vessel JCO with exemption request submitted
..___._._....._.._._.._.-__._.-_._.....____.________.______________.____,____m.____m..___--___-
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--_____7 ANO RCP Lube Oil Collection System Collection system for remote oil addition system
- ANO's analysis - remote oil addition system not within scope of Appendix R Not part of the RCP lube oil system Not considered potentialleakage site l
- Dry system Sloped to prevent standing oillevel Above reservoir operatinglevel
- Infrequently used
- Use closely monitored Risk of oil spill lower for remote addition
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_________________.________u_
ANO RCP Lube Oil Collection System Low pressure component drip protection
- Some components could have leaks not contained
- Result of three causes:
Apparent design error
- No oil collection for Unit 2 RCPs lower level transmitters
- No oil collection for Unit 1 RCP "B" (new motor) fill connection Modification installation errors (Unit 1)
- Oillevel switches changed to transmitters (1996)
- One transmitter out of eight placed outside drip collection Potential re-orientation during use (Unit 1)
- Three sight glasses out of eight outside drip collection system
- Probably re-oriented (easily rotated) for accessibility
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ANO RCP Lube Oil Collection System Spray protection for flanged connections Unit 1 "B" RCP motor (new motor) replaced 1995 Fire Protection members of the design team-Fire Protection screening of modification resulted in:
- Revised oilinventory calculations
- Ensuring SSE design oflube oil system
- Elimination of PVC jacketed cable No Fire Protection review of high pressure piping configuration
- Design communication 7.ndicated high pressure piping within motor shroud l
e ANO RCP Lube Oil Collection System Spray protection for flanged connections High pressure piping reviewed for IN 94-58 (Haddam Neck Fires)
- Conditions not applicable to ANO RCP motor configurations No PVC fittings or air flow problems
- High pressure piping extended above the top of the oil shroud Within drip collection system Not spray protected Determined acceptable configuration
- Failed to identify flanged connections with no spray protection
.l ANO RCP Lube Oil Collection System Conclusions
- Some collection systems deficiencies did exist for low pressure reservoir components
- Spray protection not provided for some flanged connections ("B" RCP) in high pressure piping
- Based on historical correspondence Spray protection for high pressure piping (including welded joints) not required Spray protection only for mechanicaljoints (flanged or gasketed)-
- Collection system not required for remote oil addition systems beyond fill connections
- Upgraded systems meet current understanding of the requirements of Appendix R
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.._______a ANO RCP Lube Oil Collection System Corrective Actions Rick Lane l
Director, Design Engineering l
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m ANO RCP Lube Oil Collection System Corrective Actions Unit 1
- Remote oil addition system is currently tagged out
- Remote oil addition system modifications Evaluate installing hard pipe system during 1R14 JCO will be written for continued safe operation if remote addition is required during power operations "A", "C", and "D" RCP discrepancies resolved by extension of drip trays, addition of shields, etc., for drip and spray protection
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ANO RCP Lube Oil Collection System Corrective Actions
- fnit 1 (Continued)
B" RCP (new motor) enhanced with spray and drip protection for high and low pressure lube oillines
- ANO will evaluate the welding procedures utilized by Jeumont and will address the existing welds B" RCP high pressure oil system tagged out
ANO RCP Lube Oil Collection System Corrective Actions Unit 2
- Drip tray provided at the top of the "D" ring for the manifold, funnel area, and drip collection at the motor for remote oil addition system
- JCO developed for continued safe operation and Appendix R exemption request submitted for remote oil addition system
- Drip pans, shields, etc., to collect drips and sprays from low pressure piping were installed during 2F96-1
- 2F96-1 modification made to address high pressure piping for spray and drip protection
e ANO RCP Lube Oil Collection System Corrective Actions Common l
- Procedure was revised for functionality inspection of the oil collection system at the beginning of each refueling outage
- Containment Closecut procedure has been revised to require a walkdown to ensure system configuration at end of refueling outage prior to heat-up-
- Electrical Maintenance personnel were trained on importance of Appendix R requirements for the RCP lube oil collection system
ANO RCP Lube Oil Collection System Corrective Actions
~
Common (continuea)
- Station Information Management System (SIMS) was revised to contain additional guidance on RCP motors
- Tech manuals and vendor prints have been revised to address RCP lube oil collection system
- Design process procedure enhancements have been made Walkdowns after RCP motor modifications Field validation of critical design requirement / assumptions Verification process for program design input information
- Evaluate and enhance the RCP spray and drip protection features
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ANO RCP Lube Oil Collection System Corrective Actions Summary
- Unit 1 and 2 RCP lube oil collection systems have been modified consistent with current understanding of j
Appendix R requirements
- Knowledge and awareness of Appendix R requirements i
.(including training) upgraded
- Process and procedure changes made to address.RCP 1
motor concerns and broader perspective 1
i
Enforcement Perspective Dwight Mims Director, Nuclear Safety
Unit 1 Reactor Building Fire Event Severity Level Apparent violation involves the failure to identify and take prompt corrective action for three instances of observed oilleakage
- Oilleakage caused by cracked weld
- Reports of excessive smoke and oil-soaked insulation
- Oil on reactor building floor identified by RP personnel-
Unit 1 Reactor Building Fire Event Severity Level Not aware oflagging fire phenomenon (auto-ignition temperature reduction)
Oilleakage caused by cracked weld
- Discovered during post-maintenance testing
- High pressure lift oil pump run time of ~15-30 seconds
- Minimal oil spilled - none on insulation
- Appendix R and Condition Reporting implications not recognized l
Reports of excessive smoke and oil-soaked insulation
- Communicationissues
-- Not appropriately sensitive to smoke during heat-up
- Concluded no fire danger existed Oil on reactor building floor identified by RP personnel
- Small quantities indicated minor leak or spill following maintenance
- Considered to be a housekeeping issue
Unit 1 Reactor Building Fire Event Severity Level Actual Safety Consequences
- Fire did not cause adverse effects upon safe shutdown equipment
- Damage was limited to component insulation
- No personnelinjuries resulted from this event Conclusion
- Event had no actual safety consequences
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Unit 1 Reactor Building Fire Event Severity Level i
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Potential Safety Consequences
- Redundancy was not lost for systems or components required to safely shutdown the reactor or maintain in a shutdown condition Conclusion
- Low potential safety consequences
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Unit 1 Reactor Building Fire
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Event Severity Level Regulatory Significance
- Fires and conditions leading-to fires are unacceptable and ANO has taken comprehensive corrdctive actions to l
address the root and contributing causes independent of any enforcement actions
- Condition does not reflect a programmatic deficiency
- Not representative of overall ANO performance i
- Not preventable by corrective action for a previous l
violation
- Not willful
- Event reported to NRC Conclusion
- Low regulatory significance; regulatory concern i
i
Unit 1 Reactor Building Fire Event Severity Level Conclusion
- Regarding severity level the following factors should be considered:
- No reasonable prior opportunity existed since information was not available which should have caused action to be taken in two cases - the excessive smoke and the oil on the reactor building floor
- Condition report required on cracked weld Fire did not cause adverse effects to safe shutdown equipment l
No actual safety consequences Low potential safety consequences IAw regulatory significance of the condition
- Basis exists in Section 8.1.7 of the NRC Enforcement Manual to l
conclude that the ANO condition is a Severity LevelIV violation Failure to meet one or more fire protection requirements that do not result in a Severity Ievel I, II, or III violation and which have more than minor safety or environmental significance 1
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System Severity Level Apparent violation of 10 CFR Part 50, Appendix R
- The lube oil collection systems for the "B" RCP in~ Unit 1 and all the RCPs in Unit 2 had not been designed to l
collect oilleakage from all pressurized and unpressurized locations
- The Unit 1 "A", "C", and "D" RCP lube oil collection systems were not maintained to collect oil from i
unpressurized locations a
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ANO RCP Lube Oil Collection System Severity Level Low pressure component drip protection
- Components could have leaks not contained Apparent original design error (Unit 1 "B" RCP, Unit 2)
Modification installation error (Unit 1)
- One transmitter out of eight placed outside drip collection Potential re-orientation during use (Unit 1)
- Three sight glasses out of eight outside drip collection system Spray protection for flanged connections
- Failed to identify high pressure flanged connections with l
no spray protection (Unit 1 "B" RCP)
Different causes for discrepancies
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3 g-gg-ANO RCP Lube Oil Collection System Severity Level Spray protection for high pressure piping / welds
- Absence of spray / drip protection for high pressure piping on each unit was communicated
- Spray protection required only for flanged /gasketed mechanicaljoints
- Detailed design documents submitted / accepted
- Believed in compliance with Appendix R
- Subsequentinspections acceptable
- No generic correspondence (ins and GLs) caused ANO to believe design change required Oil collection for remote oil addition systems
- Not within scope of Appendix R Not part of the RCP lube oil system Not considered potential leakage site Risk of oil spill lower for remote addition Conclusion
- No violation
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ANO RCP Lube Oil Collection System Severity Level Actual Safety Consequences
- Condition did not cause adverse effects upon safe shutdown equipment
- Confl guration did not jeopardize ability to achieve and i
maintain safe shutdown conditions as required by Appendix R Conclusion
- No actual safety consequences
System Severity Level Potential Safety Consequences
- Redundancy was not lost for system or components required to safely shutdown the reactor or maintain in &
shutdown condition Conclusion
- Low potential safety consequences m..-.
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3gww ANO RCP Lube Oil Collection System Severity Level Regulatory Significance
- ANO clearly understands the importance of this condition and has shown commitment to taking comprehensive corrective actions to address the root and contributing causes independent of any enforcement actions
- Not representative of overall ANO performance
- Not repetitive
- Not willful
- Resident inspector kept informed (10CFR50.72 reporting not required)
Conclusion
- Low regulatory significance; regulatory concern
ANC' RCP Lube C'il Collection System Severity Level Conclusion
- Regarding severity level the following factors should be considered:
Fire did not result from Appendix R non-compliance No actual safety consequences Low potential safety consequences Low regulatory significance of the condition Appendix R issues did not have same cause
- Basis exists in Section 8.1.7 of the NRC Enforcement Manual to conclude that the ANO condition is a Severity Level IV violation Failure to meet one or more fire protection requirements that do not result in a Severity Level I, II, or III violation and which have more than minor safety or environmental significance
e Civil Penalty Assessment Should a Severity LevelIII NOV be considered the following factors apply
- Enforcement History ANO has had a Severity Level III enforcement action during the past 2 years
- Identification Credit Problem was revealed through an event No reasonable prior opportunity existed to identify action that would have prevented the fire
- Lack of knowledge oflagging fire phenomenon Thorough root cause analysis
- Corrective Actions prompt and comprehensive Immediately initiated condition repoic Multi-discipline team reviewed event Comprehensive to prevent occurrence of violation with similar root cause Procedure changes and communication were prompt, and schedule for longer term actions has been developed
- Conclusion No Civil Penalty should be proposed
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Conclusion 3
Randy Hutchinson j
Vice-President, ANO I
2
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