ML20153B053

Special Rept:On 980817,errors in Implementation of Selected Licensee Commitment Testing Requirements on Fire Protection Sys Instruments,Was Discovered.Caused by Error in Interpretation of SLC Requirement.Will Revise Procedures

ML20153B053
Person / Time
Site:	Catawba
Issue date:	09/16/1998
From:	Gordon Peterson DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9809220297
Download: ML20153B053 (9)

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[S Duk) Energy Corporati:n

/ e- i IU b @= Catawba Nuclear Station 4800 Concord Road York, SC 29745 Gary R. Peterson , (803) 831-4251 omCE MceIWsiderst (803) 831-3426 FAX l

l September 16, 1998 U.S. Nuclear Regulatory Commission

' ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Corporation Catawba Nuclear Station Units 1 and 2 Docket Nos. 50-413 and 50-414 Special Report: Fire Protection Program Errors'in Implementation of Selected Licensee Commitment Testing Requirements Pursuant to Facility Operating License Section 2F, License Conditions 2.C.(8) for Unit 1 and 2.C. (6) for Unit 2, and

-Selected Licensee Commitment 16.9.6, Fire Detection Instrumentation, attached is a Special Report concerning Errors in Implementation of Selected Licensee Commitment Testing Requirements on Fire Protection System Instruments.

This condition was discovered on August 17, 1998.  ;

Commitments associated with this Special Report are provided in the Corrective Action Section.

Questions regarding this Special Report should be addressed to M.H. Chernoff at (803) 831-3414.

Very tr ' yours, f a

G. R. eterson ga

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Attachment 3z 9909220297 900916 9 '

PDR ADOCK 050004137 I S PDRjj

_ ,c U.S. Nuclear Regulatory Commission September 16, 1998 Page 2 xc: L. A. Reyes U. S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA'30303 P. S.. Tam NRC Senior Project Manager'(CNS)

U. S. Nuclear Regulatory Commission Mail Stop O-14H25 Washington, DC 20555-0001 D.J. Roberts Senior Resident Inspector (CNS)

U. S. Nuclear Regulatory Commission Catawba Nuclear Site

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i U.S.-Nuclear Regulatory Commission

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Attachment l L Special Report l

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Abstract:

u On August 17, 1998 with Unit 1 in Mode 5,. Cold Shutdown, and j Unit 2 operating in Mode 1 (Power Operation) at 100% power, l it was determined that the 6 month visual inspection of the  !

spot type heat. detectors for the Auxiliary Feedwater Pump and Diesel Generator rooms was not being performed once per 1 six' months as required by the Fire Protection Program in l l Selected Licensee: Commitment (SLC) 16.9.6. This occurred

l. because the detectors were grouped with the associated Carbon Dioxide system and were not included in the

. procedures which govern visual inspection of Fire Detection Instruments. The inspections were subsequently performed satisfactorily.

On August 18, 1998, it was discovered that the SLC-16.9.6 requirement to test 2 percent of the non-restorable spot type heat detectors every five years was not being  !

performed. In 1992, this type of detector, with the exception of 12 Control Room detectors, was excluded from L

the SLC. During implementation of this change the tests on these 12 detectors were erroneously deleted. These 12 detectors were replaced.

On August 21, 1998, during a thorough review of SLC required fire detector testing, it was discovered that not all

-inaccessible restorable spot type heat detectors were being tested each Refueling Outage. This was due to an error in interpretation of the SLC requirement. For Unit 1, the i required tests were pert __med and failed detectors were replaced. The tests will be done on the Unit 2 detectors '

during the current outage.

The appropriate testing procedures will be revised to be consistent with the SLC Testing Requirements.

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l U.S. Nuclear Regulatory Commission September 16, 1998 Page 4 l Introduction i

Catawba Nuclear Station Units 1 and 2 are four loop Westinghouse Units. Catawba Nuclear Station Unit 1 and Unit

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2 Facility Operating Licenses NPF-35 and NPF-52 require that i Duke Energy Corporation implement and maintain in effect all I provisions of the approved Fire Protection Program, as amended. It was determined that the events described in this-report constitute noncompliance with this license condition.

Consequently, these events were reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of I discovery. pursuant to the provisions of Facility Operating l License Section 2F. This written follow-up is being provided within 30 days of the first event.

At the time of these events, Unit 1 was in Mode 5, Cold Shutdown, and; Unit 2 was in Mode 1, Power Operation, at approximately 100 percent rated thermal power.

Background

Selected Licensee Commitment (SLC) 16.9.6, Fire Detection Instrumentation, is a part of the Catawba Fire Protection

[EIIS:KP] Program and is subject to the provisions of the Catawba Facility Operating License Condition 2.C. (8) for NPF-35 (Unit 1) and License Condition 2.C.(6)for NPF-52 (Unit 2). SLC 16.9.6 specifies that the detection instrumentation for each fire detection zone listed in Table 16.9-3 be i operable whenever the equipment protected by the fire l detection instrument is required to be operable. The SLC also provides Testing Requirements to verify operability of the instruments and Remedial Actions to be taken if an instrument is inoperable. The events described in this report involve errors in implementing three of the Testing Requirements applicable to heat detectors delineated in the SLC.

One Testing Requirement associated with the SLC requires that all spot-type heat detectors which are accessible during plant operation be visually inspected at least once per 6 months.

l l Another Testing Requirement requires, in part that for non-restorable spot-type detectors, at least two detectors out of every 100, or fraction thereof, be removed every 5 years and functionally tested. For each failure that occurs on l

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,. U.S. Nuclear Regulatory Commission l September 16, 1998

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the detectors removed, two additional detectors shall be removed and tested, i l

l. The non-restorable spot-type heat detectors at Catawba are

. " rate of rise / fixed temperature" detectors. These two l' features are independent of each other. The rate of rise

}. feature is restorable and there are different Testing l Requirements for this feature. The " fixed temperature" feature is the non-restorable function of the detector and is subject to this Testing Requirement. This Testing Requirement applies to 12 detectors in the Control Room.

For these 12 detectors, both the rate of rise and fixed L ' temperature features are credited.

j For restorable spot-type detectors that are inaccessible during plant operation, the SLC Testing Requirement requires l performance of a Trip Actuation Device Operational Test l during each refueling outage. This Testing Requiremont applies to 4 rate.of rise heat detectors in each containment (8 total).

SLC 16.2.7 allows a 2 .our period to perform a missed SLC Testing Requirement pr cr to initiating Remedial Actions.

The Remedial Action for more than one-half of the Function A (early warning fire detection and notification only)

~ detection instruments in any fire zone shown in the SLC table, or with any Function B (actuation of fire suppression system and early warning and notification) detection instruments shown in the Table inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a fire watch patrol to inspect the' zone (s) with the inoperable instrument (s) at least once per hour, unless

'the instrument (s) is located inside the containment, then inspect that containment zone at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or monitor the containment air temperature at least once per hour at specific locations.

Description of Event

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August 17, 1998 Approximately 1600 It was discovered that the visual l inspection on the Function B spot heat detectors for l the Auxiliary Feedwater Pump and the Emergency Diesel Generator rooms for Units 1 and 2, required to be performed once per 6 months, was not included in the Catawba Surveillance Program. Function B is defined as

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U.S. . Nuclear Regulatory Commission l September 16, 1998 Page G actuation of fire' suppression system and early warning and notification.

r-The affected detectors were declared inoperable. Wcrk Requests were written to conduct a visual inspection of these detectors during the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permitted to conduct'the testing prior to imposition of the Remedial Action.

August.18, 1998 Approximately 0450 The visual inspection was completed L with no problems noted. )

0945 Review of the inspection results was completed, and the detectors were restored to operable status.

Approximately 1555 During a procedure review, it was discovered that the pre-defined Work Request for the ,

procedure used to satisfy the requirement to test 2 out l of every 100 non-restorable spot detectors every five

'l years had been deleted. 1 Approximately 1835 .The 12 affected Control Room detectors were declared inoperable, and the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> permitted to conduct the testing prior to imposition of the Remedial Action was invoked.

August 19, 1998 Approximately 0405 The 12 Control Room detectors were I replaced.

0953 The detectors were restored to operable status.

A thorough review was initiated of fire detection instrumentation testing requirements as delineated in the SLCs.

August 21, 1998 Approximately 1215 The review of SLC Fire Detection

, Instrumentation Testing identified that the SLC Testing Requirement for inaccessible restorable spot type heat detectors was not being properly implemented. The L procedure required only one detector per zone be tested i each refueling outage, rather than requiring testing of

! all the inaccessible restorable spot type detectors.

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U.S. Nuclear Regulatory Commission September 16, 1998 Page 7 The affected detectors are associated with the Filter Bed Units in the Reactor Buila ogs.

A Work Request was initiated to test the heat detectors for Unit 1 prior to plant start-up. A Work Request has been e'stablished to test the rate-of-rise detectors on

' Unit 2 during its End of Cycle 9 Refueling Outage, which began on September 5, 1998. Remedial Actions as specified in SLC 16.9.6 are being implemented for Unit 2,

pending restoration of the detectors to operable status.

y Several of the detectors on Unit 1 failed the test and were replaced. The detectors were restored to operable status following successful completion of the testing.

Cause Of Event The visual inspections on the heat detectors for the Auxiliary Feedwater Pump and Diesel Generator rooms were not included in the Surveillance Program because these detectors are associated with the suppression systems in these rooms, rather than the detection systems. Visual inspection of these detectors was inadvertently omitted from the series of procedures that govern fire detection instrumentation visual inspections.

Deletion of the Model Work Order for testing of the Control Room heat detectors was the primary cause of the failure to perform the 5 year test on the non-restorable spot type heat detectors. This has been attributed to an oversight that occurred in 1992. In 1992, based on the results of a design study, all but 12 fixed temperature heat detectocs were deleted from the scope of the SLC's. The subsequent deletion of the Model Work Order removed the work control vehicle for tasting of the fixed temperature heat detectors.

Additionally, the testing procedure did not contain an all inclusive list of the fixed temperature heat detectors.

The error in testing the restorable spot type heat detectors located in inaccessible areas has been attributed to a lack of clarity in the SLC requirements. The lack of clarity resulted in a misinterpretation of the SLC requirements.

Corrective Actions The semi-annual Auxiliary Feedwater and Emergency Diesel Generator Carbon Dicxide system performance tests will be revised to add a visual inspection for the heat detectors.

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U.S. Nuclear Regulatory Commission September- 16,'1998  ;

Page 8 Procedures"affected are PT/1(2)/A/4450/13D (Aux FDWP CO2 System Semi-Annual Test) and PT/1(2)/A/4450/10D (Diesel Generator CO2 System Semi-Annual Test). '

Selected Licensee Commitment 16.9.6 will'be revised to remove the Control Room heat detectors. Each of these detectors.is paired with an ionization detector located directly adjacent to them. Based on the combustible loading in the Control Room and the effectiveness of the ionization detectors themselves, deletion of the heat detectors from the scope of the SLC's is appropriate.

Procedures IP/0/A/3350/031 (032) (EFA System Detector Test Procedure for Data Gathering Panel 28 (29)) will be revised

'to ensure all restorable spot type heat detectors located in inaccessible areas are tested during each refueling outage.

Additionally, an evaluation will be performed to determine ,

if the inaccessible heat detectors can be removed from the scope of the SLC's.

Additional Information The failure to perform the required visual inspection of the.

heat. detectors in the Auxiliary Feedwater Pump rooms did not degrade the performance of the fire protection system. The visual inspection is conducted to ensure there are no obvious signs of' damage to the detector and that there are no obstructions that.would impair functioning of the detector. The location of these detectors and the controls associated with the modification program <would greatly reduce the likelihood of damage or obstructions. The visual inspections were conducted with no problems noted.

The failure to test 2 percent of the heat c.etectors with a non-restorable feature in the Control Roor. likewise did not degrade performance of the fire protection system. There is a smoke detector adjacent to each heat detector in the Control Room. The smoke detectors are appropriate for the l type of combustibles in the Control Room and would provide a l quicker response than heat detectors. Furthermore, the Control Room is continuously manned, thereby ensuring early l detection and response to a developing fire.

l There are additional' fire protection system features that can be relied'upon'to compensate for the inoperability of the inaccessible heat. detectors. There are smoke detectors i adjacent to each of these heat detectors. These detectors

, are associated with Lower Containment Ventilation System 3- Filter' Bed Units in the Reactor Building. The Filter Bed 4

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l U.S. Nuclear Regulatory Commission September 16, 1998 l

Page 9 l Units are serviced by a fan unit that is part of the Reactor Building Ventilation System. The fan unit contains a '

thermal detector that-alarms in the Control Room and is in service any time the. filter-bed fan is in service. The smoke detectors.and the Ventilation System temperature sensors would have provided adequate early warning detection i capability.

l The health and safety of the public and site personnel were i

.not jeopardized by the events described in this report.

A search of the corrective action database for the previous two years for events involving Fire Detection System Testing Requirements did not identify any previous similar occurrences. One event involving a failure to inspect Fire l Hose Gaskets was discovered on April 15, 1998. This )

occurrence was reported in a Special Report, submitted on

, May 12, 1998. That event was attributed to a failure to transfer inspection requirements from one procedure to o another and was considered to be historical in nature.

There are no EPIX reportable failures associated with the occurrences described in this report ~.

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