ML20207K854
| ML20207K854 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/18/1986 |
| From: | Knightly J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K578 | List: |
| References | |
| SWEC-SQN-27, SWEC-SQN-27-R02, SWEC-SQN-27-R2, NUDOCS 8701090545 | |
| Download: ML20207K854 (8) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-27 SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Appendix R. Fire Protection REASON FOR REVISION: Revised to incorporate SRP comunents SWEC SUNNARY STATENENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic, analysis. All items evaluated within this report were verified to be adequately addressed and will be ready for closure following completion of corrective actions. -
PREPARATION PREPARED BY:
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- SRP Secretary's signature denotes SRP concurrences are in files.
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i TENNESSEE VALLEY AUTHORITY
- WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP I
4 Element: Appendix R. Fire Protection I SWEC Concerns: A02850320009-001 A02850403009-001 lp A02850403009-002 y A02850403009-003 A02850403009-004
, A02850403009-005 A02850403009-006 A02850403009-007 l A02850403009-008 j
A02850403009-009 3
i Source Documents: NRC Reports 50-327/85-01 and 50-328/85-11 j Report Number: SWEC-SQN-27 Evaluator: il!i
- J. J. Knightly Date i
i Reviewed by: If bw //-41-96.
Date I K. R. Gass Approved by: U= = a II//a/f6
- A. G. Debbde bate J
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, '. y Raport SWEC-SQN-27 NRC Reports 50-327/85-01 and 50-328/85-11 I. Introduction During a Nuclear Regulatory Commission (NRC) inspection January 14-18, 1985, of Sequoyah Nuclear plants (SQN) reevaluation of 10 CFR 50, Appendix R compliance, NRC verified (Reference 1) that SQN had identified significant requirements. violations to the Appendix R Fire protection ,
held in the NRCAn Enforcement Region II officeConference to 28, on February discuss this matter was 1985 (Reference 2).
NRC confirmed seven violations, one unresolved item, one inspector followup item, and an enforcement conference conclusion which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis as follows:
A02850320009-001, (Enforcement Conference), TVA failed to meet Appendix R Fire Protection Requirements due to lack of understanding of NRC rule and internal programmatic failures.
A02850403009-001, (Violation 50-327, 328/85-01-01), Failure to neet requirements of Appendix R,Section III.G with regard to maintaining one train of hot standby systems free of fire damage.
A02850403009-002, (Violation 50-327, 328/85-01-02), Failure to provide adequate breaker / fuse protection for equipment required for hot standby.
A02850403009-003, (Violation 50-327, 328/85-01-03), Failure to have procedures in effect to implement safe shutdown capability and procedures to repair damaged equipment for achieving cold shutdown conditions.
A02850403009-004, (Violation 50-327, 328/85-01-04), Oil collection system III.0 for reactor coolant pumps does not meet Appendix R, Section requirements.
A02850403009-005, (Violation 50-327, 328/85-01-05),
units do not meet Appendix R,Section III.3 requirements. Emergency lighting A02850403009-006, (Violation 50-327, 328/85-01-08), Failure to include cable fire barrier inspection program.assemblies in a surveillance or maintenance A02850403009-007, (Violation 50-327, 328/85-01-09), Failure to maintain fire barriers for three conduits in the Auxiliary Building.
A02850403009-008, (Unresolved item 50-327, 328/85-01-06), Review resolution to TVA identified Appendix R deviations pending review by NRC's Nuclear Reactor Regulation (NRR) organization.
A02850403009-009, (Inspector Followup Item 50-327, 328/85-01-07), Fire protection system. and raw service water pumps are not operated as a Train A-D Information on the background, corrective actions taken, verification methodology, verification analysis, completion status, and pertinent references for these ten SWEC issues are included in this report.
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II.
V rificetion of SWEC Issu_es A. Background NRC attributed SQN's failure to meet Appendix R Fire Protection requirements at SQN to a lack of understanding of the requirements and to internal programmatic failures. The internal programmatic factor was a lack of multi-discipline evaluation of the requirements. The specific deficiencies were identified as follows:
1.
(-O01) It appeared to NRC that if a fire were to occur in any of several identified plant areas, redundant hot standby systems could be rendered inoperable; thus, the plants ability to achieve and maintain hot standby could not be assured (Violation 85-01-01).
- 2. (-002) There were 295 circuits identified as having a common power source with shutdown equipment and the power source was ,
not properly electrically protected from the circuit of concern (Violation 85-01-02).
- 3. (-003) Operating procedures were not available to implement safe shutdown capability for all specific fire areas in the plant. A casualty procedure to implement repairs to systems required for cold shutdown was not available (Violation 85-01-03).
- 4. (-004) The oil collection systems for the reactor coolant pumps were inadequate in that drain piping systems were not designed to function following a safe shutdown earthquake, and the drainage tank was of inadequate size to hold the entire lube oil system inventory (Violation 85-01-04).
- 5. (-005) The emergency lighting was inadequate in that (a) only 76 battery-powered light units were installed within safe shutdown plant areas, but 150 were needed, and (b) light units had battery-power supply ratings of 3 3/4 hours; 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> are needed (Violation 85-01-05).
6.
- (-OO6) Cable fire barrier assemblies were not included in the fire barrier surveillance program (Violation 85-01-08).
7.
(-007) The "KA0 WOOL" one-half hour fire barrier material was missing or damaged on three conduits containing cables associated with pressurizer pressure and level indication (Violation 85-01-09).
8.
(-008) One NRC unresolved item concerned NRC's need to review SQN's resolution to 19 various Appendix R ltems identified in Sequoyah correspondence to NRC, December 18, 1984 and January 11, 1985 (URI 85-01-06).
- 9. (-009) SQN operating procedures do not clearly specify that one A train and one B train fire and raw service water system pumps be aligned to the fire protection system at all times (Inspector followup item 85-01-07).
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B. Corr 7ctivw Actions Sequoyah completed its reevaluation of compliance to Appendix R requirements in December, 1984 and a schedule for modification completion was reviewed and accepted by NRC during their Appendix R inspection of January 14-18, 1985 (Reference 1). Corrective actions in specific areas were as follows:
1.
(-O01) Corrective actions were defined to assure separations of ,
cables and equipment of redundant divisions in order that one division necessary for hot standby is free of fire damage (Reference 2, page 20).
2.
(-002) SQN performed a circuit analysis to identify circuits which did not have proper fuse / breaker coordination, and initiated modifications to ensure adequate electrical protection (Reference 2, page 21).
- 3. (-O03) SQN is developing or revising operating procedures to address manual operation of all valves for cold shutdown in the event of fire damage, and casualty procedures to address repair of cabling to cold shutdown valves (Reference 2, page 20).
4.
(-004) NRC approved on an interim basis, in Inspection Report 85-01 (March, 1985) a deviation to requirements based on the following equivalent actions by SQN: System Operating Instruction, SOI-55-INS, " Annunciator Response" wa s revised to maintain the auxiliary sump at less than half-full at times specified in order to have available sufficient capacity to hold the oil from one reactor coolant pump.
- 5. (-005) SQN added additional light packs in various plant areas. Emergency lighting was modified to obtain an eight hour capacity. The NRC inspection of August 12, 1986 (Reference 5) verified that SQN's Appendix R emergency lighting is now sufficient.
- 6. (-006) SQN revised Surveillance Instruction SI-233.4, " Visual Inspection of Thermal Fire Barriers," (Revision 2) to
- incorporate cable fire barrier assemblies into the surveillance program.
- 7. (-OO7) SQN repaired or replaced fire barriers for conduit in the Auxiliary Building. NRC Inspection Report 86-40 (Reference E) stated that the NAO-WOOL, fire barriers in the Auxiliary Building were inspected and that damaged insulation had been replaced or repaired. By LER 327/85-002, TVA committed to surveillance and maintenance activities to assure that the fire barriers will be maintained.
8.
(-O08) Several specific deviations to Appendix R requirements were approved (Reference 4) by NRC Nuclear Reactor Regulation (NRC-NRR) dated May 29, 1986. All deviations requested by SQN were approved with the exception of the cold leg temperature indicator for the auxiliary control room, which is still under review.
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- 9. (-009) TVA rsvissd System Opsrating Instruction SOI-26.1, "High Pressure Fire Protection Systems," (Revision 30) to require pumps IA and 2B to be in automatic position and pumps IB and 2A to be in standby, or pumps IB and 2A to be in automatic position and pumps 1A and 2B to be in standby position. NRC closed this followup item August 12, 1986 (Reference 5).
TVA stated (reference 3) that two major factors contributed to the l Appendix R deficiencies (1) Lack of detailed understanding of specific l requirements, and (2) Lack of multi-disciplined evaluation of these IR2 requirements. Corrective actions for these contributing factors were i ,
stated in the SQN Nuclear Performance Plan (reference 3) as follows: l 4
- Additional clarifications regarding Appendix R requirements (in the !
form of workshops, generic letters, etc.) resulted in increased TVA understanding of the actual Appendix R requirements. l In the past, problems and confusion existed within TVA's Nuclear Engineering Program as both the Engineering Organization and the Sequoyah Nuclear Power Organization performed engineering activities. ... Correction of these problems include organizational and program changes . . . Responsibilities which are being consolidated within engineering include: l
- Directing multi-discipline engineering teams created to investigate and resolve engineering issues (such as fire protection . . . ) associated with the plant.
C. Verification Nethodolotr The SWEC concerns identified for Employee Concerns Task Group (ECTG) verification were stated as follows:
RINS NUMBERS ISSUES RINS ITEN A02850320009 TVA failed to meet Appendix R Fire , RINS-001 Protection requirements at SQN due to lack of understanding of NRC rules and internal programmatic failures.
A02850403009 Violation preidentified: failure RINS-001 to meet the requirements of Appendix R.Section III.G with regard to maintaining one train of hot standby systems free of fire damage.
A02850403009 Violation preidentified: failure to RINS-002 provide adequate breaker / fuse pro-protection for equipment required for hot standby (common power source not electrically protected).
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A02850403009 Violation, failure to havs procedures in RIMS-003 effect to implement safe shutdown and to repair damaged equipment for cold shutdown conditions.
A02850403009 Violation, oil collection system for RIMS-OO4 reactor coolant pumps does not meet appropriate requirements, drain pipe system not designed for post seismic safe shutdown, plits inadequate size drain tank.
A02850403009 Violation, emergency lighting units RIMS-005 do not meet appropriate requirements (inadequate number of lighting units plus deficient battery-power supply to units installed).
A02850403009 Violation, failure to include cable RIMS-OO6 -
fire barrier assemblies in a sur-surveillance or maintenance program (as required by Tech Spec).
A02850403009 Violation, failure to maintain fire RIMS-OO7 barriers for three conduits in the Auxiliary Building (cabling associated with pressurizer pressure and level indication).
A02950403009 Review resolution to TVA identified RIMS-@8 Appendix R deviations, pending review by NRR, 19 of these deviations were reported to NRC By TVA for approval.
A02850403009 Fire protection and raw service water RIMS-009 pumps are not operated as a train A,8 System Operating Procedures need revision to specify pump alignment to Fire Protection System.
D, Verification Analysis ECTG verified that corrective actions have been planned, documented, and scheduled, or accomplished, as defined in Section II.B above.
ECTG verified that TVA performed a comprehensive review of Appendix R implementation at SQN, established a corrective action implementation schedule, reviewed overall status with NRC at the February , 1985 enforcement conference (Reference 2), and established dates prior to plant startup for completion of Appendix R related modifications. It was verified that SQN's plan and schedule of corrective action were found acceptable to the -
NRC. During NRC's July 1986 inspection (Reference 5) concerning SQN's implementation of Appendix R corrective actions, no violations or Page 5 of 6
,e d3victions wers id2ntified. All fire protection modifications inspected by the NRC during July 1986 were found to be properly installed, fully functional and adequate with respect to meeting requirements.
Compliance with Appendix R requirements is identified as a SQN startup issue, and NRC closure of the Appendix R items is required prior to plant s rtup. The overall Appendix R modification effort was estimated by SQN (Reference 3) to be 95 percent complete.
E. Completion Status SQN has implemented an extensive corrective action program to ensure compliance with Appendix R Fire Protection requirements.
Planned and documented corrective actions are in progress for all open SWEC issues. Following completion of SQN's planned corrective actions and NRC closure, these SWEC issues can be closed.
References
- 1. NRC Inspection Report Numbers 50-327/85-01 and 50-328/85-01, dated March 29, 1985, from J. N. Grace to H. G. Parris
- 2. NRC Meeting Summary Report Numbers 50-327/85-11 and 50-328/85-11, SQN Unit 1 and 2, dated March 18, 1985, from J. N. Grace to' H. G. Parris
- 3. SQN Muclear Performance Plan, Revision dated June 17, 1986
- 4. NRC memorandum, " Deviation Requests from Appendix R of 10 CFR Part 50," dated May 29, 1986, from 8. J. Youngblood to S. A. White 5, NRC Inspection Report Numbers 50-327/96-40 and 50-328/86-40, dated August 12, 1986, from G. G. Zech to S. A. White ,
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