ML20235U820

Special Rept 89-001:on 890120,fire-rated Assemblies Inoperable for More than 14 Days.Caused by Inadequate Design.Limiting Condition for Operation Established for Each Identified Deficiencies

ML20235U820
Person / Time
Site:	Hatch
Issue date:	02/28/1989
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-001, 89-1, HL-342, NUDOCS 8903090385
Download: ML20235U820 (8)

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' fl.,Rhld Opf"lih0"5 HL-342-0027V X7GJ17-H540 February 28, 1989 U. S. Nuclear Regulatory Commission ATTN: ' Document Control Desk ,

Washington,'D. C. 20555 -

1 PLANT HATCH - UNIT 1, 2 NRC DOCKET 50-321, 50-366 OPERATING LICENSE DPR-57, NPF-5 SPECIAL REPORT 89-001 FIRE RATED ASSEMBLIES IN0PERABLE ,

FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS REOUIRED BY FIRE HAZARDS REPORT l

Gentlemen: J In accordance with the requirements of the Plant Hatch Unit 1 and Unit 2 Technical Specifications Section 6.9.2, and the Fire Hazards' Analysis (FHA)

Appendix B, Georgia Power Company is submitting the enclosed Special ' Report (SR) concerning an event where fire rated assemblies were inoperable longer than 14 days.

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Sincerely, id.). {hYd H. G. Hairston, III l

CLT/eb

Enclosure:

SR 50-321/1989-001 c: (See next page.)

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t U. S. Nuclear Regulatory Commission February 28, 1989 Page Two c: Georaia Power Comoany Mr. H. C. Nix, General Manager - Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Engineering and Licensing GO-NORMS U. S. Nuclear Reaulatory Commission. Washinaton. D. C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Reaulatory Commission. Reaion II Mr. M. L. Ernst, Acting Regional Administrator Mr. J.-E. Menning, Senior Resident Inspector - Hatch i

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ENCLOSURE PLANT HATCH - UNIT 1 AND UNIT 2 NRC DOCKET 50-321 AND 50-366 OPERATING LICENSE DPR-57 AND NPF-5 SPECIAL' REPORT 89-001 FIRE RATED ASSEMBLIES INOPERABLE FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS'REOUIRED BY FIRE HAZARDS REPORT A. REQUIREMENT FOR REPORT This report is required by Unit 1 and Unit 2 Technical Specifications, section 6.9.2. This section of Technical Specifications states that special reports for fi re protection equipment operating and surveillance requirements shall be submitted as required by the Fire Hazards Analysis (FHA) and its Appendix B requirements.

The FHA, Appendix B, Section 1.1.1, states that fire rated assemblies separating portions of redundant systems important to safe shutdown within a fire area shall be operable. ACTION statement b. of FHA, Appendix B. Section 1.1.1 allows for the fire rated assembly (s) to be inoperable for up to 14 days from identification of the condition.

If this time limit is exceeded, a special report is required.

B. UNIT (s) STATUS AT TIME OF EVENTS On 2/03/89, Unit 1 was in the run mode at an approximate power level of 2433 MWT (approximately 100 percent of rated power) and Unit 2 was in the run mode at an approximate power level of 2436 MWT (approxirrately 100 percent of rated power).

C. DESCRIPTION OF EVENT This report describes deficiencies which were found by the two Architect Engineers (A/Es) in the course of ongoing efforts to assure the continued compliance of Plant Hatch Units 1 and 2 with 10 CFR 50 Appendix R.

1 Appendix R modifications for both Units 1 and 2 were made throughout 1986. Full compliance with Appendix R was achieved in November, 1986, based on implementation of an overall program acceptable to the NRC and documented calculations which constituted an acceptable Safe Shutdown Analysis. To achieve compliance with Appendix R in parallel with other onrd g plaat modifications, a design freeze of June,1.986 was adopted fc' the purpose of applying Appendix R requirements.

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. ENCLOSURE (Continued)

FIRE RATED ASSEMBLIES INOPERABLE FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS RE0VIRED BY FIRE HAZARDS REPORT  ;

For those plant modifications implemented in parallel with the Appendix R modifications (therefore not reflected in the plant drawings as of June 1986) compliance with current Appendix R requirements is assured by a review of As-Built Notices (ABNs) and Work Completion Notices (HCNs) upon completion of the modifications. For design modifications initiated since approximately June 1986, implementation of Appendix R criteria is part of the initial design process. As additional assurance, each design modification is again reviewed upon completion of implementation against Appendix R criteria.

Additionally, to assure effective, long-term maintenance of the Plant Hatch Appendix R program, a documentation enhancement program has recently been completed, resulting in the issuance of Revision 0 of the ,

Safe Shutdown Analysis Report (SSAR). In the course of the documentation enhancement program, a re-evaluation was performed of all circuits required for Appendix R safe shutdown.

On January 20, 1989, Plant Hatch Engineering personnel received information from the A/Es identifying five deficiencies, four identified as a result of the Appendix R documentation enhancement program and one identified through the ongoing ABN/NCN review process. An inspection by the Engineering personnel confirmed the identified raceways were not in complian:e with Appendix R.

Limitiry Conditions for Operation (LC0's) 1-89-41, 1-89-42, 1-89-43 &

1-89-44 for Unit 1, and 2-89-18 for Unit 2, were written at 1100 CST and 1130 CST on 1-20-89, respectively. Hourly fire watch patrols were immediately initiated to satisfy the requirements of the Plant Hatch FHA, Appendix B Section 1.1.1, ACTION a. for inoperable fire rated assemblies. Deficiency Cards 1-89-331, 1-89-332, 1-89-333 and 1-89-334, as well as 2-89-170 were written to document the conditions as required by the plants' administrative control procedures. Since the five deficiencies could not be corrected within the 14 day period ending on l 2/3/89, this special report is required.

The specific deficiencies and how they were identified are described in two groups based on their different characteristics.

Group 1 During the circuit review to support preparation of Revision 0 of the SSAR, it was determined that Unit I circuit R25-S064-M34, located in l fire area 0024 (Cable Spreading Room), is improperly routed. This circuit provides power to instruments in the Remote Shutdown System required for Appendix R path 3 safe shutdown.

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_. ENCLOSURE (Continued)

FIRE RATED ASSEMBLIES IN0PERABLE FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS RE0UIRED BY FIRE HAZARDS REPORT DESCRIPTION OF EVENT: (Continued)

In the design work performed in 1986 to achieve Appendix R compliance, it was assumed that all power and control power circuits required for Appendix R path 3 shutdown were routed outside of the control complex l (the control complex is defined as the fire area comprised of the main I control room, the cable spreading room, and the computer room). This assumption was based on General Electric design specifications 'which stated "the remote shutdown system shall be designed to control the required shutdown systems from outside the control room irrespective of shorts, opens, or grounds in the control circuits in the control room that may have resulted from the event". During preparation of Revision 0 of the SSAR, a review was conducted of the routing of all power and control power circuits required for Appendix R path 3 shutdown. During this review it was determined that circuit R25-S064-H34 was routed through the cable spreading room which conflicts with the aforementioned assumption.

Group 2 The second, third, and fourth deficiencies were identified during the re-evaluation of all circuits required for Appendix R safe shutdown to support issuance of Revision 0 of the SSAR.

The second and third deficiencies concern Unit I circuits R24-S011-ES7-C85A and R24-S012-ESB-C49A, located respectively in fire areas 1203 and 1205, which are presently not protected by a fire barrier. These are control circuits for valves E11-F091A and Ell-F026B which are used in the alignment of the steam condensing mode of the Residual Heat Removal (RHR) system. Tnese valves are required to remain in the closed position for Appendix R isolation. Without a fire barrier, a fire related fault may cause the valves to spuriously open.

The fourth deficiency concerns Unit 2 circuit RIE827C05, located in fire area 2408, which is presently not protected by a fire barrier. This is a control circuit in the under-voltage relay scheme for 600 V Station Service Switchgear Bus 2D (2R23-S004). A fire related fault may trip the feeder breakers to battery chargers 2R42-S029, S030, and S031.

These chargers feed 250 V DC battery switchgear (2R22-S017), which is required for paths 2 and 3 safe shutdown.

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l ENCLOSURE (Continued)

FIRE RATED ASSEMBLIES INOPERABLE FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS REOUIRED BY FIRE HAZARDS REPORT DESCRIPTION OF EVENT: (Continued)

The fifth deficiency was identified through the ongoing ABN/HCN review process. Unit I circuits H11-P621-ES9-C003 and H11-P621-ES9-C058, located in fire areas 1104 and 1017, are presently not protected by a fire barrier. These circuits are part of the Reactor Core Isolation Cooling (RCIC) turbine Electro Governor-Magnetic pickup (EGM) control scheme and are required for automatic operation of the RCIC pump (E51-C001).

D. CAUSE OF EVENT The root cause of the improperly routed circuit in the Remote Shutdown System is inadequate design. Based on the review of circuit routing conducted for preparation of Revision 0 of the SSAR, this is considered an isolated case since no other improperly routed circuits of this type were found.

The root cause of the second, third, and fourth deficiencies is inadequate design by the A/E, who failed to properly recognize the identified circuits as affecting safe shutdown and therefore failed to require appropriate fire barriers or alternative measures to achieve compliance with Appendix R requirements. Again due to the re-evaluation of all circuits required for Appendix R safe shutdown conducted for Revision 0 of the SSAR, these deficiencies are considered isolated Cases.

The root cause of the fifth deficiency, which was identified through the ongoing ABN/HCN review process, was inadequate design guidance regarding the application of Appendix R requirements in the design and implementation process for the RCIC turbine EGM circuits. Although design measures were in place to address Appendix R requirements for those plant modifications (primarily associated with the Analog Transmitter Trip System (ATTS)) implemented in parallel with Appendix R modifications, the design guidance was modified several times based on  ?

l the continued evolution of Appendix R requirements. The present, ongoing review of ABNs/HCNs was initiated to verify compliance with current Appendix R requirements.

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ENCLOSURE (Continued)

FIRE RATED ASSEMBLIES INOPERABLE l

FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS REOUIRED BY FIRE HAZARDS REPORT E. ANALYSIS OF EVENT In this event, licensed personnel declared the identified deficient fire rated assemblies inoperable on 1/20/89. Appropriate fire detectors were verified operable and an hot:rly fire watch was established to comply with ACTION statement a. of Section 1.1.1. ACTION statement a. requires that:

With one or .nore of the above required fire rated assemblies and/or sealing devices 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 continuous fire watch on at least one side of the affected assembly (s) and/or sealing device (s) or verify the operability of fire detectors on at least one side of the inoperable assembly (s) and sealing device (s) and establish an hourly fi re watch patrol.

These actions ensured that if a fire had occurred, it would have been '

promptly detected and extinguished.

Specifically, regarding the improperly routed circuit in the Remote Shutdown system, it is protected by the fire detection system and manual fire suppression capability in the cable spreading room.

Regarding the two valves, Ell-F091A and E11-F026B, used in the alignment of the steam condensing mode of RHR, each of the affected valves is one i of three valves in each of two affected lines capable of providing  ;

isolation. The three valves in each line separate high and low pressure i portions of the RHR piping when operating in the steam condensing mode.

It is highly unlikely that any single fire could cause simultaneous actuation (opening) of all three valves.

Regarding the lack of fire barrier for the control circuit impacting three battery chargers on Unit 2, existing procedures for handling loss of offsite power events contain adequate compensatory actions should the circuitry's operation be affected by fire.

Finally, concerning the circuits in the RCIC EGM control scheme without fire barriers, should a fire have impacted this circuitry affecting automatic RCIC operation, Operations personnel could take steps to enable manual operation of RCIC.

Based on the above information, it is concluded that this event had no adverse impact on nuclear safety. The above analysis is applicable to all power levels.

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.- . ENCLOSURE'(Continued)

FIRE. RATED ASSEMBLIES INOPERABLE FOR GREATER THAN 14 DAYS RESULTING IN SPECIAL REPORT AS RE0UIRED BY FIRE HAZARDS REPORT F. CORRECTIVE ACTIONS The corrective actions for this event include:

1. A Limiting Condition for Operation (LCO) was established for each of the identified deficiencies.

2. The affected fire rated assemblies were declared inoperable, and an hourly fire watch patrol was established for each of the identified deficient areas.

3. The scope and implementation schedule of the design change necessary to address the improperly routed circuit in the Remote Shutdown System will be determined by 4/31/89.

4. In lieu of providing a fire barrier for control circuitry for valves Ell-F091 A and Ell-F026B, a design change will be implemented to remove power from the valves by opening the respective supply breakers by 4/14/89. The plant procedure covering alignment of the steam condensing mode of RHR will be updated by 4/14/89 to require closure of the breakers before operation of the valves.

5. In lieu of providing fire barriers for the control circuit impacting the Unit 2 battery chargers, plant procedure 34AB-FPX-053-2S will be revised by 3/31/89 to specify any further appropriate compensatory actions in the event of a fire.

6. The affected raceways for the circuits in the RCIC EGM control scheme will be fire wrapped by 8/31/89.

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