05000312/LER-1987-029, :on 870516,surveillance Testing of Unsupervised Circuits Used to Transmit Signal to Control Room Inadequate. Continuous Fire Watch Posted at Local Fire Panels to Monitor Fire Alarm Sys Annuciation: Difference between revisions

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{{Adams
#REDIRECT [[05000312/LER-1987-029]]
| number = ML20215D853
| issue date = 06/15/1987
| title = :on 870516,surveillance Testing of Unsupervised Circuits Used to Transmit Signal to Control Room Inadequate. Continuous Fire Watch Posted at Local Fire Panels to Monitor Fire Alarm Sys Annuciation
| author name = Andognini G, Colombo R
| author affiliation = SACRAMENTO MUNICIPAL UTILITY DISTRICT
| addressee name =
| addressee affiliation = NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
| docket = 05000312
| license number =
| contact person =
| document report number = GCA-87-202, LER-87-029, LER-87-29, NUDOCS 8706190166
| document type = LICENSEE EVENT REPORT (SEE ALSO AO RO), TEXT-SAFETY REPORT
| page count = 13
}}
{{LER
| Title = :on 870516,surveillance Testing of Unsupervised Circuits Used to Transmit Signal to Control Room Inadequate. Continuous Fire Watch Posted at Local Fire Panels to Monitor Fire Alarm Sys Annuciation
| Plant =
| Reporting criterion = 10 CFR 50.73(a)(2)(1), 10 CFR 50.73(a)(2)(i)(B)
| Power level =
| Mode =
| Docket = 05000312
| LER year = 1987
| LER number = 29
| LER revision = 0
| Event date =
| Report date =
| ENS =
| abstract =
}}
 
=text=
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NIC Form M6 U 5. NUCLEAR REGULATORY COMMIS5 BON APPROVED OMB NO 316.olod I
j LICENSEE EVENT REPORT (LER)
***REs s>sv9e PACILITY NAME n, DOCKET NUMBER (2)
PAGE (3, RANCHO SECO NUCLEAR GENERATING STATION 01510101013 l 112 1 }oFl1 l2 TWf PROTECTION PROGRAM DEFICIENCIES WITH RESPECT TO TECHNICAL SPECIFICATIONS AND COMMITMFNT9 EVENT DAYS (Si LE R NUMBE R I.)
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LICEN$EE CONTACT FOR THIS LER 1121 NAML TELEPHONE NVMBER ARE A CQDE Ron W. Colombo, Regulatory Compliance, Superintendent 916 4 5121 -1 3121111 i 1 COMPLETE ONE LINE FOR E ACM COMPONENT FAILURE DESCRIBED IN TH18 REPORT (13)
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The surveillance testing of unsupervised circuits between the Pyrotronics or Notifier panels and the auxiliary relays used to transmit signals to the Control Room was not adequately performed in conformance with Technical Specification 4.18.1.3.
This situation was corrected by establishing a continuous fire watch post at the local fire panels to monitor fire alarm system annunciation, thereby eliminating reliance en the unsupervised circuits.
The District committed to comply with various requirements of the National Fire Protection Association standards via the District response dated August 31, 1976 to the NRC Branch Technical Position (BTP) APCSB 9.5-1, which was issued by the NRC on May 1, 1976.. This commitment was essentially restated by the NRC in the Safety Evaluation Report issued as Amendment 19 to the Facility Operating License on February 28, 1978.
This report provides the NRC with information concerning deviations from several of those commitments which may or may not affect the NRC's SER for the Rancho Seco fire protection program.
The specific deviations are contained in District internal report numbers ERPT E-033, -034, -035, -037, -039, -047, and -048.
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J.RC Fe#sp D4A U.S. NUCLEAR fiEGULATOM COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROvso oMe No. 3ao-oio4 EXPrAES: 8/31/8B PACILITY NAM 8 m DOCKET NUMBER (2)
Lf R NUMBER (6)
PAGE (3) vraa
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RANCHO SECO NUCLEAR GENERATING STATION o ls lo jo l0 l3 l1l2 8l 7 012l9 0l 0 0l 2 OF 1 l2 TWCT (# anse sysse de nuges>sst ses adsIWens/ WAC perm Ms) 11D This report is of an operation or condition orchibited by the olant's Technical Specifications.
Control Room Fire Alarm Annunciation System Testinc i
The surveillance testing of unsupervised circuits between the Pyrotronics or Notifier panels and the auxiliary relays used to transmit signals to the control Room was not adequately performed I
in conformance with Technical Specification 4.18.1.3 (RE:
Occurrence Description Report (ODR) 87-570).
That is an event which is reportable as a condition prohibited by the technical specifications (10 CFR Part 50.73 (a) (2) (1) (B)).
Because of the lack of adequate surveillance, the affected portion of the Control Room fire alarm annunciation system was, thus, inoperable during power operation although it was in-service.
The technical specification required thirty day special report following fourteen days of being out-of-service was not made.
The failure to report until this LER exceeded the action statement of technical specifications.
This occurrence is reportable according to 10 CFR Part 50.73 (a) (2) (1) (B) as a condition prohibited by the plant's technical specifications.
This situation was corrected by establishing a continuous fire watch post at the local fire panels to monitor fire alarm system annunciation, thereby eliminating reliance on the unsupervised circuits.
This report is on conditions which deviate from commitments made to the NRC in safety analysis and District Desitionaz l
The District committed to comply with various requirements of the National Fire Protection Association standards via the District response dated August 31, 1976 to the NRC Branch Technical Position (BTP) APCSB 9.5-1, which was issued by the NRC on May 1, 1976.
This commitment was essentially restated by the NRC in the Safety Evaluation Report issued as Amendment 19 to the Facility Operating License on February 28, 1978.
There are three classes of commitments for the Rancho Seco Fire Protection Program.
First, the District made commitments describing how items in the BTP would be handled.
Second, the SER provides the final understanding on issues contested during the development of Amendment 19 to the District's license.
Third, an updated Fire Hazards Analysis pursuant to 10 CFR Part 50.48 and Appendix R to 10 CFR Part 50 was completed and forwarded to the NRC for approval.
Only one SER regarding fire protection at Rancho Seco has been issued by the NRC.
That SER
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was license Amendment 19 dated February 28, 1978.
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NRC PerAn 304A U.S. NUCLEAR QEOULOTO:0V COMMISSION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION areaovEo ous No 3 iso-oioo EXPtRES. 8/31/88 F ACILif Y NAME (1)
DOCKET NUMBER (2)
Lf R NUM8ER {6)
PAGE (3)
UAd th Me l
l RANCHO SECO NUCLEAR GENERATING STATION o l5 jo l0 jo l3 l1l2 8l 7 0l2l9 0l0 0 l3 OF 1l2 TERT (# snm spese 4 seedW, ese salmonaf NAC Form JmL4'sJ (17)
This report provides the NRC with information concerning deviations from several of those commitments which may or may not affect the NRC's SER for the Rancho Seco fire protection program.
The specific deviations are contained in District internal report numbers ERPT E-033, -034, -035, -037, -039, -047, and -048.
The District committed to comply with the guidelines of the NFPA code sections cited below.
The deviations from the codes listed l
below were reviewed and found:
o not to impact system operability o
not to violate technical specifications o
not to impact the plant's ability to achieve and maintain safe shutdown.
The NFPA codes are as follows:
o carbon dioxide systems -- NFPA 12 (RE: ODR 87-589) o sprinkler systems -- NFPA 13 (RE: ODR 87-591) o standpipe and hose stations -- NFPA 14 (RE: ODR 87-603) o water spray fixed systems -- NFPA 15 (RE: ODR 87-590) o fire pumps -- NFPA 20 (RE: ODR 87-606) o private fire service mains -- NFPA 24 (RE: ODR 87-605)
However, as a result of the District's commitment to the guidelines of NFPA 72D (which makes direct reference to NFPA 72E), fire detector locations were also reviewed.
Although all detection systems were determined to be operable in accordance with technical specifications, their ability to provide prompt indication of a fire was marginal in some plant areas using criteria from NFPA 72E.
To enhance the ability to obtain prompt indication for fires in those areas, fire watches were established.
l Control Room Fire Alarm Annunciation System (NFPA 72D) 1 The Control Room fire alarm annunciation system is not in compliance with the National Fire Protection Association standard for proprietary protective signaling systems, NFPA 72D.
It should be noted that the Technical Specifications 4.18.1.2 and j
4.18.1.3 do not indicate that not all alarm circuits are required to be supervised, only that unsupervised ones need to be tested monthly.
The District is left to determine which circuit is, or is not, supervised.
Therefore, this deviation from the NFPA standard may not constitute a Technical Specification violation.
I N C FOCM 366A
*U S GPO 1986 0 624-538,455
 
NAC Portp 396A i
U.S. NUCLEAR REGULOTOQY COMMISSION UCENSEE EVENT REPORT (LER) TEXT CONTINUATION mPRovEo ouB No 3 iso-oio4 EXPlRES; 8/31/08 FACILITV NAaAE tt)
DOCKET NUMBER (2)
LER NUMBER (6)
PAGE (31 vraa 5' map.'' ': ",W',T RANCHO SECO NUCLEAR GENERATING STATION o l5 l0 lo lo l3 l 1l2 81 7 012l9 010 0 l4 OF 1 l2 7987 pmeme ausse e seguemer, aus asisIWorief NAC form JpM'st (1M Three conditions which may prevent the system from reliably providing prompt notification to the operators are as follows:
Portions of the signaling circuits and power supply are o
unsupervised so that a single break or ground would not be specifically annunciated in the Control Room.
o A trouble signal instead of an alarm signal is annunciated when the first detector senses an alarm condition in the Auxiliary Building carbon dioxide protected zones.
o The computer generated audible alarm in the Control Room for zones in the Nuclear Services Electrical Building, Auxiliary Feedwater Pumps, and two zones in the Auxiliary Bui-lding is inadequate per NFPA 72D (because it is not distinct) although visual alarm is provided.
This situation was mitigated by installation of continuous fire watches at the local fire panels to monitor alarm system annunciation which is an adequate compensatory measure for the following reasons:
o Circuitry from the fire detection instrumentation to the l
local panels is supervised and is tested semi-annually in accordance with Technical Specification 4.18.1.2.
The i
continuous fire watch posts eliminate any reliance on the i
unsupervised circuits between the local panels and the Control Room.
o The local panels provide a distinct annunciation for fire upon the first detector trip.
The continuous fire watch posting is thereby notified at the first indication of fire.
Detection is one element in the fire protection program.
Suppression is not affected by fire alarm discrepancies, so this is not a-condition which alone could prevent the fulfillment of safety functions of plant systems.
Plant oDeratina conditions before the event.
J The plant has operated at power since the time that these conditions were identified to the District.
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C fotA 364A U.S. NUCLEAR KEGULATORY COMMi$$lON LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVED OMB NO. MO-0IO4 EXPIRES: 8 / 3 1 /118 P ACILITY NAME H)
DOCKET NUM8ER (2)
LER NUMBER (6)
PAGE (3) naa
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RANCHO SECO NUCLEAR GENERATING STATION o l5 l0 lo l0 l311l2 8l 7 0l2l9 0l0 0l5 OF ql2 m r,,
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, e crom,m a on The method of discovery of each component or system failure or procedural error (testina, investicatina, troubleshootina, tour, observation).
Reports provided to the District document an analysis of the conformance of the District's fire protection system to NFPA requirements which became the basis of a fire protection system status review.
That system status report was inspected by the NRC during a fire protection program review.
The NRC questioned whether the items presented in that report were evaluated against 10 CFR Part 50.72 and 50.73 for reportability to the NRC.
Dates and acoroximate times of occurrences.
The occurrence Description Reports for these conditions were filed between May 15 and May 21, 1987.
The reports which are the bases of these ODRs are dated July and August 1985.
The fintermediate and root 1 causeisi of each comoonent or system failure or eersonnel error, if known.
Surveillance Procedures -- monthly circuit check deficiency The surveillance program did not verify that there was an item for item correspondence between technical specification surveillance requirements and procedures which implement them.
The procedure for Technical Specification 4.18.1.3 was not fully adequate to demonstrate circuit operability for the normally open contacts in the circuits which serve as the interface between the local fire alarm panels and the Control Room indications.
Failure to orovide timely report The District organization responsible for writing Licensee Event Reports is singly dependent upon the internal generation of an Occurrence Description Report (ODR) which records potentially reportable events.
This event demonstrates that the ODR process (embodied in Administrative Procedure AP.22) was not consistently used by every Rancho Seco organization within the District.
In addition, the fire protection discrepancies were discussed in the process of developing the restart plan (QCI-12 process).
Senior management in those meetings, who otherwise recognized the ODR process, did not write ODRs due to the lack of reportability determination being part of their "QCI-12" charter.
Furthermore, the training to the system engineers to write ODRs on significant issues described in their respective system status reports, as an outgrowth of LER 86-21 and LER 86-23, was apparently ineffective in this case.
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aHIC poem ge6A UA NUCLEA3 p EIULAfoRY COMMIS$10N UCEN2EE EVENT REPORT (LER) TEXT CONTINUATION AmovEc ous No. siso-eio.
EXPIRES: 8/31/88 FAC4WTY NAME H3 DOCKET NUMBER (2) nn" "Lt*. :
RANCHO SECO NUCLEAR GENERATING STATION o ls jo lo j o l3 l 112 81 7 0l2l9 010 0l 6 OF 1 l2 An assessment of the safety consecuences and inolications of the event re.a.. imolication of the event if it occurred durina other olant conditions, especially oower operations - or why it could not have hannened durina oower operations 1.
This includes the availability of other systems or components that can perform the same function as the components and systems that failed durina the event for why there were not any safety implications referrina to the USAR analysis 1.
Summary
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The ODRs written to describe the discrepancies from the NFPA standards outlines problems well known to the District.
This report is made to satisfy the reporting requirements of the NRC.
The discrepancies outlined by the ODRs are compensated by continuous and/or hourly fire watches in the affected parts of the plant.
Prior to fire watches being instituted, safety-consequences were nominal.
Rancho Seco has an active fire protection program based on diverse actions, all designed to minimize eliminate conditions that may initiate or propagate a fire, and mitigate the effects of any fire that might occur in the plant.
Controls (e.g., hot work controls, combustible control), personnel activities (e.g., fire brigades) and hardware systems (e.g., equipment separation) provide the plant with defense in depth against fires.
An individual fire in any specific area of the plant would not preclude shutdown of the plant. An individual fire in any specific area of the plant would not preclude shutdown of the plant.
The NFPA code deviations described in the ODRs were reviewed to determine their impact on the following issues:
o compliance with technical specifications o
impact on the ability to achieve and maintain safe shutdown fire protection system reliability.
o The criteria for plant safety were derived from technical specification requirements and the Fire Hazards Analysis Report (FEAR).
The impact of each issue reported is described below.
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NRc i a atu I u.s, NUCLE AR REGULATORY COMMisslON LICENSEE EVENT REPORT (LER) TEXT CONTINUATION ueRovfo oue No siso-oio4 EXPIRES: 8/31/86 FACILITY NAME 0)
DOCKET NUMBER (2)
LER NUMBER (6)
PAGE (31 NYeIm eIn YEAR RANCIl0 SEC0 NUCLEAR GENERATING STATION o l5 j o [o j o 13 l 112 81 7 012 l 9 j lp 010 01 7 OF TWtf Masse misse a meutet use G-4/N4C Foan Jesr l(17) e Qontrol Room Fire Alarm Annunciation System Testiner The Control Roon fire alarm annunciation system is actuated by detectors that sense fire conditions within fire zones and detectors that sense operation of a fire suppression system.
The fire detectors include:
(1) smoke detectors (2) heat detectors (3). flame detectors (4) air duct smoke detectors Monitoring of the fire suppression systems includes the f
following:
(1) water flow alarm (2) sprinkler system supervision (3) fire pump supervision (4) carbon dioxide system supervision Unsupervised circuits between the " instrument" and the Control Room are required to be demonstrated operable at least once every 31 days by section 4.18.1.3 of Technical Specifications.
The affected local panels are:
H4FCP1 --
Turbine Buildin'7, Transformer Yard H4FCP2 --
Auxiliary Building (other than CO2 zones),
Reactor Building H4FCP5 --
Nuclear Services Electrical Building (NSEB)
H4FCP8 --
Auxiliary Feedwater Pump system and Auxiliary Building Zone 109 H4FDC02A Auxiliary Building CO2 protected zones H4FDC023 Auxiliary Building CO2 Protected zones H4FDCO2C Auxiliary Building CO2 Protected zones The local fire alarm panels and control room annunciators alarm
)
specific fire zones.
The alarm circuits to the auxiliary relays in the local panels and to the control Room annunciators are considered unsupervised because a single break or ground fault will not be distinctly annunciated in the Control Room as a
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trouble signal.
It will either be a false alarm signal or no 1
signal at all.
Because the validity of the Control Room panel 1
indication is based on testing unsupervised circuits every month (which was not adequately performed) the control Room Fire alarm annunciation system was declared inoperable.
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NRC Fere 366A U.S. NUCLEAR REQULATOaY COMMIS$10N UCENSEE EVENT REPORT (LER) TEXT CONTINUATION mRovEo oms No mo-oio4 EXPinES: 8/31/88 f ACILITY NAME (1)
DOCKET NUM8LR (21 LER NUMBER 16)
PAGE(31 n'"
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1 RANCHO SECO NUCIE g NERATING STATION o ls jo lo la l3 l1l2 8l 7 012l9 01 0 0l8 OF glp T3KT tirmars essse 4 seeden est esisseuraaf AIAC Fems JfEA's)(17)
Control Room Fire Alarm Annunciation System (NFPA 72D)
In addition, due to faulty logic conditions, the first detector l
for a carbon dio m e zone (in the Auxiliary Building only) is 1
annunciated as a trouble condition in the Control Room.
The operators will not respond to trouble signals in carbon dioxide protected zones because the same signals are sent whenever the carbon dioxide system is disabled before personnel enter the zone.
This situation was created in 1985 when administrative procedures were changed to drop the requirement that personnel notify the Control Room before the carbon dioxide panels were disabled.
A cross-zoned detection signal (one detector each from the "A" and "B" loop in the room) must be received in order to have distinct fire signal annunciation in the Control Room.
Because two detectors must alarm in order to provide a fire signal, this condition effectively doubles the detector zone spacing and may prevent the operators from re:.:eiving early warning of a fire.
Suppression initiation is unaffected by this detector circuit logic problem C.m, a cross-zoned detection will release CO )*
2 Alarm signals are annunciated av
% local panels over supervised circuits.
The lack of the operdia unsupervised alarm signaling circuit would not prevent automatic suppression from initiating.
The supervised circuits have been tested semi-annually in accordance with Technical Specification 4.18.1.2.
As a result of the ODR, a continuous fire watch was placed at the local fire alarm panels.
The fire watch posting, therefore, provides a
" constantly manned" location directly in front of each local penel.
All detector alarms are correctly annunciated at the local panels.
Operability concerns and technical specifications are, therefore, satisfied.
Tha FHAR fire areas which required automatic fire detection and suppression by the BTP 9.5-1, Appendix A and the applicable section of Appendix R to 10 CFR Part 50, were analyzed (RE: SMUD Report ERPT-E0023, August 1985) when the NFPA code deviations were first reported to the District in August 1985.
The fire watches recommended in ERPT-E0023 wern initiated in 1985.
Additional fire watches were initiated recently to enhance the ability to obtain prompt indication of a fire in those areas.
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NMC P'ere 308A U S. NUCLEAR REGULATORY COMMIS$10N LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Aeraoveo oMe No. siso-oio4 EXPtRES: 8/31/8B PAC 0LITY NAME (1)
DDCKET NUMBER (2)
LER NUMBER (61 PAGE (3) vea
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RANCil0 SECO NUCLEAR GENERATING STATION o ls j o lo j o 13 l 112 8l 7 0l2l9 01 0 019 OF j lp
.. n wnac i.,., mmu nn Eleven fire areas (ten in the Auxiliary Building and one in the 3
Turbine Building) were analyzed (RE: ERPT-E0023).
Three of the l
fire areas had NFPA 72E code deviations which could potentially j
impact prompt detection of a fire.
Although the. detection systems were determined to be operable, fire watch patrols were established where judged necessary to ensure prompt and extinguishment of a fire.
The fire watches will remain in effect until alternative corrective actions are taken.
The following Auxiliary Building zones were determined to have a marginal i
number of smoke detectors for beam ceiling construction (the detector coverage did not meet the criteria from NFPA 72E):
i Zone 13 (Fire Area 17) West 480V Switchgear Room, Mezzanine Level Zone 16 (Fire Area 20) East 480V Switchgear Room, Mezzanine Level g
Zone 43 (Fire Area RG-1) Grade Level Controlled Area In addition to protecting redundant components, automatic fire detection is important to aid the operators in performing manual actions during a fire.
The FHAR credits manual actions in several fire areas.
The fire detection system is intended to provide early warning of fires.
The operators can use this warning to initiate manual actions, if the fire is located in a area requiring manual actions.
Delays in alarm notification can reduce the time available for such action.
The FRAR assumes loss of all functions in a fire area during a fire.
The analysis concludes that an individual fire will not pose a safety concern.
Fire Punos (NFPA 20)
The use of the existing controller for the electric motor driven fire pump impacts only the ability to obtain spare parts for maintenance activities.
This is because the existing controller is obsolete.
A listed controller is available in a warehouse on-site to replace the old controller.
The fire protection water system electric driven fire pump (P-440) and diesel driven fire pump (P-996) have both demonstrated
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the ability to perform their intended functions during
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surveillance tests.
The discrepancies noted are, therefore, 3
judged by the District not to be significant.
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'e NRCF.eun3e6A U.S. NUCLE AJt MOULATORY COMMIS$10N LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Arenoveo owe No. siso-oio4 EXPIRES: $131/N
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RANC110 SECO NUCLEAR GENERATING STATION o ls l0 l0 lo l3 l1l2 81 7 012 l 9 0l0 1l 0 OF 1 lg senw me m m wwc m amn A descrintion of any corrective actions olanned as a result of the event, includina those to reduce the probability of similar event occurrina in the future.
Control Room Fire Alarm Annunciation System Testina An alarm circuit will be installed between each local fire alarm panel and annunciator windows in the Control Room.
The alarm circuits will provide audible and visual indication in the Control Room for each panel.
The operators will then be able to go to the local panel and determine which zone is in alarm.
The new alarm circuits will be tested at least once every 31 days, in conformance with technical specifications.
Control Room Fire Alarm Annunciation System (NFPA 72D)
The fire alarm annunciating system will be upgraded by the conclusion of the next refueling outage (Cycle 8) to comply with NFPA 72D guidelines or demonstrated equivalents.
The detailed evaluation of current design discrepancies will be submitted to the NRC by December 31, 1987.
Prior to the conclusion of the current outage:
Additional smoke detectors will be installed in the East and West 480V Switchgear Rooms.
Alarm circuits will be installed between panels H4FCP1, H4FCP2, H4FCP5, H4FCP8, H4FDC02A and annunciator windows in the Control Room in olace of the continuous fire watch at the local nanels.
The alarm circuit will provide audible and visual indication in the control Room for any detector alarm associated with panels H4FCP1, H4FCP2, H4FCP5, H4FCP8, H4FDC02A and H4FDCO2B and C.
The operators will then be able to go to these local panels and determine which zone is in alarm.
The plan and schedule to complete the long term upgrade modifications will be submitted to the NRC by December 31, 1987.
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NAC fosse 306A U.S. NUCLEAR REGULATORY COMMIS$lON UCENSEE EVENT REPORT (LER) TEXT CONTINUATION ArrHoveo ous No. siso-oio4 EXPIRES; 8/31/88 FACIL87Y NAME III DOCK 4T NUMetR (2)
LER NUMBER (6p PAGE (3) naa
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TJ'#2 RANCHO SECO NUCLEAR GENERATING STATION o ls jo jo jo l311l2 8l 7 012l9 0l0 1 11 OF j lg 13t? drmemo esses e amenseg ses ashakenst NAC #sme M W (17)
Fire Pumos (NFPA 20) i The controller for the electric motor driven fire pump will be replaced by a controller which satisfies NFPA 20 requirements prior to the conclusion of the current outage.
The existing controller satisfactorily passed the surveillance required by technical specifications.
It will be replaced as part of Rancho Seco's improvement in preventive maintenance.
The component is already available on-site.
Root cause response Surveillance Procedures -- monthly circuit check deficiency The District is currently conducting a review of the surveillance program to verify that there is an item for item correspondence between technical specification surveillance requirements and procedures which. implement them.
This program was initially instituted following Notice of Violation 86-06/07.
This evaluation is considering the adequacy of the procedures.
ODRs I
are generated for those instances when deficiencies are uncovered.
ODRs are tracked to completion of corrective actions.
The procedure for Technical Specification 4.18.1.3 was not identified until 1985 because it was the District's position up until that time that there were no unsupervised fire alarm circuits.
The surveillance subsequent to the discovery of unsupervised circuits did not adequately check the entire instrument loop for the alarms.
That procedure, currently SP.338, " Monthly Surveillance of Detector Alarm Circuits," will
.be revised to correctly test the unsupervised circuits following the circuit modification described above.
The modification will allow the District to remove the continuous fire watches at the local panels.
Procedure SP.338 will be revised and performed on the new circuits prior to the removal of the continuous. fire watches.
4 Failure to Drovide timelv renort A provision for reportability determination will be included in
'the "QCI-12" charter.
The District will re-emphasize to all system engineers, and others responsible for documenting and resolving problems, the importance of adhering to the procedure for issuing occurrence description reports (ODRs).
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NMC'F.em 354A U.S. NUCLEAR REGULATORY COMMi&SION UCENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVED OMB NO.3150-0104 EXPIRES: 8/31/88 FACILITY NAME (U DOCKET NUMBER (2)
Lf R NUM8ER (6)
PAGE (3)
Iv eIn U'"
N
' RANCHO SECO NUCLEAR GENERATING STATION o ls jo jo lo l3 l1l2 81 7 0l2l9 01 0 112 OF 1 lp 1
e.,u m n m m mcr sewaun Additional evaluations of non-safety discrecancies d
The remaining NFPA code deficiencies, found in 1985, do not impact technical specifications or safe shutdown analysis.
However, several of these deficiencies affect the overall reliability of the fire protection systems.
Correcting some of these deficiencies would benefit plant operations. 'Many of the deviations identified in 1985 have been corrected, or alleviated i
by changes in the plant.
An internal District report will be prepared by October 31, 1987, an evaluation of reports ERPT E-033, -034, -035, -037, -039, -047 and -048 to identify modifications which should be made to enhance the reliability of the fire protection systems.
Reference to any Drevious similar events at the same plant that are known to the licensee.
LER 86-23 was an instance where the District failed to report conditions in a timely fashion.
Fire protection design discrepancies at Rancho Seco were not previously reported as LERs.
The Enerav Industry Identification System component function identifier and system name of each component or system referred to in the LER.
The fire protection deluge spray systems, suppression sprinkler systems, fire protection hose stations, and fire protection water system electric driven fire pump (P-440)' and diesel driven fire pump (P-996) are all NRC LER System Code "KP."
The Control Room fire alarm annunciation system is NRC LER System Code "IC."
1 1
poRM asea ou S QPO1986 0 624 538,455
 
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$ SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT L" 6201 S Street, P.O. Box 15830. Sacramento CA 95852-1830.(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA GCA 87-202 JNN 151987 l
U. S. Nuclear Regulatory Commission Attn Document control Desk Washington, D.
C.
20555 Docket No. 50-312 l
Rancho'Seco Nuclear Generating Station License No. DPR-54 LICENSEE EVENT REPORT 87-29: FIRE PROTECTION PROGRAM DEFICIENCIES WITH RESPECT TO TECHNICAL SPECIFICATIONS AND COMMITMENTS
 
==Dear Sirs:==
In accordance with the requirements of 10 CFR Part 50.73 (a) (2) (i) (B) and special reporting requirements of technical specifications the Sacramento Municipal Utility District hereby submits Licensee Event Report Number 87-29.
If there are any questions concerning this report, please contact Mr. Ron W.
Colombo at (916) 452-3211, extension 4236.
l Sincerely,
'sYk /k *xo G.
Car And nini Chief Executive Officer, Nuclear Attachment cc:
A. D'Angelo G. Kalman J. Martin (2)
INPO V
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RANCHO SECO NUCLEAR GENERATING STATION 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333 2935
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