ML043310166

Draft Inspection Report Input IR 05000390-04-006 and IR 05000391-04-006

ML043310166
Person / Time
Site:	Watts Bar
Issue date:	05/07/2004
From:	Matt Thomas Division of Nuclear Materials Safety II
To:
References
FOIA/PA-2004-0277 IR-04-006
Download: ML043310166 (4)

See also: IR 05000390/2004006

Text

WATTS BAR TRIENNIAL FIRE PROTECTION INSPECTION REPORT INPUT, Rev. 1 517/04

Inspector:

M.Thomas

'

Report No.: .-50-390,391/2004-006

Inspection Dates: '3/29 - 4/212004 and 4/12-16/2004

.

-

.

1 :

-

I,

1.

REACTOR SAFETY

CORNERSTONES:

Initiating Events, Mitigating Systems, and Barrier Integrity

- ...

.

~7 .:

.1

.

,

.-

.

.

a4 Dn%^

I MUD

riiu ri1uiLiLiUr I I

I II I .Uo I I

.05

O6erational Irnplementation of Post-Fire Safe Shutdown Capability'

a. " Insdection Sone

-

The team reviewed the operational implementation of the SSD capabilityfor an

Appendix R fire in' Fire Areas 14,-27,- 33, or 48 to verify thiat-'(1) the training program for

licensed personnel included main control room (MCR) and alternative safe shutdown

capability; (2) personnel required to achieve and maintain the plant in hot sta'ndby, from

the MCR or auxiliary control room (ACR), following a fire could be provided from normal

onsite staff, exclusive of th'e'fire~brigade; (3) the licensee had incorporated the'

'operability of alternative shutdown transfer and contrbl functions into plant Technical

Specifications (TS); and (4) the liceinsee periodically performed op6rability testing of the

alternative shutdown instrumentation, and transfer and control functions. The team

reviewed abnormal operati!g initruction'(AO) AOI-30.1,' Plant Fires; and ~selected

sections of AO1-30.2, Fire Safe Shutdown. The reviews focused on ensuring that all

required 'functions for post-fir6 safe 6hutdown,' and the6'correspondin'g"equipment

necessary to perform those functions, were included in the pro'edures for the selected

fire areas.

b.

Findings

Introduction: The team identified a non-cited violation (NCV) of Operatinig Licerise

'Condition 2.F. for inadequate implementation of the approved fire protection program

(FPP). The licensee implemented a 'design change notice (DCN) which revised a local

manual operator action (that had been previously approved by the NRC duririg Watts

Bar Unit 1 licensing in 1 995) for a fire in' Room 757-A5 (Fire Area 27). The licensee's

process for evaluating the impact of design changes on the FPP (e.g.', local manual

operator actions) was' not adequate to ehsure that the changes would not adversely

affect the ability to achiev4.and maintain safe shutd6wn'in the event of a fire.

Description: The licensee's process for evaluating the impact of design changes on the

FPP was addressed in several procedures. This included procedures FPDP-3,

Management of the Fire ProtectionReport; SPP-9.3,Plant Modification's and

Engineering Change Control;' and TI-277, Modification Compliance Review -' Fire

Protection. During review of these procedures, the team noted that the process for

evaluating the impact of design changes on FPP local manual operator actions only

addressed whether. emergency lighting was affected (e.g'., changes to emergency light

(</

I'it

positions or additional emergency lights required). The team noted that evaluating the

availability of emergency lighting alone was not sufficient to determine if the local

-

manual operator actions could be performed within the required time in a satisfactory

manner. The procedures did not consider other conditions such as location of the

manual actions with respect to the fire, complexity, accessibility, environmental

considerations, etc., which could affect the operators' capability to perform the action.

This process could result in the licensee inappropriately implementing changes to the

FPP which may, not lead to a safe plant condition and could adversely affect the ability to

achieve and maintain safe shutdown in the event of a fire, without receiving prior NRC

approval.

An example of this process was noted during the team's review of design change notice

(DCN) 39742-A. The licensee implemented DCN 39742-A in December 1997, which

revised a local manual operator action (that had been previously approved by the NRC

during Watts Bar Unit 1 licensing in 1995) for a fire in Room 757-A5 (Fire Area 27). The

DCN added manual switches to the control circuits for MCR air handling units (AHU) A-

A and B-B and identified new local manual operator actions for restarting the AHUs.

The new manual actions replaced previous manual operator actions included in the

licensee's Fire Protection Report.

During implementation of DCN 39742-A, the licensee performed safety

assessment/safety evaluation WBPLEE-97-1 54-0 to evaluate the impact of this DCN on

the FPP. The DON was evaluated against the design and licensing bases and was

found to be acceptable by the licensee. The team noted that the evaluation did not

address the impact of the DCN on FPP emergency, lighting, as required by Procedure

SPP-9.3. .The team further'noted that other conditions which could affect capability of

the operators to perform this new manual action were not addressed, such as,

accessibility, environmental considerations, etc. The new; rmanhual operator action for

AHU A-A was incorporated into Section C.23 of AO1-30.2. This procedure section

provided MCR and local manual operator actions for a fire in Room 757-A5.

During in-plant walkdowns of procedure AO1-30.2, Section C.23, the team observed that

the new switch for AHU A-A and the associated new local manual operator action were

located in Room 757-A2 of the auxiliary building, which was adjacent to Room 757-A5

(Fire Area 27).' The teamn initially questioned'whether this new manual action was within

the capability of the operator performance, based on the potential impact of the fire

brigade activities in the immediate vicinity of Room 757-A2, and possible smoke

migration from Roorm 757-A5 into Room 757-A2. After additional walkdowns of AOI-

30.2, Section C.23, and discussionr of possible scenarios for the fire brigade activities

with licensee fire operations personnel, the team conciuded that the new manual

operator action could reasonably be accomplished within the time required by the Fire

Protection Report (FPR).,

Analysis: The finding adversely impacted the reliability and capability of equipment

required to achieve and maintain a safevshutdown condition following an Appendix R

fire. The finding is greater than minor because it is' associate'd'with the protection

against external factors attribute and degraded the reactor safety mitigating systems

cornerstone objective. The team determined that this finding was of very low safety

significance (green>, because the manual operator action was considered within the

3

capability of the operator and could beyreasonably accomplished within the 15-minute

time specified in the Fire Protection Report. This determination was based on field

walkdowns of the Procedure AO1-30.2, Section C.23, and review of pre-fire plans and

fire brigade activities for a fire in Room 757-A5.

Enforcement: Operating License Condition 2.F requires that the licensee shall

implement and maintain in effect all provisions of the approved fire protection program,,

as described in the Fire Protection Report for Watts Bar Unit 1,-as approved in

Supplements 18 and 19 of the SER (NUREG-0847). License Condition 2.F further --

states that the licensee may make changes to the approved fire protection program

without prior NRC approval, only if those changes would not adversely affect the ability

to achieve and maintain safe shutdown in the event of a fire. The licensee's process for

evaluating the impact of design changes on the FPP was addressed in Procedures

FPDP-3,-Management of the Fire Protection Report; SPP-9.3, Plant Modifications and

Engineering Change Control; and TI-277, Modification Compliance Review - Fire

Protection.

Contrary to the above, the licensee's process for evaluating the impact of design

changes on the FPP (e.g., local manual operator actions) was not adequate to ensure

that the changes would not adversely affect the ability to achieve and maintain safe

shutdown in the event of a fire. The procedures for evaluating the impact of design

changes on FPP local manual operator actions only require that the evaluation address

whether emergency lighting was affected; The procedures did not consider other

conditions such as location of the manual actions with respect to the fire, complexity,

accessibility, environmental considerations, etc., which could affect whether the manual

actions could reasonably be accomplished. This process could result in the licensee

inappropriately implementing design changes which may not lead to safe plant,

conditions and could adversely affect the ability to achieve and maintain safe shutdown

in the event of a fire, without receiving prior NRC approval: This finding is a violation of

NRC requirements and will be identified as NCV 50-390/2004-006-001 Evaluation

Process for Design Changes Which Could Affect Safe Shutdown in the Event of a Fire

Without Obtaining Prior NRC Approval.- This finding was entered into the licensee's

corrective action program as PERs 34252 and 34259.

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Davis, Fire Operations Support -

J. Young, Operations Specialist

.

Other licensee employees contacted included operations, security, and radiation protection

personnel.

II

4

LIST OF DOCUMENTS REVIEWED

Procedures

AO1-30.1, Plant Fires, Rev. 6

AO1-30.2, Fire'Safe Shutdown, Rev.15

SO1-236.01' 125V DC Vital Battery Board 1, Rev. 16;

FPDP-3, Management of the Fire Protection Report, Rev. 4

SPP-9.3, Plant Modifications and Engineering Change Control, Rev. 9

TI-277, Modification Compliance Review - Fire Protection, Rev. 0

Completed Surveillance Procedures

1 -31-0-53-A, 18-Month Verification f Remote Shutdown Transfer Switches for Train A, Rev. 14

1 -S1-0-53-B, 18-Month Verification of Remote Shutdown Transfer Switches for Train B, Rev. 18

Lesson Plans/Job Performance Measures (JPM)

TO BE ADDED BY KATHLEEN

Problem Evaluation Revort (PER)

WBN-00-01 6440-000, Revise Note in AO1-30.2, Section C.69, to be consistent with the FPR

Drawings

1-47W801 -1, Main and Reheat Steam Flow Diagram, Rev. 38

1-47W803-2, Auxiliary Feedwater Flow Diagram, Rev. 49'

1-47W809-1, Chemical and Volume Control System Flow Diagram, Rev. 48

1-47W813-1, Reactor Coolant System Flow Diagram, Rev. 39

1 -47W845-3, Essential Raw Cooling Water Flow Diagram, Rev. 20

1-47W859-1, Cornporient Cooling System Flow Diagram, Rev. 44-

1-47W859-2, Component Cooling System Flow Diagram, Rev. 34

Calculations

WB-DC-40-51, Fire Protection of Safe Shutdown Capability, Rev. 3

WBN-OSG4-031, Equipment Required for Safe Shutdown Per 10CFR50 Appendix R, Rev. 32

Miscellaneous Documents

Technical Specification 3.3.4, Remote Shutdown System Instrumentation

DCN 38919-A, Appendix R Manual Action Requirements

DCN 39742-A, Add Manual Switches to Resolve Appendix R Control Circuit Interaction