05000482/FIN-2008010-01
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Finding | |
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| Title | Post-Fire Safe Shutdown Procedure did Not Identify Diagnostic Instrumentation |
| Description | The team identified an unresolved item concerning the availability of diagnostic instrumentation needed to respond to a loss of reactor coolant pump seal cooling during certain fire scenarios. Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. One of the procedures covered by this requirement is Procedure OFN KC-016, Fire Response. Procedure OFN KC-016, Revision 19, identified that fire damage in the following four fire areas could isolate both reactor coolant pump seal injection and thermal barrier cooling: • Fire Area A-21 Control Room AC and Filtration Units (Room 1501) • Fire Area C-22 Upper Cable Spreading (Room 3801) • Fire Area C-30 South Vertical Cable Chase (Room 3617) Control Building Elevation 2047-6 to 2073-6 • Fire Area C-33 South Vertical Cable Chase (Room 3804) Control Building Elevation 2073-6 Reactor coolant pump seal injection and thermal barrier cooling are the two methods used to cool the reactor coolant pump seals. One method of seal cooling must be maintained during reactor coolant pump operation to prevent seal failure, which, in some cases, could lead to increased seal leakage beyond the capacity of the charging pump. Procedure OFN KC-016 requires operators to recognize when one or both seal cooling methods were lost and take specific mitigating actions. While checking the feasibility of manual actions, the team identified that neither Procedure OFN KC-016 nor any other fire protection program document identified the instrumentation needed to identify a loss of seal cooling. Since the procedure required operators to recognize the loss of cooling and take response actions and the procedure did not identify the instrumentation to be used, the team could not verify that it would remain free of fire damage for fires in these four fire areas. The team was unable to verify that manual actions used as compensatory measures for potential fire damage could be reliably performed (these compensatory measures were implemented in response to Apparent Violation 05000482/2005008-03, Failure to Ensure Redundant Safe Shutdown Systems Are Protected in Accordance with the Provisions of the Approved Fire Protection Program). If the operators failed to implement appropriate actions, seal failure and an uncontrolled loss of coolant could occur. Such a seal failure was not analyzed as part of the approved fire protection program. The team determined that this deficiency may be more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems Cornerstone and could affect the availability, reliability, and capability of systems that respond to fire events to prevent undesirable consequences. Additional information is needed from the licensee in order to determine whether the instrumentation needed to promptly recognize and diagnose challenges to reactor coolant pump seal cooling was available and would be free of fire damage. The significance of this issue will be determined if this issue does involve a performance deficiency. The licensee implemented an hourly fire watch in the affected fire areas as a compensatory measure. The licensee entered this issue into their corrective action program as Condition Report 2008-005171. Enforcement. Technical Specification 5.4.1.d states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Report E-1F9910, Post-Fire Safe Shutdown Analysis, Revision 4, documents an area-by-area analysis of the post-fire safe shutdown capability. The post-fire safe shutdown analysis is part of the approved fire protection program as defined in License Condition 2.C.(5), Fire Protection. The post-fire safe shutdown analysis identified the potential for the loss of reactor coolant pump seal injection and thermal barrier cooling for fires in Fire Areas A-21, C-22, C-30, and C-33. Procedure OFN KC-016, Fire Response, Revision 19, identified the operator actions necessary to mitigate possible failures of equipment due to fire damage in order to implement the post-fire safe shutdown analysis. The team was concerned that the procedural guidance provided may not be adequate to allow operators to successfully perform the required post-fire safe shutdown actions required by the approved fire protection program. This issue could impact the ability to control reactor coolant system inventory and pressure to support the post-fire safe shutdown. Additional information is needed from the licensee in order to determine whether the instrumentation needed to promptly recognize and diagnose challenges to reactor coolant pump seal cooling was available and would be free of fire damage. This information is needed to determine whether a violation existed for this issue. Therefore, this issue is being treated as an unresolved item (URI): URI 05000482/2008010-01, Post-Fire Safe Shutdown Procedure Did Not Identify Diagnostic Instrumentation |
| Site: | Wolf Creek  |
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| Report | IR 05000482/2008010 Section 1R05 |
| Date counted | Dec 31, 2008 (2008Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | G Vasquez J Drake P Jayroe R Kopriva S Alferink A Fairbanks C Alldredge C Cauffman C Long C Peabody D Graves D Loveless G Millera Dahbur J Adams J Mateychick N Okonkw |
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Finding - Wolf Creek - IR 05000482/2008010 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Wolf Creek) @ 2008Q4
Self-Identified List (Wolf Creek)
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