05000266/LER-2007-002

LER-2007-002,

Docket Number
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition
Initial Reporting
ENS 43353	10 CFR 50.72(b)(3)(ii)(B), Unanalyzed Condition
2662007002R00 - NRC Website

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Point Beach Nuclear Plant 05000266 YEAR

Event Description:

With both Point Beach Nuclear Plant units operating in MODE 1 on May 9, 2007, it was determined that 284 manual operator actions employed to achieve and maintain hot safe shutdown were non-compliant with Appendix R Paragraph III.G.1 and III.G.2. This condition was discovered as part of the PBNP transition to NFPA 805. The purpose of NFPA 805 transition task SUP-1 was to document the compliance status of manual actions performed for Appendix R Paragraph III.G.1 and III.G.2 fire areas and fire zones against RIS 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions.

RIS 2006-10 provides the guidance used to assess manual actions for compliance with regulatory criteria.

The identified manual actions were specified to be performed as a result of a fire in an Appendix R Paragraph III G.1 or III G.2 fire area. The manual actions do not meet the criteria specified in RIS 2006-10.

The study identified 39 fire areas with non-compliant manual actions. Per RIS 2006-10, non-compliant manual actions are indicative of missing or degraded fire barriers. A detailed list of the specific fire areas is provided in the Additional Information section of this report. In the ENS notification for Event Number 43353, there was identified three non-compliant actions in Fire Area All and one non-compliant action in Fire Area A61. Further evaluation determined there were six non-compliant actions in Fire Area All and two non-compliant actions in Fire Area A61. These additional non-compliant actions were covered by compensatory actions currently in place.

Event Analysis:

As part of the NFPA 805 transition, a study of plant manual actions was conducted. Currently there are 995 actions specified in procedure FOP 1.2, "Potential Fire Affected Safe Shutdown Components." These actions were compared to criteria set forth in RIS 2006-10. Unless alternative or dedicated shutdown capability is provided or an exemption is granted from Paragraph III.G.2 of Appendix R, circuits which could cause maloperation or prevent operation of redundant trains for post-fire safe shutdown and are located in the same fire area must be protected in accordance with Paragraph III.G.2. The study concluded 284 manual actions did not meet these criteria.

Safety Significance:

Manual operator actions which are required to recover functionality of a system that is credited to achieve and maintain hot safe shutdown for a fire in a III.G.1 or III.G.2 fire area are indicative of a missing fire barrier.

PBNP maintains administrative controls for the introduction of combustible materials and ignition sources to limit the probability of a fire. All areas are provided with fire protection features and most have fire detection and/or suppression systems. The operator manual actions, while non-compliant with the RIS 2006-10, remain proceduralized and provide assurance that hot safe shutdown can be achieved and maintained.

Based on these administrative controls and fire protection features, the safety significance is considered to be low.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) Point Beach Nuclear Plant 05000266

Cause:

Prior to issuance of RIS 2006-10, "Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions," PBNP considered these types of manual actions acceptable. The RIS provided clarification of the regulatory expectations associated with the use of operator manual actions in III.G.1 and III.G.2 fire areas. Actions that were previously considered to be acceptable are now recognized to be non-compliant with Appendix R requirements.

Corrective Action:

The non-compliant manual actions have been documented in the PBNP corrective action program.

Remediation of these conditions will be coincident with PBNP's intent to transition to the risk-informed, performance-based, fire protection approaches contained in NFPA 805.

As compensatory measures, hourly fire watches were implemented for the 39 fire areas of concern in accordance with PBNP procedure OM 3.27, "Control of Fire Protection & Appendix R Safe Shutdown Equipment.

The NFPA 805 transition team will either evaluate the non-compliant manual actions as acceptable due to detailed fire modeling and/or risk assessment or the non-compliant manual actions will be corrected via physical changes to the plant.

Previous Occurrences:

None

Additional Information:

The following table lists the fire area for which a fire may require use of non-compliant manual actions.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6 PAGE (3) # Manual Actions Area Description Fire Area 11 1 B-32 MCC Area A06 1 1 P-2C CVCS Charging Pump Cubicle A03 1 1 P-2B CVCS Charging Pump Cubicle A04 1 1 P-2A CVCS Charging Pump Cubicle A05 6 Chemical Drain, Laundry Tank and Reactor A07 Coolant Pump Seal Filter Room 5 HVAC Equipment Room & Pipeway No. 1 Valve A08 Gallery 5 Primary Auxiliary Building El. 44'& 66' (Except A01-D FX237) 5 Unit 1 Facade A01-G 5 Unit 2 Facade A01-H 3 Radioactive Gas Treatment Area Al 0 6 Pipeway No. 4 Valve Gallery Al 1 1 2P2C CVCS Charging Pump Room Al2 1 2P2B CVCS Charging Pump Room A13 1 2P2A CVCS Charging Pump Room A14 12 2B32 Motor Control Center Area Al 5 21 North Side of Auxiliary Feedwater Pump Room A23N 19 South Side of Auxiliary Feedwater Pump Room A23S 8 D06 Battery Room A25 9 D05 Battery Room A26 7 GO1 Diesel Generator Room A27 7 G02 Diesel Generator Room A28 1 Air Compressor Room A29 2 P206A & P207A Fuel Oil Pump Room A61 7 Diesel Generator Building Train B Areas A71 28 Primary Auxiliary Building El. 8' & Below A01-A 18 Containment Spray/ Safety Injection Pump Room A02 11 Primary Auxiliary Building El. 26' North Wing A01-CN 10 Primary Auxiliary Building El. 26' South Wing A01-CS 9 D106 Battery Room A16 9 D04 Electrical Equipment Room A17 9 D03 Electrical Equipment Room A18 8 D105 Battery Room A19 16 Turbine Building & South Service Building A01-E 1 Yard Area A01-F 1 D305 Swing Battery & D301 Charger Rooms A54 5 Unit 1 Containment Area A36 5 Unit 2 Containment Area A46 7 Train B East Duct Bank & Manholes A68 2 Train A West Duct Bank & Manholes A70