ML051520410

Action Request 000997103

ML051520410
Person / Time
Site:	Harris
Issue date:	10/23/2003
From:	- No Known Affiliation
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2004-0277
Download: ML051520410 (38)

Text

Page I Printed: 10/23/03

'ACTIOi'REQUEST 00099710 3,

Type  : NCR Orig Date: 07/23/03 11 sj 03 :00 Subject 0 1-5 DescriptiOnA DURING THE VALIDATION OF THE HNP SSD ANALYSIS BY THE AE, IT WAS DISCOVERED THAT A POST TED FIRE INDUCED SPURIOUS OPE Cf, NING OF EIT RES IN THE CONTE NTS OF THE bIA REFER TO DRAWING 3al`

THESE TWO VALVES ARE NOT C LY INCL UDED IN T SD ANALYSIS AS REQUIRED EQUIPMENT AND APPE ARS TO BE A HISTORICAL OMMISSION. A REVI THE ' FO R THESE VALVES, DETERMINED THAT THE CABLES OF CONC HOSE CA BLES FOR WHICH A FIRE INDUCED HOT SHORT COULD CAUSE SPURIOU S ACTUATION, ARE SA FOR ICT

.. THE LISTED CABLE ROUTES WERE TRACED ON PLANT TRAY-`AND UIT D RAWINGS. THE RESULTANT ROUTE SHOWED THAT CABLE 2

Ew EAS ARE SIGNIFICANT AS TH BLES FOR ARE ALSO ROUTED IN THESE FIRE AREAS. IF THE POSTULATED FIRE AFFECTED OPERATION OF T THEEN OFbwa R OF THESE VALVES, THEN THE REQUIRED INVENTORY MAY NOT BE A VAILABLE FROM THE RWST. THIS CONDITION IS SIMILAR TO THE P REVIOUSLY REPORTED 0S FER TO LER2002-004-01) FOR THE POTENTIAL FOR F VIA SI SYSTEM VALVES. REFER TOI HO WEVER, WHERE THAT POSTULATED FIREREQUIRED MULTIPLE SPUROIU S OPERATION OF VALVES IN THE FLOW PATH BETWEEN THE THIS CONDITION ONLY REQUIRES A SINGLE 3SPURIOUS OPE IN THE FLOWPATH BETWEEN .

IT IS NOTED THAT COMPENSATOR Y MEASURES, I.E. -HAD ALREADY BE EN IN PLACE FOR HER SSD RELATED ISSUES INJACH OF THE ARE AS OF CONCERN p AND REMAIN IN PLACE.

Priority  : 1 Report To  : Status: APPROVED 07/25/03 Due Date  : 02/10/05 Event Originator : KUNZMJ Originator Group:

Facility  : HNP Department  : JJ8 Organization:

Owed To  : Owed To Group  : ESSUEVAL Dwed To Fac: HNP Department  : Discipline A

Page  : 2 Printed: 10/23/03

• ACTION REQUEST 00099710 Request Attribute Value Reqd Date 1A POT'L OPER/REPORT Y Y 07/23/03 Name : JOHN KUNZMANN Request Attribute Value Reqd Date 2 SUPERVISOR REVIEW Y N 07/23/03 Name : JAMES MANESS Request Attribute Value Reqd Date 2A CR VALID? y Y 07/23/03 Name : JAMES MANESS CT VALVES ARE NOT IN CURRENT SSA.

Request Attribute Value Reqd Date 2B FURTHER INVN REQD Y Y 07/23/03 Name : JAMES MANESS 64L4 PNSC REVIEW AND CONCURRENCE IS REQUIRED FOR LERS. JPY 7/24/03 Request Attribute Value Reqd Date 2C RECOMMENDED OWNER KUNZMANN N 07/23/03 Name : JAMES MANESS Request Attribute Value Reqd Date 2D OPER/REPORT ISSUE Y Y 07/23/03 Name : JAMES MANESS SPURIOUS OPENING OF i VALVES COULD CAUSE DEFENSE I N DEPTH MEASURES IN ALACE FOR FIRE IN THE AREA OF ERN TO MI IGATE SI I FaC DEGRADATION Request Attribute Value Reqd Date 2E MAINT RULE APPLIC Y N 07/23/03 Name : DAVID CORLETT Request Attribute Value Reqd Date 2F SYSTEM 2070 Y 07/23/03 Name : DAVID CORLETT Request Attribute Value Reqd Date 3 OPERATIONS REVIEW N Name :

Request Attribute Value Reqd Date 3A IMMED REPT ISSUE N N 07/23/03 Name : DAVID CORLETT THIS CONDITION IS NOT IMMEDIATELY REPORTABLE DUE TO THE HOURSLY ROVING FIRE WATCH THAT WAS IN EFFECT AT THE TIME OF DISCOVERY.

Request Attribute Value Reqd Date 3B OCR N Name :

Page 3 Printed: 10/23/03 ACTION REQUEST 00099710 request Attribute Value Reqd Date IBI OPER ISSUE N N 07/23/03 lame : DAVID CORLETT request Attribute Value Reqd Date 3B2 REPORT ISSUE Y N 07/23/03 lame : DAVID CORLETT rHIS CONDITION IS REPORTABLE 1equest Attribute Value Reqd Date 3B3 REW N 4ame :

eoquest Attribute Value Reqd Date 3C TRACKING NUMBER N 4ame :

Request Attribute Value Reqd Date I REG AFF REVIEW N

'ame :

Request Attribute Value Reqd Date iA OPER/REPORT ISSUE Y Y 07/24/03 game : JOHN YADUSKY SEE SUPERVISORS COMMENTS IN ATTRIBUTE 2D AND OPERATIONS COMMENTS IN ATTRIBU rES 3A AND 3B2. NOT IMMEDIATE REPORTABLE PER 10 CFR 50.72, BUT 60-DAY WRIT rEN REPORT TO NRC REQUIRED PER 10 CFR 50.73. JPY 7/24/03 Request Attribute Value Reqd Date MAl OPER ISSUE N Y 07/24/03 gTame : JOHN YADUSKY Request Attribute value Reqd Date dA2 REPORT ISSUE Y Y 07/24/03 same : JOHN YADUSKY SEE COMMENTS IN ATTRIBUTE 4A ABOVE. JPY 7/24/03 Request Attribute V alue Reqd Date 4B FOLLOWUP ASG REQD Y Y 07/24/03 game : JOHN YADUSKY NOT IMMEDIATE REPORTABLE PER 10 CFR 50.72, BUT 60-DAY WRITTEN REPORT TO NRC REQUIRED PER 10 CFR 50.73. PLEASE ASSIGN AN ACTION ITEM TO JOHN YADUSKY T D SUBMIT A REVISION TO LER 2002-004 TO REPORT TO THE NRC THE ADDITIONAL CON DITION OF THIS AR. DUE DATE 9/22/03 (60-DAYS FROM EVENT DISCOVERY). JPY 7

/24/03 ********** UPDATE ON 9/11/03: ADDED 'GL91-18' KEYWORD. PER WCM-00 1, PARAGRAPH 5.3.2 FOR DEFECTIVE EQUIPMENT ISSUES REQUIRING PROMPT CORRECTI VE ACTION, SAN ACTION ITEM WILL BE GENERATED FROM THE ASSOCIATED AR TO OUTA 3E AND SCHEDULING REQUIRING CORRECTIVE ACTIONS PROMPTLY (NOT TO EXCEED THE NEXT REFUELING OUTAGE UNLESS JUSTIFIED)." PLEASE ASSIGN AN ACTION ITEM TO D&S (JOHN COOK) TO ENSURE PROMPT CORRECTIVE ACTIONS AT THE FIRST AVAILABLE DPPORTUNITY (DUE DATE 11/10/04 - RFO-12). JPY 9/11/03 Request Attribute Value Reqd Date 4C T. SPEC VIOLATION N Y 07/24/03

.ame : JOHN YADUSKY

Page  : 4 Printed: 10/23/03

-ACTIOI' REQUEST 00099710 Request Attribute V alue Reqd Date

{D ADD'L REPORT REQD Y Y 07/24/03 fame : JOHN YADUSKY SEE FOLLOW-UP ASSIGNMENT REQUIRED IN ATTRIBUTE 4B ABOVE. LER 2002-004-02 (

REVISION o02N OF LER 2002-004) MUST BE SUBMITTED TO THE NRC NO LATER THAN 9

/22/03 (60 DAYS FROM EVENT DISCOVERY). JPY 7/24/03 Request Attribute Value Reqd Date GE PNSC/CIRP REQD Y Y 07/24/03 Name : JOHN YADUSKY PNSC REVIEW AND CONCURRENCE IS REQUIRED FOR LERS. JPY 7/24/03 Request Attribute Value Reqd Date 5 CLASSIFN/ASSIGNMNT 6.A N 07/25/03 Name : VERONICA HAMILTON Request Attribute Value Reqd Date 5A CR VALID? Y Y 07/25/03 Name : VERONICA HAMILTON Request Attribute Value Reqd Date 5B FURTHER INVN REQD Y Y 07/25/03 Name : VERONICA HAMILTON Request Attribute Value Reqd Date 6 MISCELLANEOUS N Name Request Attribute Value Reqd Date 6A COMMENTS N Name :

Request Attribute Value Reqd Date 6B COMMENTS N Name :

Request Attribute Value Reqd Date 6C COMMENTS N Name :

Request Attribute Value Reqd Date 6D COMMENTS N Name :

Request Attribute Value Reqd Date 6E COMMENTS N Name :

Request Attribute Value Reqd Date 6F SCHD ISS CLOS DT N Name :

ACTION REQUEST APPROVAL REVIEW

Page 5 Printed: 10/23/03 ACTION REQUEST 00099710 toute List: 001 Route List Initiator: KUNZMJ Alert Send Send Action Action

?ASSPORT Fac Group/Type Last Name Date Time Taken Date/Time LANESJ HNP ESSDSUPV A I4ANESS 07/23/03 11:41 APPROVED 07/23/03 14:43 ORLED HNP CONTROOM A CORLETT 07/23/03 14:43 APPROVED 07/23/03 15:08 tADUSJ HNP REGREV A YADUSKY 07/23/03 15:08 APPROVED 07/24/03 08:48

{AMILV HUP UNITEVAL A HAMILTON 07/24/03 08:48 APPROVED 07/25/03 10:08

ERALJ NCP CREGREV I GERALD 07/23/03 11

41 07/23/03 12:52 BNP REGREV I 07/23/03 11:41 3RIGHR01 CR3 REGREV I BRIGHT 07/23/03 11:41 07/23/03 12:57 rREND-CAUSE

• acility: HNP Trend 1: EC Trend 2: CM Trend 3: CM1 Date:

Process: N/A Org: N/A Rank: Assign:

Description:

REG OR DESIGN REQT NOT SATISFIED IN THE PHYS/FUNC Facility: HNP Trend 1: EC Trend 2: ES Trend 3: ES2 Date:

?rocess: N/A Org: N/A Rank: Assign:

==

Description:==

DOCUMENT PREPARATION/UPDATE Facility: HNP Trend 1: RC Trend 2: M Trend 3: M2 Date: 08/20/03 Process: N/A Org: ESSD Rank: H Assign:

==

Description:==

INADEQUATE OR FAULTY ANALYSIS WITH EQUIPMENT OR ST MR EQUIPMENT REFERENCES Facility: HNP Unit: 1 Op System: System: 2070 krea: Class: Division:

Equipment Type: OA Equipment: CT-V7SB

omponent Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: ISV Equipment: CT-V7SB Component Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: ISV Equipment: CT-V7SB Component Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: ISV Equipment: CT-V7SB Component Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: MOA Equipment: CT-V6SA Component Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: ISV Equipment: CT-V6SA Component Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: ISV Equipment: CT-V6SA Component Type: Component:

Facility: HNP Unit: 1 Op System: System: 2070 Area: Class: Division:

Equipment Type: ISV Equipment: CT-V6SA Component Type: Component:

Page 6 Printed: 10/23/03 ACTION REQUEST 00099710 LR EQUIPMENT REFERENCES Facility: HNP Unit: 1 Op System: System: 2070 krea: Class: Division:

Equipment Type: TNK Equipment: 1X-SAB-DFW

omponent Type: Component:

Page 7 Printed: 10/23/03

-ACTIO'N REQUEST 00099710 ASSIGNMENT NUMBER 01 SUB Type  : INVN Due Date 09/23/03 Status  : COMPLETE Reschedule  : 3 Pri Resp Group: ESSSUPT Assigned To : J KUNZMANN Sec Resp Group:

Subject  : SIGNIFICANT ADVERSE CONDITION INVESTIGATION Aff Facility: HNP Unit  : System UCR Schedule Ref Organization: Department JJ8_ Discipline Est Manhrs  : Est Comp Date Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 EVALUATOR/ASSIGNEE N Name :

Assignment Attribute Value Reqd Date IA COMMITTED N Name :

Assignment Attribute Value Reqd Date 1B CHANGE BASIS N Name :

DAILY NCR REVIEW MEETING COVER SHEETS SHOWS DUE DATES AS FOLLOWS: 8/13 RCRT

, 8/18 SECTION MGR APPROVAL, 8/20 PNSC, 8/22 INVESTIGATION COMPLETE. REVISE DUE DATE TO 8/22/03 . JAM 8/11/03 Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Assignment Attribute Value Reqd Date 2A COMMENTS EXTENSION REQUEST N 08/12/03 Name : VERONICA HAMILTON REVISE DUE DATE TO 8/18/03. APPROVED BY PAUL FULFORD 8/12/03 (ACTING SECTIO N MANAGER).

Assignment Attribute Value Reqd Date 2B COMMENTS RETURNED N 09/08/03 Name : DAVID SHOCKLEY EXTEND TO 9/8/03 DUE TO PNSC BEING SCHEDULE FOR 9/3/03. ENRG APPROVALS ARE COMPLETE. JAM 8/15/03 THIS AR WAS REOPENED DUE TO AN INADVERTENT APPROVAL OF THE AAA BY PNSC (CONCURRENCE RECEIVED FROM B. DUNCAN). PNSC IS SCHEDUL ED FOR 9/3/03. DL SHOCKLEY Assignment Attribute Value Reqd Date 2C COMMENTS EXTENSION REQUEST N 09/08/03 Name : DAVID SHOCKLEY PNSC RESCHEDULED TO 9/17/03. REVISE DUE DATE OF THIS AR TO 9/23/03. JAM, AP PROVED BY DIYA, THE PNSC HAS SINCE BEEN RESCHEDULED TO 9/10/03, INVESTIGATI ON SHOULD BE COMPLETED EARLIER THAN EXPECTED.

Page 8 Printed: 10/23/03

-ACTION REQUEST 00099710 ussignment Attribute Value Reqd Date 2D COMMENTS BASIS FOR RETURN N 09/15/03

.Tame : DAVID SHOCKLEY REASSIGNED TO KUNZMANN TO INCORPORATE PNSC COMMENTS IN MANESS' ABSENCE. RE TURNED TO KUNZMANN TO INCORPORATE ADDITIONAL COMMENTS FROM OPS.

assignment Attribute Value Reqd Date 2E COMMENTS BASIS FO RETURN N 09/17/03 Name : DAVID SHOCKLEY BASIS FOR RETURN: INCORPORATE PNSC COMMENTS.

COMPLETION NOTES CAUSE/ACTION ASSIGNNENT COMPLETION APPROVAL Route List: 001 Route List Initiator: MANESJ Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time FULFOJ HNP ESSSUPT A FULFORD 08/14/03 14:32 APPROVED 08/15/03 10:09 FULFOJ HNP ESSMGR A FULFORD 08/15/03 10:09 APPROVED 08/15/03 10:09 THERID01 HNP OECOORDS I THERIT 08/14/03 14:32 08/15/03 07:32 HNP PNSC A THERIT 08/15/03 10:09 BYPASSED 08/15/03 14:26 SHOCKD HNP ESSUEVAL A SHOCKLEY 08/15/03 14:26 RETURNED 08/15/03 14:27 FULFOJ HNP ESSSUPT A FULFORD 08/15/03 14:28 APPROVED 08/15/03 14:34 FULFOJ HNP ESSMGR A FULFORD 08/15/03 14:34 APPROVED 08/15/03 14:35 THERID01 HNP OECOORDS I THERIT 08/15/03 14:28 08/18/03 14:27 DUNCAR HNP PNSC A DUNCAN II 08/15/03 14:35 APPROVED 08/20/03 13:33 SHOCKD HNP ESSUEVAL A SHOCKLEY 08/20/03 13:33 APPROVED 08/20/03 14:23 Route List: 002 Route List Initiator: KUNZMJ Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time OCONNS01 HNP ESSSUPT A O'CONNOR 08/21/03 10:10 APPROVED 08/21/03 10:17 OCONNS01 HNP ESSMGR A O'CONNOR 08/21/03 10:17 APPROVED 08/28/03 08:33 HNP PNSC A O'CONNOR 08/28/03 08:33 BYPASSED 09/02/03 08:10 THERID01 HNP OECOORDS I THERIT 08/21/03 10:10 08/26/03 07:19 HNP ESSMGR A THERIT 09/02/03 08:10 BYPASSED 09/04/03 07:21 HNP PNSC A THERIT 09/04/03 07:21 BYPASSED 09/04/03 07:21 SHOCKD HNP ESSUEVAL A SHOCKLEY 09/04/03 07:21 RETURNED 09/04/03 07:22 OCONNS01 HNP ESSSUPT A O'CONNOR 09/08/03 15:23 APPROVED 09/08/03 16:53 DIYAFA HNP ESSMGR A DIYA 09/08/03 16:53 APPROVED 09/10/03 14:41 HNP PNSC A DIYA 09/10/03 14:41 BYPASSED 09/11/03 07:32 THERID01 }HUP OECOORDS I THERIT 09/08/03 15:23 09/09/03 16:34 SHOCKD HNP ESSUEVAL A SHOCKLEY 09/11/03 07:32 RETURNED 09/11/03 07:33 OCONNS01 HNP ESSSUPT A O'CONNOR 09/11/03 09:01 APPROVED 09/11/03 15:52 HNP ESSMGR A O'CONNOR 09/11/03 15:52 BYPASSED 09/15/03 11:15 HNP PNSC A O'CONNOR 09/15/03 11:15 BYPASSED 09/15/03 11:16 THERID01 HNP OECOORDS I THERIT 09/11/03 09:01 09/11/03 11:47 SHOCKD HNP ESSUEVAL A SHOCKLEY 09/15/03 11:16 RETURNED 09/15/03 11:17 DIYAFA HNP ESSSUPT A DIYA 09/15/03 12:14 APPROVED 09/17/03 14:37 DIYAFA HNP ESSMGR A DIYA 09/17/03 14:37 APPROVED 09/17/03 14:37 HNP PNSC A DIYA 09/17/03 14:37 BYPASSED 09/17/03 15:44 THERID01 HNP OECOORDS I THERIT 09/15/03 12:14 09/18/03 10:22 SHOCRD HNP ESSUEVAL A SHOCKLEY 09/17/03 15:44 RETURNED 09/17/03 15:45 HNP ESSSUPT A SHOCKLEY 09/17/03 15:57 BYPASSED 09/18/03 07:07 DIYAFA HNP ESSMGR A DIYA 09/18/03 07:07 APPROVED 09/18/03 07:35 BURNSP HNP PNSC A BURNS 09/18/03 07:35 APPROVED 09/18/03 07:40 THERID01 HNP OECOORDS I THERIT 09/17/03 15:57 09/18/03 10:22 SHOCKD HNP ESSUEVAL A SHOCKLEY 09/18/03 07:40 APPROVED 09/18/03 07:55

Page 9 Printed: 10/23/03 ACTION REQUEST 00099710 ISSIGNMENT NUMBER 04 SUB rype  : CAPR Due Date 11/11/04 3tatus  : CANCELED Reschedule  : Pri Resp Group:

assigned To : J KUNZMANN Sec Resp Group:

ubject

IMPLEMENT EC-54065

%ff Facility: HNP Unit System JCR Schedule Ref  : HlR12D Organization: Department  : JJ8 Discipline Est Manhrs  : Est Comp Date kssignment Attribute Value Reqd Date BENEFIT REALIZED N fame :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N game :

Pssignment Attribute Value Reqd Date 1A COMMITTED Y N 09/19/03 Name : DAVID BARKER ACTION COMMITTED TO NRC IN LER 2002-004-02.

assignment Attribute Value Reqd Date 1B CHANGE BASIS DUPLICATE - CANCEL N 09/22/03 Name : VERONICA HAMILTON SEE ASSIGNMENT #12 Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Page  : 10 Printed: 10/23/03 ACTION REQUEST 00099710 ssignment Attribute Value Reqd Date A LTCA APPROVAL N lame :

.ssignment Attribute Value Reqd Date B LTCA CONCURRENCE N lame IOMPLETION NOTES AUSE/ACTION tSSIGNMENT COMPLETION APPROVAL toute List: 001 Route List Initiator:

Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time HUP ESSDSUPV A HNP ESSSUPT A iAMILV HUP ESSUEVAL A HAMILTON CANCELED 09/22/03 07:53

Page Printed: 10/23/03 ACTION REQUEST 00099710 SSIGNMENT NUMBER 05 SUB ype  : CORR Due Date  : 11/11/04 tatus  : ACC/ASG Reschedule Pri Resp Group:

ssigned To : M FLETCHER Sec Resp Group:

ubject  : ESTABLISH/MAINTAIN COMPENSATORY FIRE WATCH

.ff Facility: HNP Unit  : System CR Schedule Ref rganization: Department  : DC8 Discipline st Manhrs : Est Comp Date

.ssignment Attribute Value Reqd Date ENEFIT REALIZED N

• ame :

.ssignment Attribute Value Reqd Date

.UNIT/SECT EVALUATR N rame :

.ssignment Attribute Value Reqd Date

.A COMMITTED Y. N 09/19/03 lame : DAVID BARKER

OMMITTED ACTION TO NRC PER LER 2002-004-02.

Lssignment Attribute Value Reqd Date

.B CHANGE BASIS N lame :

Lssignment Attribute Value Reqd Date

! MISCELLANEOUS N Tame :

kssignment Attribute Value Reqd Date

'A COMMENTS N lame :

Lssignnent Attribute Value Reqd Date

!B COMMENTS N tame kssignment Attribute Value Reqd Date IC COMMENTS N

'ame :

kssignment Attribute Value Reqd Date 2D COMMENTS N lame :

Assignment Attribute Value Reqd Date 2E COMMENTS N

,Tame :

Page  : 12 Printed: 10/23/03 TACTIONI REQUEST 00099710 Psssignment Attribute Value Reqd Date 3A LTCA APPROVAL N Ilame:

hssignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N

.ame:

OMPLETION NOTES AUSE/ACTION LSSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator:

Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time HNP ESSFP A HNP ESSUEVAL A

Page 13 Printed: 10/23/03 ACTIONu REQUEST 00099710 SSIGNMENT NUMBER 06 SUB

'ype  : EREV Due Date  : 02/10/05

tatus  : ACC/ASG Reschedule Pri Resp Group: ESSSUPT

.ssigned To : J MANESS Sec Resp Group:

ubject  : EFFECTIVENESS REVIEW

.ff Facility: HNP Unit System rCR: Schedule Ref 2rganization: Department  : JJ8 Discipline

st Manhrs  : Est Comp Date

.ssignment Attribute Value Reqd Date IENEFIT REALIZED N rame :

.ssignment Attribute Value Reqd Date

. UNIT/SECT EVALUATR N rame :

.ssigmnent Attribute Value Reqd Date A COMMITTED N rame :

.ssignment Attribute Value Reqd Date

.B CHANGE BASIS N rame :

.ssignment Attribute Value Reqd Date MISCELLANEOUS N rame :

.ssignment Attribute Value Reqd Date A COMMENTS N tame :

.ssignment Attribute Value Reqd Date B COMMENTS N iame :

.ssignment Attribute Value Reqd Date C COMMENTS N ame

.ssignment Attribute Value Reqd Date D COMMENTS N ame

.ssignment Attribute Value Reqd Date E COMMENTS N ame

Page  : 14 Printed: 10/23/03 rACTIOU REQUEST 00099710 Assignment Attribute Value Reqd Date 3 ASSGN INIT DATE N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator:

Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time HNP ESSSUPT A HNP ESSMGR A HNP ESSUEVAL A

Page  : 15 Printed: 10/23/03

ACTION- REQUEST 00099710 LSSIGNMENT NUMBER 10 SUB rype

GNRL Due Date  : 09/22/03 Status  : COMPLETE Reschedule  : Pri Resp Group: LICENSUPV kssigned To : J YADUSKY Sec Resp Group:

subject  : SUBMIT A REVISION TO LER 2002-004 kff Facility: HNP Unit System 3CR  : Schedule Ref Drganization: Department  : IAF Discipline Est Manhrs  : Est Comp Date ussignment Attribute Value Reqd Date BENEFIT REALIZED N Same Assignment Attribute Value Reqd Date 1A COMMITTED N Same :

Assignment Attribute Value Reqd Date 1B CHANGE BASIS N f.ame Assignment Attribute Value Reqd Date 2A COMMENTS N Iame

-OKPLETION NOTES SEE NOTES IN TAB 1 (ASSIGNMENT INFO). JPY 9/19/03 CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: YADUSJ Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time

AVESJ HUP LICENSUPV A CAVES 09/19/03 16:15 APPROVED 09/19/03 16:20 RAMILV HNP ESSUEVAL A HAMILTON 09/19/03 16:20 APPROVED 09/22/03 07:41

Page  : 16 Printed: 10/23/03 ACTION REQUEST 00099710 ASSIGNMENT NUMBER 12 SUB Type  : CAPR Due Date 11/11/04 Status  : NTFY/ASG Reschedule Pri Resp Group: ESSFP Assigned To : J KUNZMANN Sec Resp Group:

Subject  : IMPLEMENT EC 54065 Aff Facility: HNP Unit System UCR Schedule Ref  : HlRl2D Organization: Department  : JJ8 Discipline Est Manhrs  : Est Comp Date Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

Assignment Attribute Value Reqd Date 1A COMMITTED y N 09/22/03 Name : VERONICA HAMILTON ACTION COMMITTED TO NRC IN LER 2002-004-02.

Assignment Attribute Value Reqd Date 1B CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Page 17 Printed: 10/23/03 ACTION REQUEST 00099710 assignment Attribute Value Reqd Date 3A LTCA APPROVAL N lame :

Issignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N fame :

OMPLETION NOTES

AUSE/ACTION

%SSIGNMENT COMPLETION APPROVAL loute List: 001 Route List Initiator:

Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time HNP ESSFP A HNP ESSSUPT A HNP ESSUEVAL A

Page 18 Printed: 10/23/03 ACTION REQUEST 00099710 ASSIGNMENT NUMBER 13 SUB

.ype  : CORR Due Date 09/26/03

tatus

COMPLETE Reschedule  : Pri Resp Group: OPSSSUPV

,ssigned To :W SCOTT Sec Resp Group:

ubject

REVISE AOP-036 iff Facility: HNP Unit System TCR Schedule Ref

)rganization: Department  : H45 Discipline Cst Manhrs  : Est Comp Date Lssignment Attribute Value Reqd Date 3ENEFIT REALIZED N lame :

Lssignment Attribute Value Reqd Date

. UNIT/SECT EVALUATR N Tame :

Lssignment Attribute Value Reqd Date LA COIMITTED N lame :

Lssignment Attribute Value Reqd Date LB CHANGE BASIS N lame :

Issignment Attribute Value Reqd Date 1 MISCELLANEOUS N lame :

kssignment Attribute Value Reqd Date 1A COMMENTS N

'ame :

'5ssignment Attribute Value Reqd Date 2B COMMENTS N lame :

kssignment Attribute Value Reqd Date 2C COMMENTS N lame :

kssignment Attribute Value Reqd Date 2D COMMENTS N lame :

kssignment Attribute Value Reqd Date 2E COMMENTS N

-lame :

Page  : 19 Printed: 10/23/03

.CTION REQUEST 00099710 isignment Attribute Value Reqd Date i LTCA APPROVAL N ime :

isignment Attribute Value Reqd Date 3 LTCA CONCURRENCE N ime :

DMPLETION NOTES iIS ACTIVITY WAS INCLUDED IN, ISSU l

) 9/17/03. BILL SCOTT 9/22/03 9CORPORATED CHANGES EMPORARY CHANGES LC DOC SUB DOCUMENT REV MIN TITLE TYP TYP OR SP POM EMG AOP-036 SAFE SHUTDOWN FOLLOWING A FIR

&USE/ACTION SSIGNMENT COMPLETION APPROVAL oute List: 001 Route List Initiator: SCOTTWO1 Alert Send Send Action Action ASSPORT Fac Group/Type Last Name Date Time Taken Date/Time EBERM HNP OPSSSUPV A WEBER 09/22/03 09:10 APPROVED 09/22/03 11:58 HOCKD HNP ESSUEVAL A SHOCKLEY 09/22/03 11:58 APPROVED 09/22/03 14:55

Motor.-operated al operate-d valves FRare not credited in the SSA. The cables for these motor r not protected from maloperation in postulated fire scenarios.

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Significant Adverse Condition Investigation Form Action Request Number: 99710 Event Time: 1100 Facility: HNP Event Date: 7/23/03 Unit: 1 Investigator: T. Maness Management Sponsor - Paul Fulford/Sean O'Connor (Superintendent - Design Engineering)

Team Leader - Tony Maness (Fire Protection Supervisor - Design Engineering)

Team Members - John Kunzmann - Engineering (Safe Shutdown Program Manager)

1. Event Description/Problem Statement An NRC inspection of the fire protection and safe shutdown program completed on 12/20/02 identified 9 issues that had not been identified prior to the NRC inspection. Issues Included postulated fires in several areas where control wiring damage could result in equipment mal-operation which were not identified in the safe shutdown analysis (SSA), and problems associated with the feasibility of manual actions prescribed In the SSA and implementing procedures. Refer to Mor the root cause investigation regarding these findings.

One of the corrective actions resulting from the root cause investigation was to perform a validation of the HNP SSA.

During performance of Task 4, "Validate Safe Shutdown Equipment List and Logics", of the validation ofte fh P SSA, ould Itresult was discovered that a postlted fire indu In the contents of th N IRe W uo f eth drawin These two valves are not currently included in the HNP SSA as required e ui ment and the omission appears to be a historical. A review of the CWD's for these valves, determined that the cables of concern thse cables for which a fire inded hot short could cause sprious actuatior a r t _

i Ji _ The listed ca butes were traced on plant tray and conduit drawings. The resultant route showed that cable These areas are significant as the cables r alsrouted in these fire areas. If thePos ulated fire affected operation o f then normal charging from -

eit u to the s u opening of either of these valves, then the Truired Bs inventory may not be available from the This condition is, r to the pre condition (refer to LER 2002-004-01) fore pgI*ntSal 10 via Si system valves. Refer t However, where that postulated fire required mill'Wt cnirin^9 to env zrtin - -h-zn In 4h- fin1d nnth h01A1rn h 0RW:nrS

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Problem Statement What Should Be?

NUREG 0800 Attachment 1 (BTP CMEB 9.5-1) section C.5.b (hereafter referred to as NUREG 0800) requires fire protection features be provided for structures, systems and components important to safe shutdown (SSD). These features should be capable of limiting fire damage so that, (a) One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and (b) Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

What Is?

• The HNP SSD Analysis does not include the following components as part of the analysis. The components should be included as they are boundary valves to ensure that the inventory in a SSD credited component is available such that cold shutdown can be achieved and maintained.

-I Control Cables for the following components do not meet NUREG 0800 C.5.b criteria for Protection: -

What Is Wrong?

• All required equipment to achieve and maintain SSD has not been included In the station SSD Analysis.

• Control Cables for proposed SSD equipment do not meet NUREG 0800 criteria for protection.

Real or Potential Consequences:

• For postulated fires In three areas MI( Mdeq uate design measures do not exist to ensure a protected component remains available wHich constitutes an unanalyzed condition. Specifically, the affected valves listed above are required to remain shut to prevent

.A spurious openin of these valves from a fire in any of the three fire areas could result in inadvertl V occ-urhewtrIs o If this transfer of in were to occur, the water used fort,,-

2. Data Collection/Extent of Condition Data Sources Program Documents and Procedures

• NUREG-0800, BTP CMEB 9.5-1, dated July, 1981

• HNP FSAR, Section 9.5.1

• NUREG-1038. HNP RFR Other Reference Information

• LER 02-004-01 Investigation Aporoach/Techniques The scope of this investigation Is focused on tbe issue describ above. However, it Is noted that this issue parallels the issues identified I hich addressed deficiencies associated with the SSD Analysis program. Generic issues as i ey pertain to this investigation will be Included.

The Issue was investigated utilizing gap analysis and barrier analysis as applicable. Document reviews were performed, interviews with personnel knowledgeable of the history of the Fire Protection and Safe Shutdown programs were conducted, and circuit analyses were performed to validate specific findings to support the conclusions of the safety significance analysis and to support corrective action development.

Pertinent Facts/Sequence of Events/Analysis The nature of this issue is not driven by a specific sequence of events.

The Safe Shutdown Analysis refers to some terms that are used in this report.

A. Associated Circuits - Circuits and cables not required to operate for passive safe shutdown components (safety-related, non-safety-related, Class 1E, and Non-class 1E) that have a physical separation less than that required by NUREG-0800, 9.5-1 and have one of the following:

Type 1: A common power source with the shutdown equipment (redundant or alternate) which is not electrically protected from the circuit of concern by coordinated breakers, fuses, or similar devices; Type 2: A connection to circuits of equipment whose spurious operation would adversely affect the shutdown capability; Type 3: A common enclosure with the shutdown cables (redundant and alternative) which are either not electrically protected by circuit breakers, fuses, or similar devices, or will allow propagation of the fire across a fire barrier Into the common enclosure.

B. Nonessential - Equipment and cables not required to perform a safe shutdown function or whose maloperation could have no effect on safe shutdown.

C. Required Cable - Cables for which continuity is required to perform a safe shutdown function.

D. Required Equipment - Equipment required to perform a safe shutdown function or whose maloperation could affect a safe shutdown system's capability.

E. Spurious Siqnal - A signal resulting from a fire-induced electrical hot short, open circuit, or short to ground.

F. Spurious Operation - Maloperation of equipment due to an occurrence of a spurious signal which could affect safe shutdown.

Also, an understanding of the SSD program history and differences between the designations for fire areas vs. safe shutdown areas is warranted.

Fire Protection Program The HNP fire protection program consists of design features, personnel, equipment, and procedures to provide defense-in-depth protection of public health and safety. The purpose of the fire protection program is to prevent significant fires, ensure the capability to safely shut down the reactor, maintain it in a safe shutdown condition in the event of a fire. The program is implemented through plant system and facility design, fire prevention, fire detection, annunciation, confinement, extinguishment, administrative controls, fire brigade organization, inspection and maintenance, training, quality assurance, and testing.

he Fire Protection Program is described in th Iand the plant& WjD rovides a general description'of the fire protection design requirements and administrative controls. ontains the Fire Hazards Analysis (FHA). The FHA Is a physical description of the separate fire areas that have been established in the plant for the purposes of separation of equipment required to shut down the plant in the event of a fire. The FHA describes the locations of physical fire protection features such as rated fire barrier floors and walls, installed fire suppression and detection systems, and manual fire fighting equipment such as hose stations and fire extinguishers. The FHA also Includes a description of the in-situ fire hazards in each fire area, the combustible loads and the equipment required for safe shutdown (SSD). The Safe Shutdown Analysis (SSA) Is a subset to the FHA which looks specifically at the electrical equipment and circuits in the plant required for SSD.

Safe Shut Down Analysis The SSA is incorporated by reference into the FSAR The original SSA was developed by EBASCO in June 1983 and submitted to the NRC along with the FHA as part of the fire protection program submittals. The SSA consists of a series of site calculations, operating procedures, and drawings which combined demonstrate that for a fire in any plant area, the plant can be safely shut down. The SSA consists of the following documents:

This calculation identifies the major assumptions and methodology for the SSA. It identifies the systems and functions required for SSD. It also includes a SSD results summary by fire analysis areas for each of the plant areas.

Attachment A of this calculation identifies the specific components required for SSD and their associated cables and routing. Attachment B of the calc identifies the SSD required circuit location by fire analysis area and it identifies the resolution code for each circuit.

This calculation documents the breaker fuse coordination required for common power supplies with SSD required equipment This calculation Identifies worst case short circuit conditions for use in the breaker fuse coordination II

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These drawings provide a plan view of the SSD circuit raceway routing in the plant by analysis area. They also show raceway fire barriers wrap locations.

These drawings show the credited systems and their SSD flow paths. These drawings are used to a great extent to identify the components required for SSD.

SSA Methodology To achieve SSD, a set of basic required system functions was established which was based primarily on NRC requirements. Using the required system functions, a set of SSD flow diagram drawings were established to identify the necessary system flow paths. Using these drawings, the equipment required for SSD was identified and the equipment's required SSD function (i.e. to open, to Isolate) was identified. Support equipment for the required functions were also identified such as area HVAC cooling. Next, using NRC guidance on circuit analysis, the electrical cables for each piece of equipment was categorized as essential, associated or non-essential. Drawings which identify the specific routing in the plant of the cables were developed and finally an evaluation was performed for each fire area to determine if one train of equipment was maintained free of fire damage. For each fire area the required cables were provided with a resolution code to identify the results of the analysis. The resolution codes detail how the circuit meets the NUREG 0800 requirements. Examples include resolution code 1, the cable Is protected with a 1 or 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier or resolution code 5, post fire manual operator actions include the manual repositioning of this component to the position required for SSD. Post fire operator manual actions were detailed in the Operations procedure (a ffi During the original NRC submittal, a primary focus was a severe fire in th control room that would require evacuation and shut down from 2The onr'nal approved submittal addressed specf erator actions allowed in the control room, and In the plant which were contained In Specific drawings showing the access path ways for each manual action and the location of 8-hour battery backed lighting were de lo ed alo with a time line to show the plant could be shut down using the actions described I also contained any identified operator actions for the other plant fire analysis areas.

In 1990 a major upgrade to the SSA format was conducted resulting in the format that is used today.

At that time t s for areas other than the control room were split out o0_

Extent of Condition The identified deficiency documented in this Investigation came from a review of SSD program constituents (analyses, procedure e .)a,The fundamental nature of the deficiency parallels the findings identified In nd further indicates that the condition extends throughout the program constituents impact any of the other un-reviewed fire areas. A corrective action is included under do perform a validation of the existing SSD program analysis to determine all areas of noncompliance with existing regulatory standards and guidance.

3. Investigation Results f either of the following were to occur:

r the A-train, the following would need to occur.

• . za normally closed, non-SSA credited MOV, would need to spuriously open.

In order for following would need to occur:

ValveF a normally closed, non-SSA credited MOV, would need to spuriously open.

A review of the CWD's for these valves ijd MR = _ Ti determined that the cables of concern, those cables for w1ih a fire induced hot short could cause spurious actuation, are:

I 3 The listed cable routes were traced on plant tray and conduit drawings. The resultant route showed:

These areas are significant as the cables fore also ute areas. If the postulated fire afce prto o~uld be lota eNthe r u e to the ing of eitheof

~reiredMese v!ves, t~henthe Inventory may not be available fro u This condition Is similar to the previously reported.condition (refer to LER 2002-004-01) for the potentialor draining the RWST to the containment sump via SI system valves. Refer to AR #'s However where that postulated fire reCuired multiple spurious operations of valves in the flow path between thethis conditiorion!re ires a single spurious operation of a valve in theflowpath between th A review of the S$A Cable Analysis calculation ound that the analysis does not currently credit However, Calculatio states that "All components whose maloperation could possibly affect essential systems are analyzed to consider the efects of spurious signals". Contrary to this, the affects of .the maloperation of eitherre not considered for the effects on the__b_ _f Inappropriate Act

1. Motor-operated valves en1ot credited in the SSA. The cables for these motor operated valves Zjla re not protected from maloperation in postulated fire scenarios.

Causal Factors

1. Historical error in the original HNP SSD analysis calculations

4. Inappropriate Acts / Equipment Malfunctions Inappropriate Act/Equipment Cause C/Aff Failure or Malfunction Type Description Code C/A Motor-operated valves Historical error in SSD anal is Ma 2, 3, are not credited in Root calculation 4 the SSA. The cables for these motor ogaied valves II.re not protected V4ŽP from maloperation In postulated fire scenarios.

5. Does this event Involve a loss of a Maintenance Rule function? LI Yes 0 No

6. Previous Operating Experience (Internal and External)

In a typical root cause Investigation this section provides lists of internal and external operating experience and an evaluation of how each may provide insights on previously unrecognized failure mechanisms, how SOER recommendations are considered, and an analysis of the effectiveness of previous corrective actions to ensure proposed corrective actions will be effective.

erformed a detailed review of how OE review (internal and external) relative to the SSD program. This review and associated findings are applicable to this investigation and will not be repeated within the scope of this investigation. This root cause investigation referred to HNP LER 97-020-00 but did not discuss why the previous corrective actions did not prevent recurrence. For completeness, this discussion is contained in this root cause. The previous corrective action did not identif or prevent the deficiencies identified by this LER because the valve identified in this fire area was not included in the SSA. The root cause for the previous event performed a review In the additional fire area only of associated cables credited in the SSA.

Two additional OE events were discovered that are pertinent to this issue.

LER 91-004-00, RWST Water Inadvertently Drained to Containment, dated April23, 1991 (Joseph M.

Farley Nuclear Plant)

The LER describes a maintenance activity that resulted in the RWST inventory being transferred to the containment sump. While this LER was not associated with the plant's safe shutdown program, it did establish the potential pathway from the RWST to the containment sump via containment spray system pump suction valves.

LER 03-02-00, Appendix R Safe Shutdown Analysis Issues, dated March 26, 2003 (PrairieIsland Nuclear Generating Plant)

The LER describes a deficiency in the plant safe shutdown analysis where a spurious opening of the containment spray pump suction valves could result In the RWST Inventory being transferred to the containment sump and that specific actions to prevent this diversion were not credited In the plants safe shutdown analysis.

7. Generic Implications ddresses the generic Implications as they apply to the SSD program and defici re aed to errors In the analysis. As a result of the review of the generic Implications under a validation of the HNP SSD program was warranted and is being currently being performed. This deficiency was identified during the validation of the SSD program. The deficiency Identified in the scope of this AR Investigation Is one example of the type of generic deficiencies that are expected to be identified during the validation of the SSD program.

No further review for generic implications Is required.

8. Safety Significance Basis for AR Classification as Siqnificant This AR was classified as significant under the following criteria from CAP-NGGC-0200, Attachment 1:

4.c) - Reportable condition per 1OFR50.72 and 10CFR50.73. One example provided in NUREG-1022, Rev. 2, Section 3.2.4 provided clarity in evaluating this condition:

"Beyond the examples given in 1983, an example of an event reportable as an unanalyzed condition that significantly degraded plant safety would be the discovery that a system required to meet the single failure criterion does not do so. In another example, if fire barriers are found to be missing, such that the required degree of separation for redundant safe shutdown trains Is lacking, the event would be reportable as an unanalyzed condition that significantly degraded plant safety."

Actual Safety Consequences:

All of the findings are based on scenarios that have not actually occurred. Therefore there are no actual adverse safety consequences.

Potential Safety Consequences:

This discussion provides an evaluation of the specific safety significance associated with the Identified deficiency and deemed reportable to the NRC as unanalyzed condition that significantly degrades plant safety.

I

1. The s urious operation of an MOV which could result in transferring of tt

2. Potential for equipment damage/unavailability due spurious actuation of components.

The*111mould be initially used as the suction source unntil such time that this suction Path Is no lonaer'a6aliable. At that time. the ould be relied upon to Drovide suction to the charging pumps. If tha resut pe ofthe purous 'hen ~e~-13-TWOE nedtouse~'

resul penin of teof spuious ethert~imre that system line-u

__e RKNote that the use oP406 has been accepted the NI byas a beInventory source t. le the plant to achieve safe shutdown u ntl1 Refer to Safety Evaluation Reporguplemn3 lolbeot ~ ~

addition to the spurious operation (closure) of an the spurious o eration (opening) Of oD . 1 fire _ a _Hhertnvowevr, based onithe potentia gnitiosoron for the BAT level transmitter cables, it has been evaluated that one of the level transmitters will be unaffected by the postulated [ire as adequate separation from the postulated fire location and the cable exists. Thus, one means oaI be available.

Further, based on the NRC guidance on Risk-informed Inspection Guidance for Post-Fire Safe-Shutdown Inspections, contained in the Federal Register Vol. 68, No. 159, dated August 18, 2003, the WV inspectors need only assume a maximum of two concurrent spurious operations for scenario evaluated. Thus, the licensee need only evaluate and take the necessary respons to a maximum of two concurrent spurious operations for each scenario evaluated. For fire area the two s urious operations which would have the greatest Impact on SSD in case of a ire wouLdbe the The consequences of the above actions are also minimized by the effective implementation of the HNP fire protection program. The HNP fire protection program consists of design features, personnel, equipment, and procedures provided to protect the health and safety of the public. The purpose of the fire protection program is to prevent significant fires, ensure the capability to safely shut down the reactor, maintain it in a safe shutdown condition, and to limit the radioactive release to the environment in the event of a fire. The program is implemented through plant system and facility design, fire prevention, fire detection, annunciation, confinement, extinguishment, administrative controls, fire brigade organization, inspection and maintenance, training, quality assurance, and testing.

The defense-in-depth concept Is used to achieve the desired degree of fire safety. This concept is applied to the fire protection program to achieve an appropriate balance in:

a) Prevention of fire initiation through the administrative controls governing separation and guarding of ignition-sources; b) Prompt detection of fires or incipient fire conditions via installed automatic detection systems In areas containing safety related equipment or in areas of high combustible loading which may expose safety related equipment; c) Effective suppression of fires to limit consequences and to reduce exposure of safety related equipment using installed automatic fire suppression systems backed up by a trained qualified 5-member fire brigade; d) Confinement of fires to their areas of initiation through use of fire barriers, spatial separation and segregation of combustibles; and e) Separation of redundant safety related equipment to maintain operational capability under postulated fire conditions.

Maintenance Rule Impact This Issue does not involve the loss of any Maintenance Rule function.

9. Corrective Actions Planned/Completed Assmt. Assignee Due-Date Corrective Action Type Implement Ro ensure the required analysis Iscompleted for the affected components and cables and to prove a.

CAPR ENG 11/11/04 changes required to S ble analysis calculatiS D analysis calculationrSSD implementing proceduren W and any required field work to protect the cables In accordance with the requirements of NUREG-0800.

ssh and maintain a fire watch I s a compensatory measure until such time that coimpliance with NUREG-0800 Isestablished. (Note: The fire CORR ENG 11/11/04 Ak watch was existing in these areas for a previously identified Issue.) (Fletcher) (Note 1)

Issue a Night Order to Operations describing the identified CORR Ops Completed condition and clarifying the operations response to the event on 09/10/03 described herein. (Warner)

CORR Ops 9/26/03 I the even of the loss of_0 The Interim guidance will remain until the SSA Scott validaton Is complete and full compliance with NUREG-0800 Is ( o )

achieved.

Perform an effectiveness review of the completed corrective actions EREV ENG 2-10-05 (Maness)

Note 1- Corrective action due-dates for the implementation o will exceed the initial due date guidance of CA- GC-0200. Per CAP-NGGC-0200, Attachment 2, Note 3, the following justification is provided as been prioritized based on apparent significance, and completion time estimates were generated based on the expected time for ECR design, maintenance implementation, and ECR closeout.

10.PNSC/CIRP Review required? Yes Z No LII

11. Do you recommend this event be disseminated as an Operating Experience (OE) Program entry? (Refer to CAP-NGGC-0202 Attachment 6 for guidance. If yes, contact appropriate OE Program Coordinator)?

Yes 0 No LI

Action: Implemen o ensure the required analysis is completed for the affected components and cables and to provide any changes re, to SSD cable analysis calculatio SSD analysis calculationSSD implementing procedur and any required field work to protect the cables in accordance with the requirements of NUREG-0800.

Response

Action: Establish and maintain a fire watch in %M_

Was a compensatory measure until such time hat compliance with NUREG-for a 0800 is established. (Note: The fire watch was existing in these areas previously identified issue.) cc"J

Response

ATTACHMENT 4 Sheet 1 of 1 EFFECTIVENESS REVIEW (EREV) FORM Form CAP-NGGC-0200-4-8 EREV Evaluator__ EREV Date:_

AR Number/Title:

Event Summary:_

1. Is the current set of Corrective Actions to Prevent Recurrence the same as in the original approved OYes ONo Corrective Action Plan?

[Indicate changes, additions, deletions, and reason (e.g., training needs analysis required adding training to LOCT, etc.)]

Comments/

References:

2. Have the Corrective Action(s) To Prevent Recurrence been completed and has there been sufficient time for the result of implementation to be assessed?

[Indicate how long the CAPR have been in place and degree to which they have been challenged. D Yes O No Comnments/

References:

3. Are appropriate barriers in place to prevent recurrence of the Event?

[Consider the effectiveness of the barrier resulting from each individual CAPR as well as the collective effectiveness of the barriers.] DYes ONo Comments/

References:

4. Based on a review of Corrective Action data, has a Repeat Event been prevented?

[If review identifies recurrence of this condition or a condition sufficiently similar to indicate the problem still exists indicate NCR# and source (e.g., NAS, PES, INPO, NRC, Self-Assessment, etc.)] DYes ONo Comments/

References:

5. Based on interviews with personnel, has a Repeat Event been prevented?

[If not provide specifics, including references to the Repeat Event documentation. List type of personnel interviewed (supervisors, craft, etc.)]

DYes DNo Comments/

References:

6. Overall, are the Corrective Actions to Prevent Recurrence considered effective such that no further actions are required to prevent recurrence?

Comments/

References:

DYes ONo

-AR 00099710 - - Submit a revision to LER 2002-004 to report to the NRC the additional condition of this AR. - - -

RESPONSE

LER 2002-004-02 (HNP-03-104) was approved and submitted to the NRC on 9/19/03. JPY 9/19/03

-AR 00099710 - - Implemen o ensure the required analysis is completed for the affected com onents and cables and to provide an changes required to SSD cable anal sis calculatlo SSD analysis calculatio SSD implementing procedure d and any required field work to protect the cables in accordance with the requirements of NUREG-0800. --- ((J+

RESPONSE

ARO09099710 - - Revise o include inteji. wr -ural actions to be taken in the event of- The interim guidance will remain until the SSA validation is complete and full compliance with NUREG-0800 is achieved. - - -

RESPONSE: This activity was included inissued 9/17/03. Bill Scott 9/22/03