ML040280187

Letter to Mullikin, NRC from Sullivan, Brookhaven National Laboratory, Re Triennial Fire Protection Baseline Inspection, South Texas Project Units 1 and 2. IR 05000498-02-003 and 05000499-02-003

ML040280187
Person / Time
Site:	South Texas
Issue date:	06/06/2002
From:	Sullivan K Brookhaven National Lab (BNL)
To:	Mullikin R NRC Region 4
References
FOIA/PA-2003-0358, Job Code J-2843 IR-02-003
Download: ML040280187 (7)

Text

Energy Sciences and Technology Department 8uldig 130 P.O. Box 5000 Upton, NY 11573-5000 Phone 631 344-7915 0.00% ~~~~~~~~~~~~~

631 344-5389 BROOK&F-AWN ~~~~~~~~~~~

NAT yOJCOOL LABORATORY ,, , .

managed by Brookhaven Science Associates b~~~~~~~~~~~~~~~~~~~~~~~fr the U.S. Department of Enarnr wwwbnlgov June 6, 2002 Mr. R Mullilin U.S. Nuclear Regulatory Commission Rgion V 611 Ryan Plaza Drive, Suite 400 Arlington, Texas

Reference:

Triennial Fire Protection Baseline Inspection, South Texas Project Units 1 and 2.

Inspection Report Nos.: 50-498/02-03 and 50-499/02-03

Dear Mr. Mullikin:

The enclosed technical letter report (MLR) describes the results of my activities during the Triennial Fire Protection Baseline Inspection performed at Units 1 and 2 of the South Texas Project . Due to the similarity in design between units, inspection efforts focused on an assessment of the adequacy of fire protection features provided for the following five fire areas of UnitNo. 1: Fire Area 1, 2, 3, 7 and 31 As described in the Inspection Plan, my primary area of responsibility was to provide technical assistance in an assessment of the adequacy of the licensee's Post-fire Safe Shutdown Circuit Analysis.

As you are aware, the following two deficiencies were identified during my review: (1) Implementation ofthe licensee's procedural process for achieving post-fire safe shutdown conditions is largely dependent onthe operators' ability to detect fire-induced mal-operations as they occur. However, the licensee's evaluation had not fily' considered the potential for fire to damage diagnostic instmentation needed to assure this capability in the event of fire; and (2) An inconsistency was identified between post-fire safe shutdown compliance strategies documented m the licensee's Safe Shutdown Analysis (Calc SA01 IMC6023) and the implementing procedure (Operator Action List).

It was a pleasure to work with you and other members ofthe inspection team Please do not hesitate to contact me at 631-344-7915 if you have any additional questions or couments.

, e ' ',y Kenneth Sullivan, Nuclear & Infiucture System Division cc: D. Diamond, wo Enc.

J. Higgins W. Horak, w/o Enc D. Norkin, (NRC)

BROOKHAVEN NATIONAL LABORATORY Energy Sciences & Technology Department Report Input to U.S. Nuclear Regulatory Commission Region IV Triennial Fire Protection Baseline Inspection of South Texas Project (STP)

Units 1 and 2 (JCN: -2843 Task Order 8)

Facility: South Texas Project (STP)

NRC Inspection Report No.: 50498/02-03 and 50-499/02-03 Inspection Conducted May 20-23, 2002 NRC Inspectors:  : R Mulllldn RIV/DRS (Team Leader)

G. Miller RIV/DRS R. Nease RIV/DRS N. O'Keefe RIV/DRP BNL Technical Specialist:

116,toldw Dat6 11

Introduction The inspection effort focused on an assessment ofthe adequacy of fire protection features provided for five specific fire areas that, based on the inspection team's review of the licensee's IPEEE submittal, in-plant walk-downs, and fire protection program documnentation, were determined to have fire-risk significance. The specific fire zones selectedfor review were:

1. Fire Area I (Control Room/Relay Cabinet Area/Watch Supervisor's Office)

2. Fire Area 2 (Multiple fire zones including Train A ESF Switchgear Room)

3. Fire Area 3(Multiple Zones Including Corridor at Elevation 10P)

4. Fire Area 7 (Auxiliary Shutdown Area) and

5. Fire Area 31 (Train B Cable Spreading and Cable Room on Elevation 60')

1. Reactor Safety Cornerstones: Initiating Events, Mitigating Systems IR05 FIRE PROTECTION

.01 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown (Reviewed by other inspection team members)

.02 Fire Protection of Safe Shutdown CaMabilitv (Reviewed by other inspection team members)

.03 Post-fire Safe Shutdown Circuit Analysis

a. Insection Scoe On a sample basis, an evaluation was performed to verify that cables of equipment required to achieve and maintain safe shutdown conditions in the event of fire in the selected fire areas had been adequately protected to ensure that fire-induced faults (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown. During the inspection a sample of components associated with the Component Cooling Water (CC), Charging (CV), Auxiliary Feedwater (AFW), Diesel Generator (DG) and and Reactor Coolant (RC) were selected for detailed review. Specific components include:

System Components CC Pumps I A, B and C Train B CCW Hx Valves MOV 644 and 645 Train A Pump Suction Isolation Valve MOV0052 MOV 404 and FV4493 CV NlCVFCV0201 - CCP IA Min Flow recirc valve CCP Room IA Cooler BlCVMOV0033A, B, C and D - (Seal Water to RCP 1A, B, C and D)

ClCVHCV0218 (Seal Inj Supply Isolation Valve)

BlCVMOV13A and MOV112B (VCT Outlet Isolation Valves)

Charging Pumps 1A, and B AFW Motor Driven Pumps A, B, and C DO D 11,12,13 RC Pressurizer PORVs and Block Valves From this list of components, cable routing data depicting the routing of power and control cables associated with each of the selected components, was reviewed. Additionally, on a sample basis, the team also reviewed the licensee's analysis of electrical protective device (e.g., circuit breaker, fuse, relay) coordination and the adequacy of electrical protection provided for non-essential cables which share a common enclosure (e.g., cable tray) with cables of equipment required to achieve and maintain safe shutdown conditions.

b. Fundings 10 CFR 50.48, "Fire Protection," and Appendix R to 10 CFR 50, "ire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979" establish specific fire protection features required to satisfy General Design Criterion 3, "Fire Protection" (GDC 3, Appendix A to 10 CFR 50).Section II.G of Appendix R requires fire protection features be provided for equipment important to safe shutdown. An acceptable level of fire protection may be achieved by various combinations of fire protection features (barriers, fire suppression systems, fire detectors, and spatial separation of safety trains) delineated in Section M.G.2. For areas of the plant where compliance with the technical requirements of Section U1.G.2 can not be achieved, licensees must eiher seek an exemption ifom the specific requirement(s) or provide an alternative shutdown capability in accordance with Sections lII.G.3 and 11LL ofthe regulation.

In SER Supplement No.2, Sect. 9.5.1.7, Fire Protection Of Safe Shutdown Capability, 1987 the staff states that with the exception of one fire area (containment) two redundant safe shutdown pathways will be available for safe shutdown. The licensee has subsequently revised its methodology to credit the availability of only a single train of shutdown equipment for several fire areas. This revised approach (single train shutdown) meets the requirements of Appendix R Section I.G.

1. Inconsistency Between SSA results and Guidance Provided in Operator Action List From a review of cable routing infinmation provided by the licensee, the inspection team determined that cables associated with redundant trains of the Pressurizer PORVs and Pressurizer PORV Block Valves, are within Fire Areas 2, 7, 3, and 31. Specifically, Train "A" PORV(PCV 655A) and PORV Block valve (MOV000lA) are susceptible to spurious actuation in the event of fire in either Fire Area 2 or 7 and Train

'¶B'TORV (PCV656A) and PORV Block Valve (MOVOOOIB) are susceptible to spurious actuation in the event of fire in either Fire Areas 3 or 31. To mitigate this event, operators are instructed (per the Operator Action List) to actuate disconnect switches that have been installed to ensure closure of a spuriously actuated PORV. While appearing to satisfy the STP fire protection licensing basis, the actions described in the OAL were found to be inconsistent vnth Compliance Strategies documented in the SSA for fire Areas 2, 3, 7, and 31 to the extent that the SSA compliance strategy credits the use of the High Head Safety Injection (SI) Pump as a means of mtigating a fire-induced acation of the PORV. Additionally, although the use of the SI pump is identified on the SSA compliance strategies developed for these areas, the capability and availability of the SI system to perfo this function in the event of fire had not been fully evaluated by the licensee. On 5/23/02 the licensee issued Condition Report No. 02-7750 to track resolution of the apparent inconsistency betweenthe OAL and the SSA.

2. Diagnostic Instrumentation The licensee's post-fire safe shutdown strategy relies heavily on having sufficient instrumentation available to enable operators to properly detect fire-induced mal-operations and implement actions needed to defeat them in a timely manner. Accordingly, the success of this approach is largely dependent on the insumentation being available to ensure prompt detection of any mal-operations that may occur. This type of instrumentation is referred to as "diagnostic instrumentation." As stated in Generic Letter 86-10, "diagnostic instrumentation" is instrumentation needed to assure proper actuation and functioning of safe shutdown equipment and support equipment (e.g., flow rate, pump discharge pressure). The specific diagnostic ins on needed depends on the design of the shutdown capability. From a review of the licensee's documentation (SSA and required equipment list) and discussions with the licensee's staf, it does not appear that "diagnostic instrunentation" has been fully evaluated for the effects of fire damage. On 5/23/02 the licensee issued Condition Report No. 02-7757 to track resolution of this inconsistency.

c. Conclusion

Based on the findings described above, the inspector could not conclude that licensee's strategy for achieving and maintaining post-fire safe shutdown conditions meets the fire protection licensing basis documented by the staff in its Safety Evaluation Report (SER Supplement No.2, Sect. 9.5.1.7, Fire Protection Of Safe Shutdown Capability, 1997).

.04 Alternative Shutdown (ASD) Capabilitv (Reviewed by other inspection team members)

.05 OVerational Implementation of ASD Capability (Reviewed by other inspection team members)

.06 Connunications for Performance of ASD Capability (Reviewed by other inspection team members)

.07 Emergenc Lighting for Performance of ASD Canability (Reviewed by other inspection team members)

.08 Cold Shutdown Repairs (Reviewed by other inspection team members)

.09 Fire Barriers and Fire Area/Zone/Room Penetration Seals (Reviewed by other inspection team members)

.10 Fire Protection Sstems. Features and Equipment (Reviewed by other inspection team members)

.11 CoMensatorv Measures (Reviewed by other inspection team members)

.12 Identification and Resolution of Problems (Reviewed by other inspection team members)

Partial List of Persons Contacted D. Wiegand STP Lead Fire Protection W. Mookhoek STP Licensing R. Piggott STP Liceng F. Cox STP Fire Protection R. Dukes STP Consultant - Safe Shutdown Anabis E. Heacock ST? Electrical Design B. Wiegand STP Cable Routing Partial List of Documents Reviewed Fire Hazards System Design Basis Document (DBD) 7A369MB1033, Rev. 1, 7/26/96 Bechtel Energy Corporation, Post-fire Single Train Shutdown Analysis ST-YB-HL-14152, Rev. 1 Calculation 5AOI IMC6023, Appendix R Evaluation, Rev. 7, 4/1/98 Calculation 85E019EL0003, Safe Shutdown Circuit Analysis Report, Rev. 0, 511/86 Calculation EC5053, Protective Device Coordination for Appendix R., (Sheets: 24 - 33,36,37,42,44, 177, 197, and 200) 3/23/80 Calculation 5EO1 lELOO02, Safe Shutdown Circuit Listing, Rev. 2, dated 4/1/89.

Plant Database Management System (PDMS) cable routing data for selected components Plant Database Management System (PDMS) cable data for cabling routed in trays TR A1XE2ATSAA and TR AIXM3BTrVA I