05000255/FIN-2007005-01
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Finding | |
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| Title | Incorrect Instructions to Operators in Appendix R Post Fire Alternate Safe Shutdown Procedure |
| Description | For Fire Area (FA) 9, Intake Structure, the inspectors reviewed SSA reports EA-APR-95-007, 10 CFR Part 50, Appendix R, Fire Safe Shutdown Analysis Report, Revision 3, Appendix D, and EA-APR-95-008, 10 CFR Part 50, Appendix R, Safe Shutdown Manual Actions Feasibility Analysis, Revision 2, Appendix A. The inspectors also reviewed component fire protection logic diagrams, P&IDs, ASD procedures and electrical design drawings. During this review, the inspectors identified several discrepancies in the Compliance Strategies provided in SSA report EA-APR-95-007, for safe shutdown valves CV-1318, Service Water Header Isolation Valve, and CV-1359, Service Water to Non-Critical Loads. Specifically, for CV-1318, the SSA report stated that a fire in FA 9 is assumed to damage cables to CV-1318 and may cause the valve to fail open or spuriously close. The Compliance Strategy in the analysis for safe-shutdown valve CV-1318 stated, deenergize CV-1318 at ED-11-2, breaker 72-129 in room 224 (cable spreading room) in order to fail the valve open. Similarly, for CV-1359, Non-Critical Service Water Isolation, the SSA report stated that a fire in FA 9 is assumed to damage cables to CV-1359 and may cause this valve to fail close or spuriously open. The Compliance Strategy in the analysis for safe-shutdown valve CV-1359 stated, to isolate the non-essential service water header, de-energize CV-1359 at ED-11-2, breaker 72-129 in room 224 (cable spreading room) in order to fail the valve closed. The inspectors reviewed related electrical single line, schematic and logic diagrams and determined that references to 125 Vdc electrical distribution cabinet ED-11-2 and breaker 72-129 were incorrect for safe shutdown valves CV-1318 and CV-1359 and should have been D-21-2 and breaker 72-229 to confirm to the as-built plant configuration. Similar discrepancies were noted with 11 additional safe shutdown CV circuits fed from the same breaker 72-229, located in cabinet D-21-2. The inspectors also reviewed Attachments 3 and 5 of procedure ONP - 25.2, Alternate Safe Shutdown Procedure, dated January 16, 2007, Revision 22, to determine if the procedure provided adequate instructions/steps for the operator to follow in the event of a fire. This procedure is used for ASD and to mitigate spurious operation of electrical components. The function of ONP-25.2 is to procedurally implement the compliance strategies of the Appendix R SSA, to ensure that SSD performance goals of reactor reactivity control, reactor coolant inventory control, reactor coolant pressure control, decay heat removal, process monitoring, and support functions are met when mitigating the effects of fires in alternate shutdown areas. Achievement of these performance goals ensures that the reactor will be safely shut down, cooled down and maintained in a shutdown condition. The inspectors identified a number of discrepancies in the instructions/steps of Procedure ONP-25.2. The inspectors determined that from December 6, 1995, to May 10, 2007, procedure ONP-25.2, Attachment 3, Manual Actions to Mitigate the Spurious Operation of Air-Operated Valves, instructions/steps for 13 of 20 CVs were inconsistent in that they specified an incorrect electrical distribution panel number as the location of a breaker which feeds the 20 safe shutdown CVs. Specifically, Attachment 3, specified 125Vdc distribution panel number D21-1, as the location of breaker 72-229. Consequently, the procedure instructed the operator to open circuit breaker 72-229 at DC distribution panel D21-1 to de-energize the 13 CVs in order to mitigate potential spurious operations of these valves. Breaker 72-229 provided 125Vdc control power to CV solenoids in CW, SW, and ESS systems. However, circuit beaker 72-229 is actually located at DC distribution panel D21-2. In order to evaluate the significance of the procedure error, the inspectors observed a simulated operation by a former operator familiar with the subject operations procedure. The overall intent was to observe the simulated use of discrepant Procedure ONP-25.2 and determine the feasibility and timeliness of the operator actions at the alternate shutdown location of the DC distribution cabinets. The inspectors concluded, based on this observation, that in the event of a control room or intake structure fire, the operator would be challenged and potentially not be successful in completing the required procedure instructions/steps within the assumed times for completion of the activity. For example, the operator action required to de-energize and close CV-1359, by opening breaker 72-229 had time constraint of 3.43 minutes from time of fire/spurious valve actuation in order to isolate the non-essential service water header and prevent overheating the Diesel Generator. Based on the observations, the inspectors could not conclude that the action would have been successful due to the incorrect procedure. Upon discovery, the licensee placed this issue into their corrective action program as AR 01087847, AR 01088311 and AR 01088327. The licensee performed an extensive extent of condition review per AR 01087847-1 for this finding and identified a number of additional similar discrepancies in procedures ONP-25.1, ONP-25.2, several fire protection analyses and Appendix R drawings. For example, licensee identified that safety injection refueling water (SIRW) level indicator LI-0332B, located on remote shutdown panel C-150A, was incorrectly identified in ONP-25.2 as LI-0322B located on panel C-150. Also, 480Vac breaker 52-227 was incorrectly identified as52-225 on Attachment 4 of ONP-25.2 for MO-2160. The licensee generated corrective actions to evaluate the identified discrepancies and make the applicable corrections to the affected documents. On May 6, 2007, the licensee also initiated CAP 01087686 to document that specific diagnostic instruments to be used to identify or confirm spurius signals (operations) were not completely identified in post fire alternate shutdown procedures ONP-25.1 and ONP-25.2, and in the safe shutdown manual action feasability analysis. Licensee compensatory actions included hourly fire tours, further evaluation of the manual actions and risk significance in accordance with enforcement discretion requirements for plants transitioning to NFPA - 805. Since, this finding was indirectly related to a circuit-analysis issue and the licensee was in transition to NFPA 805, this finding is considered an Unresolved Item (URI 05000255/2007005-01(DRS) pending the licensees completion of a risk assessment evaluation to determine risk significance in accordance with established the NRC Enforcement Discretion regarding plants in transition to NFPA 805. Subsequent NRC review of the risk evaluation will determine if this finding meets the four criteria established by Section A of the NRC\\\'s Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) |
| Site: | Palisades  |
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| Report | IR 05000255/2007005 Section 1R05 |
| Date counted | Jun 30, 2007 (2007Q2) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | C Zoia A Dahbur J Cassidy J Ellegood T Taylor A Scarbearyd Schrumz Falevits M Munir |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2007005 | |||||||||||||||||||||||||
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Finding List (Palisades) @ 2007Q2
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