05000333/FIN-2014008-01
Finding | |
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| Title | Licensee-Identified Violation |
| Description | The team determined that the condition identified in LER 50-333/2013-003 constituted a Green violation of Condition 2.C(3) of Renewed Facility Operating License DPR-59, in that Entergy did not ensure that equipment required for post-fire safe shutdown was protected from the effects of a postulated fire. Specifically, Entergy did not provide overcurrent protection for wiring associated with DC ammeter indication in the control room to prevent the wires from overheating due to fire-induced faults. The issue was identified by Entergy during review of industry operating experience. Description: During JAFNPPs review of operating experience information from the DavisBesse and Cooper stations, plant staff determined that the condition pertains to JAFNPP. The stations review determined that the plant wiring design for the station battery ammeter circuits contains a shunt in the current flow from each DC battery, with leads to an ammeter in the main control room. The ammeter wiring attached to the shunts does not have overcurrent protection devices, and if one of the ammeter wires shorts to ground during a fire at the same time another DC wire from the opposite polarity on the same battery also shorts to ground (as a result of the fire), a ground loop through the unprotected ammeter cable could occur. With enough current flowing through the cable, the potential exists that the overloaded ammeter wiring could damage safe shutdown wiring in physical contact with the cable resulting in a loss of the associated safe shutdown component or a secondary fire in another fire area. The cause of the condition is that the original design criteria did not specify overcurrent protection for shunt fed ammete
circuits. Renewed Facility Operating License DPR-59, condition 2.C(3) requires Entergy t implement and maintain the fire protection program as documented in the Updated Final Safety Analysis Report and approved in various safety evaluation reports (SERs) including the SER dated August 1, 1979. Section 5.11 of the SER dated August 1, 1979 evaluates the Battery Charger Rooms, and concluded that with the proposed modifications (installation of fire detection and signaling systems), the areas will meet the objectives set out in Section 2.2 of the SER, and are therefore acceptable. The objectives set out in Section 2.2 include (3) maintain the capability to safely shut down the plant if fires occur. Entergy did not meet this requirement, and did not protect other safe shutdown equipment from the effects of postulated fires. Entergy initiated condition report CR-JAF-2013-05546 for evaluation and resolution of the condition. Entergy reported the issue to NRC on October 31, 2013 via event notification 49491 in accordance with 10 CFR 50.72, and initiated LER 50-333/2013-003 to report the issue to NRC in accordance with 10 CFR 50.73. Entergy implemented compensatory measures in accordance with their technical requirements manual for degraded barriers to prevent the spread of a fire to other areas. Entergy subsequently initiated design change EC 48868 to install fuses in the DC ammeter circuits. The team concluded that Entergys interim compensatory measures were commensurate with the risk significance of the issue. Analysis: Entergys failure to protect safe shutdown cables from the effect of postulated fires was a performance deficiency. This issue is more than minor because it is associated with the External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems to prevent undesirable consequences. Specifically, the availability of safe shutdown cables was not ensured for fires in the Battery Charger Rooms, Battery Room Corridor, Cable Spreading Room, Relay Room, and Control Room. As stated previously, Entergy entered this issue into the corrective action program and promptly initiated compensatory measures in accordance with their fire protection program. Inspection Manual Chapter (IMC) 0609, Appendix F, Fire Protection Significance Determination Process, was used to evaluate the issue. Because the spread of fire to other areas if the cable ignited, the condition was considered a high degradation of the fire confinement category. As a result, the issue did not screen in Phase 1. Phase 2 requires the development of credible fire scenarios. An NRC inspector reviewed cable routing information for the ammeter cabling and walked down the cable routing in the plant. The inspector determined that there were no in-situ or transient combustible materials which could result in a credible exposure fire to cause damage to the ammeter cables. This meets the screening criteria of IMC 0609, Appendix F, Step 2.3.5. Therefore, the inspector determined that this licensee-identified violation would be of very low safety significance (Green). In addition, the team concluded that Entergys interim compensatory measures for degraded fire barriers until final resolution of the issue is completed wa commensurate with the risk significance. Cross-cutting aspects are not applicable to ol design issues which do not represent current performance. Enforcement: Condition 2.C(3) of Renewed Facility Operating License DPR-59 requires that Entergy implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in various SERS, including the SER dated August 1, 1979. The August 1, 1979, SER indicates that with the proposed modifications to the battery charger rooms, the ability to safely shut down the plant will be maintained. Contrary to the above, on October 31, 2013, Entergy identified that they did not meet this requirement for the Battery Charger Rooms, Battery Room Corridor, Cable Spreading Room, Relay Room and Main Control Room fire zones and failed to maintain post-fire shutdown cables free of the effects of fire induced cable faults during postulated fires. This issue existed since the plant was constructed in the early 1970s. In addition to the above licensee identified violation the inspector noted that Entergy identified the issue as a result of its operating experience review program. Interim compensatory measures were implemented immediately on discovery, and long-term actions are in progress to correct the deficiency. Entergy is performing an extent of condition review to determine if other DC circuits are susceptible to similar overcurrent conditions as a result of fire-induced circuit faults. The condition was not likely to be identified by other efforts such as normal testing or routinely scheduled reviews such as Quality Assurance or fire protection program reviews. This issue is not linked to current Entergy performance, but rather, is tied to design standards and construction activities in the 1960s and 1970s and there was no prior notice so that Entergy would not have reasonably identified the condition earlier. |
| Site: | FitzPatrick  |
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| Report | IR 05000333/2014008 Section 4OA7 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | D Orr J Rady J Rogge R Fuhrmeister W Schmidt |
| Violation of: | License Condition - Fire Protection |
| INPO aspect | |
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Finding - FitzPatrick - IR 05000333/2014008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2014Q4
Self-Identified List (FitzPatrick)
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