05000275/LER-2012-007-01, Inadequately Compensated Non-Conformances in the Fire Protection Program
| ML13042A097 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/08/2013 |
| From: | Allen B Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-13-008 LER 12-007-01 | |
| Download: ML13042A097 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(9) 10 CFR 50.73(a)(2)(viii)(9) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(9) 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(9) |
| 2752012007R01 - NRC Website | |
text
Pacific Gas and Electric Company February 8, 2013 PG&E Letter DCL-13-008 Barry S. Allen Site Vice President Diablo Canyon Power Plant Mail Code 104/6 P. o. Box 56 Avila Beach, CA 93424 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 10 CFR 50.73 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Licensee Event Report 1-2012-007-01 z Inadequately-Compensated Non-Conformances in the Fire Protection Program
Dear Commissioners and Staff:
Pacific Gas and Electric Company (PG&E) is submitting the enclosed Licensee Event Report (LER) supplement identifying fire areas that did not conform to 10 CFR 50, Appendix R requirements and did not have proceduralized or practiced
. compensatory measures in place. PG&E is submitting this supplement in accordance with 10 CFR 50.73(a)(2)(ii)(B). This LER supplement includes the cause and corrective actions for this event. PG&E will process these corrective actions in accordance with the site Corrective Action Program.
PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this report. PG&E will implement corrective actions in accordance with the Diablo Canyon Power Plant Corrective Action Program.
This event did not adversely affect the health and safety of the public.
Sincerely, 0c:25.~
Barry S. Allen wrl8/6980/50517211 Enclosure cc/enc:
Elmo E. Collins, NRC Region IV Thomas R. Hipschman, NRC Senior Resident Inspector Joseph M. Sebrosky, NRR Senior Project Manager INPO Diablo Distribution A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde
- San Onofre
- South Texas Project
- Wolf Creek
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010)
, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the information collection.
- 3. PAGE Diablo Canyon Power Plant, Unit 1 05000-275 1 OF 6
- 4. TITLE Inadequately Compensated Non-Conformances in the Fire Protection Program
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED YEAR I SEQUENTIAL I REV FACILITY NAME DOCKET NUMBER MONTH DAY YEAR NUMBER NO.
MONTH DAY YEAR Diablo Canyon, Unit 2 05000-323 FACILITY NAME DOCKET NUMBER 10 08 2012 2012
- 007
- 01 02 08 2013
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
D 20.2201 (b)
D 20.2203(a)(3)(i)
D 50.73(a)(2)(i)(C)
D 50.73(a)(2)(vii) 1 D 20.2201(d)
D 20.2203(a)(3)(ii)
D 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A)
D 20.2203(a)(1)
D 20.2203(a)(4)
[Z] 50.73(a)(2)(ii)(9)
D 50.73(a)(2)(viii)(9)
D 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A)
D 50.73(a)(2)(iii)
D 50.73(a)(2)(ix)(A)
- 10. POWER LEVEL D 20.2203(a)(2)(ii)
D 50.36(c)(1)(ii)(A)
D 50.73(a)(2)(iv)(A)
D 50.73(a)(2)(x)
D 20.2203(a)(2)(iii)
B 50.36(c)(2)
D 50.73(a)(2)(v)(A)
D 73.71(a)(4) 100 D 20.2203(a)(2)(iv) 50.46(a)(3)(ii)
D 50.73(a)(2)(v)(9)
D 73.71(a)(5)
D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A)
D 50.73(a)(2)(v)(C)
D OTHER D 20.2203(a)(2)(vi)
D 50.73(a)(2)(i)(9)
D 50.73(a)(2)(v)(D)
Specify in Abstract below or in YEAR
- 6. LER NUMBER I
SEQUENTIAL I NUMBER 2012..
007 REV NO.
01 3
- 3. PAGE OF 6
an alternate compensatory measure (ACM) could be developed and implemented. PG&E established multiple ACMs to address the identified Appendix R non-conforming conditions.
At the start ofDCPP's NFPA 805 transition in December 2005, fire protection regulatory guidance regarding circuit failure issues and multiple spurious operations (MSOs) was still being developed. As a result, PG&E concluded that MSOs were not part of the current licensing basis for Appendix R SSD analysis, and that MSO issues would be tracked and addressed as a part of the NFPA 805 transition. MSOs identified during this transition period were reviewed by an expert panel and the credible scenarios were incorporated into the Appendix R SSD analysis and plant procedures. PG&E implemented CMs, as recommended by the expert panel, until the MSOs could be resolved via the Risk Evaluation process in NFP A 805.
In October 2009, the NRC provided MSO guidance and CM implementation guidance in Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," Revision 2. The purpose of Regulatory Guide 1.189 was to provide clarifications and additional NRC guidance for fire protection programs. PG&E did not evaluate the previously-identified MSOs against the new Regulatory Guide 1.189 guidance.
In 2010, NFPA 805 Project Procedure, EPM-DP-RSD-001 was revised (Revision 2) to establish a process for identifying and evaluating variances from deterministic requirements (VFDRs) as part of the fire risk evaluation process. This procedure established the standard for the NFPA 805 transition project that is still underway.
On March 29,2011, PG&E implemented Plant Procedure XII.DC2, "Regulatory Operating Experience," to provide requirements for proactively communicating, evaluating and acting on industry experience regarding certain NRC violations, proposed changes to regulations, inspection procedures, NRC standards and guidance documents that have a potential to apply to DCPP. This procedure was established as a best practice for DCPP based on lessons learned, but was not applied retroactively to previously published regulatory information.
B. Event Description
On October 8, 2012, during the review ofNFP A 805 variances from deterministic requirements (VFDRs), PG&E identified fire areas that did not conform to 10 CFR 50, Appendix R requirements and did not have proceduralized or practiced CMs in place. PG&E identified these concerns in the course of responding to requests for information and questions from NRC inspectors conducting a DCPP Triennial Fire Protection Inspection. The NRC had requested copies of all the 10 CFR 50, Appendix R, non-compliances identified by NFP A 805 and the ACMs subsequently taken. One of the concerns PG&E identified was the potential to lose both trains of heating, ventilation and air conditioning (HVAC) [VK] to the 480-volt switchgear and battery [BTRY]/inverter [INVT]
rooms in the event of a fire. PG&E originally identified this concern on September 9, 2008; however, PG&E did not implement CMs or make the necessary changes to the SSD analysis or procedures. PG&E also identified the potential to lose all reactor coolant pump (RCP) [P] seal [SEAL] cooling in the event of a fire. PG&E originally identified and evaluated this MSO concern and implemented a CM in 2008. However, the time-critical operator action did not properly account for the time it would take to traverse through the area in which the fire occurred.
This was not addressed by the current SSD analysis or CM for the area. On October 9,2012, at 21:32 PDT, PG&E reported these concerns to the NRC via Event Notification 48395.
YEAR
- 6. LER NUMBER I
SEQUENTIAL T NUMBER I 2012..
007 REV NO.
01 4
- 3. PAGE OF 6
On October 23,2012, the NRC Triennial Fire Protection Inspection team postulated a MSO scenario that could result in steam generator (SG) [SG] overfill. DCPP SSD analysis credits manual closure of the main steam isolation valves [ISV] to isolate steam supply to the main feedwater pumps. However, the time it would take to complete these manual actions could exceed the time to prevent SG overfill. PG&E already had an established CM for this fire area. Accordingly, PG&E documented this new fire concern as an additional item to be addressed by the compensatory measure.
On October 31, 2012, at 21 :28 PDT, PG&E provided an update to NRC EN 48395 identifying that several ACMs were not in plant procedure, CP M-1 0, "Fire Protection of Safe Shutdown Equipment." PG&E identified these concerns while reviewing implementation of ACMs due to questions from NRC inspectors conducting a DCPP Triennial Fire Protection Inspection. PG&E has evaluated this further and concluded that ACMs had been adequately implemented in CP M-10. Therefore, on January 30, 2013, at 16:44 PDT, PG&E retracted the October 31,2012, EN update.
On November 1,2012, while responding to a 2012 NRC Fire Protection Triennial Inspection request for information, PG&E identified that multiple hot shorts could result in the loss of control of the RCP seal charging flow control valve (FCV) [FCV] or fail the valve in the open position. The Appendix R SSD analysis credits anoperator action to open the valve's breaker [BKR] and control the valve from the hot shutdown panel [PL].
However, opening the breaker is not adequate because an additional hot short could prevent control of the valve.
PG&E already had a CM established for this fire area. Accordingly, PG&E documented this new fire concern as an additional item to be addressed by the CM.
PG&E established CMs in accordance with the DCPP Fire Protection Program requirements and plant procedures upon discovery of each condition that did not have a CM established at time of discovery.
C. Status of Inoperable Structure, Systems, or Components That Contributed to the Event None.
D. Other Systems or Secondary Functions Affected
None.
E. Method of Discovery
The concerns were discovered during the response to NRC requests for information and questions from the NRC inspectors conducting DCPP's 2012 Triennial Fire Protection Inspection.
F. Operator Actions
Operators established compensatory measures as required by the DCPP Fire Protection Program requirements.
G. Safety System Responses None.
III. Cause ofthe Problem YEAR
- 6. LER NUMBER j
SEQUENTIAL I NUMBER 2012..
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- 3. PAGE OF 6
PG&E concluded that there was no formal process established to evaluate open items identified during the earlier stages of DCPP's NFPA 805 transition. Also, PG&E had no formal process to assess changes in NRC regulatory guides for impact to DCPP. Therefore, reconciliation of past evaluations had not been performed using current-day NRC guidance.
The most probable cause of the concern identified on November 1,2012, was a human error made in the 1990's by evaluators developing the Appendix R compliance strategy for the RCP seal charging FCV.
IV. Assessment of Safety Consequences
PG&E's risk assessment for the applicable fire areas concluded that these concerns were not risk significant and did not adversely affect the health and safety of the public.
V. Corrective Actions
A. Immediate Corrective Actions PG&E established CMs in accordance with ECG 18.7.1 on the date each concern was identified. PG&E established I-hour roving fire watches in the areas with the potential for a fire scenario to cause a condition where there are no current actions to mitigate the respective concerns in the SSD procedures.
PG&E reviewed the NFP A 805 project open items to ensure they complied with Appendix R or were addressed in the corrective action program with CMs established as necessary. Additionally, PG&E reviewed all alternate compensatory measures implemented by the fire protection program to ensure that all credited ACMs were adequate to ensure SSD. An extent of condition review identified no additional conditions affecting SSD analysis.
B. Other Corrective Actions PG&E developed the following corrective actions to address the concerns ofthis report:
- 1) PG&E will revise Appendix R safe shutdown analysis calculations M-928, "10 CFR 50 Appendix R Safe Shutdown Analysis," M-I088, "10 CFR 50 Appendix R Post-Fire Operator Manual Action Feasibility," and implementing procedure CP M-I0 to incorporate the issue ofloss of HVAC and require the use of portable fans to mitigate that loss.
- 2) PG&E will revise the Appendix R safe shutdown analysis calculations M-928, M-944, "10 CFR 50, Appendix R Alternate Shutdown Methodology - Time and Manpower Study/Safe Shutdown System Considerations," and implementing procedures OP AP 8A, "Control Room Inaccessibility - Establishing Hot Standby," and OP AP 8B, "Control Room Inaccessibility - Hot Standby to Cold Shutdown," to provide control of pressurizer auxiliary spray.
- 3) As part of the NFPA 805 transition, PG&E will review all VFDRs for potential Appendix R compliance concerns to ensure all gaps to Appendix R compliance are adequately addressed while transitioning to NFPA 805.
This action will be completed prior to the NFP A 805 License Amendment submittal.
VI. Additional Information
A. Failed Components None.
B. Previous Similar Events
None.
C. Industry Reports None. 6