ML040090218
| ML040090218 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/22/2003 |
| From: | Mark King, Merriweather N, Casey Smith, Necota Staples, Wiseman G Division of Reactor Safety II |
| To: | |
| References | |
| FOIA/PA-2003-0358 IR-02-005 | |
| Download: ML040090218 (4) | |
Text
Briefing Summary of Crystal River Triennial Fire Protection Baseline Inspection Inspection Dates:
June 24-28, 2002 and July 8-12, 2002 Report Number:
50-302/02-05 Inspection Team:
C. Smith, Lead Inspector and Electrical Inspector, D. Billings, Reactor Systems/Operations Inspector, G. Wiseman, Fire protection Inspector, N.
Merriweather, Electrical Inspector, ( for first week of onsite inspection only)
Accompanying Personnel:
M. King, Resident Inspector, VC Summer N. Staples, DRS Intem (bag man trip only)
Scope:
The inspection was conducted in accordance with revised inspection procedure IP 7111105T. The fire areas chosen for inspection were: (1) CC-108-102, Hallway and Remote Shutdown Room: (2) CC-108-106, Battery Charger Room 3A; (3) CC-108-107, 4.16 KV ESB Switchgear Room; and (4) CC164-121, HVAC Equipment Room.
Inspection Results:
No violations or deviations were identified.
The team independently verified several examples where local manual actions were taken in lieu of complying with the requirements of 10 CFR50 Appendix R, Section III.G.2. The licensee identified a similar finding in their self-assessment of the Fire Protection Program performed prior to the NRC onsite inspection. This item was included in the Corrective Action Program as NCR No. 61781. The licensee concurred with the inspection team that current guidelines suggest that FPC should have formally requested Appendix R exemptions or deviations. No such exemptions or deviations were requested during correspondence with NRR concerning the use of manual actions. The team enquired if the licensee in their correspondence with NRR had described the difference between local manual actions and remote manual actions taken from the Main Control Room using plant design features that had been protected in accordance with the requirements of 10 CFR 50 Appendix R, section IlIl. G.2. The licensee confirmed that information provided to NRR was never detailed enough to distinguish the difference between local manual actions taken at the switchgear/MCC or at the component, and remote manual actions taken from the Main Control Room using plant design features protected in accordance with the requirements of 10 CFR 50 Appendix R, Section III.G.2.
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A significant number of local manual actions have been incorporated in OP-880 in order to resolve various Thermo-Lag issues. The 10 CFR 50.59 Evaluation performed to incorporate these local manual actions did not consider the following factors:
Complexity of the new local manual actions The number of manual actions and time available for completion.
Availability of instruments to detect systemicomponent mal-operations.
Human performance under high stress Effects of products of combustion on operator performance.
Available man power, timing, and feasibility of local manual actions.
The licensee has identified this item as corrective action number 2 for NCR 61781 with a due date of October 18, 2002. Operations will, with assistance from engineering, determine the ability of the operators to perform/complete the required local manual actions of OP-880A assuming the worst case fire damage scenario, minimum staffing etc. Changes to the operations procedure will be implemented as required.
The team identified one example where the feasibility /completion of a required local manual action was indeterminate because of hazardous smoke, fire, and water environmental conditions. The extent of condition for this potential concern which involves a significant number of local manual actions has not been determined by the licensee. This item was identified as an URI pending completion of corrective action number 2, which will provide more information for the inspectors to make a significance determination for this potential concern.
Three findings of low safety significance were identified as follows:
NCR No. 65525, Fire in certain areas of the Control room Complex will damage the control cables for FSV-257 and cause the solenoid valve to fail close. This will require manual action outside the Control Room to open the valve to admit water to the Control Room Complex fire hose stations. This local manual action could result in delay of Fire Brigade response time.
NCR No. 61031, Discrepancies were identified during cold shutdown repair walk down of the licensee's pre-staged material while using MP-192. (Appendix R repair kit box). This item was previously identified by the licensee.
NCR 61867, During the fire protection inspection in 2000, an observation was made that a Fire Brigade locker room should have some type of battery backup emergency lighting. PC 00-0653 was generated and assigned to Engineering.
REA 00-0134 was generated and provided a recommendation to provide the battery powered lights. This recommendation has not been implemented.
V General Observations NCR No. 64170; The team identified that a series of computer cabinets (MUX) located in the control room complex had the doors removed. The process used for this plant modification was unknown and assigned to the SRI for follow up.
NCR No. 61321; When reviewing the Improved TS for determination of operability of cell
- 109 of DPBA-1B the team determined that the surveillance procedure was unclear as to whether cleaning was required to be performed if corrosion was identified during visual inspection.
NCR No: 65455: Section 2.2.5.9 of the Appendix "R" Topical Design Basis Document states the following:" Post fire manual actions for III.G.1 and III.G.2 fire areas must be reasonable and be contained either in a special post fire shutdown procedure or in an existing normal, emergency, or abnormal operating procedure." The team identified that this statement conflicts with NRC letter dated May 16, 2002, to Mr. Alexander Marion of NEI which states... the use of manual actions for complying with Section III.G.2 requires staff approval by issuance of an exemption prior to implementation.
NCR No. 65592: The work planning process, CP-1 13B and ADM-NGGC-0104, both reference consideration for combustible transient loading when preparing work packages. The team identified that adequate guidance does not exist, however, to ensure risk significance of transient loads is evaluated prior to work being performed.
NCR No. 65310: The team identified that some design inputs (4) to the FHA and to the IPEEE are different for the CC-108-102 fire area.
NCR No. 64207: The team identified that all fuse data associated with MAR 97-03 01 should be reviewed to ensure that the information is included in the EBD. This is a documentation problem only.
NCR No. 65405: The team identified a drawing error in drawing 208-082 RS-06, Valve DHV-1 (DHV-1 0) should be DHV-1 11 (DHV-1 0). This is a documentation error only.
NCR No. 56381: The team identified a need for a step to be put in AP-880 to actuate FSV-257 (with contingencies ) on confirmation of a fire in the Control complex. This would reduce the burden on the Fire Team Leader and provide for a more rapid fire brigade response.
NUPOST 107348: The team noted that the Chemistry Laboratories (CC95-101) are located directly below several of the NRC selected fire areas. The team enquired as to what controls the the Chemistry Department have in place to minimize transient fire exposures to SSC equipment and cables.
PPR 65608: The team observed that a fire in certain fire areas may affect the operation of FSP-1. Licensee should consider adding this information to Enclosure 2 of the Fire Pre-Plan.
NTM 65579: Fire team leaders are trained to request backup from the fossil fire brigade in the event of a large fire. The team identified that FPC is not conducting fire drills to 0
determine the effectiveness of this response. FPC needs to evaluate and place in the correct procedure, a requirement to conduct a drill at least annually with agencies that would be expected to respond.