05000275/LER-2012-007, Regarding Inadequately Compensated Non-Conformances in the Fire Protection Program
| ML12342A414 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/07/2012 |
| From: | Allen B Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-12-125 LER 12-007-00 | |
| Download: ML12342A414 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(8) |
| 2752012007R00 - NRC Website | |
text
Pacific Gas and Electric Company December 7,2012 PG&E Letter DCL-12-125 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 1-2012-007-00, 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) identifying fire areas that did not conform to 10 CFR 50, Appendix R requirements and did not have established, proceduralized, or practiced compensatory measures in place. PG&E is submitting this LER in accordance with 10 CFR 50.73(a)(2)(ii)(B).
PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this report.
This event did not adversely affect the health and safety of the public.
Sincerely,
&-~~
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 (10-2010) u.s. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013
, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
LICENSEE EVENT REPORT (LER)
(See reverse for required number of digits/characters for each block) 05000-275
- 3. PAGE Diablo Canyon Power Plant, Unit 1 1 OF 5
- 4. TITLE Inadequately Compensated Non-Conformances in the Fire Protection Program
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR I SEQUENTIAL I REV MONTH DAY NUMBER J NO.
YEAR Diablo Canyon, Unit 2 05000-323 FACILITY NAME DOCKET NUMBER 10 08 2012 2012 - 007 -
00 12 7
2012
- 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 SO.73(a)(2)(i)(C)
D SO.73(a)(2)(vii) 1 D 20.2201(d)
D 20.2203(a)(3)(ii)
D SO.73(a)(2)(ii)(A)
D SO.73(a)(2)(viii)(A)
D 20.2203(a)(1)
D 20.2203(a)(4)
[(] SO.73(a)(2)(ii)(8)
D SO.73(a)(2)(viii)(8)
I---------t D 20.2203(a)(2)(i)
D 50.36(c)(1)(i)(A)
D SO.73(a)(2)(iii)
D SO.73(a)(2)(ix)(A)
D 20.2203(a)(2)(ii)
D SO.36(c)(1)(ii)(A)
SO.73(a)(2)(iv)(A)
D SO.73(a)(2)(x)
- 10. POWER LEVEL D 20.2203(a)(2)(iii)
B 50.36(c)(2) 50.73(a)(2)(v)(A)
D 73.71(a)(4)
D 20.2203(a)(2)(iv) 50.46(a)(3)(ii)
D SO.73(a)(2)(v)(8)
D 73.71(a)(S)
D 20.2203(a)(2)(v)
D 50.73(a)(2)(i)(A)
D SO.73(a)(2)(v)(C)
D OTHER D 20.2203(a)(2)(vi)
D 50.73(a)(2)(i)(8)
D SO.73(a)(2)(v)(D)
Sp~cify in Abstract below or In YEAR
- 6. LER NUMBER I
SEQUENTIAL I NUMBER 2012 -
007 REV NO.
00 Appendix R require compensatory measures in accordance with DCPP Equipment Control Guideline (ECG) 18.7.1, "10 CFR 50 Appendix R Fire Rated Assemblies."
B. Event Description
- 3. PAGE 3
OF On October 8, 2012, during the review ofNFPA 805 VFDRs, PG&E identified fire areas that did not conform 5
to 10 CFR 50, Appendix R requirements and did not have established, proceduralized, or practiced compensatory measures in place. PG&E identified these concerns in the course of responding to requests for information and questions from NRC inspectors conducting a triennial fire protection inspection. One of the concerns PG&E identified was the potential to lose both trains of heating, ventilation and air conditioning [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 compensatory measures 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 compensatory measure 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. PG&E identified the potential to lose the ability to trip the running RCPs in the event of fire. This was not addressed by the current SSD analysis or compensatory measure for the area. On October 9,2012, at 16:30 PDT, PG&E reported these concerns to the NRC via Event Notification 48395.
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. Compensatory actions had already been established prior to identifying this concern.
On October 31,2012, PG&E provided an update to NRC EN 48395 identifying that several alternate compensatory measures were not in plant procedure, CP M-10, "Fire Protection of Safe Shutdown Equipment."
PG&E is currently.evaluating this further and will provide the conclusions in a supplemental report.
On November 1,2012, PG&E identified a MSO that could result in the loss of control of the RCP seal charging flow control valve [FCV] or fail the valve in the open position. The Appendix R SSD analysis credits an operator 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 as an additional hot short could prevent the control of the valve.
Compensatory actions had already been established prior to identifying this concern.
PG&E established compensatory actions in accordance with the DCPP Fire Protection Program requirements and plant procedures upon discovery of each condition that did not already have one established. Also, PG&E reviewed the extent of these conditions and identified no additional issues.
YEAR
- 6. LER NUMBER I
SEQUENTIAL I NUMBER 2012 -
007 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
REV NO.
00 4
- 3. PAGE OF The concerns were discovered during the response to requests for information and questions from the NRC inspectors conducting DCPP's 2012 Triennial Fire Protection Inspection.
F. Operator Actions
Operators established fire watches as compensatory measures as required by the DCPP Fire Protection Program requirements.
G. Safety System Responses None.
III. Cause of the Problem PG&E will provide the cause in a supplemental report.
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 compensatory measures 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.
B. Other Corrective Actions PG&E will provide the corrective actions in a supplemental report.
VI. Additional Information
A. Failed Components None.
B. Previous Similar Events
None.
C. Industry Reports None.