United States Nuclear Regulatory Commission - Protecting People and the Environment


ACCESSION #: 9804230185

                       LICENSEE EVENT REPORT (LER)



FACILITY NAME:  Clinton Power Station                     PAGE: 1 OF 6



DOCKET NUMBER:  05000461



TITLE:  Remote Shutdown Panel Operation of Reactor Core Isolation

        Cooling System May be Prevented Following Main Control

        Room Fire Due To Supplier Design Lacking Circuit

        Isolation



EVENT DATE:  09/29/86   LER #:  98-013-00   REPORT DATE:  04/20/98



OTHER FACILITIES INVOLVED:  None                    DOCKET NO:  05000



OPERATING MODE:  5   POWER LEVEL:  000



THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR

SECTION:

50.73(a)(2)(ii)

OTHER



LICENSEE CONTACT FOR THIS LER:

NAME:  D. L. McMillan, Corrective Action Team

        Lead Engineer                       TELEPHONE:  (217) 935-8881,

                                                         Extension 3920



COMPONENT FAILURE DESCRIPTION:

CAUSE:      SYSTEM:       COMPONENT:       MANUFACTURER:

REPORTABLE NPRDS:



SUPPLEMENTAL REPORT EXPECTED:  NO



ABSTRACT:



With the plant in COLD SHUTDOWN, engineers identified that electrical

short circuits caused by fire-related cable damage following a fire in

the Main Control ROOM (MCR) may prevent the Reactor Core Isolation

Cooling (RCIC) System from being operated from the Remote-Shutdown Panel

(RSP) as designed.  The engineers identified that two cables interfacing

with the control circuit for the RCIC turbine cannot be isolated from the

MCR by operation of the remote transfer switch.  The cause of this event

is attributed to an error in a supplier design change.  Additionally,

corrective actions for previously identified design error were

ineffective in identifying the potential extent of the issue.  Corrective

action for this event includes revising the engineering review standard

for fire protection/safe shutdown, performing a comprehensive review of

safe shutdown required equipment circuits for operation from the RSP, and

modifying the RSP interface with the two RCIC cables to provide adequate

isolation.  This event is also reportable under 10CFR21.



END OF ABSTRACT



TEXT                                                          PAGE 2 OF 6



DESCRIPTION OF EVENT



On March 25, 1998, the plant was in mode 4 (COLD SHUTDOWN) during the

sixth refueling outage, and reactor (RCT) coolant temperature was being

maintained within a band of 95 to 115 degrees Fahrenheit and pressure was

zero pounds per square inch.  Engineers were conducting circuit analysis

reviews in response to recommendations in an engineering evaluation

prepared to address an audit finding.  At about 1730 hours, the engineers

identified that operation of the Reactor Core Isolation Cooling (RCIC)

System [BN] may not be available from the Remote Shutdown Panel [PL]

(RSP) as designed as a result of electrical short circuits caused by

fire-related cable [CBL] damage (hot shorts) following a fire in the Main

Control Room (MCR).  Condition Report (CR) 1-98-03-499 was initiated to

track further investigation and resolution of this issue.  Operations was

notified of this condition and placed a restraint against entering Modes

1 (POWER OPERATION), 2 (STARTUP), and 3 (HOT SHUTDOWN).  Per Technical

Specification 3.5.3, "RCIC System," the RCIC system is required to be

operable in Modes 1, 2, and 3 with reactor steam dome pressure greater

than 1150 pounds per square inch gage; therefore, there was no immediate

impact on plant operation.



10CFR50, Appendix R, Section III.G.3, requires that remote shutdown

capability be provided for areas which do not meet the physical and

electrical separation requirements of Section III.G.2 of Appendix R.  The

remote shutdown capability must be physically and electrically

independent of the area of concern such that one safe shutdown method

remains available from locations outside the area of concern.  This

electrical independence criteria includes postulation of the circuit

failure modes described in NRC Generic Letter 86-10, Section 5.3.1.  To

mitigate the potential adverse affects of the postulated circuit failure

modes on the selected safe shutdown method, remote transfer contacts are

installed in the control circuits for selected safe shutdown equipment to

isolate the portion of the equipment control circuit from the area of

concern.



Clinton Power Station provides remote transfer capability for the RCIC

system to provide reactor pressure vessel level control for the remote

shutdown method.  The engineering reviews discussed above identified that

two cables in the control circuit for the RCIC turbine [TRB] cannot be

isolated from the area of concern (Main Control Room) by operation of the

respective remote transfer switch (HS).  The cables are 1RI85B and 1RI85C

which are routed from the RSP, 1c61-P001 to Main Control Room Panel

1H13-P706E.



In August 1985, prior to initial plant fuel load the final revision of

General Electric (GE) Field Deviation Disposition Request (FDDR) LH1-1308

was issued to install interface connections to the RCIC system to provide

inputs for the GE Transient Analysis Recording System (GETARS) (IQ)

equipment.  The GE design of this FDDR included connection of signal

monitoring interfaces with the RCIC control and indication circuits

between the MCR multiplexers [MPX] and the RSP.  The design did not

provides adequate isolation from some MCR circuits and connecting cables

via transfer switch contacts to address the potential for fire-induced

circuit failure modes.  The design lacked isolation for cable 1RI85C

connected to the flow control input at the signal converter [CNV],

1E51-N590, and cable 1RI85B connected to the RCIC turbine EG-M Control

Box, 1351-N591, speed output to the turbine tachometer [TAC].  The FDDR

included specifications for connecting other MCR GETARS inputs to RCIC

signals, but those specifications did include interface modules at the

RSP that provided adequate isolation features.



TEXT                                                          PAGE 3 OF 6



On July 9, 1997, an engineering review of Updated Safety Analysis Report

(USAR) Appendix F, "Fire Protection Safe Shutdown Analysis," identified

that operation of the Division 1 Essential Switchgear Heat Removal System

supply air fan [FAN] discharge damper [DMP], 1VX03YA, may not be

available from the RSP following a fire in the MCR due to electric shorts

resulting from fire-related cable damage.  On July 16, 1997, CR

1-97-07-164 was initiated to document further evaluation of this issue.

A review to determine the extent of this issue included other heating,

ventilating and air conditioning (HVAC) systems required for safe

shutdown; however, no similar control circuit errors were identified.

The cause of this event was attributed to oversight in the original

design of either the Essential Switchgear Heat Removal System, or the

Remote Shutdown System.  This issue was reported in LER 97-019.



On July 31, 1997, engineers were performing a vertical slice review of

selected safe shutdown components in response to audit finding CR

3-97-06-310.  During the review, the engineers determined that operation

of the Division 1 Diesel Generator Feed Breaker, 252-DG1KA, may not be

available from the RSP following a fire in the XCR due to electrical

shorts resulting from fire-related cable damage.  CR 1-97-07-350 was

initiated to track the investigation and resolution of this issue.  This

issue was reported in LER 97-021 and 10CFR21 Report 21-97-040.  All

circuits routed through the RSP were reviewed to ensure that a MCR fire

would not prevent operation of those circuits from the RSP, because of

the similarities of LERs 97-019 and 97-021.  The review did not identify

any additional circuit design errors that would prevent operation of

components from the RSP.



On September 10, 1997, an engineering evaluation was issued in response

to a corrective action step for audit finding CR 3-97-06-310.  The

specific corrective action step required a sample review of safe shutdown

circuit analyses completed by Sargent & Lundy prior to initial plant

operation.  The evaluation concluded that the previous review of all

circuits routed through the RSP was not adequate to ensure there was no

potential impact to Remote Shutdown capability, because the review was

inappropriately performed on a schematic level and needed to be continued

at the cable level.



In December 1997, NSED engineers began a more comprehensive review of the

Remote Shutdown System circuits in response to the engineering evaluation

issued on September 10, 1997.  During this review on March 25, 1998,

engineers discovered the lack of isolation capability for RCIC cables

1RI85B and 1RI85C as discussed above.



RCIC cables 1RI85B and 1RI85C have lacked proper isolation capability

from MCR circuits since initial plant operation on September 29, 1986,

when the plant was in Mods 5 (REFUELING) for initial plant fuel loading.

At that time reactor coolant temperature was ambient and pressure was

atmospheric.



No automatic or manually initiated safety system responses were necessary

to place the plant in a safe and stable condition.  This event was not

directly affected by other inoperable equipment or components.



TEXT                                                          PAGE 4 OF 6



CAUSE OF EVENT



The cause of this event is attributed to an error in the design of FDDR

LH1-1308 that was likely the result of inadequate design change controls,

and supplier and Illinois Power design engineers unfamiliarity, prior to

initial plant operation, with the potential failure mechanisms associated

with fire-induced circuit damage.



Factors that may have contributed to the cause of this event include, the

complex circuit design and interface requirements may have contributed to

the possibility of errors; time pressure at the time immediately prior to

plant start-up may have reduced the level of detail of engineering

reviews, and communications between three different engineering

organizations (Illinois Power, Sargent & Lundy, GE) may not have been

rigorous.



Corrective actions for previous LERs 97-019 and 97-021 were ineffective

in identifying the potential extent of this issue for remote shutdown

circuits because the reviews were inappropriately performed on a

schematic level rather than at the cable level.



CORRECTIVE ACTION



Illinois Power will modify the interface of GETARS cables 1RI85B and

1RI85C with the RSP to provide adequate isolation.



Illinois Power will perform a comprehensive review of safe shutdown

required control circuits to ensure that the potential for fire damage in

the Main Control Room is properly evaluated for impact on Safe Shutdown

operation from the RSP.



Engineering standard GD(RS)-01.00, "Fire Protection/Safe Shutdown

Engineering Review Standard," has been revised to provide appropriate

review criteria for changes to the safe shutdown analyzed equipment

specified in USAR, Appendix F.  The revision strengthens barriers to

prevent design changes that create a potential for adversely affecting

the post-fire Safe Shutdown Analysis with respect to fire-induced circuit

failures.



Engineering standard EE-01.00, "Safe Shutdown Cable Selection," was

issued to outline rigorous methods for safe shutdown circuit analysis.

Changes to the hardware change program in administrative procedure CPS

1003.01, "CPS Hardware Change Program," require Illinois Power

engineering personnel to perform a review of all supplier design

products.  These procedural controls provide significant changes from the

conditions that existed when the error discussed in this report occurred.



TEXT                                                          PAGE 5 OF 6



ANALYSIS OF EVENT



This event is reportable under the provisions of 10CFR50.73 (a) (2) (ii)

(B) because the lack of proper isolation for cables 1RI85B and 1RI85C is

not in accordance with the design basis of the plant.



An assessment of the safety consequences and implications associated with

this event identified that this issue has potential safety significance.



In the event of a control room evacuation, the Remote Shutdown System

(RSS) provides the capability for direct manual control of certain

components of the RCIC system.  To assure a controlled safe shutdown of

the reactor from outside the MCR, the RSS overrides the usual control

room signals for these components when the appropriate transfer switches

are actuated at the RSP.  The RCIC pump, turbine and controls are the

only equipment operated at the RSP capable of ensuring adequate reactor

water inventory is maintained durIng HOT SHUTDOWN.



This event should have no impact on normal plant operation since normal

operations are not conducted from the RSP.  However, during abnormal

operations such as a fire in the MCR, operation from the RSP may be

required to achieve safe shutdown of the reactor.  At this time, fire

damage to cable 1RI85C causing a short circuit could disable control of

the RCIC pump turbine resulting in a loss of function, or could result in

aberrant flow control with component damage likely.  Short circuit damage

to cable 1RI85C could disable the RCIC turbine speed indication on the

Remote Shutdown Panel.  Loss of RCIC turbine speed indication would

affect the operators ability to monitor performance of the RCIC turbine.



ADDITIONAL INFORMATION



No equipment failed during this event.



Similar previous events are discussed within this report.



For further information regarding this event, contact D. L. McMillan,

Corrective Action Team Lead Engineer, at (217) 935-8881, extension 3920.



10CFR, PART 21 REPORT 21-98-026



IP has completed the evaluation of this issue and concludes that this

issue should be reported under the provisions of 10CFR21. The following

information is provided in accordance with 10CFR21.21 (d)(4).  Initial

notification of this matter will be provided via facsimile of this report

to the NRC operations center in accordance with 10CFR21.21(d)(3) within

two days of the responsible officer approval of this report.



(i)  Walter G. MacFarland, Senior Vice President and Chief Nuclear

Officer of IP, Clinton Power Station, Highway 54, 6 Miles East, Clinton,

Illinois, 61727, is informing the Nuclear Regulatory Commission of a

condition reportable under the provisions of 10CFR, Part 21.



TEXT                                                          PAGE 6 OF 6



(ii) The basic component involved in this condition is the interface of

cable's 1RI85B and 1RI95C in the Remote Shutdown System in accordance

with FDDR LH1-1308 as discussed in the LER DESCRIPTION OF EVENT section

of this report.



(iii) The design of cables 1RI85B and 1RI85C in the Remote Shutdown

System discussed in this report was supplied to Clinton Power station by

General Electric.



(iv) Cables 1RI85B and 1RI85C in the control circuit for the RCIC turbine

cannot be isolated from the Main Control Room by operation of the remote

transfer switch as designed and required by 10CFR50, Appendix R, Section

III.G.3.  The cables are routed from the Remote Shutdown Panel,

1C61-P001, to Main Control Room Panel 1R13-P706E in the Remote Shutdown

System and do not have appropriate isolation from Main Control Room

Circuits.



IP concludes that if this issue had gone uncorrected it could have caused

a loss of the RCIC turbine control following a fire in the Main Control

Room and subsequent use of the RSP.  This condition could have resulted

in the inability to control reactor coolant inventory during HOT

SHUTDOWN.



(v)  The deficiency in the Remote Shutdown System design was identified

on March 25, 1998, as discussed in the LER DESCRIPTION OF EVENT section

of this report.  If determined that this issue was potentially reportable

under the provisions of 10CFR21 at that time.  Condition Report

1-98-03-499 was Initiated to track an investigation and resolution of

this issue.



(vi) As discussed in the LER DESCRIPTION OF EVENT section of this report,

LER 97-019 and LER 97-021 (10CFR21 Report No. 21-97-040) discuss similar

events.  Corrective action for this issue includes performing a

comprehensive review of safe shutdown control circuits to ensure that the

potential for fire damage in the Main Control Room is properly evaluated

for impact on Safe Shutdown from the Remote Shutdown System.  This review

will identify any other similar issues.



     IP is not aware of other facilities that could be affected by this

issue.



(vii)  Corrective action for this issue is discussed in the LER

CORRECTIVE ACTION section of this report.



(viii) IP has no advice for other purchasers or licensees regarding this

issue.



*** END OF DOCUMENT ***





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