IR 05000255/1998013
| ML18066A313 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/07/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18066A312 | List: |
| References | |
| 50-255-98-13, NUDOCS 9810070082 | |
| Download: ML18066A313 (15) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Docket No:
License No:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved by:
9810070082 980807 PDR ADOCK 05000255 G
PDR REGION Ill 50-255 DPR-20 50-255/98013(DRS)
Consumers Energy Company 212 West Michigan Avenue Jackson, Ml 49201 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530 July 20-22, 27-29, 1998 D. Chyu, Reactor Engineer Ronald Gardner, Chief, Engineering Specialists Branch 2 Division of Reactor Safety
EXECUTIVE SUMMARY Palisades Nuclear Power Station NRC Inspection Report 50-255/98013 This inspection reviewed the fire protection program, an aspect of Plant Support. This was an announced inspection conducted by one regional inspector. The following strengths and.
weaknesses were identified:
During this inspection period, minimal amounts of combustible material were noted in the plant. The material condition of most fire protection equipment appeared to be good. The fire brigade turnout gear lockers appeared to be well controlled and, with minor exceptions, contained the proper equipment. (Section F2.1)
A potential weakness was noted in the control of combustible materials in the plan lndivid_ual work groups may bring in amounts of combustible material that are below the procedural limits. However, the accumulated effect of multiple introductions of combustible materials into a plant area are not monitored and may exceed established limits. In addition, the monthly fire protection inspections lacked rigor in that personnel had not toured all areas in the auxiliary building for five out of the last six months. (Section F3.1)
The corrective actions modifying 16 MOV circuits for the conditions identified in Information Notice 92-18 did not address the consequences of multiple hot short The new cables/conductors, installed during the modifications, remained susceptible to shorts to grounds and shorts between cable conductors. The current circuit design. appeared to be contrary to the requirements of 10 CFR 50, Appendix R, Section 111.G.2. This is an unresolved item pending generic resolution of multiple hot short circuit analysis requirements. (Section F2.2)
The hydraulic calculation for the sprinkler system in the electrical equipment room contained an unverified assumption concerning the friction loss factor (C-factor). In addition, the licensee did not analyze the sprinkler system flow test data to ensure capability of the water supply. This is an unresolved item. (Sections F3.2 and F3.3).
The performance of the observed fire drill was good. The training provided to the fire brigade appeared fo be adequate. The annual physical examinations were kept up-to-date. (Sections F4 and F5)
A weakness was noted with the audits performed by the Nuclear Performance Assessment Department (NPAD). The audit reports and checklists did not reveal substantive inspection in the area of penetration seals for the last three year (Section F7)
Report Details IV. Plant Support F2 Status of Fire Protection Facilities and Equipment F Plant Tours Inspection Scope
- The inspector toured the areas of the turbine and auxiliary buildings, and fire pump area to observe the adequacy and control of combustibles, dampers, fire doors, hose stations, detection equipment, extinguishers, sprinkler systems, emergency lights, fire pumps, and housekeeping. The inspector reviewed Fire Protection Implementing Procedure FPIP-7, "Fire Prevention Activities," Revision 1 Observations and Findings Minimal amounts of combustible material were noted in the plant. The inspector noted that several pump areas had designated open areas for storing lubrication oi The lubricating oil was considered a Class Ill combustible liquid with a high flash point (140°F or higher). In.accordance with Section 6.3, "Flammable/Combustible Liquids," of FPIP-7, the licensee did not require such liquid to be stored in approved safety cans but in containers of good quality free from leakage of either liquid or vapors. The inspector also verified that the additional quantity of oil in the
component cooling water (CCW) pump area was included as part of the in-situ fire load. The inspector considered this to be acceptable. There were also a low number (eight as of July 21, 1998) of fire impairments in the plan The inspector, accompanied by fire protection training personnel, also inspected the turnout gear lockers in the service and turbine buildings. A brigade-qualified security officer was asked to demonstrate how to don fire fighting gear. The first locker the security officer attempted to use contained the wrong size pants. In addition, the*
same locker was missing a glove. The licensee indicated that there were more lockers than the actual required number of personnel who comprised responding fire brigades. However, the inspector considered the potential for the fire brigade having to make several attempts to locate required fire fighting gear prior to responding to an actual fire to be a weaknes The licensee planned to modify the existing monthly surveillance of the brigade lockers to include steps to verify the sizes of turnout gear matched the locker designation Conclusion During this inspection period, minimal amounts of combustible material were noted in the plant. The material condition of most fire protection equipment appeared to be good. The turnout gear lockers appeared to be well.controlled and had proper equipment with the exception of a locker in the service building which contained the wrong size pants and was missing a glov F Corrective Action for Potential Fire-Induced MOV Damage Inspection Scope The inspector reviewed the corrective actions and modifications for the MOVs which could be physically damaged during a fire in the control room or cable spreading room. This condition was specifically described in Information Notice (IN) 92-18,
"Potential for Loss of Remote Shutdown Capability During a Control Room Fire." Observations and Findings In 1995, the licensee identified 20 MOVs which could be actuated by fire-induced hot shorts in the control room, bypassing their torque and limit switches. The licensee performed two types of circuit modifications in an attempt to correct the proble The type A modification consisted of a modification in the motor control center bucket to move the torque and limit switches to below the starter coil. There were four MOVs requiring Type A modification. The Type B modification was to add additional cable (via splicing existing cable or pull new cable). There were 16 MOVs requiring Type B modification. The following discussion will focus on the Type B modificatio There were two MOVs, M0-2087 (volume control tank outlet valve) and M0-0216 (safety injection refueling water to charging pump valve}, requiring spliqing of existing cables in the control room to move the torque and limit switches to below the starter coil. The single cable with multiple conductors ran from cable spreading room to the control room, from the control room back to the cable spreading room, and from the cable spreading room to the valves. The single cable with multiple conductors contained conductors which could be hot shorted (original concern in IN 92-18) and contained conductors below the starter coil which could be shorted to ground in a control room fire. The licensee recognized that the potential combination of a hot short with a short to ground could cause the valve to over-drive. However, the licensee stated that the smart short condition was not considered credibl O CFR 50, Appendix R, Section 111.G.2 stated that except as provided in paragraph G.3 of Appendix R, Section Ill, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieveand maintain hot shutdown conditions were located within the same fire area outside of containment, protection that ensures one of the redundant trains was free of fire damage shall be provided. In the licensee's analysis of the modification, consideration was given to a combination of hot shorts and shorts to ground on
these MOVs, However, the licensee considered this combination was not credible and did not protect one train as require The remaining 14 MOVs required pulling new cables to ensure that the torque and limit switches were below the starter coils. However, these new cables were in the same fire area as the cables susceptible to hot shorts (original IN 92-18 concern).
The inspector noted that inside control room panels C03 and COS that some of these cables were separated by approximately six feet at control room floor penetrations and others were located within the same penetration. These cables eventually terminated in the same panels where they would be susceptible to hot shorts and shorts to ground. The issue of multiple hot shorts and the requirements of 10 CFR, Appendix R, are currently undergoing generic industry/NRG revie Conclusions The in.specter determined that the corrective actions modifying 16 MOV circuits for the conditions identified in IN 92-18 did not address the consequences of multiple hot shorts. This is an unresolved item pending generic resolution of Appendix R circuit analysis (hot short) requirements (URI 50-255/98013-01 ).
F3 Fire Protection Procedures and Documentation F Weak Control of Transient Fire Combustibles Inspection Scope The inspector reviewed Fire protection Implementing Procedure FPIP-7, "Fire Prevention Activities," Revision 1 O; monthly fire protection inspection reports dated from January to June 1998; and interviewed an auxiliary operator, a security officer, and a shift enginee Observations and Findings Section 6.4 of FPIP-7 required personnel to complete Attachment 5 of the procedure if any of the following exist during maintenance activities:
A combustible solid transient fire load exceeds 1000 pound A Class 1 (flammable liquids) transient fire load exceeds 15 gallons, or
- A Class 2 or Class 3 (combustible liquids) transient fire load exceeds 55 gallon *
During the inspection period, the inspector did not observe the above limits being exceeded in the plant. The inspector noted that each work group could introduce combustibles into the plant as long as the transient fire loading remained below the procedural limits. However, the accumulated effect of added combustible loading from different work groups could potentially exceed the procedural limits. The security officer responsible for performing fire tours did not normally tour the entire plant for inspection of transient fire loading on a daily basis. The auxiliary operators did tour the entire plant every shift; however, the operators appeared to be the last barrier preventing transient fire loads exceeding the procedural limit Section 7.0, "Fire Protection Inspection," of FPIP-7 required periodic fire protection inspections to be conducted by the fire protection section at least once each month while the plant was operating and more frequently when the plant was shutdow The inspector reviewed portions of outage inspection reports which contained more details of inspections conducted. The inspector also reviewed the monthly fire protection inspection reports from January to June 1998. The documentation revealed that the fire protection personnel did not tour all areas in the auxiliary building except during one incident where the fire protection personnel accompanied a property insurance individual..
The licensee planned to establish a lower limit of combustible material in procedure FPIP-7 and to revise the predetermined periodic activity control (PPAC) to better explain the attributes for effective monthly inspection Conclusion*
The inspector did not identify any example of transient fire load exceeding the procedural limits but considered the administrative controls to be weak. In addition, the monthly inspections conducted by the fire protection personnel lacked rigor in that personnel did not tour all areas in the auxiliary building during five out of six inspections conducted since January 199 F Hydraulic Calculation and Surveillance for Fire Suppression Water System Inspection Scope The inspector reviewed EA-FPP-96-009, "System Hydraulic Analysis for the Electrical Equipment Room," Revision Observations and Findings Section 9.6.3, "System Description and Operation," of the Palisades Final Safety Analysis Report (FSAR), stated, in part, that the fixed water spray systems were designed, installed, and tested in accordance with the guidance of National Fire Protection Association (NFPA) 13-1968, "Installation of Sprinkler Systems," and NFPA.. 15-1.966, "Water Spray Fixed System~ for Fire Protection."
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Section 7330.(c) of NFPA 13-1968 stated that the pipe friction loss (C-factor) was 140 for cement-lined cast iron and 100 for unlined cast iron pipe. Chapter 5, Section 11 of the Fire Protection Handbook, 14th edition, stated the need to lower the C-factor for unlinep cast iron pipes as the pipes aged. For example, the C-factor for new unlined cast iron could be at 120. However, for unlined pipes containing mildly corrosive water that were 30 years of age, the C-:factor was lowered to 8 In Assumption 3.4 of EA-FPP-96-009, the licensee used a C-factor of 100 for both cement-lined and unlined cast iron pipes. This assumption further stated that actual pipe material used in the underground piping was a mixture of lined and unlined cast iron. Therefore, the assumption indicated that a C-factor of 100 was used as it added an extra level of conservatism to the calculation The inspector disagreed with the above assumption. Since there was no age adjustment needed for cement-fined cast iron pipes, the use of a C-factor of 100 was conservative. However, there was no age adjustment of the C-factor for aged unlined cast iron underground. piping. In addition, fire protection engineering could not provide data regarding how much of the underground piping was cement-fined or unlined cast iron. Therefore, it was inconclusive that the C-factor of 100 was sufficiently conservativ The water density required to extinguish a fire in the electrical equipment room was 0.3 gpm/ft2 (Calculation EA-FPP-96-009). The current calculated water density for this area with a C-factor of 100 was 0.34 gpm/ft2* With an age adjusted C-factor of less than 100, the water density may not meet this requirement. Lower water density would mean that the sprinklers in that area would not be capable of delivering sufficient water to extinguish a fire, thus compromising the operability of equipment in that are The licensee provided a justification for a C-factor of 100 for both the cement-fined and unlined cast iron. However, the justification assumed a higher C-factor for new unlined cast iron than that specified in NFPA 13-1968. The inspector considered this justification to be inadequat Con cf usions The inspector identified an unverified assumption in the hydraulic analysis for electrical equipment room suppression piping. The C-factor used for cement-lined cast iron pipe was lowered from 140 to 100 as a measure of conservatis However, the C-factor for unlined cast-iron pipe was not adjusted for age and therefore added non-conservatism to the calculation. The licensee was unable to provide data identifying the proportions for the two types of cast iron for underground piping. See item F3.3 (below) for further discussion of this issu ** *
F Inadequate Analysis of the Fire Suppression Water System Flow Test,Inspection Scope The inspector reviewed Fire Protection Surveillance Procedure (FPSP)-R0-10, "Fire Suppression Water System* Flow Test," Revision Observations and Findings Section 9.6.7.2, "Testing Requirements," *at the Palisades' FSAR stated, in part, that the fire suppression water system shall be tested by performing a flow test of the system in accordance with Chapter 5, Section 11. of the Fire Protection Handbook, Edition 14. The test was to be done every three year The inspector reviewed Section 5.3 of FPSP-R0-10 for inside loop testing. The test procedure contained appropriate elements to properly test the system. The acceptance criteria for the inside loop was greater than or equal to 1100 gpm with residual pressure of greater than or equal to 120 psig. However, the procedure did not call for analysis of the test data to determine whether overall system flow requirements were being me Chapter 5, Section 11 of the Fire Protection Handbook, 14th edition, stated that the major purpose of flow testing is to determine whether or not the available water supply could meet the water demand required for acceptable protection of identified fire areas. Section F of this chapter discussed plotting the test data on log paper, extrapolating water supply minus the 500 gpm hose demand, and correcting the data for elevation differences between the ground level and the top line of the sprinkler Section G of this chapter also discussed the method of utilizing hydraulic gradient and pipe profile to calculate real C-factors. The inspector questioned fire protection engineering personnel as to why such an analysis of the*test data was not performed.. The fire protection engineer's response was that the FSAR required only testing a.nd not analyzing the fire suppression system Conclusions The responses from fire protection engineering personnel concerning the unverified assumption for C-factor (Section F3.2) and lack of further analysis of the sprinkler system flow test data were considered inadequate and lacked good engineering practices. With consideration of the unverified assumptions for C-factor as discussed in Section F3.2 and lack of analysis of the fire suppression water system test data, it w~s uncertain to the inspector that the current sprinkler systems would be able to supply adequate water density to plant areas. The licensee planned to form an action plan which may include a sensitivity study of C factors used in the hydraulic calculation and actual flow tests to verify C-factor. The elements and milestones of the action plan were indeterminate at the time of the exit meeting. This is a unresolved item pending licensee resolution as to the acceptability of the assumption (Section F3.2) and the capability of the sprinkler system to deliver the required flow (URI 50-255/98013-02).
F4 Fire Protection Staff Training and Qualification Inspection Scope On July 28, 1998, the licensee conducted an unannounced fire drill in the 1 D switchgear room 223. The inspector observed the drill and attended the subsequent critique meetin Observations and Findings All five brigade members arrived at the area within *10 minutes of the announcement of the fire drill. The inspector observed that one brigade member did not wear the required fire retardant hood for protection under his hard hat. When the brigade members responded to the drill location, none took extra equipment such as extra fire hose or breathing bottles with the The brigade leader dispatched two hose teams (two brigade members per team) to attack the simulated fire. The two teams took two different paths into the room and arrived about the same time. However, the hose utilized by the backup hose team was not long enough to reach the fire location. When two non-brigade qualified personnel arrived later, an extra section of hose was obtained and the individuals simulated adding the extra hose to the backup team. In this scenario, the licensee assumed one sprinkler head was operating. The first hose team simulated putting water on the fire source. The remainder of the drill was well conducte In addition, the inspector reviewed the critique reports for 1998 (total 17). Three reports dated March 29, April 12, and May 20, 1998, also indicated that fire hoses were not long enough. The inspector could not readily determine whether the hoses of insufficient length were associated with the primary or the backup hose team. The fire protection trainer had placed an extra section of fire hose at each locker locatio However, the brigade members were not expected to carry the extra hose to the fire location. A health physics technician, who was not brigade qualified, was expected to respond to the fire location and act as a supply sergeant to obtain equipment as neede Conclusions I
The performance of the observed fire drill was good. However, recurring problems were noted with fire hose lengths being inadequate to reach fire area FS Fire Protection Staff Training and Qualificatio The fire brigade members included all auxiliary operators and 30 security officers (40 percent of all officers). Each fire brigade member received 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of initial training. A portion of the initial training was provided at an offsite fire school where they would practice using fire extinguishers, hose handling, etc. Each brigade member also receives four quarterly training sessions. One of the quarterly training sessions would be treated as an annual requalification which consisted of two-day training at an offsite fire school. The remaining quarterly training sessions would be
conducted in a local fire department. There were a total of 30 announced fire drills per year which were conducted by shift supervisors. There were five unannounced fire drills per year, one for every operation shift crew. The inspector briefly reviewed the training record which appeared to be in good orde In addition, the licensee conducted one fire drill with offsite fire departments. The fire fighters from the local fire department were all badged for quick onsite access and were issued TLDs. * It appeared the licensee had a good relationship with the local fire departmen The inspector also reviewed the due dates of the annual physical examinations for auxiliary operators and security personnel with brigade responsibility. The records were kept up-to-dat F7 Quality Assurance in Fire Protection activities Inspection Scope The inspector reviewed the last annual, biennial, and triennial Nuclear Performance.
Assessment Department (NPAD) reports and the system health assessment reports for fire barrier subsystem, fire suppression water supply system, eight-hour emergency lighting system, alternate shutdown panel, and fire detection syste The inspector also interviewed an NPAD inspector and supervisor concerning the fire protection audit Observations and Findings The system health reports appeared to be comprehensive in evaluating each system's hardware performance. Several attributes for each system were evaluated on a quarterly basis. These included open corrective work orders, open temporary modifications, condition reports, maintenance rule performance, and daily priority items. However, the inspector did not evaluate in detail how licensee management addressed each recommendation in the repor The required NPAD reports for 1995, 1996 and 1997, did not contain details for penetration seals. The reports mostly indicated that penetration seals were visually inspected during plant walkdown. The inspector also reviewed the checklists used in these audits. In 1995, a reference was made to the documentation on penetration seals which appeared to be adequate. However, there was no specific and substantive inspection of penetration seals concerning their design, installation process, testing methods, fire test reports, etc. In the upcoming triennial fire protection audit in Fall 1998, the licensee planned to perform inspections of penetration seals for damage, degradation, correct installation per design requirements, and design documentatio * Conclusion The system health assessment reports for fire protection systems appeared to be comprehensive. The inspector identified a weakness where the penetration seals did not receive any substantive audit from the NPAD personnel for the last three year F8 Miscellaneous Fire Protection Issues F (Closed) VIO 50-255/95004-04: Inadequate control of combustible material and inadequate surveillance of extinguishers in the construction group areas. The inspector identified that combustible material for various maintenance activities was stored at the bottom of the stairwell leading to the safeguard rooms. This configuration was previously evaluated and allowed by the fire protection grou However, the justification for this deviation was not documented. The licensee revised procedure FPIP-7 to require documentation of any variance including the basis for the variance from the procedural requirements. In addition, the inspector identified that several extinguishers used by the construction group personnel did not receive annual maintenance as required by NFPA-10. These extinguishers were normally used by the construction group during hot work activities. For hot work purposes, the licensee replaced the extinguishers with hand pumps (water extinguishers). The rest of the fire extinguishers in the construction areas were controlled and inspected per Fire Protection Check Sheet FP-PE-15, "Construction Building and Contractors Outbuilding," Revision 0. This item is close F (Closed) URI 50-255/95004-05: Fire wall enhancement. The inspector identified two walls of concerns. The first was the west wall of the turbine oil storage room. This wall was initially constructed as a non-rated wall because it was an outside wal However, at the time of the 1995 inspection, it was no longer an outside wall due to a feedwater purification modification. The then-current FHA did not reflect the as-built configuration. In addition, there was an opening approximately 1 O' x 12' existing between the turbine building and the CCW pump room in the auxiliary building. on the 590' elevation near the turbine lube oil storage room. The licensee has since provided additional automatic sprinkler protection in the turbine building in the area of the turbine building/CCW pump room wall. The NRC concluded in a safety evaluation report dated October 14, 1997, that these areas with fire protection features provided reasonable assurance that a fire in the turbine building will not adversely affect the CCW pumps and will not adversely affect the plant's ability to achieve and maintain post-fire safe shutdown conditions. This item is close F (Closed) URI 50-255/96002-03 and LER 50-255/95015: Inoperable MOVs after a postulated fire scenario. * The licensee identified that 20 MOVs required for post-fire safe shutdown conditions could be damaged because of bypassing the torque and limit switches while the MOVS spuriously operated. This condition, as described in NRC I N_92=18, could result in an unrecoverable scenario during a postulated fire in the control room. This issue was the subject of an escalation enforcement action (50-255/96004-01 ). The corrective action to this issue will be evaluated as a part of the overall corrective action to the escalated enforcement action. These items are close *
F (Open) VIO 50-255/96004-01: Failure to provide an operable alternative or dedicated shutdown capability. The inspector reviewed the modifications for the MOVs which were susceptible to fire-induced hot shorts and subsequent damag The details of inspector review is documented in Section F V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to the members of licensee management at the conclusion of the inspection on July 29, 1998. The licensee acknowledged the findings presente The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED Licensee S. Cote Property Protection Supervisor A. Dahbur Engineer D. Engle Licensing Engineer J. Ford Manager, Engineering Program K. Haas Engineering Director N. Haskell Licensing Director C. Holman Fire Protection Instructor D. Jones NPAD Supervisor B. Kilroy Fire Protection Engineer J. Kuemin Program & Systems Supervisor T. Palmisano Site Vice President D. Rogers
. General Manager G. Watters Fire Protection Engineer.
J. Lennart Senior Resident Inspector INSPECTION PROCEDURES USED IP 64704 IP 92703 Fire protection Follow up on previously identified items Closed 50-225/95004-04 50-255/95004-05 50-255/96002-03 50-255/95015 Opened 50-255/98013-01 50-255/98013-02 Discussed 50-255/96004-01 capability ITEMS OPENED, CLOSED, AND DISCUSSED VIO Inadequate control of combustible material and inadequate surveillance of extinguishers in the construction grou URI Fire wall enhancement
URI Inoperable MOVs after a postulated fire scenario
- LER Inoperable MOVs after a postulated fire scenario URI Unverified Assumption for C-factor and the lack of analysis for hydraulic flow test data URI Inadequate corrective action for MOVs which were susceptible to hot shorts during a control room fire (IN 92-18)
- Failure to provide an operable alternate safe shutdown
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ccw CFR DRS FPIP FPSP FSAR IN LER MOV NFPA NPAD PPAC URI VIO LIST OF ACRONYMS USED Component Cooling Water Code of Federal Regulation Division of Reactor Safety Fire Protection Implementing Procedure Fire Protection Surveillance Procedure Final Safety Analysis Report Information Notice Licensee Event Report Motor Operated Valve National Fire Protection Association Nuclear Performance Assessment Department Predetermined Periodic Activity Control Unresolved Item
_Violation
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LIST OF DOCUMENTS REVIEWED NFPA 13-1968 Edition, "Standard for the Installation of Sprinkler Systems" Administrative Procedure FPIP-4, "Fire Protection Systems and Fire Protection Equipment," Revision 15, dated 3/25/9 Administrative Procedure FPIP-7, "Fire Prevention Activities," Revision 10, dated 5/21/9 Procedure FPIP-5, "requirements for Inspection and Testing of Fire Protection Systems and Fire Protection Equipment," Revision 9, dated 2/5/97 Technical Specification Surveillance Procedure AE-5, "DC Lighting Test - Turbine and Auxiliary Buildings," Revision 20, dated 11/26/97 Technical Specification Surveillance Procedure RE-87, "DC Lighting Test -
Containment Building," Revision 3, dated 10/31/96 Fire Protection Surveillance Procedure FPSP-AE-4, "Emergency Lighting Unit Battery Conductance and Discharge Tests," Revision 3, dated 6/19/98 Fire Protection Surveillance Procedure FPSP-AE-5, "DC Lighting Test - Nonsafety-related Feedwater Purity, Security, Switchyard, and Service Buildings," Revision 1, dated 8/14/9 Audit Report PA-95-20, "Palisades - Fire Protection Appendix R Program," dated 1/19/96 NPAD PA-96-23, "Palisades Fire Protection," dated 11/22/96 NPAD PA-97-16, "Palisades Fire Protection," dated 2/1/98 EA-FPP-95-028, "Analysis of Combustible Loading for Fire Area 16, Component Cooling Pump Room," Revision 1, dated 9/16/96