IR 05000275/1987027
| ML16341E390 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/30/1987 |
| From: | Ramsey C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341E389 | List: |
| References | |
| 50-275-87-27, 50-323-87-27, GL-86-10, IEIN-86-106, IEIN-87-014, IEIN-87-14, NUDOCS 8708140120 | |
| Download: ML16341E390 (28) | |
Text
'
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-275/87-27, 50-323/87-27 Docket Nos.
50-275, 50-323 License Nos.
Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Facility Name:
Diablo Canyon Units 1 and
Inspection at: Diablo Canyon Site, San Luis Obispo County, California Inspection Conducted:
July 6 through 10, 1987 Inspector:
C.
Ramsey, Regional In pector 7$oZ Date Signed Approved by:
S.
Richards, C i f Engineering Section Date igned
~Summar:
Ins ection Durin the Period Jul 6 throu h 10 1987 Re ort Nos.
50-275/87-27 and 50-323/87-27 Areas Ins ected:
Routine, unannounced inspection by one regional based inspector involving followup on previous NRC and licensee identified open items.
A limited assessment of specific areas of fire protection program implementation was made to verify licensee's compliance with NRC guidelines and regulations.
During this inspection, Inspection Procedures 30703, 64100, 62704 and 92701 were used.
Results:
In the areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted Pacific Gas and Electric PG8E R.
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5'D Thornberry, Plant Manager Banton, Engineering Manager Sexton, Plant Superintendent Gisclon, Assistant Plant Manager Kohout, Emergency Safety Services Supervisor A. Panero, Nuclear Operations Safety P.
Flahaus, guality Support Group Boots, C8 RP Townsend, Support Services Angus, Work Planning Fridley, Operations Molden, Training Warrick, DER Hubbler, Security Oliver, Materials B. McLane, Compliance Engineer Doss, OSRG G. Crockett, I&C C. Grebel, Regulatory Compliance Miklush, Maintenance NRC
"J. Burdoin, Reactor Inspector
"K. Johnston, Resident Inspector
"Denotes those attending the exit meeting held on July 10, 1987.
2.
Licensee Action on Previous Ins ection Findin s
A.
Closed LER No. 86-03 - "Failure to Meet Technical S ecification L.C.O. for Cable S readin Room CO~
S stem 0 erabilit."
The licensee reported in this LER that a fire watch did not comply with the instructions on the fire watch log and misunderstood his duty to remain in the Cable Spreading Room until the CO> system was returned to service.
The licensee corrective action for this event included additional training of the responsible individual and others designated to perform fire watch duty.
This training and administrative action taken by the licensee to inform employees of this event and its root cause appeared to be satisfactory.
Therefore, this item is close (Closed) Information Notice No.86-106 - "Inadvertent Actuation of Fire Su ression S stem Causin Ino erabilit of Safet -Related E ui ment."
This Information Notice informed licensees about the catastrophic failure of feedwater piping and inadvertent actuation of fire suppression systems attributing to the severity of the event at Surry, Unit 2, on December 9, 1986.
In response to the Notice, the licensee analyzed the potential adverse effects that can result from spurious release of fire suppression agents in all safety-related areas.
Based on this analysis, the licensee determined that the inadvertent discharge of fire suppression agents due to shorts in the circuitry of associated control panels as a result of major steam or water leaks is possible.
However, the compromise of the habitability of the control room would be unlikely.
In response to Information Notice No. 85-85, the licensee identified a potential system interaction involving inadvertent actuation of a sprinkler system or fire water supply line where water damage could penetrate through a register for ventilation supply fans and eventually come into the control room.
Action Request No.
A0011442 was initiated by the licensee to provide spray protectors over the registers to mitigate this potential concern.
Based on the licensee's analysis and identified corrective action, this item is considered closed.
(Closed Information Notice No. 87-14 - "Actuation of Fire Su ression S stem Causin Ino erabi lit of Safet -Related Ventilation E ui ment This Information Notice informed licensee's of the NRC's concern over continuing events regarding fire protection system interaction with safety-related systems.
In response to this Notice, the licensee performed a study to verify the impact of automatic actuation of fire suppression systems on the operability of all safety-related systems at Diablo Canyon.
All issues associated with the actuation of fire suppression systems, including licensee action in response to Information Notice Nos.
85-85 and 86-106 were reported to be addressed and closed out in the licensee's internal correspondence No. 016-14, dated Nay 5, 1987.
Based on the licensee's actions, this item is closed.
Closed 0 en Item 275/85-35-01
- "Failure of Fire Doors to Close and Latch Under Certain Conditions."
This finding documented the NRC's concern regarding potential failure of fire doors to close under certain ventilation air flow conditions.
In response to this concern,. the licensee's corrective action included the following:
Installation of fire door sel f-closing devices.
Having fire doors evaluated by Underwriters Laboratories, Inc.
Completing modifications recommended by Underwriters Laboratories, Inc., to achieve required fire door rating and labelling.
Balancing ventilation system air flow differential pressures.
Implementation of administrative controls and visual aids (signs) requiring that fire doors be kept closed.
Based on these actions by the licensee, this item is considered closed.
However, some remaining fire door discrepancies are still outstanding.
This is further discussed in paragraph 3.D. of the report.
Closed 0 en Item 275/85-36-01
- "Lack of Fire Barrier Protection for Structural Steel.
'his finding documented the NRC's concern that the licensee's fire protection provided for structural steel appeared to be inadequate.
During the inspection, the licensee's staff and the inspector toured the facility and visually observed examples of the licensee's corrective action for these conditions.
In most instances, the inspector concluded that adequate fire barrier protection was provided for load bearing structural steel as required.
However, in some instances, the licensee elected to perform technical evaluations in accordance with NRC Generic Letter 86-10 as justification for instances where structural steel was not protected by fire barriers.
This is further discussed in paragraph 4.D. of the report.
Based on these actions by the licensee, this item is considered closed.
Closed 0 en Item 275/85-36-02
"Lack of Fire Barrier Protection for Bus Duct Penetration 0 enin s."
This finding documented the NRC's concern that the licensee's fire protection for bus duct openings penetrating fire bar riers was inadequate.
During the inspection, the licensee's staff and the inspector toured the facility and visually observed examples of the licensee's corrective action for these conditions.
In most instances, bus duct openings through fire barriers were sealed to provide a fire resistive rating equivalent to the fire barrier wall, floor or ceiling that is penetrated.
Where the licensee deviated from a tested configuration for sealing fire barrier penetration opening, an evaluation was performed in accordance with NRC Generic Letter No. 86-10 as justification.
This is further discussed in paragraph 4.D. of the report.
Based on these actions by the licensee, this item is considered close (Closed 0 en Item 275/85-36-03
- "Inade uate Fire Detector Locations."
This finding documented the NRC's concern regarding the ability of spot-type fire detectors to provide the earliest possible detection of fire occur rences in all safety-related areas.
During the inspection, the licensee's staff and the'inspector toured the facility and visually observed examples of the licensee's corrective action for these conditions.
In most instances where fire detectors locations were of questionable adequacy, additional detector were installed or detectors were relocated.
In areas where the licensee determined that the adequacy of fire detector locations remained questionable but additional detectors were not installed, the licensee performed a technical evaluation in accordance with NRC Generic Letter No. 86-10 as justification for these conditions.
This is further discussed in paragraph 4.D. of the report.
Based on these actions by the licensee, this item is considered closed.
(Closed 0 en Item 323/85-34-01) - "Inade uate Fire Su ression Ca abilit in the Unit 2 Auxilsar Feedwater Pum Room.
This finding documented the NRC's concern regarding the adequacy of automatic sprinkler protection for the Unit 2 auxiliary feedwater pumps.
During the inspection, the licensee's staff and the inspector toured the facility and visually observed enhanced automatic sprinkler protection for the Unit 2 auxiliary feedwater pumps and examples of upgraded automatic sprinkler protection in other safety-related areas.
Where the licensee determined that automatic sprinkler protection was not installed in accordance with governing code requirements, a technical evaluation was performed in accordance with NRC Generic Letter No. 86-10 as justification for these conditions.
This is further discussed in paragraph 4. D. of the report.
Based on these actions by the licensee, this item is considered closed.
(Closed 0 en Item 275/85-36-04
- "Inade uate Fire Dam er Installations."
This finding documented the NRC's concern regarding the ability of fire dampers to contain fire occurrences to within the fire area of origin.
In response to this finding, the licensee's correspondence No.
DCL-86-133 to the NRC documents the results of the licensee's evaluation of installed fire dampers and corrective actions taken.
By letter dated October 16, 1986 (H. Shierling -
NRC to J.
D.
Shiffer - PG8E),
the NRC advised the licensee of its conclusion that the licensee's evaluation and corrective actions were acceptable.
Based on this review by the NRC staff, this item is considered close.
Im lementation of Fire Protection Pro ram Re uirements The licensee is required by Condition No. 2.C(5) of Facility Operatng License No.
DPR-80 for Unit 1 and Condition No.
2. C(4) of Facility Operating License No.
DPR-82 to implement all provisions of the approved fire protection program.
The approved fire protection program is described in Section 9.5-1 of the FSAR and in the NRC staff's Fire Protection Evaluation in Supplements 8, 9, 13, 23, 27 and 31 to the Diablo Canyon Safety Evaluation Report.
Section 6.5.2.8 of the Technical Specifications requires that periodic audits be performed of the fire protection program and its implementing procedures to verify conformance to the provisions contained in Technical Specifications and applicable license conditions.
The inspector's review of the licensee's fire protection program implementation is as follows:
A.
Manual Fire Su ression Ca abilit The capability of the licensee's staff to detect, respond and manually suppress fires occurring at the site was assessed in the following areas:
(1)
Fire Pum s and Mater Su lies The primary water supply source for fire protection continues to be from a 4.5 million gallon raw water storage reservoir which is elevated above the plant and provides a static pressure of approximately 93 psig due to gravity feed into the plant yard underground loop.
A secondary water supply is provided by two electric motor driven fire pumps which are installed in parallel and take suction from a separate 300,000 gallon water storage tank.
Both pumps start automatically and sequentially upon low system pressure.
The 300,000 gallon water storage tank is common to both units and serves as a
backup water supply to the auxiliary feedwater system.
Taken separately as the single primary water supply source, the 4.5 million gallon raw water storage reservoir provides marginally adequate dynamic pressure (S 65 psig) for firefighting purposes.
Therefore, Technical Specification No.
3/4.7.9 has been amended to require at least one electric fire pump and its water supply source be operable in order to supplement the 4.5 million gallon raw water storage reservoir as a primary supply source.
Because the electric motor driven fire pumps also have limited capacity to meet the expected combined demand for manual and automatic fire suppression activities in the power block (vital areas),
and because of site expansion outside of the power block (non-vital areas),
a supplemental site fire protection water supply has been provided.
This additional supply source is available from the southside fire water system through 2-12-inch underground water main crossties to the power block
firewater distribution system.
Two 2,000 GPM fire pumps which take suction from a separate 470,000 gallon water storage tank are provided.
The pumps are installed in parallel and start automatically and sequentially to provide water to the plant yard underground fire suppression loop upon decreasing pressure.
Therefore, plant has three separate, but interconnected fire water distribution systems.
The static pressure for the entire interconnected system is normally maintained (R 150 psig) by one of two jockey fire pumps taking suction from the 470,000 gallon water storage tank.
If neither of the jockey fire pumps are available, system static pressure is provided by gravity feed from the 4.5 million gallon raw water storage reservoir.
The water supply and the distribution system appears to be adequate for expected combined automatic and manual fire suppression activities at the site.
No violations or deviations were identified.
Fire Pum Technical S ecification Surveillance Results The electric motor driven fire pumps are required to be operable by Plant Technical Specification No. 3/4.7.9.
The inspector reviewed the licensee's technical specification surveillance results from Surveillance Test Procedure Nos.
13A and 13B for the fire pumps, which were performed on August 8, 1986, June 20 and July 1, 1987.
The tests were performed in accordance with governing code and pump manufacturer's requirements.
Both pumps performed satisfactorily with no visible evidence of deterioration or mechanical malfunction.
No violations or deviations were identified.
Man ower and Manual Firefi htin Ca abilit I
The licensee maintains a site fire brigade of at least five members who are exclusive of the minimum crew necessary for safe shutdown of either unit in accordance with Technical Specification No. 6.0.
The fire brigade training program and records of individual training was determined satisfactory.
In addition, to enhance orderly firefighting responses, the licensee has implemented a life safety program to educate all plant personnel on prompt reporting of fires and proper responses.'uring normal hours, a maintenance fire brigade composed of plant personnel other than operators is available to supplement the five-man fire brigade.
During backshift hours, this maintenance fire brigade would not normally be available to supplement the five-man brigade.
The five-man brigade is responsible for all manual fire suppression activities at the site (vital areas and non-vital areas within the owner-controlled area) at all time Since the owner-controlled area involves significant land areas outside of the power block (vital areas),
including elevated terrain (potential wildland fires) and nonsafety-related structures, the inspector questioned the availability of personnel to fight fires in power block vital areas during backshift hours while the fire brigade could be combating a
fire outside of the power block in a remote location of the owner controlled area.
To provide firefighting access to these non-vital remote areas, a 1968 Dodge model light attack fire apparatus is provided to transport fire brigade manpower and equipment.
The reliability of this apparatus was questioned for the following reasons:
The apparatus equipment storage capacity is limited.
Therefore, equipment is stored on the floor of the driver/passenger compartment and expose the driver and passenger to potential injury while the apparatus is in motion.
The apparatus has seating for only a driver and possible two fire brigade members in the passenger compartment.
Suitable seating is not provided for remaining fire brigade members.
The only provision on the apparatus to accommodate transportation of these brigade members is a
'ear platform that represents a significant potential to injure personnel while the apparatus is in motion.
The apparatus has limited pumping capacity.
Thus, the need for manpower when utilizing the apparatus to combat fires is essential.
In view of these concerns, the inspector concluded that the challenges of manual firefighting at Diablo Canyon are unique and possibly outside of the original intent of Technical Specification No.
6. 0. fire brigade responsibilities.
This conclusion is further discussed in paragraphs 3.A(4) and 3. B(1).
(4)
Offsite Fire De artment Assistance The geographic location of the site isolates it from a rapid response by offsite fire departments.
The average response time of the nearest offsite fire department to the site is reported to be approximately 35 minutes.
In order to reach the site, offsite fire department vehicles must travel seven miles on a narrow two-lane access road to the plant.
Because of the mutual aid agreement between the offsite fire departments, it is possible that offsite assistance may not be available for several hours due to fire occurrences offsite.
According to the licensee, in 1985 the offsite San Luis Obispo County Fire Departments fought a major wildland fire in which the county's firefighting resources were expended.
If a fire had occurred at Diablo Canyon simultaneously, the response time
for offsite fire department assistance to reach the plant would have been increased considerably.
Based on the inspector's understandings regarding manpower availability for firefighting, the inspector questioned the ability of the five-man plant fire brigade to fulfill responsibilities for first and second line firefighting in power block vital areas, as well as first and second line firelighting for all non-vital areas outside of the power block and within the owner-controlled site area.
The licensee indicated that an evaluation would be made to determine if the current challenges to the fire brigade were outside of the original intent of anticipated fire brigade's responsibilities.
The language of Section 6. 2. 2. e of Technical Specification No.
6. 0 does not limit the responsibilities of the site fire brigade or make a distinction between vital and non-vital areas.
Therefore, it is not clear that a requirement exist in this regard.
This (Items 3A(3) and (4)) is considered an Open Item (50-275/87-27-01)
pending Region V review and acceptance of the licensee's evaluation.
B.
Automatic Fire Alarm S stem The plant's automatic fire alarm system consist of automatic fire suppression system and automatic fire detection system actuations.
The results of the inspector's review of the automatic fire alarm system is as follows:
Fire Detection and Su ression Alarms Annunciation of fire detection and suppression system actuation indication is provided in the control room on several annunciator panels which appear to be installed in locations that are remote and inconvenient to operators in that they are remote from the main control room annunciator boards normally utilized by operators.
Because of the arrangement of the alarm annunciator panels inside the control room, the inspector questioned the design of supervisory circuits associated with the alarms.
The licensee stated that the alarm systems were installed in different time frames and indicated that an evaluation was in progress to determine appropriate upgrading.
In this regard, the inspector cautioned the licensee of the important reliance the plant places on the earliest possible detection of a fire in order to initiate prompt extinguishment.
The licensee acknowledged that a delayed receipt of alarm notification of an actual fire could adversely impact the severity of the fire due to limited onsite firefighting capability and the availability of offsite fire department assistance.
This is considered an Open Item (50-275/87-27-02)
pending Region V review and acceptance of the licensee's evaluatio (2)
Fire Detection Alarm S stem Technical S ecification Surveillance Results Fire detector supervisory circuits associated with detector alarms must be demonstrated operable by performance of a channel functional test every six months in accordance with Technical Specification No. 3. 3. 3. 8.
The inspector reviewed selected results of the licensee's Surveillance Test No.
STP I-34 which was performed to satisfy the technical specification requirements.
The tests appear to have been conducted in accordance with governing code requirements and the test results were satisfactory.
No violations or deviations were identified.
C.
Carbon Dioxide (CO~
Automatic Fire Su ression S stems CO~ automatic fire suppression systems are installed in safety-related areas where the licensee desires to minimize the affects of fire suppression activity on equipment and where containment of the gaseous agent can be ensured.
Technical Specification No. 3.7.9.3 requires that CO~ systems be tested every 18 months to ensure that they are properly charged and in good working condition.
The inspector reviewed selected results of the licensee's Surveillance Test No.
STP M-39 which was performed to satisfy the technical specification requirements.
The tests appear to have been performed in accordance with governing code requirements and the test results were satisfactory.
No violations or deviations were identified.
D.
Fire Barriers Fire barriers are included in the plant's design features as part of a compartmentalization concept to contain the spread of fires.
Fire barriers include walls, floor, ceilings, doors, dampers, fire stops, wrap materials, etc.
Technical Specification No. 3/4.7. 10 requires that'ire barriers be inspected. every 18 months to ensure that they will function as intended.
The inspector reviewed selected results of the licensee's Surveillance Procedure No.
STP M-70 which was performed to satisfy the technical specification requirements.
The inspector's followup on a fire door deficiency noted in a July 18, 1986, surveillance resulted in a review of a number of outstanding Action Requests (ARs) on fire door deficiencies.
AR No.
A0027655 initiated a request to repair broken hasps on RHR pump room door Nos.
B-17 and B-18 on June 20, 1986.
Work Order No.
C0010466 was initiated on February 8, 1987, to complete this work.
However, at the time of the inspector's followup on July 8, 1987, the work was not don At the inspector's request, the licensee initiated an investigation into all outstanding ARs relating to fire door deficiencies to determine if work orders had been initiated and completed in a timely fashion.
According to the licensee, of 33 ARs initiated on fire door deficiencies and shown as open on the Plant Information Management System (PIMS),
23 work orders had actually been completed but the PIMS had not been updated to reflect this.
Work orders had been initiated on the remaining 10 outstanding ARs (including AR No.
A0027655 for the RHR pump room fire doors and ARs involving three security doors) but the work had not been completed.
The licensee indicated that completion of the work to close out AR No.
A0027655 for the RHR pump room fire doors was scheduled in the near future.
However, the maintenance department was encountering manpower difficulties as a result of recent NRC security requirements regarding the qualifications of personnel performing these work activities.
The inspector acknowledged the validity of the licensee's personnel problem in this area and informed the licensee that a further verification of timely closure of identified fire door deficiencies would be made during a subsequent inspection by the NRC.
The licensee indicated that actions to enhance assurance of fire door integrity were already being implemented in the form of an additional maintenance inspection procedure.
A draft copy of this procedure was provided to the inspector.
After reviewing the draft procedure, the inspector agreed with the licensee that if implemented, the procedure could serve to improve the licensee's control over maintaining fire door integrity.
This is considered an Open Item (50-275/87-27-03)
pending further licensee action and Region V review.
No violations or deviations were identified.
4.
Safe Shutdown Ca abilit The licensee's fire protection program was developed, in part, to limit the affect of system failure in both units due to fire damage.
A fire hazard analysis of the plant's safe shutdown capability is described in the licensee's
"Fire Protection Review," which was submitted to the NRC as Amendment No.
51 to the facility's application for an operating license.
As a supplement to the fire hazard analysis, a safe shutdown analysis was performed by the licensee using the criteria of Appendix R
to 10 CFR 50.
Deviations from the NRC's fire protection criteria were identified by the licensee and submitted to the NRC on July 15, 1983 for Unit 1 and December 6,
1984 for Unit 2.
The NRC staff's evaluation of these submittals by the licensee are contained in supplements 8, 9, 13, 23, 27 and 31 to the Diablo Canyon Safety Evaluation Report and support the bases for the NRC's issuance of Facility Operating License Nos.
DPR-80 and DPR-82 for Unit 1 and Unit 2, respectively.
To determine whether the facility continues to be capable of achieving post fire safe shutdown using the physical plant configuration, procedures and trained personnel, the inspector verified the licensee's established safe shutdown capability as follows:
A.
Safe-Shutdown Procedures Procedures are in effect implementing the established safe shutdown methodology.
Operations Procedure No.
AP-8 is a symptom based procedure which directs operators to take specific actions upon loss of system function or control room inaccessibility due to fire or other events.
Emergency Procedure No.
EP M-10 is an event based procedure which directs operators to take specific actions to mitigate the adverse consequence of fire occur rences in any plant fire area.
Emergency Procedure No.
EP R-6 contains pre-fire plans and specific operator action for fire occurrences in radiological areas, and Emergency Procedure No.
EP M-6 contains pre-fire plans and specific operator action for fire occurrences in non-radiological controlled areas.
The procedures were properly documented with copies located in the control room, remote shutdown panels and other prescribed emergency stations.
B.
Procedural Enhancements Subsequent to the Appendix R to 10 CFR 50 inspection conducted by the NRC staff during November-December 1985, the licensee made enhancement revisions to post fire safe shutdown procedures as follows:
(1)
0 erations Procedure No.
AP-8 Revision No.
3 to Operations Procedure No.
AP-8 was added to specify manual backup actions to ensure that all equipment designated for achieving and maintaining safe shutdown conditions could be made functional under all postulated fire scenarios.
(2)
Emer enc Procedure No.
EP M-10 Revision No.
3 to Emergency Procedure No.
EP M-10 was added to provide operators with current and accurate correlations between fire alarms and associated safe shutdown equipment that could be lost in a given plant fire area.
(3)
Emer enc Procedure Nos.
EP R-6 and EP M-6 Revision No.
12 of Emergency Procedure No.
EP R-6 and Revision No.
14 of Emergency Procedure No.
EP M-6 were added to provide operators with specific information regarding pre-fire plans and firefighting strategy in radiological and non-radiological controlled areas.
From a review of each procedural revision, the inspector determined that the information and direction provided to operators was useful and served to enhance effective and efficient mitigation of the a'dverse affects of fire damage to the plant's ability to achieve and maintain post fire safe shutdown.
No violations or deviations were identifie erator Trainin The fire protection program requires that the licensee's training program for licensed and non-licensed personnel be expanded to include post-fire alternative or dedicated safe shutdown capability.
On July 9, 1987, the inspector reviewed the licensee's operator training program to determine the extent that training in post-fire safe shutdown is provided to operators.
The licensee's initial, requalification and upgrade training programs contain classroom lectures and hands-on training that challenge operator response to mitigate the affects of fire damage on the plant.
quarterly drills, approximately 50-60 hours simulator training and 10 percent of classroom lesson plans require operators successfully demonstrate the proper response to the affects of fire damage scenarios.
Physical walkdowns, validation of procedures and simulator manipulations include focusing on loss of systems, fire-induced transients and control room inaccessibility.
Based on the inspectors review, the training program appears to satisfy the objectives specified by the safe-shutdown analysis for the facility.
No violations or deviations were identified.
Plant Ph sical Confi uration/Protection of Safe-Shutdown S stems During plant tours, the licensee staff and the inspector observed the physical protection provided for systems and components needed to achieve and maintain safe-shutdown conditions.
In most cases, the licensee utilized the compartmentation concept for safe shutdown configuration control.
This concept employs various type fire barriers.
In addition, the safe shutdown protection method include separation of redundant trains by distance and automatic fire suppression and detection systems.
The licensee elected to achieve compliance with the NRC's fire protection of safe shutdown capability requirements by following their understanding of the guidance contained in NRC Generic Letter No. 86-10.
This approach resulted in the licensee implementing physical configurations that deviate from those described in the NRC's Fire Protection Safety Evaluation Reports for Unit 1 and Unit 2.
According to the licensee, there are approximately 85 deviations of this type which the licensee has evaluated and justified in accordance with NRC Generic Letter 86-10.
The inspector and the licensee's staff discussed the appropriate mechanism for NRC's review of the evaluations.
Based on this discussion, the licensee indicated that consideration would be given to notifying appropriate NRC personnel by separate correspondence once the evaluations are finalized.
However, in the event that such a separate correspondence is determined unnecessary, the deviations and their associated justifications will be submitted to the NRC as part of the next FSAR update.
The inspector informed the licensee that the language of condition No. 2.C(4) for the Unit 1 operating
'
license and condition No. 2.C(5) for the Unit 2 operating license appears to prescribe the actions to be taken regarding the evaluations.
This is considered an Open Item (50-275/87-27-04)
pending further licensee action and followup by the NRC.
equality audits of the plants fire protection program and implementing procedures are required to be performed in accordance with Technical Specification 6.5.2.8.
The inspector reviewed equality Assurance Audit Report Nos.
87061T dated May 15, 1987 and 86083T dated May 17, 1986.
The audits appeared to be thorough and contained the required content to meet the NRC guidelines of Generic Letter No. 82-21.
No violations or deviations were identified.
6.
~Den Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC, the licensee, or both.
Open items disclosed during the inspection are discussed in paragraphs 3.A(3), 3.A(4), 3.8(1),
3.0.
and 4.0.
7.
Exit Inter view The inspector met with the licensee's representatives (noted in paragraph 1) at various times during the inspection and formally on July 10, 1987, to summarize the scope of the findings and inspection activities described in this report.
The licensee's representatives acknowledged the statements made by the inspecto )
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