IR 05000293/1987022

Insp Rept 50-293/87-22 on 870504-15.No Unacceptable Conditions Identified.Major Areas Inspected:Licensee Effort to Comply w/10CFR50,App R,Section Iii.G,J & L Requirements Re Fire Protection Features to Assure Safe Shutdown

ML20216E385
Person / Time
Site:	Pilgrim
Issue date:	06/11/1987
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216E347	List: IR 05000293/1987022 ML20216E343
References
50-293-87-22, NUDOCS 8706300689
Download: ML20216E385 (17)

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U.S. NUCLEAR REGULATORY COMMISSIO REGION I

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Report No.- -87-22'

Docket N License'No. . DPR-35 Priority --

Category C Licensee:- Boston Edison Company Facility Name: Pilgrim Nuclear Power Station Insp'ection At: Plymouth Massachusetts

' Inspection Conducted: May 4 - 15, 1987 Inspector: '

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N. VEasopoulos, Reictor Engineer d' ate

'Also participating in the inspection and contributing to the report were:

L. Doerflein, Reactor Engineer, Region I D. Notley, Fire Protection Engineer, NRR R. Hodor, Mechanical Systems Specialist, BNL-

'H. Thomas, Electri 1 Systems Specialist, BNL Approved by: C 6 / fr7 -

C. J/ Anderson, Chief, Plant Systems date Section, DRS Inspection-Summary: Inspection on May 4-15, 1987 (Report No. 50-293/87-22)

Areas Inspected: Special, announced team inspection of the licensee's effort-to comply with the requirements of 10 CFR 50, Appendix R, Section III. G, J and-L concerning fire protection features to ensure the ability to achieve and maintain safe shutdown in the event of a fir Results: No unacceptable conditions were identifie ;

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.e DETAILS'

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.Et 3,3 'Poston Edison _ Company (BECO)

• R. 'E. Bird, Senior Vice President

• L. Beckwith, Compliance Engineer

• S. Hudson, Operations Section Manager

• C, Kuhns, QA Engineer Q'% "

, *K. Roberts,. Nuclear Operations Manager i, *T. VanKataraman, Project Licensing Engineer

, *W.- Sullivan, Sr. Fire Protection Engineer

%' *R. Levin, Electrical Engineer b? *R. Kirven, Electrical Engineer

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• S. Wo11 man, Principal Operations Engineer

• T. Trepanier', Operations (General Electric Employee)

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' , , *P. Hamilton, Compliance Group Leader (acting)

e- *J. Quinn, Sr. QA Engineer T'x ' *F. Wozniak, Fire Protection Group Leader WM '

• R. Velez, . Fire Protection Project Manager

~ R. Coulombe, Engineer (General Electric Employee)

J. Coffey, Engineer (General Electric Employee)

J.: Waal, Consultant (J.C. Waal Engineering Co.)

P,- Rainey', Engineer (P.A. Rainey Engineering Co.)

D. Gerlits, Engineer, Systems and Safety. Analyst

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S. Burke, Engineer ~ (Impe11 Corp.)

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1.2 Nuclear Regulatory Commission (NRC).

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• McBride, Ph.D., Sr.- Resident Inspector

• L. Bettenhausen; Ph.D., Acting Deputy Director, DRS, Region I my/ *J. - Lyash. Resident ~ Inspector Aq

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F' * Denotes those'present at the exit meeting,

"2 Follow up of Previous Inspection Findings l 4 .(Closed) Unresolved Item (85-30-04) Inadeguate Safe Shutdown Procedure

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and Operator Training Q fl)}; f f . A~ Safety Systems Functional Inspection (SSFI) performed to assess the M~ cp.j' -operational readiness of selected safety systems ' identified the e following weaknesses in the licensee's safe shutdown capability in the

, event of a' fire:-

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Inadequate operator training and knowledge of safe shutdown l procedure;

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Safe, shutdown procedures lack detail and are incomplete;

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Emergency Lights not' properly installe i A special safety inspection specifically performed to inspect the licensees I capability to safely shutdown the plant reviewed all of the above concerns <

and weaknesses. The results of this insp'ection are contained in this  ;

report. Two unresolved items remained at the end of the inspection'and appear in .section 8.1 and 8.2 of this repor Since all of the SSFI concerns in the safe shutdown area were reviewed '

during this inspection, this item is closed administrativel (Closed) Unresolved Item (85-50-05) Emergency Lighting For "butdown

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During the SSFI inspection (Report 85-30) a number of emergency light deficiencies were identifie The deficiencies in general were a backlog of maintenance request for work on_ emergency lights, apparent misplacement or misalignment of the lighting fixtures and problems with light surveillanc Inasmuch as these deficiencies as stated, appear to be a violation of the requirem'ents, during this inspection which was conducted to evaluate the emergency lights for compliance with the requirements, the available data could not verify the violatio To followup this item however, the inspectors reviewed the installed Emergency Lighting and work in process and did not identify any unacceptable conditions. The inspectors also revievied the maintenance request list to identify whether a back-log exists on maintenance work for emergency lights. No emergency light maintenance activities were identifie The licensee stated that all maintenance work on emergency lights was completed in June, 1986. In addition, the licensee stated that a walkdown was performed in May of 1986 to identify additional lighting needs resulting from modifi-cations to the alternate shutdown panels. As a result of this review, the licensee initiated activities to install additional lighting units.

l No unecceptable conditions were identified.

l l- This item is resolve (Closed) Unresolved Item (86-06-11) Fire WatcLTraining and Fire Watch Training Procedures The NRC identified the concern that fire watches have not received training in fire extinguishment using portable fire extinguisher The licensee stated that the primary function of the fire watch is to alert the control room in the event of a fir The licensee, however, thru their fire watch contractor, the National Fire and Medical Services, Inc. (FNMS) committed to and has implemented a training program to train fire watch personnel in the proper use and safe operation of fire

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extinguishers. This is accomplished through classroom instruction and actual fire extinguishment (Hands-or practice).

This training program has been completed and all fire watchers, as of May 15, 1987, have received hands on practice. The actions taken by the licensee satisfy the NRC concerns in this are This item is resolve (Closed) Deviation (86-25-01) Failure of Fire Fighters to Participate in the Required Number of Drills The licensee committed to conduct sufficient drills each calendar quarter to assure that each Brigade member participates in at least two drills per year. The inspector reviewed the drill attendance records and the records for drill participation for each Brigade member and determined that each Brigade member currently on the Brigade availability list has participated in at least two drills per year. To assure that the above requirements i are implemented, the licensee revised the Fire Brigade Training Drill '

Procedure 1.4.23, Revision 8 to include the following: i

"The PNPS Fire Plan and NRC commitments require that a sufficient number of drills be conducted so that each Brigades-man participates in two (2)

drills per year. These fire drills should be scheduled so that the Brigade member meet the requirement Scheduling should also include fire drills to be conducted on the back shifts. A minimum of five drills will be conducted per quarter. The Plymouth Fire Department should participate in one drill per yea Documentation of all drills shall be forwarded to all observers, training department, Fire Protection Group Leader, and Chief Operating Engineer."

To prevent recurrence, the licensee improved the tracking method of the training given to the firefighters, by setting up a training documentation file that is reviewed by the Fire Prctection Group Leader prior to the issuance of the Brigade availability roste No unacceptable conditions were identified. This item is resolve (0 pen) Unresolved Item (86-36-01) Maintenance Work on Fire Protection Equipment and Excessive Reliance on Fire Watches The concern raised by the NRC was that maintenance and repair work on fire protection equipment was not implemented expeditiously. In addition, a large number of fire barriers were identified as degraded by the licensee, which necessitates implementation of fire watches as a compensatory measure for both the degraded fire protection equipment and the fire barrier The licensee in a Management Meeting held on January 20, 1987, at the Region I office, acknowledged the above concerns and committed to

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imp 1'ement repairs on'the fire protection equipment and fire barriers expeditiously and to reduce reliance on the fire watche The inspector-reviewed the licensee's efforts in this area and determined that-the licensee is making progress.toward these goals. -The revie identified that the licensee reduced the number of outstanding maintenance

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requests from about 300 to 85. All but one of the maintenance requests affecting.the fire pump system have been completed. Reliance.on fire watches continues to exist, however, this condition exists primarily because the work on fire barriers separating safe shutdown systems is not completed. The licensee stated that they intend to complete all such fire barrier work before restar This item continues to be unresolved pending an-inspection of the completed. work on fire barrier (Closed) Violation (86-36-03) Fire Fighters Fail to Attend Quarterly

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Meeting The--licensee agreed with the violation. To prevent recurrence, the licensee revised the training manual to accurately reflect the regulatory requirements in this area. The revised training manual section 4.2.1.1.8-states that, "Any individual who does not complete'his quarterly training obligations, will be removed from the active fire fighter list until the training is mad.e up", The inspector reviewed the training records to verify that all Brigade members have participated in.the required quarterly training sessions. The. inspector.did not identify any unacceptable conditions. This item is close (Closed) Violation (86-36-04) Failure to Adequately Implement Fire Watch Procedures The licensee's corrective actions were to reinstruct the fire watch personnel and increase the field supervision of the fire watches to ensure that they perform as require The inspector reviewed certain routes taken by the watches to verify that the watches can perform as required within the time allotted. The inspector interviewed fire watch personnel to verify that they are cognizant of their duties and also reviewed instruction sheets issued to the fire watche No unacceptable conditions were identifie This item is closa '(Closed) Violation (86-37-06) Failura to Conduct Adequate Fire Drills The licensee initiated corrective actions to address the concern. These actions included a revision of the drill procedures requiring written drill critiques and a commitment to simulate drills realisticall The

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licensee also committed to invalidate the drill performed on November 4, 1986, because the drill participants did not perform adequately. The inspector reviewed the drill records and verified that the drill was invalidated. The inspector also witnessed two drills to evaluate the training of the drill participants. The five Brigade members who participated in the drills' responded properly and they demonstrated a successful simulated extinguishment of the assumed fir They demonstrated knowledge of equipment and usage and proper extinguishment techniques. The follow up critiques by the Brigade instructor were comprehensiv !

An interview of the Brigade members by the inspector verified that the firefighters receive adequate firefighting training by qualified training personne This item'is close .0 Purpose This inspection was performed to ascertain that the license is in 4 conformance with 10 CFR 50, Appendix R, Sections III. G, J, and L, including exemptions approved by the Office of Nuclear Regulation (NRR).

4.0 Background The licensee is required to comply with the requirements of 10 CFR 50 Appendix R, Section III. G, J, and The schedule for compliance with the above requirements is set forth in 10 CFR 50.4 Section III. G of Appendix R requires that fire protection is provided to ensure that one safe shutdown train remains available in the event of a fir Section III. J requires that emergency lights are installed in all areas required for safe shutdown purposes and Section III. L specifies the requirements for alternate shutdown capabilit .0 Correspondence Correspondence between the licensee and the NRC concerning compliance with Section III. G, J, and L was reviewed by the inspection team in preparation for the site visi Attachment 1 to this report is a listing of the correspondence reviewe .0 Post-Fire Safe Shutdown Capability 6.1 Systems Required for Safe Shutdown The licensee has specified that the following systems be used for !

safe shutdown in the event of a fire when offsite power is lost: I

! Reactor protection system (RDS) 1 i

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29 Automatic depressurization system (ADS) Reactor. core isolation cooling (RCIC) system High Pressure coolant injection (HPCI). system Residual heat removal (RHR) system, low pressure coolant H injection (LPCI) mode Residual. heat removal (RHR) system, torus cooling-mode .

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~ Residual heat removal (RHR) system, shutdown cooling mode, and

. Core spray.(CS) system

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Safe shutdown reactivity control is initiated from the' control room by a manual scram of the control rodstor by action of.the reacto protection syste Reactor coolant inventory canibe maintained by

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either the reactor core isolation cooling-(RCIC) system, the high

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pressure coolant injection (HPCI) system during high pressur conditions or'the low pressure coolant injection (LPCI)' system or the

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core spray (CS) system in conjunction with the automatic

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depressurization system (ADS) during low pressure conditions,

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Reactor coolant system pressure is controlled by either the RCIC, the E HPCI or the: ADS in conjunction with the residual heat' removal (RHR).

system in the' steam condensing mode.- Decay heat removal is provided by either.the.RHR inLthe' shutdown co'oling mode or the LPCI'or core-spray in ' conjunction with the RHR in the suppression . pool cooling mod The support systems required for safe shutdown include the salt service water ' system, the reactor building closed cooling water-system, the primary containment isolation system, the essential ventilation systems, the emergency diesel generator, the essential-electrical distribution system and the' process monitoring syste The above systems will be monitored and controlled from the control room or the remote shutdown panels.and' local contt01 station .2 Alternate Safe Shutdown Areas The licensee's safe shutdown' analysis identified the need to. provide alternate safe shutdown capability in the following fire areas:

Fire Area (FA) East Side Reactor Buildup i Fire Area (FA) 1.10 West Side Reactor Buildu !

Fire Area (FA) 3.1 The Control Room Fire Area (FA) 3.2 The Cable Spreading Room

- Remaining Plant Areas l

Safe Shutdown Plant Systems not in compliance with the requirements of Section III. G.2 of Appendix R must be provided with an alternate safe shutdown system unless an exemption request has been approved by J the Commission, j The licensee requested a number of exemptions to certain requirements of- Appendix R which were evaluated and granted by the NRC. The j

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licensee stated that 5. exemptions are currently under review by NR In addition, the licensee'is in the process of requesting four j additional exemptions in this area. Attachment 2 of this report is a it listing of all.the exemption request .4 -Alternate Safe Shutdown System l

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The alternate safe shutdown systems required for the areas not meeting Section III. G.2 utilize the existing. plant. systems and equipment identified in section 6.1 along with the alignment of local manual valves and local instrumentation.and local control of' shutdown and support. equipment. The alternative shutdown' capability consists of 14 remote shutdown panels, local control and isolation switches and alternate control power' feeders. The licensee has proposed pulling fuses'and opening circuit breakers as a r.ethod of electrically. isolating some equipment during shutdown outside the 1 control-room. This is the subject of a pending exemption reques The shutdown panels are located near the. associated. equipment and consist of locked enclosures housing switches and instrumentati Applicable operating procedures are kept inside each shutdownLpanel to guide.the operators in carrying out emergency operations at the panel The panel (eq'ipment) u n' umbers, locations and associated shutdow systems are as follows:

PANEL- LOCATION SYSTEM C163 RB el. 23' SE RHR-C156 RB el. 23' E ADS C152 RB el. 23' E . RHR C158 RB el'. 238 W HPCI-C155 RB el.'23' W HPCI C157 RB el'. 23' W ADS C153 RB el. 23' W RHR-C165 RB el. 23' W Torus In C159 RB el. 23' SW' RCIC C154 RB el. 23' SW RCIC C151 Aux Bay A el. 3' SSW/RBCCW A A150 Aux Bay B el. 3' SSW/RBCCW B C160 EDG A room EDG A

, C161 EDG B room EDG B

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For a fire in the Control Room or the Cable Spreading Room, alternate shutdown capability utilizes HPCI, RCIC or ADS with RHR in the LPCI mode or ADS with the core spray system. For a fire in the East Side Reactor Building (F. A.1.9) shutdown capability is available using ADS with RHR in the LPCI mode. For a fire in the West Side Reactor Building (F. A.1.10) shutdown capability is. available using ADS with the core spray system or ADS with RHR in.the LPCI mod RHR in the torus cooling mode and shutdown cooling mode is available for a fire in the Control Room, Cable Spreading Room, F.A. 1.9 and F.A. 1.1 ,

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Instrumentation for the alternate. shutdown-capability for the Control Room and Cable Sp~ reading Room is provided at a remote. shutdown panel:

and a loca1Linstrument. rac Instrumentation for alternate shutdown; ;

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capability.for, fire, area 1.9 is provided in the Control Room and at.a., '

remote shutdown pane Instrumentation for alternate shutdown __

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capability for fire area.1.10 is provided in the Control Room. _All' i the necessary support. systems such as Emergency Diesels' Salt Service

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. Water,and' Reactor Building' Component Cooling Water, etc., that are '

necessary to . support these primary-shutdown systems are also

available for a fire in these~ fire area . Inspection Methodology

.The inspection. team examined the: licensee's capabilities for separatin and protecting equipment, cabling and associated circuits necessary'to achieve and maintain hot.and' cold shutodwn conditions.. This inspection sampled selected fire areas which.the licensee had identified as'being in compliance:with Section II The'foll'owingLfunctional; requirements were reviewed for achieving and-

. maintaining hot and cold shutdown:

• Reactivity control

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• . Pres'sure control

• Reactor coolant makeup

• - D'e cay heat removal l Support. systems

<* Process monitoring-The. inspection team examined the licensee's capability to achieve and maintain hot shutdown and the capability to bring the plant to cold

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shutdown conditions in the event of a fire in various areas of the plan ~

The examination included a review of drawings, safe shutdown procedures and other document Dra'

w ings were reviewed to verify electrical independence from the fire' areas of concer Procedures were reviewed for general content and. feasibilit Also inspected were' fire detection and suppression systems and the degree of physical separation between redundant trains of Safe Shutdown Systems (SSSs). The team review included an evaluation of the susceptibility of

.the'SSSs to damage from fire suppression activities or from the rupture or

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inadvertent operation of fire suppression system ,

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The inspection team examined the licensee's fire protection features  !

provided to maintain one train of equipment needed for safe shutdown free of fire damage. Included in the scope of this effort were fire area i

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boundaries,-(including walls,' floors and ceilings), and fire protection of openings such as fire doors,1 fire dampers, and penetration seal l The inspection: team also examined the licensee's compliance with Section

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III.J, Emergency Lighting. Appendix R,Section III.0, 011 Collection ,

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System for.the Reactor Coolant-Pump, is not an Appendix-R requirement for i plants such as Pilgrim since the containment is inerted during normal

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8.0 Inspection of Protection Provided for Safe Shutdown Systems i

" k 8.1 Protection in-Various Fire ~ Area  !

i The team reviewed the protection provided to.SSSs and work in '

progress 11n_. selected fire areas for compliance with Appendix R, Section'III.G.1, 2.and The fo.11owing fire areas were inspected:

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Fire Area . Reactor Building - East Side Elevations-17', 3', 23' and 51'

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Fire Area 1.10 Reactor Building - West Side Elevation ~

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"B" Switchgear Room Diesel Building, Division B

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Reactor Building Closed Cooling Water Pump Room, Division A Fire Area 1.21 Reactor Building Closed Cooling Water Pump-Room, Division B Fire Area Control Room

, Fire Area Cable Spreading Room

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Fire Area 3.3- Radwaste and Control Building Corridor -

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' Elevation 23 feet Fire Area Diesel Building, Division A Fire Area Salt Service Water Pump Room, Division A Fire Area Salt Service Water Pump Room, Division B

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'The only deficiencies. identified in the~abovefareas are discussed-

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The team in reviewing the Appendix R analysis determined that it'1 1s ..

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difficult to follow and may create compliance ~ problems in the future ~

A document' that/ clearly describes theilicensee's , detailed basis' fo ; Appendix R compliance is desirable in the-long term. Thi s ti s'. to ;

prevent;the potential l for degrading ' Appendix R protection when future'

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plant ' modifications.'are made. ' The licensee agreed with the team's ;

concern and stated that they planned to'. develop-.such a' documen i Pending implementation.of this commitment and review ~of the proposed 1 document this" item remains unresolved pending-. licensee completion of-

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'thisdocument.(87-22-01).

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8.2 JSafe Shutdown Procedures'

8. procedures' Review y , q

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m- The team reviewed procedure no. 2.4.143, " Shutdown.From

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~Q utside' Control' Room", Revision 6;

.The scope of this-review was to-ascertain that the shutdow '

could be attained Infa safe andl orderly manner, to determine the level of difficulty: involved in. operating equipment, and to verify that there was not dependence on repairs (for achieving hot shutdown. For review purposes, a repair may include i.nstalling. electrical.or pneumatic jumpers, wires or fuses to preform'an action required fo hot shutdown. For cold shutdown, repairs are allowed using ;

'in place procedures and materials availabl.e onsite with the ;

provision that cold shutdown be achievable with 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> The' procedure,'which would be used in event' of. a fire in the control room or the ' cable spreading room, was approved

, by the 0perations Review Committee on May 6, 1987. The procedure had.not been approved by the Nuclear Operations Mana~ger and will not~be implemented until all operators. .

have been trained on the procedure. The licensee. indicated-

that lesson plans were being developed and the training would be completed prior to startup.

P 4 In addition to the cable spreading room and the contro room, the licensee has identified two other fire areas, mainly the East Side and the West Side of the Reactor Building 23 foot elevation, which require procedura actions to ensure that the redundant train of the systems

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necessary to achieve and maintain hot shutdown conditions will be availabl The licensee showed the team a draft procedure for shutdown with a fire in either of the-fire areas noted abov _

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h The licensee alsol stated their commitment to perform a test to verify shutdown from outside the control room using the ,

alternate shutdown panels. The details of: this test have

- not been developed,.but the licensee ~ stated that the NRC i

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will be notified prior to this' test. The team did not i

identify any unacceptable conditions,.but since the a

' shutdown. procedures have not been completed, the operators'

have not.been trained in the procedure and the shutdown

test has not been performed; the team, considered.this to be.an unresolved item subject to completion of-these items (87-22-02).

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8.2.2- Procedure Walk-Through?

Theiteam walked through' selected portions of procedure n !

2.4.143, " Shutdown From Outside Control Room," to determin I by simulation.that. shutdown from outside the control room-Y 'could be attained in an. orderly and timely fashion. .The procedure walk-through was accomplished by four members of .

the licensee's operations support. staff. The walk-through began in the."A" switchgear room and the p'rocedure was

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. conditions were achieved. The team paid particular-attention to the feasibility of each man'ual action, ease of, access, communication and sequence.of operatio During the walkdown, the tead obrerved that communications using the two 'way walkie talkies were not effectiv The ilicensee is installing modification PDC No. 87.29,'which will include installation of a radio repeater system to provide reliable communications to all the required areas of the plant. The team noted that the licensee has not yet established procedures for. periodically inventorying or surveilling;the toolboxes which contain the communication equipment, tools,.keyscand jumpers required for shutdown outside the control room. Implementation of these procedures as well as the adequacy of the communications will be reviewed in connection with closing the previously identified . unresolved item 87-22-02, described in Section 8. '

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8.3 Protection for Associated Circuits

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Appendix R,Section III.G requires that protection be provided for associated circuits that could prevent operation or cause

, maloperation of redundant trains of systems necessary for safe i shutdown. The circuits of concern are generally associated with safe

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shutdown circuits in one of three ways:

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+ Common bus concern l

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!*~ Spurious signals concern

', * Common' enclosure concern '

The associated circuits were evaluated by the team for common bus, n

. spurious. signal,'and common enclosure. concern Power, control, and (

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instrumentation circuits were examined on a sampling' basis-for j potential problem l J

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8. Common Bus Concerns

~The common bus concern may.be found in circuits, either 4 safety related or non-safety related, where .there is 'a

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source.is not electrically protected from the circuit of I concer The team examined,'on a sampling basis, 4160V, 480V,.

120VAC, 125V.O.C. and 250 V.D.C. bus protective relay coordination. The licensee presented sample. coordination curves dated May 7, 1987, at the. time of the audit. The team also examined, on.a sampling basis, the protection for specific. instrumentation, . controls, and power circuits, including the coordination of fuses and circuit breaker '

The licensee plans.to perform checks'of relay settings at approximately 24-month interval No unacceptable conditions were identifie . Spurious Signals Concern Th'e spurious signal concern is made up of 2 items:

False motor control and instrument indicatio'ns can occur such as those encountered during the 1975. Browns Ferry fire. These could be caused by fire initiated grounds, short or open circuit *

. Spurious operation of safety related or non-safety related components can occur that would adversely affect shutdown capability (e.g., RHR/RCS isolation valves).

The team examined, on a sampling basis, the following areas to ascertain that no spurious signal concern exists:

Current transformer secondaries

• High/ low pressure interfaces

General fire instigated spurious signals , a t. .

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The team determined that the licensee conducted an analysis which identified a number of high/ low pressure interface t In order to protect against the possibility of spurious .

actuation of high/ low pressure interfaces, the licensee is I 1) utilizing check valves, 2) removing power by pulling fuses and 3) using closed block valves to assure low 1 pressure. system isolatio The current transformer j secondaries of concern are protected by the installation of j isolation switches which disconnect and short the secondarie Each fire area was analyzed to determire the impact of !

general fire instigated spurious signals. The licensee identified a number of cases which were resolved by closing in-line block valves, and/or installation of isolation !

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Within this area the licensee is preparing exemption request No. 21 to request permission to replace fuses i during hot shutdow Fuse replacement is censidered to be a repair. This activity requires an exemption from the j Appendix R rule where this manual action is to be performed 1 to-achieve hot shutdown conditions. The reason for the request is that the potential exists for blowing fuses in the HPCI, RHR-LPCI, RHR Suppression Pool Cooling, and Salt Service Water Control Circuits for a Control Room Cable Spreading Room Fir This item will be resolved when NRR responds to the exemption request. No unacceptable conditions were !'

identifie .3.3. Common Enclosure Concern The common enclosure concern may be found when redundant circuits are routed together in a raceway or enclosure and !

they are not electrically protected or when fire can destroy both circuits due to inadequate. fire barrier A number of circuits, selected on a sampling basis were examined for this concer The common enclosure concern was satisfactorily addresse k

The redundant cables for divisions A, B and X are not run in the same tray or conduit In addition, all circuits are protected with coordinated circuit breakers or fuse i No unacceptable conditions were identifie !

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l ' Emergency Lighting L {10 CFR.50," Appendix R, Section_III J , requires'that emergency lighting units .with ~at least an 8-hours battery po_wer supply shall be provided in all areas needed for operation of safe shutdown equipment and in access

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and egress: route's.theret The~ team examined the plant emergency lighting system along with the units

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currently being installed to ascertain the licensee's compliance with the

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above requirements.

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The team did not identify any unacceptable condition .0 011- collection System for Reactor Coolant Pumps-10 CFR_50, Appendix R,Section III.0, requires that the reactor coolant

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pumps shall be equipped with an oil collection system if the containment

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~1s-not inerted during_ normal operation. As the containment.in this plant islinerted during normal operation, the above requirement does not' apply to this plant,

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y -11.0' Quality Assurance During the course of'the inspection, the team reviewed several drawings, the1 fire hazard analysis, . fire protection modification packages, procedures, and other fire protection documents. The scope of this review included verification of their technical adequacy, appropriate reviews,-

-design and procurement controls, and other Quality Assurance requirements of the licensee's fire protection program. Except as noted in the previous section of this report, the-team did not identify any:other unacceptable condition '

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12.0 Unresolved Items

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Unresolved items are matters for which more information is_ required in' I order to ascertain whether they are acceptable, violations, or deviation Unresolved' items are discussed in Section 8.1'and .0 Exit Interview The inspection team met with the licensee representatives, denoted in 1 Section_11.0, at'the conclusion of the inspection on May 15, 1987, and the-team leader summarized-the scope and findings of the inspection at that tim ,

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The' team leader also confirmed with the 1.icensee that the report will not contain any proprietary'information. The licensee agreed that the

. inspection report may be placed in the Public Document Room without prior ,

licensee review for proprietary information (10 CFR 2.790).  ;

At no time during this inspection was written material provided to the '

licensee by the tea ,

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ATTACHMENT 1 .

i List of Corresgondence

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NRC to BECO November 10, 1981 Fire Protection Exemption Request ,

j NRC to BECO November 2, 1983 Safety Evaluation for Appendix R items ;

III.G 3 and II NRC-to BECO June 10, 1985 Correction to Exemption and Safety Evaluation related to Section III.G of .I Appendix R NRC to BECO August 19, 1986 Installation of Water Curtain, Reactor Building i

BECO to NRC February 3, 1986 Pilgrim Appendix R Exemption Request BECO to NRC April 21, 1987 Appendix R Exemption Request Supplemental i Information

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A,TTACHMENT 2 eLIST OF EXEMPTION REQUESTS :

5 EXEMPTION REQUEST (ER) _ GRANTED ER#05~ TORUS WATER LEVEL ER#06 TORUS WATER TEMPERATURE

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ER#07 FIXED SUPPRESSION SYSTEM (ZONES 1.9 & 1.10)

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ER#08 FIXED. SUPPRESSION (ZONES' 1.11 & 1.12)

ER#09 AREAS WITH ALTERNATE SHUTDOWN & NO FIXED SUPPRESSION

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5 EXEMPTION REQUESTS UNDER NRR REVIEW

. 1 ER#11 LACK OF RATED BARRIER BETWEEN TORUS AND CRD QUAD .

I ER#12 LACK OF RATED BARRIER BETWEEN TORUS AND RHR QUAD ER#13 UNPROTECTED STRUCTURAL STEEL IN TORUS COMPARTMENT j ER#14 UNPROTECTED STRUCTURAL STEEL IN STEAM TUNNEL ;

ER#17 EMERGENCY LIGHTING OUTSIDE PROCESS BUILDING l 4 EXEMPTION REQUEST IN PREPARATION ER#15 LACK OF RATED BARRIER BETWEEN CORR. 137 & RADWASTE ER#18 WATER TREATMENT - FT SEPARATION ER#21 FUSE REPLACEMENT AS REPAIR AND EAC JUMPERS ER#22 TORUS WATER LEVEL

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