IR 05000302/1997018
| ML20198P238 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/06/1998 |
| From: | Belisle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198P217 | List: |
| References | |
| 50-302-97-18, NUDOCS 9801220041 | |
| Download: ML20198P238 (36) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION II'
Docket No:
50 302 l
License No:-
DPR 72
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t Report No:
50 302/97 18
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Licensee:
Florida Power Corporation
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facility:
Crystal River Nuclear Station Unit 3
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Location:
15760 West Power Line Street
Crystal River, FL.34428 6708 l
Dates:
November 17 21 and December 1-12, 1997 i
Inspectors:
C. Julian Technical Assistant, Division of Reactor-f Safety
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P. Fillion. Reactor Inspector (Electrical)
i M. Hiller, Reactor Inspector (Electrical)
I W. Miller, Jr., Reactor Inspector (Fire Protection).
G. Wiseman, Reactor Inspector (Fire Protection)
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i Approved by:
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- George A, Bellsle,(Chief-f/
fate' 51gned Special Inspection Branch
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Division of Reactor Safety i
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EXECUTIVE SUMMARY Crystal River Unit 3
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NRC Inspection Report 50 302/97-18 i
This routine, announced inspection was conducted in the area of plant support
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by five regional inspectors. The report cevers a 3 week period of inspection
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to review the resolution of fire protection issues associated with the
requirements of 10 CFR 50 Appendix R.
i Plant Suonort j
AneffectiveAbpendixRcorrectiveactionprogramwasbeingimplemented.
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sufficient num er of personnel with a good knowledge of the Appendix R fire protection requirements were assigned to resolve the identified discrepancies.
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Good engineering documents had been developed.
Work was either being implemented or had been completed on all of the required restart issues.
It was concluded that the unit will be ready for rescart when the licensee's
i required restart issues on the licensee's * Restart Mode Restraint Report" have
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been completed.
(Section Fl.1)
The licensee had completed a reassessment of the CR3 Appendix R fire protection requirements and ap3ropriate actions were being taken to revise the
CR3 Appendix R Fire Study and )rocedures OP-880 and AP 990.
An NRC review of the revisions to the Fire Study and to Procedures OP 880 and AP 990 will be
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performed during a subsequent NRC inspection.
(Section F1.2)
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The licensee's corrective action for the problems associated with the seismic expansion joint fire barriers between the Reactor Building and the Auxiliary and Intermediate Buildings was appropriate and of sufficient scope to resolve this issue.
(Section F1.3)
The licensee's corrective action, including modifications and repairs to the RCP oil collection system, was sufficient to place the RCP oil collection system in compliance with the require,aents of 10 CFR 50 Appendix R. Section 111.0.
(Section F1.4)
The current transformer secondary protectors were being installed in accordance with the licensee's commitments and requirements and met the NRC regulations of Appendix R.
Completion of these items were being tracked as Restart Mode Restraint (RMR) No. 97 0286.
(Section F1.5)
The licensee had implemented extensive corrective action to correct the design errors regarding hot shorts with remote shutdown circuits that resulted in operation outside the design basis of 10 CFR 50 Appendix R. (Section F1.6)
The licensee had either completed all of--the required independent assessment restart issues or scheduled completion of the issues prior to the unit's restart, except for several items related to documentation issues.
The open issues were being tracked by the licensee's program for commitment issues and will be inspected by the NRC.
(Section F1.8)
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The power cables for DHV 3 and DHV 4 were to be rerouted prior te the unit
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entering Mode 3 to prevent fire induced hot shorts from disabling both valves.
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Following completion of this modification, the power cables for valves DHV-3 and DHV 4 will meet the requirements of 10 CFR 50 Appendix R. Section Ill.G.
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(Section F1.9)
The licensee's resolutions of the remote shutdown Janel instrumentation issues l
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were acceptable.
The scope and accuracy of the RS) instrumentation met the requirements of 10 CFR 50 Appendix R Sections Ill.G and Ill.L.
(Section F1.10)
Com)letion of the modification work associated with rewiring the circuits for 26 MOVs would place the facility into compliance with the industry's intent of IN 92-18. This work was scheduled to be completed prior to restart and was being tracked, (Section F1.11)
l Completion of the installations of the additional emergency lighting units should bring the plant into compliance with the requirements of 10 CFR 50
Appendix R Section Ill.J.
(Section F1.12)
i Based on the inspection of a sample of the circuits which were rerouted as part of the Thermo Lag resolution project. the modifications to reroute the
cable raceway circuits were satisfactory to ensure the separation of system redundant components and circuits as required by 10 CFR 50 Appendix R Section III.G.
(Section F1.13)
The installation of the *MECATISS" electrical raceway fire barrier was of high quality and continuous for cable tray raceway 120 to ensure the protection of system redundant components and-circuits within Fire Area CC-108 102.
The installation of the ~MECATISS' fire barriers met the requirements of 10 CFR 50 Appendix R Section Ill.G.
(Section F1.15)
The modifications to reroute the control circuits associot.ed with chilled watercooling4Bweresatisfactorytoensuretheseparationofsystemredundant to the emergency feedwater initiation and control (EFIC) room chiller AHF s components and circuits as required by 10 CFR 50 Appendix R Section Ill.G.
(Section F1.16)
The resolution to control the heat-buildup and use of alternative coolin0 in the Control Building complex in the event of possible closure of the fire dampers in building ventilation system was satisfactory and should provide sufficient cooling for the safety related components in this building to meet the requirements of 10 CFR 50 Appendix R Section Ill.G.
(Section F1.17)
The design documents for CR3 provided sufficient information on the installation of seals for electrical penetrations of fire barriers which. if properly _ installed, should prevent the spread of smoke and hot gases in the event of fire in one fire area from passing through the penetration into adjacent fire areas that are separated by appropriate. fire rated barriers.
Revisions were being made to existing maintenance procedures to assure that
.the design requirements are followed on future maintenance and modification
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work activities involving electrical penetrations through fire barrier walls.
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ceilings and floors.
(Section F1.lB)
Appropriate action had been implemented to resolve the fire protection issues identified during the August 1997 NRC inspection.
The resolution of these issues was either complete or in progress and scheduled for completion within
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a satisfactory time frame.
For those issues not completed, the licensee
tracking program was considered acceptable to assure that the corrective l
actions would be completed.
(Section F1.19)
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The modifications to control circuits for emergency diesel generator room air handling fans due to power upgrading and Appendix R requirements had been
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completed.
(Section :1.20)
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The licensee was performing an appropriate evaluation to correct the previously identified weakness involving an inadequate maintenance inspection and cleaning program for the fire protection water tcnks.
(Section F1.21)
The corrective action to resolve the Appendix R cable interaction problems associated with the circuits controlling 'B' Train emergency feedwater flow to the steam generators was satisfactory and resulted in these circuits being
rerouted to meet the separation requirements of 10 CFR 50 Appendix R Section
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G.Ill.
(Section F8.1)
The licensee's evaluation and corrective action on the transfer switch fuse 3roblem related to ES MCC 3AB was correct and resulted in the installation
)eing modified to meet the requirements of 10 CFR 50 Appendix R Section Ill.G.
(Section F8.2)
Appropriate action had been implemented to provide an alternative method of restoring power to the HPI valves in the event the normal power supply were to be lost as the result of an Appendix R type fire in the control room or cable spreading room.
This modification was listed on the licensee tracking system and will be completed prior to the unit entering Mode 4.
(Section F8.3)
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For each item inspected and closed, the inspectors assessed the licensee's performance in the five areas of continuing concern.
For all items inspected.
the ins)ectors found performance to be good in the four areas of Management Oversigit. Engineering Effectiveness. Knowledge of Design Pasis, and Compliance with Regulations.
Operator Performance was not evaluated during this inspection.
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Report Details i
Plant Suonort i
F1 Control of Fire Protection Activities F1.1 General Comments In 1991. the NRC found that Thermo Lag fire barrier material did not aerform to the manufacturer's specifications. The NRC issued NRC 3ulletin 92 01 " Failure of Thermo Lag 330 Fire Barrier System to Maintain Cabling in Wide Cable Trays and Small Conduits Free from Fire Damage" and requested licensees with Thermo Lag fire barriers to take the a)propriate compensatory measures for the areas where the Thermo Lag fire yarriers were installed.
Based on the unfavorable results of Thermo Lag fire barrier installations tests performed during 1993 and 1994 by the nuclear
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industry. the licensee initiated the Crystal River 3 (CR3) Thermo-Lag Resolution Program to review the use of Thermo-Lag at CR3 and to develop other means of meeting the requirements of 10 CFR 50 Appendix R.
Sections III.G. Fire Protection of Safe Shutdown Capability. This review included a reanalysis of the safe shutdown systems and performance goals, safe shutdown procedures and review of other available fire barrier materials for replacement of the Thermo Lag material.
The reanalysis also reevaluated the requirements for Appendix R Sections Ill.J. Emergency Lighting and 111.0, 011 Collection System for Reactor Coolant Pump.
This resulted in a number of revisions to the CR3 Appendix R Fire Study changes to the Appendix R post fire shutdown procedures. circuit reroutes, development of repair procedures and the use of an alternative fire barrier material ("Mecatiss") in order to meet the Appendix R requirements.
During the reanalysis some discre)ancies and inconsistencies were discovered in the CR3 Appendix R Jire Study. These problems were identified and documented by the licensee's Precursor Card (PC) program for the identification, tracking and corrective action.
Significant discrepancies were reported to the NRC in accordance with the requirements of 10 CFR 50.72 and 50.73.
In November 1996, an independent assessment of the Appendix R safe shutdown analysis was completed by an outside Appendix R engineering firm.
For each discrepancy item identified by the assessment, the licensee initiated an evaluation to determine the approprirte corrective action.
The licensee developed an action plan to resolve each issue.
Most of the issues were scheduled to be corrected prior to the restart of the unit from the current outage, Issues not essential for safe shutdown and documentation issues were scheduled to be corrected following the outage.
The NRC staff had previously reviewed and approved the licensee's implementation schedules.
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This NRC inspection concentrated on the items required to be completed prior to restart and provided an assessment and documentation for the items evaluated by the inspectors.
Conclusion Based on a detailed evaluation and review of the licensee's corrective actions to address the identified 10 CFR 50 Appendix R discrepancies, the inspectors concluded that an effective program was being implemented.
A sufficient number of personnel with a good knowledge of
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the Appendix R fire protection requirements had been assigned to resolve the identified discrepancies.
Good engineering documents had been developed. Work was either being implemented or had been completed on all of the required restart issues.
The inspectors concluded that the unit will be ready for restart when the recuired restart issues on the licensee's " Restart Mode Restraint Report" have been completed.
F1.2 (Closed) Restart Issue 0 11. Annendix R Review (Closed) LER 50 302/97-010 00. HVAC Was N3t Considered for Manual Oneration of Safe Shutdown Equipment in Post Fire Conditions Resultina in Non-Comnliance of 10 CFR 50 Annendix R a.
Insoection Stone The inspectors reviewed the licensee's correcti'.'s actions for the resolution of the discrepancies associated with.ne CR3 Appendix R safe shutdown analysis which were identified as not. macting the requirements of 10 CFR 50 Appendix R Sections Ill G and Ill.L.
b.
Observrtions and Findinos During the initial resolution of the Thermo Lag issue at CR3. several Appendix R related concerns were identified.
These issues were initially grouped into a sinale work package for resolution and were identified as Restart Issue D 11.
However, as the evaluation continued.
additional Appendix R discrepancies and concerns were identified.
To document the action taken on each of these issues adequately, the licensee separated the issues into different individual restart issue a
items. Four of the initial items were assigned new restart issue numbers. as follows:
0 11C. Current Transformer Secondary Protection:
0 110. Hot Short Effect on Remote Shutdown Panel Fuses: D 11E. NI (Source Range) Detector Thermo Lag Fire Barrier Removal: and D-11G.
Separation of Power Cables for DHV-3 and DHV-4.
Restart Issue D-11 was revised to include the revalidation of the post-fire shutdown analysis following an Appendix R type fire and the resolution of any identified concern identified during this evaluation.
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The licensee had completed the technical review of the post-fire safe shutdown analysis.
This review included: an evaluation of the criteria
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for the selection of the safe shutdown systems, components and electrical circuits: verification of the required separation of the
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redundant safe shutdown systems, components and circuits: verification
of appropriate fuse and breaker coordination: verification of
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appropriate calculations for high impedance faults: verification of the (
consistency between the Fire Study and OP 880. Fire Service System.
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t Revision 12. and AP 990. Shutdown from Outside of the Control Room,
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Revision 9: and verification of the adequacy of the emergency lighting for pust-fire safe shutdown action.
The licensee's evaluation identified a number of issues which ns; ' "
be resolved to meet the requirements of 10 CFR 50. Appendix R. bections lli.G and Ill.L.
During this inspection, the Fire Study was being revised to address these issues, and revisions were being made to Procedures OP 880. Fire Service System. and AP 990. Shutdown from Outside of the Control Room.
Revisions of these procedures were required to be completed prior to the unit start up (Mode 4).
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During the Appendix R reanalysis, the licensee discovered that heating, ventilation, and air conditioning (HVAC) consideration in support of post fire manual actuation of safe shutdown equipment had not been specifically evaluated and documented in the CR3 Fire Study. Revision 4.
Subsequent evaluations by the licensee determined that the circuits for
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control of the plant's HVAC systems were not protected from the effect
of fire.
This resulted in the possibility the HVAC systems would not be
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available to cool certain plant areas required for manual operation of safe-shutdown components.
This issue was identified as LER 50 302/
97 010 which was evaluated by the NRC and identified as NCV 97 11 08.
Inadequate 50.59 Evaluation for Revision 0 to Procedure AP 990.
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The licensee evaluated the HVAC available to all plant areas required to be accessible to operate manually equipment needed for post fire safe shutdown.
For plant areas subject to elevated temperature, alternative means of cooling were specified.
The inspectors reviewed the licensee's evaluation and noted that appropriate alternative ventilation measures had been specified or an eppropriate evaluation had been performed to justify personnel entry into high heat areas to perform the required manual operations.
For example, on the 119' elevation of the Intermediate Bmiding, the maximum calculated temperature for the area
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was calculated to be 157 degrees F at eight hours into an Appendix R
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transient fire. To reduce the heat in this area. Procedure OP-880 was being revised to open the doors penetrating the fire wall separating the Intermediate Building from the Turbine Building.
This would reduce the heat in the area to 138 degrees F.
An Appendix R fire in some plant areas would require an operator to enter this area of the plant to manually operate main steam atmospheric dump valves MSV 25 and MSV-26.
Personnel operations within this area at-an elevated temperature of 157 degrees F was evaluated using the EPRI Heat Stress Management Program HEXAN Version 1.3.
This analysis found that an operator could be exposed safely to this elevated temperature for up to 30 minutes without
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any special clothing or other considerations.
Procedure OP 880 was being revised to identify this potential situation and to address personnel safety measures to be following for entry into this area if the HVAC system is lost and elevated temperature existed in the area.
The revisions to Procedures AP 990 and OP 8BD and an interim CR3 Fire Study to address the Appendix R related discrepancies will be completed prior to the unit's restart.
Verification that these revisions were completed will be validated during a subsequent post-restart inspection.
This item is another example of Inspector Follow up Item 50 302/
97 11 10, Post Restart inspection to Validate Completion of Fire Protection Enhancement items.
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Conclusion The inspectors verified that the licensee had completed a reassessment of the CR3 Appendix R fire protection requirements and actions were being taken to develop the interim CR3 Appendix R Fire Study and to revise Procedures AP-990 and OP 880. An NRC review of the revisions to the Fire Study and to Procedures OP 880 and AP 990 will be performed during a subsequent NRC inspection.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve these issues, in the five areas of continuing NRC concern:
Management Oversight - Good
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Engineering Effectiveness - Good
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Knowledge of the Design Basis - Good
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Compliance with Regulations - Good
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Operator Performance - N/A
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F1.3 (Closed) Rrstart issue No D-II A. Dearaded Seal Between the Reactor Bu11dina Exterior Wall and The Auxillarv/ lntermediate Buildina Insnection Stone (92904)
The inspectors reviewed the modifications made to the seismic expansion joint fire barriers between the Reactor Building and the adjacent Auxiliary Building and Intermediate Building to determine if these modifications upgraded these barriers to the requirements of 10 CFR 50 Appendix R Section Ill.G.
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Observations and Findinas The originally installed seismic expansion joint material installed between the Reactor Building and the adjacent Auxiliary Building and Intermediate Building consisted of once tight fitting cork layers between the adjoining structures.
This material was credited as a "non rated' fire barrier.
Over the years the material had dried out and contracted so that the fit was loose in most areas and had been dislodged or fallen away from the original locations.
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The licensee performed waltdown inspections of the seismic expansion joints.
The degraded conditions were identified and documented in Precursor Card (PC) 97 0989.
Plant modification. MAR 97-06 07 01, was developed to replace and upgrade the scismic expansion joint fire barriers between the Reactor Building and the adjacent Auxiliary Building and Intermediate Building to a three hour fire rated design required for Appendix R separation of redundant circuits and components.
The replacement expansion joint fire barrier penetration seal design consisted of removal of the existing cork material to a depth of at least 12 inches and the installation of a permanent 1 inch thick damming
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board, a silicone foam penetration seal to approximately 10 inches
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thickness, and an additional 1 inch thick top layer of a protective silicone elastomer sealant.
The inspectors reviewed the work package for MAR 97 06-07 01 and verified that all of the modification work had been completed and inspected by 0A audits for con.pliance to the design and construction documents 3rior to the closure of the work package.
The inspectors also reviewed t1e fire barrier penetration seal installer training program records and verified that the installers were )roperly trainer' Vd certified to work on the expansion joint fire Jarrier penetra6 el seals.
The inspectors reviewed fire barrier penetration seal Surveillance Procedure SP 407. Tire Barrier Penetration Seals,' Revision 27 and verified that the licer,st.e had added Sections 3.6.2 and 3.6.3 to the inspection program for the additional reactor building exterior expansion joint fire barrier penetration seals.
The inspectors performed walkdowns of the expansion joint fire barrier
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penetration seals installed in the horizonal expansion joints between the Reactor Building and the 95* and 119' elevation of the Intermediate
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Building (Fire Areas IB 95 200 and 1B 119-201) and the vertical expansion joints between the Reactor Building and the 95* and 119'
elevation of the Auxiliary Building (Fire Areas AB-95 3 and AB 119-6).
The walkdown identified no deficiencies and verified that the installed fire barrier penetration seals were continuous with no gaps cracks, voids or holes in the barrier material.
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Conclusion The inspectors, concluded that the licensee's corrective action for the problems associated with the seismic expansion joint fire barriers i
between the Reactor Building and the Auxiliary and Intermediate
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Buildings was appropriate and of sufficient scope to resolve this issue.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue in the five areas of continuing NRC concern:
Management Oversight - Good
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Engineering Effectiveness Good
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Knowledge of the Design Basis Good
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Compliance with Regulations Good
Operator Performance N/A
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fl.4 (Closed) Restart issue D 11B. Reactor Coolant Pumn Oil Collection Syst em (Closed)
LER 302/97-09 00 and 01 Inadeouate Desion Resulted in Reactor coolant Pumn Lubricatina Oil Collection System Be1no Outside the 4eauirements of 10 CFR 60 Annendix R (Closed)
V10 302/96 15 02. Failure of Reactor Coolant Pymn Oil Collection System to Retain 011 Leak 1ria f rom Reactor Coolant Pumn Motor LClosed) URI 302/97 07-04 Unanalyzed Comtsstible Burden in Reactor Contalnment Bu11dina HVAC System a.
Insnection Stone (92904)
The inspectors reviewed the modifications made to the reactor coolant pump (RCP) lubrication system to determine if these modifications would result in the lubrication system for the RCP motors being in compliance with the requirements of 10 CFR 50 Appendix R Section 111.0, b.
Observations and Findinas The initially designed and installed oil collection systems on the RCP motors did not catch all potential leakage points from the lubrication system for the RCP motors and transfer the leaking oil to the lube oil collection system storage tanks.
The lubrication systems for the RCP motors had a history of leaking oil and the oil collection system provided for these pumas did not catch all of the leaking oil and transfer this oil to t7e associated collection tank.
The licensee performed walkdown inspections of all of the RCP motors and all potential leakage sites were identified.
Repairs were made to stop the leaks from the initially installed lubrication system.
Modification MAR 97 06 16 01 was developed to provide a method to catch and transfer all potential leakage to the oil collection tanks.
The original oil collection system was extended to catch additional potential leakage sites that were previously not covered by the original oil collection system. A~ll potential high pressure leakage sites were provided with enclosures or spray shields arranged to catch potential spraying oil leakage from all high pressure portions of the lubrication system.
Drip pans were provided to catch drip type leakage from all potential low pressure leakage points.
The spray enclosures and drip pans were provided with drain piping arranged to drain to the oil collection tanks.
The inspectors reviewed the work package for KAR 97-06-16-01 and verified that all of the modification work had been functionally tested to assure that the oil collection system did not leak, all new work had
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been completed and inspected for compliance to the design and construction documents prior to the closure of the work package, j
i The licensee repaired the sections of the oil collection system which had not been modified but which had previously leaked, and a new sealant was installed in the portions of the collection system which had been leaking.
The procedures for use by maintenance following repairs were reviewed and determined to oe adequate for future restoration activities.
The LER for this issue was related to VIO 50 302/96 15 02. Failure of Reactor Coolant Pump Oil Collection System to Retain Oil Leaking from Reactor Coolant Pump Motor.
The licensee inspected the HVAC system for the reactor building.
A minor amount of oil was found inside the HVAC ventilation ducts and on the duct outlet registers.
This oil was determined to have apparently leaked from the lubrication system for the RCP motors.
The licensee considered that the small quantity of oil within these ducts did not present a significant fire hazard.
All of the HVAC ducts and outlet registers were cleaned and the system was restored to service to meet the design requirements.
The system engineer for the reactor building HVAC system had been assigned the task of inspecting and verifying the operability of the HVAC system r ior to the restart from any future outages.
The inspector reviewed work request No. NU 0345910 and noted that a detail inspection had been performed on the HVAC and appropriate action had been taken to clear the oil residue from the HVAC system, c.
Conclusion The inspectors concluded that the licensee's corrective action.
including modifications and repairs to the RCP oil collection system, were sufficient to place the RCP oil collection system in compliance with the requirements of 10 CFR 50 Appendix R, Section 111.0.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve these issues, in the five areas of continuing NRC concern:
Management Oversight - Good
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Engineering Effectiveness - Good
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Knowledge of the Design Basis - Good
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Compiiance with Regulations - Good
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Operator Performance - N/A
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F1.5 (Closed) Restart issue D llc. Current Transformer Secondarv Protection a.
Insnection Scone (92903)
The inspectors reviewed the documentation and installation of the secondary protectors installed across the outputs of the current transformers in 4ky Unit and ES Bus cubicles for Trains A and B and in
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the current transformers (CT) in the-A and B emergency diesel generators i
to verify that the installations were in accordance with the licensee's
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commitments and met the 10 CFR 50 Appendix R requirements.
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Observations and Findinas
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The Crystal River CR-3 Fire Study. " Analysis-of Safe Shutdown Equipment and Operations." specified the essential safe shutdown equipment in eacn
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fire area. As part of that equipment, current transformers (CT)
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associated with safe shutdown circuits that could experience fire
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induced open circuits were identified.
In order to ensure the j
availability of electrical power for Appendir. R safe shutdown equipment.
the licensee installed secondary protectors across the outputs of the
current transformers 1.1 the 4kV Unit and ES Bus cubicles for Trains A anc C.
Protectors were also installed across the cts in the A and B t
diesel generator control panels.
The cts function includes sending current signals to watt hour metering, differential relaying, ground differential relaying. and over current relaying.
The NRC was informed of the final 10 CFR 50.59 determitation and evaluation for the addition of secondary protectors for w rrent transformers in Florida Power (FPC) letter 3F0897 18. datec August 19.
1997.
It also was a follow up to a meeting July 20 and 21. 1997, where FPC advised the NRC of the Appendix R CT protectors and coordinated fuses. An attachment to this letter contained a description of the proposed CT modification.
The inspectors verified that the modification was in accordance to the description in the attachment.
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The licensee completed the implementation of a modification package MAR 97 02-11 01. " Current Transformer Secondary Protector Installation." for l
the installation of the CT protectors.
The inspector conducted a walkdown inspection of the A and B diesel generator panels and Trains A
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and B switchgear rooms for the Unit and ES buses to examine the installations.
The CT secondary protectors were installea in separate panels from the cts in accordance with the MAR package requirements and
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t. $ctrical drawings.
The purpose of a CT secondary protector was to short out an open circuited CT that could be caused by fire induced burned wiring.
The output of a CT is wired to another electrical device such as a meter or
relay located in a different area that could be subject to a fire.
If a
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CT became open circuited, an extremely high voltage would be generated that would result in an unsafe condition.
Each protector was a disk shaped device several inches in diameter mounted on an insulated base
.and wired to a CT.
It would operate from high voltage generated when the.CT was open circuited. The high voltage would cause an internal thermistor in the protector ta heat and close a bimetallic switch that
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would short out the CT and return it to a safe condition.
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[onclusion The inspectors ccncluded that the CT secondary protectors were being installed in accordance with the licensee's commitments and requitements and met the NRC regulations of Appendix R.
This item was closed based on the work being completed prior to restart.
It was being tracked as restraint item RMR-97 0286 for Mode 4 on the licensee's " Restart Mode Restraint Report."
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight Good
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Engineering Effectiveness Good
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Knowledge of the Design Basis - Good
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Compliance with Regulations Good
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Operator Performance N/A
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F1.6 (Closed) Restart Issue D 110. Hot Shnrt Effect on Remote Shutdoan Panel 10.1osed) Licensee Event Reports (LER) 96-022-0) and 01. Desian Error
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itqardina Hot Shorts Results in ODeration Outside 10 CFR 50 Annendix R Jeslan Basis a.
In3pect ion Stone (92903)
The inspectors reviewed the design and modification package and conducted a walkdown inspection to verify the licensee had implemented appropriate corrective action to resolve the design error associated with the potential loss of remote shutdown capability due to hot shorts following an Appendix R type fire.
b.
Observation and Findinas Licensee Event Report (LER) 96 022 01. " Design Error Regarding Hot Shorts Results in Operation Outside 10 CFR 50 Appendix R Design Basis" identified several design basis deficiencies, During a self-initiated assessment of the Appendix R program, components controlled from the Remote Shutdown Panel were discovered to potentially lack the electrical independence from the main control room and the cable spreading room fire areas defined in the FSAR and design basis document.
It was determined that fire indue.ed hot shorts involving DC power control circuits could adversely impact the remote shutdown capability.
Fire-induced hot short in the main control room or cable spreading room involving DC circuit could result in failure of the control power source prior to transfer to the remote shutdown panel.
Consequentially, after transfer to the remote shutdown panel, the affected components would not be operable.
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Two modification packages were developed to correct these pro'. ems.
Modification package MAR 97-03 02 01. " Remote Shutdown holation fusing.* was developed and the design implemented to correct design deficiencies that would have allowed fire induced not shorts to adversely impact the remote shutdown panel.,
The W.+.' cation included the addition of numerous fuses 1 solation relay contacts. Pod isolation modules for safe shutdown DC control circuitry.
The list of components that had their circuitry modified (rewired for hot shorts) included the following: decay heat pump 18. EDGs 1A and IB circuit breaken in the 4160 VAC ES Buses 3A and JB. makeup pumps 18 and 1C and associated lube oil pumps, emergency service seawater pumps 2B and 3B, emergency closed cooling pumps IA and 18. various associated emergency feedeter MOVs.
,
and the service CCC water reactor building fan assemb h isolation valves.
The other modification package was MAR 97 06 14 01 which reroute.1 a
,
number o' cables to meet the required Appendix R sep6 ration requirements.
The inspectors reviewed a sample of cable mooificetions that rerouted the physical location of a section of circuits for the t
makeup system pump isolation valves. MUV-3. MUV 62, and MUV-69 outside of the cable spreading room (Fire Area CC-124 118A).
Through review of the as built drawings for MAR 97 06-14 01 and inspection walk downs, the inspectors observed that raceway circuits for MUC-373. 377, and 379 had been rerouted from their respective A 1 or B-1 remote shutdown relay cabinets through the *A* 4160 VAC switchgear room (Fire Area CC 108 108)
to the Auxiliary Building. The inspectors co,1 firmed that th; control circuit cables had been rerouted as intended by the modification package through verification of installation of its cables, outside of the cable s) reading room fire area in fire areas CC-108 107. CC-108 108 and A3119 6A.
The cables had not yet been terminated at the remote shutdown panel located in fire area CC-108-102: however, these cables were to be terminated prior to the unit's startup.
The inspectors reviewed the engineering design the modification package the field installation work packages and the completed " Return To Service" documents to verif A
walkdown inspection was also e.y that the work had been completed.
onducted to examine the quality of work and material condition of ie installation. All work and wiring examined was neat and were considered quite good.
The documer.ts examined were in accordance with the licensee's commitments and requirements and NRC regulations.
The inspectors verified the licensee implemented very extensive corrective cction to addressed the deficiencies discussed in LERs g6 022-00 and 01.
These LERs are closed.
Although this item is a noncompliance with regulatory requirements, for reasons-discussed in NRC-Inspection Report 50 302/97-21. the licensee meets the criteria for enforcement discretion per Section Vll.B.2 of the NRC Enforcement Policy as described in HUREG 1600.
Consequently, this item is closed and is' identified as another example of Non-Cited
.
Violation NCV 50 302/97-21-01. Examples of Noncomplianc?s in Design Control. 50 59 Evaluations. Procedure Adequacy. Reportability, and Corrective Actions That Are Subject to Enforcement Discretion.
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c,
[onclusion The inspectors concluded that the licensee had implemented extensive corrective action to correct the design errors regarding hot shorts with remote shutdown circuits.
These modifications were satisfactory to provide electrical inde)endence of the Remote Shutdown Panel functions from fire induced hot s1 orts in circuits located in the Main Control Room or Cable Spreading Room fire areas and ensure the separation of system redundant components and circuits as required by 10 CFR 50 Appendix R Section III.G. and 111.1..
This item was closed based on the work being completed prior to restart.
The work was being tracked on the licensee's * Restart Mode Restraint Report" as items RMR 97 0287 and 0415.
The inspectors assessed the licensee's performance. relative to the corrective action to resolve these issues, in the five areas of continuing NRC concern:
Management Oversight - Good
Eng1r.eering Effectiveness Good
.
Knowledge of the Design Basis Good
.
Compliance with Regulations Good
.
Operator Performance - N/A
.
F1.7 (Closed) Restart Issue D 11E. Nucl ur Instrumentation Detector Thermo.
Laa Removal ($ource Rance)
This issue was evaluated during the NRC inspection of emergency operating procedures and will be closed by NRC Inspection Report 50 302/97 12.
F1.8 (Closed) Restart Issue D 11F. IndeDendent Assessment of Annendix R (Closed). IF] 50 302/96-17 04 Adecuacy of 10 CFR 50 ADD!sdix R Fire Study and Doqvm_entaljpg a.
InsDection Scone (92904j The inspectors reviewed the licensee's corrective actions on the findings from an independent assessment of the CR3 post fire. safe shutdown analysis that was completed in November 1996.
The assessment identified issues requiring resolution in order to meet the requirements of 10 CFR 50 Appendix R.
b.
Qhgervations and Findinas in November 1996, an independent assessment of the CR3 Appendix R. safe shutdown analysis was completed by an outside Appendix R engineering firm.
The findings of this independent assessment were:
4 issues deviated from the requirements of Appendix R: 1 1ssue was inconsistent with previous commitments to the NRC: 11 issues were classified as
indeterminate compliance issues. due to unavailable analysis documentation, unanalyzed conditions, and differences of opinions on the interpretations of Appendix R requirements that could result in deviations frohl the requirements of Appendix R: and 14 issues were classified as not critical to regulatory compliance but could hinder the implementation and the long term maintenance of the Appendix R program.
The licensee's letter 3F0797 33 to the NRC dated July 3. 1997.
documented the licensee's commitment to resolve the finding from the independent assessment prior to the unit restart. except for documentation related issues.
The documentation related issues were scheduled to be completed after restart.
This schedule was approved by the NRC CR3 Restart Board.
The inspectors reviewed the status of each assessment finding and verified that the work had been completed or was scheduled to be completed prior to restart. except as follows:
Issue 3.3.4. Single Spurious Operation:
The single spurious
.
operation methodology used by the CR3 Appendix R Fire Study was consistent with industry practice.
However, the NRC staff interpretation of the requirement of NRC Information Notice 92 18 is that evaluation for simultaneous multi)le spurious operations is required.
The nuclear industry has taten exception to this NRC position and the NRC is reevaluating this issue.
The licensee has deferred further review on this issue perding NRC's resolution.
Resolution on the following items was scheduled to be completed 90
days after restart:
Issue 3 3 3 Sourious Operations.:. The original evaluation
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in the CR3 Fire Study did not provide enough documentation to conduct a proper assessment of associated circuits.
The Fire Study was being reevaluated and appropriate documentation was to be provided.
Issue 3.3 9. Borated Water Storaae Tank (BWST) level:
The
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original Fire Study did not list BWST level as a required component for safe or alternative shutdown.
However. BWST level instrumentation is provided on the Remote Shutdown Panel.
The Fire Study was being revised to identity the BWST level as a safe shutdown component for alternative shutdowns outside of the main control room.
Issue 3 4 5. A mendix R Deston Basis Dorumentation (DBD):
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The CR3 Appendix R DBD did not address the requirements of Information Notices 85 09. ~ Post fire Shutdown Capability.'
and 92-82.
Thermo Lag Combustibility Testing.~ The DBD will be revised to correct this issue.
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15_ sue 3 4.8. Surveillangf of Alternative Shutdown Eauipment:
lhe assessment identified certain alternative shutdown
instrumentation that was not addressed by a surveillance procedure. This instrumentation will be added to the CR3 Fire Plan Table 6.9, and in the appropriate surveillance procedure, Item 3 4.13. Diaanostic Instrumentation:
The diagnostic
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instrumentation required for alternative shutdown equipment was not identified in the original Fire Study. This instrumentation was provided on the RSP, but is isolated to meet Appendix R criteria and is available to the operators following an Appendix R control room or cable spreading room fire.
The Fire Study is to be revised to address this issue.
The following items will be completed by Mid 1998:
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Issue 3.4 2. AJoendix R Documentation:
The assessment
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recommended that all Appendix R documentation be consolidated and reviewed for consistency and data integrity. The complete consolidation of all A)pendix R related documents will be completed following 11e unit's restart.
Issue 3.4 3. Confiauration Control of Anoendix R
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Documentatlann The assessment recommended that the engineering procedures be revised to reference appropriate Appendix R electrical design criteria.
The applicable administration control procedures will be revised following the unit's restart.
The issues scheduled to be completed following restart will be evaluated during a subsequent NRC inspection.
Existing NRC Inspector Follow up Item IFI 50-302/97 11 10 Post Restart Fire Protection Inspection to Validate Completion of Fire Protection Enhancement items, will be expanded to include these additional items.
c.
Conclusion The licensee had either completed all of the required independent assessment restart issues or scheduled completion of the issues prior to the unit's restart, except for several items related to documentation issues which were scheduled to be completed after the unit's restart.
The open issues were being tracked by the licensee's program for commitment issues.
The NRC will further inspect inis item.
The inspectors assessed the licensee's performance. relative to the corrective action to resolve these issues, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
Compliance with Regulations Good
.
Operator Performance - N/A
.
fl.9 (Closed)
Rutart issue D 11G. Separation of Power Cables for DHV 3 And DHV-4 a.
Inspection Scone (92903)
The inspectors reviewed the licensee's corrective action to provide the required separation between the electrical power cables for )HV 3 and DHV 4 to meet the requirements of 10 CFR 50 Appendix R. Section Ill.G.
b.
Observations and Findinos The power cables for DHV 3 and DHV 4 were both susceptible to fire-induced three phase hot shorts in the intermediate building and in portions of the reactor building. The inspectors reviewed the modification package and conducted a walkdown inspection of the conduit to assess the corrective action being implemented.
Modification package MAR 97 02 18 01. *DHV 3 and DHV-4 Cable Reroute.'
was initiated by engineering to provide a design to reroute the cables.
In addition to rerouting the cables. E0 Grayboot connectors were installed where cable splices were needed.
The inspector verified new.
seismically qualified conduit was installed, and the cables were pulled.
The cables were scheduled to be terminated during the transition period from Mode 4 to Mode 3.
The valves are currently required to be operable for decay heat removal.
The inspectors verified that the modification package, documentation, and installation reviewed were in accordance with the licensee's procedures and NRC regulations and that the modification was being tracked for closure by the licensee.
C.
Conclusion The inspectors verified that the power cables for DHV 3 and DHV 4 were to be rerouted prior to the unit entering Mode 3 to prevent fire induced hot shorts from disabling both valves, following completion of this modification, the power cables for Valves DHV-3 and DHV 4 will meet the requirements of 10 CFR 50 Appendix R. Section Ill.G.
This item is closed based on the work being completed prior to restart.
This item is beino tracked on the licensee's " Restart Mode Restraint Report ~ as items RMR 97 0456 and 97-0457.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight Good
.
Engineering Effectiveness Good
.
Knowledge of the Design Basis - Good
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Compliance with Regulations - Good
.
Operator Performance N/A
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F1.10 (Closed) Restert issue D-11H. Remote shutdown Instrumentation issues a.
Jnn s tion Scone (92904)
The inspectors evaluated the Remote Shutdown Panel (RSP) instrumentation scope and accuracy for compliance with the requirements of 10 CFR 50 Appendix R Section Ill.G and Ill.L.
b.
ObservationsandFindinas This issue dealt with questions of instrumentation scope and accuracy for the RSP.
The inspectors reviewed the emergency operating procedure Technical Basis Document for B&W plants. This procedure seemed to specify that, when controlling the plant in natural circulation from the RSP, natural circulation must be verified by use of incore thermocouples at the RSP.
However, no readout of the incore thermocouples was provided at the Crystal River RSP.
The licensee consulted the reactor vendor. Framatome Technologies, and concluded that incore thermocouple readouts at the RSP are not a necessity. Other methods are available to verify natural circulation such as. observing the difference between Thot and Tcold, confirm heat removal.pling between Tcold and steam generator pressure to and observing the cou Another concern was the instrument accuracy of the two. redundant wide range RCS (RC 158, 159 PIl 0 3000 psi) 3ressure instruments on the RSP.
Although two -
row range instruments (RC 148,149 PIl 0 600 psi) are installed o'
- RSP. these instruments are not credited by analysis as surviving a,>ntrol room fire.
There was concern that the +/- 156 asi wide range loop inaccuracy would make it difficult to confirm that RCS pressure is less than 284 psi, the maximum allowable pressure for placing the Decay Heat system in service.
In response to the concern, a revised instrument error calculation was performed to reevaluate the accuracy of the wide range instruments.
The inaccuracies were determined to be +/- 77.4 psi.
The results of these calculations were incorporated in revised RCS cocidown limit curves to be used for either wide or narrow range RCS pressure instruments at the RSP.
The resulting curves were forwarded to the group responsible for incorporating these curves into the plant procedures.
This item was being tracked to completion under the licensee's restart action items OP 19A and 190.
C.
@nClusion'.
The licensee's actions to resol /e the RSP instrumentation issues were acceptable.
The scope and accuracy of the RSP instrumentation meet the requirements of 10 CFR SO Appendix R Sections III.G and Ill.L.
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The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effects.eness Good
.
Knowledge of the Design Basis Good
.
Compliance with Regulations Good
.
Operatcr Performance - N/A
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F1.11 (Closed) RestAtt 1ssue 0111. NRC Information Notice 9218: MOVs Which MaY Be Subject to a Hot Short Condition a.
Insoettion Stone (92903)
The inspectors review the licensee corrective actions concerning fire induced hot shorts in safe shutdown MOVs to meet the guidelines of NRC Information Notice 92 18.
b.
Ottservations and Findinos On February 29. 1992, the NRC issued Information Notice 92-18:
' Potential for loss of Remote Shutdown Capability During a Control Room Fire ~ The purpose of IN 92-18 was to alert addresses to conditions that could result in the loss of capability to maintain the reactor in a safe shutdown condition in the unlicely event of a control room fire.
One concern was that a fire in the control room could cause hot shorts, i.e., short circuit between control wiring and power sources, for certain motor operated valves (MOVs).
If a fire in the control room forced the operators to evacuate, the MOVs could be operated from the remote or alternate shutdown panel.
However, hot shorts combined with bypassing overload protection of the torque switch, could cause MOV damage before the operators shifted to the remote or alternate shutdown panel.
The licensee implemented corrective action for their various MOV control circuits subject to fire induced hot shorts.
These modifications were for circuits in MOVs that could spuriously energize the valve operator and bypass the MOV torque switch contact.
The licensee performed an Appendix R evaluation of the control circuitry for each safe shutdown MOV to identify specific fire areas where a fire could cause a hot short that bypassed the torque switch contact and spuriously energized the valve.
Those fire areas were then compared to areas requiring operation of a safe shutdown MOV.
The evaluation only credited a single hot short that bypassed the torque switch contact and spuriously operated the valve for modification.
(Also, refer to Restart Issue 0-11F. Item 3.3.3.)
Hot shorts that bypassed the torque switch contact but recuired a separate spurious action to energize the valve were not consicered for modification.
The licensee identified 26 safe shutdown MOVs that met the criteria of IN 9218 for spurious operation from a fire induced hot short.
Sixteen MOVs were required for hot shutdown or when the plant was at power.
Ten
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MOVs were required to maintain the plant in a cold shutdown condition.
The twenty six MOVs that were modified by rewiring were DHVs 4. 5. c.
34. 35, 39. 40. 41. 42, 43. 110. and Ill: EFVs 11. 14. 32, and 33: end MUVs 23, 24. 25. 27. 26, 55. 56. 58. 73, and 567.
The inspectors reviewed the engineering design End modification package MAR 97 06 13 01. " Appendix R MOV Rewire." The field installation work packages and the completed " Return to Service" documents were examined for most of the MOVs.
In addition a walkdown inspection of several MOVs and their control circuits was conducted.
All work and wiring examined was neat and considered good..11 documents examined were in accordance with the licensee's commitments and requirements and NRC regulations.
The modification work for all of these valves had not been completed: however, this work was scheduled to be completed and was on the licensee's tracking system for completion prior to the unit'*
restart, c.
Conclusion The inspectors concluded that completion of the modification work associated with rewiring the circuits for 26 MOVs would place the facility into com]liance with the intent of IN 92 18.
T11s item was closed based on t1e wo t completed and schedaled prior to restart.
The item was being tracked item RMR 97-0289 for Mode 2 on the licensee's
" Restart Mode Restraint Report."
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis Good
.
Complience with Regulations - Good
.
Operator Performance - N/A
.
Fl.12 LClosed) Restart issue D llJ. ( Hour Emeroency Lichtina a,
jnsnectionScone 192904)
The inspectors reviewed the licensee's enhancement program for installation of additional 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery powered emergency lighting units to meet the requirements of 10 CFR 50 Appendix R. Section Ill.J.
b.
Observations and Find,Lngi
.
The licensce's independent assessment of CR3's Appendix R safe shutdown analysis identified several areas within the plant in which 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency battery powered lighting units appeared to be required but were not installed.
The licensee's reevaluation of this issue found that emergency lighting was actually not required for these areas.
However, the licensee performed a review of the manual actions specified
by Abnormal Procedure AP 990. " Shutdown from Outside Control Room.' and found a number of areas within the plant in which adoitional emergency lighting units were required to meet the requirements of Appendix R.
Section III.J.
Modification MAR 97 09 04 01 was developed to install ten additional emergency battery powered lighting units.
These were installed where manual actions were recuired by AP 990. The iris)ectors reviewed the MAR work package and tourec the plant to review the )attery installation work in process.
The installation of the additional battery units was either completed c.r in process.
Subsequent to the inspectors' walkdown inspection, the licensee Identified another area within the control complex which required additional lighting.
A field change request had been made to provide this lighting.
The licensee had scheduled the performance of Surveillance Procedure SP 807, Mounted Emergency Battery-Powered Light Units." as late as possible during the unit's restart phase.
This surveillanc! will verify the operability of each emergency lighting unit and that the battery lamp lights are properly oriented to illuminate the required access / egress routes or component to be operated.
c.
Conclusion Completion of the installations of the additional emergency lighting units should bring the plant into compliance with the requirements of 10 CFR 50 Appendix R Section Ill.J.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
Compliance with Regulations Good
.
Operator Performance N/A
.
F1.13 (Closed) Restart item D llX. Thermo Lao fircuit Reroutes a.
Insoection Scone (92904)
This issue involved the rerouting of certain electrical cable raceway circuits to eliminate the protection requirements for the safe shutdown cables that were located in the raceways previously 3rotected with Thermo-Lag fire barriers.
The inspectors reviewed tie niodifications made to reroute electrical cable raceway circuits to determine if these actions would ensure the separation of the system redundant components and circuits as required by 10 CFR 50 Appendix R Section Ill.G.
i
b. Observations and findinos i
The inspectors reviewed the licensee's corrective action modification.
MAR 97 05-17-01.
The inspectors reviewed a sample of cable mod fications that re-routed the physical location of a section of the circuits to avoid those fire areas for which the circuit needed to maintain its integrity (required to be protected with a fire barrier wrap) to support safe plant shutdown operation.
The inspectors reviewed the cable control circuits reroute of Circuit Number MUM 56 (for the Makeup System Pump MUP 1A outside of Fire Area CC 103 105) and Circuit Number MTM268 (for the emergency diesel generator EDG 1A Breaker 3029 outsideoffireareasCC-108103andCC108105).
Through review of the 6s built drawings for MAR 97-05 17 01 and inspection walk downs, the inspectors observed that raceway circuits MUM 56 and MTM268 had been rerouted from their respective A-1 remote shutdown relay cabinets through the "A" 4160 VAC switchgear room (Fire Area CC-108-108), the "A'
480 VAC switchgear room (Fire Area CC-124 117) to the cable spreading room (Fire Area CC-124-118A).
The inspectors confirmed that the centrol circuit cables had been rerouted as intended by the modification package through verification of installation of its cables, outside of Fire Areas CC-108-103 and CC-108 105.
From the set of cables that were being installed as part of the Thermo-Lag reduction effort, two cables were selected at random for verification of installation: MTM-268 and MUM 56.
The cables were installed under MAR 97 05 17-01. The inspector verified by field walkdown that these cables were in fact pulled in to the correct equipment and were the correct ty)e of cable.
Cable MTM 268 was verified correctly terminated at )oth ends by the inspectors.
Cable MUM 56 was not terminated at the time of the inspection.
However, this fact did not represent a problem as the termination sheet had not ueen signed off, and the cable was scheduled for termination as part of the normal modification proces:
The purpose of these inspections was to verify through sampling methods that the design basis was translated to the as built installation, and this was verified by the inspector.
C.
C.gnclusion Based on the inspection of a sample of the circuits which were rerouted as part of the Thermo-Lag resolution project, the inspectors concluded that the modifications to reroute the cable raceway circuits were satisfactory to ensure the separation of system redundant components and circuits as required by 10 CFR 50 Appendix R Section III.G.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
.
Compliance with Regulations Good
.
Operator Performance - N/A
.
cl.14 (Daen) Restart Item D-11K. Analysis Chances Removino Reliance on Thermo-Lao Fire Barriers Part of the effort by the licensee to resolve degraded Thermo-Lag fire barrier issues at Crystal River 3 includes a complete reanalysis of the Appendix R fire protection program to minimize reliance upon electrical raceway fire barriers.
The reanalysis had not been completed at the time of the inspection.
An interim analysis was to be completed prior the units restart to support and provide the technical basis for Procedures AP-990. Shu down from Outside the Control Room, and OP-880.
Fire Service System.
lne CR3 Fire Study, which is the Appendix R analysis for the plant. will not be completed until Mid-1998.
This analysis will be evaluated for adequacy by the NRC during a subsequent NRC inspection.
This issue is being tracked as a part of IFI 50-302/
97-11-10. Post Restart Fire Protection Inspection to Valid'te Completion of Fire Protection Enhancement items.
F1.15 (Closed) Restart item D-11K. Mecatiss Fire Barrier Installation a.
insnection Scone (92904)
The inspectors reviewed the installation of "MECATISS" electrical raceway fire barriers to determine whether the installations were adequate to ensure the separation of system redundant components and circuits and met the requirements of 10 CFR 50 Appendix R Section III.G.
b, Observations and Findinos In 1991, the NRC founu that Thermo-Lag fire barrier material did not perform to the manufacturers specifications.
Specifically, the installed Thermo-Lag barriers would actually provide approximately one half of the specified rating i.e., a 1-hour fira rated barrier would provide approximately 20 to 30 minutes of protection.
The NRC issued NRC Bulletin 92-01 and requested licensees with Thermo-Lag fire barriers
,'
to take the appropriate compensatory measures for the areas where the Thermo-Lag materials were installed.
FPC respon%d to this bulletin by letters dated July 29, 1992 and October 2. 1995.
Subsequently. FPC sent a number of letters to the NRC to address this issue.
Initially, approximately 2.400 linear feet of electrical raceways at CR3 were covered by the Thermo-Lag fire barrier material.
FPC performed a reanalysis which eliminated the need for Thermo-Lag fire barriers by either rerwting cables, installing a different type fire barrier material ("MECATISS"), or requesting an exemption from NRC for certain plant areas.
The inspectors observed completed "MECATISS" installations for cable tray raceway 120 located in control complex fire area CC-108-102.
The inspectors noted that the installation of the
"MECATISS" electrical raceway fire barrier was of high quality and
continuous for about 12 feet for cable tray raceway 120 that passed through fire area CC-108-102.
c.
Conclusion The inspectors concluded that the inst 611ation of the "MECATISS" electrical raceway tire carrier was of high quality and continuous for cable tray raceway 120 to ensure the protection of system redundant components and circuits within fire area CC-108-102.
The installation of the 'MECATISS' fire barriers met the requirements of 10 CFR 50
,
Appendix R Section Ill.G.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effcctiveness - Good
.
Knowledge of the Design Basis - Good a
Compliance with Regulations - Good
.
Operator Performance - N/A
.
F1.16 (Closed) Restart Item D-11L. Protection of Conduit CHF-38 in Fire Area CC-124-111 (Closed) LER 50-302/97-026-00: Failure to Perform a Field Validation Remited in a Deviation to 10 CFR 50 Annendix R Reauirements a.
Insoection Scope (92904)
The inspectors reviewed the corrective actions for protection of electrical conduit CHF-38 to determine if these actions would ensure the separation of redundant components and circuits met the requirements of 10 CFR 50 Appendix R Section III.G.
b. Observations and Findinos This LER involved an inadequate validation to assure that Conduit CHF-38 was protected against a fire in the control rod drive equipment room (Fire Area CC-124-111).
Without the protection, the potential existed for the loss of the chilled water cooling to the emergency feedwater initiation and control (EFIC) room Chiller AHF-548.
The chiller was used to supply cooling to the EFIC rooms for safe shutdown operations of the emergency feedwater system in the event of a fire in fire area CC-124-111.
The inspectors reviewed the licensee's corrective action modification.
HAR 97-06-14-01, that rerouted the conduit raceway CHF 38 circuits for the EFIC room chiller AHF-54B outside of Fire Area CC-124-111.
Through review of the as-built drawings for MAR 97-06-14-01 and inspection walk dcwns, the inspectors observed that conduit raceway CHF 38 circuits had
.
been rerouted from the local control station AH-40 in the EFIC Room "B" (Fire Area CC-124-115) through Fire Areas CC-108-105 and CC 108107 to the remote shutdown panel room (Fire Area CC-108-102).
The inspectors confirmed that conduit CHF-38 was installed at local control station AH-40 in the EFIC Room "B."
The inspectors also confirmed that the control circuit cables associated with chilled water cooling to chiller AHF-548 for the EFIC room had been rerouted as intended by the modification Jackage through verification of installation of its cables outside of rire Area CC 124-ll1. in Fire Areas CC-108-105 and CC-108-107.
The cables had not yet been terminated at the remote shutdown panel located in Fire Area CC-108-102: however, the cables were to be terminated prior to Mode 4 Although this item is a noncompliance with regulatory requirements for reasons discussed in NRC inspection Report 50-302/97-21. the licensee meets the criteria for enforcement discretion per Section VII.B.2 of the NRC Enforcement Policy as described in NUREG-1600.
Consequently, this item is closed and is identified as another example of Non-Cited Violation NCV 50 302/97-21-01. Examples of Noncompliances in Design Control. 50.59 Evaluations. Procedure Adequacy. Reportability, and Corrective Actions That Are Subject to Enforcement Discretion.
C.
f_gnchs, ion The inspectors concluded that the modifications to reroute the control circuits associated with chilled water cooling to the EFIC room chiller AHF-54B were satisfactory to ensure the separation of system redundant components and circuits as required by 10 CFR 50 Appendix R Section III.G.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
Compliance with Regulations - Gcad
.
Operator Performance - N/A
.
F1.17 (Closed)
Restart issue D-llM. Potential Loss of HVAC for Control Comolex Rooms (Closed)
tFR 50-302/97-33-00. Loss of Control Complex Ventilation System Due o Electro Thermo Link and Fusible Link Fire Damoer Automatic Closure a.
Insoection Scoce (92904)
The inspectors evaluated the licensee's corrective action to resolve a concern involving the loss of ventilation to rooms containing safe shutdown equipment in the Control Building complex.
A fire within the
_ _ _ _. _ _ _ __. _.
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_ _
.
N 23-
- Control Building could cause closure of the ~ ventilation system fire
>
dampers and shutdown of the ventilation fan and result'in an increase of-temperature within the Control-Building complex. One train of components for plant safe-shutdown is required.to be maintained free from fire damage by 10 CFR 50 Appendix R.Section Ill.G.
- b.
-Observations and Findinos
>
-
'In August 1997. the licensee discovered that the CR3 Fire Study had not-evaluated the effects'that automatic closure of the fire dampers-in the Control Building complex would have on the safe shutdown equipment installed in the building. :Two types of fire dampers are installed in this' ventilation system.
Some of the dampers are closed by electro-thermo links (ETL) actuated by.high temperature switches located in the Control Building complex.
Other dampers are closed by fusible link devices located on each fire damper.
The licensee's evaluation found
.
that the components within the Control Building could withstand a maximum temperature of 104 degrees F but that this temperature would be exceeded in most areas of the Control Building if some of these dampers closed due to a fire.
Since this condition was outside the design basis, the licensee reported this condition to the NRC by LER 97-33 and implemented compensatory measures including placing these areas under the fire watch patrol.
Although this item is a noncompliance with regulatory requirements, for reasons discussed-in NRC Inspection Report 50-302/97-21. the licensee
,
meets the criteria for enforcement discretion per Section VII.B.2 of the
'
~
NRC Enforcement Policy as described in NUREG-1600.
Consequently, this
,
item is closed and is identified as another example of Non-Cited Violation NCV 50-302/97-21-01. Examples of Noncompliances in Design Control. 50.59 Evaluations. Procedure Adequacy. Reportability, and Corrective Actions That Are Subject to Enforcement Discretion.
The licensee developed time versus temperature heat up curves to determine the need for operator actions to restore ventilation for the Control Building. The Fire Study and Procedure OP-880, " Fire Service System." were being revised to address the required operators' actions and implementation time to im)lement compensatory measures and alternative ventilation for t7e building. These documents were to be revised prior to the unit entering Mode 4.
Modification MAR 97-07-05-02
'
-.-was issued to disconnect the control circuit for-two ETLs located in the control rvom.
The revisions to Procedure OP-880 were to require the dedicated-JAppendix R" Control Building chiller unit to be operated for a number of rooms in the Control Building. Additional ventilation was to-be provided for other rooms by opening doors-in.the area.
.
The inspectors reviewed the-heat-up calculation and proposed revisions Lto Procedure l0P-880 and concluded that these changes were appropriate.
.
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The inspectors perform a walkdown inspection of the * Appendix R Chiller." The licensee informed the inspectors that the components for this chiller unit were receiving routine preventive maintenance but the components were not included in a surveillance test program.
The chiller normally provides cooling for a switchgear room in the Turbine Building and must be manually realigned and manually started to perform the Appendix R cooling functions.
The licensee stated that the surveillance requirements for this equipment would be determined and added to Table 6.9 of the CR3 Fire Plan.
This item will be reviewed during a subsequent NRC inspection and is another example of IFl 50-302/97-11-10. Post Restart Fire Protection Inspection to Validate Completion of Fire Protection Enhancement items, c.
Conclusion The hcensee's resolution to control the heat buildup in the Control Building complex in the event of possible closure of the fire dampers in building ventilation system was satisfactory and should provide sufficient cooling for the safety related components in this building to meet the requirements of 10 CFR 50 Appendix R Section Ill.G.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineeri j Effectiveness - Good
.
Knowledge af the Design Basis - Good
.
Compliance with Regulations - Good
.
Operator Performance - N/A
.
F1.18 (Closed) Restart issue D-llN. Internal Conduit Seals a.
Insoection Scone (92904)
The inspectors reviewed the licensee's resolution for sealing electrical raceway penetrations through fire barriers for compliance with the NRC requirements of NUREG 0800. Section 9.5-1. Item C.5.a(3) and Generic Letter 86 10. Section 8.8.
b.
Observations and Findinas In September 1997, several examples of apparent inadequate fire barriec seals were found for electrical raceways penetrating the fire barrier enclosure for the cable spreading room in the Control Building. The licensee identified this item as a potential problem and initiated action to evaluate the issue and develop appropriate corrective action.
During the evaluation of this issue, the licensee found that one of the identified inadequate penetrations was degraded due to modification work activities. This penetration was covered by a breach permit and the appropriate compensatory measures, including a roving fire watch. The
other items which were identified as apparent discrepancies were found to meet the requirements of the design documents.
in general. NRC licensing guidance, issued in July 1981 by NUREG 0800.
Section 9.5-1. item C,5.a(3), stipulated that openings through fire barriers should be sealed or closed to provide a rating at least equivalent as the fire barrier.
This specification was apparently not applicable to plants licensed prior to July 1981.
CR3 was licensed in 1977.
However. based on the guidance of GL 86-10. Section 8.8. the licensee should assess the openings through fire barriers and develop appropriate measures to assure that flame, smoke and hot gases would not pass through the barrier.
TFe licensee's evaluation of the design requirements for sealing of electrical penetrations through fire barriers at CR3 found that sufficient information was provided on Design Drawing No. E-107-013 to limit the propagation of smoke and hot gas through electrical raceways which penetrate fire barrier walls and floors.
The drawing required conduit 4-inch or smaller in diameter to be sealed with noncombustible materials such as ceramic fiber or RTV foam to prevent the spread of smoke and hot gases from one side of the penetration to the other side.
Conduits greater than 4-inches in diameter are to be plugged with ceramic fiber or RTV foam within 1-foot of the fire barrier. The material was to be installed within an electrical conduit fitting installed within 1-foot of the barrier.
Procedure MP-805. ' Sealing of Penetration." Revision 9, was to be revised to specify clearly the type and thickness of sealing materials to be used.
These documents were to be used during the future surveillance, inspections and maintenance of penetration seals to assure that the seals will be properly maintained.
This met the guidance of GL 86-10, c.
Conclusion The design documents for CR3 provided sufficient information on the installation of seals for electrical penetrations of fire barriers which, if 3roperly installed. Should prevent the spread of smoke and hot geses in t7e event of fire in one fire area from passing through the penetration into adjacent fire areas that are separated by appropriate fire rated barriers.
Revisions were being made to existing maintenance procedures to assure that the design requirements are followed on future maintenance and modification work activities involving electrical penetrations through fire barrier wails, ceilings and floors.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
'
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
Compliance with Regulations - Good
.
Operator Performance - N/A
.
26 F1.19 (Closed)
Restart issue D-110. Correction of Fire Protection Q11creoancies Prior to Restart (Closed)
IFT 302/97-11-09. Correction of Fire Protection Discrecancies Prior to Restart.
a.
Insnection Scope (92904)
The inspectors reviewed the corrective action taken on previous identified fire protection d'..,crepancies for compliance with the CR3 licensing requirements and the guidelines of NRC document Appendix A to Branch Technical Position BTP 9.5-1. Fire Protection Program, b.
Observations and Findinos During an August 1997 NRC inspection. 22 fire protection issues were identified which involved problems and enhancements needed to comply with the NRC fire protection guidelines of NRC document Appendix A to Branch Technical Position BTP 9.5-1. Fire Protection Program and to meet the requirements of 10 CFR 50 Appendix R.
These items were identified and grouped into a single inspector follow-up item for review during a subsequent NRC inspection.
These items included inadequate compensatory actions for long term degraded fire protection features, inaccurate fire brigade fire fighting strategies, inadequate fire protection surveillance test procedures, fire protection system design discrepancies, errors in fire protection documents, and correction of items identified by the licensee's OA audits.
The licensee issued a discrepency report (precursor card) on each of these issues and corrective action was identified for each item. The evaluations for these corrective actions had been completed and the actions required to resolve each issue had been identified.
The inspector reviewed the licensee's evaluations on these issues and noted that the evaluations were thorough, adequately addressed the issues, and identified the appropriate corrective actions.
The licensee's identified corrective actions had been completed. were in process, or a scheduled completion date had been established for each issue.
The licensee's evaluations determined that several of the fire protection system design issues were loss prevention or insurance requirements but were not required to be implemented at CR3 by the NRC during the licensing review. The lack of fire rated separation between the fire pumps and station transformers were examples of the loss prevention items which were not required at CR3 by the NRC.
The inspectors reviewed the NRC safety evaluation reports issued for the fire protection features and concurred with the licensee's assessment.
Automatic sprinkler protection had been proposed for the unsprinklered operations office on the 95' elevation of the Auxiliary Building.
This installation will be accomplished during the upgrades to the Auxiliary Building autom. tic sprinkler systems which were scheduled to be performed after restart.
This area had been included in the hourly fire
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watch patrol for.the-Auxiliary' Building.
This fire' watch' will be-
maintained until this sprinkler protection has been installed. The
'
inspectors concluded that this was satisfactory..
'
- The issue related to tne lack of available documentation to verify that
- the installed fire barrier penetration seals were installed in
,
accordance with design specifications bounded by configurations'that had-
. satisfactorily' passed a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire resistance test remained open.
The
'
fire barrier penetration seals at CR3 were installed by a number of-different vendors over several years.
Documentation was not available
>
.
to indicate clearly that the design. specification used during the-
.
construction or installation of each penetration seal. The licensee had developed a project to perform a field walkdown of all of the
'
penetration seals to determine the design specification used.for the
,
installation and if the installed seals were bounded by. tested'
.
configurations.
Penetration seals found not bounded by a tested
. configuration will be upgraded or an engineering evaluation will be
!
. performed to justify that the *as built installation is acceptable.
'
- This project was in the initial stages of implementation and was scheduled to be completed in late 1998.
Pending completion of this aroject, this item is identified as IFI 50 302/97-18-01. Evaluation of fire Barrier Penetration' Seal Enhancement Program, and will be reviewed during a subsequent NRC inspection.
a c.
Conclusion t
The licensee had implemented appropriate action to resolve the fire
protection -issues identified during the August 1997 NRC inspection.
The resolution of these issues was either complete. in progress. -or-
scheduled for completion within a satisfactory time frame.
For those
-
,
issues not completed, the licensee tracking program was considered i
acceptable to. assure that the corrective actions would be completed.
The inspectors assessed the licensee's performance,- relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
_
..
Management Oversight - Good
-
Engineering Effectiveness - Good
.
Knowledge of.the Design Basis - Good i-
..
Compliance with Regulations - Good
.
,
Operator. Performance - N/A-
.
F1.20lClosed) Restart Issue D-295. AHF-B. C. D Emeroency Diesel Generator Power UDorade and ADoendix R Reauirements-a, insoection Stone (92903)
,
.
LThe inspectors reviewed the design and construction modification F
associated with the power upgrade to the emergency diesel generators
. ventilation fansifor compliance with the separation requirements of 10
-
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CFR 50' Appendix R.Section III.G.
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Observations and Findinos For each emergency diesel generator, the ventilation system incorporates two fans.
As a result of the emergency diesel generator power upgrade modification, both fans became required equipment, whereas prior to the upgrade only one fan was required.
This new requirement on the fans meant that the control circuits for Fans AHF-228 (train A) and AHF-22D (train B) would have to be retrofitted with an isolation switch and a fuse to allow isolation of control room devices per Appendix R requirements.
in addition, the routing of certain control cables would have to be modified to achieve the physical separation required by Appendix R Section Ill.G.
Drawing B-208-005-AH-78. Revision 17. as-built for MAR 97-05-19-01 on November 6, 1997, showed the control circuit for AHF-220 with the new isolation switch contacts and fuse. Through review of this drawing the inspectors observed that the isolation switch contacts were in the correct position to obtain the desired isolation of control room devices and allow control of the fan after operation of the isolation switch.
The inspectors verified that the isolation switch contacts had been wired into the circuit by verifying that cables AHC 1040 and AHC-1041 were installed and terminated at the correct terminals in remote shutdown relay cabinet B.
The inspectors verified that the new fuse for AHF-220 control circuit was installed and had correct wire numbers connected.
The inspector also verified that conduit AHC-1040 was installed at motor control center 381. The inspectors verified that cables AHC-988 and AHC-559, associated with fan AHF-22D had been reroute as intended by the modification package through verification of installation of conduit AHC-1043 and its cables in the battery charger room.
C.
Conclusions The inspectors concluded that the need for modifications to control circuits for emergency diesel generator room air handling fans due to power upgrading and Appendix R requirements had been satisfied.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good.
.
Compliance with Regulations - Good
.
Operator Performance - N/A
.
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F1.21 (Closed)- Restart Issue D-37 Failure to Ensure Fire Water Storace Tank Contained Adeauate Volume of Water
'
This item was evaluated and closed in NRC inspection report No. 50-302/97-16.
a.
Insnection Scone (92904)
The inspectors reviewed the inspection cleaning and repairs in process on the fire protection water storage tanks (FST Nos. lA and B).
b.
Observations and Findinos Tank FST-1A was opened after condensate storage tank CDT-1A was found to need repairs for wall thinning. The licensee investigated and found that tank FST-1A had not been inspected since original plant
-
construction.
The licensee *s inspection revealed that approximately one inch of crud had built up on the inside of the tank.
The licensee evaluated the situation and developed a plan to resolve concerns with the tank condition and potential impact on the fire protection system water pumps.
The licensee's evaluation concluded that this issue had not resulted in operability concern for the fire protection water system.
The licensee's plan was to bring in a contractor company experienced with water tank inspections and repairs.
The tanks will be cleaned and inspected.
Neoded repairs will be completed and the tank interior will be sandblasted and recoated.
Following com]letion of the work and restoration to operable status of FST-1A. tie second tank. FST-1B will be removed from service and inspected, cleaned, repaired, and recoated.
The licensee performed a search of commitments and found no commitment to NFPA 22. Standard for Water Tanks for Private Protection, which is the industry standard for water storage tanks for fire protection a
systems.
This standard normally requires a periodic inspection, every two years, of the storage tanks.
The licensee wcs evaluating this issue to determine the appropriate maintenance and inspection to perform an the fire protection water storage tanks.
The licensee action on this issue will be evaluated during a subsequent NRC inspection.
This is; e is another example of IFl 50-302/97-11-10 c.
Conclusion The inspectors concluded that the licensee was performing an appropriate evaluation to correct the previously identified weakness involving an inadequate maintenance. inspection and cleaning program for the fire protection water tanks.
30 F1.22 (Closed) Restart Issue 0-52 Seismic Ruoaedness of Fire Service Water i
'
tire in Emaraency Diesel Generator Room This issue was evaluated and closed in NRC Inspection Report 50-302/
97-17.
F1.23 (Ocen) Restart Issue OP-19A. Revise and Validate Procedure AP-990.
' Shutdown Outside Control Room" Procedure AP-990 will be revised prior to the unit's restart to incorporate plant changes made to correct the identified Appendix R discrepancies and incorporate the revisions to the CR3 Appendix R reanalysis. This issue will be reviewed by the NRC during a subsequent inspection.
FB Miscellaneous Fire Protection Issues F8.1 (Closed) Licensee Event Report-(LER) 50-302/96-01-02. EFIC Control Circuits Misrouted a.
Insnection Scone (92904)
The inspectors reviewed the licensee's corrective action of rerouting the circuits controlling ~B' Train emergency feeawater flow to the steam generators which were installed in the same fire area as the "A" Train circuits were installed.
These cables were rerouted to meet the separation requirements of 10 CFR 50 Appendix R Section III.G.
b.
Observations and Findinos On January 10. 1997, the licensee identified that electrical raceway conduits EFS56 and EFS57, which contained circuits for controlling ~B" Train emergency feedwater flow to the steam generators, were installed in the same fire area ('A" Train 480V engineered safeguards switchgear room) as redundant "A" Train safe shutdown circuits.
The conduits EFS56 and EFS57 were not enclosed within a fire barrier nor provided with 20 foot separation from the redundant train to meet the seaaration requirements of Appendix R Section III.G. To correct t,is discrepancy, the licensee developed MAR 96-01-15 which removed conduit EFS56 from inside the "A" Train 480V switchgear room and installed this conduit in-Fire Area CC-124 111.
This conduit was also enclosed within a 1-hour fire barrier wrap.
The conduit was installed in an area provided with automatic sprinkler protection.
The circuits previously installed in conduit EFS57 were rerouted in conduit EFE121 which was located in a 'B" Train area and properly separated from "A" Train components.
This issue was previously reviewed and identified as NCV 50-302/96-01-03. Failure to Maintain 10 CFR 50. Appendix R Separation Criteria for the Emergency Feedwater_ System.
c.
Conclusion The licensee corrective action to resolve the Appendix R cable interaction problems associated with the circuits controlling *B" Train emergency feedwater flow to the steam generators was satisfactory and resulted in these circuits being rerouted to meet the separation requirements of 10 CFR 50 Appendix R Section G.III.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
Compliance with Regulations - Good
.
Operator Performance - N/A
.
F8.2 LClosed) LER 50-302/97-29-00. Failure to Perform a Field Validation Resulted in a Deviation From Appendix R Recu1rements a.
Insoection Scone (92903)
The inspectors evaluated the LER 50-302/97-29 and reviewed the licensee's corrective actions to prevent the loss of engineering safeguards motor control cabinet MCC 3AB in the event of an Appendix R fire.
b.
Observations and Findinos Motor control center ES-MCC-3AB powers safety-related equipment, some of which is required to operate as part of the shutdown strategy for fires in certain Appendix R fire zones.
This motor control center may be powered from either Train A or Train B 480 V switchgear.
Transfer switch MTXS-1 provides the means of transfec.
MTXS-1 is contactor type equipment that may be controlled from push button switches in the main control room or switches mounted on the transfer switch cabinet. The transfer switch is not wired for automatic transfers.
It performs manual transfers only.
The contactors and relays for MTXS-1 operate at line-to-line voltage which is 480 V.
The only control wiring that leaves the transfer switch is a pair of 2-conductors running between the switch and relay racks.
Cable MTL-105 runs from the transfer switch located in switchgear room A (fire zone cc-124-117) to relay rack RR3B in the control rod drive and relay room (fire zone cc-124-111), and is routed through the cable spreading room (fire zone cc-134-118A) abne the switchgear room.
Cable MTL-106 runs from the transfer switch to 21ay rack RR3A (fire zone cc-124-111), and is routed through switchgear room B (cc-124-116) and the spreading room.
..
.
.
,
,-
.The problem with the original installation as described in the LER was that the wires in cables MTL-105 and MTL-106 were not fused at their source in the transfer switch.
This meant that fire induced faults in these cables (specifically wires connected to phase C) could cause the-source breaker to trip and thereby prevent 0)eration of equipment needed for shutdown from'that fire. After this proalem was identified, the licensee realized that an unrelated modification was installing fuses on Cables MTL-105 and MTL-106 for personnel safety and good practice reasons.
This was modification 97-07-01-01, and it corrected the above problem.
The LER states:
"Ap)endix R design drawings and Fire Study will be revised to reflect tie modified field condition by March 31. 1998."
This statement was included to cover the possibility that MTL-105 and MTL-106 would be wrapped or rerouted.
Since installation of fuses corrected the problem, revision of these documents was not needed.
The inspectors reviewed drawing B-208-040-Mi-125. Revision 11.
Elementary Diagram Transfer Switch and those portions of modification 97-07-01-01 which modified the control circuit to install fuses and agreed with the licensee's analysis and corrective action.
The inspectors reviewed the role that the transfer switch ) lays in the safe shutdown analysis for fires in the fire zones where Ca)les MTL-105 and MTL-106 are routed. The inspector also reviewed Procedure OP-880. Fire Service System. Rev 12. Enclosure 1. as it relates to this LER. The inspectors postulated various fire induced faults on the cables of interest and evaluated the effects on the shutdown strategy.
The inspectors agreed that, after installation of the fuses, the transfer switch control circuit meets the Appendix R requirements.
The inspectors verified that fuses MTXS-1-FU-03. 04, 06 and 07, 5 A. 600 V, fast acting Bussman KTR-5 fuses were mounted in the transfer switch.
Although this item is a noncompliance with regulatory requirements for reasons discussed in NRC Inspection Report 50-302/97-21. the licensee meets the criteria for enforcement discretion per Section VII.B.2 of the NRC Enforcement Policy as described in NUREG-1600.
Consequently this item is closed and is identified as another example of Non-Cited Violation NCV 50 302/97-21-01. Examples of Noncompliances in Design Control. 50,59 Evaluations. Procedure Adequacy. Reportability, and
'
Corrective Actions That Are Subject to Enforcement Discretion.
c.
Conclusions The inspectors agreed that the licensee's evaluation of the problem stated in the LER related to ES MCC 3AB was correct, and the ins)ectors verified the corrective actions.
These corrective actions met t1e requirements of 10 CFR 50 Appendix R Section III.G.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
'
.
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
Compliance with Regulations - Good
.
Operator Performance - N/A
.
F8.3 (Closed) LER 50-302/97-035-00. A Desian Error Resulted in the Inability to Provide Reactor Coolant System Inventory Mateuo Durina a Postulated Anoendix R Event a.
Insoection Scope (92903)
The inspectors reviewed the corrective action implemented by the licensee to meet the requirements of 10 CFR 50 Appendix R Section Ill.G to protect the power supplies that power the makeup and purification system high pressure injection valves and normal makeup valves from the effect of a postulated Appendix R type fire in the main control room or cable spreading room, b.
Observations and Findinas On October 16, 1997, during the ongoing 10 CFR 50 Appendix R Fire Study Review. the licensee discovered that electrical power for Makeup Valves MUVs 23, 24. 25. and 26 was not protected from the effects of a Jostulated fire in the control room or cable spreading room.
Abnormal procedure AP-990. " Shutdown From Outside Control Room" specified the use of the makeup valves to establish HPI flow.
During this inspection, correction of this design deficiency was in process and was scheduled to be completed prior to restart.
Plant modification MAR 97-10-13-01. " Appendix R Power Source Bypass Switch for HPI Valves" was almost completed.
This modification involved adding two bypass disconnect switches.
One disconnect switch was installed at motor control center MUMC 1 for Valves MUVs 23 and 24.
The second disconnect switch was added at motor control center MUMC 2 for Valves MUVs 25 and 26.
The purpose of the disconnect switches was to provide an alternate source of power if the transfer switches in the main control room became disabled during a fire.
Abnormal Procedure AP-990 was being revised to reflect the use of the new switches.
The new disconnect switches will be normally locked in the open position.
Although this item was a noncompliance with regulatory requirements. for reasons discussed in NRC Inspection Report 50-302/97-21. the licensee meets the criteria for enforcement discretion per Section VII.B.2 of the NRC Enforcement Policy as described in NUREG-1600.
Consequently, this item is closed and is identified as another example of Non-Cited Violation NCV 50-302/97-21-01. Examples of Noncompliances in Design Control. 50.59 Evaluations. Procedure Adequacy. Reportability, and Corrective Actions That Are Subject to Enforcement Discretion.
c.
Conclusion The licensee had implemented appropriate action to provide an alternative means of restoring power to the HPI valves in the event the normal power supply is lost due to an Ap)endix R type fire in the control room or cable spreading room.
Tais modification is listed on the licensee tracking system and will be completed prior to the unit entering Mode 4.
The inspectors assessed the licensee's performance, relative to the corrective action to resolve this issue, in the five areas of continuing NRC concern:
Management Oversight - Good
.
Engineering Effectiveness - Good
.
Knowledge of the Design Basis - Good
.
Compliance with Regulations - Good
.
Operator Performance - N/A
.
F8.4 (Dnen)
IFl 50-302/97-11-10. Post Restart Fire Protection Insnection to Validate Comnletion of Fire Protection Enhancement items.
During a previous NRC inspection in August 1997, a number of issues were identified which the licensee planned to correct after the unit is restarted from the current outage.
These items were identified as an Inspector Follow up Item to review during a subsequent NRC inspection.
During the inspection completed in December 1997, additional items were identified which were not to be corrected until after the unit is restarted but which were considered of sufficient importance to required an NRC review during a subsequent inspection.
A tabulation of the items identified during these two inspections which are scheduled to be reviewed by the NRC during a subsequent inspection is as follows:
a.
Improvements and enhancements to the fire protection surveillance test procedures (IR 97-11. Section F2.2).
b.
Revision to CR3 Fire Hazards Analysis to address "as built" plant configuration (IR 97-11. Section F3.1).
c.
Reevaluation of the scope of fire brigade physical examinations (IR 97-11. Section F3.1).
d.
Revision of CR3 Fire Protection Plan to incorporate recent changes and modifications to the plant (IR 97-11. Section F6.1).
e.
Evaluation of cable spreading room Halon extinguishing system (IR 97-11. Section F8.2).
f.
Surveillance test program for 8-hour emergency lighting (IR 97-11.
Section F8.2).
-
_-
_
g.
Revision of CR3 Fire Study: AP 990. " Shutdown from Outside Control Room": and OP 880. * Fire Service System" (IR 97-18. Section F.'
?
and F1.8).
h.
Revision of engineering documents to incorporate Appendix R modification (F1.8)
I, Conficaration control program for Appendix R related documents (IR 97-18. Section F1.8).
.
J.
Surveillance test requirements for Appendix R chillers (IR 97-18.
Section F1.17)
k.
Automatic sprinkler protection for NLO work space on 95* elevation of Auxiliary Building (IR 97-18. Section F1.19).
1.
Maintenance, inspection and cleaning program for fire protection water tanks FST-1 and FST 2.
(IR 97-18. Section F1.21)
Manaaement Meetino and Other Areas X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on December 5.
1997 and by telephone conference call on December 17, 1997.
An interim exit meeting was held on November 21, 1997. to discuss preliminary
.
inspection findings, The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any material examined during the inspection should be considered proprietary.
No proprietary information was identified.
PARTIAL LIST OF PERSONS CONTACTED Licensee J. Baumstark. Director. Quality Programs R. Grazio. Director. Nuclear Regulatory Affairs B. Hickle. Director. Restart R. Layton. Appendix R Fire Protection Project Manager J. Maseda. Manager Engineering Programs W. Pike. Manager, Nuclear Regulatory Assurance W. Rossfeld, Manager Site Nuclear Services M. Schiavoni.. Assistant Plant Director. Maintenance Other licensee employees contacted included technicians, operators, engineers, mechanics, security force members, and office personnel.
_
NRC Personnel S. Cahill. Senior Resident inspector
- T Cooper. Resident inspector
,S. Sanchez_ Resident-Inspector INSPECTION PROCEDURES USED IP 92903:
Follow-up - Engineering IP 92904:
Follow up - Plant Support
-
ITEMS OPENED. CLOSED. AND DISCUSSED
"
Opened
.IFl 50 302/97-18-01 Evaluation of Fire Barrier Penetration Seal Enhancement Program.
fSection F1.19)
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Closed
'V10 50 302/96-15-02 Failure of Reactor Coolant Pump 011 Collection System to Retain Oil Leaking from Reactor Coolant. Pump Motor.
(Section F1.4)
IFI.50-302/96 17-04 Adequacy of 10 CFR 50 Appendix R Fire Study and Documentation.
(Section F1.8)
URI 50 302/97-07 04 Unanalyzed Combustible Burden in Reactor Containment Building HVAC System.
(Section i
F1.4)
-IFI 50-302/97-11-09 Correction of Fire Protection Discrepancies Prior to Restart.
(Section F1.19)
LER 50-302/96-01-02 EFIC Control Circuits Misrouted (Section F8.1)
LER 50-302/96-22-00 and 01 Design Error Regarding Hot Shorts Results in Operation Outside 10 CFR E0 Appendix R Design Basis.
(Section F1.6)
LER 50 302/97-09-00 and 01 Inadequate Design Resulted in Reactor Coolant Pump Lubricating 011 Collection System Being Outside.the Requirements of 10 CFR 50 Appendix R.
(Section F1.4)
LER 50-302/97-10-00 HVAC Was Not Considered for Manual Operation of Safe Shutdown Equipment in Post Fire Conditions
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Resulting in Non-Compliance of 10 CFR 50 Appendix R.
(Section F1.2)
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LER 50-302/97-26 00 Failure to Perform a Field Validation Resulted in a Deviation to 10 CFR 50 Appendix R Requirements.
(Section F1.16)
LER 50 302/97-29-00 Failure to Perform a Field Validation Resulted in a Deviation From Appendix R Requirements.
(Section F8.2)
LER 50-302/97-33-00 Loss of Control complex ventilation System Due to Electro Thermo link and Fusible Link Fire Damper Automatic Closure.
(Section F1.17)
LER 50-302/97-035-00 A Design Error Resulted in the Inability to Provide Reactor Coolant System Inventory Makeup During a Postulated Appendix R Event.
(Section F8.3)
Discussed IFI 50-302/97-11-10 Post Restart Fire Protection Inspection to Validate Completion of Fire Protection Enhancement Items.
(Section F8.4)
LIST OF ACRONYMS USED AHF Air Handling Fan BWST Borated Water Storage Tank CFR Code of Federal Regulations CR3 Crystal River Unit 3 CST Condensate Storage Tank CT Current Transformer DBD Design Basis Document DHV Decay Heat Valve EFIC Emergency Feedwater Initiation and Control EFV Emergency Feedwater Valve EDG-Emergency-Diesel Generator EPRI Electric Power Research Institute ES Engineered Safeguards ETL Electro Thermal Link E0 Environmental Qualified FPC F'orida Power Corporation FST Fire Storage Tank GL (NRC) Generic Letter HVAC Heating Ventilation and Air Conditioning i
HPI High Pressure Injection IFI
_ inspector Follow-up Item KV-Kilo-Volts LER Licensee Event Report MUV Make up Valve
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MSV Main Steam Valve i
MOV Motor Operated Valve
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NCV Non-Cited Violation j
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h
NI Nuclear Instrumentation
- NL0 Non Licensed Operator
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NRC Nuclear Regulatory Commission NUREG hRC Published Document PC Precursor Card-
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- PSI Pounds per Square Inch
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- RCP Reactor Coolant-Pump RCS Reactor Coolant System RSP Remote Shutdown Panel
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i URI Unresolved item V10 Violation
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e 6