IR 05000312/1987015
| ML20235M087 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/29/1987 |
| From: | Ramsey C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20235M061 | List: |
| References | |
| 50-312-87-15, NUDOCS 8707170050 | |
| Download: ML20235M087 (15) | |
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l U. S. NUCLEAR REGULATORY COMMISSION i
REGION V
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Report No. 50-312/87-15 Docket No. 50-312 l
License No. DPR-54 l
Licensee: Rancho Seco Nuclear Generating Station
' Sacramento Municipal Utility District 14440 Twin Cities Road.
Herald, California 95638-9799 Facility Name:
Rancho Seco Vait 1 Inspection at:
Herald, California (Rancho Seco Site)
Inspection Conducted:
April 28 through May 1 and May 12 through 15, 1987 Inspectors:
. 6MA 6,/2 9 h 7
,w m C. Ramsey, Re ional Ihspector Date Signed Approved by:
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A!JfifP;7 S. Richards, Chief Date Signed Engineering Section
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Summary:
Inspection During the Period April 28-May 1 and May 12-15, 1987 (Report No.
50-312/87-15)
Areas Inspected:
Routine, unannounced inspection by regional based inspector involving followup on previous NRC and licensee identified open items.
A limited assessment of specific areas of fire protection program implementation was made ard followup was performed on licensee identified fire protection program deficiencies contained in a licensee internal document entitled " Fire Protection System Review Package and plant tours of the facility".
During this inspection, Inspection Procedures 30703, 62704 and 92701 were used.
Results:
In the areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted Sacramento Municipal Utility District
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M. Roush, Operations Fire Protection D. Powell, Operations Fire Protection
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J. Robertson, Licensing
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T. Schewski, Quality Assurance F. Hauck, Regulatory Compliance
- D. E. Tipton, Operations Superintendent
- J. Lee, Nuclear Engineer - Fire Protection
- K. Jindal, Facilities Group Leader (Mechanical)
- C. Stevenson, Regulatory Compliance
- S. Redeker, Assistant Nuclear Operations Manager
- S. Farkas, Regulatory Compliance
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NRC i
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- C. J. Myers, Resident Inspector
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Licensee Actions on Previous Inspection Findings A.
(0 pen) Open Item (50-312/86-18-07) - Lack of Drainage Capability for
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l Fire Suppression Water Discharged in the Technical Support Center j
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l A review of the licensee's analysis of this condition was performed
by the inspector.
Based on this review, the inspector determined the analysis to be inconsistent with the licensee fire hazard analysis description of the fire suppression system and.the
licensee's FSAR response to NRC question no. 1, item 5, regarding
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this drainage capability.
To clarify this inconsistency, the licensee indicated that further analysis would be performed using the suppression system's designed discharge capacity, as described i
in the FSAR, for the basis of assumptions made.
This item remains j
open pending further NRC review.
B.
(0 pen) Special Report No. 83-01 - RCP Room Fire Detectors not Tested I
as Required by Technical Specification No. 3.14.1
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According to the licensee, this problem involves. inaccessibility to the RCP. room fire detectors.. As corrective action, the licensee.
i indicated that the applicable technical specification surveillance
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procedures were in the process of being revised to address the
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problem.
This item remains open pending further NRC review, C.
(0 pen) Special Report No. 87-04 - Significant Number of Breached Fire Barriers According to the licensee, the number of breached fire barriers appears to be declining significantly as construction activities are J
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being completed.
The inspectors' review of licensee internal correspondence indicated that the licensee has identified breached fire barriers as a " degrading trend'.' with a potentially serious safety significance.
To resolve this concern, the licensee stated i
that their goal is to have all breached fire barriers restored to an l
operable status prior to restart.
Progress toward this goal will be
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reflected in updated special reports to the NRC.
This item remains open pending further NRC review.
D.
(0 pen) LER No. 87-15 - Carbon Dioxide Protected Fire Zones Left Deactivated and Zones Left Unattended To address this problem, as a near term solution, the licensee provided the inspector with a station approved revision of Administrative Procedure No. AP 30, " Entrance Into Carbon Dioxide i
Fire Protected Areas," which was modified to ccntain additional strict language for administrative control over disabled CO,, fire suppression systems.
However, the licensee indicated that the long term solution to this problem will require additional administrative controls, such as further revision of Administrative Procedure No.
AP 30 and possibly plant hardware changes.
Fire protection alarm system design is further discussed in paragraph 3A of the report.
This item remains open pending NRC review of the licensee's long term corrective action.
E.
(0 pen) LER NO. 87-12 - Failure to Perform Surveillance Procedure No.
I S.P. 711 per Technical Specification J
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As reported by the licensee in the LER, although the fire protection i
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water system was technically inoperable from November 29, 1986 to January 4, 1987, in actuality the system was fully functional and capable of providing fire suppression water as designed during the entire period that the surveillance was not performed.
Furthermore, this occurred during the current plant outage so there was no effect l
on the plant or public safety as a result of this event.
l For corrective action, the licensee plans to prevent reoccurrence of this event by reviewing the. surveillance procedure, its scheduling and the technical specification requirements, to determine the appropriateness of revision.
This item will remain open pending further licensee action and Region V verification.
F.
(0 pen) LER No. 87-02 - Diesel Generator Circuitry has an Appendix R I
Deficiency I
i This deficiency relates to inadvertent tripping of Diesel Generator l
Breaker No. 54A08 due to hot shorts introduced as a result of a
control room fire.
In response to LER Nos. 85-16 and 86-10, the
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licensee's ongoing cable raceway tracking system reassessment effort is under review by the NRC.
Closure of this item will be tracked under the NRC's followup on this reassessment effort by the licensee.
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(0 pen) LER No. 87-10 - RCS High Point Vent Valves Susceptible to Opening due to Hot Shorts This deficiency relates to the potential for a small break loss of,
coolant accident due to spurious opening of the RCS high point vent valves due to fire induced hot shorts..The licensee plans to implement modifications to correct this deficiency'in accordance with Appendix R to 10 CFR 50 prior to restart from the current outage.
This item.will be tracked by the NRC in conjunction with the licensee's response to LER Nos. 85-16 and 86-10.
H.
(0 pen) LER No. 87-13 - Redundant Instrumentation Cables Routed Through the same Fire Area This discrepancy relates to misrouting of instrumentation cable nos.
1Y3X205A1, 1Y3X205B1, 1Y3X205C1,-1Y3X210A1 and 1Y3X235A1 such that fire damage could have prevented the fulfillment of the safety
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functions of the systems needed to achieve and maintain safe shutdown as required by Appendix R to 10 CFR 50.
Closure of this item will be tracked by the NRC in conjunction with the licensee's response to LER N0s. 85-16 and 86-10.
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(Closed) LER No. 86-31 - An Hourly Instead of a Continuous' Fire Watch was Performed This item is closed based on the licensee's establishment of specific terminology for the fire protection staff to use when communicating fire protection requirements and the licensee's issuance of Special Order No. 87-15 which requires that the shift supervisor make the proper determination for required fire watch patrols or other compensatory measures.
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(Closed) LER No. 86-32 - An Hourly Fire Watch was Missed This item is closed based on improvement noted in the licensee's delegation of responsibility through administrative procedures and l
special orders to verify proper implementation of required I
compensatory measures.
K.
(Closed) LER No. 87-03 - Continuous Fire Watch Duty not Performed while Welders were on Breaks during Jobs l
This item is closed based on the improvements noted in the l
licensee's delegation of responsibility through administrative procedures and.special orders to verify proper implementation of required compensatory measures.
L.
(Closed) LER No. 87-04 - Continuous Fire Watch Post Abandoned for 5 minutes This item is closed based on the licensee's revised administrative procedures.
Further, the licensee issued Special Order No. 87-15
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and revised the training program for operators and security I
personnel.
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(Closed) LER No. 87-19 - Continuous Fire Watch not Performed while Fire Detection was Removed for a Welders Job This item is being closed based on the discussion provided above (items 2.I.,
J., K. and L).
3.
Implementation of Fire Protection Program Requirements The licensee is required by Section 6.6.1(f) of Technical Specification 6.8 to have written procedures established to implement and maintain the facility's fire protection program.
The fire protection program is described in the NRC's Safety Evaluation Report for the facility dated December 24, 1978, and in licensee documents entitled, " Fire Hazard Analysis Report," dated August 1, 1977; " Updated Fire Hazard Analysis Report", dated May, 1985; " Fire Protection Program Manual", dated July 19, 1985; Sections 9.9 and Appendix F of the USAR.
Periodic quality assurance audits are required to be performed in accordance with Section 6.5.2.8 of Technical Specification 6.5 in order to assess the plants fire protection equipment and program implementation and to verify that a level of safety consistent with NRC guidelines and requirements continues to be provided.
In addition, any event or condition that could prevent the fulfillment of safety functions that are needed to safely shutdown the reactor are required to be reported to the NRC pursuant to Section 6.9.4.1 of Technical Specification 6.9.4.
The inspector concentrated inspection efforts on assessing the licensee's fire protection program implementation in the following areas:
Plant wide carbon dioxide fire suppression system design.
Organization and staffing provided for implementation of fire protection program requirements.
Effectiveness of Quality Assurance Audits.
18 licensee identified deficiencies in a licensee document entitled
"Systern Review Package" (SRP).
The results of the inspector's assessment are as follows:
A.
Carbon Dioxide (CO2) Fire Suppression System and Fire Detection Alarm System Designs By reply to NRC position no. IV C.5(a) through (f) of the USAR, the licensee is committed to design and install carbon dioxide fire suppression systems to conform to National Fire Protection Association (NFPA) standard no. 12 (1968 and 1980).
By response to NRC question no. 34, item 90, of the original fire hazard analysis, the licensee is also committed to design and install associated fire detection alarm systems to conform to NFPA standard no. 720.
Based on the inspector's review of the licensee purchase specification No. M1403, associated drawings, documentation of test results and walk down of as built system installations, the
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licensee's CO, fire suppression system installations conform to the minimum requirements of NFPA Standard No. 12.
NFPA 12 permits manual or automatic CO, system actuation.
Each of the licensee's CO system installations are provided with a manual isolation
(de-energization) switch on respective control panels located outside of the zone / area being protected from fire by CO systems.
Manual operation of this switch opens the automatic fire detectior, circuit signal to the C0 system actuation selector valve and
prevents automatic discharge of the C0 fire suppression agent.
Thisfeaturewasincludedinthesystedtdesigntoaccommodate additional concerns for personnel safety during occupancy of CO2 protected zone (s)/ area (s) by plant personnel.
Whenever a C0 fire suppression system's automatic actuation feature
is disabled by manual operation of the system isolation switch, the fire detection alarm system for the affected zone / area is. designed to remain unaffected.
Therefore control room operators should receive early,varning of a fire in the affected zone (s)/ area (s).
However, the licensee has apparently experienced other design discrepancies which affect the reliability of the fire detection alarm system.
For example:
Problem nos. 1 and 2 of the licensee's System Review Package (SRP) for fire protection systems identifies the following fire detection alarm system deficiencies which inhibit control room operator response to fire alarms:
(1) Apparently a trouble signal instead of an alarm signal can be annunciated in the
control room when the first detector (of two) goes into alarm in the.
J Auxiliary Building C0 protected areas.
(2) The_ fire alarm zones i
p as annunciated in the control room overlap in several areas and are I
not consistent with the fire hazard analysis area / zone designations for the facility.
(3) Spurious fire alarm signals are displayed in I
I the control room during AC power transients and a break occurs in some circuits which result in the failure of certain supervisory equipment.
(4) Combined fire alarm signals can be received from i
different devices (i.e., sprinkler water flow, smoke detector actuation or CO, system discharge can be received as one signal by control room opbrators).
l LER No. 87-15 reports that there have been a number of occurrences where personnel disabled CO, system automatic actuation functions by manual operation of the system isolation switch and failed to re-activate these systems.
To resolve the concerns reported in LER No. 87-15, the licensee proposed to revise administrative procedures controlling access to C07 protected areas.
However, this resolution
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does not appear to adequately address the fire detection alarm
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system hardware deficiencies.
In response to the inspector's concern over fire detection alarm system discrepancies, the licensee indicated that further discussion of these discrepancies would be held with appropriate levels of i
licensee management and a decision would be made on required hardware changes necessary prior to restart from the current outage.
This is considered an open item (50-312/87-15-01) pending further licensee action and NRC review.
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B.
Fire Pump Operability Pursuant to Technical Specifications and Governing Code Requirements By reply to section 9.9.3 and NRC question no. 17, item 57 of the FSAR, the licensee is committed to design, install and maintain the I
fire pump installation for the facility in accordance with the minimum requirements of NFPA standard no. 20 (1970).
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the licensee's FSAR response to NRC question no. 17, item 57, the largest sprinkler system flow demand on the facility's fire pumps is 2607 GPM over 10,000 ft2 at 87.6 PSI which can be met by either the electric or diesel fire pump.
Item No. 1.2.f. of the licensee's fire protection annual Quality
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Assurance Audit No. 0-790 dated July 30, 1986, identifies specific J
deficiencies in the licensee's acceptance criterion contair,ed in the surveillance procedures for fire pump operability.
For example:
(1) Completed Enclosures No. 6.1, " Data Sheet for Motor Driven Fire Pump P-440 monthly surveillance," of Test Procedure No. SP201.03B,
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indicate that on three occasions the discharge pressure of the motor I
driven fire pump exceeded the acceptance criterion of 126 1 10 psig l
by 14, 14 and 20 psig.
The pump speed also failed to nieet the acceptance criterion of.1750 rpm on eleven (11) occasions ranging from 1700 to 1725 rpm.
(2) Surveillance procedure no. SP201.03B did not contain pre.ssure, rpm or temperature acceptance criterion to confirm proper operation of the diesel fire pump.
l In addition, during plant tours of the facility, it was observed by l
the inspector and the licensee's staff that the controller for the l
electric fire pump is not U.L. Listed for this application as I
required by NFPA 20 and because the controller is obsolete, the licensee has been unable to obtain replacement parts in the event repairs are needed.
The air release valves associated with both j
fire pumps are undersized and pressure relief valve setting for both pumps is below the shutoff head of the pumps.
The air release valve
ensures proper venting of the pump casing.
These deficiencies.are also identified in the licensee's System Status Report.
The licensee's proposed corrective action for several of these deficiencies consist of revising Surveillance Procedure SP201.03B to incorporate acceptance criteria which will verify proper operation of both fire pumps and to install a U.L. listed electric fire pump controller (stored onsite) in the event that the existing controller becomes inoperable.
The inspector determined that the licensee proposed corrective actions would satisfactorily address the respective identified deficiencies.
However, it is unclear what corrective actions are proposed for the electric fire pumps unsatisfactory pe.rformance on 14 occasions; the problems of undersized air release valves;' and pressure relief valve settings of both pumps below the shut off heads of the pumps which reduces the flow capacity.
According to the licensee, these issues will be the subject of further discussions with appropriate levels of licensee management.
This is
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considered an open item (50-312/87-15-02) pending further licensee action and NRC review.
C.
Quality Assurance Audits Section 5.0 of the licensee's Fire Protection Program Manual describes the licensee's August 31, 1976 reply to NRC Branch Technical Position (BTP) 9.5-1 concerning quality assurance for fire protection at nuclear power plants.
The licensee elected to meet the NRC's fire protection quality assurance criteria by applying 10 CFR 50, Appendix B, to fire protection.
Included in this criteria are provisions for quality assurance audits to verify proper implementation of fire protection program requirements.
Technical Specification No. 6.5.2.8.1. and j. require that audits of.the fire protection program be conducted annually and triennially.
At the exit interview, the inspector informed the licensee that the scope and content of annual and triennial audit no.87-009 appeared inadequate in that the audit depth was less than that described by NRC Generic Letter 82-21.
Subsequent to the exit meeting, the inspector's Region V in-office review of this audit found the audit to be satisfactory and fully meeting the guidance of the generic letter.
Furthermore, the inspector's review of annual audit Nos.
0-871 and 0-790 also found those audits to be satisfactory.
No violations or deviations were identified.
D.
Organization and Staffing for Fire Protection Program Implementation Section 2.0 of the licensee's Fire Protection Program Manual requires that the licensee's organization with administrative and functional responsibilities for fire protection be identified and that the authority of individuals delegated responsibility for implementation of the program be described.
According to the licensee, the current fire protection organizational chart contained in the FSAR is incorrect.
Under a new organizational scheme, the licensee is in the process of revising Administrative Procedure AP-23 to include a total of 5 operations and 3 engineering positions with direct responsibility for fire protection program implementation.
This revised approach eliminates the facility's reliance on contractor personnel for fire protection program implementation and places full responsibility for implementation of the program on permanently staffed individuals.
However, all of the new permanent positions were not filled at the time of this inspection.
In response to the inspector's concern over the apparent breakdown in the program's implementation, as indicated by the number of deficiencies identified in the licensee's System Review Prograni (see paragraph 4), and by the scope of problems documented in recent LER's and special reports, the licensee acknowledged that this breakdown did occur and stated that as part of the resolution to this problem, permanent staffing needed to effectively implement the program and prevent future serious programmatic breakdowns would be
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provided.
Fire protection staffing is considered an open item (50-312/87-15-03) pending licensee action to permanently staff the fire protection positions and Region V followup.
4.
Licensee Identified Fire Protectiori Program Deficiencies In preparation for the NRC's August 12-16, 1985, Appendix R audit, the licensee began a programmatic re-assessment of its fire protection program implementation.
Part of this assessment and the assessment of the plant status for re-start is contained in the licensee's document entitled " Fire Protection Systems Review Package (SRP)".
The 68 findings or concerns pertaining to fire protection in the SRP were the result of voluntary observations expressed by the licensee's staff.
Of these, 19 appeared to the inspector to have potential safety significance as l
follows:
A.
Fire Detection Alarm System-Deficiencies As discussed in paragraph 3.A. above, problem nos. 1 and 2 of the fire protection SRP identifies deficiencies in the fire alarm system installation.
An hourly fire watch was established for these conditions on May 14, 1987.
Further, problem no. 6 of the fire protection SRP identifies the lack of updated as-built drawings for
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In addition, during plant tours of the facility, the licensee staff and the inspector identified the following apparent fire detection alarm system deficiencies:
(1) The fire alarm system does not meet NFPA standard no. 72D because no printer is provided in the control room for older portions of the system.
The licensee is committed to this standard.
1 (2) The Diesel Generator Building (fire zenes 105 and 106) fire
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alarm circuitry to the control room does not meet NFPA standard no. 72D because complete alarm actuation signal is not received inside the control room.
B.
Emergency Pre-Fire Plans and Required Operator Training Deficiencies Problem no. 3 of the fire protection SRP identifies that the licensee's emergency pre-fire plans, Annunciator Response Procedures and Emergency Plan are inconsistent on approaches to be taken for fighting plant fires and required operator actions to be taken in the event of a fire in zones / areas for which alternative control room safe shutdown capability is not provided.
Furthermore, it-appears that operators had not been trained on required operator actions specified in the fire hazard analysis for fire occurrences in specific areas of the plant.
The extent of these actions can be l
significant and therefore training in the use of pre-fire plans may l
be warranted.
For example:
for a fire occurrence in the west 480V l
switchgear room (fire zone 17), the following operator actions are
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required in order to mitigate adverse impact on safe shutdown functions due to fire induced spurious actuation of equipment.
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(1) The makeup tank isolation valve would have to be manually re positioned.
(2) The makeup tank flow control valve would have to be manually re positioned.
(3) The re-heater isolation valve would have to be manually closed.
(4) The atmospheric steam isolation valves would have to be manually closed.
(5) The turbine would have to be manually tripped at the turbine stand.
(6) The auxiliary feedwater turbine steam supply valve would have to be manually closed.
(7) The auxiliary feedwater system crosstie valves would have to be manually positioned.
The inspector reviewed portions of the licensee's revised AP 500 (causalty) procedure and pre-fire plans which address general precautions for various plant fires.
The AP 500 casualty procedures are symptom based and address loss of equipment and required operator actions.
Annunciator Response Procedure No. C-48 is an event oriented procedure which was being revised to address specific plant fires and required operator actions.
The licensee indicated that revision and implementation of the procedures was scheduled to be completed prior to re-start from the current outage.
However, the time frame for training of all operators on the revised procedures would be discussed with the appropriate levels of licensee management.
C.
Fire Detector Location Deficiencies Problem no. 9 of the fire protection SRP identifies inadequate spacing / location of fire detector units in the Auxiliary Building Switchgear Rooms and the NSEB Switchgear, Electrical, Mechanical and Computer Rooms.
For this condition in the Auxiliary Building Switchgear rooms, the licensee indicated that compensatory fire watch patrols were implemented on May 14, 1987.
In addition, during plant tours of the facility, the licensee's staff and the inspector obser * questionable fire detector unit locations in the west 480V
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switchgear room of the Auxiliary Building (fire zone 17), Diesel Generator Building (fire zones 105 and 106) and in the control room / computer rooms (fire zones 1 and 4A) in that the locations did not appear to comply with the licensee's commitment to NFPA 72E with regard to ventilation duct obstructions and ceiling pockets.
The licensee's staff was uncertain of long term corrective actions that would be taken for these conditions.
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D.
Auxiliary Building Ventilation System Interlocks into Fire l
Protection Alarm System
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Problem No.10 of the fire protection SRP identifies that Auxiliary Building ventilation and other power block ventilation exhaust fans
are shutdown by fire protection system interlocks.
The fans cannot be restarted for smoke removal in the event of fire because of the interlocks.
According to the licensee, this condition results in a technical specification violation when the Auxiliary Building loses negative pressure.
In addition, during plant tours, the licensee's staff and the inspector observed a condition in the auxiliary building grade and mezzanine level where HVAC dampers could fail
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open upon a loss of division II power and cause the loss of CO concentration.
Thelicenseeconsideredthistobeacasewherbonly
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one safe shutdown division could be lost.
Therefore no corrective action was necessary.
However as corrective action for the former problem, the licensee is in the' process of completing ECN No. 1142 and ECN No. 1078 to modify the associated ventilation fan circuits to permit operators to restart the fans and to separate the ventilation damper circuits by installing a 3 position switch.
The licensee also plans to develop I
administrative procedures and operator training for using this Auxiliary Building Ventilation System restart capability.
E.
Fire Protection Water Distribution System Deficiencies
Problem No. 15 of the fire protection SRP identifies the following deficiencies / concerns regarding the fire protection water distribution system:
(1) The setting of the fire pump pressure relief valves is too low.
This reduces the quantity of water available for fire suppression (also discussed in paragraph 3.B above).
(2) An additional sectional control valve should be installed in the west segment of the underground fire main to allow for proper isolation of portions of the main.
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(3) All fire hydrants installed on the underground fire main should be provided with a separate shut off valve in order to avoid multiple water supply system impairment as a result of a single i
impairment.
(4) A total flow meter and flow alarm is recommended to be installed in the connection between the fire system and plant water supply to enable determination of fire main leakage rates l
and detection of failure or actuation of the fire water system.
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The licensee indicated that assessment and resolution to the conditions were in progress.
However, specific resolution to each concern had not been reached by the conclusion of the inspection.
F.
Fire Pump Installation Deficiencies Problem nos. 16 and 17 of the fire protection SRP identifies some of the same fire pump deficiencies discussed in paragraph 3.B abov.-_
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The analysis performed by the licensee's staff to verify the fire pump installation conformance to NFPA standard no. 20 identified 17 deviations on the pumping system.
These included 8 items on the electric pump (P-440), 4 on the diesel driven pump (P-996) and 5 items common to both pumps which include inadequate supervision of the pump controllers in the control room.
The licensee's staff indicated that final resolution of corrective actions required for these deficiencies would be discussed with the appropriate levels of licensee management.
G.
Required Shutdown Actions If Fire Water System Is Lost Problem no. 18 of the fire protection SRP identifies the lack of instructions in procedures no. A.33 and C.117 to adhere to the
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requirements for shutdown actions of Technical Specification 3.14.2.3 if the fire water system is lost.
Apparently, both fire pump controllers are powered from the same 3E bus and could be lost due to a single failure, j
l The 3E bus supplies power to the electric fire pump controller and to the 1E bus s:hich supplies power to the diesel driven fire pump controller.
According to the licensee, no corrective action is required for this condition because upon a loss of the 3E-1E bus, the diesel fire pump will automatically start within 20 seconds due
to a fire water system pressure drop.
The inspector questioned this
position.
However, the licensee responded to the inspector's l
question by pointing out that Technical Specification No. 3.14.2.3.
t allows the licensee up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to establish a backup water supply before entering into shutdown actions if both fire pumps are lost.
Therefore, sufficient time is allowed to restore power to the bus, if needed.
H.
Automatic Sprinkler System Deficiencies Problem Nos.13, 23 and 24 of the fire protection SRP identifies
deficiencies in the facility's automatic sprinkler system l
installations as follows:
(1) During the December 26, 1985 event which led to the current extended outage, the Technical Support Center (TSC) pre-action sprinkler system actuated and discharged fire suppression water onto the floor of the TSC.
The flow of this water was not directed to a floor drain.
It was recommended that the licensee verify that all floor drains throughout the plant have
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protection system actuation or line rupture.
This_is further discussed in paragraph 2.A of the report.
(2) An analysis performed in 1985 to verify compliance of automatic sprinkler system installations to NFPA standard no.13 identified 13 major deviations in systems protecting the Auxiliary Building, Turbine Building, NSEB and Diesel Genarator Buildings.
This analysis also identified 15 major deviations
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from NFPA Standard No. 15 for deluge system installations protecting the Transformer Yard, NSEB and the Turbine Buildings.
J (3) During plant tours of the facility, the licensee's staff and the inspector observed Diesel Generator Building automatic
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sprinkler deficiencies that include improper location of
sprinkler heads with respect to ceiling height and obstruction of sprinkler distribution patterns by ceiling mounted i
ventilation ducts over 4 feet wide.
In the Auxiliary Building main corridor at grade level (fire zone 42) a sprinkler distribution pattern was obstructed by electrical raceway supports.
Sprinkler installation practices are described in NFPA 13, to which the licensee is committed.
Furthermore, where NFPA 13 permits 100 sprinkler heads' to be installed on a pipe schedule system using a 4 inch feed, the licensee installed 103 sprinkler heads on the auxiliary building sprinkler system.
Also, in the Auxiliary Building East Cable shaft (fire zone 81) the deluge sprinkler' system installation appears to not be in conformance with NFPA Standard No. 15 because the system is manually actuated instead of_ automatic.
Sprinkler heads are also obstructed and the system design calculations appear inaccurate due to the installation of incorrect fittings which may affect system flow.
New fittings appear required in order to achieve the system's designed water density.
The licensee was considering these observations at the conclusion of the inspection.
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Standpipe Fire Hose Stations Problem No. 25 of the licensee's fire protection SRP identifies 10 major deviations from NFPA standard no.14 for standpipe fire hose station installations.
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Fire Dampers Problem Nos. 40. 41, 42, 43, 44 and 48 of the fire protection SRP resulted in the licensee's issuance of ECN Nos. R10078 and R0458 requiring wiring changes to the NSEB Class II power supplied fire damper installation, which could fail in the open position during a fire and release CO from protected areas.
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NFPA, FSAR and Appendix R Inconsistencies Problem No. 50 of the fire protection SRP identifies that interviews with the licensee staff resulted in a conclusion that NFPA, FSAR and Appendix R inconsistencies mandate licensee _ action as follows:
(1) A budget was requested to be implemented to addressed identified NFPA code deficiencies.
(2)
It was recommended that delayed modification no. 132 for the installation of train "A" isolation switch replacement be completed in order to comply with Appendix R requirement ___
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(3).It was recommended that modification no. 143 for HPI circuit.
rerouting be completed in order to comply with NRC
requirements.
j (4) It was recommended that fire protection system interlocks on the transformer fans and pumps be installed as required by-j section 8.2.2.11 of the USAR.
i The licensee has issued ECN No. 1128, requiring that these actions be completed by the end of cycle 8 (next refueling outage).
L.
Auxiliary Feedwater Pump Fire Protection Problem No. 53 of the fire protection SRP identifies. the lack of Appendix R separation between auxiliary feedwater pumps P-318 and
P-319.
For this condition ~, the licensee requested an exemption from i
the NRC based on installed automatic fire detection and' fire-i suppression in the area.
The suppression system'is a deluge j
sprinkler system.
The licensee's staff was concerned with.the
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possible. inadvertent actuation of the' deluge. water spray fire
suppression system resulting in potential water damage to'both auxiliary feedwater pumps or associated electrical circuits.
The licensee provided the inspector with a copy of Special Test Procedure (STP) no. 949, " Acceptance Test Auxiliary Feedwater' Pump Area Fire Protection Deluge System Zone 110" dated June 6, 1986.
This test apparently verified that the system design adequately
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protects the area.
The question of inadvertent actuation and
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possible water damage to both auxiliary feedwater pumps was not clearly addressed by the test results.
However, prerequisite no.
3.7 of the test procedure indicates that Auxiliary Feedwater Pump area equipment, junction boxes, conduit fittings, instruments, etc.
were verified closed and sealed for the test.
M.
Overdue Fire Protection System Surveillance Problem No. 63 of-the fire protection SRP identifies fire protection system surveillance which are overdue.
In response to this concern the licensee indicated all fire.
protection system surveillance are being reviewed and revised where necessary.
Furthermore, a new administrative procedure will be implemented which will cross reference and ensure timely performance of all technical specification' surveillance procedures.
N.
Fire Protection of Structural Steel Problem No. 64 of the fire protection SRP identifies the lack of protection for structural steel and cable tray. supports as required by Appendix R for structures erected since the implementation of'
Appendix R.
.During plant tours, the licensee's staff and the inspector observed unprotected structural steel in the diesel generator' building.
z.
In response'to this concern the licensee indicated that corrective action for these conditions is in progress.
O.
Fire Pump Motor Internal Heater j
Problem.No. 68 of the fire protection SRP identifies'a' potential
deficiency with the motor driven fire pump' caused by de-energization I
of the pumps internal heater.to the starter when the breaker for the motor is opened and racked out.
This could'present a problem to the pump motor internals.upon re-energizing the motor after maintenance.
In response to this' concern, the licensee's internal memo dated October 31,.1986 documents a confirmation that the pump motor internal heater.(space heater) is on a separate power source from the pump motor.
Therefore. racking out-the breaker on the pump motor power. supply has no effect-on the pump motor' internal heater.
The inspector questioned whether several.of'the'above deficiencies that-y
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were not reported to the NRC'should have been reported.
For each of the above (Items A through 0) concerns, the licensee indicated that a re-assessment would be made to determine appropriate deportability (i.e.
Technical Specification, 10 CFR 50.72, 10 CFR 50.73, formal deviation or
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Compensatory measures have been or will be j
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established and appropriate corrective actions will be'made where-determined necessary in accordance-with a schedule agreed.upon.by appropriate levels of licensee management. -The inspector informed the licensee that upon further review, the NRC may be in disagreement with'
the licensee's approach to resolution of some:of the concerns..However, i
any differing NRC views will be the subject of additional meetings.with
the licensee.and separate correspondence.
The licensee's' action on the above deficiencies and their review of deportability are considered an.
open item (50-312/87-15-04) pending further. licensee action and NRC review.
'i 5.
Open Items i
Open items are matters which have been discussed with the licensee, which
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will be reviewed further by the. inspector, and which. involve some action
.l on the part of the NRC, the-licensee, or both.
Open items disclosed during the inspection are discussed in paragraphs.2.A,'2.B, 2.C,-2.D,
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2.E, 2.F, 2.G, 2.H, 3.A, 3.B, 3.D and 4.A.'
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6.
Exit Interview The ' inspector met with the licensee's representatives (noted in paragraph 1) at various times during the inspection and formally on May 15, 1987, to summarize the scope of the findings and inspection activities L.-
described in this report.
The licensee's representatives acknowledged the statements made by the inspector.
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