IR 05000312/1987039

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Insp Rept 50-312/87-39 on 871116-19.No Violations or Deviations Noted.Major Areas Inspected:Followup on Previously Identified Open Items & Fire Protection Program
ML20234F166
Person / Time
Site: Rancho Seco
Issue date: 12/24/1987
From: Ramsey C, Richards S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20234F133 List:
References
50-312-87-39, NUDOCS 8801110361
Download: ML20234F166 (17)


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I U. S. NUCLEAR. REGULATORY COMMISSION-

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REGION V

Report No. 50-312/87-39 Docket No. 50-312 License No. DPR-S4 1 '

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l- ' Licensee: Rancho Seco Nuclear Generating Station-Sacramento Municipal Utility District 14440 Twin Cities. Road Herald, California. 95638-9799 Facility Name: Rancho Seco Unit 1 Inspection at: Herald, California (Rancho Seco Site)

Inspection Conducted: November 16 through November 19, 1987 Inspector: _ &&s_ , ._ /2/t)/Ty C. Ramsey, egional Insp or Date Signed-Approved by: ,

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chards, Chfef ' ~ Date_Sf n d E ineering Section Summary: ..

Inspection During the Period November 16 and November 19, 1987 (Report N ~

50-312/87-39)

Areas Inspected: Routine, un' announced inspection by regional based inspector involving followup on previous NRC and licensee identified open items. 'A limited assessment of specific areas of fire protectioniprogram implementation was made. During this inspection, Inspection Procedures 30703, 62704 and 92701 were use Results: In the areas inspected, no violations or deviations were identifie l I

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DETAILS Persons Contacted SMUD G. C. Andognini, Chief Executive Officer, Nuclear

  • V. Cranston, Manager, Nuclear Engineering
  • B. Croley, Director, Technical Services
  • K. A. Meyer, Manager, Licensing
  • D. Tipton, Operations J. P. Flynn, Plant Performance
  • Coleman, Quality Assurance
  • Lippincott, Fire Protection Training
  • E. Turner, Training
  • T. Khan, Mechanical Engineer
  • Sarver, Licensing
  • Mueller, Licensing R. Burns, Licensing S. Crunk, Licensing E. M. Weaver, Mechanical Engineer
  • Stahl, Startup
  • K. Zimmerman, Fire Protection Coordinator
  • J. Zott, Fire Protection Coordinator
  • J. Kittler, Senior Fire Protection Engineer
  • J. Seaphur, Fire Protection
  • K. Jindal, Nuclear Engineering
  • D. Graham, Fire Protection
  • G. Bertsch, Fire Protection Training
  • J. A. Lee, Fire Protection
  • S. Tyler, Fire Protection
  • J. Kelly, Nuclear Engineering
  • D. J. Alemayehu, Nuclear Engineering Bechtel B. Evans, Fire Protection Systems Engineer l
  • Denotes those attending the exit meeting of November 19, 198 l Licensee Action on Previously Identified Oper. Items (Closed) Licensee Event Report (LER) No. 87-12 " Failure to Perform Fire Suppression System Surveillance" This item is closed based on the licensee's replacement of Surveillance Procedure No. SP.711 with procedure No. SP.100 which requires that the fire suppression water system be flushed in accordance with Technical Specification 4.18.2.1.d.

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B. (Closed) LER No. 87-15 "CO, System Deactivated" This item is administrative 1y closed based on the licensee's discussion of this issue in LER 87-2 C. (Closed) LERs 87-10-0 and 87-10-1 " Spurious Actuation of RCS High Point Vent Valves Due to Fire" and " Redundant Cables Routed in the Same Fire Area" This item is closed based on the licensee's corrective actions which included revision of the control scheme of the steam generator and the high point pressurizer venting solenoid valves to prevent the valves from being energized due to a fire induced hot shor ECN No. R-1615 was issued on May 15, 1987, requiring this work to be complete According to the ECN, the work has been complete D. (Closed) LER No. 87-02 " Diesel Generator Appendix R Circuits Protection" This item is closed based on the licensee's corrective actions which included installation of isolation switches to provide alternate shutdown capability in the event of a control room fir ECN N R-1128E was issued on December 16, 1986, to require installation of the isolation switches. According to the ECN, the work was completed on July 30, 198 E. (Closed) LER No. 87-13 " Redundant Cables Routed in the Same Fire Area" This item is administratively closed due to the discussion provided in Inspection Report No. 50-312/87-3 F. (Closed) Special Report No. 83-01 " Fire Detectors Not Tested" This item is closed based on the licensee's corrective actions which included revision of Surveillance Procedure No. SP.345 to require that radiation protection qualified personnel perform the surveillance during each cold shutdown exceeding 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> G. (Closed) Special Report No. 82-01-X0 " Missed Fire Watch" This item is closed based on the licensee's improved control over delegation of responsibility for required fire watch compensatory measures through Administrative Procedure No. AP-64 and Special Order No. 87-1 H. (Closed) Open Item 312/87-15-01 (50.55.E Report) "CO, System Alarm Deficiency" This item is administratively closed based on the licensee's discussion of this issue in LER 87-2 _ -_ _

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I. (Closed) Open Item 312/87-15-02 (50.55.E Report) " Fire Pump Deficiencies" This item is administratively closed based on the licensee's discussion of this issue in LER 87-29 and licensee's proposed corrective actions prior to restart (paragraph 2.0(2) of this report).

J. (Closed) 312/87-15-04 (50.55.E Report) Multiple Fire Protection Program Deficiencies" This item is administratively closed based on the licensee's j discussion of these issues in LER 87-29 and licensee's proposed )

corrective actions prior to restart (paragraph 3 of this report). i K. (Closed) 312/86-18-07 " Water Control in the TSC Upon Fire System Actuation" i

This item is closed based on the licensee's corrective actions which included installing auxiliary floor drains at low points in the TSC, installing permanent drain piping for TSC fire suppression system, and installing a seal trap in the drain line of the system to withstand the pressure differential from the control room in accordance with ECN Nos. R-0197 and R-109 The licensee's engineering calculation No. ERPT M-0072 documents the licensee's l analysis of flooding of the TSC using the fire suppression system's '

designed discharge capacity as the basis for assumptions mad ]

Based on this calculation, the licensee concluded that future flooding of the TSC by fire suppression water will not result in damage to safety-related equipmen L. (0 pen) Special Report No. 87-04 "Significant Number of Breached I Fire Barriers"

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During the inspection and at a meeting in the Region V office on November 23, 1987, the licensee indicated that breached fire barriers were being restored to an operable status continually as a result of decreased construction activities and the removal of certain barriers from the report that are not required by Technical Specificatio During the November 23, 1987, meeting in Region V, the licensee provided the Region V staff with a graphic depiction of declininc fire barrier breaches. As of November 23, 1987, the graph shows that a total of 44 breaches remain. This is a reduction of 400 since February 1987.-

According to the licensee, their goal is to have all breached fire barriers operable prior to restar Progress toward this goal will be reflected in updated special report This item will remain open pending further verification by Region ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ - _

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M. (0 pen) Part 21 Report No. 86-14 " Automatic Sprinkler Corporation-Model 'C' Deluge Valves Failing to Open" In response to this Part 21 report, the licensee is-in the process of replacing all Model."C" type' deluge valves manufactured b Automatic . Sprinkler Corporation. Installation and testing of the replacement valves is expected to be completed prior to restar This item remains open pending further Region V revie N. (0 pen)312/87-15-03"Organit,*j'andStaffineforFireProtection Program Implementation" The licensee's' approach to resolution of this issue has involved the hiring of. permanent staff to carry out implementation of the ,

program. 'At the time of the inspection, three operations and three engineering positions were fille The licensee indicated that a fourth operations position would be filled on December 2, 198 Although the permanent staff employed by the licensee appear to.be qualified and capable of effectively implementing the program, the!

licensee's administrative procedures'(AP-23 and NEAP 4119),.the FSAR-and organizational chart had not been revised to reflect the new organizational scheme and functional responsibilities of these individuals. The licensee indicated that.these documents would be updated prior to restart.-

This. item remains open pending licensee action and Region V review.-

0. (0 pen) LER No. 87-29 " Fire Protection Program Deficiencies With Respect to Technical Specifications and Commitments" This LER reported licensee's Fire Protection Program activities that were.in nonconformance with Technical Specifications, commitments made to the NRC and 10.CFR 50.73 reporting requirements. This LER was submitted by the licensee as a result of NRC's concerns documented in Inspection Report No.. 312/87-15. The LER indicates-that the licensee's plans and schedule to complete.the long-term upgrade modifications for these conditions will be submitted to the ;l NRC by December 31, 1987. However, the results of the inspectors 1 follow up activities on Inspection Report No.:312/87-15 are as-follows:

(1) Fire Alarm System Deficiencies (Nos. 2.D, 3.A,'and 4.A of.0 pe Item No_._ 312/87-15-04 and LER No. 87-15)

The inspector identified a CO 2 system alarm deficiency that was-described in the licensee's internal Fire Protection System Status Report as problem No. 1. ~The licensee identified.thi condition as a deviation from governing code requirements in LER Nos. 87-15 and 87-29. The licensee's corrective' actions for these conditions are as follows:

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S I Interim Compensatory Measures Technical Specification compensatory measures will be in place for restart (this is further discussed in paragraph 4). Interim Hardware Modifications ECN Nos. R-1993 and R-1079 document the licensee's installation'of additional fire alarm circuits in the control room. Although this installation provides for an alarm annunciation window inside the control room'for each local fire alarm panel, it does not provide for a distinctive alarm output signal or for supervision of fire suppression system activation, fire damper closures, or local alarm activation. The licensee has identified this as an interim corrective action that is supplemented by administrative procedures which require that an operator be dispatched to the local fire alarm panel upon receipt of a control room alarm to make a distinction of the type and location of the incoming alarm. The interim alarm circuits will.be demonstrated operable every 31 day Long-Term Corrective Actions The licensee acknowledged in ECN No. R-1993 that the interim fire alarm system control room circuit installation does not comply with governing code NFPA 72-D because the interim circuit installation is unsupervise For long-term corrective action, the licensee plans to upgrade the fire alarm system to meet NFPA 72-D requirements or demonstrate equivalency prior to cycle 8 operation - next refueling outag (2) Fire Pump Operability Pursuant to Technical Specification and Governing Code Requirements (Items 4.E and 4.F of Open Item N /87-15-04)

The licensee's proposed or implemented corrective action for these deficiencies are as follows: Corrective Acticos to be Completed Prior to Restart-The licensee indicated that the following corrective actions regarding the fire pump installation would be completed prior to restart:

The pump surveillance procedures will be revised to incorporate testing of pump parameters and acceptance criteria of governing code NFPA 20 to determine pump operabilit Addit,ional testing of the pumps will be performed using the governing code test parameters and pump

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manufacturer's' design specifications as the basis of'

testing. (This testing will include blocking off o resetting system relief. valves, performing pump discharge head or shut-off tests, and measurement'of vibrations under full load conditions.) The test'

results will establish acceptance criteria and~

characteristic pump' curves to monitor future pump

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l performanc The licensee indicated that the acceptance test results will clarify the test data anomalies for both pump H I

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clarification would also be provided for the licensee's FSAR response to NRC question No. 17, Item 57, and the licensee's engineering calculation No.-

64-15SH. -The statements made in this response appear to be inconsistent with the fire pumps' ability to-supply the required q'antity of fire suppressio '

u water to.the Turbine Building mezzanine leve This inconsistency further impacts the adequacy of fire pump testing to meet the requirements of Technical Specification No. 4.18.2.1.F(2) in that, if only.the lesser Technical Specification flow requirement of 2000 gpm at_125 psi is. met, the maximum-head and flow required for fire suppression that is permissible

, under.the pumps design limitations will not be-verified. Because of this inconsistency, the licensee's test procedure Nos. SP 201.03B'and SP 705 for the pumps require testing ~of the pumps'to demonstrate their ability to meet the maximum expected flow rates required for fire suppressio This flow rate appears to be outside'of the original design limitations for the pump The licensee indicated that a new controller for the electric pump would be installe Long-term Corrective Actions

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The licensee indicated that the following fire pump modifications would be made post restart on a schedule that will be discussed in the licensee's.LER No. 87-29-submittal prior.to December 31, 1987:

The air' release-valve which ensures proper' venting of L

the electric fire pump casing will be replaced with a more appropriately sized valve.

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. 7 (3) Fire Hose Stations Inside Containtrent (Item 4.I of Open Item 312/87-15-04)

The licensee indicated that the fol' vowing corrective action would be taken regarding Reactor Building's manual fire suppression system: Corrective Action to be Completed Prior to Restart The inspector reviewed the licensee's position provided to the NRC in the licensee's February 1, 1978, response to an NRC request for additional informatio The licent.ee's response did not fully address the configuration and limitations of this system. Instead, it implies that the system's water supply is equivalent to the remainder of the facilities standpipe hose stations which are governed by NFPA 14, where water is supplied through minimum 2 inch standpipes into 1 inch fire hos The inspector determined that the supply through a inch orifice into 1 inch fire hose is not adequate for fire fighting purposes in the Reactor Buildin In response to this concern, the licensee indicated the following actions will be performed:

Procedures would be revised to leave valve No DMW-421 and DMW-422 to the miscellaneous water system in the open position and the system's drawings would be revised to reflect the new valve position Verification will be made so that with the inch restricted-orifice installed in the miscellaneous water system supply, the minimum nozzle flow and pressure rating for full fog firefighting hose streams inside containment will be obtaine Firefighting pre plans will be revised to require that the fire brigade use extra lengths of fire hose as necessary to obtain primary water supply for fighting fires inside containment from the closest Reactor Building standpipe outlet that is supplied by the station fire pumps, if the miscellaneous water system supply is inadequat A justification will be provided for the lesser capability Reactor Building Standpipe System if it is determined to be less than described in Item 7, page 6 of the licensee's respons ___ _ -________________ . _ _ . _ _ _ .

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8-i The licensee will also' provide a discussion of the

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operability of this system based on the NRC's ,

acceptance of this approach in supplement No. l't !

the Fire Protection SER, dated December 14,'1978_

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(Modification No. 3.1.39).  : Long-Term Corrective Actions j The licensee indicated that hose stations for the Reactor Building containment would be upgraded to conform with- 1 NFPA 14. The schedule for upgrading this fire suppression )

capability will be provided in the-licensee's LER 87-29.-

submittal prior _to December 31,.198 (A) Fire Detector Locations (No. 4.C of Open Item 312/87-15-04)

In response to this item, the licensee installed additional .

fire detectors and_ revised the' detector. configurations ~ in some areas of the plant in accordance with ECN Nos. R-0767_and R-2066. The inspector _and the-licensee staff: verified the'

adequacy of these installations during physical walkdowns during the inspectio For areas where the licensee determined that the detector locations appear to be' questionable but not significant, the licensee indicated that a description of.these configurations-would be provided in the licensee's NFPA/FSAR review which will be included in the licensee's LER 87-29 submittal prior to December 31, 198 (5) _ Power Block Ventilation Exhaust Fan Interlocks (No. 4.D of Open 2 tem 312/87-15-04)

In response to Item 4.D of Open Item.No.'312/87-15-04, the

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licensee removed the fire system interlocks from the fans in accordance with ECN No. R-1142. According to-the ECN, the fans can now be used in their existing configuration for smoke contro (6) Automatic Sprinkle'r System Deficiencies (No. 4.H of Open Item '

No. 312/87-15-04)

, The licensee's internal engineering evaluation No.-ERPT-M0049 concludes that the remaining system deviations have no impact on plant Technical Specifications or safe shutdown capabilit Therefore, the licensee has elected to address these deviations as part of their LER 87-29 submittal prior to December 31, 198 During the inspection, the inspector and'the licensee staf performed a physical walkdown _of sprinkler. system modifications'-

that were performed'in accordance with ECN Nos.'R-0767, R-1401,

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. 9 and R-045 The installations observed by the inspector appeared to be satisfactor (7) Fire Damper Installations (Nos. 4.0 and 4.J of Open Item N /87-15-04)

ECN No. R-1128 required the installation of replacement train

"A" fire damper isolation switche According to the ECN and the licensee, these modifications have been completed. The licensee indicated that there were outstanding plant betterment issues relating to fire dampers that are being tracked as LRSL

  1. 495 for implementation post restart. This will be discussed in the licensee's LER 87-29 submittal prior to December 31, 1987 (Item 4.J of Open Item 312/87-15-04).

(8) FSAR/NFPA Code and Appendix "R" Discrepancies (No. 4.K of Open Item 312/87-15-04)

The licensee indicated that the budget approval and schedule for completing an assessment of these deficiencies will be addressed in the licensee's LER 87-29 submittal prior to December 31, 1987. The licensee reported in LER 87-29 that the licensee's Occurrence Description Report (ODR) was not consistently used within the organization regarding the deportability of fire protection discrepancies. The licensee's corrective actions to LER Nos. 86-21 and 86-23 were apparently ineffectively applied to fire protection (10 CFR 50.72 and 50.73).

(9) Installation of Spray Shields for Auxiliary Feedwater Pump Motor Air Intakes (No. 4.L of Open Item No. 312/87-15-04)

ECN No. A-5530 required the subject spray shields to be installed. During the inspection, the inspector and the licensee's staff made physical verification of this installation. The inspector concluded that the spray shield installations appeared to adequately protect the motors from fire suppression water that would be discharged on actuation of sprinklers installed for protectio (10) Overdue Fire Protection System Surveillance (No. 4.M of Open Item 312/87-15-04)

The licensee indicated that overdue fire suppression system surveillance would be performed prior to restart and that Administrative Procedure No. AP 303.04, " Planning schedule for Required Technical Specification Surveillance," would be revised to ensure timely performance of these surveillance in the futur This will be verified by Region V prior to restart.

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-(11) Fire Protection for Structural Steel (No. 4.N of Open Item No. 312/87-15-04)

In response to this concern for the Diesel Generator Building, the licensee's engineering calculation Nos, SMUD 2-DGB-00126 and 2-DGB-C0128 provides the licensee's justification for not protecting these structural members from fire damage. Based on the assumption that the steel structural members are non-load bearing and low fire potential within the Diesel Generator Buildings, the inspector determined that the licensee's justification appeared to contain an acceptable level of conservatism. The licensee indicated that this issue would be addressed in their LER 87-29 submittal prior to December 31, 198 This item remains open pending further licensee action and Region V revie . Additional Licensee Identified Fire Protection Discrepancies The inspector performed a followup on fire protection concerns identified in the licensee's internal "EASTRP" evaluation of.the facility's Fire Protection Systems. The results of the inspector's followup activities are as follows: Reactor Coolant Pump Oil Collection System The licensee's Request for Inforn.ation No. (R.I.) 206 expresses the-following concerns regarding the RCP eil collection system: '

Adequacy of seismic qualification for the RCP lube oil tanks and attached pipin Potential overflow from the lube oil tanks onto a recirculation i fan and/ hot pipin Ability of containment sump to handle the oil overflow considering elease of all RCP lube oi Control of corrosion inside RCP lube oil tank *

Administrative control of debris which could impair the system catch basin Based on a physical walkdown of the RCP lube oil collection system by the inspector and the licensee staff, the licensee indicated that i the following corrective actions would be taken for these concerns-prior to restart:

(1) Justification for Seismic Qualification i

A revised engineering calculation confirming the adequacy of l the Class III seismic supports for the RCP lube oil tanks would be performed and submitted to NRR as clarification of the I

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tank's seismic design so that proper consideration.can be given to the licensee pending exemption request regarding this syste (2) Revision of Appropriate Quality-Related Documents to Reflect _

-Seismic Classification The licensee indicated that the appropriate quality-related documents would be revised to reflect the seismic qualification attached to the RCP lube oil collection-tank (3) Administrative Controls to Verify Operability of the RCP Lube Oil Collection System The' licensee indicated that administrative controls will-be in place prior to this, and each restart hereafter, verifying the following:

The collection system catch ~ basin and piping is free of foreign debris which could impair the syste The interior.of the tanks will be inspected for corrosion and foreign deposits ~ .

(4) Ability of Containment Sump to Handle RCP Lube Oil System Overflow The. licensee indicated that the.information provided to the inspector confirming the containment sump's ability to contain i the overflow'from the entire lube oil system will.be included in the licensee's submittal to NRR, clarifying the Seismic

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design'of the RCP lube oil tanks. This.is considered an Open Item (312/87-39-01), pending further licensee action and Region V revie B. Fire Brigade Training The licensee's fire brigade training program is required to meet the requirements of NFPA-27. The licensee is experiencing difficulty finding an outside training facility to provide this trainin To meet the objectives of fire brigade training, the licensee indicated that a budget has been approved and plans are being implemented for the construction of an onsite fire brigade training facilit The training. facility will be complete by the-fall'of 1988 (post restart).

This is considered an Open Item 312/87-39-02,.pending further licensee action and Region V revie C. Operator Training in' Emergency Annunciator Procedures For plant. fires that do not require control room evacuation (alternative shutdown capability), the-licensee has developed

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casualty Procedure No. AP 500 which delineates corresponding operator actions to fire brigade pre plans for these fire occurrence The procedures are symptom based and are written in the format of the licensee's casualty emergency procedures for all other scenario Licensee Position l

The licensee took the position that operators are specifically trained on the implementation of event based procedure Nos. 13A and 138 for fires requiring alternative shutdown capabilit In {

addition, the licensee stated that the operators received general j training on the format of casualty symptom based procedure Therefore, additional training of operators on the required actions ]

for fire occurrences was not necessary (Item 4.8 of Open Item l 312/87-15-04).

The inspector noted that some of the operator instructions contained in casualty procedure No. AP-500 involve extensive manual actions by operator The inspector was concerned that operator performance of these actions was verified to be achievable within acceptable time frames. Followup on this concern will be conducted in a subsequent NRC inspectio No violations or deviations were identifie Quality Assurance Program The licensee's internal EASRTP report RI No. 195 identified the j following deficiencies in the licensee's quality assurance program for fire protection:

A procedure to authorize and guide inspection / inspection planning of testing does not exist (QAP 6 scheduled to be approved).

Nonconforming conditions for fire protection equipment are not being identified on Non Conforming Reports (NCRs)as required by the licensee's commitment to NRC Branch Technical Position 9.5- The licensee indicated that corrective action for these deficiencies would be made prior to restar This is considered an Open Item (312/87-39-03) pending further licensee action and Region V revie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC, the licensee, or bot Open items disclosed during the inspection are discussed in paragraphs 1.L,.2.M. 2.N, 2.0, 3.A, 3.8, and _ _ . _ _ __ _ .-. _ . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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5. Exit Interview The inspector met with the licensee representatives (noted in paragraph 1) at various times during the inspection and formally on November 19, 1987, to summarize the scope of the findings and inspection activities described in this repor The licensee representatives acknowledged the statements made by the inspecto I

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APPENDIX A Summary of Corrective Actions to be Performed Prior to Restart The licensee's goal is to have.all breached fire barriers operabl In' response to Part 21 Report No.'86-14, the licensee will have all replacement Automatic Sprinkler Model "C" Type Deluge Valves installe The licensee will have approved Administrative Procedures.that govern the functional responsibilities of individuals implementing the fire protection program in place. The FSAR and functional organizational charts will be revised to reflect the current delegation of responsibilities to staf Because of continuing problems associated with de-activated automatic CO 2 systems, the licensee will implement Technical Specification compensatory measures for all CO 2 system protected area The licensee will have prccedures in place requiring an operator to be dispatched to local alarm panels to make a distinction of fire alarms received in the control room, and the licensee will perform functional testing of unsupervised fire alarm systems every 31 day The licensee will perform testing of the fire pump assemblies in accordance with pump manufacturer specifications and governing code requirements to establish actual pump performance curves and pump operating parameter acceptance criteria for future pump testin The licensee will provide clarification for the greatest expected fire suppression system flow rate discussed in the FSAR and the apparent inability'of a single fire pump to meet this demand while operating within original pump design specification The licensee will install a new controller for the electric fire pum . The licensee will have approved procedures in place requiring that miscellaneous water system valve Nos. DMW-421 and DMW-422 are kept in the open positio The system drawings will also be revised to reflect this chang 'The licensee will verify that the inch restricted orifice in the miscellaneous water system supply will allow the minimum nozzle flow and pressure rating to be obtained for full fog firefighting hose streams inside containmen K. - The licensee will revise firefighting pre plans to require that the fire brigade use extra lengths of fire hose as necessary in order.to obtain primary water supply for fighting fires inside containment-from the nearest Reactor Building standpipe outlet that is supplied by the station fire pump _ _ _ _ _ - _ - _ - _ .

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-2-L. The licensee will provide jus'tification for the lesser capability of the miscellaneous water system supplying water for firefighting purposes inside containment than previously described to the NR The licensee will further provide in this justification a discussion of the operability of this system based on the NRC's acceptance of it in Supplement No. 1 to the Fire Protection SER, dated December 14, 197 M. The licensee will provide an engineering calculation supporting'the seismic qualification of the Reactor Coolant Pump oil collection system and discuss the capability of the containment sump to hold the entire overflow from this syste The justification will be submitted to NRR in support of the licensee's pending exemption request on this syste N. The licensee will revise appropriate quality-related documents to reflect the licensee's designation of seismic qualification of the RCP oil collection syste O. The licensee will implement administrative controls for inspection of the interior of the RCP oil collection tanks, the collection ,

system catch t,asin and associated piping to ensure that they are )

free of corrosion or foreign deposits that could impair the syste P. The licensee will implement quality assurance procedures to ensure that fire protection inspection and testing is performed and that nonconforming fire protection program requirements are identified in NCR I Q. The licensee will provide a schedule for completing corrective actions for fire protection concerns that are not completed before restart in their LER No. 87-29 response that is to be submitted to the NRC by December 31, 198 I

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V APPENDIX B Summary of Corrective Actions to be Performed Post Restart The licensee indicated that the following corrective actions to fire protection program concerns will be completed after restart on a schedule that will be provided in the licensee's LER No. 87-29 submittal to the NRC prior to December 31, 1987: The licensee will provide a schedule for completing hardware modifications to upgrade the fire alarm system to be in full conformance with NFPA 72 The licensee will provide a schedule for completing the hardware modification to upgrade the electric fire pump air release valve installatio The licensee will provide a schedule for completing the hardware modifications to upgrade the Reactor Building containment fire hose standpipe system to be in conformance with NFPA 1 The licensee will provide a schedule for completing the hardware modifications to provide a training facility onsite for the fire brigade that will permit this training to be conducted in conformance with NFPA 2 _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ - _ - _ - _ _ - _ - _ _ - .