IR 05000327/1986040

Insp Repts 50-327/86-40 & 50-328/86-40 on 860707-11.No Violations or Deviations Noted.Major Areas Inspected: Implementation of Corrective Actions Re App R Fire Protection Discrepancies & Previously Identified Items

ML20205G011
Person / Time
Site:	Sequoyah
Issue date:	07/31/1986
From:	Conlon T, Madden P, Miller W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205F991	List: IR 05000327/1986040 ML20205F984
References
50-327-86-40, 50-328-86-40, NUDOCS 8608190381
Download: ML20205G011 (16)

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Sn Kar ug UNITED STATES f NUCLEAR REGULATORY COMMISSION

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n REGION 11 g j 101 MARIETTA STREET, *I g ATLANTA, GEORGI A 30323

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Report Nos.: 50-327/86-40 and 50-398/86-40 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted > -11,1 Inspect .e . - - / N 3C "M P. ayen (

Date Signed

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hg W. H. Miller, Jr. v

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7-30-9(.

Date Signed Approved by P 6ff T. E. Conlon, Section Chief

1. 7'DateS/Signed

'b Plant Systems Section Division of Reactor Safety ,

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SUMMARY

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Scope: This special, announced inspection was conducted in the areas of licensee's implementation of corrective actions associated with Appendix R fire protection discrepancies and on items previously identified by TVA and NR Results: No violations or deviations were identifie ,

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8608190381 860812 PDR ADOCK 05000327 G PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• H. Abercrombie, Site Manager

• W..E. Andrews, Site Quality Manager

• H. Baker, Safety / Fire Protection ,

• C. Birchell, Licensing Engineer i

• E. Craig, Mechanical Modifications

• E. A. Craigge, Industrial Safety Staff

• L. 'M. Nobles, Superintendent Operations

• A. Purcell, Compliance Licensing

• J. H. Sullivan, FORS Supervisor

• R. E. Thompson, Assistant Branch Chief, ONP

• P. R. Wallace, Plant Manager

• K. C. Weller, Systems Engineer Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and

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g office personne NRC Resident Inspectors

• K. Jenison

• P. E. Harmon

• 05 P. Loveless

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 11,1986,. with those persons indicated in paragraph 1 above. The inspector described the creas inspected and discussed in detail the ins'pection finding No dissenting comments were received from the license The licensee did not

. identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection, Licensee Action on Previous Enforcement Matters

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Unresolved Item (50-327, 328/85-01-06), Review Resolution to TVA-Identified l Appendix R Deviations Pending Review by NRR. The deviations have been I ereviewed by NRC and Safety Evaluation Report issued by letter, dated May 29, l 1986. All deviations have been approved, except'for the deviation regarding the lack of T-cold instrumentation in the auxiliary control room which is still under revie TVA is currently accomplishing the modifications required by the deviation These items are scheduled to be completed by-i

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September 30, 1986 and will be reviewed'during a subsequent NRC inspectio This item is closed.

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4. Unresolved Items Unresolved items were not identified during the inspectio . Compliance with 10 CFR 50, Appendix R, Emergency Lighting Appendix R,Section III.J, requires emergency lighting units with at least an eight-hour battery power supply to be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes theret The inspectors reviewed the emergency lighting provided to meet the Appendix R requirement For a fire within the control room, procedure A0I-27, Control Room Inaccessibility (Revision 5), lists a number of manual operations required to be performed for plant shutdown. Manual operations are required to be conducted in the following plant areas:

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6.9 KV Shutdown board rooms A and B

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480V Shutdown board rooms (four rooms / unit)

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480V Reactor MOV board rooms (four rooms / unit)

- Diesel Generator Building, 480V DG Auxiliary board rooms (four rooms) '

The inspectors toured these areas, conducted blackout-emergency lighting tests in several electrical board rooms (Rooms 734-A2, 734-AS, 749-A15, and 749-A16) and verified that the lighting provided met the minimum require-ments of Appendix R,Section II Fires in other plant areas also require a number of manual operation These operations are identified by procedure S01-26.2, Fire Interaction Manual (Revision 3). The locations in which the following manual operations are required for plant shutdown were also reviewed by the inspectors and verified to have sufficient lighting to meet the minimum requirements of Appendix R,Section III.J.:

Location Item-Auxiliary Building - 690' 1 FCV-70-156 Auxiliary Building - 714' Valves62-692 and 62-693 Auxiliary Building - 714' Manual Valves 3-828, 3-836, 3-829, and 3-837 Auxiliary Building - 759' Motor generator set - breakers A/B Turbine Building Station air compressors

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{* The 12 portable handlights, six in cabinet adjacent to auxiliary control room and six in control room office, required for supplemental emergency lighting were also inspected and verified to be functional and available for 1 use if neede !

TVA tested all fixed emergency lighting units and verified that each light-ing unit would illuminate for at least eight hours by work package 11721,

! Appendix R Light Pack Post Modification Test. This was was completed on

June 18, 1986. Future maintenance, inspections, and tests of these units q j are to be conducted in accordance with the manufacturer's requirement * ,

Within the areas examined, no deviations or violations were identifie . Compliance with 10 CFR 50, Appendix R, Section III.G.2, Fire Protection of Safe Shutdown Capability Inside the Containment i An inspection of the licensee's analysis was conducted to determine if the

, fire protection features provided safe shutdown capabilities inside the containment at Sequoyah Units 1 and 2 were in compliance with 10 CFR' 50,  !

Appendix R,Section III.G. The scope of this inspection determined if the fire protection features provided inside the containment for reactor coolant system (RCS) cold (Tc) and hot (Th) leg temperature, steam generator level and pressurizer level and pressure instrumentation were capable of i maintaining one train of the required nuclear instrumentation essential to

achieving and maintaining hot standby free from fire damag i i The licensee analysis identified seven areas inside the containment where separation of the required nuclear instrumentation did not meet the requirements of 10 CFR 50, Appendix R, _ Section II The inspectors reviewed the following reactor building interaction studies and the licensee's corrective actions associated with these Appendix R discrepancies

' Interaction Study RB-1, Unit 1 Reactor Building Annulus, Azimuth 200 to 260 , Elevation 750'-0"

i A fire in this containment area could have potencially _affected RCS temperature indication for all four RCS loops, all three pressurizer level transmitters (LT-68-320, -335, and -339), steam generator level narrow range and steam generator pressure for RCS loops 2 and . Therefore, in order to correct these Appendix R discrepancies, the licensee initiated engineering change notice (ECN) 6642, work plan (WP)

4 12062 which installed sprinkler protection and detection in the areas of these cable interactions. The sprinkler system modification in this

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l area consisted of ten additional sprinkler heads extended off the

! existing system. The WP associated with this interaction was completed

' on June 30, 198 Therefore, based on' the sprinkler modification i associated with interaction study RB-1, the subject Unit I reactor

, building annulus area appears to meet the requirements of 10 CFR 50,

Appendix R,Section III.G.

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4 Interaction Study RB-2, Unit 2 Reactor Building Annulus, Azimuth 200*

to 260 , Elevation 750'-0"

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A fire in this plant area could have potentially affected RCS l temperature indication for all four RCS loops, all three pressurizer.

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level transmitters (LT-68-320, -335, and -339), steam generator level

! narrow range and steam generator pressure for RCS loops 2 and 3.

j Therefore, in order to correct - these . Appendix R discrepancies, the i i licensee initiated engineering change notice- (ECN) L6642, work plan '

l (WP) 12063 which installed sprinkler protection and detection in the i

areas of these cable interactions. The sprinkler system modification i in this area consisted of ten additional sprinkler heads extended off the existing syste The WP associated with this interaction was completed on June 27, 1986. Based on the sprinkler modification l

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associated with interaction study RB-1 the subject Unit 2 reactor l l building annulus area appears to meet the requirements of 10 CFR 50, Appendix R, Section III.G.

i 4 Interaction Study RB-3, Unit 1 Reactor Building, Elevation 693'-0" and i 680'-0" Accumulator Room No. 1 and Raceway Below, Azimuth 34 to 60

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l A fire in the accumulator room No.1 and/or the raceway below from

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Azimuth 34 to 60 presents an interaction through penetrations in the 2 accumulator room floor which could affect RCS temperature indication

"A" train conduit IPM 865I (Loop 1, Tc and Th) and "B" train conduits

IPM 9831I and IPM 9821I (Loops 3 and 4, Th). Thus, in order to correct this Appendix R discrepancy, the licensee initiated ECN L6642, WP 12103 which sealed penetrations 503, 530, 531, 532,~533, 628, and 754 in the accumulator floor with a fire barrier penetration sealant materia This modification provided separation between the "A" train conduits in i

the raceway area and "B" train conduits in the accumulator room. The i WP associated with this interaction was completed on June 27, 1986.

Therefore, based on the modifications associated with interaction study RB-3, the subject reactor building area appears to meet the require-ments of 10 CFR 50, Appendix R, Section III.G.

, Interaction Study RB-4, Unit 2 Reactor Building, Elevation 693'-0" and 680'-0", Accumulator Room No. 2 and Raceway Below Azimuth 34 to 60 A fire in the accumulator room No.1 and/or the raceway below from Azimuth 34 to 60 presents an interaction through penetrations in the accumulator room floor which could affect RCS temperature _ indication

"A" train conduit 2PM 865I-(Loop 1, Tc and Th) and "B" train conduits 2PM690II (Loops 3 and 4, Th). The licensee in order to correct this Appendix R discrepancy rerouted the "A" train cables in conduit 2PM8721, which does not come through the polar crane wall into the accumulator room at the 60 azimuth. This reroute maintains a minimum 20 feet

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separation between trains "A" and "B" train RCS temperature instrumen- l tation cabling and appears to meet the requirements of 10 CFR 50, Appendix R, Section III.G.

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Interaction Study RB-5, Unit 2 Reactor Building, Elevation 693'-0",

Accumulator Room No. I and Inside Polar Crane Wall, Azimuth 40 Cables for Th Loops 3 and 4 in conduit 2PM982II interact through an unsealed mechanical sleeve in the polar crane wall with 2PM872I l j containing cables for the Tc and Th ~ Loop 1. The cable reroute 1

' described in interaction- study RB-4 above corrected this Appendix R )

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discrepancy. Therefore, this plant area appears to meet the require- j ments of 10 CFR 50, Appendix R, Section II l 4 Interaction Study RB-6, Unit 2 Reactor Building, Azimuth 10 to 60

Inside Polar Crane Wall Conduits 2PM586II containing cabling for Th for RCS Loop 4 and 2PM978II containing cables for Tc RCS Loop 4 and Tc RCS Loop 3 interact with RCS I

Loop 1 conduits 2PM872I and 2PM5901 containing cables for Tc and Th RCS

< Loop 1 as they pass within 20 feet of each other inside the polar crane wall in the area of steam generator No. 1. The licensee, in order to j correct this Appendix R discrepancy, initiated WR 121392 which '

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installed a ten gauge steel radiant energy heat shield between conduits l 2PM586II and 2PM97811 from where they go past the steam generator .

platform to a point where the horizontal distance between these l

. conduits and conduit 2PM872I exceeds 20 feet. The WP associated with  !

this interaction was completed-on June 30, 1986. Therefore, based on 1

the modifications associated with interaction study RB-6, the subject i reactor building area appears to meet the requirements of 10 CFR 50,

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Appendix R,Section II Interaction Study RB-7, Unit 2 Reactor Building, Azimuth 60 to 110 ,

Incore Instrument Room In the incore instrument room, pressurizer level transmitters

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2-LT-68-320, 335, and 339 are all located within 20 feet of each other 1 in the incore instrument room. In order to correct this Appendix R j discrepancy, the licensee relocated pressurizer level transmitter

, 2-LT-68-320 outside the 20-foot fire zone of ' influenc This

modification was performed under ECN 6439/6533, WP 11882 which was-

completed on June 29, 1986. Therefore, it appears that the modifica-

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tions associated with interaction study RB-7 resolved the Appendix R discrepancy and that the subject reactor building area meets the i requirements of 10 CFR 50, Appendix R, Section III.G.

! Licensee Identified Items, Licensee Event Reports (LER). and Special Reports i

(Closed) LER 327/84-051,. Failure to Comply with Appendix R ~of 4 .10 CFR 5 The licensee on September 25, 1984, identified the

following plant areas where redundant cabling, equipment and/or components required for safe shutdown were not separated in accordance

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with Appendix R,Section III.G.:

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l (1) Interactions exist between trains "A" and "B" at elevation  ;

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734 in the auxiliary control room. Train "A" consists of cables for steam generator level control for motor driven auxiliary feedwater pump 1A-A (cables IV1083A, IV1061A, and IV1063A). Train

"B" consists of cables for steam generator level control for motor driven auxiliary feedwater pump 18-B (cables IV1123B and IV1103B).

Also, at the location (cable tray PA-B), the above cables interact with those for auxiliary feedwater turbine driven pump (cables 1M811A and ISG480).

(2) Interactions exist between trains "A" and "B" at elevation 714 in the auxiliary building at column lines A-8 and Q. Train "A" consists of cables to handswitch in the main control room (MCR) to l AC breaker 1912 to 6900 shutdown boards (panel 6). Train "B" l consists of cables to handswitch in MCR for AC breakers 1728 )

and 1914 to 6900 shutdown boards 1B-8 (panels 16 and 6). Also, 1 interaction exists at same location with cable IPP460B for hand-  ;

switch in MCR to D/6 parallel operator or breaker 1726 and 1728 to l 6900 shutdown board 18-B (panel 6). l (3) Interactions exist between trains "A" and "B" at elevation 714 at column lines A-8 and Q. Train "A" consists of cables i IPP655A and IPP653A to motor driven auxiliary feedwai.er pump 1A- Train "B" consists of cables 1PP6678 and IPP665B to motor driven auxiliary feedwater pump 18-B. Also, interaction exists at the same location for turbine driven auxiliary feedwater pump (cables ISG240A, 1M1450,.IV3241A, IV3251A, ISG480, ISG481, and ISG461).

With respect to the above Appendix R discrepancies, the licensee in Enclosure 5 to their December 21, 1984 submittal analyzed these 4^

discrepancies and identified the appropriate corrective actions to resolve them in interaction study Nos.15,16, and 1 In addition, the licensee in Enclosure 8 to their December 21, 1984 submittal committed to a schedule to complete the required plant fire protection modifications associated with the protection of safe shutdown capabilities by June 30, 1986. Thus, based on the corrective actions )

identified in the subject interaction studies, the inspectors performed )

an inspection of the required raceway fire barriers, sprinkler system  !

modifications, and the one-hour fire barrier wall installation along column line A-8 on reactor auxiliary building elevation 714'-0" and i determined that the subject fire protection modifications were properly '

installed, fully functional and adequate with respect to meeting the requirements of 10 CFR 50, Appendix R, Section III.G.2. Therefore, this item is close b. (Closed) LER 327/84-057, Failure to Comply with Appendix R - of 10 CFR 50. The licensee on October 10, 1984, identified the following i

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plant areas where redundant cabling, equipment and/or components were not separated in accordance with Appendix R,Section III.G.:

(1) Power and local control cables for 1A,1B, 2A, and 2B RHR pump room coolers interact such that all four could be lost in a single fire. Cables involved:

IPP3031A, IPP3033A, IPP3041B,1PP3043B, 2PP3031A, 2PP3033A, 2PP3041B, and 2PP3043 (2) The A-A and B-B main control room air handling units and compressors have cables which interact such that a fire could take out both "A" and "B" train. Cables involved are:

1PL4500A, 1PL4501A, IPL4520A, IPL4527A, 1PL4510B, IPL4511B, 1PL45128, 1 PL4540B , I PL45478, 1PL45128, 1PLA501 A , 1 PL4502A ,

IPL4520A, and IPL4527 (3) Cables which supply all four RCS loop temperature indications interact at one location on elevation 714 in the auxiliary building. Cables involved are:

IPV330K and 1PV320J (4) Interactions exist between "B" train 6900 volt shutdown boards and cables for various "A" train valves. Valves and cables involved are:

2V1963A 2-FCV-3-136B),2V1953A 2-DCV-3-136A),

2V2953A 2-FCV-3-116B),2V2952A 2-FCV-3-1168),

2V2931A 2-FCV-3-116A),2V2200A 2-FCV-67-125),

2V2201A (2-FCV-67-125), 2V2203A (2-FCV-3-125),

2V2211A (2-FCV-67-126), 2V2422A 2-FCV-67-146), ,

2V2423A(2-FCV-67-146),2V2425A 2-FCV-67-146), '

2V2968A (2-FCV-67-223), 2V2969A 2-FCV-67-223), l 2V1983A (2-FCV-67-81), and IV2425A (1-FCV-67-146). )

(5) Interactions exists between "A" train 480 volt shutdown boards and I cables for various "B" train valves and "B" train ERCW pump cables. Cables involved are: )

2V2941B (2-FCV-3-126A), 2V2961B (2-FCV-3-1268 ,

2V2083B (2-FCV-3-179A), 2V2131B (2-FCV-3-179B ,

2V28078 (0-FCV-67-152), 2V27918 (0-FCV-67-152 ,

2V27948 (0-FCV-67-152), 2V2160B 2-FCV-67-123),

2V27928(0-FCV-67-152),2V2173B 2-FCV-67-124),

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2V2160B (2-FCV-67-123), 2V2431B 2-FCV-67-147),

l 2V2170B(2-FCV-67-124),2V2161B 2-FCV-67-123),

j 2V24298(2-FCV-67-147),2V20038(2-FCV-67-82), i 2PP7048, 2PP706B ERCW Pump M-B), i 2PP7168, 2PP718B ERCW Pump P-B), l

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1PP704B, IPP706B ERCW Pump L-B),

IPP7168, 1PP7188 (ERCW Pump N-B).

(6) Interactions exist between "B" train 480 volt shutdown boards and cables for various "A" train valves and "A" train components. The cables and components are listed belo IV2951A(1-FCV-3-1168),_IV1953A(1-FCV-3-136A),

IV1960A (1-FCV-3-1368), IV1983A (1-FCV-67-81), ,

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IV2200A(1-FCV-67-125),IV2211A(1-FCV-67-126),

IV2423A (1-FCV-67-146), IV2431A (1-FCV-67-147), ;

IV2971A(1-FCV-67-223),IV641A(1-FCV-67-424),

2V2971A (2-FCV-67-223), 2PLW227A (2-FCV-67-492),

IV2792A (0-FCV-67-151), IPP679A (ERCW Pump J-A),

IV681A(ERCWPumpK-A),IV691A(ERCWPumpR-A),

IV691A (ERCW Pump Q-A), IPLW203A (A, ERCW Traveling Water Screen), 2PLW211A (D, ERCW Traveling Water Screen).

(7) Interactions exist between train "A" 6900 volt shutdown boards and train "B" cables for valves and components. Involved cables are:

1V2941A(1-FCV-3-126A),IV2961B(1-FCV-3-126B), ,

IV20818 1-FCV-3-179A), IV2130B (1-FCV-3-1798),

IV2003B 1-FCV-67-82), IV2163B (1-FCV-67-123),

IV2173B 1-FCV-67-124), 2V2428B (2-FCV-67-147),

2PLW233B (2-FCV-67-489), IV3350B (1-FCV-67-478),

1PLW2338 (1-FCV-67-489), IPLW1908 (ERCW Screen Wash Pump B), 2PLW180B (ERCW Screen Wash Pump C),

1PLW211B(ERCWTravelingScreenB),2PLW203B(ERCW Traveling Screen C).

(8) Unit 1 - In the auxiliary building on elevation 714 at A6Q and in the auxiliary control room on elevation 734 at RA6 the control ,

cables for containment isolation valves, for normal letdown path, I interact and fail to meet the 20-foot separation criteria required by Appendix Cables involved are:

1V4423A, IV4435A, IV4473A, IV4488A, and IV4503 (9) Unit 1 - A fire at location A3 to AS/r to t on elevation 690 in auxiliary building could take out the following cables due-to interactions with less than 20-foot separatio (a) Train A: Handswitch for 1A-A AFW pump (cable 1PP652A) and 6900 volt to 1A-A AFW pump (cable 1PP650A).

(b) Train B: Handswitch for 18-B AFW pump (cable 1PP6648) and

6900 volt to IB-B AFW pump and 18-B AFW pump and moto l

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(c) Steam driven AFW pump cables:

ISG461 and ISG481 (LCV status light),

1PV105A Vital AC supply to 1-L-381),

ISG240A Vital AC to 669 transfer switch, normal),

IM811A (1-PS-3-138A), IM1450A, IM1452A (Steam supply transfer, IV2623A, IV264A (1-FCV-1-17),

IPV185B (Vital AC to 1-L-381), and ISG221B, ISG241B l

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(alternate transfer switch).

(10) Unit 1 and Unit 2 - A fire at A12-A13/r line wall could involve the following "A" train components and "B" train reactor M0V board. Train "A" cables are:

1V2425A (1-FCV-67-146), 2V1955A (2-FCV-3-136A),

2V1965A (2-FCV-3-1368), 2V1985A (2-FCV-67-81),

2V2200A, 2V2201A, 2V2203A (2-FCV-67-125),

2V2211A(2-FCV-67-126),2V2422A,2V2423A(2-FCV-67-146),

2V2931A (2-FCV-3-116A), 2V2951A, 2V2953A (2-FCV-3-1168), l

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2V2968A, 2V2969A (2-FCV-67-223).

Train "B" cables are reactor MOV board 282-B and associated cable tray (11) Unit 1 - A fire at location A3 to A10/Q to V on elevation 714 in the auxiliary building could involve cables for both motor driven and turbine driven auxiliary feedwater pumps along with their associated level control valves. (Listed below are the TDAFWP cablesinvolved).

IV3250A, IV3251A, IV3253A (1-FCV-1-15),

IM1452A, IV3240A, IV3243A, IV3241A, IM1450A, IM1451A (1-FCV-1-16),

i IV2624A, IV2620A, IV2621A, IV2623A (1-FCV-1-17),

IV26338, IV2634B, IV26358 (1-FCV-1-18), '

ISG480, ISG481, ISG461, ISG250S, ISG251S, ISG252S, 1SG229S (control cables, TDAFWP).

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As a result of the above Appendix R discrepancies, the licensee in Enclosure 5 to their December 21, 1984 submittal analyzed these discrepancies and identified the appropriate corrective actions to resolve them in interaction study Nos.18, 19, 20, and 2 In addition, the licensee in Enclosure 8 to their December 21, 1984 submittal committed to a schedule to complete the required plant fire protection modifications associated with the protection of safe shutdown capabilities by June 30, 198 Thus, based on the corrective actions identified in the subject interaction studies, the inspectors j performed an inspection of the required raceway fire barrier, and

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verified that the procedure identifying the required manual operator actions for safe shutdown had been implemented and that the power had been removed from motor operated valves which could affect safe-shutdown if they spuriously operate The inspectors determined that the raceway fire barrier identified in the licensee's interaction study No. 21 was. properly installed, fully functional and adequate with respect to meeting the requirements of 10 CFR 50, Appendix R, Section III.G.2. In addition, the inspectors determined that the manual operator actions required by interaction study Nos.18,19, and 20 were implemented by the licensee's fire interaction manual S0126.2, Revision 3, and that the power to the motor operated valves identified in interaction study No.18 had been removed. Therefore, this item is closed. (Closed) LER 84-074, Failure to Comply with Appendix R of 10 CFR 5 On December 31, 1984, the licensee identified the following plant areas where redundant cabling, equipment and/or components were not separated in accordance with Appendix R,Section III.G.:

(1) 1-FCV-68-332 cable IV2449B interacts with 1-PCV-68-340A cable IV5612A in the auxiliary building on elevation 734 in the 6.9kV shutdown board room "A" at A3-6/R-S lin (2) 2-FCV-68-333 cable 2V2455A interacts with 2-PCV-68-334 cables 2V55938 and 2V5594B in the auxiliary building on elevation 734 in the 6.9kV shutdown board room "B" at A11-13/R lin (3) 1-PCV-68-334 cable IV55988 and train "A" power to 1-FCV-68-333 interact on elevation 748 in the auxiliary building in the 480 volt transformer room "1A".

(4) 2-PCV-68-340A cable 2V5610A interacts with train "B" auxiliary power cables to block valve 2-FCV-68-332 in the auxiliary building at elevation 714 on A8/Q lin (5) 2-PCV-68-334 cable IV5596B interacts with train "A" auxiliary ,

power cables to block valve 2-FCV-68-333 in the auxiliary building i at elevation 714, A6-8/Q-R lin I I

(6) 2-PCV-68-340A cable 2V5612A interacts with train "B" auxiliary power cables to block valve 2-FCV-68-332 at elevation 759 in the auxiliary building in the CRD equipment roo (7) Cables for "A" train valves 0-FCV-70-193 and 0-FCV-70-197 and "B" train valves 0-FCV-70-194 and 0-FCV-70-198 interact on elevation 714 in the auxiliary building with the IAA, 2AA, IBB, 288, and C-S ,

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(8) 2-FCV-74-1 cable 2V2780A interacts with "B" train auxiliary power for 2-FCV-74-2 in the auxiliary building at elevation 759 in the CRD equipment room at A13/ (9) In the auxiliary building at elevation 734 in the Unit I reverse osmosis room, cables for 1-FCV-74-2 interact with cables for normal and excess letdown. For a fire involving normal and excess letdown, the shutdown logic requires that 1-FCV-74-1, -2 be open within 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.

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(10) Interacts exist between 1-LCV-62-132 (cables IV2761A, IV2764A, IV2765A) and 1-LCV-62-133 (cables IV2771B, IV27748, IV2775B) such that spurious operation of either valve could be caused by a fire ,

in the auxiliary building at elevation 69 '

(11) Cables for 1, 2-FCV-70-156 (1V2562A, IV2565A, 2V2562A, 2V2565A)

train "A" and 1, 2-FCV-70-153 (1V25568, IV2559B, 2V25568, 2V25598) train "B" interact with each other and cables associated with CCS pumps 1AA, 2AA, 188, 2BB, and CS. These interactions exist in the auxiliary building on elevations 690, 714, 734, and

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74 With respect to the above Appendix R discrepancies, the licensee, in

! Enclosure 5 to their December 21, 1984 suomittal, analyzed these 4 discrepancies and identified the appropriate corrective actions to resolve them in interaction study Nos. 109, 110, 111, 112, 113, 114,

115, 116, 117, 118, 119, and 12 In addition, the licensee in Enclosure 8 to their December 21, 1984 submittal committed to a

schedule to complete the required plant fire protection modifications associated with the protection of safe shutdown capabilities by June 30, 1986. Thus, based on the corrective actions identified in the subject interaction studies, the inspectors performed an inspection of the raceway fire barriers, cable reroutes, sprinkler system  ;

modifications and verified that the procedure identifying the required manual operator actions for safe shutdown had been implemented and that the power had been removed from motor operated valves which could affect safe shutdown if they spuriously operate The inspectors determined that the raceway fire barrier, cable reroutes and sprinkler )

modifications identified in the licensee's interaction study Nos.112  ;

and 113 were installed and implemented properly, fully functional and '

adequate with respect to meeting the requirements of 10 CFR 50, I Appendix R,Section III.G.2. In addition, the inspectors determined that the manual operator actions required by interaction study Nos.115,116,117,119, and 120 were implemented by the licensee's fire interaction manual SOI 26.2, Revision 3, and that the power to the motor operated valves identified in interaction study No. 120 had been removed. Therefore, this item is close .. . _ . . - _ _ _ _ _ _ - .- . _-_

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4 d. (Closed) LER 327/84-073, Fire Door Inspection, Resulting in 110 Doors Failing to Meet UL Standards. TVA's report, dated December 26, 1978, identified 110 fire doors which did not meet the requirements of NFPA-80, Fire Doors, or the applicable UL standards. Thirty-six of these doors contained deficiencies which resulted in these doors being considered nonfunctional. These deficiencies were attributed to the lack of or type of maintenance and modifications previously performed on the doors. TVA's existing fire watch program was expanded to include the areas adjacent to the doors as required by Technical Specification 3.7.12. During this inspection, the inspector reviewed ten of the 36 deficient doors (Door Nos. A62, A75, A124, A131, A143, A168, A189, A193, C49, and C50) and verified that the deficient doors had been repaired or replaced with new approved fire doors. The work package for the repair modifications was reviewed and found to be complete. Therefore, this item is close e. (0 pen) LER 327/84-046, Failure to Comply with Appendix R of 10 CFR 5 The licensee, in Enclosure 5 to their December 21, 1986 submittal, analyzed the Appendix R discrepancies identified in the subject LER and determined that the corrective actions required by interaction study No. I required a deviation to 10 CFR 50, Appendix R, Section III.G. in order to achieve compliance. On May 29, 1986, the NRC issued their SER granting the licensee's Appendix R fire protection deviation reques Currently, TVA is scheduled to complete the auxiliary building elevation 690 sprinkler modifications above the counting room suspended ceiling prior to the plants restart. Therefore, this item remains open and the corrective actions associated with this LER will be inspected during a subsequent NRC inspectio f. (0 pen) LER 327/84-049, Failure to Comply with Appendix R of 10 CFR 5 The licensee, in Enclosure 5 to their December 21, 1984 submittal, analyzed the Appendix R discrepancies identified in the subject LER and identified the appropriate corrective actions to resolve these discrepancies in their interaction study Nos. 2, 3, 4, 6, 10, 11, 12, 13, and 14. In addition, the licensee determined that the corrective actions required by interaction study No. 6 required a deviation to the requirements of 10 CFR 50, Appendix R, Section III.G. in order to achieve compliance. On May 29, 1986, the NRC issued their SER granting i the licensee's Appendix R fire protection deviation reques !

Currently, TVA is scheduled to complete the auxiliary building north stairwell water and draft curtain modifications prior to the plant's restar Therefore, this item remains open and the corrective actions associated with this LER will be inspected during a subsequent NRC inspectio ;

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g. (0 pen) LER 327/84-059, Failure to Comply with Appendix R of 10 CFR 5 The licensee, in Enclosure 5 to their December 21, 1984 submittal, analyzed the Appendix R discrepancies identified in the subject LER and identified the appropriate corrective actions to resolve these discrepancies in their interaction study Nos. 22, 23, 24, 25, 26, 27, 30, and 34. In addition, the licensee determined that the corrective actions required a deviation to the requirements of 10 CFR 50, Appendix R, Section III.G. in order to achieve compliance. On May 29, 1986, the NRC issued their SER granting the licensee's Appendix R fire protection deviation request. Currently, TVA is scheduled to complete i the 1828 and 2A2A 480V shutdown board room cable tray water spray system installations prior to the restart of the plan Therefore, this item remains open and the corrective actions associated with this LER will be inspected during a subsequent NRC inspectio h. (0 pen) LER 327/84-063, Failure to Comply with Appendix R of 10 CFR 5 In Enclosure 5 to the licensee's December 21, 1984 submittal, the licensee analyzed the Appendix R discrepancies identified in the

subject LER and identified the appropriate corrective actions to resolve these discrepancies in their interaction study Nos. 46, 47, 48, 49, 50, 51, 56, 57, 58, and 5 The licensee determined that the corrective actions required by interaction study Nos. 57, 58, and 59 requiced a deviation to the requirements of 10 CFR 50, Appendix R, Section III.G., in order to achieve complianc On May 29, 1986, the NRC issued their SER granting the licensee's Appendix R fire protection

,

deviation request. Currently, TVA is scheduled to complete the south, No. 6 and No. 5 stairwell water and draft curtain modifications prior to the restart of the plant. Therefore, this item remains open and the corrective actions associated with this LER will be inspected during a subsequent NRC inspectio . (0 pen) LER 327/84-067, Failure to Comply with Appendix R to 10 CFR 5 The licensee, in Enclosure 5 to their December 21, 1984 su bmittal ,

, analyzed the Appendix R discrepancies identified in the subject LER and identified the appropriate corrective actions to resolve these ,

discrepancies in their interaction study Nos. 86, 98, 100, 101, 102, '

103,104,105,107, and 108. The licensee also determined that the corrective actions required by interaction study Nos. 101, 103, and 104 ,

required a deviation to the requirements of 10 CFR 50, Appendix R,  !

Section III.G. in order to achieve complianc The NRC on May 29, 1986, issued their SER granting the licensee's Appendix R fire  :

protection deviation request. TVA, currently is scheduled to complete l the Units 1 and 2 auxiliary building water and draft curtain modifica- '

tion prior to plant restart. Therefore, this item remains open and the corrective actions associated with this LER will be inspected during a subsequent NRC inspectio _ ._ . -. - . _- . _ _ . . . _ . _ _ _

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(0 pen) LER 327/85-002, Failure to Comply with Appendix R of 10 CFR 50. TVA's report of January 29, 1985, identified three conduits which had

missing or damage KAO-Wool fire barrier insulation. However, the areas l_ in which these conduits were located were included within a fire watch

program which had previously been established for other firc protection '

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violations. The fire watch surveillance program met the action l I statement of Technical Specification 3.7.1 TVA has repaired or j replaced the damaged insulation and added the KAO-Wool insulation to ,

the fire barrier surveillance inspection progra The inspector i

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reviewed procedure SI 233.4, Visual Inspection of Thermal Fire Barriers

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(Revision 2) and verified that the KAO-Wool fire barriers had been l

incorporated into the surveillance program. The KAO-Wool fire barriers

! in the auxiliary building were inspected. It appeared that the damaged

! insulation had been replaced or repaired. However, the insulation on j several conduits in a number of locations within the auxiliary building l

were noted to be damaged. The licensee issued a repair work order for  ;

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the damaged insulation and repaired the damaged insulation prior to the  !

completion of this inspection. A fire watch program has been in effect  ;

j for these areas since the original Appendix R fire protection i

! deficiencies were identified in 1984. This program is to maintain in  !

effect throughout the plant until all of the fire protection  ;

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j modifications are complete.

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Although TVA has completed the corrective action specified by the LER, additional action is required to assure that the integrity of the a KAO-Wool fire barriers will be maintained in the future. TVA is to

! evaluate the problem and revise this LER by September 15, 1986, to j indicate the additional corrective actions to be take Therefore, j this item remains ope ;

j k. (Closed) Special Report 327 and 328/84-08, Sprinkler System Modifica-l tions. TVA's special reports, dated December 19, 1984 and May 17, i 1985, identified a number of modifications required to bring the i auxiliary buildir.g automatic sprinkler systems into compliance with the requirements of NFPA-13, Automatic Sprinkler System These modifications required relocating approximately 418 sprinkler heads, j removal of approximately 400 sprinkler heads and the installation of

approximately 226 additional sprinkler heads. Also, the sprinkler

systems for Units 1 and 2 elevations 734', 749' and 759' have been j provided with additional flow paths to assure adequate pressure and

flow are available to these areas. The system for each unit area,

i.e., a system for each unit, is now supplied from the original four-inch feed main and a new six-inch feed main. The two feed mains to each system are provided with preaction valves. The two valves to

! each system are activated simultaneously by the smoke detector system within each area. All sprinkler system piping has been installed to i meet TVA Class G piping support requirements for pressure retention l l following a seismic event. The inspector conducted a plant tour to l l review the new system installation and modification These i modifications appear to bring the systems into compliance with NFPA-13

and the NRC guidelines. Therefore, this item is closed.

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8. Inspector Followup Item (Closed) Inspector Followup Item (50-327, 328/85-01-07), Fire Protection and Raw Service Water Pumps are Not Operated as a Train A-B Syste TVA has revised procedure No. S01-26.1, High Pressure Fire Protection Systems (Revision 30),Section V.A.7-10 to require pumps 1A and 28 to be in automatic position and pumps 1B and 2A to be in standby or pumps 18 and 2A to be in automatic position and pumps IA and 28 to be in standby positio This item is close l l

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