IR 05000336/1997084
| ML20202G646 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/09/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20202G578 | List: |
| References | |
| 50-336-97-84, 50-423-97-84, NUDOCS 9802200189 | |
| Download: ML20202G646 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION RE0lON I Docket Nos: 50 336,50 423 Report Nos: CO 336/97 84,50 423/97 84 License Nos: DPR-65, NPF 49 Licensee: Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385 I
Facility: Millstone Nuclear Power Station, Units 2 and 3 Location: Waterford,CT Dates: September 15 19,1997 Inspectors: Roy L. Fuhrmeister, Senior Reactor Engineer -
J. Thomas Shediosky, Senior Reactor Analyst Kenneth Sullivan, NRC Contract Engineer Anthony Fresco, NRC Contract Engineer j Approved by: William H. Ruland, CNef - 1 Electrical Engineering Branch Division of Reactor Safety 9002200189 990209 PDR ADOCK 05000336 G PDR
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TABLE OF CONTENTS PAGE E X E C U TIV E S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . lil F2 Status of fire Protection Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . 1 F Surveillance Testing of Fire Related Sofe Shutdown Equipment a t U ni t 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 F Design Reviews and Modification Packages at Unit 3 . . . . . . . . . . 2 F Temporary Modifications at Unit 3 . . . . . . . . . . . . . . . . . . . . . . . 5 F3 Fire Protection Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . 7 F Unit 3 Emergency Operating Procedures for Post Fire Safe Shutdown .......................................7 F Unit 2 Fire Protection Surveillance Requirements . . . . . . . . . . . . . 8 F Unit 2 Fire Protection Alternative Shutdown Capability . . . . . . . . 11 F Unit 2 Potential for Loss of Remote Shutdown Capability . . . . . . 13 F7 Quality Assurance in Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 F Fire Protection Program Audits . . . . . . . . . . . . . . . . . . . . . . . . 13 F8 Miscellaneous Fire Protection issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 F Compliance With Licensing Basis . . . . . . . . . . . . . . . . . . . . . . . 17 V. M AN AG EM E NT M E ETI N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 h X1 s
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Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 PARTIAL LIST OP PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 MILLSTONE UNIT 2 FIRE PROTECTION PROCEDURES REVIEWED DURING TH IS IN S PECTIO N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 LIST O F AC RO NYM S U S E D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 FIRE PROTECTION AND POST FIRE SAFE SHUTDOWN CONFIGURATION CONTROL INSPECTION REQUIREMENTS ............E1
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EXECUTIVE SUMMARY Millstone Nuclear Power Station Combined inspection 336/97 84;423/97 84 The inspection consisted of a review of the post fire safe shutdown program for Unit 2 and the control of the configuration of the post fire safe shutdown equipment for Unit 3. The inspection guldance used was an appendix to the draf t Temporary Instruction for the Fire Protection Functional Inspections. A copy of the inspection guidance is attached at the end of the repor Plant Support Fire Protection
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Implementation of licensing commitments to specify fire protection actions in plant emergency procedures were found to have been ineffective. (Section F3.1)
- The Unit 2 procedures generally implemented the Technical Requirements Manual surveillance. Exceptions noted included: partialinspection of fire damper tracks without technical basis; fire assemblies (walls, floors, ceilings) are not routinely inspected for deficiencies; fire board used to protect some cable trays is inspected through a preventive maintenance action instead of a surveillance procedur (Section F3.2)
The Unit 2 surveillance procedure for inspection of penetration seals, and the Unit 2 abnormal operating procedures for shutdown and cocidown in the event of a control room fire had been placed in a "Do Not Use" status because of deficiencies identified by NU personnel. (Section F3.2)
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Design controls were found to have been effective in preventing modifications from causing adverse impacts to the Unit 3 post fire safe shutdown equipmen (Section F2.2)
- Audits of the Unit 3 fire protection program have been effective in identifying deficiencies; however, in the past, corrective actions have been ineffective in correcting the identified deficiencies. (Section F7.1)
- Surveillar.co testing of the Unit 3 fire related safe shutdown equipment has been inadequate. (Section F2.1)
- NU audits of fire protection activities at Unit 3 concluded that there is no assurance Unit 3 could achieve safe shutdown after a postulated fire in the plan (Section F7.1)
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a Report Details IV. Plant SupngIt F2 Status of Fire Protection Facilities and Equipment F2,1 So,veillance Testina of Fire Related Safe Shutdown Eautoment at _U.clL3 a. Scoos of Insoection To evaluate the required testing of post fire safe shutdown equipment, the testing planned and that actu8ily performed, the inspector reviewed the following documents:
Millstone 3 Technical Requirements Manual (TRM)Section I, " Fire Related Shutdown Components."
Action Request (AR) 9600252 Fire Protection Evaluation Shutdown System Availability Summary, NERM 64, Revision 2, dated August 13,198 Work Orders M3 96 07414 and M3 961420 Calculation No. P(B) 1130, " Temporary Ventilation for CCP Pumps Area During Loss of Primary Ventilation Due to a Fire," dated July 30, 198 b. Observations and Findinas Functional Testing of Alternate Shutdown Capability The NU fire protection staff was unable to provide documentation that the Alternate Shutdown Panel and its isolation transfer switch capability had ever been functionally tested either during the original stortup of Unit 3 or since that tim Additionally, NU did not have a test procedure in effect to perform such testin Surveillance Testing of Safe Shutdown Components Operability requirements for Fire Related Safe Shutdown Components were found to be addressed in Section I, " Fire Related Shutdown Components," of the Technical Requirements Manual. However, surveillance procedures necessary to address TRM surveillance requirements have not yet been developed. AR 96002527 has been initiated to develop new surveillance procedures prior to restart. NU was unable to provide information to confirm that fire-related shutdown components delineated in the TrtM had been tested. Additionally, AR 96002527does not specify performance of the new procedures prior to restar J
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Testing of Temporary VentNetion Equipment in NERM 64, Revision 1, Section 5, " Reactor Coolant System Boration Seal Water injection _ Summary," the analysis indicated total loss of charging may result from a fire in the Auxiliary Building which damages either both charging pump cooling pumps (CCE) on the 24 ft. 6 in, elevation, or the charping pump ventilation supply fans on the 66 ft. 6 in, elevation. Because the clearging pumps (CHS) are located in a confined space, they cannot be operated without cooling. The reactor plant component cooling water system (CCP) will be available for reactor coolant pump mechanical seal cooling and they can be operated for approximstely 1 % hours without ventilation.- NU considered this sufficient time to provide temporary ventilatio The inspector asked whether the temporary ventilation, which consisted of two
. 24 inch diameter, 6060 cubic feet por minute (CFM), electrically powered fans mounted in a frame sized to be placed inside a doorway, had ever been tested to
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verify the actual cooling capacity The fans were powered by a separate portable
- gasoline-driven electric generator. NU's Calculation No. P(B) 1130, " Temporary -
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Ventilation for CCP Pumps Area During Loss of Primary Ventilation Due to a Fire,"
July 30,1965, indicated that 10,660 CFM of ventilation would be required under ~
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design conditions to maintain a temperature of 110'F. With respect to actual testing, the fire protection stafi provided copies of Work Order M3 96 07414 and
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- M3 9614208 which Indicated only that the fans had been tested in the warehouse for a half hour until the gasoline driven generator ran out of fuel. The inspector concluded that the temporary ventilation had not been tested in plac , Conclualons The inspector conclud' ed, based on the information provided by_ NU personnel, that,' for the most part, the safe shutdown equipment had never been tested. For uthose components that could be verified to have been tested, the tests were inadequate to demonstrate that they coul_d perform their intended function. This issue remains unresolved pending completion of corrective actions ~and further
'NRC review for enforcement action. (URI 50423/97 84-01)
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F2.21 Deslan Reviews and Modification Packanes at Unit 3
- a. - = Scone of inanection To evaluate whether changes made to MP 3 had resulted in a reduction of the sievel of protection from the effects of fires, the inspector reviewed the following documents:
? Engineering Self Assessment of the Fire Protection / Appendix R Program, Millstone Nuclear Power Station, Unit No. 3, Engineering Self Assessment Report (ESAR), ESAR PES 97 0006,Rev. O, dated April 12,199 .
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- Nuclear Group Procedure (NGP) 5.12 " Performance of Fire Protection Reviews," Rev. 7, dated December 1,199 * NGP 5.24, " Maintenance of Appendix R/BTP 9.51 Program," Rev. 5, dated November 8,199 * Design Change Notice (DCN) DM3 00 0620 97," Throttling of Valves 3CDS V76 and 3CDS V131."(with " Figure 7.3 10CFR 50.59 Safety Evaluation Screening," Activity No. DM3 00 0620 97,07/28/9 Minor Modifications (MMOD) M3 96596, Rev. O,07/17/97,"CO2 Abort and Discharge Switches."
- MMOD M3 970549, Rev. O,07/27/97," Addition of Battery Voltage Adjusting Rheostat to 3FPG PNLO1 & 3FPG PNLO2."
- MMOD M3 97560, Rev.1,07/97, " Interconnect Main, Normal, and Reserve Transformer Dikes."
- MMOD M3 96294, Rev. O,07/03/97," Cable Tray Covers and Penetrations."
- Design Change Request M3 97036," Install Mounting Hardware for Future Emergency Lighting for Appendix R Program (Early Release),"
07/08/9 Memorandum " Licensing Basis Review of DCR M3 97036,07/30/9 Plant DCR No, MP3 93 082," Installation of Rockbestos "Filerone R" Cable in raceway 3CC900PB to replace Thermo Lag Barrier," dated June 1,1994, Observations and Findinos At the request of the inspection team leader, the NU fire protection staff provided ,
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modification packages directly related to fire protection or post fire safe shutdown and initiated since the last refueling outage. The NU fire protection staff indicated that there were 130 modification packages in process for Millstone Unit 3 since the last refueling outage in 199 The NU staff acknowledged that modifications performed prior to 1996 were not consistently subjected to a comprehensive review for their impact on fire protection or post fire safe shutdown capability. A potential contributing f actor for this deficiency is described in NU's self assessment of the fire protection program, )
" Engineering Self Assessment of the Fire Protection / Appendix R Program, l Millstone Nuclear Power Station Unit No. 3," dated April 12,1997. Specifically, '
in a discussion of the fire protection organization, this evaluation notes that the existing organization places the day to-day responsibilities for the fire protection l
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and post fire safe shutdown programs to individuals in the Design Engineering and Technical Support Department. Since these individuals typically have multiple program assignments involving engineering functions having a relatively limited scope (i.e., mechanical, electrical, or system specific engineering), NU's self
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assessment was concerned that they may not have a sufficiently detailed background in regulatory fire protection and post fire safe shutdown compliance program development and Implementatio As part of its corrective actions, NU la providing additional training for individuals l responsible for determining if a proposed modification could adversely affect the post fire safe shutdown capability or impact the fire protection progra Additionally, NU is verifying and/or upgrading existing fire protection programmatic controls.' Specific examples include recent revisions to procedure NGP 5.12,
" Performance of Fire Protection Reviews," which defines the process for performing fire protection reviews of plant changes, and procedure NGP 5.24,
" Maintenance of Appendix R/BTP 9.51 Program" which provides instruction for evaluating the impact of proposed modifications on safe shutdown methods described in the BTP 9.51 Compliance Report. NU has also developed two new
. fire protection program instructions (Pis) which were in " Draft" form at the time of
. the inspection. However, due to their draft nature, the team did not review these two program instruction To evaluate the potential impact of modifications on the plant's fire protection licensing basis, several modification packages were selected for review. Specific modifications reviewed are identified in the inspection scope paragraph abov Except for the_following observation, the inspector did not identify any apparent weaknesses in the modification packages which would indicate any unidentified-impacts on the existing fire protection or post fire safe shutdown capability of the plan Plant Design Change MP3 93 082," Installation of Rockbestos Firerone R Cable to Replace Thermo Lag Fire Barrier," was initiated to remove the control cables of the Containment Fire Protection Water Isolation Valve (3FPW'CTV49), which were
_ protected by a Thermal Science Inc. (TSI) Thermo Lag fire barrier and replace them with Rockbestos Inc. Firerone R cable. The Rockbestos cable is qualified in accordance with IEEE 3831992 and IEEE 3231990 for Class 1E service and meets a one hour fire rating por ASTM standard E 119 testing. While the
' inspection team did not identify any technical deficiencies'with this modification, it noted that the removal of the Thermo Lag fire barrier material may result in a different configuration than that described in the plants licensing basis as
' documented in SERs issued by the NRC staff. The NU fire protection staff agreed to review and update its licensing basis as necessary to provide a clearer understanding of the final plant configuration, c.- Conclusions
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Based on the sample of modification packages reviewed, the inspector concluded
- that NU's current process for reviewing design packages is effective in identifying impacts on the existing fire protect!on or post fire safe shutdown capability of the
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F Temocrarv Modifications at Unit 3 Scoos of insoection To evaluate the effectiveness of reviews of temporary modifications for their effect on fire protection, the inspector requested a copy of the current log of open temporary modifications, and selected those which appeared as though they could affect post fire safe shutdown equipment or methods. Specific documents reviewed were:
Procedure WC 10, " Jumper, Lif ted Lead, and Bypass Control,"
Rev. O, dated April 29,1994, and changes through Change Request No. 6, January 3,199 '
Jumper Device Control Sheet (ACP OA 2.068) 3 93152. "CCP RTDe for RCP Thermal Barriers.'
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Procedure WC 10, Revision 0, Attachment 5, Jumper Device index Sheet for 3 93 152.
l Stop 1.6 of WC 10, Revision 0, included the following instructions which formed the basis for the review of handling of temporary modifications:
1. PROVIDE a copy of " Jumper Device Control Sheet (s)" installed greater than 3 months to o Operations Manager....
1. PROVIDE a copy of " Jumper Device Control Sheet (s)" installed greater than 6 months to the Unit Directo . ENSURE PORC reviews and approves all " Jumper Device Control Sheets" for jumper devices Installed greater than 3 months and beyond their expected removal dat . MAINTAIN copy of PORC reviews for active jumper devices installed greater than 3 months with " Jumper Log Book."
1.6.10 REVIEW all jumper devices installed greater than 3 month .6.11 DOCUMENT review in PORC minutes stating 1 of the following:
The continued need for jumper device and expected future restoration dat * Requirement to remove jumper device and estimated removal dat * Need to convert jumper device to a permanent design change and estimated PDCR implementation dat .
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6 Obaaryations and findings NU had in effect Station Procedure WC 10, " Jumper, Lifted Lead, and Bypass Control," Revision 0, Unit 3 effective date June 6,1994. This procedure had six Procedure and Form Change Request forms in effect, Change No. 6 being effective January 3,1997. The licensee acknowledged past weaknesses in the area of temporary modifications and indicated that a revision to procedure WC 10 was in draft form. In view of its draft nature, the inspector did not review the revised i version, u ..
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In view of the procedural requirements, the inspector reviewed the current Attachment 5, " Jumper Device Index Sheet," which is part of Procedure WC 10, Revision 0, as maintained by the Control Room. The attachment indicated that
- jumpers were installed, on certain nonsafety related equipment, as far back as 1966, and still not restored. The inspector selected one example, Jumper N , "CCP RTDs for RCP Thermal Barriers," which was installed on October 8,1993, and restored on July 22,1997, to determine if this jumper had any effect on post fire safe shutdown capability for a fire inside the containment building. The purpose of this modification was to monitor the thermal barrier performance of all reactor coolant pumps. The modification consisted of installing a abort piece of insulation on the pipes on the outlet side of the component cooling water from the reactor coolant pump thermal barrier, together with -
clamping of resistive temperature detectors (RTDs) to the pipes and the insulatio The jumper package of documentation provided by NU correctly included an Unreviewed Safety Question Determinatio Although the possible impact on post fire safe shutdown capability was not .
specifically addressed in the USQ determination, it did not appear to the inspector
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that this modification had any significant impact on post fire safe shutdown capability.- However, the inspector was concerned with the duration of the jumper modification, of almost four years, in view of the draft nature of the current revision to procedure WC 10, the inspector was not able to draw any conclusions -
on the potential effectiveness of NU's future jumper control program with respect to assessing imnect on post fire safe shutdown capability and fire protection features, although the NU fire protection staff readily admitted that the previous program was Mt con ** t dy effectiv c.- Conclualons The inspector found the temporary modification process weak in that evaluation of impact on fire related safe shutdown equipment was not specifically required. NU had previously identified this problem, and had initiated corrective actions. This
. Issue remains unresolved pending completion of corrective actions and further NRC review for enforcement action. (URI 50 423/97 84-01)
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F3- Fire Protection Procedures and Documentation i F Unit 3 Emeraancy Ocaratina Proceduras for Pont Fire Safe Shutdown
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The inspector reviewed Emergency Operating Procedure (EOP) 350g, Rev.13, Fire j Emergency, dated March 21,1997, to determine if licensing commitments j regarding tripping fans for fire dampers which could not close against flow were i
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being maintained. In addition, the inspector evaluated whether the procedure ;
provided adequate guidance regarding required actions and protected instrument !
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channels for dealing with any fires which might occu Ohaarvations and Findinas f; Supplement 4 to the Safety Evaluation Report (SER) for Millstone Unit 3 (SSER4), ,
in Section g.5.1.4, describes deficiencies with Ruskin fire dampers, which ,
prevented their closure with flow in the ducts. Reference is made to a prior 4
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commitment by NU to implement shutdown procedures for those damps.: that cannot be effectively modified or repaired. Review of this commitmentis *
documented in NRC Inspection Report 50 423/85 69,Section 2.2, which states !
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"The applicant identified the dampers involved and revised the Emergency Operating Procedure 350 (sic) to include the step that, in the event of a fire, the associated verification (sic) fan will be turned 'off'." l
Section g.5.1.4 of Supplement 2 to the Millstone 3 SER (SSER2) documents a i commitment by NU that "...the station emergency shutdown procedures will specify the manual actions required and will address manpower requiremnnts."
The NU fire protection staff acknowledged that previous implementation of safe ;
shutdown requirements and commitments into plant EOPs was not effectiv insights from the FPER, which call out manual actions for particular fire areas, .;
were not carried over to the EOPs. NU is now performing a maior revision to -
Emergency Operating Procedures for fire events (EOP 350g, Fire Emergency) to ' ,
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incorporate all fire area evaluations contained in the BTP g,51 Compliance Repor NU fire protection staff is developing thirty two (32) separate attachments to EOP ,
'350g, one for each of the analyzed fire areas. At the time of the inspection, the
- NU fire protection staff was in the process of developing the new EOPs. They were not evaluated due to being draft document Table 1 of Revision 13 to EOP 350g contains a listing of specific fire areas <
containing ventilation units. The table directs tripping certain of the ventilation units in the event of a fire in that area, to allow fire damper closur >
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8 Conclusions The inspector determined that earlier implementation of the licensing commitments to include fire protection actions in the EOPs was ineffective. Efforts are underway to implement the licensing commitment to specify manual actions in the station emergency procedures. This issue remains unresolved pending completion of corrective actions and further NRC review for enforcement action (URI 50 423/97 84 01)
F Unit 2 Fire Protection Surveillance Reaulrements Scoos of insoection The inspectors reviewed the Surveillance Requirements for certain Fire Protection System Limiting Conditions for Operation (LCO) stated in the Technical l Requirements Manual (TRM). Those surveillance requirements were also reconciled with the details of implementing surveillance procedures for fulfillment of these requirements. Specific equipment of interest were: fire protection l
' components within the reactor containment, contrul room, turbine building cable vault, East and West DC equipment rooms, East and West cable vaults, East and West battery rooms, diesel generators and diesel genarator day tank rooms.
I Observations and Findinos
, The inspectors selected LCOs for fire detection instrumentation, suppression water j and sprinkler systems, halon fire suppression and fire barriers and traced the LCO
! and surveillance requirements through the surveillance procedures. The inspectors
} noted that, with few exceptions, the fire protection survell lance procedures fulfilled the TRM surveillance requirements and verified system or component operability. A listing of the surveillance procedures reviewed is provided at the end of this repor Fire Detection Fire detection instruments are identified by the TRM for each zone. The surveillance is a channel functional test conducted at least once every six month The inspectors noted that the data sheet for the channel functional tests of smoke detectors located inside of the reactor containment, Form 2618C 2, was titled
" Fire Protection System Smoke Detector Test (REFUEL)." The TRM surveillance frequency for section A.4.1 is each cold shutdown exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless performed in the previous 6 months. However, the inspectors confirmed that NU had been performing this surveillance every six months by review of completed surveillance data sheets, on other than on a refuel interval as specified 3 the procedure titl .
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Fire Barriers . Ventilation Dampers The TRM requires that all fire rated assomblies (walls, floors /collings, cable tray enclosures, and other fire barriers) separating safety related fire areas or separating portions of redundant systems important to safe shutdown within a fire area and all sealing devices in fire rated assembly penetrations (fire doors, fire windows, fire dampers, cable, piping, and ventilation duct penetration seals) shall be operabl The fire rated assemblies and penetration naling devices are to be verified operable by visualinspection. Fire dampers are to be inspected at least once per eighteen months. Although the intent of the TRM is to verify operability of all dampers by visual inspection at least every eighteen months, the scope of the visual inspection is no'. defined in that documen The inspectors found that surveillance procedure SP 2618G implemented the TRM for determining fire damper operability. This is accomplished through visual inspection of the dampen. The pmcedure established that the dampers be visually inspected by removal of , .spection covers, its acceptance criteria was that the fire dampers be free of debris and damage, which may prevent the damper from fully closing, that the damper be open with a fusible link in plUe and that there be no indication of corrosion in the track area that could cause damper failure. The inspectors noted that the procedural requirement was for a minimum of 50% of each damper track to be inspected for damage, debris and oxidation that would prevent the damper from fully closing. The procedure further clarified the intent of the inspection was to examine the entire track using reasonable efforts such as use of a flashlight and extension mirror, and established a 50% minimum J inspection of each damper trac The completion of the fire damper visualinspection was to be recorded on surveillance data sheet, Form 2618G 1, by date and initial. The inspectors noted that there was no provision to record the details when individual dampers could not be fully inspected. Without this information, there was no record of the frequency and circumstances of partialinspections. The inspectors inquired as to the supporting basis that allowed a partialinspection of the damper tracks. The licensee was not able to provide an engineering basis that sanctioned partial inapections but acknowledged the value of additionalinspection detailin the data sheets. The lack of a technical basis for accepting less than full track inspection is an unresolved issue which will require resolution and subsequent NRC review for enforcement actions. (URI 50 336/97 84 02)
The inspectors further noted that procedure SP 2618G, section 6.2, required a closure test of 10% of the fire dampers at least every eighteen months. The test was to be conducted with flow if less than 5,000 cfm, and any failure resulted in testing an additional 10% population, in the case of multiple failures, progressive testing continues until all of the dampers in a sample are acceptable or 100% of the dampers are inspected. This functional test is in addition to the TRM required visualinspection. Although the relationship with the visualinspection of fire damper tracks was not specifically addressed by the licenne, the inspectors concluded that this test, coupled with the visualinspections, improved the likelihood that the dampers would work as designe ,
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The inspectors performed a visualinspection of accessible dampers in the DC Switchgear Rooms, Battery Rooms, Cable Spreading Room and the 4160 volt cable tunnel. All dampers were clean and free of debris and the track areas could be observed with an extension mirro Fire Barriers Penetration Seals The TRM surveillance for penetration seal operability is a visualinspection of at least 10% of the total number of seals. The sample is to be increased to an additional 10% sample if any secs are found to be ineperable. Sampling continues until all of the seals in a sample are found operable or 100% of the seals are inspecte The inspection of fire penetration seals is made in accordance with the requirements of procedure SP 2734D. The current version of that surveillance, Revision No. 4, Change No.1, is under revision and was placed in a 'Do Not Use" status on August 31,1997, as defined by administrative procedure DC1 because of known deficiencies. The inspectors reviewed this embargoed procedure and a recent audit to learn of the licensee identified deficiencie The triennial audit of the fire protection program by the licensee's Oversight organization (Audit No. A24057)ldentified several deficiencies with this surveillance relating to accuracy its identification of boundaries, procedural allowance for visual inspections without ladders or scaffolding, and inadequate documentation of the 10% sample. The procedure is currently under revision to correct the deficiencies identified in the audi The inspectors noted that the TRM fra operable fire assemblies is not implemented through a surveillance procedure. They were informed by the licensee that the area inspections of penetrations were assumed to provide an opportunity to identify deficiencies in walls, floors, ceilings, cable tray enclosures, and other fire barriers. However, SP 2734D did not specifically address this type of inspectio The lack of specific guidance for these inspections remains unresolved pending completion of corrective actions, and subsequent NRC review for enforcement action. (URI 50 336/97 84 02)
The inspectors performed a visualinspection on a sample of penetrations in walls or ceilings in the cable spreading room. There were no deficiencies identified with either penetration seals or fire assemblies that were inspecte Fire Barriers Fire Coating and Fire Board The integrity of fire coatings is verified through SP 2618L. The procedure provides location guides for coatings used over structural steel and for coatings used to protect cable trays, conduit and cable _ _ - _ - _ _ .
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Fire ooard is used to protect some cable trays in the auxillary building and the East cable vault. The inspector noted that cable tray fire board is inspected through a preventive maintenance (Maintenance Form 2701J 93) action and not by a surveillance. Scheduling and deferral of preventive maintenance is through a different process than used to schedule and track completion of surveillance action The inspectors examined the condition of fire coating and fire board installed in the cable spreading area. There were no deficiencies identified, c. Conclusions With few exceptions, the licensee's procedures implemented TRM surveillance requirements. Although the licensee functionally tests at lent 10% of the fire dampers every eighteen months, the TRM surveillance requirement for visual inspection was defined within the surveillance procedure as intending full inspection of damper tracks but allowing a 50% minimuminspection of each track. The surveillance records do not record when this allowance was used in the past. There was no technical basis for accepting less than fullinspection of a fire damper. The surveillanca procedure for penetretinn seals had been placed in a
"Do Not Use" status by the licensee because of documented defic! wins Neither this nor other fire systams surveillance procedures documents inspection of tire assemblies. That is walls, floors, ceilings, cable tray enclosures and other fire barriers separating safety related fire areas. Fire board is used to protect some cable trays, but is inspected through use of a proventive maintenance action rather than a surveillance procedur F3.3 Unit 2 Fire Protection Alternative Shutdown Caoability
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f The inspectors reviewed the abnormal operating procedures for shutdown in the event of a fire within the cortrol room that leads to personnel evacuation, b. Observations and Findinos Abnormal operating procedures AOP 2579A and 2579AA state the process to achieve Hot Standby and Cold Shutdown, respectively,in the event of a fire in the control room. The current versions of those procedures are Revision No. 6, Change No.1, and Revision No. 3, Change No. 4. Both were under revision during the inspection and were both placed in a "Do Not Use" status on October 4,1996, because of known deficiencies. This process is defined by administrative procedure DC1. The inspectors reviewed those embargoed procedures and the relevant Adverse Condition Report to understand the licensee identified deficiencie U
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The licensee identified discrepancies between the Appendix R Compliance Report and the calculations on which the report was based. The assumptions used for some of the calculations were also questioned. These deficiencies were documented within Adverse Condition Report ACR M2 96 0588,which was dated November 1,1996. Calculations provided the basis for the abnormal operating procedures and modeled the transient making use of the Appendix R safe shutdown equlpment. This was necossary because licensee did not provide replacement instrumentation for monitoring all plant parameters, in a few cases c,aiculations were made to bound some parameters. The following are not monitored: No.1 steam generator level; service water, reactor building closed cooling wtter and shutdown cooling systems flow, pressure and temperature. The ACR detailed deficiencies including the calculation for refilling a dry steam generator with auxiliary feedwater, and for reactc pressure control to provide adequate subcooling without the use of pressurizer heaters. The ACR also documented differences between the licensing configuration and the design configuration in that safe shutdown equipment identified in the Appendix R compliance report did not include all plant equipment referenced in the Final Safety Analysis Report and in the NRC Safety Evaluation Report. For example, NU determined that the FSAR requires that the safety injection tank outlet isolation valves be closed during a plant cooldown. These valves, however, are not identified as Appendix 3 safe shutdown equipment, and may not be accessible in the case of a control room fir NU also determined that the NRC Safety Evaluation for Millstone Unit 2 Appendix R compliance makes reference to plant procedures which specify the use of pressurizer heators, if they are available, and to high pressure safety injection system components. This equipment, however,is not identified as Appendix R safe shutdown equipment, in addition, an Appendix R compliance report calculation for reactor coolant system subcooling without the use of pressurizer heaters assumes that there are no pressurizer in-surges and out surges. Following their most recent review, NU does not bellove that this is very likely for a cooldown from outside the control roo Other equipment that is required, but not identified as Appendix R safe shutdown equipment, included the safety injection header check valvo leakago drain stop valves, the service water stralners, and flow, pressure, and temperature instruments used to monitor the service water, reactor building closed cooling water, and shutdown cooling system The in-place abnormal operating procedures were found to be reasonally detailed despite the above deficiencies. The procedure did not detail the deployment logistics of the minimum sift personnel, but appeared to be within reach of three two person team The inspectors were informed that the verification and validation process for the replacement procedure would include simulator evolutions to develop an event time line and also in-plant deployment of the minimum shift personne .
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c., Conclualons .
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Licensee' identified deficiencies resulted in placing the abnormal operating i
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proceduros for control room fire in a "Do Not Use" status. Following resolution of
, those issues, NU plans to verify and validate the procedures using both the-simulator _and in-plant walkthroughs. This matter remains unresolved, pending - ,
completion'of the revisions, verifications, and subsequent NRC review for enforcement action. (URI 50 336/97 94-02) ~ l i
F3.41 Unit 2 Potential for Loss of Remote SbjfA&1 Canability l v
- ' Scone of insoection- j
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t 6 The ir.spectors reviewed the licensee's actions taken in response to NRC L .;
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information Notice 9218:: Potential for Loss of Remote Shutdown Capabilit i During a Control Room Fire, dated February 28,1992.
l - b. : : Observations and Findir}gg i
The NRC Information Notice provided details about'a condition which could cause _ motor-operated valves (MOV) to reposition and fail due to a fire-induced hot shor The condition was described with a specific control circuit configuration and: ;
- motors 'without thermal overload protection.-
p s The inspectors discussed the issue with licensee representatives and reviewed an Engineering. Work Request, EWR No, M2 97158,to prcvide a design change' which- !
would correct the' potential hot short condition for sixteen MOVs. The final design configuration was not available during the inspection.- The licensee intends to :
a . make the change during this outage. The inspectors determined that the MOVs jz ? identified in the EWR included those listed in the TRM listing of Appendix R safe
,
shutdown related equipmen c; Conclusions
_ This Work is in progress. There was no material available to evaluate the design
' change. -This issue remains unresolved, pending completion of corrective actions, '
and subsequent NRC review for enforcement action. (URI 50-336/97-84-02) -
- F7 Quauty Amaurance in Fire Protection
l - F7.1 ' fire Protection Prooram Audits
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- Scone of incoaction i The inspector reviewed the reports of audits and assessments of the fire
- L protection program which were conducted during the past two years, to evaluate 4 the scope and depth of the audits, and the facility response to audit findings. Tha-specific audits reviewed were:
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QAS Audit No. A24050," Fire Protection," Millstone Station, dated August 16,199 QAci Audit No. A30339," Appendix 'R' (CMEB BTP 9.51) Fire Protection," Millstone Unit 3, dated March 6, 199 Nuclear Oversight Audit Package A24057/A25119," Triennial Fire Protection Program Millstone and Connecticut Yankee," dated March 10,199 .
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Engineering Self-Assessment of the Fire Protection / Appendix R Program. Millstone Nuclear Power Station, Unit No. 3, dated April 12,1997, b. Observations and Findinos Due to the number and magnitude of the deficiencies NU has identified in the fire protection program, the audit frequency has been increased to every six months, to track and document progress of corrective action Observations regarding specific audit reports are provided below, grouped by the audit report number:
Audit No. A24050," Fire Protection," Millstone Station The audit was conducted to satisfy Technical Specification (T.S.) requirements 6.5.3.7.d. The audit identified four programmatic weaknesses in fire protection, and one in material control. The fire protection programmatic weaknesses included inadequate scheduling of and participation in unannounced fire drill This was a repetitive issue in that the audit report states that the issue was previously identified by NRC. The material controlissue involved the use of non-k quality assured (QA) material for making temporary modifications to fire protection system The audit findings which were not resolved during the course of the audit were documsnted in Adverse Condition Reports (ACRs), which require reportability evaluations, root cause analyses, and corrective action Audit No. A30339," Appendix 'R' (CMEB BTP 9.5-1) Fire Protection," Millstone Unit 3 The audit was conducted to verify that Unit 3 had correctly implemented the program requirements to ensure the capability to perform a shutdown and cooldown in the event of a fire in the facility. This audit also had repetitive findings related to the ciming of emergency lighting units (ELUs) from 1991 and inadequate definition of positions and responsibilities from 199 . . . . . .
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The audit concluded that some corrective actions for previous audit findings had not been timely, because they were still not completed several years later. No new ACRs were generated in response to this audi Nuclear Oversight Audit Package A24057/A25119," Triennial Fire Protection Program Millstone and Connecticut Yankee" This review was conducted by the Audits and Evaluation Group to satisfy the requirement of Technical Specification 6.5.3.7,0, that the fire protection equipment and program implementation be reviewed using an outside independent fire protection consultant or a qualified offsite licensed fire protection engineer, at least once everf 't4 month The auditors concluded that there was a lack of attention to the fire protection program at Millstone, and there was no assurance that Millstone Unit 3 could perform a safe shutoown after a fire. The audit identified a number of deficiencies throughout the fire protection prograrn. Those documented in the audit report include:
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Nuclear Group Procedure (NGP) 2.14, " Nuclear Plant Fire Protection Program" has not been updated regarding the organizational structure for the fire protection program for several years. This is a repeat of a 1996 NRC findin Annual updates of the Fire Hazards Analysis for each of the units have not been performed as required, in addition, combustible loading calculations are in error, for all three units. This issue was identified during a March 1996 audit of Unit 3, and is documented in ACR 8830. Corrective actions were not yet complete Surveillance procedures for some Unit 3 safe shutdown equipment had not been develope While procedures provide guidance on revising the TRM, none describe the required content. Some fire protection equipment which should be in the TRM is not (such as some Unit 2 smoke detectors and the materials to install the spare component cooling pump motor in Unit 3). The Unit 3 TRM did not contain a section designating surveillance testing and limiting conditions for operation (LCOs) for safe shutdown equipment. Several of these issues are repetitions of issues identified by Unit 3 engineering in 1995 and a March 1996 audi Maintenance procedures for the Unit 3 ELUs were found to be inadequat _ . . . . . .
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The Unit 3 main generator exciter enclosure fire detection equipment had only been tested twice since initial startup (1989 and 1995), and testing is required when the turbine is shut dow The original Unit 3 Safety Evaluation Report (SER) required the enclosure of 15 feet of supplementary leakage collection and release system (SLCRS) ductwork on the 69' elevation of the aaxiliary building with a fire barrier having a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating. The ductwork is provided with a 1-hour barrier. This was documented in NCR 387-085, and dispositioned to accept the 1-hour barrier. Change 87-MP3-20 to the Final Safety Analysis Report (FSAR) incorrectly approved the one hour barrie The requirement for a backup water supply identified in Supplement 4 to the Unit 3 SER (SSER 4), has not been appropriately incorporated l Into the Unit 3 TR Design modification packages consistently did not properly complete
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the fire protection checklist required by the DCM. The checklists were completed and included, but did not identify when safe shutdown equipment was involved, ignition sources were invc!ved, nor when combustible loadings would chang The site fire protection department performed a self-assessment in June 1996, and identified several weaknosses. Corrective actions for the weaknesses were not documented, and the site fire protection department was not successfulin getting their recommended corrective actions implemente Corrective actions for previous audit findings and unresolved items have not been effectively implemented. Examples from 1994,1995, and 1996 were cite Cable and tools necessary to accomplish cold shutdown repair activities specified in Emergency Operating Procedures (for installation of spare CCP pump motor) were missin Failure to maintain the analysis of electrical protection provided for cables which share a common enclosure with cables of equipment required for post-fire safe shutdown (Common Enclosure Analysis).
The Audits and Evaluation Group documented the audit findings in Adverse Condition Report (ACR) M3-97-0176. This ACR was characterized as Significance Level B, and assigned to the Unit Directors, Manager Programs and Engineering Standards, and Site Fire Protection for development of corrective actions and schedules for completion. The corrective action plan was reviewed by Audits and Evaluations in March 1997, and found to be unacceptable for a number of reasons, inc' Ming failure to address the causes of the identified problems, and downgrading of the ACR from Level B to Level . . . . _
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Engineering Self Assessment of the Fire Protection / Appendix R Program, Millstone Nuclear Power Station, Unit No. 3, ESAR PES 97 0006 This review was conducted as part of NU'o Pl 21 methodology for reviewin Engineering Topical Areas. This arsessment focused on the programmatic aspects of fire protection, and not equipment issues. The review was conducted by an independent team of outside consultants with fire protection expertise. Significant findings included:
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The interrelationships between fire protection features, administrative controls, surveillance procedures, safe shutdown equipment and cab!et, operator actions, and regulatory compliance strategies were not well defined.
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The technical and administrative controls applied to the program were implemented in a haphazard fashion, depending on the work load of the responsible personnel.
, Conclusions Based on the reviews of the audit findings, the insperLr determined that the audits of t te fire protection program have been effective in identifying deficiencies and identifying corrective actions. The corrective actions, however, have not always been effective in resolving the problems, nor prevent!ng recurrence. This issue remains unresolved, pending completion of corrective actions and subsequent NRC review for enforcement actions. (URI 50-423/97-84-01)
-l F8 Miscellaneous Fire Protection lasues F Comoliance With Licensino Basis S. cone of Insoection To evaluate the conformance of the fire protection program to the licensing
. commitments, the inspector reviewed the following documents:
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NU Letter to NRC, 10/21/85," Response to Open item 14.3, Request for Deviation from BTP CMEB 9.5-1 - Auxiliary Building Separation Criteria."
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NU Letter to NRC, 11/04/85," Audit Open items and Additecel Information to the Request for Deviation from BTP CMEB 9.5 NRC IE Inspection Report No. 50-423/85-69, November 12-14,20-22,25 27,1985: Closure of Unresolved item (50-423/85 53-03)
" Fire Protection for Areas That Do Not Meet the Guidelines of BTP 9.5-1."
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NUREG 1031, Millstone Point Unit 3, Safety Evaluation Report, through Supplement No.' Millstone Point Unit 3 Compliance Book, Revision 0, " Auxiliary Building Fire Area AB-1 Appendix R Exemption Request and Supplement," June 7,198 Millstone Point Unit 3 Compliance Book, Revision 1,'" Auxiliary --
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Buildir.g Exemption Deviations From As-Built Conditions."
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-Engineering Self Assessment of the Fire Protection / Appendix R
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- Program, Millstone Nuclear Power Station, Unit No. 3, Engineerin Self Assessment Report (ESAR), ESAR-PkS 97-0006,Rev. O, .
April 12,199 . Millstone Unit 3 Appendix R Audit Report, VECTRA Technologies Inc., _ 1 June 14,199 Northeast Utilities System Memorandum No. MP3 0 993, From-S. P. Fournier, Yankee Atomic Electric Company, To: S. J. Calig.ari,
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Unit 3 Design Engineering, dated December 5,199 Fire Protection Program Manual, Rev. 0; July 30,1997.-
b. . 1 Observations and Findinas -
As part of NU's current on-going self assessment program, the MP-3 Fire - ;
' Protection Evaluation Report has undergone several independent reviews for '
E
_ accuracy. Based on a determination that the original evaluation document, Fire
_. Protection Evaluation Shutdown System Availability Summary," Rev. 2, dated -
August _13,1985 (identified as "NERM 6_4"), which formed the licensing basis for MP-3,1was too cumbersome to use, maintain and update, in October 1990, NU contracted IMPELL Corp to review the existing analysis for MP-3 (NERM 64, H
- Rev. 2). The results of this review led to issuance of "BTP 9.51 Compliance Report Update," Rev 0, dated May 24,1991. From a subsequent review of this-document, NU discovered additional deficiencies including that the review-performed did not include a review of plant design changes for their impact on results and conclusions presented in the analysis. As a result, NU then contracted Yankee Atomic Electric Company (YAEC) to perform a validation of BTP 9.5-1 -
Compliance Report, Rev 0. The result of this effort led to the issuance of Re of the Compliance Report, dated October.20,1993. The 9.5-1 Compliance Report
- was intended to replace NERM 64 and was issued as a controlled document. NU '
engineering personnel stated that the analysis revisions which led to the issuance of the 9.5-1 Compliance Report Update, Rev.1, were editorialin nature and that the post fire safe shutdown compliance strategy presented in NERM 64 and reviewed by the staff has not been altere _
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The current version (Rev 1) of the BTP 9.5-1 Compliance Report Update has been subjected to two separate independent reviews. One audit was conducted by VECTRA,in June 1996, and another was conducted by a team of YAEC and-
- Engineering Planning and Management (EPM) representatives. The results of the most recent audit are documented in " Engineering Self Assessment of the Fire Protection / Appendix R Program, Millstone Nuclear Power Station Unit No. 3,"
dated April 12,1997.- This evaluation was found to conclude that both Rev. 2 to .
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NERM 64 and Rev.1 to the Millstone Unit 3 BTP 9.51 Compliance Report-accurately represent that the design basis for post fire safe shutdown are based on compliance with BTP CMEB 9.5 .s inspector's review of the shutdown methodology described in Rev.1 of the 9.51 Compliance Report did not find it to differ significantly from the post fire shutdown methodology and equipment presented in the original analysis (NERM 64). However, the inspector's review of Attachment A, "SSD Equipment -
Physical and Cable Separation Analysis," to BTP 9.5-1 Compliance Report, Rev.1, dated October 20,1993, indicated that this portion of the analysis had not received a comprehensive review. Specifically, Attachment A, which was prepared to provide a description of systems having equipment located in primary reactor containment (fire area RC 1) that could be affected by a fire in the RC-1 area (RCS Letdowr; RCS Boration; RCS Depressurization; Process instrumentation, Residual Heat Removal) was found to contain several apparently outdated and inaccurate statements regarding the actual current configuration of certain process instrumentation systems. Specifically, section 4.5.1 of this attachment was found to indicate that cables and conduits for core exit thermocouples and RCS loop cold leg temperature elements were not yet physically routed. In response to this observation, the NU fire protection staff initiated DCN DM3 021134-97to review-and revise Attachment A as necessary to more accurately reflect the configuration of safe shutdown equipment it describe ' The analysis performed to demonstrate the ability to achieve and maintain safe shutdown conditions in NERM 64 and the BTP 9.5-1 Compliance Report relies heavily on the accuracy of cable routing information in the cable routing databas The inspector requested copies of the documentation for the contrr ,, on and '
verification of the database. NU could not provide any document ~ which would demonstrate that the cable routing database information was ever verified by'walkdown or other methods, to ensure that the database ' = .ately depicts the as installed configuration of cables in the plan ' Conclusions The inspector concluded that the post-fire safe shutdown program as currently described in the BTP 9.5-1 Comp;iance Report for MP-3 is in compliance with the licensing commitment _ - _ _ _ _ - - _ _ _ - - ---
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V. MANAGEMENT MEETINGS X1 Exit Meeting Summary The results of the inspection were discussed with members of your staff at a meeting conducted September 19,1997. At that time, the findings were not conteste PARTIAL. LIST OF PERSONS CONTACTED Northeast Utilities D. Amerine, Vice President, Nuclear Engineering and Support S. Scace, Director, Engineering Programs B. Wilkins, Manager, Programs and Engineering Standards
. E. Groover, Manager, Plant Support and Nuclear Oversight E. Kleinsorg, Fire Protection Coordinator J. DiMarzo, Supervisor, Technical Programs J. Regan, Senior Design Engineer P. Raimondi, Senior Design Engineer l H. Durrani, Senior Design Engineer
! J. Mangeno, Fire Protection Engineer
! J. Gianet, MP3 NRC Coordinator Nuclear Reaulatorv Commission
'A. Cerne, Senior Resident inspector MILLSTONE UNIT 2 FIRE PROTECTION PROCEDURES REVIEWED DURING THIS INSPECTION:
AOP-2579A, Fire Procedure for Hot Standby Appendix "R" Fire Area R 1; AOP-2579AA, Fire Procedure for Cooldown and Cold Shutdown /.ppendix "R" Fire Area R-1;
- SFP-5, - Fire Door Inspections (Site Fire Procedure];
SP-2412A, East DC Switchgear Room Halon Fire Suppression System Functional Test; SP-2412B, West DC Switchgear Room Halon Fire Suppression System Functional Test; SP-2413, DC Switchgear Room Duct Detector Operability Test; SP-2618A, Monthly Fire Protection System Fire Pump Automatic Start Test:
SP-2618C, Fire Protection Smoke Detector Test; SP-2618D, Fire Protection System Sprinkler and Deluge Design Functional Test:
SP-2618F, Fire Pump Performance Test; SP-2618G, Fire Damper Operability Verification; SP-2618L, Fire Protection Coating inspection; SP-2734D, Fire Penetration Seal Inspection; PM Form 2701J-93, Fire Board Inspectio i
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LIST OF ACRONYMS USED ACR Adverse Condition Report AOP Abnormal Operating Procedure Appendix R Code of Federal Regulations Titto 10, Part 50, Appendix R, Fire Protection Program for Nuclear Power Plants Operating before January 1,1979; AR Action Request APCSB Auxiliary and Power Conversion Systems branch ASTM American Society for testing and Materials BTP Branch Technical Position CCE Charging Pump Cooling Pumps CCP Reactor Plant Component Cooling Water System CFR Code of Federal Regulations CHS Coolant Charging System CMEB Chemical Engtovering Branch CO2 Carbon Dioxide DCM Design Change Manual DCN Design Change Notice DCR Design Change Record ELU Emergency lighting Unit EPM Engineering Planning and Management ESAR Engineering Self Assessment Report EWR Engineering Work Request FSAR Final Safety Analysis Report
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IEEE Institute of Electrical and Electronics Engineers IP inspection Procedure IR Inspection Report LCO Limiting Condition for Operation l MMOD Minor Modification
} MOV Motor Operated Valve
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MP-3 Millstone Nuclear Power Station - Unit 3 NCR Non-Conformance Report NGP Nuclear Group Procedure NRC Nuclear Regulatory Commission NU Northeast Utilities Northeast Nuclear Energy Company Pl Program Instruction OA Quality Assurance RCS Reactor Coolar.t System RTD Resistance Temperature Detector SE Safety Evaluation SER Safety Evaluation Report SFP Millstone Site Fire Prc, 3ction Procedure SSER Safety Evaluation Report Supplement SLCRS Supplementary Leakage Collection and Release System SP Surveillance Procedure TRM Technical Requirements Manual Technical Specifications TSI Thermal Science incorporated UFSAR Updated Final Safety Analysis Report USQ Unreviewed Safety Question YAEC Yankee Atomic Electric Company
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E-1 FlHE PROTECTION AND POST-FIRE SAFE SHUTDOWN CONFIGUrtATION CONTROL INSPECTION REQUIREMENTS
'1, 50.59 Process. Review the licensee's 50.59 review process for conformance with the requirements of 10 CFR 50.59 (review of the application of the 50.59 process
- . to fire protection and post-fire safe shutdown configurations is addressed below). Design Reviews and Modification Packages i (a)- Modifications ' Evaluate the impact of selected post fire safe shutdown configuration
modifications performed since the plant's fire protection program was l : originally reviewed and approved by the NRC staff and inspected l: under IP 64100,- Ensure that fire protectim and post fire safe shutdown configurations have been mali ( e.e For plants that have adopted the standard fire protection license condition- .
(see GL 8610 and GL 8812), verify that changes made to the _ fire
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- protection program under the provisions of 10 CFR 50.59 do not adversely affect the level of separation and protection provided for redundant trains of shutdown equipment, invalidate the shutdown methodology approved in the staff's Fire Protection SER, or institute a new, but potentially unsuccessful safe shutdown strategy / methodolog The inspector should specifically verify that: !
(a) Changes in the plant's mechanical and electrical design were-appropriately evaluated for their potentialimpact on plant fire safety'
by qualified personnel,' knowledgeable in the reactor plant's safe shutdown analysis, (b) The modifications do not compromise the plant's ability to achieve and maintain safe shutdown conditions,
-(c) The installed mechanical and electrical configuration conesponds to the modification design requirements and ir. In agreement with the -
facility documents, and (d) Appropriate phisical separation and/or electrical isolation has been maintained between redundant divisions of equipment and cables required for post fire safe shutdow ,
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E2- Examples of fire protection configuration management program implementation lines of inquiry include:
(a)- New fire area boundaries or fire barrier penetetion (b) Changes to emergency lightin (c) Changes in access for manual fire fightin (d) Changes in automatic fire suppression systems (e.g., changes from wet pipe to dry pipe sprinkler system design).
, Verify that temporary modifications are tracked, controlled, and -
reviewed for their potential impact on fire safety and post fire safe shutdown capabil!'y by qualified operations, engineering, and fire protection personnel knowledgeable in the plant's safe shutdown and fire hazards analyses. Temporary modifications frequently involve the use of electrical jumpers in indication and control cabinets, and are-typically tracked in control room log books. The inspector should consider whether:
(a)- Potential fire hazards were or are being created due to the presencs of electrical jumper (b) The temporary modifications existed for the minimum duration practica (c) The temporary modifications potentially disabied the reactor plant'J safe shutdown capabilit . Review the activities of plant review committees with respect to fire protection and post fire safe shutdown configuration managemen . 4. . Review FSAR updates for selected plant modification END
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