IR 05000338/1988013
| ML20154J403 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/13/1988 |
| From: | Conlon T, Harris J, Hunt M, Ward D, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20154J392 | List: |
| References | |
| 50-338-88-13, 50-339-88-13, GL-86-10, IEIN-88-004, IEIN-88-4, NUDOCS 8809230016 | |
| Download: ML20154J403 (33) | |
Text
r i
..
,
p* *'49
'
y*
UNITED STATES
{'
j NUCLEAR REGULATORY COMMIS810N
'"
.
,
f REGION 11
[
o 101 MARIETTA ST., N.W.
l
%*e.... p*
ATLANTA. GEORGIA 30323 Report Nos.:
50-33S/8S-13 and 50-339/SS-13 Licensee:
Virginia Electric and Power Ccmpany P.ichmond, VA 23261 l
Docket Nos.:
50-333 and 50-339 License Nos.:
!
Facility Name:
North Anna 1 and 2 I
i Inspection Conducted: July 18 22, 1933 l
Inspectors:
& k. h
_
_
_ hNg I
J. Harr}
Date Signed f
if. W 9//.W88 i
D. Ward
~Date Signed l
.Yl3
-
rW G. Wisenan Date Signed-
,
l2$ $ W
-- -.
_$* l 3 ' N
'
Date Signed M. Hunt,,ean
'
e eer
.
,
Approved by
. _
h _
A>p,*, y g _
7 - / [4 - P7 1.
Conlon, Chief Oate Signed Plant Systens Secticn
!
Engineering Branch (
Division of Reactor Safety (
!
i
$ bvy,ARY j
Secpe:
This was an announced Triennial Postfire Safe Shutdown Capability Reverification and Assessment (Module 64150).
The tean assessed I
whether tne licensee has a functioning configuration management (
program as it relates to fire protection and postfire safe shutdown
!
capability.
The inspection verified whether the licensee has
!
properly raintained the postfire safe shutdown capability achieved
!
during the initial valication inspection previously conducted at l
North Anna on September 9-13, 1935.
l l
The inspection covered four major areas as they relate to Appendix R j
compliance and postfire safe shutdown capability including plant I
rodification review; reverification of Appendix R fire protection features; review of postfire safe shutdewn procedures and equipment; l
and, review of Generic Letter S6-10 engineering evaluations.
s
.
$$0"S0c$ SS0hD G
l
>
-
.
-
-
-
-
r E
. ' '
,
'
.
Emphasis was placed upon review of the plants configuration control
,
l program procedures as they relate to maintaining Appendix R compli-i ance and the postfire safe shutdown capability.
This inspection included review of postfire shutdown procedures; plant fire protection features and safe shutdown systems walkdowns; review of l
Generic Letter GL S6-10 engineering evaluations for fire protectien, and interviews of personnel at various corporate and site levels.
l The inspectors also reviewed NRC Information Notice No. SS-04, Inadeauste Qualification Documentation of Fire Barrier Penetration Seals, and evaluated the licensee's short term and programenatic actions in this area.
Results:
During this inspection, the NRC inspectors discussed the plant Appendix R configuration management program history with plant and corporate management.
The licensee's raponses to these discussions and results of this assessment indicate that the single wea) ness identified by the inspectors had been pr0viously identified by licensee management and that actions necessar/ to assure that similar problems with the configuration management control program for Appendix R fire protection do not reoccur.
In general, the licensee's configuration management program as it relates to maintaining Appendix R compliance and post fire safe shutdown capability was found to be adequate with several strong features. Management appears to be taking the appropriate actions to maintain Appendix R fire protection long term complianue. Therefore, based upon the satisf actory results of this inspection, a detailed 10 CFR 50 Appandix R compliance reverification inspection for North Anna is not warranted at this time.
Strengths and weaknesses are s m arized belew:
Strenoths It is apparent that VEPC0 management has made a strong I
-
co-mitment to ensure long term compliance with Appendix R f
and to maintaining the postfire safe shutdown capability.
This is evident by the VEPC0 managements approval and implementation of design. control procedures which include a detailed review 'to determine if the change will imoact l
Appendix R compliance and the postfire safe shutdown f
capability.
l
,
The licensee has included a detailed Appendix R Checklist I
-
'
in a
plant Standard.
Design Change packages and Engineering Work Requests must be reviewed to ensure compliance to the design criteria in the checklist.
The checklist is of sufficient detail to provide guidance to j
evaluate Appendix R and postfire safe shutcown capability I
concerns.
.
.
-
- - -
-
- -
- -
-
-
-
-
-
-
i t
..
,
i
!
i
t
.
)
!
-
!
i
.
The licensee's approach to the resolution of.echnical fire
!
-
protection concerns indicates a clear understanding of the
issues. This is evident by the quality of the engineering
!
.
evaluations prepared by the licensee's staff to document i
'
acceptability of deviations from NFPA codes.
'
The onsite engineering organization persennel are well-
-
!
informed on Appendix P design criteria.
This was evident
!
in the design change documents reviewed during the inspection.
Weaknesses j
.
A single weakness in the configuration management progran was j
l identified during the inspection. The weakness was in the area r
{
of Design Change Packages prepared by VEPCO contractors.
These
!
contractors eay not be fully aware of the potential impact of l
a design change on Appendix R compliance since they may not be
!
familiar with the postfire safe shutdown capability at North l
Anna.
This weakness appears to have been corrected by the
licensee prior to the inspection. Plant procedres now require
!
all Design Change Packages to be reviewed by VEPCO's Nuclear i
Engineering / Design Control Group who is responsible for ensuring i
l long term compliance with Apoendix R.
This weakness appears to
[
be the root cause for an inadequate Appendix R Checklist review
j of two Design Change Packages which resulted in the issuance of the enclosed violation, j
One violation was identified, Inadequate Evaluation of Appendix R
!
Checklist By VEPCO Contractor, Paragraph 2.a.(2).
l
One unresolved item was identified Entry Into Fire Area for Manual j
Operations of Safe Shutdown Equipment, Paragraphs 2.e.(5) and 2.e.(6).
!
i l
I
1
!
l
'
I
l l
,
!
t i
!
.
-
- -
- - -
-
.
... _.
_ _
.
_
,
j
..
,
i
-
.
!
'
,
!
REPORT DETAILS l,
i i
i 1.
Persons contacted t
l Licensee Employees
- W. Adams. Supervisor Plant Engineering i
- M. Bowling, Assistant Station Manager p
"R Carroll Senior Staff Engineer, Nuclear Engineering / Design Control
- R. Champagne, Configuration Control Engineer i
- J. Downs, Supervisor, Administrative Services
!
- A. Oriscoli, Manager Quality Assurance i
"G. Clowers, Nuclear Specialist l
- G. Gordon, Supervisor Electrica Maintenance
!
- 0. Heacock, Superintencent Technical Services l
'J. Hegner, Licensing Engineer I
- B. Jacobs, Supervisor Training l
- G. Kane, Station Manager j
- J. Kansler, Supsrintendent Maintenance
- P.
Lienhart, Ti ining l
- G. Mocarski, Station Loss Prevention Coordiaator l
- M. Phillips, Senior Engineer
!
- W. Robbins, Senior Engineer Corporate Loss Prevention
!
- L. Narnicki, Power Station Engineer, Fire l
'J. Wroniewicz, Supervisor Site Nuclear Engineering l
Other licensee erployees contacted during this inspectien included engineers, operators, technicians, and administrative personnel.
}
)
Other Organizations
- N. Hanley, Stone and Webster Energy Corporation
"R. Sheets, Stone and Webster Energy Corporation
,
- C. Sinopoli, TENERA Corporation NRC Resident Inspector i
"J. Caldwell i
i
- Attended exit interview i
i 2.
Assessment Of The Licensees Configuration Management Pregram j
Section 50.43 of 10 CFR SO requires nom h Anna tw comply with Sections III.G, III.J, ar.d III.0 of Appendi,: R Fire Protection Program I
for Nuclear Facilities Operating Prior to January 1,197s North Anna's Coxpliance r.h 10 CFR 50 Appendix R was initially serifi ' by the NRC
during an inspection cencucted Septe c er 9-13, 1935.
l
!
,., _
_
_
..
'
'
The purpose of this inspectiun was to determine whethei the licensee had developed and implemented a configuration management program which insures that Appendix R compliance and the postfire safe shutdown capability is maintained over the life of the plant.
If this inspection had determined that such a program did not exist or was not functioning 3 detailed inspection to reverify the licensees continued compliance with the requirements of 10 CFR 50 Appendix R would have been recommended, a.
Configuration Management Program In order to verify that the configuration management program related to Appendix R compliance and postfire safe shutdown capability was adequate, the inspectors conducted a detailed review of plant and corporate procecures governing the preparation and review of design change documents to determine:
that these procedures include provisions that ensure all desigr
-
chsnge documents are reviewed for Appendix R compliance and postfire safe shutdown concerns,
-
that these procedures provide adequate guidance for the reviewer to determine if there is impact on Appendix R compliance and the postfire safe shutdown capability, and
-
that these procedures include provisions to ensure that all design change documents which do impact Appendix R compliance r
and postfire safe shutdown capability are incorporated into the
,
'
analyses, procedures, and programs which support and implement this capability.
In addition, to verify the implementation of these procedures the inspectors selectively reviewed design change documents for modifications tc those plant systems required for postfire safe shutdown.
(1) Configuration Control Procedures Initially in the review of the design change program at North j
Anna, the inspectors established the methods by wnich a change
'
to the plant can be made.
Through discussions with plant personnel, three types of design change documents were identified.
,
Design Change Package (DCP)
Engineering work Requests (EWR)
,
Field Chcnge Request (FCR)
The following procedures governing the preparation and review of DCPs, EWRs and FCRs were reviewed by the inspectors:
,
I
,.
-
~-
\\
.
..
.
-
Procedures No./ Revision Title NOCM-3.21/Rev. 4 Design Change Package (DCP)
Preparation Guidelines NOCM STD-GN-0001/Rev 8 Instructions for DCP Preparation ADM-3.7/7-7-88 Engineering Work Requests NASE 0-002/Rev. 2 Field Change Processing STD-GN-0021/Rev.1 Appendix "R" Design Guidelines Physical changes to the plant are initiateJ by the preparation of a DCP or EWR, OCPs prepared in accordance with procedure NOCM STD-GN-0001 are required by Section 3.1 to have a review pe formed to insure the proposed modification conforms with current Regulatory requirements ' and other VEPC0 corporate positions on fire protection.
This review is conducted by the preparing engineer using the guidance provided in standard STD-GN-0021 which includes an Appendix R Checklist that must be completed and included in the DCP.
Presently, all 00Ps are required to be reviewed by Nuclear Engineering / Design Control group.
This group, located in the VEPC0 Richmond Corporate Office, has been assigned responsibility for long term compliance with the requirements of 10 CFR 50 Appendix R.
EWRs involving a plant modification are also required tc be reviewed against the design criteria outlined in the Appendix R Checklist.
However, this review is only required to be docu-mented in the checklist if it is determined by the preparing engineer that a change to the Appendix R Report is required.
The inspectors were concerned that EWRs which could effect Appendix R compliance ard the postfire safe shutdown capability would not get an adequate level of review since the preparing engineer and the Site Engineering Organization (SEO) are responsible for the Appendix R Checklist review.
The admin-1strative procedure governing EWRs does not require reviews by the corporate Nuclear Engineering / Design Control group.
The licensee representatives stated that the organization responsible for long term Appendix R compliance not being directly involved in the review of EWRs is not a weakness since
,
the Appendix R checklist is very detailed and provides adequate guidance to the prtparing engineer to evaluate Appendix R concerns.
The inspectors review of the Appendix R Checklist, Attachment 5.4 of standard GN-0021, co irmed the licer.see s position.
The checklist provides the reviewer with guidelines for determining if the modification has impact on:
i
...
.
.....
...
.
-
'
l*
.
~
.
the electrical separation of safe shutdown equipment /
'
-
'
components the coordinated circuit study
-
'
-
telecommunication system
-
cable
-
safe shutdown instrumentaticn
-
-
,
i
-
combustible loading
-
fire area boundaries fire protection systems l
-
fire barriers, fire stops, and radiant energy shields
-
safe shutdown required ventilation system
-
reactor coolant pump iube oil collection system
-
'
safe shutdown systems / components
-
The checklist appears to provide adequate guidance to ensure that DCPs or EWRs which do impact Appendix R compliance will be identified.
'
The inspectors also reviewed the training given to SE0 personnel on familiarization and use of the Appendix R program documents and tha Appendix R Checklist.
This training includes Basic y
Engineer Training (BET-12) provided for all new engineers entering the SEO. Further training is received through the SEO continuing engineering training and job performance programs.
The inspectors reviewed the required reading list for SE0 personnel and verified that the subject matter of the Appendix R program documents as referenced in Section 4.1.6 of Standard GN-0021 were included in the r1 quired reading for engineering personnel and those persons responsible for reviews of OCPs and EWRs. The inspectors determined the training to be adequate and effective to assure that site engineering organization personnel
are knowledgeable of the North Anna Appendix R Report and preparation of DCPs and EWRs.
FCRs are issued against DCPs to revise the DCP after approval by the North Anna Station Nuclear Safety and Operating Committee
,
(SNSOC).
Por Chapter V of Standard GN-0001, initiating a FCR
'
against a DCP requires that the entire OCP be reviewed to ensure i
the change does not adversely impact any section of the DCP.
'
This review includes a reevaluation of the Appendix R Checklist.
Provisions are provided in the procedures for processing DCPs
and EWRs to ensure that any changes required to the North Anna
.
Appendix R Report, plant procedures or any other supporting documents as a result of the design modification are.
incorporated upon completion of the modification.
l
,
,
_ -., -
-
- - -. _ -. -
- _ -, _... _ - - _,. _ - -
-.
_ - _,. _.
...
..
,
~
.
Based upon the inspector's review of the procedures and standards; Appendix R Checklist; and the SEO training program for Appendix R, the North Anna program established for configu-ration management of Appendix R compliance and the postfire safe shutdown capability appears to be adequate.
(2)
Implementation of Configuration Control Procedures The inspectors reviewed the following DCPs and EWRs in order to
verify that procedures for configuration control are being adequately implemented:
Number Description
'
DCP 83-24 Appendix R Emergency Diesel Generator Isolation DCP 84-56 HPSI Flow Transmitter Podification DCP 85-08 Inadequate Core Cooling Monitor System Upgrade DCP 87-01 and 87-02 Units 1 and 2 Steam Supply to Turbine Driven Auxiliary Feedwater Pump
'
Solinoid Operated Valve Relocation
,
EWR 84-36 Ecotech Study to Insure Non-Safety
Equipment Faults Will Not Cause Loss of Safety-related Power Boards and Feeders
EWR 84-785 Replace Fuses On control Transforner 480V MCC i
i
.
EWR 85-467 Control Circuitry to PORV Block Valves EWR 86-545 Replacement of Control Room Fire Door
!
EWR 87-339 Re'ocated Supply Fan for Unit 1 Chiller Room EWR 87-605 Replacement of Fuses in Emergency Diesel Generator Circuits
'
These DCPs and EWRs were prepared and reviewed ir, accordance
with VEPC0 procedures except, DCP 87-01 and DCP 87-02.
These two OCPs relocated the Solinoid Operated Valves (SOVs),
S0V-MS111A and B for Unit 1 and 50V-MS211A and B for Unit 2, associated with the steam inlet valves to the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) from the Main Steam Valve
..
-
House (Fire Areas 17-1 and 17-2) to the Quench Spray Pump House (Fire Areas 15-1 and 15-2). Prior to the implementation of this modification Abnormal Procedures (APs) for a fire in the Control Room, Emergency Swithgear, or Cable Vault required an operator to be dispatched locally to the Main Steam Valve House to fail the steam inlet valves open.
During the period from October 1987 to June 21, 1983, when it was identified in Deficiency Report 88-510 that these vaives were required to be operated locally as part of the postt' ire safe shutdown capability, had a fire occurred in one of the named areas the operator would not have been able to take the local action at the main stean valve house required to establish steam flow to the T0AFWP as described in the AP.
However, the licensee presented an evaluation to the inspectors which identi'ied alternative means by which the steam inlet could be operated.
Based on the licensee evaluation, the inspectors agreed that alternate methods were available to establish steam flow to the TDAFWP which would have allowed the Auxiliary Feedwater System to accomplish its performance goal of reactor heat removal.
The root cause of the SOVs being relocated without the impact on postfire safe shutdown capability being realized was the result of an inadequate review of the Appendix R Checklist by the preparing engineer and reviewir g engineers.
The preparer and reviewer failed to recognize that the SOVs were associated with tne TOAFWP trip valves.
In addition it appears the preparer and reviewer were also unaware of fire area boundaries established for separation of redundant safe shutdown equipment. OCP 87-01 and 87-02 were prepared by a North Anna Contractor and identify an apparent weakness in the configuration control program for DCPs generated by outside contractors who may not be f amiliar with the postfire safe shutdown capability at North Anna.
At
.
the time these DCPs were generated and reviewed VEPC0 had
'
discontinued its practice of having all DCPs reviewed by the engineering organization', Nuclear Engineering / Design Control, responsible for ensuring long term compliance with Appendix R.
Failure of the preparing engineer to adequately evaluate the criteria outlined in the Appendix R Checklist is identified as Violation Item 88-13-01, Inadequate Evaluation of Appendix R Checklist By VEPC0 Contractor.
The licensee's corrective action to resolve this finding includes:
Upon discovery that the 50V's had been relocated, the
licensee initiated changes to the safe shu*down procedures to instruct the operators as to the new location of-the SOV's. This corrective action was ef ferthe to address the immediate plant operating concern._ _ _______________
i
.
.
.
.
.
The licensee initiated an EWR which was implementated on July 13, 1988, which provided additional air stop and bleed valves at the original lucation in the Main Steam Valve House.
This corrective action achieved full compliance with the requirements of plant procedures.
The licensee has also reinstated the practive of having all DCP's reviewed by the Nuclear Engineering / Design Control goup who is responsible for ensuring long term compliance with Appendix R.
This corrective action appeart to be adequate to ensure similar violations do not occur.
All of the above corrective actions were implemented prior to this inspection and appear adequate to resolve the finding.
In
,
addition, subsequent to the completion of the inspection the
'
licensee issued volur.tv y LER 88-019-00 dated August 10, 1988, which identified addidonal corrective actions which will be implemented.
The implement 1 tion of these corrective actions will be followed up on in a future inspection.
l The inspectors also reviewed Deficiency Report (DR) that was l
written when the licensee identified that the SOVs had been relocated from elevation 272 ft. in the Main Stem Valve House to elevation 256 ft. in the Quench Sp-ay Pun.p House. DR 88-510 was i
initiate;d to relocate the emergency lights to insure that the l
path was lighted in the event a fire with the loss off-site l
power and operator action was required in this area. The DR was I
reviewed for reportability and found non-reportable.
The engineering review revealed that the relocation of the S0Vs was into an area that was separate from the original fire area and it was now possible that all auxiliary feedwater could be lost if a fire in the new location fire area were to occur.
The records reviewed by the inspectors indicated that only the original portion of the OR was evaluated for reportability and that the portion added by the engineering section with regard to the loss of auxiliary feedwater had not been evaluated or addressed since this part had been added to the report at a latter time.
The licensee presented evidence that even though the original report had been modified it had in fact been evaluated for reportability.
The licensee further advised the
{
inspectors that the manner in which this DR had been processed was an isolated case, and this was not the standard or normal method for handling and evaluating ors.
b.
Appendix R Features Appendix R tc 10 CFR 50 requiras certain fire protection features to be provided for the separation of redundant safe shutdown systems /
components in the same fire area.
These features include automatic suppression, automatic detection, fire barriers, radiant energy
_ _ _ _ _ _ _ _ _
>
.
..
,
,
-
shields and spacial separation.
If a licensee proposes alternate methods of protecting the redundant systems / components, an exenption from the applicable requirements of Appendix R must be requested.
During the NRC's initial Appendix R compliance inspection at North Anna, September 9-13, 1985, many of these fire protection features were inspected. However, the licensee's exemption requests which had been submitted to NRR had not yet been approved.
Subsequently, the NRC approved the licensees exemption requests in a November 6,1986 Safety Evaluation (SE).
During this inspection, the inspectors selectively reviewed those Appendix R fire protection features.not addressed c*uring the initial inspection and also verified that the bases for the NRC's November 6,
!
1986, SE still reflected the plant configuration.
In addition, the inspectors selectively reverifi?d that certain plant areas had adequate emergency lighting for operator access, egress, and manual operations.
(1)
November 6, 1986 SE Review The inspectors selected the following features for inspection to verify the November 6, 1986, SE still reflected the plant configuration:
Exemption
_ Request _
Feature
A detector is provided in each charging pump cubicle and one in each HVAC retur1 duct from the cubicles.
The Unit 2 CCW pump, power cable is wrapped with a one hour fire barrier until 20' separation is achieved.
Fire stops are provided in cable trays between the CCW pumps en the 259'-6" elevation of the Auxiliary Building.
Detection in the Quench Spray Pump House will be upgraded to provide full area coverage per NFPA 72E.
Manual action of the PORVs in the Main Steam Valve House is required.
Verify access, l
egress, and PORVs have adequate emergency lighting.
i
__
_
.-..
--.
._., - ---- - -
.
'
.
..
,
'
.
,
5 and 23 To north wall of the AFW pump house which separates the TOAFWP from the MDAFWP has all penetrations sealed with 3-hour rated seals.
.
Emergency ventilation equipment to supply cooling to the charging pumps and component cooling water pump area is provided in a fire rated enclosure in the Auxiliary Building.
31, 32, 33 Portable lights are to be provided for use in the Unit 1 and Unit 2 Seal Water Filter Area.
The two approved unprotected openings are the only unsealed openings in the wall j
,
i between the Unit 1 and 2 chiller rooms into the turbine building.
All of these features were verified to be in place by field inspection. No discrepancies were noted except, the inspectors found in their field walkdown of the emergency ventilation equipment in the Auxiliary Building that emergency lights ELT-AB009A through 0 did not appear to provide adequate lighting in the area.
The licensee had previously identified thir concern in DR 88-542 on July 6,1988. The licensee has drafted
'
EWR 88-183 to relocate the emergency lights. This item will be
!
l followed up on in a future inspection.
!
In addition, the two following programmatic requirements were verified to have been incorporated into plant procedures:
$
Exemption i
Request _
Programmatic Requirements 5 and 23 Procedures for using TOAFWP suction
pressuie to determine CST level.
Verified to be Step 12 of AP50.6.
Procedures for reestablishing ventilation to
,
CCW pumps and charging pumps shall be i
'
proceduralized.
Veri fied EMP-C-EP-11 l
includes rigging the ventilation.
,
(2)
The following Appendix R fire barrier penetration seals were inspected to verify that they met the requirements of Technical
!
I
-
-
\\
_
_ _ _ -
_
.
..
.
.
'
.
Specification 3/4.7.15, Penetration of Fire Barriers and Station Administrative Procedure 3.3 Cable and Pipe-Penetration Silicone Foam / Installation Repair.
Penetration No.
Location 1CK900RA Unit 1 Control Room Floor 1WL002N04 Unit 1 Control Room Floor ICK900RA Unit 1 Control Room Floor 2CC0010NA3 Unit 2 Diesel Generator Room 2CCX015NA3 Unit 2 Diesel Generator Room 2CX0015R0 Between Auxiliary Building and Cable Tunnel 2CX0016WF Between Auxiliary Building and Cable Tunnel 2WC02N06 Between Turbine Building and Switch Gear Room 2WX002N09 Between Turbine Building and Switch Gear Room
2WX002N40 Between Turbine Building and Switch Gear Room l
2WX003N48 Between Turbine Building and Switch Gear Room i
2WX004N09 Between Turbine Building and Switch Gear Room
)
2FC001017 Between Turbine Building and Switch Gear Room 2FC005N26 Between Turbine Building and Switch Gear Room i
2FK001005 Between Turbine Building and Switch Gear Room
!
2DK001081 Fire Wall Cable Tunnel No. 2 l
20X002NA2 Fire Wall Cable Tunnel No. 2
2FC005N26 Fire Wall Cable Tunnel No. 2 Review of the above penetrations indicated that they met the requirements of Technical Specification 3/4.7.1.5 and Station
Administrative Procedure 3.3 and were in accordance with the l
guidelines of Appendix A to Branch Technical Position APCSB
'
9.5-1.
The licensee provided documentation to substantiate the fire rating of the three-hour penetration se,1s used in the penetrations for cable trays, conduits and piping.
(3) Separation of Redundant Systems / Components The Units 1 and 2 Control Room HVAC systems are located in the Turbine Building, Fire Area 8, elevation 254'-0" Air Conditioning Chiller Rooms.
Either the Unit 1 or Unit 2 equipment is required to remain operable following a fire to ensure adequate Control Room cooling. The equipment is located in separate rooms in the turbine building separated by aporoximately 150 feet.
In addition, a non-rated wall separates each room from the remainder of the turbine building fire area.
The licensee's Appendix R Report shows that the cables associated with the Unit 1 equipment and Unit 2 equipment all run directly from the Air Conditioning Chiller Roon.s to each unit's Air Conditioning Rooms.
The Air Conditioning Rooms are located in separate fire areas. Fire Area 6-1 for Unit 1 and Fire Area 6-2 for Unit 2.
The inspectors verified that the
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
h
.
.
following cable raceways for the Unit 1 arJ' Unit 2 Control Room HVAC equipment pass directly from the Unit 1 and Unit 2 Air Conditioner Chiller Rooms each units Air Conditioning Rooms.
UNIT 1 EQUIPMENT Equipment Conduit Cable 1-HV-E-4B 1CL017PA 1HVCJPL210 Conterl & Relay Room Chiller 1-HV-E-4C 1CL01800 1HVCUOLO65 Control & Relay Root Chiller 1-HV-P-20B 1CK050PA 1HVCJPK200 Chilled Water Pump 1CK050PA3 1-HV-P-20C 1CK0790F 1HVCH0K210 Chilled Water Pump 1CK0970G3 1-HV-P-228 1CK050PB 1HVCJPK250 Condenser Water Pump 1CK050PB6 1-HV-P22C ICK0790E 1HVCH0K245 Condenser Water Pump ICK0790E4 MOV-HV-111B ICK050PA 1HVCJPK210 Chilled Water Pump Discharge VLV.
1CK050PA2 1HVCJPK211 UNIT 1 EQU1PMENT E
Conduit Cable (quioment Coni 9)
MOV-HV-111C ICK0790E 1HVCH0K260
,
Chilled Water Pump Discharge VLV.
1CK0790G2 1HVCH0C261
'
MOV-HV-113B 1CK050PB 1HVCJPK260 Condenser Water Pump 1CK050PBS 1HVCJPK261 Discharge VLV.
MOV-HV-113C 1CK0790E 1HVCHOK075 Condenser Water Pump ICK0790E1 1HVCH0K076 Discharge VLV.
,
.
.
.
.
.
.
.
.
.
..
..
.
..
.
..
.
.
l i
,
i I
UNIT 2 EQUIPMENT Equipment Condun Cable 2-HV-E-4B 2CL006PA 1HVZJPL210 Control & Relay Room Chillers 2-HV-E-4C 2CLOO50C 2HVZHOLO65 Control & Relay Room Chillers 2-HV-P-208 2CK015PB 2HVCJPK200 Chilled Water Pump 2CK015PB3 2-HV-P-20C 2CK0860A 2HVCH0K210 Chilled Water Pump 2CK0860A3 2-HV-P-22B 2CK015PC 2HVCJPK250 Condenser Water Pump 2CK015PC2 2-HV-P-22C 2CK0360E 2HVCH0K245 Condenser Water Pump 2CK0360E2 MOV-HV-2118 2CK015PB 2HVCJPK210 Chilled Water Pump Discharge VLV.
2CK015PB1 2HVCJPC211 MOV-HV-211C 2CK0860A 2HVCH0K260 Chilled Water Pump Discharge VLV.
2CK0860A2 2HVCH0C261 UNIT 2 EQUIPMENT Equipment Conduit Cable
-
(Cont'd)
MOV-HV-2138 2CK015PC 2HVCJPK260 i
Condenser Water Pump 2CK015PC1 2HVCJPC261
!
Discharge VIV.
MOV-HV-213C 2CK0860E 2HVCH0K075 Condenser Water Pump 2CK0860E1 2HVCHOC076 Discharge VIV.
,
I (4) Emergency Lighting The following emergency lights installed to illuminate operator access and egress paths and safe shutdown equipment were inspected rad verified to be operable and properly aimed.
I
-
-
.
o.
'
.
Emergency Light Location 2ELT-CV001 Unit 2 Cable Tunnel 2ELT-CV002 Unit 2 Cable Tunnel 2ELT-AB009A Unit 2 CCW Pump Area 2ELT-AB009B Unit 2 CCW Pump Area PELT-AB009C Unit 2 CCW Pump Area In addition, two lights, 2ELT-CV001 and 2ELT-CV002, provided in the east west corridor of the Unit 2 cable tunnel were tested under blackout condition.
This test verified that there is adequate illumination for operator access through this corridor.
c.
Postfire Safe Shutdown Procedures (1) Procedure Review The inspectors reviewed operations Appendix R postfire safe shutdown procedures to determine that any revisions made to the procedures did not impact on the licensee's postfire safe shutdown capability as reviewed and accepted during the initial Appendix R inspection.
It was noted that procedure, EEMP-C-EP-11 Rigging Of Emergency Ventilation, had been deleted due to modifications having been made which added two air handling units to the top of the Auxiliary Building. Temporary air d' acts have been installed and stored in fire rated storage spaces
-
until required.
Emergency Electrical Maintenance Procedure EEMP-C-RH-01, Installation Of Emergency Tenporary RHR Motor Feeder Cable, was reviewed and a walkdown was conducted to examine the materials that were in special storage areas of the ware house as r'equired by the procedure. The materials were set aside in a caged area and locked to insure proper control.
Abnormal Procedure 1-AP-50.1, Control Room Fire, was revised to i
reflect the changes discussed and the commitments made to the NRC by the licensees durlng the original Appendix R inspection.
(2) Licensed Operator Requalification Program for Abnormal Procedures for Fire Events The inspectors reviewed the documentation outlining the Licensed Operator Requalification Program (LORP) on APs for fire events (AP-50 series) as required in the LORP program guide ADM21-04 dated March 15, 1988.
This t 31ning consists of the operators
,
review of the AP-50 series procedures during the Cycle 88-6
operator in-service week, continued training on the simulator, and/or other classroom review of these AP...
.
.'
,
..
.
.
In lieu of walkthraugh of the AP-50 series precedures, the licensed operators view a 1 hour-30 mihute video tape outlining the use'of safe snutdown equipment described in the AP-50 series procedures during Cycle 88-5 of th. LORP.
The inspectors
.
'
reviewed the shif t training sheets for the "A",
"C" and
"D" shif ts which indicated this training was completed on June 23, 1933, June 9,1988, and May 26, 1988, respectively.
No shift walk through drill of the AP-50 series abnormal prccedures was conducted during this inspection; however, based on the review of the above training records the LORP training on the abnormal procedures for a fire event appeared complete and effective, d.
Associated Circuits Review
,
A review of maintenance activities was made to insure that relay / fuse coordination was included in the evaluation and planning as part of the App.: dix R revicy of maintenance work orders.
The inspectors reviewed the licensee's process for the control of replacement fuses.
Discussions were held with both electrical and I&C maintenance supervisory personnel.
It was noted that the only method of replacement fuse control was identified in Administrative Procedure 16.7 which places the responsibility at the cogni:: ant craf t foreman level. This procedure also requires an EWR to evaluate and approve a change before substitute components can be used.
This must be done prior to the work starting if the EWR does not address the specific
application.
Dt. ring discussions with the licensee, it was pointed out that it might be advantageous to have the replacement criteria and rules expressed / written in some of the training sessions for employees.
t The licensee agreed to review this possibility.
e.
Review of Engineering Evaluations (1) Engineering Evaluation Number 1, Evaluation of Minor Modifica-tions To Fire Doors I
Fire rated doors (3-hour rated U.L. labeled doors) are used to l
protect personnel openings in fire rated walls, including those required for separation of Appendix R fire areas (in accordance with Section III.G of Appendix R to 10 CFR 50). The Appendix R
'
fire doors were originally visually reviewed and a list was prepared of doors that needed:
to be replaced, to have exemption requests developed and submitted to the NRC, to be repaired, or to be evaluated to determine the potential effects
,
l of minor modifications to the doors, i
t
..
..
__
.
..
.
.
.
-
The final category is specifically addressed by Generic Letter 86-10 Enclosure 2, Section 3.2.3 which states: ~ where a door is part of a fire area boundary, and the modification does not effect the fire rating (for example, installation of security controls), no further analysis need be performed.
If the modifications reduce the fire rating (for example, installation of a vision panel), the fire rating of the door should be reassessed to ensure that it continues to provide adequate margin considering the fire loading on both sides.
This engineering evaluation only considers door originally identified as having minor modifications.
During this inspection, the inspectors conducted a walkdown of the plant and examined modifications that were done on the doors.
The fire doors reviewed in the evaluation that separate fire areas containing safe shutdown equipment will provide separation equivalent to that required by Apperdix R,Section III.C.
The minor modifications to the doors will not adversely effect thair performance under fire conditions as shown in the individual evaluation of each modification.
This is based on the doors being located in areas prer.ected by fire detection and suppression systems. The minor nwdifications are similar to those that Underwriters Laboratories have found acceptable in other nuclear power stations.
Tne modifications appeared to be ir compliance with the guidance of Section 3.2.3 of Generic Letter 86-10.
Therefore, the inspectors found this engineering evaluation to be acceptable.
(i) Engineering Evaluation Number 2, Evaluation of the Seismic Separation (Rattlespace) Between Various Concrete Walls Several buildings, the Auxiliary Building, the Cable Vault /
Tunnel, Safeguards, Main Steam Valve Houies, and Quench Spray Pump House. have common walls that have a rattlespace (to allow for a seismic event movement) between the com.?on wall and a perpendicular wall.
In some cases, a combustible material was used as a spacer material during the concrete pour.
Seismic gaps or rattlespaces, are standard in the construction of concrete structures. The job of the rattlespace is to leave enough space between walls (especially perpendicular walls) to permit movement without buckling during a seismic event.
A standard industry practice is to use styrofoam, as was the practice of North Anna.
The width of the seismic gaps are approximately 2 inches. The thickness of the walls involved are 12 inches to 24 inches.
l
._
-
".
e.
.
.
'
Angle iron approximately 2h" by 2h" by h" thick was bolted to t
one side of the wall to cover the gap.
The same type of angle iron was used on the other side of the barrier.
The evaluation states a number of factors that mitigate the potential of fire spread through the seismic gaps.
These factors along with the licensee's justification are provided below:
Most of the areas involved in the Fire Detection
-
-
evaluation have either heat and/or smoke detectors that j
annunciate to the Control Room. Detection systems provide early warning of a fire condition to permit prompt station
"
action.
This early notification provides extra time for
'
the fire brigade to assemble and attack the fi. ! while it is still in an incipient stage, thereby reducing the potential exposure to the seistt'c gap.
.
-
Fi re Suppression In general, fire areas with a
-
combustible loading that results in an equivalent fire severity of over 60 minutes have a fire suppression system.
A fire suppression system is designed to extinguish a fire before it can reach flashover or the point where the fire
'
grows beyond the general area of origin. This will reduce any exposure threat to the barrier.
'
-
Coubustibles In the areas revieweJ, the vicinity of
-
seismic gap was free of combustibles on both sides of the barrier.
This will reduce the amount of direct flame impingement on the seismic gap on the exposed side of the barrier.
This also means that there is little possibility of ignition on the unexposed side, even if the heat did
'
pass through the seismic gap.
In addition, the overall level of combustibles in most of the areas when there is no
fire suppression where seismic gaps occur is low (an
- !
'
equivalent fire severity of 20 minutes or less).
The l
exception is the Cable Vault / Tunnel v.hich nas a suppression t
system.
The cype of combustibles in the vicinity of the
,
seismic gap is also an important factor. Although there are few, if any, combustibles in the direct vicinity (up to j
5 ft.) of the seismic gap, those tha; were present were primarily cable insulation.
Cable insulation requires a
substantial amount of concentrated heat to ignite, and it
,
',
is unlikely that this would occur via the seismic gaps.
-
Area Configuration - As stated earlier, most of the areas
-
!
with seismic gaps are on the primary side of the plant.
These rooms are large concrete structures' with high ceilings that will allow heat to rise and dissipate.
,
I i
-
-
- -
. -
.
-
.
'
,
..
.
.
~
-
Seismic Gap Configuration - There are several factors in the seismic gaps that will prevent the passage of heat and flame through the gap.
This barrier is installed on both sides of the gap. This barrier will prevent the passage of heat and flame for most fires in the area.
There are no conduits or other items which penetrate through this barrier and the seismic gap since the seismic gap is only 2 inches wide.
If the fire is close enough to directly impinge on the barrier, the rubber gasket will f ail, but the barrier on the other side shielded by the reinforced t
concrete wall will prevent passage of heat and flame. The
~
combustible fill within the seismic gap may also actually serve to block the passage of flame if there is insufficient oxygen in the gap to permit total combustion.
Secondly, as mentioned above, the thickness of the walls are an important consideration.
The walls involved are a minimum of 12 in. thick, and some go up to 24 in.
This thickness will shield the barrier on the unexposed <ide and permit the fire gases to cool as they pass throus the wall.
This will also provide extra time for fi-ek action.
-
Safe Shutdown Equipment - There are no major cor the safe shutdown or alternate shutdown systems
,e direct vicinity (5 f t.) of the seismic gap.
Oi the gaps that were field verified, the closest component to a gap are the RHR power feeds where they enter containment in the electrical penetration area of the Cable Vault and Tunnel (CV/T).
These cables are approximately 8 f t.
away.
The CV/T has detection and suppression.
-
Fire Code Conparison - The passage of limited amounts of gases and even flaming is acceptable for other barrier penetrations.
For example, fire door testing as outlined in NFPA-252 paragraphs 6-1.1.1, 6-1.1.2, and 6-1.1.4 permits flaming of up to six (6) inches along the edges of the door.
During the course of the evaluation it was determined that this concern brJ been discussed during the Appendix A evaluation of the late 1970s.
NRC question 16, which is answered in supolement 3 of the North Anna Fire Protection Systems Review (FP59) dated October 1,1978, specifically addresses the use of styrofoam filler in the rattlespace. The Virginia Electric and Power response appears to adequately cover this NRC cancern.
The Fire Protection Safety Evaluation Report (SER) issuch by the NRC in February of 1979 specifically references the VEPC0 FPSR
....
.
~
.
..
.
.
.
Supplement 3 as a source document.
The SER in Section III - A found that North Anna was in compliance with the guidelines of Appendix A to BTP-9.5-1 in terms of fire barriers and penetration seals.
According to the NRC's Generic Letter 86-10, Enclosure 2, Section 3.1.2, this cc. figuration does not need to be reviewed by the NRC.
The proposed Generic letter states that:
a) if openings in fire area boundaries are specifically identified and justified in.the fire hazards analysis performed in ' the l
Appendix A process and b) if these boundaries are evaluated and accepted in a published SER, then the: fire area boundary does not need to be reviewed for compliance with Section III.G of Appendix R.
The seismic separation (rattlespace) meets these guidelines.
The seismic gap rattlespace configtration will provide adequate separation between adjacent fire areas.
The technical bases which justify this conclusion can be summarized as follows:
-
The fire areas (which contain shutdown components) have fire detection systems that alarm in the Control Room on both sides of fire barriers with seismic gaps.
-
The fire areas with the seismic gaps in general have combustible loadings that result in an equivalent fire severity of approximately 20 minutes or less. The notable exception, the Cable Vault and Tunnel, has a fire suppression systen.
The barrier presently installed over the seismic gap on
-
both sides of the barrier will provide sone degree of separation, especially on the unexposed side.
-
The configuration of the structures involved (primarily heavy concrete with high ceilings and cubicles) will limit exposure to the gaps.
There are few combustibles and safe shutdown components
-
within the direct vicinity of the seismic gaps, and there are no penetrations through the seismic gap.
The passage of limited amounts of heat and even flame is
-
permitted by NFPA codes for such barrier penetrations as fire doors.
This configuration has been previously described to the NRC
-
,
via the Fire Protection System Review submittal.
The Fire Protection SER issued by the NRC did not raise further
,
- - - -
.
.
- - -
- -.
..
'
..
..
.
.
'
.
concerns.
According to guidance in 'he NRC's proposed Generic Letter 86-10, this configuration does not need to be reviewed again by the NRC.
During this inspection, the inspectors conducted a walkdown and
-
examined the rattlespace areas and verified that the above referenced requirements were being met.
TF,refore, the inspectors found this engineering evaluation acceptable.
(3) Engineering Evaluation #5:
Evaluation Of Sprinkler Head
'
Placement For the Partial Area Sprinkle System In the Auxiliary Building North Anna Power Station In response to the guidance provided in Appendix A of BTP 9.5-1 and in order to comply with 10 CFR 50 Appendix R section III.G separation requirements, VEPCO has installed a sprink,ler system on the 244'-6" and 259'-6" elevation of the Auxiliary Building.
The purpose of this sprinkler system is to provide protection to the charging pumps and their associated cables and the component cooling water pumps and their associated cables.
Since this system does not provide coverage to the entire fire area VEPCO requested an exemption from the requirements of 10 CFR 50 Appendix R Section III.G from providing full area coverage.
This exemption was granted in the SE enclosed in the November 6, 1986, letter from the NRC.
Subsequently, the licensee had determined, that due to the great deal of congestion at the ceiling in these elevations, many of the sprinkler heads are partially obstructed and do not strictly comply with the guidance in NFPA-13.
In accordance with the guidance provided in Generic Letter 86-10, the licensee has identified the partial obstruction of these sprinklers as deviations from NFPA-13 and has provided an evaluation for each partially obstructed sprinkler.
The licensee bases their evaluation of the acceptability of these obstructions on:
NFPA-13 guidance on location of sprinkler heads in relation
-
to obstructions, the design basis of the system to protect the charging
!
-
pumps, component cooling water puTps and their associated cables,
.
and good engineering practice since the spacing of the
-
sprinkler heads is such that there is a great deal of overlap in coverage.
-
-
-
-
'
.,
,,
.
.
'
Using this basis, 28 of the 50 sprinkler heads were evaluated.
All 28 heads were found to provide adequate coverage by the licensee's staff.
The inspectors' review of the licensee's evaluation included a review of the technical bases for the code deviations and a walkdown of selected sprinklers to insure the configuration was within the parameters of the engineering evaluation.
Based on this review the inspectors found that although the sprinklers are partially obstructed, adequate protection is provided for the safe shutdown systems / components in the area. Most of the obstructions are minor and in cases where large obstructions exist another adjacent sprinkler is available to protect the area.
Therefore, the inspectors found the engineering evaluation to be acceptable.
(4) Engineering Evaluation #A, Evaluation of t' e Potential for Flooding In the Emergency Switchgear Rooms North Anna Power Station In acccrdance with the NRC's Safety Evaluation Report dated February 1979, VEPCO installed hose stations in each unit's Emergency Switchgear Room and a sprinkler system in each unit's Cable Vault / Tunnel.
In order to prevent damage to vital electrical equipment in the emergency switchgear room due to flooding the piping for these systems is maintained dry by closing the isolation valve to the systens.
However, the isolation valve is located in the Emergency Switchgear Room air conditioning area.
Therefore, the potential for a pipe break below the isolation valve to result in flooding of portions of the Emergency Switchgear Room was evaluated. The purpose of the licensee's evaluation was to evaluate this flooding level.
The bases for this evaluation is:
the criteria outlined SRP Section 3.6.1 and BTP ASB Section
-
3-1 for postulating piping failure in moderate energy pipe systems and the assumption that the duration of the leak will be 30
-
minutes
Using this bases the licensee evaluation sstablished that in 30 minutes 3480 gallons of water would be released into the Air Conditioning Room.
The configuration of the potentially floeded area is the Air i
Conditioning Room an elevation 254' separated from the Emergency Switchgear Room one elevation 254' by the Instrument Rack Room which is at a lower elevation 252'.
Therefore, a line break in
. _
-
.
.-
-
.
-.
..
<
.o o,
.
.
'
-
the Air Conditioning Room would first have to fillup ' the
,
Instrument Rack Room to reach any vital switchgear.
The
'
licensee's evaluation shows that if 3480 gallons of water i
accumulated in the Instrument Rack Room the water level would be
,
2.7" in Unit 1 and 3" in Unit 2.
These values were obtained by assuming no drainage from floor drains in the air conditioning rooms and instrument rack rooms.
In addition, the licensees evaluation shows that hose failure l
during fire fighting activities in the Emergency Switchgear Room would drain to the Instrument Rack Room.
The floor is sloped
.,
from the Emergency Switchgear Room to the Instrument Rack Room.
Based on the inspectors' review of the licensee's evaluation, a
pipe failure would not have adverse impact in the Emergency
'
Switchgear Room.
Therefore, this engineering evaluation was
found to be acceptable.
(5) Engineering Evaluation #7; Evaluation Of Operator Access to the
'
Charging Pump Cubicles North Anna Power Station
,
The North Anna plant design includes the capability to crosstie the discharge of each units charging pumps such that Unit 1 pumps could supply Unit 2 or Unit 2 pumps could supply Unit 1.
.
The licensee has elected to use this methodology to satisfy the requirements of 10 CFR 50 Appendix R.
Therefore, in the fire safe shutdown analysis, the licensee postulates t'iat all three charging pumps for a single unit will be lost ir a fire and charging flow will be provided by the opposite units pumps. The crosstie of the charging pumps requires an operator to enter the 2A or 1C charging pump cubicles from the 259'-6" elevation and i
l manually open the crosstie valve.
L
This manual action would require the operator to enter the same elevation as the postulated fire within 30 minutes. The purpose
]
of the licensee's evaluation is to provide a justification for
[
this entry.
,
The licensee justification for operator entry is based upon
!
!
the division of the 259'6" elevation into two separate fire
-
zones based on separation of the Unit 1 and Unit 2 charging i
i pump cables.
There is not a physical barrier, i
access is available from opposite :ones and emergency i
-
,
lighting are provideo,
cperators are familiar with the area, l
-
breathing apparatus is available.
-
}
.
i
.
.
.
..
.
.
'
o
..
.
'
combustible loading is low and configuration of
-
combustibles wil. reduce exposure to the pathways, ionization smoke detectors are provided,
-
an automatic sprinkler system is provided for protection of
-
the power cables for the charging pumps and component cooling water pump on the 244-6" and 259'-6" elevations, and the station fire brigade will control or extinguish a fire
-
in the area within 30 minutes.
Traditionally, the NRC has not approved the entry into a "fire" area to take manual operations to mitigate the consequences of a fire within 60 minutes of a fire event. This position is based on the number of uncertain variables which can occur during an
actual fire situation.
In addition, the inspectors questioned whether the engineering evaluation actually constituted an exemption request from the requirements of 10 CFR 50 Appendix R Section III.L.3 which requires alternate shutdown capability for specific fire areas to be independent of that fire area.
l Based upon these concerns the inspectors elected to identify this engineering evaluation as Unresolved Item 88-13-02, Entry Into Fire Area for Manual Operation of Safe Shutdown Equipment, and a request for technical assistance from NRR has been generated to determine the acceptability of the licensee's proposed operator action.
In addition, the inspectors expressed concern to the licensee that the compensatory measures outlined in plant Technical Specifications for action to be taken when detection is inoperable in this area may not be adequate.
The inspectors concern is based on the fact that the manual action is required within 30 minutes of a fire event. The purpose of the detection system in this area is to provide early warning of a fire.
l Should the detection system become inoperable the Technical
Specification action statement requires an hourly roving fire watch.
The inspectors felt this compensatory neasure was inadequate for this area due to the importance of a prompt fire brigade response. Therefore, the inspectors recommended that if detection becomes inoperable in this area a continuous fire watch be established.
The licensee agreed to issue a Standing Order which would l
require a continuous fire watch in this area if detection becomes inoperable.
The Standing Order will remain in effect
'
until NRC determines if the licensee's proposed operator actions are acceptable.
,
f
-
-
-
.
_ _ _ _ _ _ -
.3
.
.
.
(6) Engineering Evaluation #8; Evaluation of Operator Access Tu the Motor Driven Auxiliary Feedwater Pump Room North Anna Power Station A fire in the Unit 1 or Unit 2 Motor Driven Auxiliary Feedwater Pump (MDAFWP) Rooms would result in a loss of both MDAFWPs for each unit.
Under this scenario the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) would be used to satisfy the reactor heat remov61 performance goal via feedwater flow to one steam generator.
By this mechanism adequate heat removal can be accomplished for approximately 30 minutes. After 30 minutes the TDAFWP must be realigned to the other steam generator for adequate heat removal.
The realignment of the AFW system requires an operator to enter the MDAFWP room, the area of the postulated fire, and manipulate a number of valves.
This operator action is required within 30 minutts of the fire event.
The licensee's justification for operator entry is based upon:
-
low combustible loading in the rooms and lack of exposed fixed ccabustible,
-
ionization smoke detectors are provided.
-
portable fire extinguishers and fire hydrants are available for manual fire fighting.
-
the station fire br!gade will control or extinguish a fire in the MDAFWP room within 30 minutes, and breathing apparatus is available.
-
Traditionally, the NRC has not approved the entry into a "fire" area to take manual operations to mitigate the consequences of a fire within 60 ninutes of a fire event. This position is based on the number of uncertain variables which can occur during an actual fire situation.
In addition, the inspectors questioned whether the engineering evaluation actually constittted an exemption request from the requirements of 10 CFR 50 Appendix R Section III.L.3 which requires alternate shutdown capability for specific fire areas to be independent of that fire area.
Based upon these concerns the inspectors elec*.ed to identify this engineering evaluation as another example of Unresolved Item 88-13-02.
In addition, the inspectors expressed concern to the licensee that the compensatory measures outline in plant Technical Specifications for action to be taken when detection is inoperable in this area may not be adequate.
The inspectors concern is based on the fact that the manual action is required
)
<
_ _
'
..
.
.
'
.
I within 30 minutes of a fire event. Tha purpose of the detection system in this area is to provide early warning of a fire.
Should the detection system become inoperable the Technical Specification action statement requires an hourly raving fire watch.
The inspectors felt this compensatory measure was inadequate for this area due to the importance of a prompt fire brigade response. Therefore, the inspectors recommended that if
"
detection becomes inoperable in this area a continuous fire
watch be established.
F
'
I The licensee agreed to issue a Standing Order which would r
require a continuous fire watch in this area if detection
[
becomes inoperable.
The Standing Order will remain in effect
'
unti! NRC determines if the licensee's proposed operator actions are acceptable.
l
!
,
(7) Engineering Evaluation #9; Evaiuation of Smoke Detector Design
Criteria - Emergency Switchgear Rooms North Anri i Power Station L
The smoke detection systems in the Unit 1 and Unit 2 Emergency
!
Switchgear Rooms are installed to satisfy the requirements for l
!
area wide detection in 10 CFR 50 Appendix R Section III.G.3.
In
'
reviewing these systems for compliance with the spacing requirements outlined in NFPA-72E, Automatic Fire Detectors, the licensee found that detector locations do not meet the spacing
,
criteria outlined in the NFPA Code.
I i
i Generic Letter 86-10 states that licensees should identify deviations from NFPA codes and provide a justification for the
deviations.
In accordance with this guidance the licensee's I
engineering evaluation documents the acceptability of the smoke l
detector installation in the Emergency Switchgear Rooms.
[
l NFPA-72E requires the installation of smoke detectors in all beam pockets formed by beams exceeding 18 inches in depth end i
grecter than eicht feet on contars. However, a detector has not been,11 aced in every beam pocket in the Emergency Switchgear
,
.
Rooms at required by the code.
The licensee states that the
'
present detection system installation is equivalent in l
effectiveness and safety to NFPA-72E based on the following:
l
<
The ceiling space in the room i s very congested and
-
'
therefore it is highly unlikely that smoke from a fire would accumulate in a single beam pocket,
j All of the beam pockets where detectors would be required
-
by NFPA-72E are formed by 21 inch beams, i
!
Spacing per smoke detector is approximately 250 f t.2, far
-
j below the 900 f t.2 per detector allowed for smooth ceilings
,
construction.
l
- -
.
-
-
-
-
-
-
-
- - -
-
-
-
-
-
-
-
,
. _ _ - _ _ _ _ _ _ _ _ _ _ _ _
'
e e.
.
'
.
The volume of the beam pockets is relatively small. Thus,
-
even if the smoke accumulated in a beam pocket without a detector the delay would not be sabstantial.
The inspectors reviewed the technical basis for the deviations and conducted a walkdown of the detection sy s tem s.
The inspectors found that the majority of the room did have detectors spaced in accordance with NFPA 72E. The exception to the NFPA 72E spacing requirements occurred mainly between Column Lines 7-9 and C-0.
In this area there were six beam pockets which are not presently provided with detectors. The inspectors were concerned that a small fire could occur under these beam pockets and go undetected until it had grown to a significant size. The Emergency Switchgear Rooms are fire areas which would require plant shutdown from outside the control room in the event of a significant fire.
The inspectors found by field walkdown, the ceiling space below these beam pocke'.s is highly congested.
The smoke from a fire would be greatly dispersed as it travels to the ceiling.
Therefore, it is not feasible to assume the smoke would accumulate in a single beam pocket without a detector.
Based on the inspectors' review of the licensee's evaluation and the field walkdown of the detectors placement, the addition of detectors to comply with NFPA-72E would not significantly improve detector response in the Emergency Switchgear Rooms.
Therefore, the inspectors found this engineering evaluation to be acceptable.
(8) Engineering Evaluation Number 11, Evaluation of Pipe Tunnel Penetrations A rated barrier or seal is not provided at the ends of saveral pipe tunnel penetrations located below grade which provide an access for pipes to be routed between buildings.
These pipe tunnels are addressed in an engineering evaluation since GL 86-10 Section C specifically states that the licensee may develop an evaluation for items such as a fire area boundary, as 1.c a s the evaluation is performed by a fire protection engineer and retained for a future NRC audit.
The pipe tunnels penetrations addressed in this evaluation are:
a)
Tunnel between Unit 1 Quench Spray Pumphouse and Unit 1 Turbine Building b)
Tunnel between Unit 2 Quench Spray Pumphouse and Unit 2 Turbine Building
_...
.
-
..
..
'
- .
.
c)
Tunnel between Unit 1 Quench Spray Pumphouse and Unit 1 Auxiliary Feedwater Pumphouse
'
d)
Tunnel between Unit 2 Quench Spray Pumphouse and Unit 2 Auxiliary Feedwater Pumphouse
e)
Tunnel between Wastes Disposal Building and Fuel Building
The QSPH - Auxiliary Feedwater Pumphouse tunnels and QSPH -
J Turbine Building. tunnels are sealed on all but one end of each tJnnel.
The penetration seals are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire-rated except for
'
the steel plates used at the following locations:
Two plates in the Unit 1 QSPH basement One plate in the Unit 1. TOAFW Pump Room i
One plate in the Unit 2 TDAFW Pump Room
'
,
i The Fuel Building - Waste Disposal Building tunnel is scaled on one end with a non fire-rated cenetration seal.
The steel plates and penetration seal are evaluated below:
{
The steel plates used to seal the pipe penetrations are made of
'
approximately 3/8 inch thick steel which is bolted to the
,
concrete wall. A high temperature rated caulk is applied around
'
the edges of the steel plates in order to provide an airtight seal.
The caulk is rated to stay pliable up to approximately i
500 F.
The steel plates and caulk arrangement used to seal these pipe tunnel penetrations providas an acceptable seal
.,
!
against the passage of smoke and hot gases from one fire area to
another.
The steel plate is not fire rated, but this is i
j acceptible due to the following factors:
!
t
-
!
The pipe tunnels contain no combustibles so a fire could l
-
!
not travel through the tunnel.
'
lj l
The combustible loading in the QSPH's, TOAFWP Room, and
-
MDAFWP Room are all l o,(,
so, if a fire does occur in one
!
j pump roo.T. it is expected to be a small fire.
!
I j
If a fire occurs in the Turbine Building, it would not f
-
}
affect the steel plate in the QSPH due to the long length
'
j of the tunnel, l
i i
i The tunnel openings form a labrinth configuration between
!
-
the Unit 1 MDAFWP Room and the Unit 1 TOAFWP Room.
There
'
i is a sut.p in esch pump room.
The openings to the tunnel i
i are raised about 14" high so that the wall forms a dike l
between the sump areas and the tunnel.
The size of this dike, in coordination with the open drain pipe in the sump l
'
i
-
j i
l
,
-
_
..
-
_
.
.
.-
-..
e
..
.
.
l
.
area, is such that the postulated flammable liquid spill
,
will be contained in the MDAFWP Room, thereby confining all
_
combustibles to this area. This will prevent direct flame
!
impingement c,n the steel plate in the ad.iacent TDAFWP Room I
and, therefore, the steel plate is adequate to prevent the
!
I passage of smcke and hot gases.
i
If a fire occurs in the OSPH or TDAFWP Room which exposes
-
,
the steel plate or caulk to direct flame impingement, smoke
and hot gases may be able to pass around the plate, but
flame would not be able to pass to the adjoining fire area l
l due to the length of and lack of combustibles in ti.< pipe j
tunnels.
'
The Fuel Building-Waste Disposal Building tunnel does not need a
3 hr. fire-rated seal at either end due to the following (
i factors:
i j
There is no safe shutdown equipment in the Waste Disposal i
-
j Building, so, even if a fire spread from the Fuel Building,
j both units could be safely shutdown.
l The pipe tunnel is over 140 ft. long and contains no
-
'
-
combustibles, so a fire cannot travel through the tunnel.
.
,
i j
The combustible loadings in both the Fuel Building Basement
!
-
i and the Waste Disposal Building are low, so, if a fi_re does
!
occur in either area. it is expected to be a small fire.
,
Ouring this inspection, the inspectors conducted a walkdown and
}
inspected the areas discussed in the above paragraphs.
This
{
inspection verified that the fire areas separated by the pipe
[
tunnels have separation equivaler.t to that required by f
Appendix R Section Ill G.2.(a).
The technical bases which i
j justify this conclusion are summarized as follows:
.
!
j The Turbine Building-QSPH Tunnels and QSPH-AFW Pumphouse are i
scaled on all but one end of each tunnel.
The pipe tunnels j
contain no combustibles.
The steel plates which seal the ends j
of some tunnels have a high temperature rated caulk applied
!
]
around the edges of the steel in order to provide an airtight i
seal against the passage of smoke and hot gases.
The l
l combustible loading are low in the rooms where steel plates are l
j installed.
The tunnel configuration between the Unit 1 MDAFWP
and TOAFWP rooms is such that a flammable liquid spill will be-l
)
contained in the MDAFWP Roon tump.
There is no safe shutdown l
j equipment in the Waste Disposal Building. The distance between
'
the Fuel Building and Waste Otsposal Building fire areas through (
the tunnel is approximately 140 feet. Therefore, the inspectors
!
found this engineering evaluation to be acceptable.
l
i
!
I
!
i
!
i
.
i i
_ _ _
-
-
- - - -
--
-o
. -.
_
.
-- _.
.
. -.
._.
...
..
e.
.
.
~
f f.
NRC Information Notices
(1)
Information Notice No. 88-04, Inadequate Qualification and
!
!
Documentation of Fire Barrier Penetration Seals, February 5, i
~
1988.
During this inspection the inspectors asked the licensee how
,
they had responded to Information Notice No. E8-04.
The
!
I licensee indicated a prelimirary engineering review was done on
March 31, by Engineering and Construction.
This review by l
j Engineering and Construction was completed on April 13, 1938,
!
)
and it was determined that there was a possible station impact.
The preliminary review recommended further review to concentrate
j in four areas:
correlation of fire seals, temporary seals
'
q (Surry only),
training of installers, inspection repair (
modification.
'
r
i
The station re;ponse to the preliminary engineering review was i
to attempt to form a multidiscipline working group at the l
j station to address recommendations.
The task was assigned on L
'
uune 18, 1998.
On July 20, 1988, the Supervisor of Project
-
l Engineering concluded that station resources would not be
sufficient to address all of the concerns in the notice and l
recommended to the Superintendent of Technical Services that Engineering Construction (power engineering services)
be reinvolved Type 1 turnover of work.
On July 21, 1998, the Superintendent of Technical Services agreed to authorize such a
!
.l Type 1 turnover.
The Type 1 turnover to power engineering i
-
j services to perform the applicable portion of the preliminary
engineering recommendations will be i ssued by July 22, 1983.
Based upon the results of this work station procedures may or
I
,
may not require revision, i
i
!
'
!
3.
Action On Previous Inspection Findings (92701)(92702)
3.
(Closec) Violation 333,339/37-37-01, Failure to Develop and Implement Surveillance Procedures for Appendix R Fire Barrier Wrap Enclosures, j
Fire Stops, and Radiant Energy Shields.
The inspectors reviewed the folloning fire protectiom maintenance
!
procedures which have been developed for surveillance of the j
Appendix R separation fire barriers.
i k
!
i
I
!
I
-... -
- -. - -
- - -.
-
- - -
.- _
,
- " *
.
.
.
Procedure
No. (Revision)
Title Inspection Interval l
,
1-FPMP-0.0 (3/31/SS)
Visual Inspection Unit 1 18 months i
2-FPMP-9.0 (3/31/8S)
(Unit 2) Containment Fire
'
Retardant Wraps, Radiant i
Energy Shields and Cable Tray Firestops Required By
,
Appendix R 1-FPMP-9.1 (3/31/88)
Auxiliary Building cire 18 months Regardent Coatings, Cable Tray Fire Steps, and
'
Penetration Seals Required By Appendix R l
2-FPMD-9.2 (3/31/83)
Appendix R Vent Duct 18 months i
l 1-PT-iO5.1.4 (4/14/83)
Fire Protection Systua 18 months Fire Barriers - Revistoc 3 Based on this review, it appears that these surveillance procedures for Appendix R separation barriers are complete and accomplish the required testing and inspection for the North Anna Fire ?rotection Program.
This item is closed.
b.
(Closed)
IFI 338,339/87-37-02, Emergency Lighting Sur.eillance l
Procedure Does Not Include Light Beam Aiming Details for Safe j
Shutdown Equip ent IlluM nation.
The procedures for periodic
inspection of Appendix R energency lights, Eli ELT/M-1 and
I E21-ELT/M-1, did not contain adequate information regarding the
'
aiming of the lights and the safe shutdown equipment to be i
)
illuminated.
l
.
'
The licensee has now generated a procedure deviation to these two
'
procedures which includes a revised table which gives detailed
'
i instructions on pathways and equipnent to be illuminated by each j
Appendix R emergency light. Tne procedure deviations will remain in
}
effect until a permanent change is made to the procedures. This item j
is closed.
i
I c.
(Closed) Violation 333,339/87-37-03, Failure to Implement Fire
!
i Brigade Training and Timely Corrective Action for Fire Protection QA l
j Audit Findings.
Review of training records indicated fire brigado
j shif ts did not participate in the required eu-ber of quarterly i
drills.
This item had also been identified as a finding in the i
!
licensee's Triennial Fire Protection Audit. No corrective action was I
J taken to correct this audit finding.
l
!
!
,
,
.
.
.
.
.
-,.,_ -
-
,
=0 e,
.
.
Corrective actions taken included drills conducted for the shif ts that had not ret the ninimum requir:ments of the North Anna Fire Protection Plan and development of a fire protection maintenance procedure to procedurali:o the conduct of fire brigade drills and provide formal transmittal of records to the training department.
The North Anna Fire Protection Plan was also revised to specify that drills are to be pre-approved by station management and shall only be cancelled with the station managament approval.
During this inspection the inspectors reviewed the fire protec+..n mtintenance procedure and verified that members of the A, B, C, 0, F
hif ts had participated in the required number of drills
.adu.ead from October 1937 through July 1933.
The inspectors also
.arif;ed that all mercers assigned to the brigade had received the required amount of training.
This item is closed.
4.
Exit Interview The inscecticr, scope and results were summarized on July 22, 1933, with those persons indicated in Paragraph 1.
The inspectors described the arsas inspected and discussed in detail the inspection resu'ts listed below. In response to inspectors concerns regar' ding the acceptability of operator mccess into a "fire" area to manually operate plant equipment i
within 30 minutes of a fire event in the area (URI 333,339/33-13-02), the licensee committed to initiate a Standing Order to establish a continuous fire watch if cetection becoret inoperable in the changing pump cubicles, Auxiliary Building 244' elevation c.
259' elevation, or the Unit 1 or Unit 2 Motor Driven Auxiliary Feedwater Pump Rooms.
These compensatory
'
measures will ensure that if detection is inoperable prcmpt notification of the fire brigade can be achieved by the fire wat'h.
Thi s Star. ding Order will re ain in effect until the NRC determines the acceptability of the licenses propcsed manual actions.
Preprietary information is not contained in this repor t.
Dissenting co-ents were not received from the licensee.
Item Number Description and References 325,339/SS-13-01 Violation - Inadequate Evalurtien of Aapendix R Checklist by VEPC0 Contractor
,
333,339/83-13-02 URI - Entry Into Fire Area for Manual Operation of Safe Shutdown Equipment
,
-
-
- -.