IR 05000341/1989020

Insp Rept 50-341/89-20 on 890626-30 & 0720.Deviation Noted. Major Areas inspected:post-fire Safe Shutdown Capability Configuration Mgt Program & Fire Protection Program

ML20246F168
Person / Time
Site:	Fermi
Issue date:	08/23/1989
From:	Darrin Butler, Gardner R, Holmes J, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246F134	List: IR 05000341/1989020 ML20246F130 ML20246F159
References
50-341-89-20, IEIN-88-004, IEIN-88-060, IEIN-88-064, IEIN-88-4, IEIN-88-60, IEIN-88-64, NUDOCS 8908300181
Download: ML20246F168 (29)

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1. < Inspection'Att Fermi /2~ Site, Newport,' Michigan; ,

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w..w 1 Irispeci.ionICoriducted ? June 26-30 and July 20,:1989' '

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' Approved [By:..RonaldN.:Gardner, Chief ~

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Inspection Summary ,

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Inspection on June 26-30'and July 20, 1989;(Report No. 50-341/89020(DRS))  ;

4 Treas Inspected: Special, announced team inspection to review the implementation .

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of the_ post fire safe shutdown capability configuration management program and ,

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the fire protection programiincluding'a followup'of;1icensee actions ~on previous l g tinspection. findings; deviation event reports; Configuration control procedures j ( review; engineering da. sign'packaJe' review;* operator: training:for the dedicated

,} 4 rshutdown panel;l fire. barrier / cable separation / associated circuits review; -)

& emergency lighting;. the fire protection ~' system surveillance' test program;.

T communications; plantL. tour observations; and pre-fire plans-(30703, 64150, ' ' '

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64704,and192701). -

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Results: ~0f the eleven areas inspected, one deviation was identified (failure -!

to adequatcly? implement the annual requalification program -' Paragraph 6.c).' j i ,

-One unresolved and three~open items were identified in this report. .Th ,

unresolved item, concerned the need for.the licensee to develop a method to l s

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' calibrate th'e SGTS CO 2 ;. tank level -indicators (Paragraph 9.c). . The first open M

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item concerns-the performance of a more detailed'. review to ensure that water--

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impingement from.firefighting hose streams will'not affect safe shutdown

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i ' systems (Paragraph 3). The second..open item. concerns'the-labeling of the-

- primary Position B breaker.and. correcting of-applicable. documents (Paragraph 5 a). ~

The third ~open item concerns additional procedural ~' control to' assure that

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valve E11-F027A is' closed (Paragraph 5.e).

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?+*R;:C.D Anderson,; Principal Engineer, Nuclear Engineering .

&  ;*S.cJ ; Booker,: Principal.: Engineer, Maintenance

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. pw ' ' *P.,Fesslerp Director, Plant Systems". . v .*J. R. Green',-Supervisor, Electrical,sNuclear Engineering

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1*G. Overbeck, Director,.NuclearLTraining.

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- *D..-Holland,: Nuclear Fire Protection Specialist '

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+ * Pendergast, Licensing Erigineer .

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• J:-H. P1onaLOperations Support Engineer

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• G.;Preston,~0perations. Engineer

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• G.' Reece , : Supe rv i sor , : Nucl ear i Trai ni ng h* * Rotordo,-Supervisor, Corrective Action-

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~ +S.LWilliams, Electrical Engineer; Nuclear Engineering '

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• K. Ridgway,. Acting' Resident Inspector

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p i , "%L TRogers, Senior.. Resident' Inspector n.c , .

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J Theinspectorsalsoc.ontactedotherlicenseepersonnel~duringthecourse Lofithe.. inspectio * Denotes persons' attending the exit interview on June 30, 198 + Denotes,pers'ons participating by.telecon in the exit intsrview

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. ( L on July. 20,1989; cR , ' Action On Previou's Inspection' Findings 4

1. (Closed) 10 CFR 50.55(e) (341/84008-EE): This item pertained to W 4 a potential design deficiency.in_the buried fire protection water piping. By letten dated October 23,.1985, the' licensee committed to maintaining a constant flow of water (0.1 gpm) through the affected

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fire protection ~ piping throughout the' winter season. During.this

inspection, the~ inspector confirmed through review of selective

, operator shift logs that licensee personnel have been performing

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. inspections during the; winter months"togassure that a constant flow

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,of water was being maintained. According to the licensee, no related p fire protection" water system problems have occurred since this

? deficiency wasidiscovered. Therefore, this item is considered'

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b .- (Closed) Open item (341/87040-01(DRS))

This item concerned two

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. observations made by an inspector relative tr improvements needed V in the fire brigade;

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41, ,K i, The first item concerned the difficulty of the Health Physics iTechnician in donning the assigned self-contained breathing apparatus'

@ -(breathing air line appeared to.have been-disconnected). During

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activation of the fire brigade on a June 28, 1989 fire drill, the-inspector observed the timely activation and assembly of the fire brigade. No problems'were noted with the donning of the breathing apparatus. During a fire drill witnessed by the NRC on January 25,.

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'1988,: the inspector.also' noted no problems with the donning of th E breathing' apparatus. Therefore, this portion of,the item is considered close The second item concerned bu'nched up (dangled) fire hose which occurred during a fire dril This could have resulted in an ineffective fire attack (kinked fire hose) when the fire hose m was charge During the previously mentioned January 25, 1988 NRC witnessed fire drill, one of two brigade teams was' observed taking special precautions to assure the fire hose was not bunched.u However, during the fire drill critique,-specific comments were made of the second team concerning.the need to unbunch the fire hoses-to prevent kinking. Subsequently, an additional drill was witnessed'

during this inspection on June 28, 1989. The inspector observed that the fire brigade effectively lead out the fire hose utilized for the fire attack. Therefore, this item is considered close Lc. -(Closed) 03en Item (341/87040-06(DRS)): The licensee was to

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evaluate tie need to add two additional fire protection systems to the Technical Specification.(TS), list of systems that protect safe

shutdown equipmen The licensee's evaluation specifies that.the two fire protection systems were being surveilled and maintained. Therefore, rather than' address where philosophical differences appear to exist, the inspector's primary concern has been resolved by the licensee in

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surveilling and maintaining,the two fire protection system Therefore, this item is considered closed.' (Closed)'0)en Item (341/87040-07(DRS)): Three Deviation Event Reports (DERs) were previously reviewed by the inspector, however, final corrective action was not yet completed. The first DER No.87-274 pertained to the closing coii shorting out during the starting of the electric' fire pump. The licensee discussed the e potential root cause with the vendor's Product Service Engineer who believed the problem to be caused by aging and a humid atmospher .

According'to the licensee,:this failure is not a recurring proble !

The licensee's Nuclear Engineering Department recommended a preventive maintenance (PM) program be established for the fire pump switchgea 'The inspector confirmed that a PM program is now in place and due to the historical information, no other action appears warranted at this tim The.second DER No.87-330, pertained to defective batteries causing a start-failure of the diesel fire pump as a result of low surveillance test acceptance criteria. The licensee has changed the acceptance criteria accordingl No further action appears warranted l

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,@ M, atthistime.JThejthirdDER,No.87-336ppertainedtothreefire i t a rated penetrations r'equiring:to be reworked.five times in'a three-(e,jf W monthperiod.:)The: sea 1'failuresweresbelieved'tobecausedby: axial l w pipelmovementc- Two'of the threeiseals were modified in that:the foam-

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seal!depthfwas; increased:from 7"-to a minimum.of 16"; uThe licensee

.. l determined the' third seal did not' require modification'since the -

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opppsite. wall was' determined to beathe required fire rated barrie 'N "The inspector was provided general area # drawings showing the area- ,

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. , .' wall penetration seal;1ocations. 'Following this review, a planti -

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tour ~by:thelinspector was able to. confirm that each of these . seals-was installed-(astinspected on atileast one side'of the inplace?

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%' ,, (walls). , Based on the results of the preceding reviews, this item g

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j . F (Closed)'Vio1ation(34D68018-01):- The licensee was maintaining

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,fcontrolled copies of maintenance-instructions-(MI) that prescribe E' '

activities affecting quality which had exceeded their two year-sJ review cycleLand whose approval was indeterminate. The licensee

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committed.to convert all.the mis to procedures,-and to suspend ~ ors

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cancel any remaining mis by ' January 1,l1989. ' The inspector reviewed

'the: procedures that were maintained -in the Metrology Laboratory and

' verified that the. procedures maintained in the lab had been converted to nuclear production procedures; Further, the procedures were within their.two year.. review cycle, were approved,- and distributed in'accordance with plant administrative procedur.es. eThe inspector:

has no,further. concerns on this iten; therefore, this -item is g

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considered' close "

f.- '(Closed) Unresolved -Item (341/88018-02): . Followup on the 81icensee's root cause determination and' corrective a'ctions to ensure b that disconnected leads are reterminate Transmitter C36-N405"

-(tor'su wide range level) was found electrically disconnected and;.

inoperable. _The.trans'mitter leads were disconnected by EOP 4847'

Eduring' the relocation of Transmitter T50-N406A. . . Originally,

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Transmitter.C36-N405 was not to.be disconn'ected during the

!"< -implementation of EDP.4847. The' licensee-determined that the

. disconnection of C36-N405 was outside of the original scope of-EDPL4847. Thus, the EDP package should have been' reviewed and o  ; appropriate. concurrences obtained. : As a. result, the EDP was not .

changed to incorporate the determination.of C36-N405 and post modification testing was not-specifie ,

.The licensee conducted a lessons learned Accountability Meeting (88-018) and during the meeting the plant manager stressed the

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• Multiple discrepancies occurred during the work.

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• The Nuclear Shift Supervisor (NSS) was unaware of plant F , equipment which was taken out o,f servic * Craftsmen / foremen overlooked the determination of leads on necessary equipmen '

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!Thistitem appears.to be thesresult of personnel error ~;ein that, thei Y :

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personnel-involved did not r~ecognize~that the-disconnection:of- ' !

my, 4" 4 transmitter C3G-N405 was a' change:in the scope of the original f.DPL

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e .andfshould,have been reviewed; Direct accountability for this event  !

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, could not)be' determined,' but the' Plant Manager stressed to. everyone~ q k that ~many individuals .along theLway could have prevented the,

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problems l encountered. It does not appear!to.be a programmati i P problem;Lprocedure steps yere-in place that should have' prevented n ,

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k this' item from occurring. Further, other torus level instrumentation

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'r w Iplant~ safety as the!C36-N405 transmitter.was not required to be >H '

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. : operable at the time'of.' discovery. -The inspector has no further'

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- t-fconcerns.at.this time and this' item:1s-considered closed.

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A, - Deviation' Event-Reports s

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The inspect 6r reviewed D'ERs;related to penetration fire l seals. In  :

'; accordance with licensee procedures, following NRC. issuance of-an j 4  ; Information Notice (IN), a DER number is assigned to:the IN. The K< inspectorwassubsequently-providedevaluationsofIN'srelativeho ,

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fire barrier penetration seals, fire deportability, and inadvertent

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Loperation of water spray. fire protection systems;

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.Thesevaluation'of IN 88-04, Supplement 1, concerning the. potential'

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, misapplication of. silicone foam material around diesel. generator exhaust ,i

• < piping:and main steam line penetrations specified that none of the; l gy diesel exhaust pipes are sealed, due to the pipingsnot passing through- ,!

.a divisional' fire barrier. The licensee,. identified 14 penetrations:

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containing silicone foam (Dow Corning RTV23-6548) that are associated I

- with the main steam lines. The normal operating temperature of the  ;

main steam' lines is 550 F. According to the licensee's evaluation,  :

I degradation of.the: silicone foam begins.at 660 F. However, th # inspector's' review of the vendor information indicates that short-term (minutes) degradation begins at 660 F for this' type of seal,"but that long term (years) continuous' stability of the seal may'begin to reduce

at temperatures above 457 F. - Therefore, the inspector questioned

,y the licensee's evaluation. The licensee's technical specialist for W; penetration fire seals did not dispute this information'but referenced G = additional vendor'information that'specified when thermal degradation

. does occur. the ' silicone foam slowly loses ~ its elastomeric flexibility,

, slowly.becomes' firm,' brittle, and charred. However, the charred area .,

~does. maintain certain' thermal insulation characteristics. As a result, 1

& the licensee concluded that a 100% surveillance of each of the 14 seals ,

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rather than_the'10% required by TSs was appropriate. In addition,'the i

' licensee's: evaluation indicated that the questionable seals have been i m

_ inspected and no problems have been noted since installation. Based i on the' licensee's assurance that continued surveillance of all such questionable seals will be maintained,'this evaluation is considered acceptabl ~

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, Another evaluation reviewed by the inspector concerned IN 88-56 that l relates to potential nonconforming conditions:such as splits, gaps, voids,

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and lack.of fill in the~ sealing material. TheJinspector discussed the

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flicensee's seal evaluation with.the licensee's penetration. seal technical L specialist and determined that pre-installation, in process, and post.QA L < inspections were regularly conducted during the construction phase of

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installing the seal >

' Basedontheabove,theinspectorconc[udedthatsufficientassurance

.was provided to show that the types of problems described in.this IN l would have been identified during installation. Therefore, this evaluation'

was deemed-acceptabl ' '

The. licensee's evaluation of IN 88-64 concerning the. reporting of i

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plant-fires was reviewed by the inspector. This review determined that u implementation of Emergency Procedure 101 is consistent with NRC guidance i

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-in this area and no further review was necessar f Lastly,-IN 88-60 was reviewed. This discussed an inadvertent operation of a water' spray fire protection system in which water accumulated around a cable penetration. The water seeped through a watertight seal, through'

the floor and into'the control room below. The water. entered into various process panel. cabinets causing a spurious pressurizer high level signal

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and alar The inspector requested and received DER 88-1580 that was written to i address this IN. The investigation and corrective action (Page 3 of 10) of this DER indicates the following:

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• Fermi 2 watertight' penetration seals have been installed per approved and tested details. To date, none of the watertight penetration seals-

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have or are expected to fail in the mode cited in the notice or in any other mod *. DER 88-1580 is not a condition adverse to quality and no remedial p corrective action, root cause, or corrective action to prevent recurrence'is required to.close this documen '

In the licensee's DER Review Form,.it indicates in part that Plant Safety and Site Management has reviewed the response to this DE Plant Safety and Site Management indicated in Part 4A of this response, that a general

. statement in the DER is broad and indicates there is no impact at Fermi; however,.this response is devoid of any specifics. This is not to say that the response is not reflective of,the present. acceptable condition of the plant regarding watertight' seals, it is due to inadequate level of detail regarding items presented via IE Notice 88-6 In response to the Plant Safety and Site Management observation, the DER Part 4A incorporated the' follow;ng respons * Fermi 2 does not use the penetration detail shown in Figure 1 o of the NRC Information Notice 88-60 in the Control Room, nor does it have a fire protection system consisting of water (Water Sprinkler System) above, in or below the Control Roo Therefore, with neither of these required ingredients to create the Vogtle

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Unit1'scenarioLat Fermi 2, ittis concluded that the NRC y information-bas no impact on Fermi 2 operatio '

Based'onreviewofthelicensee'sDER,.it-doesnot. appear.Ihatthe 'l y licersee reviewed the applicability of this. Information Notice to-their ibility in enough detai For example,hto avoid a similar problem where seals may not provide watertight' barriers between redundant safe shutdown trains, the licensee did not address the concern when utilizing manual hose ' stations.within .

safety-related areas land areas adjacent to safety-related area The licensee indicated that additional-review of-the installation of

. plant watertight seals pursuant to this Information stice would be performed from the standpoint of assuring _ that firefighting water hose streams will not involve loss of required safe shutdown trains wncn these trains.are. separated by wall and floor assemblies. Pending review and acceptability of the licensee's actions, this is considered an open item.(341/89020-01(DRS)).

4; Configuration Management Program To assure that the licensee's post fire safe shutdown capability was being maintained'in accordance with licensee commitments and NRC regulations,

.the inspectors conducted a review of tre ,' ant configuration management-program including modifications and chano s, and a selective sample inspection of the, applicable 10 CFR Part 50, Appendix R requirement ,

Configuration Control Procedures Review In preparation for and during the inspection, the inspectors performed in-office and onsite reviews respectively of plant.. procedures governing the configuration control: program, including the various methods by which a change to the plant can be made. The following interfacing procedures governing these methods included: No. FIP-CM1-12, " Engineering Design' Packages," Revision 0, dated March 29, 198 , No. FIP-CM1-14, "As-Built Notices," Revision 0, dated March 3, 198 ^ No. FIP-CM1-01, " Potential Design Changes," Revision 2, dated April 12, 1989.

c No. FIP-0P1-02, ." Temporary Modifications," Revision 0, dated November. 28, 198 No. FIP-CM1-13, " Design Verification," Revision 0, dated March 29, 198 The inspector's selective review of the above pr.)cedures coupled with the implementation review addressed in various other areas of this inspection report demonstrate that the procedures were satisfactor t

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1,5.3 ' Engineering-Design Package (EDP) Reviet i e

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The EDPs wereireviewed to verify that the~ packages;were receiving an y

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4 appropriate) level of' fire l protection:reviewt . The review considered such-- '

items as the impact of design changes on's'fe~ a shutdown capability; the..

m l -adequacy of'theLlicensee's evaluation _of fire' protection components an ,

• ~ equipment in the' safety evaluation'processL..the adequacy of; the review and approval of plant analyses, calculations, procedures,E and licensing-

? documents; and the verification of-complianc'e of_the-as-built configuration with theiapproved desig [' . The following EDPs were reviewedi

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l1 " EDP-1701: ' Dedicated Shutdown-System - Balance'of Plant (B0P)'

Switchgear -and Motor Control Center (MCC) Modification, Lichting, '

N . Communications, Supervisory Controle Fermi 1 Relay Room Modifications'-- ,

, and 120 KV Switchyard Modifications The inspector rev.iewed the following portions.of the EDP.to' determine-if the_ equipment / components'wer6 ~ identified in the" interim Appendix R:

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• Alternative Shutdown TS'(Letter RA-LG-88-0113).

(1) Switchgear Modifications - Buses 64Vaand 65W

• lSBFW Pump Al Breaker' Control =' .,.

lf *: SBFW Pump.B Breaker Control

!, 3  :*' 4160V Position V1 Breaker Controli L * : :4160V Position"V3 Breaker Control

• . ?4160V Position W5 Breaker Control-(2)' MCC'Mo' deifications - 260 Vdc MCC-2PC-l'

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• . LSBFW F1ow' Control N21-F002

• ' iSBFW Flow Control N21-F00 * .SBFW Iso Valve'N21-F001~

'(3) Fermi 2 Control Center Modifications

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• . Dedicated Shutdown Systems (H11-P811)

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(4) Supervisory Control

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e' EF1 Supv Control e '

• EF2 System Transfer e'~ Voltage Control

• Governor, Control '

• - CTG 11. Unit 1 Control / Status ,

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• 120 KV Pos'GM Bkr. Control

• 120 KV Pos GK Bkr Control

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• 120 KV Pos'GH Bkr Control l * 120 KV Pos GD Bkr Control

• CTG 11 Pos A2 Bkr Control

.* '13.2 KV Pos A7 Outbuilding - TSC Fd Bkr Control

• - 13.2 KV Pos A6 5564 Alt Fd Bkr Control

• SS64 Pri Pos D Bkr Control

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.SS66 PriiPos C BkV Contro ,' >

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'-*; sTrans11/Sec Pos A-Bkr Control l 3 g.:r 4 V + JN ;

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TThe' inspector'notedlone; discrepancy-in;the ab6ve (*); interim TS1 ,

Dli.sti ngs. Primary Position B- Control Breaker SS67 was identified:

cy7 , y, 1 .as.Br'aker e No.D68 in7. Steps-5.2.8 and 5.2.21'of.Procedurec gy

,

a- , .No. NPP-24.321.06 (Revision 20)? " Dedicated Shutdown Panel H21-P623 P' - ;W '

Operability: Test lEF-1 Supervisory Control." The. licensee verified-

-

-

afor;the? inspector,that"the breaker labeling lin. Panel H21-P623 was:a~ '

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T68 4 Discussions with the licensee indicated there.wis'some confusion; CS P .as' to. what the . breaker number should be. l0ne line diagram

' Not.6SD721-2500-1 (Revision P), " Plant 4160V'and 480V> System Service d Unit'2,"..'also' indicated thel breaker:numberJwas 67. .Pending thet

' licensee's determination of which! number they'are~ going to use to;'-

'

[b l ,

hlabel thefprimary Position B breaker and to correct all applicable

~ documents',: this is c_onsidered an Lopen -item (341/89020-02(DRS)).

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However, since the procedure'and, panel 11abeling match, the' operator Jshould belable to, perform'the required procedure steps <and.the:.

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ilabelingsdiscrepancy'should=notl affect the. operation of the dedicated

"

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' shutdown; syste , ,

' '

.

$ ;The$inspectorfurther^reviewedProce'dureNosiNPP-24'.321.06 l,, '

'and NPP-24;321.05'(Revision 20), " Dedicated Shutdown' Panel H21-P623 L"'

Operability Test EF2;SystemLTransfer," to assure that the above f *~ , ' ' s

listed 7 equipment / components were being tested as required byLinterim LTS 8.1.1.2. 1These procedures'showed' adequate testing of the~ system

transferfswitches', power suppliest and control; circuits for' the

'

, >

.aboveilisted equipment / components'.

{ 'EDP-1702: <0edicated Shutdown-System - Class 1E MCCs and 4160V m ,

,

'Switchgear Modification, Instrumentation, Installation, and SRV-

Control-Modification

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r .The' inspector reviewed the following portions of the EDP to

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. ' determine /if the equipment / components were identified in the J interim TS:

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,

-(1)L' Instrumentation

• Combustion Turbine Generator (CTG) Unit 1-Volts

• CTG Unit 1-Frequency <

• * CTG Unit 1-Watts

g * CTG Unit 1-Vars

• Condensate Storage Tank Level fM ,

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Standby Feedwater Flow Reactor Water Level-e . Reactor Pressur ' '

• Torus Water Temperature K'*. .

'

• Primary Containment Temperature (2) ' Division II Safety Relief Valve Control

'

• SRV Line B B21F013G s

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1 Allioff th'e?above"itemsswereJ$dequately _ identified in)therin.terim,TS;

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" :The transfer switch schame for the transferring'of manua12 control .

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J of 4RV B21F013G .to . panel H21-P623 was' adequately. tested (interim 1 ~E:

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ETS?8.1.1.2) in Procedure No.124.321.05. ;The' inspector ~ reviewe t , , :the following procedures to ensure that the dedicated shutdown

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, linstrumentationNas-- being calibrated in"accordance with interim 1 CTS 8.1.1.1: ,<

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NPP-44 110.020

.  ? Alternate Shutdown System; .

,

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-(Revisionf20)f Condensate Storage Tank Level s N,. Channel Calibration ' -

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,

'* NPP-44.110.0211 '

Altern' ate Shutdown System

..

.

(Revision.20)- Standby Feedwater Flow Channel

.L

,' M Calibration-

'

L* ' NPP-44.110.'022 'Alternats Shutdown System. ' . ;(Revision 320), Reactor. Water Level Channel; Calibration #

'

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'

, '*[ NPPk44.110.023 ' Alternate Shutdown System L(Revision 20)- Reactor Pressure Channel Calibration c4

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• J NPP-44.11'0.024  : Alternate Shutdown Syste '

L(Revision 20)1 Torus _ Water Temperature Channel ,

Calibration

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? '*- NPP-44;110.025 AlternateiShutdown System .

L (Revision 20) Torus Water Level Channel. Calibration

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-* 'NPP-44.110.026 Alternate Shutdown. System ,

• '

(Revision 120)' . Primary' Containment Temperature Ch'annel

'

Calibration

-

, * 'NPP-44.321.02- Alternate ~ Shutdown System

.(Revision 22) CTG-11 Meter Calibration

=All of the above instrument channel calibrations.were. fulfilling m ;the' requirements of interim TS 8.1.11. Procedure No. NPP-24.324.01

.-(Revision 20)', " Combustion Turbine Generator'11 Unit l' Monthly Operability Check," was also reviewed. Steps 5~.1.10'through 5.1.13

+ '

adequately-fulfilled the monthly interim TS 8.1.1.1 requirement to

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= perform a channel check of. the CTG Unit'1, Volts, Frequency, Watts,

, ,

u and Vars panel indicators, i ' EDP-1794: Addition Of Thermo Blend Device To Fuel Line Of The

'

Diesel Driven Fire Pump-

C :The'thermo blend device was added to decrease the possibility of

,

, paraffin crystal formation in the diesel fuel which~ could potentially

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plug the' diesel fuel filter. 1The device recirculates deaerated warm fu'el directly to the filter and injection system rather:than allowing _

o it to return to the fuel storage tank. The device was added to increase the cold starting. reliability of the diesel fire' pum and was. installed prior to the 1icensee receiving an NRC operating licens The EDP did.not address any potential failure modes of the thermo blend device in regards to a thermostat failure that would permi the fuel to be1 heated above the 110 F thermostat' automatic recycling setpoint. The inspector requested that an engineering' evaluation be performed for this failure mode. The licensee performed an evaluation on.this failure mode,and provided additional information on the device failing open and continuously; recycling fuel back to the storage tank. The inspector reviewed the engineering evaluation and concurs with the licensee that the above thermo blend failure modes would not prevent the diesel fire pump from performing it's design function.' In addition, the licensee informed the inspector that they had contacted the diesel manufacturer. The thermo blend'

fuel. warmer was approved for use by the manufacturer, The thermo blend device has been in service for'over four years. The licensee nas experienced no difficulties with the device preventin diesel s',arting when the diesel' fire pump is run weekly at load fo one hour. Further, there is also a motor' driven fire pump available 4 to bachup the diesel fire pump. The inspector had no further concerns-on this' ite EDP-5126: : Transfer Of Torus Water Level Valvce Control To Panel H21-P625

,

.The licensee identified (DER NP-65-679) that valves E41-F400 and

.T50-F412A were subject to. fire induced spurious closure during events requiring the use of the dedicated shutdown panel (H21-P623).

Spurious closure of these. valves would result in the loss of torus water level indication at panel;H21-P623. The licensee installed a transfer switch scheme and separate power feed to' alleviate this proble The inspector and licensee walked down several of the EDP installed cables to assure that they were routed in compliance with Appendix R Section III.G.2. The following cables were walked down:

Cable Routing 262187-1C Conduit CC-052-1C Conduit DD-090-1C 262189-1C Conduit DD-091-1C  !

262191-1C Cable Tray 1C-056 Cable Tray IC-055 L

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Ob_L_ _ z __ _ ___ .

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l 214292-1C Cable Tray 1C-033

, Cable _ Tray 1C-034 Cable Tray 1C-035

.

'

Cable Tray 1C-053 Cable Tray 1C-094 The above cables are required to be operable for certain fire l scenarios involving the Auxiliary Building. .The walkdown verified l' that the above cables were routed through the Reactor Building and would be available to operate valves E41-F400 and T50-F412A from panel H21-P62 l The EDP also installed additional control power fuses. The two 5A :

fuses, Type FRN-R-05, installed in power distribution panel 2PA2-14 I were adequately sized for this application and they were coordinated with their upstream protective devic e. EDP-8576: RHR Valve Interlocks To Prevent Inadvertent RPV Draining This EDP is scheduled for implementation during the upcoming RF01 outage. The Institute of Nuclear Power Operations (INP0), through SOER 87-002 informed the nuclear utilities that seven separate events had occurred where reactor vessel water level was inadvertently lowered by improper valve line ups in the RHR system shutdown cooling (SDC) mode. The licensee has been using administrative controls to prevent this from occurring. This EDP will provide interlocks to suppression pool suction valves E11-F004A, B, C, D, and test return valves E11-F028 A, B, with shutdown cooling suction valves E11-F006 A, B, C, and D. The interlocks will prevent the opening of the E11-F004 and E11-F028 valves if their associated, divisional Ell-F006 valves are open, to prevent draining the reactor vessel water inventory to the suppression poo ,

Valves E11-F004C, E11-F028A, and E11-F006C controls are  :

transferable to dedicated shutdown panel H21-P626. These valves )

are used when shutdown torus cooling is required per Procedure i No. NPP-20.000.18, (Revision 6), " Control of the Plant From the j Dedicated Shutdown Panel." The EDP adds the E11-F006 interlock'

contacts upstream of the Ell-F028A transfer switch contact Therefore, valve E11-F028A may be opened when E11-F006C is.open .

as per the EDP design, when shutting down the plant from the i dedicated shutdown panel. When torus cooling is no longer required, l Step 25 of Procedure No. NPP-20.000.18 requires that E11-F028A be closed and that torus cooling / test isolation valve E11-F024A (which is in series with E11-F028A) also be closed. Administrative j controls are therefore used in the dedicated shutdown procedure to l prevent the accidental opening of E11-F028A if E11-F006C is ope I Further, if E11-F028A is accidentally opened, valve E11-F024A is available to prevent inadvertent RPV draining. After discussion with the inspector, the licensee agreed to consider adding a note to Procedure No. NPP-20.000.18 to alert the operator, when shutting down the plant from the dedicated shutdown panel, that the potential i for draining the reactor vessel to the torus exists since the logic I does not prohibit the opening of valve E11-F028A when valve E11-F006C is ope ,

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f,. ' fA'second7 reactor pressure! vessel (RPV)Tdrainage path could ' occur:if ,

fy * * s E11-F006C)and E11-F028A were;open togethe Valve E11-F027A, "

RHR :

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D ,

y -Loop'A Suppression? Chamber; Spray' Inboard: Isolation Valve," tis in: ,

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.

' series' with E11-F028Atin1the torus: spray piping.1This valv'e _ is: .

. N inormally closed.' :.However,VitsJcontrol cable < is'run throughJseveral' -

A 'of'the fire-zones'that:use'the dedicated shutdown 1 panels lfor' safe 1

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- ' The inspectorJwas concerned that E11-F027A'may: spuriously open- from

.

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,c _"r a fire'in the control room or' cable spreading room. .,The position '

t-of E11-F027A:is not verified in Procedure.No. NPP-20.000.18. Since

1. closure 'of_ E11-F028A<is assured by administrative ~ controls only,

'

"w

.

< when usingLthe dedicated' shutdown panels, the'potentialLexists"to ,

~inadvertentlyLlower reactorivess'el level by an impr'oper' valve line -

up when using'the dedicated 3hutdown panels. The first! scenario

[ , ri .(E11-F028A and E11-F024A) relied'on'two series valves to. prevent the

'

. inadvertent draining of the!RPV. In the second scenario (E11-F028Ai and E11-F027A) E11-F027A is in a paraller path with E11-F024A and inL

~

, series with E11-F028A. ;Since E11-F027A'may:spurio_usly open.due,to a

.

fir ~e in the control' room or cable' spreading room, this;1 eaves'only'

~

i

.one. administratively' controlled _ valve'(E11-F028A) to_ prevent the

'

' '

-

inadvertent draining of the_RPV. Pending the licensee's" analysis o thistscenario'foria possible'way to assure E11-F027A is closed, thisi

'

-

is considered.Jan'open it'm e (341/89020-03(DRS)).

^ '

' EDP-4797: . Fire W' rap Wire Way RI-069 And Conduit RI-005-2 , . 7 lThis'EDP: conc $rnedithe installation 'of a one hourifire barrier wra .

- " encompassing wireway RI-069 and conduit RI-005-2P, _both of which ares located on the second floor mezzanine'at elevation l631'0"'by-

Col umn" F-11.' This fire wrap was to be installed in accordance with

'

Project Specification No. 3071.327, " Installation Work For Fire

'

. Protection.of CablecTrays, Conduits, and Hangers;",Rev.ision1F, dated Decembhr 1984. The inspectoh performed a visualiinspection of the installed'. fire wrap, in part? using the Project' Specification

. document and confirmed that the' fire barrier material was in plac P

,

'as require .EDP-4944: Addition of Fire Wrap On Division II Trays In Auxiliary Building First Floor Mezzanine-

' This.EDP pertained to the-installation of a one hour fire ~ barrier wrap to cable trays containing Division Il post fire safe shutdown circuits, that-are; located within twenty feet of the Division I

'

H-

1. ' cable trays in the^ auxiliary building, first floor mezzanine. Project

.

'i" . Specification No'. 3071-327 and drawing 6E721-2808 sheets 19'through J < ^25 and 68 through;71 were to.be utilizedfto install the required fire wra The inspector conducted a visual inspection of cable trays 2C-012

, ,

and 2C-030, in part, and confirmed that the fire barrier material was in place as. required. Asipart of the EDP 4797 and 4944 .

'

m reviews, the_ inspector was provided a' copy of Surveillance

,

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Procedure No. ;NPP-24.501.12 (Revision 20), " Fire Barrier Inspection,"

which was also used during the inspector. reviews of the installed fire' wrap materia *

_"

, in summary, the licensee was adequately implementing their design process

'

in Jaddressing the aspects of fire protection. The EDPs reviewed

- considered such elements as'the impact.on safe shutdown equipment; the safety evaluations presented an adequate basis to determine that the EDP did not involve an unreviewed safety question;'the documentation

.to' support the EDPs was in the package or easily retrievable; and the walkdowns verified that the drawings reviewed represented the as-built configuration of the plan : Operator Training for the Dedicated Shutdown Panel

,

As part of the functioning configuration management program with, respect to postfire safe. shutdown capability, the inspector reviewed operator training to verify that the training is in accordance with licensee commitments and NRC regulation The result of the inspectors review

, of the operator. training program follows: Instructors Lesson Plans The inspector reviewed the licensee's lesson plan titled " Remote Shutdown Systems," plan number LP-0P-315-144 which encompasses operator training for the. dedicated shutdown panel (3L Panel).

No discrepancies were identified during this revie ; Operator Training Handouts The inspector was provided with a copy of the operator training material titled " Remote Shutdown System (PIS C35-36)," Procedure No. ST-0P-315-044-001, Revision 5. The inspector reviewed a portion

.of the procedure regarding the dedicated shutdown panel (3L Panel). !

No discrepancies were identified during this revie Training Records ,

By letter dated October 14, 1986, the licensee committed to performing annual retraining on the 3L panel. According to License Condition 2.C.9(d) of the licensee's Operating License No. NPF-33, the 3L panel was to be made operational by December 31, 198 The inspectors requested the licensed operator attendance records j for training on the dedicated shutdown panel for 1985 through 198 At the time of the onsite inspection, the licensee was unable to provide many of the records requested and therefore additional time was needed. To follow up on this' concern, the licensee forwarded a letter dated July 10, 1989,:(NL-89-0163) from G. Reece to J. Holmes which indicated the'following:

1985 Training was conducted for all shift personnel upon installation of the panel beginning on November 25, 198 !

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1986 Nh l documentation l on:the13L Panel" training 1was' foun ,=

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< 4 71987'

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Documentation shdws the trairdng was conducted for;all"

..alicensed operator personnel during thef requalification' '

& *- .

.

'

cycle of! February 19, 1987 through December 30,:198 f /< 1Thisl training only involvedJa lectur ~

(1988 Documentation shows the training was conducted for-shift 5 <

n, ' personnel on_1y from February 7,t1988 to February 8,.198 ,

' '*

,

,

'

,

This' training.. included lecture and walkdow 'L ,

, r 1989' -The;traininghas(beenreinsfatedandconduct$dduring'bothi ,

'

, licensed and non-licensed operatorLrequalification

>

'

training from June 9; 1989,' through. July. 7,1989, with thei

,

- remainder of the: shifts to. complete;the' training durin ;their training requalification weeks. This' trainin ..i< included lecture and;walkdown.-

g 'i . Failure tLo implement the annual requalification training for hhe?

'

dedicated ~ shutdown panelJis considered a deviation'as~ described in

,

a the' Notice of Deviation (341/89020-04(DRS)).

T0n' July 14,1989L the zinspector questioned why ;the training was not

"_ completed as required. The licensee ~ indicated that as part.of :their

,

,

, taskilist'~in 1985 which apparently described the items,to be: covered

'

in the, initial operator training, the; dedicated shutdown system was

'

,

'

,

-

not included'in the , task lis Further, according to the. licensee, the reason why th'e yearly

<

'

training'had not been done as required was that the commitment

> letter; was dispositioned;as a' one time regulatory; action commitment >

'(RACTS) item and no separate: commitment covering ongoing training had been created. Consequently,Ta DER was issued.as:a result'of-this' inspection and a new RACTS Item, No. 89357, was written to

)q capture the 1986 commitment and ensure that annual trainin'g on

+ " b. 3 the 3L panel would be performed in the' futur ^

. ,'

The' July 10, 1989 letter also indicated that the supervisor of E nuclear training responsible for operator training recognized that ,

the 3L panel, training 'needed to be on the requalification schedul This was based on the infrequent use and the importance of the panel.-

After recognizing the need,: the supervisor took action and placed the 3L panel training in the 1989 requalification program for all' operating personnel; however, the inspectors identified that j' previous required training as described in the Notice of Deviation

> was not satisfactorily performed. ~ The classroom lecture and walkdown were scheduled for cycle four which was completed for all shifts b ,

Ey July 14, 198 t Procedure'Walkdow <

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'

"

~ The inspsctor accompanied by licensee personnel performed a .

- walkdown' of the dedicated shutdown panel procedure (for hot shutdown only).  !

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.( R Shift Composition- ,-

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U In the event of'a disabling fire that. requires" evacuation E of the-control. room,:theglicensee is required to. provide

[ sufficient personnel to' provide an orderly shutdown and L .cooldowntof;thecreactor as well'as provide a minimum of a

[ five person fire' brigade to control and extinguish the' fir _

b In the Fermi-2 FSAR, Table 6.2.2-1 titled " Minimum Shift Crew Composition," itLindicates that the following individuals would be; required with the reactor at powe Number of

,

Position Personnel l" Nuclear Shift Supervisor .

(NSS) 1 k Nuclear-Assistant Shift Supervisor (NASS) 1

, Nuclear Supervising Operator (NS0) 2 Nuclear Power Plant Operator / Nuclear (NPP0/NAPP0) 2 Assistant' Power Plant Operator Shift Technical Advisor (STA) 1 The review of Procedure No. NPP-20.000.18, " Control of the

"

. Plant from the Dedicated Shutdown Panel," requires one licensed operator at the dedicated shutdown panel and one non-licensed operator to perform necessary manual actions to provide power and control to equipment that was determined to be free of fire

~ damage for a fire in the following areas:

(a) Relay Room (b) . Second Floor Mezzanine Auxiliary Building (c)' Cable Spreading Room-(d) Control Room, Control Room Offices (e) Third Floor MCC Area-(f) Fourth and Fifth Floor Auxiliary Building It should also be noted that manual actions are taken by the non-licensed operator to prevent high impedance faults from affecting the equipment required to bring the reactor to hot shutdown condition One additional licensed operator may be required, as indicated by the procedure, to scram the reactor and trip the main turbine if this is not accomplished initially by the licensed operator reporting to the dedicated shutdown pane Based on the " Minimum Shift Crew Composition" table, there are at least four licensed operators available at the

},

plant during normal plant operation (2) Fire Brigade Personnel l-The licensee's procedure for shift turnover in the control

'

room, NPP.-0P1-05, Revision 2, requires the control room nuclear station operator to verify the following personnel are aware of their assignments to the fire brigade:

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, 1(a) One'NSO, Fire Brigade' Leader .

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, '(b)'1ThreeiNPP0's,YFireBrigade1emberJ ,

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,' .(c)L 0ne'I&CLTechn.ician'or an additional NPPO, Fire Brigade;'~ '

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, l (3)L iC5r.clusion > .

' y %z :j i, MT Basedon:reviewofthededicated~ shutdown!procedurepFSARL .i 715,, m

,

N fable 6.2.2-11 titled in part, " Minimum Shift Crew Composition,"

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theLlicensee?has provided administrative' controls to' ensure m that adequate. person'nel:are provided.to implement'the dedicatedl

"

.

'

. ' shutdown l procedure 1and maintain' a five person fire brigad w: ,

. . . .

"

- 0 lTh,e{ inspector'requestedandreceivedtheshiftassignments;for; K<  % May;30;11989; Junet18,' 1989; and June 28,fl989 (three' shifts

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per day)L ' ' 1  !

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'f Based ori r'eview of;the'~ shift- assignments, sit appeared. tha '1 A , , ' adequate personnel'were available to implement the dedicated : ,

,

'

^ safe shutdown Procedure No. NPP-20.000:18 and simultaneously 'l

'

'

maintain a ;five person fire brigade. -No violations or l deviationsfwere

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identifie , ,

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Fire Barriers / Cable. Separation / Associated Circuits j!

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'

,

As part of'the' configuration program review, to; assure that-fire barriers ~

'

y and~ cabling 1 required to remain separated was being maintained, the 1

^

.

in.spectors performed a selected review of. designated fire barrier walls i

" ^

Hincluding the fire barrier penetrations (fire doors,Lfire dampers, etc.), l

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and associated circuit ,

-

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' Fire Barriers ,

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,

-Section9A.4.2.6'o'ftheUpdatedFinal'SafetyAnalysisReport(UFSAR)/ l

'

.

- regarding the cable tunnel, Zone .5'of the Auxiliary Building on- j

1. 4 f elevation 613' 6'E specifies' that7the tunnel is divided by a three

,

>

Lhour fire rated gypsum wall that separates Division I and 11 safe ,

shutdown equipment and cables. During'an in plan _t inspection, the  !

'". "~

inspector used "Firewall In Cable ~ Tunnel" Drawing No. 6A721-2426, .

Revision B," dated January 3,1M and verified that a' gypsum wall y j

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with' fire; rate'd doors and.dampera was being maintaine Although thisxlocation was poorly. illuminated, the. inspector used portable l

', , O handheld'lightirig ano did not observe any unsealed penetration  !

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openings. The inspector also confirmed the fire rating of certain  !

r4 fire' barrier penetration !

- Additionally, while touring other vital plant areas, the inspector j e observed certain fire barrier penetrations such as fire doors to  !

G 'have minor' deficiencies. However, the licensee staff had already  !

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- identified these deficiencies and corrective actions hcd been l initiated. None of the noted deficiencies appeared to affect I i

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the. fire-door $' operability. iDuringjthese plant. tours, the inspector-

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obs'erved;that roying fire watch patrols were in progress and:

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idetermined they were being conducted in' a,. satisfactory manner.

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" ' Cable ^ Separations ji 3 Mc <

A review of the_ Standby Feedwater System (SBFW) cabling was. performed

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t as this system is required for' post fire safe. shutdown. .SBFW post y fire safe shutdown Calculation No. .1020-014-300, which was performed W  ;"

• ibyla' licensee contractor,:specifie's.that this system'would be used g-

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in the event ofL a ^ fire'in the controle center complex. and'othe <

designated; fire zones lwithin the Auxiliary B.uilding.3 These areas; W '

, are; referred to as the e' inate shutdown areas. Therefore, the f .inspectortverified by drawing review'and plant walkdown.that the SBFW Pump "A" power feed, which.would be required to be' independen .

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.of the alternate shutdown ~ areas for use with the Dedicated Shutdown

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tSystem,'isephysically ndependent i as re' quired.-

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-FurOier,Lwith the addition of the dedic'ated shutdown panel th fv post fire safe shutdown capability fire barrier requirements were

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' revised to reduce the amount-of fire wrapping 1 required.- Since

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J certain trays and conduit mayL have already been fire wrapped,

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l, . a question was' raised as to how the licensee would assure that~

$ m equipment requiring fire wrap would not inadvertently be allowed to I

become: degraded over the life of the plant.. The licensee provided-

? an interna 1L clarification . letter dated November 26, 1986, that

& specifically_ identified those trays and conduits needing to be fire'

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wrapped. According to the licensee's staff,' appropriate licensee personnel have been advised accordingl Consequently, the inspector selectively sampled six additional cable trays' and/or conduits L required-to be fire wrapped in the basement of the Auxiliary Building l* and confirmed that the applicable equipment was' wrapped. Therefore, the inspector' concluded that the licensee was adequately maintaining the fire wrap configuration as. require Associated Circuits

'The spurious signal concern is made up of the following two items:

? (1) Ths false p tor, control and instrument readings such as

' occurred at the 1975 Browns. Ferry fire. These could be caused

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by fire initiated grounds, shorts, or .open circuit ~.

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(2)c Spurious operatio~t of safety-related or non safety-related i

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,. components that would' adversely affect safe shutdown capability, l- -

• such as RHR/RCS isolation valves, a?n

' d kiW W The licensee has analyzed and i tatified the hi-low pressure interface .

valves which may be susceptible to sp.rious signal actuation. These~

3' are' the RHR suction isolation valves from the recirculating pump 4 i y p suction (E11-908, E11-F009, and E11-F608).

The inspector' reviewed Calculation No.> 1020-009-300, "High Pressure a W to Low Pressure' Interface Analysis," and Modifications for Fire l[ ,

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Protection Systems (Section 9.5.1;'SSER No. 5 and SSER No. 6). The

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SSER stated in part that1the licensee shall continue to remove power from the Division I cooling. tower bypass valve (E11-F603A) and from.

• T" z either the series valve (E11-F008) in the RHR system or the two-parallel RHR suction valves (E11-F608 and E11-F009) du,'ing normal plant operation until the independent alternate system is declared operational. The inspector verified the configuration of the above valves in the control' room. All of the valves were closed and ha power;to them, except E11-F008 which was closed and had pasition indication only (control fuses installed). The NSO info'med the inspector-

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that the E11-F008 power fuses were removed. The licensee considers l

the alternate shutdown system to be operable. Thus, the as-found condition of the above valves was acceptabl .

The inspector: and an operator inspected the MCC compartment .for  ;

valve No. E11-F008. The power fuses were removed as required in Procedure.No. NPP-23.205 (Revision 29), " Residual Heat. Removal l System." /The operator informed the inspector that the fuses were removed for, Appendix R reasons. The power fuses removed were FRS-R-80s~and the installed control power fuses were:KLM-30s. This agreed with Specification No. 3071-128 STD-FJ-2-1, " Class IE and IE-B0P -Isolation Fuse List" (Revision J) ard Schematic Diagram 61721-2201-05 (Revision U), " Reactor Recirculation Extraci.or to RHR Outboard Isolation Valve E1150-F008,".Nott Therefore, administrative controls of the E11-F008 valve were acceptable and the inspector has no further concerns on.this ite . Emergency Lights, Emergency Lights Walkdown

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The inspector ob'.z ved in general that the emergency lights for dedicated safe shutdown were found to be installed to provide-adequate lighting for equipment and pathways. However, emergency lighting was-lacking in the following are (1) Pathways and equipment for 260V MCC 2PC-2 (TB2-M2)

(2) E1150-F603A (Division ~I cooling tower bypass valve),

E1150-F604A and E1150-F605A (Division I cooling tower inlet valves).

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(3) Emergency Diesel-Generator 13 and Emergency Diesel Generator 1 Y (4) MCC 728 4 The licensee provided the inspector with DER 88-1559 dated (discovery l date) August 24, 1988, that indicated during a waltdown of Procedure No. 20.000.18, that it was notee that Section 1.2.2 required operator actions at MCC 2PC-2 (TB2-M2) and'that there are no emergency lights provided for the path leading to or at MCC 2PC-2. The DER recommended

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that the operators use the carpenter lights located in the fire brigade dress out area'for illumination at MCC 2PC-2 and pathway l According to the licensee, operators are aware that portable lights are available. The corrective action was to be effective until permanent' emergency lighting was installed with an original due date of December 2, 198 . Based on review of the documentation for DER 88-1559, the priority for the installation of. these emergency lights was low (e page 11

~ of DER 88-1559' dated May 18, 1989, it indicates that~ minor MOD,9529 was assigned a low priority (3), therefore, a schedule could not be

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provided). In addition,' plant engineering issued a work request on-May 18, 1989, to perform the following:

• Add minor MOD 9529 to.the plan of the day (P00) list for accountability, tracking and scheduling

• Obtain a daily update on the progress of the minor MO l

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0n July 7, 1989, the licensee indicated that.the tentative date for completion of the walkdown and installation of the emergency lights was expected to be May 1, 199 j

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Based on licensee's identification and followup action, the ,

inspector determined that no violation was appropriat E_meroency Lights Surveillance Procedure In the DER, Part 4E, it indicates that a discrepancy. exists between Procedure Nos. NPP-27.322.01, " Monthly Inspection of Emergency Lights,"

and NPP-37.000.014, "18 Month Emergency Lighting Performance Evaluation,"

in that the monthly surveillance lists about 126 lighting units by PIS Nos. and the 18 month procedure lists only 87 u11ts. In addition, the DER indicates that neither procedure provides verification that

'the lamps are positioned properly as installed (some lamps are subject to bumping and could be mispositioned) to provide emergency lighting for safe shutdown equipment and pathways to safe shutdown equipmen However, during the inspector's procedural walkdown, no emergency lighting lamps were identified as being mispositione The licensee informed the inspector that resolution of this concern l'

and upgrading of the procedures will be completed by May 1, 199 The inspector has no further concerns un this item at this time.

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, ' Fire _, Protection System Surveillance Test Program i

The inspectors reviewed, in part, the licensee's fire protection system ,

surveillance test program as implemented by plant TSs. The fire protection i

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TS system review included the examination of fire protection surveillance

. test procedures; a selective sampling of specific fire protection ,

areas and equipment; the' calibration of plant-installed fire protection instrumentation; and the observation of surveillance testin ;

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^ Surveillance Test Procedure Reviews

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t-0 The" inspector reviewed the following procedures:

Proc'e dure Title

• NPP-20.000.18 Control Of The Plant From The Dedicated (Rev. 6) Shutdown Panel

'* NPP-24.501.05 Fire Suppression Water System (Rev. 20) Simulated Automatic Actuation Test

,-  :*- NPP-24.501.07 . Diesel Fire Pump Engine Operability Test (Rev. 20)

All of the above procedures were adequately fulfilling.their  !

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associated TS requiremen During the review of Procedure No.' NPP-2'0.000.18, the insoector noted in Step 7 that the operator was required.to start both SBFW pumps. Since the suction source is the condensate storage tank (CST)_and suction is taken through a standpipe, the inspector was concerned that the operator may not be cognizant of the standpipe and that the potential existed to lose pump. suction at approximately

~ine n (9) feet indicated CST. level. -There are no alarms associated with the 9 ioot leve1 ~ and there ..is no automatic sucti9n transfe The inspector discussed'this concern with the training department and'the operetions surveillance procedure writers. The licensee indicated that a caution note was' appropriate and was pursuing the incorporation ef a note into' Procedure No. NPP-20.000.18. The inspector has no further concerns on this ite Fire Protection Equipment

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(1) Diesel Fire Pump Discussions were held regarding the loss of offsite power resulting in only tne diesel fire pump being operationa The concern regards the scenario when the diesel fire pump may be out of service for maintenance and a loss of offsite power occurs causing a loss of the remaining fire pump (electric).

The licensee identified the Fermi I diesel fire pump as an alternate source of water to supply the fire protection system demand. At the exit interview on June 30, 1989, the licensee acknowledged that a note would be added to an appropriate operations procedure designating the Fermi 1 diesel fire pump ,

as an alternate source of water for the above scenario. In

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addition, to avert the need to use the Fermi 1 diesel fire pump during the above scenario, the licensee provided the inspector with documentation showing that the Surveillance Scheduling and Tracking System recommends the 18 month surveillance of the

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p*( @g" , W > I /Fermic2 diesel fire pump.be pedformed only during operationa ,

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1> . modes four and.fiv'e. .The. licensee's actions.were' prudent and-ff[, re s ol ved : thel i nspecto r' s , conce rns .' <

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l(2)hCarbon' Dioxide-(CO)FireSystems? 2 7p , e

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( iThejinspector'selectivelyexaminedtheCO 2 i' ire. systems $ including:

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'the CO2 system concentration test results,from three' specific' '

, plant-areas,-verified the correct use of the: installed nozzles,

. 'and; confirmed.the correct C02 system valve alignment. These

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.plantiareas included.the' emergency dibsel generator rooms

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numbered'13<and 14, and the. cable tunnelltest.results. A E f Jreview of those area'CO2 concentration test (strip charts).

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results and: accompanying-documentation; including discussions

,, ~ with the' licensee's. technical staff; demonstrated that: .

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ls jsuccessful.' concentration. tests had been performed in accordance twith the licensee commitments.

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LDuring.a plant tour, the' inspector. requested the licensee to; J

+ fconfirm that the..i_nstalled CO '2 discharge nozzles'were approved b

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for.C02 system.use. Subsequently, the licensee'provided documentation to demonstrate that the installed nozzles 1are m

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Chem'etron brand nozzles which ape approved as suitable.for,002

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, system us p .' 'As

part. of;ths Linspector's review,~ physical in plant' inspections were conducted toiverify that three 'of the low pressure C02

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storage tank pilot valves were being administrative 1y maintained ~

t in:the proper (open) position. The inspector accompanied by-the-

plant nuclear' fire protection specialist confirmed that.,the.three

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valves ~were in.their proper ~ position'. . Calibration

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?' The$inspectorreviewedthe'TSsandselectedthsperformance z

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parameters' that! are used to assess fire suppression-systems operability and verified that th'e instrumentation monitoring these-

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Eparameters was.in a calibration progra The,following TSs were

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J reviewed: s

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-Parameter * Inst ~ PM (Calibration)

TS -

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'4.7.7.1.1.f.1? FP Flow Calibrated test gauge and Pilot ey-#"

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FP Rated Pressure Motor X80RA03 J426 Diesel- X80RA03 J427

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..4.7.7.1.1.f.3 FP System Pressure

. Start Motor X80N460 W97 ~ <

Diesel X80N461 W976 m ,

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. 4.7.7.1.-2.a.1 FP Diesel Fuel! Storage Dipstick

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TankLLevel'

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I 1 L4.7.7.3. CO2 Systems Pressure L SGTS Div. I T46R008A' 0349 0' SGTS Div. 11 T46R008B '

U357 EDG Div. I X80RA05A 'J417-ElG Div.'II X80RA05B J418 Cable Tray /

!, . Div..II switchgear P80R006 .P217

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4.7.7.3.2.a1 'CO2 Systems Level .

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SGTS Div. I T46R009A None SGTS Div. II- T46R009B None EDG Div. X80RA06 J415

,, x EDG Div. II X80RA06B J420

' Cable Tray /  !

Div.;II Switchgear P80N069 P223

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[ ' The inspector was concerned that the SGTS CO2 tank level indicators

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were not'being calibrated. The indicator is operated by a mechanical ,

float arrangement and was supplied with the tanks with no means to

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isolate the indicator for. calibration purposes. The level indicator y . is a standard device and is used with this style of tank at other utilities and private industr At present, it appears that the only way to calibrate the indicator is by draining the tank and open.ing >

'the inspection cover. However, this is not a good maintenance  ;

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. practice and would make the SGTS CO2 system inoperable.' j The inspector' considers the'SGTS C02 system to be operable based on the following: (1) this style of gauge is standard throughout th industry; (2) the pressure indication on the tank'was in calibration and was. checked on a weekly basis; (3) low tank pressure indicatio could be an indicator of a system leak (decreasing level as the .)

- result ofiinventory loss); and (4) overall system testing was l

completed satisfactorily. However, to ensure that the level instrument continues to function correctly, and to adequately fulfill TS 4.7.7.3.2.a, the licensee needs to develop a calibration method or j develop another method for determining tank level. This .;onsidered ;

an unresolved item (341/89020-05(DRS)). { Observation'of' Surveillance Testing  !

The following surveillance tests were observed:

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(1) NPP-42.501.01, " Diesel Fire Pump Battery Inspection - Weekly,"

Revision 21. This surveillance test is performed weekly .

as required by TS 4.7.7.1.3.a. The test was completed i satisfactoril The electricians performing the test were qualified and had previously performed this test, selected the correct measuring and test equipment (MTE), verified the instruments'were within their calibration due date and

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maintained good personnel safety habits while wo hing on

- - the batteries.'. The inspector reviewed the. calibration.

- records for the following MTE

(a) Thermometer 6T.027-M s-

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(b) Digital Density Mete FTE-6425 The instruments were being adequately calibrated and controlle .(2) .NPP-44.160.001, " Fire Detection Operability and Functional

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Test,"' Revision 22. This surveillance test is performed once-

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lper 180 days 'ts required by TS 4.3.7 9.1'and TS 4.3.7.9.2. The

~. inspector obseived a portion of Zont 10 - Reactor Building, 2nd i

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floor testin In addition to the functional test, the .

c Pyrotronics Model DIS-5B ionization detectors were inspected, cleaned and caliirated as a PM practice. Procedure No.. NPP-46.505.0i1 (Revision 20), " Calibration of Pyrotronics Fire Detector Models DIS-5B, DIA-7, DI-7, DI-4A, DI-4D, DI-4H, j DPS-2, and DPS-3," was-used to conduct the PM. The inspector

- noted that the PM did not reference Procedure No. NPP-46.505.00 Maintenance Instrument and Control (I&C) personnel indicated that they were cognizant of this. As.the PMs are performed, they are i reviewed and the additional job' instruction section of the PM '

1was being changed to reflect the work being performed. The PMs' ";

were also being closely scrutinized to change.any. reference to maintenance instructions to their appropriate nuclear production procedure (NPP). The I&C foremen were familiar with what procedures

.were required to perform a particular maintenance activity and as a result, it was.their responsibility to choose the correct procedure. The inspector verified.that the correct procedures

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t were being use , q Two detectors, T82N438U and T82N438T, satisfactorily passed the i functional test and'the calibration verified the detectors were l within their required manufacturer sensitivity (Vendor Manual VMB 11-2.0, "Pyrc.ronics - Operation Principle of the PYR-A-LARM Ionization Detector and Application Engineering Fundamentals").

A third detector, T82N438L, failed'the calibration and was replace I The I&C technicians performing the test were qualified and had i previously performed this test, they selected the correct MTE,  ;

and verified the instrument was within its calibration due  :

date. The inspector reviewed the. calibration records for the Fire Detection Sensitivity Meter, SCU-9, used during the tes The instrument was being adequately calibrated and controlled, i I

The inspector. discussed with the I&C technicians the level l of fire protection instrumentation training that they had receive The technicians indicated they had received training in the last quarter under' Continuing Training. The training l 25 1 ,

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e lasted three days and the technicians indicated the training was very goo The inspector reviewed Student' Text ST-IC-331-019,

" Fire Protection System." The material was in-depth and covered the fire protection systems utilized at Fermi 2. The degree of instruction was to the component level. The inspector found the level of training provided to the I&C technicians to be acceptabl .1 Communications Dedicated shutdown panel Procedure No. NPP-20.000.18 does not require e mandatory use of portable radios or any other type of communicatio However, based on discussion with the licensee, it was the inspector's-understanding that the portable radios would be available in the event of a fire requiring evacuation of the control room-and a loss of offsite powe At the inspector's request, a communication test wasLconducted between the dedicated shutdown panel and the following areas:

Location panel AB2-F10 H21-628 RB2-B15' H21-625 RB1-F14 H21-626 RHR Complex l'G-11 RHR Complex DIV ' Pump Room No discrepancies were observe .

1 Plant Tour Observations The i^spectors toured many of the safety related areas in the Auxilt ry and Reactor Buildings. The inspectors noted that the fire protection equipment such as dry chemical, carbon dioxide extinguishers, and hose stations were found in good condition. In general'the housekeeping in these areas was also good; however, the inspectort observed that the safe shutdown cabinet (2nd floor switchgear room Radwaste Building) was being utilized as a table for electricians performing surveillance 'in the area. The plant fire protection specialist took immediate corrective actions to remove the electrician's equipment from blocking access to the safe shutdown cabine The inspectors discussed this event with the licensee and indicated that plant personnel should be aware of the safe shutdown cabinet and fire protection equipment so that the equipment is not blocked in the event it is nee &d. The plant nuclear fire protection specialist indicated that this is the first instance that he was aware of that the safe shutdown cabinet was being utilized as a table l

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by the electricians.and indicated that there'are' portable carts.that are available for plant personnel to use. Based on.the licensee's j"

'immediate corrective actions of removing th0 electrical. equipment' .

from the safe l shutdown' cabinet and informing the individuals involved h ~

to utilize.the carts provided for.their use, no further action'is require During the inspectors'. tour outside within the protected area, the

[- inspectors observed that housekeeping in general was' good; however;

the

following observations were made:

f(1)"LLadders, pallets and miscellaneous items were stored in storage

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Building No.'41 such that' access throughout the building was-

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severely restricted; for fire fighting personnel.

p (2) The: licensee is; currently storing _ low level dry radwaste.outside in approximately/12 metal trailers, north of the,Radwaste Buildin The inspectors obsecved that one-of.the metal trailers was provided with wooden doors and. aluminum siding. This traile was. adjacent to a smoking are The~ inspector observed '

-approximately 50 cigarette butts near this traile ~

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(3) The.inspectovs:cbserved that the auxiliary boiler l fuel oil localflevel gauge (Type 2 fuel oil).was'out of servic The following corrective actions were initiated:

(1) In Building No. 41, the licensee took immediate corrective actions and within two days provided adequate access for fire fighting personne (2)' The licensee relocated the aluminum trailer with the wooden door to the west side of Building No; 41 and restricted access to the other radwaste storage trucks. The licensee indicated that the tentative schedule for removal of the radwaste storage trucks was January 199 (3) The licensee provided the inspector with the work request scheduling / tracking (Plan of the. Day (POD) Scheduling Information) that indicated that a purchase requisition

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had been written and the part was on hold since June 25, 1989 (the approximate day the gear in the level gauge was damaged).

At the time of the inspection, the gear had not yet arrived from'

the manufacturer; however, the. licensee indicated that the part

+

should be available and work completed by August 17, 198 Additional observations made by the inspactors include the following:

(1) A review of the licensee's safe shutdown analysis indicated that in the event of a fire and a loss of onsite and offsite power with no operator action and an isolated core, suppression pool temperature would only rise approximately 30 F in 70

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, v minutes due to safety relief valve'blowdowns into the toru The licensee was requested to verify the accuracy of this calculation. The licensee _ identified that the temperature change in the suppression pool would occur at a' higher rate of approximately 43 F in 45 minutes. -This increase in suppression

. pool l temperature does not. appear to be consistent with Figure 7.5-10 of the Safety Analysis Report. During the telephone exit of July-20,1989, the licensee acknowledged that a

. E. ;4 ' revision to the UFSAR and safe shutdown analysis is appropriate and will be performe (2) . An inspection of the licensee's emergency equipn.ent cabinet revealed the usage of leather lineman gloves used in conjunction with electrical safety gloves. The leather gloves utilize a strap and metal buckle on the back of the hand to tighten the gloves around the user's hand. The licensee'was questioned about the personnel safety of using these gloves in high voltage areas with the exposed metal buckl With regard to this issue, during the July 20, 1989 telecon, the licensee indicated the metal buckles from the back of the lineman gloves were planned to be removed from each pair of glove (3) During the " Remote Shutdown System" walkdown, it was noted that a cable run above local Control Panel H21-P626 was found to be inconsistent with other cable runs in the plan In addition, along the top edge of this switchboard, a. piece of orange cable was installed with duct tape. Polaroid pictures of the cable run and the orange cable were obtained for review by the electrical inspecto According to the licensee's staff on July 20, 1989, the

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inconsistent cable run observed above the local Control Panel H21-P626 was a balance of plant (B0P) cable used for annunciation only with isolation provided by the relay contacts. With regard to the orange cable installed along the top edge of the control panel switchboard, the licensee's technical staff stated that the installation observed was the outer jacket of a piece of orange cable that was being used as an edge protector for the cables passing over the control panel switchboar In several areas, the gray duct tape holding the orange jacket material in place had come loose. Both important to safety cables and BOP cables pass over the control panel lip. There appears to be some concern by the licensee for protecting the cables passing over the cabinet lip, or the lip would not have been covere The inspectors recommended that the licensee review and determine if a more suitat.te arrangement was available to cover the cabinet li __

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1 Pre-Fire Plans'

The inspector requested the pre-fire plans for.the following locations for review: 4 i Auxiliary Building, Division.I Switchgear Room, Zone 9, i Elevction 613 feet 6 inche < Relay Room, Zone 8, Elevation 613 feet 6 inche ;

1 Hydrogen' Storage Tank Are J

, Transformers Elevation 583 feet 6 inche Auxiliary Boilerhouse Oil Storage Tan l

'The inspector's review did not identify any discrepancie f 1 Open Items Open items are' matters which have been discussed with the-licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open Items disclosed during the inspection are discussed in Paragraphs 3, 5.a, and ,

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1 Unresolved Items 1 Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items; items of a violation, or a deviatio An unresolved item disclosed during the inspection is discussed in Paragraph . Deviations A licensee's failure to satisfy a written commitment or to conform to the provisions of applicable codes, standards, luides, or accepted i industry practices when the commitment, code, standard, guide, or i practice involved has not been made a legally binding requirement by the Commission, but is expected to be implemented. A deviation from a written licensee commitment is discussed in Paragraph . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on June 30, 1989, and summarized the scope and findings of the inspection. The inspectors also discussed the l likely informational content of the inspection report with regard to j

. documents reviewed by the inspectors during the inspection. The licensee i did not identify any of the documents as proprietary. Since additional j information from the licensee was necessary to be reviewed by the inspectors in the office following the inspection, a conference call was held between licensee representatives and two inspection team members on 1 July 20, 1989 to discuss the results of this revie _ - _ _ _ - __ _ _ _ -