IR 05000341/2002008
| ML030070265 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/03/2003 |
| From: | Gardner R NRC/RGN-III/DRS/EEB |
| To: | O'Connor W Detroit Edison |
| References | |
| IR-02-008 | |
| Download: ML030070265 (28) | |
Text
ary 3, 2003
SUBJECT:
FERMI POWER PLANT NRC INSPECTION REPORT 50-341/02-08(DRS)
Dear Mr. OConnor:
On December 6, 2002, the NRC completed an inspection at your Fermi Power Plant. The enclosed report documents the inspection findings which were discussed on December 6, 2002, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, this inspection focused on the triennial fire protection baseline inspection.
Based on the results of this inspection, the inspectors identified two issues of very low safety significance (Green). The issues were determined to involve violations of NRC requirements.
However, because of the very low safety significance and because the issues have been entered into your corrective action program, the NRC is treating these issues as Non-Cited Violations, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you contest the violations or significance of the Non-Cited Violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Fermi 2 Nuclear Power Plant. In accordance with 10 CFR Part 2.790 of the NRC's Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by Roger Lanksbury Acting For/
Ronald N. Gardner, Chief Electrical Engineering Branch Division of Reactor Safety Docket Nos. 50-341 License Nos. DPR-43 Enclosure: NRC Inspection Report 50-341/02-08(DRS)
cc w/encl: N. Peterson, Director, Nuclear Licensing P. Marquardt, Corporate Legal Department Compliance Supervisor R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Monroe County, Emergency Management Division Emergency Management Division MI Department of State Police
SUMMARY OF FINDINGS
IR 05000341-02-08(DRS); Detroit Edison Company; on 11/19-12/6/02, Fermi Power Plant;
Unit 2. Fire Protection Triennial.
The inspection was conducted by a team of three Region III specialist inspectors. The inspection identified two Green Non-Cited Violations (NCVs). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector Identified Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified that the licensee failed to have adequate procedures in effect for alternative shutdown in accordance with their license conditions. Specifically, performance of necessary actions to conduct an alternative shutdown would have required operators to perform steps contrary to the emergency operating procedures. The failure to have adequate procedures in effect for alternative shutdown is a violation of a license condition.
This issue was greater than minor because the conflict between procedures could result in operator delay and confusion for performance of necessary alternative shutdown steps. The finding was determined to be of very low safety significance, i.e., Green, because the finding did not affect a fire protection feature and interviews with operators indicated that they would take the necessary actions. Because the finding was of very low safety significance, and the finding was captured in the licensees corrective action system, this finding is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (Section 1R05.5.b.1).
- Green.
The inspectors identified that the licensee failed to promptly correct identified deficiencies in the alternative shutdown procedure which specified safe shutdown actions to be taken in the event of a fire in an affected fire area.
Specifically, the alternative shutdown procedure which specified operator actions in the event of a fire in fire area 11ABE relied upon operator actions to be taken in the same area. As such, operators may not have been able to perform the directed actions due to exposure to the fire, the actions may not have been effective due to fire damage, and the carbon dioxide fire suppression system for the area could have been adversely affected. The failure to take prompt corrective actions is a violation of a license condition.
The issue was greater than minor because specified actions may not have been effectively accomplished and a fire protection feature was affected. The finding was determined to be of very low safety significance, i.e., Green, because there were no identified fire damage scenarios which would require alternative shutdown. Because the finding was of very low safety significance, and the finding was captured in the licensees corrective action system, this finding is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy (Section 4OA2.b.1).
REPORT DETAILS
Summary of Plant Status
Unit 2 was operated at or near full power throughout the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection
The purpose of this inspection was to review the Fermi fire protection program for selected risk-significant fire areas. Emphasis was placed on verifying that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available.
The inspection was performed in accordance with the Nuclear Regulatory Commissions (NRCs) new regulatory oversight process using a risk-informed approach for selecting the fire areas and attributes to be inspected. The inspectors used the Fermi 2 Individual Plant Examination (External Events) (IPEEE) to choose several risk-significant areas for detailed inspection and review. The fire areas chosen for review during this inspection were:
01AB, Auxiliary Building Basement 02AB, Auxiliary Building Mezzanine/Cable Tray Area 11ABE, 3rd Floor DC/MCC [Direct Current/Motor Control Center] Area For each of these fire zones, the inspection was focused on the fire protection features, the systems and equipment necessary to achieve and maintain safe shutdown conditions, determination of license commitments, and changes to the fire protection plan.
.1 Systems Required to Achieve and Maintain Post-Fire Safe Shutdown
The guidelines established by Branch Technical Position (BTP), Chemical Engineering Branch (CMEB) 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1),required the licensee to provide fire protection features that were capable of limiting fire damage to structures, systems, and components (SSCs) important to safe shutdown.
The SSCs that were necessary to achieve and maintain post-fire safe shutdown were required to be protected by fire protection features that were capable of limiting fire damage to the SSCs so that:
- One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and
- Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
General Description of Fermi 2s Safe Shutdown Paths and Capability The licensees safe shutdown methodology relied upon the identification of those components necessary and available to achieve and maintain hot shutdown conditions following a fire condition. Once identified for all plant areas, the licensee selected the components necessary to achieve and maintain the reactor in a hot shutdown condition which could be operated from the main control room or which could be operated locally and were not within the fire affected area. The methodology further identified those components necessary to achieve and maintain cold shutdown assuming limited repairs.
The licensee also identified an alternate or dedicated shutdown capability for fire conditions that affected the main control room and other areas requiring alternative or dedicated shutdown capability. For each of these areas, the licensee relied upon the operators use of the dedicated shutdown panels and local operator actions to ensure that the reactor could be brought to and maintained in a hot shutdown status.
a. Inspection Scope
The inspectors reviewed the plant systems required to achieve and maintain post-fire safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions for each fire zone selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring, and support system functions. This review included the fire protection safe shutdown analysis.
The inspectors also reviewed the operators ability to perform the necessary manual actions for achieving safe shutdown, including a review of procedures, accessibility of safe shutdown equipment, and the available time for performing the actions.
The inspectors reviewed the final safety analysis report (FSAR), as updated, and the licensees engineering and/or licensing justifications (e.g., NRC guidance documents, license amendments, technical specifications, safety evaluation reports, exemptions, and deviations) to determine the licensing basis.
b. Findings
No findings of significance were identified.
.2 Fire Protection of Safe Shutdown Capability
The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraphs (2)(a) and (3), required separation of cables and equipment and associated circuits of redundant trains by a fire barrier having a 3-hour rating. If the guidelines cannot be met, then alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided.
a. Inspection Scope
For each of the selected fire areas, the inspectors reviewed the licensees safe shutdown analysis to ensure that at least one post-fire safe shutdown success path was available in the event of a fire. This included a review of manual actions required to achieve and maintain hot shutdown conditions and make the necessary repairs to reach cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The inspectors also reviewed procedures to verify that adequate direction was provided to operators to perform these manual actions. Factors, such as timing, access to the equipment, and the availability of procedures, were considered in the review.
The inspectors also evaluated the adequacy of fire suppression and detection systems, fire area barriers, penetration seals, and fire doors to ensure that at least one train of safe shutdown equipment was free of fire damage. To do this, the inspectors observed the material condition and configuration of the installed fire detection and suppression systems, fire barriers, and construction details and supporting fire tests for the installed fire barriers. In addition, the inspectors reviewed license documentation, such as deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, fire hazard analysis (FHA) reports, safe shutdown analysis, and National Fire Protection Association (NFPA) codes to verify that the fire barrier installations met license commitments.
b. Findings
No findings of significance were identified.
.3 Post-fire Safe Shutdown Circuit Analysis
The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1), required that SSCs important to safe shutdown be provided with fire protection features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Options for providing this level of fire protection were delineated in BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (2). Where the protection of systems whose function was required for hot shutdown did not satisfy BTP CMEB 9.5-1, Section C.5.b, Paragraph (2), an alternative or dedicated shutdown capability and its associated circuits, was required to be provided that was independent of the cables, systems, and components in the area. For such areas, BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (3),specifically required the alternative or dedicated shutdown capability to be physically and electrically independent of the specific fire areas and capable of accommodating post-fire conditions where offsite power was available and where offsite power was not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
a. Inspection Scope
On a sample basis, the inspectors investigated the adequacy of separation provided for the power and control cabling of redundant trains of shutdown equipment. This investigation focused on the cabling of selected components in systems important for safe shutdown. The inspectors review also included a sampling of components whose inadvertent operation due to fire may adversely affect post-fire safe shutdown capability.
The purpose of this review was to determine if a single exposure fire, in one of the fire areas selected for this inspection, could prevent the proper operation of both safe shutdown trains.
The team reviewed the licensees fuse/breaker coordination analysis for the 4.16 kiloVolt and 480 Volt alternating current (AC) switchgear required for post-fire safe shutdown and the vital low-voltage AC and DC buses. The purpose of this review was to verify that selective coordination exists between branch circuit protective devices (fuses, breakers, relays, etc.) and the bus feeder breaker/fuse to ensure that in the event of a fire-induced short circuit, the fault is isolated before the feeder device trips. In addition, a review of the licensees fuse replacement procedure was conducted to determine if adequate administrative controls existed to prevent the inadvertent substitution of incorrectly sized fuses in critical circuits.
b. Findings
No findings of significance were identified.
.4 Alternative Safe Shutdown Capability
The guidelines established by BTP CMEB 9.5-1, Section C.5.b, Safe Shutdown Capability, Paragraph (1), required the licensee to provide fire protection features that were capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions remained free of fire damage. Specific design features for ensuring this capability were provided in BTP CMEB 9.5-1, Section C.5.b, Paragraph (2). Where compliance with the separation criteria of BTP CMEB 9.5-1, Section C.5.b, Paragraphs
- (1) and
- (2) could not be met, BTP CMEB 9.5-1, Section C.5.b, Paragraph
- (3) and Section C.5.c, required an alternative or dedicated shutdown capability be provided that was independent of the specific fire area under consideration. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions and achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. During the post-fire safe shutdown, the reactor coolant process variables must remain within those predicted for a loss of normal AC power, and the fission product boundary integrity must not be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).
a. Inspection Scope
The inspectors reviewed the licensees systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and support system functions.
b. Findings
No findings of significance were identified.
.5 Operational Implementation of Alternative Shutdown Capability
The guidelines established by BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (2)(d), required that the process monitoring function should be capable of providing direct readings of the process variables needed to perform and control the functions necessary to achieve reactivity control, reactor coolant makeup, and decay heat removal.
a. Inspection Scope
The inspectors performed a walkdown of a sample of the actions defined in Procedure 20.000.18, Control of the Plant from the Dedicated Shutdown Panel, which was the procedure for performing a plant alternative shutdown from outside the control room.
The inspectors conducted the walkdown to verify that operators could reasonably be expected to perform the procedure actions within the identified applicable plant shutdown time requirements and that equipment labeling was consistent with the procedure.
The inspectors reviews of the adequacy of communications and emergency lighting associated with these procedures are documented in Sections 1R05.6 and 1R05.7 of this report.
b. Findings
b.1 Failure to Have Adequate Procedures in Effect for Alternative Shutdown The inspectors identified that the licensee failed to have adequate procedures in effect for alternative shutdown in accordance with their license conditions. This issue was considered to be of very low safety significance and was dispositioned as a Green Non-Cited Violation (NCV).
Based on interviews with licensed operators and review of operating procedures, the inspectors determined that operators could potentially be using Emergency Operating Procedure (EOP) 29.100.01, Sheet 2, Primary Containment Control, and Abnormal Operating Procedure (AOP) 20.000.18 simultaneously. In addition, licensed operators informed the inspectors that EOP 29.100.01 took precedence over AOP 20.000.18.
Step DWT-5 of EOP 29.100.01, Sheet 2, directed operators to isolate emergency equipment cooling water (EECW) to and from the drywell. Step W of AOP 20.000.18 directed operators to unisolate EECW to the drywell. Although the actions of AOP 20.000.18 were necessary and correct, they were in conflict with those of EOP 29.100.01. Consequently, operator confusion and delay could occur in performance of those actions. During interviews with licensed operators, the licensed operators indicated that they would unisolate EECW to the drywell as required by AOP 20.000.18. However, the inspectors determined that by doing so, operators would be performing steps contrary to EOP 29.100.01, a procedure required by Technical Specification 5.4.1.b. Performing actions contrary to EOP 29.100.01 would be in violation of Technical Specification 5.4.1, which required, in part, that written procedures for EOPs be implemented. As such, the licensee would be in the position of operating under 10 CFR 50.54(x), which allows reasonable actions to be taken that depart from a technical specification in an emergency when the action is necessary to protect the health and safety of the public and no action consistent with license conditions and technical specifications which can provide adequate or equivalent protection is immediately apparent. The inspectors considered the necessity of operating under 10 CFR 50.54(x) to perform alternative shutdown actions to be equivalent to not having procedures in effect to implement alternative shutdown capability.
License condition 2.C(9) of the facility operating license stated, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report (FSAR) for the facility.
Section 9A.3 of the FSAR for the facility, as updated, stated, in part, that an alternative shutdown system had been designed and installed to meet the technical requirements of 10 CFR Part 50, Appendix R, Sections III.G.3 and L. Appendix R of 10 CFR Part 50, Section III.L.3 stated, in part, that procedures shall be in effect to implement alternative and dedicated shutdown capability. Contrary to the above, procedures were not in effect for implementing alternative shutdown capability in that actions necessary to implement alternative shutdown capability were in conflict with EOP steps.
In accordance with Inspection Manual Chapter (IMC) 0612, the inspectors determined that the issue was more than minor because the finding was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems reactor safety cornerstone and affected the mitigating systems objective. In accordance with IMC 0609, Appendix A, the inspectors performed a Significance Determination Process (SDP) Phase 1 screening and determined that the finding degraded the Fire Protection portion of the Mitigation Systems Cornerstone. As such, screening under IMC 0609, Appendix F, was required. Based on review of IMC 0609, Appendix F, the inspectors determined that the finding did not require a Phase 2 analysis because no fire protection feature was affected. In addition, although the procedure conflict could result in delay and confusion, the inspectors determined that operators would likely perform the correct actions based on interviews of licensed operators. As such, this finding was considered to be of very low safety significance (i.e., Green). The failure to have adequate procedures in effect for alternative shutdown was a violation of a Fermi 2 license condition (2.C(9)). This violation was associated with a finding that was characterized by the Significance Determination Process as having very low risk significance (i.e., Green) and was being treated as a Non-Cited Violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. This violation was in the licensees corrective action program as Condition Assessment Resolution Document (CARD) 02-19225 (NCV 50-341/02-08-01).
b.2 Actions Specified in Affected Fire Area A finding relating to the licensees failure to promptly correct a procedure which specified safe shutdown actions in an affected fire area was identified and is discussed in Section 4OA2.b.
.6 Communications
The guidelines established by BTP CMEB 9.5-1, Section C.5.g, Lighting and Communication, Paragraph (4), required that a portable communications system be provided for use by the fire brigade and other operations personnel required to achieve safe plant shutdown. This system should not interfere with the communications capabilities of the plant security force. Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure to fire damage.
a. Inspection Scope
The inspectors reviewed the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties.
b. Findings
No findings of significance were identified.
.7 Emergency Lighting
The guidelines established by BTP CMEB 9.5-1, Section C.5.g, Lighting and Communication, Paragraph (1), required that fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual 8-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas.
a. Inspection Scope
The inspectors performed a walkdown of a sample of the actions defined in plant procedures used to control local equipment operations. As part of the walkdowns, the inspectors verified that sufficient emergency lighting existed for access and egress to areas and for performing necessary equipment operations.
b. Findings
No findings of significance were identified.
.8 Cold Shutdown Repairs
The guidelines established by BTP CMEB 9.5-1, Section C.5.c, Alternative or Dedicated Shutdown Capability, Paragraph (5), required that equipment and systems comprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.
a. Inspection Scope
The inspectors reviewed the licensees procedures to determine if any repairs were required to achieve cold shutdown.
b. Findings
No findings of significance were identified.
.9 Fire Barriers and Fire Zone/Room Penetration Seals
The guidelines established by BTP CMEB 9.5-1, Section C.5.a, Building Design, Paragraph (3), required that penetration seal designs be qualified by tests that are comparable to tests used to rate fire barriers.
a. Inspection Scope
The inspectors reviewed the test reports for 3-hour rated barriers installed in the plant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with tested configuration.
b. Findings
No findings of significance were identified.
.10 Fire Protection Systems, Features, and Equipment
The guidelines established by BTP CMEB 9.5-1 required that fire protection systems, features and equipment were designed in accordance with the following:
Fire Protection Systems, BTP CMEB 9.5-1 BTP CMEB 9.5-1 Features and Equipment Section Title Fire Brigade Capabilities C.3 Fire Brigade Passive Fire Protection C.5.a Building Design Features Fire Detection System C.6.a Fire Detection Fire Suppression System C.6.b Fire Protection Water Supply Systems C.6.c Water Sprinkler and Hose Standpipe Systems Manual Fire Fighting C.6.f and C.3 Portable Extinguishers and Equipment Fire Brigade
a. Inspection Scope
The inspectors reviewed the material condition, operations lineup, operational effectiveness, and design of fire detection systems, fire suppression systems, manual fire fighting equipment, fire brigade capability, and passive fire protection features. The inspectors reviewed deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, and FHA reports to ensure that selected fire detection systems, carbon dioxide systems, portable fire extinguishers, and hose stations were installed in accordance with their design, and that their design was adequate given the current equipment layout and plant configuration.
b. Findings
No findings of significance were identified.
.11 Compensatory Measures
a. Inspection Scope
The inspectors conducted a review to verify that adequate compensatory measures were put in place by the licensee for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features. The inspectors also conducted reviews to verify that short term compensatory measures were adequate to compensate for a degraded function or feature until appropriate corrective actions were taken.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
The guidelines established by BTP CMEB 9.5-1, Section C.4, Quality Assurance [QA]
Program, Paragraph h, required that measures be established to ensure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformances, are promptly identified, reported, and corrected.
a. Inspection Scope
The inspectors reviewed a selected sample of condition reports associated with Fermi 2s fire protection program to verify that the licensee had an appropriate threshold for identifying issues. The inspectors evaluated the effectiveness of the corrective actions for the identified issues.
b. Findings
- Failure to Promptly Correct Procedure Which Specified Safe Shutdown Actions in Affected Fire Area The inspectors identified that the licensee failed to promptly correct, as required by a Fermi 2 license condition, a procedure which specified safe shutdown actions in an affected fire area This issue was considered to be of very low safety significance and was dispositioned as a Green NCV.
The licensee identified that their safe shutdown analyses inappropriately took credit for actions performed in fire area 11ABE. Specifically, AOP 20.000.18, the procedure for alternative shutdown, specified actions to be taken in event of a fire in fire area 11ABE.
However, AOP 20.000.18 directed operators to take actions in fire area 11ABE (i.e., the an area potentially affected by fire.) The inspectors noted that 10 CFR Part 50, Appendix R, Section III.L.3, required, in part, that alternative shutdown capability be independent of the specific fire area. The license was committed to 10 CFR Part 50, Appendix R, Section III.L by license condition. The licensee documented this issue in their corrective action program on CARDs 00-15865 and 00-15866, dated June 16, 2000. The CARDs specifically identified that area 11ABE could potentially be filled with smoke, carbon dioxide (CO2), and heat. As such, operators might not be able to perform the actions specified by the procedure. The CARDs identified that spurious events could occur as a result of not being able to perform the actions specified by the procedure. As a compensatory measure, the licensee instituted hourly fire watches.
CARD 00-15865 was closed on February 26, 2001, although resolution of the analysis issues and compensatory measures remained open on CARD 00-15866. The actions of CARD 00-15866, which included actions to resolve associated analysis issues, were transferred to CARD 99-17222, a broader scope CARD related to NRC Information Notice 99-17, Problems With Post-Fire Safe Shutdown Analysis, on December 13, 2001. Corrective actions were subsequently rolled into CARD 02-11747, initiated in May 2002.
During this inspection, the inspectors noted that the procedural steps and associated cautions for actions taken in fire area 11ABE were essentially the same as those in the June 2000 version of the procedure when the licensee had originally identified the issue.
No substantive corrective actions had been taken to correct the procedure. The inspectors noted that self-contained breathing apparatus had been provided in nearby locations for the operators. However, even if an operator were able to perform the actions specified by the procedure, the inspectors noted that the actions may not be effective due to fire damage. In addition, fire area 11ABE was protected by a CO2 system which required that a tight envelope be maintained for the required soak time in order for the CO2 to be effective in extinguishing the fire. However, having an operator perform the procedure steps would have required the operator to breach the CO2 envelope for the fire area thereby impacting the effectiveness of the CO2 system.
As a result of the inspectors raising the above issues and the timeliness of the licensees corrective actions, the licensee initiated CARD 02-19401 and revised AOP 20.000.18 during this inspection. The revised procedure was issued on November 27, 2002, and directed operators to perform actions outside of fire area 11ABE if the fire was in fire area 11ABE.
Section 2.C.9 of the Fermi 2 Facility Operating License stated, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report (FSAR) for the facility.
Section 9A of the FSAR, as updated, outlined the licensee commitments for fire protection. Section 9A.5 of the FSAR, as updated, provided a point-by-point comparison with Appendix A to NRC Branch Technical Position APCSB 9.5-1, dated August 23, 1976. Position c.8 listed in Section 9A.5 of the FSAR, as updated, identified the NRC position regarding quality assurance requirements for corrective action. The licensee response was that this item is included in the quality assurance program.
Section 17 of the FSAR, as updated, is the quality assurance program for the licensee.
Section 17.2.16 of the FSAR, as updated, established the quality assurance requirements for corrective action. Section 17.2.16 of the FSAR, as updated, stated, in part, that measures are established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected. Contrary to the above, the licensee failed to promptly correct AOP 20.000.18 which directed actions which potentially could not have been accomplished, potentially could have been ineffective, and could have adversely affected the operability of an installed fire suppression system. Although inadequacies associated with AOP 20.000.18 were originally identified on June 16, 2000, the inadequacies were not corrected as of November 26, 2002.
In accordance with Inspection Manual Chapter (IMC) 0612, the inspectors determined that the issue was more than minor because the finding was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems reactor safety cornerstone and affected the mitigating systems objective. In accordance with IMC 0609, Appendix A, the inspectors performed a Significance Determination Process (SDP) Phase 1 screening and determined that the finding degraded the Fire Protection portion of the Mitigation Systems Cornerstone. As such, screening under IMC 0609, Appendix F, was required. Based on Figure 4-1 of IMC 0609, Appendix F, the finding was determined to affect fixed suppression capability. Under the screening criteria for Figure 4-3 of IMC 0609, Appendix F, the inspector determined that the fixed suppression system was affected. As such, a Phase 2 analysis was required. Although there was equipment in the fire area, the equipment present was of relatively low voltage and did not have openings in the top which could allow a fire to propagate to cables along the room ceiling. Additionally, the licensees institution of fire watches ensured that there were no transient combustibles stored in the room. Consequently, the inspectors were not able to postulate a fire damage scenario for Phase 2. As such, this finding was determined to be of very low safety significance (i.e., Green). The failure to promptly correct the procedure for alternative shutdown was a violation of a Fermi 2 license condition (2.C(9)). This violation was associated with a finding that was characterized by the Significance Determination Process as having very low risk significance (i.e., Green) and was being treated as a Non-Cited Violation (NCV),consistent with Section VI.A.1 of the NRC Enforcement Policy. This violation was in the licensees corrective action program (NCV 50-341/02-08-02).
4OA6 Meetings
Exit Meeting The inspectors presented the inspection results to Mr. W. OConnor and other members of licensee management at the conclusion of the inspection on December 6, 2002. The licensee acknowledged the findings presented. No proprietary information was identified.
KEY POINTS OF CONTACT Licensee W. OConnor, Vice-President, Nuclear Generation D. Cobb, Plant Manager K. Burke, Supervisor, Nuclear Performance Engineering R. Johnson, Supervisor, Nuclear Licensing R. Libra, Director, Nuclear Engineering J. Moyers, Manager, Nuclear Quality Assurance S. Peterman, Manager, Operations N. Peterson, Manager, Nuclear Licensing S. Stasek, Director, Nuclear Assessment J. Thorson, Acting Manager, Nuclear Performance Engineering NRC R. Gardner, Chief, Electrical Engineering Branch, Region III J. Larizza, Resident Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-341/02-08-01 NCV Failure to Have Adequate Procedures for Alternative Shutdown in Effect 50-341/02-08-02 NCV Failure to Take Prompt Corrective Actions to Correct Identified Deficiencies in Alternative Shutdown Procedure Closed 50-341/02-08-01 NCV Failure to Have Adequate Procedures for Alternative Shutdown in Effect 50-341/02-08-02 NCV Failure to Take Prompt Corrective Actions to Correct Identified Deficiencies in Alternative Shutdown Procedure LIST OF ACRONYMS USED AC Alternating Current ADAMS Agencywide Documents Access and Management System AOP Abnormal Operating Procedure BTP Branch Technical Position CARD Condition Assessment Resolution Document CFR Code of Federal Regulations CMEB Chemical Engineering Branch CO2 Carbon Dioxide DC Direct Current DRS Division of Reactor Safety EECW Emergency Equipment Cooling Water EOP Emergency Operating Procedure FHA Fire Hazard Analysis FSAR Final Safety Analysis Report IMC Inspection Manual Chapter IPEEE Individual Plant Examination of External Events IR Inspection Report LLC Limited Liability Company MCC Motor Control Center NFPA National Fire Protection Association NRC United States Nuclear Regulatory Commission OA Other Activities PARS Publicly Available Records QA Quality Assurance SDP Significance Determination Process SSC Structure, System, or Component LIST OF
DOCUMENTS REVIEWED
The following is a list of licensee documents reviewed during the inspection, including
documents prepared by others for the licensee. Inclusion on this list does not imply that NRC
inspectors reviewed the documents in their entirety, but rather that selected sections or portions
of the documents were evaluated as part of the overall inspection effort. Inclusion of a
document in this list does not imply NRC acceptance of the document, unless specifically stated
in the inspection report.
CARDs Reviewed
99-15137 Licensee response to NRC Notice 99-17; May 8, 2002
Problems associated with Post-Fire Safe-
Shutdown Circuit Analysis
99-17222 Identified issue in which 20.000.18 does not isolate October 27, 1999
P5000F154 for all Dedicated Shutdown Fire Zones
00-15865 Procedural discrepancies that may prevent or June 21, 2002
negate actions required for 20.000.18
00-15866 Lack of analysis supporting stripping of DC supply June 16, 2002
to RHR Complex during implementation of
20.000.18
01-17245 NFPA 13 Sprinkler system discrepancies. July 19, 2001
01-17246 Audit Finding: Wet sprinkler system pressure is July 24, 2001
high for several areas in the Reactor Bldg.
2-11059 Pendant Sprinkler installed without return bend as February 26, 2002
required by NFPA 13 in Aux Bldg 1st Fl Mezzanine
and cable tray area.
2-11747 Fire Protection Program Improvements. August 14, 2002
2-12387 NFPA 13 requirements for spare sprinklers are not July 10, 2002
met.
2-12388 The FP Self Assessment NFPA 13 1980 Ed. Code July 6, 2002
compliance review has a concern that the
hydraulic reference points on the fire protection
system are not the same as those used in DC-
5713.
2-12399 Some sprinklers have protection areas in excess April 25, 2002
of the limits specified by NFPA 13.
2-12403 Spacing of some branch lines end sprinklers is April 25, 2002
greater than what is allowed by NFPA 13.
2-12404 Inadequacies exist in sprinkler coverage for cable April 25, 2002
trays.
2-12412 Valve N2000F636 operator has been rotated 180° May 2, 2002
and is not operable from the floor
2-13702 Electric Fire Pump starts cause Fire System flange April 16, 2002
leakage.
2-19161 FP-AB-3-14f Fire Protection Pre-Plan Section 6.2 November 21,
identifies fewer ventilation dampers closing than 2002
28.502.07 or 28.501.02 when CO2 system initiates
2-21263 Discrepancy between FP-AB-3-14f and 23.501.02 November 26,
with regards to CO2 soak time 2002
2-21266 Determine if the fire detection installation in December 2, 2002
UFSAR fire zone 1AB, control air compressor
room is required to conform to the NFPA 72E 1974
Ed. criteria for high ceiling
CARDs Initiated as a Result of this Inspection
2-19164 Evaluate effectiveness of fire detectors in 11AB November 11,
2002
2-19224 Procedure 20.000.18 Enhancement November 2, 2002
2-19225 EOP interaction with post fire shutdown using AOP November 22,
20.000.18 2002
2-19401 Untimely corrective actions for Zone 11AB fire November 26,
scenario 2002
2-19497 Fire protection program with regards to UFSAR December 4, 2002
Chapter 17
2-21271 In various areas in Fire Zone 2AB, cable trays December 6, 2002
installed above the sprinklers
2-21272 The fire test information available for review for 3M December 4, 2002
M20A/CS195 fire barriers is insufficient
Engineering Evaluations
EVAL-DE0035- Evaluation of Fermi 2 Wet Pipe Sprinkler Systems Revision 0
for Compliance with the requirements of NFPA-13,
Standard for the Installation of Sprinkler Systems
EVAL-DE0035- Evaluation of Fermi 2 Wet Pipe Sprinkler Systems Revision 0
for Compliance with the Requirements of NFPA-
13.
EVAL-DE0027- Evaluation of Fermi 2 Wet Pipe Sprinkler Systems Revision 0
for Compliance with the Requirements of NFPA-
13.
Fire Protection Self-Assessment May 31, 2002
TSR-30217 Time to Void EECW in Drywell During Dedicated Revision 0
Shutdown
Drawings
6E721-2808-12A Cable Trays & Conduits Fire Protection Barriers Revision D
6E721-2808-12C Cable Trays & Conduits Fire Protection Barriers Revision D
6E721-2808-19 Cable Trays & Conduits Fire Protection Barriers Revision A
Installation Details
6E721-2808-20 Cable Trays & Conduits Fire Protection Barriers Revision F
Installation Details
6E721-2808-21 Cable Trays & Conduits Fire Protection Barriers Revision E
Installation Details
6E721-2808-22 Cable Trays & Conduits Fire Protection Barriers Revision E
Installation Details
6E721-2808-23 Cable Trays & Conduits Fire Protection Barriers Revision E
Installation Details
6E721-2808-24 Cable Trays & Conduits Fire Protection Barriers Revision D
Installation Details
6E721-2808-25 Cable Trays & Conduits Fire Protection Barriers Revision E
Installation Details
6E721-2808-68 Cable Trays & Conduits Fire Protection Barriers Revision A
Installation Details
6E721-2808-69 Cable Trays & Conduits Fire Protection Barriers Revision 0
Installation Details
6E721-2808-70 Cable Trays & Conduits Fire Protection Barriers Revision 0
Installation Details
6E721-2808-71 Cable Trays & Conduits Fire Protection Barriers Revision A
Installation Details
6M721-2006 Condensate Storage and Transfer System Revision BA
Diagram
6M721-2035 High Pressure Coolant Injection System (HPCI) Revision BC
Reactor Bldg
6M721-2044 Diagram RCIC System Revision AW
6M721-2045 Diagram RCIC System Barometric Condenser Revision AJ
6M721-2083 Residual Heat Removal (RHR) Division II Revision BD
6M721-2084 Residual Heat Removal (RHR) Division I Revision BA
6M721-2135 Diagram Fire Protection System (Sheet 1) Revision AS
6M721-2135 Diagram Fire Protection System (Sheet 2) Revision O
6M721-2255 Ventilation Ductwork 3rd Floor Reactor Building Revision W
6M721-2707 Flow Diagram Reactor & Auxiliary Building Revision L
Ventilation System
6M721-4526-1 Piping Isometric Fire Protection Sprinkler Feed Revision L
System Reactor and Auxiliary Buildings
6M721-4529 Typical Cable tray Fire Protection Details Auxiliary Revision D
Building
6M721-5068 Fire Protection Plan -Cable Trays -Area at Revision G
Elevations 568-6 & 603-6".
6M721-5069 Fire Protection Sections of Auxiliary Building Cable Revision C
Tray Systems
6M721-5072 Fire Protection Plan -Cable Tray Area at Revision J
Elevations 551-6" & 562-6" Aux. Bldg.
6M721-5083 Piping & Instrument Diagram - Standby Feedwater Revision R
System
6M721-5436 Emergency Cooling-Battery Charger Area Plan & Revision A
Sections-Third Floor Auxiliary Building
6M721-5506 Fire Protection Auxiliary Building Cable Tray Areas Revision B
Sprinkler System at 603-6"
6C721-2304 Primary Containment Penetrations Drywell Revision T
6I721-2201 RHR System Schematic Diagram Series of Various Revisions
Drawings
6I721-2205 RHR System GE Schematic Diagram Series of
Drawings
6I721-2225-04 Schematic Diagram - HPCI System Logic Circuit
Part 2
6I721-2225-13 Division I & II HPCI Torus Level Isol Vlvs V5-2550, August 9, 1983
V5-2551, V5-2552, & V5-2553
6I721-2235-03 RCIC System Logic Circuit Schematic Diagram Revision Z
Part 2
6I721-2317-28 Schematic Diagram - SBFW System Isolation Revision F
Valve N2103F001
6I721-2441-02 Schematic Diagram - EECW Sys EECW Return to Revision I
RBCCW & RBCCW to EECW Stop Valves
6I721-2441-09 Schematic Diagram - EECW System - EECW Revision O
Drywell Supply Iso and EECW Drywell Return Iso
Valves P4400F606A and P440F607A
6I721-2671-11 Schematic Diagram - Torus Level Measurement Revision J
System Isolation Valves
6I721-2784-01 Dedicated Shutdown Panel Revision 0
6I721-2785-01 Schematic Diagram - Dedicated Shutdown Panel Revision D
H21P623 Transfer Relaying
6I721-2868-09 Installation Fire Detection System Reactor Building Revision F
Basement EL. 562-0"
61721-2868-11 Installation Fire Detection System - Reactor Bldg. Revision G
1st Fl. El. 583-6" 1st Mezz. El. 603-6" - Zone 6.
6I721-2868-15 Installation Fire Detection System 3rd Floor Revision K
Reactor Building EL 643-6" Zone 14
6I721-2868-78 Installation Fire Detection System Outside The Revision F
Division II Switchgear Room 3rd Floor Auxiliary
Building EL. 643-6" Zone 14
6SD721-2530 One Line Diagram - Battery Distribution Series Various Revs
Drawings
Procedures
20.000.18 Control of the plant from the Dedicated Shutdown Revision 23
Panel
20.000.18 Control of the plant from the Dedicated Shutdown Revision 24
Panel
20.000.18 Control of the plant from the Dedicated Shutdown Revision 27
Panel
20.000.18 Control of the plant from the Dedicated Shutdown Revision 31
Panel
20.000.18 Control of the plant from the Dedicated Shutdown Revision 32
Panel
20.000.22 Plant Fires Revision 33
20.300.260VESF Abnormal Operating Procedure - Loss of ESS Revision 0
130/260 V Battery Busses
23.205 Attachment 2C; Non-Divisional RHR Electrical Revision 0
Lineup
23.324 System Operating Procedure - 120 kV Switchyard Revision 46
and CTG11 Generators
24.321.06 Dedicated shutdown Panel H21-P623 Operablity Revision 32
Test EF-1 Supervisory Control
28.502.07 CO2 Fire Suppression Functional Test Zone 14, Revision 8
Auxiliary Building, 3rd Floor
28.504.03 Fire Suppression Water System Simulated Revision 15
Automatic Actuation Test.
28.504.04 Fire Suppression Water System Flow Test. Revision 8
28.504.04 Fire Suppression Water System Flow Test. Revision 12
28.508.04 Emergency Equipment Monthly Revision 22
Inventory/Inspection
29.100.02 RPV Control Revision 9
sheet 1
29.100.02 RPV Control - ATWS Revision 7
sheet 1A
29.100.02 Primary Containment Control Revision 8
sheet 2
29.100.02 RPV Flooding Emergency Depressurization & Revision 6
sheet 3 Steam Cooling
29.100.02 RPV Flooding & Emergency Depressurization - Revision 8
sheet 3A ATWA
29.100.02 Primary Containment H2/O2 Control Revision 8
sheet 4
29.100.02 Secondary Containment and Rad Release Revision 7
sheet 5
29.100.02 Curves, Cautions and Tables Revision 8
sheet 6
29.ESP.13 Emergency Support Procedure - Defeat of HPCI Revision 2
High Torus Water Level Suction Transfer and High
Area Temperature Isolation
29.ESP.16 Emergency Support Procedure - Defeat of RCIC Revision 3
Low RPV Pressure and High Area Temperature
Isolations
FP-AB-1-6a Auxiliary Building Cable Tray Area, North, Zone 6 Revision 2
FP-AB-1-6b Auxiliary Building Cable Entry Room, Zone 6, EL. Revision 3
583-6"
FP-AB-1-6c Auxiliary Building Cable Tray Area, South, Zone 6, Revision 2
EL. 583-6"
FP-AB-1-6d Auxiliary Building 1st Floor Mezzanine, Zone 6, EL. Revision 2
603-6"
FP-AB-3-14f Auxiliary Building, DC Motor Control Center (MCC) Revision 2
Room Zone 14, EL. 643-6"
FP-AB-BMT-4 Control Air Compressor Room, Zone 4, EL. 551-0" Revision 2
3071-327 Installation Work for Fire Protection of Cable Revision G
Trays, Conduits & Hangers
MES36 Engineering Support Conduct Manual - Cable Revision 4
Pullcards
MGA03 General Administration Conduct Manual Chapter 3 Revision 11
- Procedure Use and Adherence
ST-OP-315- Operations Training - EDG Load Shedding and Revision 14
0065-001 Digital Load Sequencer
PRET.H4000.001 Procedure for Determining Proper Two-Way Radio Revision 0
Communications
SOE 96-12 Partial DCAT testing for EDP 28129 (pertaining to Revision 0
refurbishment of CTG 11-1)
Calculations
Chemetron FL- Low Pressure Carbon Dioxide Flow Calculation - March 8, 1982
37762 Area Outside Switchgear Room EL. 643-6"
DC-5713 Vol. I Hydraulic Evaluation of the Fire Distribution Loop. Revision C
DC-1021 DC Distribution Cabinet Loads
DC-2912 DC Distribution Cabinet Loads (130 VDC)
DC-2914 DC Distribution Cabinet Loads September 18,
1990
DC-4921 Appendix R Calculations Revision D
DC-5783 Appendix R Equipment and Cable Justifications Revision A
Fire Test Related Documents
Letter from 3M List of Test Reports and Associated Documents on September 8, 1993
M20-A Mat System
Installation Interam rigid Panel System M20-A Mat & CS-195 March 1, 1985
Manual Composite Sheet 3 HR Fire Protection System
Installation Product Data Sheets/Catalog Cuts; Clarification April 17, 1984
Manual Letter on Wrapping 5" Conduits
Installation Letter on CP-25 Caulk and Putty December 10,
Manual 1985
Installation Clarification Letter on Wrapping Techniques January 10, 1986
Manual
Installation Letter on Tensile Strength of C-34 Restraining May 30, 1986
Manual Cord
SWRI # 01-8818- Ampacity Test Report September 29,
208/209b 1986
3M Fire Test Fire Barrier Wall June 2, 1982
Report 82-22
3M Fire Test Fire Barrier Cable Tray June 16, 1982
Report 82-29
3M Fire Test Fire Barrier Electrical Raceway Support June 16, 1982
Report 82-35
3M Fire Test Fire Test for 1" Conduit June 2, 1982
Report 82-51
3M Fire Test Fire Test for 4" Conduit June 2, 1982
Report 82-52
3M Fire Test Fire Barrier Composite Sheet Material June 23, 1982
Report OFT-1
3M Fire Test Fire Test for 4" Conduit October 12, 1982
Report
3000230701
3M Fire Test Fire Test for Cable Bundle Drop-out November 2, 1982
Report 82-65
3M Fire Test Failure Point for Specific Detroit Edison Cable January 13, 1984
Report
9380030601
3M Fire Test Justification of 12" Rule March 19, 1984
Report 84-10
3M Fire Test Junction Boxes May 22, 1984
Report 84-16
3M Fire Test Junction Box on a Unistrut Frame July 18, 1984
Report 84-18
3M Fire Test P1001 Unistrut December 19,
Report 84-105 1985
UL Fire Test Classification Coverage for Type M20-A Mat September 27,
Reports 1983
UL Fire Test Electrical Circuit Protective Materials October 19, 1983
Reports
UL Fire Test Type M20-A Intumescent Mat on a 24" Cable Tray November 2, 1983
Reports
UL Fire Test Type M20-A Mat & CS-195 Sheet Protective January 19, 1984
Reports System
UL Fire Test Fire Endurance Test of Conduit System April 18, 1984
Reports
UL Fire Test Type M20-A Mat & CS-195 Sheet Protective August 7, 1984
Reports System
UL Fire Test Review of Temperature Data September 25,
Reports 1984
UL Fire Test Review of Temperature Data October 2, 1984
Reports
File R10125-1, -2 Report on Electrical Circuit Protective Materials October 10, 1983
Project
2NK21937
Safety Evaluation Report, NUREG-0798
SSER 2 Safety Evaluation Report related to the operation January 1982
of Fermi-2
SSER 5 Safety Evaluation Report related to the operation March 1985
of Fermi-2
SSER 6 Safety Evaluation Report related to the operation
of Fermi-2
Letters
NRC Meeting Summary for September 8, 1986, Meeting January 8, 1987
on Alternative Shutdown Panel
Licensee to NRC Alternative Shutdown System January 3, 1986
Licensee to NRC Alternative Shutdown System Procedures November 27,
1985
Licensee to NRC Request for Amendment to Technical September 27,
Specifications for the Alternative Shutdown 1985
Program
Licensee to NRC Additional Clarification on Fire Doors and Fire June 18, 1985
Detectors
Licensee to NRC Detroit Edison Response Inspection Report 50- June 10, 1985
341/85009
Licensee to NRC Comments on SSER 5 June 3, 1985
Licensee to NRC Resolution of Certain Fire Protection Issues March 4, 1985
Licensee to NRC Additional Fire Protection Information February 4, 1985
Licensee to NRC Qualification of 3M Fire Wrap October 22, 1984
Licensee to NRC Design of Alternative shutdown Approach October 22, 1984
Licensee to NRC Implementation of Alternative Shutdown at Fermi 2 October 22, 1984
Licensee to NRC Alternative Shutdown in the Control Center August 16, 1984
Complex
NRC Summary of meeting on July 11, 1984, Regarding August 6, 1984
Fire Protection Measures for the Fermi-2 Facility
Licensee to NRC Transmittal of Fire Protection Information August 4, 1984
Licensee to NRC Submittal of Deviation from Staff Interpretation of August 3, 1984
Fire Protection Features in 10 CFR 50, Appendix
R and Justification
NRC Summary of Meeting on June 5, 1984, Regarding July 13, 1984
the Compliance of the Fermi-2 Facility with
Appendix R to 10 CFR Part 50
Licensee to NRC Changes in Provisions in Plant Fire Protection March 1, 1983
NRC Summary of December 4, 1981 Meeting January 20, 1982
Regarding Operating License Review: Fire
Protection
Licensee to NRC Transmittal of the Updated Fire Hazards Analysis, July 31, 1981
FSAR Appendix 9B
Licensee to NRC Fire Protection Review June 29, 1981
Licensee to NRC Response to
- Q. 021.32 June 29, 1981
Licensee to NRC Fire Protection Commitments June 18, 1981
NRC Summary of May 27, 1981 OL Review Meeting June 4, 1981
Regarding the Fermi-2 Fire Protection Review
3M to Licensee UL Test Report dated August 7, 1984 August 8, 1984
GE to Licensee Updated UFSAR Figure 7.5-10 - Maximum Time July 30, 1996
Available for Operator Action
Safety Evaluations
93-0038 Thermo-Lag Material Fire Barriers in the Auxiliary Revision 2
Building
93-0070 Modification to HPCI Return to CST Valve and Revision 1
Isolation of Air to This Valve During Alternative
Shutdown Operation
96-0050 Installation of Fire Barriers on Division 1 Trays in Revision 0
Fire Zone AB1
97-0129 Penetration Seals on the Turbine Building West Revision 0
Wall at 603 Elevation
98-0076 Restrictions on operation of the drywell coolers Revision 1
subsequent to a LOCA and reasons for
restrictions.
00-0045 Revise UFSAR to Correct Appendix R Safe Revision 0
Shutdown Component List and to Identify Location
of Equipment Credited in the FHA
00-0049 Revise UFSAR to Show the Relocation of a Fire Revision 0
Break in Auxiliary Building Mezzanine and Cable
Tray Area.
References
Vendor Manual Fire and Smoke Detection Systems Revision D
VMB11-2.0
NFPA 72E Automatic Fire Detectors 1974
NFPA 13 Standard for the Installation of Sprinkler Systems. 1980
USFAR Chapter Quality Assurance Rev 11
Technical Appendix R Alternative Shutdown Instrumentation Revision 31
Requirement
Manual, Section
3.3.9
Spec. 3071-128- Design Instruction - Thermal Overload Heater Revision B
EZ-03 Sizing
28