IR 05000348/1988027
| ML20205Q879 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/28/1988 |
| From: | Conlon T, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205Q863 | List: |
| References | |
| 50-348-88-27, 50-364-88-27, GL-86-10, IEIN-84-16, IEIN-86-017, IEIN-86-17, IEIN-88-004, IEIN-88-4, NUDOCS 8811090387 | |
| Download: ML20205Q879 (25) | |
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.l* * 4 UNITED STATES
[. .j NUCLEAR REGULATORY COaAMisslOld
o ! MEGION 11 8 101 MARIETTA ST., !
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\ ,, p ATLANTA. GEORGIA 30323
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Report No.: 50-348/88-27, 50-364/88-27 i
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Licensee: Alabama Power Company ;
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600 North 18th Street j j Birmingham, AL 35291-0400 t t
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l Docket No.: 50-348, 50-364 License No.: NPF-2 and NPF-8 l
Facility Name: Farley 1 and 2 !
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j Inspection Conducted: September 26-30, 1988 ;
Inspectors: M G. R. Wiseman, Team Leader
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/ 5' /# C . Y Dat: Signed fj
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i feam Members: D. C. Ward
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J. R. Harris I
! Accompanying Personnel: E. Reeves, LPM, NRR Approved by: e se/f /vDatebSigned f
T. E. Conlon, Chief l l
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Plant Systems Section ;
- Engineering Branch i i Division of Reactor Safety !
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l SUMMARY
] Scope: This was an innounced Triennial Postfire Safe Shutdown Capability j Reverification and Assessment (Module 64150). The team assessed f
! whether the licensee has a functioning configuration management ;
program as it relates to fire protection and postfire safe shutdown
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- capabilit The inspection verified that the licensee has l l properly maintained the postfire safe shutdown capability achieved j during the initial validation inspection previously conducted at ;
. Farley on August 19-23, 198 j
! l The int.pection covered fcur major areas as they relate to Appendix R l
- compliance and postfire safe shutdown capability including plant j
' modification review; reverification of Appendix R fire protection ;
! features; review of postfire safe shutdown procedures and equipment; l
! and, review of 50.59 safety evaluations for fire protection, j 1 !
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! l jO s7 SSI103
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gCK03000349
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PDC t
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Emphasis was placed upon review of the plants configuration control program procedures as thsy relate to maintaining Appendix R compliance and the aaitfire safe shutdown capabilit This inspection included review of postfire shutdown procedures; plant fire protection features and safe shutdown systems walkdowns; review of 50.59 safety engineering evaluations for fire protection, and interviews of personnel at various corporate and site level The inspectors also reviewed actions taken by the licensee in response to fire protection related NRC Information Notice Results: During this inspection, the NRC inspectors discussed the plant Appendix R configuration management program history with plant and corporato managemen The licensee's responses to these discussions and the results of this assessment indicate that Alabama Power Company has developed and implemented a design change program which considers the potential affects of plant modifications on Appendix R compliance and the postfire safe shutdown capabilit In general, the licensee's configuration management program as it relates to maintaining Appendix R compliance and postfiro safe shutdown capability was found to be adequate with several strong features. Management appears to be taking the appropriate actions to j maintain Appendix R fire protection long term compliance. Therefore, based upon the satisfactory results of this inspection, a detailed 10 CFR 50 Appendiu R compliance reverification Inspe: tion for Farley is not warranted at this tim Strengths and weaknesses are summarized below:
Strengths
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T ie licensee Architect Engineer who is responsible for maintaining the sites Appendix R Compliance Report his developed and implemented a detailed design review checklist which is included in their design review procedur The checklist identifies specific design considerations for Appendix R compliance which must be considered in the review of all design change Licensee management is very respor sive to NRC initiativer. This is evident by their willirgness to upgrade plant proceduros for raceway fire barrier and emergency light surveillar.ce to inclede l imprevements identified by the inspectors.
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The licensee has included the evaluation of control room and operator manual actions required for post fire safe shutdown l capability in the routine fire brigade drill progra In addition, operator training includes simulator hot shutdonn esaluations.
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. 3 Weaknesses The inspectors did not identify any significant progrannatic weaknesse However, the licensee staff is presently reviewing the circumstances surrounding the one Unresolved Item identified in this repor There is potential that this review could identify a significant weaknes This will be followed up on in a future inspectio One Unresolved Item was identified, Unsealed Penetrations In Barriers Credited for Appendix R Exemptions, Paragraph 2.b.(1).
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REPORT DETAILS E Persons Contacted ,
Licensee Employees ,
i "C. Buck, Manager, Plant Modifications Department J. Deavers, Shift Supervisor, Operations j G. Dykes, Engineer, Plant Modifications Department
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- S. Fulmer, Safety Audit and Engineering Review J Hayes, Engineering Aide, Fire Protection
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- Henley, Plant Instructor Training Department !
- D. Jones, Manager Engineering, Nuclear Engineering & Licensing l
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J. Knowles Engineering Aide, Fire Protection i *R. Marlow, Technical Supervisor
G. Meintz, Engineering Aide, Fire Protection
- 0. Morey, Plant General Manager
'C. Nesbitt, Technical Manager
- J. Osterholtz, Operatiors Manager
'W. Shipman, Assistant General Manager R. Smith, Engineer, Plant Modifications Department
- L. Troutt, Project Engineer
- F. Watford, Fire Marshal
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Other licensee employees contacted during this inspection included ,
i engineers, operators, security force members, technicians, and 1 administrative personne ,
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j i Other Organizations l t
i Bechtel Power Comporation L l A. DiPerna, Clectrical and I&C Group Supervisor l l
D. DiPerna, Electrical Engineer ;
C. Folt:, Supervisory Designer l 1 "J. Love, Assistant Project Engineer !
R. Puhl, Electrical Engineer !
l C. Va:, Site Resident Engineer
, i j Southern Company Services I N. Stringfellow, Licensing Engineer J. Wilson, Fire Protection Engineer NRC Resident Inspectors
j *G. Maxwell
- E. Reeves, Senior Project Manager - NRR
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- Attended exit interview
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I Assessment Of The Configuration Management Program
Seci.fon 50.48 of 10 CFR 50 requires Farley to comply with Sections II ! III.J, and III.0 of Appendix R, Fire Protection Program for Nuclear !
Facilities Operating Prior to January 1, 197 Farley's Compliance with 10 CFR 50 Appendix R was initially verified by the NRC during an ;
inspection conducted August 19-23, 198 l r
i The purpcse of this inspection was to determine whether the licensee had [
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developed and implemented a configuration management program which insures i i that Appendix R compliance and the postfire safe shutdown capability is i
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maintained over the life of the plant. If this inspection nad determined l i that such a program did not exist or was not functioning a detailed I inspection to reverify the licensees continued compliance with the f requirements of 10 CFR 50 Appendix R would have been recommende l
{ Configuration Management Program !
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! In order to verify that the configuration management program related !
to Appendix R compliance and postfire safe shutdown capability was (
) adequate, the inspectors conducted a detailed review of plant and (
) corporate procedures governing the preparation and review of design l
- change documents to determine
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that these procedures include provisions that ensure all design !
t change documents are reviewed for Appendix R compliance and !
postfire safe shutdown concernt, j l'
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that these procedures provide adequate guidance for the reviewer to determine if there is impact on Appendix R compliance and the -
1 postfire safe shutdown capability, and v
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that these procedures include provisions to ensure that all design change documents which do impact Appendix R compliance and postfire safe shutdown capability are incorporated into the i analyses, procedures, and programs which support and implement j this capability.
- In addition, to verify the implementation of these procedures the inspectors selectively reviewed desig. change documents for
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modifi:ations to those plant systems required for postfire safe
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! (1) Configuration Control Procedures l
! Initially in their review of the design change program at Farley, the inspectors established the methods by which a change to the plant can be nad Through discussions with piant personnel, two types of design change documents were identified.
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Production Change Notice (PCN)
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Minor Departure (MD)
The following procedures governing the preparation and review of PCNs and MDs prepared by site engineering, corporate engineering. Farley's Architect Engineer (AE) and Farley's Service Company were reviewed:
Procedure No./ Revision Title FNP-0-AP-8/Rev. 13 Design Modification Control EDPI 3.16-17/Rev. 12 Project Work Requests (Bechtel)
EDPI 4.27-17/Rev. 5 Design Verification (Bechtel) ;
GD-NG-11/Rev 7 Design Change and Design Control i 70.90-2/Rev. 3 Farley Nuclear Plant Modifications (Southern Company Services) I l
The PCN is the primary method used to generate design changes I to the plant which could affect Appendix R compliance. By l definition a MD'is very limited in scope and a design change j involving an unreviewed safety question cannot be processed as a MD. Therefore, the inspection effort focused primarily on the preparation, review and implementation of PCN Instructions for the preparation, review and implementation of PCNs are provided in FNP-0-AP- In addition to this plant procedure Farley's AE and Service Company have developed procedures for the prepar? tion and review of PCNs internal to their organization The method used by APC0 to implement the design change program at Farley is unique in that the licensee i relies heavily on their AE and Service Company to develop most design changes. Farley's AE is also responsible for maintaining the document, Appendix R Compliance Report, which demonstrates compliance with Appendix In addition, these two organizations are also responsible for maintaining plant drawings current.
i The PCN process originates with any employee identifying a I potential design change he feels could resolve an eristing plant system or equipment preblem, enhance plant or personnel safety or performance, or satisfy a licensing or regulatory requirement. This potential design enange is then considered by plant management and if the need for the design change is justified, a Production Change Request (PCR) is generated. This request is also reviewed by management and, if approved, the Plant Modifications Manager assigns design development to the appropriate organi:ation for PCN developmen As stated earlier, the majority of PCNs are developeo by Farley's AE
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and/or Service Company; however, the procedure does allow for
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the development of PCNs by these offsite organizations and onsite engineering (APC0 personnel). ,
Of fsite design development is to be administered by the General I Of fice-Nuclear Support Group in the APC0 corporate office in ,
accordance with GO-NS-ll. These offsite designs, PCNs, are developed in accordance with the AEs and Service Compaav i procedure The inspectors review of these organization procedures found that an interdisciplinary review of all PCNs r internally generated is required. This review includes a review i by the design group responsible for m11ntaining the Appendix R ;
Compilance Repor In addition, both these organi:ations ;
pro:edures include checklists to assist the reviewer in ;
determining if there is potential impact oq compliance with !
I Appendix R or the fire protection program. The AE's procedure i
! contains a very detailed checklist in SPIP-38-2, Supplementary ;
i Project Instruction for Review of Production Change Notices [
- (PCNs) for Their Impact on 10 CFR 50 Appendix R Safe Shutdown !
, (S50) \nalysis. The inspectors considered these checklists a '
! strengt.' in the licensee configuration management program since .
j 6 , v.svide a valuable guide to the PCN reviewe l l
Af ter the PCN has been prepared by these offsite organizations, !
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the PCN is further reviewed by the Flant Modifications Manage t
- In addition, Plant Operation; Review Committee review is
j required for all PCNs which are: [
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10 CFR 50.59 applicable
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Initial issue of the PCN i
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Revisions to the PCN which increase the scope of the design i change !
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The inspectors determined from their review that the PCN precess for offsite design development appeared adequate to ensure j design changes are reviewed for impact on Appendix R compliance i and the fire protection progra I I
- Plant staff, onsite, design development is also discussed in j FNP-0-AP- The processing of PCNs developed in this menner includes a similar management review of those PCNs gtnerated by of f site organizations. Tnese PCNs include a safety evaluation which requires the preparer to evaluate the design change for impact on the Fire Protection Program Report (FPPR) and .
Appendix R co'npliance. An independent review is also required (
of PCNs generated by the plant staf The inspectors expressed concern that the procedure for plant :
- staf f generated PCNs were not required to be reviewed by the l offsite organi
- ation responsible for maintaining the Appendix R
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Compliance Report prior to implementatio The licensee justifies the lack of such a review based on the limited number of plant staff developed PCNs, the limited scope of plant staff developed PCNs, management involvement in the -eview of these PCNs, and the procedural requirement that all drawing change PCNs be processed by the organizations responsible for upkeep of plant drawings which is Farley's AE and Service Company. The inspectors tonfirmed the licensee's justification by reviewing several plant staff developed PCNs. In addition, the licensee g provided the inspectors with a computer printout that showed no plant staff P'.Ns had been generated since 1?85. Based on Farley management's initiative to limit the number of plant staff generated PCNi and the fact that all drawing c5ange PCNs are reviewed by the off-site organi:ations responsible for maintaining tre Appendix R Compliance Report, the inspectors
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! determined the procedural requirements for plant stuff developed PCNs were adequat ,
As stated earlier, design changes to the plant can also be made ;
, through the MD proces The requirements for tr e preparation.
l review and implementation of MDs is also outlined in Procedure
! FNP-0-AP- The procedure requires a Pre-inplementation :
j Checklist to be prepared for each MD. This cher,klist includes '
1 consideration of adverse affects on fire protection, if the MD j
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will change the basic function of the structure, system or I a component involved or has any adverse affects on operating a l t PORC design parameter If any item on the checklist is
- answered "YES" PORC review is required for the design change to i'
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be implemented as a MD. In addition, management approval of the MD is required prior to implementation. Any MDs which result in drawing changes require a drawing change PCN to be generated which receives a review by the offsite design organization. The ,
d inspectors determined the procedural requirements for develop-j ment of a MD are adequate to ensure that a MD which affects .
Appendix R compliance or the fire protection program will be j j identifie :
In addition to the requirements for the development of design ,
changes outlined in FNP-0-AP-8, the procedure also provides :
detailed instructions for updating plant procedures, programs, l and training pian as a result of the design chang The ,
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procedure requices each group manager to review the design I change description for each modification to determine if the change has any impact on procedures, programs, and/or training ;
plans within tieir area of responsibilit Revisions to the procedures and programs are then istued following the implementation of the modification. This procedural requirement 1
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appears adequate to enaure that procedures and programs which l
} support and impitment Appendix R compliance and the postfire j safe shutdown capability will remain curren i
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J Based on the inspectors review of the procedures governing the
design change process at Farley, it appears the licensee has developtd procedures which insure that Appendix R compliance
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and the postfire safe shutdown capability receive adequate consideration in the design change proces (2) Implementation of Configuration Control Procedures The inspectors reviewed the following PCNs and MOs in order to
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verify that procedures for configuration control are being adequately implemented:
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MD 88-1885 PCN S85-2-3270 L MD 88-1916 PCN S85-1-3286 l PCN 80-1-758 PCN 585-2-3299 i PCN 80-1-759 PCN 885-2-3302 ,
PCN 81-1-1058 PCN B85-2-3384 PCN 884-2-2632 PCN B85-2-3385 ,
PCN S84-2-2732 PCN S85-1-3462 PCN B84-1-2864 PCN 886-2-3499 PCN S8( 2-2915 PCN B86-1-3763 '
PCN 884.-1-3018 PCN 886-2-3796 PCN 564-0-3151 PCN S86-1-;929 PCN B85-0-3183 PCN B87-1-4S18 !
PCN B87-1-4351 ,
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i These PCNs and MDs were prepared, reviewed and implemented in
- accordance with APC0 procedures ex 'ept PCN 886-1-3763. The j implementation of this PCN resulted in a breakdown in the ;
, penetration seal program. As a result of this breakdown an s
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Unresolved Item was identifitd and is discussed in paragraph ,
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2.b.(1). i Appendix R Features Appendix R to 10 CFR 50 requires certain fire protection features to '
, be provided for the separation of redundant safe shutdown systems / l l components in the same fire area. These features include automatic 1 suppression, automatic detection, fire barriers, radiant energy i shields and spacial separatio If a licensee proposes alternate !
methods of protecting the redundant systems / components, an exemption
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front the applicable requirements of Appendix R must be requested, j During the NRC's initial Appendix R compliance inspection at Far'ay,
- August 19-23, 1985, many of these fire protection features were '
1 inspecte However, the licensee's exemption requests were '
! subsequently approved by the NRC in Safety Evaluation (SEs) following the inspectio ,
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During this inspection, the inspectors selectively reviewed those Appendix R fire protection features not addressed during the initial i inspection and also verified that the bases for the NRC's SE still refisited the plant configuration, i in addition, the inspectors selectively eeverified that certain plant areas had adequate emergency lighting for operator access, egress, and manual operation ,
(1) NRC Safety Evaluation Review The inspectors selected the following features for inspection to verify thst the September 10 and December 29, 1986, Safety Evaluations (SE) still reflected the plant configuratio ,
(a) September 10, 1986 SE i Exemption Requests Feature i a
i 1-22 Redundant cabling in fire area
- 1-502 is protected by fire j barrier wrap l l 1-24 Provide redundant signal process !
indication between reactor hot leg ;
temperature loops j l 1-25 Sprinkler system installed in [
l room 345 will act as a water 3 I curtain to prevent passage of i fire from fire area 1-042 to [
adjacent areas.
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t 1-31 One train of Auxiliary Feedwater :
isolation valve cables are l protected by a fire barrier in !
fire area 1-009 l t
1-34 Penetrations in charging pump (
rooms 173, 174, and 181 are sealed )'
and included in the surveillance program (b) Decer.ber 29, 1986 SE [
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Exemption Request Feature j i
2-8 penetrations in charging pump t rooms 2173, 2174 and 2181 are l sealed and included in the I surveillance program f
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Exemption Request Feature (cont'd)
t Partial suppression system is F installed between FCV01139-A and [
FCV011SA-A l
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2-19 One hour fire protection wrap is h provided for control cable l associated with at least one auxiliary feedwater isolation l i v al vt t
2-26 Fire resistance coating was ,
applied to watertight door ,
between fire area 2-030 and fire area , ^16 and added to the plant j surveillance program i
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i 2-35 Added additional sprinklers in j CCW pump room to avoid overhead [
j obstructions :
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j All of these features were verified to be in place by field [
i ri spec ti on . No discrepancies were noted except, the inspectors ;
found in their field walkdown of the charging pump rooms (173, '
f 174, and 181), Fire Area 1-005 of the Auxiliary Building, that !
l penetration 26-100-8 on drawing 0-350822 was unsealed. The l penetrations in the pump room walls internal to fire area 1-005 [
are to be sealed to provide a watertight bounda ry and are l credited in the approved exemption from the technical l requirements of 10 CFR 50 Appendix R Section III.G.2.a to i provide an adequate barrier to inhibit the spread of fire, smoke !
{ or gas between these rooms. Based on this finding, the licensee I j immediately initiated a review of the other walls internal to i fire areas 1-005 and 2-00 This review identified several
! other unsealed cenetrations (nos. 49-100-37, 50-100-37, ;
i 37-100-37, 35-100-37, 26-100-37 37-100-37). Unit 2 was not I
, affected. The itcensee also prepared administrative LCOs for :
- the breached penetrations and established an hourly fire watch i 4 in the affected plant areas as required by the Plant Technical
- Specification During the inspection, PCN No. BSS-1-5419 i I
was prepared to revise plant penetration seal drawings and
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Maintenance Work Requests (Nos. 179172, 182973, 182974, 182975, )
j 182976, 182977, and 182978) were implemented to reseal the j identified breached penetrations. The licensee stated that a I l 100*. review of this type of internal barrier seal would be ;
) conducted for Unit 1 plant area l l
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In addition to the actions noted above, the licensee initiated a ;
i review to determine the root cause of the unsealed penetrations ;
for Unit This review identified that several of the open
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p2netrations should have been affected by the implementation of PCN B86-3763 which changed the cooling water supplies to the gear oil and bearing oil coolers of the charging pumps from ;
service water to component cooling wate This change ;
necessi?.ated the removal and addition of piping from a number of l penetrations through the internal walls to the charging pump i rooms. Plant procedures require that breached fire barriers be resealed by Maintenance Work Request, however, the licensee was i
unable to identify documentation that these affected types of !
internal barriers were sealed during the implementation of the !
I PCN. The licensee identified that the affected penetrations had t been visually inspected on September 14, 1937, following PCN ;
){ 86-3763 implementation, however, no deficiencies were 2 discovere The licensee is continuing their investigation :
i of the circumstances surrounding the failure to seal these
- penetration This is identified as Unresolved Item
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i 50-348/88-27-01, Unsealed Penetrations in Barriers Credited for j Appencitx R Exemptions, pending the completion of the licensee's I j investigation, !
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! In addition, the following operational programmatic requirements !
! were verified to have been incorporated into plant procedures: i j !
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t Exemption Request Programmatic Requirement 2-8 Procedures for fire ares 2-005 covering l
! the manual operator actions required l
1 to regain RCS makeup and regain the ,
control of the reactor head vent i j valves. Verified to be Steps 1.2 and
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i 1.3 of AOP-29.0, Appendix 12
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2-9 Procedures for manual operation of ;
disconnect switches outside the
! Electrical Penetration Room to allow ;
- salves for charging purtp suction and j discha"}e to be opened. Verified to
. l be Step 3.0 of AOP-29.0, Appendix 1 ;
' 2-15 Procedures for fire area 2-013 to regain control of pressurizer PORVs i
, by restoring instrumentation of ,
N2P19HV3SS5-B. Verified to be steps :
] 2.0 and 5.0 of AOP-29.0, Appendix 5 3 i
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- Exemption Request Programmatic Requirement l
(cont 9) l 2-18 Procedures for fire area 2-034 covering ;
i manual actions to regain charging pump :
! mini-flow, to estaolish RCP seal
! injection and isolate RCS sample line !
! Verified to be steps 2.3, 2.4 and 3.0 j
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of AOP-29.0, Appendix 1 (
2-36 Procedures for fire area 2-001 to regain control of instrament air and (
one of the three mainstream atmospheric '
relief valve Verified to be j Steps 2.0 and 3.0 of A0P-2 l Appendix 12.
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i 1-3 Procedures for fire area 72 to place !
i service water discharge on emergency !
recirculation to the service water i
! pond, Verified to be Step 1.0 of :'
) A0P-29.0, Appendix ,
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i 1-12 Procedure for fire area 2-076 for !
I ranual actions required to regain {
l normal control of a pressurizer POR '
Verified to be Steps 1.0 and 2.0 of ;
) AOP-29.0, Appendix 5, t
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] (2) Fire Barriers (
The following Appendix R fire barrier penetration seals were l l inspected to verify that they reet the requirements of Technical (
l' Specification 3/4.7.12 and that the seals were as specified on i plant design drawings.
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penetration No, location Auxiliary Building I'
j 01-100-OS Room 174 Elevation 100 !
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02-100-08 Room 174 Elevation 100 t j 03-100-08 Room 174 Elevation 100 j i 04-100-0S Room 174 Elevation 100
- 05-100-OS Room 174 Elevation 100 l
i 06-100-0S Room 174 Elevation 100 i j 07-100-08 Room 174 Elevation 100 !
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08-100-0B Room 174 Elevation 100 {
i 09-100-08 Room 174 Elevation 100 !
4 10-100-03 Room 174 Elevation 100 I 11-100-OS Room 171 Elevation 100 l
! 12-100-0S Room 171 Elevation 100 )
J 13-100-03 Room 171 Elevation 100 1
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Penetration N Location Auxiliary Building !
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14-100-08 Room 171 Elevation 100 15-200-08 Room 171 Elevation 100 l
16-100-08 Room 171 Elevation 100 ;
17-100-08 Room 171 Elevation 100 18-100-08 Room 171 Elevation 100 19-100-08 Room 171 Elevation 100 l 20-100-08 Room 171 Elevation 100 1 21-100-03 Room 171 Elevation LOO i Room 171 Elevation 100
'22-100 08 f 1 23-100-08 Room 171 Elevation 100 ,
l 24-100-08 Room 171 Elevation 100 1 25-100-08 Room 174 Elevation 100 i 27-100-08 Room 171 Elevation 100 01-100-23 Foom 192 Elevat t or.100
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! 02-100-23 Room 192 Elevation 100 i 09-100-23 Room 192 Elevation 100 l
! 04-160-23 Room 192 Elevation 100 j
, 05-100-23 Room 192 Elevation 100 :
- 06-100-23 Room 192 Elevation 100 ;
] 07-100-23 Room 192 Elevation 100 !
- 08-100-23 Room 192 Elevation 100 l i
09-100-23 Room 192 Elevation 100 i
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10-100-23 Room 192 Elevation 100
- 11-100-23 Riem 191 Elavation 100
12-100-23 Room 191 Elevation 100 l 13-100-23 Room 191 Elevation 100 I
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] 14-100-23 Room 191 Elevation 100 j 15 100-23 Room 192 Elevation 100 l 16-100-23 Room 192 Elevation 100 l 17-100-23 Room 192 Elevation 100 !
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18-100-23 Room. 192 Elevation 100 l 15-100-37 Room 173 Elevation 100 1 16-100-37 Room 173 Elevation 100 1 17-100-37 Room 173 Elevation 100 1 18-100-37 Room 173 Elevation 100
- 19-100-37 Room 173 Elevation 100 t I 20-100-37 Room 173 Elevation 100 :
l 21-100-37 Room 173 Elevation 100 i l 24-100-37 Room 173 Eievation 100 ;
i 25-100-37 Room 173 Elevation 100 i i
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26-100-37 Room 173 Elevation 100 i 27-100-37 Room 173 Elevation 100 j SS-100-37 Room 181 Elevation 100 4 59-100-37 Room 181 Elevation 100 i
hcept as noted in paragraph 2.b.(1), all penetration seals j inspected were found installed as recuired oy plant Technical Specifications and plant crawings.
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1 The following raceway fire barriers Installed to meet the separation requirements 'f Aprendix R were inspected and found functiona Raceway N Location ,
BFD 02B Auxiliary Building Elevation 100 l
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BF0 03B Auxiliary Building Elevation 100 i a BF0 06B Auxiliary Building Elevation 100
< BHM 09Z Auxiliary Building Elevation 145'-6" Al*FISA Auxiliary Building Elevation IC3 ;
1 AHD128 Auxiliary Building E'evation 100 Auxiliary Building Elevatien 100
A!0258 AID 128- Auxiliary Building Elevation 100 A0015B Auxiliary Building Elevation 100 1 AHD310 Auxiliary Building Eievetion 100 ;
AHE071 Auxiliary Building Elevation 139 i BHJ511 Auxiliary Building Elevation 139 BHJV18 Auxiliary Btilding Elevation 139 ,
i BHJV21 Auxiliary Butiding Elevation 139 '
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BHJW12 Auxiliary Building Elevation 139 BHKZ18 Auxiliary Building Elevation 139 ,
l BHKZ21 Auxiliary Building Elevation 139 j
- AHP448 Service Water Intake Structure ;
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AHZ281 Service Water Intake Structure J AEP310 Service Water Intake Structure i
! AH5419 Service Water Intake Structure j AM5421 Service Water Intake Structure !
AEP320 Service Water Intake Structure i l AH5376 Service Water Intake Structure i l AEW252 Service Water Intake Structure
AHPS50 Service Water Intake Structure :
) AEN2!,1 Service Water Intake Structure !
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ADW390 Service Water Intake Structure l ADN391 Service Water Intake Structure l l i j In addition, the licensee's Procedure FNP-0-FSP-43, Visual [
4 Inspection of Kao wool Wraps, for inspecting these raceway fire ;
barriers was reviewe The procedure does not presently ,
, identify the specific raceways which are to be protecte (i I Instead the procedure instructs the inspector to visually i
inspect all of the fire barriers in a given roo The inspectors expressed concern that by not specifically identifying the raceways required to be wrapped in the procedure .
that it is possible that missing wraps eay not be identified !
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during the periodic inspection, In response to this concern the licensee comitted to strengthen the procedure by referencing !
the Appendix R Aao wool fire barrier design drawings for eaci i room in the procedure and verifying the raceway Kao wool wraps {
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are installed in accordance with these drawings. This will be adequate to resolve the inspectors concerns. This is not identified as an inspection finding since all of the raceway fire barriers inspected were found to be intac ; (3) Separation cf Redundant Systems / Components The inspectors reviewed the separation provided for the control '
cables associated with the Volume Control Tank (VCT) outlet
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valves. ;CV-0115C-A and LCV-0115E-B. and the A. B and C train j charging pump cables. The inspectors wished to verify that with *
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the spurious closure of the VCT outlet valves due to fire would
' not affect the ability to supply charging flow since the pumps :
would be without a suction supply until the operators manually j opened the Refueling Water Storage Tank (RWST) outlet valves, t
The design of the Chemical and Volume Contrnl System (CYCS) at ;
Farley includes three charging pumps for each unit, one A train ;
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pump, one B train pump and a swing pump capable of being powered ,
by A or B train. Each pump is 100% capacity and therefore, only
! one pump is required for postfire safe shutdown. The A and B i train pumps are designed to start on a loss of offsite powe .
l The C train pump must be manually starte Therefore, it is '
4 possible that the A and B train charging pumps could be damaged I due to pump cavitation if a fire should occur in a plant area l I
where the spurious closure of the VCT outlet valves is a concer However, the swing pump would not be damaged.
Therefore the inspectors verified the separation of the power
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cables for the swing pump from the VCT outlet valve ;
The licensee has identified the following plant areas where the j VCT discharge valves control cables could be damaged which could j result in the spurious closure of the valv j i
. Unit 1 Unit 2 [
VCT Valve N Fire Area Fire Area Description l
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! LCV 0115C-A 1-035 2-035 Train A Electrical Penetration Room .
1-404 2 040 Cable Spreading Room !
- 44 44 Main Control Room j i LCY 0115E-8 1-034 2-034 Train B Electrical l
] Penetration Room l 3 1-502 2-502 Stairwell 2 l
1-040 2-040 Cable Spreading Room l
44 44 Main Control Room l l
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l The inspectors verified by review of the Appendix R Cornpliance i Report and field walkdown that none uf the cables associated
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with the charging pumps pass through Fire Areas 1 034, 2-034, j
! 1-035, 2-035, 1-502 or 2-502. The charging pump cables are i l routed in the Cable Spreading Room, Fire Areas 1-040 and 2-040, l
! and the Main Control Room. APC0 has provided alternate shutdown -
l capability for these fire areas. The het shutdown panels are f
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provided with hand switches and circuits for control of all l three charging pumps for each Unit. Both trains of RWST outlet >
valves can also be opened f rom the hot shutdown panel, t
Csseo on this review, the inspectors found that for a postulated !
fire in any plant area where the VCT outlet valves could !
spuriously close that at least one charging pump, C train, would I be undamage (4) Emergency Lighting !
f The emergency lights installed to illuminate operator access and !
egress paths and safe shutdown equipment for several plant areas denoted in Steps 5.1 through 5.15 of Procedure FNP-2-AOP-28.2, .
Revision 5, Fire in the Control Room, were inspected and i verified to be operabl The inspectors also reviewed the licensee's procedures that ensure emergency lights will be maintained in accordance with the manuf acturer's instruct' ns and ensure that they will be operable in the event that they are require Electrical maintenance procedures FNP-1-MP-2041 and FNP-2-MP-2042 titled :
Maintenance of Emergency Lighting Units 1 and 2 Appendix "R" ;
address visual inspection for damage, the electrolyte level and ;
charging state of the battery. The inspectors expressed concern that these procedures did not specifically verify that the lights are properly aime In response to this concern the licensee committed to enhance the procedure to add a sign-off to !
verify that the beams on the unit are aimed in the direction as I denoted on drawings referenced in the procedure data sheet l This will be sufficient to resolve the inspectors concerns and i is not identified as an inspection finding, Postfire Safe Shutdown Procedures i (1) Procedure Review ,
The inspectors reviewed operations Appendix R postfire safe li shutdown procedures to determine that any revisions Made i to the procecures did not impact on the licensee's postfire !
safe shutdowr. capability as reviemed and acceptec during the :
initial Appendia R inspectio It was noted that Frocecure I A0P-1-ACP-28.1 had been revised to include not only a fire event l
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l in tht Cable Spreading Room but also inadvertent fire protection ,
syncem actuation in that plant area. All procedure enhancements [
l appeared to be adequat L
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(2) Licensed Operator Requalification Program for Abnormal l Procedures for Fire Event > j The inspectors reviewed the documentation for verification !
of reactor operators annual procedure review for requalification i training on the abnormal operating procedures. This training ;
requires each reactor operator and senior vperator to review the L c1r. tents of all AOPs on an annual basis and continued training i on the simulator which includes the Hot Shutdown Panel and/or !
other classroom review In lieu of regular walkthroughs of the AOP Fire Safe Shutdown l procedures the licensed operators participate in the required ,
quarterly fire brigade drills which include a review and !
criticue of the control room operator's utilization of AOP-29 i and AOP 28.11.2 to take necessary actions to maintain at least '
one train of safe shutdown systems operable for various plant (
fire drill scenario No shif t walkthrough drill of the AOPs [
was conducted during this inspection; however, based on the i review of the licensee's training records and fire brigade drill i critique comments for 1988, the licensee trsining on the [
abnormal procedures for a fire event appeared to be complete and [
effectiv j l
(3) Damage Control Measures l
Appendia R Section !!!.L.5 requ're fire protection features to I be p ovided for structures, systems and components important to
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safe shutdown and to be capable of limiting fire damage so that systems necessarv to achieve and maintain cold shutdown are free of fire damage or can be repaired such that the equipment can be madv 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 />, f
Materials for such repairs are required to be readily available on site and procedures are to be ih effect to implement such {
repair [
Tre inspectors reviemed portions of Farley's AOP 28.1 for a t fire in the cable spreading room. This procedure is used to j bring the plant to hot stardby and cold shutdown under enormal i conditions and provf Jes for eepair measures, if necessary, to l affect cold shutdow The equip-ent for the repair measures identified by this p*ocedure have been dedicated for this purpose ar.) are located in the Turbine Building Electrical Maintenance Storage Area under lock and ke All of the equipment was audited to the .
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procedure requirements and was found tagged to identify it I to the applicable procedure section so that its location and ,
- use, in an emergency, could be readily determine l
- Associated Circuits Review i The inspectors verified that the licensee had established a program !
l for ensuring that the replacement of breakers and fuses was !
i controlled such that breaker / fuse coordination is maintaine Discussions were held with electrical engineers from the Plant (
! Modifications Grou It was noted that replacement of components, :
breakers or fuses, is recuired to be with parts described on design l
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drawings per Procedure FNP-0-6MP-0.1, General Maintenance Procedur [
] The manufacturer, type and rating of breakers and fusees are ;
j designated on electrical design drawings. Therefore, any thing less !
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than a like for like replacement of breakers or fuses could not be ,
1 done under a Maintenance Work Order (Mdo) per FNP-0-AP-52. Equipment l l Status Control and Maintenance Authorication. The replacen:ent of a i i breaker or fuse with other than what is designated on design drawings .
) would as a minimum constitute a drawing change which would require a ;
I PCN to be generated. As stated in Section 2.a.(1), PCNs are reviewed [
l by the offsite organi:ation responsible for maintaining the
) Appendix R Compliance Report wnich includes breaker / fuse coordina- :
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tio Therefore, this rethod of controlling breaker and fuse l l replacement appears adequate to ensure coordination is maintained.
j in addition, the inspectors field verified that a sample of breakers ,
j and fuses installed in the panels were as specified on plant drawings i i and in the Fariny Breaker / Fuse Coordination Study Calculation. The I j inspectors found no discrepancies i curing this inspection, j
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j Review of 50.59 Evaluations i
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The licensee has recently incorporated the description of the Farley i Fire Protection Program from the Farley Fire Protection Program [
J Reevaluation (FPPR) document into Appendix 9B of the Final 5sfety l
- Analysis Report (F5AR). This charge was made in response to the
] guidance provided in Generic Letter (GL) 66-10, Implementation of a
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fire Protection Requirement This GL directed all licensees to incorporate their approved fire protection programs into the FSAR and :
then apply for the standard license condition outlined in ths GL.
! APC0 is presently in the process of preparing a submittal to request {
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the standard fire protection license conditio !
Under the new licensa condition APCO will be permitted to make
! Changes to the fire ^tection problem contained in the FSAR through !
i the 50.59 process witr~ t prior NRC approval of the Corrission if the :
j change would rot adversely affect the ability to achieve and etaintain !
j shutdown in the event of a fire. APC0 has begun implementing this i j proce s s for making changes to the fire protection program anc ;
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generated a number of 50.59 evaluations to justify changes to the program between incorporating Amendment 8 of the FPPR and into [
Appendix 9B of the FSA f The inspectors reviewed a sample of these 50.59 Evaluation The i evaluations reviewed are described belo l 1 (1) Revision to Sectien 4.2.4.1.6 of the TPPR to create Section l J 9B.4.1.6 of the FSAR. This change deleted a previous l a requirement to protect compressible cork material with a 1/2 t hour fire barrier where the material was part of a fire barrier :
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i separating two fire area The licensee's evaluation states
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that this requirement was included in Amendment 8 of the FPPR in !
j error. The deletion of this requirement was approved by the NRC I
- and is documented in a Pecember 9, 1983 APC0 lette The l j inspectors found this avaluation acceptable.
l (2) Revision to Section 4.2.4.2.5 of the FPPR to create Section !
! 98.4.2.4 of the FSA This change deleted the statement from l i Amendment 8 of the FPPR that there is no safe shutdown equipment [
] in the Turbine Building and that the Turbine Bu11dir.g walls are l 1 three hour fire rated. The itcensee's evaluatica states that ;
- this change was r
- ade to clarify the as-built status of the l I Turbine Buildin As the result of the Appendix R analysis it (
I was recognized that the Turbine Building did in fact contain ,
equipment required for shutdown. Therefore, the statement that L i
it did not was deleted. The statement regarding the Turbine !
) Building having three hour fire rated walls was deleted since l 1 the wall separating the Turbine Building from the Service ,
Building is the only three hour rated wal). The licensee stated j
, that a reclarification would be added to Appendix 95 of the FSAR ,
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in the next revision and that the wall between the Service ;
Building and the Turbine Building would be maintaines as a threo !
hour barrie The inspectors found this evaluation acceptabl f l l
- (3) Revis.on to the Fire Hazards Analysis Sections of the FPPR, ;
- regarding combustible loading increases in plant fire areas 7 where emeuptions from the requirements of 10 CFR 50 Appendin R ;
1 were granted, to create the Fire Hazards Analysis Sect. tons of i
{ Appendix 98 of the F5AR. This change increased the combustible l i leading for cable insulation in a number of p? ant area The j j inspectors expressed concern in these increasen since many of ;
the exemptions from the requirements of Appendix R were based I l partly on the combustible leading of the area. The licensee's ;
J evaluation states that these values increased as a result of a I
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, reevaluation of combustible loading performed in April of 1937.
- In t,he reevaluation it was conservatively assume 1 that all
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raceways were filled to the easinam allowed by electrical cedes.
l This would prevent the licensee frem having t,o revise the j co-bustible leading every time new cable was routed in the
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l plant. When the revision was made the safety evaluation failed to address the affects of the new combustible loadings on NRC
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approved exemption However, at the time of this inspection l the licensee provided the inspectors with a new safety j evaluation for the combustible loading value This evaluation j demonstrated t,ha t in all but six rooms the conservative
- combustible loading calculation increases were in rooms where i NRC granted exemptions were not based on combustible loading j values. In the six rooms whare NRC exemptiens were granted I t ased on combustible leading values, the licensee recalculated the actual combustible loading and demonstrated that the actual i loading had not changed from that in the NRC approved exemptio ! Although the original safety evaluation did fail to antlyze the 1 effects of the combustible loading changes on NRC approved
! exemptions, this is not identified as an inspector finding since
the actual plant configuration had not changed from that i discussed in the approveG exemption. The licensee has committed j in the safety evaluation to revise the combustible loading j values in the FSAR for the six rooms affected and to control the i addition of combustibles to the rooms to ensure the NRC approved exemptions are not invalidate The inspectors found this
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evaluation acceptabl . Action 01 NRC Information Notices
! IE Infor1 ration Notices 84-16, Failure of Automatic Sprinkler System
! Valves to Operate, March 2, 1984; and IE Information Notice
] No. 86-17 Update of Failure of Automatic Sprinkler System Valves to j Operate, March 24, 195 I i Information Notices 84-16 and 86-17 were issued to notify nuclear I power reactor facilities of the operational f ailure of dekge a.id j pre-action fire protection valves, identified as Model C,
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nanufactured by Autoratic Sprinkler Co"porat, ton of America.
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In response to these notices, the licensee had implemented the j corrective actions recomended by t,he manuf acturer of replacing the I valve clapper latch assembly and latch arm on all six inch Model C .
j' v e es. The licensee has six of these type valves in use at Farley
- serve non-safety related deluge suppression systems. The
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, latch assemblies and latch arm were purchased from Automatic I er Corp uncer purchase request 87-05312 and were replaced in
.uge valves on the sys'. ems by the W Os listed belo j System Neber WC
1 2TR-66 146439 j 2TR-65 146440 j 2TR-64 146441 J 2TR-67 146442
) 4TR-63 146443 1 2TR-69 146444
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V The Itcensee's corrective action is adequate to resolve the concerns outlined in the information notic NRC Inforcation Notice No. 88-04, Inadequate Qualification and t
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> documentation of Fire Barrier Penetration Seals, February 5,1588; ,
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and Supplement 1. August 9, 198 ,
Information Notice 88-04 and it's supplement were issued to notify ;
'J nuclear power reactor facilities that some installed fire barrier l
! penetration seal designs may not be adequately qualified for the i destpn rating of the penetrated fire barrier, i
As discussed in the notice, the licensee has completed a review to
- define the licensing basis as it relates to fire barrier penetration ;
seal design. This review determined that the penetration seal design !
and fire test irfomation was originally reviewed by the NRC during
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the initial review of the fire protection program in 197 In l response to a series of questions generated by the NRC, the licensee
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j provided the seal design and fire test documentation to NRR for review. In April of 1979 the NRC issued a SER which although, did !
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not specifically accept the penetration seal and test report, it did ;
j acknowledge acceptance of the licensee's responses to the NRCs i
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questions genecated in order to prepare the SE l
) The licensee had not detemined what additional action, if any, would j be taken in order to address the concerns in the notice. Any further i
action taken by the licensee will be reviewed in future inspections, i
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4. Action On Previous Insptetton Findings (92701 and 92702)
, (Closed) Deviation 348/88-13-01, Designated Combustible Storage 1 Area Not Separated From Safe Shutdown Related Areas by Approved Fi w l
) Wall [
This deviation resulted from the licensee's failure to maintain the i fire walls separating combustible storage in Room 444 from the i remainder of the plant. The licensee comitted to provide fire walls l for this room in Section 98.2.2.2 of the FSAR.
! The licensee's cc.rective acti;n for the deviation has been to remove I J all the combustibles from Room 444 and not allow further combustible !
i storage in this are In addition, a sprinkler was reinstalled !
j in the roo The inplementation of these corrective actions was i verified by a field l'ispectio l
- (Closed)URI 348/88-16-01, Failure To Provide Fire Breats In Vertical !
- Cable Trays, '
I During an inspection of the Unit 1 Conteirrent Building by the l Resident Inspector it was noted thet vertical cable trays were not :
provided with fire breaks as required by the FPPR and Section 9B !
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. of the FSA Section 4.2.4.1.26 of Revision 8 of the FPPR and
) Section 98.4.1.26 of the FSAR state that fire breaks shall be !
provided as required by the Fire Ha:ards Analysis and in all cases f where a vertical tray runs for more than 20 feet with no penetration ;
seal, However, the licensee has determined that these fire breaks are no longer required to provide separation of redundant trains i i required for postfire safe shutd The licensee provided the !
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inspectors with a Safety Evaluation which justifies not providing .
1 the fire breaks as required by the FPPR and FSA The licensee's l
} justification is based upon the fact that no credi* has been taken [
for these fire breekt in meeting the separation requirements of r
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10 CFR 50 Appendix The commitment to provide these fire breaks was made when APO initially compared their Fire Protection Program l ll
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to the guidance of Appendix A to BTP APCSB 9.5-1 and was never deleted from ths FPPR following the reevaluation of the program to
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i the separation requirements of Appendix R.
l The inspectors verified that the fire breaks were not credited for providing separation of components required for postfire safe [
t shutdown by conducting a detailed review of the licensee's Fire i Hazards Analysis and NRC generated SEs approving exemptions from the
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I j requirements of Appendix R. The inspectors did not identify any area j j where the fire breaks were credited with providing Appendix R i i separatio The licensee stated that the requirements to provide f j these fire breaks will be deleted from the FSAR in a future revision. l
} Th FPPR has been superseced by Section 98 of the FSAR therefore a j revision to the FPPR is not required.
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j Although the licensee failed to implement their commitments l documented in the FPPR and FSAR regarding fire breaks, tne failure to
! provide these fire breaks had no safety significance. TM licensee !
! has provided the required separation of redundant saf, shutdown !
1 trains and has not crecited the fire breaks for pre <tding this separatio Therefore, the f ailure to provide the f;re breaks had
! no impact on the licensee's ability to achieve anS maintain safe l
! shutdown following a fire. In addition, the f ailure to provide the j j fire breakt does not constitute a reduction in the effectiveness of !
the fire protection program since the cable provided at Farley is !
qualified not to propagate flare and to be self extinguishin [
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I (Closed) URI 348; 364/8S-26-02, Inadequate Fire Protection Features l j Provided for Service kater Mnor 0;erated Velves Controlling Return ;
! Flow in Service Water Syste {
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I During a design review of a modification to an electrical duct bank containing electrical cables for the service water system, the licensee's design engineering firm (Bechtel) identified several cables to service water valves which do not meet the fire protection !
! separation requirements of Appendix R. A fire in Unit 1 Fire Area j 56. Train A switchgear roo . of diesel generator bvilding, could i
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cause the spurious operation or closure of valva Q1P16V549-A which controls return service water flow from both trains to the river. A fire in Unit 2 Fire Area 2-004, 155' elevation of auxiliary building, could cause the spurious operatien or closure of valve Q2P16V549-A which controls return service water flow from coth trains to the river. Closure of either of these valves could result 'n the loss of the service water system .'or the affected unit since the return flow path would % blocked by the shut valv A' interim correction, the licensee promptly verified valves 01P16VL49-A and Q2P16V549-A open and removed power to these valve The breakers for these sal,es were opened under administrative procedures and taggea accordingly. A safety evaluation was performed and procedures FhP-1-50P 24.0 and FNP-2-50P 24.0 were issued on September 16, 1988 to reflect power lockout from valves Q1P16VC49 and Q2P16V54 During this inspection the lir.. n se e provided the inspectors with an evaluation which stated that the loss of service water would be readily identified should these valve spuriously close and that existing emergency plant procedures cover this condition to mitigate the consequences of the accident and restore the plant to a desirable conditio In addition the licensee stated the diesel generators could de supplied service water from either unit by cperating valves controlleo from the control room and that the charging pumps could be affected but in the short term could be assund to be operable for up to 15 minute Although the licensee's analysie failed to adequately address the loss of service water causid by the spurious operation of the com on service water discharge valves for a fire in area 1-56 A or 2-4 assuming loss of of f site power, this f ailure wovid have no signifi-cant af fect on safe shutdown capabilit The licensee has provided an acceptable correction eethod by open breakers to these valves to prevent spurious valve operation. Tnerefore, there is assurance that one service water discharge flow path fer each untt will remain available for a fire in areas 1-56 A or 2-4. This item is considered close . Enit Interview
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The inspection scope and results were sumarized on Septetber 30, 1958, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in cetail the inspection results listed below. During the inspection the licensee's staff rade various written cortmitments in response to inspector questions to resolve micer discrepancies and to imple-ent program improvements. Each of these comitments was restated to APC0 manageeent during the exit interview to insure their concurrenc These co.mitments tre outlined in the applicable sections of the repor Proprietary information is not contained ir, this re; ort. Cissenting ec-sents were not received from the license . _ _ _ _ _ - _ _ _ _ _ _ - - - _ _ _ _ - - _ _ _ - - _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - - _ _ - _ _ _ _ _ _ _ _ - _ -
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i Item Number Pieriptio_ i
i i URI 348,/88-27-01 Unsealed Penetrations In Barriert ;
Credited for Appendix R Exemptions j
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