IR 05000387/1985006
| ML17156A196 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/10/1985 |
| From: | Anderson C, Krasopoulos A, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156A193 | List: |
| References | |
| 50-387-85-06, 50-387-85-6, 50-388-85-06, 50-388-85-6, NUDOCS 8505030555 | |
| Download: ML17156A196 (54) | |
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U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
50-387/85-06 Report Nos.
50-388/85-06 50-387 Docket Nos.
50-388 NPF-14 License Nos.
NPF-22 Priority Category C
Licensee:
Penns lvania Power and Li ht Co.
2 North Ninth Street Allentown PA 18101 Facility Name:
Sus uehanna Steam Electric Station Units 1 and
Inspection At:
Salem Townshi Penns lvania Inspection Conducted:
Februar 11-15 1985 Inspectors:
5I Pull ni e Protection Engineer date A. G. Krasopoulos, Reactor Engineer Also participating and contributing to the report were:
A. Fresco, Mechanical Systems Specialist, BNL D. Kubicki, Chemical Engineering Branch, NRR E. MacDougall, Electrical System Specialist, BNL 4 l'o d te Approved by:
C. J.
Anderson, Chief, Plant Systems Section, DRS date Ins ection Summar:
Ins ection on Februar 11-15 1985 Ins ection Re ort Nos.
50-387/85-06 and 50-388/85-06
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capability of the plant in the event of a fire, (2) emergency lighting, (3)
oil collection system for reactor coolant pumps, and (4) the fire protection/prevention program.
The inspection involved 154 inspector hours on-site and 66 inspector hours in-office by the team consisting of 5 inspectors.
8505030555 850429 PDR ADOCX 05000S87
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Results:
Two violations and one deviation were identified.
Eight items remained unresolved at the end of the inspection (see Attachment 3 for a summary of inspection findings).
DETAILS 1.0 Persons Contacted 1. 1 Penns lvania Power and Li ht Com an PP5L K. Backenstoe, Senior Project Engineer
- T. Bai leys, Fire Protection Engineer
'W. Barberich, Manager, Nuclear Licensing
- R. Byram, Technical Supervisor
"C. Coddington, Senior Project Engineer, Licensing
~T. Crimmins, Manager, Nuclear Plant Engineering
"H. Keiser, Station Superintendent D. Kohn, Fire Protection Engineer G. Merrill, Power Production Engineer
- R. Prego, guality Assurance Supervisor, Operations J.
Todd, Compliance L. Weed, Project Engineer C. Whirl, Senior Project Engineer 1.2 Nuclear Re ulator Commission NRC
~C. Anderson, Chief, Plant Systems Section J. Durr, Chief, Materials and Process Section H. Gregg, Lead Reactor Enginee'r L. Plisco, Resident Inspector
- R. jacobs, Senior Resident Inspector The team also interviewed other licensee and contractor personnel during the course of the inspection.
- Denotes those present at the exit meeting.
2.0
~Pur oae This inspection was to ascertain that the licensee is in conformance with the applicable requirements and his previous commitments with respect to (1) the safe shutdown capability of the plant in the event of a fire, (2)
emergency lighting, (3) oil collection system for reactor coolant pumps, and (4) the fire protection/prevention program.
3.0
~Back round
CFR 50.48 and Appendix R of 10 CFR 50 became effective on February 17, 1981 for plants licensed prior to January 1,
1979.
For plants licensed or to be licensed after January 1,
1979 (Susquehanna Units 1 and 2 fall under this category),
CFR 50.48 and Appendix R are invoked by the licensing process which includes a review of the Fire Protection Program for conformance with the Standard Review Plan (NUREG-0800),
Section
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9.5.1, dated July 1981 or its previous version, BTP APCSB 9.5-1 including its Appendix A.
Susquehanna Units 1 and 2 were reviewed against the latter document.
The review of the licensee's Fire Protection Program is documented in the Safety Evaluation Report (SER) dated April 1981 and its supplements
through 6.
Various licensee commitments are documented in the SER, its supplements, and several licensee submittals.
One such commitment, applicable to both units, was in a licensee letter dated March 26, 1981, stating that the licensee will comply with the requirements of Appendix R to 10 CFR 50 and in particular Sections III.G, J, and 0. Supplement 1 to SER, in Section 9.5.8, reiterates the commitment to backfit Sections III.G, J, and 0 and concludes that, upon completion of the required modifications, Susquehanna Units 1 and 2 fire protection program will meet the intent of Appendix R.
A similar statement is also in Section 9.5.8 of SER Supplement 6.
Unit 1 Facility Operating Licenese, Amendment 16, dated September 28, 1983, Paragraph 2.c(6), requires that the licensee shall maintain in effect and fully implement all provisions of the approved Fire Protection Review Report (FPRR),
as amended through Revision 2, dated November 1982, and that the licensee shall maintain the fire protection program set forth in Appendix R to
CFR Part 50.
For Unit 2, Facility Operating License, dated March 23, 1983, Paragraph 2.C(3), requires that the licensee shall maintain in effect and fully implement all provisions of the approved fire protection program.
This paragraph also references the SER and its supplements 1 through 3.
As discussed earlier, Supplement 1 reiterates the licensee commitment to comply with the requirements of Appendix R, Sections III.G, J, and 0.
In summary, all provisions of Appendix R, Sections III.G, J, and 0 and the approved fire protection program as contained in the FPRR, Revision 2, were made a condition of the Unit 1 Facility Operating License.
The requirements and commitments discussed above were used by the team as bases for the inspection.
guestions were raised during the inspection regarding the applicability of the legal requirements of Appendix R, Sections III.G, J and 0 as they apply to Unit 2.
This issue has been referred to NRR for their resolution.
Section III.G of Appendix R requires that fire protection be provided to ensure that one train of equipment necessary to achieve and maintain safe shutdown remains available in the event of a fire at any location within a licensed operating facility.
For hot shutdown conditions, one train of the systems necessary must be free of fire damage (III.G.l.a).
For cold
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shutdown conditions, repair is allowed using in place procedures and materials available onsite with the provision that cold shutdown be achievable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the initiating event (III.G.l.b).
Section III.G.2 lists specific options as follows to provide adequate protection for redundant trains of equipment located outside of the primary contain-ment:
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Separation by a fire barrier having a three hour rating (III.G.2.a).
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Separation by a horizontal distance of at least 20 feet with no intervening combustibles and with fire detection and automatic fire suppression installed in the fire area (III.G.2.b).
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Enclosure of one train in a fire barrier having a one hour rating in addition to having fire detection and automatic suppression installed in the fire area (III.G.2.c).
If the protection required by Section III.G.2 is not provided or the systems of concern are subject to damage from fire suppression activities,Section III.G.3 of the rule requires that an alternate or dedicated shut-down capability be provided which is independent of the area of concern.
Any alternate or dedicated system require
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NRC review and approval prior to implementation.
For situations in which fire protection does not meet the requirements of Section III.G, however, such protection is deemed to be adequate by the licensee for the specific situation, t! e rule allows the licensee to request an exemption on a case-by-case basis.
Such exemption requests are submitted to the NRC for review and approval and must be justified by the licensee on a technical basis.
All correspondence on the subject, between the licensee and the NRC, was reviewed by the inspection team in preparation for the site visit.
Attachment I to this report is a listing of the correspondence reviewed.
5.0 Post-Fire Safe Shutdown Ca abi lit The Fire Protection Review Report, Revision 3, describes the post-fire safe shutdown capability with and without offsite power and also the remote shutdown capability (from outside the main control room).
5. 1 Plant Shutdown with Offsite Power A normal plant cooldown is accomplished by heat rejection to the main turbine condensers with makeup water supplied by the condensate and feedwater system.
The residual heat removal (RHR) system is used to remove the residual heat from the core after the reactor coolant has
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been reduced to approximately 90 psig.
Once the reactor system has been placed in the cold safe shutdown condition, it is maintained in this condition by the RHR system in its shutdown cooling mode.
The following systems would also be required to reach the cold shut-down condition in the manner described above:
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Division I or II RHR service water system to supply cooling water to the RHR heat exchangers.
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Division I or II emergency service water system to supply cooling water to the RHR pump motor lube oil coolers, the pump seal coolers, and RHR pump room unit coolers.
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Offgas system
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- Service water system
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Instrument air system All other systems required for the operation of the steam plant and condenser but not those systems or components required only for electrical power generation.
5.2 Plant Shutdown without. Offsite Power In case of loss of offsite power and/or a single fire in any one fire zone, reactor cooldown can be effected without reliance on any nonsafety-related systems.
The cooldown to 90 psig would be accomplished, assuming a loss of offsite power, by discharging steam to the suppression pool via any of the main steam safety relief valves and providing makeup to the reactor from the reactor core isolation cooling (RCIC) system.
The main steam isolation valves would be closed to avoid depending on the non-safety turbine stop valve and main steam bypass valves.
The RHR system would be operated in the suppression pool cooling mode to reject heat to the ultimate heat sink (spray pond).
Alternatively, the RHR heat exchangers could be used in the steam condensing mode to transfer heat directly to the ultimate heat sink.
After cooldown to approximately 90 psig, the RHR system would be used in the shutdown cooling mode to cool the reactor directly and to achieve and maintain the reactor in a cold shutdown condition.
The following systems would also be required to achieve cold shutdown in the manner described above:
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Division I or II RHR service water
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Division I or II emergency service water
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Division I (AEC) or II (BED) emergency diesel generators.
Miscellaneous divisionalized support systems are listed in Table 40.95-1 of the Final Safety Analysis Report (FSAR), response to FSAR guestion 40.95 (see Attachment 2 to this report).
A complete divisionalized list of safe shutdown equipment is found in FSAR Table 40.95-2.
Except for the RCIC system and the RHR shutdown cooling suction line, each of the systems required for cold shutdown have redundant loops, one associated with Division I, and one associated with Division II.
The HPCI system (Division II) provides a redundant backup to the RCIC system (Division I).
Additionally, the following system com-binations are capable of safely making the transition to 90 psig where the RHR shutdown cooling mode would be effective:
Automatic depressurization system (ADS) plus low pressure coolant injection system (LPCI) (Division I or II)
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ADS plus core spray system (Division I or II)
5.3 Remote Shutdown Ca abilit The plant is designed with a main control room that is common to Units 1 and 2.
A Remote Shutdown Panel (RSP) is provided for each unit in the event the control room becomes uninhabitable.
The design is such that the reactors can be placed and maintained in a safe cold shutdown condition from outside the main control room.
Transfer switches on the RSP allow the operator to isolate and transfer control from the control room to the RSP instrumentation and controls for the following system functions:
RCIC Nuclear boiler safety and re 1 i ef valves Containment instrument gas to supply air to relief valves RHR (suppression pool cooling mode)
RHR (shutdown cooling mode)
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Emergency service water II
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Reactor pressure vessel (RPV) and containment monitoring 6.0 Ins ection Methodolo The inspection team examined the licensee's capabilities for separating and protecting equipment, cabling and associated circuits necessary to achieve and maintain hot and cold shutdown conditions.
The inspection sampled selected fire areas which the licensee had identified as being in conformance with BTP APCSB 9.5-1/Appendix R.
The following functional requirements were reviewed for achieving and maintaining hot and cold shutdown:
Reactivity control Pressure control Reactor coolant makeup Decay heat removal Support systems Process monitoring The inspection team also examined the licensee's capability to achieve and maintain hot shutdown and the capability to bring the plant to cold shutdown condition in the event of a'ire in areas where remote shutdown capability is provided.
The examination included a review of the drawings for the remote shutdown capability and review of the procedures for achieving
';he remote shutdown.
Drawings were reviewed to verify elec-trical independence from the areas of concern.
Procedures were reviewed for general content and feasibility.
Also inspected were fire detection and suppression systems and the degree of physical separation between redundant trains of Safe Shutdown Systems (SSSs).
The team review included an evaluation of the susceptibility of the SSSs for damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.
The inspection team examined the licensee's fire protection features provided to maintain one train of equipment needed for safe shutdown free of fire damage.
Included in the scope of this effort were fire area boundaries, including walls, floors and ceilings, and fire protection of openings such as fire doors, fire dampers, and penetration seals.
The inspection team also examined the emergency lighting for areas of the plant necessary for safe shutdown, the oil collection system for the reactor coolant pumps, and the licensee's fire protection/prevention progra.0 Ins ection of Protection Provided to Safe Shutdown S stems 7. 1 Protection in Various Fire Areas The team attempted to review the protection provided to SSSs in selected -fire areas for compliance with the applicable NRC require-ments and licensee commitments towards Appendix R.
The following fire zones were selected for review:
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1-IE RHR Pump Room (Unit 1)
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1-IF RHR Pump Room (Unit 1)
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2-IE RHR Pump Room (Unit 2)
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2-IF RHR Pump Room (Unit 2)
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1-ID RCIC Pump Room (Unit 1)
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2-ID RCIC Pump Room (Unit 2)
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1-IC HPCI Pump Room (Unit 1)
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2-IC HPCI Pump Room (Unit 2)
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1-lA Core Spray Pump Room (Unit 1)
1-1B Core Spray Pump Room (Unit 1)
2-1A Core Spray Pump Room (Unit 2)
2-1B Core Spray Pump Room (Unit 2)
1-2D Remote Shutdown Panel Room (Unit 1)
2-SA Fuel Pool Pumps and Heat Exchangers - Reactor Vessel Level and Pressure Panels (Unit 1)
'-4E Control Rod Drive Repair Area - Diesel Generator Coolers (Unit 1)
1-5A Fuel Pool Pumps and Heat Exchangers Reactor Vessel Level and Pressure Panels (Unit 1)
0-51 Engineered Safeguards Service Mater (ESSM)
Pump House Loop A -Pump Room (Common to Units 1 and 2)
0-25A Lower Cable Spreading Room (Unit'2)
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0-25E Lower Cable Spreading Room (Unit 1)
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0-27B Upper Cable Spreading Room (Unit 2)
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0-27C Upper Cable Spreading Room (Unit 1)
The team's attempt to verify compliance with Appendix R in the above zones were limited by the fact that the licensee'
analysis itself was not oriented to show compliance with Appendix R (see Section 7. 1. a below).
The team identified several unacceptable conditions as described below:
a.
Fire Hazard Anal sis Inade uate to show Com liance
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By letter dated March 26, 1981, the licensee made a commitment, applicable to both units, to comply with the requirements of Appendix R to 10 CFR 50 and in particular Sections III.G, J, and 0.
Appendix R, Subsection III.G.1, specifies that fire protection features shall be provided to limit the fire damage so that one train necessary for safe shutdown is available (free of fire damage for hot shutdown systems and repairable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for cold shutdown systems).
Appendix R specifies that fire barriers or automatic suppression system or both shall be installed as necessary to protect redundant safe shutdown systems.
Appendix R further specifies that a fire hazard analysis, to determine the consequences of fire on the ability for safe shutdown and to specify fire protection features for each fire area important to safety, shall be performed in accor-dance with NRC guidelines and regulations.
The fire hazard analysis is to be performed based on a fire area concept rather than fire zone concept.
NRC guidance was provided to all licensees for this purpose (Appendix R, Sections II.B, II.C.5, III.G; BTP APCSB 9.5-1 and its Appendix A; see also footnotes 3 and 4 of 10 CFR 50.48).
Further NRC guidance was provided via Generic Letter 83-33 dated October 19, 1983 (see Item 2) and Region I Workshop conducted on April 18, 1984 (see Appendix R Questions and Answers, Section 3. 1).
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After reviewing the licensee's fire hazard analysis, the team could not determine that the licensee satisfied Appendix R
because of the following reasons:
1.
The analysis is not based on a fire area concept as specified by Appendix R, but instead is based on a fire zone concept.
2.
Fire areas are bounded by rated fire barriers whereas the fire zones are subdivisions of fire areas.
Because the licensee'
fire zone boundaries are not necessarily fire rated, there is no assurance that the fire will be confined to a specific fire zone and not propagate to adjacent zones within the same fire area.
Therefore, redundant trains in adjacent fire zones could be damaged.
This invalidates the conclusions of the analysis that sufficient systems free of fire damage would be available for safe shutdown, in the event of a fire in any fire zone.
A majority of the fire zones in the plant, housing safety related components, have unrated fire barriers (see FPRR, Revision 2); examples of such fire zones are:
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Unit 1 and 2:
1/2 - 1/A, 1B, 1C, 1D, 1E, 1F, 1G, 1H, 2A, 2B, 2C, 3A, 3B, 3C, 4A, 4B, 4C, 40, 4E, 4F, 4G, 5A, SB, 5C, 5D, SE, 5F, SG, 5H, 6A, 60, 6E,,6F, 6G, 7A;
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Unit 1:
1-2D, 6I, 7B, 8A;
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Common to Units 1 and 2:
0-8A, 21A, 22A, 26B, 26C, 260, 26F, 26G, 26H, 26I, 26J, 26M, 26N, 26P, 26R, 26S, 26T, 26V, 28A, 28B, 28C, 28D, 28E, 28F, 28G, 28H, 28I, 28J, 28K, 28L, 28M, 28N, 280, 28P, 28R, 28S, 28T, 29B, 29D, 30A, 41A, 41B, 41C, 41D, 51,
Note:
A specific example of a deficiency with respect to Appendix R,Section III.G.2, which is partly due to non-rated fire barriers, is identified in Section 7. l.b of this report.
3.
Appendix R requires the assumption of an exposure fire involving in situ or transient combustibles in a given fire area and still one train of hot shutdown equipment to be free of fire damage.
However, the licensee's analysis assumes limited fire in several fire zones, involving only
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.in situ combustibles to assess the fire damage to the redundant trains, and makes conclusions on the availability of one train based on limited fire damage resulting from such a fire.
Examples of such fire zones are:
Units 1 and 2: I/2-1F, 1G, 2D, 3A, 4A, 4B, 5A, 5B;
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Common to Units 1 and 2:
0-51,
4.
The licensee's analysis to determine the need to protect a raceway (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> wrap or reroute) is based on the assump-tion that all "majority division" cables in any specific zone are damaged by a fire in that zone and on the necessity to protect the essential
"minority division" cables to satisfy the safe shutdown requirements.
Where the adjacent fire zones are of redundant majority divisions and the intervening boundary is not fire rated, the fire could spread across the boundary and damage the redundant trains simultaneously.
Examples of such fire zones are:
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Unit 1:
1-1D and 1-lE
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Unit 2:
2-10 and 2-lE 5.
The licensee's analysis, in general, is directed to show conformance with BTP APCSB 9.5-1 and is not directed to show that it satisfies Appendix R.
The licensee was unable to show that they satisfied Appendix R in various fire areas selected for the inspection.
The licensee agreed to provide additional information at a later date to demonstrate that they do satisfy Appendix R.
In the mean time the licensee instituted immediate interim compensatory measures (hourly fire watch patrol in the fire zones in the reactor building where safe shutdown systems are located)
and committed to continue such measures until the issue is resolved and/or it is determined that adequate protection exists.
This issue was referred to NRR for resolution with the licensee.
b.
Lack Pending completion of the above licensee action and its review by NRR, this item remains unresolved (50-387/85-06-01 and 50-388/85-06-01).
of Se aration/Protection in RHR Pum Rooms Appendix R,Section III.G.2, lists specific options as follows to provide adequate protection for redundant trains of safe shutdown equipment located outside of the primary containment:
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Separation by a fire barrier having a three hour rating (III.G.2.a).
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Separation by a horizontal distance of at least 20 feet with no intervening combustibles and with fire detection and automatic fire suppression installed in the fire area (III.G.2.b).
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Enclosure of one train in a fire barrier having a one hour rating in addition to having fire detection and automatic suppression installed in the fire area (III.G.2.c).
If the protection required by Section III.G.2 is not provided or the systems of concern are subject to damage from fire suppression activities,Section III.G.3 of the rule requi res that an alternate or dedicated shutdown capability be provided which is independent of the area of concern.
- Contrary to the above, as of February 15, 1985, redundant'rains of RHR pumps located in the RHR pump rooms of Units
and 2 (Fire Zones 1-1E, 1-1F, 2-1E, and 2-1F) are not provided with any of the above protective options.
Specifically, the barrier between the redundant trains (wall) is not fire rated; the separation is more than 20 feet, detection is provided, but the suppression is manual; and no alternate or dedicated shutdown capability is provided.
The licensee has agreed to provide additional information to establish the adequacy of the unrated fire barrier at a later date.
Pending receipt and review of this information by NRR, this item remains unresolved (50-387/85-06-02 and 50-388/85-06-02).
Incom lete One Hour Fire Barriers in Fire Zone 2-4A To comform with the protective option under Appendix R, Paragraph III.G.2.c (see Section 3.0 of this report),
the licensee installed automatic suppression, detection and one hour fire barrier enclosure (wrap) for the following raceways, in Fire Zone 2-4A (Unit 2 Containment Access Area).
Racewa No.
T e of Cable E1K 715 E2P J19 E2K J19 F2K 123 Division I, Control Division I, Power Division I, Control Division II, Control However, the team noted that the one hour fire barriers were incomplete (not wall to wall in the fire area).
In addition, the flashings at the interface of the raceway fire barriers and
walls were not provided in accordance with the manufacturer's installation procedures.
Therefore, the installation did not provide the required one hour separation/protection.
Pending the NRR determination regarding the applicability of Appendix R to Unit 2, this item remains unresolved (50-388/85-06-03).
d.
Lack of Automatic Su ression in E ui ment Remova]
Area and E ui ment Shaft Area The Facility Operating License for Unit 2, Paragraph 2.c.(3),
requires that the licensee shall maintain in effect and fully implement all provisions of the approved fire protection program.
The program, as contained in the licensee's Fire Protection Review Report (FPRR),
was approved in the SER and its Supplements 1 through 3 referenced by the Paragraph 2.c.(3).
The approved revision of the FPRR (Revision 2), in Figures 5. 10 and 5. 12 and Table 6-1, indicated that the Equipment Removal Area of Fire Zone 2-3B and the Equipment Shaft Area of Fire Zone 2-5A are provided with automatic suppression.
Contrary to the above, as of February 15, 1985, the lIcensee has not fu',ly implemented. the approved fire program in that the automatic suppression in the above two areas is not installed.
Pending the NRR determination regarding the applicability of Appendix R to Unit 2, this item remains unresolved (50-388/85-06"04).
7.2 Safe Shutdown Procedures 7.2.1 Procedure Review The team reviewed the following safe shutdown procedures:
E0-100-001, Reactor Scram, Revision
E0-100-004, Unit 1 Response to Loss of All Offsite Power, Revision
E0-100-009, Plant Shutdown from Outside Control Room, Revision
E0-100-030, Station Blackout, Revision
E0-100-032, HPCI System Operating Guidelines during Station Blackout, Revision
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E0-100-003, RCIC System Operation Guidelines during Station Blackout, Revision
The scope of review was to ascertain that the shutdown could be attained in a safe and orderly manner, to determine the level of difficulty involved in operating equipment, and to verify that there was no dependence on repai rs for achieving hot shutdown.
For purpose of the review, a repair would include installing electrical or pneumatic jumpers, wires or fuses to perform an action required for hot shutdown.
The team did not identify any unacceptable conditions.
7.2.2 Procedure Malk-Throu h The team walked through selected portions of the procedures to determine that shutdown could be attained in an orderly and timely fashion.
The team did not identify any unacceptable conditions.
7.3 Protection for Associated Circuits Appendix R,Section III.G, requires that protection be provided for associated circuits that could 'prevent operation or cause malopera-tion of redundant trains of systems necessary for safe shutdown.
The circuits of concern are generally associated with safe shutdown circuits in one of three ways:
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Common bus concern
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Spurious signals concern
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Common enclosure concern The associated circuits were evaluated by the team for common bus, spurious signal, and common enclosure concerns.
Power, control, and instrumentation circuits were examined on a sampling basis for potential problems.
7.3.1 Common Bus Concern The common bus concern may be found in circuits, either safety related or non-safety related, where there is a
common power source with shutdown equipment and the power source is not electrically protected from the circuit of concern.
The team examined, on a sampling basis, 4160V, 480V and 125V DC bus protective relay coordination.
The team also examined, on a sampling basis, the protection for specific instrumentation, controls, and power circuits, including
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the coordination of fuses and circuit breakers.
The licensee's plan to perform periodic relay setting is specified in the plant Technical Specifications.
No unacceptable conditions were identified.
7.3.2 S urious Si nals Concern The spurious signal concern is made up of two items:
False motor, control, and instrument indications can occur such as those encountered during 1975 Browns Ferry fire.
These could be caused by fire initiated grounds, short or open circuits.
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Spurious operation of safety related or non-safety related components can occur that would adversely affect shutdown capability (e.g.,
RHR/RCS isolation valves).
The team examined, on a sampling basis, the following areas to ascertain that no spurious signal concern exists:
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Current transformer secondaries
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High/low pressure interface
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General fire instigated spurious signals No unacceptable conditions were identified except as follows:
Lack of Anal sis for S urious Si nals Concern Caused b
0 enin of Current Transformer Secondar b
Fire The licensee's FPRR, Revision 2, did not include the above analysis, nor did they have a separate analysis.
However, for other reasons, the licensee addressed part of this concern in October 1984.
They contacted the manufacturers and others and came to the conclusion that the opening of secondary leads of current transformers, as a result of a fire, will not cause a second fire in the current trans-former itself due to high induced voltage.
The licensee believed that no further analysis beyond this is required for this concern.
However, if the secondary leads of any current transformer associated with a safe shutdown equipment open as a result of a fire, the associated protective relay could trip open its circuit breaker and make the equipment inoperabl P'
This could affect the safe shutdown.
The licensee had not analyzed this concern.
This is an unresolved item for Units 1 and 2, pending completion of the above licensee action and its review by NRC (50-387/85-06-05 and 50-388/85-06-05).
7.3.3 Common Enclosure Concern The common enclosure concern may be found when redundant circuits are routed together in a raceway or enclosure and they are not electrically protected or when fire can destroy both circuits due to inadequate fire barrier pene-trations.
A number of circuits, selected on a sampling basis, were examined for this concern.
No unacceptable conditions were identified.
7.4 General Fire Protection Features The team examined the general fire protection features in the plant provided to maintain one train of safe shutdown equipment free of fire damage.
Included in the scope of this effort were:
fire area boundaries, including walls, floors and cei lings; fire protection of openings such as fire doors, fire dampers and penetration seals; fire protection systems; and other fire protection features.
No unacceptable conditions were identified except as follows:
Failure to Produce the Duct Failure Anal si s The NRC Safety Evaluation Report documented a concern that the actual installation of an approved fire damper in a drywall assembly had not been previously fire tested or approved.
By letter dated March 26, 1981 and during a meeting held on March 25, 1981, the licensee com-mitted to analyze duct failure potential and provide, where neces-sary, duct support fire proofing and/or additional supports suffi-cient to prevent the duct dampers from being pulled out of the wall.
Based on the licensee's commitments, the staff concluded that the fire damper installation met the guidelines of Appendix A to BTP 9.5-1 and was therefore, acceptable.
(see SER Supplement 1, Section 9.5.2.2).
Contrary to the above licensee commitment, as of February 15, 1985, the licensee could not demonstrate that they conducted the duct failure analysis.
This represents a deviation from the licensee commitment applicable to Units 1 and 2 (50-387/85-06-06 and 50-388/85-06-06).
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8.0 Emer enc Li htin
10 CFR 50, Appendix R, Section III.J, requires that emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
The team examined the plant emergency lighting. system to ascertain the licensee's compliance with the above requirement.
The team did not identify any unacceptable conditions except as follows:
a.
Emer enc Li htin Batter Power Su
Not 8-Hour Rated in Fire Zone 2-2A The emergency lighting battery power supply unit installed in the stairwell to the Remote Shutdown Panel at elevation 670 feet of Unit-2 Reactor Building (Fire Zone 2-2A, Core Spray Pump Room) was manufactured by Exide and was obviously physically different from the Dual-Lite Model No.
ASY5 220 ACO units prevalent throughout the plant in other safety-related areas.
While the licensee was able to document that the Dual-Lite units were rated for 8-hours, they stated and subsequently obtained manufacturer confirmation that the Exide unit as installed at the location (with 2 bulbs in place)
was rated for 3.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />.
Pending NRR determination regarding the applicability of Appendix R
to Unit 2, this item remains unresolved (50-388/85-06-07).
b.
Emer enc Li htin Units Misaimed at Several Areas The team noted that the emergency lighting units, installed in several areas needed for operation of safe shutdown equipment in Units 1 and 2, were not properly aimed to illuminate the equipment.
Some specific examples of these areas are:
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Stairwell to the Unit 2 Remote Shutdown Panel at Elevation 720 feet
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Lower Cable Spreading Room at Panel C-301 at Elevation 714 feet The licensee indicated that all emergency lighting units will be properly aimed and adjusted as required.
This is an unresolved item for Units 1 and 2, pending completion of the above licensee action and its review by NRC (50-387/85-06-08 and 50-388/85-06-08).
9.0 Oil Collection S
stem for Reactor Coolant Pum s
CFR 50, Appendix R,Section III.O, requires that the reactor coolant pumps shall be equipped with an oil collection system if the containment is not inerted during normal operation.
As the containment in this plant
is inerted during normal operation, the above requirement does not apply to this plant.
However, SER dated April 1981, Paragraph 9.5.4.3, indicated that the recirculation pumps contain lube oil that could leak out after a seismic activity.
The NRC staff was then concerned that this oil could be ignited and create a fire inside the containment structure.
To preclude this possibility, the staff required and the licensee agreed to provide an engineered oil collection system that will meet the require-ments of Regulatory Guide 1.29, Paragraph C.2.
During this inspection, the licensee clarified that the above requirement and the commitment to provide an engineered oil collection system was based on the fact that the Susquehanna containments were not to be inerted originally.
Because the containments are now inerted, the above require-ment do not apply to this plant.
The licensee indicated that they will clarify the matter in a letter to NRR.
No unacceptable conditions were identified.
10.0 Fire Protection/Prevention Pro ram The team reviewed several documents in 'the following areas of the program to verify that the licensee had developed and implemented adequate proce-dures consistent with the Fire Hazard Analysis (FHA), Final Safety Analysis Report (FSAR),
and Technical Specifications (TS).
The documents reviewed, the scope of review, and the inspection findings for each area of the program are described in the following sections.
10. 1 Pro ram Administration and Or anization The team reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls
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Nuclear Department Instruction NDI-gA-15.3. 1, Fire Protection Program, Revision
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Administrative Procedure AD-gA-100, Station Organization and Responsibilities, Revision
The scope of review was to ascertain that:
a.
Personnel were designated for implementing the program at the site; and b.
gualifications were delineated for personnel designated to implement the program No unacceptable conditions were identifie I ~
y C
ra
10.2 Administrative Control of Combustibles The team reviewed the following licensee documents:
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Administrative Procedure AD-gA-140, Use and Storage of Combus-tible/Hazardous Materials, Revision
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Administrative Procedure AO-gA-503, Housekeeping/Cleanliness Control, Revision
The scope of review was to verify that the licensee had developed administrative controls which included:
a.
Special authorization for the use of combustible, flammable or explosive hazardous material in safety-related areas; b.
Prohibition on the storage of combustible, flammable or explosive hazardous material in safety-related areas; c.
the removal of all wastes, debris, rags, oil spills or other combustible materials resulting from the work activity or at the end of each work shift, whichever is sooner; d.
All wood used in safety-related areas to be treated with flame retardant; e.
Periodic inspection for accumulation of combustibles; f.
Transient combustibles to be restricted and controlled in safety-related areas; and g.
Housekeeping to be properly maintained in areas containing safety-related equipment and components.
No unacceptable conditions were identified except as follows:
Inade uate Administrative Control of Combustibles The team reviewed work authorization packages and administrative control of combustibles procedures to determine whether the licensee's procedures in this area are adequate.
Guidance provided in 10 CFR 50, Appendix R, Section II.K.4, states that an on-site staff member reviews proposed work activities to identify potential transient fire hazards.
The licensee relies on the job planners who review the work packages to determine the level of fire protection required for each proposed work package, rather than designate an on-site staff member to review the proposed work activities for fire protectio The team reviewed work authorization package S45145 and noted that the job planner for this work allowed combustibles to be stored unattended for up to two hours in the Diesel Bay.
Licensee Procedure AD-gA-140, Use and Storage of Combustible/Hazardous Materials, Revision 2, requires that combustibles shall not be left unattended unless stored in approved containers.
Work package S45145 did not identify the type or quantity of combustibles that may be stored in the Diesel Bay.
Another deficiency in this area is in Procedure AD-gA-140.
This procedure does not limit the amounts of combustibles that may be allowed in safety related areas in accordance with the guidance in Appendix R, section III.K.3.
The procedure specifies that combus-tibles shall be minimized.
This is inadequate since a job planner or contractor may interpret this to mean that any quantity of combus-tibles may be allowed in safety related areas as long as it is required for the job on hand.
This is an unresolved item pending review of the licensee's action in this area (50-387/85-06-09 and 50-388/85-06-09).
10.3 Administrative Control of I nition Sources The team reviewed the following licensee documents:
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Administrative Procedure AD-gA-142, Control of Ignition Sources/Cutting and Welding Permits, Revision
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Administrative Procedure AD-gA-143, Fire Watch Procedure, Revision
The scope of review was to verify that the licensee had developed administrative controls which included:
a.
Requirements for special authorization (work permit) for acti-vities involving welding, cutting, grinding, open flame or other ignition sources and that they are properly safeguarded in areas containing safety-related equipment and components; and b.
Prohibition on smoking in safety-related areas, except where
"smoking permitted" areas had been specifically designated by plant management.
No unacceptable conditions were identified.
10.4 Other Administrative Controls The team reviewed the following licensee documents:
Technical Specifications, Section 6, Administrative Controls
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Nuclear Department Instruction NDI-gA-15.3.1, Fire Protection Program, Revision
The scope of review was to verify that the licensee had developed administrative controls which require that:
a.
Work authorization, construction permit or similar arrangement is provided for review and approval of modification, construc-tion and maintenance activities which could adversely affect the safety of the facility; b.
Fire brigade organization and qualifications of brigade members are delineated; c.,
Fire reporting instructions for general plant personnel are developed; d.
Periodic audits are to be conducted on the entire fire
- protection program; and e.
Fire protection/prevention progra'o is included in the licensee's gA Program.
No unacceptable conditions were identified.
10.5 E ui ment Maintenance Ins ection and Tests The team reviewed the following randomly selected documents to determine whether the licensee had developed adequate procedures which establish maintenance, inspect,ion, and testing requirements for the plant fire protection equipment:
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Procedure SM-13-012, 6 month inspection of fire doors, Revision
Procedure SM-113-009, 18 month inspection of Fire Windows/Fire Damper s and associated hardware, Revision
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Procedure SM-13-005 Diesel Driven Fire Pump Batteries, 7 day,
day and 18 month check, Revision
In addition to reviewing the above documents, the inspector reviewed the maintenance/inspection/test records associated with the above documents to verify compliance with Technical Specifications and established procedures.
No unacceptable conditions were identified except as follows:
'I, i
~ Jg
Inade uate Testin of Fire Dam ers The team noted that fire dampers installed in fire walls are not tested according to NFPA.
The licensee, in Procedure NDI-QA-15.3. 1, Fire Protection Program, Revision 1, section 6.3, specifies that fire protection tests shall encompass the applicable NFPA require-ments and in section 6.4 of the same procedure, specifies that plant equipment shall be tested on regularly scheduled basis.
NFPA 90A requires that fire dampers shall be'functionally tested every
months.
The licensee has a procedure to visually inspect the fire dampers installed in walls protecting safety related equipment, but no pro-cedure exists to test fire dampers installed in walls the licensee committed in the FPRR to maintain as fire walls.
An example would be the lube oil reservoir rooms in Units 1 and 2 (Fire Zones 1-33D and 2-33D).
The FPRR indicates that, because the lube oil reservoir rooms contain significant quantities of lubricating oil, the rooms are enclosed with three hour rated walls.
Fire walls are accepted if the components of construction such as wall materials, penetration seals and fire damper s etc.
are approved by a recognized laboratory, and maintained in accordance with industry standards, in this case, the standards of NFPA.
The failure to ;est the fire dampers in accordance with NFPA is not in conformance with the licensee proce-dure NDI-QA-15.3.1.
The Facility Operating Licenses for Units 1 and 2, dated September 28, 1983 and March 23, 1984 require that the licensee shall fully implement and maintain all provisions of the approved fire protection program contained in the licensee's FPRR, Revision 2 (see Section 3.0 of this Inspection Report).
The provisions include the fire dampers installed in all fire barriers.
Contrary to the above, as of February 15, 1985, the licensee did not maintain certain provisions of the FPRR in that the fire dampers installed in the fire barriers of non-safety related areas in Units
and 2 (for example, Lube Oil Reservoir Rooms)
were not functionally tested to ensure that they will close in the event of a fire.
Even though those fire dampers are located in non-safety related areas, the adjacent safety related areas could be affected, if the dampers do not close in the event of a fire.
This is a violation of the Facility Operating Licenses applicable to Units 1 and 2 (50-387/85-06-10 and 50-388/85-06-10).
Fire Protection Pro ram A Audits The team verified that, the licensee has a program to conduct QA audits of the Fire Protection Program in accordance with the Technical Specification, Sections 6.5.2.8.h, i and >
The team also reviewed the reports of the following audits, performed by the licensee to ascertain that the audit findings were resolved in a timely and acceptable manner:
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Annual Audit 0-84-15, performed on June 18, 1984 to September 14, 1984
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Biennial Audit 0-83-08, performed on May 23, 1983 to June 9,
1983
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Triennial Audit of Unit 1, performed on May 12-20, 1983, by Factory Mutual Research.
No unacceptable conditions were identified.
0.7 ~Fi i T
The team examined fire protection water systems, including fire pumps, fire water piping and distribution systems, post indicator valves, hydrants and contents of hose houses.
The team toured accessible vital and nonvital plant areas and examined fire detection and alarm systems, automatic and manual fixed suppression systems, interior hose stations, fi're barrier penetration seals, and fire door=-.
The team observed general plant housekeeping conditions and randomly checked tags of portable extinguishers for evidence of periodic inspections.
No deterioration of equipment was noted.
The inspection tags attached to extinguisher s indicated that monthly inspections were performed.
No unacceptable conditions were identified except as follows:
Non-Functional Fire Doors The team observed that several fire doors, installed in fire barrier walls of Unit, 1, were non-functional.
Examples of non-functional doors are Door No.
211 in Reactor Building Elevation 683 feet, Door No.
109 in core spray pump room elevation 670 feet, and the door to the North Load center room.
The doors are considered non-func-tional, because they were either held open or would not lock shut due to a broken latch or inadequate closer.
The team also observed doors to protected stairwells that were held open by a fusible link.
The Fire Protection Program of Susquehanna was reviewed per the requirement of Appendix A to BTP APCB 9.5-1.
One of these requirements is that stairwells should be designed to minimize smoke infiltration during a fire.
Stairwells should serve as escape and access routes for fire fighting.
By installing the fusible link on the fire doors and holding the doors in the open position, the licensee is defeating the purpose of the doors to minimize smoke infiltration in the stairwells.
Further, by keeping a
l
number of fire doors open, in the event of a fire, smoke may infiltrate different smoke detection zones and provide the operators with false or confusing information on the fire detection panel.
This may result in a delayed dispatch of the fire brigade to where the fire is actually located.
The Facility Operating License for Unit 1, dated September 28, 1983 requires that the licensee shall maintain all provisions of the approved fire protection program contained in the licensee's FPRR, Revision 2 (see Section 3.0 of this Inspection Report).
The provisions include the fire doors installed in all fire barrier walls.
Contrary to the above, as of February 15, 1985, the licensee did not maintain certain provisions of the FPRR in that several fire door installed in fire barrier walls of Unit 1 were non-functional as discussed before.
This is a violation of the Facility Operating License for Unit
(50-387/85-06-11).
During the course of the inspection, the team reviewed several drawings, fire hazard analysis, fire protectio'n modification packages, procedures, and other fire protection documents.
The scope of review included veri-fication of their technical adequacy, appropriate reviews, design and procurement controls, and other guality Assurance requirements for the licensee's fire protection program.
Except as noted in the previous sections of this report, the team did not identify any other unacceptable conditions.
12.0 Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable, violations, or deviations.
Unresolved items are discussed in Sections 7. 1.a, 7. l.b, 7. 1.c, 7. l.d, 7.3.2, 8.a, 8.b, and 10.2.
13.0 Conclusions The findings of this inspection are summarized in Attachment 3 to this report.
Two items are violation of the Facility Operating License(s).
One item is a deviation from a licensee commitment.
Eight items remained unresolved at the end of the inspection.
To alleviate the potential safety significance of these items, the licensee instituted appropriate interim compensatory measures (see Section 7.1.a).
14.0 Exit Interview The inspection team met with the licensee representatives, denoted in Section 1.0, at the conclusion of the inspection on February 15, 1985.
The team leader summarized the scope and findings of the inspection at that time.
The team leader also confirmed with the licensee that the documents reviewed by the team did not contain any proprietary information.
The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).
At no time during this inspection was written material provided to the licensee by the tea ATTACHMENT 1 LIST OF CORRESPONDENCE Date March 26, 1981 Title Licensee to NRC Letter:
and other items Licensee commitment to Appendix R
October 26, 1981 Licensee to NRC Letter:
26, 1981 letter February 9, 1982 Licensee to NRC Letter:
Variance Supplemental information to March Fire Protection Request for June 9,
1982 Licensee to NRC Letter:
Fire Protection SER Item. 52 August 31, 1982 Licensee to NRC Letter:
October 25, 1982 Licensee to NRC Letter:
License Condition 7, Unit
License Condition C(7), Unit
March 11, 1983 Licensee to NRC Letter:
Proposed Amendment 21 to Licensee NPF-14, Unit 1 (Technical Specifications)
December 13, 1983 Licensee to NRC Letter:
Variance Fire Protection Request for December 23, 1985 Licensee to
<<IRC Letter:
Report, Revision
Submits Fire Protection Review
~~g j
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ATTACHMENT 2 FSAR TABLE 40.95-1 S stems Re uired For Shutdown GROUP I - Systems Required for Hot 5 Cold Shutdown Control Rod Drive Manual Scram Circuits only Main Steam Isolation Valves (manual closure functions only)
Suppression Pool Temperature Monitoring Reactor Pressure Vessel Instrumentation GROUP II Systems Required for Hot Shutdown Division I RCIC or RHR (LPCI) or Core Spray ADS ESW ESSW Pumphouse HVAC Diesel Generators and Auxiliaries Diesel Generator HVAC Containment Instrument Gas Division II HPCI or RHR (LCPI) or C.S.
plus all Division II of these systems under Group II, Division I except RCIC.
GROUP III - Systems Required for Cold Shutdown Division I RHR (Suppression Pool Cooling Mode 5 Shutdown Cooling Mode~)
RHRSW ESW ESSW Pumphouse HVAC Diesel Generator s and Auxiliaries Diesel Generator HVAC Division II All Division II of above
"For a fire affecting RHR valve HV-1F009 or its power supply, the use of RHR/ADS/CS in the Alternate Shutdown Mode will be require Item No.
(Unit 1&2)
ATTACHMENT 3 SUMMARY OF INSPECTION FINDINGS Descri tion For Details Refer to Section 1.
Violations of Facilit 0 eratin License s
50-387/85-06-10 Inadequate Testing of Fire 50-388/85-06-10 Dampers 50-387/85-06-11 Non-Functional Fire Doors 2.
Deviations from Licensee Commitments 10.5 10.7 50-387/85-06-06 50-388/85-06-06 3.
Unresolved Items 50-387/85-06-01 50-388/85-06-01 50-387/85-06-05 50-388/85-06-05 50-388/85-06-07 50-387/85-06-08 50-388/85-06-08 50-387/85-06-09 50-388/85-06-09 50-387/85-06-02 50-388/85-06"02 50-388/85-06-03 50-388/85-06-04 Failure to Produce the Duct.
Failure Analysi s Fire Hazard Analysis - Inadequate to Show Appendix R is satisfied Lack of Analysis for Spurious Signals Concern Caused by Opening of Current Transformer Secondary by Fire Emergency Lighting Battery Power Supply Not 8 Hour Rated in Fire Zone 2-2A Emergency Lighting Units Misaimed At Several Areas Inadequate Administrative Control of Combustibles Lack of Separation/Protection in RHR Pump rooms Incomplete One Hour Fire Barriers in Fire zone 2-4A Lack of Automatic Suppression in Equipment Removal Area and Equipment Shaft Area 7.1.a 7.3.2 8.a 8.b 10. 2 7.l.b 7.1.c 7.