IR 05000400/1985040

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Insp Rept 50-400/85-40 on 851118-22.No Violations or Deviations Noted.Major Areas Inspected:Fire Protection/ Prevention
ML18019A498
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 12/12/1985
From: Conlon T, Miller W, Wiseman G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18019A497 List:
References
50-400-85-40, NUDOCS 8512270339
Download: ML18019A498 (24)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323 Report No.:

50-400/85-40 Licensee:

Carolina Power and Light Company P.

0.

Box 1551 Raleigh, NC 27602 Docket No.:

50-400 Facility Name:

Harris Inspection Conduct In spec W.

H.

G..

Wis~em Approved mber 18-22, 1985 Fore:

License No.:

CPPR-158

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Date Signed

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E. Conlon, Section Chief Plant Systems Section Division of Reactor Safety Date Signed SUMMARY

.1 Scope:

This routine, announced inspection entailed 72 inspector-hours on site in the area of fire protection/prevention.

Results:

No violations or deviations were identified.

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REPORT DETAILS Persons Contacted Licensee Employees

  • N. J. Cheiangi, Manager, QA/QC Harris Project
  • S. Hardy, Harris Project Engineering Support

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S. Hinnant, Manager, Startup

  • J.

L. Harness, Assistant Plant General Manager

  • P.

W. Howard, Regulatory Compliance

  • L. Loflin, Manager, Harris Project Engineering Support
  • D. C. McCarthy, Principle Engineer
  • C. L. McKenzie, Acting Director, QA/QC Operations

"M. R. Oates, Nuclear Licensing J. Pierce, Harris Project Engineering Support - HVAC

  • J.

F. Pinto, Harris Project Engineering Support Fire Production

  • H. Smith, Harris Project Operation Support, Supervisor

"F. Strehle, Project QA Engineer Operations

'M. Stokes, Harris Project Operation Support - Fire Protection

  • M. F. Thompson, Jr.,

Manager Harris Plant Engineering Management

  • E. J.

Wagner, General Manager

  • J.. L. Willis, Plant General Manager
  • C.

R. Williams, Harris Project Construction Support

  • S.

R.

Zimmerman, Manager, Nuclear Licensing Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, and mechanics'ther Organizations

  • M. A. Serbanescu, EBASCO - Fire Protection
  • R. A. Somers, Daniels, CI Superintendent NRC Resident Inspectors
  • G. Maxwell
  • S. Burris Attended exit interview Exit Interview The inspection scope and findings were summarized on November 22, 1985, with those persons indicated in paragraph 1 above.

The inspector described the areas inspected and discussed in detail the inspection findings.

No dissenting comments were received from the license ~ ~

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Inspector Fol 1owup Item (400/85-40-01),

Fire Protection Systems, Features and Administrative Procedures Are Required to be Operational Prior to Fuel Load paragraph 5.

Inspector Followup Item (400/85-40-02),

Revisions Required to Fire Protection/Prevention Procedures In Order to Meet NRC Guidelines-paragraph 5.a.

Inspector Followup Item (400/85-40-03),

Incomplete Operation Survei 1-lance Test Procedures for Fire Protection Features paragraph 5.b.

Inspector Followup Item (400/85-40-04),

Operation Surveillance Test Procedures are Not Developed and Issued for Permanent Plant Fire Protection Features paragraph S.b.

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Inspector Followup Item (400/85-40-05),

Additional Personnel Required To be Provided with Fire Brigade Training Prior to Fuel Load-paragraph 5.d.(2).

Inspector Followup Item (400/85-40-06),

Fire Brigade Equipment and Storage Lockers are Required to Be Provided Prior to Fuel Load paragraph 5.d.(3).

Inspector Fol 1 owup Item (400/85-40-07),

Engineering Analysi s Testing and Justification for Non-Standard Penetration Seal Configurations-paragraph S.e.(1)

Inspector Followup Item (400/85-40-08),

Revisions Required to Fire Door Inspection Procedures to Meet NFPA Standards paragraph 5.e.(2).

Inspector Followup Item (400/85-40-09),

Piping to Automatic Sprinkler System and Interior Fire Hose System for Diesel Generator Building Fire Suppression Systems is Not Designed to Meet Single Failure Criteria As Required by FSAR paragraph 5.e.(5).

Inspector Followup Item (400/85-40-10),

Verification That Pre-Action Fire Suppression Valve Installations Conform to the Manufacturers Requirements - paragraph 5.e.(5).

Inspector Followup Item (400/85-40-11),

Reevaluation of Sprinkler System Obstructions - paragraph 5.e.(5).

Inspector Followup Item (400/85-40-12),

Two Fire Pumps are Not Provided for Supply to SSE Interior Fire Hose System - par agraph 5.e.(6).

Inspector Followup Item (400/85-40-13),

Reactor Coolant Pump Oil Collection System is Not Designed to Maintain Structural or Pressure Integrity Following a

SSE and Mas Not Constructed Under a

QA/QC Program - paragraph If

n.

Inspector Followup Item (400/85-40-14),

Procedure Required to Drain or Verify Reactor Coolant Pump Oil Collection System Drain Tanks are Empty Prior to Startup paragraph 5.f.

o.

Inspector Followup Item (400/85-40-15),

Review of Completed Fire Detection System Inspections and Pre-operational Tests paragraph S.e.(4).

The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.

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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

4.

Unresolved Items

.

Unresolved items were not identified during the inspection.

Fire Protection/Prevention Program (64704)

The inspectors reviewed the permanent plant fire protection program and features.

The licensee's letter to the NRC of October 14, 1983, and the fire protection sections of the FSAR and NRC's Safety Evaluation Reports (NUREG 1033) of November 1983 and June 1985 were used in this inspection to determine the fire protection commitments and requirements.

At the time of this inspection, the approximate construction status of the fire protection systems and features were as follow:

automatic sprinkler systems 60%

installed and 0% functionally tested; interior fire hose system 99% of piping installed with no hydrostatic tests performed and no hose and equipment installed on the system within the main power block; fire detector system installations for power block 40%, diesel generator building 98%,

fuel oil tank building 100%,

and intake structure 0% complete; penetration seals for power block 15%

and 100% for other buildings; fire doors 95%

installed, but none inspected; fire dampers 35% installed.

SER of November 1983, Section 9.5. 1 (page 9-46) states that the NRC staff will require the fire protection program to be operational before initial fuel load.

This will be verified by Region II and is identified as Inspector Followup Item (400/85-40-01),

Fire Protection Systems, Features and Administrative Procedures are Required to Be Operational Prior to Fuel Load.

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Fire Prevention Administrative Control Procedures The inspectors reviewed the following fire prevention/protection administrative procedures:

FPP-001, FPP-002, FPP-004, FPP-006, Fire Protection Conduct of Operations (Revision 2)

Fire Emergency (Revision 3)

Control of Transient Combustibles (Revision 0)

Control of Ignition Sources - Hot Work Permit (Revision 0)

FPP-007, Fl ammab1 e Liqui d s (Rev i s i on 1)

FPP-008, Fuel Gases and Oxygen (Revision 1)

FPP-010, Fire Protection Housekeeping (Revision 0)

TI-105, Fire Protection Training (Revision 0)

TI-906, Training Records (Revision 2)

CP8 L QA Manual - Section

FPP-012, Pre Fire Plans (Revision 0)

Pre Fire Plan Zone 1-A-3-PB B-236'levation Pre Fire Plan Zone 1-C-1-BAL 236'levation Pre Fire Plan - Control Room 236'levation PLP-601, Plant Program for Plant Modification MOD-100, Plant Modification Control (Revision 0)

MOD-200, Plant Change Request Implementation (Revision 0)

Based on this review, it appears that the above procedures meet the NRC guidelines of 10 CFR 50 Appendix R - Fire Protection for Nuclear Power Facilities, Sections III.I and III.K, NUREG-0800, Section 9.5. 1

"Standard Review Plan Fire Protection Program,"

and the licensee's commitments in the letter to NRC dated October 14, 1983, except for the following discrepancies:

(1)

Procedures have not been prepared covering the restrictions on smoking within safety-related areas'2)

Procedure TI 105, Section 3.23, requires fire brigade drills to be conducted quarterly in lieu of a maximum of 92 days between drills as indicated by the NRC guidelines.

(3)

Procedure TI 105, Section 3.2.5.5, stipulates that fire brigade response to fires can be counted as fire brigade drills where as the NRC guidelines indicate that routine drills are required every 92 days for each brigade team.

The licensee is to revise the procedures to correct these concerns.

This is identified as Inspector Followup Item (400/85-40-02),

Revisions Required to Fire Protection/Prevention Procedures in Order to Meet NRC Guidelines, and will be reviewed during a subsequent NRC inspection.

The licensee has not yet implemented the above procedures.

FSAR Section 17.2 requires these procedures to be implemented 90 days prior to fuel load.

Fuel load is presently scheduled for March 1986.

Fire Protection Surveillance Procedures The inspector reviewed the following fire protection system operation surveillance procedures:

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Procedure No.

Titl e OST-3001 OST-3002 OST-3003 OST-3004 OST-3006 OST-3008 OST-3101 OST-3120 OST-3212 OST-3380 Main Fire Pump Operability Test Fire Main Valve Position Verification Fire Suppression Valve Cycle Test Main Fire Pump Flow Test (Annual)

Fire Main Flow Test (Three-Year)

Fire Hydrant Inspection (Annual)

Hose Rack Inspection (Auxiliary Building)

Fire Hose Valve Operability Test (Auxiliary Building)

Fire Detection Functional Test Local Fire Detection Panel

Functional Test Fire Suppression Containment The above surveillance procedures'were reviewed to determine if the various test outlines and inspection instructions adequately implement the surveillance requirements of the plant'

proposed fire protection Technical Specifications.

In addition, these procedures were reviewed to determine if the inspection and test instructions followed general industry fire protection practices, NRC fire protection program guidelines and the guidelines of the National Fire Protection Association (NFPA) fire codes.

Based on this review, it appears that the above procedures are adequate with respect to implementing the proposed Technical Specification requirements and follows fire protection industry inspection and testing practices which meets the intent of the inspection and test guidance recommended by the NFPA Fire Codes, except that the test procedures for the fire protection valves, hose racks, and hose station fire hose valves were incomplete in that the data sheets did not list the specific equipment to be tested.

Additionally, the fire main system flow test did not include steps for valve alignment to develop adequate flow paths or the required specific instrumentation to accomplish the test.

These are identified as examples of Inspection Followup Item (400/85-40-03),

Incomplete Operation Surveillance Test Procedures for Fire Protection Features.

In addition, the inspectors noted that surveillance test procedures were not developed or issued for:

fire doors, fire dampers, fire barriers, penetration seals, fire detection system, and fire hose stations and fire hose.

This is identified as Inspector Followup Item (400/85-40-04),

Operation Surveillance Test Procedures are not Developed and Issued for Permanent Plant Fire Protection Features.

Fire Protection Audits The most recent audit report of the Harris Fire Protection QA Program was reviewed.

This was CP&L QA audit of September 16, 1985 (Audit Report No. QAA/XX81-85-04).

This audit identified several findings and concerns related to the fire protection program.

The licensee appeared to be taking action on most of the audit items; however, during the

.inspectors'lant tour several instances of the QA audit concerns

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related to housekeeping and control of combustibles in areas designated for turnover to the plant operations and startup organization appeared to still exist in the Diesel Generator Building.

These specific items were identified to the site Fire Protection Staff.

The licensee is to review this item and take appropriate action.

d.

Fire Brigade Organization The fire brigade is to be composed of approximately 65 personnel from the operation's staff.

The brigade leader for each shift is to be the senior control room operator and the remaining members are to be two shift auxiliary operators and two shift rad-waste operators.

This staffing will apparently meet the NRC require-ments.

(2)

(3)

Training A total of 30 personnel or approximately 50% of the proposed fire brigade members have received the required fire brigade training.

A sufficient number of brigade members must be trained prior to fuel load to meet the required staffing level of at least five brigade members per shift.

This training program will be reviewed during a subsequent NRC inspection and is identified as Inspector Followup Item (400/85-40-05),

Additional Personnel Required to be Provided With Fire Brigade Training Prior to Fuel Load.

Fire Brigade Equipment The required fire brigade equipment and equipment storage lockers have not yet been installed.

These must be provided prior to fuel load.

This is identified as Inspector Followup Item (400/85-40-05), Fire Brigade Equipment and Storage Lockers are Required to Be Provided Prior to Fuel Load, and will be reviewed during a

subsequent NRC inspection.

Permanent Plant Fire Protection Systems Fire Barrier Penetration Seals The inspectors reviewed the following fire barrier penetration seals:

Penetration No.

Location Date of Final Construction

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P-3947 Fire Zone D1DGB-ASU MS-5 Diesel Generator Building (DGB)

07-01-85 P-3615 MS-5 06-27-85

Penetration No.

P-3616 P-3617 P-3680 Location Fire Zone lDDTB (DG B)

~Te MS-5 MS"5 MS-5 Date of Final Construction A/

C Ins ection 06-28-85 07-01-85 07-08-85 P-3681 P-3953 MS-5 MS-2 07-09-85 09-06-85 E-2190 DGB MC-1 07-03-85 E-2189 DGB MC-2 07-08-85 (2)

These penetration seals were reviewed and appeared to conform to the design requirements, except that penetration P-3953 appeared to be installed in a configuration that was not tested and approved under the licensee's Final Fire Test Report Fire Qualifications Test on Silicone Foam Floor Penetration Seals, dated July 25, 1980.

This is identified as Inspector Followup Item (400/85-40-07),

Engineering Analysis, Testing and Justification for Non-Standard Penetration Seal Configurations.

Installation of penetration seals for safe shutdown plant areas has not been completed.

This is considered part of Inspector Followup Item (50-400/

85-40-01).

The inspectors observed a penetration seal foam operation and the licensees'QA/

QC pre-installation inspection for electrical penetration No.

E-2108 on Elevation 261, Column C and 21, within Fire Area 1-A-BAL of the Reactor Auxiliary Building.

The pre-installation foam sample indicated that the foam material was within acceptable density, and the cell structure and color were within limits set by the manufacturer.

Review of the final QA/QC inspection documentation for this penetration firestop will be reviewed during a future NRC inspection.

Fire Doors Fire doors Nos.

835, 843, 910 and 911 were reviewed during the inspectors'alkthrough of the Diesel Generator Building and Diesel Fuel Oil Storage Tank Building.

The installation of these doors was practically complete except that final door adjustments and the QA/QC inspections had not been completed.

This is another example of IFI (400/85-40-01)

and will be reviewed during a

subsequent NRC inspection.

The inspectors reviewed the licensee's work procedure MP-54, Revision 1,

dated October 25, 1985, for the Field Installa-tion of Permanent Plant Doors and Technical Procedure TP-70,

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Revision 0, dated June 25, 1985, for the Inspection of Permanent Plant Fire, Control, and Special Doors.

These procedures appeared satisfactory except, that they did not address acceptance criteria for fire door features such as (1) door latch engagement, (2) free swing, (3) automatic closures, or (4) the installation of astragals on double leaf fire doors as outlined in the National Fire Protection Association (NFPA) Standard No. 80, Standard for Fire Doors and Mindows.

The licensee stated that these items would be reviewed and the procedures revised accordingly.

This will be reviewed during a

subsequent NRC inspection and is identified as Inspector Followup Item (400/85-40-08),

Revisions Required to Fire Door Inspection Procedures to Neet NFPA Standards.

(3)

Fire Dampers An inspection was made of the fire damper installations.

The damper installations had received a

QA/QC configuration inspection, visual weld inspection and cycle tests to verify that the dampers were installed in accordance with the construction documents and were functional.

The following dampers were inspected and QA/QC type records which verify that the installation conform to the construction documents were reviewed and found to be satisfactory:

~Dam er No.

Size Location CZ-FDAH5-1 CZ-FDAM6-1 CZ-FDAS11-1 CZ-FDAS14-1 FP-FDAS1-1 FP-FDAS2" 1 24" x 72" 20" x 72" 26" x 36" 24" x 36II 12" x 36" 12" x 36" Control Room Control Room Process Instrument Room Process Instrument Room Fuel Storage Tank Bldg.

Fuel Storage Tank Bldg.

As noted above, only approximately 35% of the total number of required fire dampers have been installed.

The remaining dampers should be installed and functional prior to fuel load.

This will be verified during subsequent NRC inspec-tions and is an example of above Inspector Followup Item (400/85-40-01).

The Harris site fire dampers are unique in that these dampers have been designed and installed to function following either a fire or seismic event and to operate under the airflow normally associated with the applicable ventilation system.

The following test documents are available on site to demonstrate that the dampers will meet these design require-ments:

Fire Test:

Conducted by Underwriters Laboratories, Inc., File No.

R4708, on December 5,

1984 Air Flow Test:

Conducted by American Warming and Venting, Inc.,

Document No.

AWV S.O.

67269-701, on July 18, 1985 Seismic gualification Test:

Conducted by International Consulting Engineers, Inc.

at Farwell and Hendricks, Inc.

Test Facility on December 20, 1984 (EBASCO Specification No.

CAR-SH-BE-04A)

Fire Detection System The inspectors reviewed the following inspection and test data for the cable installation to the fire detection system in the Diesel Generator Building:

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~/0 19602A-I25 06/08/85 06/18/85 06/18/85 19602B-I25 05/07/85 05/15/85 06/18/85 The inspectors conducted a

walkdown of these cables and verified that the detection system wiring was installed in accordance with the cable termination cards and report data.

During the detection system walkdown in the Diesel Generator Building it was noted that some ceiling bays within the diesel generator rooms were not provided with detectors as required by the industry detection standards NFPA 72 D and E.

The licensee stated that this discrepancy had been previously identified by the site design organization and that corrective action will be taken as identified in Field Change Request FCR-I-2791 '

review of this modification will be performed during a future NRC inspection.

The licensee stated that the Preoperational Test Procedure for the fire detection system had been prepared in "draft" form and was presently being reviewed by the plant staff.

As presently written, this procedure does not include calibration of the ionization detector's sensitivity.

The licensee stated that a sensitivity check for these detector s will be included in the preoperational test program.

Review of this item will be performed during a future NRC inspection and is identified as. Inspector Followup Item (400/85-40-15),

Review of Completed Fire Detection System Inspections and Preoperational Test k )

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Automatic Sprinkler Systems A review was made of the following automatic sprinkler systems:

Location Isometric Dw

.

No.

Diesel Diesel Diesel Diesel Diesel Generator Building Generator Building 1-FP-416 1-FP-421 Generator Building 1-FP-425 Generator Building 1-FP-428 Generator Building 1-FP-432 Diesel Fuel Oil Storage Building Fuel Storage Tank Building Fuel Storage Tank Building 1"FP-433 1-FP-434 1-FP-435 The above systems had received a

QA/QC visual weld inspection and piping configuration inspection to verify that the systems were installed in accordance with the construction documents.

During the walkdown inspection of these systems the inspector noted that the piping installation appeared to conform to the design drawings, except the systems had been modified by a field change to supply additional fire hose stations within the diesel generator building.

This change resulted in the new hose stations being supplied from the same piping system as the automatic sprinkler systems and without sufficient control valves to sectionalize either the sprinkler system or hose station in the event of a line rupture in either system.

This is a failure to meet the single fai lure design specifications of the FSAR and the licensee's letter of October 14, 1983, Enclosure Sections C. 1.C(1)

and (2)

and C.6.c, but is not an enforcement item since the plant is not yet operational.

This is identified as Inspector Followup Item (400/85-40-09),

Piping to Automatic Sprinkler System and Interior Fire Hose System for Diesel Generator Fire Suppression Systems is Not Designed to Meet Single Failure Criteria as Required By FSAR, and licensee's corrective action will be reviewed during a

subsequent NRC inspection.

The sprinkler systems for the diesel generator and fuel oil tank storage buildings are designed as pre-action type systems but are presently being maintained as wet pipe systems pending completion of the fire detection system installation and system pre-operational functional tests.

This results in the pre-action valve installations being slightly modified to allow the system to function as a wet pipe system.

These valves will be reviewed during a

subsequent NRC inspection to verify conformance to the manufactures design and installation requirements.

This is

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identified as Inspector Followup Item (400/85-40-10)

Verification That Pre-Action Fire Suppression Valve Installations Conform to the Manufactures Requirements.

A plant tour was made of the reactor and auxiliary buildings to review the installation of the automatic sprinkler systems being installed in these buildings.

It appears that the sprinkler system coverage in several areas will be deficient due to obstructions from ducts, cable trays, pipe, conduit, structural components, etc.

which are located beneath the installed ceiling level sprinklers.

The licensee has developed Procedure WI-141, As-Constructed Pipe, and Drawing No.

SD/C-A1023, Interference Guidelines for Sprinkler Installation, for use in evaluation of the obstructions to the systems.

These inspection documents have not yet been used for inspection of the reactor and auxiliary building sprinkler systems since the installation of these systems is incomplete.

The sprinkler obstructions throughout the plant will be reviewed during a subsequent NRC inspection.

This is identified as Inspector Followup Item (400/85-40-11),

Re-evaluation of Sprinkler System Obstructions.

The inspector reviewed the following hydrostatic test data for the following systems:

Location Date of Test Diesel Generator Building Fuel Tank Storage Building 10-16-85 11-02-85 These tests appeared to meet the 200 psi for two hour test requirements of NFPA-13, Sprinkler Systems, and are satisfactory.

The sprinkler systems are required by the SER to be operational prior to fuel load.

This is another example of Inspector Followup Item (400/85-40-01).

Interior Fire Hose System Practically all of the piping for the hose station systems has been installed, but only a small portion of the piping has been hydrostatically tested.

The inspectors reviewed the following gA/gC inspection data, inspected the piping installations and noted that the portions inspected appeared to conform to the construction documents:

Location Line No.

Isometric Dw

.

No Auxiliary Bldg

286'uxiliary Bldg -

236'uxiliary Bldg 236'

261'uxiliary Bldg -

236'uxiliary Bldg -

236'FP2 z 200

8FP4-134-1 8FPZ~-208-1 8FP4-135-1 8FP8-132-1 FP-122 FP-115

& 119 FP-115 FP-114 FP-99, 100, 101

& 110 The hydrostatic tests for the above piping had not yet been conducted.

Also, the fire hose for each hose station had not yet been installed.

These items must be completed prior to fuel load and are another example of Inspector Followup Item (400/85-40-01).

The FSAR and licensee's October 14, 1983 letter to the NRC, Enclosure Section C.6.C.(4),

contained a

commitment to provide an interior fire hose system within all areas containing safe shutdown equipment, except for diesel generator and diesel fue'1 oil buildings.

This hose system would be functional following a

Safe Shutdown Earthquake (SSE)

and was to be supplied from two boaster fire pumps taking suction from the emergency service water system.

However, following the cancellation of Harris Unit 2, one of these pumps was deleted from the project and an additional pump supply was not provided.

It appears that two pumps may be required to meet the licensee's commitments'his item is being evaluated by the licensee and is identified as Inspector Followup Item (400/85-40-12)

Two Fire Pumps are Not Provided for Supply to SSE Interior Fire Hose System.

The licensee's evaluation and corrective action will be reviewed during a subsequent NRC inspection.

f.

Reactor Coolant Pump Oil Collection System An oil collection system has been provided for the lubricating system for each reactor coolant pump motor to meet the provisions of NUREG 0800, Standard Review Plan, Section 9.5. 1, Fire Protection Program.

The collection system for the lubrication system to each reactor coolant pump motor is arranged to catch any leakage from the following sources:

oil level assembly; upper bearing return conduit box enclosure; oil level alarm; oil cooler enclosure; oil drain enclosure assembly; and bottom drip pan.

The collection system for each pump motor is arranged to drain into an independent drain tank of approxi-mately 290 gallons.

This is of sufficient capacity to hold the entire lubrication system capacity of approximately 265 gallons from each pump.

Each tank vent is equipped with a flame arrestor.

The tank and drain piping systems are seismically supported, but were apparently not designed or constructed to maintain their structural or pressure

integrity following a

Safe Shutdown Earthquake (SSE).

However, the licensee stated that the system was analyzed and determined to be designed such that there was reasonable assurance that the collection system will withstand the safe shutdown earthquake.

Furthermore, the licensee states that the lubrication system for the pump motor is seismically qualified to function following a SSE.

Since the collection system was not seismically designed and not included in the Fire Protection Quality Assurance Program, PSAR Table 1.8-3, there was no QA/QC inspections performed on the collection system other than those for the seismic hangers.

The inspector reviewed the design and construction documents including FCR M-1212 and performed a walkdown inspection of the collection systems.

The systems appeared to meet the construction documents and NRC requirements, except the draining piping system is not designed or constructed to maintain structural or pressure integrity following a

SSE.

The licensee is to review this problem.

This is identified as Inspector Followup Item (400/85-40-13),

Reactor Coolant Pump Oil Collection System is Not Designed to Maintain Structural or Pressure Integrity Following a

SSE and Was Not Constructed Under a

QA/QC Program.

The licensee's review and corrective actions will be reviewed during a

subsequent NRC inspection.

Presently, there are apparently no procedures which require the oil collection tanks to be drained or verified empty prior to unit startup following an outage.

The licensee is to include this requirement in one of the existing operating procedures.

This will be verified during a

subsequent NRC inspection and is identified as Inspector Followup Item (400/85-40-14),

Procedure Required to Drain or Verify Reactor Coolant Pump Oil Collection System Drain Tanks are Empty Prior to Startup

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Hydrogen Piping System A review was made of the hydrogen gas piping system to the volume control tank within the Reactor Auxiliary Building (RAB).

The hydrogen supply to the CVCS tank is from a storage tank located outside the RAB.

The piping is routed through the turbine building to the RAB.

The piping through the RAB is provided an excess flow check valve, Dragon Model 15682-15SW.

The hydrogen gas piping to the volume control tank inside the tank room is designed and installed to seismic loading requirements.

The following hanger supports were reviewed to verify that this portion of the system was seismically supported in accordance with the construction drawings:

Han er No.

Date of Seismic Calculation A

royal 1-CS-H-4286 1-CS-H-4288 06/20/85 12/14/84

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1-CS-H-4310 1"HY-H-11 1-HY-H-12 08/15/85 06/18/85 06/18/85 Based upon the above review, the hydrogen piping within these safety-related plant areas appears to meet the general design requirements and the licensee's commitments.

Inspector Followup Items (IFI)

The licensee's action on the following IFI was reviewed:

(Open)

IFI (400/84-40-01)

Review of Fire Protection QA/QC Program to Address Accessibility/Operability and Design Requirements of NFPA Codes.

The licensee has developed',

an inspection procedure to verify that the hose station system will be operable.

However, thi s QA/QC inspection program has not yet been implemented.

The inspectors noted a number of interior fire hose stations throughout the plant which were obstructed by hangers and other structural supports.

This item remains ope C.

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