IR 05000412/1987017

Insp Rept 50-412/87-17 on 870309-13.No Violations Noted. Major Areas Inspected:Capability to Shut Down Plant in DBE & Insp of Emergency Lighting Sys.Unresolved Item Re Fire Wrap Cable Tray Supports Noted

ML20209C905
Person / Time
Site:	Beaver Valley
Issue date:	04/13/1987
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20209C877	List: IR 05000412/1987017 ML20209C871
References
50-412-87-17, NUDOCS 8704290106
Download: ML20209C905 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-17 Docket N License N CPPR-105 Category B Licensee: Duquense Power & Light Post Office Box 4 Shippingport, Pennsylvania Facility Name: Beaver Valley 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: March 9-13, 1987 Inspectors: ll //jf ?

X.' Kfasopoulos, Fi're Protection Engineer 'I date Also participating and contributing to the report were:

R. Hodor, Mechanical Systems Specialist, BNL K. Parkinson, 1 ctrical Systems Specialist, Sonalyst In .

Approved by: b/

C. JI Anderson, Chief k h /W date Plant Systems Section, DRS Inspection Summary: Inspection on March 9-13, 1987 (Report No. 50-412/87-17)

Areas Inspected: Special announced team inspection to assess the applicant's capability to safely shut down the plant in the event of a design basis fire and inspection of the emergency lighting system provided for safe shutdown purposes. The team also inspected the oil collection system provided for the reactor coolant pump Results: No violations were identified. One item remained unresolved at the conclusion of the inspection (Fire wrap required for cable tray supports).

8704290106 G70420 PDR G ADOCK 05000412 PDR

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Details 1.0 Persons Contacted 1.1 Duquense Light Co. (DLC)

• R. Martin, Manager Regulatory Affairs G. Beatty, Lead Licensing Engineer

• H. Cox, Training Engineer

• J. Crum, Training Engineer

• J. Moaracek, Sr. Licensing Supervisor

• J. Harding, Engineer

• K. DeBerry, Engineer

• F. Nelson, Nuclear Shift Supervisor

• J. O'Neil, Licensing Engineer

• L. Miller, EN0

• E. McFarland, NCO

• Svaranowic, Fire Protection Engineer

• J. Greco, NCO

• A. Beckert, NCO

• W. Laughlin, S Engineer

• W. Henrich, NCO

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! * Sovick, Sr. Licensing Supervisor

*J. Thomas, Manager of Engineering

• A. Lerczak, Procedures Supervisor

• P. Cadela, Supervising Engineer

• F. Schuster, NSOS R. Marietta, Training G. Wargo, Assistand Director QC 1.2 Stone and Webster Engineering Corp (SWEC)

• K. Fitzgerald, Power Engineer

• R. Dunne, Electrical Engineer t

• R. Wittchen, Licensing Engineer

• P. Talbot, Assistand Supervising Engineer

• F. Collins, Engineer

• Sibulkin, Electrical Engineer

• Thompson, Controls Engineer M. Lapia, Electrical Engineer R. Matei, Electrical Engineer U.S. Nuclear Regulatory Commission (NRC)

i J. Beall, Sr. Resident Inspector

, A. Asars, Resident Inspector

• L. Prividi, Resident Inspector

• S. Peleschak, Reactor Engineer

• Denotes those present at the exit interview

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2.0 Follow-up of previous inspection findings (Closed) Unresolved Item (87-11-03) Fire Brigade Training During an inspection of the licensee's Fire Protection Program the NRC raised the concern that the fire fighter training may not be adequat The basis for this concern was the limited amount of time dedicated to classroom and hands on training for each fire brigade member. The initial training given to each brigade member was about 8 hrs. The licensee agreed that this area of the Fire Protection Program may be enhanced and committed to improve the program. The proposed training program includes the following:

(a) For initial training, each brigade member will receive 2 days of hands on training and 2 weeks of total classroom training, This training will include the following:

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GET training and station orientation

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Respiratory protection training

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First aid training and instruction specific to the fire protection program such as pre-fire strategies, plant fires and structural fire fighting (b) Annual requalification training for the fire brigade will include at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands on practice for each brigade member and a search and rescue fire drill in full gear, in the cable spreading room. The inspector reviewed the proposed training program and determined that it is compatible with the Branch Technical Position (BTP) 9.5.1 requirement This item is resolve .0 Purpose This inspection was performed to verify the applicant's ability to safely shutdown the plant in the event of a fire and to verify the adequacy of the plant's emergency lighting system and oil collection system provided for the reactor coolant pump .0 Background The applicant is required to comply with the guidelines contained in Standard Review Plan (NUREG-0800) Branch Technical Position (BTP) Section 9.5-1, Fire Protection, dated July 1981. The guidelines forming the bases for this inspection are contained in the following sections of BTP 9.5-1:

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Safe shutdown capability to be in accordance with BTP 9.5-1 section C. . - - _ - _ _ _ _ _ _

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Alternative shutdown capability to be in accordance with BTP 9.5-1 section C. Emergency Lighting Systems to be in accordance with BTP 9.5-1 section C.5.G and

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An oil collection system for the Reactor Coolant Pumps to be in accordance with BTP 9.5-1 Section C.7.a(1)(e)

5.0 Correspondence All correspondence of the subject, between the applicant and the NRC and internal NRC documents were reviewed by the inspection team in preparation for the site visit. Attachment 1 to this report is a listing of correspondence reviewe .0 Post Fire Safe shutdown Capability 6.1 Safe shutdown Methodology The applicant stated that, for a design basis fire which will require control room evacuation, the operators will trip the reactor from the control room. The reactor coolant boron concentration will be increased using the high head charging pumps which maintain Reactor Coolant System (RCS) inventory and deliver borated water to the RC Two sources of borated water can be used. The boric acid transfer pumps may supply borated water to the charging pump suction or water from the refueling water storage tank may be injected by the charging pumps via direct suctio Cooldown of the reactor to the hot shutdown condition is accomplished by removing the reactor core heat by the generation and release of steam by the steam generators. During thi: phase the RCS temperature is reduced from 540 F to less than 350 Core heat is transferred by the RCS to at least two (A&B) steam generators by natural circulation if the reactor coolant pumps are not available. Heat is removed from the steam generators using the atmospheric steam release system in combination with the auxiliary feedwater system. Steam is released by the atmospheric dump valves while feedwater is supplied to the steam generators by the auxiliary feedwater system. This system which utilizes the " orange" electric feedwater pump or the steam driven feedwater pump takes suction from the primary demineralized water storage tan l Cooldown from 350 F to less than 200 F is accomplished by utilizing the residual heat removal system. The residual heat removal pumps circulate reactor coolant from the RCS through the residual heat removal heat exchangers and return the coolant to the RCS. The I residual heat removal heat exchangers are, in turn, cooled by the I component cooling water system which is cooled by the service water 1 syste l l

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6.2 Systems required for safe shutdown The systems and functions required for safe shutdown as listed in the applicants FPER are as follows:

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Auxiliary Feedwater System to maintain the steam generator level and to remove reactor hea Main steam system to remove reactor decay heat by closing the MSIV's and releasing steam from the atmospheric dump valves and residual heat release valves. The main steam safety valves also protect against steam generator overpressurization. This system also provides the motive force for the steam driven auxiliary feedwater pum Residual heat removal system (RHR) which removes heat from the i reactor coolant system (RCS).

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Component cooling water system (CCW) which provides cooling water to the RHR heat exchangers and the RHR pump seal cooler Chemical and volume control system (CVCS) which is used to maintain the RCS inventory and to increase the reactor coolant boron concentrations to a cold shutdown value before cooldown and depressurization is initiated. During cooldown the reactor coolt.nt inventory is controlled to maintain a relatively constant pressurizer water level by the use of charging and letdown subsystems. Borated water is injected into the RCS via the charging system (to maintain the RCS inventory). The letdown system is used to reduce the RCS inventor Service water system supplies cooling water to the CCW heat exchangers, emergency diesel coolers, charging pump coolers and various heating ventilating and air conditioning (HVAC)

cooling coil Reactor coolant system (RCS) circulates the reactor coolant thru the reactor vessel to the steam generators where heat is removed by the main steam system or the auxiliary feedwater syste Gaseous nitrogen system. Portions of this system are used to vent the safety injection system accumulators and to allow RCS d

depressurization without accumulator injection into the RC Emergency diesel generator fuel oil storage and transfer system provid.es fuel for emergency diesel generators which are operated to supply shutdown loads following a loss of offsite power (Loop).

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Safety injection system which provides alternative charging flow paths for RCS inventory control and boration. Also by the use of the accumulator isolation valves a sudden accumulator injection into the RCS during cooldown is prevente Heating, ventilating and air conditioning systems for the cable vault and rod control area, the control room, the primary aux-iliary building, the diesel generator building, the emergency switchgear room in the service building intake structure, the alternate shutdown panel room and the reactor buildin Post accident reutron flux monitoring system which provides outputs to the plant safety monitoring system and the alternate shutdown pane Electrical systems to provide power to safe shutdown equipmen .3 Alternative shutdown capability The applicant committed to provide alternative shutdown capability independent of the control room, the instrumentation and relay room, cable tunnel, cable spreading room and the west communication roo .4 Remaining plant areas The applicant identified certain areas of the plant where they deviated from the NRC Guidelines for safe shutdown provisions given in BTP 9.5.1 Section C.5.6. These areas include PA-3, PA-4 CV-4, CV-5, SG-15, MS-1, RC-1, SB-4 and PT-1. For these areas the applicant has submitted deviation requests based on technical justifications. The deviation requests are currently under review by

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NR .0 Inspection Methodology ,

The inspection team examined the applicant's capabilities for separating and protecting equipment, cabling and associated circuits necessary to achieve and maintain hot and cold shutdown conditions. The team inspected randomly selected fire areas which the applicant had identified as being in conformance with BTP 9.5- 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 i

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The inspection team also examined the applicant's capability to achieve i and maintain hot shutdown and the capability to bring the plant to cold

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shutdown condition in the event of a fire in areas where remote shutdown

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capability is provided. The examination included a review of the 7 drawings for the remote shutdown capability and review of the procedures for achieving the remote shutdown. Drawings were reviewed to verify electrical independence from the areas of concern. Procedures were

reviewed for general content and feasibilit 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 iceluded an evaluation of the susceptibility of the SSSs for damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression system The inspection team examined the applicant'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 seal Also, the team reviewed the applicant's emergency lighting system for areas of the plant required for safe shutdown and the reactor coolant i pumps oil collection syste .0 Inspection of Protection Provided to Safe Shutdown Systems 8.1 Protection in Various Fire Areas The plant is divided into fire areas which are described in the applicant's Fire Protection Evaluation Report (FPER)' Appendix 9.5A Section 9.5A. The team inspected the following areas because these areas contain safe shutdown equipment:

Fire Area Description ASP Auxiliary building-ASP room l CB-1 Instrumentation and relay room

CB-2 Cable spreading room CB-3 Control room CB-5 Fan room CB-6 West communication room (ESP station)

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4 CT-1 Cable tunnel / fan room i

CV-1 Cable vault and rod control (west)

i CV-2' Cable vault and rod control (east)

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CV-3 Cable vault and rod cont ol i

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CV-4 Cable vault and rod control

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CV-5 Cable vault and rod control

CV-6 Cable vault and red control (relay room)

DG-1 Diesel generator building (south)

DG-2 Diesel generator building (north)

MS-1 Main steam valve area PA-3 Auxiliary building i

PA-4 Auxiliary building PA-5 Auxiliary building ,

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PA-6 Auxiliary building

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PA-7 Auxiliary building PT-1 Pipe tunnel RC-1 Reactor contain SB-1 Service building (West) , ,

, SB-2 Service building (East)

l SB-3 Service building (cable tray area)

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SB-4 Service building  ;

SB-5 Service building SB-6 Service building - battery room 2-1 l l

SB-9 Service building battery room 2-4  ;

SG-IN Safeguardsbuilding(north) -

SGN-1S Safeguards building (south)

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Turbine building

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VP-1 Valve pit (east)

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a The scope of the review was to ascertain compliance with Sections C.5 b. and C.5.c of BTP 9.5-1 and to assess the adequacy of the fire protection in these area The only deficiencies identified are discussed below:

Fire wrap for cable tray supports The B.T.P 9.5.1 section C.S.B specifies that in order to assure that one train of systems necessary to achieve hot shutdown is free of fire damage one method of protection is to enclose one train in a fire barrier having a one hour rating in addition to having fire detection and automatic suppression in the are The team observed that the licensee is providing one hour fire wrap to cable trays in the cable spreading room. However, the licensee does not provide any fire wrap protection to the cable

tray supports. Recent NRC guidance contained in generic letter 86-10 states that "In general, cable tray supports should be

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protected, regardless of whether there is a sprinkler syste However, they need not be protected if (1) the qualification tests were performed on wrapped cable trays with unprotected supports, and the supports are shown to be adequate, or (2) an analysis is performed, which takes into account the fire loading and automatic suppression available in;the area, and which demonstrates that the unprotected support (s) will not fail and cause a loss of the cable tray fire barrier required for the postulated fire."

The licensee did not have an analysis'to verify the adequacy of the unprotected supports and during the period of the inspection the licensee could not determine if qualification tests on the unprotected supports were performe The licensee commited to either wrap the support with a one hour fire barrier or perform an analysis to verify that protection of the tray supports is not required, or' produce the documention of qualification tetts that may have been performed. If the licensee elects 00 to wrap the tray supportsc the analysis and/or qualif\'at0.1 tests should be submitted to NRC for revie This is ar. .are, m fid item (50-412/87-17-01).

Miscellaneous Fire Protection Observations The team observed that the heat detectors that actuate the preaction sprinkler system over the emergency fe were placed on the ceiling away from the pumps.With ,edwater the pumps

sprinkler actuating detectors located far from the heat source

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the sprinkler response time is increased. The licensee upon reviewing the system committed to relocate the detectors close to

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+ the ignition source i.e. the feedwater pump motor '

, Another observation by the team was that since some of the hose stations are located within the fire areas that they are

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designed to protect, the hose may be destroyed if a fire f- originated near the hose station. The licensee committed to

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review the fire fighting capability for each area using a hose a

rack from an adjoining roo If this review determines that-additional hose is. required to fight a fire from a hose station of an adjoining area the licensee committed to install additional hose lengths outside the affected roo .2 Safe shutdown procedures The team reviewed the following safe shutdown procedure:

Procedure No. OM2 56C, Alternate Shutdown From Outside the Control Room Rev. O dated 12/15/86

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The purpose of the review was to verify the adequacy of the procedure to achieve the safe shutdown goals for hot standby and cold shutdown. The procedure was developed to place the plant

in a hot standby and cold shutdown respectively following a

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'desfgn basis fire in areas CB.-2 the cable spreading room, CB-1 the instrumentation and relay room, CB-3 the control room, CB-6 the" west communication room and CT-1 the cable tunnel. A fire in these areas will necessitate evacuation of the control room and safe shutdown actions will take place outside the control roo '

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The team " walked-down" the procedure to assess its feasibilit No unacceptable conditions were identifie Following the " walk-down", the licensee committed to include a map of the route to be taken by the operators in this procedure

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to facilitate its us .3 Protection for Associated Circuits BTP 9.5-1, Section C.5.b, requires that protection be provided for associated circuits that could prevent operation or cause

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maloperation 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

Spurious signals concern 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 for potential problem . 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 concer ,

The team examined, on a sampling basis, the 4160V bus protective relay coordination. The team also examined, on a sampling basis, the protection for specific instrumentation, control, and power circuits including the coordination of fuses and circuit breakers for 4160V, 120 VAC and 125 VDC. The licensee plans to perform relay setting at approximately 18 month intervals.

i No unacceptable conditions were identifie . Spurious Signal Concern The spurious signal concern is made up of 2 items j

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False motor control, and instrument indications can occur such as those encountered during 1975 Browns

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Ferry fire. These could be caused by fire initiated i

grounds, short or open circuit Spurious operation of safety-related or nonsafety-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:

Current transformer secondaries High/ low pressure interfaces

General fire instigated spurious signals l

. No unacceptable conditions were identified.

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8. 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 indequate fire barrier penetrations.

A number of circuits, selected on a sampling basis, were examined for this concer No unacceptable conditions were identified.

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8.4 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 where fire area boundaries, includins walls, floors and ceilings, and fire protection of openingt such as fire doors, fire dampers, penetration seals, fire protection systems, and other fire protection feature No unacceptable conditions were identified except as indicated in Section 8.1 of this report.

] 9.0 Emergency Lighting i

BTP 9.5-1, Section C.S.g, 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 applicant committed to provide such lighting in the

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FPER response to BTP 9.5-1, Section C. The team inspected the emergency lighting and did not identify any unacceptable conditions. The I

licensee has provided battery operated lights in all safe shutdown

{ areas. Other plant areas have been provided with lights powered from a reliable source such as the non IE diesel or the station batterie No unacceptable conditions were identifie .0 011 Collection System for Reactor Coolant Pumps BTP 9.5-1, Section C.7.a, Paragraph (1)(e), requires that the reactor coolant pumps shall be equipped with an oil collection system if the containment is not inerted during normal operation. The applicant has installed an oil collection system for the reactor coolant pumps. The team's review did not identify any unacceptable conditions.

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11. Unresolved Items Unresolved items are matters for which additional information is required in order to ascertain whether they are acceptable, violations, or deviation One unresolved item is discussed in Section . Exit Interview The inspection team met with the licensee representatives, denoted in Paragraph 1, at the conclusion of the inspection on March 13, 1987. The team leader summarized the scope and findings of the inspection at that tim The team leader also discussed with the licensee the contents of the inspection report and ascertained that it would 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 l l

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ATTACHMENT 1

! List of Correspondence I

Letter from DLC transmitting Fire Protection Evaluation Report May 16, 1983

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Generic Letter 83-33 - NRC Positions on Certain Requirements Oct 19, 1983 of Appendix R.

Fire Protection Evaluation Report - Amendment 1 Oct 27, 1983 (2NRC-3-080)

NRC Letter transmitting questions on potential effects of Apr 18, 1984 relocated gasoline pipeline Letter from DLC transmitting status of fire protection open May 23, 1984

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items (2NRC-4-063)

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! Letter from DLC concerning calbe spreading room protection May 30, 1984 requiremen (2NRC-4-067)

Letter DLC transmitting FPER - Amendment 2 Aug 27, 1984 i

(2NRC-4-135)

i NRC Notice concerning Fire Protection Meeting Sep 26, 1984 l Letter from DLC concerning illumination levels Nov 8, 1984 (2NRC-4-185 Letter from DLC regarding Status of Backfit Nov 20, 1984 (2NRC-4-19 Generic Letter 85-01 - Fire Protection Policy Steering Jan 9, 1985 .

Committee Report *

! NRC Letter regarding backfit items Jan 10, 1985 l NRC Letter regarding backfit items Feb 5, 1985

Letter from DLC proposing appeal meeting date Feb 13, 1985 -

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NRC Letter regarding forthcoming appeal meeting Feb 25, 1985 1 NRC Letter regarding appeal of requirements of fire suppres- Mar 8, 1985

sion in the cable spreading room

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1 Letter from DLC transmitting revised responses Mar 27, 1985 (2NRC-5-054)

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Lettcr from DLC regarding cable spreading room Apr 25, 1985 (2NRC-5-064)

letter from DLC regarding illumination levels May 6, 1985 (2NRC-5-065)

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Letter from DLC regarding safe shutdown and alternate shut- May 13, 1985 l down capabilities (2NRC-5-069)

I Letter from DLC regarding use of carbon dioxide in cable May 24, 1985 spreading room (2NRC-5-076)

NRC Letter forwarding request for additional information Jun 18, 1985

regarding post-fire safe shutdown capability NRC Letter providing updated status of backfit items Jun 20, 1985

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Letter from DLC providing information on illumination levels Jun 25, 1985 (2NRC-5-094)

NRC Letter transmitting decision on appeal of requirements on Jul 11, 1985

! fire suppression in cable spreading room Letter from DLC forwarding status schedule for final draft SER Aug 7, 1985 and asking schedule for issuance of Final Environmental Statement (2NRC-5-116)

l Letter from DLC transmitting responses to requests for infor- Sep 13, 1985 mation concerning post-fire safe shutdown capability (2NRC-5-133)

Letter from DLC regarding decision on cable spreading room Oct 8, 1985 backfit appeal (2NRC-5-137)

i Letter from DLC regarding Potential Significant Deficiency Aug 8, 1986

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Report 86-10 (2NRC-6-082) ,

NRC Notice of Fire Protection Meeting Oct 23, 1986 NRC Summary of Meeting dated 11-5-86 Nov 18, 1986 Letter from DLC regarding FSAR Update and SER Response Jan 6, 1987 (2NRC-7-003)

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Letter from DLC regarding SER Backfit Item 7 Jan 28, 1987 (2NRC-7-017)

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Letter from DLC transmitting FSAR Amendment 14 Jan 30, 1987 (2NRC-7-014) l l

Letter from DLC related to NRR Fire Protection Site Visit Feb 11,-1987 i (2NRC-7-026)

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Letter from DLC transmitting comment on SER Mar 4, 1987 (2NRC-7-038)

Letter from DLC regarding Fire Detection Evaluation Mar 5, 1987 (2NRC-7-040)

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