IR 05000424/1988049
| ML20196A089 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/22/1988 |
| From: | Conlon T, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20196A087 | List: |
| References | |
| 50-424-88-49, 50-425-88-59, IEIN-85-009, IEIN-85-9, NUDOCS 8812050255 | |
| Download: ML20196A089 (28) | |
Text
7 -T 4 y'f
$ '
-.
'
-r y
pa tto
,so .
E' -' t UNITED STATES
- .; NUCLEAR REGULATORY COMMISSION
-
k [
REGION 11 g*... ,
101 MARIETTA ST., ATLANTA. GEORotA 30323 Report Nos.: 50-424/88-49 and 50-425/88-59
'
Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-424 and 50-425 License Nos.: NPF-68 and CPPR-109 Fccility Name: Vogtle 1 and 2 Inspection Conductod: October 17-20, 1988
"
Inspector: - .
u[e G. Wiseinan, Team Leader Ik I/
Oati S1'g ned Team Members: J. Harris
. M. Hunt D. Ward P. Ta/ lor ,
'
Approved by- _ <PA' W / // 2. A h
. Conlon, Chief Date Signed Plant Systems Section Engineering Branch Division of Reactor Safety
- SUK%RY Scope
- This routine, special inspection was conducted in the areas of fire
- protection and the licensee's actions regarding the implementation of the plant safe shutdown guidance provided in Standard Review Plan 9.5-1, positions C.5.b. and C.5.c and C.5.a. This inspection covered four major are#5 as they relate to fire protection and safe shutdown
! capability as denoted in NRC Manual Chapter Procedure 64100 including separation and protectior, of redundant cabling, equipment, and/or components required to achieve or maintain hot standby conditions; i associated circuits of concern; emergency lighting and i
communications; and alternate shutdown procedures for a major control l room fire. The review of the licensee's commitments associateci with the reactor coolant pump oil collection system for Unit 2 was
- previouLly addressed in NRC Report No. 50-425/88-32.
!
'
Results: In the areas inspected, violations or deviations were not identifie Strengths and weaknesses are summarized below:
(
,
8812050255 003125 PDR ADOCK 05000424 0 PNU
U O
.
.
Strengths
- With few exceptions, the licensee provided timely responses to NRC requests for information and our questions during the site audi fianagement was aware of the importance of fire protection and took steps to see that the NRC review and site audit went well, including making design Architect Engineering (A/E)
representatives available as neede Weaknesses The inspectors did not identify any significant programmatic weaknesse However, the licensee staff is presently evaluating and developing justification for their position that embeddea c,'nduits provide three-hour fire barrier separation for safe shstdown cables, identified as an Unresolved Item in this repor There is potantial that this review could identify a significant weakness affecting both Units 1 and This will be followed up on in future NRC inspection One Unresolved Item was identified, Justification of Embedded Conduit for Safe Shutdown Cable Separation, Paragraph 2.a.(2).
i i
!
L-- I
_,
c
.
.
.
REPORT DETAILS Persons Contacted Licensee Employees
- J. Bailey, Manager of Licensing /SCS
- E. Groover, QA Site Manager - Construction /GPC
- C. Hayes, Vogtle QA Manager /GPC
- G. Lee, Operations Supervisor /GPC
- J. Maddry, Unit 2 Fire Protection Manager /SCS
- R. Pinson, Vice President /GPC
- K. Pointer Senior Plant Engineer /GPC P. Rice, Vice President and Project Director /GPC
- R. Sprankle, Senior Engineer Nuclear Operations /GPC
- H. Varnadoe, Plant Engineer Supervisor /GPC Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personne Bechtel Power Company
- J. Foley
- C, Foster
- S. Gasperin
- J. Holmes
- S. Kotelsen
- E. Lamer
- l3rson
- Reed NRC Resident Inspectors
- C, Burger
- R. Schopens
- Attended exit interview Compliance with NUREG 0300. Standard Review Plan 9. Positions C.S.b, Fire Protection of Sa'e Shutdown Capability and C.5.c. Alternative Shutdown Capabilit An inspection was conducted to determine if the proposed fire protection features for structures, systems and components important to safe shutdown at the Vogtle Unit 2 facility will be in compliance with Standard Review Plan (SRP) 9.5.1, positions C.S b and C.5.c. The scope of this inspection determined if the proposed fire protection features as described in the I
U o
.
.
licensee's Fire Hazards Analysis (Section 9.5.1 of the Vogtle FSAR) which will be provided for reactor coolant system inventory control, steam generator inventory control, and reactor coolant system pressure control would be capable of limiting potential fire damage so that one train of these systems essential to achieving and maintaining hot standby from either the control room or emergency control stations are free from fire damag On the basis of the above licensee documents, licensee commitments and the SRP 9.5.1 criteria, the inspectors verified the separation provided for redundant safe shutdown components associated with satisfying the above performance goals was adequate within the fire area described in this repor Conclusion The safe shutdown components, both redundant functions and trains, which were reviewed, during this inspection will, upon completion of the fire protection systems and features and resolution of the Unresolved Item identified in Paragraph 2.a.(2), meet one of the following classifications:
- safe shutdown trains (equipment, components and cabling) are to be located in separate fire areas that will be separated from each other by three-hour fire rated construction;
-
redundant shutdown trains will be located in the same fire area but will be separated by more than 20 feet with no intervening combustibles and with an automatic fire suppression system and smoke detection system provided in the fire area;
- cabling for both redundant safe shutdown trains are to be located in the same fire area and one of the cable raceways for one train will be enclosed within a three-hour fire rated barrier; and ;
- safe shutdown trains within containment will be separated from each l other by either three-hour fire rated construction, noncombustible l radiant energy shield, or by a horizontal distance of more than 20 i
feet with nocombustibles, intervening intervening'. combustibles (FSAR contains a deviation for Fire Protection of Safe Shutdown Systems / Components l Vogtle Unit 2, upon completion of construction will be divided into approximately 89 separate Unit 2 fire areas. An inspection was made
,
of a sample of these fire areas to determine if redundant cabling, equipment, and/or components required to achieve or maintain hot j standby and cold shutdown conditions are going to be provided with ;
adequate separation and/or protection in accordance with SRP 9.5.1
,
position C. .
i
!
i
_ - _ _ . - ~ _ - . _ _ _ _ . _ . _ . _ - - _ -
.____m I
,
a
'
,
Included in the review was an evaluation of the acceptability of the barrier or enclosure construction configuration as a fire rated barrier as used in the plant. Also, the review verified the adequacy of the penetration sealing systems, and fire dampers / fire doors with respect to installation and completeness, physical condition, and fire test documentation, Within the following fire areas, the cable routing for redundant safe shutdown and the fire protection features afforded were reviewed:
(1) 2-AB-LD-A - Auxiliary Building (Fire Zones 9 and 118), Levels 0, C, 3, A, 1 and The licensee's safe shutdown analysis for Fire Area 2-AB-LD-A demonstrates that for a fire in this area shutdown Train A will be available. The fire barriers which make up the fire area boundary are three-hour rated except the south wall adjoining the stdirwell which is two-hour rated and exterior walls which are not rated. Penetrations through rated fire barriers will be sealed with penetrations seals, fire doors and fire dampers equivalent in fire rating to the barrier in which they are installed or a deviation has been identified in the VEGP FSA The fire aret is provided with automatic preaction sprinkler system protection which provides total zone coverage to Fire Zone 9 and partial zone coverage to Fire Zone 118. Fire detection is provided toroughout the fire area. Fire hose stations are available for manual firefighting activities within the fire are The licensee's analysis identifies a number of Train A shutdown cables and N-Train cables which are routed through the are The majority of these cables have been identified as only having spurious actuation concerns for which the licensee has identified sore mitigating action or the cables are associated with equipment for which an alternate Train-A piece of equipment capable of fulfilling the same safe shutdown function is available outside the fire area. However, the licensee's analysis does identify three Train A shutdown cables associated with equipment which is required to be operable for a fire in this fire are An inspection was made to verify the routing of the cables associated with these three pieces of equipment:
Raceway Fire Zone Equipment Cable / Raceway Location FT-0935. Con'ainment 23CQPS3XY/ 118 Pressure Transmitter 2CE442RX294
)
o
Raceway Fire Zone Equipment Cable / Raceway Location (cont'd)
2PT-0408, RHR Valve 23CQPS3YY/ 11B Pressure Interlock 2CE442RX294 PT-11'/41, NSCW 23RV288XA/ 118 Pumps Discharge 2CE442RX294 Pressure All of these Train A shutdown cables are routed in conduit 2CE442RX294 which the licensee has proposed to enclose in a three-hour rated fire barrier. The fire barrier is a preformed conduit wrap design by TSI utilizing Thermo-lag 330 fire barrier material. The barrier design is the same as that used in Unit 1 to protect conduits containing safe shutdown related cable This design was reviewed during the Unit 1 compliance inspectio The fire barrier had not been installed on conduit 2CE442RX294 at the time of the inspection. The inspectors were told by the licensee that none of the Unit 2 raceway fire barriers or radiant energy shields required to comply with SRP Section 9. Position C.S.b separation requirements had been installed. This is identified as Inspector Followup Item 50-425/88-59-01, Review -
Three-Hour Raceway Fire Barrier and Radiant Energy Shield Installation Based on the review of the licensee's safe shutdori analysis and the routings of the above sampled safe shutdown related cables, ,
it appears that, upon completion of the fire protection features for this plant area, the level of fire protection in fire area
)
2-AB-LD-A should maintain one train of system necessary to achieve and maintain hot standby free from fire damag l (2) 2-AB-LD-B - Auxiliary Building (Fire Zones 13, 24, 25, 38, 40, 41,41,192) Levcis D, C, B, A, and 1.
l The licensee's safe shutdown analysis for Fire Area 2-AB-LO-B .
!
demonstrates that for a fire in rooms 011 of Fire Zone 13. C21 i
of Fire Zone 24 or C29 Fire Zone 40 shutdown Train A will be available. In all other zones within this fire area shutdown Train B is available. The fire barriers which makeup the fire area boundary are three-hour rated except the wall adjoining stairwell 2 which is two-hour rated and exterior walls which are
- not rated. Penetrations through rated fire barriers will be i sealed with penetration seals, fire doors and fire dampers
! equivalent in fire rating to the barrier in which they are
! installed or a deviation has been identified in the VEGP FSAR.
i i ;
_
_ _ _9_
.
.
~
The fire area is provided with automatic preaction sprinitler system protection which provides partial zone coverage to Fire Zones 13, 38 and 46 and total zone coverage to Fire Zom 2 The remaining Fire Zones, 24, 40, 41 and 192, are not provided with sprinkler protectio Fire detection is provided in all fire zones, except zones 41 and 192. Fire hose stations are available for manual firefighting activities within the fire are The licensees analysis for this fire area identifies a number of special operational considerations which are required due to the presence of both Train A and Train 8 shutdown equipment and cables within this fire area. These special considerations are discussed belmn
- Redundant safe shutdown equi Service Cooling Water (NSCW)pment PT-11741, cooling tower bypass Train A Nucle interlock pressure transmitter, and PT-11742. Train B NSCW cooling towe" bypass interlock pressure transmitter, have their associated instrumentation cables routed in this fire are PT-11742 is located in roou 011 of Fire Zone 13. One of these transmitters is required to remain operable for a fire in this fire are The licensee's analysis credits spacial separation for providing the separation required by SRP Sectior. 9.5-1 Position C.5.b. The C and D levels of Fire Area 2-AB-LD-B contain both Train A and Train B snutdown cables associated with the trarsmitters. On these levels, PT-11742 and its associated cables are separated by at least 70 feet horizontally from any Train B shutdown cable Intervening combustibles in the form of non safety-related cables traverse this separation area and full area suppression is not provided. This configuration has been identified as a deviation from the requirements of SP.P Section 9.5-1 Position C.S.b. in the VEGP FSA This deviation will be reviewed by NRR as part of the Safety Evaluation (SE) being prepared as part of Unit 2 licensin The B level of the fire area contains only the cables associated with PT-1174?.
The inspectors reviewed the cable routings for the transmitters to verify the separation described in the licensee's analysis:
Raceway Fire Zone Equipmen t rable/ Raceway location 97-11741 24RV280XA/
(Train A) 2CE442RX294 24 PT-11742 24RV28tXD/
(Train B) 20E441RX00 , 24, 40 20E443KXJ01 40 20E443RX001 40
>
_ __ - _ . _
-.____7______
o e
'
,
This inspection verified the separation described in the licensee's analysis. However, during this inspection i was noted that the cables for PT-11742 are run in an embedded conduit (IDE441RX001) in the wall separating Fire Area 2-AB-LD-A and 2-AB-LD-B. Pull box 2DE443KXJ01 is exposed on the Fire Area 2-AB-LD-B side of this wall and the licensee has proposed to protect the cables for PT-11742 in the box with a three hour rated barrier. The separation of the cables in the embedded conduit from the remainder of Fire Area 2-AB-LD-B is based on the licensee's position that a three-hour fire barrier is provided. The inspectors requested the licensee provide the basis for this position and documentation that verified that the depth of the conduit as embedded constitutes a three-nour fire barrie The licensee was unable to provide any documentation to support their position on embedded conduit Therefore, this item was identi fied as Unresolved Items 50-424/88-49-01 and 50-425/88-59-02, Justification of Embedded Conduit for Safe Shutdown Cable Separatio This is identified as an unresolved item for Unit 1 as well, since the same position was taken in preparing the Unit 1 safe shutdown analysi The licensee's analysis shows that damage to Train B shutdown cables associated with the RHR pump 2-1555-A7-008-M1 room cooler motor and RHR room cooler temperature interlocks is possible. However, the licensee has identified a special operational consideration to start the room cooler from the remote shutdown panel. The transfer switch at the shutdown panel will effectively isolate the circuits su.i et to fire damage from the circuits required for fan operatio The cables fer both Boric Acid Transfer Pumps discharge valves and tne level transmitters for the Boric Acid Storage Tank could be damaged due to a fire in this are However, the licensee's analysis provides for a redundant means of reactivity co' trol by using the Refueling Water Storage Tank (RWST} and RCS letdown to achieve RCS bora tio The inspectors veri /ied that the cables associated with the outlet valves from the RWST, LV-1120 and LV-112E, are not routed through Fire Area 2-AB-LD-B. The cable routings for these valves are described in Paragraph 2.a.(3).
- The cables associated with RHR Pump 2 Miniflow valve 2f ,-0611 (Train B) are also routed in this fire are To mitigate the consequences of damage to these cables the licensee has identified manual operator actions to realign the valve in its correct position after tripping it's power suppl . __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ ___ _____- _ _______________ . ___________ _ __
_ _ _ _ - - _ -
.
.
.
~
.
,
The licensee's analysis also identified a number of Train B shutdown cables and equipment and N-Train cables which are in
Fire Area 2-AB-LD-B. Damage to these cables and equipment is identified as having only spurious actuation concerns for which the licensee has identified some mitigating action.
,
Based on the review of the licensee's safe shutdown ar.alysis and 1 the routings of the above sampled safe shutdown related cables, it appears that, upon completion of the fire protection features and the resolution of the unresolved item for this plant area, the level of protection in Fire Area 2-AB-LD-B should maintain
- one train of systems necessary to achieve and maintain hot standby free from fire damage.
i (3) 2-AB-LD-G - Auxiliary Building (Fire Zones 3, 5, 14A, 148, 14C, l
,
140, 21, 22, 26A, 30, 32, 36, 48, 49 and 54), Lovels D, C, B, A, j 1 and 2.
e The licensee's safe shutdown analysis for Fire Area 2-AB-LD-G l'
demonstrates that for a fire in Fire Zone 14C shutdown Train A j will be available and for a fire in any other zone within the j fire area shutdown Train B will be available. The fire barriers j which makeup the fire a.'ea boundary are three-hour rated except the walls separating the fire area from stairwell 4 and elevator i 2 which are two-hour rated and exterior walls which are not s j rated. In addition, the floor of Fire Zone 14C and the wall [M
!
separating Fire Zone 14C from Fire Zone 140 are three-hour fire
! rated. Penetrations through rated fire barriers will be sealed l with penetrations seals, fire doors and fire dampers equivalent i in fire rating to the barrier in which they are installed or a l deviation has been identified in the VEGP FSAR. The fire area j is provided with automatic preaction sprinkler system protection which provides partial zone coverage to Fire Zones 3, 21, 26A, 32, 48, 49 and 54 and total zone coverage to Fire Zones, 5,14C, 140, 30 and 36. The remaining fire zones,14A and 148, are not provided with sprinkler protection. Fire detection is provided throughout the fire area. Fire hose stations are available for manual firefighting activities within the fire are The licensee's analysis credits spacial separation for providing the separation of Fire Zone 14C from the remainder of the fire area. Fire Zone 14C is ptysically separated from all other fire zones within the fire area by three-hour rated fire barriers; however, a rated fire barrier is not provided between Fire Zones 14A and 14C. Since the fire area is not provided with full area suppression it does not meet the requirements of SRP Section 9.5-1 Position C.S.b for spacial separation. The licensee has identified this as a deviation from the SRP in the VEGP FSA This deviation will be reviewed by NRR during the preparation of the SE for Unit 2 licensin The remainder of the fire area contains both Train A and Train 8 shutdown equipment and cable ,
y- -- - - - - - - - - - - - - - - -----------------_---------- - - - - - - - _ _ _
_
.
-
.
.
In addition, a number of N-Train cables are also routed in the fire area out 'de Fire Zone 14C. The majority of the Train B cables and a'. i of the N-Train cables have been identified as only having spurious actuation concerns for which the licensee has identified some mitigating action. A number of the Train B shutdown cables are Train A shutdown related and have no Train B shutdown impac Finally, several Train B shutdown cables associated with the level transmitter (LT-0104) for the Boric Acid Storage Tank (BAST) and Boric Acid Transfer Pump (2-1208-P6-007) are subject to fire damage due to a fire outside zone 14C. To mitigate the consequences of fire damage to this Tra'n B shutdown equipment and cables the licensee's analysis i entifies a special operational consideration for a fire outside zone 14C which may recuire the use of the RWST and RCS letdown to achieve RCS boratio An inspection was made to verify that the following safe shutdown related cables would be protected in accordance with SRP 9.5-1 Position C.S Raceway Fire Zone Equipment Cable / Raceway Location (s)
Train A/ Charging Pump 2AA0213EA/ 22 and 140 Power Cable 2AE452TEAB, 2-1208-P6-002 2AE452TEAH, 2AE452 TEAK Train 8/ Charging Pump 2BA0313EA/ 14C Power Cable 2BE452TGCR 2-1208-P6-003 Train A/RWST 2ABD08LA/ 22 and 140 Outlet Valve 2AE452TLZF, LV-1120 2AE452TLAE, 2AE462TLAD, 2AE452TLAC, 2AE452TLAH, 2AE452TLAJ, 2AE452TLAK, 2AE452RL006, 2ARJB3691 2AB008LB/ 14D 2AE452RL466 Train B/RWST 2BBD08LA/ 14C Outlet Valve 2BE452TLCR, LV-112E 2BE452TLCS, 2BE452RLOO2
_ _ ,
.
-
.
'
Based on *he review of the licensee's safe shutdown analysis and the routings of the above samoled safe shutdown related cables, it appears that, upon completion of the fire protection features
,
for this plant area, the level of fire protection should
'.
maintain one train of system necessary to achieve and maintain ,
hot standby free from fire damag '
,
(4) 2-CB-LC-B - Control Building (Fire Zone 60) Levels, B, A,1, 2, The licensee's safe shutdown analysis for Fire Area 2-CB-LC-B i
, demonstrates that for a fire in this area shutdown Train B will !
be available. The fire barriers which makeup for fire area boundary are three-hour rated except the north wall on Level B which adjoins Elevator 1 and exterior walls which are not rate l Penetrations through rated fire barriers will be sealed with penetration seals fire doors and fire dampers equivalent in fire
- j rating to the barrier in which they are installed or a deviation l has been identified in the VEGP FSAR. The fire area is provided i
with automatic preaction sprinkler system protection which provides partial coverage to Fire Zone 80. Fire hose stations
,
are available for manual firefighting activities within the fire
'
area.
- A review of the licensee's safe shutdown analysis for this fire '
i area found that fire damage to the Train B CBSF battery room exhaust fans and their associated discharge dampers may require the use of portable ventilation equipment to dilute hydrogen
- buildup in the Train B battery room. The licensee justification i
for allowing fire damage to this equipment is that portable ventilation will not be required for at least 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> The i licensee's analysis (1s0 identifies a number of Train B shutdown
'
cables and N-Train cables which are located in this fire are A number of these Train B shutdown cables and all of the
N-Train cables are identified as having spurious operat;ons concer*4 only. To titigate the consequences of these spurious i signals the licensee has identified a number of manual action However, the licensee's analysis does identify a number of the i Train 8 shutdown cable associated with safe shutdown equipment ,
,
which is required to remain operable for a fire in this are (
i The licensee has proposed to protect these cables with a three
.
hour rated raceway fire barrier in this fire area. The licensee identified the following Train B shutdown raceways which are ,
) required to be protecte '
' 2DE350TXAH 2BE350TLAM ,
i 2BE350RS13E 2DE350TQAG !
!
2BE350RS323 20E350RQ210
'
2BE350R5077 2DE350RX142 -
2BE350RX286 2DE350RX145 l
2BE350RR218 20E350RQt27
_ _ .
_ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ . _ _ - _ . _ _ _ - . _ _-.
-
- - . . - . _
. . .
. - -
?, ' ;
-
,
!
'
, 10 !
.
'
An inspection was made of the routing of the following Train 8 shutdown cables to verify they are routed in the :
raceways identified by the licensee:
Raceway :
Fire Zone j Equi pma.at Cable / Raceway location s i
Diesel Generator 2B 2B01106LA/ !
Gen Contral Panel 2BE350TLAM 80 ,
i Battery Charger 2BBA04LA/ l 2BDICA 2BE350TLAM 80 !
PT-11742 NSCW 24RV289XA/ :
Pumps Discha,ge Pressure 20E350RX142 80 i Train B 20E3500TXAH t i
In addition, each Train B raceway identified by the licensee as !
aquiring three-hour fire barrier protection was inspected to -
ver!fy that the safe shutdown related cables would be protected :
in accordance with SRP Section 9.5-1 Position C.5.b. This inspection found that if the fire barrier is applied to the .
raceways identified by the licensee the cables in these raceways !
will be adequately separated from the remainder of the fire '
are ;
The raceway firc barrier had not been installed at the time of !
this inspection; however, the design of these barriers is the i same as that utilized in Unit This design was reviewed [
during the Unit 1 compliance inspectio' The installation of ,
the raceway fire barriers vill be reviewed during a future i inspectio This is another example of Inspector Followup Item l
'
$0-425/88-59-0 Based on the review of the licen.aee's safe shutdown analysis and
! the routings of the above sarrpled safe shutdown related cables, I
! it appears that, upon completion of the fire protection features
! for this plant area, d.s level of fire protection in Fire Area
- 2-CB-LC-B should maintain u" train of systems necMsary to i achieve and maintain hot standby Oee from fire damage.
(5) 2-CB-LB-A - Control Buildin9 (Fire 2.ines 59, 69, 72, 93,143)
l Level B ,
i
'
The licensee's safe shutdown inalysis for Fire Area 2-CB-LB-A .
'
demonstrates tnat for a fire in this area shutdown Train B will be available. The fire barriers which make up the fire area boundary are three-hour rated except the walls adjoining i
! !
! !
! !
l, s
>-r----em,r-----.~e, -.m._.. m, _ _. , . ,_ ,,
.._ - _ _ _ __ _______ ___-____ __ _ - _ _ _ _ _ _ _ _ . _ __ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
- l
-
.
,
^
i stairwell 4 and Elevator 1 which are two-hour rated and exterior walls which are not rated. Penetrations through rated fire barriers will be sealed with penetration seals, fire doors and fire dampers equivalent in fire rating to the barrier in which
they are installed or a deviation has been identified in the VEGP FIA The fire area is provided with automatic preaction sprtakler system protection which provides partial coverage to zones 72, 73 and 14 The remaining fire zones, 59 and 69, are not provided with sprinkler protection. Fire detection is provided throughout the fire area. Fire hose stations are available for manual fire fighting activities within the fire are The licensee's analysis identified a number of Train B
shutdown cables associated with the Reactor Trip Switchgear t (2-1606-56-002) which is routed through Fire Zone 69. To l
mitigate the consequences of damage to these cables the licensee
< nas identified a special operational consideration whereby reactor trip may need to be ensured by tripping breaker at 480V switchgear 2NB08 and breaker at 480V switchgear 2NB0 This i
action will ensure reactor trip by de-energizing the rod drive
- -
motor generator set .
An inspection was made to verify the separation of circuits
,
) associated with Train A battery chargers 2A01CA and 2ADICB and Train B battery chargers 2BDICA and 2B0100. Only cables
,
associated with battery charger 2ADICB are routed through Fire J
Area 2-CB-LB-A as noted below:
J l Raceway
' Fire Zone Equipment Cable / Raceway Location
{
l 2ADICB 2ABE38LA/
4 Battery Charger 2AE371TMAK, 73 Train A 2AE371TF%C, 73 l-2AE371TMAA 73 2AE340TMAK 73 l
2AE340TMAJ 73 i 2AE340TMAG 73
'
Based on the review of the licensee's safe shutdown analysis and the routings of the above sampled safe shutdown cables, it appears that, upon completion of the fire protection features i
for this plant fire area, the level of fire protection in Fire
Area 2-CB-LB-A should maintain one train of systems necessary to
- achieve and maintain hot standby free from fire damage.
l
!
l
1
-- . . . _ . _ . . - __.,.,___,.__.._,,_,_._,,._,_s.cm , ,--.._m.,._ ,mm a c_ ________ ,._
, ,-,c, e,_ - , ., .,.,,1,
__ ,
.
'
.
(6) 2-CB-LB-0 - Control Building (Fire Zones 60, 62, 65, 66, 67, 68, 70, 144) Level B The licensee's safe shutdown analysis for Fire Area 2-CB-LB-D demonstrates that for a fire in this area shutdown Train A will be available. The fire barriers rhich make up the fire area boundary are three-hour rated except the wall separating the [
fire area from the containment building and exterior walls which are not rated. Penetrations through rated fir ( barriers will be sealed with penetration seals, fire doors and fire dampers j equivalent in fire rating to the barrier in which they are installed. The fire area is provided with automatic preaction sprinkler system protection which provides partial zone coverage i to Fire Zone 144 and total zone coverage to Fire Zones 60, 62, !
65, 66, and 67. The remaining fire zones, 68 and 70, are not ,
provided with sprinkler protectio Fire hose staticns are ;
available for manual firefighting activities within the fire ,
t area, The licensee's analysis shows that both Train A and Train 8 shutdown cables as well as N-Train cables are routed through this fire area. A number of the Train A shutdown cables and all ;
of the N-Train cables have been identified as only having spurious actuation concerns for which the licensee has identified some mitigating actio Three Train A shutdown cables associated with Steam Generator Loop 4 Wide Range Level Instrumentation (2LT-0504) and RHR Loop 1 Inlet Isolation Valve 2HV-8701B which are required to be operable for a fire in this area are also routed in this fire area. These cables are routed in conduits embedded in the floor of fire zones 65, 66 and 6 The licensee's analysis includes the assumption that embedded conduits are provided with adequate separation from the remainder of the fire area; however, the licensee does not have an evaluatton to support this assumptio This is another .
example of Unresolved Item 50-424/88-49-01 and 50-425/88-59-0 Four pull boxes associated with these embedded conduits are exposed in the fire area. The licensee has proposed to provide a three hour fire barrier to srparate the following pull boxes from the remaind2r of the fire area:
2CE340KXH02 2CE361KXH01 2CE340KPHOP 2CE361KPH01 l t
As part of their safe shutdown cable separation review, the :
inspectors selected cables associated with the Diesel General 2A !
and 28 Control Panels for inspection. The separation of these ;
cables was verified to meet the separation requirements of .
SRP 9.5-1 Position C.5 b through field walkdown of the cable l routings. The cable for the 2A Diesel Generator Control Panel -
is not routed in Fire Area 2-CB-LB-D. The cable for the Diesel Generator 28 Control Panel are routed through l
_ ._
, _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ i
-
.
'
. 13 i
Fire Area 2-CB-LB-D in the following raceways: i
'
Fire Zone Equipment ' Cable / Raceway Location l t
Diesel Generator 2BD1106LA/ i 28 Control Panel 28E350TMAK 62 ;
2BE350TMAL 67 :
2BE340TMAF 67 2BE340TMAH 67 :
2BE340TMAJ 67 l t
2BE361TMAB 67 2BE361TMAF 67,66 i
'
2BE361TMAE 66 2BE361TMAD 66 8C3RLD65 66, 65, 144 !
8C3TLAB 144 j
!
Based on the review of the licensee's analysi ,and the routings of the above sampled safe shutdown related cables, it appears that, upon completion of the fire protection features for this f plant area and the resolution of the Unresolved Item identified, !
the level of fire protection if Fire Area 2-CB-LB-D should ;
'
maintain one train of systems necessary to acliteve and maintain hot standby free from fire damag l (7) 2-CB-LA-A - Control Building (Fire Zone 101), Level A i
The licensee's safe shutdown analysis for Fire Area 2-CB-LA-A <
demonstrates that for a fire in this area shutdown Train A will t b6 available. The fire barriers which make up the fire area l boundary are three-hour rated except the exterior ceiling which is not rated. Penetrations through rated fire barriers will be i sealed with penetration seals, fire doors and fire dampers ;
equivalent in fire rating to the fire barrier in which they are i installed. The fire area is provided with automatic preaction :
sprinkler system protection which provides partial coverage to j the area. Fire detection is provided throughout the fire are ;
Fire hose stations are available for manual fi refighting !
activities within the fire are l The licensee's analysis identifies a number of Train A shutdown !
cables and Train A Steam Generator Pressure Transmitters which I are located in this area. The cables associated with these I pressure transmitters and fire damage to these transmitters is l identified as only having spurious operations concerns for vhich the licensee has identified mitigating actions. The remaining Train A shutdown cables are associated with the Main Feedwater i Isolation Pypass Valves, 2HY-15197A and 2HY-15198, and Steam j Generator 2 and 3 Feedwater Isolation Valves, 2HY-5228 A, B, C, j D and 2HY-5229 A, B, C, D. Damage to these cables may result in ;
i k
_. - - _ - . - - . _ - -
, _
__ _ _____ _____ ____________ _ _ -
.
.
the need to accomplish main feedwater isolation by using Train 8 shutdown circuits which would not be damaged by a fire in this a rea . The licensee has identified the use of these Train B shutdown circuits as a special operational consideration for a fire in this Train A shutdown fire are The inspectors verified that these Train 8 shutdown circuits are not routed through Fire Area 2-CB-LA- Based on this review it appears that upon completion of the fire protection features for this plant area, the level of fire protection in Fire Area 2-CB-LB-0 should maintain one train of systems necessary to achieve and maintain hot standby free from fire damag (8) 2-CB-LA-K - Control Building (Fire Zone 95 and 169) Level A i
The licensee's safe shutdown analysis for Fire Area 2-CB-LA-X demonstrates that for a fire in this area shutdown Train B will be available. The fire barriers which make up the fire area boundary are three-hour rated. Penetrations through rated fire barriers will be sealed with penetration seals, fire doors and fire dampers equivalent in fire rating to the fire barrier in which they are installed. The fire area is provided with automatic preaction sprinkler system protection which provides partial zone coverage to Fire Zone 95. Fire Zone 169 is not provided with sprinkler protection. Fire detection is provided throughout the fire are Fire hose stations are available for i manual firefighting activities within the fire area.
l l The licensees analysis identifies a number of N-Train cable *,
routed through this area. All of these N-Train cables are identified as being Train A related and have no impact on Train B safe shutdown or the cables have spurious actuation concerns only. The licensee has identified mitigating actions for each of the spurious actuation concerns. In addition, the analysis identified a Train B shutdown cable associated with Control Room Emergency Lighting routed through the fire area. The emergency lighting is required to be operable for a fire in this area.
.
!
An inspection was made to verify the routing of the Train B shutdown cable associated with the Control Room Emergency
'
Lighting. Within Fire Area 2-CB-LA-K this cable is routed in the following raceway:
Racewal Fire ?one Equipment Cable / Raceway Location i Cantrol Room 288'23LA/ 169 l Emergency Lighting 2BE352RL369 i Power Feeder
!
I _ _ _ _ , _ _ _ _ - _ . - _ _ _
g ..
,
.
.
'
15 l The licensee's analysis identifies 2BE352RL369 as required to be i protected by a three hour rated raceway fire barrier. The inspectors found that if three hour fire barrier protection is provided for this raceway the Train B shutdown cable will be separated from the remainder of the fire area in accordance with SRP 9.5-1 Position C. The raceway fire barrier had not been installed at the time of the inspection; however, the design of these barriers is the same as that utilized in Unit 1. The design was reviewed during l the Unit 1 compliance inspection. The installation of the
'
raceway fire barriers will be reviewed during a future ,
inspectio This is another example of Inspector Followup Item 50-425/88-59-0 Based on the r3 view of the licensee's safe shutdown analysis and the routing of the above sampled safe shutdown related cable, it +
appears that, upon completien uf the fire protection features for this plant area, the level of fire protection in Fire Area 2-CB-LA-K should maintain one train of system's necessary to ,
achieve and maintain hot standby free from fire damag l (9) 2-CB-LA-M - Control Building (Fire Zone 06) Level The licensee's safe shutdown analysis for Fire Area 2-CB-LA-M '
demonstrates that for a fire in this area shutdown Train B will be available. The fire barriers which make up the fire area boundary are three-hour rated. Penetrations through rated fire l barriers will be sealed with penetration seals, fire doors and !
fire dampers equivalent in fire rating to the barrier in which '
they are installed. A Halon 1301 automatic suppression system is installed in the fire area; however, at the time of the inspection this system had failed to satisfactorily pass the i preoperational acceptance tes There are three Halon suppression systems in Unit 2 and at the time of this inspection only the system protecting the Train A Shutdown Room (Room 76)
had passed the preoperational tes Therefore, this is identified as Inspector Followup Item 50-425/88-59-03, Review of Halon System Discharge Test Data. Fire detection is provided throughout the fire area. Fire hose stations are available for manual firefiqhting activities within the fire are The licensee's analysis identifies a number of N-Train cables routed in the area which are of spurious act'ation concern. For each spurious actuation concern the licensee has identified an action to mitigate the concer The inspectors verified that no Train B shutdown cables were routed in this fire area by review of the licensee's analysis, plant raceway drawings and by reviewing a sample of the raceways in the area to ensure Train B cables were not routed in the a rea .
,--
.
e
Based on the review of the licensee's sufe shutdown analysis and cables in the area, it appears that, upon completion of the fire protection features for this plant area, the level of fire protection in Fire Area 2-CB-LA-H should naintain one train of systets necessary to achieve and maintain hot standby free from fire damag (10) 2-CB-LA-X - Control Building (Fire Zone 94) Level A The licensee's safe shutdown analysis for Fire Area 2-CB-LA-X demonstrates that for a fire in this area shutdown Train B will be available. The fire barriers which makeup the fire area boundary are three-hour rated except the north wall adjoining elevator 1 which is two-hour rated. Penetrations through rated fire barriers will be sealed with penetration seals, fire doors <
and fire dampers equivalent in fire rating to the barrier in which they are installed. Automatic suppression is not provided in the fire area. Fire detection is provided throughout the fire are Fire hose stations are available for manual firefighting activities within the fire are The licensee's analysis identifies a number of N-Train cables and B-Train shutdown cables which are routed through the are The N-Train cables have been identified as only having spurious actuation concerns for which the licensee has identified some mitigating action. The Train B shutdown cables are associated with Neutron Flux Detector RE131350 which is required to be operable for a fire in this are An inspection was made to verify the routing of the cables associated with this detector. The cables are routed in the following raceways within Fire Area 2-CB-LA- Raceway Fire Zone Equipment Cable / Raceway Location Neutron Flux 22R13135BXG, 94 Detector 22R13135BX4, RE13135B 22R13135BXJ, 22R13135BXK, 22R13135BXL/
2BE342RX135 All of these Train B shutdown cables are routed in conduit 1GE342RX135 which the licensee has proposed to enclose in a '
l three-hour rated fire barrier. The inspectors found that if three hour rated fire barrier protection is provided for this raceway, the Traia B shutdown cables will be separated from the
'
remainder of the fire area in accordance with SRP 9.5-1 Position C. , _ _ -- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ __
,
J \
p .
-
l
'
,
,
i
, , .
)
The raceway fire barrier had not been installed at the time of
.
the inspection; however, the design of these barriers is the i same as that utilized in Unit 1. The design was reviewed during i
[ the Unit 1 compliance inspection. The installation of the i s raceway fire barrier will be reviewed during a future f inspectio This is another example of Inspector Followup Item i 50-425/88-59-0 !
!
Based on the review of the licensee's safe shutdown analysis and ,
the routings of the above sampled safe shutdown related cables, !
it appears that, upon completion of the fire protection features i for this plant area, the level of fire protection in Fire Area {
2-CB-LA-X should maintain one train of systems necessary to l ochieve and maintain hot standby free of fire damage, j
During the review of the fire protection features provided in the above l fire areas the inspectors noted a discrepancy between sectiote 9.5.1.2. of the VEGP FSAR and the as-built configuration of the Unit 2. fire l detection system. This section of the FSAR states that some detectors ;
have been wired in parallel on detector circuits in such a way that the i detectors are not supervised in accordance with National Fire Protection ;
Association (NFPA) code requirement However, the inspectors found that L this design deficiency had been corrected in the Unit 2 fire detection i system design. The licensee comitted to clarify the statement in the l FSAR to state that tjie coda deviation only applied to Unit 1. This is !
identified as Insrector followup Itera S0-425/88-59-04, FSAR Change to !
"
Clarify Statement Regarding Paraelel Wiring of Fire Detector . Associated Circuits of Concern
! General j i
An inspection was made of associated circuits as defined in Generic j Letter (GL) 81-12 of February 00, 1981, and Supplement to GL-81-12 r issued in the Spring of 198 An analysis of these associated circuits of concern was perforned for the Vogtle Electric Generating f Plant in accordance with NRC Geraric Letter 81-12 and subsequent NRC clarificatio Associated circuits of concern are defined as those circuits that have a physical separation less than that required by ,
Standard Review Plan 9.5.1, Position C.S.6, and have one of the i following: !
!
(1) A comon power source (common bus) with the shutdown equipment l and the power source is not electrically protected from the ;
circuit of concern by coordinated breakers, fuses, or similar !
devices; or
,
!
,
- \
.
'
(2) A connection to circuits of equipment where spurious operation (spurious signal) would adversely affect the shutdown capability; or (3) A common enclosure with the shutdown cables, and (Type 1) are not electrically protected by circuit breakers, fuses, or similar devices, or (Type 2) will allow propagation of the fire into the enclosure, b. Associated Circuits by Comon Power Supply (Comon Bus)
Circuits and cables associated by common power supply are non-safe shutdown cables where fire-induced failure would cause the loss of a power source (bus, distribution panel, or MCC) that is necessary to support safe shutdown. This problea could exist for power, control, or instrumentation circuits. The problem of associated circuits of concern by common power supply is resolved by ensuring adequate electrical coordination between the safe shutdown power source supply breaker and the component feeder breaker or fuse ,
The inspectors reviewed Bechtel Calculation X3CT08, Rev. 5, which I includes a coordination study for the safe shutdown buses, and concluded that the concern of associated circuits by comon power
, supply is resolved with the exception of the batteries A, B, C, and D breake*s and one Main Control Board Termination Cabinet (2BCPT08).
1 The breaker coordination curve for the C train battery breaker (20D01) and the curve for Motor Control Canter (MCC) 2C1M feeder
,
breaker (200111) overlap between current flows of approximately 1400 to 1800 amps and 8500 to 36000 amps. (Note, the maximum fault current
,
is less than 15000 amps). The AE has proposed to change the long
' time delay band setting for Breaker (20D01) from the minimum to the intermediate range and change the short time delay band setting for Breaker 200111 from the max 1 mum to the intermediate range. These new
settings will provide adequate coordination. A similar condition exists in the D Train batteries between breaker 20D101 and 200108.
'
The changes described for the C train battery Breakers will be mad The coordination curves for the Train A and B feeder breakers (2AD105 and 2BD105) for DC distribution panels 2A011 and 2BD11 over lap slightly with the largest breaker (125 amp) in each pane The circuits from these 125 amp breakers are protected such that shutdown separation is accomplished. The adequacy of cable separation from these breakers was verified for each 125 amp breakt.r load for the various fire zones that the cables transvers However, good engineering practice indicates that coordination should be improved by adjustrent of the long time delay band on the feeder breaker __ _
i
.
.
'
An Engineering Action Item No. EAI-B-5167-PK was issued for the above ,
listed battery related breaker adjustments to be reviewed by the licensee's Protective Relaying engineering grou The followup of these circuit breaker adjustments is identified as an i Inspector Followup Item, 50-425/88-59-05, Verify that Corrective '
Actioas for Batteries A, B, C and D Circuit Breakers are Complet Review of the coordination curves for the Main Control Board Termination Cabinet 2BCPT08 which is used for safe shutdown (SSD)
identified that the feeder breaker to fuse coordination for this i panel was accomplished by the use of a particular 3 amp fuse (FNM-3). :
Other SSD panels contain a 3 amp fuse (FNQ) which is the same physical size supplied by the same vendor and are similar in -
appearanc The panel 2BCPT08 had the designated FNM-3 type fuses while adjoining panels had both types of fuses installed. Not all circuits from these panels had been energized leaving several fuse '
holders empt The inspector expressed a concern that the installation of the fuses having the proper operating characteristics to insure coordination with the panel feeder breaker was being accomplisned. The engineering drawings only identify fuses by size (amperage rating) and not by particular characteristic. The licensee agreed to review this situation and determine what actions have been or need to be taken to insure that the proper type fuses are installed to meet the breaker coordination scheme. This licensee i action will be reviewed further and is identified as an Inspector l Followup Item (IFI) 50-425/88-59-06, Yerify Proper Fuses by Model and !
Size are Installed in All Panels and Circuits, c. Associated Circuits Causing Spurious Operation (Spurious Signals)
Circuits associated because of spurious operation are those that can, by fire-included failures cause safe shutdown equipment or non-safe shutdown equipment to maloperate in a way that defeats the function of safe shutdown systems or equipmen Examples include the uncontrolled open:ng or closing of valves, or of circuit breakers, due to fire-induced damage to non-safe shutdown instrument and control circuits that affect the control circuit interlocks of the safe shutdown component The inspectors reviewed plant-specific design features, control circuits, and the licensee's safe shutdown analysis to determine that the concern of possible spurious operations is resolved. Particular attention was given to Hi/ Low pressure interface valves that are part of the Residual Heat Removal System and similar system The licensee's A-E has identified the reactor coolant system effluent ,
lines that present High/ Low pressure interface concerns. These are listed belo u- -
e
.
Line Normally Closed RCS Effluent Line Description Size Series Valves Number Fail Position (1 Train A RHR pump suction 12" 2 as is Train B RHR pump suction 12" 2 as is Train A pressurizer PORV 3" I closed Train B pressurizer PORV 3" 1 closed Train A RPV head vent path 1" 3 closed Train B RPV head vent path 1" 3 closed Normal letdown path 3" 0 ------
Excess letdown path 1" 3 closed The breakers for the RHR pump suction valves are locked in the tripped position with the valves closed during normal operation. In addition, there exists an interlock to preclude the opening of these valves while the RCS pressure is greater that the RHR design pressur Since High/l ow pressure interface situations require full evaluation for cable to cable hot shorts (Generic Letter 86/10 paragraph 5.3.1)
the licensee furnished additional analysis dat The RHR suction line from Hot Leg 1 to the Train A RHR pump has two motor operated valves (MOV) in series. One is powered from a Train A motor control center (NCC). The other is powered from an inverter supplied C Train MCC and the power cable is installed in single conduit for the entire length from the MCC to the valve. The conduit would preclude a possible phase to phase short that would cause a spurious operation. Likewise the suction line to the Train B RHR pump from Hot leg 4 contains a B train valve and a D train valve with the D train valve power cables installed in condui The pressurizer PORV for Trains A and B are backed up by fail-as-is MOV The PORVs close on loss / removal of power. To meet the intent of G/L 86-10 cable-to-cable het short scenario, the licensee has identified the cables that carry DC voltage and share cable trays with the PORV DC power cables in the various fire areas. When an abnormal / alarm condition is annunciated on the fire alarm compute The area in alarm is indicated. The procedure No.17103-C, Annunciator Response Procedures for Fire Alarm Computer will be used to identify the DC circuit breakers to be opened to prevent spurious operation of the PORVs due to cable to cable hot shorts. This procedure is still being revised / developed and does not list the DC breakers that require operation in the various area The licensee advised that these circuit breakers will be identified and included in the appropriate table in Procedure No. 17103-C. This is identified as an Inspector Followup Item, 50-425/88-59-07 Review Precedure 17103-J to Insure that Additional PORY DC Ci-cuit Breaker Operations are Identifie j
_ _ . __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
Item Nos. 5, 6, and 8 in the above table would be considered small line leaks and an engineering evaluation shows that the safety injection system can adequately provide makeup for losses in the RCS inventory should a valve in a 1" line spuriously ope ;
Item No. 7 in the above table was evaluated and it was determined that the normal letdown path flow is limited by orifice Two ;
normally open, fail-closed, air operated valves serve as the containment isolation valve Two additional, normally open fail-closed, pneumatic operated valves in series with the two containment isolation valves close automatically when low pressurizer level occur ;
The inspector questioned the possibility of a spurious signal causing a run back of a diesel generator speed controller during a fire in the main control room. This question was also posed during an Appendix R inspection of Unit The nachanical run back is set to stop when the frequency falls to G Hz. on the Unit 1 diesel generator However, there was at the time of this inspection no information to indicate that a similar action had been taken for the '
Unit 2 diesel generator speed controllers. This is identified as an Inspector Identified Item 50-425/88-59-08 Verify That the D/G ,
Frequency Setpoint is Set at 57 H :
The licensee's evaluation and findings regarding the effect of spurious closure of the VCT outlet valve (LV-01128 or LV-0112CO)
revealed that damage could o'ccur to the centrifugal charging pumps l within ten sec. when both pumps are started in the event of LO With this concern in mind the licensee had requested to be allowed to realign the centrifugal charging pump suction to the Refueling Water :
Storage Tank (RWST) before abandoning the main control room. In view !
of the fact that all licensees are evaluated on the basis of only I tripping the reactor prior to control room abandonment, this action !
was not considered as part of this inspection. Since the question of realigning the centrifugal charging pump prior to abandoning the '
control room is undet e"view by NRC for Unit 1 and the situation being the same for both Vogtle Units 1 and 2 as well as other Westinghouse PWRs this item is identified as an Unresolved Item 50-425/88-59-09, Review Single Failure Criteria for the VCT Outlet Valves, Associated Circuits by Common Enclosure ,
A circuit, whether safety-related or not, is classified as an associated circuit of concern if it shares a common enclosure (e.g.,
cable tray, conduit, panel or junction box) with a "Required Circuit", and, is not adequately protected by circuit breakers, fuses, or similar devices, or could allow fire propagation into the ,
Shared Comon Enclosure, j l
,
i
..- . - .___ __ _ ___ __ . __ , ._
. -. . . - _ _ - _ _ _ _ - .
.
.
,
At the Vogtle Electric Generating Plant, the concern was answered satisfactorily when a sample of circuits selected were all found to be electrically protecte Fire stops are designed to be installed whenever a cable penetrate, the boundary of a fire area. IEEE383 qualified cable is installed in areas where safe shutdown cables are route he inspection of cable separations and fire stops is ,
discussed in the review of fire areas section of this repor Double Fusing for the Alternate Shutdown Panel I IE Information Notice 85-09, "Isolation Transfer Switches and .
Post-Fire Shutdown Capability" identifies a potential problem ;
concerning fuses in control circuits associated with the alternate shutdown panel. Control circuits for equipment controlled from the alternate shutdown panel typically have wires that inter-connect field devices, devices at the alternate shutdown panel, and devices in the main control room. Even though isolation transfer switches at !
the alternate shutdown panel will isolate interconnections with the control room, a system of double fusing must be utilized to ensure i that a fire in the control room cannot disable control from the alternate shutdown pane Review of varf ous safe shutdown equipment schematics verified that the double fusing had been designed and ,
rtflected in the schematics. Curing previous inspections the ;
inspectors had visually verified that the additional fuses had been installed in the various required circuit l Compliance with NUREG 0800, SRP 9.5-1, Position C.5.g. , Lighting and Connunication I
' Emergency Lighting Emergency lighting units equipped with at least an 8-hour battery power supply are required to be provided in all areas required for operation of safe shutdown equipment and in access and egree routes ,
theret l The inspectors reviewed the design and instal'e tion of the 8-hour ,
lighting units to be provided for Vogtle Unit 1. The lighting units l reviewed are sho'.<n on design Lighting and Comunications drawings ,
noted as follows: 2X3DH8F4, Reactor Make-Up and Refueling Water i Storage Tanks; 2X3DHSC(, Auxiliary Feedwater Pumphouse; 2X3DH8D3, :
Diesel Generator Building; 2X30G341 through 2X3DG390, Control l Building; 2X3DG441 through 2X3DG460, Auxiliary Buildin Emergency DC lighting is provided in the control room complex and for [
access and egress routes located on the the exterior of the main (
plant structure The lighting from the control room is supplied !
from the nonnal plant emergency power supplies. This DC lighting [
consi'sts of separated and protected redundant lighting circuits f powered from the onsite diesel generators. The lighting for the l i
i i
. __ . _ . . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ ___
_-
.
.
,
l exterior routes is supplied from the security lighting system. The licensee has identified these deviations and provided justifications to NRC/NR These are presently under NRC review and will be i
addressed in the Unit 2 SE a The lighting units being installed are two lamp Holophane Models, M-19-2A-X-SE15-PT, with an emergency load rating of 8-hours at 36
.
Watts D.C. Lamp size provided is 18 watt PAR 36 sealed beam The inspectors performed a walkdown examination of the design and li installation of emergency lighting Units for Unit 2 based upon the l licensee drawings noted above, the post-fire alternate shutdown procedure utilizing the alternative shutdown system, Abnonnal Operating Procedure A0P 18038-2, Operation from Remote Shutdown Panels, Revision 0, and the Bechtel fire event safe shutdown evaluation, Control / Repair Station Listing, Revision 2 dated October 3,198 This was to verify that the emergency lighting units were situated such that the steps outlined in the procedure and
,
l
- could be performed by the operato i 1 As a result of the emergency lighting walkdown, it appears that marginal emergency lighting conditions existed in the following locations
l (1) No 8-hour battery powered lighting unit was provided for the i Refueling Water Storage Tank (RWST) level indicator LI-0990C in
! Room 101 of the RWST Building. The unit indicated on the design J drawing would be obstructed and not effectively illuminate the level instrument.
J (2) The lig5 ting unit provided for the manual operation of valve
-
HV-3009 located in the Auxiliary Building Room 159 was mounted below and behind the valve's access platform such that this I ob:truction eliminated its effectiveness to illuminate the j required shutdown equipment, t
I (3) The lighting units provided for the access and egress path to be Remote Shutdown Panel rooms in corridor R-A18 of the control j building provide marginal lighting levels for the operator to i navigate through the corridor to reach the recuired room !
l (4) Procedure 17103-C, Annunciator Response Procedures for Fire j Alann Computer will be used by the licensee to identify specific
'
alternative shutdown operator actions to mitigate the l
consequences of spurious signals, and/or accomplish safe l
shutdown manual alignments for fire events outside the Main j Control Roo At the time of this inspection, this procedure
!
was still being revised / develope The final revision may require additional emergency lighting be installed for these identified nanual actions which have not been reviewed by the
,
NR This will be reviewed during a future NRC inspectio *.
!
!
<
)
, _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
e
.
r l
The licensee stated that these items will be addressed during the '
future performance of Preoperational Test 2-3QD-01 which includes an operation walk through of all areas to verify safe movement on all !
operator routes and equipment visibility utilizing emergency i lighting. The inspectors' review of Sections 6.*1 and 6.14 of the !
test procedure verified that this statement is accurat l However, the above items collectively are identified as Inspector i Followup Item 425/88-59-10, Review of Identified Marginal Emergency :
lighting for Safe Shutdow l The inspectors also expressed concern that VEGP procedure A0P 18038-2 t in several places provides for operator actions for local control or '
verification of plant equipment that is not identified on the safe !
shutdown station (SSD) equipment list (FSAR Table 9.5-1 or the ,
Bechtel SSO Control Station listing which assures that the listed [
equipment / station is available for various fire events. The licensee !
stated that a comitment will be assigned to the alternate shutdown procedures (180381/2 and 17103-C to ensure that the operator actions are consistent with the safe shutdown evaluation control station This is identified as listings such Inspector that allItem Followup documents ag)re /88-59-11 , Review of Licensee's Actions for Discrepancies Between A0P Safe Shutdown Controls and Safe Shutdown Station and Equipment Lists. These items will be reviewed during subsequent NRC inspection L Fixed Emergency Comunications Fixed emergency communications systems independent of the normal plant communication system are required to be provided at preselected shutdown control stations, j The licensee has identified the locations within the plant in which a !
fixed independent comunication station is required. These locations l as identified by the Fire Event Safe Shutdown Evaluation Control l Station Listing, Revision 2, October 3, 1988, include selected rooms ,
containing the remote shutdown panels, diesel generator panels, j switchgear and motor control centers, atmospheric relief valve local hand pump stations, pressure gauges, tank level gauges, and mnual ;
valve l
!
A review of the above noted lighting and communication drawings l indicated that an independent dedicated sound powered telephone i system was to be provided in each of the identified locations. The {
inspectors noted that this system was provided as an isolation switch }
in the corridor / lobby outside the control room which isolated the l dedicated system from the remainder of the system in the event of a i control room fire. During the plant tours, the inspectors verified l that the system had been installeo for theses areas. The inspectors ,
reviewed Acceptance Test Procedure 2-4QF-02 Section 6.2, In-Plant ;
i
, g _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
u
.
Communication System / Sound-Powered Phone This test procedure should assure that ell the sound powered phone stations and the control room isolation switch will be functional if required for service and is to be completed prior to fuel loa Within the areas examined, no violations or deviations were identifie . Alternative Shutdown Capability Review of Plant Procedures AOP 18038-2, Revision 1, Operation from Renote Shutdown Panels was issued and approved October 11, 1988, for Unit 2. This procedure provides detailed instructions concerning the evacuation of the main control room due to a major fire and operating selected plant systems and corponents of the remote shutdown panel Both train A and B safe shutdown systems and components can be isolated from the main control room either locally or 6t the shutdown panel Train B remote shutdown panels and components are the preferred system to use for a control room fir Based on the review of the above procedure, the licensee has incorporated systems, components and operator actions to accomplish the performance goals for alternate shutdown identified in BTP-CMEB 9.5-1, section C. . Exit Interview The inspection cope and results were summarize.d on October 20, 1988, with those perscns indicated in paragraph 1. The inspectors described the areas inspected end discussed in detail the inspection results listed belo Proprietary information is not contained in this repor Dissenting carents were not received from the license IF! 50-425/88-59-01, Review Three Hour Raceway Fire Barrier and Radiant Energy Shield Installation UNR 50-424/88-49-01, Justification of Enbedded CondJit for Safe 50-425/83-59-02, Shutdown Cable Separation IFI 50-424/88-59-03, Review of Halon System Discharge Test Data IFl 50-425/88-59-04, FSAR Change to Clarify Statement Regarding Parallel Wiring of Fire Detectors IFI 50-425/88-59-05 Verify that Corrective Actions for Batteries A, B, C, and D Circuit Breakers are Complete IFI 50-425/88-59-05 Ve ri fy Proper Fuses by Model and Size are Installed in all Panels and Circuits I
_
.-
,
.
IFI 50-425/88-59-07 Review Procedure 17103-C to Insure that Additional PORV DC Circuit Breakers Operations are Identified IFI 50-425/88-59-08 Verify that the DG Frequency Setpoint is Set at 57 Hz UNR 50-425/88-59-09 Review Single Failure Criteria for the VCT Outlet Valves IFI 50-425/83-59-10 Review of Identified Marginal Fmergency Lighting for Safe Shutdown IFI 50-425/88-59-11 Review of Licensees Actions for Discrepancies Between AOP Safe Shutdown Controls and Equipment Lists