IR 05000461/1998026

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Insp Rept 50-461/98-26 on 981013-30.Violations Were Identified,But No Notice Was Issued.Major Areas Inspected: Engineering & Plant Support
ML20206N477
Person / Time
Site: Clinton Constellation icon.png
Issue date: 12/13/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206N474 List:
References
50-461-98-26, NUDOCS 9812180152
Download: ML20206N477 (24)


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U.S. NUCLEAR REGULATORY COMMISSION l REGION 111

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~ Docket No: 50-461 I License No: NPF-62 Report No: 50-461/98026(DRS) ) l

Licensee
lilinois Power Company l

' i Facility: Clinton Power Station j

:      1 1      j Location: Route 54 West l

Clinton, IL 61727  ; I , Dates: October 13 - October 30,1998 i

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Inspectors: D. Butler, Team Leader, Rlli D. Chyu, Reactor Engineer, Rlli P. Madden, Fire Protection Engineer, NRR P. Qualls, Fire Protection Engineer, NRR j , Approved by: Ronald N. Gardner, Chief I Engineering Specialist Branch 2

9812180152 981213 PDR G ADOCK 05000461 PDR

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, EXECUTIVE SUMMARY I ' Clinton Power Station NRC Inspection Report 50-461/98026(ORS) ! An announced four member team inspection composed of Regional inspectors and NRR fire l . protection technical reviewers was performed during the period of October 13-30,1998. The j team reviewed the engineering organization's effectiveness in resolving fire protection safe l shutdown concems identified as NRC Case Specific Checklist Matrix Item IV.5. As a result of this inspection, two violations of NRC requirements were identified. Enforcement discretion was exercised for both violation : l Enaineerina ! l- '

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The team concluded that the licensee's revised safe shutdown analysis met the plant's licensing basis. However, a number of safe shutdown actions (e.g., completion of safe shutdown procedures) remain to be completed and reviewed by the NRC before restart (Section F2.1).

. A violation was identified regarding the licensee's failure to ensure that 54 MOVs would , remain free of fire damage due to fire induced hot shorts in the valves' control circuitry . I Enforcement discretion was exercised. The remaining corrective actions rented to this 1 violation will be reviewed by the NRC prior to restart (Section F2.2).

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The team concluded that the 3M fire barrier material used to replace the Thermo-Lag material installed inside containment met NRC fire protection guidance. However, the licensee was unable to provide acceptable industry fire barrier test reports to support the upgrada of an installed Thermo-Lag fire barrier assembly in Fire Zone CB-1f. This issue will remain open pending NRC review prior to restart (Section F2.3).

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The team concluded that the cable test documentation utilized by the licensee to i support the qualification of Whittaker fire-rated safe shutdown cables did not adequately demonstrate that the fire-rated cables provided equivalent fire protection as that provided by a rated fire barrier. This issue will remain open pending NRC review prior to restart (Section F2.4).

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The team concluded that, due to obstructions, sprinkler systems installed in several risk significant fire areas may be incapable of suppressing a fire. This issue will remain ! ! open pending NRC review prior to restart (Section F2.5).

A violation with three (3) examples was identified regarding the failure to provide adequate electrical circuit isolation for several safe shutdown component Enforcement discretion was exercised (Sections F8.2, F8.4 and F8.5).

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Report Details The NRC Special Evaluation Team (SET) inspection, conducted in August 1997, identified a number of significant issues regarding the Clinton Power Station (CPS) fire protection program. As a result of the SET findings, the licensee issued the Fire Protection Plan for Excellence. Included in the Plan for Excellence were actions to address SET fire protection issues as well as actions to address fire protection issues identified during the licensee's Integrated Safety Assessment, Nuclear Station Engineering Department fire protection self-assessments, and Quality Assurance fire protection audits.

The purpose of this inspection was to review actions taken by the CPS engineering organization to resolve fire protection safe shutdown concerns identified as NRC Case Specific Checklist Matrix Item IV.5. Specific fire protection features reviewed included the licensee's safe shutdown methodology, the Thermo-Lag upgrade program, and motor operated valves (MOVs) hot short design changes. The inspection team reviewed the licensee's revised safe shutdown analysis and safe shutdown procedures, selected fire areas, and selected safe shutdown component IV. Plant Support F2 Status of Fire Protection Facilities and Equipment F Safe Shutdown Comoliance Reviews Insoection Scope The inspection team reviewed the licensee's post-fire safe shutdown methods to determine if the systems identified for use to achieve and maintain safe shutdown conditions were adequately separated as specified by 10 CFR 50, Appendix R, Section Ill.G, and as required by CPS fire protection operating license condition Observations and Findinas The systems used at a boiling water reactor (CPS is a boiling water reactor) to achieve post-fire safe shutdown conditions must be capable of achieving the following performance goals:

. Reactivity controls capable of achieving and maintaining cold shutdown reactivity conditions (K, < 0.99 and reactor molant system (RCS) temperature less than or equal to 200*F).
  • Reactor coolant makeup capable of maintaining water level above the top of the core at all times during shutdown operatio . Process monitoring capable of providing direct readings to perform and control the above function . . -------- . -. - - ._ - .- - - -. .- . - - .- - . - - -

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l . Supporting functions capable of providing process cooling, lubrication, etc., j necessary to ensure safe shutdown equipment operation.

l The equipment and systems used to achieve and maintain hot standby conditions must 1

be free of fire damage during accomplishment of the above goals. Additionally, the
equipment and systems used to achieve and maintain cold shutdown conditions must
be free of either fire damage or the damage must be limited to allow repair, within 72
. hours, of the systems necessary to achieve and maintain cold shutdown conditions
from either the control room or emergency control station (s).

1-l During a post-fire shutdown, the reactor coolant system process variables must be j maintained within those predicted for a loss of offsite power, and fission product boundary integrity must be maintained; that is, no damage to the fuel cladding, and the

integrity of containment and the primary coolant system pressure boundary must be j maintained.

l ! Post-fire Safe Shutdown Re-Validation Project ' !

The CPS Appendix R safe shutdown design basis re-validation project was initiated in

, July 1997. The primary objective was to verify the accuracy of Updated Safety Analysis i Report (USAR) Section 9.5.1, " Fire Protection System," and Appendix F, " Safe

. Shutdown Analysis." The activities associated with this project included an evaluation
of the existing safe shutdown equipment list and the Sargent and Lundy Interactive

! Cable Engineering (SLICE) database update as well as the re-validation of safe l shutdown circuit analyses, fire area assessments, safe shutdown system functional requirement analyses, and operator manual action feasibility assessments.

! ! The licensee's re-validation project performed a 100% safe shutdown equipment and ' component review. This review included the components documented in USAR j Appendix F, Tables 1.8-2 and 1.8-3 and resulted in safe shutdown equipment additions , i and deletions from the USAR Appendix F tables. The following components were  ; ! reviewed: ! l }. . All instrumentation required for a safe shutdown or whose spurious operation

could adversely affect safe shutdown including Emergency Core Cooling l System WCCS) automatic initiation,
  . Non-electrical components that establish safe shutdown system boundaries, t   . Valves listed in the USAR, Appendix F, Table FA-1, " Potential Spurious Valve j    Operations that Could Affect Safe Shutdown,"

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  . Scram discharge volume vent and drain valves, j   . Intemal 120Vac distribution panels and transformers,    '

j . Control room heating, ventilation and air conditioning (HVAC) dampers,

  . Essential switchgear cooling retum fans,
  . Feedwater isolation valves, a Reactor Water Clean Up (RCWU) isolation valves,
  . Additional suppression pool temperature indication capability, and
  . Seven additional safety-relief valves (SRVs)
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The licensee performed a re-validation of previously completed circuit analyses in two phases. In the first phase, the licensee sampled the original circuit analysis to gain

. insights into the original circuit selection methodology. Even though the original methodology was conservative, the following original analysis weaknesses were

identified by the licensee:

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. Non-safe shutdown / safe shutdown (SSD) interface components - Spurious operation impact of non-SSD components were not uniformly addressed,
. Inappropriate use of generic notes to disposition spurious valve operations, such as, refer to USAR Appendix F, Table FA-1,
. Instrumentation interlocks and permissives were not completely reviewed for all SSD components, and
. Circuit design for some SSD components credited for an a!temative shutdown (remote shutdown) did not have adequate electrical isolatio The re-validation effort resulted in an additional 163 electrical components being added to the safe shutdown equipment lis As a result of the circuit analysis weaknesses noted above and the identification of additional equipment required to be added to the safe shutdown equipment list, the licensee performed additional circuit analyses (second phase) for the following SSD components:
. All Division 1,2, and 3 instrumentation required for a safe shutdown or whose spurious operation could adversely affect safe shutdown including ECCS I  automatic initiation,
. Valves listed in the USAR, Appendix F, Table FA-1, " Potential Spurious Valve Operations that Could Affect Safe Shutdown,"   '
* Scram discharge volume vent and drain valves,
= Control room HVAC dampers,
. Essential switchgear coohng retum fans, e Feedwater isolation valves,
. RWCU isolation valves,
. Suppression pool temperature indication capability,   I
. All 16 SRVs
. Division 1,2, and 3 - 4.16KV switch gear breakers,
* Division 1,2, and 3 - 480V Load Centers,   4
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* Division 1, 2, and 3 - 480V Motor Control Centers (MCCs),
. Intemal and extemal 120Vac distribution panels and transformers,
* All safe shutdown Method 1 (Division 1) components required for an attemative/ remote shutdown,
. Cables running to main control room (MCR) panels. and
. Motor operated valves with both active and passive. 3SD function _ _ __ . . . _ _ _ _ . _ _ _ _ - _ _ _._ - _ _ _ _ _ _ _

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The inspectors determined that the licensee's re-validation of the CPS safe shutdown analysis was sufficient in depth and scope to ensure Appendix R separation and performance criteria would be met.

I b.2 Separation of Post-fire Safe Shutdown Functions The licensee developed three safe shutdown methods that could be used for achieving

safe shutdown depending on the location of the fire and the safe shutdown equipment , determined to be free of fire damage. These methods included the following components: , Method 1 . - This method would use Division 1 components and the Reactor Core Isolation Cooling , (RCIC) system with the steam turbine exhausting to the suppression pool. The residual . Heat Removal (RHR) system would be operated in the suppression pool cooling mode.

' in addition, several electrically operated SRVs would be used to control reactor vessel pressure and to depressurize to cold shutdow Method 2 i

This method would use manual actuation of the Division 2 Automatic Depressurization l System (ADS) valves to depressurize the reactor pressure vessel (RPV) to about 250 psig so that Low Pressure Coolant injection (LPCI) could provide RPV makeu The licensee's report, " Safe Shutdown Analysis for Fire Protection," dated February 1986, identified that this method would cause the top of active fuel (core) to become uncovered. In Supplement 6 to its Safety Evaluation Report (SSER), the NRC l reviewed General Electric (GE) analysis No. NEOD 24780A and determined that the core would be uncovered for a short duration of time, however, this short duration would not result in fuel damage. The SSER concluded that CPS use of this method was acceptabl i Method 3 This method would use Division 1 and 3 components. The High Pressure Core Spray (HPCS) system would be used with Division 1 SRVs and RHR Loop A used in the suppression pool cooling mode. For a cold shutdown, RHR Loop A would be used in the shutdown cooling mode along with Division 1 SRVs for reactor depressurizatio ,

I The inspectors evaluated 58 components associatec' with safe shutdown Methods 1,2 I and 3. These components, their required cables, and their physical fire zone / area j locations are summarized in Table 1 of this report. The inspectors used P&lD drawings j to determine the equipment needed to provide reactor water makeup for a post-fire I safe shutdown. Specifically, the inspectors reviewed the following P&lDs: l i l

- RCIC system drawing M05-1079, Sheet 1, Revision AE
- RCIC system drawing M05-1079, Sheet 2, Revision AB
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- HPCS system drawing M05-1074, Revision AD
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RHR system drawing M05-1075, Sheets 1,2,3, and 4, Revision AK, AD, Y, and AA, respectively Using these P&lDs, the inspectors verified that shutdown analysis logic diagrams CPS-SSD-LOG-101, Revision 0; CPS-SSD-LOG-102, Revision 0; and CPS-SSD-LOG-106, Revision 0, established an acceptable reactor water makeup path for the different shutdown methods. In addition, the inspectors confirmed that these logic diagrams properly identified components and/or control systems whose nie induced circuit failure (spurious operation) could prevent the operation or cause the maloperation of safe shutdown equiprnen The inspectors did not identify any Appendix R related separation concems associated with the components / safe shutdown methods reviewe b.3 Qircuit Analysis of Reauired Post-Fire Safe Shutdown Functions The inspectors reviewed the circuit analysis packages identified in Table 2 of this report. Specifically, the inspectors assessed the completeness and conservatism used by the licensee's circuit analysis methodolog The inspectors did not identify any concems associated with the methods used by the licensee to identify circuits / cables needed or associated with supporting or maintaining post-fire safe shutdown condition Post-Fire Safe Shutdown Operatina Procedures - The inspectors reviewed procedure CPS No. 4003.01, Revision 12, " Remote Shutdown (RS)," to ensure that operator actions and fire protection modifications identified during the licensee's safe shutdown re-analysis had been incorporated in the procedur The inspectors determined that procedure CPS No. 4003.01, Revision 12, did not incorporate all of the operator actions and equipment changes identified during the safe shutdown re-analysis. The procedure was in draft during the inspection. Also, since the procedure was in draft, the inspectors were unable to evaluate operator trainin Safety-Relief Valve (SRV) Sourious Operation The inspectors reviewed the licensee's actions in response to industry initiatives to resolve spurious SRV opening due to hot short The potential existed for a single fire to cause two spurious RPV high pressure signals due to hot shorts. Two pressure signal cabies were routed from containment to the MCR for each division. Each cable provided an output signal for one pressure transmitter. If the two wires in a cable should short, the logic circuit would interpret the output as a valid high-high reactor pressure signal. Each division contained a two-out-of-two, high-high pressure logic. Since both divisional pressure signal cables were routed in the same enclosed (solid metal bottom) tr sy, a single fire could affect the

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. j cable tray causing all 16 SRVs to open due to hot shorts. This could induce a severe ' plant transient.

~ In response, the licensee indicated that this transient could be mitigated by non-fire affected ECCS equipment for all plant areas outside of the MCR.

' For a MCR fire, the divisional cables enter their respective logic panels through the

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power generation control complex (PGCC) utilizing the under floor raceway. The raceway and respective logic panels were provided with smoke detectors. In addition, ! each panel was provided with a manual halon suppression system; however, the j detectors alarmed in the back panel area.

' The inspectors were concemed that the control room operators could have difficulty in identifying which raceway or panel had an alarming smoke detector. For a MCR fire, . the operators would have to recognize the fire and take immediate positive control (by . procedure) of the potentially affected SRV logics, such as inhibiting the logics to ! prevent spurious SRV opening. If the MCR had to be evacuated, the operators would

,  have to de-energize the SRVs in the switchgear rooms. The inspectors noted that j  emergency lighting was not installed in the Division 2 area where SRV control power
, de-energization would occu At the time of the inspection, the licensee had no written procedures and had not trained the operators on methods to mitigate or prevent fire induced spurious SRV openin Conclusions The inspectors concluded that the licensee's revised Appendix R re-validation project adequately demonstrated that the safe shutdown analysis met the plant's licensing basis. However, a number of licensee safe shutdown actions (e.g., completion of safe shutdown procedure reviews) remain to be completed before restart. These items could affect safe shutdown capability. Therefore, safe shutdown capability adequacy -

will remain open pending NRC review of additionallicensee corrective actions to resolve Case Specific Checklist Matrix (CSC) Item IV.5, prior to restar F2.2. IN 92-18 Hot Shorts Desian Chanae Reviews Insoection Scope The inspectors evaluated the licensee's efforts to prevent damage to safe shutdown MOVs as a result of spurious operation or maloperation due to fire induced hot short Observations and Findinas The NRC issued IN 92-18 on February 28,1992, to alert licensees to conditions that could lead to the loss of capability to maintain the reactor in a safe shutdown condition in the unlikely event that a MCR fire forced reactor operators to evacuate the control room. A fire in the MCR could induce hot shorts between energized circuits, such as valve position

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I , indication circuits, and the open/close circuits causing spurious MOV operation without  ? I limit / torque switch protection. The potential existed for safe shutdown MOVs to sustain mechanical damage before operator actions could be taken to remove electrical power from affected MOVs or transfer MOV control to the remote shutdown panel (RSP). This could result in control room operators being unable to manually reposition the valves, and impair the licensee's capability to achieve and maintain safe shutdown condition ' The licensee completed their IN 92-18 evaluation on July 14,1992. The evaluation determined that valve motor thermal overload protection devices were bypassed at Clinton i during normal plant operation. The evaluation concluded that safe shutdown could be obtained during an MCR fire due to CPS having either safe shutdown Method 1 or 2 available.

l During a Quality Assurance (QA) audit on June 19,1997, the auditors identified that the original IN 92-18 evaluation had used Power Generation Control Complex (PGCC) design i attributes, such as divisional separation, to conclude safe shutdown capability would not ; be impaired; however, the evaluation did not consider multiple cable to cable hot shorts i during a MCR fire. Fifty-four valves were identifiet y the licensee that could be damaged ! due to cable to cable fire induced hot shorts during a MCR fire rendering the valves incapable of manual operation. This was significant since the Clinton safe shutdown j procedure relied on operator manual valve manipulations. In response, the licensee i initiated CR 1-97-06-214, dated June 24,1997, and LER 97025, dated October 28,199 l 10 CFR 50, Appendix R, Section Ill.G.1, required that fire protection feabres be provided l to limit fire damage so that one train of systems necessary to achieve and maintain hot ' shutdown is free of fire damage. Section Ill.G.2 specified separation requirements for cables and equipment, including associated circuits, as a means of ensuring that one redundant train of safe shutdown equipment remains free of fire damage. The licensee identified 54 valves that were not adequately protected to ensure that they would remain free of fire damage due to fire induced hot shorts in the valve control circuitry. The failure to provide adequate measures to ensure one train of systems necessary to achieve and maintain hot shutdown is free of fire damage is a Severity Level (SL) Ill violation (VIO 50-461/98026-01) of 10 CFR 50, Appendix R, Ill.G.2. However, enforcement discretion was applied as discussed in the cover letter, MOV Hot Short Modifications The following valves (54) were identified as susceptible to fire induced hot shorts and were scheduled for modification: System Modification MOV Modification Status , RH-047 1E12-F003A Work Complete RH-047 1E12-F004A Work Complete RH-047 1E12-F009 Work Complete RH-047 1E12-F014A Work Complete ! i l I 9

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RH-047 1E12-F024A Work Complete RH-047 1E12-F027A Work Complete RH-047 1E12-F028A Work Complete RH-047 1E12-F037A Work Complete RH-047 1E12-F042A Work Complete RH-047 1E12-F047A Work Complete RH-047 1E12-F048A Work Complete RH-047 1E12-F053A Work Complete RH-047 1E12-F064A Work Complete RH-047 1E12-F068A Work Complete RH-048 1E12-F006A Work Complete RH-048 1E12-F006B Scheduled Start November 1998 RI-049 1E51-C002E Work Complete RI-049 1E51-F010 Work Complete RI-049 1E51-F013 Work in Progress RI-049 1E51-F019 Work in Progress RI-049 1E51-F022 Work in Progress Rl-049 1E51-F031 Work In Progress RI-049 1E51-F045 Work In Progress RI-049 1E51-F046 Scheduled Start October 1998 RI-049 1E51-F059 Scheduled Start November 1998 RI-049 1E51-F063 Scheduled Start October 1998 RI-049 1E51-F064 Scheduled Start November 1998 RI-049 1E51-F068 Scheduled Start November 1998 RI-049 1E51-F076 Scheduled Start October 1998 RI-049 1E51-F077 Work in Progress . RI-049 1E51-F078 Scheduled Start October 1998 l RI-049 1E51 F095 Work in Progress RT-039 1G33-F001 Work in Progress RT-039 1G33-F004 Work in Progress  !

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RT-039 1G33-F101 Work In Progress RT-039 1G33-F102 Work In Progress 1 FW-040 1821 r065A Work Complete FW-040 1821-F065B Scheduled Start December 1998 IA-021 11A-012A Work In Progress IA-021 ilA-013A Work Complete MS-044 1B21-F019 Work In Progress SX-048 1SX-003A Work Complete SX-048 1SX-004A Work Complete SX-048 1SX-008A Work Complete SX-048 1SX-011 A Work Complete SX-048 1SX-012A Work Complete SX-048 1SX-014A Work Complete SX-048 1SX-016A Work Complete SX-048 1SX-062A Work Complete SX-048 1SX-063A Work Complete SX-048 1SX-073A Work Complete SX-048 1SX-076A Work Complete

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_ , - - - - _ . - - - - . - - - - - _ - _ - - - - . - - . . . - - - . _ - SX-048 1SX-107A Work Complete SX-048 1SX-173A Work Complete The inspectors reviewed 20 Engineering Change Notice (ECN) design packages associated with the hot short modifications. The wiring changes were predominately performed at the MOV motor control center cubicles. The MOV open/close contactors were rewired between the limit / torque switches and the MCR control circuits. In some cases, transfer switches and fuses were installed to isolate the MOV control circuit from the MCR. This would provide local / emergency control for repositioning a valve during safe

 - shutdown recovery actions. Though a valve could spuriously reposition due to a fire induced MCR hot short following these modifications, the limit / torque switches would now

. protect the valve from mechanical damage. Using the safe shutdown procedure, the ! operators could remove power from the valve or isolate the MCR circuit via transfer switches allowing manual or electrical repositioning of the valve. The inspectors determined that the proposed modifications would correct the hot short concem described in IN 92-1 The inspectors observed the MCC cubicle and RSP wiring changes for MOVs ilA-012A and 1E51-F013. The changes were correctly installed per applicable design drawings, in , addition, the inspectors reviewed the electrical circuit checks and post modification testing l for MOV 1E51-F013. The tests performed satisfactorily overlapped unmodified portions of the valve control circui Enaineerina Review Standards The inspectors reviewed engineering standard No. GD (RS)-01.00, Revision 5, " Fire l Protection / Safe Shutdown Engineering Review Standard." The standard was revised with

the following steps added or changed in the safe shutdown engineering analysis applicability review questions
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Step 4.2.4.3 - Impact the SSD [ safe shutdown] circuit analysis for an SSD service (and its associated cables), by modifying its electrical schematics (EO2s), interlocks to/from other equipment, normal breaker position, normal power supply, or circuit failure modes?

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Step 4.2.4.8 - Create the potential for spurious operation of electrically energized equipment?

 - Step 4.2.2.9 - Add, delete, or affect a manual action necessary to achieve and maintain a post-fire safe shutdown?

The inspectors determined that appropriate steps were added to the review standard to ensure IN 92-18 concems would be addressed in the future. In addition, the inspectors determined that the licensee was appropriately reviewing other components, such as interlocks and permissives, to ensure that hot shorts would not affect safe shutdown capability.

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l i Conclusions ! A violation of NRC requirements was identified regarding the licensee's failure to ensure l that 54 MOVs would remain free of fire damage due to fire induced hot shorts in the

va!ves' control circuitry. However, enforcement discretion in accordance with the NRC's Enforcement Policy was exercised. The inspectors concluded that the licensee was implementing appropriate corrective actions (e.g., wiring modification at the MOV motor control center cubicles) to address these MOV hot short issues. Additionally,21 of the 54 MOVs still needed to be modified to correct the hot short issue. Therefore, the hot short issue for these 21 MOVs will remain open pending NRC review and verification that the modifications have been completed prior to restar F2.3 Thermo-Lao Desian Chanae Reviews Inspection Scope The inspectors reviewed the licensee's actions to resolve the technical issues associated l

with Thermo-Lag used as a fire barrier system for post-fire safe shutdown equipment

protection.

l Observations and Findinas In response to NRC Bulletin 92-01, " Failure of Thermo-Lag 330 Fire Barrier System," the licensee declared all installed Thermo-Lag electrical raceway fire barrier systems  ! inoperable in nine fire zones and established the appropriate compensatory measures,  ! such as fire watches. The licensee described their corrective actions to resolve Thermo-Lag fire barrier technical issues in CR 1-92-07-024. This resulted in six modification packages. Three modifications, FP-094, FP-097, and FP-098, will be installed before restart. The remaining modifications, FP-099, FP-100, and FP-101, were  ; included in a commitment to the NRC to be completed before the end of 199 I l The following options were selected by the licensee to resolve the Thermo-Lag fire barrier technicalissues: ! Fire Zone C2 (containment) Replace Thermo-Lag with fully qualified firebreak / radiant heat shield materia Fire Zones CB-4, CB-Sa, CB-1g Reroute circuits / cables out of the fire zone / area of concem.

i !. Fire Zones CB-8, A-ia Replace Thermo-Lag with a conventional fire barrier l material.

l Fire Zone D-8 Credit offsite power for non-altemate shutdown area.

l l Fire Zone CB-1e Upgrade the 1-hour Thermo-Lag raceway fire barrier

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system to fully meet the required 1-hour fire resistive i rating.

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_ _____ . _ _ _ . . . _ _ _ _ . _ _ . _ _ _ _ _ -_ _ _ _ __. _ Fire Zone CB-1f Upgrade the Thermo-Lag raceway fire barrier system to fully meet the required 1-hour fire resistive rating, i add a area sprinkler system and use fire rated cabl l The inspectors reviewed portions of the containment firebreak replacement and proposed  ! Fire Zone CB-if Thermo-Lag fire barrier upgrade modification ! b.1 Containment Firebreak Replacement I Modification FP-097 replaced the fire break / radiant energy heat shield material inside containment. The revised design required cable trays P2E, C2E, and K2E to be protected l with a fully qualified 3M E-54C 1-hour fire rated design with a minimum of three E-54C ' layers to be applied to each cable tray. The specific design and construction attributes  ! used were described on Promatec Technologies Inc., vendor drawing Nos. PSI-3061, i Sheets 1 and 2, Revision 4; PSI-3063, Sheets 1,2, and 3, Revision 3; PSI-3901 CPS, I Sheet 1, Revision 0; PSI-3902 CPS, Sheet 1, Revision 2; PSI-3905 CPS, Sheet 1, Revision 0; and PSI-3909, Sheet 1, Revision 0. The inspectors performed a material's  ! combustibility review for this assembl The inspectors reviewed the licensee's combustibility assessment for 3M product line E-54C firebreak / radiant energy heat shield, dated October 23,1998. The material consisted of an Alumina Tri-hydrate and Aluminum Silicate mat with a stainless steel foil covering attached to the mat with an organic adhesive. The NRC considered fire barrier material to be noncombustible if it exhibited the following behavior when subjected to a fire environment:

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Material which, in the form it was used and under the conditions anticipated, will not ignite, bum, support combustion, or release flammable vapors when subjected to fire or heat (generally demonstrated by subjecting a sample to an ASTM E-136 Test).

- Material having a noncombustible material structmal base with a surface less than

 %-inch thick that had a flame spread rating less tmn 50 when measured in accordance with ASTM-E8 j in order to demonstrate the fire behavior of this material, the vendor subjected the material to an ASTM E-136 test, " Standard Test Method for Behavior of Material in a Vertical Tube Fumace at 750'C." This test was conducted at Omega Point Labs, Cypress, Texas, for Peak Seals, Inc. The Omega Point test report, dated January 17,1995, demonstrated that the base material (E-54C without the foil) was noncombustible. In order to evaluate the composite material (E-54C with the foil), the licensee used the ASTM E-84, " Standard Method for Surface Buming Characteristics of Building Material," test results documented by Underwriters Laboratories (UL). This test was conducted for 3M and documented in UL report R10125, dated September 26,1983. Underwriters Laboratories tested 3M E-50 material (E-50 material is the same as E-54) with the stainless steel foil covering. The flame spread was 0.7. The inspectors determined that the licensee's combustibility assessment adequately demonstrated that the 3M material used inside containment was noncombustibl ,
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i assessment adequately demonstrated that the 3M material used inside containment was noncombustible, b.2 Thermo-Laa Fire Barrier Uparades Proposed for Fire Zone CB-1f The licensee initiated Modification FP-100 to install a new sprinkler system and upgrade the existing Thermo-Lag fire barrier systems in Fire Zone CB-1f. At the time of this inspection, the sprinkler system installation and fire barrier upgrade designs were being fir alized, installation was expected to be completed by the end of 199 me inspectors walked down Fire Zone CB-1f and selected the Thermo-Lag raceway fire barrier installed along column line 129/AC for further review. This fire barrier system was similar to a cable vault and enclosed three 24"x12" cable tray risers (P2E, C2E and K2E)

in a common enclosure. The inspectors reviewed calculation IP-M0340, Rev.1, Vol A,

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    " Fire Endurance Evaluation of Thermo-Lag Fire Barriers in Fire Zone CB-if." Several concerns were noted including the adequacy of the evaluation, the basis for the current
fire resistant rating, and the rating of this barrier assembly once it was upgraded. The l following technical concems were identified:
    . The actual construction methods used to assemble the existing fire barrier system were unknow . The evaluation referenced Nuclear Electric Institute and Tennessee Valley l     Authority test results that contained a failed junction box test.

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    . The Tennessee Valley Authority test used a superstructure to support the Thermo-l     Lag panels and a U-shaped 38"x52"x48" common enclosure for the tested

! configuration. The licensee's installed configuration contained a front surface (126 l ft*) that was constructed from multiple panels with intersecting seams and no i i superstructure to support the panels.

l The team determined that the installed 216"x84"x18" configuration was not bounded by i- the referenced tests, in addition, the inspectors noted that the evaluation did not address l the cable tray transition from a common cable tray riser enclosure to separate trays.

l Therefore, the inspectors could not determine if the installed enclosure would have a l 1-hour fire resistant rating. This issue was under review by the license ;

l Conclusions The inspectors concluded that the fire barrier material used to replace the Thermo-Lag l inside containment met NRC fire protection guidance. From a limited review of the l Thermo-Lag upgrades in Fire Zone CB-1f, the inspectors could not determine if the cable L vault fire barrier assemblies could be upgraded to a 1-hour fire barrier and be bounded by ' industry fire barrier test reports. Therefore, the Thermo-Lag upgrade program will remain open pending NRC review of additional licensee corrective actions to resolve this issue.

!

14  ! l l

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l

          !

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - , _ _ _ _ . _ - _ _ , , _

- - - . - ~ - _ _ . - . - ._. - __._ - . - . - - - - _ . . -_ - --
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l . I F Fira-Rated Whittaker Cable

! Insoection Scope The inspectors reviewed the fire test reports for the installed Whittaker cables to ensure that the cable providing safe shutdown inverter power would perform as required for a fire

, in Fire Area CB-4.

, i Observations and Findinas j

I i The inspectors reviewed the Whittaker cable fire testing documentation and noted that the I
fire exposure tests did not test the cable supports. In addition, there was no hose stream test conducted on the cables subsequent to the fire test, and the fire heat up rate was much slower than described in the test standards. The inspectors determined that the tested cable characteristics were not representative of the installed configuration.
In response, the licensee began acquisition of additional test information from other

, industry sources and the manufacturer. This test data was not available for review during I , this inspection. However, the licensee indicated that the safe shutdown method for this j fire area was being re-analyzed and it was their opinion that the affected cables may not be required for safe shutdown.

Conclusions
!

' The inspectors concluded that the Whittaker cable test documentation was not adequate i to demonstrate that the installed fire-rated cables were equivalent to protecting the cables

with a rated fire barrier. In addition, the licensee had not requested from the NRC a deviation for the installation of an unreviewed fire barrier system as described in GL 86-1 . Therefore, Whittaker cable adequacy as a fire barrier system will remain open pending l NRC review of adddionallicensee actions to resolve this issu F2.5 Automatic Sprinkler Protection For Risk Sensitive Fire Areas Inspection Scope The inspectors reviewed the fire suppression system installation in Divisions 1 and 2 cable spreading rooms 6ad in the Division 3 switchgear room. The licensee's Individual Plant Examination - Extemal Events (IPEEE) credited automatic fire suppression for these fire areas and reduced the core damage frequency (CDF) by a factor of 266. The sprinklers were inspected for obstructions to ensure that they were installed in accordance with National Fire Protection Association (NFPA) 1 Observation and Findinas The inspectors observed that the sprinklers in Fire Areas CB-2, CB-4, and CB-3a (top 3 risk areas noted in the IPEEE) were obstructed by plant equipment located below the sprinkler heads. The potential existed for the sprinkler system to be incapable of controlling a fire anywhere within the fire are . . _. - - - . - - - - - - - - -.-_ - .- - - - . - -.- a

       ,

i l . The sprinkler systems in Fire Areas A-1b and CB 1e were needed to protect redundant l l safe shutdown trains located within the same fire area. Modification FP-099 (CB-1e) was initiated to improve the sprinkler system design and to address the obstructions. The licensee had identified other obstructed sprinkler heads. The corrective actions for these l areas were documented on CR 1-97-06-215-0. These obstructions were being reviewed

       '

by the engineering staff; however, the engineering staff evaluations justified the existing ceiling level sprinklers with obstructions as being acceptable. The inspectors were concemed that the installed sprinkler systems may be incapable of suppressing a fir ' In response, the licensee indicated that the obstructed sprinkler system reviews had not been completed and that the inspectors' concems would be evaluated, Conclusion The inspectors concluded that, due to obstructions, the licensee's installed sprinkler systems may be incapable of suppressing a fire in risk significant fire areas. Therefore, sprinkler system adequacy will remain open pending NRC review of additional licensee actions to resolve this issu F8 Miscellaneous Fire Protection issues F8.1 (Closed) LER 50-461/97006-00 and 01: The licensee identified on February 19,1997, that one non-safe shutdown load breaker for each of three (3) 120 volt distribution panels did not coordinate with the upstream 480 volt transformer feed breaker. The problem existed for motor control centers 1B1,1 AP75E; MCC H, OAP57E; and MCC 1 Ai, 1 AP72E. The coordination problem could only occur for a line-to-line fault that occurred at the distribution panel. Therefore, this condition was unlikely to occur. In addition, the distribution panels were divisionally separated and were located in different fire areas. In the event of a fire at any one of the three distribution panels, there existed at least one method to achieve and maintain safe shutdown conditions. The licensee replaced the feeder breakes with ones that coordinated with the downstream load breakers. This item is close i F8.2 (Closed) LER 50-461/97019: The licensee identified on July 9,1997, that the control circuit for Division 1 essential switchgear heat removal system supply air fan discharge damper,1VX03YA, would not be free of fire damage when using the RSP. Specifically, < I the control circuit was routed through the MCR to provide operators with damper position indication. A MCR fire could cause the operators to evacuate to the RSP. A hot short

   .    !

could open the control circuit fuse preventing the damper from automatically opening to ' provide a discharge flow path for the supply air fan. Due to the loss of power to the damper hydro-motor, there would be no capability to transfer control of this damper to the RSP in the event of a MCR fire. Even though essential switchgear heat removal Divisions 2 and 3 were available, these systems were not credited as safe shutdown systems for a MCR fir This lack of Division 1 switchgear room, battery room, inverter room, and cable spreading area ventilation could result in increased room temperatures and hydrogen buildup in the battery room. This could exceed room design ratings and affect safe shutdown Method

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l

No.1 recovery. Therefore, the ability to achieve and maintain safe shutdown conditions could be adversely affecte CFR 50, Appenaix R, Section Ill.G.3, required, in part, that attemative or dedicated t shutdown capability and its associated circuits, independent of cables, systems, er components in the area, room or zone under consideration be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph lit.G.2. Section Ill.L.7, required, in part, that safe shutdown equipment and systems for each fire area be known to be isolated from associated ! non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment. The ' failure to electrically isolate essential switchgear heat removal system supply fan damper 1VXO3YA RSP control switch from the MCR is considered a SL lil violation of 10 CFR 50, Appendix R, Section Ill.L (VIO 50-461/98026-02a). However, enforcement discretion was applied as discussed in the cover lette The licensee initiated ECN 30254 and installed an additional fuse in the damper control ' circuit. For an MCR hot short, the MCR fuse would open; however, power to operate the damper would be available through the remote ft 3e. Therefore, this condition was I resolved and is close I I F8.3 (Open) LER 50-461/98021: Medium and high density silicone penetration seals did not l l meet their design basis due to crack formation from thermal expansion and contractio The seal design documentation did not incorporate the correct coefficient of thermal expansion for the sealant material. In February 1998, the licensee identified cracks in l penetration seal DG-762-01-5003. This seal was located in the floor of the Division 3 EDG HVAC fan room intake plenum. The cracks were attributed to sealant material shrinkage. Vendor literature stated, in part, that the sealant material had a notable volume coefficient of thermal expansion which resulted in the cured sealant material increasing or decreasing in volume approximately 8% for each 100*C of temperature differential. The ; licensee indicated that the curing temperature at the time of initial installation may not I have been properly controlled and the sealant material may have cured at a higher

       ]

temperature. The cracks observed in the penetration during February 1998, had ' disappeared in June 1998, due to warmer temperatures (this penetration was exposed to ; outdoor temperatures). ' As of October 22,1998, the licensee had inspected 358 of 359 safety related penetration seals and identified 66 degraded seals. Forty-five seats were repaired by removing the I defective portions of the seals and refilling with new sealant material. Licensee

       '

inspections revealed that large block-out or partitioned penetration seals were especially susceptible to thermal expansion or contraction. The licensee added a comment form to

       )

the installation procedure requiring the curing process to be maintained at the average I temperature between the high and low temperatures that the seal would be exposed t I l The above penetration seal was 54"x60"x18" in size and was used to cover (seat) an opening containing a 24-inch carbon steel pipe. The seal was partitioned with Marinite (M)-boards into four smaller areas with the pipe in the middle. The licensee indicated that the installation was according to detail drawing No.102. However, the detail drawing

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_ _ _ _ . . _ - . _ _ . _ _ _ _ . _ . - . _ _ . _ _ _ _ _ _ ...._ .___. __.__ l l configuration used concrete as the barrier material to cover a 30"x30" ft - ar wall opening containing a 6-inch pipe. This was different than the installed configurabon. In addition, concrete has better heat sink capabilities than M-board when exposed to a fire. The inspectors determined that the installed configuration of penetration seal DG-762-01-5003 was not supported by detail drawing No.10 l The licensee indicated that detail drawing No.102 was developed based on BISCO fire ' test report Nos. 748-63A and 748-175. Fire test report 748-63A discussed a fire barrier test on a 48"x48"x12" concrete test slab with the following components penetrating the seal: l

 . 6-inch oil base coated pipe thru a 12-inch epoxy coated steel sleeve with 1-inch ceramic board dam on the fire exposed side. This penetration was filled to a depth of 12-inches with BISCO SF-2 . 6-inch conduit, 50% cross-sectional area filled with instrumentation, control and
         '

power cables thru a 12-inch steel sleeve. This penetration was filled with 5-inches of BISCO SF-60 in both th., annular gap and conduit interio . 4-inch flexible conduit passing through a 6-inch sleeve. This penetration was filled with 9-inches of BISCO SF-20 and a 1-inch ceramic board dam was installed on the fire exposed sid l

         '
 . 6-inch conduit, 50% cross-sectional area filled with instrumentation, control and power cables passing through a 12-inch opening. This penetration was filled with 5-inches of BISCO SF-60 at the annular gap and 8-inches of BISCO SF-60 in the condui Fire test report 748-175, dated November 28,1984, discussed a fire test configuration for a 3-hour rated BISCO SF-60 seal. The barrier test was performed on a 48"x48"x12" concrete slab with a 30"x30" clear opening. A 4-inch pipe was placed 2%" and 14" away from two sides of the opening and filled with 5-inches of BISCO SF-6 Both fire tests were completed with satisfactory results. However, penetration seal DG-762-01-5003 was not bounded by these two test reports since the tests did not use partitioned penetration seals. During a walkdown, the inspectors noted other large block-out walls containing various penetrating materials. Penetration seals CB-781-20-4003 and TB-762-01-3001 were also evaluated. The fire test reports supporting their design were 748-100 and 748-105. However, the two reports did not contain tested configurations representative of the plant's as-built configurations. In addition, ASTM-E119 specified a

partition wall size that was to be no less than 100 ft However, the test reports reviewed did not indicate test sample siz The licensee recognized that several large block-out or partitioned walls could not be supported by fire test reports, in October 1997, the licensee initiated a penetrations seal upgrade program to review and reconstruct critical penetration seal design parameter Field surveys were also started in January 1998 to gather the required dimensional data for each seal. The penetration seats that were not bounded by test reports were sent

_ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . - _ . _ _ _ i offsite for engineering evaluation. The current schedule for completing the penetration i seal upgrade program was May 1999. This item will remain open pending NRC review of l

       '

the bounding fire test reports for penetration seals DG-762-01-5003, CB-781-20-4003, and TB-762-01-3001. The inspectors concluded that this item was not a restart issue because the sealant material expands at an exponential rate when exposed to hea Therefore, the seals would re-seal quickly under fire condition F (Closed) LER 50-461/98013: The licensee identified, on March 25,1998, that two cables

       '

in the control circuits for the RCIC turbine could not be isolated from the MCR when operating RCIC at the RSP. Cables 1Rl85B and 1Rl85C were routed from the RSP to the l MCR. Cable 1Rl85C was connected to the flow control input at signal converter 1E510N590. Damage to this cable could cause a short circuit disabling RCIC due to l unstable flow control or result in flow controller damage. Cable 1Rl858 was connected to ! RCIC turbine speed control box 1E51-N591. A short circuit could disable RCIC turbine l speed indication at the RSP. Loss of RCIC turbine speed indication could affect the operators' ability to monitor turbine performanc CFR 50, Apperdix R, Section Ill.G.3, required, in part, that alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems, or components in the area, room or zone under consideration be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph lli.G.2. Section Ill.L.7, required, in part, that safe shutdown equipment and systems for each fire area be known to be isolated from associated i non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in ' the associated circuits will not prevent operation of the safe shutdown equipment. The failure to provide RCIC control circuit isolation between the MCR and the RSP for a MCR fire is an example of a SL ll1 violation of 10 CFR 50, Appendix R, Section Il (VIO 50-461/98026-02b). However, enforcement discretion in accordance with the NRC's l Enforcement Policy was applied, as discussed in the cover lette The licensee initiated ECN 30968 to add spare isolation contacts to cable 1Rl858 circuits and to rewire cable 1Rl85C circuits. This modification was scheduled to be completed before restart. This item is close F8.5 (Closed) LER 50-461/97021: The licensee identified on August 25,1997, that control cable 1DG11U circuits had been routed to the MCR without an isolation contact at the RSP. This control cable carried control power to Division 1 EDG output breaker 252-DG1KA and to offsite source permissive hand switch 1HS-DG214. For a postulated fire in the MCR and a loss of offsite power, this circuit could ground and cause a loss of control power for the EDG output breake The Division 1 EDG was the credited trairi for a MCR fire. In addition, the EDG would receive an automatic start signal for a loss of offsite power. However, the EDG output breaker would not automatically respond due to the loss of control power. Operators could readily identify that the EDG output breaker did not close. However, the operators would have to verify that an electrical fault did not exist on the safe shutdown electrical t bus and that all feed breakers had opened prior to manually closing the EDG output i

_ _ _ _ _ __ _ _ _ _

, breaker. The licensee indicated that there were no procedures describing the steps required to troubleshoot the EDG output breaker's failure to close.

l 10 CFR 50, Appendix R, Section Ill.G.1, required, in part, that fire protection features be l provided for systems important to safe shutdown so that one train of systems necessary to ' achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage.10 CFR 50, Appendix R, Section Ill.G.3, required, in part, that altemative or dedicated shutdown capability and its associated circuits, independent of cables, systems, or components in the area, room or zone under consideration be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph lil.G.2.10 CFR 50, Appendix R, Section Ill.L.7, required, in part, that safe shutdown equipment and systems for each i fire area be known to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment. The failure to provide Division 1 EDG control circuit isolation between the MCR and the RSP for a MCR fire is an example of a SL lli i ' violation of 10 CFR 50, Appendix R, Section Ill.L (VIO 50-461/98026-02c). However, enforcement discretion in accordance with the NRC's Enforcement Policy was applied, as discussed in the coverlette The licensee initiated ECN 30352 to add isolation contacts for hand switch 1HS-DG214 to prevent a MCR fire from causing DC control power loss to the Division 1 EDG output breaker. This modification was completed on August 6,1997. This item is close F8.6 (Closed) LER 50-461-97025: Potential MOV damages as described in IN 92-18. This item was discussed in detail in Section F2.2 and is close V. Manaaement Meetinas i X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on October 30,1998. The licensee acknowledged the findings presented. The inspectors questioned the licensee to determine whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie ! I l l

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i i

1 _ _ . _ . ._. . . , . _- _ . _ . . _ _ _ _ . . _.

l l 4 PERSONS CONTACTED Licensee K. Baker, Director- Support Engineering R. Bhat, Fire Protection W. Bousquet, Director -' Plant Support Services B. Ford, Fire Protection l J. Hanson, Director - Nuclear Training ! G. Hunger, Manager- Clinton Power Station D. MacDougall, Fire Protection W. MacFarland, IV - Chief Nuclear Officer  ! W. Maguire, Director- Uperations l E. Patel, Director- Project Engineering l R, Phares, Manager- Nuclear Safety and Performance Improvement W. Romberg, Manager - Nuclear Station Engineering Department J. Sipek, Director- Licensing M. Stickney, Suporvisor - Regional Regulatory Interface l M. Stookey, Licensing i J. Taylor, Director - Administration I ' NRC R. Gardner, Chief, Engineering Specialist Branch 2 K. Stoedter, Resident inspector ! INSPECTION PROCEDURE USED IP 92904: Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED

' Opened 50-461/98026-01 VIO Enforcement Discretion per Vll.B.2: Potential MOV damages as described in IN 92-1 /98026-02a VIO Enforcement Discretion per Vll.B.2: Switchgear heat removal system fan discharge damper control circuit was routed through the MCR and could fail during a MCR fir /98026-02b VlO Enforcement Discretion per Vll.B.2: A lack of circuit isolation at the RSP may effect RCIC operation during a MCR fire, i l 21

I

      ,

50-461/98026-02c VIO Enforcement Discretion per Vll.B.2: Control circuit for Division 1 EDG output breaker did not meet design basis due i to a design error.

Closed  ! i l 50-461/97006-00 and 01 LER 120 volt non-safe shutdown circuit breakers in distribution panels with safe shutdown circuit breakers lacked I coordination.

50-461/97019 LER Switchgear heat removal system fan discharge damper control circuit was routed through the MCR and could fail during a MCR fire.

50-461/98013 LER A lack of circuit isolation at the RSP may effect RCIC operation during a MCR fire.

50-461/97021 LER Control circuit for Division i EDG output breaker did j

      '

not meet design basis due to a design error.

50-461/97025 LER Potential MOV damages as described in IN 92-1 ) 50-461/98026-01 VIO Enforcement Discretion per Vll.B.2: Potential MOV damages as described in IN 92-1 l

50-461/98026-02a VIO Enforcement Discretion per Vll.B.2: Switchgear heat removal system fan discharge damper control circuit was routed through the MCR and could fait during a MCR fir i 50-461/98026-02b VIO Enforcement Discretion per Vll.B.2: A lack of circuit isolation ! at the RSP may effect RCIC operation during a MCR fire.

50-461/98026-02c VIO Enforcement Discretion per Vll.B.2: Control circuit for l Division 1 EDG output breaker did not meet design basis due 1 to a design error.

Discussed NRC CSC ltem I Resolve Fire Protection Safe Shutdown Concerns.

50-461/98021 LER Medium and high density silicone penetration seals did not meet their design basis due to crack formation from thermal expansion and contractio . _ - . . .

i LIST OF ACRONYMS AC Alternating Current ASTM American Society for Testing and Materials CDF Core Damage Frequency CFR Code of Federal Regulation CPS Clinton Power Station CR- Condition Report D Direct Current DRS Division of Reactor Safety-GE General Electric GL NRC Generic Letter ECN Engineering Change Notice EDG Emergency Diesel Generator eel Escalated Enforcement item FPPFE Fire Protection Plan for Excellence GE General Electric GL Generic Letter HPCS High Pressure Core Spray HVAC Heating, Ventuation, and Air Conditioning IN NRC Information Notice IP . Illinois Power Company IPEEE Individual Plant Examination-Extemal Events LER Licensee Event Report LPCI Low Pressure Coolant injection M Marinite Board MCC- Motor Control Center MCR Main Control Center MOV Motor Operated Valve NEl Nuclear Electric Institute NFPA National Fire Protection Association NSE Nuclear Station Engineering Departments P&lD Piping and Instrumentation Diagram PFE Plan for Excellence-QA Quality Assurance RCIC Reactor Core and Isolation Cooling RCS Reactor Coolant System RHR Residual Heat Removal RPV Reactor Pressure Vessel RSP Remote Shutdown Panel RWCU Reactor Water Cleanup SET Special Evaluation Team SRV Safety Relief Valve SS Safe Shutdown Analysis SSD Safe Shutdown SSER Safety Evaluation Report UL Underwriter Laboratory USAR Updated Safety Analysis Report

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_ __ __ _ _ _ _ . . _ . . . _ _ _ _ _ . _ _ _ _ _ . _ . - . _ _ _ _ _ _ _ . _ _ __ PARTIAL LIST OF DOCUMENTS REVIEWED MOV Hot Short Documentation NRC Information Notice (IN) 92-18, " Potential for Loss of Remote Shutdown Capability During a Control Room Fire" Condition Report (CR) No. 197-06-214, "Information Notice 92-18 Response is inappropriate" Licensee Event Report (LER) No. 97025, " Design Deficiency Results in Plant Being Outside Design Basis for a Fire in the Main Control Room Potentially Damaging Valves Required for Safe Shutdown of the Plant" Calculation No.19-BD-38, " Failure Modes & Effects of MOVs Control Circuits Modified for NRC IN 92-18 Resolution" Calculation No. IP-Q-0402, " Seismic Evaluation of Electrical Devices for Use in Motor Control Center [MCC) 1AP74E"

. Calculation No.19-AJ-71, " Evaluation to Determine Voltage at the MCC Buses to Ensure l that the End Device Fed from MCC Bucket Control Transformers will Operate" l Nuclear Station Engineering Standard No. GD (RS)-01.00, " Fire Protection / Safe Shutdown l

' Engineering Review Standard" Electrical Engineering Review Standard No. GD (RS)-08.00, " Electrical Engineering Review Standard" Sargent & Lundy (S&L) Standard No. STD-EA-205, " Installation & Termination of Control

 & Instrumentation Cables and Wires" l 1 General Electric (GE) Specification No. 272A7917, " Purchase Part Wire, TEFZEL" l 1 Clinton Power Station (CPS) Drawing Nos.:

l E02-1CC99, Sheet 4, "Comoonent Cooling Water System Fuel Pool Cooling Heat ! Exchanger 1 A CCW Inlet Valve 1CC075A & 1CC076A" l ' E02-1RH99, Sheet 13, " Residual Heat Removal System (NSPS)" E02-1Rl99, Sheet 9, " Reactor Core Isolation Cooling System (RI)" E02-1RS99, Sheets 3,104 and 107, " Remote Shutdown System (RS)" E03-1C61-P001, Sheet 9, " BOP [ Balance of Plant) Shutdown VB" E03-1 AP00, "Intemal Wiring Diagram Motor Cont. Center Starter and Mis. Details" 1 CPS Procedures Reviewed: CPS No. 9027.01, " Remote Shutdown Panel Operability Check" CPS No. 9027.01C002, "RSP Operability - RCIC Checklist" i CPS No. 9054.02, " Reactor Core isolation Cooling Valve Operability Checks" l CPS No. 9054.02D001, "RCIC Valve Operability Data Sheet" l CPS No. 9381.01, "MOV Thermal Overload Bypass Verification" l 1 Maintenance Work Request (MWR) No. D82004, "MOV [1E51-F013] is Susceptible to Fire induced Hot Shorts in its Control Cable" , ' 1 Engineering Change Notice (ECN) Nos. for Hardware Change No. RH-047: ECN 30491 - MOV 1E12-F004A ECN 30496 - MOV 1E12-F024A ECN 30501 - MOV 1E12-F042A 1 Hardware Change No. RI-049: l ECN 30467 - MOV 1E51-F010

ECN 30468 - MOV 1E51-F013
ECN 30469 - MOV 1E51-F019 j;

l 24 l . __ _ _ ._ . ._ _ _ _ _

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ECN 30476 - MOV 1E51-F064 1 . Hardware Change No. SX-048: ECN 30327 - MOV 1SX014A ECN 30979 - MOV 1SX012A ECN 30980- MOV 1SXO62A 1 Hardware Change No. MS-044: ECN 30670 - MOV 1821-F019 ECN 30999 - Miscellaneous Wiring Changes ECN 31005 and 31046 - Fuse Holder Installation ECN 31072 - Panel Wiring 1 Hardware Change No. FW-040: ECN 30671 - MOV 1821-F065A ECN 30776 - MOV 1821-F065B _1 Hardware Change No. lA-021: ECN 30868 - MOV ilA012A 2 Hardware Change No. RT-039: . ECN 30465 - MOV 1G33-F004 2 Hardware Change No. RH-048: ECN 30492 - Interlock Changes to MOVs 1E12-F004A, F006A and F024A Safe Shutdown Capability Documentation Safe Shutdown Analysis for Fire Protection, Amendment 1, February 1986 CPS Fire Protection Appendix R Safe Shutdown Compliance Summary Report, Revision 2, dated October 29,1998 - USAR, Appendix F, Table FA-1, Potential Spurious Valve Operations that Could Affect Safe Shutdown M Fire Barrier Material Combustibility Assessment, dated October 23,1998 Underwriters' Laboratories, Inc., Report R10125, dated September 26,1983 ASTM E-136, " Standard Test Method for Behavior of Material in a Vertical Tube Fumace at 750'C, Test of 3M E- 50 Fire Barrier Material, Omega Point Labs, January 17,1995 Calculation IP-M0340, Fire Endurance Evaluation of Thermo-Lag Fire Barriers in Fire Zone CB-1f, Rev.1, Vol A CPS No. 4003.01, Remote Shutdown (RS), Revision 12, dated December 18,199 . Piping and instrument Drawings: Reactor Core isolation Cooling System drawing M05-1079, Sheet 1 Rev. AE, Reactor Core Isolation Cooling System drawing M05-1079, Sheet 2, Rev. AD High Pressure Core Spray System drawing M05-1074, Rev. AD Residual Heat Removal System drawing M05-1075 Sheets 1,2,3, and 4, Rev. AK, AD, Y, and AA respectivel . Single Line Diagrams: E02-1NB99, SHEET 120, REV. F E02-1NB99, SHEET 109, REV. E E02-1NB99, SHEET 110, REV. E

- E02-1NB99, SHEET 112, REV. G E02-1NB99, SHEET 113, REV. E E02-1NB99, SHEET 114, REV. E E02-1RP99, SHEET 004, REV. L

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E02-1NB99, SHEET 121, REV. E  ! E02-1NB99, SHEET 110, REV. E E02-1NB99, SHEET iii, REV. E

' E02-1NB99, SHEET 114, REV. E       i
. E02-1NB99, SHEET 115,- REV. F E02-1NB99, SHEET 116, REV F E02-1RP99, SHEET 004, REV. L E02-1 AP03, REV. J E02-1 AP12, SHEET 011, REV. Y E02-1AP099, SHEET 023, RE E02-1 AP99, SHEET 038, REV. V E02-1NB99, SHEET 113, REV.' E E02-1Rl99, SHEET 009, REV. K E02-1Rl99, SHEET 506, REV. J E03-1DC13E, SHEET 004, REV. N E02-1RS99, SHEET 105, REV. F E02-1SX99, SHEET 001, REV. AA E03-1 AP07ED, SHEET 001, REV. R
. E02-1RH99, SHEET 508, REV. F E02-1RH99, SHEET 013, REV. K E03-1RH00, SHEET 004, REV. J E02-1 AP76E, SHEET 010, REV. J E03-1 AP94E, SHEET 005, REV. F      l 1 SSA Logic Diagrams:

CPS-SSD-LOG-101, Rev. 0 l CPS-SSD-LOG-102, Rev. O CPS-SSD-LOG-106, Re ; 1 Vendor Raceway Fire Barrier Drawings PSI-3061 Sheets 1 and 2, Rev. 4 PSI-3063, Sheets 1,2, and 3, Rev. 3 PSI-3901 CPS, Sheet 1, Rev. O PSI-3902 CPS, Sneet 1, Rev 2 PSI- 3905 CPS, Sheet 1, Rev. O PSI-3909, Sheet 1 Rev. O.

. L 26

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I l l , TABLE 1 SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES Shutdown Method Post-fire Safe Required Fire Zone Locations of Shu'.down Component Cables Component / Cable , _ RCIC Turbine Speed 1Rl76C A1-1 A, A1-B, A-2K, CB-4, CB-6A

 : Control Square Root 1RI76E
 ? Converter  1Rl85C 1RSO4A RCIC Storage Tank Level 1RS06B A-2N, A-1B, A-2D, A-2K, F-1M
 - Transmitter F-1 1RS77C i

RCIC Turbine Speed 1RSO4A A-2N, A 1 A, A-18, A-2K, CB-4, CB-Control- Flow 1RI76C 6A 1Rl76E

 ;7

_ 1Rl85C l RCIC Turbine Speed 1RSO4A A-2N, A-1 A, A 18, A-2K, CB-4, CB- , Control Flow Indicator 1Rl76C 6A l I . 1R176E 1Rl85C  ! , RCIC Turbine Speed 1RSO4A A-2N, A 1 A, A-1B, A-2K, CB-4, CB- 1 Indication 1Rl24J 6A l 1Rl76C l 1Rl858 l RCIC Storage Tank Level 1RS068 A-2N, A-1B, A-2D, A-2K, F-1M Indicator 1RS77C RCIC Turbine 1R124C A-1 A, A-1B, A-2A, A-2K, A-2N, CB-4,

 '

1Rl24G CB-6A g 1Rl24H 1Rl24J 1Rj24K 1Rl76A 1Rl76B 1Rl76C 1 1Rl76F 1R!84A 1Rl848

,
- .   .. .. -
   . . - . .- . . - -. . . . . - - . . - _ . . -

l

        !

l

!
TABLE 1 l SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES
'

l Shutdown Method Post fire Safe Required Fire Zone Locations of I Shutdown Component Cables Component / Cable

 -
 -

RCIC Turbine Trip Throttle 1R126A A-1A, A-18, A-2A, A-2K, A-2N, CB4, Valve 1Rl26B CB4A - MZ 1R126C 1R126D

 -

1R126E , 2P 1R126G J ' 1R126H l g 1Rl26J - ' g 1Rl26K _- 1R127F _ g_ - 1R127G  ;

-= _'N
  , RCIC Turbine Trip Throttle 1RSO4A A-2A, A-2N Valve - Continued     .

. M

-
        '
, -  RCIC Steam Seal  1DC01J A-1 A, A 1B, A-2A, A-2K, A-2N, CB-4, l M_  Compressor  1R125A Cl34A M   1Rl25B    l j~_   1Rl25C 1R125D i

m- 1R125E ' N 1Rl25F

~

1RS04A e = _ -- - l J RCIC Turbine Exhaust 1R109A J -1 A, A-1B, A-2A, A-2K, A-2N, A-3F, ! M Drain isolation Valves 1R118C CB-1C, CB-1D, CB-1E, CB-1F, CB-2, _N-____ 1R118F CB-4, CB4A , 4 _d 1Rl18G j h 1R119C ' 1R119F 1Rl23A

 - -   1Rl238 M-
 -

1R123E 1 ~M . M RCIC Pump Suction Com 1R104A A-1 A, A-1B, A-2A, A-2K, A-2N, CB-4,

-

M Condensite Storage Tank 1Rl048 CB4A j M- Valve 1Rl04C  ; N 1R104D l l

1R104E

'

 --

1R1088 1R108C-4 __ 1Rl080 1R123A ' 1R127F i

-E-)- .

1Rl27G 1Rl270 k

_ _ _ _ _ . . . . _ . _ . . . _ . _ _ _ _ _ _ _ _ . . . . . . . _ _ _ _ _ . _ . _ _ _ _ . _ . . _ . . _ _ . _ _ _ _ _ . _ . _ . _ _ _ . . _ , . _ . s , I g

'

j

            *

,. i j .- l1 TABLE 1 .

    - SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES j                  ,

l

- -
              .

l, ~ Shutdown Method Post fire Safe Required Fire Zone Locations of , , Shutdown Component ~ Cables Component / Cable  !

_

j

-

RCIC injection Shutoff 1Rl05A A-1A, A-18, AJA, A-2F, A4K, A4N, '

 ,     Valve . 1R1088  C8-4, C84A
.

. , 1R106C  ! 1R105D ' b 1Rl06E , 1R106F I I 1R106G ! - 1R109D l 1R123A !'-

    -

1Rl24A >

   -

1Rl248 [ 1R127F i 1Rl27G !- i RCIC injection Shutof RSO4A A-2F, A-2N i' Valve - Continued f [ ! _ RCIC Pump Min Flow Recirculation Valve 1R106B 1R106C A-1A, A-18, A-28, A-2K, A-2N, CB-4, C84A R106D l: ' 1R106F 1R109D - ! 1R123A ' l 1Rl24A {-

    -

1Rl248 1R127F 1R127G

    -

i 1Rl78A i 1Rl788 l .

    -

1R106G !' RCIC Pump IST Valve to 1Rl07C A-1 A, A-1B, A-28, A-2K, A-2N, CB 4, Condensate Storage Tank 1R107D C84A ! 1R1088 1R123A

     -

l

-

1R127F R127G i !' RCIC Turbine Steam 1Rl09D A-1 A, A-18, A-2A, A-2K, A4N, A-3F, l' Supply Drain isolation 1R119C CB-1C, CB-1D, CB-1E, CB-1F, C84, l ' _ Valve 1Rl18C CB 4, CB4A 1RI 23A

,     _-     1R123B       j
                ~

5' _- 1R123E

i' o j 3 i E i o i.-.. ._ - . . _ . . _ - - _ .-.. _ . - _ , . -. . . . _ . . _ . . . . - _ . . . _ ~ . . _ . _ _ _ . . . , . . - , - - - . - , _ .

~

l l l l

      !

i TABLE 1 l SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES

      !

Shutdown Method Post-fire Safe Required Fire Zone Locations of ) Shutdown Component Cables Component / Cable ' RCIC Pump Suction From 1LD26A A 1 A, A-18 A-2A, A-2D, A-2K, A-2N, Suppression Pool Valva 1LD26B A-3A C-2, CB-4, CB-CA, F-1M i 1LD26C l

      '

1LD26D 1LD29A 1LD29E 1LD29G j

      '

1LD55A 1LD57B i

      '

1LD64A 1LD648 1Rl08A - 1Rl08B 1R108C 1R108E 1R108D , 1Rl08D ' 1Rl11D 1R123A e 1R127F  ; 1R1270 l 1Rl79C l , 1R179D  ! 1R181A 1R181B I 1Rl81C 1Rl81D 1R1270 1RSO4A 1LD29B 1LD57A 1R107D .

.
.. _ . - .. - . -..- - - -.. _ . .. - - -- - -- - ...... - ..- - . - . ~ . -     . - . - - - .-~ , -
            .

t 1 y i.

jJ j i . i i.-

TABLE 1
 -
, - SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS I CABLES

. e j- Shutdown Method Postdire Safe _ Required Fire Zone Locations of

Shutdown Component Cables Component / Cable 3 . _
           . . . ...

F - Steam to RCIC Turbine 1R100A A-1A, A-18, A-2A, A-2K, A 2N, CB4,

_ Valve 1R1098 C84A
1R100C ]
- -

1R109D l- 1R1000 } 1R100H ji 1R1091  :

1R109J  !

j 1R1138 _ 1R113G i 1Rl23A !- 1R127F J-~ 1RI27G i 1RSO4A i 1VY04G  : j l RCIC Pump Supply to 1R110A A-1A, A-18, A-2A, A-2K, A-2N, CB-4, ) i Turbine Lube 011 Cooling 1R1108 C84A . Valve 1Rl10C

1R110D

. _

1Rl10E l

        -    '

1R110L !- 1R110M ' 1R127F i i 1Rl270 1RS04A

    -

l  : ,

, RCIC Pump Second Test 1R1088 A-1 A, A-13 A-28, A-2K, A-2N, C8-4,

!'- Valve to Condensate 1R106C C84A l Storage Tank 1R108D

~ 1R111C

!' _ 1Rl11D j g 1Rl11E 1Rl23A

    -

i 1Rl27F - }' 1Rl27G j: __ _ 1RS04A ,. i.

l-f

I i t l I i- 5 i' f i I

',
'

. E r- m, s-,- -ss e w -w .m.- -e,n , w --4 -o --e- ~ - + ,w-rn-w---, m-w-r- < e -6 -

- .. _ ..   .
    -

___ l l

      !

TABLE 1 SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES Shutdown Method Post-fire Safe Required Fire Zone Locations of Shutdown Component Cables Component / Cable _ RCIC Steam Supply Line 1LD26E A-1A, C-1, CB-1C, CB-1D, CB-1E, T Inboard Isolation Valve 1LD26F CB 1F, CB2, CB4A Q= 1LD26G 1LD30A 1LD30B 1LD30E

 -

1LD56A 9 1LD58A-5 1LD588

 --

1LD65A R

 =

1Rl028-M 1Rl02C 1R102D 1R102F

 -

1Rl02G

 -

1R123D 1R127H _ R127J

-   1R127K M   1Rl27L
-_--M- '   1Rl80A 1R180B

_= 1RS05A f r l 6

TABLE 1 SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES Shutdown Method Post 4 ire Safe Required Fire Zone Locations of Shutdown Component Cables Component / Cable __ . _ _ . . RCIC Steam Supply Line 1LD26A A-1 A, A-1B, A-2A, A-3A, A-2K, A-2N, Outboard loolation Valve

  -

1LD268 CB-4, CB 6A 1LD26C

  -

1LD26D

 -

1LD29A

  -

1LD298 1LD29E 1LD29G

  -

1LD55A 1LD57A 1LD57B

  --

1LD64A 1LD648

 -

1R103F r 1R112A 1Rl12B E 1R112C

  -
-

1Rl12E 1R123A T ' 1R127F 1RSO3A RCIC Steam Supply Line 1Rl27G

 -

Outboard Isolation Valve 1R127G __ _ (Continued) 1Rl79C

  -

1R1790

 ---
 --

RCIC Turbine Exhaust to 1R113A A-1B, A-2A, A-2E, A-2K, A-2N, Suppression Pool Valve 1Rl13B CB-1E, CB-1F, CB-4, CB-6A-7 1Rl13C q 1Rl13E ' 1 3G Rl13H T - 1R127F 1R127G

-

j 1RSO4A I

- .

..
   .
    .
     .
       .
       .
        . - _ _ _ _ .

, __ _ _ . - __ . _ _ . _ __ _ _ _

      ,
    *

I TABLE 1 SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES Shutdown Method Post-fire Safe Required Fire Zone Locations of Shutdown Component Cables Component / Cable RCIC Steam Line Warm- 1LD26E C-1, C-2, A-3D, A-3F, CB-1C, CB-1D, up Line Isolation Valve 1LD26F CB-1E, CB-1F, CB-2, CB-6A I 1LD26G 1LD30A 1LD308 1LD30E 1LD56A 1LD58A 1LD588 1LD65A 1LD65B 1Rl15A 1Rl15B ' 1R115C 1Rl15D 1R115E 1R115F 1Rl23D 1R127H l 1Rl27K 1Rl27L 1R180A 1Rl80B 1RS05A RCIC Exhaust Vacuum 1LD64A C-2, A 18, A-2E, A-2K, A-2N, A-3D, Breaker isolation 1LD64B A-3F, CB-4, CB-6A Outboard Valve 1LD65A 1LD658 1Rl03A 1R103B 1Rl03C 1Rl03D 1R103F 1Rl17A 1Rl178 1Rl17C 1Rl17D 1R127F 1R127G 1RS03A 1RS05A RCIC Exhaust Vacue,n 1R117B A fd, A-28, A-3D, A-3F Breaker Isolation inboard 1Rl17C

.

Valve 1RSO5A

. . _ . _ . _ _ _ . _ . _ _ . . _ . _ . _ _ _ _ _  _ . _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . ,
         !
- 1
I y ,
         ,
i l-
 ,
         ;

L TABLE 1  ! SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES i .

       .
         ~

l l~ Shutdown Method . . ' Post-fire Safe Required - Fire Zone Locations of > Shutdown Component Cables Component / Cable s Steam Warm-up Line 1R1000 A-1A, A-18 A-2A, A-2K, A4N, CB ! leolation Valve 1R1138 CB4A'

- 1R113G l 1R123A
         '

}: 1Rl31A b 1Rl318

      -
         ;
1Rl31C  !

!. -- 1Rl31E ' !? 1Rl31F . 1RS04A ! -

   :. 1mHF

!< 1R1270 i

-

_ _

RCIC Turbine Speed 1R123A A-2A, A-2N, CB-4, CB4A )

Control Square Root 1R176D Converter 1R176E , j: RCIC Turbine Speed , 1Rl76E A-1 A, A-18, A-2, A-2K a Control Flow Transmitter ' ! l i RCIC Storage Tank Level 1R181A' A-18, A-2D, A-2K, A-2N, CB-4, Transmitter 1Rl618 CB4A, F-1, F 1M

  -

. c 1R123A ! RCIC Pump Discharge 1Rl78A ' A-1A, A-15, A-2A, A-2K, A-2N, CB4, i Pressure Transmitter RNIO60 CB4A ! _ RCIC Pump Discharge 1Rl788 A-1A, A-18, A-2A, A-2K, A-2N, CB-4, ? Flow Transmitter RIN061 CB4A $ _ _ ! RCIC Turbine Speed 1Rl76A A 1A, A-2A 1 Element RCIC Turbine Speed 1Rl24K A-1 A, A-18, A-2, A-2K, A-2N, CB-4,

  -

Control RPM Generator 1Rl768 CB4A 1Rl76C RCIC Turbine Speed EGM 1Rl76A A-1 A, A-18, A-2, A-2K, A-2N, CB-4, Control Box 1Rl768 CB4A

  --

1Rl76C 1Rl760 __ 1Rl76E 1Rl76G

  --

1RS04A

         -
. - - . . . --  . - . - - - . . _ ~ _ = . -- -. __ .. . ..

i I TABLE 1

.

l SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES I 4 Shutdown Method Post-fire Safe Required Fire Zone Locations of  ; Shutdown Component Cables Component / Cable  !

)
'

RCIC Turbine 1RP01F A-2A, A-1A, A-1B, A-2K, A-2N, CD-4,

 -

SpeediFlow Controller 1R123A CB4A 1R124G i __ 1R124K 1R176C 1Rl76D

'   -

1Rl76E 1Rl76G 1Rl85C l RCIC Turbine 1RP01F A-2A, A-1A, A-1B, A-2K, A-2N, CB-4, I i Speed I Flow Indication 1R123A CB4A

1Rl24G

1R124K

  --

1Rl76D

,
'

2 1R176E

 =    1Rl76G

'

Me 1Rl85C

 -

RCIC Turbine Speed 1RP01F A-2A, A-2N, CB 4, CB4A Indicator 1R1858

 ~M RHR Pump 1-C   1RH02C A-1 A, A-1B, A-3B, A4D, A-3F, CB-2, M    1RH03A CB4A 1RH03B
 =    1RH03C i
 "-_
 -

1RH03D j - 1RH03E

'

W 1RH03F

  -

1RH03G i '

 -    1RH04E
,      1RH118

_ 1RH11C i" M RHR Pump C Test Valve 1RH20A A-1 A, A-1B, A-1E, A-3D, A-3F

.

_-Q _ to Suppression Pool _ a !

.

l 10 . . . - _ . . - . - - - . . TABLE 1 SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES I Shutdown Method Post-fire Safe Required Fire Zone Locations of Shutdown Component Cables Component / Cable RHR LPCIInjection Spray 1NB58A A-1 A, A-1B, A-1E, A-3D, A-3F, C-2, l Valve 1NB58B CB-1G, CB-2, CB4A, CB4B i 1RH04E 1RH29A 1RH29B 1RH29C 1RH90A 1RP76A 1RP76B 1RP76E 1RH02C RHR Pump Minimum Flow 1RH03C A-1 A, A-1B, A 3B, A-3D, A4F, CB-2, Valve 1RH04E CB4A , 1RH52A l 1RH528 1 1RH52C 1RH74E 1RH95A l RHR Pump C Suction 1RH11A A-1 A, A-1B, A-3B, A-3D, A-3F, CB-2, Valve 1RH118 CB4A 1RH11C , 1RH11D , _

RHR C Flow Transmitter 1RH79E A-1 A, A-1B, A-3, A-3D, A-3F, CB-10, 1RH85A CB-2, CB4A, CB4B RHR C Pump Minimum 1RH95A A-1 A, A-1B, A-3B, A-3D, A-3F, CB-2, Flow Transmitter RHN052C CB4A RHR Flow Indicator 1RH79E A-1 A, A-1B, A-3D, A-3F, CB-10, 1RH85A CB-2, CB4A CB4B HPCS Pump 1HP08A A-2N, A-20, CB4A, CB-7, F-1B, THP08B F-1M, F-1P, CB4A, CB4D 1HP08C 1HP22H HPCS / RCIC Tank Suction 1HP10A A-2N, A-20, CB4A, CB-7, F-1B, Valve 1HP10B F-1 M, F-1P, CB4A, CB4D, CB-7, 1HP10C D-4A, F-18, F-1P 1HP15B 1HP15C 1HP22E mm-3 1HP22F

TABLE 1 SEPARATION OF POST-FIRE SAFE SHUTDOWN COMPONENTS / CABLES Shutdown Method Post-fire Safe Required Fire Zone Locations of Shutdown Component Cables Component / Cable [% .:,%&.d_ _ . N HPCS Injection Shutoff Valve 1HP11B 1HP11C A-2N, A-20, CB-5A, F-1B, F-1M, F-1P, CB-6A, CB-6D, CB-7 p?gg,"*r. "a .

  "

1HP11E 1HP11F g

 -

g HPCS Test Return to RCIC 1HP12A A-2N, A-20, F-1B, F-1M, F-1P, CB-( . _ ggg f Storage Tank Valve 1HP128 5A, CB4A, CB4D, CB-7, D 4 i N

5- " Y

 '
.

1HP15C 1HP22E W

. .

thpade$g < 1HP22F i M 'h@ h HPCS Test Return to RCIC 1HP13A A-2N, A-20, F-18, F-1M, F-1P, CB-

 $2L "t*

Storage Tank Valve 1HP13B SA, CB4A, CB4D, CB-7, D-4A 1HP13C i 1HP15B f  ! 1HP15C

$   K  1HP22E
*   '

1HP22F HPCS Suppression Pool 1HP14A A-2N, A-20, F-1B, F-1M, F-1P, CB- 'gy Minimum Flow Bypass 1HP14B SA, CS4A, CB-6D, CB-7

 ,
  ) Valve  1HP14C
$g :g4gp   1HP77A

$, ~ h 9fing g 1HP77B s-

'

t w

@g  M$]p$ HPCS Suppression Pool 1HP12C A-2N, A-20 F-1B, F-1M, F-1P, CB-jh  g ;
 .p Suction Valve 1HP13B 1HP13C 5A, CB4A, CB4D, CB-7 4 p > C%bj'g   1HP15A

[d 1"$kdNhik'i 1.WWV#W 1HP158 1HP15C f;^hmhShdbhhh5 N$hhhb 1HP78A 1HP788 $Q;f$ spd N d M j /F[M M 1HP78C 1HP78D N @ $ h@ 4 m.,j $kMl:) g 1HP78D $ jkh[f$ 1HP12B 3 #"""WMM[l[hikhh

 "
 $ k HPCS Test Return To  1HP16A A-214, A-20, F-1B, F-1M, F-1P, CB-h Suppression Pool Valve 1HP16B 5A, CB4A CB-6D, CB-7 l 9, k  ,

1HP16C b I HPCS Flow Transmitter 1HP76A A-2N, A-20, F-1B, F-1M, F-1P, C ([ ._18 , .A[ .. Division 3 1HP76D 5A, CB-6A, CB-6D, CB-7 K . . 1RP03F

l

       ,

_ TABLE 2 CIRCUlT ANALYSIS / CIRCUlT SELECTION FOR POST-FIRE SAFE SHUTDOWN EQUIPMENT AND COMPONENTS u Shutdown Method Post-fire Safe Required Fire Zone Locations of Shutdown Component Cables ComponentICable

\$h$h  $ HPCS Pump Discharge  1HP77A A-2N, A-20, F 18, F 1M, F 1P, CB 5A,
$jQj "r== - Pressure Transmitter  1RP03F CB4A, CB4D, CB 7 g gi'     HPN051
. h ~a :

Nggb%p]Syg HPCS Pump Discharge 1RP03F A 2N, A-20, F 1B, F 1M, F 1P, CB-5A, M Flow Transmitter 1HP778 CB4A, CB4D, CB-7

%gfg; F"M    HPN056
 ,

HPCS Flow Indicator 1RP03F A 2N, A-20, F 1B, F 1M, F 1P, CB-5A, gg Division 3 1HP76A 1HP76D CB4A, CB4D, CB-7 , M g _,._- ,

        .

i

. . .
.w n y :y . .. .. . ..
   [ m; _ ,. ..g; ;, ?  g .

h jk ,7h3khNkh' ' [# air.f Q*

   '
     [: p[ . 'hf"?
      '
      ;%  -
 $ghtg"C wk:t:   VM:;[(. -4' Y
   .
    " ab;JT
      ' '
        ,.li
     " ' '
.n y f "M_?_w }DTJ:kn,j?.t> n fa;& n::k W.nd n ,
.

ug _ v ' ' ' '

       .un a y

1821-N068A REACTOR PRESSURE 1NB98A (INSTRUMENTATION) E021NB99-120(F) l TRANSMITTER TRANSMITTER TO ELECTRICAL E021NB99-109(E) PENETRATION 1EE28E E021NB99110(E) E021ND99112(G) 1NB988 (INSTRUMENTATION) E021NB99-113(E) ELECTRICAL PENETRATION E021NE39114(E) 1EE28E TO TERMINATION E021RP99 004(L) CABINET 1H13-P706F 1RP01F (POWER) 1C71-P001 A TO TERMINATION CABINET , 1H13-P706A , 1 f I i

.

i l l TABLE 2 l CIRCUIT ANALYSIS / CIRCUIT SELECTION FOR POST-FIRE SAFE SHUTDOWN EQUIPMENT AND COMPONENTS l

   ^

TsAFE'2: (. , ~DESCRNm0Na$kf , '

  . _g M ; k CABLEIh i [ rF .DRA4nnG8 L REFERENCE $ '

suuTnown y ', 1lh[?& v , 13[' Q Sid,.. 1RM - > sSt , m $r

 '
    @(

ape:gy;; bg'g'lyg;g(fg@g;cfy?lylhl3 3jg g gf jy jp 'fjW

  '

s M4,, ?% EQUI.PMENT . 1 jy ty;: x<

    ,
    , g7 j
     -
      .

1B21-N068B REACTOR PRESSURE 1NB74A (INSTRUMENTATION) E02-1NB99-121(E) , TRANSMITTER TRANSMITTER TO ELECTRICAL E02-1NB99-110(E)

      '

PENETRATION 1EE33E E021NB99111(E) E02-1NB99-114(E) 1NB74B (INSTRUMENTATION) E021NB99115(F) ELECTRICAL PENETRATION E021NB99116(F) 1EE33E TO TERMINATION E02-1RP99-004(L) CABINET 1H13-P707B 1RP02F (POWER) 1C71-P001B TO TERMINATION CABINET 1H13-707B i l

4 I i t

    - - - - - - - - - ~
-

l l TABLE 2 CIRCUlT ANALYSIS / CIRCUlT SELECTION FOR POST-FIRE SAFE SHUTDOWN EQUIPMENT AND COMPONENTS aAFE/ 2 gg 45 Gpiib 0 . y lf O REFWtBNCE i SHUTDOWN... MSCMPW0lf[dQ.4'J

 ~*. . ^4f -

CAWLR % , 6p y DgQg{ % M@(Wtjgj; [- ;

     ,
     ' ' DitAWINGS @

MQv[4 yiy,f' d;p.gj4p{$)gtygp

  <     '

EQUIPIRElf '/ l 1Q 4:p j' @.p , y@ s ,

 '
  .

pMy y q , gt m

       <
       ,

SRV.D1 SAFETY RELIEF VALVE 1NB73A (INSTRUMENTATION) 1821 E02-1NB99121(E) l AUTO DIVISION 1 - AUTO N068F TO ELECTRICAL E02-1NB99110(E) PENETRATION 1EE33E E021NB99111(E) E021NB99-114(E) 1NB73B (INSTRUMENTATION) E02-1NB99-115(F) ELECTRICAL PENETRATION E02-1NB99116(F) 1E33E TO TERMINATION E02-1RP99 004(L) CABINET 1H13 P707B 1NB74A (INSTRUMENTATION)1B21 l i N068B TO ELECTRICAL I PENETRATION 1EE33E l 1NB748 (INSTRUMENTATION) ELECTRICAL PENETRATION 1EE33E TO TERMINATION CABINET 1H13-P707B 1RP02F (POWER)1C71 P001B TO TERMINATION CABINET 1H13-P707B SRV.D1- SAFETY RELIEF VALVE 1NB98A (INSTRUMENTATION) E021NB99120(F) AUTO DIVISION 1 AUTO 1821-N068A TO ELECTRICAL E021NB99109(E) PENETRATION 1EE28E E021NB99110(E) E021NB99112(G) 1NB988 (INSTRUMENTATION) E021NB99-113(E) ELECTRICAL PENETRATION E021NB99-114(E) 1EE28E TO TERMINATION E02-1 RP99-004(L) CABINET 1H13-P706F 1NB99A (INSTRUMENTATION)1821 N068E TO ELECTRICAL PENETRATION 1EE28E 1NB998 (INSTRUMENTATION) ELECTRICAL PENETRATION i 1EE28E TO TERMINATION l CABINET 1H13-P706F i l 1RP01F (POWER) 1C71-P001 A TO TERMINATION CABINET 1H13 P706A ,

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i TABLE 2 CIRCulT ANALYSIS / CIRCUIT SELECTION FOR POST-FIRE SAFE SHUTDOWN EQUIPMENT AND COMPONENTS

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EQUIPMENT 1

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r i iB21-N068E REACTOR PRESSURE 1NB99A TRANSMITTER (INSTRUMENTATION) 1821 E021NB99120(F) l N068E TO ELECTRICAL E021NB99109(E) l PENETRATION 1EE28E E021NB99-110(E) l E021NB99112(G) 1NB99B (INSTRUMENTATION) E021NB99-113(E) I ELECTRICAL PENETRATION E021NB99-114(E)

      '

1EE28E TO TERMINATION E021RP99-004(L) CABINET 1H13-P706F 1RP01F (POWER) 1C71-P001A TO TERMINATION CABINET 1H13-P706A l 1B21-N068F REACTOR PRESSURE 1NB73A (INSTRUMENTATION) 1821- E02-1NB99121(E) TRANSMITTER N068F TO ELECTRICAL E021NB99110(E) PENETRATION 1EE33E E021NB99111(E) E021NB99114(E) E02-1NB99115(F) 1NB73B

      '
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ELECTRICAL PENETRATION 1E33E TO Tl RMINATION CABINET 1H13 P7078 1RP02F (POWER) 1C71-P001B TO TERMINATION CABINET 1H13-P7078 1APO7EJ 480V AUXILIARY 1AP28A (POWER) 4160V FROM BUS 1 A1 E021 AP03(J) TRANSFORMER 1 A& A1 CUBICLE J TO 480V E021 AP12-011(Y) FEED BREAKER TRANSFORMER 1 A E02-1AP099-023(J) E021 AP99-038(V) 1 APT 28 (POWER) 4160V FROM BUS 1 A1 TO CUBICLE J TO 480V TRANSFORMER A1 1AP34P (POWER) 125VDC FROM DC MCC 1 A COMPARTMENT 11 A CIRCUlT 2 TO BUS 1 A1 CUBICLE G

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ri i ry': pO + Wy:' ~ 4% > , 1AP34Q (POWER)125VDC FROM DC MCC 1 A COMPARTMENT 11 A CIRCUlT j 5 TO BUS 1A1 CUBICLE G

1AP28C (CONTROL) BUS 1 A1 CUBICLE J

TO TERMINATION CABINET ' 1H13-P741 A , 1AP28M (CONTROL) BUS 1 A1 CUBICLE J

i TO 480V TRANSFORMER A1 1AP28U (CONTROL) BUS 1A1 CUBICLE J TO 480V TRANSFORMER 1 A CUBICLE 3 i 1AP28V (CONTROL) BUS 1 A1 CUBICLE J I J TO 1C61-P001 ) 1AP28W (CONTROL) BUS 1A1 CUBICLE J TO 1C61-P001 1821- MAIN STEAM SAFETY 1NB34D (CONTROL POWER) FROM MCC E021NB99-113(E) F051C.D1 RELIEF VALVE 1 A TO MAIN CONTROL ROOM ' TERMINATION CABINET 1H13-P706B

l 1NB35A (CONTROL) MAIN CONTROL ROOM TERMINATION CABINET 1H13-P706B TO REMOTE SHUTDOWN PANEL 1C61-P001 1NB35C (CONTROL) REMOTE SHUTDOWN PANEL 1C61-P001 TO PENETRATION 1EE18E 1NB35D (CONTROL) PENETRATION 1EE18E TO JUNCTION BOX 1JB733 1NB35H (CONTROL) 1JB733 TO 1B21 F051C

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l l l (ARLE 2 CIRCUlT ANALYSIS / CIRCUlT SELECTION FOR POST-FIRE SAFE SHUTDOWN EQUIPMENT AND COMPONENTS

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l _ , g(ib @fAyf;hTSp$ g ,j j,., p, 3, . ., jj$g g $g 6 A6 i@dsMR ef@' nWu 1E51-F04 STEAM TO TURBINE 1R109A (POWER) FROM 125VDC MCC E021Rl99 009(K) VALVE 1A COMPARTMENT TO MOV E021Rl99-506(J) 125VDC MOTOR E03-1DC13E-004(N) E02-1RS99105(F) i 1Rl091 (POWER) FROM 125VDC MCC 1 A COMPARTMENT 7B TO MOV 125VDC MOTOR 1R109H (POWER) FROM 125VDC MCC , 1 A COMPARTMENT 7B TO MOV ' 125VDC MOTOR l 1Rl09J ' (POWER) FROM 125VDC MCC 1A COMPARTMENT 7B TO MOV 125VDC MOTOR 1R1098 (CONTROL) FROM 125VDC MCC 1 A COMPARTMENT 78 TO MOV LIMIT SWITCH 1R109C (CONTROL) FROM 125VDC MCC 1 A COMPARTMENT 7B TO REMOTE SHUTDOWN PANEL 1RSO4A 125 VDC CONTROL POWER SUPPLY FROM 125VDC DISTRIBUTION PANEL AT MCC 1 A COMPARTMENT 11 A CIRCUIT 16 TO REMOTE SHUTDOWN PANEL 1C61-P001C _ _ _ 1SX01P SHUTDOWN SERVICE iSX01A (POWER) FROM 4160V BUS 1 A1 E021SX99 001( A A) WATER PUMP 1 A CUBICLE D TO PUMP 1-A E03-1 AP07ED4)01(R) MOTOR 1SX01J (CONTROL) FROM 4160V BUS 1 A1 CUBKLE D TO REMOTE SHUTDOWN PANEL 1C61-P001E 1DG01R (CONTROL) FROM 4160V BUS 1 A1 CUBICLE D TO PANEL 1PL92JA

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i i l 1RS04A 125VDC CONTROL POWER SUPPLY FROM 125VDC DISTRIBUTION PANEL AT MCC1 A COMPARTMENT 11 A, CIRCUlT 16 TO REMOTE 1 SHUTDOWN PANEL 1C61-P001C

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1RS06A 125VDC CONTROL POWER SUPPLY FROM REMOTE SHUTDOWN PANEL 1C61-P001C TO 1C61 P001E 1E12- RHR TO UPPER POOL 1RH64E (CONTROL) FROM MCC 182 E02-1RH99-508(F) F037 COOLING SHUTOFF COMPARTMENT 10B TO MAIN E021RH99-013(K) VALVE CONTROL ROOM TERMINATION E03-1RH00404(J) CABINET 1H13-P707F E021 AP76E-010(J) E031 AP94E 005(F)

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