IR 05000498/1987017

Insp Repts 50-498/87-17 & 50-499/87-17 on 870330-0403.No Violations or Deviations Noted.Major Areas Inspected: Implementation of Fire Protection Program & Compliance W/Requirements of 10CFR50,App R (Safe Shutdown)

ML20214R813
Person / Time
Site:	South Texas
Issue date:	05/29/1987
From:	Constable G, Garrison D, Hunter D, Mullikin R, Murphy M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214R811	List: IR 05000498/1987017 ML20214R809
References
50-498-87-17, 50-499-87-17, NUDOCS 8706080344
Download: ML20214R813 (35)

Text

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 60-498/87-17 Construction Permits: CPPR-128 S0-499/87-17 CPPR-129 Dockets:

50-498 S0-499 Licensee: Houston Lighting & Power Company (HL&P)

P. 0. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 (STP)

Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: March 30 through April 3, 1987 Inspectors:

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R. P. Mullikin, Project Inspector, Project Date Section B, Reactor Projects Branch h7 M. E. Murphy, Project * Ins,pettor, Project Date

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Section B, Reactor Pro $ects Branch W3fD p D. L. Garrison, Resident Inspector, South Date v

Texas Project Participating in the inspection:

A. Singh, Office of Nuclear Reactor Regulation R. P. Goel, Office of Nuclear Reactor Regulation

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K. Sullivan, Brookhaven National Laboratory M. Villaran, Brookhaven National Laboratory D. Arnold, Rolf Jenson and Associates i

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I 8706080344 870601 PDR ADOCK 05000498 G

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Approved:

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D. R. Hunter, Chief, Project Section B Date Reactor Projects Eranch 9 97

,-Gonstatrle~, ~ Chief, Project Section C Date

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Reactor Projects Branch

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Inspection Summary Inspection Conducted March 30 through April 3,1987 (Report 60-498/87-17; j

S0-499/87-17)

Areas Inspected: Special, announced inspection of the implementation of the.

fire protection program and compliance with the requirements of 10 CFR S0, Appendix R (safe shutdown) and BTP 9.b-1, per FSAR commitments and SER evaluation. A physical verification of commitments was performed for Unit 1 only.

Results:

_ ithin the areas inspected, no violations or deviations were W

identified.

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DETAILS 1.

Persons Contacted Houston Lighting & Power Company (HL&P)

• J. Bailey, Licensing Engineer D. E. Baker, System Engineer M. Berrens, Reactor Operator

• S. Blinka, Performance Support Supervisor D. Cox, Reactor Plant Operator

• M. Decamp, Engineer

• E. W. Dolson, Engineering S. Dugger, Reactor Operator

• S. Eldridge, Nuclear Plant Operations M. Friedlander, System Engineer R. Graham, Unit Supervisor

• W. Harrison, Supervising Licensing Engineer

B. Hing, Supervisor

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• G. W. Jaunal, Engineering ~

• K. Jolley, Engineering J. A. Labuda, Fire Protection Engineer S. Law, Technical Support D. Legler, Reactor Plant Operator C. B. Lunsford, Electrical Maintenance Supervisor G. D. Manasco, Electrical Engineer

• M. McBurnett, Licensing-D. N. McCallum, Shift Supervisor D. Nester, Lead Electrical Systems Engineer

• P. D. Newcomb, Engineering

• G. D. Prudon, Engineer

• V. E. Reddy, Engineering

• E. Simbler, Engineering

• C. Turner, Engineering G. Weldon, Supervisor, Nuclear Training M. Wisenburg, Project Management

• C. D. Wren, Nuclear Plant Operations Bechtel Engineering

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M. Bali, Engineering Supervisor

• A. Gruidry, Engineer R. Jadau, Electrical Engineer

• R. Johnson, Engineer B. J. Jones, Electrical Senior Designer R. Kattner, Lead Architect

• D. R. Quathoriocchi, Engineer M. Vaccaro, Senior Engineer

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Impell Corporation

• R. T. Cupp, Technical Manager

• J. Echttinacht, Fire Protection Engineer

• S. R. Whitsett, lead Senior Engineer

• Denotes those attendirq the exit interview conducted on April 3, 1987.

lne fiRC inspectors also interviewed other STP personnel during the inspection.

2.

List of Documents Reviewed a.

Letters, Reports, and Procedures Title Date Safety Evaluation Report, South Texas Project, Units 1 4/86

& 2, NUREG-0781, Revision 0.

Fire Hazards Analysis Report, South Texas Project, 2/87 Units 1 & 2, Fire Protection Program, OPGP03-ZF0001, Revision 2 2/2/87

" Residual Heat Removal Pump 1B In Service Test,"

Undated IPSP03-RH-0002, Revision 1

"High Head Safety Injection Pump 1B In Service Test,"

3/19/87 1PS03-SI-0005, Revision 1

" Auxiliary Feedwater Pump 14 In Service Test,"

3/3/87 1 PSP 03-AF-0007, Revision 1

" Shutdown from Outside Control Room," 1 PEP 04-ZY-0035, 7/31/86 Revision 1 Final Safety Analysis Report, Units 1 & 2, Amendment 56

" Auxiliary Feedwater Pump 13 In Service Test,"

8/7/86 IPSP03-AF-0003, Revision 1

" Auxiliary Feedwater System Valve Checklist,"

10/31/86 1 PSP 03-AF-0009, Revision 1 I

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" Preparation and Approval Of Fire Preplans,"

3/10/87 OPGP03-ZF-0015, Revision 3

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" Post Fire Operator Actions and Equipment Protection 3/26/87 Requirements," 5A019MFP001, Revision 3

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" Control Room Evacuation," 1P0P04-ZZ-001, Revision 0 Undated South Texas Project Unit 1 & 2 Fire Hazards Analysis / Cold 10/31/86 Shutdown Report.

Westinghouse FHA /CS Analysis, Revision 1

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Technical Specifications, South Texas Unit 1 Proof and 2/12/87 Review copy.

" Preplan for Reactor Containment Building Pressurizer 4/7/86 Enclosure," 1RCB63-FP-0224, Revision 1.

"Firefighting" (Station Procedure, Safety-Related),

12/30/85 OPGP03-ZF-0012

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Bechtel Power Corporation Interoffice Memorandum From:

1/16/84 R. A. Schmitter, To:

C. W. Jordan, Subject:

Open Circuit 1E Current Transformers Appendix R Separation inside STP Containment Bechtel 3/19/87 Calculation No. 5A011MA6065 High Impedance Cable Failures, Safe Shutdown Circuit 2/24/87-Analysis, EC5061, Revision 0 Appendix R Backup Evaluation Bechtel Calculation 4/1/87 No. 5A011MC6050, Revision 1

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Appendix R Evaluation Bechtel Calculation 4/1/87 i

No. 5A011MC6023, Revision 3

" Calibration of ITE-51 Relays," PMP5-ZE-37, Revision 0 5/18/84

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"4160V Gould Breaker Tests," PMP5-NA-02 3/5/85

" Calibration of ITE-27 Relays," 0PMP05-ZE-0034, 3/9/85 Revision 1

" Reactor Trip or Safety Injection," 1P0P05-E0-E000, 1/5/87 Revision 1

" Loss of All AC Power," 1P0P05-E0-EC00, Revision 1 1/5/87

" Reactor Trip Response," 1 POP 05-E0-ES01, Revision 1 1/5/87

" Loss of Reactor Secondary Coolant," 1 POP 05-E0-E010, 1/5/87 Revision 1

" Emergency Classification," OEPP01-ZA-0001, Revision 1

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" Natural Circulation Cooldown with Steam Void in Vessel,"

1/5/87 1P0P05-E0-ES03, Revision 1

" Preplan for Electrical Auxiliary Building Main Control 3/30/87 Room," 1EAB01-FP-0034

" Natural Circulation Cooldown," 1P0P05-E0-ES03 1/5/87

" Fire Protection Program," 0PGP03-ZF-0001, Revision 2 2/2/87

" Fire Brigade Drills," OPGP03-ZF-0002, Revision 0 9/11/85

" Breaching of Fire Barriers," 0PGP03-ZF-0003, Revision 1 1/16/87

" Control of Transient Fire Loads," OPGP03-ZF-0004, 4/22/87 Revision 1

"Use of Flammable Liquids and Gases," 0PGP03-ZF-0005, 9/29/86 Revision 1

" Control of Ignition Sources," OPGP03-ZF-0006, 1/16/87 Revision 1

" Control of Solvents, Paints, and Painting Processes,"

3/20/87 OPGP03-ZF-0007, Revision 0

"STPEGS Fire Brigade," 0PGP03-ZF-0011, Revision 1 3/30/87

" Fire Fighting," OPGP03-ZF-0012, Revision 0 12/30/85

" Fire Prevention Surveys," 0PGP03-ZP-0014, Revision 0 6/5/85

" Preparation and Approval of Fire Preplans,"

3/10/87 OPGP03-ZP-0015, Revision 3

" Fire Protection Unanticipated Impairment,"

1/16/87 OPGP03-ZP-0017, Revision 1

"Use of Fire Protection Equipment," PGP3-ZF-08, 2/27/85 Revision 0

" Smoking Control Program," PGP3-ZF-09, Revision 0 7/5/84

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" Fire Watch Program," PGP3-ZF-13, Revision 0 1/25/85

" Fire Hazards Evaluation," 0PGP03-ZA-0005, Revision 2 1/16/87

" Recurring Action Tracking System," 0PGP03-ZA-0068, (Draft)

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" Fire Protection System Operability Requirements,"

3/30/87 OPGP03-ZF-0018, Revision 2

" Preplan for Mechanical Auxiliary Building Service 3/27/87 Areas and BRS Recycle Holdup Tanks," IMAB03-FP-0130, Revision 1

" Preplan for Auxiliary Building Main Control Room,"

3/30/87 IEAB01-FP-0034, Revision 1

" Control Room Evacuation," IPOP04-ZZ-0001, Revision 0 (Draft)

" Fire Brigade Training Program - Learning Objectives and Lesson Plans," FBT001.01 through FBT001.26,

" Fire Watch Training," NTD036.01 1/20/87

" Preventive Maintenance Form - STPEGS (Emergency DC Lighting - Appendix R)," Revision 0, OPGP03-ZM-0002 b.

Drawings Date Number Title 9/4/85 55144F00024, Revision 6 Piping & Instrumentation Drawing-Auxiliary Feedwater 10/14/85 SR179F05005, Revision 6 Piping & Instrumentation Drawing-Chemical & Volume Control System 10/16/85 5R179F05005, Revision 3 Piping & Instrumentation Drawing-Chemical & Volume Control System 10/16/85 SR179F05005, Revision 6 Piping & Instrumentation Drawing-Chemical & Volume Control System 07/21/85 SR179F05005, Revision 6 Piping & Instrumentation Drawing-Chemical & Volume Control System 11/14/85 5R109F05017, Revision 6 Piping & Instrumentation Drawing-Component Cooling Water System 11/14/85 5R109F05018, Revision 6 Piping & Instrumentation Drawing-Component Cooling Water System r

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11/14/85 SR109F05019, Revision 6 Piping & Instrumentation Drawing-Component Cooling Water System 11/14/85 5R109F05020, Revision 6 Piping & Instrumentation Drawing-Component Cooling Water System 11/14/85 5R109F05021, Revision 6 Piping & Instrumentation Drawing-Component Cooling Water System 07/08/85 SR169F2000, Revision 4 Piping & Instrumentation Drawing-Residual Heat Removal System 10/29/85 SS109F00016, Revision 6 Piping & Instrumentation Drawing-Main Steam 09/13/85 5S199F00020, Revision 7 Piping & Instrumentation Drawing-Condensate Storage System 09/04/85 5S149F00024, Revision 6 Piping & Instrumentation Drawing-Auxiliary Feedwater System 11/22/85 SN129F05013, Revision 5 Piping & Instrumentation Drawing-Safety Injection System 11/06/85 SR149F05001, Revision 5 Piping & Instrumentation Drawing RCS Primary Coolant

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02/16/87 9-E-PMAA-01 #1, Revision 9 Single Line Drawing 480V Class-1E Motor Control Center EIA1 01/12/87 9-E-PEAN-01 #1, Revision 6 Single Line Drawing 480V Load Control 1W 02/03/87 9-E-VAAA-01 #1, Revision 8 Single Line Diagram Vital 120V AC Dist. PNLS DP001, DP1201, Channel 1 0-E-AAAA-01, Revision 5 Single Line Diagram Main One Line Diagram Unit Nos. 1 & 2 05/10/86 0230-040-0008, Revision 0 SSD Circuit Analysis i

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09/04/84 PW-N10071-720, Revision 9 Wiring Details TX SW PNL ZLP-653 04/01/86 9-E-CV-26-01, Revision 4 Elem. Diagram Cent. CMC PMPS 1A & IB (PA101A & PA101B)

12/15/86 9-E-2816-01, Revison 12 Elec/Elec Aux Bldg.-Conduit

& Tray Plan E1. 10'

05/22/86 9-E-2816-02, Revision 7 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 10'

08/20/86 9-E-2817-01, Revision 12'

Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 10'

04/21/86 9-E-2817-02, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 23'

12/23/86 9-E-2818, Revision 11 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El 10'

09/09/86 9-E-2819, Revision 11 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 10'

07/23/86 9-E-2820, Revision 10 Elec/Elec Aux Bldg.- Conduit

& Tray Plan El. 10'

10/01/86 9-E-2821, Revision 10 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 10'

07/17/86 9-E-2824, Revision 14 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 20'-6" 12/12/86 9-E-2825, Revision 12 Elec/Elec' Aux Bldg.-Conduit &

Tray Plan El. 21'

12/23/86 9-E-2826, Revision 14 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 21'

08/18/86 9-E-2827-01, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 35'

07/02/86 9-E-2827-02, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 35'

07/02/86 9-E-2830, Revision 10 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 35'

09/13/86 9-E-2831, Revision 12 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 35' & 45'

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05/13/86 9-E-2832, Revision 9 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 35'

11/03/86 9-E-2833-01, Revision 12 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 35'

11/03/86 9-E-2833-02, Revision 14 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 35'

08/28/86 9-E-2835-1, Revision 7 Elec/Elec Aux Bldg.-Conduit &

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Tray Plan E1. 60'

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11/03/86 9-E-2835-02, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1.-60'

09/09/86 9-E-2836, Revision 9 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 60'

12/15/86 9-E-2838, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 60'

04/10/86 9-E-2839, Revision 9 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 60'

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08/26/86 9-E-2840, Revision 10 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 60'

04/03/86 9-E-2841, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 48'

11/02/86 9-E-2843-00 Revision 11 Elec/Elec Aux Bldg.-Conduit &

Tray Plan El. 72'

05/09/86 9-E-2843-04, Revision 7 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 86'

08/28/86 9-E-2844, Revision 6 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 74'

08/18/86 9-E-2845, Revision 9 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 72' & 74'

10/01/86 9-E-2846, Revision 8 Elec/Elec Aux Bldg.-Conduit &

Tray Plan E1. 76'

09/09/86 9-E-55107, Revision 7 Elec/Elec Aux Bldg.-Conduit &

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Tray Plan E1. 86'

04/15/86 9-E-1631-01, Revision 12 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 10'

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06/20/86 9-E-1631-02, Revision 15 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 10'

03/18/87 9-E-1631-03, Revision-14 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 10'

09/09/86 9-E-1632-02, Revision 10

' Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 19'

08/28/86 9-E-1632-03, Revision 12 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 10'

09/09/98 9-E-1632-12, Revision 11 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 10'

04/11/86 1-E-1634-01, Revision 9 Elec/ Mech Aux Bldg. Conduit

& Tray Plan El 26'

03/04/86 1-E-1634-02, Revision 10 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 26'

03/06/86 9-E-1637-01, Revision 8 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 41'

04/21/86 9-E-1637-02, Revision 8 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 41'

05/22/86 9-E-1640-01, Revision 8 Elec/ Mech Aux Bldg. Conduit &

Tray Plan El. 60'

04/31/86 9-E-1640-02, Revision 12 Elec/ Mech Aux Bldg. Conduit &

Tray Plan E1. 60'

08/20/86 9-E-1649-01, Revision 6 Elec/Isol Valve Cubicle Conduit Plan El 10'

08/05/86 9-E-1649-02, Revision 5 Elec/Isol Valve Cubicle Conduit Plan E1. 34'

03/13/86 9-E-1649-03, Revision 6 Elec/Isol Valve Cubicle Conduit Plan E1. 51'

07/22/86 9-E-2815, Revision 4 Elec/Isol Valve Cubicle Tray Plan E1. 10'

11/14/86 9-E-2828, Revision 3 Elec/Isol Valve Cubicle Tray Plan El 34'

11/14/86 9-E-2874, Revision 2 Elec/Isol Valve Section and Details

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06/06/86 9-E-1606-04, Revision 5 RCB Conduit Plan El. 19'

05/28/86 9-E-1607-01, Revision 4 RCB Conduit Plan El. 37'-3 03/24/86 9-E-1609-04, Revision 5 RCB Conduit Plan El. 37'-3" 06/06/86 9-E-1610-01, Revision 2 RCB Conduit Plan E1. 68'

06/11/86 9-E-1610-04, Revision 5 RCB Conduit Plan E1. 68'

08/22/86 9-E-2469, Revision 8 RCB Conduit Plan E1. 19'

07/02/86 9-E-2470, Revision 11 RCB Conduit Plan El. 19'

11/18/85 9-E-2472, Revision 5 RCB Conduit Plan El. 19'

04/18/86 9-E-2473, Revision 8 RCB Conduit Plan El. 37'-3" 09/09/86 9-E-2474, Revision 11 RCB Conduit Plan E1. 37'-3" 09/09/86 9-E-2476, Revision 7 RCB Conduit Plan E1. 37'-3" 11/18/85 9-E-2478, Revision 5 RCB Conduit Plan El. 37'-3" 11/18/85 9-E-2478, Revision 5 RCB Conduit Plan E1. 52'

11/18/85 9-E-2479, Revision 5 RCB Conduit Plan El. 52'

11/18/85 9-E-2480, Revision 6 RCB Conduit Plan E1. 52'

3.

Fire Protection / Prevention Program This part of the inspection was conducted to evaluate the overall adequacy of the licensee's fire protection program and determine whether it is in conformance with regulatory requirements and industry guides and standards.

The NRC inspector reviewed the documentation constituting the licensee's fire protection program.

The licensee's program provided for the control of combustible materials and housekeeping for reduction of fire hazards.

Administrative controls had been established to handle disarmed or inoperable fire detection or suppression systems; to provide for maintenance and surveillances on fire suppression, detection, and emergency communications equipment; to address personnel fire fighting qualifications, and fire protection staff responsibilities; to provide fire emergency personnel designations as well as plans and actions; and to provide controls for welding, cutting, grinding, and other ignition sources, f

The licensee's criteria and administrative controls for determining fire barrier functionality with respect to requirements and commitments I

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appeared adequate. The licensee has provided controls for breaching and restoration of fire barriers.

Fire brigade training and drill records were reviewed, as well as selected

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personnel records.

Individual qualifications and training were found to meet the licensee's committed requirements. A review of the current 1.

roster of qualified personnel against the assigned fire brigade members for April 2,1987, day shift verified that brigade composition was in accordance with Technical Specification requirements. Administrative controls were in effect that insure manual fire fighting equipment and personnel protective gear were available and operable.

Formal training for qualification as fire watch was provided to selected personnel. Personnel interviews confirmed that these individuals were

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knowledgeable of their duties, responsibilities, and required actions.

The licensee's QA program for fire protection appeared adequate and

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provided for management inspections, fire prevention program audits, identification and correction followup of program discrepancies, processing program changes, system and equipnent alterations, tests, surveillances, and maintenance. Records preparation, maintenance, and retention were provided for in the administrative controls.

4.

Reactor Coolant Pump (RCP) Oil Collection System

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The NRC inspector reviewed the installation of the RCP oil collection system. The NRC inspector looked at two of the four RCPs and verified that all external potential leakage areas were adequately covered and would drain oil into a separate collection tank.

The design drawings, purchase order, and seismic analysis were reviewed which provided reasonable assurance that the system was seismically qualified and that each collection tank could hold all of the oil inventory from its associated punip.

5.

Emergency Lighting for Safe Shutdown Equipment The installation and testing of the emergency lighting required for safe shutdown was not completed at the time of the inspection. The completion of the lighting and testing (, as well as associated surveillance procedures is considered an open item 498/8717-01).

FSAR, Section 9.5.3.2.3 required the installation of Holophone M-18-2A-X-SEIS-PT emergency lighting units. However, the units that were to be installed were Model M-19-2A-X-SEIS-PT. This discrepancy was noted to the licensee and a FSAR change notice was promptly initiated. The NRC inspector noted that this was a typographical error in the FSAR. This discrepancy was adequately resolved.

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Fire Protection, Detection, Suppression The installation of all fire barriers, seals, wrap, detection, and fireproofing was not complete at the time of the inspection.

This will remain an open item pending completion (498/8717-02).

The following areas were reviewed and found to require additional work to satisfy commitments, a.

Containment In Section 9.5.1.6 of the South Texas SER, the licensee committed to comply with Section III.G.2 of Appendix R to 10 CFR 50 inside containment where cables and equipment and associated non-safety circuits of redundant trains were not separated by a horizontal

distance of more than 20 feet free of intervening combustibles or fire hazards.

Because the redundant safe shutdown trains within containment were to be protected in accordance with NRC guidelines,

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the NRC concluded that the installation of an area-wide fire

detection system in the reactor containment building would not significantly increase the level of safety.

Therefore, the NRC found the omission of an area-wide fire detection system was an acceptable deviation from Section F.1 of Appendix A to BTP APCSB 9.5-1.

Subsequent to the SER, in Amendment 3 to the FSAR, the licensee

modified their commitment for compliance with the technical requirements of Appendix R inside containment.

Specifically, the licensee proposed and installed a manually actuated special hazard water suppression system inside containment for use in separating cables and associated non-safety circuits not separated by a distance of more than 20 feet.

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During a meeting on March 18, 1987, the NRC expressed concern i

regarding the acceptability of this deviation.

The NRC's specific concerns revolved around the manual nature of the suppression system in lieu of the passive requirements of Section III.G 2 of Appendix R.

At the meeting, the licensee proposed that the system would not be operated until a plant operator was dispatched into the containment

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to investigate the need for activating the system.

The NRC was

concerned that excessive time delay in system activation could lead to fire damage of redundant safe shutdown trains and was unacceptable.

The licensee responded to the NRC's concern by several physical and

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procedural changes to the system.

The system was inspected and the proposed procedural changes were reviewed during the inspection. At t

the conclusion of the inspection, the NRC required that the licensee perform a detailed safety evaluation of the proposed system and

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associated procedures which demonstrates the basis for equivalency to

the requirements of Appendix R,Section III.G.2.

The resolution of this item will remain open (498/8717-03).

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b.

Fire Suppression Systems Section E.3.C of Appendix A to BTP APCSB 9.5-1 states that automatic sprinkler systems should, as a minimum, conform to the requirements of appropriate standards such as NFPA 13 and NFPA 15.

During the inspection, the licensee requested a deviation from NFPA 13-1976 to the extent that it requires the deflectors of sprinklers in bays formed by beams to be located 1 to 18 inches below floor decks.

The licensee stated that in some cases, sprinklers have been relocated to avoid obstructions or to optimize spray coverage of cable trays.

The licensee requested a deviation for these cases.

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While reviewing the requested deviation, the NRC observed sprinklers located in bays formed by beams which exceeded 18 inches below the floor deck and were not relocated due to obstructions or to optimize spray coverage of combustibles.

The sprinkler deflectors were in their as-constructed locations.

The licensee committed to relocate j

such sprinklers in accordance with the requirements of NFPA 13 with respect to deflector to ceiling distance in bays formed by beams.

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The South Texas SER states that automatic total flooding Halon 1301 fire suppression systems were provided for the control room computer room and sub-floor space, associated battery and charger rooms, relay room, and technical support center computer room and sub-floor space.

The systems were designed to provide a concentration of 7 percent Halon 1301 within 10 seconds of discharge and meet NFPA 12A, j

" Standard on Halon 1301 Fire Extinguishing Systems."

During the inspection, the NRC inquired whether full-scalb Halon concentration testing had been performed on the relay room Halon 1301 system.

The licensee responded that testing had not yet been performed, but would be accomplished prior to fuel load.

Upon inspection of the relay room (Fire Area 1, Fire Zone Z032), the NRC noted that thresholds were not installed under fire zone boundary doors.

The NRC suggested that such thresholds be installed to ensure t

the ability to contain the Halon 1301.

The licensee concurred with the NRC's recommendation and will install thresholds in the relay

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room as required to successfully pass Halon concentration testing.

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The relocation of sprinklers, completion of Halon concentration testing, and the addition of thresholds in the relay room are considered an open item (498/8717-04).

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c.

Fire Detection Section E.1 of Appendix A to BTP APCSB 9.5-1 provides the minimum

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requirements for fire detection systems.

Detection systems, as a minimum, should comply with NFPA 720, " Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems."

NFPA 720 indicates that detectors should be located in accordance

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with NFPA 72E which provides guidance on the location and spacing of

detectors.

Table 4.2 of the licensee's FHAR stated that fire

detectors were to be located in accordance with NFPA 72E-1978 and stated that each bay formed by beams which project more than i

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18 inches below the ceiling and which were more than 8 feet on-center, should be treated as a separate area requiring at least one detector.

i During the inspection, the NRC identified several plant areas where the above criteria was not met, such as the cable spreading rooms and l

the catwalk area above the control room ceiling.

In general, the.

ceilings in these areas have bays which were formed by beams projecting greater than 18 inches from the ceiling and which were between 7 feet and 8 feet on centers.

Strict interpretation of-Section 3.5.1.1 of NFPA 72E would require this configuration to have a detector in at least every area formed by every other beam. The licensee has installed detectors on the ceiling in-these plant areas in bays formed by every third or fourth projecting beam.

This configuration does not conform to the licensee's commitment.

The licensee committed to add detectors to beam pockets such that the criteria of NFPA 72E is met in accordance with commitments made in the FHAR.

The additional detectors in beam pockets is an open item (498/8717-05).

d.

Portable Fire Extinguishers Section E.6 of Appendix A to BTP APCSB 9.5-1 provides staff guidelines regarding the installation of portable fire extinguishers.

It states that fire extinguishers should be provided in accordance with guidelines of NFPA 10, " Standard on the Installation of Portable Fire Extinguishers."

Table 4.2 of the licensee's FHAR states that portable extinguishers, in accordance with NFPA 10-1975, are provided at locations throughout the plant including locations that contain or could present a fire exposure hazard to safety-related equipment.

During the inspection, the NRC observed that the seismic catwalk area located above the control room (Fire Area 1) was not provided with a fire extinguisher

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in accordance with the licensee's commitment to the requirements of NFPA 10.

The licensee committed to install a fire extinguisher in this location in order to meet their commitment.

This item will remain open pending the addition of the portable fire extinguisher

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l (498/8717-06).

i e.

Fire Barriers

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The South Texas Project has utilized Rodofoam as a seismic gap

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sealing material.

This material is combustible and is not fire rated in thicknesses and depths normally used at STP.

Approximately 1200 linear feet of this material was installed in slabs and walls at

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South Texas which were required to be fire rated or serve as fire area boundaries.

The licensee stated that they will remove all I

Rodofoam in required barriers for 12-inch depth applications and replace it with approved fire rated seals.

In addition, the licensee stated that they will perform a fire test to evaluate thicker

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applications of Rodofoam used in seismic gaps to determine the acceptability of:

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(1) Leaving the Rodofoam in place without modifications by demonstrating it is a 3-hour fire-rated fire seal in the thickness and depth installed, or i

(2) Combine the Rodofoam in place with an additional approved fire

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seal material to fonn a fire-rated barrier qualified by a

standard fire test.

The licensee committed to submit final seismic gap fire seal details

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and supporting test data for NRC review if Rodofoam was to be

' utilized in any final configuration. This item will remain open

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p(ending completion of the licensee's work on the Rodofoam issue 498/8717-07).

Section D.1.j of Appendix A to BTP APCSB 9.5-1 states that fire i

barriers enclosing separate fire areas should have a minimum fire rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The NRC observed removable block wall sections in the boundaries of Fire Areas 25 and 26. The licensee's FHAR states

that the boundaries of these fire areas are 3-hour rated. During the

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inspection, the licensee could not provide test data or an engineering evaluation supporting the 3-hour rating of these removable block wall sections.

The removable sections were constructed of solid concrete blocks with off-set joints stacked to

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l the same thickness as the wall in which they are installed. The licensee committed to evaluate the removable wall sections for

j equivalency to a 3-hour rated wall.

If not found equivalent, the

walls will be upgraded to a 3-hour fire wall or provided with an equivalent level of fire protection for the hazards present. This is

>

l consideredanopenitem(498/8717-08).

f The circuits for the centrifugal charging pumps (CCP) are located in a tray below Fire Area 77. The only unrated 3enetrations in the Fire i

Area 77 slab are two HVAC ducts which do not lave. fire dampers. The

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licensee committed to either install fire dampers or protect the l

train C cables for the CCP and submit a deviation for not having

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dampers. Thisisconsideredanopenitem(498/8717-09).

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7.

Post-Fire Safe Shutdown Capability

a.

Systems Required for Safe Shutdown

The general fire protection design objective at South Texas Project

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is to provide two redundant, safe shutdown pathways for bringing the plant to hot standby and then achieving and maintaining cold

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shutdown, after a fire in any location. The systems to be used were grouped according to the performance goals for PWR safe shutdown functions to achieve both hot standby and cold shutdown.

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(1) Reactivity Control Upon notification of a major fire, initial reactivity control is provided by initiating a reactor manual trip from the control room. The control rods will be inserted into the reactor core thereby bringing it subcritical. The reactor may also be tripped from outside the control room by opening the reactor trip system breakers in the electrical auxiliary building, elevation 60.

Additional negative reactivity required to achieve and maintain cold shutdown will be added by boration. The borated makeup will be providad by the chemical and volume control system (CVCS) centrifugal charging pumps 1B (train A power) and 1A (train C Power) through the normal or alternate charging lines, and/or the RCP seals. The positive displacement charging pump (TSC diesel power)(can also supply borated makeup to the reactor coolant system RCS) via the RCP seals. The charging pumps which normally take suction from the volume control tank, will be realigned to take suction from the refueling water storage tank (2500 ppm minimum boron concentration per Technical Specification (TS))ortheboricacidtank(7000ppmminimum boron concentration per TS.)

(2) Reactor Coolant Makeup (Level and Pressure Control)

Reactor coolant system inventory control is maintained by supplying borated makeup to the primary coolant via the charging

pumps as discussed above, controlling RCS letdown, and assuring the integrity of the RCP seals while monitoring pressurizer level.

Reactor coolant pump seal integrity is maintained by ensuring-that component cooling water flow is established and continued.

This provides the necessary cooling for the RCP thermal barriers or seal injection charging.

RCS normal and excess letdown are initially isolated during a post-fire shutdown. Once charging flow has been reestablished, RCS letdown will be provided through the normal letdown pathway, excess letdown pathway, or seal letdorn to the CVCS or diverted to the holdup tanks. The reactor vess.1 head vent line may also be used as a letdown pathway to the pressurizer relief tank.

lished by using the pressurizer RCS pressure control is accomp(PORVs) or the pressurizer power operated relief valves auxiliary spray for depressurization, or the pressurizer backup heaters to maintain or increase system pressure.

There are two pressurizer backup heaters to maintain or increase system pressure. There are two pressurizer PORVs one powered from train A and one from train 8, to provide redundant means for

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depressurization.

The pressurizer auxiliary spray may also be used to collapse the steam bubble in the pressurizer to decrease pressure.

In addition, the reactor vessel head vent valves may be used as necessary to decrease RCS pressure if the PORVs are

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not available.

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Pressurizer heater backup groups 1A (train A power) and 1B (train C power) are used to maintain or increase pressurizer pressure to keep the steam bubble in the pressurizer.

The

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backup heaters together with use of the pressurizer PORVs allow

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the necessary subcooling during the RCS cooldown to prevent void formation in the vessel.

During RCS depressurization the high head safety injection pump will be manually blocked to prevent initiation.

This may be done at the 4160V ESF switchgear pump breakers for each train for shutdown from outside the control room.

Similarly, the

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safety injection accumulators will be manually isolated during RCS depressurization to prevent injection.

If power is unavailable to any one of the accumulator discharge isolation valves, depressurization of the accumulator tanks can be accomplished by opening either of the accumulator nitrogen

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supply header vent valves in conjunction with the affected accumulator vent valve.

L (3) Decay Heat Removal Decay heat will be removed from the reactor following a scram via the four steam generators by natural circulation or, if RCPs are available, by forced RCS circulation.

Feedwater is supplied to the steam generators by the auxiliary feedwater system to i

provide makeup for the inventory discharged as steam from the steam generator PORVs and backup safety relief valves.

The auxiliary feedwater system consists of three motor-driven pumps and one turbine-driven pump each supplying high pressure feedwater to the secondary side of a dedicated steam generator.

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The motor-driven auxiliary feedwater pumps 11, 12, and 13 are powered from trains A, B, and C, respectively.

Each supplies feedwater to its associated dedicated steam generator which has a PORV powered from the same train as the pump.

The turbine-driven auxiliary feedwater pump is powered by steam from Steam Generator ID main steam line, and feeds Steam Generator 10.

The PORV for Steam Generator 10 is powered from the train D Class 1E battery which is charged by the train A diesel generator.

The i

auxiliary feedwater system and steam generator PORVs can be operated from the main control room or the auxiliary shutdown i

panel.

• The auxiliary feedwater pumps are aligned to take suction from the 525,000 gallon capacity auxiliary feedwater storage tank

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(518,000 gallon minimum TS reserve capacity). Nonnally, two auxiliary feedwater pathways will be utilized for a post-fire

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shutdown, which would give approximately a 22-hour supply of water from the auxiliary feedwater storage tank (AFST). This

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allows sufficient time for cooldown, including an 8-hour soak period, to reach residual. heat removal (RHR) system entry conditions.

If only one auxiliary feedwater pump is available, a single pump has enough capacity to supply a second steam generator to sustain the natural circulation cooldown. The interconnection of any auxiliary feedwater pump to a second steam generator is accomplished by operating a crosstie header valve at the pump discharge, either from the control room or locally for shutdown

from outside the control room.

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Additional makeup water for the AFST from the 1,000,000 gallon

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l demineralized water storage tank is available, if required, after 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.

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(4) Process Monitoring The following process monitoring instrumentation is available directly at auxiliary shutdown panel, as well as in the control room:

Pressurizer level

RCS wide range T cold

Steam generator wide range level (4 S/G's)

Neutron flux monitor RHRtemperature(3 loops)

RHRflow(3 loops)

Centrifugal charging pump flow (2)

Essential cooling water pumps discharge pressure (6)

Essential cooling water pumps discharge valve position (6)

RCS pressure Auxiliary feedwater flow to each steam generator (4 S/G's)

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In addition to the above direct instrumentation, South Texas Project has installed a qualified display processing system (QDPS) in the main control room and at the auxiliary shutdown panel. QDPS is a qualified Class 1E data acquisition and display sytem designed to meet the isolation and separation requirements for 10 CFR 50, Appendix R. safe shutdown equipment trains. The six QDPS function keyboard / display units in the control room and two function keyboard / display units on the auxiliary shutdown panel will provide redundant monitoring of

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all of the above paraneters and in addition give the following

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process indications:

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• Pressurizer pressu>e

Main steamline pressure (4 S/G's)

RCS wide range T hot Refueling water storage tank level

Auxiliary feedwater storage tank level Reactor core exit temperature

Letdown flow

Volume control tank level

RCP seal injection flow CCW pump discharge pressure

CCW flow to engineered safety feature components

Essential cooling water flow

RCS subcooling

Reactor vessel water level (5) Support Systems The safe shutdown components and systems described in paragraphs 7.a.(1) through 7.a.(4) require the operation of a number of critical support systems to properly perform their safe shutdown function.

The following systems must have one train operating to support the post-fire safe shutdown:

Component cooling water (CCW) system (3 loops)

Essential cooling water system (3 trains)

Class 1E standby diesel generators (3 trains)

Class 1E AC power distribution system (3 trains)

Class 1E batteries and DC distribution system (4 trains)

Instrument air system Emergency lighting system

Safety-related heating ventilation and air conditioning (HVAC) systems

Qualified display processing system (QDPS)

Communication system

Balance of plant diesel to power instrument air compressor

Technical support center diesel to power positive displacement charging pump

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l (6) Cold Shutdown The reactor coolant system temperature and pressure will be reduced as described in the preceding sections using forced circulation if reactor coolant pumps are available, or natural circulation to reject decay heat to the steam generators. The auxiliary feedwater pumps continue to provide makeup to the steam generators for inventory discharged as steam.

Reactivity will be controlled during the cooldown by continuing to monitor neutron flux and by obtaining reactor coolant samples at the post-accident sampling system lab to analyze for boron concentration.

Boration of the RCS, by means of the CVCS charging pumps taking suction from the refueling water storage tank (2500 ppm boron concentration) or the boric acid tank (7000 ppm boron concentration), will continue as required to

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maintain the required shutdown margin.

l Once the reactor coolant system temperature and pressure have been reduced to RHR system entry conditions (less than 350*F, less than 350 psig), cooldown to cold shutdown can be acheived using this system. Three redundanct trains are available, any one of which is capable of transfering sufficient reactor decay heat to the CCW system via its heat exchanger to achieve and maintain cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

For shutdown from outside the control room, the system can be operated from the auxiliary shutdown panel with some local operations at motor control center breakers and relay racks.

(?) Alternate Shutdown In the event of a fire in the main control room which results in functional loss of control room instrumentation and controls, or requiring evacuation of the control room, the licensee will use the auxiliary shutdown panel (ASP) and local operation of required equipment to achieve and maintain cold shutdown.

The reactor will be manually tripped from the control room upon receipt of the evacuation order.

Transfer of control from the control room to the ASP and local control stations is primarily achieved at local transfer switch panels located in the three redundant switchgear rooms in the electrical auxiliary building, elevations 10 ft. (Fire Area 2), 35 ft. (Fire Area 3), and 60 ft. (Fire Area 4).

The remainder of the transfer switches are located at the ASP on elevation 10 ft. of the electrical auxiliary building (Fire Area 7), in the three redundant Class 1E standby diesel generator rooms, and on the ventilation fan motor control centers at the essential cooling water intake structure.

The transfer switches provide isolation of safe shutdown equipment control circuits from the potential damaging effects of a control room fir _

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8.

Procedures The procedures reviewed during this inspection are listed in paragraph 2.

These include a post-control room fire safe shutdown procedure, Technical Specifications surveillance procedures for safe shutdown equipment and systems, an emergency classification procedure, emergency operating procedures, and fire protection administrative procedures.

A sampling of fire preplans was also reviewed.

a.

Control Room Evacuation Procedure IPOP04-ZZ-0001

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l In the event of a fire in the main control room which necessitates a

control room evtcuation, the licensee may shutdown the reactor from

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outside the control room in accordance with Procedure IPOP04-ZZ-0001.

l The control room operating shift complement consists of the following personnel:

Title Control Room Evacuation Assignment i

Shift Supervisor Auxiliary Shutdown Panel, EAB elev 10'

Unit Supervisor A Train ESF Switchgear Room, EAB elev. 10'

Primary Reactor Operator Auxiliary Shutdown Panel. EAB elev. 10'

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Secondary Reactor Operator C Train ESF Switchgear Room, EAB j

elev. 60'

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Mechanical-Electrical B Train ESF Switchgear Room, EAB Auxiliary Building elev. 35'

Reactor Plant Operator

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Turbine Generator Building DGB (if required), then ECW intake Reactor Plant Operator structure These six people are required to implement the control room evacuation procedure.

The shift supervisor is in charge of the

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I normal operating shift and he continues in that role upon entry into

the procedure.

He also serves as the emergency director of the j

emergency response organization until the technical support center is activated.

The fire brigade itself is manned by on-shift chemistry technicians.

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Once the decision to evacuate the control room has been made, the

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primary reactor operator will manually trip the reactor from the

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control room driving the control rods in for initial reactivity i

control.

The primary and secondary operators will each attempt, if time permits, to perform three additional manual actions prior to I

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evacuating.

The operating shift personnel then proceed to their post evacuation locations as indicated above, to implement their assigned procedure addenda. The remainder of the shutdown is implemented and directed from the auxiliary shutdown panel (ASP) as described in paragraphs 5.a.(1) through 5.a.(6) in accordance with the control room evacuation procedure.

The ASP is located in the auxiliary shutdown area, in the southeast part of the electrical auxiliary building (EASB), elevation 10 ft.

Transfer of control from the control rcom to the ASP and local control stations is accomplished using the transfer switch panels in

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the three ESF switchgear rooms and transfer switches on the ASP a

itself, at the Class 1E standby diesels, and at the essential cooling water (ECW) intake structure.

Controls for the following systems and components are at the ASP:

Safety injection accumulators discharge valves (3)

Let down stop and isolation valves

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Boric acid transfer pumps 1A and 1B

Motor driven auxiliary feedwater pumps (3)

j Turbine driven auxiliary feedwater pump (1)

Pressurizer PORVs (2)

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Pressurizer block valves (2)

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Pressurizer backup heaters 1A and IB j

RHR pumps and isolation valves (3 loops)

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Reactor vessel head vent valves j

Essential cooling water pumps

b.

Fire Preplans Fire preplans are grouped by buildings, with a specific preplan for fires in each fire zone.

The fire preplans for the main control room

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and the pressurizer area were reviewed with respect to applicability-

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to post-fire safe shutdown and the operator action list, which will

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be an attachment to all preplans after the present update cycle l!

(target completion date May 30, 1987).

The preplans are not considered procedures but rather guideline documents for use by

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control room personnel and fire brigade members.

As such, review and

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approval is similar to that followed for nonsafety-related

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procedures, except that no license compliance review is required and attachments such as the operator action list may be revised without formal review.

l The operator action list provides a summary of operator actions identified in the safe shutdown pathways fire hazard analysis

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entitled, " Post Fire Operator Actions and Equipment Protecticn Requirements," Document No. 5A019MFP001, Revision 3.

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actions required to mitigate damage to safe shutdown components and

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systems, and to preserve safe shutdown pathways are listed along with j

the time periods during which they should be performed.

The fire

i preplan documents are available to the operators in the main control

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room and at the auxiliary shutdown panel for their reference and

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information.

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c.

Procedure Walkdown The control room evacuation procedure (1P0P04-ZZ-0001 Revision 0)

walkdown was initiated using six people from the licensee's operating staff with the proper training and qualifications to fill the control room operating shift positions.

At the time of the walkdown, the procedure was not yet through its initial review and approval cycle.

Since the procedure is symptom oriented, the following initial conditions were presented:

Fire in control room of sufficient size to require evacuation Coincident loss of offsite power Reactor at 100 percent power All 3 standby diesel generators failed to auto start All system lineups as normally found at full power One inspector accompanied the shift supervisor and the primary reac. tor operator to the auxiliary shutdown panel and remained there to observe operator actions, crew direction and leadership, communications, and training and familiarity with the procedure.

He also made choices simulating spurious operation and equipment nonavailablility as appropriate throughout the exercise.

A second inspector went with the TGB reactor plant operator first to the standby diesel generators, and then to the ECW intake structure.

The third and fourth inspectors accompanied the secondary reactor operator and the MEAB reactor plant operator to the B and C ESF switchgear rooms.

They observed lighting at local panels and work stations and along access routes, local starting and loading of the standby diesel generators, communications, local transfer switching, local operation of valves and circuit breakers, and operator training and familiarity with the procedures.

The procedure was halted at Step 5.2.26 which demonstrated that a stable hot shutdown could be achieved and a controlled rate of cooldown was to be commenced.

An ALERT was declared from the ASP within 6 minutes of the start of the event all three diesels were running and loaded within 7 minutes of start of event.

Transfer switching addenda checklists at all three ESF switchgear rooms were completed by 10 minutes into the exercise.

Feedwater flow to all four steam generators had been established within 9 minutes.

The following deficiencies were identified during the procedure review and walkdown:

In addition to the manual trip of the reactor, six additional manual actions are directed by procedure Steps 4.2 through 4.3 prior to control room evacuation.

The procedure does not direct the operators as to how these actions may be performed from outside the control room.

The applicant committed to revising the procedure to address this problem for main turbine trip, main steam isolation initiation, RCP trips, feedwater isolation

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initiation, charging pumps trip, and pressurizer block valves Closure.

t The procedure does not' include specific steps for local manual start of the standby. diesel generators in the event of loss of offsite power with failure to auto start.

Procedure should be

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revised to include these steps or provisions made.to have a l

controlled copy of a manual start procedure available to the operator at the diesel panels'.

The emergency response facility. data acquistion and display

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systems, or ERFDADS, istnot a protected system with respect to 10 CFR 50, Appendix R, safe shutdown at South Texas Project.- No credit is taken for use of'ERFDADS in the safe shutdown

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analysis.

However, the ERFDADS is called out for use in at-least four procedure steps (5.2.1.1, 5.2.21.2, 5.2.23.3, and 5.2.26.3) and as an alternate check in at least three places (5.2.5.1, 5.2.7, and 5.2.10.6).

Procedure.should be revised to i

obtain this information from' protected safe shutdown indicators available to the operator such as'those on-the ASP, QDPS, or

local indicators without relying on ERFDADS.

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It is recommended'that for purposes of the Appendix R safe shutdown training, operators be taught not be rely on ERFDADS in

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this situation.

Control room fire could result in loss of the ERFDADS or erroneous indications of system and equipment status

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i on the ERFDADS displays.

The deficiencies note above are considered an open item pending licensee resolution (498/8717-12).

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Additional concerns and recommendations were identified during the

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procedure review and walkdown.

These are not regulatory requirements -

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but are considered enhancements..Theys are:

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Step should be added to have control room personnel take appropriate keys, handheld radios,(and perform a radio check),

and flashlights as required prior to evacuating the control-

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room.

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The interplay among the various procedures that apply to'the control room fire evacuation situation should be more clearly defined.

If the control room evacuation procedure (IP0P04-ZZ-0001).

is the lead procedure, and is intended to consolidate into one procedure the' steps from one or more:other procedures, then this

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.should be'so stated.

If other procedures are to be applied at s

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given steps in the control r60m evacuation procedure, then this

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should be so stated.

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This shortcoming manifested itself'particularly during the critical time period when the shift supervisor and primary

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reactor operator first arrived at the auxiliary shutdown panel.

The procedure entitled " Emergency Direction" was used to declare an ALERT and to notify security of the situation, but this was not stated in Step 5.1.1 of the control room evacuation procedure, nor was it listed in the reference section at all.

Emergency Classification (OEPP01-ZA-0001) is listed in the

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references, but it was not observed to be physically used by the

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shift supervisor.

If the declaration of ALERT due to control room fire and evacuation is sufficient to activated fire brigade personnel, then this.should be added to the control. room evacuatioa procedure.

If the notification of security of the situation at Step 5.1.1 is sufficient to prompt security personnel to activate the emergency response organization, then this should be so stated; if not, appropriate steps should be added to the procedure to activate or direct someone else to activate the emergency response organization.

Procedure (OPG03-2F-00012), " Fire Fightirig", was not referenced in the control room evacuation procedure nor was it observed to

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be used during the walkdown, yet it contained' fire response i

action checklists for the shift supervisor and control room operator.

If it is not applicable to control room fires, this

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fact should be noted in both procedures.

Notes should be added at appropriate steps in the cooldown

portions of the procedure, to have the operator check for formation of a void in the vessel..The emergency operating procedure entitled " Natural Circulation Cooldown with Steam Void in Vessel," (1 POP 05-E0-ES03), should'be added to the Section 6 references.

Step should be added to the end of each addendum in the control room evacuation procedure to call in to the shift supervisor that the list had been completed.

This provides positive verification to the shift supervisor that these sections of the procedure have been implemented.

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Step 1.0, Addendum 1, of Procedure OPGP03-ZF-0012 should be

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amended to have the fire brigade leader notify the shift

supervisor at the ASP of response to fire for the case of a control room fire with evacucation.

This provides positive verification to the shift supervisor that the fire brigade has assembled and responded.

The procedure should provide some guidance as to when and how.

the control room fire preplan (1EAB01-FP-0034) guideline and its

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post-fire operator actions list are to be used with respect to the control room evacuation procedure.

During the walkdown, the ASP personnel referred to the postfire operator action list once a controlled cooldown rate had been established, to verify that i

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the recommended actions on the list had all been performed via the procedure.

No mention is made in the control room evacuation procedure of the shift supervisor's role as emergency director or the turnover of this responsibility once the technical support center is activated.

If this information is adequately addressed in an. emergency plan implementing procedure, then such a procedure should be listed in the reference section.

Availability of a work table or podium (s) for laydown of procedure books used by the operations personnel would be beneficial in the final configuration of the auxiliary shutdown panel room.

9.

Associated Circuits The South Texas Project was inspected for compliance with the following associated circuit provisions of 10 CFR 50, Appendix R:

Common bus concern Spurious signal concern Common enclosure concern a.

Common Bus Concern The common bus concern is found in circuits, either safety-related or nonsafety-related, where there is a common power source with shutdown equipment and the power source is not electrically protected from the circuit of concern.

The common bus concern consists of two items:

Circuit breaker / fuse coordination High Impedance fault analysis (1) Circuit Breaker / Fuse Coordination Circuit coordination was inspected by reviewing the time-current characteristic curves developed during the licensee's bus coordination study.

At the South Texas Project, a sample of circuits was selected arid their corresponding time-current characteristic curves were examined for proper coordination.

During the inspection the following circuits were reviewed:

CIRCUIT COMMENT MCC-E1A1 Coordination Satisfactory MCC-E1A2 Coordination Satisfactory-l

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t

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MCC-E181 Coordination Satisfactory MCC-E1C2 Coordination Satisfactory TSC 480V Load Center Coordination Satisfactory PL-139A (125 VDC)

Coordination Satisfactory PL-139B (125 VDC)

Coordination Satisfactory 120 VAC Dist. PNL. El-I Coordination Satisfactory 120 VAC Dist. PNL. El-IV Coordination Satisfactory The licensee's circuit coordination practices were determined to be acceptable.

(2) High Impedance Faults The high impedance fault concern is found in the case where multiple high impedance faults exist as loads on a safe shutdown power supply and cause a loss of the power supply source breaker prior to clearing the high impedance faults.

In response to this concern, the licensee submitted Calculation EC-5061, "High Impedance Cable Failures," which was

performed to evaluate the exposure of safe shutdown supplies to loss due to multiple high impedance faults.

The analysis determined that the worst case high impedance fault load would result in the loss of the individual load feeder breaker prior to the loss of the supply source breaker.

A review of the licensee's analysis found this concern to be adequately addressed.

,

b.

Spurious Signals The spurious signals concern is made up of two items:

False motor, control and instrument indications such as those encountered at the 1975 Browns Ferry fire.

These could be caused by fire initiated grounds, short, or open circuits.

Spurious operation of safety-related or nonsafety-related components that would adversely affect shutdown capability (e.g.

RHR/RCS isolation)

(1) High/ Low Pressure Interfaces The following high/ low pressure interfaces and their corresponding method of control have been identified by the licensee:

INTERFACE METHOD OF CONTROL RHR Suction Valves to be maintained closed with

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<

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breakers open when RCS pressure exceeds RHR system pressure Pressurizer PORVs Administratively controlled by post-fire operator actions list to fail the valve closed Pressurizer PORV Admin. control by post-fire Block Valves operator actions list to fail the valves closed.

In addition to the above, the licensee submitted an analysis to determine loss rate via the normal letdown, excess letdown, and reactor head vent lines. The analysis determined the following:

NORMAL LETDOWN: Maximum loss rate:

150 gpm (FSAR Table 9.3.10)

EXCESS LETDOWN: Maximum loss rate: 30 gpm (FSAR Table 9.3.10)

REACTOR HEAD VENT: Maximum loss rate: 50 gpm 0 1500 psi (FSARTable 9.3.9)

The analysis determined the capacity of an individual charging pump to be 230 gpm (FSAR Table 9.3.10). The loss rate through any one of the above flow paths could, therefore, be replenished by the operation of a single charging pump.

The licensee's analysis and method of control were found to be acceptable.

(2) Current Transformer Open Circuit Secondaries At the time of the inspection it was identified that the licensee had not prepared a site specific analysis of this'

concern. The licensee's lack of an analysis makes this concern an open item.

(498/8717-10)

(3)

Isolation of Fire Instigated Spurious Signals The licensee has provided isolation of fire instigated spurious signals by various methods including isolation switches; a qualified display processing system (QDPS); providing 3-hour fire-rated protective covering on cables, trays, and enclosures; and administrative controls.

On a random basis, the train A transfer switch panel (4Z351ZLP-653)

and the qualified display processing system (QDPS) were selected for review of proper spurious signal isolatio.

.

The train A transfer switch panel is located in the train A switchgear room.

In the event of a major fire involving the control room which requires evacuation, isolation switches located within this panel will be used to transfer control of the train A loads important to safe shutdown from the control room to the ASP located in Fire Area 7Z701. Should the control room fire damage circuits prior to the transfer of control, fuse replacement would not be required as the design is such that redundant fusing is automatically accomplished upon the repositioning of the transfer switch. The licensee's methodology for mitigating spurious signals in the event of a control room fire was found to be in conformance with Inspection and Enforcement (IE) Information Notice 85-09 and is, therefore, acceptable.

The QDPS provides signal processing and display of safe shutdown parameters at both the control room and the ASP.

The system is microprocessor based and all signals are electrically isolated between the control room and the ASP.

Circuit failures in the form of open circuits, hot shorts, or shorts to ground at either the control room or ASP will not affect control or display capability at the other location.

Four remote processing unit cabinets are powered from associated trains (trainA,B,C,orD)andareeachlocatedinseparate fire areas. The train A and C QDPS processing cabinets are located in separate fire areas and each is capable of displaying all four channels of safe shutdown indications at either the control room or the ASP. A review of this system found it to be in compliance with the spurious signal concern and is, therefore, acceptable.

It should be noted, however, that the installation of the 3-hour fire-rated protective wrapping on cables, trays, and enclosures of concern was still in progress and is not yet complete. The licensee's incomplete installation of protective fire wrap causes the spurious signal concern to remain an open item as identified in paragraph 6.

c.

Comnon Enclosure The common enclosure associated circuit concern is found when redundant circuits are routed together in a raceway or enclosure and they are not electrically protected or fire can destroy both circuits due to inadequate fire barrier penetration.

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At the South. Texas Project this concern was found to be addressed

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satisfactorily when a random sample of associated circuits, routed together with circuits-important to safe shutdown, were examined and found to be protected by coordinated protective devices.

In addition, the licensee stated that nonsafety-related cables were never routed from one division to another and cables for redundant safe shutdown divisions are never routed within a common enclosure.

A physical in plant inspection did not identify any exceptions to these statements.

(1) Cable Routing To inspect.for this concern a sample of cables important to safe shutdown was selected and. reviewed for redundant circuit separation compliance.

The following cables were selected'for_ review:

COMPONENT CABLE NUMBER FUNCTION Positive Disp.

N1CVBCC1HA Power Char 0ing Pump Charging Pump 1B

.A1CVAAC1GA Power Charging Pump 1A CICVACC1GA

. Power A1CV-MOV-8377B A1CVAKC1HA Power CICV-M0V-8377A CICVAMC1HA Power Steam Generator AIMSAAC1HA'

Power-PORV - A (AIMSPV7411)

A1MSABC1HA Power A1MSAACISA Power A1MSAECISA Power Steam Generator B1MSADC1HA Power PORV - B (B1MSPV7421)

BIMSAEC2SA Power B1MSABC2SA Power Steam Generator C1MSAGC1HA Power

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PORV - C

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(C1MSPV7431)

CIMSAEC4SA Power C1MSACC1SA Power Steam Generator A1MSABC1HA Power PORV - 0 (D1MSPV7441)

A1MS20CISA Power D1MSABCISB

. Power

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33'

Diesel Generator A1SPAAC1SA-Power Load Sequencer Train-A Diesel Generator BISPACCISA Power Load Sequencer.

Train-B Diesel Genrator CISPADC1SA Power Load Sequencer Train -.C Pressurizer Pressure A1RC22C1PA Instrument-(A1 RCPT 0455)

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Instrument A1RC22C1PB A1RC22C1PC Instrument A1RC22C1PD Instrument Pressurizer Pressure D1RC22C1PA Instrument (D1 RCPT 0456).

01RC22C1PB Instrument D1RC22C1PC Instrument D1RC22C1PD-Instrument Pressurizer Pressure D1RC22C1PA-Instrument (D1 RCPT 0456)

D1RC22C1PB Instrument D1RC22C1PC Instrument D1RC22CIPD Instrument.

Pressurizer Pressure B1RC22CIPA Instrument, (B1 RCPT 0457)

B1RC22C1PB Instrument B1RC22C1PC Instrument-B1RC22C1PD Instrument Pressurizer Pressure CIRC 22C1PA Instrument (C1 RCPT 0458)

CIRC 22C1PB Instrument, CIRC 22C1PC Instrument CIRC 22C1PD Instrument Pressurizer Level A1RC22C2PA Instrument (A1RCLT0465)

A1RC22C2PB Instrument.

A1RC22C2PC Instrument A1RC22C2PD.

Instrument l

i Pressurizer Level D1RC22C2PA

. Instrument j

(A1RCLT0466)

)

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<-

,4 a

DIRC22C2PB Instrument D1RC22C2PC Instrument DIRC22C2PD Instrument Pressurizer Level B1RC22C2PA Instrument (B1RCLT0467)

81RC22C2PB Instrument 81RC22C2PC Instrument BIRC22C2PD Instrument Pressurizer Level CIRC 22C2PA Instrument (C1RCLT0468)

CIRC 22C2PB Instrument CIRC 22C2PC Instrument CIRC 22C2PD Instrument Based on a review of cable routing drawings, Bechtel calculation,

" Appendix R Separation Inside STP Unit Containment,"

(Calc. No. 5A011MC6065, Revision 0, March 19, 1987) as well as, physical in-plant inspection of Unit 1, the following concerns were identified:

The installation of 3-hour fire-rated protective wrapping on cables, trays, and enclosures of concern is still in progress and is not complete.

Within containment, protection for the pressurizer level and the RCS pressure monitoring systems is incomplete. Bechtel Calculation 5A011MC6065 details the specific methodology to be used to assure the availability of at least one channel of pressurizer level and pressure indication in the event of fire in the containment building.

In general, the train B pressurizer level and pressure channels (LT-0467 and PT-406) are to be protected.

The licensee's analysis of protection requirements for this concern were found to be acceptable. However, the incomplete installation of equipment and circuit protection methods as described above, causes this concern to remain an open item as identified in paragraph 6.

10. Communications j

The licensee has identified two communications systems available for safe shutdown:

LOSSY LOOP repeater / radio system Sound powered phones The LOSSY LOOP repeater / radio system has not been analyzed to determine availability in the event of fire. The licensee will use this system if

J o

35 it is available for alternate shutdown communications; however, the applicant does not take credit for this system.

The sound powered phone system is the designated means of communication in the event-of fire requiring alternate shutdown.from outside the control room.

During ~the procedural walkdown of alternate shutdown requiring control room evacuation, this system was observed to perform satisfactorily..It is important to. note, however, that the applicant has not completed an analysis to determine the protection requirements necessary to insure the availability.of-sound powered phone-system in the event of fire.

Pending completion of the licenee's analysis,z as well as.any required design changes which may be necessary to achieve complete compliance, communications will remain an open item (498/8717-11).

11. Open Items Open items are matters which have been discussed with the licensee, which will b'e reviewed further by the inspector, and which involves some action on the part of the NRC or licensee or both.

Open items disclosed during the inspection are discussed in paragraphs 5, 6, 8, 9, and 10 of the report.

These open items must be dispositioned prior to fuel load.

12.

Exit Interview An exit interview was conducted on April 3,1987, with those personnel denoted in paragraph 1 of this report.

The NRC resident inspectors.for construction also attended.

At this~ meeting, the scope of the inspection and the findings were summarized.

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