IR 05000528/1985006

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Insp Repts 50-528/85-06,50-529/85-11 & 50-530/85-08 on 850304-08.No Violation or Deviation Noted.Major Areas Inspected:Compliance w/10CFR50,App R Sections G,J,L & O
ML17298C077
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/02/1985
From: Miller L, Qualls P, Ramsey C, Thomas Young
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17298C076 List:
References
50-528-85-06, 50-528-85-6, 50-529-85-11, 50-530-85-08, 50-530-85-8, NUDOCS 8504290016
Download: ML17298C077 (26)


Text

U. S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos.

50-528/85-06, 50-529/85-11, 50-530/85-08 Docket Nos.

50-528, 50"529, 50-530 License 'No.

NPF-34 Construction Permit Nos:

CPPR-142 and CPPR-143 Licensee:

Arizona Public Service Company P.

O. Box 21666 Phoenix, Arizona 85036 Facility Name:

Palo Verde Nuclear Generating Station - Units 1, 2 and

Inspection at:

Palo Verde Site, Wintersburg, Arizona Inspection conduct March 4-8, 1985 Inspectors:

P. squalls, Reactor Inspector Date igned

. Ramsey, React Inspec r

Date Signed Approved By:

T.

oung Jr.,

Chi f, Engi r

g Section

. Miller, ef, Reactor Projects Section

Date Signed V-z-3~

Date Signed Summary:

Ins ection on March 4-8 1985 (Re ort Nos. 50-528/85-06 50-529/85-11 and 50"530/85-08 Areas Ins ected:

Announced inspection by a five member team consisting of three NRC inspectors and two consultants from Brookhaven National Laboratory of the licensee compliance with 10 CFR 50 Appendix R sections G, J, L and 0.

The inspection involved 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br /> of onsite inspection by five inspectors.

Results:

No violations or deviations were identified.

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DETAILS Persons Contacted-W.

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AJ E DAB Montefour, APS/QA Bloom, APS/Licensing Huber, BPC Project Quality Coordinator Larson, BPC/Engineering/Licensing Kershaw, ANPP/IRC Engineer Baldasari, BPC/Licensing McCandless, APS/Licensing Quan, APS Licensing Souza, APS Assistant Corporate QA/QC Manager Shepherd, BPC Nuclear Engineering Neal, APS Licensing Fernow, Manager, Plant Services Bynum, Plant Manager Karner, Nuclear Production Koppelman, APS Operations Smith Jr.,

Compliance Engineer Morita, APS Licensing Harris, Operations Engineering Rash, Operations Engineering Meyer, APS Fire Protection Green, APS Training Supervisor Boles, BPC Gonsowski, APS/STA Hypse, Electrical Engineer Buckingham, APS Operations Smith, APS Operations Florence, APS Operations Bragg, APS Operations Samulian, APS Operations Wilson, APS Operations Van Brunt, Executive Vice President Quinn, ANPP QA Supervisor

-"Denotes those persons attending main exit meeting on March 8, 1985.

--Denotes those persons attending second exit meeting on March 8, 1985.

The inspectors also talked with other licensee and contractor personnel during the inspectio ( ~

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2.

Documents Reviewed a

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Letter ANPP-31808, January 28, 1985, Van Brunt to Knighton,

"Inclusion of Appendix R Spurious Actuation Analysis Summary for each zone into Pre-Fire Strategies Book."

b.

Fire Notification and Response Procedure:

14AC-OZZ02, Rev.

1, December 20, 1984.

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Letter ANPP-E-117786, July 25, 1984, Spurious Actuation Analysis-SDC Isolation Valves.

d.

Conduct of Shift Operation, 40AC-9ZZ02 Rev. 3, March 1, 1985.

e.

Letter ANP 31366, December 7,

1984, Revision to,Spurious Actuation Analysis.

Shutdown Outside the Control Room due to Fire and/or Smoke 41AO-lZZ44, Rev.

1, March 2, 1985.

g.

'Outside Control Room Fire Spurious Actuation Study; Study 01-NS-110, Rev.

1, November 6, 1984.

h.

Control Room Fire Spurious Actuation Study; Study 13-NS-109 Rev.

1, November 6,

.1984.

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SSER No. 7, December 24, 1984.

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Eighteen Month Containment Penetration Protective Relay Surveillance Test, 32ST-9ZZ01, Rev. 0, January 10, 1985.

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Molded Case Circuit Breaker Surveillance Test, 32ST-9ZZ74, Rev. 0, September 9,

1983.

Surveillance Test Procedure for the Class 4160 Bus Undervoltage Protective Relays, 32ST-9ZZ03, Rev. 0, October 29, 1984.

m.

Eighteen Month Containment Penetration Conductor Low Voltage Overcurrent Protection (S.S.T.),

32ST-9ZZ02, Rev. 0, October 16, 1984.

n.

Sixty Month Molded.Case Circuit Breaker Surveillance Test, 32ST-9ZZ07, Rev.,0,- September 31", 1983.

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Pe Sixty Month Containment Penetration Conductor Iow Voltage Circuit Breaker INSP/PM,'2ST-9ZZ05,'ev.

1, October 29, 1984.

Sixty Month Containment Penetration Conductor 13.8KV Breaker Inspection,'esting and PM, 32ST-9ZZ06, Rev.

0, January 16,'198 '

PI T I 4'

Facilit Desi n - 10 CFR 50 A endix R Com liance The licensee committed to meet the technical requirements of Appendix R to 10 CFR 50 in the facility's design as discussed in Appendix 9B of Amendment No.

3 of the Palo Verde FSAR, dated April, 1982; and in other submittals to the NRR that are referenced in the SER and SER supplements.

The Appendix R criteria specified, requires that the fire protection features provided in the facility's design be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or remote shutdown station be free of fire damage.

Systems necessary to achieve and maintain cold shutdown conditions are required to be repairable in order to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from either the control room or remote shutdown station.

A collective assessment of selected areas containing structures, systems and components important to safe shutdown was made by the inspection team.

The following conclusions were ascertained:

A.

Com liance with Section III.G.2 Systems necessary to achieve and maintain hot shutdown conditions were examined for physical separation of equipment, associated circuits and protection from fire damage.

One of the following methods was utilized to satisfy this criteria:

Three hour rated fire barriers were installed between redundant safe shutdown trains.'

one hour rated fire barrier was installed around one safe shutdown train and automatic fire detection and suppression was installed in the fire area.

A minimum of 20 foot horizontal separation, with no intervening combustibles was provided between redundant trains and automatic fire detection and suppression was installed in the fire area.

Alternative shutdown capability was provided for the control room where it was not practical to utilize the methods discussed above.

Deviations approved by the NRC for certain plant areas with low fire potential and adequate separation to withstand the effects of a postulated fire were obtained.

Interim compensatory measures were taken while modifications are being performed to improve the fire 'integrity of certain existing fire barriers which were of concern to the NRC.

In general,'he, areas, systems'nd associated circuits examined were provided with adequate fire protection features to mitigate the affects of fire throughout the facility.'he inspectors concluded that the licensee safe shutdown capability can be maintained free of

fire damage and the fire protection features provided for systems needed to achieve the safe shutdown functions satisfies the criteria specified in Section III.G.2. of Appendix R to

CFR 50.

Other areas inspected are discussed below.

No violations or deviations were identified.

S urious Actuation Anal sis for A Fire in Containment Section III.G.2. of Appendix R requires that safe shutdown cables and equipment for redundant trains located in the same fire area that could prevent operation or cause maloperation of safe shutdown functions due to hot shorts, open circuits or shorts to ground be protected from fire damage.

In determining the ability of the plant to safely shutdown in the event of a fire in containment, the inspectors noted that the licensee's submittal of October 16, 1984 (page 89) to the NRC was silent regarding spurious actuation of valves and instrumentation circuits inside containment that are required for safe shutdown.

During the inspection, the inspectors informed the licensee that although their October 16, 1984, submittal to the NRC requested a deviation from the fire protection criteria specified in Section III.G.2 of Appendix R, a spurious signal analysis for safe shutdown components located inside containment is required.

The licensee acknowledged the inspector concerns and agreed to perform the analysis.

This is considered an Open Item (50-528/85-06-01),

pending NRR's review and acceptance of the licensee's submittal.

No violations or deviations were identified.

(2)

Common Bus Concern The common bus associated circuit concern relates to circuits, either non-safety related or safety-related, where there is a

common power source with safe shutdown equipment and the power source is not electrically protected from the circuit of concern.

A selected sample of such circuits were examined during the inspection which consisted of:

Charging Pumps A, B and C circuits P01 Essential Cooling Water Pumps A and B Circuits POl Essential Spray Pumps A and B Circuits POl Auxiliary Feedwater Pump B Circuit POl Atmospheric Dump Valve Nos.

178, 179, 184 and 185 circuits For all of the sample fuses, circuit breakers and relays, the coordination was satisfactory.

The licensee has an acceptable relay maintenance program which requires surveillance and

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maintenance of relays at a maximum frequency of three years.

Procedure No. 32ST-9ZZOl requires 18 month surveillance of containment penetration overcurrent protective devices per technical specification No. 8.3.2.

No violations or deviations were identified.

(3)

S urious Si nal Concern The spurious signal concern relates both to false control and instrument readings and to spurious operation of motors and valves that could adversely affect safe shutdown capability, These signals and adverse actuations could be caused by fire induced hot shorts, shorts to ground, or open circuits such as those that occurred in the 1975 Browns Ferry Fire.

(a)

Current Transformer Secondaries The licensee's internal memorandum from Bechtel Architectual Engineers of January 16, 1984 (R. A. Schmitter to C.

W. Jordan)

showed that satisfactory consideration was given to the concern for a second fire starting due to a postulated first fire causing a current transformer secondary open circuit.

However, this memorandum did not indicate that proper consideration had been given to relay malfuctions due to the same postulated fire.

This concern was satisfactorily resolved during the inspection with the inspectors verification of adequate separation.

No violations or deviations were identified.

,(b)

Hi h low Pressure Interfaces All high low pressure interface concerns were satisfactorily resolved as discussed in Appendix 9B of the FSAR.

No violations or deviations were identified.

(c)

Isolation of Other Fire Insti ated Si nals The diesel generator control and load sequencer could be affected by a control room fire.

Control from the control room would be negated.

Local control"of the diesel and loading of essential loads would be required.

This local start and load capability was determined to be satisfactory.

J No violations or deviations were identified.

(4)

Common Enclosure Concern

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The common enclosure concern relates to redundant safe shutdown circuits which are routed together in a raceway or enclosure and they are not electrically protected and a single fire could destroy both circuits due to the lack of fire protection features.

This concern was satisfactorily resolved when a sample of selected circuits were all found to be electrically protected.

Furthermore, the licensee stated that non-safety related circuits were never routed from one redundant train to another.

During the physical plant review, no exceptions to this statement were found.

In all cases, adequate fire protection features were provided to mitigated the consequences of a postulated fire.

No violations or deviations were identified.

Hi h Im cdance Faults High impedance faults due to an exposure fire appear to be unlikely as a result of the typical wide separation of most loads from a load center or motor control center.

The licensee's November 28, 1984 submittal to the NRC regarding high impedance faults (Summary Table IV) was found to be acceptable.

Of all of the components considered in this analysis, four would have enough fault energy to trip prior to any upstream breaker.

Three components (120 Volt AC, 125 Volt DC and 120 Volt instrumentation panels)

would not have enough fault energy to trip and their upstream breakers would not trip for the same reason.

The licensee's assumption that high impedance faults are five percent of the circuits normal operating current, appears to be reasonable.

No violations or deviations were identified.

Plant Differences The SER and supplemental SER's indicate Units 2 and 3 are identical to Unit 1.

During the inspection, the licensee provided the inspectors with copies of a draft unit comparison which identified construction differences between Units 1,

and 3.

All of the differences identified appear to be minor with no significant impact on safe shutdown capability.

However, the inspectors requested that the licensee formally submit an analysis of all identified differences between units to NRR for review.

This is considered an open item (50-529/85-11-01, 50-530/85-08-01)

pending NRR review and acceptance of the licensee's submittal.

No violations or deviations were identified.

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Waterti ht Door Se gratin Auxiliar Feedwater Pum s

Fire doors were examined to ensure compliance with 10 CFR 50 Appendix R Section N, which gives four options to ensure that a

fire door will protect an opening as required in case of fire.

PVNGS uses one of the applicable options for each door or area requiring protection.

In the course of the inspection it was found that the door between the two Auxiliary Feed Pump Rooms was open.

This door is a special watertight door with no self-closing or self-latching mechanism.

This was not a violation because the licensee has an hourly fire inspection in this area.

The licensee has committed to administratively ensure that the door is closed.

This item will be examined at a later inspection (50-528/85-06-02, OPEN).

No violations or deviations were identified.

(8)

Fires Occurrin Outside the Control Room By letter dated September 26, October 5, 16 and November 13, 1984, the licensee submitted the results of spurious actuation analyses and required operator actions for fires occurring in each fire zone outside the control room.

Once a spurious actuation was identified, either action or inaction of a component resulted, Actions available to operators to identify the problem and mitigate the consequences of the undesirable event were delineated.

The time constraints that affected rectification of the event were quantified.

The actions required to prevent spurious operation of equipment were identified and compensatory measures needed to implement corrective actions were specified.

In those instances where operator actions are required to mitigate the consequences of fire induced spurious signals that would affect safe shutdown capability, such actions were not delineated in procedures.

During the inspection, the licensee agreed to implement a

procedure for fires occurring outside the control room which would refer plant operators to the plant fire pre-plans that are to be revised to contain all of the specific required operator actions'nd compensatory measures specified in the analysis.

This will be accomplished by April 30, 1985 or, prior to exceeding five percent power, whichever comes first.

This is considered an Open Item (50-528/85-06-03)

pending verification by Region V.

No violations or deviations were identifie (9)

Fire Detectors Extended from Ceilin s in areas Containin Redundant Safe Shutdown Trains Where the separation criteria specified cannot be met,Section III.G of Appendix R to 10 CFR 50 requires automatic fire detection to be installed in the fire area.

The licensee committed in Section III E-l of the FSAR to install fire detection devices in accordance with Appendix A to NRC Branch Technical position 9.5-1 and the codes and standards of the national fire protection association (NFPA).

For consideration of beam construction, NFPA 72E is specific.

Where the beams exceed 18 inches 'in depth and are more than 8 feet on centers, each bay should be treated as a separate area, requiring at least one spot type fire detector.

Also, the spacing of spot type fire detectors in the direction perpendicular to the beams is required to be reduced.

The licensee's fire detector installation outside fire zone 34B in the auxiliary building and throughout the plant does not conform to the NFPA 72E criteria for beam construction.

Consideration appears to have been given to the possible effects of gas stratification at levels below the ceiling in that on a staggered basis, the detectors are installed in bays at the ceiling or installed out of bays extended from the ceiling approximately 6 inches below ceiling beams that are 36 inches in depth.

The ceiling height outside fire zone 34B of the auxiliary building is less than 20 feet and the concern for gas stratification does not appear to be significant.

During the inspection, the licensee's staff indicated that the rationale and basis for fire detector installation followed the guidance of NFPA 72E with due consideration for the effects of gas stratification, air velocities and spacing.

Justification for the detectors as-built configuration and deviations from NFPA 72E requirements will be submitted to NRR for review and acceptance prior to exceeding five percent power.

This is considered an open item (50-528/85-04)

pending NRR review and acceptance of the licensee's submittal.

No violations or deviations were identified.

B.

Com liance with Sections III.G.3 and III.L.

Where it is not possible or practical to meet the requirements of Section III.G.2. of Appendix R, alternative or dedicated shutdown capability must be provided in accordance with sections III.G.3 and III.Lof Appendix R.

Due to the adequacy of separation and protection of redundant safe shutdown trains outside the control room, the licensee provided alternative shutdown capability for only one area (control room, fire zone 17).

This capability is independent, of the control room and 'consists of a remote shutdown panel; local operations for'he charging system, diesel generators

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and reactor coolant system; and, local operation of various valves and circuit breakers.

Alternative shutdown capability is provided for one division of safe shutdown systems (Train B).

Remote shutdown capability is provided for Train "A".

However, this panel is not electrically isolated from the control zoom.

Train "B" is electrically isolated from the control room.

Disconnect/transfer switches are provided on Train "B" which are properly fused to provided true isolation as is discussed in Information Notice No. 85-09.

Given a control room fire that damages both redundant safe shutdown trains inside the control room, Train "A" could be lost in the control room and at the Train "A" remote shutdown panel.

Because of the electrical isolation features, the disconnect/transfer switches provided on Train "B" would be used to mitigate the consequences of circuit failures inside the control room and enable local control of equipment required for hot shutdown from the "B" remote shutdown panel and other local control stations.

All remote shutdown panel instrumentation and disconnect/transfer switches are contained in plant technical specification No. 3.3.3.5.

The "B" remote shutdown panel provides the capability to control the auxiliary feedwater system including atmospheric dump valves.

Instrumentation monitoring pressurizer pressure and level, reactor coolant, system hot and cold leg temperatures, steam generator pressure and level, auxiliary feedwater flow and condensate storage tank level is provided.

The control room alternative shutdown capability was determined to be satisfactory.

However, some minor deficiencies were identified and are discussed below.

No violations or deviations were identified.

(1)

Hot Shutdown Procedures Based on the control room alternative shutdown methodology used by the licensee, a supplemental safe shutdown procedure was developed and implemented for Unit 1 on March 2, 1985 (Procedure No. 41A0-1ZZ44, Revision 1) in accordance with Section III.I,. of Appendix R.

The inspectors evaluated the procedure to verify the feasibility of required operator actions that provide control of process variables such as reactivity control, reactor coolant makeup, decay heat removal, process monitoring and support functions when offsite power is available and when offsite power is unavailable.

The procedure review resulted in the inspectors concluding that the performance goals for the shutdown functions could be met within the minimum threshold criteria specified in the CESAR, SER and plant technical specifications if all required operator actions were achievabl To verify the effectiveness of the procedure, a walkdown of the procedure was conducted by the inspectors and the licensee's staff during the inspection.

The licensee provided additional operations personnel to demonstrate the required operator actions.

Therefore, normal plant operations were not interrupted during this activity.

The walkdown demonstrated that disconnect/transfer controls, control switches, circuit, breakers, manually operated valves and other equipment required for safe shutdown were accessible and in most cases properly identified.

All operations were determined to 'be feasible and it. appeared that plant operators could accomplish them without difficulty.

The operations personnel who participated in the demonstration were competent and knowledgeable of the required operator actions.

As a result of the walkdown, some minor discrepancies were observed in the procedure and in the identification of required safe shutdown equipment.

In general, the discrepancies observed were not necessary for Appendix R compliance but corrective action would improve equipment identification methods and investigative measures to better enhance operator accessibility to certain required equipment.

The licensee took appropriate corrective actions to some of the identified discrepancies during the inspection and agreed to review and take corrective action to others prior to exceeding five percent power.

Identified discrepancies included the following:

(a)

A~endix B Step 6 (page 2) should be changed to read ZAN-COp instead of C03.

(b)

A~endix B - Step 3.2 to 3.4 should read elevation 120 feet instead of elevation 100 feet.

(c)

A~endix A - Page 4 of 7, 480 Volt Switch for power supply to charging pump was mislabelled (the procedure was correct, but the switch label was incorrect).

(d)

A~endix A The inspectors suggested that the sequence of steps contained in this appendix be rearranged if possible to reflect actual operator movements.

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" *""* ( o appendix was not attached in proper sequence.

During the procedure demonstration, the operator almost missed an important step to notify the shift supervisor as a result of this error.

v (f)

Re uired Com onent Identification and Accessibilit

- The inspector suggested that improvements be made in labeling of certain electric panels, circuit breakers and

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disconnect switches which operators must operate to enhance more timely operator accessibility.

(g)

Alternative Primar Pressure Control -,The procedure did not specify an alternative method of pressure control upon a loss of pressurizer heaters due'to a fire in the pressurizer cubicle.

This (items B (a) thru (g)) is consider an open item (50-528/85-06-05)

pending verification of the licensee's corrective actions by Region V.

No violations or deviations were identified.

(2)

Cold Shutdown Procedures The operator actions required to achieve and maintain cold shutdown conditions for the control room fire are contained in Procedure No. 41AO-1ZZ44.

Required cold shutdown repairs, including pulling of fuses, lifting leads/jumpers were determined to be acceptable.

All required materials such as fittings and hardware in place were referenced in the procedure.

The exception was thought to be Table 9.4.1-B of the FSAR.

However, the licens'ee pointed out that this table is being deleted per the licensee's

'February 28, 1985 FSAR Change request.

The procedure was deficient in that it did not require that cold shutdown be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by Section III.L.'fAppendix R.

In response to this concern, the licensee stated that there were no constraints to achieving cold shutdown within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time frame.

According to the licensee, a soak time of approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> is necessary after achieving hot shutdown.

Plant technical specifications require that the maximum cooldown rate does not exceed 100 degrees per hour.

l Based on the information provided by the licensee and plant technical specification requirements, cold shutdown can be achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Therefore, during the inspection, the licensee agreed to make a formal submittal to NRR, committing to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and to revise procedure No.

41AO-1ZZ44 to reflect this commitment prior to exceeding five percent power.

This is considered an open item (50-528/85-06-06)

pending NRR review and acceptance of the licensee's submittal.

No violations or deviations were identified.

(3)

Man ower Re uirements Table 6.2.2.1,of Technical Specification No. 6.0 specifies the minimum shift crew complement independent of the fire brigade

needed to accomplish safe shutdown.

The shift crew compliment specified in Table 6.2.2.1 is inconsistent with the number of operations personnel independent of the fire brigade, which are required to implement procedure No. 41A0-1ZZ44.

A total of nine operations personnel are needed to implement procedure No.

41AO-1ZZ44 and to simultaneously man the fire brigade.

Table 6.2.2.1 of Technical Specification 6.0 requires that only seven operations personnel be onsite at all times during Modes 4, 5 and 6.

The licensee's administrative procedure No. 40AC-9ZZ02 (Conduct of Shift Operations)

was consistent with Table 6.2.2-1 of Technical Specification 6.0.

During the inspection, the licensee agreed to revise administrative procedure No. 40AC-9ZZ02 to specify the minimum shift crew complement require to implement procedure No.

41AO-1ZZ44 while simultaneously manning the fire brigade in accordance with Section III.L. of Appendix R.

This is considered an open item (50-528/85-06-07)

pending verification of the licensee's corrective actions by Region V.

No violations or deviations were identified.

C.

Communications Suitable communications to Accommodate Safe Shutdown is required by Section 9.5.2 of the FSAR and Section III.K(j)of Appendix R.

The licensee's normal communication systems include a telephone system, sound powered telephone, an intercom system, VHF radios and a public address system to accomplish normal onsite communications between the control room and various plant locations.

Some of these communicative means cannot be relied upon during abnormal conditions caused by fire.

Therefore, as a result of analyses performed by the licensee, the electronic private automatic branch exchange telephone system or UHF portable radios were designated for use to implement procedure No. 41AO-lZZ44 when accomplishing post fire safe shutdown.

The inspectors reviewed the circuitry for the electronic private automatic branch exchange telephone system for the availability of local phone line No.

6297 in the event of a control room fire.

The 25 pair cable that serves this line are routed to various operating locations throughout the plant.

The cable terminates in the communications room at elevation 100 feet in the control building.

From this point, there are two pairs of cable which are routed to the control room.

Both pairs of cable could be damaged by a control room fire, however, these cables would be isolated from the rest of the phone system circuit by a phone computer in this event, Therefore, the remainder of the phone system circuits should function given a control room fire.

During the walkdown of procedure No. 41AO-lZZ44, plant operators experienced difficultywith communications over the phone system,

possibly due to other faults with the system or unidentified interferences.

Portable radios were also used during the procedure walkdown.

Portable radio communications from the remote shutdown panel and in various other areas of the plant where operators had to perform local operations or manual actions was not reliable.

Impairments in radio transmissions and receptions were apparently caused by the presence of numerous

"dead spots" in the plant.

In response to the inspector identified communication concerns, during the inspection, the licensee agreed to reanalyze the adequacy of existing communicative means and to take appropriate corrective actions to the reliability of this support function to safe shutdown prior to exceeding five percent power.

This is considered an open item (50-528/85-06-08)

pending verification of the licensee's corrective actions by Region V.

No violations or deviations were identified.

Q.

~Trainin The licensee training records were examined to verify that all licensed and non-licensed operators had been trained in the procedure to perform a plant shutdown outside of the control room, Procedure No. 41A0-1ZZ44, all personnel had been satisfactorily trained.

No violations or deviations were identified.

4.

Com liance with Section III.V - Emer enc Li htin Section III.J. of Appendix R requires emergency lighting units with at least an 8-hour battery power supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

At the time of the inspection, the licensee was in the process of installing additional emergency lighting units to support safe shutdown functions.

Many of existing lighting units were inoperative during the inspection as a result of ongoing modifications to lighting units.

By letter dated December 1984, the licensee committed to have this work completed by April 30, 1985, or prior to exceeding five percent power for Unit, l.

The inspectors recommended to 'the licensee that once this work is completed, appropriate consideration should be given to the adequacy of illumination levels in the required safe shutdown areas.

This is considered an open item (50-528/85-06-09)

pending verification by Region V.

No violations or deviations were identifie I

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5.

Com liance with Section III.O. - Reactor. Coolant Fum Oil Collection

~Setem The lube oil collection system for the reactor coolant pumps was examined for compliance with the requirements of 10 CFR 50 Appendix R Section 0.

7VNGS provided a lube oil collection system for the non-welded joints that will collect oii from leakage during normal or accident conditions or after a safe shutdown earthquake.

The system consist of two tanks each, collecting the leakage from two pumps.

Each tank has excess capacity above the combined volume of two reactor coolant pump oil systems.

Each tank is closed and vented with a flash arrestor in the vent.

No violations or deviations were identified.

6.

Exit Interview An exit meeting was held with members of the plant staff in the morning of March 8, 1985, and a meeting was held with the APS Executive Vice President and the APS (}uality Assurance Manager in the afternoon of March 8, 1985.

The items 'listed in this report were discussed at these meetings.