ML17055A824
| ML17055A824 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point |
| Issue date: | 11/21/1985 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055A821 | List: |
| References | |
| 50-410-85-34, NUDOCS 8512040150 | |
| Download: ML17055A824 (38) | |
See also: IR 05000410/1985034
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
85-34
Docket No.
50-410
License
No.
CRRP-112
Priority
Category
B
Licensee:
Nia ara
Mohawk Power Cor oration
300 Erie Boulevard
West
S racuse
13202
Facility Name:
Nine Mile Point Unit 2
Inspection At:
Scriba
Inspection
Conducted:
October
21
25
1985
Inspectors:
A. G. Krasopoulos,
Reactor
Engineer
date
Also participating
and contributing to the report were:
D. Kubicks, Chemical
Engsneersng
Branch,
A. Coppola,
Mechanical
Systems Specialist,
K
so
Electrical
Systems
Speci al i st,
Approved by
C. J.
nderson,
Chief
Plant
ystems Section,
, yF
ate
Ins ection Summar:
Ins ection
on October 21-25
1985
Ins ection
Re ort
~/
A~I:
l
d
l
l
A
capability to safely shut
down the plant in the event of a design
basis fire
and inspection of the emergency lighting system provided for safe
shutdown
purposes.
The inspection
involved 138 inspector
hours on-site
by a team consisting of 4
inspectors.
Results:
No violations were identified.
Seven
items remained
unresolved at
the
end of this inspection.
85i2040ISO SSii2
ADOCK .OSO004i0
g
~ +
N
~ ~
h
l4
x
~ I
p
~14,
~c'I
DETAILS
1.0
Persons
Contacted
Nia ara
Mohawk Power
Cor oration
- R.
G.
C.
AJ
- J
AW
M.
- D
AG
~R.
G.
- p
- T
- N.
- R.
- R.
Abbott, Station Superintendent
Afflerback, Startup
Manager
Beckham,
QA Projects
Buckley, Operations
Corcoran,
Supervisor Fire Protection
Fenton, Audit Group Leader
Hansen,
Manager Nuclear Engineering
Kammer, Fire Protection
Engineer
Keller,
QA Engineer
King,
QA Supervisor
Lempges,
Vice President
Nuclear Generation
Loveland, Project Engineer
Matlock, Deputy Project Director
Moyer, Station Shift Superintendent
McNally, Assistant Supervisor Fire Protection
Perkins,
General
Superintendent
Quamme,
Project Director
Rademacher,
Licensing Engineer
Ray,
Manager Special
Projects
Raymond,
Supervisor
Fire Protection
Schulman,
Assistant Construction
Engineer
1.2
Stone
and Webster
En ineerin
Cor
.
- C
B.
R.
E.
- J
D.
'kA
S
~
- M
T.
~H.
C.
M.
Bishop,
Deputy Project Director
Char lson, Project Director
Das, Electrical Engineer
Dehart, Site Engineering
Gallagher,
Site Licensing Engineer
Godard,
Area Manager
Gwal,
Lead Electrical
Engineer
Hobner, Assistant Superintendent
of Engineering
Lipsett, Site Engineering
Group
Ortner,
Power Engineer
Pinkston,
Controls Engineer
Sutton,
Fire Protection Coordinator
Terry, Projects
QA Manager
Zaccaria,
Electrical
Design
1.3
Com is Services
and others
- D. Becker, Audit Coordinator
(CS)
P.
Eddy, Sr., Site Representative,
New York Public Service
Commission
"S. Savar,
Electrical
Engineer
(CS)
- E. York, Assistant Audit Coordinator
(CS)
la4
U.S. Nuclear
Re viator
Commission
- R. Gramm,
Senior
Resident
Inspector
- Denotes those present at the exit interview.
2.0
~Pur
oae
This inspection
was performed to verify the applicant's ability to safely
shut
down the plant in the event of a fire, and to verify the adequacy
of
the plant's
emergency lighting system
and oil collection system provided
for the reactor coolant
pumps.
3.0
~Back round
"By letter dated October
15,
1981 (D. Eisenhut to G.
Rhode),
the Commission
informed the licensee of the practice to perform fire protection reviews
using the provisions of Appendix
R to
Accordingly the
Commis-
sion requested
the licensee
to include
a comparison of their fire protec-
tion program to the requirements
of Appendix
R and specifically identify
and justify deviations
from these
requirements.
The licensee
responded
to
this request
by committing to include
a comparison of the Nine Mile Point
2 Fire Protection
Program to the requirements
of 10 CFR 50 Appendix
R as
part of the overall fire protection
program submittal.
This comparison is
contained
in the licensee's
Final Safety Analysis Report
(FSAR), Appendix
9B, "Appendix
R Review Safe
Shutdown Evaluation".
This submittal outlines
the methodology
used to address
the provisions of Sections III G and III L
of Appendix
R which deals with the fire protection of safe
shutdown
and
remote
shutdown capability.
These
commitments,
documented
in the
FSAR, were
used
by the team
as the
basis for this inspection,
and in particular,
the commitments to provide
safe
shutdown capability in accordance
with the requirements
of Appendix
R,Section III G alternative or dedicated
shutdown capability in accor-
dance with Section III L, an emergency lighting system,
in accordance
with
Section III J,
and
an oil collection
system for the reactor coolant
pumps
in accordance
with Section III 0.
The requirements
of the above mentioned
sections of Appendix
R are
as
follows:
Section III G of Appendix
R requires that fire protection
should
be pro-
vided for structures,
systems
and components
important to safe
shutdown.
These features
should
be capable
of limiting fire damage
so that:
a.)
one train of systems
necessary
to achieve
and maintain hot shutdown
conditions
from either the control
room or emergency control
station(s)
is free- of fire damage;
and
b.)
systems
necessary
to achieve
and maintain cold shutdown
from either
the control
room or emergency control stations
can
be repaired within
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
To meet the above guidelines,
one of the following means of ensuring that
one of the redundant trains is free of fire damage
should
be provided:
~
Separation
by a fire barrier having
a three
hour rating;
~
Separation
by a horizontal distance of at least
20 feet with no
intervening combustibles
and with fire detection
and automatic fire
suppression
installed in the fire area;
~
Enclosure of one train in a fire barrier having
a one hour rating in
addition to having fire detection
and automatic
suppression
installed
in the fire area.
If the protection required
by Section III G is not provided or the
systems
of concern
are subject to damage
from fire suppression
activities, Section
III L requires that
an alternate
or dedicated
shutdown capability be pro-
vided, which is independent
of the area of concern.
(
In addition,Section III J requires that
an emergency lighting system is
in place for areas vital to safe
shutdown
and emergency
response
in the
event of a fire.
The emergency lighting should
be fixed, self-contained
units, with individual 8-hour minimum, battery
power and should
be
installed in areas
that must be manned during safe
shutdown operations
and
for access/egress
thereto.
Section III 0 requires that the reactor coolant
pumps in non-inerted
con-
tainment,
shall
be equipped with an oil collection system
so designed that
failure will not lead to fire during normal or design basis accident con-
ditions.
All correspondence
on the subject,
between
the applicant
and the
NRC and
internal
NRC documents
were reviewed
by the inspection
team in preparation
for the site visit.
Attachment
1 to this report is
a listing of corre-
spondence
reviewed.
5.0
Post Fire Safe
Shutdown
Ca abilit
The applicant's
FSAR Appendix 98 describes
the post-fire safe
shutdown
capability of Nine Mile Point Unit 2.
The document lists the systems
required for safe
shutdown
and describes
methods to achieve
and maintain
safe
shutdown
using these
systems.
5. 1
S stems
Re uired for Safe
Shutdown
Systems
and functions required for safe
shutdown
as listed'in
Appendix 98 of the applicant's
FSAR are
as follows:
Automatic Depressurization
System
(ADS)
High Pressure
(HPCS)
Low Pressure
(LPCS)
Reactor
Core Isolation Cooling (RCIC)
Residual
Heat
Removal
(RHR)
(SW)
Diesel
Generator
Support
System
HVAC Systems
Onsite
Power Systems
Control
Systems for ESF Systems
Control
Systems
Required for Safe
Shutdown
Other Control
Systems
Required for Safety
The applicant
has issued
a licensing document
change notice
(LDCN-
NMPC-333), which changes
the
FSAR Section
9B4 to reflect the way in
which the
ADS and
LPCS systems
are
used.
They are
used in conjunc-
tion with the
HPCS and
RCIC system for decay heat removal.
If these
systems
were to be used for inventory control (ie.
without HPCS or
RCIC), core uncovery is possible.
The applicant
has ascertained
that
either
RCIC or HPCS is always available for safe
shutdown,
and there-
fore,
ADS and
LPCS are only used for decay
heat removal.
The options available for a safe
shutdown in the event of a design
basis fire with concurrent
l.
If the high pressure
(HPCS)
system is available,
reactor water level
can
be maintained,
as required,
using
HPCS.
Reactor overpressurization
can
be relieved
by the main
steam
(SRVs).
Suppression
pool cooling can
be
accomplished
by the residual
heat
removal
(RHR) system.
To
achieve cold shutdown
from this point, it will be necessary
to
manually depressurize
the reactor
vessel
using the safety relief
valves
(ADS) so that the
shutdown cooling mode of
RHR can
be
initiated.
'.
If HPCS is not available,
the reactor water level
can
be
maintained
using
RCIC.
Reactor pressure will be controlled by
the
ADS valves,
which are also
used to transfer
decay heat to
the suppression
pool.
Suppression
pool cooling can
be accomplished
by RHR.
Once the
reactor is depressurized
sufficiently, the
shutdown cooling mode
of RHR can
be initiated to achieve
a cold shutdown.
Two redundant trains of
RHR are available to achieve
a safe
shutdown
under each of these
two options.
Each train is powered
from a separate
emergency diesel
generator
(2EGS"EG1-Division I
and 2EGS"EG3-Division II).
Either train by itself can
be relied
upon to shut
down the plant.
The
system is powered
from a
separate
diesel
generator
(2EGS*EG2-Division III).
The
RCIC is
a steam driven
pump and requires
only
DC power for controls.
The applicant's
safe
shutdown analysis
states
that systems
needed for hot and cold shutdown are redundant
and that one
train of systems
needed for safe
shutdown would be free of fire
damage
because
of separation,
fire barriers and/or alternative
shutdown capability.
The safe
shutdown analysis
included
components,
cabling
and support
equipment
needed
to achieve
hot
and cold shutdown.
For hot shutdown,
at least
one train of the following systems
would be available following a fire in any plant area:
high
pressure
system
(HPCS), reactor core isolation
cooling system
(RCIC), main
steam safety/relief valves
(MS/SRVs),
and the residual
heat
removal
system
(RHR) in the
suppression
pool cooling mode.
The
RHR system would be used for
long term decay heat
removal
and provides the capability to
achieve cold shutdown with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after
a fire.
The support
systems
for post-fire safe
shutdown include the diesel
generators,
service water system,
and the necessary
systems.
The applicant performed
an essential
cabling study as
a part of
the shutdown analysis
in order to ensure that at least
one train
of the above
equipment
and essential
instrumentation
is
available in the event of a fire in areas
which might affect
these
components.
The applicant utilized a computer to verify
cable separation.
Safe
shutdown
equipment
and cabling were
identified and traced
through
each fire area
from the components
to the power source.
Additional equipment
and cabling con-
sidered
as associated
either because
of a shared
common
power
source
or common enclosure,
or whose fire induced
spurious
operation
could affect shutdown,
were also identified.
For the
identified associated
circuits, the applicant
has provided power
lockout, circuit isolation and/or procedures
to ensure that cir-
cuit failures would not prevent safe
shutdown.
For example,
in
order to prevent fire induced spurious signals
from causing
a
LOCA from sources
such
as the
RHR suction line,-the applicant
has stated that power will be locked out to one of the two
suction line valves during power operation.
Similarly, the
operator will trip the power supply breakers for other valves
whose controls are not provided at the remote
shutdown panel,
thereby preventing their fire induced spurious actuation.
With regard to high impedance faults resulting from damage to
two or more cables
connected
to power
sources
required for hot
shutdown
equipment,
the applicant
has stated that the cabling
for redundant divisions
( I and II) are located in separate
fire
areas,
and therefore
a fire in any one area will result in loss
of only one of the redundant
shutdown .equipment
power sources.
5.2
Alternative Shutdown
Ca abi lit
The design objective of the remote
shutdown panels is to provide
a
central point to control
and monitor plant shutdown
independent
of
the control
room and relay room in the event of a fire in these
areas.
All other
areas of the plant will meet the separation
of
Appendix R,Section III.G or
an approved deviation.
There are
two
redundant
remote
shutdown panels,
one each for train A and
B.
One
panel is located in the east area,
El. 261'nd
one in the west area,
El. 261'.
Both panels
are
used for post-fire alternate
shutdown,
outside of the control
room.
6.0
Ins
The design of each
remote
shutdown
panel
provides electrical isola-
tion from the control
room and relay room for the instrumentation
indications
and control functions for the
shutdown
systems.
The
reactor
core isolation cooling (RCIC) system,
residual
heat
removal
(RHR) system
and the service
water
system
can
be controlled from the remote
shutdown panels to achieve
and maintain
hot shutdown
should
a fire disable
the control
room or relay room.
In
order to assure
the availability of these
remote
shutdown panels
in
the event of control
room or relay room fire, transfer
switches
are
provided at each
remote
shutdown
panel to transfer the shutdown
capability to the remote
shutdown panel.
Redundant
fuses,
where
required,
are provided in the circuit for controls
and instruments at
the remote panels to assure their availability following transfer
from the control
room.
Support
systems
functions are initiated
either at the remote
shutdown
panel
or at local locations.
The applicant
has stated that repairs
are not required 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 />.
Reactivity control will be
accomplished
by
a manual scram before the operators
leave the control
room.
The
RCIC system will provide reactor coolant
makeup
and the
RHR system
and safety relief valves will be used for reactor
decay
heat removal.
Reactor vessel
water level, reactor vessel
pressure,
suppression
pool water level
and temperature,
RCIC pump turbine
speed,
RHR system flow and condensate
storage
tank level are
among
the instrumentation
indications available at the remote
shutdown
panels
independent
of the control
room and relay room to provide
direct reading of process
variables.
The remote
shutdown panels
also
include instrumentation
and control of support functions
needed for
shutdown
equipment.
ection Methodolo
The inspection
team examined
the applicant's capability for separating
and
protecting
equipment,
cabling
and associated
circuits necessary
to achieve
and maintain hot and cold shutdown conditions.
The team inspected
randomly selected fire areas
which the applicant
had identified as being
in conformance with BTP 9.5-1
and
10 CFR 50 Appendix
R.
The following functional requirements
were reviewed for achieving
and
maintaining hot and cold shutdown:
Reactivity control
Pressure
control
makeup
Decay heat
removal
Support
systems
Process
monitoring
The inspection
team also examined
the applicant's capability to achieve
and maintain hot shutdown
and the capability to bring the plant to cold
shutdown condition in the event of a fire in areas
where
remote
shutdown
capability is provided.
The examination
included
a review of the drawings
for the remote
shutdown capability and review of the procedures
for
achieving the remote
shutdown.
Drawings were reviewed to verify electri-
cal
independence
from the areas of concern.
Procedures
were reviewed for
general
content
and feasibility.
Also inspected
were fire detection
and suppression
systems
and the degree
of physical
separation
between
redundant trains of Safe
Shutdown
Systems
(SSSs).
The team review included
an evaluation of the susceptibility of
the
SSSs for damage
from fire suppression
activities or from the rupture
or inadvertent operation of fire suppression
systems.
The inspection
team examined
the applicant's fire protection features
provided to maintain
one train or equipment
needed for safe
shutdown free
of fire damage.
Included in the
scope of this effort were fire area
boundaries,
such
as walls, floors and ceilings,
and fire protection of
openings,
such as, fire doors, fire dampers
and penetration
seals.
The team also reviewed the applicant's
emergency lighting system for
areas of the plant required for safe
shutdown.
7.0
Ins ection of Protection
Provided to Safe
Shutdown S'stems
7. 1
Protection
in Various Fire Areas
The plant is divided into fire areas
which are described
in Table
9.B.6-1 of the
FSAR.
The team inspected
the following areas
because
these
areas
contain
safe
shutdown
equipment:
Fire Area/Fire Sub-area
Descri tion
North Aux Bldg/FAl
Reactor
Bldg/FA2
Room, North Auxiliary Bay,
El 175 Ft.
Pump
Room A, North Auxiliary
Bay, El 175 Ft.
RHS Heat Exchanger
Room A, North
Auxiliary Bay,
E1
175 Ft.
Reactor Building,
Pump
Room,
E1
175 Ft.
South Aux Bldg/FA3
Reactor
Bldg/FA4
FA7
FA8
FA9
Control Bldg/FA21
Diesel
Gen Bldg/FA28
FA30
North Auxiliary Bay/FA5
FAll
FA37
South Auxi1 iary Bay/FA6
FA12
FA41
Control Building/FA16
Pump
Room B, South Auxiliary
Bay, El 175 Ft.
Pump
Room C, South Auxiliary
Bay, f1 175 Ft.
RHS Heat Exchanger
Room B, South
Auxiliary Bay,
El 175 Ft.
Reactor Building,
Room,
E1
175 Ft.
Electrical Tunnel,
35O
Electrical
Tunnel,
140'lectrical
Tunnel,
230
Control Building,
HPCS Cable
Routing Area,
El 244 Ft.
Control Building,
HPCS Switchgear
Room,
El 261 Ft.
Division I, Diesel Generator
Room
Division I, Diesel
Generator
Control
Room
'Division III, HPCS Diesel
Generator
Room
Division III, HPCS Diesel
Generator
Control
Room
North Auxiliary Bay,
E1
198 Ft.
North Auxiliary Bay Electrical
Room,
E1 240 Ft.
Auxiliary Bay, North Access
Area
B,
E1 215 Ft.
South Auxiliary Bay,
E1
198 Ft.
South
Auxi 1 iary Bay,
El ectri ca 1
Room,
El 240 Ft.
Auxiliary Bay, South Access
Area
B,
E1 215 Ft.
Control Building Cable
Chase,
West,
El 214 Ft.
Control Building Routing Area,
El 214 Ft.
Control Building Cable
Chase,
10
FA17
West,
El 237 Ft.
Control Building Cable
Chase,
West,
El 261 Ft.
Control Building Cable
Chase,
West,
El 288 Ft.
Control Building Cable
Chase,
West,
E1 306 Ft.
Control Building General
Area,
El 214 Ft.
Contr o l. Bui 1 di ng,
Divi s i on I
Cable Routing Area,
E1 237 Ft.
Control Building, Division I
Standby Switchgear
Room,
El 261 Ft.
Control Building Corridor,
E1 261 Ft.
Control Building, Division I
Battery
Room,
El 261 Ft.
FA18
Control Building Cable
East,
El 214 Ft.
Control Building Cable
East,,
El 237 Ft.
Control Building Cable
East,
El 261 Ft.
Control Building Cable
East,
El 288 Ft.
Control Building Cable
East,
El 306 Ft.
Chase,
Chase,
Chase,
Chase,
Chase,
FA19
FA43
FA44
FA22
Con tro 1 Bui 1 di ng,
Divi s ion II
Cable Routing Area,
E1 237 Ft.
Control Building, Division II,
Standby Switchgear
Room,
El
261 Ft.
Control Building, Division II
Battery
Room,
E1 261 Ft.
Control Building Remote
Shutdown
Room,
East
Control Building Remote
Shutdown
Room,
West
Control Building, Division I,
Cable Routing Area,
El 244 Ft.
Control Building, Division I,
HVAC Room,
E1 261 Ft.
11
Tunnels
FA23
FA24
FA25
FA26
FA27
FA76
FA34
FA55
Control Building, Division II,
Cable Routing Area,
E1 244 Ft.
Control Building, Division II,
HVAC Room,
El 261 Ft.
Control Building,
PGCC Relay
Room,
El 288 Ft.
Control Building, Division I,
HVAC Room,
E1 288 Ft.
Control Building, Hain Plant
Control
Room, El 306 Ft.
Control Building, Division II,
HVAC Room El 306 Ft.
Control Building Corridor/In stru-
ment Shop,
El 306 Ft.
Hain Steam Tunnel
Pipe Tunnel
Electrical
Tunn'el
Vent Room,
El 237 Ft.
Radwaste
Tunnel
Service Mater
Pump Area
FA60
FA61
Intake Area
FA71
Reactor Building/FSA34
Pump
Room
B
Service Mater
Pump
Room A
Intake Area
Reactor
Building General
Area,
North, El 175 Ft.
Reactor
Building General
Area,
North, El 215 Ft.
Reactor Buidling General
Area,
North,
E1 240 Ft.
Reactor Building General
Area,
North, El 261 Ft.
Reactor Building General
Area,
North, El 288 Ft.
Reactor Building General
Area,
North, El 306 Ft.
Reactor Building General
Area,
Northwest,
El 328 Ft.
Reactor Building Genral Area,
Northeast,
E1 328 Ft.
Reactor Building General
Area
12
FSA35
Reactor Building General
Area,
South,
El 175 Ft.
Reactor Building General
Area,
South
E1 215 Ft.
Reactor Building General
Area,
South,
El 240 Ft.
Reactor Building General
Area,
South,
El 261 Ft.
Reactor
Building General
Area,
South,
El 288 Ft.
Reactor Building General
Area,
South,
El 306 Ft.
Reactor Building General
Area,
Southeast,
El 328 Ft.
Other Areas
Lube Oil Reservoir
Room
Electric Fire
Pump
Room
Diesel Fire
Pump
Room
Clean
and Dirty Oil Storage
Room
The
scope of the review was to ascertain
compliance with Sections
III G and III L of Appendix
R and to assess
the adequacy
of the fire
protection in these
areas.
No unacceptable
conditions were identified except
as follows:
Su
ression
in the
20 ft. zone
In the
FSAR, the applicant
committed to separate
redundant
shutdown
related
systems
by at least
20 feet; to install fire detectors
throughout the area;
and to,install automatic sprinklers throughout
the
20 feet separation
zone.
The team observed that automatic
sup-
pression
was not provided completely throughout the
20 foot separa-
tion zone.
The applicant reaffirmed the commitment to install
automatic
suppression
(sprinklers)
throughout this zone.
In
addition,
where
an
open
hatchway exists
in this zone,
the applicant
committed to install
a water curtain sprinkler system
around the
hatchway to prevent fire spread.
Pending
implementation of this
commitment this item will remain unresolved.
(50-410/85-34-01)
Fire Proofin
of Structural
Steel
The team observed that structural
steel
members
forming part of fire
walls has not hitherto been fire proofed.
Branch Technical
Position
(BTP) 9.5-1 Section C.5.B(2)(a) stipulates
that structural
steel
members
forming part of a fire wall should
be
fire proofed.
In lieu of fire proofing the steel
members,
NRC has
issued
guidance to applicants
and licensees,
stating that
an engi-
neering analysis
may be performed to show that
a postulated fire
within the fire area will not degrade
the fire barriers.
13
The applicant explained that construction
in this area is incomplete
and reaffirmed the commitment to fire proof all structural
steel
mem-
bers forming part of a fire barrier.
Further
where the amount of
combustibles,
within a fire area
do not warrant fire proofing the
applicant committed to provide
an analysis
and identify the deviation
in Appendix
9B of the
FSAR.
This is an unresolved
item pending
com-
pletion of construction efforts in this area.
(50-410/85-34-02)
Fire Seal
in Construction Joints
In the
FSAR the applicant committed to protect all openings
in fire
barriers with doors,
or penetration
seals
which have
a fire
rating commensurate
with the rating of the barrier.
The team observed
that certain
shake
spaces,
i.e. "construction joints", located in
were not protected with a fire-rated penetration
seal.
The licensee
reaffirmed the commitment to install fire-rated seals
at these
shake
spaces.
Pending
implementation of this commitment,
this issue will remain unresolved.
(50-410/85-34-03)
Fire Detectors
in Safet -Related
Areas
In the
FSAR, the applicant committed to provide fire detection
in all
safety related
areas.
The team observed that in
some locations, fire
detectors
had not yet been installed.
The applicant indicated that
fire detectors will be installed in all areas
containing safety-
related
systems
or components.
The applicant also committed in a
future
FSAR Amendment to identify any areas
with safety related
sys-
tems where fire detectors
have not been provided.
Pending
implemen-
tation of the applicant's
commitments, this issue will remain unre-
solved.
(50-410/85-34-04)
Fire
Dam ers -
DG Fuel Oil
Da
Tank
In the
FSAR the applicant committed to protect all openings
in fire
barriers with doors,
or penetration
seals,
which have
a fire
rating commensurate
with the rating of the barrier.
The team observed
that
an
HVAC duct penetrates
the fire rated enclosure
around the
diesel
generator
(DG) fuel oil day tank and that fire dampers
were
not provided at these
openings.
In lieu of dampers
the applicant
committed to completely enclose this duct,
where it passes
through
the day tank enclosure,
with a 3-HR fire wrap.
Pending
implementa-
tion of this commitment, this issue will remain open.
(50-410/85-34-05)
NFPA Code Deviations
In the
FSAR the applicant committed to conform with the applicable
provisions of the National Fire Protection Association
(NFPA) fire
codes
in the design
and installation of fire protection
systems.
The
applicant
had previously identified and justified certain deviations
from these
codes.
II
During this inspection
the team observed
several
deviations
from
these
codes
which were not previously identified and justified.
The
applicant committed to identify and justify all remaining
NFPA code
deviations
in a future
FSAR amendment.
Pending evaluation of this
amendment
by
NRC this item will remain unresolved.
(50-410/85-34-06)
7.2
Safe
Shutdown
Procedures
7.2. 1
Procedure-Review
The team reviewed the following draft safe
shutdown
procedures:
Procedure
No. N2-IOP-101A - "Plant Start-Up"
Procedure
No. N2-IOP-78 - "Remote
Shutdown
System"
The purpose of the review was to verify the adequacy of the
procedures
to achieve
the safe
shutdown goals established
for both hot standby
and cold shutdown.
Procedure
No.
N2-IOP-101A was examined to ascertain
the positioning of
valves
and breakers
to prevent
spurious actuation of valves
at High/Low pressure
interfaces
such
as
RHR suction.
Procedure
No. N2-IOP-101A was reviewed in order to ascer-
tain the capability to place the plant in hot shutdown
and
continue
cooldown to cold shutdown conditions using the
systems
available
as outlined in Section
5.2 above.
This
procedure
is used not only to satisfy Appendix
R require-
ments which include total control
room damage,
but also for
evacuations
which involve partial or no damage
to the
control
room capability.
7.3
Protection for Associated Circuits
Appendix R,Section III G, requires that protection
be provided for
associated
circuits that could prevent operation or cause
malopera-
tion of redundant trains of systems
necessary
for safe
shutdown.
The
circuits of concern
are generally associated
with safe
shutdown
circuits in one of three ways:
~
Common bus concern
~
Spurious
signals
concern
~
Common enclosure
concern
The above mentioned
concerns
were evaluated
by the team.
Power,
con-
trol, and instrumentation circuits were examined for potential pro-
blems.
15
7.3. 1
Common
Bus Concern
The
common
bus concern
may be found in circuits, either
safety related
or non-safety related,
where there is
a
common
power source with shutdown
equipment
and the power
source is not electrically protected
from the circuit of
concern.
The team examined,
on
a sampling basis,
4160V,
600V,
120
VAC and
125V
DC bus protective relay coordination.
The
team also
examined
on
a sampling basis,
the protection for
specific instrumentation,
controls,
and power circuits,
including the coordination of fuses
and circuit breakers.
The licensee
plans to perform relay setting during refuel-
ing outages
(12-18 months).
7.3 '
No unacceptable
conditions were identified.
S urious Si nal
Concern
The spurious
signal
concern is made up.of
2 items:
~
False
motor control,
and instrument indications
can
occur
such
as those
encountered
during 1975 Browns
Ferry fire.
These
could be caused
by fire initiated
grounds,
short or
open circuits.
~
Spurious operation of safety-related
or nonsafety-re-
lated components
can occur that would adversely affect
shutdown capability (e.g.,
RHR/RCS isolation valves).
The team examined,
on
a sampling basis,
the following areas
to,ascertain
that
no spurious
signal
concern exists:
~
Current transformer
secondaries
~
High/low pressure
interfaces
~
General fire instigated
spurious signals
No unacceptable
conditions were identified.
7.3 '
Common Enclosure
Concern
The
common enclosure
concern
may be found when redundant
circuits are routed together in a raceway or enclosure
and
they are not electrically protected
or when fire can
destroy both circuits due to inadequate fire barriers.
A number of circuits, selected
on
a sampling basis,
were
examined for this concern.
No unacceptable
conditions
were identified.
16
7.4
General
Fire Protection
Features
The team examined
the general fire protection features
in the plant
provided to maintain
one train of safe
shutdown
equipment free of
, fire damage.
Included in the
scope of this effort were fire area
boundaries,
including walls, floors and ceilings,
and fire protection
of openings
such
as fire doors, fire dampers,
seals, fire
protection
systems,
and other fire protection features.
No unacceptable
conditions were identified except
as indicated in
Section
7. 1 of this report.
8.0
Emer enc
Li htin
Appendix
R,Section III J requi res that emergency lighting units with at
least
an 8-hour battery power supply shall
be provided in all areas
needed
for operation of safe
shutdown
equipment
and in access
and egress
routes
thereto.
The applicant committed to provide
such lighting in the
Appendix 9B.
The team observed that the emergency lighting installation
has not progressed
to the point that the
system
can
be inspected
to deter-
mine its adequacy.
This is an unresolved
item pending the installation of all emergency
lighting systems
by the applicant
and
a review of the systems
by NRC.
(50-410/85-34-07)
9.0
Oil Collection
S stem for Reactor
Coolant
Pum
s
Appendix R,Section III 0 requires that the reactor coolant
pumps shall
be
equipped with an oil collection system if the containment is not incr ted
during normal operations.
The Nine Mile Point
2 containment is inerted
during normal operations
and therefore
an oil collection system is not
required.
10.0 Unresolved
Items
Unresolved
items are matters for which more information is required in
order to ascertain
whether they are acceptable,
violations, or deviations.
Unresolved
items are discussed
in Sections
7. 1 and 8.0.
11.0 Conclusion
The seven
items that remained
unresolved at the end of the inspection
resulted
from the fact that construction is not yet completed.
Except
as noted in this report,
no other unacceptable
conditions were
identified.
The applicant committed to resolve all of the findings contained
in this
report
and complete all necessary
modifications prior to fuel load.
Further,
the applicant
committed to inform NRC Region I when this work is
complete
so that it can
be inspected
in a timely manner.
17
12.0 Exit Interview
The inspection
team met with the applicant representatives,
denoted
in
Section
1, at the conclusion of the inspection
on October 25,
1985.
The
team leader
summarized
the
scope
and findings of the inspection at that
time.
The team leader also discussed
with the applicant the contents of the
inspection report
and ascertained
that it would not contain
any propri-
etary information.
The applicant agreed that the inspection report
may be
placed in the Public Document
Room without prior applicant review for pro-
prietary information (10 CFR 2.790).
At no time during this inspection
was written material
provided to the
applicant
by the team.
ATTACHMENT 1
CORRESPONDENCE
LIST
7.
8.
1.
NMP2 letter
No.
0336 to A. Schwencer,
dated 2/7/85,
Non-Class
lE Devices.
2.
NMP2 letter No.
0341 to R. Starostecki,
dated 2/12/85,
High Pressure
Core
Spray Diesel Control
Panel Wiring.
3.
NMP2 letter No.
0348 to
R. Starostecki,
dated 2/25/85,
Emergency
Diesel
Generator
Panel
Wiring.
4.
NMP2 letter
No.
0344 to R. Starostecki,
dated 2/21/85,
Category I Cable
Separation.
NMP2 letter
No.
0395 to A. Schwencer,
dated 4/30/85,
Cable Separation.
NMP2 letter
No.
0441 to A. Schwencer,
dated 5/17/85, Electrical
System
Independence.
NMP2 letter No.
7461 to
R. Starostecki,
dated 9/23/83, Kerite Cables.
NMP2 letter
No
~
0320 to R. Starostecki,
dated 1/9/85,
High Pressure
Core
Spray Diesel
Generator Wiring.
9.
NMP2 letter No.
0273 to A. Schwencer,
dated 12/3/84,
Physical
Independence
of Electrical
Systems.
10.
NMP2 letter
No.
0152 to A. Schwencer,
dated 9/13/84,
Open Items.
11.
NMP2 letter No.
0122 to
R. Starostecki,
dated 8/9/84,
PGCC Separation.
12.
Region I letter to Applicant, dated 8/9/84,
1 and 2.
h
ATTACHMENT 2
ECN*LIST FOR APPENDIX
R WORK
EGP-009,
EGS-003,
EJS-007,
EJS-008,
ENS-017,
HVC-037, HVP-018,
HVR-042,
HYY-025
IAS-080, ISC-020,
SFC-023,
SFC-028,
SWP-092,
HVR-041, HVC-033, DER-026,
RHS-068
IAS-088,
EGP-010,
EJS-009,
ENS-018,
FWS-027,
MSS-043,
WCS-047,
CEC-433,
CEC-417
CEC-402
The above
ECN's is
a list provided by the applicant
as "work remaining" to
complete Appendix
R related
items.
- ECN = Engineering
change notice
order to perform work.
'
~'