ML17156B004
| ML17156B004 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/13/1989 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B003 | List: |
| References | |
| 50-387-88-21, 50-388-88-24, NUDOCS 8902020111 | |
| Download: ML17156B004 (14) | |
See also: IR 05000387/1988021
Text
U.S.
NUCLEAR REGULATORY COMMISSiON
REGION I
50-387/88-21
Report
Nos.
50-388/88-24
50-387
Docket Nos.
50-388
License
Nos.
Pr iority
Licensee:
Penns
lvania Power and Li ht Co.
2 North Ninth Street
Allentown
18101
Category
C
Facility Name:
Sus
uehanna
Steam Electric Station
Units
1 and
2
Inspection At:
Allentown
Penns
lvania and
Salem Townshi
Penns
lvania
Inspection
Conducted:
December
5-9
1988
Inspector:
A. G. Krasopoulos,
R actor Engineer
ate
Also participating
and contributing to the report were
R. Hodor, Mechanical
Systems Specialist,
K. Sullivan, Electrical
System Specialist,
Approved by:
C. J. Anderson,
Chief, Plant Systems
Section,
"/v
date
Ins ection Summar:
Ins ection
on December
5-9
1988
Ins ection
Re ort
Nos.
50-387/88-21
and 50-388/88-24
h
d
capability of the plant in the event of a fire, and of, the
provided for that purpose.
The corrective actions
taken in response
to
violations previously identifed in this area
were also reviewed.
Results:
No violations were identified.
The actions
taken to correct the
deficiencies
previously identified in this area
were determined
to be adequate.
PD9R0~0~0>> i 8901pg
GDR 'DOCK 0500008~
PNU
DETAILS
1.0
Persons
Contacted
- Penns
lvania
Power and Li ht
PPBL
J. Blakeslee,
Assistant Plant Superintendent
F. McCreesh,
Project Engineer
J..Rothe,
Supervising
Engineer,
Electrical
S. Davis, Site Fire Protection
Engineer
G. Stanley, Assistant
Outage Superintendent
R. Prego,
QA Supervisor
A. Dominguez,
Sr.
Results
Engineer,
Operations
C. Coddington,
Sr. Project Engineer
D. Klinger, Appendix
R Project Site Manager
W. Williams, Licensing
D.
Kohn, Fire Protection
Engineer
B. Slusser,
Outage
Management
D. Roth, Sr.
Compliance
Engineer
W. Barberich,
Manager,
Nuclear Planning
and Licensing
M. Gorski, Project Engineer
D. 2aprazny,
Project Engineer
A. Mihalic, Sr.
Engineer
G. Wetzel,
Sr. Project Engineer
A. White,
Systems
Engineering
R.
Tombasco,
Electrical Analyst
T. Gorman,
Supervisor
Nuclear Design
K. Backenstor,
Sr. Project Engineer
B. Palmer,
Project Engineer,
I&C Engineering
J.
Delgado,
Project Engineer,
NPE
CED
D. Parsons,
Supervising
Engineer,
NPE
2.0
Pur ose
and
Sco
e
makaaa r
a
This inspection
was conducted
to verify compliance with the
Appendix
R Sections III.G and III.J.
This regulation requires that the
licensee
be capable of shutting
down the reactor in the event of a fire
and that emergency lighting be installed for this purpose.
The corrective actions for the violations identified in this area
from
a
previous inspection
conducted
during February
11-15,
1985 were
also'eviewed.
3.0
~Back round
The licensee
via
a license condition is required to comply with the
requirements
of 10 CFR 50a48
and
10 CFR 50 Appendix
R Sections III.G and
J.
Section III.G of Appendix
R requires that fire protection features
be provided to ensure that
one train of equipment
necessary
to achieve
and maintain
s'afe
shutdown
remains available
in the event of a fire at
any location within the facility.
Section III.J of Appendix
R requires that emergency lighting be installed
to facilitate the
shutdown of the reactor in the event of a fire.
The
NRC during the week of February
11-15,
1985 conducted
an inspection
to verify the licensee's
abili.ty to safely
shutdown the reactors
(Susquehanna
Units 1&2) in accordance
with the requirements
described
above.
The inspection results
were documented
in combined inspection
Report
No. 50-387/85-06
and 50-388/85-06.
These results'included
a number of Unresolved
Items that were later
determined
to be violations of the requirements.
An enforcement
conference
was held
on October
1,
1985 at, the
NRC Region I offices.
A Notice of Violation was transmitted
to the licensee
by letter dated
June
15,
1987.
This notice contained
two violations of the Appendix
R
requirements.
Violation I contained
three
examples of violations from the
Appendix
R Section III.G requirements.
These
three
examples
were
described
as Unresolved
Items 50-387/85-06-02,
50-388/85-06-02,
50-388/85-06-03
and 50-388/85-06-04.
The resolution of these
items
and
the closure of the violations is described
in the section that follows.
Violation II described
a violation of the Appendix
R,Section III.J
requirements.
The corrective actions to this violation were reviewed
by
the
NRC resident staff and were found acceptable.
This was previously
documented
in report
No. 50-388/86-04.
In addition to the violations listed above,- the inspection report contained
an unresolved
item regarding
a concern that the licensee's fire hazard
analysis,
performed to verify the plant's
safe
shutdown capability was
inadequate.
This concern
was listed
as Unresolved
Item 50-387/85-06-01
and 50-388/85-06-01.
The licensee
committed to perform
a reanalysis
of the safe
shutdown
methodology to address
this concern.
A letter dated
December
18,
1985,
from the. licensee
stated that this reanalysis
had been initiated and would
be completed
by the fourth quarter of 1986 or the first quarter of 1987.
The licensee
completed
and docketed this
new Fire Hazard Analysis, on
June
30,
1988.
4.0
Follow u
of
revious
ins ection findin
s
Closed
Unresolved
Item
50-387/85-06-01
5 50-388/85-06-01
Fire= Hazard Analysis inade
uate to
show
com liance with A
endix
R
The
NRC determined
that the licensee's
fire hazard analysis
was
inadequate
in that it failed to demonstrate
that redundant
safe
shutdown
components
would be available if a fire occurred "anywhere
in the plant.
The licensee
committed to review and revise their Fire Hazard Analysis
to'ssure
that if a fire occurred
anywhere
in the plant one safe
shutdown
train would remain free of fire damage.
The licensee initially planned to revise the original docketed
Fire Hazard
Analysis.
This is the document reviewed'y the
NRC team in February of
1985.
Because
of problems associated
with document retrieval,
the licensee
determined that it would be better to develop
a
new fire hazard analysis
which would be developed with in-house expertise.
They had difficulty in
retrieving the data
base
used
in the original fire hazard analysis.
The
licensee
completed this
new analysis titled Fire Protection
Review Report,
Revision 3,
and placed it on the docket
on June
30,
1988.
The team reviewed this document
and did not identify any unacceptable
'onditions.
The analysis
reviewed,
provides
assurance
that one
shutdown
train will remain free of fire damage.
However,
the
team stated
to the
licensee
that the analysis
and
shutdown methodology contained
in this
document
has not been
reviewed by the
NRC office at
NRR.
Since
an
SER has
not been
issued
on the
new methodology,
the final acceptance
of the
analysis will be based
on the acceptability of this document
by NRR.
This item is resolved.
Closed
Violation
50-387/85-06-02
and 50-388/85-06-02
.
Inade uate fire
barriers
se gratin
the redundant
residual
heat
removal
um s.
The
NRC identified the concern that the fire barriers
separating
the
pumps were not fire rated because
the doors installed
on these fire
barriers did not have
a fire rating.
Additionally these barriers
contained
a seismic
gap not sealed with a fire sealant'his
was
deemed
to be
a violation of the fire separation criteria set forth in Appendix
R.
The licensee
acknowledged this violation and instituted corrective
actions that included the following:
1.
The licensee
requested
a deviation from the requirement to have
three hour rated doors
on the wall separating-the
RHR Pumps.
The
justification given was that the doors installed,
although unrated,
are of substantial
construction
having been built out of steel
plate
and they are watertight.
These
doors were evaluated
by Factory
Mutual
and
found to be
an adequate fire bar rier for the existing fire
hazard.
The licensee
has
sealed
the seismic
gap with a fire rated seal.
The
design
and installation of this seal
does
not compromise
the
function of the seismic
gap
~
The licensee
has established
a fire watch to patrol
the
RHR pump
room pending
NRC approval of the above deviation request.
This violation is closed.
Closed
Violation
50-388/85-06-03
Inade uate Fire Wra
enclosure
on
safe
shutdown
racewa
s.
The
NRC determined that certain electrical
raceways
containing cables
required for shutdown
were improperly wrapped.
The specific concern
was
,
that the wrap did .not extend
the entire length of th'e fire area.
Thus,
a
fire in the fire area
where the raceway
was not wrapped could subject the
raceway to fire damage.
The licensee
acknowledged
the violation.
However, their response
indicated that three
raceways identified in the violation were not
required for shutdown.
The fourth raceway
needed fire wrap protection
because
the
new analysis
indicated that this raceway is now required
(Raceway
No.
E2KJ19) to be protected.
In addition, the licensee
completed
the -analysis that identified all
raceways
containing safe
shutdown cables.
The raceways requiring protec-
. tive wrap were also identified.
The work to provide this wrap has
com-
menced
and is scheduled
to be completed
by December
31,
1989.
This
completion date
was committed to via a letter to
NRC dated
June
30,
1988.
This was previously discussed
in a management
meeting held at the Region I
offices
on March 31,
1988.
The inspector
observed
work in progress
and did not identify any
unacceptable
conditions.
This violation is closed
5.0
Post-Fire
Safe
Shutdown
Ca abilit
and Shutdown Methodolo
The Fire Protection
Review Report,
Revision 3, docketed
on June
30,
1988,
describes
the post-fire safe
shutdown capability with and without offsite
power and the remote
shutdown capabi-lity (from outside
the main
control room).
1
The analysis
in the report uses (with one exception)
the fire area
concept.
The analysis
assumes
the loss of all safe
shutdown
equipment
within the fire area.
assure
that the fire will not
propagate
beyond the fire area
boundaries.
The analysis
then assures
that
either redundant
or alternative
shutdown
systems exist'o
compensate
for
the
systems
assumed
lost in the fire.
With regard to the exception
mentioned
above,
in the Reactor Building, the
licensee
uses
a fire break
zone referred to as the wrap-around
zone.
Within
this zone,
the licensee
wrapped all safe
shutdown cables
and raceways with
fire protective wrap.
Thus, the, reactor building is divided into two fire
areas
separated
by the wrap-around
zone.
This zone
separates
the
Division I from the Division II equipment.
For post-fire safe
shutdown,
the licensee
has identified Safe
Shutdown
Paths
1, 2,
and 3.
The Division I train of ADS/Core Spray, Alternate
and Suppression
Pool Cooling is utilized for Path
1.
The Division II train of ADS/Core Spray, Alternate
Shutdown Cooling and
Suppression
Pool Cooling is used for Path 3.
Simultaneous
shutdown of
both units is achieved
by using safe
shutdown path
1 or 3 for the affected-
unit (the unit where the fire occurred).
The
along
with the associated
support
systems
are
used to provide reactor coolant
makeup for the unaffected Unit.
Alternate
Shutdown Cooling and Suppression
Pool Cooling capability for the unaffected unit is provided by using
Paths
1 or
3 described
above.
Path
2 is the Alternative Shutdown
Path
and is the path
used for a
Co'ntrol'oom
fire.
This requires
shutdown
from outside the Control
Room using the
remote
shutdown panels.
The Reactor Coolant Inventory Control for Paths
1 and
3 is provided by
the Core Spray
System taking suction, from the suppression
pool after
the reactor is de-pressurized
by-the
ADS.
RCIC and
HPCI are
assumed
either
damaged
by fire or unavailable.
The
licensee
has submitted Appendix
R Deviation Request
No.
33 to address
the
fact th'at the reactor coolant process
variables
are not maintained
strictly within those predicted for a loss of offsite power (a faster
de-pressurization
rate,
and lower level than level 2).
For the Control
Room fire and subsequent
evacuation
scenario,
the
RCIC system taking
suction from the Condensate
Storage
Tank is used for reactor vessel
inventory control
(Shutdown
Path 2).
For Reactor
Pressure
Control
and
Decay Heat
Removal for Paths
1 and
3, the licensee is using Manual
ADS operation
along with the
RHR in
the suppression
pool cooling mode.
The A, B, and
C SRV's and Suppression
Pool cooling are
used for Path
2.
6.0
Ins ection Methodolo
The inspection
team examined
the licensee's
capabilities for separating
and protecting equipment,
cabling
and associated
circuits necessary
to
achieve
and maintain hot and cold shutdown conditions.
The inspection
sampled
selected fire areas
which the licensee
had identified as being
bounded with fire rated walls and also
reviewed the wrap around
zone.
The following functional requirements
were reviewed for achieving
and
maintaining hot and cold shutdown:
React,ivity control
Pressure
control
makeup
Decay heat
removal
Support
systems
Process
monitoring
The inspection
team also
examined
the licensee's
capability'o 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
a review of the procedures
for
achieving
remote
shutdown.
Drawings were reviewed to verify electrical
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 the fire .suppression
systems.
4
The inspection
team examined
the licensee's
fire protection features
provided to maintain
one train of equipment
needed for safe
shutdown free
of fire damage.
Included in the
scope of this effort were fire area
boundaries.
This included walls, floors and ceilings,
and the protection
of openings
such
as fire doors, fire dampers,
and penetration
seals.
The inspection
team also examined
the emergency lighting for areas
of the
plant necessary
for safe
shutdown.
7.0
Ins ection of Protection
Provided to Safe
Shutdown
S stems
7. 1
Protection
in Various Fire Areas
The team randomly reviewed the protection provided to SSSs
in
selected fire areas for compliance with the applicable
NRC
requirements
and licensee
commitments
towards Appendix
R.
No unacceptable
conditions were identified.
,
7.2
Safe
Shutdown
Procedures
7.2. 1
Procedure
Review
The team reviewed the following safe
shutdown
procedure
~
E0-100-009,
Plant
Shutdown
from Outside Control- Room,
Revision
11.
(Unit 1)
~
E0-200-009,
Plant Shutdown
from Outside Control
Room,
Revision
12.
(Unit 2)
The
scope of review was:
to ascertain
that the
shutdown
could be attained
in
a safe
and orderly manner;
to
determine
the level of difficulty involved in operating
equipment;
and to verify that there
was
no dependence
on
repairs for achieving hot shutdown.
For the purpose of the
review,
a repair would include installing electrical
or
pneumatic jumpers, wires or fuses
to perform an action
required for hot shutdown.
The team did not identify any unacceptable
conditions.
7.2.2
Procedure
Walk-Throu
h
The team walked through selected
portions of the procedures
to determine that shutdown could be attained in an orderly
and timely fashion.
I
The team did not identify any unacceptable
conditions,
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
maloperation
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 associated
circuits were evaluated
by the team, for common bus,
spurious
signal
and
common enclosure
concerns.
Power, control,
and
instrumentation circuits were examined
on
a sampling basis for
potential
problems.
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,
4160VAC,
480VAC,
250VOC,
125VOC and
120
VAC 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.'he
following deficiencies
were identified:
Circuit Breaker Coordination
and Maintenance
The licensee
performed. an analysis
addressing
the
common
power source
concern.
.This analysis is contained
in
Report SEA-EE-40,
Revision l.
This report contains
recommendations
for modifications to
be performed
where
an acceptable
level of circuit coordina-
tion could not be demonstrated.
The team observed that
most of these modifications were already properly "dispositioned
and implemented.
However, this analysis identified the
following changes
that are required to be performed.
480V Load Center
1B210
28210
28230
Breaker
21
21
21
If
~Chan
e
For improved ground
fault coordination
all three breakers
sh'ovid have the
time delay band
changed 'from "MIN"
to "INTERMEDIATE"
2B210
2B220
1B220
1B230
1B240
13
13
13
2323'hort
time pickup
setting
from 3X-4X
Short time pickup
setting
from 3X-4X
Short time pickup
setting
from 6X-4X
Long'ime pickup
.
from 1.1 to 1.0
Long time, pickup
from "MAX" to
"INTERMEDIATE"
10
480V
2B247
Breaker
33
~Chan
e
Verify that the
instantaneous
setpoint is not
higher than
5>(
rated
Subsequent'o
this finding the'licensee
initiated
Engineering
Work Request
(EWR) Number M81474 dated
Oecember
6,
1988.
The intent of this
EWR is to evaluate
and resolve
the
480V circuit changes
identified in
SEA-EE-040.
The licensee
explained,
that the reason
these
required
modifications were not completed
was the erroneous
assumption
that these modifications were not required.
The team observed that the improperly coordinated circuits
identified represent
an isolated
example of non-coordinated
circuits.
Overall circuit coordination will be accomplished
when the modifications are complete.
With regard to circuit breakers,
an additional
concern
was
raised
by the
team
upon determining that the licensee
does
not perform scheduled
maintenance
on circuit breakers
at
the
480V load center level
and below.
Maintenance
should
be performed
on the breakers if credit for proper
breaker'oordination
is taken.
This is collectively an unresolved
item pending
a review
of the actions
taken
by the licensee
in response
to the
NRC
observations
(50-3987/88-21-01
and 50-388/88-24-01).
Anal sis of Hi
h
Im cdance
Faults
The inspection
team observed that the licensee
does not-
have specific procedures
to clear high impedance faults
nor do they have
an analysis
assuring
that
such faults
are not likely to occur.
The licensee
stated
that if such a-fault occurs
the
operators
would attempt to restore
the lost bus
by resetting
the upstream
breaker to the bus.
If this simple action is
unsuccessful,
the operators notify maintenance
to trouble-
shoot
and restore
the bus.
11
The
NRC concern is that maintenance
personnel
may not be
available
should high impedance faults occur during
a
fire.
This issue is currently being reviewed
by
NRR as part, of
the Fire Hazard Report Evaluation
and issuance
of the
Safety Evaluation Report.
7.3.2
S urious Si nals'oncern,
The spurious
signal
concern is made
up of two 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 ci rcuits.
~
Spurious operation of safety related or non-safety
related
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:
P
~
Current transformer
secondaries
~
High/low pressure
interface
~
General fire instigated
spurious
signals
Deficient conditions were identified as follows:
Communication
S stem Reliabilit
for a Control
Room Fire
The licensee's
alternate
shutdown
procedure,
indicates that
radio communication will be required for use
by the
operators
in the event of a Control
Room fire requiring
evacuation
and
shutdown
from outside the Control
Room.
However,
the licensee
did not include the communications
circuitry within the
scope of the Appendix
R analysis.
Mhile several
communication
systems
may be available,
the
ability of one communication
system to perform its function
in the event of a
Control
Room fire has not been conclusively
established.
The licensee initiated
NCR Number
88-0736'ated
December
6,
1988 to resolve this issue.
12
Pending
the licensee's
evaluation of the existing
'communication
system
and the implementation of any
modifications, this is an unresolved
item.
(50-387/88-21-02
and 50-388/88-24-02)
7.3.3
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 barrier
A number of circuits, selected
on
a sampling basis,
were
examined for this concern.
No unacceptable
conditions. were identified.
8.0
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
7.3. 1 and 7.3.2.
9.0
Exit Interview
The inspection
team met with the licensee
representatives,
denoted
in
Section 1.0, at the conclusion of the inspection
on December
9,
1988.
The team leader
summarized
the
scope
and findings of the inspection at
that time.
The team leader also confirmed with the licensee
that the documents
reviewed
by the
team did not contain
any proprietary information.
The
licensee
agreed that the inspection report
may be placed
in the Public
Document
Room without prior licensee
review for proprietary information
At no time during this inspection
was written material
provided to the
licensee
by the
team.