ML17164A779
| ML17164A779 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/04/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17164A778 | List: |
| References | |
| 50-387-97-201, 50-387-98-09, 50-387-98-9, 50-388-97-201, 50-388-98-09, 50-388-98-9, NUDOCS 9809140229 | |
| Download: ML17164A779 (28) | |
See also: IR 05000387/1998009
Text
U.S. NUCLEAR REGULATORYCOMMISSION
REGION I
Docket Nos:
50-387, 50-388
License Nos:
Report Nos.:
50-387/98-09, 50-388/98-09
Licensee:
Pennsylvania Power and Light Company
Facility:
Susquehanna
Steam Electric Station
Location:
Salem Township, Luzerne County, Pennsylvania
Dates:
July 29 - August 7, 1998
Inspectors:
Roy L. Fuhrmeister, Sr. Reactor Engineer
Approved by:
William H. Ruiand, Chief
Electricai Engineering Branch
Division of Reactor Safety
Region
I
9809i40229
980904
ADOCK 05000387
8
Table Of Contents
PAGE
Executive Summary ......... ~.....................
~... ~......
~
~ ..
~
~
~ ii
Report Details ....... ~....................... ~.....................
1
V. Plant Support ....... ~.............. ~...........................
1
I
F8
Miscellaneous Fire Protection Issues ............. ~..................
1
F8.1
(Closed) URI 50-387&388/97-201-01:
Failure to follow plant
'dministrative controls in the essential safeguards
(ESSW) pumphouse .......................
~ ~..............
1
F8.2
(Closed) Program Weakness:
Fire brigade effectiveness to control and
extinguish a flammable/combustible liquids fire ...................
1
F8.3
(Closed) Program Weakness:
Failure to meet NDAP-OA-0445 procedural
.
requirements for annual physicals for fire brigade members ...........
2
F8.4
(Closed) URI 50-387&388/97-201-02: Post-fire safe shutdown
methodology does not assure availability of keep-fill system...........
2
F8.5
(Closed) URI 50-387&388/97-201-03: Failure of the automatic
depressurization
system/core spray (ADS/CS) post-fire safe shutdown
methodology to meet the performance goal ....... ~..............
3
F8.6
(Closed) URI 50-387&388/97-201-04: Failure to identify preferred
post-fire safe shutdown instrumentation and required post-fire safe
shutdown actions in procedures ..............................
4
F8.7
(Closed) URI 50-387&388/97-201-05:
Fire mitigation system design and
installation does not appear to meet minimum industry codes and
standards ..............................................
4
F8.8
(Closed) URI 50-387&388/97-201-06: Operational suppression capability
of the CO~ systems has never been demonstrated..................
7
F8.9
(Closed) URI 50-387&388/97-201-07: Failure to provide the required
post-fire safe shutdown lighting ..............................
8
V. Management Meetings ....................... ~.............. ~... 9
X1
Exit Meeting Summary ..........................................
9
PARTIALLISTING OF PERSONNEL CONTACTED....... ~.......,............
10
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED ........................
11
LIST OF ACRONYMSUSED...........................................
13
Executive Summary
This inspection was conducted as a followup to the Fire Protection Functional Inspection
(FPFI) performed during October and November 1997, and documented
in NRC Inspection
Report 50-387 and 50-388/97-201.
The purpose of this inspection was to review the
unresolved issues from the FPFI inspection to characterize the findings for appropriate
enforcement actions.
The inspection included review of the Pennsylvania Power and Light
(PP&L) letter dated July 20, 1998, which responded to the issues raised in the FPFI
Report, independent verification of information provided in the July 20,-1 998, letter, and
tours of selected areas of the plant.
Plan
Su
o
The failure to properly implement controls of combustible material and transient
equipment in the ESSW Pumphouse
is an apparent violation.
(EEI 60-387&388/98-
09-01) (Section F8.1)
The failure to perform annual physical examinations for fire brigade members, as
required by NDAP-QA-0445 is an apparent violation.
(EEI 60-387&388/984942)
(Section F8.3)
The failure to provide the necessary tools and materials to make the connection
from the fire water system to the CTS for keepfill, as described in the post-fire safe
shutdown analysis, is an apparent violation.
(EEI 50-387&388/98-0943)
The failure of the ADS/CS shutdown methodology to meet the safe shutdown
performance goals specified in 10 CFR 50, Appendix R, Section III.Lis an apparent
violation.
(EEI 60-387&388/98%9%4)(Section
F8.5)
This failure to properly implement the requirements of NFPA 72E in the design and
installation of the fire detection system is an apparent violation.
(EEI 50-387&388/98-09-05)(Section
F8.7)
The failure to properly implement the requirements of NFPA 13 in the design and
installation of the sprinkler systems is an apparent violation.
(EEI 60-387&388/98-
09-06) (Section F8.7)
The failure to properly implement the requirements of NFPA 14 in the design and
installation of the standpipe and hose reel system was considered
a non-cited
violation as a result of being identified by PP&L. (NCV 50-387&388/98-09-07)
(Section F8.7)
The failure to provide emergency lighting an all areas requiring manual actions to
achieve safe shutdown is an apparent violation.
(EEI 50-387&388/98-09-08)
(Section F8.9)
Re ort Details
This inspection was conducted as a followup to the Fire Protection Functional Inspection
(FPFI) performed during October and November 1997, and documented in NRC Inspection
Report 50-387 and 50-388/97-201.
The purpose of this inspection was to review the
unresolved issues from the FPFI inspection to characterize the findings for appropriate.
enforcement actions.
The inspection included review of the Pennsylvania Power and Light
(PP&L) letter dated July 20, 1998, which responded to the issues raised in the FPFI
Report, independent verification of information provided in the July 20 1998, letter, and
tours of selected
areas of the plant.
IV. Rant Su
ort
F8
~
Miscellaneous Fire Protection Issues
F8.1
Closed
URI 50-387&388 97-201-0: Failure to follow plant administrative
controls in the essential safeguards
service water (ESSW) pumphouse.
Combustible
material in excess of five pounds was stored in the transient material area at the
east end of the pump house.
In addition, a portable stairway was chained to a
spare conduit without approval from engineering.
These deficiencies were corrected prior to the end of the FPFI by removal of the
combustible material and chaining the portable stairway to nearby structural steel.
PP&L personnel performed additional walkdowns of the facility and found no similar
problems.
Subsequent
actions by PP&L included prohibiting the use of small plastic
vacuum cleaners
in the plant.
The inspector conducted tours of the facilityto confirm the'effectiveness
of the
corrective actions.
No additional deficiencies were identified.
The Fire Protection Review Report (FPRR), Table 5.0-1, Section B.2.c states that
administrative controls at Susquehanna
Steam Electric Station (SSES) govern the
handling of, and limit, transient fire loads.
Procedure NDAP-QA-0440 implements
these administrative controls.
In addition, procedure NDAP-QA-0552 governs the
handling of transient equipment in the plant.
The failure to properly implement the requirements of NDAP-QA-0440, Rev. 2,
Control of Transient Combustible/Hazardous
Material," and NDAP-QA-0552, Rev.1,
"Transient Equipment Controls," in the ESSW Pumphouse
appears to be a violation
of the license condition.
(EEI 50-387&388/98-0941)
F8.2
Closed
Pro ram Weakness:
Fire brigade effectiveness to control and extinguish a
flammable/combustible liquids fire impacted by the policy to restrict the use of fire
fighting foam on site. Amendment 27 to the Final Safety Analysis Report (FSAR)
excludes the installation of fire protection foam anywhere in the plant.
In its response letter dated July 20, 1998, PP&L stated that all of the flammable
liquids hazards would be three-dimensional or pressure fires, not pool type fires with
a horizontal surface.
It further stated that, since the turbine generator lubricating oil
system, hydrogen seal oil system and transformers have pre-action or deluge
sprinkler systems, the use of manual fire fighting foam is not appropriate.
This is
due to the discharge of the sprinkler system breaking up the foam blanket and
rendering it ineffective.
The inspector reviewed the April 1981 Safety Evaluation Report (SER) for the SSES.
Amendment 7 to the FSAR added leak proof metal covers to the new fuel storage
vault, and Amendment 27 prohibited installation of fire fighting foam systems
h
i
.
i ..1~
ih
the applicants that the addition of the metal covers and the absence of fire fighting
foam systems would be an acceptable alternative to performing k
calculations
assuming optimum moderation."
The policy to restrict fire fighting foam is in
conformance to the facility's licensing basis.
This matter is resolved and closed.
F8.3
losed
Pro
a
k
s
Failure to meet NDAP-QA-0445 procedural
requirements for annual physicals for fire brigade members.
Operations Department
had changed over to biennial physicals for fire brigade members in 1995. The entire
operations fire brigade complement received their first biennial physical in 1996.
The July 20, 1998, response to the FPFI report states that the operations
department procedures NDAP-QA-0625 and 0653 have been revised to require
annual physicals for fire brigade members.
It further states that, with the
exception of five operations personnel scheduled for October 1998, all fire brigade
members have had their annual physicals.
The annual cycle for physicais willbe
restored by the end of 1998.
The revisions brings the operations procedures into compliance with NDAP-QA-
0445, Rev. 2, "Fire Brigade." The completion of the physical exams in October,
1998 willbring all members of the fire brigade into compliance with the
requirements.
The failure to perform annual physical examinations for fire brigade members, as
required by NDAP-OA-0445 appears to be a violation of the license condition.
(EEI 50-3878>388/98-09-02)
Closed
URI 50-3875388 97-201-02: Post-fire safe shutdown methodology does
not assure availability of keep-fill system to prevent water hammer in the high
pressure coolant injection (HPCI), reactor core isolation cooling (RCIC), core spray
(CSS), and residual heat removal (RHR) system discharge piping. The condensate
transfer system (CTS) and the cross-tie to the demineralized water system
alternative keepfill scheme are not powered from a 1E bus, which would make them
unavailable during a fire which causes
a loss of offsite power (LOOP). PPLL had
previously developed an alternate keepfill scheme using a temporary hose to supply
water from the fire water system to the CTS.
During a walkthrough conducted by
the FPFI team, the tools and equipment necessary to make the connection were not
available.
r
The July 20, 1998, PP&L response states that the tools and equipment necessary
to make the connection from the fire water system to CTS were staged
November 26, 1997. The response further states that the time lines documented in
calculation EC-013-0843 show the systems being initiated within the first
40 minutes after a fire in most cases, which indicates that the loss of keepfill would
not adversely affect the ability of the systems to perform their safe shutdown
functions.
This conclusion is born out by testing conducted subsequent to the FPFI
which showed that the discharge piping pressure was maintained in the CSS for
over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The inspector reviewed the timelines documented in calculation EC-013-0843,
Rev. 5, "SSES 10CFR50 Appendix R Compliance Manual," and verified the starting
times of the systems in the analyses.
In addition, the inspector inventoried the
equipment and tools staged for making the fire water to CTS cross-tie and
determined that appropriate connectors, hose, check valves and tools were
provided.
The failure to provide the necessary tools and materials to make the connection
from the fire water system to the CTS for keepfill, as described in the post-fire safe
shutdown analysis, appears to be a violation of the license condition, since
Section 1.2 of the FPRR commits to Section III.G of Appendix R to 10 CFR Part 50,
and Section 5.1.1 of the attachment to Generic Letter 86-10 states that the
performance goals of Section III.Lof Appendix R also apply to the remote and
alternative shutdown capabilities specified in Section III.G.3 of Appendix R.
(EEI 50-387&388/9849-03)
Clo ed
URI 50-3 7&
9 -2
3: Failure of the automatic depressurization
'.:
system/core spray (ADS/CS) post-fire safe shutdown methodology to meet the
performance goal of maintaining the reactor water level above the top of active fuel
(TAF). Calculation EC-013-0843 showed that spurious safety relief valve (SRV)
opening could cause reactor water level to drop below TAF. Further, calculation
EC-013-0509, Rev. 1, "Minimum Reactor Water Level Under Spurious SRV
Operation During a Control Room Fire," showed that spurious opening of one or two
SRVs could cause reactor water level to go below TAF.
Deviation Request ¹33 in the SSES FPRR states "... the reactor coolant makeup
function will be capable of maintaining the reactor coolant level above the top of the
core." The deviation request was to allow use of the ADS/CS shutdown
methodology in lieu of high pressure injection systems.
The FPRR was approved, as
documented
in an NRC SER dated August 9, 1989.
The July 20, 1998, PP&L response to the FPFI report indicates that a revision to a
thermal-hydraulic calculation, EC-THYD-1035, was performed to evaluate the
coolant level inside the core shroud for the ADS/CS safe shutdown methodology.
This analysis did not specifically model the case of spurious actuations of SRVs
since that scenario would start the reactor depressurization
at a lower pressure,
reducing the time necessary to inject using the low pressure system.
concluded that the two-phase steam and water mixture inside the core shroud, with
a maximum void coefficient of approximately 0.8 (void fraction at core exit is
approximately 0.7 at normal full power conditions) would remain above TAF.
The inspector reviewed EC-THYD-1035, Rev. 1, "ln-Shroud Level Response for a
Boildown Transient with ADS at TAF," to evaluate the results of the ADS/CS
analysis.
Assuming that ADS actuates. automatically at the appropriate setpoint,
the calculation shows that reactor coolant level drops to 52 inches below TAF, with
partial core uncovery for a period of about 5 minutes.
If ADS actuation is delayed
until the manual action in the emergency operating procedures
(EOPs), minimum
level reaches 84 inches below TAF. The inspector also reviewed calculation
'C-013-0509, Rev. 1, "Minimum Reactor Vessel Water level Under Spurious SRV
Operation During a Control Room Fire," to evaluate the vessel level response
in the
case of spurious actuation of SRVs caused by hot shorts.
EC-013-0509 determined
that for the case of one or two SRVs opening due to fire damage, partial core
uncovery can occur for periods of up to one and one half hours if no operator action
is taken.
The failure of the ADS/CS shutdown methodology to meet the safe shutdown
performance goals specified in 10 CFR 50, Appendix R, Section lll.Lappears to be a
violation of the license condition, since Section 1.2 of the FPRR commits to
Section III.G of Appendix R, and Section 5.1.1 of Enclosure
1 to Generic Letter 86-10 states that the performance goals of Section III.Lof Appendix R apply
to remote and alternative shutdown methods under Section III.G.3 of Appendix R.
(EEI 50-387&388/98%9-04)
F8.6
I sed
Rl 5
-
&
8 9 - 0 -04: Failure to identify preferred post-fire safe
shutdown instrumentation and required post-fire safe shutdown actions in
procedures used for post-fire safe shutdown from inside the control room.
~
In the event of a fire in the plant; the operators use emergency operating procedures
(EOPs), off-normal (ON) procedures,
operating procedures
(OPs), and pre-fire plans
for guidance on actions to be taken and equipment which is available.
The ON for
fire conditions is ON-013-001, "Post-Fire Shutdown Procedure."
The inspector reviewed Revision 8 to ON-013-001 to determine what information it
provided operators for post-fire conditions.
The attachments
provide specific
guidance for actions to compensate for fires in different areas of the facility, as well
as a listing of locations of sound-powered telephone stations for establishing
communication.
The pre-fire plans for the various fire areas list the equipment and
instrumentation which may be affected by a fire in that area.
Based on the fire affected instrumentation being identified in the pre-fire plans, and
the required actions being identified in the attachments to the off-normal procedure,
there is no violation of requirements.
This issue is closed.
F8.7
Closed
URI 50-387&388 97-201-05: Fire mitigation system design and
installation does not appear to meet minimum industry codes and standards.
Smoke detector locations do not take into consideration all aspects of ceiling shape
and surface, ceiling height, and the effects of the ventilation system, as required by
National Fire protection Association (NFPA) Standard 72E. Sprinkler installations do
not conform to the requirements of NFPA 13.
Hose reel and standpipe locations do
,, ~
not conform to the requirements of NFPA 14. These deficiencies were identified by
FPFI team members who performed a walkdown of several elevations in the Unit 1
and Unit 2 Reactor Buildings, with the exception of the hose reel and standpipe
locations.
The code of record for the fire and smoke detection system is the 1975 edition of
NFPA 72D, "Standard for the Installation, Maintenance and Use of Proprietary
Signaling Systems for Watchmen, Fire Alarm and Supervisory Service." The
associated
standard for fire and smoke detector placement is the 1974 edition of
NFPA 72E, "Standard on Automatic Fire Detectors.
During tours of the facility,
the FPFI inspection identified the following deficiencies with smoke and heat
detector placement:
~
On the 670'-0" level of the Unit 1 Reactor Building, the FPFI team identified
two detectors (1-I-222 and 1-I-219) which were suspended
more than
one foot below the ceiling. This is contrary to NFPA 72E Section 4-3, which
requires that spot type smoke detectors be mounted on the ceiling.
~
On the 719'-0" level of the Unit 2 Reactor Building, the team found smoke
detectors in rooms 406 and 407 which were mounted within one foot of the
supply air diffuser, with the air flow directed across the detector.
This is
contrary to NFPA 72E, Section 4-4, which prohibits placing smoke detectors
where air from supply diffusers could dilute smoke before it reaches the
detector.
This failure to properly implement the requirements of NFPA 72E in the design and
installation of the fire detection system appears to be a violation of the license
condition.
(EEI 50-3878c388/98%9%5)
FPRR Sections 4.2, "Automatic Wet pipe Sprinkler Systems," 4.3, "Dry Pipe
Sprinkler Systems," and Table 5.0-1, Section E.3.c state that the sprinkler systems
were designed in accordance with NFPA Standard 13. The code of record for the
sprinkler systems
is the 1974 edition of NFPA 13, "Standard for the Installation of
Sprinkler Systems."
Additional guidance on sprinkler system design and installation
is contained in NRC Generic Letter (GL) 86-10, "Implementation of Fire Protection
Requirements."
During facilitytours, the inspection team identified the following
deficiencies regarding sprinkler installation:
~
The upright sprinkler head located outside door 1-109 (Unit 1 remote
shutdown panel room) has the sprinkler head and deflector located at a
45 degree angle, and appears to have fire barrier material on its fusible link
and deflector.
This is contrary to NFPA 13 Section 4-2.4.7 which requires
sprinkler deflectors to be parallel to roofs and ceilings, and NFPA 13
Section 3-16 which prohibits application of coatings to sprinklers after they
leave the place of manufacture.
~
~
~
~
An upright sprinkler head located above the Unit 1 HPCI pump is connected
to a /*"X4"pipe nipple, and is located in
a beam pocket such that the spray
pattern is obstructed on all sides.
This is contrary to NFPA 13 Section 4-2A
which requires sprinklers in bays to be at sufficient distances from beams to
avoid obstruction of sprinkler discharge pattern, and NFPA 13 Section 7-1,
which prohibits the use of ferrous piping less than one inch nominal size.
~
There are obstructions below the sprinkler heads outside the door to the
Unit 2 traversing incore probe room (door 406 on the 719'-0" level of the
Unit 2 Reactor Building) including light fixtures, beams and electrical boxes.
This is contrary to NFPA 13 Chapter 4 which requires minimizing the
interference to discharge patterns from beams, braces, girders, trusses,
lighting fixtures, and air conditioning ducts.
~
The control rod drive pump area on the 719'-0" level of the Unit 2 Reactor
Building has overhead obstructions, including lighting fixtures, beams, and
electrical components that inhibit the sprinkler from developing and delivering
an effective spray pattern to the floor within the protected area.
This is
contrary to NFPA 13, Chapter 4.
~
On the 749'-0" level of the Unit 2 reactor building, near column-line T30.5,
the ceiling level sprinklers are obstructed by a four feet wide ventilation duct
and by Thermo-Lag barrier E2KK21, which is also greater than four feet
wide. This is contrary to NFPA 13 Chapter 4.
The failure to properly implement the requirements of NFPA 13 in the design and
installation of the sprinkler systems appears to be a violation of the license
conditions.
(EEI 50-387&388/98-09-06)
FPRR Section 4.6 and Table 5.0-1 Section E.3.d state that NFPA 14 was used as
guidance for the design and installation of the system of standpipes
and hose reels
in the station.
The code of record is the 1974 edition of NFPA 14, "Standard for
the Installation of Standpipe and Hose Systems."
SSES uses
a Class II system.
consisting of 1-1/2" hoses intended for use by the building occupants until the
arrival of the fire department.
Section 3-2.2 requires that the location and spacing
of the hose stations be such that all portions of each story of the building are within
30 feet of a nozzle when attached to not more than 100 feet of hose.
The FPFI
team examined several hose stations serving the main control room and the Unit 1
lower cable spreading room.
No deficiencies were identified. During the week of
October 27, 1997 (while the FPFI team was off-site), PPSL performed additional
walkdowns, and identified several hose stations which did not meet the area
coverage requirement.
These deficiencies were documented
in condition report 97-
3650. This non-repetitive licensee-identified violation, with committed corrective
actions, of the fire protection license condition ultimately NFPA 14is being
treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC
Enforcement Policy. (NCV 50-3878c388/98-09-07)
In its July 20, 1998, letter, PP&L stated they are performing a comprehensive
assessment
of the fire detection and suppression systems for safety related areas of
the facility. This assessment
willinclude walkdowns of the in-plant installation to
determine the level of compliance of the installed systems.
Deviations from the
requirements willbe justified based on additional analyses,
or entered in to the
corrective action program.
Corrections willimplemented under the plant
modification process.
PP&L expects to complete the walkdowns and evaluations by
the end of 1998.
F8.8
Closed
URI 50- 87&3 8 97-2: Operational suppression capability of the
CO, systems has never been demonstrated
by code-required system full discharge
tests.
The only CO, total flooding system at SSES which was full discharge tested
failed the test.
No additional full discharge tests were performed, and an alternative
testing methodology was used.
FPRR Section 4.8, and Table 5.0-1, Section E.5 state that the carbon dioxide fire
suppression
systems are designed in accordance with NFPA 12. The code of record
for the carbon dioxide systems is the 1973 edition of NFPA 12, "Standard on
Carbon Dioxide Extinguishing Systems."
In addition, Table 5.0-1, Section A.2
states, "Appropriate procurement and drawing procedures existed in Bechtel for the
control of inspections, tests, and instructions for the fire protection equipment and
systems during the procurement and construction phases.
Total flooding gaseous
suppression systems are installed in cable chases,
relay
rooms, control room under floor areas, control room soffit areas, and rooms C-411,
C-412, C-413, and C-414 soffit areas.
These systems were designed and
installed
under Bechtel Specification 8856-M-344. Section 10.3 of the specification states,
"Afull carbon dioxide discharge test and concentration test shall be made for-each
hazard.
The only total flooding CO~ suppression system to be full discharge tested
at SSES, the elevation 698'orth cable chase, failed the test, due to inadequate
agent retention time. The test results are documented on work authorization (WA)
U27611. The WA does not contain any data in the "CO, Concentration %"
column. Strip chart traces attached to the WA indicate that the longest time the
agent was maintained at 50% concentration was 13 minutes at one foot from the
floor elevation.
The test results were not signed for acceptance
by the Factory
Mutual witness, as required.
In a Mutual Atomic Energy Reinsurance
Pool (MAERP)
reinspection report dated April 23, 1982, the test was accepted
on the basis that
the retention time was expected to have been met had the access door not been
left open.
The report concluded, "In the future during testing, carbon dioxide
concentration levels will be monitored for a minimum of twenty minutes to permit a
more complete evaluation of how well the extinguishing agent is holding." The
"future" tests were never conducted.
NRC Inspection report 50-387&388/89-09
documented that initial acceptance
tests of the other systems were not performed.
To resolve the 1989 open item, PP&L proposed alternate testing to verify the
capability of the carbon dioxide total flooding suppression
systems to maintain the
required concentration for the required time to ensure complete extinguishment.
This test methodology is based on the alternate testing described in the 1989
edition of NFPA 12A, "Standard on Halogenated
Fire Extinguishing Agent Systems-
Halon 1301." This alternate test methodology was reviewed and approved by the
Office of Nuclear Reactor Regulation (NRR) in an SER dated May 12, 1992. That
SER refers to the failed full discharge test documented on WA-U27611, and the fact
that no other preoperational testing was performed to demonstrate the
systems'apabilities.
Thus, it can-be shown that NRR was aware of the test failure, and the
reasons to which it was attributed, at the time they reviewed and approved the .
alternate test methodology.
4
Based on the SER specifically recognizing that the only full discharge test attempted
at SSES failed, and approving the alternate testing, this matter is resolved and
closed.
F8.9
Cl se
URI 50-3 7&388 7-2: Failure to provide the required post-fire.safe
shutdown lighting in areas, and have a program that assures the operability of
required lighting in the "E" diesel building. During a walkthrough of the procedure
for shutdown outside the control room, the FPFI team identified several areas of the
plant where manual actuations were required to be performed that did not have the
required 8-hour battery supplied emergency lights.
In addition, the team found that
the emergency lights in the "E" diesel generator building, where manual actions
would need to be performed in the event the "E" diesel generator were aligned in
place of one of the divisional diesel generators,
had not been evaluated to determine
which were needed for safe shutdown.
FPRR Section 3.3.2 and Table 5.0-1, Section D.5.a, state that SSES willconform to
the emergency lighting requirements in Section III.J of Appendix R to 10 CFR,
Part 50.Section III.J requires that emergency lighting units (ELUs) with at least an
8-hour battery power supply be provided an all areas needed for operation of safe
shutdown equipment, and in access
and egress areas thereto.
The FPFI team conducted
a walkthrough of the Unit 1 alternate shutdown
procedure, ON-100-109.
During that walkthrough, the following emergency lighting
deficiencies were identified:
The procedure required reactor water cleanup (RWCU) system equipment
located in a corridor on the west side of the 779'-0" level of the reactor
building to be checked for evidence of leakage or flow diversion.
There are
no safe shutdown emergency lights in this area.
The procedure requires that breaker 018 in power panel 1Y219 be opened to
stop RWCU leakage, or flow diversion to radioactive waste or the main
condenser via RWCU. Power panel 1Y219, located on the 719'-0" level of
the Unit 1 reactor building is not illuminated by an ELU.
To ensure that shutdown cooling return flow is injected into the reactor
vessel, rather than the recirculation loop, flow control valve HV-243-FO23A
must be closed.
Since this valve can not be controlled from the remote
shutdown panel, for shutdown outside the control room, actions must be
carried out at motor control center (MCC) 2B237043.
was installed at the MCC.
The FPFI team also evaluated emergency lighting in other areas of the plant.
In the
event that the "E" diesel generator is aligned in place of one of the divisional diesel
generators,
manual actions will need to be carried out in the "E" diesel generator
building for shutdown outside the control room.
No safe shutdown lights had been
provided in the "E diesel generator building.
In their July 20, 1998, response,
PP&L stated that the RWCU actions were not
needed to reach hot shutdown conditions.
This statement is supported by a
revision to calculation EC-013-0859, "Appendix R Analysis for a Control Room
Fire." Revision 7 to the calculation, dated June 24, 1998, documents that there are
more than eight hours after the fire, in which to isolate the RWCU system.
This
calculation revision also shows that RWCU isolation is not needed to achieve hot
shutdown conditions.
As a result, PP&L is removing the RWCU isolation actions
from the alternate shutdown procedures.
PP&L has identified those ELUs in the "E diesel generator building necessary for
post-fire safe shutdown.
Those ELUs have been added to the maintenance
and
surveillance testing programs.
The failure to provide'emergency lighting in all areas requiring manual actions to
achieve safe shutdown appears to be a violation of the requirements of Section III.J
of Appendix R to 10 CFR 50, as committed to in Section 1.2 of the FPRR, and
therefore an apparent violation of the license condition.
(EEI 60-387&388l98%9-
08)
V. IVlana ement IVlee in s
X1
Exit Meeting Summary
An exit meeting was conducted by telephone on August 7, 1998. At that time, PP&L
acknowledged the inspection findings and provided additional information regarding the
time frame for corrective actions.
The inspector was also informed that several of the
issues are being pursued generically by the Boiling Water Reactor Owners Group.
None of the information reviewed during the course of the inspection was identified as
proprietary.
PARTIALLISTING OF PERSONNEL CONTACTED
Penns
Ivania Power and
I
G. Miller, General Manager, Nuclear Engineering
R. Pagodin, Manager, Nuclear System Engineering
M. Simpson, Manager, Nuclear Technology
T. Gorman, Project Manager, Nuclear Engineering
J.
Kenney, Supervisor, Nuclear Licensing
R. Prego, Supervisor, Site Surveillance Services
R. Wehry, Supervising Engineer, licensing
S.
Davis, Site Fire Protection Engineer
W. Williams, Senior Engineer, Licensing
Nuclear Re ulato
Commission
J.
Richmond, Resident Inspector
A. Blarney, Resident Inspector
~
~
~Oened
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
0
EEI 50-387&388/98-09-01
EEI 50-387&388/98-09-02
Failure to properly implement the requirements of
NDAP-QA4440 and NDAP-OA-0552 in the ESSW
Pumphouse
Failure to perform annual physical examinations for
members of the fire brigade
EEI 50-387&388/98-09-03
Failure to provide tools and equipment necessary to
make the connection from the fire water system to the
condensate
transfer system for keepfill
EEI 50-387&388/98-094
Failure to meet the safe shutdown performance goal of
maintaining reactor vessel level above the top of the
active fuel
EEI 50-387&388/09-09-05
Failure to properly implement the requirements of NFPA
72E in the design and installation of the fire detectors
EEI 50-387&388/98-09-06
NCV 50-387&388/98-09-07
Failure to properly implement the requirements of NFPA
13 in the design and installation of the fire suppression
sprinkler systems.
Failure to properly implement the requirements of NFPA
14 in the design and installation of standpipe system.
EEI 50-387&388/98-09-08
Failure to provide 8-hour battery powered emergency
lighting units in all areas requiring manual actions to
achieve safe shutdown
Closed
URI 50-387&388/97-201-01
Failure to follow plant administrative control procedures
in the essential safeguards
pumphouse
URI 50-387&388/97-202-02
Post-fire safe shutdown methodology does not assure
availability of keepfill system to prevent water hammer
in the HPCI, RCIC, CSS and RHR system discharge
piping
URI 50-387&388/97-201-03
Failure of the ADS/CS post-fire safe shutdown
methodology to meet Appendix R reactor performance
goals by maintaining the reactor water level above the
top of the active fuel
URI 50-3875388/97-201-04
Failure to identify preferred post-fire safe shutdown
instrumentation and required post-fire safe shutdown
actions in procedures used for post-fire safe shutdown ~
'RI
50-3878(388/97-201-05
Fire mitigation system design and installation does not
appear to meet minimum industry codes and standards
URI 50-387&388/97-201-06
The operational suppression capability of the CO,
systems has never been demonstrated
by code required
system full discharge tests
URl 50-3878E388/97-201-07
Failure to provide the required post-fire safe shutdown
lighting in areas and have a program that assures the
operability of required lighting in the "E" diesel building
LIST OF ACRONYMS USED
CFR
FPFI
FPRR
GL
cleft
NRC
MAERP
ON
OP
WA
Automatic Depressurization System
Code of Federal Regulations
Core Spray System
Condensate
Transfer System
Emergency Lighting Unit
Emergency operating Procedure
Essential Safeguards
Fire Protection Functional Inspection
Fire Protection Review Report
Final Safety Analysis Report
NRC Generic Letter
High Pressure Coolant Injection
Effective Neutron Multiplication Factor
National Fire Protection Association
Nuclear Regulatory Commission
Mutual Atomic Energy Reinsurance
Pool
Motor Control Center
Off Normal Operating Procedure
Operating Procedure
Pennsylvania Power and Light
Reactor Core Isolation Cooling
Safety Evaluation Report
Susquehanna
Steam Electric Station
Top of the Active Fuel
Work Authorization
~t
A