ML17278B047
| ML17278B047 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/20/1986 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| TAC-63528, NUDOCS 8610280298 | |
| Download: ML17278B047 (11) | |
Text
October 20, 1986 Docket No. 50-397 Mr.
G. C. Sorensen, Manager Regulatory Programs Washington Public Power Supply System P.O.
Box 968 3000 George Washington Way Richland, Washington 99352
Dear Mr. Sorensen:
DISTRIBUTION:
~D:-397:
NRC PDR Local PDR BWD-3 r/f EAdensam EHylton JBradfute RBernero
JRidgely Region V (4)
RMarsh
Subject:
WNP-2 Fire Protection - Request for Additional Information (RAI)
Enclosed is the NRC request for additional information concerning the current condition of the WNP-2 facility as compared to the regulations, the WNP-2 license and your commitments to your fire protection program.
This request is not complete as additional concerns have been raised as a result of the recent fire protection inspections.
These additional concerns will be formulated into specific requests for additional information in the near future.
Your response to this RAI is requested within thirty days of your receipt of this request; however,.if you wish, your responses may be submitted individually as soon as your reviews are completed.
In the interest of a speedy resolution to these fire protection issues, we encourage you to submit your responses to the safety issues individually. Please let us know promptly if you can not respond to all issues within thirty days.
We are prepared to discuss any or all of these issues as you may feel it is necessary.
Please contact John 0. Bradfute, (301) 492-9414, of our staff if you have questions or wish additional information.
Sincerely,
Enclosure:
Request for Additional Information cc:
w/enclosures:
See next page Elinor G. Adensam, Director BWR Project Directorate No.
3 Division of BWR Licensing BW -3:
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Mr. G.
C. Sorensen, Manager Washington Public Power Supply System WPPSS Nuclear Project No.
2 (WNP-2)
CC:
Nicholas S. Reynolds, Esq.
Bishop, Liberman,
- Cook, Purcell 5 Reynolds 1200 Seventeenth
- Street, N.W.
Washington, D.C.
20036 Mr. G. E. Doupe, Esquire Washington Public Power Supply System P. 0.
Box 968 3000 George Washington Way Richland, Washington 99532 Mr. Curtis Eschels, Chairman Energy Facility Site Evaluation Council Mail Stop PY-11 Olympia, Washington 98504 P. L. Powell, Licensing Manager Washington Public Power Supply System P. 0.
Box 968, MD 956B Richland, Washington 99352 Mr. W. G.
Conn Burns and Roe, Incorporated c/o Washington Public Power Supply System P. 0. Box 968, MD 994E Richland, Washington 99352 R. B. Glasscock, Director Licensing and Assurance Washington Public Power Supply System P. 0.
Box 968, MD 280 Richland, Washington 99352 Mr. C.
M. Powers WNP-2 Plant Manager Washington Public Power Supply System P. 0.
Box MD 927M Richland, Washington 99352 Regional Administrator, Region V
U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 REQUEST FOR ADDITIONAL INFORMATION RELATING TO CONFORMANCE WITH FIRE PROTECTION PROGRAM WASHINGTON PUBLIC POWER SUPPLY SYSTEM WASHINGTON NUCLEAR PROJECT NO.
2 DOCKET NO. 50-397 In support for obtaining an operating license, Appendix F was submitted to the FSAR which provided an evaluation of the protection of the plant in the event of a fire.
This appendix identified the use of the RCIC system to achieve hot shutdown and the RHR system to achieve cold shutdown conditions in the event of a fire in the control room.
The results of the staff's review were documented in the Safety Evaluation Report (SER) dated March 1983 (NUREG-0892).
Subsequent to the issuance of the SER, the licensee amended the FSAR and undertook modifications to the plant and procedures to delete the use of the RCIC system and to use the Automatic Depressurization System (ADS) to achi.eve hot shutdown conditions.
The approved fire protection plan is the plan as submitted in the FSAR and found acceptable in Section 9.5.1 of the SER and as amended in SSER k'3 and SSER P4.
The fire protection program was inspected by Region V at the WNP-2 site on March 3 through 7, 1986.
Subsequently, R'egion V has re-evaluated the fire protection plan and the facility's compliance
'ith that plan during a site inspection in July-August, 1986.
NRR also reviewed certain aspects of the licensee's fire protection plan during a site visit on August 5 through 7, 1986.
On the basis of these
- reviews, concerns have been raised as to the ability.to shut down safely the facility in the event of a fire, as 'discussed in Section 9.5. 1 of the Standard Review Plan (NUREG-0800).
These concerns are summarized in the following questions:
1.
SAFE SHUTDOWN PROCEDURES In the Standard Review Plan (SRP),
Branch Technical Position (BTP)
CMEB 9.5-1, Position C.5.c(3), indicates the need to have a p'rocedure in effect to implement the alternative or dedicated safe shutdown capability for the specific fire area.
The procedures for WNP-2 are symptom-based procedures.
Abnormal procedure 4.12.1.1 deals with a control room evacuation for any reason.
This procedure makes use of licensee identified protected and non-protected equipment outside of the control
- room, while the guidelines of the BTP are for a procedure to use only those systems which have been 'fully protected from a fire and the effects of the fire.
a) Provide justification for not providing the operators with instructions for safely achieving both hot and cold shutdown without reliance upon equipment that has not,been protec'ted, in accordance with BTP CMEB 9.5-1, in the event of the failure of this equipment to perform its intended function.
b) The minimum time which the staff has given credit for an operator action to be taken outside of the control room is 20 minutes.
An additional 10 minutes seems reasonable for the removal of an average of four screws in each of the five SM-8 cabinets and the re-installation of these screws.
Takinq into consideration the inadequacy of the emergency lighting and the hazard in performing these tasks, it seems reasonable to allow an additional 10 minutes for conservatism.
Therefore, provide a plant
'specific analysis to'onfirm that the ADS/LPCI systems
'can be used to achieve and maintain hot shutdown conditions safely, without operating the ADS for 40 minutes.
c) Provide a discussion which substantiates that the three Division I-ADS valves are protected from the effects of a fire in the control room or in the cable spreading room.
Include in the discussion the protection of all power and signal cables and the Division I power supply and the related power and signal cables.
d)
Me understand that some of the cable routing slips were considered proprietary and were defaced.
Provide a discussion of how the location and routing of all safety related and safe shutdown related cables was verified.
2.
REPAIRS PEOUIRED FOR HOT SHUTDOh'N IN THE EVENT OF A FIRE BTP CMEB 9.5-1, Paraqraph C.S.b(1)(a),
indicates that in the event of a fire,'one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room
'or, the remote shutdown areas should be assured to be free of fire damage.
Being free from fire damage is interpreted to mean that no repairs are permitted in order to achieve and maintain hot shutdow'n conditions.
SER Section 9.5.1.5(2) states that no repairs were assumed to achieve hot shutdown in the event of a fire.
The FSAR, and in particular Appendix F, did not identify any repairs that were required as the result of a fire in order to achieve and maintain hot shutdown conditions.
a) Provide justification for why the removal and re-installation of between three and five shorting screws in five 4160 volt diesel generator bus cabinets is not considered as repairs.
b) Provide a discussion as to why a transfer switchs should not be installed for the SM-8 cabinets as a more appropriate action.
c) The repair specified in Step C.2 of Procedure 4.12.1.1 Appendix C
(associated with terminal block 1C in the cabinet CB-B/8 is necessary to achieve safe shutdown.
Me do not believe that this repair is possible under actual anticipated conditions.
Our con-clusion is based upon the possibility that the operator would be unable to complete the necessary
- action, and would likely be elec-trocuted.
Therefore, provide a commitment to modify the plant such that this repair is not necessary, or demonstrate that this repair can be effected with high reliability without endangering the operator.
3.
TESTING OF ADS COMPONENTS FROM REMOTE SHUTDOMN PANELS Regulatory Guide 1.68 concerns the testing of systems and components which are important to safety to ensure that they will perform properly.
The remote shutdown panels contain controls for the RCIC system, the ADS, and the LPCI system.
As'art of the testing program prior to initial criticality, the RCIC and the LPCI systems were operated from the remote shutdown panels.
The ADS has not been verified to be capable of maintaining hot shutdown conditions from the remote shutdown panels.
Provide justification for not functionally testing the ADS components from the remote shutdown panels.
Also, provide iustification for not functionally testing the ADS from the remote shutdown panels to achieve hot shutdown conditions.
4.
COMMON POMER SOURCE ANALYSIS As stated in the approved fire protection plan, Section F4.4.3, one category of associated circuits -which was to have been revi'ewed is in reference to those "circuits which receive their power from the same sources as the fire protection circuits".
In the event of a fire, the electrical cable insulation could degrade and thereby result in the cable carrying the full current, up to the limit of the circuit protection device.
a) In addition to the normal bus loading, can Division II cables with degraded insulation produce current sufficiently high to open the bus feeder breaker and thereby remove power from equipment needed to achieve safe shutdown of the facility7
4-b) Similarly, can spurious actuations of loads result in overloading the Division II diesel generator?
5.
FIRE MATER MAIN UNDER DIESEL GENERATOR BUILDING Regulatory Guide 1.29, Position C.2, identifies the need to protect safety related structures, systems and components from potential failures of non-safety related structures, systems and components.
Tlie diesel generator building is a safety related structure which contains safety related components and systems.
A fire water main, which is non-safety
- related, runs under the diesel generator building:
The failure
'f the fire water main could adversely affect the'structural features of the diesel generator building particularly its founda-tion; therefore, the failure could affect the availability of the diesel generator.
NFPA 24, Paragraph 8-3.1, states that "pipe shall not be run under buildings".
The fire main under the diesel generator appears to be in nonconformance with NFPA 24.
a) Provide a discussion on the effects of a leak and of a break of the fire main under the diesel generator building as it relates to the degradation of the building structure.
If there is an effect on the structure, the building could shift its position.
Include a discussion of the effects of the building shifting on the diesel generators, related
- systems, and the fuel oil lines.
b) Specify the smallest pipe leak that can be identified.
Discuss how this leakage will be detected.
Specify the surveillance frequency for detection of leakage.
Assuming that the leakage rate is just under the minimum detectable
- amount, and that this leak rate is maintained over the life of-the plant, provide a discussion of the potential for liquefaction in the area affected by the leak.
The ability of safety related structures to withstand liquefaction of affected soils should be addressed if the potential is sig-nificantly changed from that reviewed as the plant's licensing basis.
c) Provide either:
1) a justification for not relocating the fire main; or 2) a discussion of your plans for relocation of this fire main and the schedule for completion of this work.
6.
REVIEW OF ASSOCIATED CIRCUITS Ame'ndment 19 (dated October, 1981> to the FSAR incorporated the fire protection program into the FSAR.
Section F4.4.6 discusses the review of associated circuits and potential plant modifications in the past tense; i.e.,
"A review has been performed..."
and "... the circuit is modified."
This leads one to the conclusion that all reviews and work related to associated circuits are complete.
LER 84-31 and its six revisions indicate that these reviews are not complete.
Verify that all associated circuit reviews and necessary plant modifications are completed.
Specifically, discuss the "common enclosure" analysis performed for raceways.
Should you be unable to verify that all associated circuit reviews and necessary plant modifi-cations are complete,'. provide a schedule with milestones for the associa'ted circuits reviews and resulting plant modifications.
Also provide a commitment to a date when all work will be completed.
7.
HIGH/LOW PRESSURE INTERFACE IN RHR SYSTEM BTP CMEB 9.5-1, Paragraph C.5.c(l), states that "during the postfire
, shutdown, the reactor coolant system process variables shall'e
-.,'aintained within those predicted for a loss of normal ac power, and the fission product boundary inteqrity shall not be affected; i.e.,"there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary."
One area where the reactor coolant pressure boundary integrity may not be. maintained is at the high/low pressure interfaces.
The high/low pressure interfaces at WNP-2 are the RHR suction line (valves RHR-V-8 and RHR-V-9) and the two RHR return lines for normal shutdown cooling (valves RHR-V-123A 8 RHR-V-53A and RHR-V-123B 8 RHR-V-53B).
In a submittal dated July 16,
- 1986, a discussion was provided which
'indicated that removing power from at least one valve in each high/low pr'essure interface line was not reasonable.
This'submittal also
- identified a spacing of 42 feet between the redundant divisions of the pressure interlocks in the control room.
Subsequently, in a telecon, this spacing was confirmed by your staff as incorrect.
Furthermore, there is a significant fire hazard between these interlocks in the control room.
None of these lines are needed or required to mitigate the consequences of an accident or for any emer-gency operation of the RHR system.
The RHR-V-8 and -9 valves are only
'used for non-LOCA shutdown conditions.
The RHR-V-123 valves are in
, w'armup lines for normal shutdown cooling injection to the reactor
-'vessel.
According to the licensee, these valves are never used, as indicated by a recent General Electric Company analysis which shows that prewarming of the RHR return line by use of these bypass valves is not necessary.
During the site visit in August 1986, you advised
'the staff that you would modify control of these valves.
To insure the integrity of the high/low pressure interface:
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~ a)
Document your commitment to remove the power from the RHR-V-8 valve during non-shutdown operating conditions.
b) Document your commitment to remove the power from the RHR-V-123A and RHR-V-123B valves either at the valve or at the motor control center.
c) Provide a schedule and justification for the schedule to implement items a) and b) above.
8.
INADEQUACY OF EMERGENCY LIGHTING BTP CMEB 9.5-1, Paragraph C.5.g, states that lighting is "vital to safe shutdown and emergency response in the event of a fire."
Furthermore, "fixed self-contained lighting consisting of fluorescent or sealed-beam units with individual 8-hour minimum battery power supplies should be provided in areas that must be manned for safe shutdown and for access and egress routes to and from all fire areas."
"All fire areas"'ncludes those required to be manned if the control room is evacuated.
The SER states in Paragraph 9.5.1.5(7) that the utility has installed an 8-hour battery pack emergency lighting unit in all areas of the plant needed for operation of safe shutdown equipment and in access and egress, routes.
Appendix F of the FSAR states in Paragraph F.4.2 that the "The MNP-2 plant complies with the 8-hour emergency light-ing requirements".
Notwithstanding the following deviations were identified during the site visit:
a) Not all areas of the plant, not even all areas of the plant containing safety related equipment, have emergency 8-hour battery powered lighting.
b) The two battery powered lights in the remote shutdown room would provide general lighting, but would not directly illuminate the remote shutdown panel such that the identification plates could be read without difficulty.
c) There are no self-contained battery powered lights in the alternate remote shutdown room.
In accordance with the control room evacuation procedure, one valve needs to be controlled from the alternate remote shutdown panel.
d) The SM-8 room (the room which contains the SH-8 switchgear panels) contains one battery powered light.
This light
" would provide inadequate lighting in the area and no light onto the SN-8 panels or within the SN-8 cabinets.
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7 Provide a discussion that reconciles the Branch Technical Position (BTP CMEB 9.5-1), the SER 9.5.1.5 (7) finding and the FSAR Paragraph F.4.2 assertion with the identified plant conditions or provide a sched-ule for correcting the apparent deviations.
9.
FIRE DETECTORS IN THE VICINITY OF LARGE BEAMS BTP CMEB 9.5-1, Paragraph C.6.a, states that fire detector systems should c'omply with the requirements of Class A systems as defined in $ FPA 72D, "Standard for Installation, Maintenance, and Use of Proprietary Protective Signaling Systems",
Class I circuits as defined in NFPA 70, "National Electric Code",
and selected and installed in accordance with NFPA 72E, "Automatic Fire Detectors".
SSER 84 Paragraph 9.5.1.6(1) states that we, conclude that the facility meets the guidelines of NFPA 72E and the UL listing as
'elated to'etector location and 'the maximum.spacing being 750 square feet per detector, on the basis of a letter from the
- utility dated July 1, 1983.
Paragraph 4-3.7.3 of NFPA 72E states that if a beam exceeds 18 inches in depth, each side of the beam should be treated as a separate area requiring at least one detector.
a) Discuss how the remote shutdown room meets these requirements.
b) Provide drawings of the plant which specify the floor area for each, fire area, the location of each smoke
- detector, the depths and locations of all beams which extend below the ceiling, and the functions of the equipment and cables in the fire area (i.e., safe shutdown related for a fire in the control room or cable spreading room).
10.
PENETRATION SEAL INSTALLATION Are all penetration seals installed in accordance with tested configurations?
If not, justify their use in meeting fire protection requirements.