ML17279A242
| ML17279A242 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/17/1987 |
| From: | Andrea Johnson, Pate R, Ramsey C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17279A240 | List: |
| References | |
| 50-397-87-02, 50-397-87-2, GL-86-10, TAC-63528, NUDOCS 8705040108 | |
| Download: ML17279A242 (14) | |
See also: IR 05000397/1987002
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No. 50-397/87-02
Oockei No. 50-397
License No. NPF-21
.Licensee:
.Mashizgton Public Power Supply. System
.... P.- Q.. Box.968
Rich)and, washington
.99352
Facility Noae:
Washington Nuclear Project
No.
2 {MNP-2)
Inspection at:
WNP-2 Site,
Benton County, Mashington
Inspection .Conducted:
January 12-15,
1987
Inspectors:
C.
actor
nspecior
A. Johns
, Enforceme t Off>cer
a
Date
igned
7
a e
S gned
Approved by:
~Summar:
R.
ate,
C i
, Reactor Safety Branch
S. Richards,
Chs ef,
ngl neer'g
Sects on
S. Richards,
C
s
, Eng>neerlng
Sect>on
Date
sgne
//6 S7
Date Signed
0 ia 9'7
Date
S gned
.,. Ins ection on Januar
.12-15
1987
Re ort No. 50-397/87-02
m +r
.
'Arias" Ins icted: ',"Announced special
inspection'coiiduKed to fol lowup.on items
,':
'-
>dent>
sgd yn"; p'spectiOn,Report
No. '50-'397/86-25...
""'Results:
."Of'th0"*areas.examined,
.one violation was 'ident%fied-.
This violation
wi7~e addressid 'ip'a futur e .correspondence.
"
~o~yg
PSR
Q
8 P~oo~
'ea
4
5
)J
SJ4J'56 ~
46
bA 8
.24& k
I
AIUAUA A, Z IA.~,
4S~
5 Ild~ 4
~ IAA
DETAILS
Persons
Contacted
Washin ton Power
Su
1
S stem
"J.
W. Shannon,
Deputy Managing Director
"C.
M. Powers, Plant Manager
"J.
W. Bak'er, Assistant Plant Manager
"G.
C. Sorensen,
Manager,
Regulatory
Programs
"L. T. Harrold, Manager,
Generation
Engineering
-"D. $ . Felcfiaan, Manager, guality Assurance/Cohtrol
"R. L.'orcoran, Operations
Manager
'R.
B. Glasscock,
Djrector, Licensing and Assurance
"G.
D. Bouchey,
Manager,
Support Services
"J. Bell, Manager, Industrial Safety and Fire Protection
"C.
D. Eggen, Fire Protection
Engineer
"P.
L. Powell, Manager,
WNP-2 Licensing
"C.
R. Noyes,
Mechanical
Engineer
"H.
L. Aeschliman,
Sr.
Licensing Engineer
"S.
L. Washington,
Compliance Engineer
"J.
Y. Hanson,
Fire Marshal,
WNP-2
"G.
W. Bradstad,
Electrical Technical Specialist
J.
P.
Burn, Director, Engineering
"M.
R. Wuestefeld,
WNP-2 Plant Technical
Supervisor
F.
D; Frisch, Principal Engineer,
Operations
BLCPEcR
"M. Phillips, Attorney - WNP-2
Bonneville Power Authorit
"D. L. Williams, Nuclear Engineer
NRC
"R. T. Dodds, Sr. Resident Inspector
"Denotes those, attending the exit meeting of,January
15, 1987.
License 'Actions on Previous
Ins ection Findin s
,'C
A.
I 5
I
9 I
(511-391/86-25-52) - ~All
I
911
V-
" -027-03
An allegation
was received
by 'the'NRC indicating that the weight of
electrical
cables
on the bottom cables in the cable
chase will.wear
the, cable insulation.
Excessive
wearing of the cable insulation
resulting in grounding of cables
and subsequent
affect on operation
of associated
equipment
was the implied significance to plant
operation.
The inspector discussed
the concern with a
representative
of the licensee's
engineering organization.
The
licensee's
representative
stated that the licensee's
positi'on was
that the concern
was not credible.
The inspector observed
numerous
cable installations in various areas of the facility.
The inspector
observed that in all cases,
cables
were well secured to their
associated
cable trays
by tie wraps.
Cable trays that were
inspected
were free of sharp
edges or spurs,
which could possibly
cut into cable*insulation.
,No cable motion was observed
by the
inspectors
Cables entering or exiting cable trays were protected
from sharp
edges.
Based
on these
observations,
the inspector
concurred with the licensee that cable insulation wear due to the
weight. of other cables is not credible.
he allegation
was not
substantiated.
0
1
0 1
550-301/00-05-030
-
'~031 0'id
- -027-04
An allegation
was received by the
NRC indicating that fire
protection water mains to the WNP-2 Reactor Building were installed
underneath
the safe
shutdown
Emergency Diesel Generator Building, in
violation of NFPA codes.
The implied significance to plant
operation is that a rupture of these
mains could compromise the
integrity of the Emergency Diesel Generator
Building and render
associated
water supplied fire suppression
systems
In response
to this concern,
by letter dated January
15, 1987, the
licensee
provided the
NRC with a seismic analysis
and
an opinion
from an
NFPA staff engineer for these conditions.
The licensee
also
verbally explained their position to the inspectors that the
condition is not a safety concern.
The analysis
and the code
opinion are currently under review by the
NRC.
Where modifications
are proposed,
the licensee
indicated that such modifications would
be completed
'
startup
from the next refueling outage
(Spr'ing
1987).'g
NRR review and acceptance'of
the licensee's
submittals
sn
a su sequent
safety evaluation report.
~) Unresn1ved
Item (50-397/86-25-04) - Oesi
n Chan
e Pacha
es
A
ear to Have
Re uired Protection of Additional Safe
Shutdown
Circuits That Were Not Re orted in LER No.84-031
The licensee initiated over 100 design
change
packages
to correct
identified fire protection deficiencies. located .in thirteen
different five areas
during the .19&4-1985 time frame.
From the
identified deficiencies
reported in LER No.84-031 and its six
revisions, it appears that the:affected
safe
shutdown circuits of
-= concsexn"were'ocated
in the main control room, cable spread
room,
rea'ctor building general
equipment area,,and
RHR pump room/pipe
chase/heat
exchanger
and equipment room,(four fire areas).
According to the licensee,
the additional
design
change
packages
= were initiated to perform work in other fire areas
as part of the
resolution to the deficiencies identified in LER No.84-031.
The
licensee
stated this was necessary
due to the plant circuit
'dentification
scheme (i.e.,
a circuit identification number in the
control
room could change to a different number in other plant fire
areas
even though it is the
same circuit in all of the fire areas).
Due to the number of circuits and design
change
packages
involved,
the inspector
was unable to verify that circuit deficiencies
identified in LER No.84-031 were in fact the
same circuits
identified by different numbers in the design
change
packages
and
that the work required in other plant fire areas
provided resolution
to the defici'encies identified in LER 84-031.
'I
dd
A
'4
M
To resolve this concern, the licensee plans:to formulate
a eatrix-
index,.which cross
references circuit identification numbers in the
design, change
packages
and fire areas of concern,'llustrating
the
corr'esponding resolution .to the deficiencies identified in LER No.
84-03Xand its six revisions.
The licensee
indicated that this
.-
matrix index would 'be ava'ilable by January
23, 1987.
This item
remains
open pending further'NRC review..
Unresolved .Item (50-397/86-25-05) - Anal sis of Safe Shutdown
~Md
1
By letter dated
March 21, 1983, the licensee
informed the
NRC that
the method described in amendment
No.
33 of the
FSAR to achieve
and
maintain safe
shutdown conditions during and following a fire would
not be utilized.
Instead,
the ADS/LPCI method based
on a
BWR 4
design
(GE-NEDO 24708A) which relied on bivision II equipment would
be utilized.
This submittal contained
an analysis of the licensee's
chosen
ADS/LPCI methodology with assumptions
made for maintaining
reactor parameters
and process
variables within acceptable
limits.
The portion of this item pertaining to protection of Division II ADS
valves is closed
based
on the discussion
provided in Paragraph
3 of
this report.
The issues
of adequate
plant specific analysis
and
required wiring changes to achieve
and maintain hot shutdown
conditions
remains
open pending further licensee
action and
NRC
review.
The following specific
NRC concerns
are to be resolved
by
the licensee:
(1)
No discussion
was in applicable licensing documentation of
plant features
provided to protect Division I circuit ADS
valves from the effects of a fire in the control
room.
However, the inspectors
did observe this protection to be
inadequate.,
During a meeting with the licensee
on
January 21-23,
1987,
and duiing a conference call on
.december
3.8.,'1986,
the li,censee
made a commitment to the. NRC to
.- upgrade t;he existing Division I ADS valve control
room circuits
- by instal'Hng transfer'."switches 'in'these'circuits
outside the
-:"'control
- room.
A
~
~
MM
(2)
The licensee identified thatdin the control room evacuation
procedu're'the
operator 'actions to be taken are to close all
-. MSIVs.
Closing the MSIVs requires
an operator to close eight
MSIVs, two at a time.
Generic letter 86-10, enclosure
2,
paragraph
3.8.4, states that the only action for which the
NRC
has given credit in past evaluations is to scram the reactor.
Therefore,
the license should revise the method of plant
shutdown from outside the control
room by allowing only the
single action of scramming the reactor inside the control
room
4.
prior to control
room evacuation.
The methodology
may permit
operators
to close
MSIVs if there is sufficient time, or to
open
MSIV breakers
from outside of the control- room if there is
insufficient time to close
MSIVs from inside the control
room.
During a telephone
discussion with the licensee
held on April
15, 1987, the licensee statedthat
they. maintain that closure
. of the MSIVs is an acceptable
single action.
Region
V will
refer this concern to NRR for resolution.
(3)
In lieu of making repairs (installing shorting screws-in
switchgear
terminal blocks), the licensee
made
a commitment to
the
NRC to install transfer switches .for all of the shorting
screws in the SM-8 cabinets prior to startup following the next
refueling outage.
This item remains
open pending further licensee action and
verification by Region V.
~) Unresolved
Item (50-397/86-25-06)
Safe
Shutdown Procedures
The licensee is required to have procedures
in effect implementing
alternative
shutdown capability by position
No.
C. 5(b) of SRP 9. 5-1,
Section F.4.2 of Appendix F,
and the licensee's
response
to
NRC
question
Nos.
040.076
and 040.078 of th~
FSAR (approved fire
protection plan).
Under the assumption that the licensie's existing post-fire safe
shutdown methodology is acceptable,
ard required systems
and
components
are specified .in the procedure
and protected
from fire
damage in accordance
with the licensee's
approved fire protection
plan, the inspectors
and the licensee's
staff performed
a walkdown
of the licensee's
Control
Room Evacuation
Procedure
No. 4.2. l. 1,~
Revision
No. 8,
~onl
for the purpose of determining if operators
could open safety relief valves
and. initiate Low Pressure
Coolant
Injection (LPCI) within 10 minutes
as specified by the licensee's
March 21,
1983 safe
shutdown analysis.
Based
on the walkdown, the inspectors
determined that the directions
provided in Section 4.12.1.1.3,
step Np..l and Section 4.12.1.3.- 4
steps
1 through 10 of Control'Room Evacuation.Procedure"No.
4.12;1.1
were successfully
simulated 5y the plant op6rations staff witbin
approximately six (6) minutes.'...l9'roper', 'identification and
'"
accessibility of existing transfer"and control switches was'verified
and the operator's
actions appearecf"4o-be"'chievable
by t;hr'ee
operators within the'maximum threshol'd,criteria.
'The 1'icensee's
.staff participating in the walkdown'emonstrated
familiarity with
the procedure
and appeared
confid6nt in 'their action that actual
operation of the transfer capability would-control the reactor
process
variables within acceptable
parameters.
Based
on the discussion
above,
the concern over control
room
operator's ability to established
ADS/LPCI actuation
from the remote
shutdown panels within the 10-minute
maximum threshold criteria
would be resolved
by the licensee corrective actions to the plant's
safe
shutdown methodology,
as discussed
in paragraph
2.D above.
Furthermore,
because
of explicit instructions provided to operators
cautioning them about the possibility of inadvertent
drainage of the
~ RPV into the suppression
pool, the concern over
RHR valve Nos. V-4,
V-6, V-24 and V-27 is resolved.
I
.The concern over the licensee's
implementation ot'ttachment.
NO. "C"
(installation of shorting screws in terminal b)ocks) remains;open
pending the licensee
s installation,qf qualified transfer switches
and -further NRC review.
In addition, .to.assure
successful
operator
actions within the maximum threshold criteria, the licensee
stated'hat
they would revise revisian
No.
8 -of control'oom evacuation
Procedure
No. 4.12.1.1,to specify that .in the event of a control
room fire, operators
are to go immediately to the remote
shutdown
panel
room and implement attachment
No. "D" of the procedure
which
specifies
the use of only protected
systems
in the event of a fire.
This item remains
open pending further licensee action and
verification by Region
V.
Unresolved
Item (50-397/86-25-07) - Associated Circuits
ommon Enclosure
Anal sis
The licensee is required
by Section F.4.4 of Appendix i and the
response
to question
Nos.
040. 076 and 040. 077 of the
FSAR (approved
fire protection plan) to analyze conditions where circuits are
routed together
in common enclosures (i.e., raceways,
panels,
junction boxes, etc.).
The inspectors
reviewed the licensee's
documentation for the
common
enclosure
concern
and verified the completeness
of the licensee's.
review and required modifications.
The results of the
inspectors'eview
was satisfactory.
Therefore, this item is closed.
Unresolved
Item (50-397/86-25-08) - Associated Circuits
s-
ow Pressure
Interface Anal sis
The licensee is required by Section F.4.4 of Appendix F and the
response
to NRC question
No. 040.079 of the
FSAR (approved fire
protection plan) to analyze conditions where there is the potential
for fire induced spur'ious operation of single or redundant
motor
.
operated isolation valves between
high pressure
and low pressure
systems.
Isolation valves which isolate the reactor coolant system
from piping systems
which are designed for low pressure
operation
should be prevented
from spuriously opening in the event of a fire.
A fire in the control
room could result 'in spurious
opening of RHR
valves V-8 and V-9 causing
an unisolable
LOCA outside =of
containment.
During the inspection,
the licensee
indicated that removing power
from these
valves during plant operation would cause
an undue
hanlship
on the facility.
.The licensee further stated that due to
the configuration of the control
room and the ability to isolate the
~,
control
room portion of the control circuit with a switch at the
remote
shutdown panel, the licensee
had concluded that the
probability of a fire opening both valves
was remote.
s
H.-
This item remains
open.
(Closed)
Unresolved Item (50-397/86-25-09) - Associated Circuits
Common Bus
Power Source
.Circuit Overload Ana
sos
\\
The licensee is .required by Section F.4.4 of Appendix
F.. and the
response
to
NRC question 040.0/9 of the
FSAR (approved fire
protection plan) to analyze conditions, were there is a common power
source with safe
shutdown equipment
and the power source is not
electrically protected
from the circuits of concern.
Part of this
analysis is the high impedance fault consideration.
The inspectors
reviewed the licensee's
documentation for the
common
bus
(power source)
concern
and verified the completeness
of the
licensee's
review and required modifications that included adequate
consideration for high impedance faults.
The inspectors verified
that no feeder breakers will trip upon a fire induced high impedance
fault in conjunction with normal operating or spurious
loads
exceeding
the capability of the bus feeder
breaker.
The results of
the inspectors
review was satisfactory.
Therefore, this item is
closed..
(Closed)
Unresolved
Item (50-397/86-25-10) - Potential
Failure to
Identif
Cable Routin s for All Electrical
Cables
Re uired for Safe
Shutdown
Based
on information received
by the
NRC, the question
was raised
as
to whether or not the licensee
had met its commitment in submittals
to the
NRC dated January
21 and October 4, 1982 to protect one
division of safe
shutdown equipment from fire damage.
In question
was whether the licensee accurately
knew the routing of cables at
the site.
~
I
,In response
to this concern,,the: licensee
indicated that defacing of
"somie cable routing slips did occur after the,.cables
were completely
.installed
and after the routing, information had been entered into
the licensee
.s computerized cable,.4chedule..
No'plant verification
'*"program was docum'ented to prov'ide gs'surance
that the location and
','" . routing of al'1 the cab?es
important 'to safe
shutdown
was
known.
However,
based
on thy inspectors'ample
documentation
review and
corresponding
walkdown of the'location of the selected
cables in the
plant, reasonable
assurance
was obtained that plant cables important
to safe
shutdown
can be located
by their computerized
cable routing
schedule.
Therefore, this item is closed.
(Open) Unresolved Item (50-397/86-25-11) - Cable
S readin
Room
~0eni
n
Sections
C.1(a)(8)
and C.7(b) of NRC guidel,ines contained in SRP
9.5-1 specifies that each cable spreading
room should contain only-
one redundant safety division.
The licensee's
single cable
spreading
room contains all cables for both redundant
safe
shutdown
divisions.
Alternative shutdown capability was not provided for the
cable spreading
room as specified
by NRC guidelines.
Instead,
the
licensee elected to achieve
compliance with Section III G.2 of
'ppendix
R in the cable spreading
room. by coating intervening
combustibles
between
redundant
safe
shutdown divisions a horizontal
distance of 20 feet with thermal lag matev ial and installing
one-hour fire barriers
around certain divisiona1 cable interfaces
within'20.feet.
The adequacy of the licensee's
one"hour fire
barriers enveloping divisional cables, is further discussed
in
Paragraph
4 of this report.
'The following issues
require
resolution.
(1)
The licensee
provided a summary of a Underwriters Laboratories
File No.
R6076, which, indicated, that the thermolag material in
the 20 foot zone is noncombustible.
The licensee
did not have
available
a technical
basis for the method of the application.
This remains
open pending
NRC review of a technical
basis for
the method of application.
(2)
For safe
shutdown cables
located within the cable spreading
room 20-foot zone, in order to meet Section III.G.2.C of
Appendix
R to 10 CFR 50 (as specified in SRP 9.5-1), the
licensee
should demonstrate
by test results that the material
applied to these
cables in its inplace configuration affords
a
one-hour fire rated protection for the entire length of the
cables
involved.
As discussed
in paragraph
4 of this repoi't,
this issue is
a plant-wide concern.
The resolution of this
issue is discussed
in paragraph
4.
This item remains
open pending further licensee
action and
verification by Region V.
(Closed)
Unresolved
Item (50-397/86-25-12) - Installed Thermal
La
Extrusion
S ra
Pum in
Fire 8arrier Envelo
es
on
Individual or Grou
Conduits Containin
Safe Shutdown Circuits
f
"Thelicensee elected to encase
one "divihion.of redundant
safe
shutdown circuits located in the
same five area within a one-hour
fire barrier envelope
as required by Section.F.4.3
of Appendix
F of
the-FSAR'(approved fire protectio'n plan).
~ jt ....t
This item is closed
based
on the discussion
provided in Paragraph
4
of"'this report.
(Open) Unresolved'Item
(50-397/86-25-13) - Inade uate Fire Detection
~Setem
Section F.4.2 of Appendix
F to Amendment
No.
19 of the
(approved fire protection plan) requires
the licensee to install
fire detection
systems
in accordance
with NFPA standard
No.
72D and
that deviations
be identified and justified.
For location and
spacing of fir'e detectors,
Section 3-5"1 of NFPA 72D specifies that
fire detectors
be installed
and tested in accordance
with NFPA
standard
No.
72E.
The licensee
has retained
a private contractor to perform a complete
review of the plant's 'fire detector
system installation.
The
contractors
review was not complete at the time of this inspection.
The licensee
stated that a preliminary review .indicates that no
wide-spread
problem exists.,
During the inspection,
the licensee
indicated that the results of the contractors'eview
would be
evaluated,
corrective actions that would be taken determined
and .a
schedule for completion would be available by March 1, 1987.
This
item remains
open pending further licensee action and
NRC review.
(Open) Unresolved
Item (50-397/86-25-14) - Inade uate
Emer enc
~Li htin
Section F.4.2(j) of Appendix
F to Amendment
No.
19 of the
(approved fire protection plan) requires
the licensee to provide
fixed 8-hour battery pack emergency lighting units in all areas of
the plant needed for operation of'afe shutdown equipment
and in
access
and egress
routes thereto.
Deficiencies identified in this
area include the following:
(1)
The two battery powered lights in the .remote
shutdown
room
would provide general
lighting but would not illuminate
directly the remote
shutdown p.intel.
Hence,
the identification
of controls
and instruments
on the panels
may not be easily
read.
P
(2)
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 altey nate
remote
shutdown panel.
(3)
The SM-8 room (the
room contains
the SM-8 switchgear panels)
contains
one battery powered light.
This light would provide
minimal lighting in the area
andPno light onto the SM-8 panels
or within the SM-8 cabinets.
As part of the licensee's
overall fire protection program
re-evaluation,
the licensee
indicated that appropr iate corrective
actions would be taken to address
each 'of 'the items discussed
above.
' ~
This item remains
open pending further licensee action and
verification by Region
V.'Closed)
Unresolved Item (50-397/86-25-16) - Safet -Related
Racewa
s
Filled in Excess of Prescribed
Am acit
Limits and Adherence to
Am acit
Deratin
S ecifications for Racewa
s Encased
in Thermal
La
Fire Barrier Material
Electrical Specification
No. 2808-218; Plant Maintenance
Procedure
No. 16.25.57;
TSI Technical
Report
No. 111782;
Burns
and
Roe
9
Memorandum
No. 1272 and Industrial Testing Laboratory Report
No.
82-5-355C establish limiting criteria for electrical
raceway
ampacity fill in accordance
with
the licensee's
Section 8.3.1.4
FSAR commitment to the
NRC.
A previous review by the inspector of a
printout listing raceway fill indicated that numerous
cable trays
were overfilled.
Followup by the licensee
determined that tray
dimensions
used .to determine tray..fill were less than actual tray
dimensions .and that errors existed in the computer program for.
determining fill under certain circumstances.
The inspector
reviewed recent printouts of'able .tray fill.
No overfill
conditions were identified on the printouts.
The inspector selected
two safety"related
cable tray sections
=used for power cable routing,
which had,previously
been identified as'.overfilled.
Both trays were
now listed as close to their 40 percent limit.
The inspector..',',
visual'ly sighted the trays
and verified that their physical
dimensions
were approximately those dimensions
used in the computer
'
program.
The inspector also estimated that the number of cables in.
the trays
was the
same
as the number listed in licensee
records.
Neither tray appeared overfilled.
The inspector concluded that the
licensee
had correctly determined that actual
raceway overfill
conditions did not physically exist.
Results of the licensee's
Thermal
Lag Cable Derating Analysis will
be tracked
under revised
LER No. 86-33-01 followup.
0.
(Closed) Unresolved
Item (50-397/86-25-17) - Hot S ots Present
in
Cabl e~r'ra
a
The control
room shift managers
log entry on July 28,
1986
identified the presence
of "hot spots" in an enclosed
cable tray
where three cables
are grouped together.
The licensee
stated that
this log entry referred to the routing of a non-safety
power feeder
cable to a motor control center associated
with the cooling towers.
The three phases
of the feeder were intentionally physically
separated
during construction
due to fault current concerns.
This
apparently resulted in inductive heating of the cable tray in which
the cable
was routed.
The licensee
has initiated maintenance
work
request
AV 6610 to reconfigure the cables.
The, licensee further
stated that the configuration=was
an. isolated
case which was not
applied to any safety-related. cables.;--This, item is closed.
Potential Failure"to Ade uatel
Protect Alternative 'Control Room'Division
and Pressure 'Indicatson Circu ts'from Fire Dama
e
'- fhe .NRC's,position,as
stated, in the Approved Fire Protection
Plan for
MNP"2 (Position 'A.7 o'f the 'FSAR) requires that th'e fire protection
'rogram 'forth'e entire"reactor unit be 'fully'operational prior to initial
fuel loading.
Sy le'tter dated
May '8, "1981, -the
NRC informed the licensee
-'"that Appendix
R to 10 CFR 50 would be used
as guidance.,for review of the
Approved Fire Protection
Plan
as specified in Sections
C.5,
C.6 and C.7
of Revisions
3 of NRC Standard
Review Plan
(SRP) 9.5-1, dated July 1981.
10
The licensee's
response
to position No. A.7 of the
FSAR reads,
"7he fire
protection program for the entire power plant will be fully operational
prior to initial fuel loading."
Position
No. C.1(d) of
SRP. 9.5-1 specifies that alternative or dedicated
shutdown capability be provided where the protection of systems
whose
functions are require f'r safe shutdown-is not provided by established
fire suppression
methods or by position No. C.6 of SRP 9.5"1.
Section
C.5(c)(1) of SRP 9.5-1 'specifies that alternative or dedicated
shutdown
capability for a specific fire area
be able to achieve
and maintain
subcritical reactivity conditions in the reactor
so that the fission
product boundary will not be affected.
For example,
there shall
be no
fuel .clad damage,
rupture of any primary coolant boundary or rupture of
the containment boundary.
Regarding control
room alternative safe
shutdown capability, in reply to
NRC guestion
No. 040.076 of the
FSAR (approved Fire Protection Plan), the
licensee's
response
reads in part, "For the case of the main control
room
fire, ...main control
room remote
shutdown
s stem circuits ori inate
in the remote
shutdown
room and
do not route snto or throu
h the main
control
room
once transfer contractors
are act)vated
.
By letter dated
March 21, 1983
(G.
D. Bouchey - MNP-2 to A. Schwencer -.
NPf;.) the licensee
forwarded
an analysis to the
NRC (based
on analyses
documented
in GE-NEDO 24708 A) which changed Division I RCIC/RHR Control
Room Alternative Safe
Shut~own methodology described in the
FSAR to the
Division II ADS/LPCI (RHR t.oop B) method.
This analysis specified that
three (3) Division II ADS valves were dedicated to achieve
Depressurization
and
Low Pressure
Coolant Injection within a maximum
threshold of 10 minutes prior to any fuel clad damage.
Prior to 0. L. issuance
and initial startup,
Region
V Inspection
Report
Nos. 50-397/83-50,
50-397/83-55
and concern
No.
18 on
NRR trip
report'ated
April 13,
1983 documents
Region
V and
NRR concerns
regarding the
licensee
need to clarify the inconsistency in the Control
Room
Alternative Safe
Shutdown capability as stated in the
FSAR and as chosen
to be implemented
by the licensee's
March 21,
1983 submittal to the
NRC.
Concern
No. 18 of the
NRR trip report dated April 13, 1983 directed the
licensee to verify that all cables
and components
associated
with the
dedicated
(Control
Room Alternative Shutdown). system
be protected
from
fire damage.
The licensee's
July 1, 1983 response
to this concern read
in part, "the dedicated
cables will be protected, by a thermal
lag barrier
or by other means.
. Section 3.2 of the licensee's
March 21,
X983 analysis of the ADS/LPCI
Control
Room Alternative Safe
Shutdown methods
reads in part,
"By
providing thermal'barrier protection for ADS and
RHR Loop
B Systems,
MNP"2 assures
that core cooling is maintained
and the scenario of a'fire
plus loss of offsite power is bounded by the analysis provided in the
NEDO 24708 A."
During the inspection,
the inspector observed the following conditions
on
January
13, 1987:
A.
r
B.
C.
During the 1986 outage the controls for ADS valves that were located
on the remote
shutdown panel
were moved to the Alternate
Remote
Shutdown Panel.
The power supply to these valves
was Division I OC
power when they were installed
on the remote
shutdown panel.
These
valves continued to be supplied by Division I DC power once they
were transferred to the Alternate Remote. Shutdown
Panel
which is a
Division I panel.
'The inspector reviewed the Electrical Wiring Diagrams
EWO-IE-046,
Revision 0,
and EWD-IE-046 A, Revision 0, and confirmed that in the
event of a control
room fire, remote
manual
switches
on the
alternate
remote
shutdown panel will, when operated,
transfer the
control of valves MS-RV-2A,. -gC and -38 from the control
room to .the
Alternate
Panel
and isolate the control
room
circuits.
After the transfer
has
been
made,
these valves are used .
. for depressurizing
the reactor during the remote
shutdown will then
be powered from 125V
OC panel
E-OP-SI/IF which is a Division I power
supply.
The remote
shutdown panel
was modified during the 1986 outage to
include
(SRVs) to be used for emergency
depressurization
along with the
3 ADS valves
on the Alternate
Remote
Shutdown
Panel (Division II).
The license
's Non-Conformance
-Report
(NCR) No. 286-0332
documents
that three Division II SRV circuit Nos.
2AOS-33,2ADS-55 and
Division II reactor pressure
and le'.el instrumentation Circuit Nos.
2NS4-52 and 2NS4-53 were installed/modified during the
installation of the alternate
remote
shutdown
system.
Splices
were
made
on these
cables in panel
No.
H13-P683 in the main control
room
and were to be protected
from fire damage
by the
use- of a three-hour
fire rated wrap material.
However, the material
used (SIL Temp
Tape) to wrap these
cables
was not installed in a tested
I
configuration and it has only been tested to provide
a 15-minute
fire rating.
According to the licensee,
an assumption
was
made that
several
layers of SIL Temp Tape provided the equivalence of a
three-hour fire rating.
A control
room fire could have caused
the
failure of this circuits and rendered
the main control
room and
remote
shutdown panel (Division II) inoperable.
'l
r
D.
In.a telephone-conversation
between
Region V,and the licensee
on
January
28, 1987, the licensed" jnformed Region
V that the loss of
these"circuits
due to a control'room fire,would.not have disabled
control
r'oom alternative shutdown'capability
because
the 3 ADS
'alves
and redundant reactor
pressure
and level. instrume~tation
'is
.
isolated .from the control
room and would be available
on the
Alternate
Remote Shutdown'Panel.
NRR is reviewing the need for 6 SRVs vice 3 SRVs as part of their,
review of FSAR Amendment 37.
No violations or- deviations
were identified.
K
12
~
Failure to Install
uglified Fire Barriers to Protect
One Division of
Safe Shutdown Trains Located in the
Same Fire Area
Section F.4.2 of Appendix F of the
FSAR (approved Fire Protection Plan),
indicates that the licensee will provide fire protection of safe
shutdown
capability as described in the licensee's
Technical
Memorandum
No. 1227,
Revision 2.
Regarding electrical
raceway system protection,
Section
6. 2. 1 of Technical
Memorandum
No. 1227, Revision 2, reads:
"Protection
of raceway
systems will be accomplished primarily with blanket wrap
material
and sprinklers."
Section 6.5 reads:
"Hangers supporting
dedicated
shutdown equipment,
such astrays
and pipe will:be wrapped to
the same requirement
as the barrier..-"
1
h
In reply to
NRC guestion
No.
040,-075 of the FSAR,'oncerning fire
protection of safe
shutdown capability, the licensee's
shutdown cabling
and equipment for which protection is required will be either (1)
relocated to another
(acceptable) fire area,
(2) separated
or protected
in accordance
with Appendix R,Section III G. or (3) sub-fused
(where
practicable)."
Section F.4.3 of the
FSAR discusses
the licensee's
approach to encasement
of redundant
cable trays located in the
same fire area within a one-hour
or three-hour fire barrier envelope.
By letters dated
September
20,
1982, October
4 and 5, 1982, the licensee
informed the
NRC that "All
materials
supplied
by TSI Inc. ror the Thermo-Lag 330-1 subliming coating
envelope
system
used in the test program will be used for construction of
such envelopes
on Supply System Projects.
The product application
and
repair procedures
used in the test program...will
be adhered to in the
actual installation of the envelopes.
By contrast,
during this inspection
and the Region
V inspection
conducted
during the period of July 14-October
24, 1986, the inspectors identified
numerous
redundant
safe
shutdown cables
located within the
same fire area
that were not provided with a qualified thermo lag fire barrier envelope
system.
For example:
Division II Circuit Nos.
SM-F1-9B, 2DG2-23,
2DG2"24, 2DG2-41,
2DG2"106,
2DG2"108,
2M8BA-505 and 2M8BA-506 in the cable spreading
room; Circuit Nos.
2MBBA-318-2, 2RHR"35-2, 2CACS-269-4,
2IR 63"41"3, 2CACS"269-4,
2MBAA-164-3, 2CAS-269-3 and 2M8BB-114"1 in,-the Reactor Building,.and cable
chase interface with-redundant Division I circuits located in the
same
.fire areas
and require one-hour .or.,thr'e'e-hour rated. fire barrier envelope
.-protection.
I
V~
, Although'these circuits were protected. with the thermal lag material; the
protection prov'ided did not qualify's-a one or three-hour fire barr'ier
'because the licensee
applied the materi'al to the circuits improperly
(annulus pumping/extrusion
spray application)
and in untested
configurations.
Preliminary results of tests
conducted
by the licensee
on these installations indicate that the one-hour appl.ication- may p'rovide
a 32-50 minute fire rating.
The three-hour application
may provide a
150- to 160-minute fire rating.
This is considered
an apparent Violation of Condition No. 2.C.14 of
Facility Operating
License
No.
NPF-21 (50-397/86-02-01).
13'al
Open items are matters
which have
been discussed
with the licensee,
which
will be reviewed further by the inspector,
and which involve some action
on the part of the
NRC, the licensee,
or both.
Open items disclosed
during the inspection are discussed
in Paragraphs
2b, 2c, 2d, 2e,
2g, 2h,
2k,
2m and 2n.
Unresolved
Items
Unresolved. items are matters
about which more information is required in
.order tomscertain
whether they are acceptable
items,
items of
noncompliance,
or deviations.
Unresolved
items disclosed during the
inspection are discussed
in Paragraph
3.
~E*i
M
An exit meeting was held with the licensee's
staff on January
15, 1987.
The items of concern in this report were discussed
at that time and in
previous meetings with the licensee.
The licensee
acknowledged
the
content. and scope of the inspection findings.
Subsequent
to the exit
meeting,
members of the licensee's
staff met with the
NRC staff at
NRC
headquarters
on January 21-23,
1987,
and further discussed
the issues
identified in the inspection report as well a~ the licensee's
overall
implementation of the approved fire protection program
as required
by
condition No. 2.C. 14 of Facility Operating
License
No.