ML18052A779
| ML18052A779 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/14/1986 |
| From: | Holmes J, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052A774 | List: |
| References | |
| 50-255-86-22, NUDOCS 8611240095 | |
| Download: ML18052A779 (16) | |
See also: IR 05000255/1986022
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I I
Report No. 50-255/86022(DRS)
Docket No. 50-255
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI 49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Covert, MI
Inspection
Inspector:
Conducted:
July 28 through September 30,
C\\,,nJ ~~
'J.IDHolmes
Approved By:
.J~w~~
James W. Muffett, Chief
Plant Systems Section
1986
License No. DPR-20
D_J_L/J 3 / 1 9 80
ate
"/ i4 Is(,,
Date
Jnspecti on Summary
Inspection on Jul1~8 tb~9~9b_~~2~~~ber 30, 1986 JB~port__l!~~-§Q-2~~f§§Q~~JQB~l
Areas Inspected: Special, announced inspection by Region III based inspectors
and their consultants to determine the adequacy of the facility's post fire
safe shutdown methods, and a review of the licensee's routine fire protection
program.
This inspection was conducted in accordance with Temporary
Instruction 2515/62, Revision 2.
Results:
Of the ten areas inspected, two violations were identified. Failure
to maintain fire barrier due to unsealed conduit penetrations, Section 6.
Failure to provide Emergency Lighting as required by Appendix R,Section III.J.
in several areas, Section 11 .
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S6l1240095 ~~bfifi~55
ADOCK
G
DETAILS
1.
Persons Contacted
Consumers Power Company (CPCo)
- J. R. Bradshaw, Property Protection Operation Supervisor
- S. C. Cote, Property Protection Supervisor
E. A. Dorbeck, Staff Engineer
- J. S. Erickson, General Engineer/PSE
- H. M. Esch, Administrative Manager
D. J. Fitzgibbon, Licensing Engineer
W. L. Ford, General Engineer Electrical
R. J. Hill, Senior Quality Assurance Engineer
- T. E. Leva, Plant Project Engineer
R. E. McCaleb, Plant Quality Assurance Director
J. G. Lewis, Plant Technical Director
M. T. Nordin, Shift fngineer
R. D. Orosz, Engineer/Maintenance Manager
K. E. Osborne, Technical Engineer
T. J. Palmisado, Projects Superintendent
R. M. Rice, Operations Manager
- R. Smedley, Licensing Engineer
- K. A. Toner, Supervisory Engineer
R. A. Vincent, Plant Safety Engineering Administrator
Nuclear Regulatory Commission (NRC)
J. Muffett, Chief, Plant System Section, Region III
R. M. Perfetti, Project Engineer (NRR)
E. R. Swanson, Senior Resident Inspector
T. Y. Wambach, Project Manager (NRR)
- Denotes those persons present at the exit interview of
September 29, 1986.
2.
Post Fire Safe Shutdown Capability
a.
Safe Shutdown Capability
Following a fire the licensee is required to have capability
to control the following functions and conditions:
(1) Reactivity
(2) Reactor Coolant Makeup
(3)
(4) Process Monitoring
(5) Support Systems and Redundant Equipment
(6) Cold Shutdown
2
b.
The inspectors reviewed these systems and their modes of operation.
Regarding the support systems and redundant equipment the licensee
indicated that the following systems are not required for safe
shutdown.
Heat Tracing from BAT
1s to charging pumps
Seal cooling for primary coolant pumps
HVAC for areas involving safe shutdown equipment
The licensee was asked to provide technical justification for their
position in this matter.
The licensee 1s letter dated 10/14/86 from K. Berry, CPCo, to
J. Keppler, NRC, provided an analysis regarding the lack of heat
tracing on the concentrated boric acid piping.
The licensee also
indicated that the written analysis for operation of HVAC equipment
for cooling rooms containing essential safe shutdown equipment will
be completed by July 1, 1987.
The licensee states
11 If, during the
analysis, existing conditions are found to adversely affect safe
shutdown, immediate appropriate interim corrective action will be
implemented.
The licensee submitted results of a test to NRR with
respect for seal cooling for primary coolant pumps.
NRC is currently reviewing the analysis regarding the effect of heat
tracing on the concentrated boric acid piping and the test for seal
cooling for primary coolant pumps.
This Open Item (255/86022-01)
will remain open pending licensee 1s analysis for operation of HVAC
equipment to cool rooms containing safe shutdown equipment and the
NRC review of the submitted analysis.
Alternate Safe Shutdown
The licensee is required to have alternate shutdown capability.
The
inspectors reviewed these systems and their modes operation.
Control of the following functions and conditions are required:
(1)
Reactivity
(2)
Reactor Coolant Makeup
(3)
(4)
Process Monitoring
(5) Support Systems and Redundant Equipment
(6)
Cold Shutdown
In addition there are four areas in which fire will necessitate the
use of the alternate shutdown panel.
These are as follows:
(1) Control Room
(2) Cable Spreading Room
(3) Corridor on Elevation 590 1 fo the Auxiliary building
(4) Engineered Safeguards Panel area
3
Based on this review of systems and their operation, the Alternate
Safe Shutdown capability is acceptable.
c.
Area Compliance with Appendix Region III.G.2
During the inspection the licensee
1s associated circuit analysis was
determined to be incomplete.
The lack of a complete analysis and
comprehensive listing of required safe shutdown components precluded
meaningful determination of fire area compliance with Appendix R,
Section III.G.2.
The following areas/sub-areas were inspected for separation of
components and cabling for compliance with Section III.G.2.
(1)
Intake Structure (Fire Area 6)
The Intake Structure (Fire Area 6) was selected because it
contained redundant safe shutdown components and cabling,
including:
Function
Service Water Pumps
Diesel Engine-Driven Fire Pump
Diesel Oil Transfer Pumps
Component
P-7A
P-78
P-7C
P-41
P-18A
P-188
Documentation review and physical in-plant inspection revealed
that:
(a) Service Water Pumps P-7A, P-78, and P-7C are not in
compliance with Section III.G.2 separation requirements
(refer to Section 8).
(b)
Diesel Engine-Driven Fire Pump, P-41, (redundant service
water supply cabling may not be in compliance with
Section III.G.2 separation requirements.
The licensee has
not performed an associated circuit analysis on the cables
associated with P-41 (refer to Section 8).
(c) Diesel Fuel Oil Transfer Pumps P-18A and P-188 may not be
in compliance with Section III.G.2 separation
requirements.
The licensee does not have a documented
analysis that demonstrates that P-18A and P-188 are not
required for post fire safe shutdown (refer to
Section 4.C) .
4
(2) Auxiliary Feedwater Pump Room (Fire Area 7)
The Auxiliary Feedwater Pump Room contained redundant safe
shutdown components including Auxiliary Feedwater Pumps P-8A
and P-8B. Documentation review and physical in-plant inspection
verified that Fire Area 7 is in compliance with Section III.G.2
separation requirements since a redundant Auxiliary Feedwater
Pump, P-8C, is provided in Fire Area lOB.
(3) Battery Rooms (Fire Area 8)
The Battery Rooms contained redundant safe shutdown components
and cabling for Batteries A and B.
Documentation review and
physical in-plant inspection verified that Fire Area 8 is in
compliance with Section III.G.2 separation requirements.
(4) Charging Pump Room (Fire Area 9)
The Charging Pump Room (Fire Area 9) contained redundant safe
shutdown components and cabling for Charging Pumps P-55A,
P-558, and P-55C.
Documentation review and physical in-plant
inspection verified that:
Fire Area 9 is not in compliance with Section III.G.2
separation requirements .
The licensee has proposed to provided an alternate safe
shutdown capability for Fire Area 9 through use of the
High Pressure Safety Injection Pump, P-66B, in Fire
Area 10.
The analysis supporting the use of the HPSI pumps for primary
coolant addition is currently under review by NRR.
(5) Switchgear Room 1-D (Fire Area 3)
For the Switchgear Room, the licensee's Fire Hazards Analysis,
Revision 5 stated
11 No cables or equipment of the other train is
allowed in this room.
11
Documentation review revealed that
cabling for the following redundant safe shutdown equipment was
routed together in Fire Area 3.
Function
Auxiliary Feedwater Pumps P-8A and B
low Suction Pressure Transmitters
Auxiliary Feedwater Pump P-8C
Low Suction Pressure Transmitters
5
Component
PT-0741A, B, DD
PT-0726A, B, C
Switchgear Room 1-D (Fire Area 3) is not in compliance with the
Section III.G.2 separation requirements, and the licensee has
not provided an alternate safe shutdown capability for
Fire Area 3.
The licensee has been asked to provide a
technical justification for this configuration.
The licensee's
letter dated October 14, 1986 from K. Berry, CPC, to J. Keppler
indicated that a change to the Palisades Emergency Operating
Procedures which recognizes that safe shutdown after a fire in
the 1-D switchgear room may require the use of the alternative
shutdown panel has been drafted and will be implemented before
start up from the present outage.
This concern has been
adequately addressed.
3.
Review of Procedures Required by Appendix R
During this inspection the following two procedures were reviewed:
1) Emergency Operating Procedure (EOP) 10.1, Revision 3, July 7, 1986,
11 Fire Which Threatens Safety-Related Equipment
11
and 2) Emergency
Operating Procedure (EOP) 10.2,
11Alternative Safe Shutdown Procedure.
11
The review of EOP 10.1 and an inspection of the switchgear room revealed
three discrepancies.
These are:
(1) P-78 should not be listed in the procedure (it is unaffected by fire
in Room 223)
(2)
P-8C is inoperable if valve CV-0727 fails
(3)
The procedure does not address all cases in the loss of offsite
power scenario
The licensee has committed to addressing these discrepancies in EOP 10.1.
The review of EOP 10.2 and associated walkdown revealed two shortcomings
in the use of this procedure.
These are:
(1) Availability of lighting was poor in some areas
(2)
Inadequate radio communications
The licensee has committed to review these shortcomings and to make the
necessary improvements.
4.
Protection for Associated Circuits
Several issues concerning various associated circuits were identified.
These are the common bus concern, spurious signal concern and the common
enclosure concern.
Each of these are addressed as follows:
6
a.
Common Bus Concern
The common bus associated circuit concern is found in circuits,
either non-safety related or 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 common bus concern is made up of two items:
Breaker Coordination
High Impedance Fault Analysis
(1) Breaker Coordination
(2)
Breaker Coordination is audited by reviewing the time current
curves developed during the licensee
1s bus coordination study.
At the Palisades Nuclear Plant the following circuits were
randomly selected for review:
Circuit
SWGR lC
SWGR 10
BUS Bll
BUS Bl2
MCC 1
MCC 8
Panel Olla
Panel 021
Comment
Coordination Satisfactory
Coordination Satisfactory
Curves not available for review
Curves not available for review
Coordination Satisfactory
Curves not available for review
Curves not available for review
Curves not available for review
Licensee representatives stated that a bus coordination study
had not been performed as part of the Palisades Nuclear Plant
associated circuit analysis and provided explanation as
fo 11 ows:
Breaker coordination studies had been performed during
design of plant modifications; however, the studies
pertained only to the specific modifications under
design.
Breaker coordination studies were assumed to have been
completed during plant construction.
Time current curves were assumed to be retained in Bechtel
construction records.
High Impedance Fault Analysis
The high impedance fault concern is found in the case where
multiple high impedance faults exist as loads on a safe
shutdown power supply and cause the loss of the safe shutdown
power supply prior to clearing the high impedance faults.
7
I
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The licensee has not analyzed for multiple high impedance
faults.
The licensee was requested to provide a complete breaker
coordination study and a high impedance fault analysis.
The
licensee indicated that complete circuit/breaker coordination
analysis is scheduled to be completed by December 1, 1987.
The licensee also indicated in the letter dated September 14,
1986 from K. Berry, CPCo, to J. Keppler, NRC that during the
course of performing that analysis, if existing conditions are
found to adversely effect the Palisades Plant's post-fire
ability to attain safe shutdown, immediate interim corrective
actions will be implemented.
This is considered an Unresolved Item (255/86022-02) pending
completion of the circuit/breaker coordination and high
impedance fault analysis and any additional modifications
resulting from the analysis.
b.
Spurious Signals
The spurious signal concern is made up of two items:
The potential exists during a fire that false motor,
control, and instrument readings can be generated .
These could be cause by fire initiated grounds, short
or open circuits.
Spurious operation of safety related or nonsafety-related
components that would adversely affect shutdown capability
(e.g., RHR/RCS isolation valves).
(1)
The licensee identified only one high/low pressure
interface, shutdown cooling suction valve motor operators
(M0-3015 and M0-3016).
The licensee controls this
high/low pressure interface by administrative procedure.
The inspection team discussed the following high/low
pressure interfaces with licensee representatives:
Interface
Reactor & Pressurizer vents
Power Operated Relief Valves
Letdown
8
Licensee Response
Not analyzed for Appendix R
concern but administratively
controlled
Not analyzed for Appendix R
concern but administratively
controlled
Not analyzed for Appendix R
concern
The licensee is requested to complete high/low pressure
interface analysis.
(2) Current Transformer Secondaries
Based on the review performed by the inspectors, the
licensee has not adequately addressed the issue of burned
out current transformer secondaries inducing fires due to
current transformer open circuits.
The licensee
1s
analysis is generic in nature and not substantiated by
technical data for Palisades Nuclear Plant components.
(3) Isolation of Fire Instigated Spurious Signals
The licensee had identified components that have required
isolation due to fire instigated spurious signals.
Methods of isolation have included:
Administrative controls
Rerouting of cables
Wrapping of cables
Installing isolation switches
Based on this review, these methods were found
acceptable.
No areas of noncompliance were identified.*
(4) Spurious Signals Analysis
The Volume Control Tank outlet valve, M0-2087, was selected
because spurious operation of this valve could cause loss
of charging flowpath.
The licensee had not conducted a spurious signal analysis
on M0-2087 at the time of this inspection.
The licensee is requested to provide a complete high/low
pressure interface analysis, complete current transformer
secondary analysis and a spurious signal analysis on
M0-2087 Volume Control Tank outlet valve. This is
considered an Unresolved Item (255/86022-03) pending
review and acceptance of licensee analyses.
c.
Common Enclosure
The common enclosure associated circuit concern is found when
redundant circuits are routed together in a raceway or
enclosure and they are not electrically protected, or fire can
destroy both circuits due to inadequate fire protection.
9
d.
Licensee representatives states that:
All circuits are electrically protected by breakers or
fuses.
Cables for redundant safe shutdown divisions are not
routed in common enclosure.
Nonsafety-related cables routed in common enclosure with
safety-related cables are never routed between divisions.
The documentation review identified that the fuel oil transfer
pumps P-18A and P-18B cabling is routed in common enclosure in
the turbine building (Fire Area 27).
The licensee did not have
a documented analysis that demonstrated that P-18A and P-18B
are not required for safe shutdown.
If it is identified that
the fuel oil transfer pumps are needed for safe shutdown then
the licensee is requested to provide the measures that will be
taken to resolve the common enclosure of the fuel oil transfer
pumps P-18A and P-18B cabling.
In the licensee 1s letter dated October 14, 1986 from
K. Berry, CPCo, to J. Keppler, NRC, it indicated that the diesel
fuel oil transfer pumps are not required to attain hot shutdown.
Depending on the plant electrical load, after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, one of
the fuel oil transfer pumps may be required to attain cold
shutdown.
Spare motors and power cables for the diesel fuel
oil transfer pumps are stored onsite.
Based on the licensee
1s
response, this concern is considered closed.
Associated Circuit Analysis
The team identified that the associated circuit analysis was
incomplete (for details refer to Section 4.a, 4.b, and 4.c of
this report).
The justification for evaluating the licensee 1s associated
circuit analysis as incomplete is as follows:
Generic Letter 81-12 states
11This would require each
licensee to reassess all those areas of the plant
11 ***
where cables or equipment including associated non-safety
circuits, that could prevent operation or cause
maloperation due to hot shorts, open circuits or shorts to
ground of redundant trains of systems necessary to achieve
and maintain hot shutdown conditions are located within
the same fire area outside of primary containment ....
11
The licensee 1s associated circuit analysis did not reassess all
areas as required.
The following are examples of deficiencies
in the licensee
1s analysis:
10
Cabling in switchgear Room A-D (Fire Area 3) was found not
in compliance with Section III.G.2 separation requirements.
The licensee's analysis did not identify or propose
resolution for the configuration (refer to Section 2.c(5)).
Cabling in the Intake Structure (Fire Area 6) was not
analyzed for associated circuit concerns (refer to
Section 2.c(l)).
Redundant cables in the Turbine Building (Fire Area 27)
are routed in common enclosure and the common enclosure
analysis is incomplete (refer to Section 4.c).
The licensee's breaker coordination study was incomplete
(refer to Section 4.a).
The licensee has not analyzed for high impedance faults
(refer to Section 4.a(2)).
The licensee's high/low pressure interface analysis was
incomplete (refer to Section 4.b(l)).
The licensee's spurious signal analysis was incomplete
(refer to Section 4.b).
The licensee's analysis of current transformer open
secondaries was incomplete (refer to Section 4.b(2)).
5.
Lack of Analysis to Justify Partial Suppression and Detection
10 CFR 50.48(b) in part requires that all nuclear power plants licensed
to operate prior to January 1, 1979, shall satisfy the applicable
requirements of Appendix R to this part, including, specifically, the
requirements of Section III. G, Fire Protection of Safe Shutdown
Capability.
Generic Letter 86-10, under the heading "Documentation Required to
Demonstrate Compliance," stipulates that where a licensee chooses not to
seek prior staff approval for a particular fire protection feature, an
adequate fire hazards analysis should be performed and retained in an
auditable form for future staff review.
GL 86-10 states,
11 NRC intends to
initiate enforcement action where, for a given fire area, compliance with
Appendix R is not readily demonstrable and the licensee does not have
available a written fire hazards analysis for the area.
11
Contrary to the
above, the staff observed during the inspection that in the turbine and
auxiliary buildings, complete area wide automatic fire detection and
suppression systems were not provided in all fire areas which the
licensee indicated met the requirements of Section III.G.2 of Appendix R
to 10 CFR 50.
Also, the licensee had not performed a fire hazards
analysis per GL 86-10 to justify the observed partial protection.
While
no significant hazard was observed which would necessitate the
installation of additional fire suppression systems, the staff observed
11
.*
certain areas, such as the 590 ft. corridor, the second level of the CCW
pump room and the intake structure, where additional fire/smoke detectors
would appear to be necessary.
In addition, the staff noted that the analysis for the metal panel in the
floor of 1-D switchgear room cableway did not take into account all of
the combustible materials in the fire area below, the absence of sprinkler
protection immediately above the metal panel, and the possible loss of
redundant shutdown systems on either side of the metal panel due to a
fire below it.
This is considered an Unresolved Item (255/86022-04) pending review of
the licensee
1s October 24, 1986 submittal from K. Berry, CPCo, to J. Keppler.
6.
Unprotected Penetrations in Fire Barriers
Provisional Operating License No. DPR-20 Paragraph 3.E states
11The
licensee may proceed with and is required to complete the modifications
identified in Paragraph 3.1.l through 3.1.23 of the NRC 1s Fire Protection
Safety Evaluation on the facility dated September 1, 1978.
These
modifications shall be completed as specified in Table 3.1 of the Safety
Evaluation.in accordance with the schedule contained therein.
11
The Safety Evaluation Report dated September 1, 1978 Section 3.1.4
entitled
11Conduit and Ductwork Penetrations and Unprotected Openings
11
states,
11 Conduit penetrations of fire walls, floors and ceilings, which
are not already sealed will be sealed both between the conduit and the
concrete and between the cable and the conduit.
11
In addition, 10 CFR 50.48(b) in part requires that all nuclear power
plants licensed to operate prior to January 1, 1979, shall satisfy the
applicable requirements of Appendix R to this part, including
specifically, the requirements of Section III.G, Fire Protection of Safe
Shutdown Capability Section III.G.2.a of Appendix R to 10 CFR 50
stipulates that a 3-hour fire barrier be installed between redundant
shutdowns divisions.
Appendix A to BTP APCSB 9.5.1 to which the licensee
is committed states that penetrations of these barriers, including
conduits are to be sealed to provide a fire resistance rating at least
equal to that of the barrier itself.
Contrary to the above, the inspectors observed that conduits were not
internally sealed where they penetrate a three hour fire barrier required
by Appendix Rand enter a junction box, panel or other similar enclosure.
The inspectors do not consider the fire protection afforded by these
components equivalent to a three hour fire barrier.
This is considered a violation (255/86022-05) of 10 CFR Part 50
Appendix R,Section III.G .
12
...
7.
Fire Stop
The inspectors observed that cables penetrating the
11 Nelson
11 fire stop in
the wall between the cable spreading room and the turbine building,
appeared to exceed the maximum fill allowance (number of cables permitted
to penetrate the seal) identified in the listing criteria of Underwriters
Laboratories.
This condition could result in loss of seal integrity
in the event of a fire.
The licensee responded that the fill allowance
was not exceeded.
However, manufacturer's literature to support the
licensee's contention could not be provided during the audit.
This is
considered an Open Item (255/86022-06) that will remain open pending
review of licensee's response.
8.
Alternative Shutdown Equipment
Section III.G.3 of Appendix R to 10 CFR 50 stipulates that where
alternate shutdown is provided, it should be independent of the room,
zone or area under consideration.
Contrary to the above, the staff
observed that in the intake structure, the diesel powered fire pump is
not sufficiently protected/separated from the service water pumps and
intervening fire hazards to provide reasonable assurance that a single
fire would not damage both normal and alternate shutdown capability.
The
licensee had previously identified this condition and request a staff
evaluation of the adequacy of the protection.
The staff has identified
specific concerns regarding the level of fire protection in this area.
This is considered an Open Item (255/86022-07) pending review of
licensee's response.
9.
Fire Dampers
On November 6, 1984, NRC received a 20 CFR Part 21 report from Ruskin
Manufacturing Company which indicated that fire dampers of a type
installed at Palisades may not close under certain conditions.
As
described in this report, the fire dampers may not close under high
airflow conditions.
Consequently, during the inspection, the staff
expressed concern that fire dampers in the plant may not function under
similar circumstances.
The licensee responded that, except for the
control room HVAC system dampers, all other dampers in Appendix R
required fire barriers are functionally tested under normal airflow
conditions to assure closure.
The staff found this acceptable.
The
control room HVAC dampers are not tested.
Instead, the licensee is
visually inspecting them and performing preventive maintenance.
The
staff expressed concern that this approach would not provide reasonable
assurance of damper closure.
The licensee indicated that they will
investigate the feasibility of testing the control room HVAC system
dampers in a manner similar to that for the others.
In the licensee's October 14, 1986 from K. Berry, CPCo, to J. Keppler, NRC,
it indicates that control room HVAC system dampers will be tested before
the end of the next refueling outage.
In addition, the licensee
13
indicated that when testing is complete the appropriate testing frequency
will be determined and test procedures implemented.
Based on the
licensee's proposed corrective actions, this concern has been adequately
addressed.
10.
Use of Combustibles Insulating Material
Appendix A to BTP APCSB 9.5-1 (to which the licensee is committed) states
that interior finishes should be noncombustible and that concealed spaces
above suspended ceilings should be devoid of combustible materials.
Contrary to the above, the staff observed that significant quantities of
foam plastic insulation was installed above the suspended ceiling in the
Technical Support Center (TSC) adjacent to the control room.
To the
extent that the licensee committed to conform with Sections D.l(d), D.l(f),
and D.2(c) of Appendix A to our fire protection guidelines, this condition
represents a deviation from the licensee's commitment.
The licensee's letter dated October 14, 1986, from K. Berry, CPCo, to
J. Keppler, NRC states
11The foam will be replaced with fiberglass" and
11The fiberglass has been received and will be installed during the first
quarter of 1987.
11
This will remain an Unresolved Item (255/86022-08)
pending verification of the installation of the fiberglass above the
suspended ceiling in the Technical Support Center adjacent to the control
room.
11.
10 CFR 50.48(b) in part requires that all nuclear power plants licensed
to operate prior to January 1, 1979, shall satisfy the applicable
requirements of Appendix R to this part, including, specifically the
requirements of Section III.J. entitled "Emergency Lighting.
11
Section III.J. of Appendix R indicates that Emergency lighting units with
at least an eight hour battery supply shall be provided in all areas
needed for operation of safe shutdown equipment and in egress routes
there to.
a.
Walkdown
The inspectors observed that emergency lighting was not available in
the following areas needed for safe shutdown outside of the Control
Room.
Volume Control Room
Boric Acid Storage Tank Room.
590' level by air ejector (in pit) near fast makeup valve
Containment near valve 2001
This is considered a violation (255/86022-09) of 10 CFR Permit 50,
Appendix R,Section III.J.
14
12.
The licensee's October 14, 1986 submittal from K. Berry, CPCo, to
J. Keppler, NRC, indicated that Emergency Lighting Units will be
installed at the Boric Acid Storage Tank Room, Volume Control Room
and fast makeup valve before startup from the present maintenance
outage.
Compensatory action in the form of requiring operators to
carry portable lights while performing Emergency Operator Procedures
10.2 will remain in effect until the problem of installing an Emergency
Lighting Unit at Control Value 2001 is resolved.
b.
8-Hour Emergency Lighting Discharge Test
There was an 8-hour emergency lighting discharge test conducted on
July 31, 1986 on several emergency lighting units.
At the beginning
of the test one of the filaments in the lighting unit failed
(flashed).
The licensee indicated to the inspector that procedures for
preventive maintenance for the emergency light unit, and emergency
lighting units surveillance and currently being developed.
The
licensee was requested to provide a tentative completion date
for resolution of the filament failure of the emergency lighting
units, the finalized procedures for preventive maintenance and
emergency lighting units surveillance.
In the licensee's letter dated October 14, 1986 from K. Berry, CPCo,
to J. Keppler, NRC, it indicates that the bulb failure may be an
isolated occurrence and it is not known at this time if it is a
generic problem.
The bulbs in the Emergency Lighting Units will be
activated every six months for two years and a record kept to
determine the frequency of immediate bulb burnout.
Appropriate
corrective action will be implemented if it is determined that bulb
failure is a generic problem.
This is considered an Unresolved Item
(255/86022-13) pending review of licensee's finalized procedures for
preventive maintenance and emergency lighting units surveillance.
Oil Collection System For Reactant Coolant Pumps
Section III.O of Appendix R requires an oil collection system that is
capable of collecting lube oil from all potential pressurized and
unpressurized leakage sites in the reactor coolant pump oil system and
withstand safe shutdown Earthquake.
The inspectors reviewed this area
and based on this review and inspection found it acceptable.
13.
Open Items
Open Items are matters that 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 or licensee or both.
Open Items disclosed during
the inspection are discussed in Sections 2, 7, 8, 9.
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14.
Unresolved Items
Unresolved Items are matters about which more inform~ti~n is required in
order to ascertain whether they are acceptable items, items of
non-compliance, or deviations.
Unresolved Items disclosed during the
inspection is discussed in Sections 2, 4, 11.
15.
Exit Meeting
The inspectors met with licensee representatives denoted in Paragraph 1
at the conclusion of the inspection on August 1, 1986 and summarized the
scope and findings of the inspection.
The licensee acknowledged the
statements made by the inspector .. The inspector also discussed the
likely informational content of the inspection report with regard to
documents reviewed by the inspector during the inspection.
The licensee
did not identify any such documents as proprietary.
In addition, a
meeting was held on September 29, and 30, 1986 at Palisades to discuss
the status of the inspection findings.
(
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