ML20134M900
| ML20134M900 | |
| Person / Time | |
|---|---|
| Site: | Summer, 05000385 |
| Issue date: | 08/13/1985 |
| From: | Conlon T, Hunt M, Madden P, Miller W, Taylor P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20134M887 | List: |
| References | |
| 50-395-85-26, NUDOCS 8509040334 | |
| Download: ML20134M900 (30) | |
See also: IR 05000395/1985026
Text
> R Etc UNITED STATES
o NUCLEAR REGULATORY COMMISSION
"
[" p REGION 11
101 MARIETTA STREET, N.W.
,4 j
'
- - 't ATLANTA, GEORGI A 30323
\...../
Report No.: 50-395/85-26
Licensee: South Carolina Electric and Gas Company
Columbia, SC 29218
Docket No.: 50-395 License No.: NPF-12
Facility Name: Summer
Inspection Conducted: June 3 - 7, 1985
Inspectors: M k. k)
W. H. Miller, Team Leader
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P. A. Taylor "
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Date Signed
Accompanying Personnel: R. Anan NRC/NRR-ASB
Approved b h 8-/8' M
T. E. Conlon, Chief Date Signed
Plant Systems Section
Division of Reactor Safety
SUMMARY
Scope: This special, announced inspection entailed 144 inspector-hours on site
in the areas of the licensee's actions regarding the implementation of the fire
protection and plant safe shutdown requirements of 10 CFR 50, Appendix R,
Sections III.G, III.J. III.L and III.0.
Results: Four apparent violations and one deviation were identified in the areas
of fire protection and the licensee's compliance with 10 CFR 50 Appendix R
Sections III.G, III.J. III.L and III.0: Failure to Meet the Requirements of
Appendix R,Section III.G, with Regard to Maintaining One Train of Hot Standby
Systems Free From Fire Damage - paragraph 5.a.(1); Failure to Meet the Require-
ments of Appendix R,Section III.G with Regard to Providing Separation for
Nuclear Instrumentation Required to Support Safe Shutdown Fire Areas - paragraph
5.a(1); Inadequate Fire Barrier Between Fire Areas IB-20 and IB-25.6 - paragraph
8.a; Nonfunctional Fire Barrier for Raceway VUL 34B in Fire Zone IB-23.2 - )
paragraph 8.b; and Failure to Conduct Fire Watch Patrol for Fire Area 18-25 -
paragraph 8.c. I
e509040334 850820
PDR ADOCK 05000385
G PDR
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REPORT DETAILS
1. Licensee Employees Contacted
- 0. W. Dixon, Vice President, Nuclear Operations
- 0. S. Bradham, Director, Nuclear Plant Operations
- D. A. Nauman, Director, Nuclear Services
- J. G. Connelly, Deputy Director, Operations and Maintenance
- K. Woodward, Manager, Operations
- M. B. Whitaker, Group Manager Regulatory and Support Services
- A. R. Koon, Associate Manager Regulatory Compliance
- J. Barker, Project Manager, Fire Protection
- H. I. Donnelly, Senior Licensing Engineer
- L. W. Lunden Nuclear Engineer
- T. Wessner, Plant Operations
- H. O'Quinn, Plant Operations
- C. Fields, Plant Operations Technical Advisor
- W. L. Safley, Plant Fire Protection Coordinators
Other Organizations
- D. K. Kelly, Electrical Engineer, Gilbert
- J. Seibert, Electrical Engineer, Gilbert
- R. D. Angus, Fire Protection Engineer, Gilbert
- T. J. Keckeisen, Fire Protection Engineer, Inter Science Incorporated
Rick Christensen, Nuclear Systems Engineer, Inter Science Incorporated
NRC Resident Inspectors
- C. Hehl
P. Hopkins
- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on June 7,1985, with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection findings listed
below. No dissenting coninents were received from the licensee.
a. Unresolved Item (395/85-26-01), Review Resolution of Summer's
Appendix R Reanalysis Issues Regarding Revised Shutdown Schemes.
Associated Circuits and Demonstrating Compliance with Appendix R,
Sections III.G and III.L by NRR - paragraphs 5.a.(1) and 5.a(2)(b).
b. Unresolved Item (395/85-26-02), Review Resolution of Fire Induced
Spurious Signal and Safe Shutdown System Modification by NRR -
paragraph 5.a.(1).
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c. Violation Item (395/85-26-03), Failure to Meet the_ Requirements of
Appendix R,Section III.G, With Regard to Maintaining One Train of Hot
Standby Systems Free From Fire Damage - paragraph 5.a.(1).
d. Violation Item (395/85-26-04), Failure To Meet the Requirements of
Appendix R,Section III.G. With Regard to Providing Separation for
Nuclear Instrumentation Required to Support Safe Shutdown - paragraph
5.a.(1).
e. Inspector Followup Item (395/85-26-05), Verify Breaker Coordination
Between XBCIA and DPNIHA and XMCIDB2X and APNIFB-EM - paragraph
5.a.(2)(a).
f. Inspector Followup Item (395/85-26-06), Review the Affects of Spurious
Valve Operation for Centrifugal Charging Pump - paragraph 5.a.(2)(b).
g. Unresolved Item (395/85-26-07), Review Resolution of the Licensee's
Associated Circuit Methodology with Regard to the Sample Size and
Circuits Analyzed for Over Current Protection by NRR - paragraph
5.a.(2)(c).
h. Unresolved Item (395/85-26-08), Correct Inadequacies Identified in
Procedure FEP 1.0 Based on Review and Approval of the Licensee's
Appendix R Reanalysis by NRR - paragraph 5.a.(3)(a).
i. Unresolved Item (395/85-26-09), Provide Limiting Times / Assumptions to
Arrive at Operator Action Time Lines to NRR for Review - paragraph
5.a.(3)(b). ,
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j. Unresolved Item (395/85-26-10), Identify / Issue Procedures to Accomplish
Appendix R Section III.L Requirements and Performance Goals Which are
,
Based on the Appendix R Reanalysis Approved by NRR - paragraph
5.a.(3)(c).
k. Inspector Followup Item (395/85-26-11), Provide Training for All FEP
Procedures to Support Appendix R - paragraph 5.a.(3)(d).
1. Unresolved Item (395/85-26-12), Inadequate Number of 8-Hour Battery
Powered Emergency Lighting Units Provided for Areas Need for Operation
of Safe Shutdown Equipment - paragraph 7.
m. Violation Item (395/85-26-13), Inadequate Fire Barrier Between Fire
Areas 1B-20 and 18-25.6 - paragraph 8.a. ,
n. Violation Item (395/85-26-14), Non-Functional Fire Barrier for Raceway .
VUL 34B in Fire Zone 18-23.2 - paragraph 8.b.
o. Inspector Followup Item (395/85-26-15), Review Licensee's Analysis for
Unprotected Cable Tray Supports - paragraph 8.b.
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p. Unresolved Item (395/85-26-16), Verification That the "M" Board Fire
Barrier was Reviewed and A Deviation was Granted for This Plant
Condition by NRR - paragraph 8.b.
q. Deviation Item (395/85-26-17), Failure To Conduct Fire Watch Patrol for
Fire Area 18-25 - paragraph 8.c.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
3. Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions. Eight new unresolved items identified during this inspection are
discussed in paragraphs 5.a.(1), 5.a.(2)(a), 5.a.(3)(a), 5.a.(3)(b),
5.a.(3)(c), 7 and 8.b.
5. Compliance With 10 CFR 50, Appendix R, Section III.G And III.L
i Operating License Section 2.c.(18)a issued on November 12, 1982, states that
SCE&G shall maintain in effect, and fully implement, all provisions of the
approved fire protection plan, as amended through Amendment No. 33 to the
Final Safety Analysis Report (FSAR). In addition, this license section also
requires SCE&G to maintain the fire protection program set forth in
Appendix R to 10 CFR 50.
By letter dated April 20, 1981, SCE&G committed to the NRC to comply with
the requirements of 10 CFR 50 Appendix R Sections III.G, III.J. and 111.0.
Subsequently, on June 1,1981, SCE&G requested deviations with regard to the
literal technical requirements of 10 CFR 50 Appendix R for the following:
- Component Cooling Water Pumps B&C do not meet Appendix R separation
requirements
-
HVAC equipment water chiller pumps do not meet Appendix R separation
requirements
- Partial automatic suppression provided in the auxiliary building and
intermediate building
. - Fire detection capabilities are not provided throughout the auxiliary
,
building and intermediate building
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' On the basis of the licensee's fire hazard analysis, their commitment to
meet 10 CFR 50 Appendix R Section III.G, III.J and III.0 and the above
,
deviations, the NRC issued Safety Evaluation Report (SER) Supplement Nos. 3
and 4 on January and August 1982, respectively.
SER Supplement No. 3 indicated that the licensee's safe shutdown analysis
i identified the systems necessary to achieve and maintain. hot and cold
shutdown conditions. In addition, the SER stipulated that one of the
redundant trains required for safe shutdown would be maintained free from
fire damage by providing separation, fire barriers, repair procedures (for
i equipment required for cold shutdown only) and/or alternative shutdown
capabilities. Also, SER Supplement No. 3 indicated that the licensee's safe
,' shutdown analysis identified those components, cabling and support equipment
- required for safe shutdown and performed a cable separation analysis for all '
j rooms of the plant housing safe shutdown equipment. The licensee by letter
! dated June 1, 1981, committed to provide a li hour fire rated barrier for
l
one safe shutdown train where redundant shutdown circuits or equipment are
j not separated by 20 feet with a very low intervening fire load or no
intervening combustibles. SER Supplement . No. 3 concluded that the
licensee's separation analysis was an acceptable means of demonstrating that
separation exists between redundant safe shutdown system trains.
SER Supplement No. 4 granted the licensee's request to deviate from the
technical requirement of 10 CFR 50 Appendix R with regard to the component
cooling water pumps, HVAC water chiller pumps and partial automatic
suppression and fire detection capabilities in the auxiliary and inter-
i~
mediate buildings. Therefore, SER Supplement No. 3 and 4 concluded that the
fire protection program, with the accepted deviations, meets the technical
requirements of Appendix R to 10 CFR 50.
,
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On the basis of the additional guidance and information obtained at the
May 4, 1984, NRC Region II Appendix R Fire Protection Workshop SCE&G
- initiated an Appendix R Reanalysis. The licensee contends that the
associated circuit review guidance pertaining to spurious signals provided
in Generic Letter 81-12 and its clarification letter was not considered in
their original Appendix R safe shutdown evaluation. The licensee stated
that.this guidance was not provided to them during plant licensing and in
order to ensure compliance a complete reevaluation of-their shutdown scheme
- .was required. Generic Letters 81-12, 83-33 and Draft 85-01 and other -
, applicable interpretive documents were used as guidance for their reanalysis
j effort.
'
Therefore, an inspection of the licensee's reanalysis and revised shutdown
scheme was conducted to detennine if fire protection features provided for
structures, systems, and components important to safe shutdown at the Summer t
. facility were in compliance with 10 CFR 50, Appendix R. Sections III.G and
i III.L. The scope of this inspection determined if the fire protection
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features ' provided for reactor coolant system inventory control, steam
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generator inventory control, and reactor coolant system pressure control
were capable of limiting fire damage so that one train of these systems
essential to achieving and maintaining hot standby from either the control
room or emergency control stations are free from fire damage.
a. Safe Shutdown Capabilities
l In order to ensure safe shutdown capabilities, where redundant trains
of systems necessary to achieve and maintain hot standby conditions are
located outside the primary containment,10 CFR 50 Appendix R requires
l that one train of hot standby systems be maintained free of fire damage
l by providing fire protection features which meet the requirements of
l either Sections III.G.2.a. III.G.2.b, or III.G.2.c.
-On the basis of the above Appendix R criteria,' the inspectors made an
inspection of cabling and. components associated with the chemical
volume control system, emergency feedwater system, service water
system, chilled water system, instrumentation associated with reactor
inventory and steam generator inventory control and onsite powr-
distribution to determine the adequacy of the fire protection features
and the separation afforded for these essential systems.
(1) Separation / Fire Protection of Redundant Cabling to Safe Shutdown
Equipment
Based on the licensee's Appendix R Reevaluation, SCE8G has changed
their shutdown scheme with respect to fire conditions occurring in
plant areas outside of the control room, relay room and cable
spreading room. The licensee's preliminary results indicate that
a fire in certain plant areas outside the control room complex
could potentially cause damage to both trains of safe shutdown
systems. Thus, it appears control of the safe shutdown function
from the control room could be rendered inoperable. The licensee
indicated that local operator actions outside the control room
,
would be required in order to regain control of one train of the
fire damaged safe shutdown (hot. standby) function.
The following table, identifies the fire areas outside the control
room complex which, when affected by a fire may require local-
' operator actions in order to regain a safe shutdown function or
system and notes the safe shutdown train which will be controlled:
Level of
Designated Actions Required
Building Fire Area Shutdown Train To Regain Control
Auxiliary AB-1 A or B* Minor Local Control
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Control CB-5 B Minor Local Control
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Control CB-10 B Minor Local Control
Control CB-12 A Minor Local Control
Control CB-18 B Minor Local Control
Control CB-20 A Minor Local Control
Intermediate 18-25 A or B* Moderate Local
Control
Control CB-1 A Minor Local Control
Control CB-2 A Minor Local Control
Turbine TB-1 A or B Very Minor Local
Control
- Shutdown train utilized depends on the location of the fire
in the fire area, B train preferred.
By letter dated May 29, 1985, the licensee identified the
following B-Train equipment which is necessary for safe shutdown
and is subject to maloperation due to fire induced hot shorts.
Equipment Tag # Description
XPP-43B-CSS Charging Pump "B"
XPP-458-SW S. W. Booster Pump "B"
.
XPP-1B-CC Component Cooling Pump "B"
XPP-488-VU Chilled Water Pump "B"
MFN-978-AH and Reactor Building Train B-
MFN-97D-AH Cooling Fans
XSW-1DB-ES, U4 Switchgear, XSW-1EB Feeder
XSW-1DB-ES, U7 Switchgear, XSW-1DB1 and XSW-IDB2 Feeder
XSW-IEB-ES, U3 Switchgear, XSW-1EB1 Feeder
XSW-1DB1-ES 480V Main Breaker
XSW-1DB2-ES 480V Main Breaker
XSW-1EB1-ES 480V Main Breaker
XFN-45A-AH Diesel Generator "B" Cooling Fans
XFN-458-AH Diesel Generator '?B" Cooling Fans
XPP-39B-SW S.W. Pump "B"
XEG-1B-DG Diesel Generator "B"
XHX-1B-VU Chiller Unit "B"
At the time of this inspection, the licensee had not identified
the control cable routing for these B-Train components. There -
fore, they could not ' verify if these B-Train safe shutdown
functions were separated from the A-Train. The licensee contends
that their revised fire / shutdown scheme takes credit for local
manual control of this equipment. However, in order to implement
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local manual operator actions, the licensee proposes to either
- modify this equipment by-adding control transfer switches and
j local . controls or develope jumper procedures. The licensee
proposes to complete the plant modifications and develope the
,
appropriate jumper procedures by the end of the 3rd refueling i
outage. The inspectors informed the licensee that repairs (i.e.,
termination of leads, fuse pulling utilization of jumpers) to
.
achieve and maintain hot standby conditions have been found to be
unacceptable. The inspectors indicated that, in order to comply
l with 10 CFR 50 Appendix R Section III.G, one train of systems
j necessary to achieve and maintain hot standby conditions from
,
either the control room or emergency control stations must be
i maintained free from fire damage. The licensee contends that
repair procedures are functionally equivalent to the requirements
of 10 CFR 50 Appendix R, Section III.G.
With regard to the licensee's Appendix R reanalysis program the
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inspectors identified the following concerns: i
- The Appendix R reanalysis does not specifically demonstrate
that the alternative shutdown capability provided for the
,
control room, cable spreading room and relay room can achieve
and maintain cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
-
The Appendix R reanalysis does not identify all the equip-
ment, components and cabling required to achieve and maintain
hot standby and cold shutdown conditions. ,
4 ,
- The Appendix R Associated Circuit Reanalysis does not appear
- to follow the guidance provided in generic letter 81-12 and
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its- April 7.1982,. clarification letter with respect to
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fuse / breaker coordination, common enclosures, and spurious
signals.
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The Appendix R reanalysis does not identify the analysis
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assumptions associated with the local control of safe
j shutdown systems for fires which affect plant areas outside
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the control room complex nor did the reanalysis justify the
timeliness associated with these local controls
-
_The Appendix R reanalysis relies on fuse removal to isolate
' spurious signal to equipment and/or components which can
i cause the maloperation of systems necessary to achieve and
-maintain hot standby.
i Upon completion of the Appendix R reanalysis, the licensee
committed to revise Summer's fire protection evaluation report and
- submit a draft revision during the second quarter of 1986 to the ,
! NRC staff for review. The licensee indicated that their submittal
! will address the above inspection concerns, . describe the safe
,
shutdown system modifications required as a ' result of the
,. , .- ,.s ~ ~ , - .,, -
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reanalysis, and explain the various shutdown schemes for fires
outside the control room which utilize local manual operator
actions to regain control of shutdown functions independent of the
control room. This is identified as Unresolved Item (395/85-
26-01), Review resolution of Summer's Appendix R reanalysis issues
regarding revised shutdown schemes, associated circuits and
demonstrating compliance with Appendix R Sections III.G and III.L
by NRR.
An inspection was made to determine if the cables or equipment
including associated nonsafety 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 were provided with
adequate separation and/or fire protection features in accordance
with Appendix R Section III.G.2.
(a) Auxiliary Spray Valve Cabling
Control cabling associated with auxiliary spray valve
(XVT-8145-CS) are routed through the following fire areas:
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Auxiliary Building Fire Area AB-1
-
Control Building Fire Areas CB-6, CB-10, CB-15, and
CB-17
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Intermediate Building Fire Area IB-25
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Reactor Building Fire Area RB-1
Therefore, a fire occurring in any of the above listed fire
areas could cause spurious operation of the auxiliary spray
valve due to a hot short to the solenoid control cable.
Inadvertent opening of this valve with a charging pump in
operation could result in primary plant de-pressurization.
By letter dated May 29, 1985, the licensee identified this
condition to the NRC.
In order to preclude the potential spurious operation of the
auxiliary spray valve from an external hot short, the
licensee proposes to replace the control cables from the
control room to the valve with cabling which includes a
grounded shield. In addition, the licensee proposes to
provide a second control power disconnect independent from
the control room disconnect in order to prevent spurious
auxiliary spray valve operation in the event of a control
room fire. This modification has been scheduled to be
completed by the end of the third refueling outage (second
quarterof1987).
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(b) Steam Generator Power Operated Relief Valve Cabling
Control cabling associated with the steam generator power
operated relief valves (IPV-2000-MS, IPV-2010-MS, and
IPV-2020-MS) are routed through the following fire areas:
- Auxiliary Building Fire Area AB-1
- Control Building Fire Areas CB-1, CB-2, CB-4, CB-5,
CB-6, CB-10, CB-12, CB-17, CB-18
- Intermediate Building Fire Areas 18-20, IB-22 and 18-25
Therefore, a fire occurring in any of the fire areas listed
above, could cause spurious operation of steam generator
power operated relief valves due to a hot short to the
control cables associated with either of the two control
solenoids for each valve. Inadvertent opening of these
valves could cause excessive cooldown and reactor coolant
system shrinkage. By letter dated May 29, 1985, the licensee
identified this condition to the NRC.
In order to preclude the potential spurious operation of the
steam generator power operated relief valves from an external
hot short, the licensee proposes to replace the control
'.
cables with cabling from the control room to the valves which
includes a grounded shield. In addition, the licensee
proposes to provide a second control power disconnect inde-
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pendent from the control room disconnect in order to prevent
spurious steam generator power operated relief valve opera-
tion in the event of a control room fire. This modification
is scheduled to be completed by the end of the third refuel-
ing outage (second quarter of 1987).
(c) Excess Letdown Isolation Valve Cabling
Control cabling associated with the excess letdown isolation
,
valves (XVT-8153-CS and XVT-8154-CS) are routed through the
following fire areas:
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Control Building Fire Areas CB-1, CB-6, CB-12, CB-15 and
CB-17
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Intermediate Building Fire Area 18-25
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Reactor Building Fire Area RB-1
Therefore, a fire occurring in any of the above listed fire
areas could cause spurious operation of both excess letdown
isolation valves. Inadvertent opening of these valves could
cause a loss of reactor coolant system inventory. By letter
dated May 29, 1985, this condition was identified by the
licensee to the NRC.
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In order to preclude the potential spurious operation of both
excess letdown isolation valves, the licensee proposes to
identify the control power disconnects in the control room
and install a second set of control power disconnects in the
cable spreading room. The licensee contends that this will
ensure closure of these valves and two independent hot shorts
would have to occur in order to open these valves. This
modification is scheduled to be completed by the end of the
third refueling outage (second quarter of 1987).
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(d) Main Steam Isolation and Bypass Valve Cabling
Control cabling associated with the main steam isolation and
bypass valves (XVM-2801A, B, C and XVT-2869A, B, C-MS) are
routed through the following fire areas:
- Control Building Fire Areas
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CB-1, CB-2, CB-4, CB-6, CB-10, CB 12, CB-15,
CB-17 and CB-18
- Intermediate Building Fire Areas
18-20, 18-22, and IB-25
Therefore, a fire occurring in any of the above listed fire
areas could cause spurious operation of the main steam
isolation and bypass valves. Inadvertent opening of these
valves due to external hot shorts could cause a loss of
secondary side inventory. By letter dated May 29, 1985, this
condition was identified by the licensee to the NRC.
,
In order to preclude the potential spurious operation of the
main steam isolation and bypass valves the licensee proposes
to identify the control power disconnects in the control room
, and install a second set of disconnects in a separate fire
area. The licensee contends that this will ensure closure of
these valves and two independent hot shorts would have to
occur in order to open these valves. This modification is
scheduled to be completed by the end of the third refueling
outage (second quarter of 1987).
(e) Pressurizer Power Operated Relief Valve Cabling
Control cabling associated with the pressurizer power operat-
ed relief valves (IPV-4448, IPV-445A, and IPV-445B) are
routed through the following fire areas:
-
Auxiliary Building Fire Area AB-1
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Control Building Fire Areas
CB-10, CB-15 and CB-18
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-Intermediate Building Fire Areas
18-14, 18-20, 18-21, 18-22 and IB-25
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Reactor Building Fire Area RB-1
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Therefore, a fire occurring in any of the fire areas iisted
above could cause spurious operation of a pressurizer power
operated relief valve. Inadvertent opening of a pressurizer
power operated relief valve due to an external hot shorts
could cause a loss of reactor coolant inventory. By letter
dated May 29, 1985, the licensee identified this condition to
the NRC.
Thus, in order to preclude the potential spurious operation
of a pressurizer power operated relief valve the licensee
proposes to replace the control cabling from the control room
to the valves with cable which includes a grounded shield.
In addition, the licensee proposes to install a second set of
control power disconnects independent from the control room
disconnects in order to prevent spurious pressurizer power
operated relief valve operation in the event of a control
room fire. This modification is scheduled to be completed by
the end of the third refueling outage (second quarter of
1987).
(f) Diesel Generator Control Transfer Switch
Cables (DGM 29B, DGM 21B, and DGM 228) associated with the
train "B" diesel generator control transfer switch are routed
through the cable spreading room, CB-15. Therefore, a fire
in the cable spreading room could result in external hat
shorts which could render the Train 8 diesel generator
inoperable in addition to damaging cabling associated with
the Train "A" diesel generator. Thus, the ability to achieve
and maintain hot standby conditions from the control room
evacuation panel (CREP) utilizing onsite power capabilities
may be jeopardized.
The licensee proposes to relocate cables DGM 218 and 22B
outside the fire area of concern and cable DGM 29B will be
isolated by modifying the circuit and utilizing additional
contacts associated with the existing control transfer
switch. This modification is scheduled to be completed by
the end of the second refueling outage (fourth quarter of
1985).
(g) Current Transformer Circuits
A fire in either the contrcl room or cable spreading room
could damage both trains of switchgear required for safe
, shutdown by damaging the current transformer circuits. The
fire could possibly cause the current transformer circuit to
open, resulting in a secondary fire at the current trans-
former in the respective switchgear. By letter dated May 29,
1985, the licensee identified this condition to the NRC.
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Thus, in order to preclude the potential secondary fire in
the switchgear the licensee proposes to install surge sup-
pressors in the circuit parallel with the current trans-
former. This will prevent the over voltage surge which could
occur in the event of an open current transformer circuit.
This modification is scheduled to be completed by the end of
the second refueling outage (fourth quarter of 1985).
(h) Reactor Coolant Temperature Instrumentation Cabling
The licensee indicated that for fires which could potentially
.,
disable Train "B" power it is intended to shutdown from the
'
control room using RCS Loop "B" and steam generator "B". A
fire in the following fire areas could cause a loss of
Train "B" power:
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Control Building Fire Areas
CB-1, CB-2, CB-12, and CB-20
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Diesel Generator Building Fire Area DG-2
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Intermediate Building Fire Areas IB-4, IB-6, IB-9 and
15-20
The loss of Train "B" power presently results in a loss of
RCS instrumentation (ITE-420-RC and ITE-420A-RC) for loop "B"
Tcold. By letter dated May 29, 1985, the licensee identified
this condition to the NRC.
Thus, in order to preclude the loss of Tcold instrumentation
on RCS Loop "B" the licensee proposes to provide Train "A"
power in lieu of Train "B" power to this instrumentation.
This modification is scheduled to be completed by the end of
the third refueling outage (second quarter in 1987).
(i) Emergency Feedwater System Cabling
In the Intermediate Building, on elevation 412'-0", Fire Area
1B-25.1, over the motor driven emergency feedwater pumps on
the mezzanine level, power cables for the "A" and "B" train
motor driven emergency feedwater pumps interact with control
cabling associated with turbine driven emergency feedwater
pump discharge valves (IFV-3556-EF and IFV-3546-EF) to steam
generators B and C.
Since, these cables are not provided with 20 feet of spacial
separation without intervening combustibles, a postulated
fire in this area could potentially cause fire damage to both
redundant trains of emergency feedwater. Thus, if an expo-
sure fire were to occur in this area, there is a potential
that both trains of motor driven emergency feedwater pumps
and discharge from the turbine driven emergency feedwater
pump could be rendered inoperable. The_ licensee's proposed
'
.
13
..
shutdown scheme for a fire in this area is to fail the valves
open by pulling the control fuses in the main control board,
regaining local manual control of the turbine speed control
valve and controlling the flow to the steam generators from
inside the turbine driven pump room.
The licensee proposes to enclose Train "A" Cable Tray 3088 in
a 1-hour Fire Barrier throughout fire area IB-725. This
modification is scheduled to be completed by the end of the
first quarter of 1986.
(j) Source Range Nuclear Instrumentation Cabling
A fire in the north cable chase of the control building on
elevation 436'-0" could cause all three of the available
source range nuclear instruments to be damaged. On May 29,
1985, by letter, the licensee identified this condition to
the NRC.
In order to preclude the loss of all three source range
instruments due to a fire in fire area CB-1 the licensee
proposes to either enclose one train of source range cabling
i in an 1-hour fire barrier or install a power source selector
switch for one train of source range instrumentation. This
modification is scheduled to be completed by the end of the
first quarter in 1986.
(k) Power Cable Tray Separation
A fire in the southwest corner of elevation 412'-0" of the
intermediate building, fire area 18-25, near column line
7.5/G.4, redundant cabling required for systems necessary to
achieve and maintain hot standby conditions could be damaged.
2 Tray 3088 contains Train "A" DC control power to all ess 2n-
l tial safe shutdown systems interacts with Tray 4149 which
contains Train "B" control power for the chilled water system
and the component cooling water system. In addition, conduit
VUC-2B which contains Train "B" control power cabling for the
chilled water system and trays 1025, 2058 and 3128 which
contain Train "B" power to the chilled water system and
component cooling water system also interact with cable tray
3088. Since, the chilled water system provides bearing
cooling capabilities to the charging pumps, a fire in this
area affecting the chilled water system could possibly render
both charging pumps inoperable. By letter dated May 29,
1985, the licensee identified this condition to the NRC.
The inspector indicated that operator access into the turbine
driven pump room in order to implement local manual operator
actions may be difficult since, the access door to this area
is adjacent to the plant area experiencing the fire.
--_ .
- . _. .-. .- . . . - -._- . . . . . . - . . - . . _
'
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_
14
Based on our review of the associated circuit issue, it was
established that the licensee did not receive Generic
l Letter 81-12, associated circuit guidance during the licensing
! phase. Thus, it appears that the original associated circuit
analysis was inadequate with regard to meeting the requirements.of
! 10 CFR 50 Appendix R, Sections III.G and III.L. Therefore, the
j safe shutdown capability concerns identified in 5.a.(1)(a) through
,
5.a(1)(i) could have prevented the operation or caused the mal-
operation of -safe shutdown functions due to fire induced hot
,'
shorts, open circuits, or shorts to ground. This item is identi-
'
fied as Unresolved Item (395/85-26-02), Review Resolution of Fire
. Induced Spurious Signal and Safe Shutdown System Modifications By
NRR.
. In addition, at the time of the inspection it appears that if a -
? fire were to occur of the' plant area identified in 5.a(1)(k),
l redundant hot standby systems could be rendered inoperable; thus,
- the plant's ability to achieve and maintain hot standby could not
be assured. This is identified as Violation Item (395/85-26-03),
l
Failure To Meet the' Requirements of Appendix R,Section III.G.
' With Regard to Maintaining One' Train of Hot Standby Systems Free
From Fire Damage.
k In order to achieve and maint'ain safe shutdown. conditions, process
i monitoring functions necessary to provido direct-readings of the
process variables are required. It appears that if a fire were to
occur in the area identified-in 5.a(1)(j) redundant direct reading
nuclear instrumentation functions could be rendered inoperable;
- thus, certain process variable could not be monitored. This is
l- identified as Violation Item (395/85-26-04), Failure to Meet the
i Requirements of Appendix R,Section III.G with Regard to Providing
'
Separation for Nuclear Instrumentation Required to Support Safe
Shutdown.
(2) Protection of Associated Circuits
'
- The inspection was conducted to verify compliance with associated
circuit provisions of .10 CFR 50 Appendix R, Sections.III.G and
- - III.L. The emphasis was on the following area of concern
- -
.
'
Common Bus Concern
,
Spurious Signal Concern
Common Enclosure Concern
,
(a) -Coninon Bus Concern
i
The common bus concern is found in circuits, either safety or
,
nonsafety-related, where there is a conunon power source with
_ ,
shutdown equipment and the power source is not electrically
protected from the circuit of concern.- The licensee selected
the worst case load breaker for each unit substation. motor
i
'
a
I'
, _ , . , . _ , . - f_-.._ ..,._,...,m.- -, ,. - _ . _ - . _ . - _ . . . _ , _ , . . , _ . . .
.
15
control center (MCC) and distribution panel. Time-current
characteristic curves were then plotted to demonstrate the
coordination for each grouping of electrical equipment
associated with a common bus based on the worst case
condition.
The following time-current characteristic curves were
reviewed:
1) 7200V Board (Bvd) XSW1DA to 480V Bvd XSW10A1 to service
water pump XPP-45-A-SW motor
2) 7200V Bvd XSW1DA to 480V Bvd XSW10A2 to 480V Motor
control Center (MCC) XMCIDA2Y to Battery charger
l XBCIA-1B
] 3) MCC XMCIDA2Y to Battery Charger XBCIA-1B and 75 HP Motor
4) MCC XMCIDA2Z and Panel XPN47
5) 7200 V Bvd XSW1EA to 480V Bvd XSW1EA1, 480VMCC XMCIEAIX,
480V MCC XMC1EC1X to XPP44C (penetration pressurizing
.
equipment)
6) 125VDC Battery Bvds XBCIA, XBAIA to Distribution Panel
, DPN1HA to DPN1HA1 to Service Water System Control
Circuits XSW1DA and XSW1EA
, 7) 480V MCC XMC 1082X-ES to 125V Feeder Panel APN1FB or
'
APN1FA to the rod position indication panel which has
150A fuse protection
During discussions with the licensee representatives it was
noted that the coordination study for item (6) above was
border line in that the upper limits of the feeder breaker to
distribution panel DPN1HA1 from distribution panel DPN1HA and
the lower limit of the feeder breaker to DPN1HA from the
125VDC Battery Board XBCIA appear to overlap and approach a
comon current interrupt value. This item was identified to
the licensee who agreed to further investigate these breaker
limits.
Another possible coordination problem was identified later by
the inspector in the fuse / breaker coordination between the
feeder breaker to the rod position indication panel located
on Distribution Panel APN1FB-EM and the feeder breaker from
MCC XMCIDB2X-ES to APNIFB-EM should a fault occur between the
rod position indication panel feeder breaker and its protec-
tive fuse.
.- _ _ __ ._ _ . _ _ _ _ - - _ _ __. . _ _ ___ ._ _ __
'
.
i 16
i
i
These two items are identified as Inspector Followup Item
'
1 (395/85-26-05), Verify Breaker Coordination Between XBCIA and
DPN1HA and XMCIDB2X and APN1FB-EM. ,
,
(b) Spurious Signal Concern
! A review of the licensee's spurious signal analysis was
j conducted to determine if the following conditions had been
considered:
) -
Unwanted motor operations, control signals undesired or
.l
not responsive and false instrument readings such as
what occurred at the 1975 Browns Ferry Fire, that could
'
'
affect safe shutdown of the plant. These could be
caused _ by fire-initiated grounds, shorts or open
'
circuits,
i
! -
Spurious operation of safety-related or_ non-safety-
l related components that would adversely affect shutdown
capability (e.g., RHR/RCS Isolation Valves).
The licensee developed a composite equipment list for the
safe shutdown of the plant. The list was then evaluated for
equipment that if it were to operate spuriously the resultant
operation could jeopardize the capability to safely shutdown
+
the plant. From the evaluation, the licensee advises that-
j fuses will be pulled.on the control circuits for the equip-
ment identified as being detrimental to safe shutdown if
- spuriously operated. - Additionally, the licensee has proposed
. to install disconnect switches in circuits to replace the
fuse removal operation and perform the control functions
manually. This action is taken in lieu of protection of a
train of shutdown equipment. The present plant condition
- appears to conflict with the license requirements for compli-
~
ance with Appendix R IIIG. This is another example of
Unresolved Item (395/85-26-01).
!
The inspector also reviewed the possible consequences of a
- .. fire in the area termination cabinets with a loss of offsite
i
power and the consequences of spurious operation of the
charging pump suction and discharge valves when the centrifu-
gal charging pumps are sequenced into operation from the
2
onsite power source. During discussions it was determined
that the suction and discharge valves for the auxiliary
feedwater and service water pumps are manually locked in the
proper position at all times and would not be affected. The
licensee advised that they have selected Train B as the
4 preferred shutdown train. They further advised that they
will clear the 7200 volt Boards XSWIDA and XSWIDB in that
- order upon evacuation of the control room. These actions are
! an effort to protect /save equipment during a fire. Through
l
4
.- ._. -- -. - - __ - - - . . - . _ - - . - - - . - -
- _ - _ _ _ _ _
.
17
manual operation of breakers the needed equipment will be
started. However, the concern is the possible damage to
equipment during the time required for an operator to move to
the 7200V board rooms and deenergize the boards. The licen-
see advised that the additional charging pump "C" would be
available if it not in operation in place of the "A" pump or
the "B" pump. This substitute condition is classified as an
out of normal operating mode and is not addressed as an
Appendix R requirement. This item will be examined further
and is identified as an Inspector Followup Item
(395/85-26-06), Review the Affects of Spurious Valve Opera-
tion for Centrifugal Charging Pumps.
(c) The Comon Enclosure Concern
The common enclosure concern is found when redundant trains
are routed together with a non-safety circuit which crosses
from one raceway or enclosure to another, and the non-safety
circuit is not electrically protected or fire can destroy
both redundant trains due to inadequate fire protection
means.
The licensee performed a statistical analysis to produce a
report which indicated that there was 95% confidence that 95%
of the power circuits with cables greater than 10AWG have
overcurrent protection. A total of 1834 power circuits were
identified which had power feeds using wire size greater than
- 10. A random sample of 59 circuits was selected from all
the power circuits in the overall plant. The NRC inspector
,
'
noted that the sample included two spare circuits, sixteen
welding system feeds, eight air handling system power cir-
cuits and four control rods and position indication system
circuits. The remaining 31 circuits were spread over various
systems with no more than two circuits selected for any
system. Of these remaining circuits, several were not
associated with systems required for safe shutdown. The
actual circuits were identified by circuit number only; thus,
the actual function of the circuits could not be determined.
s But just by counting those analyzed circuits in systems that
l
would not nonnally be used for safe shutdown, there were
approximately 32 circuits or 54% of the total sample circuits
that are not related to safe shutdown systems. This was
discussed with the licensee in view of the fact that most
,
licensees have performed a 100% analysis of the safety-
l related and nonsafety circuits that are required for shutdown
in order to determine those circuits requiring protection.
The analysis results reviewed for the circuits chosen indi-
! cated that each circuit is fuse / breaker protected such that
! the power will be tripped off before auto ignition of the
cable would occur. During the inspection, the licensee
i
.- . .. .-_ - _ _ _ _ _ _ _
~
.
18
presented the analysis for two circuits to replace the two
spare circuits. Neither of these two circuits could be
identified as circuits required for safe shutdown. The
licensee was advised of the inspector's concern regarding the
number of circuits used for safe shutdown that were analyzed
versus the number of total circuits analyzed. The licensee
was advised that this concern will be identified as an
Unresolved Item (395/85-26-07), Review Resolution of the
Licensee's Associated Circuit Methodology with Regard to the
Sample Size and Circuits Analyzed for Over Current Protection
by NRR.
(3) Alternative Shutdown Capability
In a letter dated May 2,1985, to Dr. J. Nelson Grace, Regional
Administrator, Region II, the licensee submitted several sections
of a manual entitled, Preaudit Submittal Package for NRC
Appendix R Compliance Audit. This document Volume 3, Section 8.0
identifies new procedures to be used when fire has made the
control room uninhabitable and shutdown from outside the control
room must be implemented. The development of new operating
procedures is due to the licensee's Appendix R Reanalysis the
results of which were submitted to the NRC in a letter to
H. R. Denton, Director, NRR dated May 29, 1985.
(a) Procedure Development Review
Fire Emergency Procedure (FEP) 1.0, Revision 1, Control Room
Evacuation Due to Fire, is the new procedure to use for fire
in the control room complex or control building that has made
controls and indications unreliable. This procedure was
approved and issued for use May 30, 1985.
The basic concept and approach that this procedure takes is ;
one in which manual operator actions are taken to isolate the
primary and secondary system volumes to prevent significant
- losses in plant water inventory and pressure. In addition
'
electrical breakers are opened such that the incoming and
, s emergency power to the 7.2 kw switchgear loads are removed,
all electrical breakers on train A and B motor control
centers (MCC) are open to prevent spurious operation of
equipment and motor operated valves. Fluid systems such as
chemical and volume control system (CVCS), emergency feed-
water system (EFW), and service water system (SWS) have
manual valve alignments conducted in order to supply make up
water to RCS and steam generator and cooling water for the B
diesel generator. Borated makeup water from the RWST to the
RCS is via a CVCS charging pump to the reactor coolant pump i
seals. The B diesel generator is manually started and 1
operator action is taken to restore power to electrical buses
and essential equipment is energized. The licensee concept
I
-- a
.
19
indicates that pressure control for the RCS is the use of
pressurizer heaters and code safety valves. The steam
generator safety valves are used for steam generator pressure
control and decay heat removal. It should also be noted that
the licensee has selected train B equipment to provide the
Alternative Shutdown Capability.
The inspectors reviewed and walked through FEPl.0, Control
Room Evacuation Due to Fire, to verify that the procedure
incorporates the requirements delineated by Appendix R
Section III.L and the procedure can be implemented. The
following inadequacies and concerns were presented to the
licensee for resolution:
1) Procedure contains no check-off or sign-off blocks for
procedure action steps. This practice is presently
required for the plant's emergency operating procedures.
2) Procedure steps have not been provided to determine if
Natural Circulation has been established nor operator
actions to be taken if it is not established.
3) Appendix R Section III.L.2.d requires that the process
monitoring function shall be capable of providing direct
readings of the process variables that are being used.
Make up water to the reactor coolant system will be from
the refueling water storage tank (RWST). No direct
reading of tank water level is provided outside the
control room at the control room evacuation panels
(CREP) or locally at the tank to monitor changes in RWST
level.
4) Procedure step 9 Caution h allows taking the pressurizer
to solid water conditions then use the pressurizer code
safeties for pressure control. The procedure presently
requires the charging pump to be run centinuously
through the RCP seal. The licensee indicated that the
pulsation from starting and stopping the charging pump
may damage the RCP seals. The inspectors concerns with
this operation is that no analysis was provided to
ensure that taking the pressurizer solid through the
code safeties will not cause damage to the valves if
water comes in contact with the safety valve seating
surfaces. Warped valve seating surfaces could cause
pressure control and inventory control problems within
the reactor coolant system. In addition, the licensee
provided no plant procedure outlining the operational
controls necessary to manage solid plant operation if
this method was to be used.
_ . . _ _ __
_ _ _ _ _ _ _ _ _
.
20 ,
5) Procedure step 9 note h states " Consider Emergency
Boration for Shutdown Margin See Attachment VII." The
inspector is concerned that this note does not provide
the operator with the parameters or reasons he would
need to evaluate, in order to make the detennination to
emergency borate.
6) Procedure, Attachment II Step 1.0. This step as
presently written does not provide the operator with
those indications (e.g., decrease reactor power level,
rod bottom lights, etc.) to verify that'the reactor has
tripped. This infonnation is necessary in order to
determine if the " Alternative Action" steps that are
provided need to be implemented. These steps would
direct the operator to trip the reactor at the rod drive
MG sets.
7) Procedure, Attachment III Step 1.0 provides operator
actions to stop multiple spurious operation of primary
and secondary system valves (e.g., steam generator power
operated relief . valves (PORV), pressurizer PORVs,
pressurizer spray valve, main steam isolation valves,
etc.) by pulling fuses inside the main control board
thus securing the loss of water inventory from the RCS
j and steam generators. The Alternative Action states "If
fuses are not accessible, maintenance personnel will be
required to implement Attachment X when they report to
control room evacuation panels". The operator time line
shows the maintenance personnel not arriving at the CREP
for 20 minutes once FEP 1.0 is initiated. They are also
assigned to start Attachment V when they arrive at CREP.
Attachment V duties consist of opening all breakers on
the 480VAC motor control center then restoring selected
equipment needed to achieve and maintain hot standby
conditions. Attachment X consists of lifting leads to
stop multiple spurious valve operation. The time of
maintenance personnel arrival at the CREP coupled with
performing Attachment X would lead to the performance
goals and conditions of Appendix R Section III.L being
jeopardized. In addition, no operator time lines have
been established for Attachment X.
8) Attachments I through V and also procedure steps 1
through 9 are % nsary to be accomplished in order to
'
achieve and ti<im in hot standby conditions. These
portions Of tw e ocedure describe equipment such as
flash lig & , uj#, fuse pullers, wire cutters, screw
drivers, etc. as being necessary in order to do the
steps in the procedure. This equipment needs to be
placed in emergency kits at appropriate locations for
r operator use. In addition, inventory check lists need
- .- . . -- ..- -
-
. .
'
21
.
to be established under the routine surveillance program
i to ensure availability of this equipment.
9) Correct the following typographical errors:
- Procedure step 10.b change Attachment VII to VI
- Attachment V step 8b change 06EH to 06El
10) Procedure, Attachment II, steps 6 and 7 rearrange XSW1DB
bus stripping sequence to deenergize Train B switchgear
first as this train has been identified by the licensee
'
as the alternative shutdown capability.
11) Add headsets to the emergency kits as noise level could
prevent connunication using hand held radios in areas of
diesel generator operation.
12) Procedure, Attachment VI, page 3 add a note to provide
the operator with a breaker charging spring tool so
7.2kw breakers can be manually operated. This tool
should be part of the emergency kit being established
,
for this procedure.
13) Procedure Step 9.c.2 list valve XVT-8102B RCP B seal
supply isolation valve as being in 412W penetration room
- (the valve is located in 412E penetration room).
<
'
14) Procedure Step 9d requires opening valve XVT-8102C, RCP
C seal supply isolation valve and the valve is located
in 412E penetration room. Entry to this room is through
door PA103 which was locked. The operator had keys to
unlock other doors, but not this one. The valves listed
in item (13) and (14) is the flowpath to supply sealing
water for RCP B and C and make up water to the RCS.
The above procedure inadequacies and concerns will remain unre-
'
solved until the licensee has completed his reanalysis and submit-
ted his new Appendix R program to the NRC for review.and final
approval. This area is identified as Unresolved Item
(395/85-26-08), Correct Inadequacies Identified in Procedure FEP
1.0 Based on Review and approval of the licensee's Appendix R
Reanalysis by NRR.
(b) Operator Action Time Line to Achieve and Maintain Hot Standby
As previously discussed, the licensee's new program will be one of
a series of manual operations to regain control of the plant
systems on the on set of a control ~ room complex fire and subse-
l quently achieve and maintain the plant in hot standby condition.
The inspector requested the licensee's analyses and assumptions on
which the operator time lines are based. The licensee indicated
__ _ __ _ _-
.
22
!
that this analysis was not complete and no infomation was given
to the inspectors. The inspectors presented the following areas
of concern, but is not to be misinterpreted as a complete listing j
of areas that the licensee should be considering when conducting i
his analysis. 1
- Provide limiting times required to isolate and secure the l
primary volume to ensure that loss of reactor coolant system
'
water inventory and pressure doesn't exceed the performance
goals and conditions of Appendix R Section III.L.
- Provide limiting time required to isolate and secure the
secondary volume to ensure that a loss of steam generator
water inventory doesn't impair the decay heat removal capa-
bility and emergency feedwater system (EFS) is put into
service to prevent this from occurring and the perfomance
goals and conditions of Appendix R,Section III.L are met.
- Detemine the time that reactor coolant pumps (RCP) seals can
be without chemical volume control system (CVCS) sealing
water to ensure that damage to the RCP seals doesn't occur
which would result in loss of makeup water to the RCS. The
licensee source of makeup water to RCS is via the reactor
coolant pump seals which is a nominal 15gpm. Presently no
operator time line is provided as to when the CVCS charging
pump must be put into service.
The above matter will remain unresolved until the licensee has
completed his reanalysis and submitted his new Appendix R program
to the NRC for review and final approval.
This item is identified as Unresolved Item (395/85-26-09), Provide
Limiting Times / Assumptions to Arrive at Operater Action Time Lines
to NRR for Review.
(c) Additional Ple a Operating Procedure
The inspectors were provided a draft copy of FEP 1.1 Plant Shut- l
down From Hot Standby to Cold Shutdown Due to Fire In Control s
Building. This procedure is still under development and is not
complete.
The licensee has identified several fire areas outside the control
room complex where a fire could potentially effect both trains of
l systems necessary to achieve and maintain hot standby conditions.
The licensee provided a tentative completion schedule of the third
quarter 1986 for issuing these procedures which describe operator
action.
_ _. _
. _
- .
-
.
23
The above matter will remain unresolved until the licensee has
completed his reanalysis and submitted his new Appendix R program
to the NRC for review and final approval.
This item is identified as Unresolved Item (395/85-26-10) Iden-
tify/ Issue Procedures to Accomplish Appendix R Section III.L
Requirements and Performance Goals Which are Based on the
Appendix R Reanalysis Approved t,y NRR. J
l
(d) Training
l
The licensee has initiated training on procedure FEP 1.0 which
consists of a lecture series for senior reactor operators (SRO),
reactor operators (RO), and Shift Technical Advisors (STA). This
training is essentially completed for all shift operating person-
nel. The licensee is presently reviewing method of training that
will be used and how this training will be factored into the
required licensed operator requalification program. The inspector
discussed the additional FEPs that will be issued and the licensee
plans to include all FEPs in the requalification program. The
training of operators as well as maintenance personnel that are
required to support the FEPs will be reviewed at a subsequent
inspe: tion. This is identified as Inspector Followup Item
(395/85-26-11), Provide Training for All FEP Procedures to Support
Appendix R.
(e) Damage Control Measures
Appendix R Sections III.G.1.b and III.L.5 require fire protection
features to be provided for structures, systems and components
important to safe shutdown and to be capable uf limiting fire
damage so that systems necessary to achieve and maintain cold i
shutdown are free of fire damage or can be repaired such that the l
equipment can be made operable and cold shutdown achieved within
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials for such repairs are required to be readily
available on site and procedures are to be in effect to implement
such repairs.
The licensee has identified the power supply cables for the RHR pumps -
as items which could be damaged by a fire and which must be repaired to
permit cold plant shutdown. Procedure EMP-100.002, Emergency Installa-
tion of Cable For "B" RHR Motor, has been prepared to provide a guide
for installation of spare feeder cable following a fire which has
caused a loss of both RHR pumps. This procedure also identifies the
material which is to be maintained on site to accomplish these repairs.
The inspector (s) conducted an inspection to verify that the required
materials were available. Procedure EMP-100.002 Section 7.1.1 requires
a 500' reel of 3C-350 MCM cable,12 mechanical wire lugs, 3 boxes of
"biseals," 2 boxes of scotch 33+ tape, and a roll of rope. This
material is stored in warehouse "B". The cable is stored on a reel and
._
_.
.
24
4
the other items are stored in a wooden box and marked with a hold tag. l
This material appeared to be properly stored and maintained. I
A plant tour was made by the inspector (s) which verified that the cable
routes specified by Procedure EMP-100.002, Section 7.2 were feasible.
! 6. Compliance to 10 CFR 50 Appendix R Section III.0 Oil Collection System for
Reactor Coolant Pumps
The reactor coolant pumps are required to be equipped. with an oil collection
system if the containment is not inerted during nonnal plant operations.
The oil collection system is to be so designed, engineered and installed
such that failure will not lead to fire during normal or design basis
accident conditions and there is reasonable assurance that the system will
withstand the " Safe Shutdown Earthquake." The systen is to be adequately
i
sized and capable of collecting lube oil from all potential leakage sites in
the reactor coolant pump lube oil system. Leakage is to be collected and
'
drained to a closed container sized to hold the entire lube oil system
inventory. A flame arrester is required in the container vent if the flash
point characteristics of the oil presents the hazard of fire flash back.
The inspectors reviewed the design of the oil collection system for the
reactor coolant pumps. An inspection of the system was not made since the
plant was in operation and access to the containment was not possible.
However, Gilbert's Drawing B-305-601, Sheets 1-3 and Westinghouse Drawings
a 9550034, 1540E28 - E30, 1540E81 - E83, 1540E88 and 1188F97 were reviewed.
These drawings indicate that the oil collection system provided for each
pump motor contains sufficient splash guards, catch basins and enclosures at
potential oil leakage locations on the reactor coolant pump motors to
collect and drain off potential oil leaks to a collection tank. Each motor
is provided with an independent collection system arranged with a drain
piping system which terminates in a 275 gallon tank. Each tank is sized to
receive the total lube o*,1 capacity of 240 gallons for the pump to which it
is connected to. The tank vents are provided with flame arresters. The oil
spillage enclosures on each pump motor, drain piping and collection tank
have been evaluated and certified by the design organization, Gilbert /
Comonwealth, in letters dated April 12, 1982 and May 20, 1985, to remain
functional following a safe shutdown earthquake. The licensee's QC office
has conducted a detailed inspection of the collection system for reactor
coolant pump "A" and verified that the installed system is in conformance
with the construction drawings, except for several minor discrepancies which
have been reviewed by the licensee and the designer and found to be accept-
able. The oil collection systems for pumps "B" and "C" are to be inspected
by the licensee to verify that these are also in conformance with the design
requirements. These inspections are to be completed prior to startup from
the next refueling outage.
Within the areas examined, no violations or deviations were identified.
_ _. _ _ -
_ - _ _ _ _ .
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7. Compliance to 10 CFR 50 Appendix R Section III.J. Emergency Lighting l
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Emergency lighting units equipped with at least an 8-hour battery power l
> supply are required to be provided in all areas required for operation of l
safe shutdown equipment and in access and egress routes thereto.
The inspectors reviewed the licensee's evaluation of the plant's emergency
lighting in Appendix R Audit Support Package Volume 22 Section 8-3. Approx-
imately thirty 8-hour emergency lighting units are presently provided.
However, the licensee's evaluation identified.the need for approximately 40
additional lighting units and the relocation of three existing lighting
units. Approximately 20 units are required to provide illumination for
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equipment needed for manual shutdown operations as a result of the
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Appendix R reevaluation, and approximately 20 units are required for egress
and access to this equipment. Several other plant areas presently are not
provided with emergency lighting and will either require lighting or devia-
tion requests to permit the use of portable lights for reading gauges,
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verification of valve alignment, or to supplement the existing access
lighting.
During the plant tour the inspectors verified that emergency lighting was
not provided for the following plant areas as required by Appendix R: 388'
of auxiliary building at charging pumps, 412' of intermediate building, east
and west penetration rooms on 412' and 436' elevations, 424' of auxiliary
building, 436' auxiliary building filter galley, 485' of auxiliary building,
427' of diesel generator building, turbine building areas, portions of
service water pump building, and outside yard areas. This discrepancy is
identified as Unresolved Item (395/85-26-12), Inadequate Number of 8-Hour
Battery Powered Emergency Lighting Units Provided for Areas Needed for
Operation of Safe Shutdown Equipment, pending resolution of the licensee's
Appendix R reanalysis by NRR.
8. Fire Protection and Prevention Program
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a. Structural Fire Barriers
A general walkthrough inspection was conducted of the walls, floors,
, ceiling and associated penetrations of the following plant areas to
verify that 3-hour fire resistance construction is provided between
adjacent fire areas as required:
Fire Area Description
IB-2 Train A Battery Room
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IB-3 Train A Battery Charger
IB-4 Train B Battery Charges
IB-6 Train B Battery Room
IB-7 Water Chiller Pump Room
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IB-8 HVAC Equipment C Water Chiller
TB-1 Turbine Driven Feed Water Pump Room
IB-12 Train B Speed Switchgear Rocm
IB-13 Train C Speed Switchgear Room
1B-14 CREP Room
IB-16 ESF Switchgear Room
Room Cooling Units - Train A
IB-17 ESF Switchgear Room Cooling Units - Train B
IB-20 Train A Switchgear Room
IB-22.2 Train B S:witchgear Room
18-23.3 Train A Speed Switchgear Room
DG-1 Diesel Generator A
DG-2 Diesel Generator B
The walls, floors, ceiling and penetrations of the above fire areas
appear to meet the required fire resistance rating, except for fire
area IB-20. This room cannunicated with fire area IB-25.6 on the below
elevation below through an open floor penetration, approximately
6-inches by 30 feet in size, along the north wall of the switchgear
room. The lack of protection for this floor penetration is a failure
to meet Technical Specification Section 3.7.10 and is identified as
Violation Item (395/85-26-13), Inadequate Fire Barrier Between Fire
Areas IB-20 and 1B-25.6.
b. Raceway Fire Barriers
An inspection was made of the following raceways to verify that each
raceway was provided with the 3-inch "Kaowool" wrap to provide a
nominal 1-hour fire resistant rating:
Fire Zones Raceway No. Function
AB-19 1012 "B" Power Cable for B and C
AB-1.4 & 1.9 4065 "B" Control Cable for B and C
CB-12 4284 All A Train Power
IB-23.2 XX-3115B Component Cooling Pump B Power
IB-11 XX-3116A Component Cooling Pump A Power
AB-1.9 CSM1A Charging / Safety Injection
Pump A Power
AB-1.4 CSM11B Chargir.g/ Safety Injection
Pump B Power
CB-10 ESM 171B Train B 480V Power
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IB-25.6 ESM 171B Train B 480V Power
18-25.1 SWL 11A Service Water Booster Pump
Power
AB-1.9 VLC4B Charging / Safety Injection
Pump B Cooling Power
IB-23.2 VUL 34B Chilled Water Pump B Power
IB-16 and IB-17 VLC'44B Cooling Fan Power for B
Train Switchgear Room
The barriers were found to be in place and appeared to be properly
, installed, except the barrier for raceway no. VUL34B in Fire Zone
18-23.2 was not complete, in that portions of the conduit raceway was
exposed and thus not functional. This is identified as Violation Item
(395/85-26-14), Nonfunctional Fire Barrier for Raceway VUL34B in Fire
Zone 18-23.2. Also, the structural supports for the raceways enclosed
within the fire barriers have not been provided with protec', ion to
provide a fire resistance rating equivalent to the fire resistance
rating of the barriers. The licensee is preparing an analysis which is
to provide justification for the lack of this protection. A prelimi-
nary review of the licensee's incomplete analysis indicates that
sufficient data is to be provided to justify the lack of protection for
these structural supports. This item is identified as Inspector
Followup Item (395/85-26-15), Review Licensee's Analysis for Unpro-
tected Cable Tray Supports, and will be reviewed during a subsequent
NRC inspection following completion of the licensee's analysis.
The inspectors performed an evaluation to determine the adequacy of the
horizontal "M" board fire barrier provided over the "A" train service
water booster pump on elevation 412'-0" of the intermediate building to
provide protection equivalent to that of the one-hour barrier require-
ment of Appendix R Section III.G. By letter dated June 1,1981, the
licensee requested an exemption for the following:
(1) Component cooling water pump area, separation between pumps B and
C does not meet Appendix R. s
(2) HVAC equipment water chiller pump area, separation between pumps
does not meet Appendix R.
(3) Partial automatic fire suppression provided in the auxiliary and
intermediate buildings.
-(4) Partial fire detection provided in the auxiliary and intermediate
buildings.
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The licensee's June 1,1981 letter identified the rationale for their
exemption request and identified the "M" board barrier as a fire
protection feature which supports the above exemption requests.
Howevar, the licensee's June 1, 1981 letter did not specifically ask
for exemption to the technical requirements of Appendix R with regard
to the service water booster pump area. Therefore, safety evaluation
report supplement no. 4 dated August 1982, granted the licensee's
request to deviate from the Appendix R Section III.G requirement for
only those areas identified above.
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The horizontal "M" board fire barrier provided over the "A" Train
service water booster pump is supported by unprotected rod hangers and
a steel uni-strut frame assembly. This non-rated fire barrier design
was provided to separate the "A" Train pump from redundant "B" train
circuits routed in overhead raceway near the ceiling of fire zone
18-25.1.
The in-situ fire load for fire zone 1B-25.1 is 43,000 BTV/FT2 with a
total BTU content of 471,145,000 BTVs. Area sprinkler protection and
fire detection capabilities are provided above and below the barrier
assembly. In addition, fusible type water spray nozzles are provided
for the cable tray stacks in the overhead. However, the area sprinkler
protection installed in the ceiling overhead is obstructed by piping,
electrical. raceway and HVAC ducting. The sprinkler design does not
meet with the design guidance of NFPA-13, in that the system does not
compensate for significant obstructions and overlapping obstructions
exceeding 48 inches. In the event of an exposure fire in this area,
the sprinkler response to the fire condition could be delayed due to
the sprinkler obstructions. This, in conjunction with the nonfire
rated structural steel supporting the "M" board barrier, could jeopar-
dize the fire barrier design by causing structural deformation to the
barrier support system. The failure of the barrier support system
could cause both redundant trains of shutdown systems to be damaged by
fire. The licensee contends that this barrier design was found accept-
able as documented by their Jure 1,1981 letter. Therefore, this item I
is identified as Unresolved Item (395/85-26-16), Verification That the I
"M" Board Fire Barrier was Reviewed and a Dcviation was Granted for
this Plant Condition by NRR.
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c. Fire Watch
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During the licensee's Appendix R reanalysis two areas were identified
in which the need for a roving fire watch were required. SCE&G's
letter of May 29,1985, from 0. W. Dixon, Jr., SCE&G to H. R. Denton,
NRC/NRR stated that a roving fire watch was to be provided for Fire
Areas IB-25/ Room 1202, (intermediate building 412' elevation) and CB-12
(control building cable chase, room 3603).
The inspector (s) reviewed the licensee's fire watch program. Nuclear
Education and Training Group Manual, Attachment X indicates the train-
ing required for fire watch personnel. Training records for four of
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the fire watch personnel were reviewed. These personnel had received
the required training within the past twelve months.
The fire watch log data for May 29-31 and June 1-2, 1985 was reviewed.
It was noted that the log did not specify that room IB 1202 was covered
by the roving fire watch as stipulated by the above May 29, 1985
letter. This item is identified as Deviation Item (395/85-26-17),
Failure to Conduct Fire Watch Patrol for Fire Area 18-25. Fire watch
patrol was provided for the other areas indicated by the above May 29,
1985 letter.
d. Fire Brigade Drill
During this inspection, the inspectors witnessed an unannounced fire
brigade drill. The fire scenario was a fire in the cable spreading
room, fire area CB-15 on control building elevation 448'-0", the
initial fire scenario condition inside the room upon the arrival of the
fire brigade leader was heavy fire involvement in the cable trays below
the termination cabinets with heavy smoke conditions inside the room.
In addition, the sprinkler protection inside the room had operated;
however, the system was not effectively controlling and or suppressing
the fire. Five fire brigade members, in full protective clothing and
self-contained breathing apparatus, responded to the fire and placed
two.11-inch hose lines in service on the fire in approximately 25
minutes. Based on the drill / fire scenario, it was the inspectors'
observation that additional fire brigade training emphasis was needed
in ventilation, hose deployment, breathing apparatus donning, and
salvage techniques.
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