ML20137F605

Insp Rept 50-333/85-20 on 850617-21.Violation Noted:Fire Barrier Walls Between Control Room & Relay Room Found to Contain Penetrations W/Nonrated Seals

ML20137F605
Person / Time
Site:	FitzPatrick
Issue date:	08/13/1985
From:	Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137F568	List: ML20137F565 ML20137F586 ML20137F605
References
50-333-85-20, NUDOCS 8508270016
Download: ML20137F605 (19)

See also: IR 05000333/1985020

Text

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/ U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 85-20

. Docket No. 50-333

, License No. DPR-59 Priority -

Category C

Licensee: Power Authority State of New York

James A. FitzPatrick Nuclear Power Plant

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P. O. Box 41

Lycoming, New York 13093

Facility Name: James A. FitzPatrick Nuclear Power Plant

Inspection At: Scriba, New York

Inspection Conducted: June 17 - 21, 1985

i Inspectors: 9) ~

l]uC. /.3 /4 W

'A. Krasopdulos, Reactor Engineer da te'

Also. participating in the inspection and contributing to the report were:

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T. Chandrasekaran, Auxiliary Systems Branch NRR

.A. Singh, Auxiliary Systems Branch, NRR

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A. Coppola, Mechanical Systems Specialist, BNL

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H. Thomas, Electrical Systems Specialist, BNL

l P. Koltay, Senior Resident Inspector, Region I

D. Kubicki, Chemical Engineering Branch, NRR

S. West, Chemic 1 eering Branch, NRR

' Approved b'y:

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C. J.fAnderson, Chief, Plant System date

. Section, DRS

j Inspection Summary: Inspection on June 17-21, 1985 (Report No. 50-333/85-20)

Areas Inspected: Special, announced team inspection of the licensee's efforts

to comply with the requirements of 10 CFR 50, Appendix R, Sections III. G, J

and 0, concerning fire protection features to ensure the ability to achieve and

maintain safe shutdown in the event of a fire. The inspection involved 272

inspector-hours onsite and 36 inspector hours in-office by a team consisting

of 8 inspectors.

Results: One siolation was identified (Failure to maintain separation of re-

dundant components). Seven items remained unresolved at the end of the inspec-

tion. See Attachment 3 for a summary of the inspection findings.

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8500270016 850821

PDR ADOCK 05000333

G PDR

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DETAILS

1.0 Persons Contacted

1.1 Power Authority of the State of New York (PASNY)

B. Bernstein, Plant Engineer Technical Services

R. Burns, Vice President BWR Support

• R. Converse, Superintendent of Power

M. Cass, Licensing Engineer

M. Curling, Training Superintendent

F. DePoalo, Project Support Engineer

J. Ellmers, Senior Nuclear Licensing Engineer

• W. Fernandez, Operations Superintendent

N. Garofalo, Senior Plant Engineer Technical Services

• H. Glovier, Resident Manager

• J. Gray, Jr., Director Nuclear Licensing

• L. Guaquil, Director Project Engineering

R. Heath, Fire Protection Supervisor

• D. Holliday, Senior Plant Engineer

• L. Jonston, QA Supervisor

J. Kerfiev, QA Supervisor

R. Locy, Waste Management Superintendent

S. Muckherjee, Supervisory Engineer

1.2 Licensee Contractors - Stone and Webster Engineering Corp (SWEC)

EMP Inc.

S. Burke, Fire Protection - EMP Inc.

D. Cirrone, Project Manager - SWEC

A. Faramarzi, Systems Engineer - EMP Inc.

>

S.-Kohr, Power Engineer - SWEC

R. Tworek, Senior Electrical Designer (SWEC)

R. Ulftstam, Fire Protection Supervisor - SWEC

1.3 Nuclear Regulatory Commission (NRC)

• H. Abelson, Project Manager - ORB

• A. Luptak, Senior Resident Inspector (Acting)

• Denotes those present at the exit meeting.

'2.0 Purpose

This inspection was to ascertain that the licensee is in conformance with

10 CFR,50, Appendix R, Sections III. G, J, and 0, including exemptions ap-

s proved by the Office of Nuclear Reactor Regulation (NRR).

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3.0 Background

10 CFR 50.48 and 10 CFR 50 Appendix R became effective on February 17,

1981. Section III.G of Appendix R requires that fire protection be

provided to ensure that one train of equipment necessary to achieve and

maintain safe shutdown remains available in the event of a fire at any

location within a licensed operating facility. For hot shutdown condi-

tions, one train of the systems necessary must be free of fire damage

(III.G.1.a). For cold shutdown conditions, repair is allowed using in

place procedures and materials available onsite with the provision that

cold shutdown be achievable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the initiating event

(III.G.1.b).Section III.G.2 lists specific options te provide adequate

protection for redundant trains of equipment located outside of the pri-

mary containment. These options are:

Separation by a fire barrier having a three hour rating (III.G.2.a).

• Separation by a horizontal distance of at least 20 feet with no in-

tervening combustibles and with fire detection and automatic fire

suppression installed in the fire area (III.G.2.b).

Enclosure of one train in a fire barrier having a one hour rating in

addition to having fire detection and automatic suppression installed

in the fire area (III.G.2.c).

If the protection required by Section III.G.2 is not provided or the sys-

tems of concern are subject to damage from fire suppression activities,

Section III.G.3 of the rule requires that an alternate or dedicated shut-

down capability be provided which is independent of the area of concern.

Any alternate or dedicated system requires NRC review and approval prior

to implementation.

For situations in which fire protection does not meet the requirements of

Section III.G, however, such protection is deemed to be adequate by the

licensee for,the specific situation, the rule allows the licensee to re-

quest an exemption on a case-by-case basis. Such exemption requests are

submitted to the NRC for review and approval and must be justified by the

licensee on a technical basis.

4.0 Correspondence

All correspondence between the licensee and the NRC concerning compliance

with Section III.G, J, and 0 was reviewed by the inspection team in pre-

paration for the site visit. Attachment I to this report is a listing of

the correspondence reviewed.

5.0 Post-Fire Safe Shutdown Capability

5.1 Systems Required for Safe Shutdown

Safe shutdown is initiated from the control room by a manual scram of

the control rods. Reactor scram can also be initiated manually by

deenergizing the reactor protection system buses. Reactor coolant

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inventory can be maintained by either the reactor core isolation

cooling system (RCIC), the high pressure coolant injection system

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(HPCI); or the low pressure coolant injection system (LPCI) or the

core spray system (CS) in conjunction with the automatic despressuri-

zation system (ADS). Reactor coolant system pressure is controlled

by the Safety Relief Valves (SRV) either automatically or manually.

Decay heat removal is provided by either the RHR in the shutdown

cooling mode; or the LPCI or the CS in conjunction with the RHR in

the suppression pool cooling mode.

The support systems required for safe shutdown include the RHR ser-

vice water system, the emergency service water system, the essential

ventilation systems, the emergency diesel generators and the essen-

, tial electrical distribution system. The above systems are monitored

and controlled from the ntrol room or the remote shutdown panel and

local control stations.

5.2 Alternative Safe Shutdown Areas

The licensee has committed to provide alternative safe shutdown capa-

bility in accordance with the requirements of Section III.G.3 and -

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III.L of Appendix R to 10 CFR 50, for the Main Control Room, the Re-

lay Room and the Cable Spreading Room.

5.3 Remaining Plant Areas

All plant areas not provided with an alternative safe shutdown system

are required to be in compliance with the requirements of Section

III.G.2 of Appendix R unless an exemption request has been approved

by the Commission.

The licensee requested a number of exemptions to certain provisions

of Appendix R which were evaluated and granted by the Commission. The

enclosed Attachment 2 lists the requested exemptions and the Com-

mission's date of approval.

5.4 Alternative Safe Shutdown Systems

The alternative shutdown capability consists of a remote shutdown

panel (25 RSP) and three auxiliary shutdown panels 25 ASP-1, 25 ASP-2

and 25 ASP-3 which contain local control and isolation switches. The

remote shutdown panel is located in the reactor building on elevation

300 feet. The alternative shutdown capability utilizes seven safety

relief valves and the low pressure coolant injection system (LPCI).

The safety relief valves are controlled from the manual automatic

depressurization system (ADS) panel located in the reactor building.

The LPCI and the supporting RHR service water pump are controlled

from the remote shutdown panel. The instrumentation for the

alternative shutdown capability is provided at the remote shutdown

panel and a local instrument rack. The power supply for the

alternative shutdown equipment is supplied by the emergency diesel

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generator ("B" train only). The emergency diesel generators are

manually isolated from the fire areas and locally started by breakers

and controls provided in the local control panel located in the

emergency diesel generator switchgear room. The design of the remote

shutdown panel and the ADS panel includes control / isolation swi+ches

which when activated will electrically isolate the panel from tne

Control Room, Cable Spreading Room and Relay Room and will transfer

control of the shutdown equipment to the panels. A fire at the re-

mote shutdown, the ADS, or any of the auxiliary shutdown panels will

result in loss of control for only the equipment controlled from the

panel. One train of systems needed for safe shutdown will be avail-

able and controlled from the main Control Room.

6.0 Inspection Methodology

The inspection team examined the licensee's capabilities for separating

and protecting equipment, cabling and associated circuits necessary to

achieve and maintain hot and cold shutdown conditions. This inspection

sampled selected fire areas which the licensee had identified as being in

compliance with Section III.G.

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The following functional requirements were reviewed for achieving and

maintaining hot and cold shutdown:

• Reactivity control

Pressure control

• Reactor coolant makeup

• Decay heat removal

• Support systems

• Process monitoring

The inspection team examined the licensee's capability to achieve and

maintain hot shutdown and the capability to bring the plant to cold

shutdown conditions in the event of a fire in various areas of the plant.

The examination included a review of drawings, safe shutdown procedures

and other documents. Drawings were reviewed to verify electrical inde-

pendence from the fire areas of concern. Procedures were reviewed for

general content and feasibility.

Also inspected were fire detection and suppression systems and the degree

of physical separation between redundant trains of Safe Shutdown Systems

(SSSs). The team review included an evaluation of the susceptibility of

the SSSs to damage from fire suppression activities or from the rupture or

inadvertent operation of fire suppression systems.

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The inspection team examined the licensee's fire protection features pro-

vided to maintain one train of equipment needed for safe shutdown free of

fire damage. Included in the scope of this effort were fire area bounda-

ries, including walls, floors and ceilings, and fire protection of open-

ings such as fire doors, fire dampers, and penetration seals.

The inspection team also examined the licensee's compliance with Section

III.J, Emergency Lighting.Section III.0, 011 Collection System for Re-

actor Coolant Pump is not applicable to the licensee since the containment

is inerted during normal operations.

7.0 Inspection of Protection Provided for Safe Shutdown Systems

7.1 Protection in Various Fire Areas

The team reviewed the protection provided to SSSs in selected fire

areas for compliance with Appendix R, Sections III.G.1, 2 and 3.

The following fire areas were inspected:

RB-1E Reactor Bldg. Crescent Area-East

RB-1W Reactor Bldg. Crescent Area-West

RB-1A Reactor Bldg.

RB-1B Reactor Bldg.

RB-1C Reactor Bldg.

CR-1 Control Room

RR-1 Relay Room

CS-1 Cable Spreading Room

MG-1 Motor Generator Room Elev. 300'-0

AD-1 Administration Bldg. Elev. 272'-0

AD-2 Administration Bldg. Elev. 272'-0

AD-3 Administration Bldg. Elev. 272'-0

Administration Bldg. Elev. 286'-0

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AD-4

AD-5 Administration Bldg. Eley. 286'-0

AD-6 Administration Bldg. Elev. 300'-0

CT-1 Cable Tunnel West-Elev. 260'0"

CT-2 Cable Tunnel East-Elev. 260'0"

CT-3 Cable Tunnel 3, Elev. 286'-0

CT-4 Cable Tunnel 4, Elev. 286'-0

TB-1 Turbine Bldg.

RW-1 Radwaste Bldg. and Pipe Tunnel

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SH-1 Screen Well House-Elev. 272'-0"

SW-1 Switchgear Rm Elev. 272'-0" Turbine Bldg.

SW-2 Switchgear Rm Elev. 272'-0" Turbine Bldg.

FP-1 Foam Room Turbine Bldg.-Elev. 272'-0"

SG-1 Standby Gas Filter Room

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AS-1 Auxiliary Boiler Room

BR-1 Battery Room No.1

BR-5 Battery Room Corridor

EG-1 Emergency Diesel Generator Room

EG-2 Emergency Diesel Generator Room

EG-3 Emergency Diesel Generator Room

EG-4 Emergency Diesel Generator Room

EG-5 Emergency Diesel Generator Roc..

EG-6 Emergency Diesel Generator Room

SP-1 Service Water Pump Room (Train B)

SP-2 Service Water Pump Room (Train A)

The team did not identify any unacceptable conditions, except as

follows:

Inadequate Separation of Safe Shutdown Systems (SSS)

The team observed that spare conduit penetrations of the fire rated

walls in the Control Room, Cable Spreading Room and Relay Room were

scaled with pipe plugs that have not been tested for fire protection

service.

To maintain fire barrier integrity, openings in the fire barrier

walls should be sealed with non-combustible materials qualified by

tests that are comparable to tests used to rate fire barriers.

Section III.G.2 of Appendix R to 10 CFR 50 requires that redundant

SSS and associated non safety circuits that could prevent operation

or cause maloperation of the SSS, shall be separated by either a fire

barrier having three hours rating or shall be separated by a horizon-

tal distance of 20' feet with no intervening combustibles with area

suppression and detection or shall be separated by enclosing one of

the systems within an one hour barrier with area suppression and

detection. The licensee also identified cables in both East and West

Cable tunnels from redundant SSS to be within the same fire area

without proper separation. These cables may effect power to the

ventilation dampers of the Emergency Diesels. Failure of the cables

rnay result in damper closure which could result in excessive diesel

room temperatures and possible everheating and loss of the diesels.

The cables were noted to be located within close proximity to the

cables of the opposite train. The licensee explained, that the spare

conduit penetration seals were reviewed and the decision to accept

unrated seals was made after an informal consultation with the

. licensee's insurer. The licensee also explained that the unprotected

cables in the cable tunnels, was an oversight identified, during a

third party review of the systems. The licensee established fire

watches as interim compensatory measures in the areas identified by

the team as having degraded fire barriers or inadequate separation

and committed to restore the fire barriers to operable status. The

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spare conduit penetrations sealed with unrated plugs and the

redundant safe shutdown conduits and cables located within the same

fire areas constitute a violation of Appendix R Section III.G.2.

(50-333/85-20-01)

Fire Detection System not per NFPA Requirements

The licensee by letter dated January 11, 1977, subject, J. A.Fitz-

Patrick Fire Protection Program Evaluation committed to provide de-

tection systems that conform to the requirements of NFPA standard

No. 720. The current NFPA standard No. 72D requires that fire de-

tection devices shall be listed, for the protective signaling purpose

for which they are used. Listed equipment is equipment included in a

list published by an organization acceptable to the " authority having

jurisdiction" in this case NRC.

The NRC routinely accepts equipment listed for fire protection ser-

vice by either the Underwriters Laboratories (UL) or approved for

such service by Factory Mutual (FM). The team in reviewing documents

furnished by the licensee determined that the detectors used to

actuate the water curtains in the reactor building are not listed.

The licensee committed to provide NRC with documentation or proof

that the installed detectors are comparable to similar devices listed

by a listing organization. This item is unresolved pending review of

the evaluation performed by the licensee. (50-333/85-20-02)

Sprinkler System Installation not per National Fire Protection

Association (NFPA) Requirements

The licensee by letter dated January 11, 1977, subject, J. A. Fitz-

Patrick Fire Protection Evaluation committed to provide sprinkler

systems that as a minimum conform to the requirements of NFPA stand-

ards No. 13 and 15.

The team observed that the water spray nozzles of the cable tray de-

luge system located in the East and West cable tunnels are designed

to protact wall and wir.dow openings, not electrical trays. Also in-

some cases the sprinklers appeared to be misdirected for the proper

coverage of the cable trays.

The above findings are not in conformance with the current NFPA

standards.

The licensee explained that the sprinkler design and installation in

the areas identified above are in conformance with the applicable

NFPA standards in existence at the time the plant was built.

Because these standards were not available for review by the team,

the licensee committed to obtain these standards and make an evalua-

tion of the existing installation vs. the NFPA requirements. The

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licensee also committed to assess the effectiveness of the spray

pattern of the nozzles installed in the East and West cable tunnels.

The above constitute an unresolved item pending review of the actions

taken by the licensee. -(50-333/85-20-03)

Functional Testing of Fire Dampers

As a result of a recent 10 CFR 21 notice that fire dampers manufac-

turered by Ruskin Corporation may fail to close under normal system

flow, the team expressed a concern that similar dampers at this fact-

lity may not perform properly.

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The licensee agreed with the team's concern and immediately function-

ally tested all Ruskin dampers of the facility. From the dampers

that were tested one failed to close, and the licensee immediately

repa red it.

The licensee committed to establish a program to functionally test

under air flow conditions all the dampers of the facility every 18

months.

This is an unresolved item pending review of the testing program and

testing procedures. (50-333/85-20-04)

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7.2 Safe Shutdown Procedures

7.2.1 Procedure Review

The team reviewed the following interim safe shutdown

procedures:

Operation During Plant Fires - No. F-A0P-28, Revision

1, June 17, 1985.

Plant Shutdown from Outside the Control Room -

No.F-A0P-43, Revision 3, June 14, 1985.

The scope of this review was to ascertain that the shutdown

could be attained in a safe and orderly manner, to deter-

mine the level of difficulty involved in operating equip-

ment, and to verify that there was no dependence on repairs

except as noted below for achieving hot shutdown. For

review purposes, a repair would include installing electri-

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cal or pneumatic jumpers, wires or fuses to perform an ac-

tion required for hot shutdown. For cold shutdown, repairs

are allowed using in place procedures and materials avail-

able onsite with the provision that cold shutdown be

achievable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with or without offsite power.

Procedure F-A0P-28 is used to determine which of the exist-

ing plant emergency procedures would be utilized to achieve

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safe shutdown for a fire anywhere in the plant, except for

a fire in the Control Room, Relay Room and Cable Spreading

Room. This procedure contains a fire area list, and pro-

vides information to operators for system availability such

as possible loss of systems in the fire area, available

backup systems and required operator actions for a fire in

a.given area.

For a fire in the Control Room, Relay Room and Cable

Spreading Room procedure F-A0P-43 is used, to achieve safe

shutdown, utilizing the Alternative Shutdown Systems

described in Section 5.4. This procedure is an interim

procedure and will be revised once the modifications re-

sulting from the response to I.E. Information Notice (IN)

85-09 " Isolation Transfer Switches and Post Fire Shutdown

Capability" are implemented.

IN 85-09 alerted licensees about the possibility of a fire

in the Control Room disabling the operation of the plant's

alternate shutdown systems by damaging the transfer cir-

cuits between the main control panel and the alternate

shutdown panels. The licensee determined that this pos-

sibility exists at the FitzPatrick Plant and responded to

IN 85-09 by submitting a plan, in the form of an exemption

request, for interim and permanent corrective actions. The

exemption requested, was granted to the licensee by the

Commission, in a letter dated May 6, 1985. This was based

on the commitment, to provide a fire watch in the control

room and provide the capability to replace fuses as needed

in the interim. The permanent corrective action is the

addition of redundant fuses in the circuits involved for

which the schedular exemption was requested.

Based on the foregoing items the team did not identify any

unacceptable conditions in the review of the interim safe

shutdown procedures except as follows:

Exemption Request To Allow Temporary Core Uncovery

10 CFR 50 Appendix R Section III.L.b requires that the

reactor coolant makeup function shall be capable of main-

taining the reactor coolant level above the top of the core

during and subsequent to, shutdown function.

The current licensee's emergency shutdown procedures for a

fire in the Control Room Cable Spreading Room and Relay

Room require activation of the ADS for reactor depressuri-

zation and LPCI system initiation for coolant injection.

These procedures must be implemented promptly, in order not

to allow core uncovery. The licensee in order to gain

flexibility and to allow the operators to examine all

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shutdown options has applied for an exemption from the

above mentioned Appendix R requirement. The exemption re-

quest dated June 14, 1985, cites the results of certain

analysis, that justify an alternate shutdown scenario which

allows for the core to be uncovered for a short time

period. This item remains unresolved pending NRC's evalu-

ation of the licensee's exemption request.

(50-333/85-20-05)

7.2.2 Procedure Walk-Through

The team walked through selected portions of the procedures

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to determine that shutdown could be attained in an orderly

and timely fashion. The walk-through was accomplished by

using 4 operators and the shift supervisor.

A scenario for a Control Room fire was established and the

operators proceeded to simulate the steps described in the

procedure. All steps were simulated in order to demon-

strate feasibility, timely response to the emergency, abil-

ity to communicate etc.

The walk-through began at the Control Room and all steps

required for hot shutdown were completed in less than 45

minutes.

No unacceptable conditions were identified except as

follows:

Difficult Access of Fuse Box for Fuse Replacement

During a simulated attempt to replace fuses the team ob-

served that fuses located high on the fuse panels may be

inaccessible to the operators. The licensee agreed with

the team and committed to review all of the panels where

fuses may need replacement during an emergency and provide

means for access to the fuse boxes. The team also observed

that the box containing spare fuses, ear phones etc. near

Auxiliary Shutdown Panel 25 ASP-2 is located in an area

where equipment from the box may be readily lost if

dropped. The licensee agreed and committed to provide an

additional equipment box in the vicinity of the panel. The

licensee committed to provide all of the above by July 19,

1985.

This is an unresolved item pending review of the licensee's

action. (50-333/85-20-06)

7.3 Protection for Associated Circuits

Appendix R,Section III.G requires that protection be provided for

, associated circuits that could prevent operation or cause

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maloperation of redundant trains of systems necessary for safe

shutdown. The circuits of concern are generally associated with safe

shutdown circuits in one of three ways:

• Common bus concern

• Spurious signals concern

Common enclosure concern

The associated circuits were evaluated by the team for common bus,

spurious signal, and common enclosure concerns. Power, control, and

instrumentation circuits were examined on a sampling basis for

potential problems.

7.3.1 Common B'us Concern

The common bus concern may be found in circuits, either

safety related or non-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 team examined, on a sampling basis, 4160V, 600V and

125V DC bus protective relay coordination. The licensee

presented sample coordination curves dated October 31,

1974, at the time of the audit. The team also examined, on

a sampling basis, the protection for specific instrumenta-

tion, controls, and power circuits, including the coordina-

tion of fuses and circuit breakers. The licensee plans to

perform relay setting at approximately 24-month intervals.

No unacceptable conditions were identified.

7.3.2 Spurious Signals Concern

ihe spurious signal concern is made up of 2 items:

False motor control and instrument indications can

occur such as those encountered during 1975 Browns

Ferry fire. These could be caused by fire initiated

grounds, short or open circuits.

Spurious operation of safety related or non-safety

, related components can occur that would adversely

, affect shutdown capability (e.g., RHR/RCS isolation

valves).

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The team examined, on a sampling basis, the following areas

to ascertain that no spurious signal concern exists:

Current transformer secondaries

i * High/ low pressure interfaces

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General fire instigated spurious signals

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The team determined that the licensee conducted an analysis

which. identified a number of high/ low pressure interfaces.

In order to protect against the possibility of spurious

actuation of high/ low pressure interfaces, the license is

1) removing power from some valves during normal operation

and 2) is utilizing isolation switches to enable the

operators to remove power when necessary. The current

transformer secondaries of concern are protected by the

installation of transfer switches which provide the

capability to isolate and short the secondaries.

Each fire area was analyzed to determine the impact of

general fire instigated spurious signals. The licensee

identified some cases which were resolved by isolations

such as "The removal of fuses".

No unacceptable conditions were identified.

7.3.3 Common Enclosure Concern

The common enclosure concern may be found when redundant

circuits are routed together in a raceway or enclosure and

they are not electrically protected or when fire can

destroy both circuits due to inadequate fire barriers.

A number of circuits, selected on a sampling basis, were

examined for this concern.

The common enclosure concern was satisfactorily addressed.

The redundant cables for divisions A and B are not run in

the same tray or conduits. In addition, all circuits are

protected vith coordinated circuit breakers.

No unaccep:eble conditions were identified.

8.0 Emergency Lighting

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10 CFR 50, Appendix R, Section III.J, requires that emergency lighting

units with at least an 8-hour battery power supply shall be provided in

all areas needed for operation of safe shutdown equipment and in access

and egress routes thereto.

The team examined the plant emergency lighting system to ascertain the

licensee's compliance with the above requirements.

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The team did not identify any unacceptable conditions except as follows:

Marginal Emergency Lighting Conditions

The team observed during a fire area " black-out" that the existing

emergency lighting system was marginally adequate to perform the necessary

operations on the shutdown panels. The licensee agreed and stated that

this condition was identified by a third party review of the system prior

to the arrival of the audit team on site. The licensee committed to pro-

vide additional lighting in the (4) shutdown panel areas within 45 days.

This is an unresolved item pending installation of the emergency lights.

(50-333/85-20-07)

9.0 Oil Collection System for Reactor Coolant Pumps

10 CFR 50, Appendix R, Section III.0, requires that the reactor coolant

pumps shall be equipped with an oil collection system if the containment

is not inerted during normal operation. As the containment in this plant

is inerted during normal operation, the above requirement does not apply

to this plant.

10.0 Quality Assurance

During the course of the inspection, the team reviewed several drawings,

the fire hazard analysis, fire protection modification packages,

procedures, and other fire protection documents. The scope of this review

included verification of their technical adequacy, appropriate reviews,

design and procurement controls, and other Quality Assurance requirements

for the licensee's fire protection program. Except as noted in the

previous section of this report, the team did not identify any other

unacceptable conditions.

11.0 Unresolved Items

Unresolved items are matters for which more information is required in or-

der to ascertain whether they are acceptable, violations, or deviations.

Unresolved items are discussed in Section 7.1, 7.2 and 8.0.

12.0 Conclusions

The significant findings of this inspection are summarized as follows:

One violation from an Appendix R requirements to provide separation

of safe shutdown components and associated circuits.

Seven items remained unresolved at the end of the inspection as

mentioned in Section 11.0 above.

Except as above, no other unacceptable conditions were identified.

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1

13.0 Exit Interview

, The inspection team met with the licensee representatives,' denoted in

, Section 1.0, at the conclusion of the inspection on June 21, 1985, and the

team leader summarized the scope and findings of the inspection at that

, time.

l The team leader also confirmed with the licensee that the report will not

contain any proprietary information. The licensee agreed that the

inspection report may be placed in the Public Document Room without prior

.t

licensee review for proprietary information (10 CFR 2.790).

, At no time during this inspection was written material provided to the

,

licensee by the team.

.

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ATTACHMENT 1

DOCUMENT REVIEW LIST

January 11, 1977 Letter from Licensee to NRC commits to meet Section B of

APCSB 9.5-1 Appendix A

February 9,1978 Internal NRC Memorandum regarding Fire Protection Review -

Require Additional Information

May 23, 1978 Licensee Letter to NRC - Licensee will provide additional

information by June 19, 1978

October,1980 Safe Shutdown Analysis

February 4, 1981 Internal BNL Memorandum - Telephone Conference on January

21, 1981

February 19, 1981 BNL Letter to Chief of Chem. Branch - Interim Report Post

Fire Capability

- February 24, 1981 NRC internal memorandum - Licensee does not meet

Section III.G and L of Appendix R.

March 19,-1981 Licensee Letter to NRC - Request for Scheduler Exemption

Request

Appendix F - Response to NRC Staff's Generic Letter 81-12 -

Appendix G - Review Criteria for Spurious Valve Actuation

February 26, 1982 Licensee Letter to NRC - Appendix II to " Safe Shutdown

Analysis"

~ May 12, 1982 BNL Memorandun. to File - BNL Interim Report was never

transmitted to licensee

May 20, 1982 BNL Internal Memorandum to File - FitzPatrick does not meet

III.G.2, III.G.3 or III.L

,

June 11, 1982 BNL Letter to NRC " Draft" copy of Post Fire Safe Shutdown

June 14, 1982 BNL Memo to File - FitzPatrick does not intend to come in

for a meeting to discuss their February 26, 1982 submittal

c July 7, 1982 NRC Internal Memorandum to File - Minutes of Meeting in

-

Bethesda on June 29, 1982

!

( July 13, 1982 Licensee Report - A Reassessment of Conformance to Appendix

! R

I

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~_ . . -. . - _ . - _ _ . _ _ - - . _ .

.

.

2

November 2, 1982 BNL Report - Post Fire Safe Shutdown. Capability Report -

Based on July 13, 1982 submittal

November 16, 1982 NRC Internal Memorandum - Chem. Branch denies 4 exemption

request

December 14, 1982 Internal NRC Memorandum - SER III.G.3 and III.L of Appendix

R -

December 22, 1982 Internal NRC Memorandun - Chem. Branch again denies 4

exemption requests.

February 2, 1983 NRC Letter to Licensee - Informs licensee of appeal process

for exemption denials (Draft SER) ,

March 1, 1983 Licensee Letter to NRC - Licensee comments on the draft SER

April 26, 1983 NRC Letter to Licensee - Alternate Safe Shutdown Capability

SER

9

May 19, 1983 Licensee Letter to NRC - response to NRC letter dated

April 26, 1983

July 1, 1983 NRC Letter to Licensee grants exemption request for

Control Room and the Torus Room

Sept. 29, 1983 Internal NRC Memorandum grants all outstanding exemption

requests

February 1, 1984 NRC Letter to Licensee notification of granting of out-

standing exemptions

July 16,.1984 Licensee Letter to NRC - requests clarification of

exemption requests

! July 24, 1984 Licensee Letter to NRC - surveillance requirements for the

high pressure water fire protection system

January 11, 1985 NRC Letter to Licensee - Exemption Request Water Spray

System

March 15, 1985 Licensee Letter to NRC - request for schedular exemption

)

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.

ATTACHMENT 2

SUMMARY OF APPENDIX R EXEMPTIONS

. Exemption Request Description Date of Letter to PASNY

3 Phase AC and DC Power Circuits April 26, 1983

Fuse Pulling and Lifting Leads April 26, 1983

Control Room July 1, 1983

(automatic area wide suppression)

RB-1E and RB-1W February 1, 1984/

(zone interfaces at Elevs. 227'-6" and January 11, 1985

242'6")

RB-1E and RB-1W February 1, 1984/

(cable separation) January 11, 1985

RB-1E and RB-1A February 1, 1984/

(stairway from Elev. 227'6" to 272'-0") January 11, 1985

RB-1A and RB-1B February 1, 1984/

(zone interface on Elev. 272'-0") January 11, 1985

RB-1B and RB-1C February 1, 1984/

(zone interface on Elev. 300'-0") January 11, 1985

RB-1A and RB-1B February 1, 1984/

(zone interface on Eley, 300'-0") January 11, 1985

RB-1A and RB-1C February 1, 1984/

(stairway from Elev. 272'-0" to 300'-0") January 11, 1985

RB-1C and RB-IA February 1, 1984/

(stairway from Elev. 300'-0" to 326'-0") January 11, 1985

Torus Room July 1, 1983

(RHR valve separation)

RB-1B and RB-1A February 1, 1984/

(stairway from Elev. 300'-0" to 326'-0") January 11, 1985

.

.

ATTACHMENT 3

SUMMARY OF INSPECTION FINDINGS

Item Description Section Reference

Violations

50-333/85-20-01 Inadequate uncap separation of 7.1

safe shutdown systems

Unresolved Items

50-333/85-20-02 Fire detection systems not 7.1

per NFPA requirements

50-333/85-20-03 Sprinkler system installation

not per NFPA requirements

50-333/85-20-04 Functional testing of fire 7.1

dampers

50-333/85-20-05 Exemption request to allow 7.2

temporary core uncovery

50-333/85-20-06 Safe shutdown with inoperable

emergency diesel "B" system

50-333/85-20-07 Difficult access of fuse boxes 7.2

for fuse replacement

50-333/85-20-08 Marginal emergency lighting 8.0

<

conditions

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