ML20148C120
| ML20148C120 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/05/1988 |
| From: | Alden W PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin R NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8801250122 | |
| Download: ML20148C120 (1) | |
Text
.
i PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A PA.19101 (21518414000 January 5, 1988 Mr. R. E. Martin, Project Manager Project Directorate I-2 Division of Reactor Projects Attn: Document Control Desk U.
S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Appendix R Compliance, Peach Bottom Atomic Power Station
Dear Mr. Martin:
Enclosed is Inspection Report No. 87-30, dated December 4,
1987, regarding compliance with the fire protection requirements of Appendix R.
Note the circled material which discusses four open issues identified by the inspector.
The Region I inspector (Mr. A.
Krasopoulos) requested at the exit meeting that the Licensee solicit a position from NRR on these issues.
He suggested c meeting with Mr. Kudrich or Mr. Notley of NRR to obtain resolution.
It is PECo's position that we are in compliance with the regulations on these issues.
We would appreciate an opportunity to meet with the appropriate NRC Staff members to close taese unresolved items in a timely manner.
Please take the nececsary steps to arrange such a meeting.
W. M. Alden Director Licensing Section WCB:lc Attachment 8801250122 880105 gDR ADOCK05000g7 p60 g t
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NUCLEAR REGULATORY COMMISSION
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,c KING OF PRUSSIA, PENNSYLVANIA 19406 3N... 'e' DEC 0 8198, Y! * ^ ' ~ ^
DEC 0 41997 Docket Nos.
50-277 License Nos. DPR-44 50-278 DPR-56 h,.y gp
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Philadelphia Electric Company 9,i jd[,,
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Mr. J. W. Gallagher
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Vice President 9
'f Nuclear Operations 2301 Market Street
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Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
Combination Inspection Report Nos. 50-277/87-30 and 50-278/87-30 This refers to the routine safety inspection conduc*,ed by Mr. A. Krasopoulos of this office on October 19-23, 1987 at the Peach Bottom Power Station Units 2 and 3, Delta, Pennsylvania of activities authorized by NRC License Nos.
DPR-44 and DPR-56 anc to the discussions of our findings held by Mr. Krasopoules with Mr. D. Smith of your staff at 'ie conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region 1 Inspection Report which is enclosec with this letter. Within these arear, the inspection consisted of selective examinations of procedures and representative recorcs, interviews with personnel, and observatio 5 by the inspector.
i Based on the results of this inspection, it apoears that one of your activities was not conducttd in full compliance with NRC requirements, as set forth in the Netice of Violation, enclosed herewith ts Appendix A.
This violation has been categorized by severity level in accorcance with tne "General Staten'ent of Policy one Protecure for NR: Enforcemtnt Actions", 10 CFR Pc-t 2, Appe di/
(Enforcement Eclicy).
You are recuire: to respond to this 1(tter end in preparing your response, you should follow ne instrut.tions in Appendix A.
The deficiency identified in the Notice of Violation enclosed with this letter was identified during a previous inspection of your licensed activities on November 15, 1983, and was documented in the enclosure to our letter dated January 27, 1984 Your letter to this office dated February 23, 1984, stated that the norcompliance was caused by inadequate tracking systems.
You stated that the Station Superintendent issued a directive emphasi:ing the importan:e of participating in the training and made a commitment to maintain fire pro-tection training as a high priority item.
You also stated that the Operation Engineers staff will ensure that each member of the fire brigade has received the reovired training.
Fror our October 20, 1987 inspection it appeart that the stated corrective action were not effective since this item has recurred.
In your response to this letter, you should give particular attention to those actions taken or planned to ensure that the icentified item of noncompliance will be completely correctec and will not recur.
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Philadelphia Electric Company 2
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Your cooperation with us in this matter is appreciated.
Sincerely, VWV William V Johns.on, Acting Director Division of Reactor Safety
Enclosure:
1.
Appendix A, Notice of Violation 2.
NRC Region I Inspection Report Numbers 50-277/87-30 and 50-278/87-30 cc w/ encl:
Dickinson M. Smith, Manager, Pea:h Bottom Atomic Power Station John S. Kemper, Senior Vice President, Engineering and Production Thomas S. Shaw, Jr., Vice President, Production Troy B. Conner, Jr., Esquire W. H. Hirst, Director, Joint Generr. tion Projects Department, Atliitic Electric G. Leitch, iuclear Generation Manager Eugene J. wradley, Esquire, Assistant General Counsel (Without Report)
Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations W. M. Alcen, Engineer in Charge, Licensing Section i
Doris Poulsen, Secretary of harforc County Council
- Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resicent Inspector Com.onwealth of Pennsylvania 4
e
APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company
. Docket Nos.
50-277 Peach Bottom Atomic Power Station Units 2 and 3 50-278 Licence Nos. OPR-44 DPR-56 As e result of the inspection conducted on October 19-23, 1987 and in accordance with the "General Statement of Policy for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the following violation was identified:
10 CFR 50 Appendix R Section III.I.3.b. requires that fire brigade drills shall be performed at regular intervals with each fire brigade member participating in at least two drills per year.
Section~III.I.1.a. recuires'that initial and periodic refresher training be provided to all fire brigade members.
Contrary to the above, on 0:tober 20, 1987,. it was determined that at least lJ -
fire brigade members did not participate in the required two drills per year and five members did not attend either the initial or refresher tra'aing re-quired for brigade membershin. Also oli 0:tober 20, 1957, it was determined that a similar type of fire br(gade training ceficiency was identified.in 19E3 by NR as a violation and wt s aliewed :c recur in 1954, in 1955 and in 1956 as evicen:ec by :ne CA accits of ne fire origace trainir.; for ';ncse years.
This is a Severi 3 Level IV violation (Supplement I).
3 Pursuant to the provisions of 10 CFR 2.201, Philadel;nia Ele:tric Company is hereby recuir2d ec ',ubmit to this of fice withir thir;y cays of tne cate of 5
the letter whi:n transmitted this Notice, a writter statement or explanatten in reply, including: (1) tne corre:tive steos which have been taken and the results a:hieved; (2) corre::ive ste;5 wnich will be taken to av id further violations; and (3) the cate when full complian e will be a:nieved.
Wnere 90 d cause is shewn, consideration will be given to extending this resconse time.
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U.S. NUCLEAR REGULATORY COMMISSION REGION 1-Report No.
50-277/87-30 and 50-278/57-30 Docket No.
50-277/50-278 License No.
DPR-44 and DPR-56 Priority Category C
Licensee:
Philadelphia Electric Comoany 2301 Marte: Street Pn11aceiphia, Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station Units 2 and 3 Ir.spection At:
Delta. Pennsylvania Inspection Conducted:
October 19-23, 1987 Inspector:
DM&
lifh k ?
A. Kras6poUlos, keactof Engineer, DRS
/ cate Also participtting in the inspe:. ion and contributing to the report were:
K. Sullivan, ile:tri:a1 System Soe:ialist, ENL R. Hocer, Mec..anict.1 Systems Specialist, ENL 2 /7 Approved by:
/>r ' Am
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C. J? Anoerson, Cnisf, Plan 53 sten.
case See icn, ORS inste: tion Sumu ry:
- nsce:tien or 0::cber 19-22.1957, (Cembined Recer: N s.
50-277/57-30 an SC-275/E7-30).
ireas Insce::ed:
Special, announced team reinspection of the licensee's eff0rts te : mply witn :ne recuirements of 10 CFR 50, Appendix R, Sections II:. G, J, I and L, con:erning fire protection features to ensure the ability to a:hieve and maintain safe shu.00an in the even: ef a fire.
Resuits: One viciation was identified. Three items remained unresolved at the E cf the inspection.
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Details Persons Contacted 1.0 __
1.1 Philadelphia' Electric Company (PECo)
"R. Lees. Chief Electrical E
- neer
'E..ClarA, Site Administrative Engineer
'A. Denell, OA site Supervisor.
"C Swenson, Nuclear Operations
'D. Smith, Picnt. Manager "W. Soyer, Electrical Supervising Engineer
- D. Spamer, Electrical Engineer "W. Eirely, Licensing Engineer
- S.
Yuill, Fire Protection Coordinator
'G. Termine, Electrical Engineer
'W. Brady, Pe hanical Engineer
'C. Gerdes, Pecharical Engineer
- R. Dourte, QA Engineer "F. Adams, Engineering Designer
'G. Cambell, Engineering Designer
'R. Rock, Electrical Engineer
'D. Thompson, Eie:tri:al Encineer
.i
'D. Bre:Ler, Consultant (EEM)
'J. M:Cawley, Electrical Engineer
'M. Phillies, Public Service Els:t-i and Ga',
"R. Dell Angele, Enginet-irg Designer G. Mcriey, Supervising Me:nanical Engineer A. Melikian,.Corsuitant (EPM)
R. Ficf f, Censultant (EPM)
O. Brecken Censultant (EPM)
M. Lohr. Electrical Encineer J. P4::0 a, CA Engir.eer J. Ma-inu::1, Cersulttnt (GE)
M. Hamm:nc, Constru:tien Eagineer i
J. Cleary, Me:nani:ai Engineer l
1.2 Nv:leae Ee;ulatory Commission (N;C)
'T. Jennson, SRI
- E. Urbar., RI
'L. Myers, EI Den:tes inese present at the exit interview.
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3 2.0- Review of Previous Inspection Findinct Open (violation) 50-277/83-31-02 and 50-278/83-29-02:
Failure to meet the Accencix R Fire Bricace trainino-reovirements.
During the above referenced inspection performed in 1983 the NRC dettreined tnat the licensee's Fire Brigade training was deficient because training requirements were not implemented.
The deficiencies identified were the failure of brigade members to attend training meetings and f ailure to participate in the hands-on fire fighting practice.
The licensee in their annual and triannual fire protection program audits identified similar deficiencies during 1984, 1985, and 1986, calendar years.
During 1986, in audit No. AP86-121PL the licensee's audit team issued a Significant Nonconformance Report (SNCR) to the Superinten-dent - Operations because actions taken in the past failed to prevent recurrence.
The NRC in inspection 277/278/85-44 reviewed the licensee's corrective actions in this area but was unable to resolve the issue because tne licensee's corrective actions were inadecuate.
Io tssure the acequacy of the licensee's corrective actions, the inspector reviewed the following:
Attendance records for cuarterly training Attencance re:Ords for crill participation Atterdance records for hands-on practice initial training and ref resher instru: tion.
Tne intpe: tor also coserved a fire crill for training effectiveness, and reviewed the criil pro:edure.
From tne review of ne relevant fire brigace training co:uments and corresponcence, tne inspe:to* ceterrin9d the fei10 wing:
Tre records review cetermine: that at least 20 fire fighters did n0 carticioats in tne re:uirst two crilis per yea-and at least five did n0 attend the initial classr0cm and refresner instru: tion required by 10 CFR 50 A00encix R Se:ti0n III.I.
Ine inspe:t:r as:ertaine; in cis:vssions with licensee personnei that fire figniers res00nding to crills 00 n0: usually wear protective clothing er respiratory gear.
Only in less snan 20% of the crilis ce tne fire fignters use prete:tive eletning and respira:Ory a;;aratus.
During the crill odserved by tne ir.ste:ter, the brigade members were c: ached oy the :*ill :00-dinator and 101c wnat to d0.
Drilis performe: thus la:( realism and tne team practice conce:t is iest.
Inese training con: err.s were previously icentified by tne NRC and the licensee's own CA a:tivities, however, they were allowe: to re:ur.
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4 10 CFR 50 Appendix R Section III.I. recuires that the Fire Brigade train-ing program consists of initial classroom instruction followed by periodic instructions.
Fire brigade drills are recuired per 10 CFR 50 Appendix R Section III.I.3.
so that the fire brigade can practice as a team.
These drills shall be performed at regular intervals not to exceed 3 months with each member participating in at least two drills per year.
Each drill shall include an assessment of each Brigade member's conformance with the fire fighting procedures and use of fire fighting equipment including self contained breathing apparatus.
This is a violation of the above referenced Appendix R requirements (50-277/275-87-30-01).-
- ~3 r
~ Open (Unrescived Item) 50-277/84-40-0) and 50-278/84-19-01:
Visual check of Fire Campers coes nct provice assurance that Damcers wili cerform as recuiret.
1 The licensee's T.S. recuire that fire campers are inspected visually. The f
NRC raised the con:ern :nat a visual camper inspection does not previde assurance tnat tne fire dampers will be able to function properly during a fire.
This concern was raised because:
A) The licensee could not Ort-vice 0.0. recor s indicating that the fire dampe*s were crop tested after i
i installatien, as called 'nr in the engineerir; pa:kages; and, E) a recently
(
issued 10 CFR 21 i?tte* M ghlighted tne :oncern that the.ype of fi-e campers u,ed oy the licensee may not ciese uncer air flow :enditions.
The licensee accre ised :nis con:.er-cy revising the fire fighting strategy Oro:ecu*es givinc the fire Origace tne option 10 ce-ene gi:e tne ventilation syste s inv01ved. With no air flow cresumably the fire cam:ers wili :ltse.
Tne licensee's actions dic net satisfy the oricinal 1
GRC coq;ern for tre f0ilowing reasons:
l 1)
Ine ins:e:- r '. serve: a #iee tri; ace c ill.
A'.thes;n an atun:t was ma:e te ve-ify snetner ne fire jum:e: :: a*eas above tne nype-tneti:ai #i*e s:e e, n atter;; was ma:e to finc and isolate the ventliatten e:vi;reat.
2)
Assuming that the briga:e Oces turn off the air nandling units the-e is no assv-ance tna; the campers will fully close af ter the air han: ling u.its a re turned ef f.
Tnis is because the cam:ers may cr:;
I ar.d O'
- in a :a-tially open siti0n Oefere tne air fl0e is cut-:ff T0 assure that ne damrers ciese, tne licenses must p*0vice assu-ar:e
- ,at tne carre's will 010se un er nie fl0e or tnat ne air han
- lir; units are ce-energize: prior t cropping of tne camps s.
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This item continues'to be unresolved.
Considering the above concerns the inspector questioned the operability of the dampers.
Closed (Unresolved item) 50-277/84-40-02 and 50-277/84-19-02: Triannual aucit fincines not-formally resolved.
The NRC raised the concern that the American Nuclear Insurers (ANI) audits used by the licensee to satisfy the T.S. audit requirements may not satisfy the guicance issued by the NRC in Generic Letter (GL) 82-21.
This is because these audits are performed to satisfy insurance requirements.
The G.L. sets forth the scope of the triannual-audits which must be performed by an "outside" consultant.
The licensee committed to use an outside consultant henceforth to perform thest audits.
The inspector reviewec audit report AP 86-121PL which was perfcrmed by a qualified fire protection consultant.
This audit was the-first performed to satisfy the commitment. The review of this aucit did not identify any unacceptable conditions.
This item is resolved.
Closed (Viciation) 50-277/64-40-03 and 50-278/84-19-03:
Decraced fire cocr$ constitute a violation cf AcDencix R seoaration criteria.
The NRC identified several fire coors that were cegraded.
These fire d:0rs were ir, stalled in walls separating recuncar.: safe shut:own 00:p0-nents.
Ine deficiencies were:
an inability to close because of an atmospheri: Oressure cifferentials, Missing U.L. labels without Other docu entatien to assure the fire rating of the deer and celaminated co0rs.
The licensee's corre:tive actions in:lu:ed balancine of the ventilation systems so as no to affect co0r ciesure, replacing'camaged er uniateled i
c0 cts and revising a::e::an:e criteria cf tne c00r survetilan:e pre:e:u e.
Tne insce: Or surveye: :ne doors icentifie: in the violation and several Other fire cocrs and di: nc; identify any una::e::able 00nditi0ns.
ints item is rescivec.
Closed-(Unreseived items) 50-277/275/E6-08-01. 56-05-02. 56-05-03 86-0E-04, an: 56-0E-05:
Be:ause of incom:iete analysis ccm iian:e with Accen:ix R recuirements 0uic net ce verifiec.
The unresolved items listed a:0ve were identifie: during the ins:e::icn valicatin; ine 't:snave's 00m:11an:e with :ne 10 C~R 50 Arpendix R Se: icns lil G, III J, and III L. re0uirements.
These items were all administratively :icsed in 00nsiceration Of the NEC reins 0e:ti0n Of.;hese issues dis:vssed in Sections 4 thr0ugn 6 cf this inspe::icn re00rt.
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6 Closed (Violation) 50-277/86-26-02:
Fire watch-inconsistent with T.S.
recui rement s The NRC deterrined that T.S. 3.14.B.4 was violated when the fire watch,-
oosted as a compensatory measure for the inoperable Diesel Generator Room Cardox system, left the area under his watch.
The Cardox system was inoperable because the Diesel Generator Full Load Test Procedure ST S.1 requires that the Cardox system be by passed during the test of the diesels.
The NRC reviewed the licensee's corrective actions in this area which are as follows:
The licensee counseled the individual responsible for the event and also revised procedure ST S.I.to include a statement regarding the fire watch reovirements when the cardox system is defeated.
Insofar as this is an isolated incident, the preventive measures taken by the licensee are adequate.
This item is resolved.
3.0 Bacteround 30 CFR 50.48 and 10 CFR 50, Appendix R, became effective on February 17, 1931.
For Death Bottom Units 2 and 3, the applicable portions of this regulation are the Appendix R Sections III.G, "Fire i
Prote::icn of Safe Shutcown Capability," III.J, "Emergency Lighting,"
III.L. "Aiternative and Dedicated SFttdown Capability," and III.I Fire Srigade Training.
Se::i:n III.G of Accencix R reccires that fire trotection be proviced to ensu*e that cr.+ safe enutd:wn trair. remains available in tne even; ci a i
fire.
Section III.J recuires nat emergency lights are installed ir. all areas re:vired for safe snute wn pu poses and Se:: ion III.L see ifies recuiremer.ts for alternate shutcown capability.
Sectier. III.I specifies tne recuire: trcining fc? the Fire Erict.de.
Tne NRC curing March 17-21, 1956 terformed ar. inste: tion to verify tne litersee's cor:liance with the above re;uiremer.ts.
Du*ing that irsce:tien the estermination was ma:e tha the it:ensee's fa:iiities
- vid n0t be ade:U5:ely ins:e::ed te:aus.e tne su;;;* in; analyses, evaivations and pro:ecures were foun: to be in:0m:iete.
The li:enses subsecuently was requested :: Orovice the NR with a justification for continuin; coerations (J:0) af ter ne ideensee informed the NR: tha; abou 50 instan:es of Appendix R violations were icentified.
Tnis J 0 aise :or-itted :na: Unit 2 would be in : m:lian:e at the end cf the curren refusiin; ou; age and Unit 3 at :ne end a: their next refueiir; Outage.
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7 4.0 Post-Fire Safe Shutdown Capability 4.1 Systems Reouired for Safe Shutdown in the event of a fire concurrent with the loss of of fsite power, the following systems are used to provide the safe shutdown capability of the plant:
Hich Pressure Coolant Injection (HPCI) System Rea: tor Core Isolation (RCIC) System Automatic Depressurization (ADS) and non-ADS Safety Relief Valves (SRVs)
Residual Heat Removal (RHR) System-shutdown cooling mode, suppression pool cooling mode, and low pressure coolant l
injection (LPCI) mode l
Core Spray (CS) System Mich Pressure Service Water (HPSW) System Emergency Service Water (ESW) System l
Onsite A: Power Generation and Distribution System Onsite DC Power Generation and Distribution System Essential Ventilation Systems (for Emergency Diesel Rooms)
Safe shutdown is inititted from the contrcl roem by a manual scram cf the contrei rocs o-automatically by the reactor prceection l
syster Ine su;;0*: sys. ems reevired for safe shet Onn include the emergen:y service wat er sys,em (ESW) f:r ciesei generatur coolinc, hign p-essure service water syster (HPSW) for RHR neat exchanger cooling, ond te A: emergency power syster, ensite DC Emergency cower system and essential ventilation systems.
Ine licensee uses 'our methods, A, E, C and C to achieve safe Stut-00wn in :ne esert cf a fire Ine metbO: used cepen:s on ne 10:ation f tre f'-e.
Tre # ire ra:ard anclysis icentifies tne safe shute:wn retno: f:r es:n fi-e area.
inese metneds are cescrice: in tne felic in; :t-a;-a:ns.
Meino: A For Metned A, R:!: is use: to maintain reactor vessel coolant inven-to y.
RHR an: HOSW are used for su;;ression p001 ccolin; wnien is
-e:uired f:- :e:a;. heat rem: val.
Heat is transferred fr:m the vessel :: tne su:: essi:n :::1 via One ADS system an:/cr tne R ':
steam tv-cine is:narge.
Met 90: E Ier Mein d E, h0C'. is used to maintain react 0P vessel coolant i r.v e r -
1 ry, RHR and MOSW are re:ui*e: as in mein 00 A for su;pression :0:1 l
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Heat is transferred from the. vessel to the suppression pool via the ADS system and/or the HPCI steam turbine discharge.
Method C For Method C, the reactor is depressurized using the ADS system to a point where either the Core Spray or the LPCI mode of the RHR systems can be used to maintain core inventory.
Method D Method D, is the alternative shutdown method for a catastrophic fire in either the Control Room, Cable Spreading Room or the Emergency Shutdown Panel Area.
This method is described in the following section.
4.2 Alternate Safe Shutdown Areas The licensee provided alternate *sfe shutdown capability indepencen; of tne main control room, cable spreading room and the emercency shutdown panel area.
The alternative shutdown stations ar? provided with circuit isolation cacability using manual control switches, relays, breakers or fuse eisconne:t switches, to ensure that no aie:trical conne:: ion exists between the alternative shutcown circui;s and :n:se affe::ed by a fire in any one of the l
above-mentioned areas.
In the event Of an unritigated fire in these areas, the coerat:-s will pro:eed to alternative snu down stations to initiate shute:wn Ooera; ions.
Cortunications will be established te: ween the o:e-ators wno are at the altercathe shutcown stations and the Oc rcinating c;erator.
Ine siternative 00r.;rol stations for Eca:n E0;;o: are in tne foliccing locations:
l HDCI Alte-native : n:-01 $;ation - Inis panel is 10:Eted in ea:h ur.it in :ne Mi se; r00r a; eievation.35' - D".
Tne HDC: alte native
- ntr i stati0n is e:vi;;ed wi n : :: ciagnesti: instrurentati:n and transfer sei :res and alte-nl ive ::ver su;;iiss for the HP:I t u rc i r.e.
Inis :anel is ais; e:vi:;e: witn :ne alterr.ative pro:ess monit0 ring ir.strumentation wni:n in:icates reactor vessel pressure and level, su: ression ;0ci tem erature, an concensate storage tank level.
Diessi Gere-a e-s A1:eenative Cer:-ci Station - These canels are 10:a:e: in u,.1; 2 4KV ere ;en:y sei;:ngsar r:0ms 5/3 an are ::me:n
- 0 00:n Units 2 and 3.
The canels are e:vi;;et witn transfer swit:nes :: ise'. ate all rain ::ntr:1 root :entroi cirevits, and als:
Oiesel generst:r ciagncstic instrumentation.
9 4KV Emercency Switchaear Alternative Controls - These controls are located in the 4KV emergency switchgear rooms in each unit.
Transfer switches provide alternative local control and status indication for the motor control centers and for the ESW, RHR and HPSW pumps.
ADS Transfer / Isolation Station - Alternative control capabilities f or 3 ADS valves and tne associated nitrogen supply isolation valves are located on the HPCI Alternative Control Stations in the M-G Set Roems.
The transfer / isolation switches for these controls are located in the 4KV switchgear rooms. The remote locations for the transfer / isolation switches are necessary to preserve safe shutdown capability for the M-G Set Rooms.
RHR/HPSW Sucoression Pool Alternative Control Stations -
Alternative control capabilities and transfer / isolation switches fo* one loop of RHR/HPSW M0:0r Operated Valves (M3V's), needed to support Suppression Pool Cooling, are located at:the HPCI Alternative Control Stations in the M-G Set Rooms.
4.3 Remaininc Plant Areas The licensee indicated that all other areas of the plant not recuired to have an alternate safe shutdown system, ccm;iy with the rac'. ire-nents of Section III.G.2 of Appencix R, unless an exemption rec.uest has been at: roved by the staff.
5.0 Irsrectier Metnedeie:y Tne insce: tion team examined the licensee s provisicrs for separating an:
i prete::ir.g e:uicment, :aciing arc ass 0:itte: circut;s necessary to a:hieve an: maintain n:: an: 0010 snut::wn :Unditions.
Inis i.,s:e: icn sampie: sele: ed fire a eas wnien the it:ensee ha: identified as ceing in 00m;11an:e with Se::icn III.G.
Ine fellowin; fun::10nti re:uirerer.:s were reviewed for a:nieving and main;aining n:: an ::1: shu;te n:
Rea::ivi;y :0nte:1 Pressure 00ntr01 Rea::ct :00iant makeup De:ay hea; rem: val Su:00r: systems Pro:ess m ni 0 ring Ine insos:ti0n team examine: the li:ensee's ca ability te achieve and mair.tain net shut:0 n and the Oa:atii'*y :: *ing the plant t0 : l: shu -
c0wn :0n:iticr.s in the event of a fire in varicus areas cf the : Tant.
Ine examina;ien in:1u:e: a review Of crawings, safe shu : wn prc:e:gres and c;her cc:u ents.
D-awings were rev' ewe: to verify sie:tri:a1
)
10 independence 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 (5555)-
The team review included an evaluation of the susceptibility of the 555s to damage from fire suppression activities or from the rupture or inadverter-operation of fire suppression systems.
The inspection team examined the licensee's fire protection features provided to maintain one train of equipment needed for safe shutdown free of firt damage.
Incluced in the scope of this effort were fire area boundaries, inclu ing walls, floors and ceilings, and fire protection of openings su:h as fire coors, fire campers, and penetration seals.
The inspection team also examined the licensee's compliance with Section III.J, Emergency Lighting.
6.0 Insoettien of Protection Provided for Safe Shutdown Systems 6.1 Pretection in Various Fire Areas L
Tht tear. reviewed the protection proviced to SSSs in selected fire areas for ecmplian:e witn A:;endix R, Sections III.G.1, 2 and S.
During the previous A;;endix R ins;e: tion, ecmpliance in this area could n:t be verified be:ause tFe 'i:ensee's analysis was in:0mpicte.
Ineref;re, tne team :cui: net as:e-tlin whether reduncan. safe shuti;wn : mporer.ts wr<e niinin the sars fire area. The licensee's l'
current anaissis icentified the methed to be usec in each area.
The licenses also veri fied tr.at 0m:0nents r211ed upca. for shutdowr. are eitner outsics tne area Of :nn:ern or art Orctected.
Tne system review an: :lant nalkcomn ci: nct icer.tify ary unacceptable 003:1-res0 ves the previcusly identified unresolvec 1
tions.
Tais review 4 te* 00-27'//27E/55-03-01 6.2 Sa'e snute n Orc:edure Review an: Wa'L-Oewn The team reviewe: the pr0:edures used oy tne licer.see in the ever of a fire.
Foliening a report Of a fire tne Operatcrs initial gui:ance is from procedure ON-1;4 "Actual Fire Reported in the Power Elo:L, or, Diesel Generator Evilding, Emergen:y Pum:, Inner Screen, er Emer;en:y C:: ling Tower Stru:tu es - Fre:e:ure." The operaters are gui:e: by this pre:edure to : ::ecu-e.T-200 when sym:tems indi-Cate tnat fire camage inreaters saf e snutd:en systers. Tne T-200 r::edure is a sym:tema'i: Or0:edure wht:h 00r.tains an it. ex cire:t-in; the operators tc the pr:per I-300 series fire guice 10r the affected fire area.
Fer a fire in Fire Area 25 wht:n in:iu:ss the Main Centrol R:
Computer Rocm, tne Cadie 5:rea:ing Renn and tre Emer;en:y Shut::wn
11 Panel Area, Fire Guice T-325 directs the use of Procedure SE-10 "Plant Shutdown from the Alternate Shutdown Panel" if the Control Room shutdown systems are threatened by fire damage.
If the fire reautres Control Room evacuation, the operators manually scram both Reactors and take control of the plant from the alternative shutdown panels.
Shutdown Method D described in section 4.1 is used.
Procedure SE-10 as reviewed by the team was found to be adequate.
The team commented that some steps in the procedure may need signa-ture checks to assure control.
For instance the steps monitoring the rea: tors' cooldown rate and other steps that operators perform in the attachments-to the procedure do not have sign-off blocks that the operatien was performed. The licensee in subsequent discussions committed to review the procedure and add sigr.-off spaces where needed.
The procedure walkdown was performed using three operators because the operations at only the Unit 2 Alternate Shutcown panel were observed.
For an actual fire f aur_caeratar.saauld.be_uitd m l
The walkdown identified that some operations performed during the het shutdown phase are repairs.
Since repairs are not allowed by the NR* guidante the_lign sg.am Ar,ilited_tp nelw nenpaion_jIoQ NRR.
This is an unresche: item (E7 30-02).
Other observations
~~d!?Tng the wal k:0wn of the procedure were that the breaker,.anel for tne inaccre stea7 isciation valve of :ne HDCI system has a cover fastene: On witn wi ; nuts.
The team Obsersed tnat if ne wir; tuts are 100 tignt tre operators may n:t be able to open the canei.
Tne licenses stated that either 03;ger wing nuts or a t001 will te pr0-viced te assure ;anel a: ess.
Since the shutdowr cr0:edure was adecuate, this reselves the tre-vicusly icertifie: unres0ived ite 50-277/275/55-05-02 regar:in; ins la:k :f snutdown ;re:e:gres curin; inat ins e:ti0n.
During tre walk::wn Of ns Oro:scure, ine tear also ma:e 00servati0ns on tne ace:us:y Of tne e ergen:y li;nts.
Tne teet c4d n:
icentify ary una::e: table :en:iti:ns.
Inis rescives ite: 55-05-05 00n:ernin; tne acequa:y of tne emergen:y lights.
6.3 P-ete:tien for Ass::tated Oi cuits A rendix R, Se: tiers I !.G and II!.L -equire that a-:te:ti0r be r0 Viced f0- ass 0:iate: Oircuits that :Ould prevent 0;erati:r er
- ause maic:erati:r. of redun: ant trains cf systers ne:essary for safs snut::wn.
Ine cir:vits of concern are generally ass 0:tated with safe snutcown cir:vits in one cf tnree ways:
+
12 Common bus concerns
+
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.
6.3.1 Corcon us Cor:e n The common bus concern may be found in circuits, either safety related or non-safety related, wnere there is a common power source with shutdown equipment and tne power source is not electrically protected f rom the circuit of concern.
The team examined, en a sampling basis, protective relay coordi-nation'for 4160V anc 4B3V buses and protection for specific instrumentation. ecr. trol and power circuits.
The coordination of fuses an cir:vit breakers was checked oy examination of the liter.see's fuse an: breaker coordination curves.
The licenses performs relay calibration during refueling cutages on appr0xi-mately 1$ month inte vals.
A ce' icier:y was ic.=nt.i.fie..d as follows:
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The licensee committed to submit the test procedure and results to the NRC for review, Pending review of the test yby @ this item will remain unresolved. (87-30-03) 6.3.2 Spurious Sicnals Concern The spurious signal concern is made up of 2 items:
False me or con;rol and instrument indications can c: ur such as those en:cuntered during the 1975 Browns Ferry fire.
These could be caused by fire initiated grounds, shor; or open circuits.
Spu-ious operation of safety related or non-safety related components can o :ur that would adversely affect shutdown capability (e.g., RHR/RCS isolation vaives).
The team reviewed dO:uments, en a sampline basis, in the feliowing areas to ascertain that no spurious sicnal concern exists:
Cur-ent transformer setendaries Hig /iew pressure interfaces
' eneral fire instigated spurious signals A cefitiency was icert'fied as f0llors:
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cown Cecli ; Su::'e. Li e Isciation Vaives (v'-1C-17 & 15) wii' n:: resu'
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a item will remain unresolved (E7-30-04).
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ne id:ensee state: :na; a :-::ecure :: :: n: r e '.
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F 14 fuse replacement is currently in the process of being written and implemented.
The licensee further explained that fuse re-placement is currently performed by either "replace in Line" or using the Control Roon mark up drawings which call for the type of fuses to be used.
6.3.5 Ccmmon Enclosu e Conce-n The : mmon en:lesure :en:ern may be found when redundant circuits are -oute: together in a raceway or enclosure and they are not electrically protected or when a fire can destroy both circuits due to inace;uate fire barriers. The team reviewec a random sample of asso:iated circuits routed together and found these circuits to be protected by coordinated electrical prete -
tion cevices.
The review of the common enciesure concern dic not icentify any una Ceptable conditions.
7.0 Unresolved items Unresolved items are matters for which more information is recuired in orce-to ascertain whetner they are atee::able, violations, or ceviations.
Unrescived items are ciscussed in Se: ions 6.2 an: 6.3.
E.0 Exit Inte view Ine ins 0e: tion tear raet with the liter ses re:-esenta* d ves, de* t(d in
$t *'On 1.0, a: ne ::n:iusie ef *he ins:e::icn en 0::0p9-23, 1957, arc tre team isade-sur a-i:ed :ne s:::s act findirgs of ne inste:tiet at na; tir.e.
ine team lencer aise confirme: wi n :ne li:ensee tr.at the recert wi'.1 n:t
- n air ar) preprie:t y information Ine licenses a;ree tha the inste:*
tien rep;r: may be ria:ed in tne Pu:li: 00:u.te ; E00m witna"* a it:enses review for er::rie:a y inf rmati:n (.: CFR 2.79^).
A: n: tire curin:
n's ins:e::i:n was *-itten rate-iai creviced t:
s li:ensee y :*,9 ksam