ML20154D489

Notice of Violation from Insp on 830829-0802.Violation Noted:Fire Protection Features Not Provided for Certain Redundant Trains of Equipment &/Or Cabling Necessary to Achieve & Maintain Hot Shutdown Conditions

ML20154D489
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/15/1987
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154D394	List: IR 05000271/1983026 IR 05000272/1983037 ML20154D389 ML20154D422 ML20154D456 ML20154D489
References
FOIA-88-92 50-271-83-26, EA-84-007, EA-84-7, NUDOCS 8809150292
Download: ML20154D489 (25)

Text

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L NOTICE OF VIOLATION Vermont Yankee Nuclear Power Corporation Docket No. 50-271 Vermont Yankee Nuclear Power Station License No. DPR-28 EA 84-7 A special fire protection inspection conducted at the Vermont Yankee site during the period of August 29 - September 2,1983 identified violations of NRC require-In accordance with the "General Policy and Procedure for NRC Enforcement ments.

Actions," 10 CFR Part 2, Appendix C (1987), the violations are set forth below:

10 CFR 50.48(b) requires in part that all nuclear power plants licensed to operate prior to January 1,1979, such as Vermont Yankee Nuclear Power Station, shall satisfy the applicable requirements of Appendix R to Part 50 including, specifically, the requirements of Sections III.G, Fire Protection of Safe Shutdown Capability, III.J, Emergency Lighting, and III.0, 011 Collection System for Reactor Coolant Pump.

10 CFR Part 50, Appendix R, Section III.G 1 requires that fire protection features shall be provided for structures, systems, and components impor-tant to safe shutdown.

These features shall be capable of limiting fire damage so that one train of systems necessary to achiave and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage.

Sections III.G 2 and III.G 3 specify four alternatives that may be implemented outside of primary containment to assure that one redundant train of equip ent, cabling and associated circuits necessary to achieve and maintain hot shutdown remains free of fire damage.

The alternatives are:

Separation of redundant trains of equipment, cabling and associated circuits by a three-hour rated fire barrier.

I Separation of redundant trains of equipment, cabling and associated circuits by a hccizontal distance of 20 feet with no intervening combustiblet and fire detection and automatic fire suppression system' installed in the area.

Enclosure of redundant trains of equipment, cabling end associated circuits by a one-hour rated fire barrier with fire detection and automatic fire suppression systems installed in the area.

Installation of alternative or dedicated shutdown capability independent of the equipment, cabling and associated circuits under l

consideration, and installation of fire detection and fixed fire suppression systems in the area under consideration.

t 8809150292 800822 a

PDR FOIA l

JONES 88-92 PDR I

Appendix A 2

Contrary to the above, as of September 2,1983, fire protection features were not provided for certain redundant trains of equipment and/or cabling necessary to achieve and maintain hot shutdown conditions from either the the control room or emergency control stations such that one train would remain free of fire damage.

These equipment and/or cables were located in the reactor building (RB) outside primary containment. None of the alternatives provided by Appendix R,Section III.G.2 or !!I.G.3 were implemented. Specifically:

For redundant trains of systems necessary for hot shutdown a.

and in the northwest of the RB, elevation 252', although the redundant cable trays, containing control, instrumentation, and some power cables, were separated by more than 20 feet and there was fire detection in the area, an adequate fire suppression system w s not installed in that the fire suppression system was placed beneath the lowest level of cable trays which contained 4

cable not qualified as fire resistant by IEEE-383.

No alterna-tive or dedicated shutdown capabilities were provided.

b.

For redundant control cables located in cable tray R330S!! and conduit 11188JS!!X for the high pressure coolant injection (HPCI) and the reactor core isolation cooling (RCIC) inboard isolation valves V13-15 and V23-15, there was less than 20 feet of separation and there was no fire suppression or fire detection system at elevation 252' of the RB. No alternative or dedicated shutdown capabilities were provided.

Hotor control centers 898 and 90 which power RCIC and HPCI c.

inboard isolation valves V13-15 and V23-15 respectively, were separated by greater than 20 feet; however, there were inter-vening combustibles in the form of open cable trays and there was no automatic fire suppression in the area. No alternative or dedicated shutdown capabilities were provided.

d.

For the reactor vessel level and pressure transmitters located at elevation 280' of the RB, although there was more than 20 i

feet of separation, there was no automatic fire suppression or l

detection in the vicinity of the instrument racks.

No alterna-tive or dedicated shutdown capabilities were provided.

The redundant power cables to motor control centers 8B and 9B, e.

in the personnel corridor which lead to the northwest corner of 4

the RB, were separated by less that 20 feet and did not have automatic fire suppression or detection in the area.

No alter-native or dedicated shutdown capabilities were provided.

This is a Severity Level III violation (Supplement 1).

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t Appendix A 3

Pursuant to the provisions of 10 CFR 2.201, Vermont Yankee Nuclear Power Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

DC 20555 with a copy to the Reglenal Administrator, Region I and a copy 1

the NkC Resident Inspector with'n 30 days of the date of the letter trans-mitting this Notice.

Notice of Violation" and should include for each violation:This rer.ly shou i

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(1) the reason l

for the violation if adm'.cted, (2) the corrective steps that have been taken and the results achi-,ed (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

i Where good cause is shown, consideration will be given to extending the response time.

If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the licensee should not be rnodified, suspended, or revoked or why such other action as may be proper should not be taken.

time for good cause shown. Consideration may be given to extending the response FOR THE NUCLEAR REGULATORY COMIS$10N

&$UE T. f

' W i

William T. Russell i

Regional Administrator Dated at King of Prussia, Pennsylvania this If dday of June 1987.

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UNITED STATES i

f~.E NUCLEAR REGULATORY COMMISSION 5

I OFFICE OF INSPECTION AND ENFORCEMENT g,.....,/

Washington, D.C. 20566 INSPECTION AND ENFORCEMENT MANUAL DQASIP TEMPORARY INSTRUCTION 2515/62 INSPE* TION OF SAFE SHUTDOWN REQUIREMENTS OF 10CFR50, APPENDIX R (SECTION III.G) AT NUCLEAR POWER PLANTS LICENSED TO OPERATE BEFORE JANUARY 1, 1979 2515/62-01 PURPOSE To ascertain whether required licensees are in conformance with Section III.G of 10CFR50, Appendix R, including exemptions approved by the Office of Nuclear Reactor Regulation (NRR), 0.5. Nuclear Regulatory Comission.

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2515/62-02 BACKGROUND 1

Effective February 17 1981, the Nuclear Regulatory Commission amended its regulations by adding Section 50.40 and Appendix R to 10 CFR 50 to require certain provisions for fire protection in operating nuclear power plants.

This action was taken to resolve certain contested generic issues in fire protection safety evaluation reports (SERs) and to require all applicable licensees to upgrade their plants to a level of protection equivalent to the technical requirements of III.G.

2515/62-03 GENERAL INFORMATION 031 It is recommended that a team be assigned to perform this inspection.

The following is a suggested minimum team sakeup:

a. _ Team Leader - leads discussion with licensee at entrance and exit interview.

Should be a region-based inspector.

Also participates in inspection effort.

• b. Safe Shutdown Specialist - inspects the safe shutdown systems, equipment, and circuits.

• c Fire protection Specialist - inspects fire protection of the safe shutdown systems, equipment, and circuits.

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• Regions may use inspectors who have the necessary expertise, request assistance from NRR, or use IE contractors who have the necessary expertise.

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2515/62-032 SAFE SHUTOOWN 032 This is a technically complex inspection.

Because there are many variations in the technical details by which a facility can meet safe shutdown criteria, a site-specific inspection plan must be prepared.

See Appendix 1 for c'etailed guidance on the preparation of inspection plans.

2515/62-04 SPECIFIC INSPECTION REQUIREMENTS 041 Section !!!.G.2. Safe Shutdown Capability

a. Review the systems and equipment used to meet the safe shutdown requirements.

Systems included should fulfill the following requirements:

1.

The reactivity control function shall be capable of 1

achieving and maintaining cold shutdown reactivity conditions.

2.

The reactor coolant makeup function shall be capable of maintaining the level above the top of the core for BWRs and within the level indication of the pressurizer for PWRs.

3.

The reactor heat removal function shall be capable of achieving and maintaining decay heat removal,

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4.

The process monitoring function shall be capable of pro-viding direct readings of the process variables necessary to perform and control the functions in Items al, 42, and a3 above.

(See memo referenced in Appendfx 1. Section A.I.k to this temporary instruction.)

b. Verify, on a sample basis, that plant fire areas (bounded by 3-hour-rated walls or equivalent approved by NRR) that con-j tain components from both redundant trains of safe shutdown i

equipment meet one of the following:

1.

requirements of III.G.2; or 2.

an exemption to !!!.G.2 approved by NRR; or 3.

an approved alternative or dedicated shutdown capabi-lity meeting the requirements of !!!.G.3 and III.L as described in the Safety Evaluation Report (SER) issued by NRR or licensee documents referenced therein."

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• See Section 042 (below) for inspection requirements if alternative ~or dedicated shutdown is required.

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!ssue Date:

01/24/83 _ _ _ _ _ _ _. _..

i SAFE SHUTOOWN 2515/62-041c

c. Verify, on a sample basis, that modifications necessary to ensure safe shutdown are in conformance with the information describet' in the exemptions approved by NRR, c'r other

. licensee documents.

d. Verify that redundant trains of cables (safety-related, nonsafety-related, and associated circuits) and equipment in selected fire areas have been identified and analyzed by the licensee to show that they would not prevent safe shutdown operation because of hot shorts, open circuits, or short to ground.

Verify that they have required separation ot' l

barriers as required by III.G.2. of Appendix R, or are protected as described in Enclosure 2, Attachment 2, Section B of NRR letter to licensees issued on various days during 1982.

(See Appendix 2 of this temporary instruction for j

exact date.)

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e. Verify, on a sample basis, that installation and testing of necessary fire detectors and automatic fire suppression systems as required by III.G.2 are as described in the exemptions approved by NRR or other licensee documents.

i 042 Sections !!!.G.3 and L. Alternative and Dedicated Shutdown Capability"."*

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a. Review the systems and equipment used to meet the alterna-tive or dedicated shutdown requirements.

Verify they meet the following functional requirements:

1.

The reactivity control function shall be capable of 4

achieving, monitoring, and maintaining cold shutdown reactivity conditions.

1 2.

The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the i

top of the core for BWRs or be within the level indi-cation in the pressurizer for PWRs.

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• !f modifications are necessary to provide alternative or dedicated shut-down capability, those modifications are required by 10CFR50.48(c)(5) to be reviewed and approved by NRC.

A Safety Evaluation Report documenting 4

the results of the review and approval will be issued.

This SER and referenced licensee documents will form the technical basis for this inspection.

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• • 1f modifications are not necessary because a, W sive or dedicated shut-down had been previously approved, then the doc -entation supporting the previous approval should be reviewed.

Appendix R. Section !!!.L should

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be used as guidance for the review.

Any discrepancies between !!!.L and the installation should be reported to NRR for resolution.

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2515/62-042a3 5AFE SHUTDOWN i

3.

The reactor heat removal function shall be capable of achieving and maintaining decay heat removal.

4.

The process monitoring functions shall provide direct reading of the process variables necessary to perform i

and control the functions in Items al, a2, and a3 above.

(See memo referred to in Appendix 1, Section

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A.1.k of this temporary instruction. )

J b Verify that modifications necessary to assure alternative or r

dedicated shutdown capability are in conformance with infor-nation discussed in the SER and supporting documents.

c. Examine the alternative or dedicated shutdown equipment and l

verify that it is separated from the fire area of concern by Section !!!.G.2 separation requirements and that electrical j

isolation capability is provided as described in the SER and 3

supporting documents, i

d, Review the licensee's testing program for ensuring alterne-tive or dedicated shutdown capability and verify that it j

includes, as a minimum, provisions for ensuring that equip-9 ment operates from the local control station but cannot be i

j operat.ed from the control room when the transfer or isola-i tion switch is placed in the "loct1" position and that i

equipment operates from the control room but cannot be

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4 operated from the local control station when the transfer I

j or isolation switch is in the "remote" position, a

e. Verify that the licensee's training program for licensed and nenlicensed personnel has been expanded to include alterna-t j

tive safe shutdown capability training 1'a all required l

individuals in the event of a fire, j

f. Verify that personnel required to achieve and maintain the

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plant in hot shutdown, following a fire using the alterna-tive shutJown systems, can be provided from noma 1, ensite j

staff, exclusive of the five person fire brigade.

g. Verify that procedures for use of the alternative shutdown system exist. Verify the operators can perform the proce-dures in a time consistent with shutdown requirements.

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j 2515/62 05 REPORTING REQUIREMENTS 1

The results of this inspection will be documented in a standard inspection s

l report. A copy of the final report shall be forwarded to the Office of Inspection and Enforcement. Division of Quality Assurance, safeguards, and Inspection Programs, and to the Office of Nuclear Reactor Regulation, Division of Licensing.

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SAFE SHUTDOWN 2515/62-06 l

2515/62-06 STATISTICAL DATA REPORTING For module tracking system input, record actual inspection effort agai.m Module No. 255628. Credit for routine program inspections may be taken detailed in Appendix 3 of this temporary instruction.

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2 2515/62-07 EXPIRATION This temporary instruction will remain in effect for one year ? rom the date of issue.

1 END 1

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i SAFE SHUT 00WN APPENDIX 1. 2515/62 APPENDIX 1 INSPECTION PLAN PREPARATION A.

Document Review Because the inspection of the safe shutdown requirements of Appen-dix R (10CFR50, Section !!!.G) is a complex undertaking, it is important that the personnel selected to perform the inspection be prepared before they arrive at the site.

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Following is a list of documents that inspection personnel should obtsin and review before the inspection:

a. NRR letter, dated November 24, 1980, from D. G. Eisenhut to all power reactor licensees with plants licensed before January 1, 1979.

This letter details the SER open items that were appli-cable to each operating plant.

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b. NRR Generic Letter No. 81-12, dated February 20, 1981, from D. G. Eisenhut to all power reactor licensees with plants licensed ')* fore January 1, 1979.

This letter requests certain informattu to be included in licensee submittals in response

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to 10CFR50.48 and Appendix R requirements.

c. NRR letters to licensees, that provided clarification of the requirements of Generic Letter 81-12.

These letters were l

issued on various days during 1982. (See Appendix 2 to this tesporary instruction for exact date.)

d. Licensee responses to NRR letters of A.I.a. b, and c and i

exemption requests,

e. Fire Hazard Analysis and related documer.ts prepared by the i

j licensee before January 1,1979.

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f. NRR Fire Protection Safety Evaluation Report and supple-ments, and licensee documents referenced therein that provide the NRR review and approval of the Fire Hazards Analysis of.tl.a.*

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g. NRR Fire Protection Safety Evaluation Report and licensee documents referenced therein that provioe the NRR review and approval of modifications required to satisfy the alter-native or dedicated shutdown requirement of Section III.G.3 l

l of Appendix R.*

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h. Exceptions granted or denied by NRR.*

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1. Licensee's reassessment of the plant to !!!.G requirements l

that identifies redundant safe shutdown systems and compo-

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nents, defines the fire areas (bound by 3-hour-rated walls r

• Ine dates of these items may be obtained ' om the NRR project manager.

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2515/62. APPENDIX 1 SAFE SHUT 00WN or equivalent) snd locates the safe shutdown equipment and cables by fire area (part of this may include Item *. 1.e by reference).

j. NRR memorandum from Mattson to Vollmer dated July 2,1982, "Position Statement on Allowable Repairs for Alternative Shutdown and on the Appendix R Requirement for Time Required to Achieve Cold Shutdown." Copies were sent to the Regional Division Directors by J. M. Taylor en August 17, 1982.

k. Memorandum from L. S. Rubenstein to Roger J. Mattson dated January 7,1983, "Statement of Staff Position Regarding Source Range Flux, Reactor Coolant Temperature, and Steam Generator Pressure Indication to Meet Appendix R Alternative Shutdown Capability."

2.

From the documentation develop the following information:

a. Equipment required for hot shutdown.

b. Additional equipment required for cold,'. itdown.

c. Areas of the plant where alternative shutdown capability has been provided.

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d. Areas of the plant that contain components or cable runs

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(control, power or instrumentation) from both redundant i

trsins of equipment required for hot and cold shutdown.

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j 3.

The licensee should be asked to provide the following informa-i tion, if it is not available in the regional office:

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a. Emergency operating procedures or equivalent that are used

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to achieve and maintain the plant in bot shutdown following a fire.

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b. Emergency operating procedures or equivalent that are used I

to cool down the plant following a fire,

c. Results of tests run (if any) to vurify the ability to main-i tain the plant in hot shutdown following a fire with an assumed loss of of fsite power (e.g., natural circulation test while using the atmospheric steam dumps).

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d. Any documents identified in A.1 that were prepared by the licensee.

B.

Hot Shutdown Capability l

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Sy s tee / Equi pme nt/I n s t r um e n t a t i o n

a. From the list of systems, equipment, and instrumentation i

required to achieve and maintain hot shutdown, select a N

A

SAFE SHUTOOWN APPENDIX 1. 2515/62 s

sample for indepth review.

For exar.ple, in a PWR the following could be selected:

(1) reactivity control boration capability, i

(2) reactor coolant makeup - charging pump, (3) reactor pressure control pressurizer heaters, J

(4) decay heat removal - auxiliary feedwater pump, (5) process monitoring instrumentation - reactor tempera-ture and steam generator level (see A.I.k for complete list),

i (6) support - onsite AC power and its distribution system, j

il The six areas identified above generally define the areas of concern following a fire.

Selecting one or two compo-I nents from each area should be an adequate sample size.

! to NRR Generic Letter No. 81-12 provides additional information on PWR and BWR equipment required 1

for hot shutdown.

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b. For the systems, equipment, and instrumentation selected j

in B.1.a perform the following:

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(1) Using the liceasee's cable routin{, drawings or

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analysis, identify the areas of the plant traversed I

by the cables of the redundant trains of hot shut-j down equipment.

• (he cables should include

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(a) power (normal and emergency),

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(b) control, j

j (c) instrumentation, l

J (d) associated circuits of concern (see document i

referred to in A.1.c, Enclosure 2, Attachment 2, Sections A and B).

(2) Identify the areas of the plant that contain the equip-I ment of the redundant trains required for hot shutdown.

(3) Where modifications have been required to meet the requirements of !!!.G.2, review the modification packages for adequacy of licensee review and approval,

.l including 10CFR50.59 aspects.

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i (4) Inspect the areas of the plant and verify that the selected equipment and cables of the redundant trains meet the separation requirements of Section III.G.2 of j

Appendix R; 1.e., separated by a 3-hour fire barrier,

1 2515/62. APPEN0ix 1 SAFE SHUTDOWN or separated by a horizontal distance of 20 feet with no intervening combustibles with fire detection and automatic fire suppression in the area or enclosure of the cables and equip-ment in a 1-hour fire barrier with fire detection and automatic fire suppression in the area or an exemption has been approved by NPR.

2.

Alternative or Dedicated Hot Shutdown Capability *

a. From the licensee's analysis, identify the fire areas for whi h alternative shutdown has been provided or a dedicated i

shu down system has been provided,

b. From that analysis select a sample of the areas and/or equip-ment for indepth review as follows:

(1) Select a maximum of three areas of the plant where alternaative shutdown has been provided, or (2) If a dedicated shutdown system is installed select a sample of those systems (see B.1.a for an example of l

equipment and instrumentation).

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c. For the areas and/or equipment selected in B.2.b, perfors i

the following:

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(1) Using the licensee's cable routing drawings or cable analysis, identify the protective measures isolating the cables that could affect the alternative shutdown capability for that area.

These cables should include:

(a) power (normal and emergency),

(b) control, (c) instrumentation, 1

(d) associated circuits of concern (see document referred to in A.1.c, Enclosure 2 Attachment 2

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Sections A and B).

(2) Identify the location of the equipment necessary to j,

provide alternative or dedicated shutdown capability.

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i OXf the separation criteria of III.G.2 canno', t,e met for system, equipment, I

cr instrumentation required for hot shutdown, then alternative or dedicated shutdown provisions must be provided.

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Issue Date:

01/24/83 Al-A

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

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'O SAFE SHUT 00WN APPEN0!X 1. 2515/52 (3) Verify that the areas for which alternative or dedicated shutdown has been provided are protected by, fire detec-tion and a fixed fire suppression system.

(4) Where modifications have been required, review the modification packages for adequate licensee review and approval, including 10CFR50.59 review.

($) Inspect the areas of the plant to verify that the commitments of the SER have been set for the equipment and cables selected above.

3.

Procedure for Hot Shutdown

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a. Review the procedure that the licensee uses for bringing the plant to hot shutdown in the event of a fire in the:

(1) cable spreading room, (2) control room, L

(3) other selected critical areas,

b. Determine the feasibility of performing the procedure in case of fire by a walkthrough of specific sectiot.s of the procedure.

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c. Pay particular attention to modifications (if any) that must be made in order to achieve or maintain the plant in bot shutdown.

If modifications (e.g., lifting leads, pulling fuses) are necessary, NRR should be contacted for resolution.

4.

Staffing i

a. Deterstne if there are enough qualified personnel available on shif t to perfore the operations necessary to maintain the 4

l plant in hot shutdown and staff the five person fire brigade.

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b. Verify that communications capability between the various control stations is adequate for shutting down and saintain-ing the hot shutdown condition.

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• Procedures for bringing the plant to hot shutdown in the event of a fire should consider both the use of only onsite power and the use of offsite power.

Credit taken for the failed position of some equipment on loss of l

of fsite power must be addressed when offsite power is not lost. Addition-(

ally, some "associated circuits of concern" may require procedures to detect t

ard correct spurious operations of these circuits.

Thase procedures should also be included in the review,

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2515/62. APPENDIX 1 SAFE SHUTDOWN 5.

Training

a. Vorify that the Itcensee's training program includes ins'truc-tion, on a periodic basis, in the use of the procedure for hot shutdown following a fire.

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b. Interview a sample of operators with regard to:

(1) the i

adequacy of training; and (2) the usefulness and feasibility of parforming the procedure.

C.

Cold Shutdown capability j

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Systems / Equipment / Instrumentation l

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a. From the list of additional systems, equipment, and instru-l mentation required to cool the plant from hot shutdown to cold shutdewn, select a sample for indepth review.

For example, ir ; PWR the fo11cwing could be selected:

(1) reactor coolant system pressure rede:: tion - auxiliary spraf line valve controls, 1

I (2) decay heat removal - RHR pump, (3) support - onsite power.

l The above three items represent equipment, in addition to the equipment required for hot shutdown, necessary for cold l

shutdown.

Selecting one or tw components from each area should provide an adequate sample size. to NRR j

Generic Letter No. 41-12 provides additional inft.reation on PWR and BWR equipment required for cold shutdown,

b. For the systems, equipment, and instrumentation selected in C.I.a perfore the following:

(1) For postulated fire damage determine the feasibility of j

repair and cooldown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(2) Determine that any material required to repair the i

damaged area is available, on site, so that the 72-hour j

limitation can be met.

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(3) Review the licensee's procedure for effecting repairs i

l to the damaged area.

(4) Review the modification packages for adequacy of licensee revkw and approval, including 10CFR50.59 i

aspects, i

j (5) Inspot.t the areas of the plaat containing tt.a equipment, i

4 systems, and instrumentation required to cool down the plant.

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SAFE SHUT 00WN APPENDIX 1. 2515/62 2.

Procedure for Cooldown

a. Review the procedure that the licensee uses for bringing the plant to cold shutdown conditions in the event of a fire in the:

(1) cable spreading room, (2) control room,

b. Determine the feasibility of performing the procedure in case of fire by a walkthrough of specific sections of the procedure,

c. Pay particular attention to modifications (if any) or repairs that must be made in order to cool the plant to i

cold shutdown conditions,

d. If modifications are necessary, verify that a determination in accordance with 10CFR50.59 was made.

3.

Training 1

a. Verify that the licerJea's training program includes instruc-4, I

tions, on a periodic basis, for the use of the cooldown pro-cedure following a fire.

b. Interview a sample of operators in regard to:

(1) the adequacy of training, (2) the usefulness and feasibility of performing the procedure, e

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SAFE SHUTDOWN APPENDIX 2, 2515/62 APPENDIX 2 DATE OF LETTER TO LICENSEES PROVIDING CLARIFICATION OF REQUIREMENTS OF GENERIC LETTER 81-12 AND DATE OF LICENSEES' RESPONS,E Plant Ot. of Lette_r Dt. of Response Arkansas 1/2 05/10/82 07/01/82 Beaver Valley 1 05/04/82 06/30/82 Big Rock Point 1 04/30/82 07/09/82 Brcwns Ferry 1/2/3 05/05/82 06/30/82 Brunswick 1/2 05/04/82 06/30/82 Calvert Cliffs 1/2 05/10/82 07/01/82 Cook 1/2 To Be Issued 03/31/83 (Coamitted)

Cooper 05/04/82 06/28/82 Crystal River 3 05/04/82 06/30/82

'i Davis-Besse 1 No Lctter NA I

Dresden 1 05/18/82 18 mths before return to serv.

Dresden 2/3 04/30/82 07/01/82 Duane Arnold 04/20/82 06/22/82 Farley 1/2 05/04/82 07/01/82 FitzPatrick 05/10/82 07/13/82 a

Fort Calhoun 1 04/08/82 05/25/82 Fort St. Vrain No Letter NA l

Ginni 05/07/82 07/23/82 Haddam Neck 05/10/82 07/16/82 Hatch 1/2 05/03/82 07/01/82

)

Humboldt Bay No Letter NA l

Indian Point 2 08/10/82 01/10/83 (Connitted)

Indian Point 3 05/05/82 07/01/82 i

Kewaunee No Letter NA Lacrosse 05/10/82 09/28/82 i

Maine Yankee 05/19/82 11/24/82 Millstone 1/2 05/10/82 07/16/82 Monticello 05/04/82 06/30/82 Nine Nile Point 1 04/26/82 10/01/82 & 12/03/82 North Anna 1/2 04/21/82 06/22/82 Oconee 1/2/3 No Letter NA 3

l Oyster Creek 04/30/82 06/30/82 Palisades 04/07/62 07/01/82 i

Peach Bottos 2/3 05/04/82 06/28/82 Pilgrim 1 05/04/82 06/25/82 j

Point Beach 1/2 05/04/82 06/30/82

(

Prairie Island 1/2 04/28/82 06/30/82 Quad Cities 1/2 04/28/82 07/01/82 Rancho Seco 1 No Letter NA Robinson 2 05/10/82 07/30/82 A ". - 1 Issue Date:

01/24/83 i

2515/62, APPfN0lX 2 SAFE SHUTDOWN Plant Ot. of Lette_r Ot. of Response Salem 1/2 04/20/82 06/16/82 San Onofre 1 05/10/82 06/30/82 St. Lucie 1 05/10/82 06/10/82 Surry 1/2 04/12/82 06/18/82 Three Mlle Island 1 05/10/82 07/01/82 Trojan No Letter NA Turkey Point 3/4 05/10/82 07/01/82 Vermont Yankee 05/10/82 None Required Yankee Rowe 04/28/82 08/31/82 Zion 1/2 04/06/82 07/02/82 i

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_'_-..__'______J'_.'.*l-__.__.__.__.__*'_.*.__________..__-.____.,___..,_____,_________.__.

SAFE SHUTOOWN APPENDIX 3. 2515/62 APPENDIX 3 ROUTINE PROGRAM CREDIT ASSOCIATED WITH PERFORMING TI 2515/62 Following is a list of inspection procedures for which credit may be taken.

Credit taken should be based on wh-t the licensee had to do to the facility to bring it into compliance with Appendix R.

For example, if modifications were required to meet the separation requirements of Section III.G.2 of Appen-dix R (with NRR approval not required), credit for 37700 and 72701 may be taken.

However, if modifications were required to provide alternative or dedicated shutdown capability (with NRR approval), credit for 37701 and 72701 may be taken.

Because of the variations that can be taken by the licensees in complying with Appendix R Section III.G, the inspection teams, along with regional Management, should decide the applicability of reducing each inspection procedure listed below:

Procedure No.

Credit Frequency Program Title 37700 100%

A Basic Design Changes and Modifica-tions 37701 100%

WR Supp.

Facility Modifications 41700 30%"

A Basic Training 42700 50%

A Supp.

Plant Procedures 64703 0%**

3 yr.

Supp.

Fire Protection Prevention I.

Program 64704 100%

A Basic Fire Protection / Prevention Implementation 72701 100%

WR Basic Startup Testing New/ Modified 1

• If nonlicensed individuals are required to be trained to meet Appendix R backfit requirements by the licensee commitments or SER, then credit for j

up to 30 percent of this procedure can be entered in 766 data.

• • No credit saould be taken for this procedure after performing the TI since this is strictly a program review.

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!ssue Date:

01/24/83 A3-1

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=hf (hM MYO 7.

v Special Inspection - Licensee conformance with items III. c, J L and 0 of 10 CTR50, Appendix R. Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979 A.

ORJECTIVE:

To ascertain whether required licensee's are in conformance with items III. C, J, L and 0 of 10 CFR 50, Appendix R B.

BACKGROUND INFORMATION i

Effective February 17, 1981, the Nuclear Regulatory Commission aumended its regulations to require certain provisions for fire l

protection in operating nuclear power plants. This action was l

identified as appendix R to 10 CFR 50, and was taken to upgrade fire protection at those nuclear power plants licensed operate prior to January 1, 1979. The purpose of this action was to require resolution of certain contested generic issues in fire protection safety evaluation reports (SER's) and to require the licensees to upgrade their plant to meet the requirements of III.G, J. L. and 0 of 10 CR 50 Appendix R.

C.

INSPECTION REQUIREMENTS j

Specific inspection requirements for items III. U, J, L and 0 of Appendix R to 10 CTR 50 are described in Enclosure 1.

It should be noted that this effort is classified as a special inspection with possible

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i participants made up of the following types of individuals:

1.

Consultants - Fire Protection Consultant, Safe Shutdown Consultant 2.

NRR Rapresentative 3.

Regional Based Inspectors - Related Region D.

Reportina Requirements Results of this special effort will be discussed in a brief report that will be forwarded to J. Stone, Division of Reactor Programs Office of Inspection and Enforcement.

The report will identify those l

j items that are in conformance with the requirements of 10CR 50, Appendia R.

However, the report will include sufficient information

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to clearly identify those items that are not in conformance with l

information described in the SER and supporting Documents of Appendiu R to 10 CR 50.

This latter action is necessary to obtain resolution of i

the problem and permit followup by region based inspectors.

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EXPIRATION This TI will remain in effect until the special inspection effort.

is completed at all nuclear power facilities that were operating prior to January 1, 1979.

j Followup inspection effort will be performed as part of the normal inspection program and will be reported in related inspection reports.

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It HEADQUARTERS CONTACT Questions regarding this TI should be addressed to J.C. Stone 4

I (492-9656).

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G.

766 DATA INPUT For module tracking system input, record actual inspection effort i

against module l'o. 255XXB i

71 2515/XX 3

Pasa cf

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Inste Dates

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ENCLOSURE 1 j

10 Cllt 50, APPENDIE R, INSPECTION REQUIREMgNTS ITEM III.G., SAFI SNUTDOWN CAPABILITY.JtIf.T MM A[..f g $. ]

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1.

Verify that modifications necessary to assure safe shutdown are in conformance with the information described in the

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safety evaluation report (SER) and supporting documents.

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2.

Examine related cable trays and equipment in safety and o t-nonsafety circuits that could pr@ vent safe shutdown operation,,/.rdn/

or cause saloperation due to hot shorts, open circuits, or d' , t. /

i shorts to ground and verify that they have proper separation requirements and/or application of insulation or shielding N/ g",7 l

material as described in the SER and supporting documents.

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3.

Verify that installation and testing of necessary fire detectors i

and automatic fire suppression stystems are as described in the SER and supporting documents.

t 4.

Review the licensees testing program for demonstrating the adequacy of the various combinations c.f egoipment associated with the safe shutdown capability:

t a.

Discuss basis (criteria) for test with licer.see representatives and assure that testing performed included the worst case scenario.

b.

Verify that approved safe shutdown procedures have been prepared for the various combinations of equipment and circuits.

Review the qualifications of personnel responsible for c.

performing the testing, reviewing test results and preparna safe shutdown procedures and verify that they meet the qualification requirements described in the licensees managenest controls progras.

d.

If possible, witness an ongoing test of safe shutdown capability.

Review the test report and discuss identified problem e.

areas with licensee personnel.

f.

Assure that necessary changes were made to equipment, test procedures, and safe shutdown procedures and that ratesting was completed.

5.

Verify that licensees training program for licensed and nonlicensed personnel has been expanded to include safe shutdovn capability training for all required individuals.

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71 2515/XX Fase of Issue Datot t 't e a III, J.

EMERGENCY LICMTING 1.

Verify that emergency lighting units have been installed in all areas identified in the SAR and supporting documents.

2.

Review test records that demonstrate the emergency lighting units provide sufficient lighting to permit operation of the safe shutdown equipment and access and egress thereto.

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3.

Review testing documents or vendor literature to assure that the energency units meet the 8-hour battery life requirement.

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Verify that the licensee has developed administrative controls and procedures to assure proper surveillance of the units.

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( m III. L.

ALTERNATIVE AND DEDICATED gNUTD0WW CAPA31LITY I

i 1.

Verify that modifications necessary to assure alternative and i

j dedicated shutdown capability are in conformance with information i

discussed in the SER and supporting documents.

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2.

Examine the alternative and dedicated shutdown equipment, systems h

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3.

Review the licensees testing prdgram for assurids alternative and dedicated shutdown capability and verify that it includes tf j

provisions for assuring that:

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The reactivity control function shall be capable of achievingM(M a.

and maintaining cold shutdown reactivity conditions. Q g.

i b.

The reactor coolant naheup function shall be capable of I

maintaining the reactor coolant level above the top of the core for BVR's and be trithin the level indication in the pressuriser for FWR's.

t c.

The reactor heat removal function shall be capable of achieving an$ maintaining decay heat removal.

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d.

The process monitoring functions provide direct reading of the process variables necessary to perform and control the functions in Item 3.a., b. and c. above.

e.

The supporting functions are capable of providing the process l

cooling, lubrication, etc., necessary for operation of said j

shutdown equipeent.

c.

f f.

The program includes provi,sions for verifying tha alternative

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and dedicated shutdown capability can be achieve using available off site power and during periods when offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />,.

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71 2515/XX Page cf Issue Date:

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4.

Review the results of the licensees testing program for demonstrating the adequacy of alternative and dedicated shutdown capability and verify that the etiterla identified in Item 3 above were accomplighed. In.

addition,Myggent_probleis 'itens with,Disan J.1 eqteegsrs6na Assure that necessary changes were made to systems or equipment, testin(g 3

l procedures, safe shutdown procedures and that retesting was completed.

5.

Review the qualifications of personnel involved in the installation, testing, etc. activities and verify that they meet the minimum qualification requirements delineated in, licensee administrative l

controls.

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6.

Verify that the licensee's administrative controls program includes i

provisions for assuring that materials and procedures for the l

J repair of damaged systems or equipment necessary to achieve and maintain cold shutdown conditions will be readily available t

onsite for prompt repair, i

7.

Verify that approved procedures for alternative and dedicated shutdown are available for use by operating pegg.opne.

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Verify that the licensees t ning N egrans for licensed and i

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nonlicensed personnel hav een revised to include training for al ve d dedicat shu a tivitie g

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OIL COLLE IONSYSTEMFRREACTORC06LANTPUtfP

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1.

Verify that the collection system has been installed as discribed l

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in the SAR and supporting documents. This includes verification l

j that drain lines have been connected to all identified leakage points.

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Review test records that demonstrate leak tightaess of installed d

system.

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3.

Review test records that demonstrate the operability of the flame i

arrestor.

4.

Review drawings of as-built system and assure that drain lines have 4

been connected to all identified leakage points.

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l 71 2515/XX Page of Issua Date i

ENCIASURE 2 l

D.C. COOK FACILITY t

Item III. G - Inspection of safe shutdown capability - Specific activity to be conducted at D.C. Cook site A.

Obtain a listing of all safety related and nonsafety related systems, subsystems, components, control circuits and related equipment that licensee has designated for safe shotdown capability.

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Using full size, as-built, facility drawings, have licensee representative

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3.

identify the location of equipment discussed in "A" above including the specific location of redundant features -

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wt Tts.w =>M NT Sw vv t.cm T12 Aiu (wMus Aman,; p C4f."J Wh ent V l

C.

Review as-built cable routing drawings and have licensee representative identify the specific routinI of cable through cable trays for the safety related and nonsafety related equipment used for safe shutdown capability.

D.

Have a licensee representative describe the audit program, etc., that was t

used to assure that the cables were routed as identified on the drawings i

for all safety related and nonsafety rei.ated equipment required for safe shutdown capability.

The discussion should include a description of i

any specia't testing techniques that may have been used to verify the routing.

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E.

During a valk through inspection of the control room, cable spreading room and selected fire zone areas which include cable penetration areas, verify:

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1.ri Safe shutdowngcomponents identified in Iten "A" above meet separation,

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Installed separations barriers, suppressio devices, insulation

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material, etc., conform to applicable fi Fotectioncodes.

l 3.

Installed safe shutdown components are as described on drawings.

l F.

Review the licensees approved procedures for achieving safe shutdown l

conditions.

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G.

Review the licensees testing procedures and test results which were used to demonstrate that the installed safe shutdown equipment has the capability to achieve safe shutdown conditions, c

I.

Review the licensees adminsitrative controls program for assuring that i

materials and procedures for the repair of damaged systems or equipment d

necessary to achieve and maintain cold

• shutdown conditions as described in Appendix R. Item L.5.

i I.

Verify that the licensees training program for licensed and nonlicensed i

personnel has been revised to include training for safe shutdown activities. Review training records to assure that program has been implemented.

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71 2515/XX Page cf Issua Dates PROPOSED INSPECTION TEAM and 4

ESTIMATED MAN HOURS SPECIAL TIRE PROTECTION INSPECTION TEAM A.

Team sakeup 1.

Safe shutdown consultant 2.

NRR Fire protection specialist.

3.

It specialist - Related regional office 4.

Part-time participation by IE Headquarters representative 3.

Estimated Inspection Time Each Facility 1.

Preparating time - 2 weeks This involves reviewing the related safety analysis report (SAR) and suppirting documents that were submitted by licensees in response to NRR requests and the NRR issued safety evaluation report (SER).

Preparation time may decrease af ter the team members become more familiar with the installed equipment and related requirements.

2.

Inspection Time - 1 week including travel time 3.

Documentation Time 3 days 4

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TIRE PROTECTION ACTIVITIES COVERED IN ROUTINE INSPECTION HODULES 35751 -

Identifies the specific FP criteria that must be included in licensees QA program.

37700 -

Requires verification that appropriate fire protection controls were implemented for design change modifications involving welding.

cutting, etc.

i 37701 -

Requires inspection of NRC approved modifications i

37702 -

Requires verification that procedures and responsibilities for design control include provisions for fire protection / prevention requirements delineated in R.G. 1.120 54701 -

Verifies that licensee has an effective housekeeping / cleanliness j

progran 61700 -

l Includes provisions for the periodie verification that the licensee is completing the surveillance testing of fire protection components j

discussed in Facility T S 62700 -

Includes requirements for the inspector to review maintenance procedures to assure that TP requirements identified in R.G. 1.120

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are covered

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62701 -

Includes requirements for the inspector to review procedures for scheduled maintenance activity to assure that applicable requirements i

of RG1.120 are included.

64703 -

includes provisions for the periodic review of the licensees FP program for confirmation with RC 1.120 64704 -

Requires inspector to conduct a facility tour to observe the licensee's implementation of FP practices Requires the resident inspector to conduct weekly facility tours 71707 -

during long tern shutdowns to assure the effectiveness of TP practices

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71709 -

Requires the resident inspector to include the observation of TP practices during the biweekly tour of ongoing activities, i

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CH ARLES R. JONES e 13 24 HARTSDOURNE DRIVE e OERM ANTOWN. MARYLAND 20874 (3o:1e72ots?

Febevery 1, IM8 Uti.EDOM OF INFORMATIOM ACT REQUEST Rt.TA-l1-9L Mr. Donnie H. Grimsley p

Division Olrector

/g 2-// [p Of fice of Administrollon, Rules ed Records U.S. Nuclear Regulatory C mmission Washington, D.C. 20555 Attention: FOIA Deor Mr. Grimsley:

! wish to obtain several documents pertolning to 10CFR50 Appendix R Inspections and enforcement. Accordingly, the following materiols are rewested under the Freedom of Information Act:

1.

Copies of oil Heodg>orters and Regional Inspection modules used to verify nuclear utility compliance with fire protection rewirements speelfled in 10CF R50, 1

Appendix R, including drof ts and revisions of those Inspection modules.

2.

Internot corre:pondence bstween or among regional of ficas, ed between regional offices ed the l@ C Heodworters, concerning use of Appendix R inspection

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modules.

3.

Commission popers and transcripts of Commluton meettrus regarding Appenda R lempection modvies andler Irmpect on results.

4.

Commluton poper and IranscfIpt: of Commluton meetings referring to determination of enforcement octions and civil penolfles resulting from fire protection Inspections, Including

• closet hearings such as that which occurrM on or obout June 8, IM7.

5.

Notices of violation resvi ing from Appendix R t

inspections for Vermont Ymkee, Ft. Colhoun, Dovls Bene, Fort St. Vroln, Solem, end Pilgrim.

- stcD%DYA e9 PP-

CH ARLES P. JONES e 13824 H ARTSBOURNE DRIVE o OERM ANTOWN. M ARYLAND 2o074 poli e72 n197 i

6.

The Differing Professional Opinion (DPO) sired by several NRC fire protection personnel concerning Appendix R pidonce and all NRC memoredo, files, and notes pertoitt'ig to the review and disposition of the OPO.

I understand that it mer be necessary for me to pay for the stoff research and materlots involved with responding to this request. I oppreclote your assistece.

Sincerely, W

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Charles R.

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CRJ/II j

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