ML20198E570
| ML20198E570 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/09/1986 |
| From: | Anderson C, Krosopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198E563 | List: |
| References | |
| 50-277-86-08, 50-277-86-8, 50-278-86-08, 50-278-86-8, NUDOCS 8605280063 | |
| Download: ML20198E570 (10) | |
See also: IR 05000277/1986008
Text
-
.
. - - _ _ --
-
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-277/86-08 and 50-278/86-08
Docket No.
50-277/50-278
Priority
-
Category
C
Licensee: Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania 19101
Facility Name: Peach Bottom Atomic Power Station Units 2 and 3
Inspection At: Delta, Pennsylvania
Inspection Conducted: March 17-21, 1986
Inspector:
ie
Nf
Nac4- Y _ /9/6
A. Krasopoul'os, Re%ctor Engineer, DRS
- ate'
~
Also participating in the inspection and contributing to
the report were:
J. Stang, Fire Protection Specialist, NRR
K. Parkinson, Electrical System Specialist, BNL
A. Coppola, Mechanical Systems Specialist, BNL
~ St2A,A
>>44/
//9 f/o
Approved by:
,
El 3 3d* "' " '"T* ' "' * "' It**
' '
Section, DRS
V
Inspection Summary:
Inspection on March 17-21, 1986 (Combined Report No.
50-277/86-08 and 50-278/86-08)
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 L, concerning fire protection features to ensure the ability to achieve
and maintain safe shutdown in the event of a fire.
Results: No violations were identified.
Five items remained unresolved at
the end of the inspection.
6
8605280063 860514
ADOCK.0500
7
,
e
-
.
- - .
-
-
_
_ -
.
- - - -
r;
-
.
.
DETAILS
1.0 Persons Contacted
1.1 Philadelphia Electric Company (PECO)
- H. Abendroth, Co-owner Site Representative
- W. Birely, St. Licensing Engineer
- W. Boyer, Electrical Supervising Engineer
- G. Brecht, Jr., Chief Electrical Engineer
- G. Cambell, Senior Designer
- R. Dellangelo, Designer
- R. Fleischmann, Plant Manager
- C. Gerdes, Mechanical Engineer
- M. Lohr, Electrical Engineer
R. Lonabaugh, Fire Marshal
- J. McCawley, Electrical Engineer
- W. Mindick, Sr. Electrical Engineer
- G. Morley, Supervising Engineer
J. Pizzolo, QA Engineer
- G. Reid, Sr. Mechanical Engineer
- M. Ryan, Compliance Engineer
- 0. Spaner, Engineer
- S. Spitko, Administrative Engineer
- C. Swenson, Compliance Engineer
- G. Termine, Engineer
- W. Ullrich, Superintendent Nuclear Generation Division
T. Wilson, Site QA Supervisor
1.2 Licensee Contractors
- A. Melikian, Project Engineer (EPM)
- D. Brecken, Project Manager-(EPM)
1.3 Nuclear Regulatory Commission (NRC)
- T. Johnson, SRI
- G. Gears, Project Manager
J. Williams, RI
- Denotes those present at exit interview.
2.0 Purpose
This team inspection was conducted to ascertain licensee compliance with
10 CFR 50, Appendix R, Sections III. G, J, and O.
Because full compliance
with the above regulations is not required until the end of the next
i
Unit 2 refueling outage, the team reviewed the licensee's approach to
compliance, along with the plans and schedules for completing all other
modifications required in this area.
i
.
_
.
o
,
3
.
3.0 Background
10 CFR 50.48 and 10 CFR 50, Appendix R, became effective on February 17,
1981.
For Peach Bottom Units 2 and 3, the applicable portions of this
regulation are Sections III.G, " Fire Protection of Safe Shutdown Capa-
bility," III.J, " Emergency Lighting," and III.L, " Alternative and
<
Dedicated Shutdown Capability."
10 CFR 50.48 sets forth the schedule for the completion of modifications
required for compliance with the above regulations.
Section III.G of
Appendix R requires that fire protection features are provided to ensure ~ ~ ~~~
~
that one train of equipment necessary to achieve and maintain safe shut-
down remains available in the event of a fire at any location within a
licensed operating facility.
For hot shutdown conditions, one train of
the systems necessary must be free of fire damage (III.G.I.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 to provide adequate protection for redun-
dant trains of equipment located outside of the primary 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
systems of concern are subject to damage from fire suppression .
activities,Section III.G.3 of the rule requires that an alternate or
dedicated shutdown 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--
4
Section III.G, however, such protection is deemed to be adequate by the
licensee for the specific situation, the rule allows the licensee to
request 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.
Presently the licensee must comply with all of the requirements iterated
above. One exemption from full compliance is the modification work
'
associated with the alternative shutdown capability for Unit 2.
Since
some of the alternative shutdown systems are common to both units, alter-
-
- -
.
-
- - -
-
-
-
- -
- -
- - - -
-
.
-
.
-
.
.
.
4
native shutdown capability is not required for either unit until the end
of the next Unit 2 refueling outage. Also, because the licensee is
developing a more detailed fire hazards analysis, compliance with section
III.G and J. could not be fully ascertained.
The analysis will be completed
by September 30, 1986.
4.0 Post-Fire Safe Shutdown Capability
4.1 Systems Required for Safe Shutdown
In the event of a fire concurrent with the loss of offsite power, the~ ~~ ~
following systems are used to provide the safe shutdown capability
of the plant:
-
High Pressure Coolant Injection (HPCI) System
-
Reactor 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
injection (LPCI) mode
-
Core Spray (CS) System
-
High Pressure Service Water (HPSW) System
-
Emergency Service Water (ESW) System
-
Onsite AC Power Generation and Distribution System
-
Onsite DC Power Generation and Distribution System
-
Essantial Ventilation Systems
Safe shutdown is initiated from the control room by a manual scram
of the control rods or automatically by the reactor protection
system.
The support systems required for safe shutdown include the emergency
service water system (ESW) for diesel generator cooling, high
pressure service water system (HPSW) for RHR heat exchanger cooling,
onsite AC emergency power system, onsite DC Emergency power system
and essential ventilation systems.
The precise methodology used for safe shutdown has not been finalized
by the licensee. Currently, the following shutdown methods are under
review:
Method-A
For Method A, RCIC is used to maintain reactor vessel coolant inven-
tory.
RHR and HPSW are used for suppression pool cooling which is
required for decay heat removal.
Heat is transferred from the vessel
to the suppression pool via the ADS system and/or the RCIC steam
turbine discharge.
-
-
- _ _ _ _ - _ .
.
5
.
Method B
For Method B, HPCI is used to maintain reactor vessel coolant inven-
tory, RHR and HPSW are required as in method A for suppression pool
cooling.
Heat is transferred from the vessel to the suppression 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 committed to and is in the process of_ establishing
alternate safe shutdown capability independent of the main control
room, cable spreading room and the emergency shutdown panel area.
The alternative shutdcwn stations are provided with circuit isolation
capability using manual control switches, relays, breakers or fuse-
disconnect switches, to ensure that no electrical connection exists
between the alternative shutdown circuits and those affected by a
fire in any one of the above-mentioned areas.
In the event of an unmitigated fire in these areas, the operators
will proceed to the alternative shutdown stations to initiate shut-
down operations.
Communications will be established between the
operators who are at the alternative shutdown stations and the
coordinating operator. The alternative control stations for Peach
Bottom are or will be in the following locations:
4.2.1
HPCI Alternative Control Station - This panel will be located
in each unit in the MG set room at elevation 135' - 0".
The-
HPCI alternative control station will be equipped with pump
diagnostic instrumentation and transfer switches and alternative
power supplies for the HPCI turbine. This panel will be equipped -
with the alternative process monitoring instrumentation which
indicates reactor vessel pressure and level, suppression pool
temperature, and condensate storage tank level.
4.2.2
Diesel Generators Alternative Control Station - These panels will
be located in Unit 2 4KV emergency switchgear rooms B/D and are
common to both Units 2.and 3.
The panels will be equipped with
transfer switches to isolate all main control room control
circuits, and also diesel generator diagnostic instrumentation.
,
,
_
. - ~ -
_
_ _
.
6
.
4.2.3
4KV Emergency Switchgear Alternative Controls - These controls
are located in the 4KV emergency switchgear rooms in each
unit.
Transfer switches will provide alternative local control
and status indication for the motor control centers and for the
4.2.4
ADS Transfer / Isolation Station - Alternative control capabilities
for 3 ADS valves and the associated nitrogen supply isolation
valves will be located on the HPCI Alternative Control Stations
in the M-G Set Rooms.
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.
4.2.5
RHR/HPSW Suppression Pool Alternative Control Stations -
Alternative control capabilities and transfer / isolation switches
for one loop of RHR/HPSW Motor Operated Valves (MOV's), needed
to support Suppression Pool Cooling, will be located at the HPCI
Alternative Control Stations in the M-G Set Rooms.
4.3 Remaining Plant Areas
The licensee indicated that all other areas of the plant not required
to have an alternate safe shutdown system, comply with the requirements
of Section III.G.2 of Appendix R, unless an exemption request has
been approved by the staff.
5.0 Inspection Methodology
The inspection team examined the licensee's provisions 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 compli-
ance with Section III.G.
The following functional requirements were reviewed for achieving and
maintaining hot and cold shutdown:
Reactivity control
Pressure control
Reactor coolant makeup
Support systems
Process monitoring
.
-
_ _ - -
.
.,
..
.
. . ,
- . - -
.
-
.
7
.
The inspection team examined the licensee's capability to achieve and
maintain hot shutdown and the capability to bring the plant to cold shut-
down 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 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
(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.
The inspection team examined the licensee's fire protection features
provided to maintain one train of equipment needed for safe shutdown free
of fire damage.
Included in the scope of this effort were fire area
boundaries, including walls, floors and ceilings, and fire protection.of
openings such as fire doors, fire dampers, and penetration seals.
4
The inspection team also examined the licensee's compliance with Section
III.J, Emergency Lighting.
Section III.0, Oil Collection System for
Reactor Coolant Pump is not applicable to the licensee since the contain-
ment is inerted during normal operations.
)
6.0 Inspection of Protection Provided for Safe Shutdown Systems
6.1 Protection in Various Fire Areas
The team reviewed the protection prov'ided to SSSs in selected fire
areas for compliance with Appendix R, Sections III.G.1, 2 and 3.
The following fire areas were inspected:
--
The Control Room
The Cable Spreading Room
--
'The Switch Gear Room
--
--
The Battery Room
--
The Intake Structure (Fire Areas 47 and 48)
--
The Turbine Building
--
The Reactor Building, Fire Areas 5, 6, 12 and 13
.
<
. - - - .
- - - - - -
. - - .
-
-
-
.
.
.
.
-
.
.
.
- -
.
.
. - . - . . . - -
. . .
- .
. - - . - - - . -
. - -
-
. -
.
. .
- - - .
-
. - .
.
. .
. - - - . . -
.
-
. -
.
-
.
8
.
--
The Radwaste Building, Fire Areas 2 and 25
--
Yard Area Manholes 25, 89 and 90
No unacceptable conditions were identified except as follows:
Inspection effort incomplete because of unfinished analysis.
The inspection team could not ascertain the licensee's compliance
with Section III.G of Appendix R because the analysis identifying
the shutdown methodology had not been finalized at the time of the
inspection. This is an unresolved item pending completion of the
analysis.
(50-277/86-08-01 and 50-278/86-08-01)
6.2 Safe Shutdown Procedures
The team requested to review safe shutdown and alternative shutdown
procedures to ascertain that shutdown can be achieved in a safe and
orderly manner.
The licensee stated that these procedures have not been developed as
yet but will be in effect by the end of the next Unit 2 refueling
outage. This is in agreement with previous commitments made to the
NRC.
This is an unresolved item pending licensee completion of the
procedures.
(50-277/86-08-02 and 50-278/86-08-02)
'
6.3 Protection for Associated Circuits
Appendix R,Section III.G requires that protection be provided for
associated circuits that could prevent operation or cause malopera-
tion 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.
6.3.1
Common Bus 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.
- -
- - -
- -
1
.
9
.
The team examined, on a sampling basis, protective relay
coordination for 4160V and 480V buses and protection for
specific instrumentation, control and power circuits.
The
coordination of fuses and circuit breakers was checked by
examination of the licensee's fuse and breaker coordination
curves. The licensee performs relay calibration during
refueling outages on approximately 18 month intervals.
No unacceptable conditions were identified.
6.3.2
Spurious Signals Concern
~
~~
-
The spurious signal concern is made up of 2 items:
False motor control and instrument indications can
occur such as those encountered during the 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).
The team requested to review documents, on a sampling
basis, in the following areas to ascertain that no spurious
signal concern exists:
Current transformer secondaries
High/ low pressure interfaces
General fire instigated spurious signals
-
The licensee explained that an associated circuit analysis
for spurious signals is currently being developed but is
not yet finished.
This is an unresolved item pending the licensee's comple-
tion of an associated circuits analysis for spurious
signals.
(50-277/86-08-03 and 50-278/86-08-03).
6.3.3
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 a ~ fire can
destroy both circuits due to inadequate fire barriers. The
team could not inspect this area since the licensee's
analysis was incomplete. The licensee stated that this
analysis is currently in process.
..
10
,
This is an unresolved item pending licensee completion
of the analysis and reinspection in this area.
(50-277/86-08-04 and 50-278/86-08-04)
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.
~.
- _ . -
-.
Due to lack of safe shutdown procedures, the team was not able to inspect
this area. This item remains unresolved.
(50-277/86-08-05 and
50-278/86-08-05)
8.0 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 for either
unit is inerted during normal operation, the above requirement does not
apply to Units 2 or 3.
9.0 _ Unresolved Items
Unresolved items are matters for which more information is required in
order to ascertain whether they are acceptable, violations, or deviations.
Unresolved items are discussed in Sections 6.1, 6.2, 6.3 and 7.0.
10.0 Exit Interview
The inspection team met with the licensee representatives, denoted in
Section 1.0, at the conclusion of the inspection on March 21, 1986, and
the team leader summarized the scope and findings of the inspection at
that time.
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
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.