ML20214U034

Special Rept:During Update of Safe Shutdown Data Base, Conditions Re Unencapsulated Cables in Fire Areas Identified as Reportable Per Confirmatory Action Ltr 86-07 & App R. Caused by Exclusion from Previous Analysis.Fire Watch Begun

ML20214U034
Person / Time
Site:	Peach Bottom
Issue date:	06/04/1987
From:	Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
CAL-86-07, CAL-86-7, NUDOCS 8706110020
Download: ML20214U034 (4)

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. DOX 8699 PHILADELPHI A, PA.19101 (215184 f.4 50 2

. .,l.'.*.7.".'I. .l"la.= June 4, 1987 Docket Nos. 50-277 50-278 Mr. William T. Russell Administrator Region I U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Special Report: Conditions of Non-Conformance with 10 CFR 50 Appendix R at Peach Bottom Atomic Power Station Units 2 and 3 References Confirmatory Action Letter 86-07, dated April 11, 1986, from S. D. Ebneter, NRC, to S. L. Daltroff, PECo

Dear Mr. Russell:

The purpose of this letter is to report two conditions of non-compliance with the Appendix R Safe Shutdown requirements at Peach Bottom Atomic Power Station. These reportable conditions were identified during a recent update of the safe shutdown database.

Over the past two months, the database has been updated to include changes, up to and including the current Unit 2 outage modifications, that have been designed or as-built since the completion of the Philadelphia Electric Company Appendix R design verification program in 1986. The update performed a double check to ensure that the modifications designed to correct existing deficiencies, including Unit 2 alternative shutdown capabilities, do not create new deficiencies and do indeed correct all deficiencies previously identified.

The update has revealed the following conditions which are reportable in accordance with NRC Confirmatory Action Letter 86-07.

8706110020 070604 PDR B

ADOCK 05000277 '

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Mr. William T. Russell June 4, 1987 Page 2 Condition I The safe shutdown method relied upon for Unit 2 to recover from a fire in Fire Area 6S requires operation of the high pressure coolant injection (HPCI) system. An Appendix R fire in Fire Area 6S results in the failure of high drywell pressure inputs to the HPCI automatic initiation logic. Cables ZB201203A and ZA2Q1191A are in Fire Area 6S and are not encapsulated.

Significance of Condition An Appendix R fire in Fire Area 6S would result in a maintained automatic initiation signal for HPCI; consequently, control to change positions of the HPCI steam supply valves (MO 2-23-014, MO 2-23-015, and MO 2-23-016), the HPCI redundant test bypass to~66T valve (MO 2-23-024), and the HPCI flush line shutoff-to-torus  ;

valve (MO 2-23-031) would be lost. Due to other cable failures from the Appendix R fire, the capability to trip HPCI previously relied upon the ability to close one of the three steam supply valves. The failure of either of the above two cables would preclude this capability; consequently, the ability to trip HPCI could not be assured.

Secondly, the loss of operability of both the redundant test bypass to CST and the flush line shutcff-to-torus valves results in the inability to recirculate HPCI flow. The analysis done for Fire Area 6S takes credit for recirculating HPCI flow to extend the amount of time available for manual operations, required by an Appendix R fire, to establish torus cooling capabilities. The failure of either of the above two cables would preclude recirculating capabilities; consequently, adequate torus cooling i may not be available.

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Cause of Condition The previous analysis did not include these cables for the HPCI logica.

Interim corrective Action A fire watch was established in November 1986 for other Appendix R violations, as required by Technical Specifications, to assure early detection of a fire in Room 403 of Fire Area 6S. This fire watch will remain in place until all Appendix R violations are

Mr. William T. Russell June 4, 1987 Page 3 corrected. Since the plant is in cold shutdown and the HPCI system is only required for hot shutdown, further interim corrective actions are not necessary. In addition, the modification described under permanent corrective action will be completed prior to the restart of Unit 2.

1 Permanent Corrective Action The capability to trip the HPCI turbine will survive a fire in Fire Area 6S by the installation of a two-staged, separately fused, HPCI turbine trip pushbutton.

The capability to recirculate HPCI flow will survive a fire in Fire Area 6S by the installation of an isolation switch in the circuitry for the redundant test bypass to CST valve. This switch, only to be operated in the event of an Apppendix R fire, will isolate automatic close signals and restore control room control of the valve.

Condition II The safe shutdown method relied upon for Unit 2 to recover from a fire in Fire Area 6N requires the capability to trip the high l pressure coolant injection (HPCI) system. An Appendix R fire in Fire Area 6N results in the failure of high drywell pressure inputs to the HPCI automatic initiation logic. Cable ZB2Q1203A is in Fire Area 6N and is not encapsulated.

Significance of condition An Appendix R fire in Fire Area 6N would result in a maintained automatic initiation signal for HPCI; consequently, control to 1 close HPCI steam supply valves (MO 2-23-014, MO 2-23-015, and MO 2-23-016) would be lost. Due to other cable failures from the Appendix R fire, the capability to trip HPCI previously relied upon the ability to close one of the three steam supply valves.

The failure of the above cable would preclude this capability; conocquently, the ability to trip HPCI could not be assured.

Mr. William T. Russell June 4, 1987 Page 4 Cause of Condition The previous analysis did not include this cable for the HPCI logica.

l l Interim Corrective Action l A fire watch was established in November 1986 for other Appendix

! R violation, as required by Technical Specifications, to assure early detection of a fire in Room 205 of Fire Area 6N. This fire watch will remain in place until all Appendix R violations are corrected. Since the plant is in cold shutdown and the HPCI system is only required for hot shutdown, further interim l corrective actions are not necessary. In addition, the l modification described under permanent corrective action will be completed prior to the restart of Unit 2.

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Permanent corrective Action l The capability to trip the HPCI turbine will survive a fire in Fire Area 6N by the installation of a two-staged, separately fused HPCI turbine trip pushbutton (this is the same pushbutton discussed for condition I). The modification resolves previous cable problems that were dispositioned an acceptable because it was believed that the control of steam supply valve was available.

l If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours,

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cc: Addressee W. R. Butler, Director, Project Directorate 1-2, USNRC T. P. Johnson, Resident Site Inspector l

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