ML20215L878
| ML20215L878 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/01/1987 |
| From: | Anderson C, Krasopoulos A, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20215L867 | List: |
| References | |
| 50-277-87-11, 50-278-87-11, NUDOCS 8705120410 | |
| Download: ML20215L878 (5) | |
See also: IR 05000277/1987011
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U.S. NUCLEAR REGULATORY COMMISSION
-REGION I
Report Nos.-
50-277/87-11 and 50-278/87-11
Docket Nos.
50-277 and 50-278
License Nos.
DPR-45 and OPR-56
Category
C
Licensee:
Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania 19101
Facility Name:
Peach Bottom Units 2 and 3
Inspection At:
Philadelphia, Pennsylvania
Inspection Conducted:
April 9, 1987
Inspectors:
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W. K&asop6~
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teactor_Engiaeer
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4l2WP7
~S. Pull ni
Fire Protection Engineer
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Approved by:
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C. Agfderson, Chief, Plant Systems Section
date
Inspection Summary:
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Inspection on April 9,1987 (Combined Inspection Report Nos. 50-277/87-11
and 50-278/87-11)
Areas Inspected:
Special announced inspection to review and verify the 10 CFR 50 Appendix R nonconformances identified by the licensee.
Results: One violation was identified (Failure to maintain at least one safe
shutdown train free from fire damage).
Five examples of the violation were
verified.
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DETAILS
1.0 Persons Contacted (Entrance and Exit Interview)
1.1 Philadelphia Electric Company (PECO)
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W. Boyer, Supervising Engineer
D. Spammer, Electrical Engineer
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2.0 Background
The Nuclear Regulatory Commission (NRC) during March 17-21, 1986 performed
an inspection to assess the licensee's safe shutdcwn capability required
As a result of this inspection, the NRC, on
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April 11, 1986, issued a Confirmatory Action Letter requesting that the
licensee complete the Appendix R safe shutdown confirmatory program and
inform the NRC Region 1 of any violations of the Appendix R requirements.
The licensee, by letters dated May 22, 1986, September 17, 1986 and
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October 31, 1986, informed the NRC that in at least 51 instances, the
requirements of 10 CFR 50 Appendix R were not satisfied.
3.0 Purpose and Inspection Methodology
This inspection was conducted to review the details of the violations of
the Appendix R requirements identified by the licensee, and to assess the
extent of these violations. The inspectors reviewed five of the fifty-one
nonconformances identified by the licensee.
To perform this review, the inspectors examined the licensee's safe shut-
down evaluation report and reviewed their consultant's reports prepared
for determining the consequences of fire in any plant location on the
ability to safely shutdown-the plant.
The following section describes the applicable requirements and the
associated nonconformances as identified by the licensee and verified
by the inspectors.
4.0 Review of Nonconformances
10 CFR Part 50, Appendix R, Section III.G.1 requires that fire protection
features shall be provided for structures, systems, and components
iraportant to safe shutdown. These features shall be capable of limiting
fire damage so that one train of systems necessary to achieve and maintain
hot shutdown conditions from either the control room or emergency control
station (s) is free of fire damage.
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Section III.G.2 specifies four alternatives that may be implemented
outside of primary containment to assure that one redundant train of
equipment, cabling and associated circuits necessary to achieve and main--
tain hot shutdown remains free of fire damage. The alternatives are:
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Separation of redundant trains of equipment, cabling and associated
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circuits by a three-hour rated fire barrier.
Separation of redundant trains of equipment, cabling and associated
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circuits by a horizontal distance of 20 feet with no intervening
combustibles and fire detection and automatic fire suppression
systems installed in the area.
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Enclosure of redundant trains of equipment, cabling and associated
circuits by a one-hour rated fire barrier with fire detection and
automatic fire suopression systems installed in the area.
Installation of alternative or dedicated shutdown capability
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independent of the equipment, cabling and associated circuits under
consideration, and installation of fire detection and fixed-fire
suppression systems in the area under consideration.
The' licensee informed the NRC that in fifty-one instances, the require-
ments of 10 CFR 50 Appendix R were not implemented.
The inspectors reviewed five of these nonconformances to verify the vio-
lations and assess the severity. The nonconformances reviewed are as
follows:
1.
The licensee has identified four safe shutdown methods, A, B, C
and D.
All of these methods require emergency AC power which is provided by
the Emergency Diesel Generators. To prevent tripping of the Diesel
Generators from overheating, cooling water is provided only by the
Emergency Service Water (ESW) Pumps A and B.
Either pump is capable
of providing the required flow of cooling water to the Emergency.
Diesels. The licensee determined that the control cables ZB2A1603L
for ESW Pump A and ZC2A1706L for ESW Pump B are routed in fire
area 43. Because these cables are not protected or separated in
accordance with the Appendix R,Section III.G.2 requirements, a fire
induced ground of these cables in this area will render both ESW
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pumps inoperable thus causing the Diesel Generators to trip from
overheat.
Thus, a fire in fire area 43 will prevent safe shutdown of both
Units 2 and 3 by ultimately affecting the emergency power sources,
i.e., the Emergency Diesel Generators.
2.
Decay heat removal is a fun:: tion required to achieve the shutdown
goals established by CFR 50 Appendix R,Section III.G.I.
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Decay heat removal is accomplished by the use of the Residual Heat
Removal System (RHR) in the suppression pool cooling mode.
The
Unit 2 RHR system utilizes four pumps, 2AP35, 2BP35, 2CP35 and 2DP35.
Anyone of these pumps is capable of providing the flow required to
perform the decay heat removal function. Control cables from all
four pumps are routed through fire area 3S.
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Because these control cables are not protected or separated in-this
fire area as required by 10 CFR 50 Appendix R, Section III.G.2, a hot
short or short to ground by a fire in this area will render all four
RHR pumps inoperable, thus preventing safe shutdown of Unit 2.
3.
Monitoring of the reactor water level and of reactor pressure is
required to achieve ard maintain hot shutdown condition in accordance
with 10 CFR 50 Appendix R, Section III.G.I.
In Unit 3 to monitor reactor water level and pressure, the licensee
must utilize any one of the following instruments:
LI3-2-3-85A
Reactor Water Level Indicator
LI3-2-3-85B
Reactor Water Level Indicator
LI3-2-3-86
Reactor Water Level Indicator
LR3-2-3-110A
Reactor Water Level Recorder
LR3-2-3-110B
Reactor Water Level Recorder
PI3-6-90A
Reactor Pressure Indicator
PI3-6-90B
Reactor Pressure Indicator
PR3-2-3-404A
Reactor Pressure Reccrder
PR3-2-3-4048
Reactor Pressure Recorder
PR3-6-96
Reactor Pressure Recorder
However, the use of all of these instruments will be lost in a fire
within fire area 13N. This is because required associated compo-
nents of these instruments are located in fire area 13N and have
not been protected in accordance with the requirements of 10 CFR 50
Appendix R,Section III.G.2. Thus, a fire in fire area 13N will
prevent safe shutdown of Unit 3 because reactor water level and
reactor pressure could not be monitored.
4.
The licensee's safe shutdown analysis identified four shutdown
methods, A, B, C and D.
In these methods, the required reactor
coolant make-up function could be accomplished by the use of the
Reactor Core Isolation Cooling System (RCIC) in Method A or the High
Pressure Coolant Injection System (HPCI) in Method B or by the RHR
system in the Low Pressure Coolant Injection (LPCI) mode or the Core
Spray mode in conjunction with manual operation of the relief valves
for depressurization in Method C.
Method D also utilizes the HPCI
system.
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For Unit 2 in fire area 6S, the HPCI system will be lost because the
control cables to the HPCI turbine are routed through this area. The
RCIC system will also be lost because various system components such
as the power distribution panel, the RCIC flow controller, flow
indicator, the RCIC throttle valve, and the lube oil cooler isolation
valve will be affected by a fire in this area.
Also, both LPCI trains A and B and both trains of core spray system A
and B will be lost. Therefore, a fire in fire area 6S will prevent
safe shutdown because no one train of systems necessary to achieve
and maintain hot shutdown will remain free from fire damage as
required by 10 CFR 50 Appendix R, Section III.G.1 because the pro-
tection to redundant safe shutdown trains specified in 10 CFR 50
Appendix R,Section III.G.2 was not provided.
5.
All four safe shutdown methods identified by the licensee require
the manual use of the safety relief valves for depressurization.
The manual operation of these valves relies on the use of either
instrument air supply or nitrogen supply (Valves RV3-02-071A,B,C,G
and K require nitrogen, Valves RV3-02-0710,E,F,H,J and L require
instrument air).
In fire area 13S in Unit 3, the instrument air
supply to the relief valves and the nitrogen supply are routed
through this area. Because the air and nitrogen supply piping to
the valves is copper tubing with sweated joint connections, a fire
in this area will degrade this tubing, thus rendering the safety
relief valves manually inoperable.
Therefore, a fire in fire area
13S will prevent safe shutdown of Unit 3 because redundant safe
shutdown system components (instrument air and nitrogen supply
tubing) were not protected or separated as required by 10 CFR 50
Appendix R,Section III.G.2.
The nonconformances described above as identified by the licensee
and verified by the inspector are violations of 10 CFR 50 Appendix R,
Section III.G.
(50-277/87-11-01 and 50-278/87-11-01).
5.0 Exit Interview
The inspector met with licensee management representatives (see Section
1.0 for attendees) at the conclusion of the inspection on April 9, 1987.
The inspectors summarized the scope and findings of the inspection at that
time.
The inspectors 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 inspectors.