ML20235K138
| ML20235K138 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/04/1987 |
| From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235K073 | List: |
| References | |
| 50-336-87-16, GL-86-10, NUDOCS 8710020253 | |
| Download: ML20235K138 (14) | |
See also: IR 05000336/1987016
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No.
87-16
Docket No.
50-336
License No.
Priority
Category
C
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Licensee: Northeast Nuclear Energy Company
P. O. Box 270
Hartford. Connecticut 06141-0270
Facility Name: Millstone Nuclear Power Station, Unit 2 Station
Inspection At: Waterford, Connecticut
Inspection Conducted: July 13 - 17, 1987
Inspectors:
Oh C
.k A
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A. Krasdpoulos, Reactor Engineer
date
Also participating in the inspection and contributing to the report were:
D. Kubicki, Fire Protection Engineer, NRR
R. Hodor, Mechanical Systems Specialist, BNL
K. Sullivan, Electrical Systems Specialist, BNL
R. Perfetti, Reactor Systems Engineer, NRR
Approved by:
.e
9' f 8 7
C. J.l/ Anderson, Chief, Plant Systems
date
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Section, DRS
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Inspection Summary:
Inspection on July 13 - 17, 1987 (Report No. 50-336/87-16)
Areas Inspected:
Special, announced team inspection of the licensee's effort
to comply with the requirements of 10 CFR 50, Appendix R, Section III.G,J and 0
concerning fire protection features to ensure the ability to achieve and
maintain safe shutdown in the event of a fire.
Results: Two violations were identified.
(Failure to verify adequacy of a
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8710020253 8 090s
ADOCK 05000336
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Details
1.0 Persons Contacted
1.1 Northeast Utilities Corp. (N.U.)
- W.
Romberg
Vice President Nuclear Operations
- S. E. Scace
Station Superintendent
- J. Smith
Operations Supervisor
- R. Bates
Assistant Engineering Supervisor
H. Thompson
Sr. Engineer, Reactor Plant Systems
- F.
Dacimo
Engineering Supervisor
K. Deslander
Engineer
- J.
Heg
Operations Assistant
G. Closius
OA/QC Supervisor
- W. Lepper
Special Studies
R. Asafaylo
Quality Services Supervisor
- J.
Kennedy
Production Test Supervisor
- M. Ciccone
Licensing Engineer
- J. Humphreys
Maintenance Engineer
- G. Pitman
Electrical Engineering Manager
- R. Halleck
Electrical Engineer
- D.
Leduc
Station Services Engineer Fire Protection
- G. Kelliher
Station Services Engineer Fire P4atection
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- P. Blomberg
Engineer
- B.
Pokora
Reactor Plant Systems
- J. Naylor
Fire Protection Engineer
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- C
Sinopoli
Fire Protection Engineer
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- T. Patriz:
Fire Protection Engineer
- J. Rontaioli
Fire Protection Engineer
- K.
Hemeon
Engineer
- R. Ayala
Station Services Engineer
- G. Johnson
Director Generation Engineering and Design
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- G. Van Noordennen Licensing
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- G. Cornelius
Supervisor, Reactor Plant Systems
- J.
Regan
Supervising Generator Electrical Engineer
- R.
Ewing
Engineering Technologist
1.2 Nuclear Regulatory Commission (NRC)
- T. Rebelowski
Sr. Resident Inspector
- Denotes those present at the exit meeting.
2.0 Purpose
This inspection was performed to ascertain that the licensee is in
conformance with 10 CFR 50, Appendix R, Sections III.G,J and 0 including
exemptions approved by the Office of Nuclear Regulation (NRR).
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3.0 Background
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The licensee is required to comply with the requirements of 10 CFR 50
Appendix R,Section III.G,J and O.
Section III.G of Appendix R requires
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that fire protection is provided to ensure that one safe shutdown train
remains available in the event of a fire.
Section III. J requires that
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emergency lights are installed in all. areas required for safe shutdown
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purposes.Section III.0 requires that an oil collection system is pro-
vided for the the reactor coolant pumps. The schedule for compliance
with the above requirements is set forth in 10 CFR 50.48. This schedule
requires that all outage related modifications for N111 stone Unit 2 be
completed during the next refueling outage scheduled for January 1988.
All other modifications should have been completed' prior to
January 15, 1987.
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4.0 Correspondence
Correspondence between the licensee and the NRC concerning compliance
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with Section III.G,J and 0 was reviewed by the inspection team in
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preparation for the site visit. Attachment I to this report is a listing
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of the correspondence reviewed.
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5.0 Post-Fire Safe Shutdown Capability
In the event of a fire concurrent with a loss of offsite power, the
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following method is used to provide safe shutdown capability.
Reactor
shutdown is initiated from the control room by scram of the control
rods, if an automatic scram has not occurred.
Reactor coolant inventory
and reactor shutdown reactivity are maintained by a charging pump taking-
suction from the refueling water storage tank.
Additionally, primary
system pressure is maintained by a charging pump combined with letdown.
For hot shutdown, decay heat removal is accomplished by the turbine-driven
auxiliary feedwater pump supplying water to steam generator (SG) No. 2
from the condensate storage tank (CST).
The atmospheric dump valve, (ADV)
is used to remove heat from the steam generator.
For cold shutdown, decay
heat removal is accomplished by the low pressure safety injection (LPSI)
system in conjunction with the shutdown cooling heat exchangers, the
reactor building closed cooling water system (RBCCW), and the service
water system.
Cold shutdown can be achieved in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The above systems are normally controlled and monitored from the control
For a fire in the control room the licensee plans to use the Fire
room.
Shutdown Panel, (FSP) to shut-down the plant.
This panel which is located
in the 22, 4160 switchgear room provides the controls and instrumentation
necessary to maintain the plant in a hot standby conditton.
From the FSP,
the operators are able to supply and regulate the auxiliary feedwater to
steam generator 2 via the turbine driven pump and charging to RC loop 2
via the charging pumps B and/or C.
This is accomplished with some manual
valve action.
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Position control for the steam generator 2 ADV is also available.
The reactor is maintained in hot standby using natural circulation
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and one steam generator loop.
Indication provided to monitor these
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activities includes; steam generator 2 level and pressure, pressurizer
level and pressure, RC Loop 2 hot and cold leg temperature, and CST
level.
During plant cooldown, using natural circulation it may be
necessary to reflood the second steam generator.
This is accomplished
using procedures and without instrumentation on steam generator loop 1.
During the first four hours after a reactor trip, charging is not required.
Power to operate auxiliary feedwater equipment and instruments is provided
by station battery backed DC and AC supplied to the panel. When charging
is required 4160V power can be backfed from the Unit 1 RSST to Unit 2 emergency
buses.
This eliminates any need for Unit 2 diesels or service water during
hot standby.
The safe shutdown systems that may be utilized during shutdown are as
follows:
Low Pressure Safety Injection and Containment Spray
Chemical and Volume Control
a
Reactor Building Closed Cooling Water
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Electrical Distribution
Fire Water
6.0 Inspection Methodology
The inspection team examined the licensee's capabilities 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
compliance with Section III.G.
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The following functional requirements were reviewed for achieving and
maintaining hot and cold shutdown:
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Reactivity control
Pressure control
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Reactor coolant makeup
Support systems
Process monitoring
The inspection team examined the licensee's capability to achieve and main-
tain hot shutdown 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
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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 S4,atdown Systems
(SSSs).
The team review included an evaluation of the susceptibility of
the SSSs to damage from fire suppression activities or for the recture or
inadvertent operation of fire suppression systems.
The inspection team exanined the licensee's fire protection features provided
to maintain one train of equipment needed for safe shutdown free of fire
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damage.
Included in the scope of this effort were fire area boundaries,
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(including walls, floors and ceilings), and fire protection of openings
such as fire doors, fire dampers and penetration seals.
The inspection team also examined the licensee's compliance with Section
III. J, Emergency Lighting.
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7.0 Inspection of Protection Provided for Safe Shutdown Systems
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7.1 Protection in Various Fire Areas
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The team reviewed the protection provided to SSSs and work in progress
in selected fire areas for compliance with Appendix R,Section III.G.1,
2 and 3.
The following fire areas were inspected:
The Auxiliary Building,
The Turbine Building,
The Intake Structure, and
The Fire Pump Building
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The team reviewed the adequacy of the fire rated walls and floor / ceiling
assemblies; fire rated cable ar.d cable tray wraps; fire dampers, fire
doors and penetration seals; automatic fire suppression and fire
detection and alarm systems; manual fire fighting equipment and the
separation of safe shutdown systems.
The inspection of these areas identified the following concerns:
The Auxiliary Feedwater headers to Steam Generators 1 and 2 are routed
thru the same fire area, the Turbine Building elevation 14'-6".
On
each of the Auxiliary Feedwater headers, the discharge valves 2FW43A
and B are installed. These valves are located approximately 15 feet
apart.
The concern is that because of the valve proximity to each
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other and the combustibles in the area a single fire may damage both
valves thus effect the capability to establish auxiliary feedwater
flow to the steam generators and prevent safe shutdown.
The Regulations in 10 CFR 50, Appendix R, Section III.G.1.a require
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that one safe shutdown train remains free of' fire damage. To assure
that one train remains free of fire damage, the Regulations in 10 CFR 50, Appendix R, Section IIIG.2.b require that a 20 foot separation
zone free of intervening combustibles exists between redundant com-
ponents. Thus the lack of a 20 foot combustible free zone between
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the discharge isolation valves 2FW43A and B of the Auxiliary Feedwater
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headers represents a violation of the above stated requirements, since
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the licensee did not seek relief from these requirements in the form
of an exemption.
(87-16-01)
The licensee stated that an analysis was performed which concluded
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that it is very unlikely for both valves to fail closed, and since
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the valves are designed to fail open, the redundant components are
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deemed to be free of fire damage.
This determination is based on the
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fact that for the valves to fail closed multiple hot shorts are re-
quired to occur.
The licensee established an hourly fire watch patrol
of the fire area.
In order to resolve the issue and eliminate the
fire watch, the licensee committed to file for an exemption request
from the Appendix R requirement to provide a 20 foot separation
of the redundant components.
Another concern the team identified was the lack of a fire damper in
the duct penetrating the 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated wall separating the
Auxiliary Building and the West Electrical Penetration Room, fire
areas R-1 and R-2 respectively.
Since this wall separates redundant
safe shutdown components, the lack of the fire damper in the duct is
a violation of Section III.G.2.a of Appendix R to 10 CFR 50, which
requires that redundant safe shutdown trains be separated by a fire
barrier having a three hour rating.
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The licensee posted a fire watch in this area immediately.
Subse-
quently, the-licensee performed a fire hazard analysis to determine
whether a fire damper is required for that location.
The licensee
determined and the audit team agreed that because the fire loading of
the fire areas involved is small, a fire.in the area would not signi-
ficantly challenge the existing barriers, therefore a fire damper is
not required.
The team informed the licensee that since the analysis indicated that
the barrier is adequate the fire watch may be discontinued from the
area, however, the lack of the fire damper in the absence of a fire
hazard analysis at the time of the audit constitutes a violation of
the above quoted section of the regulation (87-16-02).
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The corrective actions taken by the licensee satisfy the NRC concerns
and this item is closed.
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The team also identified several areas where the installed fire
protection systems did not meet the National Fire Protection
Association (NFPA) guidance.
The need for licensees.to address
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NFFA guidelines is specified in Generic Letter 86-10. The team
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determined that the deficiencies were minor since the affected'sys-
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tems performance has no effect on plant safety or the ability of the
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plant to achieve safe shutdown.
The licensee commit 4ed to upgrade
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the effected systems as follows:
A.
In several plant locations the fire detection systems do not
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conform with the guidance of the National' Fire Protection
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Association (NFPA) Standard No. 72E.
The licensee plans to add additional detectors in accordance
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with NFPA 72 E in these locations:
Waste Tank Pump Room
Zone A-1C
Intake Structure
Area I-1
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HPSI Room
Area A-4
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Storage Crib Area
Area A-9
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Motor Drive Auxiliary Feedwater Pump Room
Area T-3
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B.
Several fire doors in the Auxiliary and Turbine buildings have
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been modified with fusible link " hold-open" devices such that
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they do not conform with the NFPA Standard No. 80.
The licensee will replace the fusible link " hold-open" devices
on the fire doors in accordance with the NFPA 80 guidelines.
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C.
Sprinkler system in Fire Zone A-19A is obstructed by a newly
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installed ceiling partition.
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The licensee will add additional sprinklers below the obstruction
in zone A-19A.
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Additionally, the licensee committed to provide NRC, within 30
days of receipt of this report, with a schedule to implement.
these modifications.
The licensee also committed to provide NRR with the design details
of the supervision of the fire alarm system.
The team's concern
was that a simple break or ground fault could render any of the
fire alarm systems inoperable without a trouble alarm being trans-
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mitted to the control room to correct the condition.
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No other deficiencies were identified.
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7.2 Safe Shutdown Procedures
7.2.1
Procedure Review
The team reviewed the following shutdown procedures to
be used by the licensee in the event of a control room
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evacuation due to a fire:
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Procedure No. A0P2579A, Rev.1, July 10,1987, " Contin-
gency Fire Procedure for Hot Standby - Appendix "R"
Fire Area F-1"
Procedure No. AOP2579AA ,. Rev.1, July 10,1987, " Fire
Procedures for Cooldown and Cold Shutdown - Appendix "R"
Fire Area F-1"
The scope of this review was to ascertain that the shutdown
could be attained in a safe and orderly manner, to determine
the level of difficulty involved in operating equipment,
and to verify that there was not dependence on repairs for
achieving hot shutdown.
For review purposes, a repair may
include installing electrical or pneumatic jumpers, wires
or fuses to perform an action required for hot shutdown.
For cold shutdown, repairs are allowed using in place proce-
dures 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 />.
The review did not identify any unacceptable conditions.
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7.2.2
Procedure Walk-Through
The team walked through selected portions of Procedure No.
A0P2579A to determine by simulation that shutdown from out-
side the control room could be attained in an orderly and
timely fashion.
The procedure walk-through was accomplished
by four members of the licensee's operations staff. The
walk-through began in the control room and the procedure
was followed through from the time the operators would have
left the control room until simulated stable hot shutdown
conditions were achieved. The team paid particular attention
to the feasibility of each manual action, ease of access,
communication and sequence of operation.
During the walkdown, the team observed that communications
using the two way walkie talkies were not effective.
The
licensee acknowledge the problem and committed to verify
the adequacy of the communication system in all shutdown
areas.
The team also observed that the radio repeaters
used to facilitate radio communications were olugged into
wall receptacles.
The team noted that the repeaters may oe
inadvertently unplugged. To prevent a power disconnect to
the radio repeaters, the licensee committed to hardwire
them. This is an unresolved item pending NRC review of the
licensee's actions to verify the adequacy of the
communication system and adequacy of the hardware
modifications to the radio repeaters (87-16-03)
During the walkdown, the team observed that the shutdown
procedure contained some steps that appeared unnecessary.
The licensee reviewed the procedure and made changes that
consolidated certain steps in the procedure.
With regard to the feasibility and ease of performance, the
team observed the following:
The operators need additional training in the pro-
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cedures since problems were encountered in certain
steps of the procedures.
The problems were, diffi-
culty in locating certain shutdown components and
difficulty in simulating removal of breakers.
Not all tools required to perform steps of the shutdown
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procedure are administratively controlled, kept'in the
safe shutdown tool lockers and properly labeled. The
licensee stated that they intend to administratively
control this equipment, label the tools and perform a
periodic surveillance of the tool inventory.
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The licensee stated that the deficiencies identified above
will be addressed prior to restart from the next refueling
outage. That is the date when these deficiencies must be
corrected to satisfy Appendix R requirements.
With regard to cold shutdown, the licensee has opted to
perform repairs during the cold shutdown phase. To achieve
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this goal, the licensee has on site all the required equip-
ment, materials and procedures to perform these repairs.
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The team review both materials and procedures and did not
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identify any unacceptable conditions.
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The licensee's analysis postulates that for certain fires,
the motor of one RBCCW pump and one motor of a service
water pump may need to be replaced. The team inspected
these motors along with the associated storage and mainte-
nance procedures to verify that the motors will perform
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adequately when required.
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The replacement service water pump motor in storage is iden-
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tical to the ones already installed.
The replacement RBCCW
pump motor is a different motor from the ones already
installed.
The licensee had to redesign the pump motor pad'
to assure quick and effective motor replacement. The team
reviewed the pad modification package to assure that the
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motor can be easily replaced and fits on the redesigned
pad.
Also, since this motor was purchased from a cancelled nuclear
project, the team reviewed the appropriate QA and storage /
maintenance records to verify that the motor qualification
is still valid.
The team also reviewed the storage and
maintenance procedures for both motors to assure that long
term motor storage will not affect motor operability, lhe
team did not identify any unacceptable conditions.
8.0 Protection for Associated Circuits
Appendix R,Section III.G requires that protection be provided for
associated circuits that could prevent operation or cause maloperation 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:
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Common bus concern
Spurious signals concern
Common enclosure concern
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The associated circuits were evaluated by the team for common bus,
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spurious signal, and common enclosure concerns.
Power, control, and
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instrumentation circuits were examined on a sampling basis for potential.
problems.
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8.1 Common Bus Concerns
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The common bus concern may be found in circuits, either safety
related or non-safety related, where there is a common power source
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with shutdown equipment and the power source is not electrically
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protected from the circuit of concern.
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The team examined, on a sample basis, 4160V, 480V, 120VAC and 125VDC
distribution bus coordination.
Improper circuit breaker coordination
practices were identified by the licensee during their review of
sample coordination curves.
In particular, circuit breakers D0105
and D0104 of the 125VDC bus 201A were found.to be miscoordinated.
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This concern has been addressed by the licensee as follows.
The
licensee is currently in the process of implementing a modification
to the 4.16KV, 480V,120VAC and 125VDC plant distribution systems to
ensure the proper coordination to all circuits of concern. This work
is being performed under modification number 85-082 dated May 31,
1987.
The analysis portion of this modification has been completed
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and circuits requiring recoordination have been idenacified.
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licensee is required to fully implement all required circuit modifi-
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cation during the next refueling outage currently scheduled for
January 1988.
Based on a review of modification 85-082, Rev. 2 as
well as discussions with licensee representatives the implementation
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of this modification will satisfy this concern. The licensee plans
to perform checks of relay settings each refueling outap for relays
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protecting the main transformer, main generator, station trans-
formers, 345kV tie lines and the diesel generators. All other
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protective relays are to be calibrated on alternating refueling
outages.
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8.2 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 and open
circuits.
Spurious operation of safety related or non safety related
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components can occur that would adversely affect shutdown
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capability (e.g., RHR/RC isolation valves).
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The team examined, on a sampling basis, the following areas to
ascertain that no spurious signal concern exists:
Current transformer secondaries
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High/ low pressure interfaces
General fire instigated spurious signals
The team determined that the licensee conducted an analysis which
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identified a number of high/ low pressure interfaces.
In order to
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protect against the possibility of spurious operation of high/ low
pressure interfaces the license is 1) utilizing check valves,
2) isolation switches, 3) removing power by tripping breakers and
4) using closed block valves to assure low pressure system isolation.
The licensee performed an analysis of current transformers which was
found to determine that the transformer secondary circuits were
protected from the effect of open circuits by the use of secondary
cabling whose insulation voltage breakdown specification of 4kV was
found to be in excess of the maximum open circuit voltage specified
by the transformer manufacturer.
No unacceptable conditions were identified.
8.3 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 electrical-
ly protected or when fire can destroy both circuits due to inadequate
A number of circuits, selected on a sampling basis were examined for
this concern.
The common enclosure concern was satisfactorily addressed. The re-
dundant cables for divisions Z1 and Z2 are not run in the same tray
or conduits.
In addition, all circuits are protected with coordi-
nated circuit breakers or fuses.
No unacceptable conditions were identified.
10 CFR 50, Appendix R, Section III.J. requires that emergency lighting
units with at least an 8-hours battery power supply shall be provided in
all areas needed for operations on safe shutdown equipment and in access
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and egress routes thereto.
The team examined the plant emergency lighting system to ascertain the
licensee's compliance with the above requirements.
The team did not identify any unacceptable conditions.
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10.0 Oil collection System for Reactor Coolant Pumps
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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
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is not inerted during normal operation.
As the containment in this plant
was inaccessible during this inspection because of the plant operating
status, the team W.s unable to inspect the oil collection system.
The oil collection system will be inspected at a future date.
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11.0 Quality Assurance
During the course of the inspection, the team reviewed several drawings,
the fire hazard analysis, fire protection modification packages, proce-
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dures, and other fire protection documents.
The scope of this review
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included verification of their technical adequacy, appropriate reviews,
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design and procurement controls, and other Quality Assurance requirements
of the licensee's fire protection program.
The team did not identify any
unacceptable conditions.
12.0 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 Section.7.1, 7.2 and 10.0.
13.0 Exit Interview
The inspection teim met with the licensee representatives, denoted in
Section 1.0, at the conclusion of the inspection on July 17, 1987, and
the team leader summarized the scope and findings of the inspection at
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that time.
The team leader also confirmed with the licensee that the report will not
contain any proprietary information.
The licensee agreed that the
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inspection report may be placed in the Public Document Room without prior
licensee review for proprietary information (10 CFR 2.790).
At ro time during this inspection was written material provided to the
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licensee by the team.
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Attachment 1
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List of Major Appendix R Related Correspondence
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March 19, 1981
W. Counsil to J. Hendrie, Licensee acknowledges Appendix R,
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requests 6 months scheduler exemption.
Nov. 11, 1982
H. Denton to W. Couns11, NRC grounds schedular exemption.
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March 1, 1982
W. Counsil to D. Eisenhut, Licensee submits plans for
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Appendix R compliance.
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May 10, 1982
H. Denton to W. Counsil, NRC Issues-Fire Protection SER and
points out the 10 CFR 50.48 schedule. dates.
Specifically
that the pro'/isions of Appendix R should be implemented in
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a schedule which begins on March 1, 1982.
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June 18, 1984
W. Counsil to R. Vollmer, Licensee commits to revalidate
previous submittals because of new knowledge stemming from
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workshops, Generic Letters and Information Notices,
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Jan. 31, 1985
Licensee submits additional information to support exemption
requests.
Requests approval to use Emergency Power from
Unit 1 Backfeed.
a
.
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April 15, 1986
A. Thadani to J. Opeka, NRC issues alternative shutdown SER
[
and grants all docketed exemptions requests.
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Feb. 20, 1987
E. Mroczka to NRC, Licensee informs NRC that all non-outage-
k
modifications have been completed as of Jan. 15, 1987.
f
,
April 9, 1987
F. Miraglia to E. Mroczka, NRC informs the licensee that by the
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10 CFR 50.48 schedule all non-outage related modifications
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should have been completed by January 15, 1987. Other modi-
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fications requiring NRC approval and plant shutdown should
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be implemented during the next refueling outage.
April 16, 1987
E. Mrozcka to NRC, Licensee submits a r.ew fire hazard analysis
with an evaluation of new fire areas.-
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1
,
1
1
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)