ML20236X321

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Insp Repts 50-277/87-30 & 50-278/87-30 on 871019-23. Violation Noted.Major Areas Inspected:Compliance w/10CFR50, App R,Section Iii.G,J,I & L Requirements Re Fire Protection Features for Achieving Safe Shutdown in Fire Events
ML20236X321
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 12/02/1987
From: Anderson C, Krasopoulos A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236X311 List:
References
50-277-87-30, 50-278-87-30, NUDOCS 8712090119
Download: ML20236X321 (14)


See also: IR 05000277/1987030

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-277/_87-30 and 50-278/87-30

Docket No. 50-277/50-278

License No. DPR-44 and DPR-56 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: October 19-23, 1987

Inspector: f 9

Kras poUlos, keactof Engineer, DRS

//[Ju!87

_A. / dafe

Also participating in the inspection and contributing to the

report were:

K. Sullivan, Electrical System Specialist, BNL

R. Hodor, Mechanical Systems Specialist, BNL

Approved by: . /k 7

C, # Anderson, Chief, Plant System 'date  ;

Section, DRS

Inspection Summary: Inspection on October 19-23, 1987, (Combined Report Nos.

50-277/87-30 and 50-278/87-30).

Areas Inspected: Special, announced team reinspection of the licensee's efforts

to comply with the requirements of 10 CFR 50, Appendix R, Sections III. G, J, ,

I and L, concerning fire protection features to ensure the ability to achieve .I

and maintain safe shutdown in the event of a fire.

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l Results: One violation was identified. Three items remained unresolved at the

! end of the inspection.

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Details

1.0 ' Persons Contacted

-1.1 Philadelphia Electric Company (PECo)

  • R. Lees, Chief Electrical Engineer
  • B. Clark, Site Administrative Engineer
  • A. Donell', QA Site Supervisor
  • C. Swenson, Nuclear Operations
  • D. Smith, Plant Manager
  • W. Boyer, Electrical Supervising Engineer
  • D. Spamer, Electrical Engineer
  • W. Birely, Licensing Engineer
  • S. Yuill, Fire Protection Coordinator
  • G. Termine,- Electrical Engineer
  • W. Brady, Mechanical Engineer
  • C. Gerdes, Mechanical Engineer
  • R. Dourte, QA Engineer
  • F. Adams, Engineering Designer
  • G. Cambell, Engineering Designer

'*R.' Rock, Electrical Engineer

  • D. Thompson, Electrical Engineer
  • D.- Brecker,. Consultant (EPM)
  • J.-McCawley, Electrical Engineer
  • M. Phillips, Public Service Electric and Gas
  • R. Dell Angelo, Engineering Designer

G. Morley, Supervising Mechanical- Engineer

A. Melikian, Consultant (EPM)

R. Ploff, Consultant (EPM)

0. Brecken, -Consultant (EPM)

M. Lohr; Electrical Engineer

J. Pizzola, QA Engineer

J. Marinucci, Consultant (GE)

M. Hammond, Construction Engineer

J. Cleary, Mechanical Engineer

1.2 Nuclear Regulatory Commission (NRC)

  • T. Johnson, SRI
  • R. Urban, RI
  • L. Myers, RI

Denotes those present at the exit interview.

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2.0 Review of Previous Inspection Findings

Open (violation) 50-277/83-31-02 and 50-278/83-29-02: Failure to meet the

Appendix R Fire Brigade training requirements.

During the above referenced inspection performed in 1983 the NRC

determined that the licensee's Fire Brigade training was deficient

because training requirements were not implemented. The deficiencies

identified were the failure of brigade members to attend training meetings

and failure to participate in the hands-on fire fighting practice.

The licensee in their annual and triannual fire protection program audits

identified similar def'.ciencies during 1984, 1985 and 1986, calendar

3

years. During 1986, in audit No. AP86-121PL the licensee's audit

team issued a Significant Nonconformance Report (SNCR) to the Superinten-

dent - Operations because actions taken in the past failed to prevent

recurrence.

The:NRC in inspection 277/278/85-44 reviewed the licensee's corrective

actions in~this area but was unable to resolve the issue because the

licensee's corrective actions were inadequate. To assure the adequacy of

the licensee's corrective actions, the inspector reviewed the following:

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Attendance records for quarterly training

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Attendance records for drill participation

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Attendance records for hands-on practice initial training and

refresher instruction.

The inspector also observed a fire drill for training effectiveness,

and reviewed the drill procedure. From the review of the relevant fire

brigade training documents and correspondence, the inspector determined

the following:

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The records review determined that at least 20 fire fighters did not

participate in the required two' drills per year and at least five did

not attend the initial classroom and refresher instruction required

by 10 CFR 50 Appendix R Section III.I.

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The inspector ascertained in discussions with licensee personnel that

fire fighters responding to drills do not usually wear protective

clothing or respiratory gear. Only in less than 20% of the drills do

the fire fighters use protective clothing and respiratory apparatus.

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During the drill observed by the inspector, the brigade members were

coached by the drill coordinator and told what to do. Drills

performed thus lack realism and the team practice concept is lost.

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These training concerns were previously identified by the NRC and

the licensee's own QA activities, however, they were allowed to

recur.

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10 CFR 50 Appendix R Section III.I. requires that the Fire Brigade train-

ing program consists of initial classroom instruction followed by periodic

instructions.

' Fire brigade drills are required per 10 CFR 50 Appendix R 3ection III.I.3.

so that the fire brigade can practice as a team. These drills shall be

performed at regular intervals not to exceed 3 months with each member

participating in at least two drills per year. Each drill shall include

an assessment of each Brigade member's conformance with the fire fighting

procedures and use of fire fighting equipment including self contained

breathing apparatus.

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This is a violation of the above referenced Appendix R requirements ~

- (50-277/278-87-30-01).

Open (Unresolved Item) 50-277/84-40-01 and 50-278/84-19-01: Visual check of

Fire Dampers does not provide assurance that Dampers will perform as

required.

The licensee's T.S. require that fire dampers are inspected visually. The

NRC raised the concern that a visual damper inspection does not provide

assurance that the fire dampers will be able to function properly during.

a fire. This concern was raised because: A) The licensee could not pro-

vide Q.C. records indicating that the fire dampers were drop tested after

installation, as called for in the engineering packages; and, 8) a recently

issued 10 CFR 21 letter highlighted the concern that the type of fire

dampers used by the licensee may not close under air flow conditions.

The licensee addressed this concern by revising the fire fighting

strategy procedures giving the fire brigade the option to de-energize the

- ventilation systems involved. With no air flow presumably the fire

dampers will close. The licensee's actions did not satisfy the original

NRC concern for the following reasons:

1) The inspector observed a fire brigade drill. Although an attempt was

made to verify whether the fire jumped to areas above the hypo-

thetical fire scene, no attempt was made to find and isolate the

ventilation equipment.

2) . Assuming that the brigade does turn off the air handling units there

is no assurance that the dampers will fully close after the air

i handling units are turned off. This is because the dampers may drop

L and bind in a partially open position before the air flow is cut-off.

To assure that the dampers close, the licensee must provide assurance

. that the dampers will close under air flow or that the air handling

L units are de-energized prior to dropping of the dampers.

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This' item continues to be. unresolved. Considering the above concerns the

inspector questioned the' operability of the dampers.

Closed (Unresolved Item) 50-277/84-40-02 and 50-277/84-19-02: Triannual.

audit findings.not-formally resolved.

The NRC raised the concern that the American Nuclear Insurers (ANI)

audits used by the licensee to satisfy the T.S. audit requirements may-

not satisfy the guidance issued by the NRC in Generic Letter-(GL) 82-21.

This is because these audits are performed to satisfy insurance

requirements.

The G.L. sets forth the scope of the triannual audits which must be

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performed by an "outside" consultant.

The licensee committed to use an outside consultant henceforth to perform

these audits. The inspector reviewed audit report AP 86-121PL which was

performed by a qualified fire protection consultant. This audit was the

-first performed to satisfy the commitment. The review of this audit

did not identify any-unacceptable conditions.

This item is resolved.

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Closed (Violation) . 50-277/84-40-03 and 50-278/84-19-03: Degraded fire

doors constitute a violation of Appendix R separation criteria.

The NRC identified several fire doors that were degraded. These fire

doors were installed in walls separating redundant safe shutdown.compo-

nents. The deficiencies were: an inability to close because of an

atmospheric pressure ~ differentials, Missing U.L. labels without, other

documentation to assure the fire. rating of the door and delaminated' doors.

'The licensee's corrective actions included balancing of the ventilation

systems so as not to affect door closure, replacing damaged or unlabeled

doors and revising acceptance criteria of the door surveillance procedure.

'The inspector surveyed the doors identified in the violation and several

other fire doors and did not identify any unacceptable conditions. This

item'is resolved.

Closed (Unresolved Items) 50-277/278/86-08-01, 86-08-02, 86-08-03

86-08-04, and 86-08-05: Because of incomplete analysis compliance with

Appendix R requirements could not be verified.

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The unresolved items listed above were identified during the inspection

validating the licensee's compliance with the 10 CFR 50 Appendix R  ;

Sections III.G, III J, and III L. requirements. These items were all

administratively closed in consideration of the NRC reinspection of these

issues discussed in Sections 4 through 6 of this inspection report. {

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Closed'(Violation) 50-277/86-26-02: Fire watch inconsistent with T.S.

requirements

The NRC determined that T.S. 3.14.B.4 was violated when the fire watch,

posted as a compensatory measure for the inoperable Diesel Generator Room

Cardox' system, left the area under his wa*.ch. The Cardox system was-

inoperable because-the Diesel Generator Full Load Test Procedure ST.8.1

requires that.the Cardox system be by passed during the test of the

diesels.

The NRC reviewed the licensee's corrective actions in this area which are

as follows: The licensee counseled the individual responsible for the

event and also revised procedure ST 8.1 to. include a statement regarding

the fire watch requirements when the cardox system is defeated. Insofar

as this is an isolated incident, the preventive measures taken by the

licensee are adequate. This. item is resolved.

, 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 the Appendix R Sections III.G, " Fire

Protection of Safe Shutdown Capability," III.J, " Emergency Lighting "

III.L " Alternative and Dedicated Shutdown Capebility," and III.I Fire

Brigade Training.

Section III.G of Appendix R requires that fire protection be provided to

ensure'that one safe shutdown train remains available in the event of a

fire. Section III.J requires that emergency lights are installed in all

areas' required for safe shutdown purposes and Section III.L specifies-

requirements for alternate shutdown capability.Section III.I specifies

the required training ' for the Fire Brigade.

The NRC during March 17-21, 1986 performed an inspection to verify the

licensee's compliance with the above requirements, During that j

inspection the determination was made that the licensee's facilities j

could not be adequately inspected because the supporting analyses,

evaluations and procedures were found to be incomplete. i

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The licensee subsequently was requested to provide the NRC with a

justification for continuing operations (JCO)' after the licensee informed

the NRC that about 50 instance; of Appendix R violations were identified.

This JC0 also committed that Unit 2 would be in compliance at the end of j

the current refueling outage and Unit 3 at the end at their next refueling j

outage. l

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4.0 . Post-Fire Safe Shutdown Capability 1

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:

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High Pressure Coolant Injection (HPCI) System

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Reactor Core Isolation (RCIC) System 1

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Automatic Depressurization (ADS) and non-ADS Safety Relief

Valves (SRVs)

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Residual Heat Removal (RHR) System-shutdown cooling mode,

suppression pool cooling mode, and low pressure coolant

injection (LPCI) mode

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Core Spray (CS) System

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High Pressure Service . Water (HPSW) System

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Emergency Service Water (ESW) System

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.Onsite AC Power Generation and Distribution System

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Onsite DC Power Generation and Distribution System

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Essential Ventilation Systems (for Emergency Diesel Rooms)

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

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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 licensee uses four methods, A, B, C and D to achieve safe shut-

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down in the event of a fire. The method used depends on the location

of the fire. The fire hazard analysis identifies the safe shutdown

method for each fire area. These methods are described in the

following paragrapis.

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.

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

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cooling. - Heat is transferred from the vessel to the suppression pool

via the ADS system and/or the HPCI steam turbine discharge.

Method C

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For Method C,-the reactor is depressurized using the ADS system to.a

.pcint where either the Core Spray or the'LPCI mode of th'e RHR-

syster.s can be used to maintain core invantory.

-Method D

Method D, is the alternative shutdown method for a catastrophic fire

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'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 provided alternate safe shutdown capability independent

of the rain control-room, cable spreading room and the emergency

shutdown panel area. The alternative shutdown stations are provided

with circuit isolation capability using manual control switches,

relays, breakers er 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 alternative shutdown stations to indtiate shutdown

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 in the following locations:

HPCI Alternativ6 Control Station - This panel is located in each unit

in the MG set room at elevation 135' e 0". The HPCI alternative

control station is equipped with pumo diagnostic instrumentation and

transfer switches and alternative power supplies for the HPCI

turbine. This panel is also equipped with the alternative process

monitoring instrumentation which indicates raattur vessel pressure

and level, suppression peol temperature, and c9ndensate s'.orage tank

level.

Diesel Generators; Alternative Control Station - These panels are

located in Unit 2 4KV emergency switchgear rooms B/D and are common

to both Units 2 and 3. Tho panels are equipped with transfer

switches to isolate all main control room control circuits, and also

diesel generator diagnostic instrumentation.

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4kV Emergency Switchgear Alternative Controls - These

controls are located in the 4KV emergency switchgear rooms in each

unit. Transfer switches provide alternative. local control and

status indication for the motor control centers and for the ESW,

RHR and HPSW pumps.

ADS Transfer / Isolation Station - Alternative control capabilities

for 3 ADS valves and the associated nitrogen supply isolation valves

are 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

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transfer / isolation switches are necessary to preserve safe shutdown

capability for the M-G Set Rooms.

RHR/HPSW Suppression pool Alternative Control Stations -

Alternative control capabilities and transfer / isolation switches

for one loop c) RHR/HPLW Motor Operated Valves (MOV's), needed to

support Suppression Pool Cooling, are 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

ta have an alternate safe shutdown system, comply with the require-

ments of Section III.G.2 of Appendix R, unless an exemption request

has been approved by-the staff.

5.0 Inspection Methodology

The inspection teain examined the licensee's provisions for separating and

protecting equipment, cabling and associated circuits necessary to

achieve .ind maintain hot and cold shutdown conditions. This inspection

sampled selected fire areas which the licensee had identified as being in

ccmpliance with Section III.G.

The following functional requirements were reviewed for achieving and

maintaining hot ard rald shutdewn:

  • Reactivity control

Pressure control

  • Support systems

Process monitoring

The inspection team examir,ed 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 othar documents. Drawings were reviewed to verify electrical

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L' ' 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 traint 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

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of. fire damage. Included in the scope of this effort were fire area

boundaries, including walls, floors and ceilings, and fire protection of

operings such as fire doors, fire dampers, and penetration seals.

The_ inspection team also examined the licensee's compliance with'Section

III.J, Emergency Lighting.

6.0. Inspection of Protection Provided for Safe Shutdown Systems

6.1 Protection in Various Fire Areas

The team reviewed the protection provided to SSSs in selected fire

areas for compliance with Appendix R, Sections III.G.1, 2 and 3.

During the previous Appendix R inspection, compliance in this area

could not ba verified because the licensee's analysis was incomplete.

Therefore', the team could not ascertain whether redundant safe

shutdown components were within the same fire area. The licensee's

current analysis identified the method to be used in each area. The

licensee also verified that components relied upon for shutdown are

either outside the area of concern or are protected. The system

review and plant walkdown did not identify any unacceptable condi-

-tions. This' review resolves the previously identified unresolved

item 50-277/278/86-08-01.

6.2 Safe shutdown Procedure Review and Walk-down

The team revlewed the procedures used by the licensee in the event

of a fire. Following a report of a fire the operators initial

guidance is from procedure ON-114 " Actual Fire Reported in the Power

Block, or, Diesel Generator Building, Emergency Pump, Inner Screen,

or Emergency Cooling Tower Structures - Procedure." The operators

are guided by this procedure to Procedure T-300 when symptom; indi-

cate that fire damage threatens safe shutdown systems. The T-300

procedure is a symptomatic procedure which contains an index direct-

ing the operators to the proper T-300 series fire guide for the

affected fire area.

For a fire in Fire Area 25 which includes the Main Control Room,

Computer Room, the Cable Spreading Room and the Emergency Shutdown

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Panel. Area, Fire Guide T-325 directs.the use of Procedure SE-10

" Plant Shutdown from the Alternate Shutdown Panel" if the Control

Room shutdown systems are threatened by fire damage.

If the fire requires Control Room evacuation, the operators manually

scram both Reactors and take control of the plant from the alternative

shutdown panels. Shutdown Method D described in section 4.1 is used.

Procedure SE-10 as reviewed by the team was found to'be adequate.

The team commented.that some steps in the procedure may need signa-

ture checks to assure control. For instance the steps monitoring the

reactors' cooldown rate and other steps that operators perform in.the

attachments to the procedure do not have sign-off blocks that the

operation was performed. The licensee in subsequent discussions

committed to review the procedure and add sign-off spaces where

needed.

The procedure walkdown was . performed using three operators because

the operations at only the Unit 2 Alternate Shutdown panel were

observed. For an actual fire four operators would be used.

The walkdown identified that some operations performed during the

hot shutdown phase are repairs. Since repairs are not allowed by

the NRC guidance.the licensee committed to seek an exemption from

NRR. This is an unresolved item (87-30-02). Other observations

during the walkdown of the procedure were that the breaker panel for

the inboard steam isolation valve of the HPCI system has a cover

fastened on with wing nuts. The team observed that if the wing nuts

are too tight the operators may not be able to open the panel. The

licensee stated that either bigger wing nuts or a tool will be pro-

vided to assure panel access.

Since the shutdown procedure was adequate, this resolves the pre-

viously identified unresolved item 50-277/278/86-08-02 regarding the

lack of shutdown procedures during that inspection. During the

walkdown of the procedure, the team also made observations on the

adequacy of the emergency lights. The team did not identify any

unacceptable conditions. This resolves item 86-08-05 concerning the

adequacy of the emergency lights.

6.3 Protection for Associated Circuits

l Appendix R. Sections III.G and III.L require that protection be

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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 concerns

  • Spurious signals concern

Commen 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.

The team examined, on a sampling basis, protective relay coordi-

nation 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 approxi-

mately 18 month intervals.

A deficiency was identified as follows:

  • High Impedance Fault Protection

In lieu of performing a complete plant specific analysis of

this concern, the licensee submitted for review test data j

which was obtained from a cable fault test. The objective j

of the test was to support the licensee's position that the ;

occurretice of multiple high impedance faults due to fire

will not have an adverse effect on the circuit l

coordination.

The test was perforr.ied by the licensee's staff during the ,

month of October 1987. The test consisted of a Cable Tray

which was filled to approximately 23*' capacity with Nuclear

Grade, IEEE 383 cables. The cabling was then exposed to a

" Simulated Appendix R Fire Source." The flame source was

ribbon in shape and located approximately 3" from the

underside of the Cable Tray. The flame had a thermal

output of 70,000 btu.

Based on the results of this test the licensee concluded

that the occurrence of multiple high impedance faults will 1

not affect the safe shutdown capability of the plant.

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Thc licensee committed to submit the test procedure and

results to the NRC for review. Pending review of the test

data by NRC this item will remain unresolved. (87-30-03)

6.3.2 Spurious Signals Concern

The spurious signal concern is made up of 2 ittmu

False motor control and instrament 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 reviewed documents, on a sampling basis, in the

following areas to ascertain that no spurious sigaal concern

exists:

Current transformer secondaries

High/ low pressure interfaces

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General fire instigated spurious signals

A deficiency was identified as follows:

High/ Low Pressuie Interface Concerns

The high/ low pressure interface analysis performed by the

licensee has determined that spurious opening of the RHR Shut-

down Cooling Suction Line Isolation Valves (MO-10-17 & 18) will

not result.in failure of the RHR Low Pressure Shutdown Cooling

Piping. This determination is based on information contained in

General Electric Co. Report NEDC-31339 "BWR Owners Group Assess-

ment of Emergency Core Cooling System Pressurization In Boiling

Water Reactors." By letter dated December 10, 1986, the

licensee has submitted this report to the NRC for review.

Pending final NRC review of the BWR Owners Group Report, this

item will remain unresolved (87-30-04).

Fuse Replacement Controls

During the review of the licensees circuit coordination study it

was identified that the licensee does not have administrative

control procedures in place to control future fuse replacement

activities. The licensee stated that a procedure to control

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fuse replacement is currently in the process of being written

. and implemented. The licensee further explained that fuse re-

placement is currently performed by either " replace in kind" or

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using the Control Room mark up drawings which call for. the type.

of fuses to be.used.

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 reviewed a.

randum sample of associated circuits routed together and found

these circuits to be protected by coordinated electrical protec-

tion devices. The review of the common enclosure concern did

not identify any unacceptable conditions.

7.0 Unresolved ~ Items

Unresolv~ed items are matters for which more information is required in .

order to ascertain whether they are acceptable, violations, or I

deviations. Unresolved items are discussed in Sections 6.2 and 6.3.

8.0 Exit Interview

The inspection team met with the licensee representatives, denoted in

Section 1.0, at the conclusion of the inspection on October 23, 1987, 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 inspec-

tion 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.

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