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{{Adams | |||
| number = ML20137F605 | |||
| issue date = 08/13/1985 | |||
| title = Insp Rept 50-333/85-20 on 850617-21.Violation Noted:Fire Barrier Walls Between Control Room & Relay Room Found to Contain Penetrations W/Nonrated Seals | |||
| author name = Anderson C, Krasopoulos A | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000333 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-333-85-20, NUDOCS 8508270016 | |||
| package number = ML20137F568 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 19 | |||
}} | |||
See also: [[see also::IR 05000333/1985020]] | |||
=Text= | |||
{{#Wiki_filter:. | |||
. | |||
/ U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION I | |||
Report No. 85-20 | |||
. Docket No. 50-333 | |||
, License No. DPR-59 Priority - | |||
Category C | |||
Licensee: Power Authority State of New York | |||
James A. FitzPatrick Nuclear Power Plant | |||
' | |||
P. O. Box 41 | |||
Lycoming, New York 13093 | |||
Facility Name: James A. FitzPatrick Nuclear Power Plant | |||
Inspection At: Scriba, New York | |||
Inspection Conducted: June 17 - 21, 1985 | |||
i Inspectors: 9) ~ | |||
l]uC. /.3 /4 W | |||
'A. Krasopdulos, Reactor Engineer da te' | |||
Also. participating in the inspection and contributing to the report were: | |||
; | |||
' | |||
'f | |||
T. Chandrasekaran, Auxiliary Systems Branch NRR | |||
.A. Singh, Auxiliary Systems Branch, NRR | |||
, , | |||
:A. Coppola, Mechanical Systems Specialist, BNL | |||
' | |||
H. Thomas, Electrical Systems Specialist, BNL | |||
l P. Koltay, Senior Resident Inspector, Region I | |||
D. Kubicki, Chemical Engineering Branch, NRR | |||
S. West, Chemic 1 eering Branch, NRR | |||
' Approved b'y: | |||
' | |||
O; TU | |||
C. J.fAnderson, Chief, Plant System date | |||
. Section, DRS | |||
: | |||
j Inspection Summary: Inspection on June 17-21, 1985 (Report No. 50-333/85-20) | |||
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 0, concerning fire protection features to ensure the ability to achieve and | |||
maintain safe shutdown in the event of a fire. The inspection involved 272 | |||
: inspector-hours onsite and 36 inspector hours in-office by a team consisting | |||
of 8 inspectors. | |||
Results: One siolation was identified (Failure to maintain separation of re- | |||
dundant components). Seven items remained unresolved at the end of the inspec- | |||
tion. See Attachment 3 for a summary of the inspection findings. | |||
' | |||
, | |||
8500270016 850821 | |||
PDR ADOCK 05000333 | |||
G PDR | |||
, . | |||
. | |||
- | |||
. | |||
DETAILS | |||
1.0 Persons Contacted | |||
1.1 Power Authority of the State of New York (PASNY) | |||
B. Bernstein, Plant Engineer Technical Services | |||
R. Burns, Vice President BWR Support | |||
*R. Converse, Superintendent of Power | |||
M. Cass, Licensing Engineer | |||
M. Curling, Training Superintendent | |||
F. DePoalo, Project Support Engineer | |||
J. Ellmers, Senior Nuclear Licensing Engineer | |||
*W. Fernandez, Operations Superintendent | |||
N. Garofalo, Senior Plant Engineer Technical Services | |||
*H. Glovier, Resident Manager | |||
*J. Gray, Jr., Director Nuclear Licensing | |||
*L. Guaquil, Director Project Engineering | |||
R. Heath, Fire Protection Supervisor | |||
*D. Holliday, Senior Plant Engineer | |||
*L. Jonston, QA Supervisor | |||
J. Kerfiev, QA Supervisor | |||
R. Locy, Waste Management Superintendent | |||
S. Muckherjee, Supervisory Engineer | |||
1.2 Licensee Contractors - Stone and Webster Engineering Corp (SWEC) | |||
EMP Inc. | |||
S. Burke, Fire Protection - EMP Inc. | |||
D. Cirrone, Project Manager - SWEC | |||
A. Faramarzi, Systems Engineer - EMP Inc. | |||
> | |||
S.-Kohr, Power Engineer - SWEC | |||
R. Tworek, Senior Electrical Designer (SWEC) | |||
R. Ulftstam, Fire Protection Supervisor - SWEC | |||
1.3 Nuclear Regulatory Commission (NRC) | |||
*H. Abelson, Project Manager - ORB | |||
*A. Luptak, Senior Resident Inspector (Acting) | |||
* Denotes those present at the exit meeting. | |||
'2.0 Purpose | |||
This inspection was to ascertain that the licensee is in conformance with | |||
10 CFR,50, Appendix R, Sections III. G, J, and 0, including exemptions ap- | |||
s proved by the Office of Nuclear Reactor Regulation (NRR). | |||
) | |||
> | |||
3 | |||
; f. | |||
. | |||
. | |||
3 | |||
3.0 Background | |||
10 CFR 50.48 and 10 CFR 50 Appendix R became effective on February 17, | |||
1981. Section III.G of Appendix R requires that fire protection be | |||
provided to ensure that one train of equipment necessary to achieve and | |||
maintain safe shutdown remains available in the event of a fire at any | |||
location within a licensed operating facility. For hot shutdown condi- | |||
tions, one train of the systems necessary must be free of fire damage | |||
(III.G.1.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 hours of the initiating event | |||
(III.G.1.b). Section III.G.2 lists specific options te provide adequate | |||
protection for redundant trains of equipment located outside of the pri- | |||
mary 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 sys- | |||
tems of concern are subject to damage from fire suppression activities, | |||
Section III.G.3 of the rule requires that an alternate or dedicated shut- | |||
down 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 | |||
Section III.G, however, such protection is deemed to be adequate by the | |||
licensee for,the specific situation, the rule allows the licensee to re- | |||
quest 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. | |||
4.0 Correspondence | |||
All correspondence between the licensee and the NRC concerning compliance | |||
with Section III.G, J, and 0 was reviewed by the inspection team in pre- | |||
paration for the site visit. Attachment I to this report is a listing of | |||
the correspondence reviewed. | |||
5.0 Post-Fire Safe Shutdown Capability | |||
5.1 Systems Required for Safe Shutdown | |||
Safe shutdown is initiated from the control room by a manual scram of | |||
the control rods. Reactor scram can also be initiated manually by | |||
deenergizing the reactor protection system buses. Reactor coolant | |||
. | |||
. | |||
4 | |||
inventory can be maintained by either the reactor core isolation | |||
cooling system (RCIC), the high pressure coolant injection system | |||
, | |||
(HPCI); or the low pressure coolant injection system (LPCI) or the | |||
core spray system (CS) in conjunction with the automatic despressuri- | |||
zation system (ADS). Reactor coolant system pressure is controlled | |||
by the Safety Relief Valves (SRV) either automatically or manually. | |||
Decay heat removal is provided by either the RHR in the shutdown | |||
cooling mode; or the LPCI or the CS in conjunction with the RHR in | |||
the suppression pool cooling mode. | |||
The support systems required for safe shutdown include the RHR ser- | |||
vice water system, the emergency service water system, the essential | |||
ventilation systems, the emergency diesel generators and the essen- | |||
, tial electrical distribution system. The above systems are monitored | |||
and controlled from the ''ntrol room or the remote shutdown panel and | |||
local control stations. | |||
5.2 Alternative Safe Shutdown Areas | |||
The licensee has committed to provide alternative safe shutdown capa- | |||
bility in accordance with the requirements of Section III.G.3 and - | |||
' | |||
III.L of Appendix R to 10 CFR 50, for the Main Control Room, the Re- | |||
lay Room and the Cable Spreading Room. | |||
5.3 Remaining Plant Areas | |||
All plant areas not provided with an alternative safe shutdown system | |||
are required to be in compliance with the requirements of Section | |||
III.G.2 of Appendix R unless an exemption request has been approved | |||
by the Commission. | |||
The licensee requested a number of exemptions to certain provisions | |||
of Appendix R which were evaluated and granted by the Commission. The | |||
enclosed Attachment 2 lists the requested exemptions and the Com- | |||
mission's date of approval. | |||
5.4 Alternative Safe Shutdown Systems | |||
The alternative shutdown capability consists of a remote shutdown | |||
panel (25 RSP) and three auxiliary shutdown panels 25 ASP-1, 25 ASP-2 | |||
and 25 ASP-3 which contain local control and isolation switches. The | |||
remote shutdown panel is located in the reactor building on elevation | |||
300 feet. The alternative shutdown capability utilizes seven safety | |||
relief valves and the low pressure coolant injection system (LPCI). | |||
The safety relief valves are controlled from the manual automatic | |||
depressurization system (ADS) panel located in the reactor building. | |||
The LPCI and the supporting RHR service water pump are controlled | |||
from the remote shutdown panel. The instrumentation for the | |||
alternative shutdown capability is provided at the remote shutdown | |||
panel and a local instrument rack. The power supply for the | |||
alternative shutdown equipment is supplied by the emergency diesel | |||
. | |||
. | |||
5 | |||
generator ("B" train only). The emergency diesel generators are | |||
manually isolated from the fire areas and locally started by breakers | |||
and controls provided in the local control panel located in the | |||
emergency diesel generator switchgear room. The design of the remote | |||
shutdown panel and the ADS panel includes control / isolation swi+ches | |||
which when activated will electrically isolate the panel from tne | |||
Control Room, Cable Spreading Room and Relay Room and will transfer | |||
control of the shutdown equipment to the panels. A fire at the re- | |||
mote shutdown, the ADS, or any of the auxiliary shutdown panels will | |||
result in loss of control for only the equipment controlled from the | |||
panel. One train of systems needed for safe shutdown will be avail- | |||
able and controlled from the main Control Room. | |||
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. | |||
' | |||
The following functional requirements were reviewed for achieving and | |||
maintaining hot and cold shutdown: | |||
* Reactivity control | |||
* | |||
Pressure control | |||
* Reactor coolant makeup | |||
* Decay heat removal | |||
* Support systems | |||
* Process monitoring | |||
The inspection team examined the licensee's capability to achieve and | |||
maintain hot shutdown and the capability to bring the plant to cold | |||
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 inde- | |||
pendence 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. | |||
. | |||
. | |||
. | |||
6 | |||
The inspection team examined the licensee's fire protection features pro- | |||
vided to maintain one train of equipment needed for safe shutdown free of | |||
fire damage. Included in the scope of this effort were fire area bounda- | |||
ries, including walls, floors and ceilings, and fire protection of open- | |||
ings such as fire doors, fire dampers, and penetration seals. | |||
:The inspection team also examined the licensee's compliance with Section | |||
III.J, Emergency Lighting. Section III.0, 011 Collection System for Re- | |||
actor Coolant Pump is not applicable to the licensee since the containment | |||
is inerted during normal operations. | |||
7.0 Inspection of Protection Provided for Safe Shutdown Systems | |||
7.1 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. | |||
The following fire areas were inspected: | |||
RB-1E Reactor Bldg. Crescent Area-East | |||
RB-1W Reactor Bldg. Crescent Area-West | |||
RB-1A Reactor Bldg. | |||
RB-1B Reactor Bldg. | |||
RB-1C Reactor Bldg. | |||
CR-1 Control Room | |||
RR-1 Relay Room | |||
CS-1 Cable Spreading Room | |||
MG-1 Motor Generator Room Elev. 300'-0 | |||
AD-1 Administration Bldg. Elev. 272'-0 | |||
AD-2 Administration Bldg. Elev. 272'-0 | |||
AD-3 Administration Bldg. Elev. 272'-0 | |||
Administration Bldg. Elev. 286'-0 | |||
~ | |||
AD-4 | |||
AD-5 Administration Bldg. Eley. 286'-0 | |||
AD-6 Administration Bldg. Elev. 300'-0 | |||
CT-1 Cable Tunnel West-Elev. 260'0" | |||
CT-2 Cable Tunnel East-Elev. 260'0" | |||
CT-3 Cable Tunnel 3, Elev. 286'-0 | |||
CT-4 Cable Tunnel 4, Elev. 286'-0 | |||
TB-1 Turbine Bldg. | |||
RW-1 Radwaste Bldg. and Pipe Tunnel | |||
; | |||
' | |||
SH-1 Screen Well House-Elev. 272'-0" | |||
SW-1 Switchgear Rm Elev. 272'-0" Turbine Bldg. | |||
SW-2 Switchgear Rm Elev. 272'-0" Turbine Bldg. | |||
FP-1 Foam Room Turbine Bldg.-Elev. 272'-0" | |||
SG-1 Standby Gas Filter Room | |||
- | |||
- - - _______. | |||
. | |||
. | |||
7 | |||
AS-1 Auxiliary Boiler Room | |||
BR-1 Battery Room No.1 | |||
BR-5 Battery Room Corridor | |||
EG-1 Emergency Diesel Generator Room | |||
EG-2 Emergency Diesel Generator Room | |||
EG-3 Emergency Diesel Generator Room | |||
EG-4 Emergency Diesel Generator Room | |||
EG-5 Emergency Diesel Generator Roc.. | |||
EG-6 Emergency Diesel Generator Room | |||
SP-1 Service Water Pump Room (Train B) | |||
SP-2 Service Water Pump Room (Train A) | |||
The team did not identify any unacceptable conditions, except as | |||
follows: | |||
Inadequate Separation of Safe Shutdown Systems (SSS) | |||
The team observed that spare conduit penetrations of the fire rated | |||
walls in the Control Room, Cable Spreading Room and Relay Room were | |||
scaled with pipe plugs that have not been tested for fire protection | |||
service. | |||
To maintain fire barrier integrity, openings in the fire barrier | |||
walls should be sealed with non-combustible materials qualified by | |||
tests that are comparable to tests used to rate fire barriers. | |||
Section III.G.2 of Appendix R to 10 CFR 50 requires that redundant | |||
SSS and associated non safety circuits that could prevent operation | |||
or cause maloperation of the SSS, shall be separated by either a fire | |||
barrier having three hours rating or shall be separated by a horizon- | |||
tal distance of 20' feet with no intervening combustibles with area | |||
suppression and detection or shall be separated by enclosing one of | |||
the systems within an one hour barrier with area suppression and | |||
detection. The licensee also identified cables in both East and West | |||
Cable tunnels from redundant SSS to be within the same fire area | |||
without proper separation. These cables may effect power to the | |||
ventilation dampers of the Emergency Diesels. Failure of the cables | |||
rnay result in damper closure which could result in excessive diesel | |||
room temperatures and possible everheating and loss of the diesels. | |||
The cables were noted to be located within close proximity to the | |||
cables of the opposite train. The licensee explained, that the spare | |||
conduit penetration seals were reviewed and the decision to accept | |||
unrated seals was made after an informal consultation with the | |||
. licensee's insurer. The licensee also explained that the unprotected | |||
cables in the cable tunnels, was an oversight identified, during a | |||
third party review of the systems. The licensee established fire | |||
watches as interim compensatory measures in the areas identified by | |||
the team as having degraded fire barriers or inadequate separation | |||
and committed to restore the fire barriers to operable status. The | |||
, | |||
. | |||
. | |||
8 | |||
spare conduit penetrations sealed with unrated plugs and the | |||
redundant safe shutdown conduits and cables located within the same | |||
fire areas constitute a violation of Appendix R Section III.G.2. | |||
(50-333/85-20-01) | |||
Fire Detection System not per NFPA Requirements | |||
The licensee by letter dated January 11, 1977, subject, J. A.Fitz- | |||
Patrick Fire Protection Program Evaluation committed to provide de- | |||
tection systems that conform to the requirements of NFPA standard | |||
No. 720. The current NFPA standard No. 72D requires that fire de- | |||
tection devices shall be listed, for the protective signaling purpose | |||
for which they are used. Listed equipment is equipment included in a | |||
list published by an organization acceptable to the " authority having | |||
jurisdiction" in this case NRC. | |||
The NRC routinely accepts equipment listed for fire protection ser- | |||
vice by either the Underwriters Laboratories (UL) or approved for | |||
such service by Factory Mutual (FM). The team in reviewing documents | |||
furnished by the licensee determined that the detectors used to | |||
actuate the water curtains in the reactor building are not listed. | |||
The licensee committed to provide NRC with documentation or proof | |||
that the installed detectors are comparable to similar devices listed | |||
by a listing organization. This item is unresolved pending review of | |||
the evaluation performed by the licensee. (50-333/85-20-02) | |||
Sprinkler System Installation not per National Fire Protection | |||
Association (NFPA) Requirements | |||
The licensee by letter dated January 11, 1977, subject, J. A. Fitz- | |||
Patrick Fire Protection Evaluation committed to provide sprinkler | |||
systems that as a minimum conform to the requirements of NFPA stand- | |||
ards No. 13 and 15. | |||
The team observed that the water spray nozzles of the cable tray de- | |||
luge system located in the East and West cable tunnels are designed | |||
to protact wall and wir.dow openings, not electrical trays. Also in- | |||
some cases the sprinklers appeared to be misdirected for the proper | |||
coverage of the cable trays. | |||
The above findings are not in conformance with the current NFPA | |||
standards. | |||
The licensee explained that the sprinkler design and installation in | |||
the areas identified above are in conformance with the applicable | |||
NFPA standards in existence at the time the plant was built. | |||
Because these standards were not available for review by the team, | |||
the licensee committed to obtain these standards and make an evalua- | |||
tion of the existing installation vs. the NFPA requirements. The | |||
. | |||
. | |||
9 | |||
licensee also committed to assess the effectiveness of the spray | |||
pattern of the nozzles installed in the East and West cable tunnels. | |||
The above constitute an unresolved item pending review of the actions | |||
taken by the licensee. -(50-333/85-20-03) | |||
Functional Testing of Fire Dampers | |||
As a result of a recent 10 CFR 21 notice that fire dampers manufac- | |||
turered by Ruskin Corporation may fail to close under normal system | |||
flow, the team expressed a concern that similar dampers at this fact- | |||
lity may not perform properly. | |||
" | |||
The licensee agreed with the team's concern and immediately function- | |||
ally tested all Ruskin dampers of the facility. From the dampers | |||
that were tested one failed to close, and the licensee immediately | |||
repa red it. | |||
The licensee committed to establish a program to functionally test | |||
under air flow conditions all the dampers of the facility every 18 | |||
months. | |||
This is an unresolved item pending review of the testing program and | |||
testing procedures. (50-333/85-20-04) | |||
. | |||
7.2 Safe Shutdown Procedures | |||
7.2.1 Procedure Review | |||
The team reviewed the following interim safe shutdown | |||
* | |||
procedures: | |||
* | |||
Operation During Plant Fires - No. F-A0P-28, Revision | |||
1, June 17, 1985. | |||
* | |||
Plant Shutdown from Outside the Control Room - | |||
No.F-A0P-43, Revision 3, June 14, 1985. | |||
The scope of this review was to ascertain that the shutdown | |||
could be attained in a safe and orderly manner, to deter- | |||
mine the level of difficulty involved in operating equip- | |||
ment, and to verify that there was no dependence on repairs | |||
except as noted below for achieving hot shutdown. For | |||
review purposes, a repair would include installing electri- | |||
' | |||
cal or pneumatic jumpers, wires or fuses to perform an ac- | |||
tion required for hot shutdown. For cold shutdown, repairs | |||
are allowed using in place procedures and materials avail- | |||
able onsite with the provision that cold shutdown be | |||
achievable within 72 hours with or without offsite power. | |||
Procedure F-A0P-28 is used to determine which of the exist- | |||
ing plant emergency procedures would be utilized to achieve | |||
- _ | |||
_ .~ _ _ _ . . _ _ ~ _ _ _ _ _ _ _ __ - -- - . _ - . | |||
. | |||
. | |||
10 | |||
safe shutdown for a fire anywhere in the plant, except for | |||
a fire in the Control Room, Relay Room and Cable Spreading | |||
Room. This procedure contains a fire area list, and pro- | |||
vides information to operators for system availability such | |||
as possible loss of systems in the fire area, available | |||
backup systems and required operator actions for a fire in | |||
a.given area. | |||
For a fire in the Control Room, Relay Room and Cable | |||
Spreading Room procedure F-A0P-43 is used, to achieve safe | |||
shutdown, utilizing the Alternative Shutdown Systems | |||
described in Section 5.4. This procedure is an interim | |||
procedure and will be revised once the modifications re- | |||
sulting from the response to I.E. Information Notice (IN) | |||
85-09 " Isolation Transfer Switches and Post Fire Shutdown | |||
Capability" are implemented. | |||
IN 85-09 alerted licensees about the possibility of a fire | |||
in the Control Room disabling the operation of the plant's | |||
alternate shutdown systems by damaging the transfer cir- | |||
cuits between the main control panel and the alternate | |||
shutdown panels. The licensee determined that this pos- | |||
sibility exists at the FitzPatrick Plant and responded to | |||
IN 85-09 by submitting a plan, in the form of an exemption | |||
request, for interim and permanent corrective actions. The | |||
exemption requested, was granted to the licensee by the | |||
Commission, in a letter dated May 6, 1985. This was based | |||
on the commitment, to provide a fire watch in the control | |||
room and provide the capability to replace fuses as needed | |||
in the interim. The permanent corrective action is the | |||
addition of redundant fuses in the circuits involved for | |||
which the schedular exemption was requested. | |||
Based on the foregoing items the team did not identify any | |||
unacceptable conditions in the review of the interim safe | |||
shutdown procedures except as follows: | |||
Exemption Request To Allow Temporary Core Uncovery | |||
10 CFR 50 Appendix R Section III.L.b requires that the | |||
reactor coolant makeup function shall be capable of main- | |||
taining the reactor coolant level above the top of the core | |||
during and subsequent to, shutdown function. | |||
The current licensee's emergency shutdown procedures for a | |||
fire in the Control Room Cable Spreading Room and Relay | |||
Room require activation of the ADS for reactor depressuri- | |||
zation and LPCI system initiation for coolant injection. | |||
These procedures must be implemented promptly, in order not | |||
to allow core uncovery. The licensee in order to gain | |||
flexibility and to allow the operators to examine all | |||
. | |||
. | |||
11 | |||
shutdown options has applied for an exemption from the | |||
above mentioned Appendix R requirement. The exemption re- | |||
quest dated June 14, 1985, cites the results of certain | |||
analysis, that justify an alternate shutdown scenario which | |||
allows for the core to be uncovered for a short time | |||
period. This item remains unresolved pending NRC's evalu- | |||
ation of the licensee's exemption request. | |||
(50-333/85-20-05) | |||
7.2.2 Procedure Walk-Through | |||
The team walked through selected portions of the procedures | |||
, | |||
to determine that shutdown could be attained in an orderly | |||
and timely fashion. The walk-through was accomplished by | |||
using 4 operators and the shift supervisor. | |||
A scenario for a Control Room fire was established and the | |||
operators proceeded to simulate the steps described in the | |||
procedure. All steps were simulated in order to demon- | |||
strate feasibility, timely response to the emergency, abil- | |||
ity to communicate etc. | |||
The walk-through began at the Control Room and all steps | |||
required for hot shutdown were completed in less than 45 | |||
minutes. | |||
No unacceptable conditions were identified except as | |||
follows: | |||
Difficult Access of Fuse Box for Fuse Replacement | |||
During a simulated attempt to replace fuses the team ob- | |||
served that fuses located high on the fuse panels may be | |||
inaccessible to the operators. The licensee agreed with | |||
the team and committed to review all of the panels where | |||
fuses may need replacement during an emergency and provide | |||
means for access to the fuse boxes. The team also observed | |||
that the box containing spare fuses, ear phones etc. near | |||
Auxiliary Shutdown Panel 25 ASP-2 is located in an area | |||
where equipment from the box may be readily lost if | |||
dropped. The licensee agreed and committed to provide an | |||
additional equipment box in the vicinity of the panel. The | |||
licensee committed to provide all of the above by July 19, | |||
1985. | |||
This is an unresolved item pending review of the licensee's | |||
action. (50-333/85-20-06) | |||
7.3 Protection for Associated Circuits | |||
Appendix R, Section III.G requires that protection be provided for | |||
, associated circuits that could prevent operation or cause | |||
.- - - - - -. - .- | |||
" | |||
. | |||
. | |||
12 | |||
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: | |||
* 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. | |||
7.3.1 Common B'us 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, 4160V, 600V and | |||
125V DC bus protective relay coordination. The licensee | |||
presented sample coordination curves dated October 31, | |||
1974, at the time of the audit. The team also examined, on | |||
a sampling basis, the protection for specific instrumenta- | |||
tion, controls, and power circuits, including the coordina- | |||
tion of fuses and circuit breakers. The licensee plans to | |||
perform relay setting at approximately 24-month intervals. | |||
No unacceptable conditions were identified. | |||
7.3.2 Spurious Signals Concern | |||
ihe spurious signal concern is made up of 2 items: | |||
* | |||
False motor control and instrument indications can | |||
occur such as those encountered during 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 examined, on a sampling basis, the following areas | |||
: to ascertain that no spurious signal concern exists: | |||
* | |||
Current transformer secondaries | |||
i * High/ low pressure interfaces | |||
' | |||
* | |||
General fire instigated spurious signals | |||
l | |||
l | |||
L | |||
_ _ _ _ . | |||
.. . . . _ . . . _ - - - - - -. | |||
. | |||
. | |||
, 13 | |||
,_ | |||
The team determined that the licensee conducted an analysis | |||
which. identified a number of high/ low pressure interfaces. | |||
In order to protect against the possibility of spurious | |||
actuation of high/ low pressure interfaces, the license is | |||
1) removing power from some valves during normal operation | |||
and 2) is utilizing isolation switches to enable the | |||
operators to remove power when necessary. The current | |||
transformer secondaries of concern are protected by the | |||
installation of transfer switches which provide the | |||
capability to isolate and short the secondaries. | |||
Each fire area was analyzed to determine the impact of | |||
general fire instigated spurious signals. The licensee | |||
identified some cases which were resolved by isolations | |||
such as "The removal of fuses". | |||
No unacceptable conditions were identified. | |||
7.3.3 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 fire can | |||
destroy both circuits due to inadequate fire barriers. | |||
A number of circuits, selected on a sampling basis, were | |||
examined for this concern. | |||
The common enclosure concern was satisfactorily addressed. | |||
The redundant cables for divisions A and B are not run in | |||
: the same tray or conduits. In addition, all circuits are | |||
protected vith coordinated circuit breakers. | |||
No unaccep:eble conditions were identified. | |||
8.0 Emergency Lighting | |||
l | |||
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. | |||
The team examined the plant emergency lighting system to ascertain the | |||
; licensee's compliance with the above requirements. | |||
i | |||
. | |||
I | |||
, .~ , - - , . . - . . . . , . , , . - - . - . . - . - - . - - , - . - , - - , - . . . - . - . - - - . , . . - - | |||
. - . - - , - . , | |||
. | |||
. | |||
14 | |||
The team did not identify any unacceptable conditions except as follows: | |||
Marginal Emergency Lighting Conditions | |||
The team observed during a fire area " black-out" that the existing | |||
emergency lighting system was marginally adequate to perform the necessary | |||
operations on the shutdown panels. The licensee agreed and stated that | |||
this condition was identified by a third party review of the system prior | |||
to the arrival of the audit team on site. The licensee committed to pro- | |||
vide additional lighting in the (4) shutdown panel areas within 45 days. | |||
This is an unresolved item pending installation of the emergency lights. | |||
(50-333/85-20-07) | |||
9.0 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 in this plant | |||
is inerted during normal operation, the above requirement does not apply | |||
to this plant. | |||
10.0 Quality Assurance | |||
During the course of the inspection, the team reviewed several drawings, | |||
the fire hazard analysis, fire protection modification packages, | |||
procedures, and other fire protection documents. The scope of this review | |||
included verification of their technical adequacy, appropriate reviews, | |||
design and procurement controls, and other Quality Assurance requirements | |||
for the licensee's fire protection program. Except as noted in the | |||
previous section of this report, the team did not identify any other | |||
unacceptable conditions. | |||
11.0 Unresolved Items | |||
Unresolved items are matters for which more information is required in or- | |||
der to ascertain whether they are acceptable, violations, or deviations. | |||
Unresolved items are discussed in Section 7.1, 7.2 and 8.0. | |||
12.0 Conclusions | |||
The significant findings of this inspection are summarized as follows: | |||
* | |||
One violation from an Appendix R requirements to provide separation | |||
of safe shutdown components and associated circuits. | |||
* | |||
Seven items remained unresolved at the end of the inspection as | |||
mentioned in Section 11.0 above. | |||
Except as above, no other unacceptable conditions were identified. | |||
_{ | |||
, -. . - - - - -.. .. . - -. --. . . _ . - .. - .- . . _ . | |||
. | |||
. | |||
: | |||
! | |||
? | |||
15 | |||
- | |||
. | |||
J | |||
1 | |||
; 13.0 Exit Interview | |||
, The inspection team met with the licensee representatives,' denoted in | |||
, Section 1.0, at the conclusion of the inspection on June 21, 1985, and the | |||
team leader summarized the scope and findings of the inspection at that | |||
, time. | |||
l 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 | |||
.t | |||
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. | |||
. | |||
i | |||
i | |||
1 | |||
0 | |||
- | |||
i | |||
[ | |||
i | |||
l | |||
: | |||
j- 1 | |||
, | |||
i | |||
4 | |||
! | |||
! | |||
, | |||
i | |||
e v w--- wm c , a-e- . , , - - , , , - . - , , , - .,w- %--- --,,_,r,, n y. . um, .--.-my,%7s ,m ym ,, , ,r-r_,__,,gy ,--p,y,,rr - " e-FT--'--"" ~T''"- | |||
. __ _ _ . . . _ . _ ._ . --_ | |||
. | |||
.. | |||
ATTACHMENT 1 | |||
DOCUMENT REVIEW LIST | |||
January 11, 1977 Letter from Licensee to NRC commits to meet Section B of | |||
APCSB 9.5-1 Appendix A | |||
February 9,1978 Internal NRC Memorandum regarding Fire Protection Review - | |||
Require Additional Information | |||
May 23, 1978 Licensee Letter to NRC - Licensee will provide additional | |||
information by June 19, 1978 | |||
October,1980 Safe Shutdown Analysis | |||
February 4, 1981 Internal BNL Memorandum - Telephone Conference on January | |||
21, 1981 | |||
February 19, 1981 BNL Letter to Chief of Chem. Branch - Interim Report Post | |||
Fire Capability | |||
- February 24, 1981 NRC internal memorandum - Licensee does not meet | |||
Section III.G and L of Appendix R. | |||
March 19,-1981 Licensee Letter to NRC - Request for Scheduler Exemption | |||
Request | |||
Appendix F - Response to NRC Staff's Generic Letter 81-12 - | |||
Appendix G - Review Criteria for Spurious Valve Actuation | |||
February 26, 1982 Licensee Letter to NRC - Appendix II to " Safe Shutdown | |||
Analysis" | |||
~ May 12, 1982 BNL Memorandun. to File - BNL Interim Report was never | |||
transmitted to licensee | |||
May 20, 1982 BNL Internal Memorandum to File - FitzPatrick does not meet | |||
III.G.2, III.G.3 or III.L | |||
, | |||
June 11, 1982 BNL Letter to NRC " Draft" copy of Post Fire Safe Shutdown | |||
June 14, 1982 BNL Memo to File - FitzPatrick does not intend to come in | |||
for a meeting to discuss their February 26, 1982 submittal | |||
c July 7, 1982 NRC Internal Memorandum to File - Minutes of Meeting in | |||
: - | |||
Bethesda on June 29, 1982 | |||
! | |||
( July 13, 1982 Licensee Report - A Reassessment of Conformance to Appendix | |||
! R | |||
I | |||
w --e--~ e+ ~'' | |||
, ,-.s .n,- ,. , . ., - , , . ,--- --- ,,, .. - | |||
----wr..-,.---,--iea. - ++-*-y<=-. --- ~-ev---+---- ~~ - '*m'*M-+ | |||
~_ . . -. . - _ . - _ _ . _ _ - - . _ . | |||
. | |||
. | |||
2 | |||
November 2, 1982 BNL Report - Post Fire Safe Shutdown. Capability Report - | |||
Based on July 13, 1982 submittal | |||
November 16, 1982 NRC Internal Memorandum - Chem. Branch denies 4 exemption | |||
request | |||
December 14, 1982 Internal NRC Memorandum - SER III.G.3 and III.L of Appendix | |||
R - | |||
December 22, 1982 Internal NRC Memorandun - Chem. Branch again denies 4 | |||
exemption requests. | |||
February 2, 1983 NRC Letter to Licensee - Informs licensee of appeal process | |||
for exemption denials (Draft SER) , | |||
March 1, 1983 Licensee Letter to NRC - Licensee comments on the draft SER | |||
April 26, 1983 NRC Letter to Licensee - Alternate Safe Shutdown Capability | |||
SER | |||
9 | |||
May 19, 1983 Licensee Letter to NRC - response to NRC letter dated | |||
April 26, 1983 | |||
July 1, 1983 NRC Letter to Licensee grants exemption request for | |||
Control Room and the Torus Room | |||
Sept. 29, 1983 Internal NRC Memorandum grants all outstanding exemption | |||
requests | |||
February 1, 1984 NRC Letter to Licensee notification of granting of out- | |||
standing exemptions | |||
July 16,.1984 Licensee Letter to NRC - requests clarification of | |||
exemption requests | |||
! July 24, 1984 Licensee Letter to NRC - surveillance requirements for the | |||
: high pressure water fire protection system | |||
January 11, 1985 NRC Letter to Licensee - Exemption Request Water Spray | |||
System | |||
March 15, 1985 Licensee Letter to NRC - request for schedular exemption | |||
) | |||
i | |||
! | |||
: | |||
l | |||
. | |||
: | |||
1- | |||
l | |||
' | |||
l | |||
. - | |||
.-. -- - - . - . - . - - - - - ,_. ,- -- - - . . - - - - . - . - - - - - . _ , _ - _ . . - _ , - . - _ _ | |||
" | |||
.. | |||
. | |||
. | |||
ATTACHMENT 2 | |||
SUMMARY OF APPENDIX R EXEMPTIONS | |||
. Exemption Request Description Date of Letter to PASNY | |||
3 Phase AC and DC Power Circuits April 26, 1983 | |||
Fuse Pulling and Lifting Leads April 26, 1983 | |||
Control Room July 1, 1983 | |||
(automatic area wide suppression) | |||
RB-1E and RB-1W February 1, 1984/ | |||
(zone interfaces at Elevs. 227'-6" and January 11, 1985 | |||
242'6") | |||
RB-1E and RB-1W February 1, 1984/ | |||
(cable separation) January 11, 1985 | |||
RB-1E and RB-1A February 1, 1984/ | |||
(stairway from Elev. 227'6" to 272'-0") January 11, 1985 | |||
RB-1A and RB-1B February 1, 1984/ | |||
(zone interface on Elev. 272'-0") January 11, 1985 | |||
RB-1B and RB-1C February 1, 1984/ | |||
(zone interface on Elev. 300'-0") January 11, 1985 | |||
RB-1A and RB-1B February 1, 1984/ | |||
(zone interface on Eley, 300'-0") January 11, 1985 | |||
RB-1A and RB-1C February 1, 1984/ | |||
(stairway from Elev. 272'-0" to 300'-0") January 11, 1985 | |||
RB-1C and RB-IA February 1, 1984/ | |||
(stairway from Elev. 300'-0" to 326'-0") January 11, 1985 | |||
Torus Room July 1, 1983 | |||
(RHR valve separation) | |||
RB-1B and RB-1A February 1, 1984/ | |||
(stairway from Elev. 300'-0" to 326'-0") January 11, 1985 | |||
. | |||
. | |||
ATTACHMENT 3 | |||
SUMMARY OF INSPECTION FINDINGS | |||
Item Description Section Reference | |||
Violations | |||
50-333/85-20-01 Inadequate uncap separation of 7.1 | |||
safe shutdown systems | |||
Unresolved Items | |||
50-333/85-20-02 Fire detection systems not 7.1 | |||
per NFPA requirements | |||
50-333/85-20-03 Sprinkler system installation | |||
not per NFPA requirements | |||
50-333/85-20-04 Functional testing of fire 7.1 | |||
dampers | |||
50-333/85-20-05 Exemption request to allow 7.2 | |||
temporary core uncovery | |||
50-333/85-20-06 Safe shutdown with inoperable | |||
emergency diesel "B" system | |||
50-333/85-20-07 Difficult access of fuse boxes 7.2 | |||
for fuse replacement | |||
50-333/85-20-08 Marginal emergency lighting 8.0 | |||
< | |||
conditions | |||
_ ._ _ _ - _ | |||
}} |
Latest revision as of 00:23, 1 July 2020
ML20137F605 | |
Person / Time | |
---|---|
Site: | FitzPatrick ![]() |
Issue date: | 08/13/1985 |
From: | Anderson C, Krasopoulos A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | |
Shared Package | |
ML20137F568 | List: |
References | |
50-333-85-20, NUDOCS 8508270016 | |
Download: ML20137F605 (19) | |
See also: IR 05000333/1985020
Text
.
.
/ U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 85-20
. Docket No. 50-333
, License No. DPR-59 Priority -
Category C
Licensee: Power Authority State of New York
James A. FitzPatrick Nuclear Power Plant
'
P. O. Box 41
Lycoming, New York 13093
Facility Name: James A. FitzPatrick Nuclear Power Plant
Inspection At: Scriba, New York
Inspection Conducted: June 17 - 21, 1985
i Inspectors: 9) ~
l]uC. /.3 /4 W
'A. Krasopdulos, Reactor Engineer da te'
Also. participating in the inspection and contributing to the report were:
'
'f
T. Chandrasekaran, Auxiliary Systems Branch NRR
.A. Singh, Auxiliary Systems Branch, NRR
, ,
- A. Coppola, Mechanical Systems Specialist, BNL
'
H. Thomas, Electrical Systems Specialist, BNL
l P. Koltay, Senior Resident Inspector, Region I
D. Kubicki, Chemical Engineering Branch, NRR
S. West, Chemic 1 eering Branch, NRR
' Approved b'y:
'
O; TU
C. J.fAnderson, Chief, Plant System date
. Section, DRS
j Inspection Summary: Inspection on June 17-21, 1985 (Report No. 50-333/85-20)
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 0, concerning fire protection features to ensure the ability to achieve and
maintain safe shutdown in the event of a fire. The inspection involved 272
- inspector-hours onsite and 36 inspector hours in-office by a team consisting
of 8 inspectors.
Results: One siolation was identified (Failure to maintain separation of re-
dundant components). Seven items remained unresolved at the end of the inspec-
tion. See Attachment 3 for a summary of the inspection findings.
'
,
8500270016 850821
PDR ADOCK 05000333
G PDR
, .
.
-
.
DETAILS
1.0 Persons Contacted
1.1 Power Authority of the State of New York (PASNY)
B. Bernstein, Plant Engineer Technical Services
R. Burns, Vice President BWR Support
- R. Converse, Superintendent of Power
M. Cass, Licensing Engineer
M. Curling, Training Superintendent
F. DePoalo, Project Support Engineer
J. Ellmers, Senior Nuclear Licensing Engineer
- W. Fernandez, Operations Superintendent
N. Garofalo, Senior Plant Engineer Technical Services
- H. Glovier, Resident Manager
- J. Gray, Jr., Director Nuclear Licensing
- L. Guaquil, Director Project Engineering
R. Heath, Fire Protection Supervisor
- D. Holliday, Senior Plant Engineer
- L. Jonston, QA Supervisor
J. Kerfiev, QA Supervisor
R. Locy, Waste Management Superintendent
S. Muckherjee, Supervisory Engineer
1.2 Licensee Contractors - Stone and Webster Engineering Corp (SWEC)
EMP Inc.
S. Burke, Fire Protection - EMP Inc.
D. Cirrone, Project Manager - SWEC
A. Faramarzi, Systems Engineer - EMP Inc.
>
S.-Kohr, Power Engineer - SWEC
R. Tworek, Senior Electrical Designer (SWEC)
R. Ulftstam, Fire Protection Supervisor - SWEC
1.3 Nuclear Regulatory Commission (NRC)
- H. Abelson, Project Manager - ORB
- A. Luptak, Senior Resident Inspector (Acting)
- Denotes those present at the exit meeting.
'2.0 Purpose
This inspection was to ascertain that the licensee is in conformance with
10 CFR,50, Appendix R, Sections III. G, J, and 0, including exemptions ap-
s proved by the Office of Nuclear Reactor Regulation (NRR).
)
>
3
- f.
.
.
3
3.0 Background
10 CFR 50.48 and 10 CFR 50 Appendix R became effective on February 17,
1981. Section III.G of Appendix R requires that fire protection be
provided to ensure that one train of equipment necessary to achieve and
maintain safe shutdown remains available in the event of a fire at any
location within a licensed operating facility. For hot shutdown condi-
tions, one train of the systems necessary must be free of fire damage
(III.G.1.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 te provide adequate
protection for redundant trains of equipment located outside of the pri-
mary 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 sys-
tems of concern are subject to damage from fire suppression activities,
Section III.G.3 of the rule requires that an alternate or dedicated shut-
down 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
Section III.G, however, such protection is deemed to be adequate by the
licensee for,the specific situation, the rule allows the licensee to re-
quest 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.
4.0 Correspondence
All correspondence between the licensee and the NRC concerning compliance
with Section III.G, J, and 0 was reviewed by the inspection team in pre-
paration for the site visit. Attachment I to this report is a listing of
the correspondence reviewed.
5.0 Post-Fire Safe Shutdown Capability
5.1 Systems Required for Safe Shutdown
Safe shutdown is initiated from the control room by a manual scram of
the control rods. Reactor scram can also be initiated manually by
deenergizing the reactor protection system buses. Reactor coolant
.
.
4
inventory can be maintained by either the reactor core isolation
cooling system (RCIC), the high pressure coolant injection system
,
(HPCI); or the low pressure coolant injection system (LPCI) or the
core spray system (CS) in conjunction with the automatic despressuri-
zation system (ADS). Reactor coolant system pressure is controlled
by the Safety Relief Valves (SRV) either automatically or manually.
Decay heat removal is provided by either the RHR in the shutdown
cooling mode; or the LPCI or the CS in conjunction with the RHR in
the suppression pool cooling mode.
The support systems required for safe shutdown include the RHR ser-
vice water system, the emergency service water system, the essential
ventilation systems, the emergency diesel generators and the essen-
, tial electrical distribution system. The above systems are monitored
and controlled from the ntrol room or the remote shutdown panel and
local control stations.
5.2 Alternative Safe Shutdown Areas
The licensee has committed to provide alternative safe shutdown capa-
bility in accordance with the requirements of Section III.G.3 and -
'
III.L of Appendix R to 10 CFR 50, for the Main Control Room, the Re-
lay Room and the Cable Spreading Room.
5.3 Remaining Plant Areas
All plant areas not provided with an alternative safe shutdown system
are required to be in compliance with the requirements of Section
III.G.2 of Appendix R unless an exemption request has been approved
by the Commission.
The licensee requested a number of exemptions to certain provisions
of Appendix R which were evaluated and granted by the Commission. The
enclosed Attachment 2 lists the requested exemptions and the Com-
mission's date of approval.
5.4 Alternative Safe Shutdown Systems
The alternative shutdown capability consists of a remote shutdown
panel (25 RSP) and three auxiliary shutdown panels 25 ASP-1, 25 ASP-2
and 25 ASP-3 which contain local control and isolation switches. The
remote shutdown panel is located in the reactor building on elevation
300 feet. The alternative shutdown capability utilizes seven safety
relief valves and the low pressure coolant injection system (LPCI).
The safety relief valves are controlled from the manual automatic
depressurization system (ADS) panel located in the reactor building.
The LPCI and the supporting RHR service water pump are controlled
from the remote shutdown panel. The instrumentation for the
alternative shutdown capability is provided at the remote shutdown
panel and a local instrument rack. The power supply for the
alternative shutdown equipment is supplied by the emergency diesel
.
.
5
generator ("B" train only). The emergency diesel generators are
manually isolated from the fire areas and locally started by breakers
and controls provided in the local control panel located in the
emergency diesel generator switchgear room. The design of the remote
shutdown panel and the ADS panel includes control / isolation swi+ches
which when activated will electrically isolate the panel from tne
Control Room, Cable Spreading Room and Relay Room and will transfer
control of the shutdown equipment to the panels. A fire at the re-
mote shutdown, the ADS, or any of the auxiliary shutdown panels will
result in loss of control for only the equipment controlled from the
panel. One train of systems needed for safe shutdown will be avail-
able and controlled from the main Control Room.
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.
'
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
The inspection team examined the licensee's capability to achieve and
maintain hot shutdown and the capability to bring the plant to cold
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 inde-
pendence 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.
.
.
.
6
The inspection team examined the licensee's fire protection features pro-
vided to maintain one train of equipment needed for safe shutdown free of
fire damage. Included in the scope of this effort were fire area bounda-
ries, including walls, floors and ceilings, and fire protection of open-
ings such as fire doors, fire dampers, and penetration seals.
- The inspection team also examined the licensee's compliance with Section
III.J, Emergency Lighting.Section III.0, 011 Collection System for Re-
actor Coolant Pump is not applicable to the licensee since the containment
is inerted during normal operations.
7.0 Inspection of Protection Provided for Safe Shutdown Systems
7.1 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.
The following fire areas were inspected:
RB-1E Reactor Bldg. Crescent Area-East
RB-1W Reactor Bldg. Crescent Area-West
RB-1A Reactor Bldg.
RB-1B Reactor Bldg.
RB-1C Reactor Bldg.
CR-1 Control Room
RR-1 Relay Room
CS-1 Cable Spreading Room
MG-1 Motor Generator Room Elev. 300'-0
AD-1 Administration Bldg. Elev. 272'-0
AD-2 Administration Bldg. Elev. 272'-0
AD-3 Administration Bldg. Elev. 272'-0
Administration Bldg. Elev. 286'-0
~
AD-4
AD-5 Administration Bldg. Eley. 286'-0
AD-6 Administration Bldg. Elev. 300'-0
CT-1 Cable Tunnel West-Elev. 260'0"
CT-2 Cable Tunnel East-Elev. 260'0"
CT-3 Cable Tunnel 3, Elev. 286'-0
CT-4 Cable Tunnel 4, Elev. 286'-0
TB-1 Turbine Bldg.
RW-1 Radwaste Bldg. and Pipe Tunnel
'
SH-1 Screen Well House-Elev. 272'-0"
SW-1 Switchgear Rm Elev. 272'-0" Turbine Bldg.
SW-2 Switchgear Rm Elev. 272'-0" Turbine Bldg.
FP-1 Foam Room Turbine Bldg.-Elev. 272'-0"
SG-1 Standby Gas Filter Room
-
- - - _______.
.
.
7
AS-1 Auxiliary Boiler Room
BR-1 Battery Room No.1
BR-5 Battery Room Corridor
EG-1 Emergency Diesel Generator Room
EG-2 Emergency Diesel Generator Room
EG-3 Emergency Diesel Generator Room
EG-4 Emergency Diesel Generator Room
EG-5 Emergency Diesel Generator Roc..
EG-6 Emergency Diesel Generator Room
SP-1 Service Water Pump Room (Train B)
SP-2 Service Water Pump Room (Train A)
The team did not identify any unacceptable conditions, except as
follows:
Inadequate Separation of Safe Shutdown Systems (SSS)
The team observed that spare conduit penetrations of the fire rated
walls in the Control Room, Cable Spreading Room and Relay Room were
scaled with pipe plugs that have not been tested for fire protection
service.
To maintain fire barrier integrity, openings in the fire barrier
walls should be sealed with non-combustible materials qualified by
tests that are comparable to tests used to rate fire barriers.
Section III.G.2 of Appendix R to 10 CFR 50 requires that redundant
SSS and associated non safety circuits that could prevent operation
or cause maloperation of the SSS, shall be separated by either a fire
barrier having three hours rating or shall be separated by a horizon-
tal distance of 20' feet with no intervening combustibles with area
suppression and detection or shall be separated by enclosing one of
the systems within an one hour barrier with area suppression and
detection. The licensee also identified cables in both East and West
Cable tunnels from redundant SSS to be within the same fire area
without proper separation. These cables may effect power to the
ventilation dampers of the Emergency Diesels. Failure of the cables
rnay result in damper closure which could result in excessive diesel
room temperatures and possible everheating and loss of the diesels.
The cables were noted to be located within close proximity to the
cables of the opposite train. The licensee explained, that the spare
conduit penetration seals were reviewed and the decision to accept
unrated seals was made after an informal consultation with the
. licensee's insurer. The licensee also explained that the unprotected
cables in the cable tunnels, was an oversight identified, during a
third party review of the systems. The licensee established fire
watches as interim compensatory measures in the areas identified by
the team as having degraded fire barriers or inadequate separation
and committed to restore the fire barriers to operable status. The
,
.
.
8
spare conduit penetrations sealed with unrated plugs and the
redundant safe shutdown conduits and cables located within the same
fire areas constitute a violation of Appendix R Section III.G.2.
(50-333/85-20-01)
Fire Detection System not per NFPA Requirements
The licensee by letter dated January 11, 1977, subject, J. A.Fitz-
Patrick Fire Protection Program Evaluation committed to provide de-
tection systems that conform to the requirements of NFPA standard
No. 720. The current NFPA standard No. 72D requires that fire de-
tection devices shall be listed, for the protective signaling purpose
for which they are used. Listed equipment is equipment included in a
list published by an organization acceptable to the " authority having
jurisdiction" in this case NRC.
The NRC routinely accepts equipment listed for fire protection ser-
vice by either the Underwriters Laboratories (UL) or approved for
such service by Factory Mutual (FM). The team in reviewing documents
furnished by the licensee determined that the detectors used to
actuate the water curtains in the reactor building are not listed.
The licensee committed to provide NRC with documentation or proof
that the installed detectors are comparable to similar devices listed
by a listing organization. This item is unresolved pending review of
the evaluation performed by the licensee. (50-333/85-20-02)
Sprinkler System Installation not per National Fire Protection
Association (NFPA) Requirements
The licensee by letter dated January 11, 1977, subject, J. A. Fitz-
Patrick Fire Protection Evaluation committed to provide sprinkler
systems that as a minimum conform to the requirements of NFPA stand-
ards No. 13 and 15.
The team observed that the water spray nozzles of the cable tray de-
luge system located in the East and West cable tunnels are designed
to protact wall and wir.dow openings, not electrical trays. Also in-
some cases the sprinklers appeared to be misdirected for the proper
coverage of the cable trays.
The above findings are not in conformance with the current NFPA
standards.
The licensee explained that the sprinkler design and installation in
the areas identified above are in conformance with the applicable
NFPA standards in existence at the time the plant was built.
Because these standards were not available for review by the team,
the licensee committed to obtain these standards and make an evalua-
tion of the existing installation vs. the NFPA requirements. The
.
.
9
licensee also committed to assess the effectiveness of the spray
pattern of the nozzles installed in the East and West cable tunnels.
The above constitute an unresolved item pending review of the actions
taken by the licensee. -(50-333/85-20-03)
Functional Testing of Fire Dampers
As a result of a recent 10 CFR 21 notice that fire dampers manufac-
turered by Ruskin Corporation may fail to close under normal system
flow, the team expressed a concern that similar dampers at this fact-
lity may not perform properly.
"
The licensee agreed with the team's concern and immediately function-
ally tested all Ruskin dampers of the facility. From the dampers
that were tested one failed to close, and the licensee immediately
repa red it.
The licensee committed to establish a program to functionally test
under air flow conditions all the dampers of the facility every 18
months.
This is an unresolved item pending review of the testing program and
testing procedures. (50-333/85-20-04)
.
7.2 Safe Shutdown Procedures
7.2.1 Procedure Review
The team reviewed the following interim safe shutdown
procedures:
Operation During Plant Fires - No. F-A0P-28, Revision
1, June 17, 1985.
Plant Shutdown from Outside the Control Room -
No.F-A0P-43, Revision 3, June 14, 1985.
The scope of this review was to ascertain that the shutdown
could be attained in a safe and orderly manner, to deter-
mine the level of difficulty involved in operating equip-
ment, and to verify that there was no dependence on repairs
except as noted below for achieving hot shutdown. For
review purposes, a repair would include installing electri-
'
cal or pneumatic jumpers, wires or fuses to perform an ac-
tion required for hot shutdown. For cold shutdown, repairs
are allowed using in place procedures and materials avail-
able 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 /> with or without offsite power.
Procedure F-A0P-28 is used to determine which of the exist-
ing plant emergency procedures would be utilized to achieve
- _
_ .~ _ _ _ . . _ _ ~ _ _ _ _ _ _ _ __ - -- - . _ - .
.
.
10
safe shutdown for a fire anywhere in the plant, except for
a fire in the Control Room, Relay Room and Cable Spreading
Room. This procedure contains a fire area list, and pro-
vides information to operators for system availability such
as possible loss of systems in the fire area, available
backup systems and required operator actions for a fire in
a.given area.
For a fire in the Control Room, Relay Room and Cable
Spreading Room procedure F-A0P-43 is used, to achieve safe
shutdown, utilizing the Alternative Shutdown Systems
described in Section 5.4. This procedure is an interim
procedure and will be revised once the modifications re-
sulting from the response to I.E. Information Notice (IN)
85-09 " Isolation Transfer Switches and Post Fire Shutdown
Capability" are implemented.
IN 85-09 alerted licensees about the possibility of a fire
in the Control Room disabling the operation of the plant's
alternate shutdown systems by damaging the transfer cir-
cuits between the main control panel and the alternate
shutdown panels. The licensee determined that this pos-
sibility exists at the FitzPatrick Plant and responded to
IN 85-09 by submitting a plan, in the form of an exemption
request, for interim and permanent corrective actions. The
exemption requested, was granted to the licensee by the
Commission, in a letter dated May 6, 1985. This was based
on the commitment, to provide a fire watch in the control
room and provide the capability to replace fuses as needed
in the interim. The permanent corrective action is the
addition of redundant fuses in the circuits involved for
which the schedular exemption was requested.
Based on the foregoing items the team did not identify any
unacceptable conditions in the review of the interim safe
shutdown procedures except as follows:
Exemption Request To Allow Temporary Core Uncovery
10 CFR 50 Appendix R Section III.L.b requires that the
reactor coolant makeup function shall be capable of main-
taining the reactor coolant level above the top of the core
during and subsequent to, shutdown function.
The current licensee's emergency shutdown procedures for a
fire in the Control Room Cable Spreading Room and Relay
Room require activation of the ADS for reactor depressuri-
zation and LPCI system initiation for coolant injection.
These procedures must be implemented promptly, in order not
to allow core uncovery. The licensee in order to gain
flexibility and to allow the operators to examine all
.
.
11
shutdown options has applied for an exemption from the
above mentioned Appendix R requirement. The exemption re-
quest dated June 14, 1985, cites the results of certain
analysis, that justify an alternate shutdown scenario which
allows for the core to be uncovered for a short time
period. This item remains unresolved pending NRC's evalu-
ation of the licensee's exemption request.
(50-333/85-20-05)
7.2.2 Procedure Walk-Through
The team walked through selected portions of the procedures
,
to determine that shutdown could be attained in an orderly
and timely fashion. The walk-through was accomplished by
using 4 operators and the shift supervisor.
A scenario for a Control Room fire was established and the
operators proceeded to simulate the steps described in the
procedure. All steps were simulated in order to demon-
strate feasibility, timely response to the emergency, abil-
ity to communicate etc.
The walk-through began at the Control Room and all steps
required for hot shutdown were completed in less than 45
minutes.
No unacceptable conditions were identified except as
follows:
Difficult Access of Fuse Box for Fuse Replacement
During a simulated attempt to replace fuses the team ob-
served that fuses located high on the fuse panels may be
inaccessible to the operators. The licensee agreed with
the team and committed to review all of the panels where
fuses may need replacement during an emergency and provide
means for access to the fuse boxes. The team also observed
that the box containing spare fuses, ear phones etc. near
Auxiliary Shutdown Panel 25 ASP-2 is located in an area
where equipment from the box may be readily lost if
dropped. The licensee agreed and committed to provide an
additional equipment box in the vicinity of the panel. The
licensee committed to provide all of the above by July 19,
1985.
This is an unresolved item pending review of the licensee's
action. (50-333/85-20-06)
7.3 Protection for Associated Circuits
Appendix R,Section III.G requires that protection be provided for
, associated circuits that could prevent operation or cause
.- - - - - -. - .-
"
.
.
12
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:
- 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.
7.3.1 Common B'us 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, 4160V, 600V and
125V DC bus protective relay coordination. The licensee
presented sample coordination curves dated October 31,
1974, at the time of the audit. The team also examined, on
a sampling basis, the protection for specific instrumenta-
tion, controls, and power circuits, including the coordina-
tion of fuses and circuit breakers. The licensee plans to
perform relay setting at approximately 24-month intervals.
No unacceptable conditions were identified.
7.3.2 Spurious Signals Concern
ihe spurious signal concern is made up of 2 items:
False motor control and instrument indications can
occur such as those encountered during 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 examined, on a sampling basis, the following areas
- to ascertain that no spurious signal concern exists:
Current transformer secondaries
i * High/ low pressure interfaces
'
General fire instigated spurious signals
l
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_ _ _ _ .
.. . . . _ . . . _ - - - - - -.
.
.
, 13
,_
The team determined that the licensee conducted an analysis
which. identified a number of high/ low pressure interfaces.
In order to protect against the possibility of spurious
actuation of high/ low pressure interfaces, the license is
1) removing power from some valves during normal operation
and 2) is utilizing isolation switches to enable the
operators to remove power when necessary. The current
transformer secondaries of concern are protected by the
installation of transfer switches which provide the
capability to isolate and short the secondaries.
Each fire area was analyzed to determine the impact of
general fire instigated spurious signals. The licensee
identified some cases which were resolved by isolations
such as "The removal of fuses".
No unacceptable conditions were identified.
7.3.3 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 fire can
destroy both circuits due to inadequate fire barriers.
A number of circuits, selected on a sampling basis, were
examined for this concern.
The common enclosure concern was satisfactorily addressed.
The redundant cables for divisions A and B are not run in
- the same tray or conduits. In addition, all circuits are
protected vith coordinated circuit breakers.
No unaccep:eble conditions were identified.
l
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.
The team examined the plant emergency lighting system to ascertain the
- licensee's compliance with the above requirements.
i
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, .~ , - - , . . - . . . . , . , , . - - . - . . - . - - . - - , - . - , - - , - . . . - . - . - - - . , . . - -
. - . - - , - . ,
.
.
14
The team did not identify any unacceptable conditions except as follows:
Marginal Emergency Lighting Conditions
The team observed during a fire area " black-out" that the existing
emergency lighting system was marginally adequate to perform the necessary
operations on the shutdown panels. The licensee agreed and stated that
this condition was identified by a third party review of the system prior
to the arrival of the audit team on site. The licensee committed to pro-
vide additional lighting in the (4) shutdown panel areas within 45 days.
This is an unresolved item pending installation of the emergency lights.
(50-333/85-20-07)
9.0 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 in this plant
is inerted during normal operation, the above requirement does not apply
to this plant.
10.0 Quality Assurance
During the course of the inspection, the team reviewed several drawings,
the fire hazard analysis, fire protection modification packages,
procedures, and other fire protection documents. The scope of this review
included verification of their technical adequacy, appropriate reviews,
design and procurement controls, and other Quality Assurance requirements
for the licensee's fire protection program. Except as noted in the
previous section of this report, the team did not identify any other
unacceptable conditions.
11.0 Unresolved Items
Unresolved items are matters for which more information is required in or-
der to ascertain whether they are acceptable, violations, or deviations.
Unresolved items are discussed in Section 7.1, 7.2 and 8.0.
12.0 Conclusions
The significant findings of this inspection are summarized as follows:
One violation from an Appendix R requirements to provide separation
of safe shutdown components and associated circuits.
Seven items remained unresolved at the end of the inspection as
mentioned in Section 11.0 above.
Except as above, no other unacceptable conditions were identified.
_{
, -. . - - - - -.. .. . - -. --. . . _ . - .. - .- . . _ .
.
.
!
?
15
-
.
J
1
- 13.0 Exit Interview
, The inspection team met with the licensee representatives,' denoted in
, Section 1.0, at the conclusion of the inspection on June 21, 1985, and the
team leader summarized the scope and findings of the inspection at that
, time.
l 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
.t
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.
.
i
i
1
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-
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. __ _ _ . . . _ . _ ._ . --_
.
..
ATTACHMENT 1
DOCUMENT REVIEW LIST
January 11, 1977 Letter from Licensee to NRC commits to meet Section B of
APCSB 9.5-1 Appendix A
February 9,1978 Internal NRC Memorandum regarding Fire Protection Review -
Require Additional Information
May 23, 1978 Licensee Letter to NRC - Licensee will provide additional
information by June 19, 1978
October,1980 Safe Shutdown Analysis
February 4, 1981 Internal BNL Memorandum - Telephone Conference on January
21, 1981
February 19, 1981 BNL Letter to Chief of Chem. Branch - Interim Report Post
Fire Capability
- February 24, 1981 NRC internal memorandum - Licensee does not meet
Section III.G and L of Appendix R.
March 19,-1981 Licensee Letter to NRC - Request for Scheduler Exemption
Request
Appendix F - Response to NRC Staff's Generic Letter 81-12 -
Appendix G - Review Criteria for Spurious Valve Actuation
February 26, 1982 Licensee Letter to NRC - Appendix II to " Safe Shutdown
Analysis"
~ May 12, 1982 BNL Memorandun. to File - BNL Interim Report was never
transmitted to licensee
May 20, 1982 BNL Internal Memorandum to File - FitzPatrick does not meet
III.G.2, III.G.3 or III.L
,
June 11, 1982 BNL Letter to NRC " Draft" copy of Post Fire Safe Shutdown
June 14, 1982 BNL Memo to File - FitzPatrick does not intend to come in
for a meeting to discuss their February 26, 1982 submittal
c July 7, 1982 NRC Internal Memorandum to File - Minutes of Meeting in
- -
Bethesda on June 29, 1982
!
( July 13, 1982 Licensee Report - A Reassessment of Conformance to Appendix
! R
I
w --e--~ e+ ~
, ,-.s .n,- ,. , . ., - , , . ,--- --- ,,, .. -
wr..-,.---,--iea. - ++-*-y<=-. --- ~-ev---+---- ~~ - '*m'*M-+
~_ . . -. . - _ . - _ _ . _ _ - - . _ .
.
.
2
November 2, 1982 BNL Report - Post Fire Safe Shutdown. Capability Report -
Based on July 13, 1982 submittal
November 16, 1982 NRC Internal Memorandum - Chem. Branch denies 4 exemption
request
December 14, 1982 Internal NRC Memorandum - SER III.G.3 and III.L of Appendix
R -
December 22, 1982 Internal NRC Memorandun - Chem. Branch again denies 4
February 2, 1983 NRC Letter to Licensee - Informs licensee of appeal process
for exemption denials (Draft SER) ,
March 1, 1983 Licensee Letter to NRC - Licensee comments on the draft SER
April 26, 1983 NRC Letter to Licensee - Alternate Safe Shutdown Capability
9
May 19, 1983 Licensee Letter to NRC - response to NRC letter dated
April 26, 1983
July 1, 1983 NRC Letter to Licensee grants exemption request for
Control Room and the Torus Room
Sept. 29, 1983 Internal NRC Memorandum grants all outstanding exemption
requests
February 1, 1984 NRC Letter to Licensee notification of granting of out-
standing exemptions
July 16,.1984 Licensee Letter to NRC - requests clarification of
! July 24, 1984 Licensee Letter to NRC - surveillance requirements for the
- high pressure water fire protection system
January 11, 1985 NRC Letter to Licensee - Exemption Request Water Spray
System
March 15, 1985 Licensee Letter to NRC - request for schedular exemption
)
i
!
l
.
1-
l
'
l
. -
.-. -- - - . - . - . - - - - - ,_. ,- -- - - . . - - - - . - . - - - - - . _ , _ - _ . . - _ , - . - _ _
"
..
.
.
ATTACHMENT 2
SUMMARY OF APPENDIX R EXEMPTIONS
. Exemption Request Description Date of Letter to PASNY
3 Phase AC and DC Power Circuits April 26, 1983
Fuse Pulling and Lifting Leads April 26, 1983
Control Room July 1, 1983
(automatic area wide suppression)
RB-1E and RB-1W February 1, 1984/
(zone interfaces at Elevs. 227'-6" and January 11, 1985
242'6")
RB-1E and RB-1W February 1, 1984/
(cable separation) January 11, 1985
RB-1E and RB-1A February 1, 1984/
(stairway from Elev. 227'6" to 272'-0") January 11, 1985
RB-1A and RB-1B February 1, 1984/
(zone interface on Elev. 272'-0") January 11, 1985
RB-1B and RB-1C February 1, 1984/
(zone interface on Elev. 300'-0") January 11, 1985
RB-1A and RB-1B February 1, 1984/
(zone interface on Eley, 300'-0") January 11, 1985
RB-1A and RB-1C February 1, 1984/
(stairway from Elev. 272'-0" to 300'-0") January 11, 1985
RB-1C and RB-IA February 1, 1984/
(stairway from Elev. 300'-0" to 326'-0") January 11, 1985
Torus Room July 1, 1983
(RHR valve separation)
RB-1B and RB-1A February 1, 1984/
(stairway from Elev. 300'-0" to 326'-0") January 11, 1985
.
.
ATTACHMENT 3
SUMMARY OF INSPECTION FINDINGS
Item Description Section Reference
Violations
50-333/85-20-01 Inadequate uncap separation of 7.1
safe shutdown systems
Unresolved Items
50-333/85-20-02 Fire detection systems not 7.1
per NFPA requirements
50-333/85-20-03 Sprinkler system installation
not per NFPA requirements
50-333/85-20-04 Functional testing of fire 7.1
50-333/85-20-05 Exemption request to allow 7.2
temporary core uncovery
50-333/85-20-06 Safe shutdown with inoperable
emergency diesel "B" system
50-333/85-20-07 Difficult access of fuse boxes 7.2
for fuse replacement
50-333/85-20-08 Marginal emergency lighting 8.0
<
conditions
_ ._ _ _ - _