ML20137K799

Insp Rept 50-334/85-25 on 851118-22.Violation Noted:Failure to Provide Emergency Lighting in Safe Shutdown Access & Egress Routes as Required by 10CFR50,App R,Section Iii.J

ML20137K799
Person / Time
Site:	Beaver Valley
Issue date:	01/09/1986
From:	Anderson C, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137K756	List: ML20137K753 ML20137K781 ML20137K799
References
50-334-85-25, NUDOCS 8601240223
Download: ML20137K799 (22)

See also: IR 05000334/1985025

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-334/85-25

Docket No. 50-334

License No. DPR-66 Priority --

Category C

Licensee: Duquesne Light Company

Post Office Box 4

Shippingport, Pennsylvania 15077

Facility Name: Beaver Valley Power Station, Unit 1

Inspection At: Shippingport, Pennsylvania

Inspection Conducted: NovmLer

b 18-22 1985

Inspector: II/cn / - S- 8 6

S. PulIanp , Firy9rotection Engineer date

Also participating and contributing to the report were:

A. Coppola, Mechanical Systems Specialist, BNL

K. Parkinson, Electrical Systems Specialist, BNL

S. We t, ical Engineering Branch, NRR

Approved by: bP $6% / fU

C.J. Anderson, Chief date

Plant Systems Section, DRS

Inspection on November 18-22, 1984 (Report No-334/85-25).

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 160 inspector hours onsite and 27 inspector hours in-office by the

team consisting of 4 inspectors.

Results: One violation was identified for failure to provide emergency

lighting in safe shutdown access and egress routes as required by Appendix R,

Section III J. In addition, four items remained unresolved at the end of

inspection. For details, see various sections of this report as listed in

Attachment 5.

B601240223 860115

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DETAILS

1.0 Persons Contacted

1.1 Duquesne Light Company (DLC)

• J. Belfiore, Senior QA Specialist

• S. Bose, Engineer

• R. Conley, Engineer, Nuclear Operations

H. Cox, Training Instructor

R. Dambaugh, Design Engineer

T. Dowhy, Engineer

J. Drosjack, Engineer

'R. Druga, Manager, Technical Services

• L Freeland, Operations Coordinator

E. Gabriel, Nuclear Control Operator

• K. Grada, Manager, Nuclear Safety

• T. Jones, General Manager

• H. Kahl, Senior Project Engineer

"M. Kilpatrick, Quality Assurance

J. Kinest, Shift Technical Advisor

L. Knapp, Senior Project Engineer

• F. Lipchick, Senior Licensing Supervisor

• J. Maracek, Senior Licensing Supervisor

• M. Rencheck, Engineer

• D. Schmitt, Acting Director Electrical

J. Sieber, General Manager, Nuclear Services

• H. Siegel, Engineering Manager

• S. Sovick, Senior Licensing Supervisor

• G. Svaranowick, Engineer

D. Topper, Nuclear Control Operator

• J. Turner, Shift Supervisor, Nuclear Operations

R. Woodhouse, Design Engineer

1.2 Hinchlif fe and Keener (Penetration Seals Contractor)

R. Hart, Technician

J. Ulizio, Quality Control

1.3 Nuclear Regulatory Commission (NRC)

• A. Asars, Resident Inspector

• P. Tam, Licensing Project Manager

• W. Troskoski, Senior Resident Inspector

• Denotes those present at the exit meeting.

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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

approved by the Office of Nuclear Reactor Regulation (NRR).

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 conditions, 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.I.b). Section III.G.2 lists specific options as

follows to provide adequate protection for redundant trains of equipment

located outside of the primary containment:

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

intervening 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).

For non-inerted primary containment,Section III.C.2 specifies one of

the above three protection options, or any of the following:

• Separation by a horizontal distance of at least 20 feet with no

intervening combustibles or fire hazards (III.G.2.d).

Fire detection and automatic fire suppression installed in the

fire area (III.G.2.e).

Separation of redundant trains by a non-combustible radiant energy

shield (III.G.2.f).

If the protection required by Section III.G.2 is not provided or the

systems of concern are subject to damage from fire suppression activities,

Section III.G.3 of the rule requires that an alternate or dedicated

shutdown capability be provided which is independent of the area of

concern. Any alternate or dedicated system requires NRC review and

approval prior to implementation.

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For situations in which fire protection does not meet the requirements l

of Section III.G, however, such protection is deemed to be adequate by

i the licensee for the specific situation, the rule allows the licensee to

, request an exemption on a case-by-case basis. Such exemption requests are

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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 Sections III.G, J and 0 was reviewed by the inspection team in pre-

paration for the site visit. Attachment 1 to this report is a listing of

the correspondence reviewed.

5.0 Post-Fire Safe Shutdown Capability

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! 5.1 Systems Required for Safe Shutdown

The systems required for post-fire safe shutdown are listed in

i Section 4.1 of the licensee's fire hazard analysis (see Attachment 2

to this report).

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Safe shutdown of the reactor is initially performed by rod insertion

from the control room. Insertion can also be accomplished by

removing power to the rod drive in the motor generator set area.

, Reactor coolant inventory is maintained by one of the three hish

pressure charging pumps which injects borated water through the

i reactor coolant pump seals, taking suction from the refueling water .

storage tank.

! Reactor coolant pressure can be maintained by one set of pressurizer

heaters and one of three charging pumps. Overpressure protection is

provided by safety / relief valves and code safety valves on the

pressurizer.

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Decay heat removal can be accomplished by releasing steam from the

steam generators via the atmospheric dump valves, the decay heat

removal dump valve and/or and the steam safety valves. Makeup water

! to the steam generators can be provided by one of the auxiliary

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feedwater pumps which take suction from the condensate storage tank,

or, as a backup, from the two demineralized water storage tunts.

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Cold shutdown conditions can be achieved and maintained by going to

I the solid steam generator mode of operation. In this method, the

, steam generator receives makeup water from the auxiliary feedwater

1 system and drains to the main condenser via steam bypass dump valves.

l The two-inch bypass valves around the main steam isolation valves

1 (MSIVs) can be throttled in conjunction with auxiliary feedwater to

l stabilize the flow to the steam generators. The main condenser can

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be drained to several iocations. A backup river water scurce is

available through safety-related piping for this function to continue

indefinitely. The licensee has analyzed the steam lines and existing

supports and determined that they are adequate for this method of

cold shutdown.

The residual heat removal (RHR) system will be used, when available,

for achieving and maintaining cold shutdown conditions. The RHR

system will not be available should a fire take place in the control

room, process equipment room, cable spreading room, containment and

cable vaults. The licensee does not intend to use the RHR system if

the control room cannot be reentered and made available following a

fire. For this eventuality, the solid steam generator method will be

used for the shutdown.

5.2 Areas Where Alternate Safe Shutdown Is Required

The licensee is required to provide alternate shutdown capability

independent of cabling and equipment in the control room (CR-1),

cable spreading room (CS-1), relay room (CR-3), instrument rack room

(CR-4), normal switchgear room (NS-1), pipe tunnel area (PT-1), CO2

storage /PG pump room (C0 2 ), containment-area (RC-1), cable vaults

(CV-1 and CV-2), auxiliary building area (PA-1A), emergency switch-

gear rooms (ES-1 and ES-2) and control room A/C room (CR-2).

The alternate shutdown will be accomplished by procedural means, with

actions performed at local shutdown stations or locally at the equip-

ment. The licensee has provided a summary of the functions for which

alternate shutdown methods may be needed, and the manual actions

required to accomplish each of the identified functions which have

been described. Alternate process monitoring capability is achieved

through a backup indication panel in the east cable vault. The

required instrumentation for process variables are available at the

backup indication panel. The licensee has installed a local steam

pressure indicator in the atmospheric dump valve area for manual

control of the steam pressure during post-fire shutdown.

Due to the proximity of the three existing auxiliary feedwater pumps

in the pipe tunnel area (PT-1), the licensee has installed a new

100 percent capacity auxiliary feedwater pump located in a separate

fire area in the turbine building. This new pump is tied to the

existing feedwater headers.

Also due to the proximity of motor-operated valves on the river

water supply to the diesel generators, in the CO storage

2 /PG pump

room, the licensee relocated one of the motor-operated valves to a

separate fire area to eliminate the possibility of coincident loss of

cooling water to both diesel generators in the event of a fire.

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The licensee intends to use portable, gasoline powered fans as a

means of providing essential ventilation in three areas in the event

of fire damage to the normal ventilation equipment. These three

areas are the primars auxiliary building area (PA-1A) the emergency

switchgear rooms (ES-1 and ES-2) and the control room A/C room

(CR-2).

The licensee has made modifications to the No. 2 diesel control

circuit and wiring since redundant control circuits for the diesel

generator were found to run in the same fire area. The modifications

were also made in areas of normal switchgear, cable spreading room,

instrument rack room, relay room and control room A/C room.

The licensee has modified the circuits of all Category I, safety

related motor control centers (480V) by installing encapsulated

control power transformers to prevent hot shorts from occurring.

5.3 Remaining Plant Areas

All other safe shutdown areas of the plant are required to comply

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

been approved by the staff.

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

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 shut-

down conditions in the event of a fire in various areas of the plant. The

examination included a review of several drawings, safe shutdown pro-

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cedures and other documents. Drawings were reviewed to verify electrical

independence from the fire areas of concern. Procedures were reviewed for

general content and feasibility.

Also inspected were fire detection and suppression systems and the degree

of physical separation between redundant trains of Safe Shutdown Systems

(SSSs). The team review included an evaluation of the susceptibility of

the SSSs for 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 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, and Section III.0, Oil Collection System for

Reactor Coolant Pump.

7.0 Inspection of Protection Provided to Safe Shutdown Systems

7.1. Protection in Various Fire Areas

The fire areas required for the safe shutdown are listed in Section

3.4 of the licensee's fire hazard analysis (see Attachment 3 to this

report).

The team reviewed the protection provided to selected safe shutdown

system components in the following fire areas for compliance with

Appendix R,Section III.G.1, 2, and 3.

Process Instrument and Rod Position Room (CR-4)

• Cable Spreading Room (CS-1)

• Emergency Switchgear Room No.1 (ES-1)

• Normal Switchgear Room (NS-1)

Diesel Generator Room (DG-2)

• Intake Structure Cubicles (IS-1, IS-2, IS-3, and IS-4)

• Pipe Tunnel Area (PT-1)

Main Steam Valve Area (MS-1)

• Primary Auxiliary Building (PAB-1)

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West Cable Vault (CV-1)

East Cable Vault (CV-2)

Cable Tunnel (CV-3)

Motor Generator Room (MG-1)

• Turbine Building General Area (TB-1)

The safe shutdown systems and components selected for inspections

in the above fire areas were based on their relative importance to

safety using Probabilistic Risk Assessment (PRA) techniques (see

Section 11.0 for details).

The team did not identify any unacceptable conditions.

7.2 Safe Shutdown Procedures

7.2.1 Procedure Review

The team reviewed the following safety shutdown procedure:

Operating Manual Chapter 56C, Alternate Safe Shutdown

from Outside Control Room, Revision 1.

The scope of review was to ascertain that the shutdown could be

attained in a safe and orderly manner, to determine the level of

difficulty involved in operating equipment, and to verify that there

was no dependence on repairs for achieving hot shutdown. For purpose

of the review, a repair would include installing electrical or

pneumatic jumpers, wires or fuses to perform an action required for

hot shutdown.

The team did not identify any unacceptable conditions.

The inclusion of the Shift Technical Adviser (STA) as an active

member of the shutdown crew, particularly the use of the STA to

establish a charging flow path, was questioned and the training of

STA's for this function was reviewed. It was determined that at

BVPS, the STA is adequately trained for this function. (i.e.,

procedure walkthrough at least once a year, fire fighting training,

and on the job checkout of operator valve manipulations are part of

STA's normal duties).

7.2.2 Procedure Walk-Throuah

The team walked through selected portions of the procedure to

determine that shutdown could be attained in an orderly and

timely fashion.

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The walk-through demonstrated that auxiliary feed water flow and

charging could be established within the time required for this

plant (30 minutes), and that stable hot standby conditions could

be established within one hour after control room evacuation.

The only communications system used during this demonstration

was the dedicated phone system, and this proved adequate for the

purpose.

Other aspects of the procedure (cooldown and preparation for

cold shutdown) were also walked through and the feasibility of

these aspects was demonstrated.

The team did not identify any unacceptable conditions except as

follows:

a. Minor Changes Required for Alternate Safe Shutdown Procedure

56C

The Nuclear Shift Supervisor (NSS) was detracted from his

main function upon arriving at the Back-up Indicating Panel

(BIP) when he began hooking up the source range monitor

which is not required at the beginning of the procedure to

achieve ~ stable hot standby conditions. It was determined

that the procedure be changed to delete this from the NSS

portion of the procedure and make it the primary respon-

sibility of the STA when he arrives at the BIP (within one

hour).

The licensee has committed to making this change to the

procedure by December 31, 1985. This is an unresolved item

pending the revision of the procedure and its review by NRC

(50-334/85-25-01).

b. Enhancement of the Key Rings Used for Access to Safe

Shutdown Areas

The key rings carried by the operators contained many

keys, not all of which are required for the procedure

under review. Finding the correct keys under poor

lighting conditions could be time consuming. It was

determined that some kind of coding be insti!.uted that

would enhance this action.

The licensee has committed to making improvements to

the key rings (key identifying devices), to enhance

key selection, by December 31, 1985. This is an

unresolved item, pending completion of the licensee

action and its review by NRC (50-334/85-25-02).

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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 malopera-

tion 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 signals, and common enclosure concerns. Power, control,

and instrumentation circuits were examined for potential problems.

A sampling basis was ased in making the examination, since many

circuits were involved and a determination of cable routing took

considerable time.

7.3.1 Common Bus Concern

The common bus concern is 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, 480V, 120V AC

and 125V DC bus protective relay co-ordination. The team also

examined, on a sampling basis, the protection for specific

instrumentation, controls, and power circuits, including the

cocrdination of fuses and circuit breakers. The licensee has

been performing relay settings at approximately 48 month inter-

vals in accordance with an established maintenance procedure.

No tnacceptable conditions were identified.

7.3.2 Spu-ious Signals Concern

Th7 spurious signals concern is made up of 2 items:

False motor, control, and instrument indications can occur

such as those encountered during 1975 Brown's 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),

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The licensee has performed a spurious signal analysis, which is

documented in the Updated Fire Protection Review, Chapter 5,

Section 5.2.2. This analysis satisfactorily addresses the

spurious signal issue.

The team reviewed the following areas:

Current transformer secondaries including Emergency

Diesel Generator differential relays.

• High/ low pressure interface

a General fire instigated spurious signals

No unacceptable conditions were identified.

7.3.3 Common Enclosure Concern

The common enclosure concern is 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 barrier penetrations.

A number of circuits selected for this concern were all found

to be electri: ally protected. In addition, the licensee stated

that non-safety related circuits were never routed from one

redundant train to another.

The licensee stated that associated circuits for common

enclosures are limited to switchgear and load center compart-

ments or panels and boards in which safe shutdown circuits

exist. The team verified this by reviewing a number of

randomly selected circuits.

No unacceptable conditions were identified.

7.4 General Fire Protection Features

The team examined the general fire protection features in the plant

provided to maintain one train of safe shutdown equipment free of

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

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

of openings such as fire doors, fire dampers, and penetration seals.

No unacceptable conditions were identified except as follows:

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Combustible Waste Storage in Primary Auxiliary Building

By letter dated June 6, 1979 (A. Schwencer to C.N. Dunn), the Com-

mission issued Amendment 18 to Facility Operating License DPR-66 for

the Beaver Valley Power Station Unit 1. The amendment added to the

operating license a condition related to facility modifications for

fire protection and completion dates for the modifications.

Section 3.0 of tne Fire Protection Safety Evaluation Report (SER)

attached to the amendment summarized the modifications and Table 3.1

listed the completion dates for the modifications.

Section 3.12-4 of the SER states that the contaminated waste storage

area will be relocated in a new building having sprinkler protection.

Table 3.1 of the SER lists October 31, 1980 as the implementation

date for this modification.

During the inspection, the team observed a contaminated waste

storage area in Elevation 735' 6" (Fire Sub-Area PA-1E) of the

Primary Auxiliary Building between the component cooling water

pumps and the charging pump cubicle hatch covers. The team also

observed that the new waste storage building is not complete.

However, the licensee indicated that there was no commitment date

for completion of the new waste storage building and that the com-

mitment date of October 31, 1980 was for the implementation of

the administrative control of unnecessary combustibles which has

been completed as required. The above commitment is documented

in the NRC memorandum, Wigginton to Schwencer, dated March 26, 1979

(Summary of meeting held on March 5, 1979 to discuss fire protec-

tion for Beaver Valley), Item 3.12.4. The SER, therefore, appears

to be in error.

The licensee has initiated actions to resolve this issue with NRR.

This is an unresolved item, pending completion of the resolution of

this issue with NRR (50-334/85-25-03).

The licensee has an existing one hour roving fire watch in the

Primary Auxiliary Building pending resolution of an outstanding

exemption request for lack of area wide automatic suppression in

the nearby charging pump cubicles located in this building (see

licensee's Updated Fire Protection Appendix R Review, Section 11.20,

for details of this exemption request). The licensee committed to

continue this fire watch pending a satisfactory resolution of the

above issue with the office of NRR.

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8.0 Emergency Lighting

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

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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 requirement.

The team identified the following unacceptable conditions:

a. Lack of Emergency Lighting in Safe Shutdown Access and Egress Routes

Emergency lighting units with 8-hour battery power supply are not

provided in the following locations serving as safe hot shutdown

access and egress routes.

1. Clean Shop (Fire Area SH-1)

2. Stairway vestibule immediately outside the Control Room in the

Service Building.

3. The corridor between the aforementioned stairway (item 2) and

the Service Building roof.

4. The Service Building roof and the Yard Area between the Service

Building and the Diesel Generator Building.

This is a violation of Section III.J of Appendix R to 10 CFR 50

(50-334/85-25-04).

The licensee committed to install an emergency lighting unit with an

8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supply in the Clean Shop (item 1).

The licensee stated that the security perimeter lighting powered by

the security diesel generator would provide adequate emergency

lighting for items 2, 3 and 4 above. Furthermore, the licensee

stated that it was their opinion that this security lighting was

equivalent to the requirements of Section III.J of Appendix R to

10 CFR 50. The licensee stated that an exemption would be requested

from the technical requirements of Section III.J of Appendix R to

10 CFR 50 for these locations.

b. Emergency Lighting Insufficient or Marginal in 4 Areas

The team walked down all of the safe shutdown access and egress

routes designated by the licensee. Emergency lighting units are

provided in the following areas:

1. Turbine Generator Building elevation 735' 6' (Fire Area TB-1)

2. Fire brigade equipment room.

3. Safeguards Containment Penetration A Area (Key access to gate)

4. Primary Auxiliary Building to Safeguards Area - elevation 722'.

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However, as the licensee could not switch off the normal lighting in

4 these areas while the plant is operating, the team could not deter-

, mine whether or not the number of units provided or the orientation

i of the lamps was adequate to allow the operators to accomplish the

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intended safe shutdown functions. The licensee could not provide an

analysis to show the adequacy of the area lighting, and certain areas

( appeared to be marginally covered.

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This is an unresolved item pending a demonstration by the licensee

that the lighting in their areas is adequate and its review by

, NRC (50-334/85-25-05)

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9.0 Oil Collection System for Reactor Coolant Pump

10 CFR 50, Appendix R, Section III.0, requires that the reactor coolant

pump shall be equipped with an oil collection system if the containment

is not inerted during normal operation. The oil collection system shall

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be so designed, engineered, and installed that failure will not lead to

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fire during normal or design basis accident conditions and that there is

, reasonable assurance that the system will withstand the Safe Shutdown

! Earthquake.

Such collection systems shall be capable of collecting lube oil from all

potential pressurized and unpressurized leakage sites in the reactor ,

coolant pump lube oil systems. Leakage shall be collected and drained

j to a vented closed container that can hold the entire lube oil system

! inventory. A flame arrester is required in the vent if the flash point

! characteristics of the oil present the hazard of fire flashback. Leakage

j points to be protected shall include lift pump and piping, overflow lines,

l lobe oil cooler, oil fill and drain lines and plugs, flanged connections

on oil lines, and lube oil reservoirs where such feature exist on the

i reactor coolant pumps. The drain line shall be large enough to accom-

l modate the largest potential oil leak.

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The team examined the licensee's drawings and design change safety

evaluation report 'or the three reactor coolant pump oil collection

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systems to ascertain that the above requirements were met. Because

of the subatmospheric condition of the containment while the plant is

operating, no actual entry was attempted,

i No unacceptable conditions were identified.

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10.0 Quality Assurance

.l During the course of the inspection, the team reviewed several drawings,

l fire hazard analysis, fire protection modification packages, procedures,

{ and other fire protection documents. The scope of review included

j verification of their technical adequacy, appropriate reviews, design

I and procurement controls, and other Quality Assurance requirements for

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the licensee's fire protection program.

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Except as noted in the previous sections of this report, the team did not

identify any other unacceptable conditions.

11.0 Use of PRA Techniques for the Inspection

The safe shutdown systems (SSSs) and components were selected for inspec-

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tion of their fire protection features, based on their relative importance

1 to safety using PRA techniques as opposed to random sampling basis (see

Section 7.1 of this report). If there exists a plant specific PRA or

related studies such as Interim Reliab.ility Evaluation Program (IREP) or

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Reactor Safety Study Methodology AppTication Program (RSSMAP), their

results could be used in the selection process. In the absence of these

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types of plant specific studies (such as for Beaver Valley, Unit 1),

generic conclusions on the relative importance of PWR and BWR systems

based on a study of 15 published PRAs could be used for this purpose, with

lesser precision (see NUREG-1050,,PRA Reference Document, September 1984,

Section B.3.2). The relative importance of PWR systems considering

dominant accident sequences from 'the 15 PRAs is reproduced in Attachment 4 to

this report.

l Comparing the systems in Attachment 4 to their functionally equivalent  ;

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SSSs in Attachment 2, the following SSSs were selected for this inspec- '

f tion, based on their relative importance:

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]

• Auxiliary Feedwater System

' * Chemical and Volume Control System

i

j * Main Steam System

i * River Water System

j * Electrical Distribution System

j In addition, some of the other SSSs such as Process Monitoring Instru-

{ mentations were also inspected because of their importance in the case of

j a fire scenario.

,

12.0 Unresolved Items

,

'

Unresolved items are matters for which more information is required in

order to ascertain whether they are acceptable, violations, or

deviations. Unresolved items are discussed in Sections 7.2.2.a,

! 7.2.2.b, 7.4, and 8.0.b.

i

!

.! ,

i

.

- _ . . . - , . .

. _ , . - ~ , _ , , , _ , , . _ . . , , _ , . , , . . _ _ __._mm_,,.._ . _ + . . _ - __m.mm,,y, , . - . , _ , _ . . , _ . .,..m.____,.,_

.

/

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15

13.0 Conclusions

The findings of this inspection are summarized in Attachment 5 and are

categorized as follows:

One violation of Appendix R,Section III.J

Four unresolved items

The details of the above violation and unresolved items are discussed in

various sections of this report as listed in Attachment 5. The licensee

actions and commitments, including the actions required to resolve the

unresolved items, are also discussed in these sections of the report.

14.0 Exit Interview

The inspection team met with the licensee representatives, denoted in

Paragraph 1, at the conclusion of the inspection on November 22, 1985.

The team leader summarized the scope and findings of the inspection at

that time.

The team leader and the licensee discussed the contents of this inspection

report to ascertain that it did not contain any proprietary information.

The licensee agreed that the inspection report may be placed in the Public

document Room without prior licensee review for proprietary information

(10 CFR 2.790).

At no time during this inspection was written material provided to the

licensee by the team.

.

/~% ~\

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ATTACHMENT 1

Correspondence List

June 6, 1979 NRC forwarded Safety Evaluation on APCSB 9.5-1

(Amendment #18 to Tech. Specs.)

June 30, 1982 DLC submitted report on 10 CFR 50.48 Appendix R

October 22, 1982 DLC submitted additional information for exemption

requests for Containment Area and Primary Auxiliary

Building

October 28, 1982 DLC provided clarification on Appendix R report,

alternate shutdown procedure and 72-hour cold

shutdown time limit.

December 10, 1982 DLC submitted summary of November 30, 1982 meeting

I

with the NRC.

December 20, 1982 DLC provided additional information on Control Room

and PAB exemptions.

Jar.uary 5, 1983 NRC issued Sa fety Evaluation on Sections III.G and

L of Appendix R.

March 1, 1983 NRC issued corrections to January 5,1983 SER

March 14, 1983 NRC grants exemptions from Appendix R requested

in DLC submittal of June 30, 1982.

April 18, 1983 DLC provides information on protection of control

power transformers and additional emergency

lighting.

May 20, 1983 DLC provides additional information on control

power transformers.

June 20, 1983 NRC approves method of protecting control power

transformers.

October 19, 1983 NRC issues Generic Letter 83-33 on clarification of

Appendix R issues.

December 16, 1983 DLC submits additional requests for exemptions based

Generic Letter 83-33.

.

.

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2

May 30, 1984 DLC provided revised exemption request on structural

steel.

August 30, 1984 NRC grants exemptions requested in December 16,

1983 submittal (except structural steel issue)

January 9, 1985 NRC issues Generic Letter 85-01 clarification of

Appendix R issues

January 14, 1985 DLC submits additional exemption requests and

clarifications of deviations from Appendix R.

June 6, 1985 DLC submits additional information on Communications

and Emergency Lighting based on Generic Letter 85-01.

July 10, 1985 DLC submits information on resolving structural

steel issue.

August 28, 1985 DLC submits additional information on Emergency

Lighting.

October 16, 1985 DLC submits the Updated Fire Protection Review

Report, dated September 1985.

v v

ATTACHMENT 2

Systems Required for Post-Fire Safe Shutdown

The determination of what systems should be utilized for safe shutdown was

based not only on normal safety-related shutdown systems but also on diverse

systems that could duplicate these functions. Those systems selected for

post-fire shutdown are as follows:

Auxiliary Feedwater System

Chemical and Volume Control System

River Water System

Electrical Distribution System

Ventilation System

Main Steam System

Process Monitoring Instrumentation

Conspicuously absent from this list are the rod control, component cooling

(CCR), and residual heat removal (RHR) systems. While these systems would

be used ir, a normal shutdown process, they are not absolutely essential

for ach4eving safe shutdown.

=

The rod control system is a fail-safe system and as such, rod

insertion can be assured by deenergizing the system at locations in

different fire zones in the plant.

If the RHR system is not available, cold shutdown could be achieved

by continuous steaming of the steam generators, and eventually a

feed-and-bleed operation on the steam generators.

The component cooling system's primary function, in support of shut-

down, is reactor coolant pump seal cooling and RHR heat removal. The

reactor coolant pumps are not essential for shutdown since natural

circulation is available and seal injection is provided by the charg-

ing system. Miscellaneous equipment that requires component cooling

water during the shutdown can be provided with alternate cooling, or

isolated.

. . _ - . - - . _~ .. . - - _- - -_.... . - . _ _ .-

*

O

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2

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ATTACHMENT 3

i

I Fire Areas Required for Post-fire Safe Shutdown

i

For the purpose of conducting the fire hazard analysis and the safe shutdown

evaluation, the plant arrangement is divided into fire areas. In general, fire

4

areas are defined by physically identifiable boundaries. Some fire areas, due

to size, nature, or floor areas involved, have been divided into subareas

within a certain fire area.

Reactor Containment Area (RC-1)

• Control Room (CR-1) including Sub-area

. HVAC Equipment Room (CR-2)

,

• Communication Equipment and Relay Panel Room (CR-3)

4 *

Process Instrument and Rod Position Room (CR-4)

}

• Cable Spreading Room (CS-1)

t

Emergency Switchgear Room No. 1 (ES-1)

! * Emergency Switchgear Room No. 2 (ES-2)

• Normal Switchgear Room (NS-1)

Diesel Generator Room (DG-1)

! Diesel Generator Room (DG-2)

Intake Structure Cubicles (IS-1, IS-2, IS-3, and IS-4)

Pipe Tunnel Area PT-1) including subarea

Auxiliary Feedwater and Quench Spray Pump Room (QP-1)

Main Steam Valve Area (MS-1)

.

Steam Generator Blowdown Room (SGPD-1)

'

• Fuel Building (FB-1)

,

Primary Auxiliary Building (PAB), composed of floor levels:

- PA-1A(Elev.768)

- PA-IC(Elev.752)

- PA-1E(Elev.735)

- PA-1G(Elev.722)

including the following sub-areas:

!

Charging Pump Cubicles (PA-1f, ig, lh)

Component Cooling Water Pumps Area (located in PA-1E)

Main Exhaust Filter Banks (MF-1 and MF-2, located

in PA-1A)

West Cable Vault (CV-1)

East Cable Vault (CV-2)

Cable Tunnel (CV-3)

*

Motor Generator Room (MG-1)

i * CO2 Storage /PG Pump Room (CO-2)

Turbine Building General Area (TB-1)

.

N

I

i

I

.

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-- .--- - . _ . .

_- . - .

e

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ATTACHMENT 4

(Reproduced from NUREG-1050, Figure B-5)

PWR SYSTEMS

i . . ...iig . . . . .i.

i i i i .iii i

MWIMUM M A RIMUM

AFWS

-

RELATIVE REL A TIVE - i

IMPORTANCE IMPORTANCE '

HPRS \_ _ / O

PCS ' AVEYtAGE

-

C l

DC IM TA E -

O ,

HPIS  : O l

CSIS 0

-

l

SWS O l

'

EMERGENCY AC C

RHRS

-

0 l

'

RPS C

'

PORV -

O

LPRS -

0 l

LPIS  ;

ESAD .

SUMP 1- l

i

i i i , iiil i i i .iiil i i e i isii

10-3 jg-2 10 " 1.0

Figure B-5. Relative importance of PWR Systems Considering Dominant Accident Sequences

tron 15 PRAs

AFWS Ausiliary feedwater systee

HPRS High-pressure recirculation systen

PCS Power-conversion system

DC Direct current power

HPIS High pressure injection system

CSIS Containment spray injection system

SWS Service water systen

Emergency AC Emergency ac power

RHRS Residual-heat-tenoval system

RPS Reactot-protection system

PORV Power-operated relief valve

LPRS Low-pressure recirculation system

1.P I S Low-pressure injection system

ESAD (To be defined)

SUMP Containment sump

HPCI High-pressure coolant injection system

LPCI Low-pressure coolant injection systee

S/R-VALVE Safety / relief valve

ADS Automatic depressucitation systee

RCIC Reactor-core isolation cooling systen

LPCS Low-pressure core spray systes

-

.

0 0m

ATTACHMENT 5

Summary of Inspection Findings

Item No. Description For details, refer to Section

1. Violations

85-25-04 Lack of Emergency

Lighting in Safe

Shutdown Access and

Egress Routes 8.0. a

2. Unresolved Items

85-25-01 Mi.ior Changes Required for

Alternate Safe Shutdown

Procedure 56 C 7.2.2. a

85-25-02 Enhancement of Key Rings Used

for Access to Safe Shutcown

Areas 7.2.2. b

85-25-03 Combustible Waste Storage in

Primary Auxiliary Building 7.4

85-25-05 Emergency Lighting

Insufficient or Marginal

in 4 areas 8.0. b

L